agea - italy on-the-spot controls sps implementation of art. 31a reg. (ec) 1122/2009 in italy...

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

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

Cyprus Presidency of the Council of the EU

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 – 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.



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.




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.


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).



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.


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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%.


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Reduction of overall cost of controlsReduction of overall cost of controls


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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



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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).





Compliances with EU Regulation requirements



Reference standard

Council Regulation (EC) 73/2009Commission Regulation (EC) 1122/2009, new article 31 a,

Reg. (EC) n.1368/2011Commission Regulation (EC) 146/2010Joint 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.



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.



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.



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).



Orthophoto time schedule (first round 2007-2009)



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.



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.



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 pro-rata 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.



Orthophoto time schedule (second round 2010-2012)



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.



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.



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