"Important changes to late applications for cattle passports"

Other cattle keepers must have received the same patronising and threatening letter, dated October 2003 and headed "Important changes to late applications for cattle passports".  When I telephoned the BCMS helpline for clarification of the sentence

"From 31 October 2003, we will not automatically issue any cattle passports for applications we receive after the legal deadline"

, it was apparent that the helpline 'voice' believed that the sentence read, or meant

"From 31 October 2003, we will not issue any cattle passports for applications we receive after the legal deadline"

.  After discussion, he agreed that the wording of the letter was misleading: but would not do anything about it unless I gave him my holding number - which I refused.  I asked him who had determined on the changes and he told me that there had been no changes - and when I read him the heading of the letter, the call became rather acrimonious and very unhelpful.
BCMS seem to have found another way of persecuting cattle keepers, and one which introduces for them a whole new class of cattle with a whole new field of bureaucracy - the "Notice of Registration" form itself and all the appeals and arguments which will be provoked by its issue - and then the special licences which BCMS are to issue...
I haven't heard a word of protest from any farmer organisation.  Why do we carry on accepting and co-operating with this sort of rubbish?
And why won't BCMS answer even a general enquiry without knowing one's holding number (and hence the wealth of information that unlocks)?  Just wait until we have to carry 'entitlement cards' or 'identity cards'...
Yours sincerely,

PS  I attach the letter I wrote to my MP on the subject.

The Rt. Hon. Nick Harvey, M P
House of Commons
18th October 2003
Dear Nick,

Cattle Passports
I have received the enclosed letter from the British Cattle Movement Service (BCMS) informing me about “important changes to late applications for cattle passports”.
The first of these, it says, is that “from 31st October 2003, we (i.e. BCMS) will not automatically issue any cattle passports for applications we receive after the legal deadline.”  A call to the BCMS helpline to clarify the circumstances in which a passport would be refused, revealed that, despite the wording of this sentence, the intention is that all applications received ‘late’ will be automatically refused.  [When I pointed out that the letter does not make this clear and if indeed this is the intention, the letter should be corrected and re-issued, their official initially disagreed: but after an increasingly heated discussion, conceded the point.  He, however, told me that he would do nothing, because I declined to give him my holding number (which would identify me and all the details of my farm held by DEFRA).]
The second change is that when a passport is refused, a document will be issued that makes the animal worthless, require yet more bureaucracy (in the form of a requirement for extra movement notifications) and will make the animal count against subsidy entitlement.
These changes seem unnecessarily onerous and unreasonably draconian.  I believe that they will have undesirable unintended effects.  I object to them and I should be grateful for your help in getting the changes withdrawn and replaced with a more constructive alternative.

Cattle keepers are given 27 days to identify, catch the new calf and insert tags in its ears, complete the passport application and get it to BCMS.  The letter makes it clear that the 27 days includes the time the application takes to be delivered by the postal service, including and allowing for any postal delays.  Cattle keepers in remote areas where the post takes longer will apparently be expected to allow accordingly and cattle keepers are apparently expected to foresee delays caused by the Christmas post – and presumably, strikes and other interruptions.  With the threatened penalty (of having the calf classified as ‘waste material’ with a negative value) this seems thoroughly unreasonable.
The letter makes it clear that if the cattle keeper does his paperwork once a month and sends a batch of passport applications once a month, some of the applications will be late and the passports refused.
The letter includes an example of the document to be issued on refusal of the passport.  It shows that the keeper has supplied all the required details for issue of a passport and the BCMS has accepted these as accurate.  There is no reason for the refusal of the passport apparent from the details recorded: and presumably we are to understand that this document will be issued as a punishment for the late arrival of the application: a punishment for infringing the arbitrary bureaucratic rules of BCMS.  The punishment will have its effect on the cattle keeper and the unfortunate calf too.
The likely effects of this absurd regime will be that cattle keepers will routinely falsify the birth dates of their calves to suit the date of the application: and that if it becomes apparent that an application will be late, it will become advantageous to leave the animal unrecorded, perhaps for ‘black market’ use.
This all seems thoroughly unreasonable and unnecessary.  It has nothing to do with food safety or animal welfare.  Neither will it save administrative time: because apart from the angry appeals and disputes likely to be provoked, the new “passport refused” documents will require additional licences and procedures.
Surely it must be recognised that, just like BCMS itself, cattle keepers can make honest mistakes – and a procedure for rectifying these must be provided.  I would like the BCMS to confirm that there will be a means by which the honest cattle keeper can obtain a passport for an animal, even after the “legal deadline” and that a passport will never be unreasonably withheld.
The 27 day period for the lodging of a passport application is arbitrarily chosen and inconvenient.  Allowing for the normal uncertainties attendant on keeping cattle, it is not generous.  Not all cattle are kept in factory farming conditions – and when kept on extensive grazing, new calves can often be hard to find and catch.  Rather than making an inconvenient and irrational system more so, it would seem more appropriate for DEFRA/BCMS to extend the period available for a passport application, so that it is possible for calves born in the open fields to be reliably found and tagged without instituting ‘panic stations’, or the cattle keeper to attend to passport applications in batches, once a month?  Apart from being a normal business practice, this latter might even make things more convenient for BCMS.
It is unreasonable to penalise the cattle keeper (and the unfortunate calf) for postal delay.  The enforcing of a deadline for receipt of applications demands clear allowance for postage time: and clear and simple rules for dealing with abnormal delay.  It is unacceptable to expect the cattle keeper to be able to rush through the tagging of the calf and completion of the application form faster than normal in order to “post early for Christmas”!
It seems particularly objectionable that this diktat should have been issued with so little regard for its consequences and so little understanding.  It seems yet another example of a government and civil service that doesn’t care and wants to be rid of farming in Britain.
I should be grateful if you can do anything to help instil some common sense and flexibility into the system.  If nothing else, BCMS should at least issue another letter which explains their intention clearly.

Yours sincerely,

Enc.  Copy of BCMS letter of October 2003.