akis1

Elements related to crosscutting objectives (knowledge, innovation, digitalisation) are relatively well covered, however also here an exclusive focus on productivity. The absence of any reference to advice is noted. Equally, no reference is made to the provision of innovation support services, which becomes a mandatory aspect as of 2023. Digitalisation aspects are covered with respect to investments but no mention of connectivity aspects / broadband that was the focus of a specific recommendation.

No acknowledgment of the importance of sustainable forestry to contribute to climate change mitigation and adaptation, biodiversity, etc., which is surprising given the large forest area in Croatia. It is also striking that the Biodiversity and the Farm to Fork Strategies are not mentioned at all.

There is also no reference to societal demands. Even if not mentioned specifically, these could be acknowledged in the economic development part (i.e. how increase production etc. while reducing use of pesticides, improving animal welfare, addressing food losses etc.) as intensification of agriculture is described as a threat in SO9, and the emphasis on economic aspects could explain how possible negative impacts would be mitigated.

The paragraph on RRP does not seem strictly necessary in the strategic statement.

Regarding the statements on organic farming and generational renewal, see under SO4 and the overview of the generational renewal strategy (3.2.).

No reference to the support for EU quality schemes (awareness raising and participation), although they have the potential to directly address core challenges outlined in the Croatian CAP strategic plan such as “recognisability of Croatian products”, “insufficient association of agricultural producers”, weak competitiveness”, “encouraging the grouping of farmers to strengthen their position on the market” and “the focus of current production on low value-added products”.

·         No prioritisation of needs (mandatory)

·         No “Need assessment to specific geographical areas” (optional)

·         No “Methodology and criteria used for prioritisation” (mandatory)

·         The justification for why Need 19 is not addressed given in the table identifying the need should be moved to the appropriate section.

·         No “Justification of the targets and related milestones” (2.1.8.)

·         No “Justification of the financial allocation” (2.1.9.)

Referring to the 80/20 ratio is a good starting point, but additional complementary information on disparities of income and direct payments among farm sizes is relevant (to identify which farms need more income support through redistribution), reflecting the outcome of the distribution of income and direct payments analysis in the ‘long swot version’ in annex. This can be done in section 2.1.1.3 (which, in the new template, is no longer only about risk management but also about fairer income support).

Forest fires bring about severe consequences for the agriculture sector in Croatia. In this regard, wildfires could be added to the list of natural disasters or catastrophic events against which risk management tools could help protect farmers.

What type of “quality labels” does HR intend to support through its CAP strategic plan?

Investing in more environmentally friendly forest techniques and digital technologies to prevent and mitigate forest –related risks (e.g. forest fires, pest diseases) could be added under the description of this need.

However, HR fails to address this by not planning any sectoral interventions except in the F&V sector where it is mandatory.

This need could also cover the forestry sector.

It is stated that irrigation areas need to be increased. However, the analysis is very rough and there is no indication regarding the situation in the different regions.

In addition, the increase of irrigated area can only be linked to the adaptation to climate change, if the present and future status of the water body affected will stay in good status and if it does not negatively affect the resilience to deal with droughts and other environmental aspects. These qualifications should be made explicit in the description of the need.

Enhancement of sustainable forest management practices towards climate change adaptation including nature-based solutions contributing to reducing climate-related and natural disasters such as wildfires and pest diseases could be added under the description of this need.

In the table that identifies this need, need 08 is linked to SO4 (which seems plausible); but in the section on the SOs and the CCO, need 08 is only linked to SO2.

Is forestry biomass included under this need?

The description of the need (in the EN machine translation) is somewhat confusing. Is it about an increase of the contribution of the agricultural (and forestry?) sector to Renewable Energy production? Or is it about increasing the use of Renewable Energy in Agriculture (and not including forestry)?

The use of different Units (PJ and MW) is also confusing.

It is mentioned here that ‘Croatia is not rich in long-lasting water reserves…’, while in need 07 it is stated that ‘Despite large water resources, only 2.5% of the surface is irrigated, therefore irrigation areas need to be increased’ – these two statements seem to be somewhat contradictory.

Needs related to water quality are not described. Diffuse pollution from agriculture is the most significant pressure on surface- and groundwater bodies, especially in the continental part of the country belonging to the Danube River Basin. Nutrient pollution is the most significant impact on surface water bodies (43% of surface water bodies affected) and on groundwater (6%). Croatia still has one of the highest phosphorus surpluses (> 5 kg/ha) in the EU.

The document should include a more detailed analysis of the problem of N and P surplus at national level as well as the relevant actions tackling this problem, i.e. description of the transposition of the Water framework Directive and Nitrates Directive i.e. in section 2.1.1.4.

The selection of interventions presented in 2.1.1.6 are not targeting the problem of the nutrient surplus and most of the actions described focus on a rational use of manure. More balanced fertilisation combining different sources or using exclusively mineral fertilisers should also be included.

Also along the same line, the use of the FaST will be an interesting element towards the objectives of the SO5 and cross-cutting objective of modernisation, digitalisation etc.

The information on soil degradation processes (focusing on soil erosion and loss of SOM only) is too generic and should be more specific (e.g. differentiated by territory: Pannonian, Mediterranean, mountainous regions, etc.).

The aspect of the need related to the conservation of genetic resources is not addressed in the description.

Sustainable forest management or/and close to nature forest management practices could be added under this need contributing to preventing biodiversity loss and preserving ecosystem services and natural resources.

What is the percentage and areas of Natura 2000 sites concerned by agriculture and forestry?

What are the key priorities for the conservation of habitats and species related to agricultural and forestry activities?

Is it possible to quantify them or estimate the magnitude of the challenges for nature conservation?

Has the Prioritised Action Framework (PAF) for Natura 2000 been taken into account?

It is indicated that the implementation of the Biodiversity Strategy and EU nature legislation has negative impacts on sustainable forestry, that it is causing loss of income and jobs, etc. It is suggested to adapt the language in these sections, as these claims seem not to be substantiated and at odds with the current EU policy documents (Biodiversity and Forest strategies in particular).

The necessity to continue to invest in infrastructure in rural areas is too broad and should be better specified / targeted – e.g. technical infrastructure (water, sewage, road), social (kindergartens) etc. Within technical infrastructure – local roads, more precise targeting is needed – e.g. improving roads that facilitate connection of rural areas’ inhabitants to nearby towns / work places / public services / amenities, etc.

The need could also further expand on the contribution of green infrastructures and nature-based solutions in rural and forest areas to the delivery of multiple economic, environmental and social benefits to local communities (e.g., ecotourism, provision of added value services and enhance recreational activities in the forest areas).

This should be further developed.

The need could be made more specific on the basis of the experience of the use of the current M14/AW.

No reference to routine pigtail docking, or need to improve animal transport (livestock vessels) which were both mentioned in the Recommendation to HR.

The justification for why Need 19 is not addressed given in the table identifying the need should be moved to the appropriate section (after the needs tables).

Refers to both agriculture and rural areas, which seems reasonable in view of some indications emerging from SWOT analyses for other SOs.

Makes reference to the need of improving knowledge on the use of digital tools but this element was originally not much developed in the (extended) SWOT analysis.

This need and the following one seem to overlap insofar they both focus on improving access to knowledge/R&I with a focus on improving the knowledge and skills of advisors. A more accurate formulation/demarcation is needed.

The need makes general reference to the inclusion of advisors in AKIS without being explicit about the integration of independent private advisors (highlighted in the EC recommendation). Reference to this issue is broadly touched upon in relevant interventions, without a clear indication on how to address it.

In the formulation, the role of digitalisation should be made clearer (tool for improving AKIS integration and advice?). To be noted that knowledge flow from farmers to advisers/research (i.e. knowledge exchange in both directions) are equally important vs. mere “knowledge transfer”.

Beside the remark raised under N22 (overlaps and sharper formulation): This need being about encouraging the uptake of innovation by means of cooperation falls short of mentioning Innovation Support (Art.15.4e). This is another key element flagged in the EC recommendations and originally missing from the SWOT. It follows that no mention is made under the AKIS strategy (Section 8) and related interventions.

The forest sector should also be included under this need. There is a need to increase support for research and innovation development in the forest sector to promote forest production and the use of innovative forest management practices to prevent forest-related risks such as forest fires, pest diseases, etc., and adapt to, and mitigate climate change.

Areas

Based on all identified needs across objectives please provide information on prioritisation of needs, the methodology and criteria used to prioritise them.

Move here the justification why need 19 is not addressed by the CAP SP.

–       References to the full SWOT analysis are missing.

Analysis:

Identification of needs, including: (a) in relation to risk management, (b) in relation to a fairer distribution and more effective and efficient targeting of direct payments where relevant taking into account their farm structure (2.1.2.):

–          A simulation showing the combined effects of all relevant income support tools on income and direct payments is encouraged (e.g. using FADN), simulating effects of BISS, CIS, ANC, CRISS, ECO scheme and all other things (structures and prices) considered equal. The analysis of effects by physical size should be included. By doing so, it would become possible to demonstrate that the tools proposed sufficiently address the need, in particular that the parameters chosen for the CRISS (up to 30ha paid (while it was up to 20ha in current period), all BISS beneficiaries covered…) are adequately addressing the need.

–          This section does not describe in detail the farmer’s needs and their prioritization in relation to risk management. We understand that the highest risk is droughts but there is no more information about animal diseases, plant pests, environmental incidents and loss of product quality (if any). There is also a differentiation between large and small farmers without any other comments.

–          It is positive that need 01 takes into account need for redistribution and fits with the requirement to have a specific assessment of needs in terms of redistribution (one element of the redistributive package introduced at the end of the legislative process). However the presentation may need to be adapted as CRISS is essentially a tool to improve the targeting of income support towards those who need it most, and not primarily to decrease the concentration of support (and related 80-20 ratio).

Intervention strategy/logic (2.1.4.):

–          Same as above, when it comes to SO1, CRISS should not only be seen as a tool to address high concentration of income support but also to target the income support to the farms with higher needs (the way the intervention CRISS is described in the intervention fiche (chapter 5) can be taken as it responds at least partially to this comment). Please also confirm there is no need for payment to small farms (EAGF small farm scheme).

Selection of result indicators (2.1.8.):

Justification of targets and milestones:

Justification of the financial allocation (2.1.9.):

–       References to the full SWOT analysis are missing.

Not explicit mention of digital technologies (for farming, forestry) neither in the SWOT nor in the intervention strategy. This, despite the fact that this aspect is raised in the identification of needs. à Result indicator 3 should be considered since investments in digital technologies are prominent in the needs analysis. Moreover, digital technologies are recognised among the key tools to address issues of productivity and competitiveness while addressing concerns of environmental and climate sustainability e.g. use of precision farming technology for rational and efficient management of input and lower nutrient losses).

Concerning forest infrastructure, any justification/quantification of the needs and targets? E.g. the close to nature/environmentally friendly low impact forestry interventions need well planned and developed fine access network in order to avoid soil disturbances/compaction/erosion, etc.

–       References to the full SWOT analysis are missing

Analysis:

Identification of needs (2.1.2.):

B3: Low interest of producer groups to participate in quality schemes (inferred from low uptake of respective support under the current RDP) as an additional weakness.

SWOT Table:

–       S1 (Increased awareness of the need to move to sustainable management systems): What is the evidence for the increased awareness of the need to move towards sustainable management systems? The first draft SWOT pointed to the positive trend in the uptake and/or number of beneficiaries of support for organic farming and agri-environment schemes. This is not sufficient. First of all, the decision to enrol in a certain scheme is certainly also motivated by economic considerations. But even if there was a direct link between uptake and awareness, the share of the area under organic farming is slightly below the EU average, and the share under agri-environment is still much lower. So things may have picked up lately, but they are still not at a level where this could be conceived as a strength. This was already noted in DG AGRI’s comments to the draft SWOT on SO4.

–       S2: While GHG emissions from agriculture have decreased by 39% compared to 1990 and 18% compared to 2005, they are stagnating since 2013, so there is no reduction trend in recent years. It is doubtful whether this can be classified as a strength.

–       S4 (Potential for geothermal energy use) is an opportunity, not a strength. This was already noted in the Commission comments to the draft SWOT on SO4.

–       W4 (Insufficient awareness of insurance needs and reduction of production risks) should be placed under SO1.

–       O3 (Growing public interest in climate change adaptation and mitigation): It is not clear in how far this represents an opportunity for Croatia. How will this translate into concrete needs on the basis of which the design of interventions, financial allocations, milestones and targets can be determined?

–       O4 (Reducing energy consumption in agriculture through energy efficiency): Is there an analysis of energy efficiency in the agricultural sector and of potential energy savings that could be achieved to support the claim that energy consumption in agriculture could be reduced through renovation of agricultural facilities etc.?

–       O5 (Sufficient quantities of water to be used for irrigation): It should be clarified that this refers to sustainable irrigation (so as to ensure to maintain/achieve good status under the Water Framework Directive and avoid any deterioration).

–       T3 (Slowly visible results of interventions can discourage beneficiaries from further activities): How will this translate into concrete needs on the basis of which the design of interventions, financial allocations, milestones and targets can be determined?

–       T4 (Further depopulation of rural areas): This should go under SO8.

Analysis:

–       The trend of decreasing GHG net removals from LULUCF is not addressed (cf. the “worrying trend of decrease in net removals from LULUCF” noted in the analysis underlying the Commission recommendations).

–       The final statement of the paragraph on renewable energy production seems to be a repetition of need 08, which should be qualified (e.g. “sustainable…production”) to minimize the potential risks linked to an increase of biomass production.

–       The SWOT and the summary should indicate that despite GHG emissions have decreased since 1990 and 2005, this trend does not continue anymore and GHG stagnate (this is a quite common pattern across the EU). In addition, emissions from cropland are increasing. (Cf. also the remarks on S2.)

–       The summary indicates that agriculture accounts for 11.4% of the total national GHG; the CCI (reported in the recommendations) indicates that this share is 14.8% (2018).

–       It is not explained how crop diversification increases water retention in soil.

–       Climate adaptation needs are not specified, e.g. for specific biogeographical regions or farm sectors at risk.

–       Climate change impacts on the risk of forest fires are not addressed.

–       Agricultural sources contribute to emissions of PM10 (from manure management, and crop and farmland production), NOX emissions from soil, and NMVOC (from cattle manure management and burning of agricultural waste). None of these pressures are explicitly mentioned.

–       Low water retention of soils, low humus content and insufficient use of agricultural practices and methods to contribute to reducing risks should be included as weaknesses.

–       The current situation on irrigation/irrigated area/irrigable area, irrigation equipment, water exploitation trends and the current situation on droughts should be covered.

–       “Large amount of biomass available to generate electricity” may be an opportunity for SO4 but could also be a threat for SO5. Please note that any promotion of biomass combustion needs to be accompanied by sufficient safeguards to ensure no negative air quality impact (notably particulate matter emissions).

–       The summary SWOT highlights floods as an issue, but there are no measures on floods in interventions.

Identification of needs (2.1.2.)

–       As the description of the need also calls for encouraging farming practices that “contribute significantly to climate change mitigation through carbon sequestration or nitrogen fixation should be encouraged through appropriate interventions”, need 10 should also be linked to SO4.

–       The following needs are not (sufficiently) covered:

–       The need for cultivating crops and breeds that are more resilient to climate change

–       The need to introduce measures addressing forest fires risks (Could also be integrated or cross-referenced under need 02)

–       Although air pollution emissions linked to livestock management still constitute a significant share of total emissions, climate mitigation needs related to livestock production are only partly addressed. Measures focusing on changes in diet of cattle and pigs and the composition of animal feed, improvement of breeding program are missing.

–       Compensation for farmers is needed to deal with natural disasters (as stated under needs 02 and 03), but there should also be funding for adaptation measures for example natural water retention measures or switching to less water consuming crops to deal with droughts. There is a need to invest in adaptation measures to deal with these natural disasters so that farmers will not be impacted as much and so that compensation funding over time can be reduced. This is also one of the CAP recommendations for Croatia and should be taken into account in the plan.

Identification of the relevant (elements of) national plans emanating from the legislative instruments referred to in Annex XI of the CAP plan Regulation that have been taken into account in the CAP plan’s needs assessment for this specific objective (2.1.3.):

–       A list of measures from NECP (and other national plans) relating to needs linked to SO4 and statements that needs linked to SO4 were identified based on a national strategy is insufficient.

–       The needs assessment should include (1) the need to decrease emissions and increase removals in order to contribute to the national climate and energy targets in the relevant areas described in the NECP (see annexes of the tool on SO4) and (2) the needs identified in the national adaptation strategy (see annexes of the tool on SO4).

–       If any of those needs are not included in the CAP plan needs assessment, or if they are mentioned but have substantially changed in content, are reasons given for this? Do the reasons seem valid?

–       The need to improve practices to adaptation and mitigation is quite broad

Intervention strategy/logic (2.1.4.):

–       The intervention strategy in the draft plan consists of declarations that the interventions planned under this SO shall be consistent with national strategies and documents and generic descriptions of those interventions (one sentence per intervention). This is manifestly insufficient.

–       What is missing is a description of the targets/milestones, interventions (including a broad justification of their choice), and the allocation of financial resources required to address the needs identified and retained (for the respective SO/CCO).

–       As regards the planned eco-schemes, the level of requirements of some seems not fit for purpose, notably the crop diversification (see comments on eco-schemes).

–       The intervention strategy refers to aid for public irrigation without reference to water quantity status or RBMP. Other climate adaptation measures should be considered including nature based solutions, natural water retention measures (which were mentioned in recommendations on the assessment of the 2nd RBMP), switching to less water consuming crops etc.

–       Many of the interventions listed under this SO are not linked to SO4 in section 5 (lack of coherence).

–       Will forestry interventions also be covered by this SO? (E.g. as part of preventive actions (forest fires, pests and diseases, natural disasters related needs)?)

Selection of result indicators (2.1.8.):

–       R.4 cannot be linked to SO4.

Justification of targets and milestones:

Missing

Justification of the financial allocation (2.1.9.):

Missing

SWOT table:

–       S1 is the same as S1 under SO4 (the same remarks apply)

–       S2 (Successful implementation of RDP measures contributing to better soil management): The successful implementation of a policy measure as such is not a strength. Presumably, the reason why these measures were programmed is because they address a need that should be grounded in a strength, weakness, threat or opportunity. In the case at hand, this seems to be poor soil quality, which may be classified as a weakness. It is of course possible that the measures programmed to address this need have so successful that what used to be a weakness now is a strength. But this strength would then be reflected in better soil quality, compared to other MS, for example.

–       T3 (Permanent conservation of economic forests/possible consequences of implementing the EU Biodiversity Strategy): It is inappropriate to list the consequences of implementing the EU biodiversity strategy as a threat. It is also unclear how this could threaten the achievement of SO5.

–       Include as a weakness that diffuse agricultural pollution is the main pressure on both surface and groundwater.

–       Include as a risk the possibility of not achieving the objectives of the WFD by 2027 of reaching good status in all waters.

Analysis:

–       The summary SWOT does not mention a significant shortcoming linked to the lack of a sufficient knowledge about the environmental situation. This concerns soils, but also water, as the network of groundwater monitoring stations is insufficient. The major part of the country (including the most productive agricultural area (Pannonian and para-Pannonian plains)) is not, or not sufficiently, covered by monitoring stations. There is a need to increase the number of stations to identify potential areas suffering from water pollution.

–       The application of mineral fertilizers – the main source of nitrous oxide emissions – and methane emissions from livestock farming are not addressed in the SWOT.

–       More information on water needs to be included in the SWOT (water status under WFD) – ecological and chemical status of surface waters and chemical and quantitative status of groundwaters and the fact that agriculture is the main pressure. On the basis of a more in-depth analysis, more concrete interventions could be proposed. Such an analysis can then also serve as a further basis for the irrigation intervention proposed under SO4.

–       Diffuse pollution from agriculture, mentioned in the EC recommendations as the most significant pressure on water bodies (and potentially a precursor or co-factor in GHG emissions), especially in the continental part of the country lying in the Danube River Basin, is not addressed.

–       The draft plan mentions a trend towards reducing emissions, but no details on this trend (data) are placed as evidence, nor further explanation on the driver(s) for this reducing trend.

–       Soil fertility and erosion are mentioned as important soil threats, but Croatia is also exposed to desertification and salinization, which is not highlighted.

–       Problems with the low soil organic matter in the most productive areas of the country (eastern Croatia), leading to risk of erosion and low level of conservation tillage are also not considered.

–       Hydromorphological pressures from drainage are not addressed at all.

–       The SWOT summary also includes no references to air pollution; this seems like a lost opportunity.

–       The summary SWOT rightly indicates that farmers’ education needs to be improved, but focusses almost exclusively on technology / precision farming as a solution, without an appropriate consideration of the role sustainable techniques can play (only organic farming is mentioned, but not agroecology, agro-forestry and conservation agriculture).

–       While there is a reference to reconstruction and conversion of degraded forests, a reference to sustainable forest management is missing and should be added.

Identification of needs (2.1.2.):

Needs in relation to water, air and soil are addressed by only one broad need (need 9), which seems to focus primarily on the need to improve soil fertility and soil health; there is a need to reduce air and water pollution also beyond the soil aspect of environmental impacts.

SO5 currently appears insufficiently addressed in the needs assessment, notably with a view to ammonia emissions to air. In line with the Commission recommendations to Croatia on the CAP SPs, also nutrient losses to air and water should be prioritised and addressed.

Another indication for the limited scope of need 9 is the fact that none of the interventions programmed are linked to the result indicator for water (despite the fact that the need 09 refers to „practices that reduce negative impacts on…water”).

Identification of the relevant (elements of) national plans emanating from the legislative instruments referred to in Annex XI of the CAP plan Regulation that have been taken into account in the CAP plan’s needs assessment for this specific objective (2.1.3.):T

–       The 3rd river basin management plan which is currently being developed and the recommendations from the 2nd RBMPs should also be taken into account where relevant.

Intervention strategy/logic (2.1.4.):

–       The intervention strategy in the draft plan consists of declarations that the interventions planned under this SO shall be consistent with national strategies and documents and generic descriptions of those interventions (one sentence per intervention). This is insufficient.

–       What is missing is a description of the targets/milestones, interventions (including a broad justification of their choice), and the allocation of financial resources required to address the needs identified and retained (for the respective SO/CCO).

–       Many of the interventions listed under this SO are not linked to SO5 in section 5 (lack of coherence).

–       Forests are assessed in both SO5 and SO6; the criteria used to address environmental/climate issues related to forests in the two SO are not specified.

–       Manure/nutrient management actions are only included extremely limited and indirectly in the list of eco-scheme interventions. Eco-schemes to also support air pollution (ammonia) reduction as part of improved nutrient management measures, should be added to the list. Especially since the results indicator “Improving air quality” is quoted in the results indicator list in section 2.1.1.10 for SO5 and fertiliser/manure management actions are in fact described under the eco-scheme „Minimum leguminous content of 20 % within agricultural areas” (p. 99 EN translation), including with references to ammonia emissions.

Selection of result indicators (2.1.8.):

–       R.4 and R.14 cannot be linked to SO5.

Justification of targets and milestones:

Missing

Justification of the financial allocation (2.1.9.):

Missing

SWOT Table:

–       It is unclear how the implementation of the EU Biodiversity Strategy can be conceived as a threat (T.6) when it comes to “halting and reversing biodiversity loss, enhancing ecosystem services and preserving habitats and Landscapes” (SO6).

–       W2 (“Degradation of the environment and biodiversity due to abandonment or intensification agriculture”): Intensification and land abandonment should be differentiated as regards their impact to biodiversity.

–       O2 (“Development of ecosystem services”): The heading is too vague. Do this refer to cultural services? It should be better elaborated somewhere which (type of) services are targeted. The SWOT should clearly recognize that nature provides key supporting and regulatory services that enable agricultural productivity to continue. And that intensification of agriculture degrades biodiversity and those very services.

–       Threats: It seems this section is rather used to find other causes for biodiversity loss, rather than addressing threats posed by agricultural/forestry activity itself.

–       T3 (“Pressure from tourism and construction”): The SWOT fails to mention here intensive agriculture, they key threat to biodiversity which the plan should deal with, but yet adds other threats which are not comparable to the former. Or does this refer to tourism and construction on farmland (under SO7 rural tourism is indicated as an opportunity)?

–       T5 (“The emergence of new plant and animal diseases; and pests or outbreaks of existing diseases and pests”): This is a threat to agricultural productivity, not biodiversity. Biodiversity actually protects against it, but if it is degraded it cannot do so.

Analysis:

–       It is unclear how he implementation of the Law on Nature Protection and the Regulation on the Ecological Network can have “negative impacts and consequences” when it comes to “halting and reversing biodiversity loss, enhancing ecosystem services and preserving habitats and Landscapes” (SO6).

–       It is unclear what “unjustified favouritism of one (organic) as opposed to the other two (economic and social) components of sustainable forest management” is supposed to mean, and there is no further analysis to substantiate this finding. In any event, it does not seem belong in a SWOT analysis for SO6.

–       Organic farming in Croatia should be better covered by the summary of the SWOT analysis. A steady increase in organically farmed (OF) area so far does not necessarily ensure that “positive trends will continue and that agricultural producers are aware of the role of organic farming in the future” (as claimed in the strategic statement). Currently app. 50% of OF area is karst pastures, grasses and meadows. Further increase of OF area for marketable crops (not karst pasture and meadows) would result in an increase of OF production, cheaper prices (economy of scale) thus resulting in increase of interest to buy organic.

–       The low share of landscape features is not mentioned in the SWOT and summary while this is a clear need in Croatia (need 12).

–       The risks related to further intensification of agriculture, such as mentioned in the EC recommendations, are not considered.

–       No reference to the status of protected habitats and species as reported by Croatia under Article 17 of the Habitats Directive and Article 12 of the Birds Directive.

o   The reporting data show e.g. only 27.59% of grassland habitat types present in Croatia are currently in favourable conservation status (FCS). Status for 13.79% is unknown, while the rest is in unfavourable conservation status (U) (24.14% U1 stable/unknown, 27.59% U2 stable/unknown and 6.9% U2 decreasing). 55% of grassland habitats assessed were reported as being affected by one or more pressures/threats from broad pressure category “agriculture”, while even 86% is threatened by being exposed to natural processes.

–       Reference should be made to the conservation status of habitats and species relevant for the proposed interventions, e.g. grasslands (including habitat types listed in Annex I of the Habitats Directive such as wet meadows, karst pastures, etc.), forest habitats, bird and other species such as butterflies and their habitats, etc.

Identification of needs (2.1.2.):

–       The needs under this SO should address organic farming

–       There is no mention of the need to protect farmland bird species (other than Crex crex).

Identification of the relevant (elements of) national plans emanating from the legislative instruments referred to in Annex XI of the CAP plan Regulation that have been taken into account in the CAP plan’s needs assessment for this specific objective (2.1.3.):

–       A broad declaration that the objectives and measures of relevant national plans are somehow linked to needs under SO6 is not insufficient.

Intervention strategy/logic (2.1.4.):

–       The intervention strategy in the draft plan consists of declarations that the interventions planned under this SO shall be consistent with national strategies and documents and generic descriptions of those interventions (one sentence per intervention). This is manifestly insufficient. Among other things, specific references to the draft action plan for organic farming and an explanation how the relevant interventions under the CAP Strategic Plan relate to the specific actions under the draft action plan for organic farming should be included here.

–       What is missing is a description of the targets/milestones, interventions (including a broad justification of their choice), and the allocation of financial resources required to address the needs identified and retained (for the respective SO/CCO).

–       The eco-scheme of ecological focus area should focus on non-productive areas and landscape features (see specific comments to this ES).

–       It seems that the needs identified in the prioritised action framework (PAF) (annual need of EUR 80 million of EU co-financing for biodiversity, 48 millions in Natura 2000) will be met only to a small extent through allocations for relevant interventions (for the whole period, 58 millions only allocated to Objective 6 minus genetic resources). Croatia is invited to the take latest version of the PAF into account in its overall strategy.

–       Some of the interventions listed under this SO are not linked to SO6 in section 5 (lack of coherence).

Selection of result indicators (2.1.8.):

–       R.4 and R.26 cannot be linked to SO6.

Justification of targets and milestones:

Justification of the financial allocation (2.1.9.):

HR lists two needs related to generational renewal, namely: Need 13 ‘Improving the age structure of farm holders’ and Need 14 ‘Facilitate access to initial capital for investments’. However, on several occasions in the draft CAP SP HR points to the lack of access to agricultural land and land acquisition opportunities as main challenges faced by YF, which results in migration of younger populations from rural areas. Also, the main weakness W1 in the SWOT analysis is the high share of rented area in total UAA.

Therefore, HR is invited to describe in SO7 strategy how main barriers to generational renewal are being addressed:

–       Improvement in disposal of 33% of agricultural land that is state-owned and is currently under the responsibility of local self-governments;

–       what are the national legislative and administrative instruments aiming to facilitate transfer of agricultural land between generations: incentives for retired farmers to do transfers, fiscal exemptions / reliefs, etc.

–       does HR face an issue of informal private leases (sofa farmers keeping agricultural land to get direct payments and letting the neighbouring active farmers cultivate the land)? If yes, what are concrete steps to counteract it?

–       How the HR authorities address an issue of getting proper cadastre titles that result in YF (together with other farmers) acquiring agricultural land and, as a result, having  insufficient collateral or guarantees to obtain loans?;

–       How do the HR authorities address the improvement of business environment for producers and agribusiness, which the Croatian YF point out as the main challenge together with the availability of subsidies, difficult access to credit and advice of extension services?

The absence of interventions aimed at fostering the socio-economic roles of forests is a missed opportunity.

As the current 1-sentence text underlines an involvement of local stakeholders in the preparation and implementation of local development strategies, the COM services expect substantial improvement in delivery of LEADER/CLLD actions under the future CAP SP. Currently the selection of interventions under LEADER remains under the control of the Paying Agency leaving little scope for LAGs to design their own bottom-up and place-based responses to local problems.

SWOT table:

Analysis:

–       This is an edited (minor editorial changes) version of the summary commented in June 2020.

–       There is no in-depth analysis of the current situation with regard to pesticides, with no reference made to trends in the use and risk of pesticides, the use of more hazardous pesticides, and integrated pest management (IPM).

–       There is not enough information to illustrate the situation with regard to antimicrobial resistance (AMR), with no figures or trends in this respect. (There is a Commission recommendation to Croatia on reducing the sale of antimicrobials.)

–       There is a general introductory reference to biosecurity in the summary of the SWOT, but this is not translated into specific needs and interventions.

–       The summary of the SWOT contains sufficient details on food waste, including a target on halving food waste per capita by 2030, at retail and consumer level, and reducing food losses throughout the chain. It also contains a reference to the need to set up a food bank to prevent food waste and tackle poverty through food donation. However, none of the programmed interventions contains specific actions with regard to food waste.

–       There is also no general analysis on how the CAP contributes to a healthier food environment.

Identification of needs (2.1.2.):

–       The incomplete assessment of weaknesses (confusion weaknesses / threats) generally negatively affects the needs assessment (need 18 and 19), as it could be more complete (ex: impacts of intensification of agriculture and climate change on animal welfare, use of pesticides, use of antimicrobials, food waste etc.).

–       The only need identified under specific objective 9 (SO9) that is addressed by the draft plan is “strengthening animal welfare practices” (need 18), but the choice of animal welfare as a means to achieve further reductions of antimicrobial use does not fully follow from the SWOT analysis.

Intervention strategy/logic (2.1.4.):

The intervention strategy is rudimentary and needs to be more precise (on the basis of an improved needs assessment).

Please describe how you are planning to scale up the deployment of the circular and sustainable bioeconomy through the support of the CAP. You might use the recommendations formulated in the Final Report of the Bioeconomy Policy Support Facility.

–       N.B. The SWOT summary table is the same as the one commented upon by AGRI in February 2020. Weaknesses pointed out on that occasion (formulation, consistency with analysis,…) were not addressed. Moreover, the accompanying summary is relatively succinct and does not add up to the table.

Analysis:

–       The SWOT summary needs to be improved. It only focuses on digital aspects and is made up by general statements. As a minimum it need to ensure that the relevant needs (N20, 21, 22, 24) are all covered, which is not the case!

Identification of needs (2.1.2.): See comments further above for each identified need.

Intervention strategy/logic (2.1.4.):

–       The two interventions selected only address AKIS aspects and not digital.

–       The above issues highlight the overall inconsistency of the intervention strategy, which by the way it is not developed. HR needs to ensure better coherence between SWOT (table + summary), needs and interventions (see also comments under section 8. Modernisation).

–       As appropriate, the SWOT, needs analysis and intervention strategy for the CCO should also cover knowledge- and digital-related aspects emerging under the other SOs. A number of such aspects appear in the SWOT analysis of other SOs, but they are not necessarily identified as needs under those objectives of the CCO. Are they sufficiently reflected in the choice/design of interventions?

–       In the field of digitalisation both is to be covered: digitalisation in agriculture and in rural areas

Selection of result indicators (2.1.8.):

Justification of targets and milestones

Missing

Justification of the financial allocation (2.1.9.):

Missing

No milestones, targets, planned outputs, national values for GD targets, no explanation how the CAP Strategic Plan will be consistent with the Union targets and make a contribution to achieving them.

Impossible to evaluate properly the ambition of the CAP SP without milestones and targets for result indicators. The ambition of a plan is a function of the design of its interventions, financial allocations, and targets/milestones.

The following elements are missing:

–       A description of the overall contribution of conditionality to the specific environmental and climate-related objectives (section 3.1.1.).

–       An overview of the complementarity between the relevant baseline conditions, conditionality and the different interventions addressing environmental and climate-related objectives (3.1.2.).

–       An explanation on how to achieve the greater overall contribution set out in Article 92 (3.1.3.).

–       An explanation of how the interventions under coupled income support are consistent with the Water Framework Directive (3.1.5.).

–       (Where relevant, CAP contribution towards LIFE projects (3.1.6.)).

The green architecture description should summarize the main environmental and climate challenges, recall the main priorities and describe how the different instruments and interventions of the CSP contribute to the challenges identified (underlining the synergies).

The information provided under 3.2. consists of very general statements regarding the interplay of agriculture and the environment and the relations of conditionality (baseline), eco-schemes (first level, voluntary schemes) and agri-environment-climate interventions under Pillar II (building on the eco-schemes) that have very little informational value. It is insufficient to provide an overview of the overall logic and interactions within the different “blocks”, particularly GAEC, ES and AECM.

Explanation of how the environmental and climate architecture of the CAP Strategic Plan is meant to contribute to, and be consistent with the long-term national targets set out in or deriving from the legislative instruments referred to in Annex XI (3.1.4., 3.2.4. in the HR draft plan):

–       What is provided is a declaration that the interventions that are part of the Green Architecture shall be consistent with the objectives set out in the national strategic documents and plans resulting from Annex XI legislation, followed by a list of those Croatian documents and plans.

–       Neither is this an explanation, nor does it address the question (how?). Hence, this is manifestly insufficient.

In particular, in view of its size in Croatia, as a major contributor to climate change adaptation and mitigation issues through the implementation of sustainable forest management practices and forest ecosystems protection measures, this section should also cover the forestry sector.

The plan includes some measures with potential negative environmental impacts (e.g. forest roads), which are not precisely defined and where no information is provided on how to mitigate adverse effects. Likewise, for investments in irrigation the provisions of Art. 74 SPR need to be respected (and adequate eligibility criteria need to be set out) to ensure such investments do not result in negative environmental impacts and are in line with WFD objectives.

According to the strategic statement, “It is important to continue the interventions for young farmers taking over or setting up new farms”. However, it is recommended to accompany the investment support co-financed from EU funds with initiatives / interventions at national level such as improved access to land, capital, well-targeted and dedicated support / accompaniment of advisors including the private ones, etc.

Promoting honey and products from apiculture, based on their value for health, cannot be accepted since there are currently no EU authorised health claims for honey or apicultural products. In addition, references to health benefits from reasonable wine consumption are not acceptable.

In 3.3.3. last indent, Wine: reference is made to 5-year period. This is not correct. Under the CAP Strategic Plan, the allocation for wine covers 4 years (2024-2027).

3.4 for F&V does not seem to match well with 5.2. There should be a list of interventions per sector in this section.

Note that this information will be included now under section 3.8 of the SFC template (scope and focus stays largely the same)

Good starting point with relevant indications. They will need to be further developed/detailed in a further stage (what is actually foreseen vs. “nice to have”)

The Croatian authorities may go further with their thinking on simplification as there could be more scope both via the use of technology (IACS especially) and support to beneficiaries.

Simplification by technology (8.2.1). This mainly focuses on access to data by PAs: what about use of technology for controls (remote sensing, satellite imagery, geo-tagged photos, components established/to be established under IACS for area-based and animal-based payments, etc.)? These have the potential to reduce the information to be provided upfront by beneficiaries. Moreover, they can be used to accompany farmers not only in the application process (single/electronic application, claimless application) but also during implementation (early warning, farm management).

It would be good to hear from HR whether any plans exist in this respect, going beyond what is required by the legislation (Art. 64 of HZR). Toolkit 8.2 proposes some questions that can be a useful guidance.

Are there any actions foreseen within the scope of the integrated farming data system to be set up via RRP funding?

Simplification by intervention design (8.2.2). Good examples that would need to be made more concrete with links to the actual CAP plan (not suggestions or “nice to have”).

Counted so far: Simplification of eligibility criteria for investments-related operations (how exactly?) including: streamlined ex-ante checks via better data access by the PA; proportionality for smaller farms (e.g. submission of shorter business plan).  Simpler eligibility conditions for young farmers (very good but how concretely?)  More/better use of SCO (where?)

Apart from the above, is there any other accompanying measure for beneficiaries that the MA can put in place to reduce burdens/costs for the beneficiary from application to implementation? (e.g. information and support for applying, including online help, use of advisory services and CAP Network,…). Particularly for non-IACS interventions.

The draft plan does not include a description of the GAECs, although relevant GAEC standards are referred to under the Eco schemes and rural development measures.

The different categories for the National Reserve proposed are not explained, justified; It should be shown that there are consistent with the needs and general principles (objective, non discriminatory and transparent).

–       Expiration of payment entitlements: more explanation of the rule would be needed.

Missing elements

–       End of payment entitlements: no date indicated yet. It should be consistent with the internal convergence path.

–       Territorialisation: territories not yet defined

–       Convergence: information are not complete and clear enough to assess

Specific comments:

–       Expiration of payment entitlements:

o   the rule seems to discriminate only a part of the payment entitlements versus other payment entitlements why no justification: ‘Beneficiaries who are granted new payment entitlements from the national reserve on the basis of the use of agricultural land owned by the Republic of Croatia are obliged to return these entitlements to the national reserve if they lose the right to use the agricultural land in question.’

o   Are you sure that no other rules are needed (such as expiration after x years that the entitlements is not activated…)?

All tasks at national level spelled out in Art. 126(4) are mandatory. The scope/focus of this summary (4.4.1) is an overview of planned objectives and activities (in line with the article’s requirements) for Croatia.

This should e.g. include specific networking structures/tools/activities to be foreseen including for innovation/AKIS support (with reference to section 8 of the CAP plan on modernisation), LEADER/LAGs, monitoring and evaluation etc.

Section 4.4.2. It would be useful to integrate the information on structure and governance with some key details about: any foreseen aspects related to the monitoring and evaluation of the network’s activities; key steps and indicative timing for setting up the Network (with an eye to ensure continuity with current NRN) and; indicative information on resources to establish and operate the Network (indicative share on TA budget, FTE/staff).

This part should be more developed and specific as to the summary of complementarities between EU funds that are relevant for rural areas; There should be more details as regards the scope of support (possibly demarcation criteria, or relevant definitions), specific categories of interventions, and an indication of which needs mentioned in the plan would be supported with other funds (needs not addressed in the plan).

Specifically, as regards the RRF, the strategic statement sections mentions indeed financing of capacity building in the agricultural, processing and food sectors with a focus on digitisation of agriculture and land consolidation. The RRF is also mentioned in Section 8 (AKIS and digital technologies) relation with internet access and digitisation (please see specific comments on that section). In addition the Croatian RRP seems to indicate relevant investments in :

–       Creation of wetlands to improve flood protection measures

–       Logistics distribution centres

–       Traceability system for local producers

–       Sustainable tourism

–       Circular economy (foodbanks)

–       Public water supply development

–       Mobile outpatient care units and mobile pharmacies

In view of the above, the statement that “The need for a demarcation between NPLO and SP CAP has not been identified and synergies have been found primarily with the reform related to the digitalisation of agriculture.” should be re-assessed, and this section could explain how the coordination, demarcation and complementarities between these investments will be ensured, given that it appears from the document that funds from the RRF would not be coordinated by the coordinating body in the ministry of regional development and EU fuds.

It is not clear what the last paragraph refers to (starting with “The implementation of public infrastructure projects…” would this refer only to investments financed from the RRF ? in any case how would the demarcation and coordination with Managing authorities be ensured ?

Would the Coordinating Body (with the Ministry of Regional Development and EU Funds) cover all CPR funds ? and LIFE funds ?

Please specify under which interventions FI will be offered. We understand for the moment no interventions are described for FIs, yet, nor financial allocation and unit amounts.

Please provide an account of the benefits your FI bring to the final recipients (e.g. longer repayment periods, lower interest rates, or lower collateral requirements).

We understand that you want to offer the one-stop-shop option (combination of financial instruments and grants in a single operation). If this is the case, please describe:

o   the form of additional support (e.g. capital rebate, performance based grant, technical support, etc.)

o   the implementing mechanism (including the triggering event and combination rules)

o   the governance arrangements between the fund manager and the CAP SP governance bodies (MA/PA)

This largely copied from the regulation.

The starting date of eligibility of costs incurred by the beneficiary shall not be set before 1 January 2023.

Additional elements common for sectoral interventions, for rural development interventions, or common for both sectoral and rural development interventions seem to be missing.

Eligibility: ‘The beneficiary undertakes an annual commitment.’ Unclear, what does it mean? Farmers have to ensure agricultural activity or maintenance, but beyond that, not sure what commitment means for BISS?

Compulsory grazing in pasture and karst is not green-box compliant.

Description of the design/requirements: please avoid repetition with eligibility and follow latest version of DP intervention template.

Justification of the unit amount and Min/max: a justification of the aid level including min./max. (fourchette) based on an envelope divided by the number of eligible hectares is not appropriate. The unit amount should be justified based on the identified needs. For example, an analysis can be done as regards the gap between the average farm income and the average income in the rest of the economy and, if a gap is detected, it could be decided to close (a certain par of) this gap. Of course, the availability of financial resources must be taken into account when performing this exercise.

There is no justification of the unit amounts and of the ha limitation.

It is not clear whether Croatia will set the limit of hectares at the level of individual young farmer in case of a legal person or group of farmers.

It is not clear whether HR decide to continue granting complementary direct payment support to such farmers who in the past received support for young farmer.

Reference is made to Article 26 (Article 39 new numbering) of SPR, which covers CRISS, and which is not an eligible intervention to meet the young farmers’ ring fencing.  To be clarified if HR means Art. 27.  If not, the ring-fencing requirements would not be met.

It is not indicated whether the eco-schemes payments are based on Art. 28 (6) a or b.

Despite this, we suspect that Croatia is planning payments additional to BIS as all the eco-schemes are open to all types of agricultural land, even if it is clear that some requirements are relevant only for specific areas (cropland or grasslands). It is not acceptable that ES based on agronomic practices that can applied only to some types of agricultural land are set to apply to all land uses. This would be against the WTO rules green box rules applying to payments for income support. This issue is addressed in the WD on Q&A on eco-schemes.

There is no information about baseline, particularly conditionality. In the absence of this information, it is impossible to assess in how far the eco-schemes go beyond mandatory requirements and hence their actual potential to contribute to environmental objectives. In addition, the draft does not provide information about links/complementarity between the eco-schemes and the AECMs.

Even if the GAECs are not defined in the CSP yet, some eco-schemes seem not to beyond the baseline and would need to be revised (e.g., payment for buffer strips for 3-10 m, whereas 3 m are already required by EU legislation).

For all eco-schemes, HR is invited to clearly indicate the current situation and the expected situation indicating the surface currently applying the indicated practices and the evolution of the surface during the next CAP. It is also invited to explain whether the proposed practices are currently being supported under the CAP or other national funds.

Given the problems experienced in Croatia with the uptake of AECM, the CSP is invited to reflect on how to promote the uptake of eco-schemes (for which similar problems are to be expected). Eco-schemes could potentially include measures formerly offered as AECM and for which the uptake was insufficient, in case this new format (eco-schemes instead of AECM) could lead to an increased adoption.

More measures directed to nature should be included in the eco-schemes (e.g. those for which support was insufficient/not interesting for farmers, see point above).

There are several measures included in eco-schemes like grazing on pastures, but the Plan should clarify if certain particular habitats will be targeted. The measure related to mosaic landscapes (currently under ecological focus areas) should provide a sufficiently increased environmental ambition. It does not mention any particular needs of species or links with protected habitats.

In terms of encoding information in the forthcoming version of SFC template, eligibility conditions must be differentiated from commitments.

Specific comments:

Diversification of farmland

• The link to R31 (habitats conservation) does not appear to be significant
• This ES seems equivalent to the current greening practices on crop diversification (that applies to cropland) while it is indicated that the scope is extended to all agricultural areas, including permanent crops, pastures and meadows.
• While requiring the presence of different grass species in pastures might be appropriate, the description of commitments is not sufficiently accurate and pastures-specific. Planting a green cover within rows of orchards/vineyards to cover the soil is appropriate but this not usually called “crop diversification”.
• The commitments of the ES should be adapted for the different land uses
• The reference to GAEC 9 should be made in the relevant heading (baseline elements)

Grazing pastures

The description of commitments should distinguish the three categories of areas mentioned

A main obstacle for supporting the high-value karst pastures and other HNV grasslands is the potential very low eligibility coefficient that might reduce considerably the eligible area for the eco-scheme. We invite Croatia to reconsider a more flexible approach to this valuable areas.

Ecological focus areas

In the Commission view, the focus should be on landscape features and non-productive areas, such as buffer strips and other non-productive strips. Catch-crops with a mix of crops species beneficial for fauna can also be appropriate. However, N-fixing crops and areas with short rotation coppice provide a very low benefit for biodiversity, which is the main objective of this ES.

In addition, the cultivation of leguminous crops is already supported with another ES.

Use of manure

The description should specify that the aim is to prepare a fertilisation plan, with support of technical advice, and comply with it (maybe translation issue).

It is not clear whether the requirements on NVZ stem from the Nitrates Action plan or are part of the ES. The section on baseline should be filled for more clarity and ensuring that baseline requirements are complied with.

The proposed eco-scheme on use of manure in restricted surfaces raises some questions with regard to its computability with the action plan under the Nitrates Directive for NVZ as the eco-scheme cannot compensate for costs for measures that are mandatory under EU legislation (in this case, the Nitrates Directive). The SP refers to a III Action Plan dated Summer 2021. What is the status of this action plan? Has it been notified to the Commission? In relation with this eco-scheme, the beneficiary is requested to conduct analysis of the soil and the manure, which could be positive. However, the costs associated with these analysis are unclear (and the question of who will bear the costs), as well as the threshold (for each parameter) that need to be met and the consequences of the results of the analysis.

Minimum leguminous content of 20%

The link to R20 (improving air quality) does not appear to be significant; the contribution to three RI appears sufficient

We do not understand the scope of this ES for which all agricultural land is eligible. The impact of the ES could be strengthened by setting out enhanced crop rotation (beyond GAEC 7).

Conservation agriculture

The link to R20 (improving air quality) does not appear to be significant; the contribution to four RI appears sufficient.

The requirement to a minimum cover of 30% of the area seems very low while this is a key practice in conservation agriculture; the need for rotation is not included.

We do not understand why the scope of this ES is the whole agricultural land of the farm, while this agricultural system clearly targets cropland.

The SWOT summary for the Specific Objective 1 (SO1) does mention under “Weaknesses” several factors that would provide the rationale for granting CIS. However, the sectors concerned are not specified, as such. We would suggest adding this element under each weakness:

Ø  W.1. Low farm income in several agricultural sectors [in particular, in sectors X, Y, Z]

Ø  W.2. Significant decline in area size, economic size and standard (size) production for small and medium-sized farms [in particular, in sectors X, Y, Z]

Ø  W.3. High and persistent dependency of agricultural income on direct payments [in particular, in sectors X, Y, Z]

The SWOT summary also highlights that “Coupled support is still needed for certain sectors suffering from production volatility. Support contributes to difficult sustainable farming activities whose income is highly dependent on direct payments and can hardly generate added value.” This raises a couple of comments:

Ø  When referring to “production volatility” (this might also be a translation issue), do you have in mind variance in the crop yields and number of animals produced or rather price volatility?

Ø  As such, the above-mentioned elements would need to be underpinned by the corresponding SWOT analysis for SO1.

o   Yet, the latter does not include sufficient information that would allow assessing the degree of the difficulty experienced by different sectors, including the underlying trends in number of hectares/animals, number of farms and output[1]. Put differently, the SWOT analysis does not clarify why other potentially eligible sectors for CIS are not considered as undergoing difficulty.

o   While Chart 19 shows FNVA/AWU by sector (TF8, FADN), no data on sectors’ importance in agricultural output or heterogeneity within sectors (e.g. by physical farm size) are provided. These elements would help designing CIS interventions in a way that is better targeted towards the actual needs (e.g. granting coupled payments up to a certain number of animals or hectares, or only to farmers joining producers’ organisation within a given sector).

Note that the Basic act provides that Member States can only design CIS interventions to support sectors/productions or types of farming therein that meet the following conditions:

·         fall in the scope of CIS (i.e. are on the list of eligible sectors/productions)[2]

·         are important for economic, social or environmental reasons and

·         are in difficulty(ies).

Consequently, given the information provided in the SWOT analysis, it is not possible to fully assess the nature and degree of difficulty experienced by the various sectors, or types of farming within these sectors. These elements are central for the design of CIS interventions (e.g. eligibility criteria, unit amounts, financial allocations)[3].

General comments

Should a MS wish to justify difficulty undergone by different sectors on economic basis, such justification may be based upon the following elements:

Ø  Decline in the production over a representative period of time;

Ø  Decline in the sale prices over a representative period of time coupled with a decrease in yields/output

Ø  Comparison of sale prices of crops produced in the MS and the sale prices of crops imported from third countries;

Ø  Decrease of the area cultivated in ha/number of animals over a representative period of time;

Ø  Decrease of the number of holdings in the sector over a representative period of time;

Ø  Low profit/income of farmers in the sector in absolute terms and/or compared to other sectors.

We would ask you to add these elements, as appropriate, for each CIS intervention.

Aim of intervention: identical text is provided for all the 8 CIS interventions

·         ‘to improve competitiveness’, and/or

·         ‘to improve quality’, and/or

·         ‘to improve sustainability’

Could you elaborate more on different dimensions, for example: how the CIS, say, for the milk sector is expected to improve the quality of milk? Have you observed such an effect under the current CAP framework with the various Voluntary Coupled Support measures? What aspect of sustainability (e.g. socioeconomic and/or environmental) is the CIS intervention aiming to improve and how? Are all the three dimensions relevant for each intervention?

Several other elements still need to be added, in particular:

Ø  Unit amounts and financial allocations

Ø  Consistency between each CIS intervention and Directive 2000/60/EC (i.e. Water-Framework Directive) – this box is already included in the revised SFC template so as to reflect the agreement reached by the co-legislators in late stages of the CAP trilogies

We understand that all the 8 CIS interventions are designed as the WTO “amber box” measures.

Targeting (this type of questions applies to the subsequent interventions as well)

Ø  This intervention is granted irrespective of the size of the herd. Are income needs and difficulties undergone by small/medium-sized farms and large farms identical?

Ø  As regards types of farming (mixed vs specialised farms), are the difficulties experienced identical?

Ø  We note that the issue of accumulation of support is taken into account as the support is limited only to those animals that do not receive the suckler cow premium.

Aim of intervention

Ø  See the relevant elements under the general comments (applicable to all the other interventions and considered as horizontal remark mentioned only once).

·         This intervention is granted irrespective of the farm size/number of animals and type of production (extensive vs. intensive). Do the difficulties experienced differ across farm sizes/types of production?

·         In particular, according to the FADN data,

Ø  The beef and veal sector earns, on average, income that is above the average agricultural income in the country. Consequently, the (economic) difficulty undergone by intensive fatteners would need to be clearly demonstrated,

Ø  In addition, the beef and veal fatteners in Croatia have typically recourse to intensive farming. Given that this type of farming is more likely to pollute inter alia ground water and also taking into account the legal requirement to ensure consistency between coupled support and the Water Framework Directive, the explanation of this consistency would be particularly pertinent.

Justification of the importance and aim of the sector

·         The explanation provided says that the “aim is to increase efficiency within the beef sector, with a view to increasing beef production … and ensure a stable supply to the meat-processing industry.”

·         We would suggest reformulating the description of this CIS measure, for example, as follows: “aim is to increase efficiency within the beef sector. As a side effect, this will also help to ensure a more stable supply to the meat-processing industry”.

·         As to the aim to increase efficiency, one possible way to generate efficiency gains is to increase herd size (irrespective of the type of production process, intensive vs. extensive). However, given the requirement to justify the consistency of CIS with the Water Framework Directive (see above), one could conjecture that targeting coupled support to extensive fatteners and/or setting a maximum limit in terms of number of eligible animals for intensive fatteners could help to strike the balance between economic and environmental aspects of beef and veal production.

Finally, to underpin the socio-economic importance of the beef sector, it may increase clarity to argue the importance of stable supply of meat in view of “preserving employment in the meat processing industry”, in particular if the sector is an important employer (this would need to be demonstrated in the SWOT analysis).

·         This intervention is granted irrespective of the farm size/number of animals or type of production (mixed vs. specialist). Is the degree of difficulty varying across different dimensions?

·         We note that the issue of cumulation of support is taken into account as the support is limited only to those animals that do not receive coupled support for dairy cows.

·         Could you please provide CN codes of the targeted varieties so as to make sure they fall within the CIS scope. To recall, sweet pepper and genus capsicum (after the foreseen amendment of the CMO) remain eligible for coupled support under the new CAP framework (following harmonisation of the nomenclature). However, genus pimenta will become potentially un-eligible.

Difficulty

·         The text says that “Due to the unfavourable market and business conditions resulting from the structure of production and the traditional resistance to pooling, small vegetable producers are unable to improve farm incomes and to withstand the challenges of this competitive sector.”

·         Consequently, one of the reasons for low income is the fact that farmers are reluctant to join producers’ organisations (PO) for historical reasons. This element could be taken into account in the eligibility conditions by, for example, targeting this intervention to farmers that are members of PO or differentiating the unit amount based on the membership in PO (granting lower amount to farmers remaining outside PO).

·         In addition, Chart 24 in the SWOT analysis (presenting income and direct payments per ha by type of farm) shows that income of horticulture farms is the second highest across all the sectors and well above the average farm income. Consequently, is CIS warranted in this case?

Importance

·         Self-sufficiency is not a valid argument for justifying socio-economic and/or environmental importance of a sector (given that the demand, in this case, for vegetables can be met via intra-EU imports, i.e. the Single Market).

·         The text reads “Fruit production is not sufficient to cover the needs of the domestic market.”

·         This is not a valid reason for justifying CIS under the CAP framework (as the demand can be met via intra-EU imports, i.e. the Single Market).

·         In addition, Chart 24 in the SWOT analysis (presenting income and direct payments per ha by type of farm) shows that income of fruit farms is the third highest across all the sectors and well above the average farm income. Consequently, is CIS warranted in this case?

Importance

·         The text merely states “The fruit sector is particularly important for economic, social and environmental reasons, but faces difficulties, and this intervention aims to maintain the current level and increase the production of traditional fruit species which are of great importance to the Republic of Croatia”.

Could you elaborate and substantiate the statements above?

Eligibility conditions include, among other, a reference to a minimum yield. However, this yield is not specified and justified as yet.

Given that soya is one of the eligible crops under this CIS intervention, the corresponding area falling under the Blair House agreement is to be specified.

–          An overview & evaluation of the current situation of the sector is lacking, no mention of apiculture in the SWOT analysis which leads to the challenges and needs of the apiculture sector in Croatia, and consequently it is difficult to justify the choice of interventions.

–          All interventions are based on the specific objective SO2 and the Need 05; surely the different interventions target other specific objectives and needs;

–          The chosen interventions and actions supported carry on practically unchanged from the current HR National Apiculture Programme 2020-2022, notwithstanding the broader scope of interventions in the SPR and emergent needs and challenges for the sector since 2019.

–          Except for the name of the intervention and eligibility conditions most other fields are either : not filled – description of the design/requirements of the intervention, WTO compliance, planned unit amounts and the financial table with outputs;

or incorrectly filled in:

Type of intervention (should be according to Article 55 of the SPR), Result indicator (RI) (only “R.35: Preserving beehives: Share of beehives supported with the CAP” applies to apiculture interventions and only for “Type of intervention under Art 55, 1b. All other apiculture interventions do not have a RI), under eligibility conditions some elements would be better suited under the description, forms and rates of support need to be clearly explained and calculation methods shown where relevant for all interventions.

–          The title or name of the intervention/s should not be the same as the type of intervention but reflect the content of the intervention and provide a clear indication of the support provided.

–          In the description, the link to the specific objective and needs should be clearly outlined and moreover it should indicate how the intervention contributes to these. It should also include a clear description of the interventions or actions which will be supported within the chosen type of intervention.

–          Beneficiaries and Eligibility conditions need to be described for the different interventions/actions and should reflect the description and objective of the intervention.

–          Planned unit amounts and outputs should be included in the financing table. Where this is feasible, unit amounts should be determined for the planned ‘intervention/s’ under the ‘type of intervention‘ chosen. The Output indicator for all types of interventions within apiculture sector is O.37: Number of actions or other units for beekeeping preservation/improvement. This is an aggregate indicator; thus for each individual intervention, either the expected number of specific actions to be carried out, number of beekeepers or number of beehives in that year constitute the planned outputs. (The planned outputs need to be specific in whether they consist of number of actions, beekeepers or beehives.) Multiplication of the latter (planned outputs) with the unit amounts should result in the planned financial allocation for the intervention concerned.

–          Too many missing/incomplete elements to properly assess these apiculture interventions.

Drinking sugar and sugar cakes insofar as being production costs are not eligible for support – refer to draft Delegated Act of the SPR, Annex II and III.

Eligible investments need to be clearly described.

Intervention could well be included together with the below intervention.

a) linked type of intervention planned. Intervention must be linked with the “type of intervention” (as listed in Art 47 of SPR).

b) linked sectoral objective. (as listed in Art 46 SPR).

Under related SOs, SO3 is not selected (only SO2). As sectoral support to F&V is channelled via producer organisations, SO3 shall be selected as an objective too.

Result indicators for sectoral interventions in F&V sector should always cover R.10 and R.11 (as support is channelled vis POs), plus possibly other result indicators if the contribution of sectoral interventions to those other RIs is direct and significant. R.10 and R.11 are missing from the CR plan as regards sectoral interventions in F&V sector.

Types of interventions and sectoral objectives not chosen

https://circabc.europa.eu/ui/group/eee95e91-908e-46ae-a186-ef44626bef5e/library/9cea5856-6ab1-4c0b-91e7-27efd2a4b620?p=1&n=10&sort=modified_DESC

At the time of writing, the following tools were available: LEADER, Young Farmers and Rural Business, Environmental, climate and other management commitments, Natural and other area-specific constraints, area-specific disadvantages resulting from certain mandatory requirements, knowledge exchange and information, financial instruments, contributions to Invest-EU.

Whilst compensation payments (presumably Natura 2000 payments) are planned in relation to constraints resulting from the implementation in Natura 2000 of conservation measures for forest habitats, such payments are not planned for other habitats such as grasslands. We recommend considering Natura 2000 payments also for constraints related to the implementation of conservation measures for grasslands and associated species

No contribution rates specified (5.3.1 in the SFC guidance, 5.3.11 in the HR draft CSP)

Not clear how this intervention can contribute to SO4, but may perhaps also be linked to SO9

No amounts of support given

No information regarding state aid assessment

No planned unit amounts and indicative outputs (5.3.9 and 5.3.13 in the SFC guidance, 5.3.12 and 5.3.13 in the HR draft CSP)

There is reference in the costing justification to cost of removal, are there annual specified time requirements relating to the actions under this intervention?

Explicit restriction on the use of pesticides could be considered

While use of pherenomes have the potential to help reduce reliance on pesticide use, how can it be controlled that farmers don’t still use pesticides despite carrying out these actions?   Is there mandatory training or other accompanying measures ?

Mechanical destruction of weeds  – it is stated’ the use of herbicides in ‘protected areas’ is prohibited’. Where are such protected areas defined. Otherwsie under this measure herbicides are still allowed?

In ‘amount of support’ section the practises are listed – these would be the basis of the cost incurred income forgone. Its important to only pay for those actions which go beyond conditionality requirements. The amounts need to be defined

For Corncrake and Lepidoptera actions, the intervention states that a minimum of 30% of the area must be in an ecological network area for the target species. Has this area been defined? Does it include areas outside of Nattura2000?  For the vegetation buffers, can this area be used to fulfil the requirements of GAEC 4? Pesticides are prohibited under the requirements, but are fertilisers permitted?

Eligibility conditions: Translation is very poor but it is presumed that the species are those that are identified as important for conservation and listed in the PAF for Croatia (to help implement the habitats and birds directives)?

Conditionality- baseline requirements: Given the many relevant aspects of conditionality it is important to define this section better to ensure that the payment only covers additional costs and income forgone.

Explanation of the basis of the unit amount : This level of detail is good to have for the certification body to check how the payment was calculated but is not explicitly required to be reported – and is not validated by the EC

Have the compulsory LU for breeds been defined as alluded to under the requirements for this intervention?

The general statement that “Original and protected breeds of farm animals are also important for economic reasons, as they provide certainty for sustainable food production in the future, especially as they are able to adapt to evolving climate change” should be substantiated.  It is unclear how original breeds can better adapt to evolving climate change than any other breed.

The minimum of 0.15 LU seems very low to effectively preserve animal genetic biodiversity.  It would be better to specify minimum LU for each type of farm animal covered by the intervention.

The first sentence under “Description” does not match the actual intervention as it refers to “preserving traditional, local conditions adapted to the species and breeds of animals”.

Description of the baseline needs to be included.

In line with the provisions of the proposed Delegated Act on genetic resources, and pending its adoption, the number of breeding females at national level should be stated, and a duly recognised relevant technical body should register and keep up-to-date the herd or flock book for the breed.  The intervention can only include the types of farm animal listed in the Delegated Act; fish are excluded.

As for other interventions based on additional costs / income foregone, the calculation of support rates should be performed / confirmed by a body that is functionally independent from the Croatian authorities responsible for the programme implementation and possessing the appropriate expertise.

Croatia is encouraged to properly assess the needs of the different sectors and the related demand of organic products from consumers in those sectors. This could help to primarily channel the support where it is really necessary and where a real added-value both from an environmental and economic point of view – and thus the potential contribution to specific objectives can be demonstrated.

To this end and as previously suggested by the COM services, the support could be territorially targeted so as to increase its efficiency. The following aspects could be considered:

–       equal spread across the whole country according to the environmental needs;

–       positive impact of respective species needs to be proven for increase of biodiversity,  counteracting land abandonment, soil erosion, etc.;

–       plantation of respective organic species should be well balanced, i.e. they are mostly needed in areas with highly intensified crops.

Is there any strategic paper(s) for the development of OF in Croatia that would present a holistic view of the sector, its current state and future development opportunities?

It seems that the following requirements have not been transposed from the RDP:

o   A minimum of 6h of training (or equivalent) related to organic farming

o   Record keeping of the implemented organic farming activities

What are the reasons for this?

As regards relevant result indicators, HR is mentioning only R29 and R22 (nutrient management). However, organic farming can also be linked to R.14 (carbon sequestration, important, as HR links the support to SO4), R.19 (soil), R.21 (water quality), R.24 (pesticides), R.31 (habitat and species, in particular when it is organic farming on permanent grassland), R.32 (biodiversity). MS may also attribute organic farming to other RI when specific requirements or conditions of the intervention can justify it.

From 1st of January 2021 onwards, the new Regulation (EU) 2018/848 on organic production will enter into force and therefore repeal Council Regulation (EC) No 834/2007. Please check and update the legal references in the plan accordingly.

Result indicators are needed.

The intervention needs to be in line with the provisions of the proposed Delegated Act on genetic resources once it is adopted. Provisions include concerted actions (e.g. exchange of information between Member State organisations) and accompanying actions (e.g. dissemination, advice, and training).

–       Designation of the areas. Are there changes compared to the period 2014-2020? A link to the Ministry’s website (or other sources) where the designated municipalities are listed should be included.

–       Please double-check the indications for the areas with specific constraints (‘And JLS cover an area of 902 ha or 16.07 % of the total land territory of the Republic of Croatia.’ To what territory does the 16.07% refer to? It cannot be the total area of Croatia.)

–       Differentiation: It is mentioned that the payments vary depending on the production method, extensive, intensive, arable or livestock farming, but the specific information regarding differentiation of unit amounts based on farming systems is missing. Please provide further information (i.e. applicable amounts (€/ha) according to the farming systems).

–       Degressivity: Payments have to be degressive with the respective thresholds to be defined by the MS, as required by paragraph 13 of Annex 2 to the WTO Agreement on Agriculture. The description of the applicable amounts (€/ha) and the support rates has to include the thresholds and levels of degressivity applied. During the Monitoring Committee session on 23 November 2021, the Commission learned that the HR authorities prepared 6 scenarios for degressivity of ANC payments. The defined thresholds will need to be duly substantiated.

–       WTO compliance: in this section, the MS is required to add a short explanation of how the intervention respects the relevant provisions of Annex 2 to the WTO Agreement on Agriculture as specified in Article 10 of this Regulation and in Annex II to this Regulation.

–       Planned Unit Amounts (financial table with output): reflect in the table the expected level of payments per financial year and link the intervention funds to the specific output indicator chosen for this intervention.

–       The description of this measure should consider the latest COM comments and conclusions presented in the latest assessment (May 2021) of the HR proposal for updating the current delimitation of Areas with Natural Constraints (ANC) based on the application of the Common biophysical criteria. Certain methodologies (e.g. dryness) have not yet been accepted by COM.

–       The calculation of support rates should be performed / confirmed by a body that is functionally independent from the Croatian authorities responsible for the programme implementation and possessing the appropriate expertise.

Other specific comments:

–       Eligibility conditions: are all farmers registered in the Register of Farmers active farmers?

–       Calculation of the payments: please provide further information. While the calculations of the payments level are not approved by the Commission, Member States must ensure that such calculations are adequate and accurate and established based on a fair, equitable and verifiable calculation method. A body functionally independent from the authorities responsible for the implementation of the CAP Strategic Plan and possessing the appropriate expertise has to either perform the calculations or confirm their adequacy and accuracy (Article 76 SPR).

–       Paragraph 5.3.9 additional questions: this section is foreseen for Art. 65 and not for Art. 66. As a reminder, the ANC payments are not conditional to any commitment.

However, the eligibility conditions seem to have been updated for:

–       Goats (i.e. whether production is for dairy, meat or combined).

–       Sheep (i.e. whether production is for dairy, meat or combined).

These eligibility criteria need better explanation with reference to the animal welfare improvements necessary. The description in very much linked to production (‘are eligible for aid for meat production, e.g. p. 253) – this is to be cross-checked for WTO compatibility (Green Box). Furthermore, why are the breeds specified, as this is not an intervention for endangered breeds?

The intervention proposed is in principle positive, but there is no clear connection with the SWOT analysis, or a focus on specific sectors, or specific practices to be improved. There is a risk that the wide scope of the intervention limits the impact on the most critical issues. For instance improvement of the commitments could be achieved by adding specific practices aiming at reducing the use of antimicrobials. In such a case, support could also count towards R43

The actions to improve housing conditions are in principle positive. However, on view of the importance of animal welfare, Croatia should consider to be more ambitious and support only increased space of more than 10% compared to baseline. Furthermore, in the case of all categories of cattle and pigs, the enrichment of deposits (bedding) alone, without increase of space, would not be a significant improvement.

For broilers, it is not clear what the ‘no more than 30 kg broiler weight/m² expressed as an annual average’ means compared to the baseline. The same comment is valid for turkeys. Dairy cattle, calves, pigs etc.: it is unclear how the feeding plan will improve animal welfare if it does not include any minimum requirements or an official evaluation.

Routine Pig tail docking is not allowed under Directive 2008/120/EC, hence baseline and therefore cannot be supported under this intervention. The request that housing conditions must ensure that at least 70 % of the animals have intact tails needs to be specified in order to be eligible for support, e.g. by clarifying that the 70% of intact tails (not only ‘not cut’, but also not bitten) need to be achieved at the moment of delivery to the slaughterhouse (to be controlled there).

Likewise, the no beak trimming commitment should be accompanied by measures to improve housing conditions and enrichment material, to ensure that it is effective (and not counterproductive). Therefore, for this commitment it is of outmost importance that it is embedded in an ambitious package approach.

Goat “hooks” seems to be a mistranslation.

Identification of relevant baseline elements: other mandatory requirements established by national and Union law beyond conditionality, where applicable, need to be described (section 5.3.7). This includes the link between GAEC, SMR and national standards with the intervention. Please also consider that where no legislation exists commitments have to go beyond “normal” farming practice (see tool 5.3.1)

Form and rates of support, planed unit amounts , WTO compliance: not filled

Contribution rates : not filled

Under number 7 ‘construction of new livestock housing in large carnivores distribution areas’ – this includes ‘a roof on one water’ please explain what this means.  In addition, as is the case for many of the measures under RDP, the baseline requirements are not listed.

For the intervention on biodiversity related habitats, what is the relationship with GAEC 8 on landscape features?

It is not sufficient to establish just the maximum support rate. The different applicable support rates need to be specified, together with the criteria on the basis of which they are differentiated.

Even though non-productive investments play a complementary role in helping to achieve agri-environment objectives or in enhancing the environmental value of protected areas, it is recommended that Member States – although allowed to apply public aid rates higher than those granted to productive investments – should not grant aid rates of 100 % of the total investment costs. As stated in past ECA reports on non-productive investments, Member States should define appropriate criteria to determine the remunerative characteristics of non-productive investments benefiting from the highest aid rates. These criteria should consider, for example, the economic benefit, the agronomical benefit, the degree of financial assistance necessary to encourage undertaking the non-productive investment and the basic support rate applicable to productive investments in the same geographical area. On the basis of this assessment, Member States should modulate the intensity of support.

Does the intervention provide sufficient explanations about how the different support rates will be applying and based on which general criteria?

Please provide further clarification on this sentence: “The investments shall not have a significant negative impact on the environment and/or the conservation objectives and integrity of the ecological network site, or where required by the competent authority, protection and mitigation measures have been applied.” By definition, NPIs have a positive environmental impact. If necessary, are preliminary studies considered to prevent possible negative environmental effects of the investments?

Regarding sub-intervention 4 (elimination of invasive alien species) and 8 (restoration of habitats relevant to biodiversity), are any selection criteria considered? For example, preference for specific areas as Natura 2000, HNV areas or other particular areas? The two proposed operations appear to be wide-ranging in terms of targeting the areas where the investments are most required. Furthermore for sub-intervention 8, habitat restoration, is it targeting grassland areas only?

Concerning the removal of invasive alien species, it is stated that “given the high regeneration capacity of these ligneous species, removals should be repeated until the population is under control”. The eventual maintenance costs of the investments are not supported under Art. 68, but under AECC (Art. 65). Furthermore, Member States are encouraged to implement non-productive investments in synergy with other rural development interventions or environmental schemes.

The eligibility conditions stipulate, inter alia, that ‘The investment shall take place at a location of investments owned or possessed by the beneficiary under lease/rent/service/utilisation if there is a valid lease/rent/service/concession for at least 10 years’.

Some members of the Monitoring Committee sessions for HR RPD 2014-2020 reported that as regards the current type of operation 4.4.1 ‘Non-productive investments related to environmental preservation’ the 10-year leases of agricultural land were not possible to obtain. E.g. as regards the floodplain pastures to Sava river, all tenants were  ineligible, as no one has contracts for more than 5 years – this issue needs to be checked by the HR authorities.

Are the de-mining actions on agricultural land will still be supported under the CAP Plan?

According to the proposal of the National Mine Action Program of the Republic of Croatia 2020-2026, it is planned to completely remove the mines from the territory of the Republic of Croatia by 1 March 2026, which is in line with international obligations (Ottawa Convention).

The nature of the investment proposed should be better explained as well as the links with SO8 and the need 15. It is presumed that the proposed intervention is similar to the current TO 8.5.2 ‘Establishment and improvement of walking trails, look-out points and other small-scale investments’. HR is invited to consider ways to improve the uptake, which for M08 currently is at 17% (EU average: 47%).

Under the same intervention, restoration of damaged forests after wildfires or pest diseases could be eligible for financial support.

Description of the design/requirements of the intervention that ensure effective contribution to the Specific Objective(s) is still missing. In this context, it should be also clarified whether this intervention is foreseen to count for the 35% ring-fencing; if it is the case, more information on the targeting is needed.

It seems that SCO per ha will be used for this intervention – please include this information also in box 5.3.7

Support rates have to be specified in the plan, according to comprehensive criteria, “up to” is not possible.

HR is invited to consider ways to improve the uptake, which for M08 currently is at 17% (EU average: 47%).

The production of forest climate and fire resilient reproductive material could be eligible for financial support under this intervention contributing to enhancing forest adaptation to climate change and preventing wildfires and other natural disasters.

It should be assured that the principles of sustainable forest management are fulfilled, a stronger focus on investments for soil- and resource-friendly harvesting machinery and practices is recommended.

For the selection of projects/operations sustainability criteria should be also taken into account (apart from the economic viability).

Support rates have to be specified in the plan, according to comprehensive criteria, “up to” is not sufficient.

Demarcation to industrial processing is provided and can be supported.

Sustainable principles should be taken into account (type of machinery, selection of projects etc.).

Support rates have to be specified in the plan, according to comprehensive criteria, “up to” is not sufficient.

Wildfire prevention forest infrastructure could be taken into consideration facilitating forest fire response activities as well.

Link to sustainable forest management important, should be more elaborated.

Support rates have to be specified in the plan, according to comprehensive criteria, “up to” is not sufficient.

Promotion projects for the marketing of wood are not eligible under the ABER. De minimis should be used.

Please elaborate more on which concrete investments/products/services should be eligible under this intervention.

Support rates have to be specified in the plan, according to comprehensive criteria, “up to” is not sufficient.

Why is this intervention linked to Need 11 (“Improve agricultural practices that contribute to the protection and enhancement of the biodiversity of habitats and species within Natura 2000 sites”?

R.33 (Improving Natura 2000 management: Share of total Natura 2000 area under supported commitments) cannot be used for this intervention since it is reserved for management commitments beyond the baseline of legal requirements. Forest Natura 2000 payments under Art. 72 should be linked to R.7 (the title is misleading but indicator factsheet clarifies that beneficiaries other than farmers are also covered).

Does this cover only Natura 2000 areas or also other delimited nature protection areas with env restrictions applicable to forests which contribute to the implementation of art 10 of Dir 92/43/EEC? Please indicate.

Concrete legal requirements /restrictions that foresters are subject to in the concerned areas need to be indicated (i.e. requirements/restrictions which are defined in corresponding management plans or equivalent instruments of the national legislation implementing the respective Union Directives) – the calculation of the payment will be based on costs incurred and income foregone stemming from these requirements.

Moreover, the scope of the intervention, and in particular to what extent the investments supported under it contribute to SO4, is unclear.

Are some of the investment operations supposed to count towards the 35% ring-fencing for environment and climate under EAFRD? If so, these would need to be singled out in a separate intervention.

Eligible type of support is not sufficiently clear (“farm restructuring and modernisation, disposal, handling and use of livestock manure with a view to reducing adverse environmental impacts and the use of renewable energy on farms for own use”) – what would be eligible under farm restructuring and modernisation?

Under “support rates” it is stated that “The aid intensity shall be up to 65 % of the value of the total eligible costs of the project and may be increased up to 80 % for investments: a) for animal welfare b) implemented by young farmers.”

Does this intervention target investments to improve animal welfare? What about investments linked to environmental objectives and renewable energy – would these also benefit from an 80% support rate?

Concerning investments in the handling of manure (- and others if relevant) – Art 73(5) needs to be taken into account (“Where Union law results in the imposition of new requirements on farmers, support may be granted for investments to comply with those requirements for a maximum of 24 months from the date on which they become mandatory for the holding.”).

To increase environmental ambition of the CAP SP what about introducing specific types of investments in RES and improving energy efficiency such as e.g. use of biomass from agriculture and forestry, use of energy from renewable sources (agricultural biogas plants), disposal of waste and by-products from agriculture, etc.?

Comment also valid for other interventions: Are the HR authorities going to introduce separate interventions in a form of grants and Financial Instruments?

Please have a look at the description of the investments to be implemented under the Croatian RRP and related to the construction and equipping of logistical distribution infrastructure (LDCs) for fruit and vegetables: ‘ They are innovative integrated projects for agriculture, energy and food production, in line with the draft 2030 low-carbon development strategy of the Republic of Croatia up to 2050 of March 2020. The built LDCs will be using renewable energy sources, and aimed at the actual expression of the carbon dioxide and greenhouse gas emission reductions (GHG) footprints will be set out in planning documents for the construction of storage capacities’. Similar statements could be used, as inspiration, to describe the agricultural products’ processing investments under this intervention.

Introduction of a list of negative activities should be considered.

Investments in improvements of existing irrigation installations/ infrastructure are expected to contribute to SO5. Investments in “new irrigation” would rather be linked to SO2.

NB that investments in the modernisation of existing irrigation installations (to make them more efficient) can count towards the 35% ring-fencing for env & climate under EAFRD. Investments in new irrigation installations cannot be counted towards the ringfencing.

Under “Eligible projects” the “construction and equipping of a public irrigation system” is mentioned – this seems to imply that this intervention is about supporting investments in new irrigation infrastructure. Can you confirm?

Does the intervention also cover investments in the modernisation of existing irrigation infrastructure? (if so the CAP Plan will need to indicate a) potential water savings (if the water body is not under stress) and/ or b) an effective reduction in water use (where water body/ies affected by the investment has less than good quantitative status), expressed as a percentage(s).

The intervention is linked to R.27 (Environmental or climate-related performance by investing in rural areas: Number of operations contributing to environmental sustainability, climate change mitigation and adaptation in rural areas). It is problematic to use this indicator for new irrigation infrastructure since this is linked to competitiveness rather than environmental objectives. Will the infrastructure be used exclusively for irrigation? If so R9 (farm modernisation) could be used for public irrigation infrastructure (if only farmers benefit)

The eligibility conditions have to reflect all provisions of art 68a [74]. Investments resulting in a “net increase of the irrigated area” are only eligible if: (a) the status of the water body has not been identified as less than good in the relevant river basin management plan for reasons related to water quantity; AND (b) an environmental impact analysis shows that there will be no significant negative environmental impact from the investment.

It is  stated that irrigation investment will not be eligible if water body is not in good status – this is good and as required under Article 68(a) on investments in irrigation. However under the section on ‘minimum water saving requirements’ it does not give a figure – please add this as there should be water savings as a result of the investment. Please also specify if this investment results in an increase in the irrigated area and please provide details – is this new irrigation or modernisation of existing irrigation? The current situation regarding irrigation and irrigated area/irrigable area should be included in the SWOT also along with water status under the WFD. Also the use of treated wastewater should be considered as an alternative supply of water for irrigation – has this been considered? Is this appropriate for here? Please add information on this. In assessment of 2nd RBMP a recommendation was given to HR to ‘ensure abstraction controls are in place and that information on uses, water exploitation and trends is collected and reported’. Information on water exploitation trends should be added to SWOT.

An important linked provision in conditionality with regard to water use/irrigation is the new SMR1 (on WFD, which requires controls / permits for abstraction to be in place). These controls (which MS may update in their 3rd River Basin Management Plan – due Dec 2021) should be designed to ensure that abstraction levels are consistent with WFD objectives – a revision of such permits and the allocation for farmers may  be needed in certain areas (especially in areas with a high Water Exploitation Index (WEI+).

The description of this intervention looks very similar to the existing M07 of the current RDP 2014-2020. To ensure bigger environmental ambition of the CAP SP, HR could include investments related to climate mitigation and adaptation under this intervention (e.g. sustainable rainwater management, collection and storage of rain and melting waters, etc.).

What about territorial targeting (based on e.g. Development Index)?

Please indicate the link with ‘Smart Villages’ concept and possibly include investments under it in the eligibility conditions for this intervention. Please indicate the link with Broadband investments supported under other national and EU schemes. To this end, please indicate (in the proper section of the SP) the link with digitalization of public services and the establishment of e-Agriculture to be implemented under the Croatian RRP and the role that the regional and local authorities will be playing in the implementation of the RRP reforms and investments. How could this digitalization processes facilitate living conditions and business environment for inhabitants/ entrepreneurs of those regional and local authorities?

Croatia is invited to consult the tool on installation of young farmers and rural businesses as published on CIRCA

https://circabc.europa.eu/ui/group/eee95e91-908e-46ae-a186-ef44626bef5e/library/fc14e656-d084-48a8-b9dd-dc8d6691f57d/details

Introduction of a list of negative activities / investments should be considered.

Croatia is invited to consult the tool on installation of young farmers and rural businesses as published on CIRCA

https://circabc.europa.eu/ui/group/eee95e91-908e-46ae-a186-ef44626bef5e/library/fc14e656-d084-48a8-b9dd-dc8d6691f57d/details

The proposed intervention seems to be a copy of M03 of the current RDP which has difficulties in attracting farmers – the current uptake at the level of 2.6% as compared to 38.5% of EU average. Therefore, based on lessons learnt, various approaches to boosting farmers’ interest / more efficient promotion / better advisory and KT activities from local NGOs, private advisors, etc. should be considered.

Boxes 1 and 2 of 5.3.8 must be completed.

Please explain how it will be ensured that innovation support captures grassroots innovative ideas and develop them into innovation projects of EIP Operational Groups.

Justification is needed for the choice regarding the minimum number of partners (7).

Description of the intervention is missing.

Boxes 1, 2 and 3 of 5.3.8 must be completed. Must be State aid cleared under the ABER (or the GBER) or under the AGRI Guidelines for non-agricultural activities.

M09 of the current RDP has difficulties in attracting farmers – the financial uptake remains at the level of 15.3% of the committed 5.6 million EUR (as compared with 47% of EU average).Therefore, based on lessons learnt, approaches to boost bigger interest from farmers  / more efficient promotion / better advisory and accompaniment activities from professional authorities, local NGOs, advisors, etc. should be considered.

Please indicate the link (under the respective SP section) with investments to be supported under other national and EU schemes, namely the RRP component ‘Construction and equipment of distribution centres for fruits and vegetables’ (Logistic Distribution Centres for storage capacity for fruit and vegetables).

To increase ambition of the SP more targeting could be introduced with regard to climate mitigation and adaptation, innovation and digitalisation aspects, etc.

Croatia is invited to consult the LEADER tool as published on CIRCA on 4 November: https://circabc.europa.eu/ui/group/eee95e91-908e-46ae-a186-ef44626bef5e/library/9cea5856-6ab1-4c0b-91e7-27efd2a4b620

Key points :

1)    Please describe how each of the seven features of LEADER/CLLD approach will be met by every LAG (Art. 31 of CPR)

–          Focus on subregional areas – (it is described but please put in the structure);

–          Partnership – how to make sure that all interests are represented (incl. civil society, public, private, environmental, women, young people, disadvantaged groups etc.) with no single interest group in control?

–          Integrated strategies – links between actors and sectors, multi-sectoral – what can the strategies cover? (any broad themes? / any exclusions? – this can be described also separately under operations)

–          Innovation at the local level

–          Cooperation

–          Networking

What are the selection criteria for LDS?

2)    Scope of Intervention:

–          Implementation of operations, including cooperation activities and their preparation;

–          The management, monitoring and evaluation of the strategy and its animation.

Please note that cooperation is now included in the LDSs (including selection)

What can the LDS cover? (any broad themes/any exclusions?) – please keep in mind both the budgets available and the added value of projects.

Please ensure that there is enough room for animation, capacity building and smaller community projects.

Will LAGs in Croatia cover: digitalisation, green transformation, Smart Village approaches, social innovation, capacity building and animation?

There is an explicit mention of start-ups – (albeit under the wrong heading) – is this obligatory in the strategies?

3)    Delivery mechanisms

Please clarify the tasks of LAGs.

How will you make sure that LAGs have sufficient resources for animation / capacity building (as their core function)?

Please briefly describe functions of MA / PA and coordination mechanisms with LAGs.

4)    Unit amounts

Generally, there should be average unit amounts per output (notably per Local Development Strategy) – what is the average unit amount foreseen?

Generally, LDS get different amounts

How many LDS do you plan to select (output indicator)

5)    Added value

Please see the Tool for more guidance

–          Social capital

–          Local governance – will LEADER ensure animation / help to beneficiaries / communication plan?

–          Unique/better project quality compared with non LEADER delivery – how will this be ensured?

In the current programming period, the LAGs’ role, in practice, is reduced to selecting projects within the calls published by the PA and carrying out some administrative checks, which are then repeated by the PA. This set-up places an unnecessarily heavy administrative burden on both the authorities and the LAGs, thus slowing down the implementation and dragging away LAGs from animation, which should be one of their core task. More importantly, however, it raises questions about the purpose, effectiveness and efficiency of LEADER support via the RDP.

The current system undermines the relevance of the local development strategy and of the LAG itself. It leaves virtually no space for bottom-up definition of responses to local problems and hinders any integration of development actions. The very objective of building communities’ capacity, fostering their involvement and enabling them to be the driving force in transition towards more sustainable future is thus neglected.

Most of the success of LEADER/CLLD lies in the way the delivery mechanisms are defined in the programme. The more flexibility offered to the LAGs, the bigger scope for LEADER to deliver its full potential. There seems to be a huge difference in the implementation model between LEADER under the current RDP and fisheries CLLD in Croatia, with the fisheries LAGs being able to work freely along the LEADER principles and the LEADER ones functioning similar to decentralised rural development grants offices.

In addition, LAGs, because of their non-profit nature, remain financially vulnerable. Obtaining banking guarantees from commercial banks, required for payment of advances for the running costs and animation, remains a challenge. Without adequate national action to address this issue there is a risk of a gap in the functioning of the LAGs entailing loss of specialised staff and community involvement.

Please explain the focus the LEADER strategy on social aspects and whether LEADER would also be used to support projects related to sustainable and resilient food systems and a sustainable bio-economy.

This intervention will be carried out by the Directorate for Expert Support for the Development of Agriculture and Fisheries of the Ministry of Agriculture. There is no information on better integration of independent private advisors and / or NGOs, as recommended by the Commission.

Advice must be made available on the elements listed in SPR Art 13(2) and (4). Could HR explain if the following areas will be covered by advisory services offered to HR farmers and processors: the Water Framework Directive, the Nature Directives (Birds and Habitats), the Clean Air Directive, the Net Emission Ceiling Directive, Art 55 of the Plant Health Law, the Animal Health Law, the elements of the Sustainable use of pesticides Directive (SUD) which are not included into conditionality and in particular the voluntary practices under Integrated Pest Management (IPM); the use of Financial Instruments,  farm practices preventing the antimicrobial resistance (AMR);  risk management; innovation support in particular for preparing and implementing the Operational Groups under the EIP-AGRI, the development of digital technologies in agriculture and rural areas?

More information is need on the ‘support demonstration activities to demonstrate in practice the application of state-of-the-art technologies, sustainable and innovative practices in the agricultural sector, enabling knowledge sharing’. Where / in which location those demonstration projects will be implemented, by whom, any targeting with regard to sector / types of production, etc.?

As for SCO (art 77) unit amounts for different categories of support should be provided for respective training modules, i.e. remuneration expressed in man-hours for stationary lectures, workshops, farm visits, demonstration projects + additional costs such as accommodation and per diems for training participants, unit cost of training materials, exams, etc. Please provide the methodology of calculation of the above unit costs and the independent bodies that have performed them.

What about digital-related needs? These clearly emerge from the SWOT for SO5 (“low level of education of farmers in digitalisation & innovation”).

Boxes 1, 2 and 3 of 5.3.8 must be completed. Must be State aid cleared under the ABER (or the GBER) or under the AGRI Guidelines for non-agricultural activities.

This intervention will be carried out by the Directorate for Expert Support for the Development of Agriculture and Fisheries of the Ministry of Agriculture. There is no information on better integration of independent private advisors, NGOs, as recommended by the Commission.

Private advisors and local NGOs often have deeper knowledge of local conditions and are already in close contact with farmers, foresters and processors.

Please indicate (in the proper section of the SP) the link of this intervention with digitalization of public services and the establishment of e-Agriculture to be implemented under the Croatian RRP. This RRP component aims ‘to provide up-to-date, structured and timely information directly from fields and farms, which, combined with adequate professional support, allows a proper decision-making’. How will the Smart Agriculture Platform including various agro-data support the provision of advisory services under this intervention?

How will the digitalization processes programmed under RRP would facilitate / rationalize production decisions of farmers (e.g. smart farming), improve marketing of agricultural products, result in more efficient use of natural resources, etc.?

Links with the needs analysis and AKIS strategy to be established.

What about support for private advisors?

The description of the intervention should detail how it will help address the Commission recommendation to increase resilience to climate change, inter alia, through awareness raising.

Boxes 1, 2 and 3 of 5.3.8 must be completed Must be State aid cleared under the ABER (or the GBER) or under the AGRI Guidelines for non-agricultural activities.

A breakdown of the allocation by year is missing, as well as information on your intention to use the flexibility provisions to transfer funds between the first and the second pillar. This breakdown is required to verify the various ring-fencing requirements as those are calculated on allocations after possible transfers.  Related comments are therefore not included at this stage.  It should be noted that no rounding up will be accepted for such calculation.

Based on information available in your draft Plan:

·        Wine: the draft plan includes an allocation for 5 years, whereas only financial years (FY) 2024-2027 are to be included. FY 2028 allocations will fall under the next Multiannual Financial Framework. Consequently, the indicated allocations for the wine sector exceed the maximum financial allocation for the 4 financial years (the maximum possible allocation is 4*EUR 10.410.000= EUR 41.640.000). However, planned amounts MUST be indicated per FY and not only the total amount for the whole period under the CSP has to be provided. Consequently, also the total amount indicated for the sectoral interventions and the further total amounts are not correct.

·         Apiculture: the indicated allocation corresponds to the maximum financial allocation for the 5 financial years concerned. However, planned amounts MUST be indicated per FY and not only the total amount for the whole period under the CSP has to be provided.

·         Fruit & vegetables sector: planned amounts MUST be indicated per FY and not only the total amount for the whole period under the CSP has to be provided.

·         EAFRD: The contribution rate for the interventions under Rural Development is missing

HR is requested to:

–       Submit financial tables based on the templates annexed to the SFC guidance (Member State allocations, transfers overview and ring-fencing requirements; more detailed financial allocations, planned outputs, and planned unit amounts per intervention per FY)

It is not clear if the MS refers to the monitoring and performance reporting system, which should be in place as of 1.1.2023 or to the AMS. In any case, both systems should be in place by 1.1.2023.

This chapter indicates, inter alia, that ‘The monitoring committee shall adopt its rules of procedure, which shall include provisions on the prevention of conflicts of interest and the application of the principle of transparency’.

During the Monitoring Committee session for the current HR RDP, a list of members for the future MC for the HR CAP SP was briefly presented to the participants. It also ignited a strong written reaction from one of the MC members representing the environmental and nature stakeholders pointing at, inter alia,  the underrepresentation of civil society NGOs in the future MC, possible conflict of interest, etc. Therefore, the HR authorities are requested to ensure that the three groups of stakeholders (public, private and civil society) are equally represented.

HR  to elaborate on the penalty system as part of IACS, demonstrate how general requirements HZR are met, for example MS can show how penalties are proportionate and graduated for ex by listing different penalty scales or grids applied and explaining how principles of severity, extent, duration and reoccurrence of non-compliance are incorporated. Instructions in SFC guidelines.

Based on the SWOT for the CCO (and the other SOs) and specific needs related to AKIS, this section should explain how foreseen interventions will work together. Actions implemented outside the scope of the CAP plan should be clearly identified (e.g. via RRP).

This section outlines the strategic approach for AKIS. The coherence of the proposed strategy with the SWOT and needs on the one hand, and foreseen interventions on the other, needs to be clarified. Reminder Article 78.5 “Member States shall ensure that actions supported under this type of intervention are based on, and are consistent with, the description of the AKIS provided in the CAP Strategic Plan in accordance with Article 114, point (a)(i)”.

Further, more explanation/clarity is needed about certain strategic elements such as: “learning systems”, “central information system in agriculture”, “public-private partnerships”,…

Reference to Innovation Support (Art. 15.4e) is missing (mandatory activity for advisors).

What role for the CAP Network and how will it be used to link researchers, advisers,…? Only few information provided.

Few details are given about private advisors & how they will be integrated in the AKIS (including aspects related to impartiality of advice).

Keeping a “business as usual” approach with respect to advice (both AKIS interventions on training and advice will be carried out mostly by the public advisory services) requires a good justification based on the requirements of Art. 15.

Digitalisation (8.1.5):

The overall structure, completeness and coherence of this section needs to be improved:

–       Summarise the needs stemming from the analysis, from the SWOT for the SOs and the CCO, and further input (e.g. DESIRA project) as appropriate with respect to digitalisation for agriculture and rural areas

–       Explain with what instruments the needs will be addressed (CAP – incl. RD. and sectoral measures as well as non-CAP, such as RRF investments) at least covering connectivity/broadband, skills, digital technologies.

The current text is very general and of a cross-sectoral nature: while is it good that the National digital Strategy is considered as one framing document, in the digitalisation strategy within the CAP SP, the specific approach to boost digitalisation in agriculture and rural areas is to be explained as well as how those ambitions will contribute to achieving other CAP objectives:

–       Be concrete on expected outcomes for the different interventions/activities.

–       As flagged under the previous section HR needs to demonstrate a higher coherence between SWOT analyses, needs and interventions (choice and design) when it comes to digital-related aspects. A number of needs identified (N04, N05, N21, N06) and elements emerging from the SWOT analyses for SOs (e.g. SO2, SO5, SO8, SO9) provide the basis for the intervention logic.

–       See comment under SO2: digital technologies only mentioned with respect to increasing productivity aspects. What about their contribution to environmental (and social) sustainability objectives?

–       Outline how digital divides between regions and types of businesses are avoided

8.2.1 Description of how technology and data can help simplify management and administration of the CAP (this information will need to be integrated in section 3.8 of the CAP plan – Simplification according to the latest SFC guidelines)

Overall comment: would need as much info, explanation as possible to understand the technology exploited and taken by MS for administrative simplification purposes, for example:

–       GSAA accelerates and facilitates entire claim and payment process while reducing errors: Encourage GSAA as prefilled as possible; several features for beneficiaries (on-line crosschecks with paying agency databases and instant warnings for potential non-compliances; can reduce errors in declarations and time PA need to do checks before payment).

–       Sentinel and remote inspection and monitoring tools: reduce burden on farmers and reduce time to carry out controls. Also geo-tagging could be part in future of remote controls; could allow clarifying fulfilment of eligibility conditions without need for OTSC. BUT technical capacity need be stepped up.

–       Integrated farm technology (to for ex transfer to applications), MS could seek opportunities to provide access to data where possible through cooperation with farmers, third parties and commercial companies to ensure farmers can obtain and integrate data into wider farm management solutions as cost-effectively as possible.

–       Alert system to notify farmers (e-mail, sms etc.) when deadline approaches and possible non-compliances are detected.