- 1 Time clash between two consecutive reporting periods
- 2 Meaning of "in tempore non suspecto"
- 3 Inspection of parcels updated during the aid application process
- 4 When will the VHR satellite images be provided?
- 5 Date of reference data for ETS input
- 6 How to take into account the area updates submitted by the farmers? (QE 2)
Time clash between two consecutive reporting periods
Delegations pointed out a time clash between two consecutive reporting periods: evaluation for year N+1 starts before the report for year N is finished. This may prevent taking all actions identified in year N for improving in year N+1.
The Commission services have noted the situation. However, tight timing of aid claims, control, and payments do not allow other alternatives. However the longer time frame for remedial actions takes into account this issue.
Meaning of "in tempore non suspecto"
The phrase literally means "time without suspicion." In legal sense the term refers to information obtained at a moment of time when the person giving the information has nothing to lose by telling the truth. For example, in case of LPISQA the information from updates that had been planned and processed before the LPIS QA control zones were known can be regarded as such. Any time that excludes possible interference or manipulation of the LPIS results is by-default "non suspecto". By contrast, prioritizing an on-going LPIS update to focus on the LPIS QA zones (or selecting zones to match a planned update) disrupts the independent time lines and invalidates the update evidence as it would bias (i.e. clean up) the ETS results. Analysis of the populations presented for the sample-pre-selection allows ex-post confirmation of "in tempore non-suspecto".
Inspection of parcels updated during the aid application process
This question addresses the difference between the eligible hectare value presented to the farmer on the pre-printed form (until 2012) or crosscheck (from 2013) and the area established after the OTSC, which constitutes the basis for payment.
It is safe to assume that for any parcel not inspected by OTSC or by the LPIS QA, and not subject to a systematic update, eligible hectare value and established area are mechanically linked through the administrative crosscheck. This crosscheck applies to all parcels, whereas the OTSC inspection covers only around 5-8 % of the agricultural parcels. For these reasons, the eligible hectare value is considered to be more representative for the LPIS as a whole.
The issue of reporting the effect of the operational update process is however relevant because
- All RP anomalies identified during OTSC and LPIS QA are expected to have been processed by the start of the following aid application periode (i.e. one full year later).
- The difference in the rate of changed parcels identified and confirmed during the OTSC and LPIS QA and the total rate of transactions in the overall LPIS provides an accurate indicator of how effectively the LIPS is kept up to date and correct by the various processes. This difference is often referred to as the "NET" rate, or the rate of "undetected" parcel changes.
- Web services offer an automated instrument to follow-up the parcels inspected in LPIS QA, which enables the member states to demonstrate that thay have addressed the anomalies found in the process.
NOTE for statistical experts: if the "NET" rate of undetected changes approaches zero, i.e. a Member State claims that it is continuously capturing and implementing all RP updates, the sampling plan according to procedure B from ISO 2859-2 could be applied for the cases when the MS operates a formal quality reporting system to other stakeholders than the European Commission.
When will the VHR satellite images be provided?
The procedure for LPIS QA image delivery is similar to that of the CwRS campaign. The raw image is provided to a Member State within days, through an application called LIO.NET. The Member State should then orthorectify that image.
NOTE: every Member State should select the zones (ensuring randomness) and then the European Commission will open the acquisition window with the image providers.
Date of reference data for ETS input
In case of AP and FB RP LPIS types lots of changes are detected and processed in the period between the pre-printed forms are generated and the time when the farmer makes the declaration. It is not obvious therefore, which of these two should be taken for reference when ETS inspection is performed.
Until and including 2012, the Commission services considered that the date on which the pre-printed form was produced represents the reference data for the assessment of reference parcel information. This date ensures the availability of a documented status of information and a uniform methodology valid for all designs and Member States. A number of the issues specific to AP and FB RP-types are addressed in the inspection guidelines.
From 2013 on, the reference date is set to the date of the closure of the aid application procedure. This date links the reference area value to its use for the administrative crosscheck. The later date allows for farmer’s updates to be better accommodated.
How to take into account the area updates submitted by the farmers? (QE 2)
The pre-established form reflects an area value from the previous year even though it may have been corrected by the farmer in the declaration process as defined in Art.12.4 of 2009R1122. This situation adversely influences LPIS QA scores. Creating a waiver for this situation is not appropriate since a farmer’s update may affect most, if not all measure. On the other hand, by definition, a waiver can relate to one and only one measure. Consequently this situation should be resolved in the methodology.
The Commission services therefore recommend an additional step in the methodology: to update the reference area from the pre-printed form with the new area value provided by the farmer in course of [data preparation] (not by the result of OTSC inspections!).
NOTE: When applying this methodology the Member State should be able to demonstrate that the rate of farmer updates in the LPIS QA zones is comparable with the national average.