Mr. Paul Savage:

I know. We take it as a given that we are endeavouring to be as simple as possible in the way that the CAP is structured. We have said in the past at member state level that it would be simpler for us to implement the CAP if we were given more subsidiarity and more responsibility for carrying out and controlling the measures. One could say that the Commission has called our bluff on that in setting out a new approach under the CAP. It is giving member states more responsibility in terms of carrying out controls and we have to do it within the broader framework that has been created at European level. Notwithstanding that, there are still a number of elements of the proposals that will not reduce but in many ways intensify the complexity of the measures that we will have to put in place and the systems we will have to put in place to monitor that. I will return to this in a moment.

In an overall sense, the Commission has called for, and member states have repeated, the need for simplification in the CAP. This should underpin all of the discussions we undertake in regard to any aspect of the CAP. As far as the new delivery model is concerned, the question is how do we make it simpler. From our point of view, the new delivery model is the key to our approach to the overall CAP negotiations. We are moving from a compliance model to a performance model where we are required to come up to a certain standard in terms of how we implement the CAP and then we have to demonstrate that. We say that member states have to be allowed to do that in a simple way and not an overly complex way.

Part of the Department's issue about the proposed new delivery model is that there are a number of very complicated elements to it which we feel are almost unworkable. For instance, there is a question as to how we establish unit amounts for non-area or non-animal based interventions to measure the impact of different actions in the delivery model. It is easy to establish unit amounts in the case of, say, direct payments, or in cases where one is talking about the number of payees, or the area to which one is applying it but, in the case of other schemes which are demand-led, for instance those under Pillar 2, it is not always easy to set out those amounts in advance because one does not know what level of response one will get, or how much money one might spend on different measures. To ask people to come up with annual unit amounts, monitor that and potentially pay penalties for deviations beyond it, seems overly complex. We must come up with a solution as to how we even set indicative targets for annual unit amounts for non-area schemes and maybe allow us, for instance, to notify those to the Commission outside the strategic planning and amendment processes in a way to allow us to identify those amounts after we have got the response to the programme from people who are applying for it. In other words, when the scheme has been established, we will then be in a position to set those figures.

There are a number of other issues around the delivery model including, for example, reporting requirements. There is a raft of result indicators and other indicators with which member states must comply. We are asking for that to be simplified. The Commission proposal talks about result indicators and annual milestones being reported on across the board. We are saying that, in the case of, say, result indicators that might apply to multiple interventions, we might only have to report on one key result indicator and not across the full range that apply in a particular scheme.

There are also issues regarding the minimisation of the reporting obligations by the 15 February deadline every year. From our point of view, there is potential for information technology to be used to a greater extent, for instance in supporting inspection activity on the ground. That is not particularly well facilitated in the proposals at the moment.

There is also a need for much more targeted measures. If the complexity of the model being used to oversee things can be reduced, then those measures can be targeted much more effectively.

From our point of view, the new delivery model does not satisfy the simplification criterion in many ways and that is something on which we have been working. To be honest, part of the problem with not achieving a partial general approach during the Romanian Presidency at the end of June was this very problem about the new delivery model and the performance framework. Many member states, including Ireland, had serious questions about that, felt the Presidency was moving too fast, and it still needs much technical discussion. We are hopeful we can make more progress on that over the next number of months under the Finnish Presidency.

On the issue of the crisis reserve, the Commission is proposing that the funds that would be used to create the crisis reserve would be from the financial discipline that would be applied in 2020, carrying into 2021. We are saying that we should have recourse to other unspent funds which would allow us to avoid taking that financial discipline from farmers in 2020 and carrying it forward into 2021. We again think it would be fairer and simpler to continue on with that and try to establish the reserve from other sources. All other sources should be used before we revert to the financial discipline that has been there in that past. We should then look at our options beyond that.

There was mention of replacing the crisis reserve with a new risk management tool but it is not so much about that. The proposal, as it stands, talks about a mandatory requirement for risk management tools on the part of member states. We would prefer risk management tools to be voluntary and we have repeated that in discussions to date. We still maintain that position. Reference was made to insurance and other potential options. That would allow us to assess what might be feasible at a member state level but it would be underpinned by a voluntary provision in the regulations.