Mr. Francesco Martinelli, ITALY

Report
AGEA - ITALY
On-the-spot controls SPS
Implementation of art. 31a Reg. (EC) 1122/2009 in Italy
Francesco Martinelli – Director of AGEA Coordinating Body
Paphos,12 -14 Sept 2012
Reg. (EC) 1122/2009, On-the-spot controls SPS: application art. 31a,
Reg. (EU) n.1368/2011 in Italy
Cyprus Presidency of the Council of the EU
Article 31a, par. 1, sub-par. 1, of the Reg. (EC) n°
1122/2009, introduced by Reg. (EU) n. 1368/2011,
allows Member States to replace the control sample, on
the basis of risk analysis, with controls based on the
ortho-photos used to update the Land Parcel
Identification System - LPIS
Reg. (EC) 1122/2009, On-the-spot controls SPS: application art. 31a,
Reg. (EU) n.1368/2011 in Italy
Cyprus Presidency of the Council of the EU
Reasons for the implementation of Article 31 a in Italy – 1/5
In the early 90's, when the Integrated Administration and Control
System (IACS) was set up, EU Regulation stated to perform 100%
administrative checks (by IT systems), while only 5% on-the-spot
checks, because the control techniques available at that time
required systematic costly and time consuming field visits.
Since 2005 two new factors occurred:
The introduction of the decoupled aids within the Single Payment
Scheme – SPS (simplification of eligibility: agricultural area vs. non
agricultural);
The large availability of digital multispectral ortho-photos 50 cm
(in addition to Satellite), allowing the appropriate interpretation, at
affordable costs.
Reg. (EC) 1122/2009, On-the-spot controls SPS: application art. 31a,
Reg. (EU) n.1368/2011 in Italy
Cyprus Presidency of the Council of the EU
Reasons for the implementation of Article 31 a in Italy – 2/5
This allowed the extension of the techniques (defined at JRC level)
and procedures, typical of the 5% checks, at the entire 100% of
Italian territory.
Therefore Italy, since 2007, for SPS has risen from 5% up to 33%
every year the controls via remote sensing, completing in 2009 the
whole country (100% farms checking).
The result of those checks was notified to the farmers.
This led to three different cases:
- Full conformity – no further action needed;
- Differences on eligibility/measurement accepted by the farmer –
updating of LPIS;
- Differences on eligibility/measurement not accepted by the farmer meeting farmer/Paying Agency and signature of a statement defining
the effective area.
Reg. (EC) 1122/2009, On-the-spot controls SPS: application art. 31a,
Reg. (EU) n.1368/2011 in Italy
Reasons for the implementation of Article 31 a in Italy – 3/5
The 2010-2012 2nd round of LPIS updating take into account the
recommendations of the Commission (tares at 100 sqm, grazing at
20% and 50% better defined), recording the land use eventually
changed from agricultural to non-agricultural areas.
The LPIS updating procedure, in case of non agricultural area, lead
to the recoveries of undue payments and the application of related
reductions and exclusions.
Reg. (EC) 1122/2009, On-the-spot controls SPS: application art. 31a,
Reg. (EU) n.1368/2011 in Italy
Reasons for the implementation of Article 31a in Italy – 4/5
The above LPIS updating procedure complies with the provisions of
art. 31a of Reg. 1122/2009, that enable Member States to replace the
control sample, on the basis of risk analysis, with controls based on
the ortho-photos.
Article 31a will be not implemented for coupled schemes (including
cross compliance and rural development).
Reg. (EC) 1122/2009, On-the-spot controls SPS: application art. 31a,
Reg. (EU) n.1368/2011 in Italy
Reasons for the implementation of Article 31 a in Italy – 5/5
Conclusively, the eligibility checks to be implemented by Italian
Administration according to article 31a and the above procedure:
- provide for 100% safeguard of European funding;
- ensure the farmer participation in the process of defining and setting
discrepancies eventually detected by LPIS refresh;
- allow the National Administration to face less cost, save time and be
reasonably sure of avoiding undue payments.
Reg. (EC) 1122/2009, On-the-spot controls SPS: application art. 31a,
Reg. (EU) n.1368/2011 in Italy
Cost / benefit analysis (1/3)
The cost benefit analysis considered the following activities and
assumptions:
•Traditional On The Spot Checks partially executed on the basis of
CwRS methodology and high rate of field survey in the period
2004-2006 and on 100% RS since 2007
•LPIS full updating on the entire national territory in the period
2007-2009 and OTSC rate at 5%
•LPIS updated on the entire national territory and reduction of
OTSC rate to 1%.
8
Reg. (EC) 1122/2009, On-the-spot controls SPS: application art. 31a,
Reg. (EU) n.1368/2011 in Italy
Cost / benefit analysis (2/3)
Reduction of overall cost of controls
9
Reg. (EC) 1122/2009, On-the-spot controls SPS: application art. 31a,
Reg. (EU) n.1368/2011 in Italy
Cyprus Presidency of the Council of the EU
Cost / benefit analysis (3/3)
 Benefit to MS: Significant reduction on the cost of controls Italian scenario in saving between 10% to 33 % with respect to
traditional OTSC – no redundancy of controls
 Benefit to EU funds: controls performed on 100% of farmers in
the 3 years period, instead of 5% per year
10
Reg. (EC) 1122/2009, On-the-spot controls SPS: application art. 31a,
Reg. (EU) n.1368/2011 in Italy
Cyprus Presidency of the Council of the EU
Additional benefits to MS and to EU funds
For EU
 In Italy the recovery of the sum lost due to irregularities at the end of the
first round of the project (100% of territory in the period 2007-2009), with
regard to 2007 claims only, amounts to over than 45 M€.
For MS
 decreasing of errors in the farmers applications and reduction of
administrative burdens (i.e. no dispute with the farmers),
 payments can be made correctly and quickly with a reduction of
administrative costs,
 compliance with the European Court of Auditors’ conclusions (overall error
rate for SPS is slightly below the material error threshold of 2% - see point
5.13 of the ECA’s annual report concerning the financial year 2008);
 retention of 20 % of the amounts recovered and credited to FEAGA
according to Reg. 1290/2005 (in Italy this implied a significant recovery of
the overall sum for the establishment of the LPIS updating procedure).
11
Reg. (EC) 1122/2009, On-the-spot controls SPS: application art. 31a,
Reg. (EU) n.1368/2011 in Italy
Cyprus Presidency of the Council of the EU
Compliances with EU Regulation
requirements
Reg. (EC) 1122/2009, On-the-spot controls SPS: application art. 31a,
Reg. (EU) n.1368/2011 in Italy
Cyprus Presidency of the Council of the EU
Reference standard
Council Regulation (EC) 73/2009
Commission Regulation (EC) 1122/2009, new article 31 a,
Reg. (EC) n.1368/2011
Commission Regulation (EC) 146/2010
Joint Research Center – JRC documents
Common technical specifications for the campaign of remote-sensing
control of area-based subsidies (annual);
Guidelines for Best Practice and Quality Checking of Ortho Imagery
(Issue 3.0);
LPIS Quality Assurance Framework - Executable Test Suite (ETS)
•ANNEX I LPIS data quality measures;
•ANNEX II Flow of events, related to the inspection of the Reference Parcel;
•ANNEX III The Concept of land cover and “eligible hectares”;
Eligibility Profile" Template, version 4.3, October 2010.
Reg. (EC) 1122/2009, On-the-spot controls SPS: application art.
31a, Reg. (EU) n.1368/2011 in Italy
Cyprus Presidency of the Council of the EU
 1° Requirement (par. 1, sub-par. 3):
Member States shall systematically update the identification system
for agricultural parcels and check all farmers in the entire area
covered by it within a period of maximum three years, covering per
year at least 25 % of the eligible hectares recorded in the
identification system for agricultural parcels.
Compliance:
Italy has systematically updated in 2007-2009 its LPIS. Moreover,
since 2010 the second round of updating started, so that each year
the LPIS is updated for about one third of the national territory,
checking all the farmers located inside that territory.
Reg. (EC) 1122/2009, On-the-spot controls SPS: application art.
31a, Reg. (EU) n.1368/2011 in Italy
Cyprus Presidency of the Council of the EU
2° Requirement (par. 1, sub-par. 4);
Member States shall have made a complete update of the
identification system for agricultural parcels concerned within the
previous three years
Compliance:
Italy has already completed the update of its LPIS in 2007-2009.
Reg. (EC) 1122/2009, On-the-spot controls SPS: application art.
31a, Reg. (EU) n.1368/2011 in Italy
Cyprus Presidency of the Council of the EU
3° Requirement (par. 1, sub-par. 5);
The ortho images used for the update shall not be older than 15
months at the date of their use for the purpose of the update of the
identification system for agricultural parcels
Compliance:
The aerial ortho-photos used in Italy are of the same year in which
the agricultural parcels updating occurs (Ortho-photo of May-July>
LPIS update from August to October).
Reg. (EC) 1122/2009, On-the-spot controls SPS: application art.
31a, Reg. (EU) n.1368/2011 in Italy
Cyprus Presidency of the Council of the EU
Orthophoto time schedule
(first round 2007-2009)
Reg. (EC) 1122/2009, On-the-spot controls SPS: application art.
31a, Reg. (EU) n.1368/2011 in Italy
Cyprus Presidency of the Council of the EU
The upgrade project, from 2007
LPIS upgrade (“Refresh project”) has been starting in 2007 based on the
following basic elements:
Land cover photo-interpretation not constrained by cadastral boundaries, but
realized as a “continuous” layer (physical block approach);
Basic legend distinguishing agricultural areas (eligible for payments) and not
agricultural areas (not eligible);
Higher ortho-imagery quality (multispectral RGB+IR and pixel 50 cm);
Digital imagery at scale 1:10,000, but working scale between 1:1,000 and
1:3,000;
3 years update cycle, but favoring a regional approach;
Widespread use of ancillary data: registries (vineyard, olive tree, nuts, …)
preserving the historical information but also checking it;
Complete coverage of the entire national territory (300,000 sq.km) not limited
to the declared parcels, including artificial, natural and forestry.
Reg. (EC) 1122/2009, On-the-spot controls SPS: application art.
31a, Reg. (EU) n.1368/2011 in Italy
Cyprus Presidency of the Council of the EU
Further Remarks from EU auditors as drivers for finely tuning
the second round
During the first updating round (2007/2009) several EU audit missions occurred
and the auditors made some remarks:
delimitation of pasture polygons was considered not always homogenous over
the territory; pieces of land with different rates of tare were found aggregated in
polygons classified with the same code, even if they locally contain unequal
percentage of not eligible elements.
The minimum mapping unit of non eligible elements used during LPIS CAPI
(400 sqm) was different from the one used during OTS, causing possible
incorrect evaluation of not eligible area: LPIS should be taken as the baseline for
the calculation in the OTS sampled farms, without a previous review from CwRS
experts.
Reg. (EC) 1122/2009, On-the-spot controls SPS: application art.
31a, Reg. (EU) n.1368/2011 in Italy
Cyprus Presidency of the Council of the EU
Further Remarks from EU auditors as drivers for tuning
the second cycle
Such remarks, together with further needs (new environmental approach) and
the new “updating” point of view brought to the changes in the second cycle of
technical procedures. The most important were:
The minimum mapping unit of non eligible elements changed from the previous
400 sqm to 100 sqm, in line with the OTS threshold.
The pro-rata LC maximum mapping unit was reduced from the previous 2000
sqm to 1000 sqm.
More severe rules were implemented about natural pastures delimitation; new
procedures with detailed description of these more strict rules for pasture prorata polygons considered not homogenous were applied, describing how pieces
of land with different tare rates had to be split in more homogeneous elements.
New tools were introduced to facilitate the individuation of changes.
Reg. (EC) 1122/2009, On-the-spot controls SPS: application art.
31a, Reg. (EU) n.1368/2011 in Italy
Cyprus Presidency of the Council of the EU
Orthophoto time schedule
(second round 2010-2012)
Reg. (EC) 1122/2009, On-the-spot controls SPS: application art.
31a, Reg. (EU) n.1368/2011 in Italy
Cyprus Presidency of the Council of the EU
4° Requirement (par. 2);
The quality of the identification system for agricultural parcels as
assessed in accordance with Article 6(2) during the two years
preceding the application of this Article, shall be sufficient to ensure
effective verification of the conditions under which aids are granted.
Compliance:
Italy verified in the two years preceding the application of Article
31a that the quality of the LPIS, evaluated according to Article 6,
paragraph 2, of Reg. 1122/2009 is in conformity to the
requirements established by JRC.
Reg. (EC) 1122/2009, On-the-spot controls SPS: application art.
31a, Reg. (EU) n.1368/2011 in Italy
Cyprus Presidency of the Council of the EU
5° Requirement (par. 3);
The rate of errors found in the random sample checked on-the-spot
shall not exceed 2 % in the two years preceding the application of
this Article. Moreover, the rate of errors shall not exceed 2 % during
two consecutive years when applying this Article.
The rate of errors shall be certified by the Member State in
accordance with the methodology drawn up at Union level.
Compliance:
Certify control statistics of the years 2010 and 2011 of all payments
agencies to guarantee the reliability and regularity of the payments
made. To this extent, an independent group of experts has been
established to perform the verification on accuracy of control
statistics.
Reg. (EC) 1122/2009, On-the-spot controls SPS: application art.
31a, Reg. (EU) n.1368/2011 in Italy
Cyprus Presidency of the Council of the EU
THANK YOU FOR YOUR ATTENTION

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