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and mitigation of its forests. This does not appear to be sufficiently addressed under this specific objective. If forestry needs in Romania are covered through other programmes (such as the Recovery and Resilience Plan), this should be clearly explained. The issue of illegal logging is not addressed, while increasing infestations by pathogens is not sufficiently tackled in the interventions (valid also for SO5). 65. Under SO4, significant biomass potential is noted as a strength. It should be noted that any promotion of biomass combustion must be accompanied by sufficient safeguards to ensure that there are no negative impact on air quality (notably Particulate Matter emissions); support for biogas production must be given in a way to ensure no negative trade off in methane vs ammonia emissions. 1.2.2 Strategic assessment of Specific Objective 5 66. The criteria used for prioritising the needs refer to coverage, coherence with other policies/strategies, contribution to socio-economic development, contribution to environment and avoiding land abandonment. Those criteria lack clarity and seems to overlap to some extent, while not considering the severity/degree of a particular need. 67. Animal welfare interventions and investments in the animal breeding sector are interventions intended to be designed under this specific objective. Romania is requested to substantiate this choice. 11 68. The Plan needs to clarify the focus of - and the conditions for - the planned investments in irrigation. Romania is invited to consider complementing such investments meeting requirments of Article 74 of the SPR with other interventions such as natural water retention measures to address water quantity issues and climate change adaptation needs. 69. The assessment related to SO 5 should be improved with a view to integrating in a clearer way the regional ecological differences of Romania (including the differences between regions of more intensive and more extensive agriculture). This is particularly the case with regard to nutrient management. While the target for result indicator R.22 (sustainable nutrient management) is high, the Commission has doubts whether this is supported by the underlying interventions. The Commission also requests Romania to provide further details behind this target, given that nutrient surplus in Romania should be considered based on a differentiated analysis. 70. Romania accepted with the adoption of Directive (EU) 2016/2284 (the National Emissions Reduction Commitments Directive – the NEC Directive) a commitment to reduce ammonia emissions by 25% until 2030 compared to 2005. Even if the emissions of ammonia remain constant or signal a slight increase, Romania is at a high risk of non-compliance with Annex II to the NEC Directive. In this regard, the share of agricultural surface proposed to support ammonia emission reduction is low. In addition, it is unclear which intervention supports good practices to reduce ammonia emissions (the eco-schemes or the agri-environmental commitments). Investments are also proposed to better manage manure, but result indicator R.16 is missing. Romania is invited to provide more details about the reduction of ammonia emission and show more ambition. 71. Integrated Pest Management is not mentioned at all, and Romania is requested to clarify whether Integrated Production will be supported. 72. The Commission encourages Romania to explain the links with the Best Available Techniques (BAT) conclusions including BAT-associated emission level (BAT- AEL) notably in the context of reducing emissions of pollutants from installations (e.g. ammonia) (also applicable to SO4). 1.2.3 Strategic assessment of Specific Objective 6 73. Romania is invited to improve the SWOT analysis, including the status and priorities of habitats and species concerned by agricultural and forestry activities and consider including a sub-chapter on landscape features. In addition, the links between the needs identified and the interventions proposed should be clarified. There are only three needs identified. The title of the two first needs, referring respectively to sustainable and traditional farming, should be clarified. In addition, it should be explained why there are no needs clearly identified concerning the 1) Preservation of habitats and species 2) Agricultural genetic resources and 3) Landscapes. It is not consistent with the weaknesses and threats identified, in particular the risk of land abandonment and loss of genetic resources associated with local varieties and breeds. 74. The Commission notes with concern that no intervention on Natura 2000 is proposed to be designed. While the Commission is aware of the constrains related to the approval of management plans for Natura 2000, Romania is however invited 12  to consider introducing such intervention for cases where the management plans are more advanced. The Commission also doubts that ANC should be designed under SO6. 75. The number of forestry elements presented is limited. There is a need for better representation of forests and forestry in the SWOT due to the importance of forestry for biodiversity and ecosystem services and landscapes (e.g. threats to forest genetic resources are not mentioned). Romania is also invited to refer to the EU Forest Strategy. 1.2.4 Green architecture (Article 109(2) of the SPR) 76. The Commission considers that the green architecture of the Plan lacks clarity and consistency. In particular, the Commission considers that a better integration of the wide regional differences (amongst intensive and extensive agricultural regions) in the SWOT would be needed to improve the identification and targeting of needs as a basis for the intervention strategy and ensuring an increased contribution. 77. A number of GAECs should be reviewed with a view to ensuring that they achieve their objectives and increase their benefits, also as a baseline for interventions. In addition, for the eco-schemes, significant clarification is needed and Romania is asked to review them to ensure that the environmental and climate contribution of the practices included go beyond the baseline. 78. As regards green investments /non-productive investments, Romania does not foresee any separate intervention for productive and non-productive green investments as referred to in respectively Article 73(4) points (a)(i) and (c)(i) of the SPR (apart from one non-productive forestry intervention). However, green investments are included in other investment interventions. Romania is invited to design a separate intervention for green productive and/or non-productive investments to show the higher environmental ambition of these investments and to be able to link them to the environmental ring-fencing referred to in Article 93 of the SPR. 79. While the SWOT analysis identifies that there are still many challenges that need to be addressed in the coming period, including: the large number of small farms (with poor access to information, advisory and training), the low technological endowment and the dual structure of agricultural holdings, the impact of climate change on farmers’ productivity (droughts, erosion), section 3.1.3 of the Plan provides very general information on the specific contribution to an ambitious climate related-objective, referring more to the EU legal framework to comply with than to how exactly the interventions are designed to support climate mitigation and/or adaptation. In addition, the link between interventions, result indicators and specific climate objectives should be improved. 80. Romania is requested to include in the Plan a clear overview of the complementarity between the relevant baseline conditions, as referred to in Article 31(5) and Article 70(3) of the SPR, conditionality, and the different interventions addressing environment and climate-related objectives. A thorough analysis is needed of the complementarity and synergies between those instruments. 13 1.2.5 Greater overall contribution (Article 105 of the SPR) 81. The Commission has concerns about the potential of the Plan to deliver a greater overall contribution to the environmental objectives of the CAP. Due to important missing information, it is also difficult to assess the greater overall contribution of the Plan for biodiversity and landscapes (including the value added of some eco- schemes addressing those). 82. Regarding conditionality, there is a lack of clarity and need for adjustment of certain GAECs. Therefore, the Commission has some difficulties to conclude that baselines are set at a sufficient level. Moreover, it is not clear that management commitments will entail significant changes in the field. In this context, it is not clear how the “traditional farming practices” will contribute to increasing the environmental contribution. Romania is requested to provide the explanation referred to in Article 105(2) of the SPR and ensure compliance with Article 105(1) of the SPR. 83. While Romania mentions that a target for organic farming is fixed in its National Plan for the Development of Ecological Production, the figure is not included. Support is foreseen for only 3.53 % of Utilised Agricultural Area (UAA). The Commission invites Romania to consider increasing the efforts on organic farming in terms of UAA covered. 84. Romania is asked to make a clear, well justified, quantitative comparison of the environment and climate ambitions of the Plan with that achieved under the 2014- 2020 Rural Development Programme (RDP). Hay meadows, butterflies and birds specific commitments are excluded. The high biodiversity landscape features and pollinators are also missing from the SWOT analysis. The commitments are linked with mandatory grazing, indicating an approach towards production and less towards the environment. 85. The level of ambition regarding the objective concerning climate change is addressed in a very diffuse way within the Plan, being spread along diverse interventions, without a particular/targeted focus on addressing the mitigation or adaptation of significant climate effects (i.e. severe droughts). Even if included and prioritized, there is a low financial allocation dedicated to climate-related objectives for making the intervention effective. Romania should better explain in the Plan how the interventions will contribute to a greater overall ambition regarding climate-related objectives. 1.2.6 Contribution and consistency with the needs stemming from and long-term national targets set out in or deriving from the legislative instruments referred to in Annex XIII (Article 109(2) of the SPR) 86. The contribution to and consistency with the long-term national targets set out in or deriving from the legislative instruments referred to in the above-mentioned Annex XIII is not reflected in the Plan. It is not clear if the planned interventions will be sufficient to bring about the scale of change that is needed. The provided targets do not appear to be coherent with the needs set out in the Environmental Planning Tools (EPTs) and national strategies. 87. Romania is requested to explain better the concrete needs stemming from the said actions and plans. It should better demonstrate the Plan’s contribution to the 14  fulfilment of the commitments and targets emanating from those acts making more use of quantitative information. 88. Romania refers to other legislative instruments relevant to renewable energy (including Directive (EU) 2018/2001 (the Renewable Energy Directive (RED II) and Directive 2012/27/EU (Energy Efficiency Directive (EED)), but the link with the Plan’s needs and interventions is not clear. 89. Romania is invited to ensure consistency between its Plan and national goals, policies and measures outlined in the National Energy and Climate Plan (NECP) as well as the National Adaptation Plan (NAP) and the Long-Term Strategy (LTS). Romania is invited to better explain and demonstrate how the needs identified in the NECP, NAP and LTS are addressed by the Plan. 90. Romania is invited to provide further explanations on the contribution of its Plan to climate change mitigation and to better demonstrate that the needs for climate adaptation will be sufficiently addressed. 1.3 To strengthen the socio-economic fabric of rural areas 1.3.1 Strategic assessment of Specific Objective 7 91. Romania is requested to:  Reconsider the SWOT summary and needs identification related to knowledge transfer to young farmers;  Provide details on the situation of young female farmers in the SWOT summary;  Explain how the needs related to access to capital, female young farmers and mountains areas are addressed in the intervention strategy;  Explain the targeting of the installation aid towards specific sectors, its link to the needs identified and its contribution to SO7;  Verify the calculation of Result indicator R.36 and include R.37 to which R.36 contributes. 1.3.2 Strategic assessment of Specific Objective 8 92. Aspects related to the socio-economic fabric of rural areas (beyond the agri-food and forestry sector) do not seem to be sufficiently addressed. Romania is invited to better explain how the needs of rural areas will be addressed. 93. LEADER is expected to cover a whole array of rural needs, including rural business start-ups, agritourism, and short supply chains, and contribute to the provision of services. The budget of LEADER, even though increased to 8% of the EAFRD funds, is not sufficient to address all these needs of rural areas, especially since LEADER’s eligibility is much broader than SO8. Romania is invited to consider targeting the scope of LEADER operations in line with its added value and the needs, in particular those in SO8. 15 94. Many needs related to social inclusion (including the situation of possible Ukrainian refugees), rural poverty and gender equality are not addressed. The same holds true for collective needs such as transport, local social activities, etc. Capacity building for creating stocks of social capital is also missing. 95. The intervention logic should address access to jobs, the unemployment rate in the rural areas and dedicated services for the self-employed in agriculture and small farmers (the most numerous and vulnerable group in the rural communities). 96. Romania is invited to confirm that a target for Result indicator R.42 will be established once LEADER strategies are known and revise R.37 after the selection of the strategies. 97. The Commission encourages Romania to promote gender equality and improve the participation of women in rural businesses, in line with the specific objective of Article 6(1)(h) of the SPR, by justified and proportionate measures. Furthermore, Romania is reminded to ensure a balanced representation of the relevant bodies in the monitoring committee concerning women, youth and the interests of people in disadvantaged situations. 98. Romania has no Bioeconomy Strategy. It is therefore invited to consider developing such a Strategy in association with the plan, to reinforce the synergies between both policies and to scale up the deployment of the circular and sustainable bio-economy 1.3.3 Strategic assessment of Specific Objective 9 99. Given that the SWOT analysis does not identify animal welfare as a weakness, the need to implement dedicated interventions and the allocation of a significant budget for animal welfare of EUR 1.5 billion does not seem justified. 100. The Plan includes welfare measures with a wide scope, including support for a substantial increase of space for sows and fattening pigs. Nevertheless, Romania is requested to further address the tail docking practises in pigs and to encourage the keeping of animals in non-confined housing system for laying hens calves and sows. 101. The Commission notes that the Plan includes interventions on animal welfare both under the eco-schemes (for cattle) and rural development (for pigs and poultry). However, increasing space by 10% for cattle, pigs or poultry would not significantly improve the welfare of animals. In addition, the commitments for pigs are not ambitious enough (space, dust, litter) to keep pigs with entire tails, especially if these commitments can be taken in isolation. 102. The Commission notes that Romania intends to achieve further reductions of antimicrobials through interventions that focus on enhanced animal welfare standards. It recognises that these interventions could help maintain the current