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/126 (general production costs such as support for solid protein feeds in intervention “IS-A-16” are ineligible as per Annex II, part I, point I). 216. The demarcation with EAFRD interventions should be clearly described in the Plan and not only in the implementation documentation as stated in section 3.5.2. 217. Under investment support IS-A-18, 19, 20 and 21, the planned unit amounts are per equipment. Romania should clarify in the description of the planned unit amount and outputs if this is the amount received per beekeeper and how many beekeepers will be assisted. 218. Interventions in this sector indicate besides contributing to economic related objectives (SO2) also a direct contribution to SO6. While most interventions might fit to SO6, further explanations are needed for some (e.g. improving the quality of products). IS-A-09 & IS-A-11— Technical assistance for beekeepers and beekeepers’ organizations — Advice in beekeeping and Organization of refresher training courses in beekeeping 219. Romania is requested to clarify what actions will be supported under Advice in Beekeeping and Organization of refresher trainings and provide examples of eligible expenditure/costs. Romania should clarify if only these two interventions will be supported or as described in section 5.2.7 other actions. 220. Whilst the support is granted to Apiculture organisations, the planned unit amount is calculated per beekeeper without any justification or explanation on how the planned amount and outputs are determined. Romania is requested to explain why only 500 beekeepers benefit from refresher training courses. 2.3.3.3 Wine 221. For financial year 2023, annual indicative financial allocations under Section 5 do not correspond to the planned amounts in the Financial Overview table under SFC Section 6. Romania is requested to revise the figures. IS-V-23: Restructuring and conversion of vineyards: 222. Romania is invited to increase the environmental ambition on water savings which currently is only 2% (also valid for IS-V-29) 223. Result indicators showing environmental contribution are missing (e.g. R.26 and/or R.29) (valid also for IS-V-24 and IS-V-29). The planned unit amount for 2023 is missing as well (also valid for IS-V-25). 33 IS-V-24: Investments in tangible and intangible assets 224. There is no expenditure planned as contributing to environmental ring fencing according to Article 57(d) of the SPR. 225. The planned unit amount and the value for Output indicator O.36 for 2023 are missing (valid also for IS-V-26 and IS-V-28). IS-V-25: Harvest insurance 226. The unit of the planned unit amount for 2024 in Euro has been determined on the basis of experience with the implementation of the harvest insurance measure; analysis of the last 3 years shows an average amount per hectare of EUR 55/ha. Romania is requested to specify the method of calculation. 227. Romania should ensure compliance with the provisions on specific eligibility conditions laid down in Article 40(2) of Commission Delegated Regulation (EU) 2022/126. IS-V-26: Information actions 228. Investments are not eligible under this type of intervention. Therefore, Romania is invited to explain the additional information included (“No support shall be granted to investments referred to in Article 58(1)(h) of the SPR for interventions that received support pursuant to points (b), (i) and (k) of Article 58(1) of that Regulation.”) IS-V-27: Promoting enotourism 229. Romania is requested to remove the link to Result indicator R.9. 230. The amount of the planned unit amount for 2024 in Euro has been determined on the basis of experience in the implementation of the investment measure. This type of intervention is not related to investments. Romania is requested to correct and explain the method of calculation of the planned unit amount. 231. Investments are not eligible under this type of intervention. Therefore, Romania is invited to explain the additional information included (“No support shall be granted to investments referred to in Article 58(1)(h) of the SPR for interventions that received support pursuant to points (b), (i) and (k) of Article 58(1) of that Regulation.”) IS-V-28: Promotion and communication in third countries 232. There is no result indicator associated to this type of intervention. Romania is requested to remove the link to Result indicator R.9. 233. Investments are not eligible under this type of intervention. Therefore, Romania is invited to explain the additional information included (“No support shall be granted to investments referred to in Article 58(1)(h) of the SPR for interventions that received support pursuant to points (b), (i) and (k) of Article 58(1) of that Regulation.”) 34 IS-V-29: Investments in tangible and intangible assets to increase the sustainability of wine production 234. As this type of intervention seems to overlap with IS-V-24, Romania is requested to explain the differences/demarcations between the two interventions. 235. The amount of the planned unit amount for 2024 in Euro has been determined on the basis of experience with the implementation of the investment measure. Romania is requested to explain the calculation method. 2.3.4 For rural development 236. Romania is requested to consider that interventions need to be designed against specific objectives to which it brings a main contribution and this does not seem to be the case in particular for SO6 and to revise accordingly. 237. Romania is requested to consider introducing in section 4.7.3 a general eligibility requirement for an assessment of the expected environmental impact in accordance with the applicable legislation for the type of investment concerned, where an investment is likely to have negative effects on the environment. 238. Financing of interventions/activities falling outside the scope of Article 42 of the TFEU must be State aid (SA) clearance established. Companies in difficulty or companies still having a pending recovery order following a Commission decision must be excluded, with exceptions in the applicable State aid law. 239. Romania needs to ensure State aid clearance, where necessary, by the end of 2022 in accordance with the rules currently in place. If state aid SA clearance is demanded after 01.01.2023, the new State aid rules in Agriculture, which will enter into force on 01.01.2023, will apply. 240. In the financial table, Output indicators should be planned per year, when the first payment is expected. 241. In case of premia calculated based on additional costs and income forgone, the methodology should be explained in the intervention fiche and the certification by an independent body is to be provided in an annex to the Plan. 2.3.4.1 Management commitments (Article 70 SPR, section 5 of the Plan) Agri-environment-climate commitments General comment applicable to DR-01, DR-02, DR-04 and DR-05 242. The section ‘Description of the territorial scope’ should include further details on this scope, if applicable. The description of the positive impact of the intervention should be shifted to sub-section 5, while avoiding redundancies. 243. Romania is requested to describe how the commitments go beyond the mandatory requirements (as referred to in Article 70(3) of the SPR). In several cases, not even a list of the relevant GAECs is included. GAEC 6 and GAEC 8 are of particular importance for the two agri-environment and climate commitments. 35 244. Romania is requested to explain the articulation between these agri-environment and climate/organic farming commitments and eco-schemes, explaining synergies and provisions to avoid overlaps. The simple statement that the interventions are consistent with eco-schemes is not sufficient. 245. The duration of the commitments should be fixed (not ‘at least 5 years’), which can include the possibility of annual extensions (DR-01 and DR-02). 246. Contribution rate(s) applicable to the interventions: it is not clear from table 11 of each intervention which of the two possible contribution rates will be applied. Romania is requested to clarify the choice made. 247. Table 13 does not provide any output and expenditure for the years 2023 and 2024. Romania is invited to explain if support under the RDP 2014-2022 will cover 2023 and 2024 commitments. 248. For agro environmental climate commitments (AECC), it is recalled that one or more uniform unit amounts are the default option, depending on the (various) commitments included. Average unit amounts should be exceptional and justified. Degressivity of payments would not be in line with AECC since the premia should be based on costs incurred and income foregone. Furthermore, Romania is reminded that partial compensation of costs incurred and income foregone is not foreseen by Article 70(4) of the SPR. DR-01: High Nature Value (HNV) grasslands 249. Low ambition of the support is envisaged for HNV areas. Out of the 2.370 million hectares of HNV area, annual support is foreseen for less than a third (778.500 ha in total). The envisaged area to receive HNV support is slightly lower than in the 2014-2022 programming period and only at around 70% of the area supported in the 2013-2020 programming period. Also in terms of environmental ambition, the commitments that go beyond baselines seems to have been reduced from the previous programming periods. 250. Romania is invited to consider including hay meadows as eligible to prevent them from being converted into arable land or scrubbed over and also to make eligible all grassland types of the country (as currently proposed grasslands are not eligible in Eastern and South-Eastern parts of Romania). 251. Romania is invited to explain its decision to increase the maximum manure quantity allowed on HNV areas from 40 kg N/ha (in RDP 2014-2022) to 50 kg N/ha. 252. It seems that many beneficiary commitments (eligibility conditions), which were present in the RDP 2014-2022, were discontinued, for example the ban on ploughing and tilling and the demonstration of proven competencies for beneficiaries. Also, as regards the ban on mowing until a certain date, or the condition to evacuate the mowed mass after two weeks since mowed, it should be made clear in the intervention if this is part of the baseline (part of SMR2) or a specific commitment of the intervention. 253. In addition, the delay of the mowing date constitutes an important part of the income foregone considered in the calculation methodology for variant 1 of the 36  intervention, although this condition seems not to be part of the beneficiaries commitments package. Romania should clarify if delayed mowing constitutes also a commitment for variant 1 (as it is in case of variant 2 and 3 of the intervention). 254. Romania outlines that the intervention follows, among others, the national legislation for the Conservation of natural habitats and of wild fauna and flora (GEO No 57/2007, as amended). However, the reference to the Prioritized Action Framework (PAF) is missing and the Plan should ensure the synergy and consistency of this intervention with the objectives of the PAF. 255. Romania well describes in general terms the risks of intensification of agriculture, including the risk of converting permanent grassland into arable land. Given the description of the eligible area, a more specific assessment would be welcomed whether this risk of intensification actually exists in those areas or whether those areas, by their simple nature, would not be suitable for intensification. 256. The intervention is attributed to many result indicators, however, the direct and significant contribution to Result indicator R.12 (climate adaptation) is not clear. On the other hand, a significant part of the eligible area is classified as Natura 2000, for which Result indicator R.33 could be relevant, as long as the commitments go beyond the legal requirements resulting from the implementation of Directives 92/43/EEC and 2009/147/EC. If this is the case, a separate unit amount for those areas may be fixed to be attributed to R.33. 257. Romania is invited to confirm whether actually only “agricultural area” is eligible for support or whether, based on the description of the areas provided, the category “agricultural land including and beyond agricultural area” would not be the correct category to choose. 258. Romania is also invited to consider building on the work on Pilot Result Based Payment schemes at landscape scale in Transylvanian HNV farmland, and mainstream them into the Plan. DR-02: Green crops 259. There are strong doubts whether this intervention is sufficiently going beyond GAEC 6, bearing in mind that under this GAEC, it is in principle expected that all arable land is covered during the most sensitive periods. Romania is requested to consider the observation made as to the GAEC 6. 260. The use of chemical fertilizers is prohibited for the catch crops. Romania should consider to introduce also a ban on chemical plant protection products on these crops in order to enhance the environmental ambition of the intervention. 261. No interventions are foreseen for the conservation management of EU protected habitats and species present on agricultural land or on Natura 2000 with agricultural land – yet several such measures were specifically proposed for this in Romania’s PAF and earmarked for EAFRD funding. The previous interventions for butterflies and birds of the 2014-2020 RDP are not included in the Plan, despite the good argumentation of their importance within the SWOT. High biodiversity landscape features and pollinators are also missing from specific interventions. Romania is invited to reconsider the above and consider including measures identified in the PAF as part of the AECC. 37 Organic Farming 262. Whereas the direct and significant contribution to R.20 should be reconsidered, Result indicators R.43 and R.44 could be relevant in case the support is for farming systems including livestock husbandry. 263. While for all packages, the unit amount for conversion is higher than the unit amount for maintenance, this is not the case for package 6, variant 6.2 where the maintenance premia exceeds to premia for conversion. This might be an error to be corrected. 264. The fact that the beneficiaries are requested to submit to the paying agency (APIA) the certificate issued by the Control Body for organic farming does not change the model of the commitment from management based to ‘hybrid’. Romania is invited to correct the classification of the interventions accordingly in section 9. 265. The Commission acknowledges that the actions and tools of the AKIS, as well as the advisory and training resources existing on the free market, are available for the beneficiaries of the support. However, a mandatory supported training should be considered in particular for those farmers in conversion to organic farming. 266. The revision clause makes only reference to cases of commitments concluded under this intervention, which go beyond the current programming period. However, Romania is requested to include also the revision clause according to Article 70(7) of the SPR in the event of changes to the basic requirements. 267. The description of the system of verification and control of the interventions could be shifted to section 7 of the Plan. 268. In section 10 on WTO compliance, it should be specified how the intervention respects the relevant provisions of Annex 2 to the WTO Agreement on Agriculture (in this case it is the fact that the payments are based on costs incurred/income foregone linked to the commitment). 269. As mentioned under ‘general comments’, table 13 does not provide any output and expenditure for the years 2023 and 2024. For organic farming, this should also be seen in the light of the very modest targets set for support of only 3.53 % of the total UAA. Romania is invited to consider whether it could aim for a greater increase as a means of delivering additional environmental benefits while also securing a higher share of added value for farmers in the food supply chain. Animal Welfare DR-06: Animal welfare 270. The intervention is programmed under SO4, SO5 and respectively SO9. While the direct link to SO9 is obvious, the direct contribution of this intervention to SO4 and SO5 does not result. Romania is requested to revise the Plan accordingly. 271. The commitments are not conducive to significantly improving the welfare of pigs and poultry, and it is not clear how they are going beyond baselines. Routine tail docking of pigs should be avoided. 38 Genetic Resources DR-03: Agri-environment-climate — Breeding of farm animals of local breeds in danger of abandonment 272. Romania is invited to fill in the dedicated section in SFC2021 explaining the commitments for this scheme (currentl