Descărcați

y the commitments are described in the eligibility section). 273. Minimum herd size per breed should be mentioned to ensure it is adequate to achieve the aims of the intervention, and to avoid excessive administrative costs. 274. In terms of the baseline, Romania should also explain how the intervention builds on experiences from 2014-2020, and how the support will improve upon the current situation. 275. The unit amount should be uniform and not average as the intervention is based on LUs. Table 13 needs to be amended accordingly. Forestry DR-07: Forest-environment and climate 276. Romania is invited to fill in the applicable support rates per hectare for the two individual sub-packages, in the SFC section dedicated to this. 277. Romania is invited to explain: 1) why the support scheme applies only for forest areas bigger than 100 ha; b) why the applicable support rate per hectare for the second sub-package – use of traditional machines to extract wood - (EUR 175) is significantly higher than the rate applicable until now under the RDP (EUR 137). In particular, as regards the 100 ha threshold, Romania is invited to clarify the number of holdings meeting this requirement and therefore potentially eligible for support against the total number of holding active in the sector. 278. Romania is requested to consider the link to Natura 2000 sites or EU protected forest species or habitats. 279. Romania is encouraged to include also a payment scheme to compensate forest owners for eco-system services, as recommended by the recently adopted Forest Strategy. 280. As this is an intervention that falls outside the scope of Article 42 of the SPR, please tick ”YES” in the relevant box of point 8. (Comment valid also for DR-8 and DR-19). DR-08: Afforestation — maintenance and care of woodland 281. The intervention does not foresee afforestation of new areas in the period 2023- 2027, but will only support previous unfinished afforestation contracts from the programming period 2014-2022. Romania is invited to explain the decision to discontinue the support for afforestation in the current programming period. Romania is invited to consider this within the framework of the Romanian Resilience and Reform Plan, where significant funding for afforestation was planned. 39 282. Romania is invited to fill in Sections 5, 6, and 7 of the intervention (in SFC) concerning the specific design, requirements, and eligibility conditions. Just a reference to the description of the similar intervention in the RDP 2014-2022 and RDP 2013-2020 does not suffice. 283. The Commission has been developing, together with Member States and stakeholders, guidelines on various forestry topics including biodiversity friendly afforestation. We recommend Romania to consider them, where relevant, and distribute them to beneficiaries and managing authorities once they will be adopted and published. 2.3.4.2 Areas with Natural Constrains (ANC) 284. Interventions should be attributed to objectives to which their contribution can be considered substantial, significant and direct. Romania is invited to further reflect on the proposed specific objectives. 285. Romania is required to provide a short explanation on how the intervention comply with the requirements of paragraph 13 of the Annex 2 to the WTO Agreement on Agriculture. The explanation should be complemented, for example, by considering that ANC payments have to be degressive. DR-09: Areas affected by natural constraints — Mountain area 286. Romania should explain the decrease of 60% of the aid compared to the 2014-2022 programming period. DR-10: Areas affected by significant natural constraints 287. The link between intervention DR-10 and SO5 and SO6 is not justified. Therefore, Romania is requested to reconsider the SO to which ANC interventions contribute. 288. The intervention specifies that in 2018 the fine-tuning was updated to exclude areas where those constraints have been overcome through investments or economic activity. Comparing the figures for Output indicator O.12 (3 930 000 ha) with the planned Output indicator 2014-2022 for M13.2 (3 850 000 ha), there is an increase in the area (80.000 ha). Romania is requested to explain why, consequently to the fine-tuning, the area is increasing instead of decreasing. 289. During the RDP 2014-2020 negotiations, Romania officially committed to undertake a study (or a suitable alternative) to establish reliable data and mapping on irrigation use at Local Administrative Units (LAU) 2 level. The study should have also been the basis for a fine-tuning exercise performed with the scope to exclude from the ANC areas receiving support, areas where the irrigation infrastructure was modernized. Romania is therefore advised to perform a new fine-tuning and to take out from the ANC areas, areas which were previously modernized with EAFRD support, but also the newly areas with permanent crops and the areas with high yields. N2000/WFD payments 290. Romania is invited to consider introducing interventions on WFD and Natura 2000 payments since mandatory instruments could usefully complement voluntary 40  interventions to help reach good status of water bodies by 2027 as required under the WFD, and to ensure non-deterioration of habitats and to prevent disturbance of species in the sites. 2.3.4.3 Investments, including investments in irrigation (Article 73-74 of the SPR, section 5 of the Plan) Productive Investments 291. For all interventions including investments in irrigation, while the Plan states that such investments will comply with Article 74 of the SPR, the Plan does not set percentages for potential water savings and effective reduction in water use as an eligibility condition. Romania is requested to set such percentages. It is not clear why on-farm irrigation investments are spread across five interventions (DR-12, DR-13, DR-14, DR-15, and other in the wine sector) and how such investments in irrigation will be monitored. 292. Non-productive investments should be planned in a separate intervention, using Output indicator O.21. Moreover, Romania is invited to take into consideration that non-productive investments should be limited to non-remunerative investments linked to the delivery of purely environmental and climate benefits. Therefore, more details on the eligible investments for “protection curtains for crops” are needed. 293. The unit amount should not be planned for the years when no financial allocation is planned. 294. Many of the investment interventions refer to renewables generation; it is thus regrettable that the Result indicator R.15 has not been included, and Romania is encouraged to add it to relevant interventions. In addition, the interventions should refer to the RED II for the promotion of the use of energy from renewable sources and its sustainability criteria. Where renewable energy production is mentioned, a clearer description of what this includes is necessary, including the cost of installations. To ensure a tangible outcome, it may be preferable to have a single intervention dedicated to the bio-economy. 295. Selection principles should reflect the intervention logic. Romania is invited to adapt them to the needs. DR-12: Investments in strengthening the farms of young established farmers and newly established farmers 296. The intervention seems to mention, as eligible expenditure, complex (or military) equipment for protection against hail such as terrestrial generators or active interventions in the atmosphere. Romania is invited to provide more information about this type of investment (Comment also applicable to instrument DR-13, DR- 14, and DR-15). 297. Romania should explain why the Authorized Physical Persons are excluded from support (Comment also applicable to intervention DR-13, DR14, and DR-15). 298. Selection principles are not very clear. Therefore, additional information is required. 41 DR-13: Investments in fruit farms 299. There are only 108 operations envisaged to be supported (for a total budget of some MEUR 151). In order to increase the number of projects supported Romania might decide to lower the maximum budget for a single project (currently EUR 1.5 million). DR-14: Investments in primary production in the vegetable and/or potato sector 300. There are only 155 operations envisaged to be supported (for a total budget of some EUR 121 million). In order to increase the number of projects supported, Romania might decide to lower the maximum budget for a single project (currently EUR 2 million). DR-15: Investments in primary production in the hops, flowers and table grapes sectors 301. There are only 63 operations envisaged to be supported (for a total budget of some EUR 50 million). In order to increase the number of projects supported, Romania might decide to lower the maximum budget for a single project (currently EUR 1 million). DR-16: Investments in primary production in the livestock sector 302. Taking into account the spread of ASF in Romania, the Commission recommends to include in the Plan a targeted intervention to limit the spread of the disease and enhance biosecurity of pig holdings, as well as targeted advisory services, knowledge sharing or risk management. 303. There are only 182 operations envisaged to be supported (for a total budget of some EUR 237 million). In order to increase the number of projects supported, Romania might decide to lower the maximum budget for a single project (currently EUR 2 million). DR-17: Investments in conditioning, processing and marketing — agricultural products and fruit trees outside the holding 304. The intervention is tailored towards big commercial undertakings (big companies, SMEs, associative forms). Moreover, only 72 beneficiaries will be supported, with a total budget of some EUR 252 million. The total budget for one project may reach EUR 15 million. Romania is invited to open the measure also to individual farmers and to better target it towards small and medium farmers, as these constitute the grand majority of farmers in Romania. DR-18: Investments in the processing and marketing of agricultural products with a view to obtaining foodstuffs and processed products other than those listed in Annex 1 to the Treaty on the Functioning of the European Union 305. The maximum value for a project supported is extremely high (EUR 15 million). Therefore, the intervention (with a total budget of EUR 202 million) will only target support to 155 beneficiaries/projects (big commercial undertakings). Romania should better explain this decision. 306. It is not clear why this intervention is linked to SO8. 42 DR-19: Investments in forestry technologies that improve the resilience and environmental value of forest ecosystems 307. This intervention targets non-productive investments, particularly purchasing of machinery and equipment. However, most of the listed items are rather multifunctional and normal equipment for productive works. Therefore, it would be better to separate these investments under a productive and non-productive interventions, e.g. items under point A, B, C, with the exception of funiculars, or very specialized non-productive tools, e.g. for working with animals, should go under productive investments with 65% support rate. 308. The remaining items under D and E (since the software is necessary for ensuring the legality of the wood) and the specialized items from B (funiculars, etc.) could go under non-productive investments with the planned 70% support rate. 309. Romania is invited to diversify the fire prevention investments (e.g. water reservoirs/points, fire breaks, fire roads) and to include investments for the prevention against other abiotic threats and pest or disease outbreaks that increase forest vulnerability. 310. As this is an intervention that falls outside the scope of Article 42, Romania is requested to tick “YES” in the relevant box of point 8. DR-24: Investment in the creation and development of non-agricultural activities 311. Romania is asked to clarify how the intervention contributes to the Cross-Cutting Objective and how the identified need 34 is addressed. 312. Romania is invited to further develop the principles of selection according to the territorial identified needs at local level, to define the size of rural settlements concerned and to provide more information about the complementarities and the demarcation line with other rural development interventions, especially with LEADER, and other Union funds active in rural areas. 313. Romania is advised to define an eligible list of services/productive activities/tourism that are most needed in rural areas, based on the SWOT analysis or other studies. Moreover, Romania is also requested to define a negative list of non-agricultural activities, which will be ineligible under the intervention. For example, Romania is strongly advised to exclude from support rural guest houses (excluded in the previous programming period) as supporting this kind of investments resulted in implementation weaknesses and therefore in significant financial corrections. Also, Romania is also advised to exclude from eligibility supporting agricultural services, as this area resulted in the past in the creation of artificial conditions to access aid (it was ineligible in the previous programming period). 314. Romania should explain why farmers are not eligible. 43 Green, Non-Productive Investments, Irrigation DR-20: Modernisation of irrigation infrastructure 315. It is understood that the intervention supports investments in the improvement of existing irrigation infrastructure, in particular to reduce water losses and improve energy efficiency. Given the link to SO5 and Result indicator R.27, investments in the construction of reservoirs, which are associated with a “net increase” of irrigated area, cannot be included under this intervention, but can be planned under a different intervention. 316. Potential water savings of 2% seem inadequate given that existing infrastructure is outdated in terms of efficiency. The rates for potential water savings and for an effective reduction in water use need to be revised since they need to reflect the technical parameters of the existing irrigation infrastructure and contribute to achieving good status of water bodies whose status is less than good in quantitative terms. 317. Romania is also invited to consider complementing such investment with other interventions to address water quantity issues, such as natural water retention measures, nature based solutions, and measures to reduce demand. 318. Romania should provide a mapping of the irrigation areas foreseen to be modernized. During the RDP 2014-2020 negotiations, Romania officially committed to undertake a study (or a suitable alternative) to establish reliable data and mapping on irrigation use at LAU2 level. The study should have also assessed and monitored the overall potential and actual impact of the irrigation infrastructure to be supported by EAFRD on water bodies from which water will be sourced. Romania is therefore advised that the interventions DR-20 and DR-21 be based on solid data provided by this study. DR-21: Establishment of irrigation systems 319. Romania should explain the complementarity with the interventions RD-13, RD- 14, and RD-15. 320. Romania is invited to consider reclaimed water as a useful alternative water supply, to be done in accordance with Regulation (EU) 2020/741 and fully respecting the provisions and objectives of the WFD. 321. Romania is invited to clarify whether the intervention covers only investments in “new irrigation” systems on farm (investments leading to a “net increase” in irrigated area), including the creation / extension of water collection and storage basins, or also investments in the improvement of existing on farm irrigation installations (to make them more efficient). 322. Romania is invited to note that where an investment in the creation of water storage basins leads to a “net increase” of irrigated area, the requirements of Article 74(6) of the SPR apply. 323. Romania should explain why the intervention starts its implementation only in 2026. 44 Infrastructure 324. Romania is invited to ensure that the challenges of poverty (not only farmers´ poverty) and social exclusion, income disparities and the special service needs of rural vulnerable groups (including people with refugee background from Ukraine) are also targeted on a corresponding way in measures DR-23 and DR-24. 325. Romania is requested to clarify the proposed investments in intangible assets and to include a list of ineligible categories of expenditure under DR-22 and DR-23. 326. Romania is asked to confirm that investments concern small-scale infrastructure under DR-2