Mr. Aidan O'Driscoll:

Yes, and they are regular. We have EU audits all of the time on all of our schemes. As the Deputy said earlier, the EU is putting enormous sums of money into these schemes and so the level of audit is not surprising. We do not have any difficulty with the fact that EU auditors investigate and trawl through the schemes in great detail. We are visited by auditors from a number of different units in Brussels as well, as I mentioned earlier, by the certifying body, which is the private accounting firm in Ireland that works on behalf of the Commission. We have all of those audits going on all of the time.

In this case, there was a series of audits from 2009 onwards. These audits would usually have been brought to a conclusion much earlier than occurred but there were a number of things that happened. We gave a robust response to each of the audits. We raised issues where we thought the Commission had got it wrong. The Commission engaged with us in this regard. There is a good deal of respect in Brussels for Irish systems. I do not believe they think we are engaged in anything nefarious. There was a lot of engagement but also a delay due to a tragic death of a Commission official who was key to the investigation which knocked back the audit for another period. It was 2013 before it came to fruition. By then, we had undertaken a large review of 900,000 parcels. A land parcel is, in most cases, a field or part of a field. We undertook a very detailed assessment of all of the land parcels. I know from talking to senior officials in Brussels that they were struck by this. Other member states had generally taken the hit and tried to negotiate a lower flat rate correction and so people in Brussels were struck by the fact that we undertook such a detailed re-assessment of the land parcels. In the process of that assessment, using the imagery which was shown earlier on screen, we found problems.

As Deputy Aylward will be aware, Ireland is marked by a lot of marginal land. The assessment of whether land is eligible or not is a tight assessment. There are some instances of where land is clearly ineligible. For example, if a house is built on a field that land is clearly no longer eligible. In situations where rushes or scrub encroaches on a field there is an assessment to be done and a judgment to be made. The orthophotography is very useful in, at least, pointing us in a direction to indicate where land might not be eligible. We conduct 5% inspections. We are required to do so by EU rules around land eligibility. The final disallowance includes a number of different elements, some of which we could have collected from farmers because it was possible to pin a disallowance to an individual farm but the bulk of it could not have been collected. Of the €67 million, the amount that could have been identified to farm level would have been, maximum, €20 million. The nature of the disallowance was extrapolated in nature such that it could not have been pinned on an individual farm.