There is no added value for AP and FB to perform the ETS
Experience shows that reference parcels based on AP or FB are not always as “pure” as the member states assume. The ETS, when correctly performed, will allow a systematic comparison of the real world with information recorded in the LPIS. In this way it may draw attention at different generic issues related to the LPIS design and implementation.
The ATS is complicated and some concepts are unclear
The ATS is a tool to check whether the LPIS model of a Member state is conformant to the LPIS Core Model (LCM). On its turn, the LCM is technical a representation of the requirements from of the legal acts (Council Regulation 73/2009 and Commission Regulation 1122/2009) as well as the best practices identified by the Member States. It can be interpreted as a checklist for verifying whether the various elements of the conceptual model in a Member State fit LCM.
Since LCM is a conceptual model, it contains all the necessary definition (i.e. feature and data types, their attributes and associations). At the moment, the LCM is focused on 1st pillar aids; therefore the eligibility profile (part of the implementation conformance statement) is limited to the concepts representing the pre-health check requirements. Module A_12 of the ATS is targeted on this part.
With the CAP reform a revised LCM will be generated, which will integrate module A_132 (cross-compliance attributes) in the eligibility profile. At the same time best efforts will be paid to clarity, refining definitions and making unambiguous what is mandatory for conformity.