In the case of Notifiable disease we already have standstill orders which we are required to abide by.
Irrespective of the definition of holding (do you mean apiary?), other than in the case of notifiable disease any form of restriction is liable to be unworkable.
If I split a colony, and in any given year I cannot determine if or when I may need to do that, and from that split have a nucleus colony, I may wish to move that colony to another apiary.. t
The point I may wish to do that is determined by how fast that colony builds up, so assuming I'm inspecting every 7 days I would only know 7 days in advance that I want to move it..
That may be a Saturday .. chances are it'd be Monday morning before I could apply for the license and most likely Wednesday (not sure which week) before it got looked at, and some time the week after before it got approved (or not) by which time my Nuc's swarmed because they've outgrown the box because I couldn't move them to the hive I wanted to put them in.
While we have mainly lived in larger properties and mostly because of wifes hobbies we have been registered small holdings, however I am not 100% up on the rules, i leave that to my wife. But i will relate the system as it applies to say sheep or chickens.
Lets assume your apiary is also your home (for the moment anyway), you would apply under the small holder scheme, this entails applying for what is known as a parish number (you get it from your local parish council).
Now what you keep at this address if under a certain number is largely not bothered about. So lets assume the final figure settled upon for Hives is 10, if you keep under 10 Hives you would be asked on the form how many you keep.
Now keeping this as general as i can.....
Currently with chickens any under 50 is considered a garden flock, it simply notifies DEFRA you are a keeper of a small number of chickens. You would not be expected to register a flock under 50 but a declaration is appreciated.
At 50 birds or under you are not considered to be a significant vector risk in the event of a disease outbreak. However as with Bees if you notice one of your chickens has a notifiable disease (such as Newcastle disease in chickens and not seen for many decades in the UK ) you are legally obliged to report it.
If there were to be a disease outbreak in your area of say Newcastle disease then at 50 birds or under you are likely to be informed last and highly unlikely to get a DEFRA or vet visit, should an outbreak occur locally (unless you ask for one), on a slight tangent but still relevant, at 50 birds or under you are allowed to sell any eggs produced 'at the gate'. You dont have to register as an egg producer or candle, grade the eggs, part of this falls under grand father rights and part is custom and practice, contrary to popular belief the government is not out to crucify the little guy.
Selling a few dozen eggs 'at the gate' does not get you a visit from the tax man either, although by the letter of the law you should actually declare the income, in reality at this level its more hassle to process than its actually worth.
Now lets say my little flock of 40 birds are lent to a friend down the road who has a slug or snail problem in there garden, no one bats an eyelid. When I bring the birds back and say buy 5 more chickens then according to the letter of the law I am at that point not allowed to move any more chickens on or off my property for 3 weeks (I think its around 3 weeks, but not 100% sure of the time scale). Again being under the 50 bird limit this is not enforced and nothing is really done.
So now lets say I have 60 chickens, then by law I am required to enter this onto my DEFRA form. These are supposedly registered and I am given a flock number, I can still sell 'at the gate' but i am limited as to the quantity i can sell without having to register as an egg producer, registering as an egg producer in done via trading standards and involves a visit from environmental health [ recently some councils have had to combine departments in order to cut costs, however the visit is conducted by an environmental health officer, but he might be under a different department!].
If i now move my flock of 60 birds down the road, I have to fill in a movement license, these are downloaded online if needed, you do not have to wait for a response and rarely get one (specific conditions trigger a response), you are allowed a time period in which to send the movement license off, i cant remember the time frame and cant be bothered to look it up (you can check yourself online) but I think its something like within 1-3 months.
If I move the flock then apart from a travel license (if over a certain distance) all I do is fill in a movement form, this allows DEFRA to keep track of the number of chickens in a given area. Chickens become a bad model at this point, but lets stick with it. The place you move them too should have a parish number, so on the form you put the parish number (small holding number) from where the birds came from, and the destination parish number of where the birds are going.
At this point there is a stand still period, I would not be allowed to move new chickens onto my small holding for 21 days (I think 21 days), nor would I be allowed to put more chickens onto the small holding where I had put my chickens for 21 days. There a mechanism you can use to get permission to break this rule, you have to apply for it and I dont really know much about it, but I think it boils down to having to have a very good reason to do so.
Now the proposal for Bees is along the same lines, at the moment nothing has been set in stone. Before anything is set in stone there would be wide consultation anyway.
The proposal currently is.................
You register say 10+ hives, where you keep them permanently (your apiary) would be given a number. Similar rules would apply as above regarding chickens.
If/when these are moved you fill out a downloadable form, you have time to do this (currently suggestion is 1 month) and send it off, you dont have to wait for anything, but you would have to put on the form the location they have been from and the location you have moved too.
You would then be under standstill for (current suggestion 4 weeks), however lets assume at home you have 15 hives and move 5, you cannot bring new Bee's into either area for the period of standstill. The difference here is in the wording NEW, if within this period you move another 5 of your original hives to the same location then these are not new bees, you do however reset the standstill date. If you move the hives to a different location you fill out a form again and put the location down, again these are not NEW Bees.
Now lets assume you get a call to collect a swarm, and your apiary is under standstill, You fill out the form (within a month) and send off, you can place the Bees ANYWHERE except an area that is under standstill.
That is roughly the current proposal being discussed. Again I must stress at this stage the proposals have not reached the stage of submitance, when they do then consultation with relevant associations etc will take place.
The fly in the ointment being if we leave the EU then I have zero idea what will happen, its likely to get kicked into the long grass for a good while.
Academia and various research groups would like to see this brought in within two years (myself included), this is about as likely to happen as Ms GB turning up on my doorstep and declaring her undying love for me!
At some point I would like to post on a new discovery (a virus) and how it came about. The reason is i get the feeling there are many assumptions that get made that are not actually how it happens, you may also find it interesting, it will certainly help explain why personally i would like to see registration as quickly as possible.