Dr. Al Grogan:

Yes. I have it on my list with a number of other items and one of them is a rock outcrop. It is difficult, and I purposely showed the shot of the mountain. In essence, it would be very difficult to get an inspector to walk over the tops of all the mountains so we have to use the best mapping and, in many cases, because of cloud cover or whatever, Mr. Harty's team would look at a range of maps to try to get a good impression or good idea of the percentage. I will link that in with the other question members raised in the context of this being out by 1% or 2%. Having seen what we were doing previously and the difficulty in that one would look at it and say it is 7% but I could look at it and say it is 11% - it is very easy to be wrong if there are 100 categories or even only ten categories - the Commission, in its wisdom, said it would change it to five categories. In its case it stopped at 50 and then there is no difficulty. It is likely that an error would be triggered if it is above 50 and that one would be out by a percentage. The term it uses is "repeatability", which is a statistical term that I will not go into, but the repeatability of it is good. It might be like classifying cattle and the difficulties that existed until mechanical means were brought in. The question is how one repeats the measure using a different pair of eyes. By having a smaller number of categories, the chances are that we repeat the evaluation, independent of person. When there is an outcrop of rock, it works fairly well. In terms of rock, I understand we do not have too many difficulties. It gets a bit more difficult with scrub where we are trying to distinguish from an ortho-image the difference between a green this, that and the other. Often when we say it needs ground verification, we have to go to ground to verify.

A member mentioned getting clarification with respect to a bog. Again, there is no issue with a bog that has been grazed but we do not want to give the impression that bog per seis ineligible. It is not agricultural land. Most of us would agree that bog per seis not agricultural land. Where it has been grazed, where someone is on the side of a bog or where it has been cut away and they have rejuvenated it in terms of growing grass or whatever, there is no difficulty. However, to give the impression that bogland is eligible would be dangerous from our point of view. From an audit point of view, for that to appear in a guidance would be dangerous as well. We chose our words carefully. Having clarified it, and nobody has a difficulty with this, most commonages have blanket peat.

The convergence issue was mentioned. That importance of the 2015 measures is that one can consolidate. If people are concerned that they have a problem, and linking it in with Deputy Ó Cuív's question about the need to have a planner, they do not have to have a planner, but we try to make sure they are up to speed on the latest information. The farmer would get whatever skills the planner has in terms of the training they got, but it is not a requirement. However, in many cases, with the online system, farmers use a planner but because the 2015 measures are very important, it is important the farmer's pot of money is put into something that is reliable and sound, and that is likely to be eligible land. That is the only caution we would advise. The Deputy spoke about accommodating it in some way. It can be accommodated if one can manage it with respect to 2015, hence the importance of this document and the importance of us getting the message out. It is unfortunate that it took time but we had many negotiations. We are always asking questions in Brussels and getting answers that can take some time but, touch wood, we got it within a month of getting in the application.

Fencing was mentioned. It is not possible to fence under certain rules. Traditionally, when a person is operating, they are abutting their commonage land and there is no need for fencing. We have concerns about fencing. Members are aware of the issue of leasing, people wanting to access land for nitrate reasons or whatever. Without going into it in too much detail, the members will have a fair understanding of the reason we need to be sure the person who should be farming is farming. Nitrates are an important factor when it comes to audits and controls, which comprise a serious area.