Mr. Brendan Gleeson:

It would. It would be possible to take 15% from pillar 2 payments and move it to pillar 1 measures. However, in either event we would be bound by the overall requirement to have a proportion of the budget for environmental and climate change measures. I imagine that in the context of the overall argument on the MFF, it will be a critical part of any case made to maintain the CAP budget. I think that is inevitable.

On genuine farmers, when the Commissioner was here, he gave an absolute assurance that under no circumstances would part-time farmers and marginal land be excluded. Again, I am not allowed to talk about policy, but I take the Commissioner at his word. We had CAP consultation meetings around the country and the issue of genuine farmers came up a lot. Everyone was able to say who was not a genuine farmer, but nobody gave us a definition of a genuine farmer. In some instances, it centres on people who may be retired and renting out land - people who worked on the farm all of their lives and are now getting an income from the land. There are very emotive issues about the definition of what is a genuine farmer.

The difficulty with the definition is that it is full of legal uncertainty. I do not know what is a negligible proportion of somebody's economic activity. It also provides for things like income tests and asks someone to look at value. I do not know how one would do that. From the point of view of running a practical payments system, it would be immensely burdensome - I would think impossible - to check such things. It ended up with people coming up with a negative list and everyone knew who was not a genuine farmer, but it was not too easy to define who was a genuine farmer. I would not be too surprised if we were to end up in a similar position this time around.

Deputy Willie Penrose asked about redistribution. I think I have dealt with that issue. He also mentioned online applications. It has been an extraordinary success story and is the to credit of farmers who have applied online. It is also to the credit of the Department which has made an enormous effort to engage with officials. It has been a tremendous success. In time it will lead to a smoother system with fewer delays in payments.

The Deputy asked about risk management. The traditional definition of risk management is that it is a subsidy for insurance premiums to cover income or perhaps stock losses, or some contribution to a mutual fund farmers would set up. It is to manage risks such as losses in income, price losses and perhaps weather related events. The last time around it was available to member states. It would require us to take a pot of the pillar 2 money and decide to use it to help farmers to obtain insurance or set up some mutual funds to help farmers in the event that there was a crisis. We decided not to do that the last time around for a variety of reasons. However, this time around it is mandatory. The regulation specifically refers to insurance and mutual funds, but it does not confine it to them. As a general proposition, we are not enthusiastic about mandatory risk management, but that is not to say we would not be prepared to consider it. It is something we have to consider, given the vagaries of the weather and the things that happen from year to year. However, we really need to penetrate the detail to decide whether we will do it. I do not think we will be too enthusiastic about a mandatory risk management requirement in the regulation, even if we decide to do it afterwards.