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tential to contributing to the Green Deal targets. The Commission makes the following observations in relation to them: 5  Anti-microbial resistance: The Commission recognises that relevant interventions proposed in the Plan can help to maintain and further decrease the relatively low level of antimicrobial consumption in the country but nevertheless Romania is requested to provide further explanations on the contribution of the Plan to this ambition and to set a national target, and is invited to consider adjustments at the level of the interventions that would support the reduction of the antimicrobials.  Pesticides, nutrient losses and high landscape feature: Romania is asked to clarify how these issues will be addressed as proposed interventions do not seem sufficient to adequately contribute to the common ambition. Romania is invited to reinforce planned interventions and develop further actions/interventions to sufficiently contribute to these targets.  Organic farming: The Commission notes that the support for organic farming in the Plan is foreseen for only 3.53% of the Utilised Agricultural Areas (UAA). In the light of the environmental benefits of organic farming and its potential for growth, the Commission invites Romania to increase its ambition and support for organic farming as a means of delivering additional environmental benefits while also securing a higher share of added value for farmers in the food supply chain.  Rural broadband: The Commission notes that the Plan appears to contain little or no information about instruments relevant to achieving 100% fast broadband access in rural areas by 2025. It requests a clear and full explanation of how Romania intends to reach the target (inside or outside the CAP). 6  Detailed observations 1 STRATEGIC ASSESSMENT 34. The intervention logic does not adequately describe how all the interventions contribute to the overall intervention logic (valid for all Strategic Objectives -SOs). 35. There is no justification of the financial allocation and how this will meet the targets set (valid for all SOs). 1.1 To foster a smart, competitive, resilient and diversified agricultural sector ensuring long term food security 1.1.1 Strategic assessment of Specific Objective 1 36. Romania should ensure that all income support instruments take into account differences in farm size, profitability, and development. In addition, Romania should explain why degressivity and capping of payments are not part of the strategy, even though in the SWOT analysis it is recognised as weaknesses that small and medium farms have lower income and that until now the direct payment support was distributed unevenly in Romania (0.27% of beneficiaries receiving 31% of direct payment in 2019). Romania is also considering as an opportunity the efficient targeting of income support, in order to develop and market orient small and medium farms; however, this is not realised through the mix of interventions. 37. The links among the SWOT analysis, the needs identified, and the intervention logic are not clear. The SWOT analysis clearly identifies as weaknesses the high percentage of small and medium farms in Romania, the fact that these have a lower income, and the inefficient targeting of direct area support until now. However, it is not clear how these weaknesses are addressed in the sections dedicated to the needs assessment and the intervention logic. Romania should also better explain the strategy for supporting small farms, including why the payment scheme for small farmers (Article 28 of the SPR) is not used. Small farms should not be excluded from any relevant interventions. 38. The Commission welcomes the degressivity of payments under ANC, although the ceilings chosen are not conducive to a significant orientation of support towards small and medium farms. 39. With 0.73%, the share of the farms with supported CAP risk management tools (indicator R.5) seems to be extremely low. Romania is invited to ensure that more beneficiaries are covered by the risk management interventions. 40. In the light of the Ukraine crisis, Romania is invited to consider planning of specific interventions or a targeted strategy for strengthening its food supply chains and agricultural systems in order to cope with various crisis situations, both caused by natural causes and man-made. 1.1.2 Strategic assessment of Specific Objective 2 41. The links between the SWOT analysis, the needs identified, and the intervention logic are not clear. Even if the SWOT analysis recognises as a weakness that small and medium farms make up the grand majority of farms in Romania (almost 2.5 7  million farms own up to two hectares each, other 660,000 farms own between 2-5 hectares) and that the market access for these farms is very difficult or in some regions not existent, the investment support under SO2 seems to be targeted towards big commercial undertakings (with the only exception being the intervention tailored for young and recent farmers). This is evident from the planned unit amounts close to the maximum aid ceilings per project supported (in some cases reaching EUR 2 million per project). In this way, most of the investment instruments under SO2 target a very limited number of beneficiaries (this comment is also valid for SO3). 42. The Commission is concerned that the overall ambition under this SO is very limited. For example, only 0.05% (some 1 700 farmers) of Romanian farms will receive CAP support for farm modernisation (result indicator R.9), whereas the share of farms benefitting from Coupled Income Support (CIS) for improving competitiveness, sustainability or quality (R.8) adds up only to 1.22% (41 800 farmers). Romania should increase its level of ambition and aim to target a substantially increased number of farmers. 43. The amount available for investments in agricultural holdings under the European Agricultural Fund for Rural Development (EAFRD) is low and therefore not conducive to meeting farmers’ needs and to enhancing their market orientation and competitiveness. In addition, the investment support seems to be limited only to selected sectors (orchards, vegetables, potatoes, hops, flowers, table grapes, animal breeders), without any clear justification. 44. In order to address efficiently difficulties and improve the competitiveness and sustainability of the sector and to avoid that the proposed CIS interventions lead to a deterioration of the environmental and climate situation, Romania is requested to clarify the interplay between CIS and other support decisions under the Plan and to improve, if relevant, the CIS interventions’ targeting (e.g. eligibility conditions for specific types of farming within a sector and CIS adapted to different local context). 1.1.3 Strategic assessment of Specific Objective 3 45. While the SWOT analysis highlights the need to increase the marketing of products through small supply chains, this does not seem to be covered by the intervention logic. 46. The whole intervention logic under SO3 seems to target big commercial units (with the exception of investment support for the setting-up of young farmers) and, in addition, seems to target a very low number of beneficiaries. For example, only around 72 beneficiaries will benefit from the EUR 253 million support for off-farm processing, due to the fact that the planned unit amounts are set around the maximum aid ceilings (in some cases reaching EUR 15 million). Romania is invited to reconsider the targeting under this SO as well as the very high maximum support per project. 47. Moreover, on-farm processing is excluded from support. Romania is invited to reconsider including on-farm processing as eligible activity. In addition, the need for strengthening big processing units is not coherent with the justification of support for CIS, where Romania identifies as a weakness the lack of raw materials for processing. 8 48. Therefore, the Commission has serious doubts that the overall objective of improving the farmers’ position in the value chain will be met through this intervention logic. Moreover, the situation of small and medium farms, which seem to be excluded from investment support, is also of great concern. 49. In addition, the share of farms participating in producer groups, producer organisations, local markets, short supply chain circuits and quality schemes supported by the CAP – Result indicator R.10, to which interventions under this SO are the main contributors – is very low (0.02%). Also the share of value of marketed production by producer organisations or producer groups with operational programmes in certain sectors – R.11 to which interventions under this SO are the main contributors – is very low (0.68%). 50. The information provided seems to be more an incomplete list of supported actions rather than an assessment of consistency between the different interventions (sectoral types of interventions, rural development, CIS). Romania is requested to fill the sections 3.5.6-3.5.10. For each sector, the general description should be completed with a more targeted assessment of the consistency and synergies between the various interventions. However, complementarity between interventions related to a sector should be assessed not only in a pure ‘technical’ sense (i.e. potential accumulation of support in case of interventions targeting the same sector), but in a broader, ‘strategic’ sense. Accordingly, Romania should explain how the combination of the relevant interventions work toward the intended objective and thus fulfil the need(s) identified for the sector concerned. 51. Romania plans sectoral interventions in fruits and vegetables (F&V), apiculture and wine sectors only (while support in wine and apiculture sectors are not channelled through Producer Organisations). However, in the SWOT analyses (under SO2 and SO3), Romania identifies weaknesses of “low level of association,” and “poor cooperation between farmers and other actors.” Considering this, Romania is invited to clarify why sectoral interventions in sectors other than F&V, apiculture and wine are not planned. Since sectoral interventions are channelled through Producer Organisations, budget for sectoral interventions would help encourage producers to cooperate and form Producer Organisations. Given also the need to improve the resilience of the food systems and reduce dependency of imports of strategic commodities, Romania is invited to explain why sectoral interventions in cereals and animal feed/protein crops sectors have not been considered. 52. Romania is invited to explain the difficult access of wine producers to the wine market, in particular as regards the intra-Union and extra-Union market considering that Romania has funded promotion action under the National Support Programme since 2009, which should have led to the development of market opportunities beyond national ones. 53. Romania should explain why the wine interventions are not contributing to SO3. 54. Taking into account the information resulting from the SWOT analysis, including the low number of Romanian products currently participating in European Geographical Indications (GIs) quality schemes, the Commission considers that increasing the uptake of GIs should be a clear objective/need to be addressed under the Plan. In this line, the objective of the “Cooperation” intervention could be better defined to clearly target an increased participation of the Romanian products in European GIs quality schemes, by encouraging the new participation of farmers 9  in EU quality schemes covering Protected Designated of Origin products (PDOs) and Protected Geographical Indications products (PGIs) and by supporting information and promotion activities implemented by groups of producers with regard to PDO and PGI products. 55. Cooperation intervention “Establishment of producer groups in the agricultural/orchards sector” aims at supporting the establishment and operation of producer groups in order to pool production for sale. Given the general low level of cooperation between producers in Romania, Romania is requested to explain why it does not plan support for the setting up of producer organisations with the aim to operate sectoral programmes. 1.1.4 Fair distribution and targeting of the support 56. Romania is invited to elaborate the corresponding overview that demonstrates that the redistributive needs have sufficiently been addressed. To justify the sufficiency of the strategy and the consistency of all income support tools, Romania is invited to provide a quantitative analysis showing the combined effects of all relevant income support tools on income per work unit by physical size (e.g. using Farm Accountancy Data Network (FADN). In particular, Romania is invited to provide a comprehensive justification for the maximum ha threshold for (CRISS). 1.2 To support and strengthen environmental protection, including biodiversity, and climatic action and to contribute to achieving the environmental and climate-related objectives of the Union including its commitments under the Paris Agreement 1.2.1 Strategic assessment of Specific Objective 4 57. The Commission considers that the proposed intervention mix will not contribute sufficiently to address the needs for this strategic objective. 58. All (but one) environmental needs (valid also for SO5 and SO6) are qualified as having an average or low priority. Romania is requested to justify this programming choice in light of the environmental needs. 59. Concerning the SWOT analysis, there are few mentions regarding renewable energy, energy efficiency, mitigation of soil degradation due to droughts and wind erosion, knowledge transfer and advisory to raise awareness of climate change and climate action, risk management for farmers associated with climate variability and extremes. Romania is invited to better address these issues. 60. Romania is requested to adequately address in the SWOT analysis the following: the low share of organic farming in the total agricultural area, the insufficient support and promotion for agricultural practices and investments aimed at reducing emissions, the need to invest in sustainable livestock and manure management, the overlap between peatland and wetland area with farmed and forested areas, the decrease of both permanent grasslands and forestland. In addition, the share of permanent grassland indicated in the SWOT analysis (64%) is very different from the one given under GAEC 1 (23%). Romania is requested to clarify this inconsistency. 10 61. In order to address efficiently difficulties and improve the competitiveness and sustainability of the sector and to avoid that the proposed CIS interventions lead to a deterioration of the environmental and climate situation (e.g. an increase in Green House Gas (GHG) emissions), Romania is requested to clarify the interplay between CIS and other support decisions under the Plan and to improve, if relevant, the CIS interventions’ targeting (e.g. eligibility conditions for specific types of farming within a sector and CIS adapted to different local context). 62. Elements related to renewable energy should be moved under SO4 while SO8 should concentrate on the bioeconomy as a whole. Romania should ensure consistency between the SWOT analyses carried out under SO4 and SO8, for example, on what concerns biomass availability (either a strength and/or an opportunity). 63. The contribution of the ANC intervention under this SO to enhancing carbon sequestration is not clear. Romania is requested to substantiate this planning choice. Similarly, the need on adapting agricultural practices in areas facing climatic risks refers to irrigation infrastructure, planning choice that is confirmed later in the Plan. This programming choice is not clear and Romania is requested to substantiate and/or revise (this comment also applies to SO5 and SO6). 64. Sustainable forest management appears as a strength. While the Commission acknowledges that Romania has a significant forested areas, those were not always managed in a sustainable way. There is an ongoing infringement procedure on illegal logging and logging which is not compatible with the Natura 2000 legislation. Romania is invited to reconsider this classification. In addition, given the increasing frequency of devastating climate events, Romania needs to step up its efforts regarding climate adaptation