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relatively low level of antimicrobial use. However, the Commission notes that the Plan does not assess sufficiently the impact of these interventions on the use of antimicrobials because it does not include a target value for Result indicator R.43. In addition, Romania has not clarified how and if measures outside the CAP are going to contribute to limiting the use of antimicrobials, in particular that of 16  fluoroquinolones. Therefore, the Commission invites Romania to modify the Plan in accordance with these observations. 103. The action to reduce density includes laying hens in cages and the Plan does not include a measure to promote the phasing out confined housing systems for laying hens. Therefore, the Commission invites Romania to extend the animal welfare intervention to promote the keeping of laying hens, sows and calves in non- confined housing systems. 104. Regarding biosecurity, and as mentioned in the key issues, the Commission notes that the Plan does not include targeted interventions on biosecurity in pig farms in the framework of ASF prevention, control and eradication in Romania. However, the SWOT analysis points out that pig farmers have been severely affected by the disease since 2017. Therefore, the Commission invites Romania to amend the Plan to include specific interventions and detailed actions to increase biosecurity in the entire pig sector, in particular in small commercial farms. 105. While the plan identifies a need to raise awareness and encourage the consumption of healthy foods, this is only partially addressed in the interventions proposed. The Commission therefore invites Romania to better explain how the shift towards healthy, more plant-based and sustainable diets will be achieved. 106. While the Commission notes that food waste is partially addressed in the Plan, it invites Romania to explain how this issue is addressed outside the CAP (national policy aimed at combating food waste in other sectors) and their relation/coordination with provisions of the Plan. 1.4 Modernising the sector by fostering and sharing of knowledge, innovation and digitalisation in agriculture and rural areas, and encouraging their uptake by farmers, through improved access to research, innovation knowledge exchange and training 107. Despite considerable needs in the area of knowledge transfer (training, advice), the related budget has been drastically reduced compared to the previous programming period. The lack of budget and of other interventions to interlink AKIS actors may render the achievement of the set objectives difficult. Romania is invited to explain how the identified needs related to AKIS will be tackled. 108. The Commission would like to raise awareness on the importance of a coordinated strategic AKIS approach in relation to the interventions, their interlinkages, their complementarity and the integration of as many as possible AKIS actors in the AKIS scope. Romania is invited to reflect on further AKIS interventions besides the digital tool. 109. AKIS and the European Innovation Partnership (EIP) operational groups are not aiming at validation and dissemination of research results. Their aim is much broader: They should help interaction, knowledge sharing and co-creation of opportunities and solutions, whether these are linked to research results or not. 110. Romania is invited to revise the SWOT for this objective and examine whether forestry and foresters could be represented in various areas of this horizontal objective, e.g. cooperation, knowledge transfer or advice. 17 111. Romania is invited to strengthen the SWOT analysis and the needs assessment for digitalisation in agriculture and rural areas and to use it to further tailor the digitalisation strategy (which does not outline a strategic approach to support digitalisation in agriculture and rural areas in Romania). 112. As Romania intends to address the need for support to investments in digital technologies through CAP interventions, the Commission invites Romania to make use of Result indicator R.3 to well reflect the intervention logic. 113. The Commission welcomes that Romania considers to achieve synergies between the CAP and the implementation of Digital Innovation Hubs. Romania is encouraged to further explore opportunities to achieve synergies with other EU and national policy instruments to boost the digital transformation. 114. Romania’s digital strategy for agriculture and rural areas does not identify or exclude possible risks of digital divides between regions or types of farms or population groups, nor are interventions to mitigate or avoid digital divides sufficiently described. 115. Despite the identified need regarding internet infrastructure in remote areas, the Plan lacks information on the broadband strategy to tackle this need and to contribute to the EU 2025 connectivity objective. Romania is invited to: 1) Provide further details on the broadband intervention strategy for rural areas, in order to ensure that the EU 2025 connectivity target of 100% of broadband coverage with very high-capacity broadband networks (at least 100 Mbps with the possibility to expand to gigabit speeds) will be met; 2) Provide information on the quality of rural 4G mobile coverage, and explain how Romania will reach the 5G target in all (populated) areas by 2030 using national or EU funds. 1.5 Simplification for final beneficiaries 116. Romania is requested to provide further information on data sharing, as referred to in Articles 67(3), (5) and (6) of Regulation (EU) 2021/2116. Romania is furthermore invited to describe if new technologies are intended for use of non- IACS controls as well as to provide information on Area Monitoring (AMS) being used or not for cases of force majeure referred to in Article 3 of the same Regulation. 1.6 Target plan 117. Romania is invited to revise:  The values of some result indicators, which seem very low: R.5, R.8 and R.9 (very low value of 0.05% and supported wine producers should also be added), R.10, R.11, R.12, R.14, R.17, R.20, R.21, R.23, R.24, R.25, R.29, R.30, R.31 and R.36 (it seems that the beneficiaries of intervention PD-3 are not counted).  Other result indicator values, which seems unreasonably high: R.31, R.35, R.44 and R.22. 118. Romania is invited to set targets for the following missing result indicators: R.2 (link to at least intervention DR-32), R.3 (link to at least intervention DR-31), R.6 (link it with the intervention PD-2), R.13, R.15 (link with intervention DR-18), 18  R.16 (link with intervention DR-16), R.17, R.20, R.23, R.26 (link with intervention IS-V-29), R.28 (link with interventions DR-29 and DR-31), , R.32, R.33 (link at least to intervention DR-01), R.34, R.37 (link with interventions PD-3 and DR-25), R.40, R.42, R.43 (link to interventions PD-07, PD-08, and DR-06). 2 OPERATIONAL ASSESSMENT 2.1 Minimum ring-fencing 119. Based on the data provided in section 5 of the Plan, a higher amount than the minimum set out in Annex XII to the SPR is reserved for young farmers. For each of the two types of intervention contributing to this ring-fencing, the amounts that are to be considered as necessary to meet the minimum ring-fencing requirements should be clearly indicated in the overview table of the financial plan (section 6.1). This information shall serve as a basis to establish the financial ceilings referred to in Article 95(4) and (5) of the SPR. 120. Romania is requested to increase the allocations for IS-V-23: Restructuring and conversion of vineyards, IS-V-24: Investments in tangible and intangible assets and IS-V-29: Investments in tangible and intangible assets to increase the sustainability of wine production or to plan additional types of interventions contributing to environmental objectives in order to achieve the compulsory environmental contribution of 5% of expenditure as required by Article 60(4) of the SPR. 121. Romania is invited to clarify the contribution of some interventions to the minimum ring-fencing (in particular on investments) as it is required by Article 93 of the SPR. 2.2 Definitions and minimum requirements 122. The following items require clarification and completion:  Section 4.1.1.1 – to confirm the use the same definition of production as set under Article 4(1)(c)(i) of Regulation (EU) No 1307/2013 or to further clarify the definition under Article 4(2)(a) of the SPR. In fact, the latter definition of production lays down the necessary common elements to be included in a more developed definition established at national level.  Section 4.1.1.2.2 – to provide in this section, criteria on the maintenance of all permanent crops (not only vineyards and orchards) which should include the criteria not only for the land, but also for the crop itself.  Section 4.1.1.2.3 – to provide only information on the maintenance of permanent grassland in a good state. In this respect, minimum livestock density, if retained, should be moved to section 4.1.1.1 as a further definition of production as stipulated in Article 4(2)(a) of the SPR (see comment on section 4.1.1.1). Also, for all areas Romania should provide a non-productive alternative besides grazing.  Section 4.1.2.1 – to provide information on the elements of agroforestry based e.g. on type of trees, their size, number, distribution in relation to pedo-climatic conditions or management practices (whether or not differentiated per type of agricultural area). 19  Section 4.1.2.2.1 – to place the information included under the section under appropriate parts of the Plan (it seemingly refers to agroforestry systems, eligible hectare, GAEC and agricultural areas outside of arable land definition).  Section 4.1.2.3.2 – to set the minimum planting density in relation to the included short rotation coppice species. Pending this information, the assessment by the Commission cannot be complete.  Section 4.1.2.4.1 – to include only the definition of grasses and other herbaceous forage. Other criteria should be put under appropriate parts of the Plan. In particular, the minimum size of the parcel, depending on its intended scope, should be put under BISS or IACS part of the plan, while the maximum number of trees – could be placed e.g. under the ‘eligible hectare’ part on ‘other landscape features not protected under GAEC’ (section 4.1.3.5) or under agroforestry part (section 4.1.2.1).  Section 4.1.2.4.4. – to provide a description of the criteria ‘reseeding with different types of grasses’ (not just an objective).  Section 4.1.3.1 – to clarify whether it is impossible for a farmer to perform an agricultural activity on the listed areas not primarily used for agricultural purposes. To note, in line with the EU jurisprudence (case C-61/09 (Landkreis Bad Dürkheim) as well as the cases C-422/13 (Wree) and C-684/13 (Demmer)), farmers should be provided a possibility to prove that they still did an agricultural activity.  Section 4.1.3.2 – to explain how the actual and lawful use of the land will be verified and to confirm that any legal possession of the land is accepted.  Section 4.1.3.3 – to clarify the duration period during which an area has to comply with the definition of ‘eligible hectare’.  Section 4.1.4.1 – to explain how the inclusion in the ONRC register proves that the farmer has at least minimum level of agricultural activity, and that farmers who do not produce are not penalized.  Section 4.1.4.2 – to place, if retained, the ‘negative list’ of areas predominantly used for non-agricultural activity under part 4.1.3.1 and to provide a farmer a possibility to prove that the agricultural activity was still done on the area in question (see comment under section 4.1.3.1). Moreover, inclusion in the list of some areas (e.g. areas on which agricultural activity is not practiced or fallow land after temporary grassland) does not seem justified. In fact, it seems that Romania does not actually use the option to implement a ‘negative list’ of activities as a complementary tool to identify non-active farmers.  Section 4.1.4.3 – to provide quantitative, e.g. the number of excluded farms, and qualitative justification for the EURO 5 000 threshold set.  Sections 4.1.5.2 and 4.1.5.3 related to young farmers - to specify the meaning of “majority” shareholder and “adequate” training/skills. 20   Section 4.1.7 – to review the threshold(s) set and its justification by taking into account the following: i. The contradiction between the area threshold indicated in section 4.1.7.2 (which is 1 ha) and the threshold indicated in section 4.1.7.1 (which is 0.03 ha); ii. Minimum size of the parcel should be defined under respective intervention or IACS part of the Plan, depending on its applicability; iii. Because Romania defined a hectare threshold, the monetary threshold only applies for those farmers, who do not meet the hectare threshold, but are entitled to receive animal-related income support; iv. On the basis of qualitative and quantitative information, to provide a justification as to how the threshold(s) set ensure(s) the reduction of administrative burden and contribute to the objective of supporting ‘viable farm income’.  Section 4.1.8 – to review this section containing definitions, which are already set at the EU level. To clarify, those should not be repeated as such in the Plan to avoid any legal uncertainty. Also, the rationale behind and the applicability of some of the definitions is not clear. 2.2.1 Elements Related to Direct Payments 123. Romania is invited to provide further information/clarifications on the implementing arrangements for the option to condition up to 3 % of direct payments to a contribution to a risk management tool. Romania is also invited to clarify the link with rural development risk management interventions. 2.2.2 CAP Network 124. In section 4.4 of the Plan, more information is needed on activities of the CAP Network as related to involvement of new participants (e.g. Pillar 1), monitoring and evaluation activities, work with EIP and LEADER/other territorial initiatives and contribution to the EU CAP network, as well as on the activities of the network at the regional level. 125. In line with Article 15 and 114(a)(ii) of the SPR, we invite Romania to include in the Plan a description of how advisors, researchers and the national CAP network will cooperate closer together to provide improved, comprehensive and up-to-date advice of high quality and a multitude of knowledge flows between all AKIS actors, and which specific CAP network actions will contribute to the former. 126. Romania is invited to consider actions creating synergies between the Plan and Horizon Europe actions with specific attention to EIP Operational Groups linkages to Horizon Thematic Networks and Multi-actor projects. 2.2.3 Coordination EU Funds 127. The description in Section 4.5 on the coordination, demarcation and complementarities is insufficient with a view to providing the overview required by 21  Article 110(d)(v) of the SPR. Romania is invited to provide a comprehensive description of how EU funds and initiatives active in rural areas work together with and concretely contribute to the Plan, in addressing certain identified needs, especially those related to digitalization in rural areas, green infrastructure and water resources, waste management, health and education, ensuring a proper monitoring and reporting system. These funds and initiatives include, in particular, the European Regional Development Fund (ERDF), the European Social Fund Plus (ESF+), the Recovery and Resilience Facility (RRF), the Digital Europe Programme (DEP), the Connecting Europe Facility (CEF2 Digital) as well as the instruments for environment and climate action, the Programme for the Environment and Climate Action (LIFE) and Horizon Europe as well as the Partnership on Sustainable food systems for people, planet and climate. 128. Romania is invited to describe how the Plan will support the implementation of Horizon Europe Missions, in particular the Missions “A soil deal for Europe “, “Adaptation to Climate Change” and “Restore our Ocean and Waters by 2030”. 129. Further detail is also needed on Strategic Objective level on how the Plan funding is coordinated with the following measures in the Recovery and Resilience Plan (RRP): 1) Afforestation and reforestation national campaign; 2) Interventions to improve the quality of life in rural areas and access to acc