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dscapes, while contributing significantly to the objectives pursued by the Priority Action Framework (PAF). Thus, compensatory payments granted to users of agricultural and forestry land are also addressed to Natura 2000 areas, environmental and climate interventions making a significant contribution to the maintenance of wildlife habitats and species in those areas as a result of the implementation of the commitments proposed by the NSP. The extension of eligible HNV areas in relation to the corresponding commitments of the 2014-2020 NRDP and the application of the conditions laid down by the intervention dedicated to high nature value grassland (e.g. reduction of the use of organic fertilizers, prohibition of the use of chemical inputs, regulation of livestock loads and periods where agricultural activities are not permitted) ensure that HNV areas are maintained at the same time as the conditions necessary to achieve the objectives related to habitat conservation and protection of wild species (including birds and butterflies), taking into account the degree of overlap with ICS/APS, respectively 68% of SPA area and 67% of SCI. At the same time, Romania considers that support for areas with natural constraints ensures the continued preservation of agricultural habitats by avoiding the abandonment of agricultural activities in areas with agricultural potential affected by unfavourable natural conditions, contributing to the achievement of the specific objective. At the same time, avoiding the abandonment of agricultural activities also contributes to the conservation of environmental factors (biodiversity, soil, water, air) in the targeted areas by addressing this type of support on a large scale. As regards the next fine-tuning exercise of areas facing significant natural constraints, in addition to the criteria relating to the extension of permanent crops or the assessment of average yields, both the areas served by the secondary irrigation infrastructure modernized by the finalized projects under the 2014-2020 NRDP and the areas irrigated at the level of Local Administrative Units (LAU2) reported by the National Agency for Land Improvement, validated with the results of the study on the mapping of irrigated areas carried out in the context of the programming process, will be taken into account. Through the rural development intervention aimed at animal welfare, Romania continues to promote the widespread adoption of high animal welfare standards in pig and poultry farming. It is important to recall that since 2012 such commitments have been implemented, which have proven to be a determining factor in improving animal health and welfare. Thus, the analyses carried out by the National Sanitary-Veterinary and Food Safety Authority showed that following the implementation of these commitments, the incidence of tail-biting decreased and the mortality rate decreased, competition between animals for food and space decreased, the incidence of respiratory diseases, podal lesions decreased, production parameters improved and the quantities of antibiotic products administered to animals were reduced. At the same time, the efforts undertaken by Romania during the last two programming periods to encourage sustainable management of natural resources, conservation of biodiversity and reduction of agricultural emissions, increasing access to environmental and climate measures and improving the quality of their implementation, were accompanied in a natural way by increasing the awareness of the users of agricultural and forestry land on environmental and climate issues, but also by improving the understanding of the manner the agricultural activities can be adapted to reduce their impact on the environment. The financial dimension of addressing environmental and climate objectives is also not to 6 be overlooked. From this perspective, it is important to note that the interventions and financial allocations were established on the basis of the SWOT analysis, the identification and prioritization of needs, but also following an intensive consultation process with the social partners. It is clear that budgetary constraints in relation to identified priorities and financing needs in all areas covered by the NSPs also need to be taken into account in the end. In a complementary way, for the period 2023-2027, addressing the European Commission’s recommendations and giving particular importance to the environmental, climate and animal welfare issues, Romania opted for 29 % of the ceiling for direct payments for eco-schemes, thus, the budget allocated to the first pillar schemes was 2.8 billion euro, the planned amount varying according to the identified needs specific to the Romanian agriculture. The financial allocation for eco-schemes, granted as an additional payment to basic support, provides the possibility for farmers to attach significant importance to environmental issues, in order to encourage the cultivation of protein species, the use of conservative agricultural technologies, nutrient management, optimal fertilization, promotion of small-scale environmentally friendly agriculture, all in order to ensure a sound management of natural resources in agriculture, as well as to maintain biodiversity and halt the depopulation of villages. Please note that the Romanian authorities have taken note of the Commission’s comments to include all the necessary details in the revised form of the Plan, so as to ensure that farmers and other beneficiaries comply with higher standards relating to the environment, climate change, public health, plant health and animal welfare. In conclusion, we consider that the environmental and climate interventions proposed by the NSP to be financed by the EGF and the EAFRD ensure that the potential to achieve the objectives pursued is maximized, in the context of the available financial resources and the balanced address of a wide range of identified needs, while contributing to the achievement of the objectives of the Green Deal and helping farmers to implement the green transition. Moving towards the objective of socio-economic development of rural areas, Romania considers that the joint effort of the CAP and structural policies leads to an adequate coverage of the needs of rural areas, including in the field of non-agricultural activities. During the bilateral discussions the Romanian authorities shall provide additional information regarding the complementarity with other European funds. With regard to the Commission’s findings on the LEADER approach, we would point out that the types of operations set out in the intervention fiche give LAGs the possibility to select from a wide range of eligible operations so that measures can be implemented to address locally identified needs in a manner specific to the LEADER approach respectively ‘bottom-up’. As regards broadband infrastructure, such interventions will not be activated through the NSP, as the National Recovery and Resilience Plan (NRRP) provides for the implementation of a scheme to support the use of communication services through different types of tools, with a focus on white areas. The objective of this investment is to ensure coverage of very high-speed internet access in areas where the market cannot provide these services on its own (villages, including disadvantaged areas) with two priorities: 7  i) an absolute priority targeting completely white rural municipalities that are not served by fixed networks, but where there is latent demand or socio-economic factors; and ii) a priority for fixed networks where speeds need to be improved and the market fails to meet these needs. We would point out that the level of ambitions under the NSP for rural development was set in direct correlation with the budget allocated to Romania from the EAFRD. As regards the budget allocated to rural infrastructure development, it was divided between the two planned interventions, following the consultation of the social partners. The need for basic infrastructure development in rural areas will be addressed both within the NSP and other European policies, benefiting from funding from the National Recovery and Resilience Plan (NRRP), the European Regional Development Fund (ERDF) but also from national funds (Anghel Saligny National Investment Programme). At the same time, agricultural access infrastructure continues to represent a need in rural areas with positive and complementary effects in achieving the objectives related to increasing the competitiveness of farms without having at its disposal another source of public funding. For the cross-cutting objective on promoting knowledge, innovation and digitalization in agriculture, Romania has addressed the chapters related to AKIS and digitalization, knowledge transfer and advice in agricultural affairs, through the proposed measures, aiming to provide targeted services to target groups, in order to improve their professional knowledge and results. In this respect, the transfer of knowledge and information, as well as advisory activities, will create the premises for farmers, including young farmers, to increase their competitiveness, to use innovative technologies and processes, to make more efficient use of resources, to improve environmental performance and to acquire knowledge for efficient management at farm level. Training courses will also include practical activities, and the provision of advisory services will lead to diversification of activities in rural areas. As regards the reduction of the budget associated to these two interventions, as compared to the previous programming period, or the non-inclusion of a specific intervention for the interconnection of AKIS actors, it should be noted that the interventions proposed in the Strategic Plan are not a single instrument to support this area. During the technical discussions we shall provide additional information regarding the Romanian approach on the matter. As regards the Commission’s comment on proposing actions to support Ukrainian refugees, the Romanian authorities consider that the issue is of major interest, making particular efforts with non-government organizations in managing the transit to other destinations or as appropriate, facilitating the establishment in Romania, access to work, education, health and income. An important role, in this respect, will be the CARE programme implementing the provisions of Regulation No 613/2022. specifically, at the level of the NSPs through the Local Action Groups, the option of financing Ukrainian refugees will be opened in line with the needs identified at local level through specific strategies. In view of these general considerations summarizing the most important issues identified following the European Commission’s letter of observations, I consider that through a 8 constructive dialogue at technical level, all the specific issues included in the Commission’s letter can be clarified so that, as soon as possible, the entire programming, analysis and approval process can be completed, thus allowing the implementation of the NSP to be successfully started from the following year. As regards the Commission’s initiative to publish their comments on the strategic plans of the Member States and their replies, I would point out that the Romanian authorities agree with this approach that guarantees an increased degree of transparency at European level regarding the process of analysing these programming documents. Yours sincerely, Adrian-lonuț CHESNOIU MINISTER 9