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2 and DR-23. DR-22: Creation/modernisation of agricultural access infrastructure 327. Romania is asked to revise the intervention logic, its consistency with SO8 and to clarify how the identified needs 29 and 35 are addressed, by taking into account that agricultural infrastructure mainly aims to improve the competitiveness of farms. 328. Romania should better justify the need of the high budget allocated to this intervention (EUR 200 million for 200 projects) as it seems excessive compared to similar allocations in previous programming periods and also to the budget allocation for intervention DR-23 (EUR 201 million for 204 projects). The SWOT analysis seems to argue for a bigger need in rural areas of basic road infrastructure than agricultural roads. Therefore, this should have been also reflected in allocated budgets. 329. Romania is invited to further clarify the principles of selection according to territorial identified needs at local level and to define the size of rural settlements served. In the text, it is mentioned that agricultural roads will be connected to other transport infrastructure, whereas neither the eligibility criteria nor the prioritization principles reflect this. 330. Romania should explain and justify why the value of the planned unit amount for an agricultural road project is similar to that of a rural road project. DR-23: Creation/modernisation of basic road infrastructure in rural areas 331. Romania is asked to clarify how the need 35 is addressed through the proposed activities. 332. Romania is invited to further clarify the principles of selection according to the territorial identified needs at local level, taking into account the needs of mountainous areas, to define the size of rural settlements served and to provide more information about the complementarities and the demarcation line with other rural development interventions and other Union funds active in rural areas. 333. The budget allocated (EUR 201 million targeting 204 road projects) seems small compared to the needs in rural Romania and also to allocations in previous programming periods (please also see comments for intervention DR-22). Romania should explain how this need is addressed both inside and outside of the Plan. 45 2.3.4.4 Installation aid (Article 75 of the SPR, section 5 of the Plan) DR-25: Support for the installation of young farmers 334. Romania is requested to: 1) Consider inclusion of need 23 in line with the intervention strategy for SO7; 2) Explain and justify the priority given to certain sectors (animal breeding, fruits & vegetables, potatoes); 3) Provide explanation on the modalities of implementation in respect to the special financial allocation allocated to certain type of farming (mountain area by specific natural and socio- economic conditions, mountain farms and organic farms); 4) Detail the way the priority to women young farmers will be enhanced; 5) Specify the required components of the business plan; 6) Make the requirements concerning head of holding and training/skills part of the definition of young farmer and ensure consistency with that definition; 7) Include Result indicator R.37 that is substantially linked to R.36. 2.3.4.5 Risk Management (Article 76 of the SPR, section 5 of the Plan) DR-26: Financial contributions to the payment of insurance premiums DR-27: National Support Instrument for farmers affected by agricultural production losses 335. Romania is requested to explain and clarify what form this instrument will take, whether it will be a Mutual Fund or other type of instrument. More information on the functioning of such an instrument, the budget allocated should be provided in the Plan. In addition, it seems that all farmers (who are in IACS) will be covered by this risk instrument (compensating for losses due to adverse climatic and environmental effects). Therefore, it seems that these will have no further incentive to insure their crops and also benefit from the other risk management instrument (insurance premia support). Romania should better explain the interplay between the two risk management instruments proposed. 2.3.4.6 Cooperation (Article 77 of the SPR, section 5 of the Plan) DR-30: Leader — Community-Led Local Development 336. Romania is invited to make sure 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 intervention. Romania can consider the use of Result indicator R.42 by this intervention. 337. Romania is requested to provide more information how it will ensure that all Local Action Groups (LAGs) will implement all principles of LEADER/CLLD method as provided for in Regulation (EU) 2021/1060 (the Common Provision Regulation - CPR). 338. Romania is invited to better describe the expected added value of LEADER in terms of social capital, local governance and project results compared with non- LEADER delivery. 46 339. Other areas for clarification include: tasks of LAGs (possibly streamline and avoid duplication), selection of LDSs, aid intensities, timing of LAGs selection (first payments). 340. Romania is requested to explain the scope of the actions concerning quality schemes included under LEADER. Cooperation DR-29: Cooperation and innovation in agriculture through EIP Operational Groups (OGs) 341. The dissemination of the Operational Groups’ plan and innovative results within the national and EU CAP networks should be added as an eligibility condition according to Article 127 of the SPR. Reference to the interactive innovation model in the eligibility conditions of the EIP OGs should also be added to meet the requirements of Article 127(3) of the SPR. 342. Romania should explain how the advisors will be integrated in AKIS (under eligible conditions or selection principles), for instance recommending or making them an obligatory partner in OGs. Please note that pursuant to Article 15(2) of the SPR, farm advisory services shall be integrated within the AKIS. 343. Having a researcher in the OG has been made an eligibility condition for EIP OGs in the Romanian Plan. It should note that not all OG project objectives require a researcher as partner. They must tackle farmers’ needs, co-create solutions and make use of complementary knowledge according to the aim of the project. EIP OGs may cover all 9 CAP specific objectives and for some, such as short supply chains or social innovation, other experts may be more adequate partners than researchers. 344. Romania is urged to start early with the preparation for the implementation of this intervention as there have been substantial delays with the implementation of this measure in the current programming period. Also, Romania should ensure that the budget allocated to the preparatory step is sufficient to enable a thorough preparation, and that adequate selection principles are applied for each step. 345. Romania is invited to explain why all 143 OGs’ projects are planned in 2026, and if it will be only one call in the whole planning period. Since neither funds nor groups have been planned for 2023-2025, a gap in the implementation will arise. To develop the grassroots ideas captured with innovation support, at least annual calls would be advisable. 346. The Commission strongly recommends and encourages Romania to implement EIP AGRI OG projects at interregional, transnational and cross-border level. Romanis should also indicate how concretely this will be organized and incentivized. 347. Romania is invited to include forestry, agroforestry, and relevant beneficiaries under the DR-29 EIP operation group or the cooperation intervention. 348. As the cooperation intervention is mainly aiming at addressing the needs for restructuring, consolidation and modernization of farms on market-oriented farms, Romania is invited to make a clear reference to climate and environment and the 47  contribution to turning farms more climate resilient or to better adapt to climate change. 349. Romania is invited to add a link to Result indicator R.28. 2.3.4.7 Knowledge Exchange and Advice (Article 78 of the SPR, section 5 of the Plan) 350. Result indicators R.2 and R.28 may be linked to both interventions. 351. Romania is invited to define the range of support at beneficiary level and fill in the related SFC section. 352. Romania is requested to re-examine the selection principles or their effectiveness to select the best trainers and advisors and to ensure an objective evaluation and thus equal treatment of beneficiaries. 353. An essential condition for the interventions for climate mitigation and adaptation to effectively contribute to SO4 are knowledge transfer and agricultural advice close to farmers (especially, accompanying the newly proposed eco-schemes targeting small and medium size farms) to raise awareness upon farming practices contributing to climate mitigation and/or adaptation, help familiarize them with new technologies. Romania is invited to plan a sufficient budget in order to achieve these new demands. DR-31: Knowledge transfer 354. Romania should explain how it will be ensured that the training programmes address the needs of the agricultural holdings and in particular those of the small agricultural holdings. 355. Romania is advised to focus on demonstrations on genuine farms working under real production conditions. 356. Romania is invited to clarify the implementation mechanism. 357. The budget of this scheme (EUR 6 million), necessary for 13 900 training, advice, and awareness actions, seems to be too low in order to allow an effective transfer of knowledge (comment also valid for intervention DR-32). 358. This intervention seems to be mixed. Romania should indicate the State aid instrument, by ticking an appropriate box (es). DR-32: Advising in agricultural affairs 359. Romania is requested to explain how exactly the implementation of this intervention will be organized and coordinated by the AKIS Coordination Body, taking into account all obligations listed in Article 15(2),(3) and (4) of the SPR, including the implementation modes and the obligatory training of advisors. 360. Romania should clarify if the advisors will provide innovation support for EIP OGs, since in Article 15(4)(e) and Article 114 of the SPR it is an obligation. Strong efforts concerning innovation support to capture and help develop grassroots innovative ideas seem to be missing. 48 3 FINANCIAL OVERVIEW TABLE 361. Romania is reminded that in accordance with Article 156 of the SPR, the sum of all payments made during a given financial year for a sector - irrespective for which programme and under which legal base those took place - cannot exceed the financial allocations referred to in Article 88 of the SPR for that given financial year for that sector. 362. As regards the type of interventions in certain sectors defined in Article 42 of the SPR, expenditure that will be paid in 2023 or in the subsequent financial years relating to measures implemented under Regulation (EU) No 1308/2013 for these same sectors shall NOT be entered in the Annual indicative financial allocations under Section 5 or in the Financial Overview table under Section 6 of the Plan. 363. The total amount for rural development interventions, plus the amount corresponding to 3.84% of technical assistance, are below the maximum rural development allocations by some EUR 76 000. 364. Romania has not selected a contribution rate for ANC interventions under Article 91(3)(a) of the SPR, although there are 3 ANC interventions in the Plan. If no specific rate is selected for Article 71 of the SPR, the specific rate of up to 65% cannot be used in the declarations of expenditure. 4 CAP PLAN GOVERNANCE, EXCLUDING CONTROLS AND PENALTIES 365. Romania is reminded to ensure a balanced representation of the relevant bodies in the monitoring committee, concerning small farmers, women, youth, and the interests of those in disadvantaged situations. 366. In section 7.1, Romania is invited to provide a description of how the Competent Authority will carry out its ongoing supervision of the accreditation of the Paying Agency and its compliance with the accreditation criteria. 367. Regarding sections 7.3 to 7.5, comments will be delivered by the Commission services in a separate communication. 5 ANNEXES 368. Annex I to the Plan on the ex-ante evaluation and the strategic environmental assessment is not provided. As this document is a main element for the approval process, Romania is invited to submit the missing Annex as soon as it becomes available. 369. The Commission invites Romania to present in Annex III to the Plan the result of the public consultations and to summarize the outcome of the comments and suggestions stemming from the consultations. 370. Romania should provide in Annex VI a complete overview indicating clearly per Transitional National Aid (TNA) intervention: 1) the original eligibility condition related to the reference period that was necessary to change; 2) the new corresponding eligibility condition; 3) the complementarity of the aid with other types of aids. 49