What is considered a homogeneous LPIS?
The question whether a population of reference parcels under inspection is homogenous and thus constitute a single "sampling lot" depends only on the processes of RP creation and RP upkeep. The physical nature of the reference parcels or the administrative subdivision of the Paying Agency/Regional centres who apply those processes can, but do not necessarily cause heterogeneity.
MS applying different subsets of parcels should define the rules and methodologies for their creation ex ante. In order to check whether the suspected sources of heterogeneity and the impact of identified RP categories (within IACS) are indeed insignificant, MS should perform ex post basic statistical analysis of the testing results.
Following ISO 2859/2-1985 (procedure A, LQ=2%), the sample size for any individual lot cannot exceed 1250 parcels. NOTE: For any given LPIS, inspecting two or more sub-lots will always require more resources than testing the whole set of parcels together.
Do we need to inspect parcels that are declared only for "other uses"?
Parcels declared for “other uses” are integral parts of the LPIS. They need to be identified to support the unambiguous location of agriculture land. If their eligibility is set to zero, a special procedure has to be set for validating their potential eligibility in the field before any payment can be made when such parcels are declared for payment. This procedure has to be demonstrated by the MS.
Because of the zero eligibility value and in absence of claims these parcels may miss the regular upkeep processes. As result, they might be outdated and appear as a sub-population of LPIS reference parcels, where the "reference area value" is outdated or missing. Only parcels that were declared exclusively for “other uses” in the previous application and have a zero reference area value are exempt from inspection.
Why consider parcels that are not-declared for aid?
It is a legal requirement that all agricultural area on the holding shall be declared and hence, also the parcels not claimed for aid must be in the LPIS. More precisely Article 19(1) of Regulation (EC) No 73/2009 establishes that farmers shall declare all the agricultural parcels of the holding. This implies that farmers must declare not only the parcels in respect of which they claim aid but also any other unclaimed parcels of the holding. The main purposes of this obligation to declare all parcels are to enable effective cross checks as well as the control of the cross compliance requirements.
In accordance with Article 55 of Regulation (EC) No 1122/2009, farmers might be subject to reductions in the case where they have omitted to declare one or more parcels. However, this Article does not provide a legal basis for imposing sanctions in the case where the farmer has declared all his parcels but with an underestimated area, i.e. a number of hectares which is below the size determined by the authorities.
How to deal with temporary (ineligible) land cover features?
The classifiers used for the land cover types relevant in this domain are not affected by temporary phenomena. When a feature, considering the local context, is determined as “temporary”, the inspector should ignore it and simply apply the “underlying“ land cover class. Of course, in this judgment the interpreter should apply the knowledge of the local practices:
EXAMPLE 1: the covering of grassland or arable land with a thin layer of sludge from the neighboring canal will not change the long term nature of the land cover.
EXAMPLE 2: A visible spray track on arable land is most likely be ploughed next year. However a path between to gates in fence is likely to persist. Although such temporal variations influence the land cover appearance, they do not influence its nature or description, and so the classification works independently of the date of observation.