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"It will not necessarily be the statutory inspections that are the problem," he says. "Think about Trading Standards, the Environment Agency and others pitching up on the farm and finding something amiss.

"The standard operating procedure, under such circumstances, will be that, once a transgression is reported - by whoever discovers it - to the Rural Payments Agency, the agency will appoint "specialist" investigators to look more closely at the issue.

"And once this investigator has reported, the Rural Payments Agency will decide whether or not to start penalty proceedings."

Other points from recent meetings…

Initially the Good Agricultural and Environmental Condition requirements bit will be "light touch" but they will become progressively more rigorous to match the aspirations of ministers.

Defra expects all land that can be registered to have been registered on the Rural Land Register by May 15, next year. Producers may want to register sooner rather than later.

The possibilities for splitting pig businesses away from arable will be more strictly limited than has generally been realised. Genuine cases will be allowed but the principles established for IACS will generally prevail. The European Union view is that a "holding" includes ALL farmed land.

Defra will increasingly rely on farmers visiting the Defra website to keep informed, as will other government departments. Producers might be wise to invest in a good, modern computer with a good modem and the latest browser software.

The ten-month-rule (potentially of significant relevance to outdoor producers on rented land) continues to be problematic. What precisely does "at the farmer's disposal" mean? Though the new flexible start and end dates are a help, this particular aspect of the implementation has the potential to cause havoc with those renting in/out land for pigs, potatoes, carrots etc.

The Defra view of the precise meaning of the ten-month-rule is that it will only be of relevance where there is a dispute between landlord and tenant, who both may feel entitled to the payment, but in reality there is still so much confusion and uncertainty

Source: National Pig Association - 22nd July 2004