In essence we all know why there was chaos in the last weeks leading up to the 15th June; the RPA pulling the plug on their new online system. Having done this towards the end of March, although offering a further month to complete claims, there were delays in providing pre-populated forms, guidance notes and plans. Some of the proactive measures the RPA took to try and help only caused more confusion. The biggest of these being an invitation to agents and farm consultants to use the back-room software and continue making online applications. SITI Farmer, created by the Italians and used by other EU member states, tempted agents to further delay making claims in the hope that it would be more efficient rather than going back to paper applications. However SITI was not generally available until mid-May and did not work as it should have and was continually being updated even to within three days of the deadline. Some aspects of the software were helpful but we suspect many, like ourselves, decided not to trust it for submitting applications, making paper claims for our clients, to avoid them getting entangled in the computerised mayhem that already existed at the RPA. Subsequently farm consultants and agents were late in preparing claims and of course the additional month given to the 15th June clashed badly with the increase of on-farm activity. 
A number of “one-offs” added to the chaos this year. If entitlements were not claimed on (or matched with eligible area) they would be lost to the National Reserve. This then made it more imperative to calculate accurately the claim which, also unusually this year had to be done by the same deadline as buying or selling entitlements. This double deadline also added to the complications, as in previous years one would have roughly guessed what entitlements one needed to buy or sell with any excess held being available for future years as needed. 
The other “one-off” was that this year was chosen to map all commons where people had merely relied on headage and grazing rights in order to claim against entitlements in the past. Subsequently ineligible features had to be identified and mapped and then the “eligible area” allocated to the individual commoners through the local associations. Impossible! One fundamental question that arose was if it was found someone had been claiming in the past on ineligible areas would the RPA confiscate the entitlements used in this way under the old two-year rule. The RPA were only able to give an answer to this four days from the deadline. There were commoners suddenly buying entitlements in large numbers or selling them gambling on what they would be allocated from their association. 
Another twist was the dropping of the 50 trees/hectare exclusion rule applying to under-grazed woodland which meant that there were suddenly buyers for large numbers of entitlements where before it had been too risky or impossible before to claim on such areas. Of course there are a lot of commons which are wooded and this merely went further to complicate the impact on the market.
As entitlement agents we had perhaps a unique insight as to how chaotic matters were as they were subsequently reflected in the chaos produced in the entitlement market. Two weeks from the deadline with the market price on the floor at £40-£50 per unit for Non-SDA there was a steady trade despite the surplus of entitlements for sale. However then large volume purchases from commoners and those affected by the under-grazing rule came to the market together with a sudden surge of buyers finishing off their claims on the 3rd June. The market had risen by the 5th to £110-£115 a unit, a staggering swing. Apart from the last minute desperate trading on the 15th, which saw the odd sale up to £170 per unit, having one evening run out of entitlements to sell, by the 9th June the market peaked at £120 a unit. This however then fell off and subsequently there was a changeable market daily, up and down. At the deadline on Monday the 15th there remained unsatisfied buyers and sellers. It was a very inefficient marketplace with other agents experiencing different trends throughout the country during the same period. I have not seen such an inefficient market in farm quotas since the early days of milk quota before we started publishing national prices in Farmers Weekly in 1991.
This analogy is probably the most damning comment we can make in respect to the chaos the RPA have caused whereby England has not been able to make proper use of the entitlements available. However if as a result there is an excessive amount of entitlements in the National Reserve there will be more money effectively shared around with a slightly higher payment for all.
Hugh Townsend

Hugh Townsend
FRICS. FCIArb. FAAV.

01392 823935
enquiries@townsendcharteredsurveyors.co.uk