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ctice regarding crop rotation is recognized as bringing environmental benefits. However, this practice forms part of the baseline in GAEC 7. If there is a particular need to ensure a crop rotation also on small holdings (below 10 hectares of arable land), these should not be subject to an exemption from GAEC 7. 27  Romania is requested to review the eco-scheme with a view to increase the expected benefits for environment, climate and animal welfare. In this context, Romania should take into account that altering the quantities of imported feedstock are not as such valid objectives justifying an eco-scheme. Romania is also requested to explain the environmental benefits and justification for targeting the eco-scheme to holdings of maximum 10 hectares of arable land. 174. Romania should clarify how this eco-scheme articulates with the CIS for certain protein crops and how it is ensured that no double funding takes place. 175. The link to R.22 and R.31 does not appear justified (also valid for PD-06). PD-06: Grassing the interval between rows in fruit, vineyards, nurseries and hamsters 176. The paid commitment to be undertaken by farmers (to grass or to leave not ploughed one in two interval rows) in orchards and vineyards is standard practice in Romania. Farmers adopt this practice so that orchards and vineyard are accessible (for works, harvest, etc.) during bad weather. Romania is therefore advised to ensure that commitments under this eco-scheme go beyond the existing, standard farmers’ practice. 177. The section describing the link between GAEC, SMR and national standards contains a description of the benefits of the eco-scheme. Romania is invited to clearly explain the link above. In particular, Romania should make sure that the practices go beyond the baseline, in particular taking into account the observations with regard to GAEC 6, which shall avoid bare soil and apply also on areas of permanent crops, as well as GAEC 5, which may also be relevant for the baseline of this eco-scheme. 178. Romania may decide to add a link to result indicator R.19. PD-07: Improving the welfare of dairy cows 179. Romania should specify how the commitments under this scheme go beyond the standard practice, as it appears that most of them add very little (and in some cases nothing) to the standard level performed by a farmer. Romania is invited to detail how the commitments go beyond standard welfare practices in the section devoted to baselines. 180. Romania is requested to explain how the commitments limit the use of anti- microbials and, if justified, link the intervention to Result indicator R.43 (valid also for PD-08). 2.3.2.5 CIS (Article 32-35 SPR, section 5 of the Plan) 181. Romania should consider to include also Result indicators R.4, R.6 and R.7 in its CIS interventions. Most interventions are connected to SO2, which is related to competitiveness, but improving competitiveness is often not indicated as aim. Please ensure consistency between the declared aim and the linked SOs. 182. The intervention on seed potatoes should be grouped under “seeds” not under “potatoes” as there is no intervention for potatoes as such. Also, the interventions for vegetables in green houses and for vegetables grown in the field both belong to 28  the sector “fruit and vegetables”, point r) in Article 33 of the SPR. Please complete the sector name in both interventions. 183. The justification of economic difficulty should be primarily based upon a low/negative profitability and/or a declining number of hectares/animals in recent years backed up by relevant data. The need for a reinforced justification for the difficulty is particularly pronounced for sugar beet, goats and silkworms, which do not address profitability or production levels at all or mention a recent increase in production. In addition, many descriptions of difficulty contain facts better suited to support the importance of the sector in question. Please streamline these texts and move facts supporting importance to the section on importance. 184. The section on importance could often benefit from streamlining, for example the intervention on forage plant seeds. In addition, some of the claims made in this section would need to be better argued, e.g., in the intervention on vegetables grown in the field or fruits. There it is argued that the intervention ensures traceability, improves marketing and that it is very important for the Romanian agricultural sector because it covers 1.67% of arable land. 185. The interventions usually specify the aim(s) as improvement of quality and sustainability but not competitiveness, which, however, is implied by the difficulties mentioned. CIS interventions ideally would ameliorate the respective sector’s weaknesses. However, most interventions provide only additional income support for the duration of the plan with no apparent measures taken for long term improvement. Romania is requested to explain why the support for many interventions, e.g., hemp and protein crops rises during the period. Furthermore, it is sometimes not clear how the intervention will achieve its stated aims e.g., for vegetables in green houses the link to research is not clear and for the intervention on dairy cows it is not clear how the quality of products will be improved. The legal framework has evolved, and this should be reflected in the intervention strategy, aim and, if needed other elements (e.g. targeting, eligibility criteria, justification). Please note that CIS interventions do not aim at self-sufficiency and balancing trade as the internal market requires not discriminating against other Member States. 186. Eligibility conditions based on EU legislation such as active farmer, minimum requirements, and compliance of supported area with the definition of eligible hectare, compliance of supported animals with identification and registration requirements do not need to be spelled out. However, it would be necessary to see a justification for any minimum (0.1/0.3 ha parcel of land) or maximum criteria introduced. Also Romania could consider adding some eligibility criteria in line with the aim to interventions that would address the difficulty e.g., introducing a top up for farmers that sell via producer organisations into the intervention on fruits. In addition, the SWOT summary refers to issues such as the potential of organic farming, or water problems that could be reflected in the eligibility criteria. Romania is invited to clarify who is eligible for the intervention on silkworms as some parts of the description suggest schools could use it. 187. In some interventions, the section on Directive 2000/60/EC (the Water Framework Directive - WFD) still needs to be filled in (for example as regards silkworms, beef meat and sheep goat). Romania is invited to clearly indicate that the beneficiaries must comply with the relevant provisions of the programme of measures 29  established for each river basin district in the implementation of the WFD. Please also clarify the environmental benefits claimed for specific interventions. In addition, please clarify how interventions that involve irrigation or plants with high water needs comply with, and/or complement, the WFD. 188. The Commission should inform Member States about reduction coefficients, if any, related to the EU WTO schedule on oilseed (Blair House) in its observations. However, the Commission has not received all the final information needed yet. Once all Member States have submitted this final information, the Commission will inform Member States, if such a coefficient is needed. 189. The explanation of the planned unit amount and its variation should be reinforced in light of the support need. In addition, please explain why the planned unit amount is fluctuating or steadily rising for many interventions (e.g. beef meat, hemp, soy, sheep and goat). 190. Some interventions are grouped in the WTO blue box, which implies a fixed number of hectares or heads (see Article 6.5 of the WTO Agreement on Agriculture). However, for some interventions (e.g., dairy buffaloes, beef, sheep) in the blue box a rise in heads is planned. This is not possible. Romania is invited to consider moving these interventions to the amber box instead or to align with the before mentioned Article 6.5. 191. In section 5.1., less than 2% of the total Direct Payments allocation has been planned for protein crops (interventions PD-9 and PD-11), in which case it is not possible to allocate a total of 15% of Direct Payments for CIS. Romania should consider if more interventions belong to the category of protein crops and are financed by the protein top up e.g. the intervention for Lucerne/alfalfa. 192. Regarding protein crops under the intervention PD-11 for vegetables for industrialisation, Romania is invited to clarify if the peas and beans are harvested at immature or mature stage and how the financing of this intervention through the protein crop top up is in accordance with Article 96(3) of the SPR. If the intervention does not specifically support protein crop production in order to reduce the Union’s deficit in this regard, Romania should consider to link this intervention to the fruit and vegetables sector without the access to the top-up. 2.3.3 For sectoral interventions 2.3.3.1 Fruit and vegetables 193. For sectors where types of interventions are implemented through operational programmes and managed by producer organisations, it is required to describe separately each type of intervention listed in Article 47 of the SPR. Romania is therefore invited to describe in detail each type of intervention in compliance with the general requirements for an intervention (Article 111 of the SPR). 194. There is no need to copy/paste the same information for each intervention description, it needs to be specific and related to the purpose/objective of the intervention. 30 195. Romania is invited to verify and properly describe in the Plan how all additional requirements set out in Regulation (EU) 2022/126, for instance, the percentage for minimum water savings (Article 11(4)(a)), are to be addressed. 196. On chapter WTO, although fruit and vegetable type of intervention is WTO compliant due to its nature, it is not sufficient to indicate the compliance with the relevant paragraph 12 of Annex 2 to the WTO Agreement on Agriculture. Romania is invited to add a short paragraph explaining how this compliance is ensured. 197. The Commission would like to enquire whether Romania intends to make use of National financial assistance. If yes, this needs to be described in Annex V. In addition, the Commission would like to remind of reporting requirements (see Article 52(3) of the SPR). 198. The intervention addresses environmental and climate change adaptation measures, but the intended actions are not detailed. Romania is invited to further detail the eligible actions besides referring that are those as included in the applicable regulation. 2.3.3.2 Apiculture 199. The interventions and supported actions described are very much a continuation of the current apiculture programme. The Commission would have expected a more ambitious and renewed programme of interventions, which is, better able to address the sectoral and specific objectives in response to new and emerging challenges and needs as well as the broader scope of interventions under SPR. 200. Section 3.5.2 should include an analysis of the sector, which leads to the needs identified, and justification of the chosen interventions and how these address the specific and sectoral objectives. The section should only include and list the chosen interventions without going into the details of the specific eligible expenditure. 201. The description of a reliable method for determining the number of beehives in accordance with the provisions of Article 37 of Regulation (EU) 2022/126 is missing and needs to be included. 202. The indicative financial allocation for 2023 should take into account any planned expenditure for implementation of measures under the National Apiculture Programme 2020-2022 during the extension period from 1 August to 31 December 2022. 203. For apiculture interventions, only Result indicator R.35 applies and only interventions under the type of interventions described in Article 55(1)(b) of the SPR should contribute to this indicator as per Article 111 of the SPR. References to other result indicators in the interventions should be removed. 204. Romania is invited to describe how Result indicator R.35 was calculated and justify the somewhat modest projection of 42.4%, considering that over 90% of the budget is spent on interventions under type of intervention in Article 55(1)(b) of the SPR. 205. Whilst the name of the intervention should reflect the supported line of actions, it does not need to include the list of supported actions. 31 206. The description of territorial scope should be concise with no further information on beneficiaries or aims of the measure, which belong in the description. Details on application procedure belong to national legislation rather than the Plan. 207. The description of the intervention in section 5 needs to be revised by providing the required information under each section in a clear and structured way and only that information which is relevant to the intervention, avoiding repetition and unnecessary information. Description should outline how the specific intervention addresses the specific and sectoral objectives and identified needs, followed by a clear description of the supported actions, eligible expenditure (providing at least some examples of eligible costs), well defined beneficiaries and eligibility requirements. 208. Section 6 could be more concise with the details on eligible expenditure included in section 5. 209. The beneficiaries for most interventions (“…natural persons or legal persons, authorised natural persons, individual enterprises, and family businesses set up in accordance with Government Emergency order No 44/2008….”) should be better defined and qualified. 210. The 14 interventions need to be streamlined into fewer interventions under the relevant types of interventions so as to avoid unnecessary repetition of information, while providing more comprehensive information on the supported actions as indicated in the point above. Eligible actions need to be clearly described in the Plan and not through a reference to Article 55(1) of the SPR. 211. Advice and organisation of training courses under IS-A-09, IS-A-11 can be described in one intervention under Article 55(1)(a) of the SPR. Promotion of beekeeping and apiculture products in IS-A-10 belong under type of intervention under Article 55(1)(f) of the SPR, equipment for processing waxes and honey packaging belong under Investments (Article 55(1)(b)) together with the other investment actions from IS-A-14 to IS-A-21. These interventions, which fall under type of intervention of Article 55(1)(b) of the SPR, can be grouped under one or more interventions in line with said Article. Analysis of honey under IS-A-22 belong to Article 55(1)(c) rather than under Article 55(1)(g) of the SPR. Interventions/actions should be supported under the relevant type of intervention outlined in Article 55(1) of the SPR. 212. Reference to apiculture year and eligibility of costs incurred during this period are up to Romania to determine. However, contrary to the current apiculture programmes, the provisions of Regulation (EU) 2015/1368 will no longer apply to apiculture interventions under the Plan, including the definition and application of apiculture year and the fixed payment period (see Ares(2022)900036 of 08/02/2022 – Explanatory Note on Commission Delegated Regulation (EU) 2022/126 of 7 December 2021, Article 39). 213. The description of the planned unit amount and outputs should explain and justify how these were determined in line with the information provided in Sections 5 and 6. An effort should be made to determine planned unit amounts and outputs for the different actions/interventions considered within a type of intervention. 32 214. The explanation of WTO compliance needs to be revised in consistency with the chosen paragraph of Annex 2 to the SPR. Restocking of beehives and rationalizing transhumance do not normally fall under paragraph 2 of Annex 2 to the WTO Agreement on Agriculture (See Annex 2 to the SPR). These should be listed either as “amber” or depending on the objectives pursued through this intervention they could also qualify as “Green box”. However, this needs to be explained. 215. The eligible expenditure should comply with the provisions of Article 22 and Annex II, part 1 of the Regulation (EU) 2022