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Departament for European Afaiers – Government of Romania

Departament for European Afaiers – Government of Romania Twinning BG 2007/AG/09/UE TWL.

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Departament for European Afaiers – Government of Romania

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  1. Departament for European Afaiers – Government ofRomania Twinning BG 2007/AG/09/UE TWL Common Agricultural Policy and direct payment component implementation in RomaniaRESULTS OF SAPS AND CNDP IMPLEMENTATION IN ROMANIAAND OVERVIEW OF FUTURE DIRECT PAYMENT POLICYOPTIONDr. Cristu CHIRFOT – counsellor Sofia, 14 05 2010

  2. Organized tasks force groups In the context of the announced agricultural policy reforms • WG regarding Direct payments and CAP reform implementation – (Ministry of Agriculture and Rural Development, P.I.A.A. and Department for European • Affaires. Monitoring and improvingdirectpayment policy implementation, and defining the PAC componentpolicy of direct payments policy, after 2013. • WG regarding the elaboration of Romanian vision regarding thefuture of the Common Agricultural Policy after 2013 - M.A.R.D.,P.I.A.A., P.A.R.D. and D.A.E. (due to the agenda at the meetings areinvited Ministry of Foreign Affaires, Ministry of Public Finance, Ministry ofEnvironment, Ministry of economy, competitiveness and for of businessframework development (SME)). As principles tasks, is to define concretesolutions for increasing Romanian agriculture competitiveness by reflectingthe new political priorities of the European Union – economic growth, jobscreation, climate change and innovation. • Sub-group optimizing agricultural structure in RO • Sub group - Choosing the optimum SPSafter SAPS termination. • Sub Group – transformation of the agriculture into a viable economic sectorfor whole rural regions, based on multifunctional role of agriculture, supplierof public goods and economic-social contributions.

  3. FIRST PILLAR – DIRECT PAYMENTS POLICY SAPS IMPLEMENTATION 1. Single area payment scheme (SAPS) Romania decided to implement SAPS from 2007, after HC of CAP until 1 of January 2013 Legal basis: R 1782/2003, R 1973/2004, Reg. 796/2004, after HC CAP Regulation 73/2009, Reg. 1120/2009, Reg. 1121/2009. PIAA implements support measures for farmers financed from European Agricultural Guarantee Fund – EAGF as direct payment under SAPS and support measures financed from national budget as Complementary National Direct Payments – CNDP, other direct payments and state aids SAPS starts in 2007 – phasing in according art. 143a of 1782/2003 or art. 121 of Reg. 73/2009, as follows: • Community as constituted on 30 April 2004: 25 % in 2007, correspondent to the national ceiling 1782/2003 is 440, 63 M € 30 % in 2008, correspondent to the national ceiling 1782/2003 is 529, 55 M € 35 % in 2009, correspondent to the national ceiling of Regulation 73/2009 is 619,83 M € 40 % in 2010, correspondent ceiling of Regulation 73/2009 is 729,86 M €, SAPS financial package ROwill be of 700.424 thou euro, because of the decrease involved by the application of art. 68. The Allocation according to Art. 68 of R 73/2009, of maximal level 3,5% of annex VIII it was calculated 25 545 205 €, the calculation is done as an adaptation of the sectors corelated with the phasing in level and the 3,5% level for each of each SAPS – FEGA components/sectors. The quantum now is 80.36 €/ha than rather 83.29 how it could be if no art. 68 aplication was done. ↓ and 100 % as from 2016, Correspondent national ceilingsfrom art. Regulation 73/2009 is 1.780,40 M € 2. CNDP for vegetal and animal breeders sectors are authorized by the European Commission on annual basis.

  4. SAPS ELIGIBLE LAND • Eligibility of land - Art. 124, paragraph 1 of COUNCIL REGULATION (EC) No 73/2009 • For Bulgaria and Romania, the agricultural area under the single area payment scheme shall be the part of its utilized agricultural area which is maintained in good agricultural condition, whether or not in production, where appropriate adjusted in accordance with the objective and non-discriminatory criteria to be set by Bulgaria or Romania after approval by the Commission. For the purposes of this Title, “utilized agricultural area” shall mean the total area taken up by arable land, permanent grassland, permanent crops and kitchen gardens as established by the Commission for its statistical purposes. • According to annex VIII 1121/2009, the SAPS eligible land is 8 716 320 ha

  5. SAPS budgetary allocation according to article 40 national ceilings and the yearly fixation Regulations for the budgeting lines. These implementation Regulations of the R 1782/2003 and 73/2009 direct payments framework were: • Regulation 552/2007 establishing the maximum Community contribution to financing the work programs in the olive oil sector and fixing, for 2007, budgetary ceilings for the partial or optional implementation of the SPS andthe annual financial envelopes for the SAPS, provided for in Council Regulation (EC) 1782/2003 and amending that Regulation. • Regulation 674/2008 modifying Council Regulation (EC) No 1782/2003, Council Regulation (EC) No 247/2006 and establishing budgetary ceilings for 2008 for the partial or optional implementation of the Single Payment Scheme and the annual financial envelopes for the Single Area Payment Scheme provided for in Regulation (EC) No 1782/2003. • Regulation 889/2009 amending Council Regulation (EC) No 73/2009 and establishing budgetary ceilings for 2009 for the partial or optional implementation of the Single Payment Scheme, provided for in Council Regulation (EC) No 1782/2003, the annual financial envelopes for the Single Area Payment Scheme and the budgetary ceilings applicable to transitional payments for fruit and vegetables and for specific support, provided for in Regulation (EC) No 73/2009.

  6. In consequence of 2009 Regulation the SAPS amount is included as component of the amount of annex VIII, THE amounts of 619 883 thou euro is splits then at the reference area of 8716 thou ha as provided in annex XXI of Reg. 1973/2004 and results the SAPS quantum of 71.12 euro / ha. • So the amount for the year 2009 for Romania and Bulgaria are 619.883 thou euro, respective 289.797 thou euro.In annex VIII of Regulation 73/2009 isincluded the national ceilling which includes the SAPS component, indicative value, toghether with of all others direct payment components. (For RO – nationalceilling is indicated for the year 2010 a value of 623 399 thou euros, out of which we have to extract the direct aids reminded before, as follows: 3 653 thou euros for sugar, 869 thou euro for transitory tomatoes schema. • AMOUNTS PRESENTED IN THE EXCEL SHEET ATTACHED

  7. SAPS Eligible land is composed by the following crops • For the 2010 in the next draft regulation for budgetary lines fixation will have ta have included also a provision for MS options application of art. 68 from Reg 73/2009, in the Romanian Case the 2010 ceilling will be reduced with the 3.5% component valueing 25 million less in SAPS granting. • EXCELL SHEET. SAPS. The costare estimates of the N.I.A.E., based on costs and tariffes of 2007. Average costs are fixed to the level from 2007, data provided by National Institute of the Economics in Agriculture.

  8. Main challenges faced in implementation the Direct Payments on area • Rural areas covers 87,1% of Romanian territory, we have 45,1% of RO population in rural areas (proxy. 9,7 million out of a total 21.7). Semi subsistence and subsistence agricultural holdings cover 45% of the UAA, representing 91% of the farm numbers. According to the National Institute of statistics, cca. 6 million hectares of agricultural land is utilized by 2 farms with sizes between 1 - 10 hectares, from which 3 million ha for about 1 million holdings with averages 2 – 5 hectares, and 1,2 million hectares in 800 thousand farms with sizes between 1 – 2 ha. • The Old population engaged in agriculture, over 52 % of rural population is over 50 years old, this conduct to difficulties in undersanding thw application format and reading of maps and corobortion with the ortofotoplansof IACS. APIA has in 209 over 5000 employees which applies the IACS. The limitted personell has to do (all the checks, administrative, on field/spot, by remote sensing, to digitize the area divided in so many parcells - in 2007 accounted up to 7.283.000parcels).

  9. Main challenges faced in implementation the Direct Payments on area • In informatics system of IACS, in 2007 have been registered 1.241.000 farms applications with 7.283.000 parcels, total declared area of 9.704.000 ha. All these conducted at a lattes the process. • APIA personnel has been trained, IT system updated and the whole structure was provided with informatics techniques and wired in intranet; for popper control on the spot it was provided a park of land vehicles and been constituted 70 mixed teams from the Offices of de Cadastral, and also were twining technical assistance from experienced all MS. In September 2007, APIA had 455 land cars, 583 cameras, 547 GPS, 576 roulette, 45 total stations. • Over declarations – due to over declarations we send request for clarification in 2007 for 450.000 applicants. We had meetings with cca. 434.000 farmers. Corrections done to 215.000 applications. Elaboration of corrections has been reintroduced in the data base, extra time for work.

  10. Measures of improvement of payment implementation taken by APIA • Preparation of APIA – endowments purchasing and trainings for the personnel, • Many information campaigns – on radio, TV, brochures. • As an imagine of managing payment dossiers in 2007 and 2008 payment campaigns

  11. Informative campaign of 2007 and 2008 SAPS implementation In 2007 were also printed 1.600.000 instructions for filling the SAPS application. The brochures includes also informations regarding cuprinzând potenţiale greşeli sau încercări de fraudare, modalitatea de evitare a acestora, precum şi sancţiunile aplicabile în aceste cazuri.

  12. Measures for improvement the payment implementation taken by APIA • Constant improvement of graphical materials provided for farmers, detailed maps with a the physical block, at a scales between 1:5000 – 1:10000, easier to underline the details from the lands, so farmers can draw correct their parcels for direct payments SAPS and CNDP on area. • Implementing the Lpisweb portal, for a wider access of visualization and identification of parcels for the farmers, system opened to public in 2008 payment campaign were involved local authorities as internet and space providers. Visualization of images can be done at different scales, and for a proper identification of the physical blocks, the farmers were counseled by ANCA – national advisory service, DADR – county agricultural directorates and PIAA employees. Lpisweb enables the measurement of the areas in order for the farmer to check the area identified on the ortophotoplan corresponds to the area registered in his documents: property act, tenure contract. • For 2009 payments was requested by PAIA the support of the National Agency for Cadastre ANCPI to provide cadastral maps in digital format at scales 1:5000 and 1:10000, to be lodedas special layer in LPIS, in order for farmers to can comparebetween Alfa-numericaldatasregistred in the property act, tenure contract, etc. • Overdeclaration of phisycal blocks– solving that problem is a complex proccess, involving many meetings with the farmers, which have been invited by notifications to APIA centers at local and county levels. Invination and meetiongs with farmers uising agricultural land in the respectives blocks, with prooviong documents for using the areas for which they requested SAPS. In order to solve overdeclaration PIAA did: sendedclariffication requests, invitations to farmersinvolved in over declaration of one phisycal blockl, in the same day and hour, carring with them in original, the documents provving the write to use the land). All these aspects spent a lot of time and administrative efforts.

  13. Applications starts in 1st of march till last day of May • The application for area payment is submitted by farmer and includes all areas schemes: -payment for SAPS, -payment for CNDP, for vegetal sector -payment for energy crops - separate sugar payment; -others schemes on area delegated from APDR measures of the Axa 2 of ruralpolicy, inserated in the National rural development plan, and transfered to be implemented by APIAwith competences in area payments. • The farmers have to register into Farmers register Solicitanţii trebuie să se înscrie în Registrul fermierilor • The deadline for application submit is 31 May

  14. Application • The eligibility conditions in accordance with Law no. 139/2007, Reg 73/2009 and 1782/2003: • eligible area of holding minimum 1 ha • eligible area of agricultural parcel minimum 0,3 ha, excepting vineyards, orchards, hops, nurseries, fruit shrubs -0,1 ha • obligations for good agricultural and environmental conditions shall be met. • The applications had been submitted: • For farmers with area holdings over 50ha to county subsidiaries of PIAA • For farmers with area holdings under 50ha to local centres of PIAA • The data on payment schemes included in applications are inserted in Data base and are processing according to IACS regulations .

  15. CROSS COMPLIANCE ELEMENTS OF SAPS IMPLEMENTATION - GAECs • In Romania GAECs have been defined by common Order of the minister of agriculture and the minister of environment:For 2007: Order 791-1381 of 2006. From 1st January 2008: Order 15-56 of 2008 GAEC requirements applied in Romania updated in 2009, as follows: • I. Standards to avoid soil erosion: • GAEC 1. During winter, the arable land must be covered with autumn crops and/or must be left un-worked after harvesting on at least 20% of the holding’s total arable area. • GAEC 2. During winter, the arable land must be covered with autumn crops and/or must be left un-worked after harvesting on at least 20% of the holding’s total arable area • GAEC 3. The terraces existing on agricultural land on the 1st of January 2007 shall be maintained • II. Standards for the maintenance of the optimum content of organic matter into the soil, by the application of certain adequate agricultural practices: • GAEC 4. Sunflower shall not be cultivated on the same parcel for more that 2 consecutive years. • GAEC 5. The burning of stubbles and vegetal remains on arable lands is allowed only with the prior approval of the competent environment protection authority.

  16. GAEC requirements applied in Romania in 2009 III. Standards for the maintenance of soil structure: • GAEC 6. The arable land with a slope above 12%, cultivated with row-plants, shall be worked along the level curves. IV. Standards for the maintenance of a minimum level of upkeeping for agriculturallands: • GAEC 7. Permanent grasslands shall be maintained by ensuring a minimum grazing level or by mowing at least once per year. • GAEC 8. The burning of permanent pastures is allowed only with the prior approval of the competent environment protection authority. • GAEC 9. The cutting of single trees and/or of the groups of trees on agricultural lands is forbidden. • GAEC 10. Avoiding the encroachment of unwanted vegetation on agricultural lands, including on the lands not anymore used for production. • V. Standards for the maintenance of the existing area covered with permanent pastures: • GAEC 11. Maintaining the area covered with permanent pastures existing at national level on 1st January 2007.

  17. SAPS implementation Results

  18. Verification of GAEC compliance • The control of the good agricultural and environment conditions is carried out by the on - the - spot Control Directorate within the Paying and Intervention Agency for Agriculture on the basis of the general rules concerning cross-compliance, stipulated in the (EC) Regulation no 796/2004 and from 2010 will be aplied new Health Check resulted control regulations R 1122/2009. • As regards the non-compliance with the GAEC, the following aspects shall be taken into account: repetition of non-compliance, its extent, severity and permanence. • The control report shall comprise a summary of the non-compliance significance as concerns each of the respective requirements and/or standards, on the basis of the “severity”, “extent”, “persistence” and “repetition” criteria, according to art. 24 of the (EC) Regulation no 73/2009, by mentioning the factors that may determine the decrease or the increase of the reduction to be applied. • Where provisions relating to the requirement or standard in question leave a tolerance margin not to further pursue the non-compliance found, the report shall make a corresponding indication.

  19. SAPS implementation Results • In 2007 PIAA registered 1.241.751 SAPS application, for an area of 9704 thou ha, from the total number of holdings 911 000 holdings have an area up to 5 hectares. • Year 2007 as the first year of application of SAPS, has been an engraved year due to human experience and informatics system maturity. • According to European legislation, for managing the communitarian funds and control of application it is mandatory a sound utilization of the IACS. This system assures the compliance with the security requests and avoiding the frauds premises, but requires specialized personnel, sound technical endowments (computers, software). • According to the legislation (RO and EU) the farmers has to declare all area used and to underlined correct the agricultural parcels, assuming the responsibility of declaration by singing the application. • As problems in implementation, the big volume of requests and overdacalartion of physical blocs. The payment authorization started in March 2008, and by June 2008 has been done daily, in average 2000 payment orders per day. • In consequence APIA managed at 30 June 2008 to authorized payments for 1 182 757 farmers in value of 386.995.606 euro FEGA, out of which paid effectively from FEGA 379 799 880 euros.

  20. SAPS implementation Results • In 2007 PIAA registered 1.241.751 SAPS application, for an area of 9704 thou ha, from the total number of holdings 911 000 holdings have an area up to 5 hectares. • Year 2007 as the first year of application of SAPS, has been an engraved year due to human experience and informatics system maturity. • According to European legislation, for managing the communitarian funds and control of application it is mandatory a sound utilization of the IACS. This system assures the compliance with the security requests and avoiding the frauds premises, but requires specialized personnel, sound technical endowments (computers, software). • According to the legislation (RO and EU) the farmers has to declare all area used and to underlined correct the agricultural parcels, assuming the responsibility of declaration by singing the application. • As problems in implementation, the big volume of requests and overdacalartion of physical blocs. The payment authorization started in March 2008, and by June 2008 has been done daily, in average 2000 payment orders per day. • In consequence APIA managed at 30 June 2008 to authorized payments for 1 182 757 farmers in value of 386.995.606 euro FEGA, out of which paid effectively from FEGA 379 799 880 euros.

  21. SAPS implementation Results • For 2008 campaign APIA managed to pay until 30 of June 2009, 93.63% from the FEGA SAPS ceiling of 529 million euros, PIAA paid to 1 018 102 farmers, from 1 130 207 SAPS applicants. As a problem to mention for 5300 farmers have been draw negative payment decisions and 21900, or so farmers did not comply with the eligibility criteria, area requested being under the limit of one hectare. • As a progress from 2007 the farmers with under payment limit or negative payment decision decreased with 42%.

  22. SAPS implementation Results • In 2009 according to art. 1 of EC Reg. 691/2009, starting 16 of October 2009, Romania choose as other Member states to pay in advance up to 70% from the payment level, with condition of finalization of checking the eligibility criteria in accordance with provision of article 20 of R 73/2009. • AS problem to mention – the control by teledetection should to be tackled. New orthophotoplanes, is a renewing of images on course in order to respect LPIS requirements. • Thefully operative implementation of the portal Lpisweb for land used parcel identification, more than 200.000 farmers used succesfuly the system, up to 10 of may have been vizualised around 2,3 million hectars.

  23. Complementary National Direct Payments

  24. Principles of the decoupled aggregate CNDP payment on area for vegetal sector in Romania • The available national budget for granting to the Romanian farmers a decoupled aggregate CNDP on area for the vegetal sector: Allocation of the CNDP on area An decopled Aggregate envelopeauthorized yearly by EC DG AGRI Decoupled Aggregate for CNDP on SAPS eligible area, Area for CNDP on Eligible SAPS Area – with the exemption of permanent crops and of permanent pastures. The Area for which is granted is 6 174 993 ha. • Specific eligibility condition for CNDP Aggregate • The eligible area for the CNDP payment on area is the eligible SAPS land, with the exemption of permanent crops and permanent pastures in amount of 6,174,993 ha.

  25. Principles of the decoupled aggregate CNDP payment on area for vegetal sector in Romania • The aid will be approved for any farmer who: • - Applies for the aid under the Single Area Payment Scheme (SAPS) and submits an application to the Local Centre of PIAA until 15 May 2010; • - Complies with the SAPS requirements, respectively: • - Holding area of 1 ha and agricultural parcel area of 0.3 ha; • - Compliance with the Good Agricultural and Environment Conditions – GAEC, in accordance with the annex 3 of Council Regulation (EC) 73/2009 and the MARD’s Order no. 791/2006; • The aid for arable land will be granted as follows: the SAPS rate of 80.24 € / ha and in addition the decoupled CNDP on area in amount of 82.94 € per ha

  26. Vegetal CNDP results

  27. Aggregate bovine scheme – decoupled CNDPs for bovines • The total envelope is calculated in accordance with the provisions of Council Regulation (EC) No. 1782/2003 and Council Regulation (EC) No. 73/2009, the number of heads, the national reference quantity and the areas included in the Accession Treaty. The total financial package allowed for this envelope is calculated as the result of the summing up of: • ANIMAL SLAUGHTERING PREMIUM – Article 130 - Regulation (EC) No. 1782/2003/ Art.116 Regulation (EC) 73/2009 • SPECIAL PREMIUM FOR BOVINES – Article 123 - Regulation (EC) No. 1782/2003/ Art 110 Regulation (EC) No. 73/2009 • EXTENSIFICATION PREMIUM – Article 132 - Regulation (EC) No. 1782/2003 • SUCKLER COWS PREMIUM – Article 125 - Regulation (EC) No. 1782/2003/ Art. 111 Regulation (EC) No. 73/2009 • DAIRY PREMIUM – Article 95 - Regulation (EC) No.1782/2003 + Additional milk products premium • Area additional payments in accordance with the EU Accession Treaty for Romania and Bulgaria and the Article 133 of Regulation (CE) No 1782/2003 – the total amount (100%) is 856 260 €, from which 90% represent 772.430 €.

  28. The total package was calculated in accordance with the Accession Treaty of Bulgaria and Romania to the European Union and in line with the European legislation. • For the schemes above mentioned we applied a 90% in 2010 tof the the EU 15 levels of support, and a 100 % in the case of the dairy premium and additional dairy payment. From the amounts for each scheme we deducted the SAPS amount resulted for the forage area of the animals under the above mentioned schemes (article 131- stocking density – in accordance with the Regulation EC 1782/2003) and also it was deducted the adaptation of the sector amount due to implementation of art. 68 of Regulation 73/2009 decided by Romania for year 2010. • The aggregate package, in compliance with the article 143 c (2) Regulation (EC) No 1782/2003/ article 132 (2) of Regulation (EC) No 73/2009. • Bearing in mind the budgetary calculations, the animal sector structure and the strategy for the development of the semi-subsistence sector, the Romanian Government reached the decision of granting a bovine flat rate.

  29. Implementation of the aggregate bovine scheme • Flat rate payment • - The Paying and Intervention Agency for Agriculture (PIAA) makes the payments to the farmers. • - The bovine scheme per farm is decoupled. • - The farmer will have to submit an application between 19th of April to 31st of May 2010; the application should include the farm code. • - The farmer can make only one application for the livestock registered in the NRE[1], [1] NRE – National Register of Exploitations (farms). • - Newcomers: are in principle new farmers commencing the agricultural activity, in the field of animal breeding (the meaning of Article 2(l) of Commission Regulation 1120/2009). • - Minimum livestock per farm of bovines is 3 heads. • - The bovine age is minimum 6 months. • - The farmer is defined in accordance with the provision of Art. 2 of (EC) Regulation 73/2009 / Art. 2 of (EC) Regulation 1782/2003.

  30. CNDP sheep and goats • Sheep and goats - Article 113 – and Article 114 Supplementary - of (EC) Council Regulation No. 1782/2003 – and additional payment amount stipulated in the Accession Treaty of Bulgaria and Romania to the European Union. • Total specific financial envelope according to art. 132 (2) of EC Regulation 73/2009 iscoupled. • Payment: 14 €/head; • In the case of overtaking of the financial package will applied a reduction coefficient, by the Paying Agency. • Eligibility Criteria • - The farmer has to register and identify the animals in the NRE, in accordance with the National Order 83/2008 of the National Sanitary Veterinary and for Food Safety Authority until 31st of March 2010. The animals are identified and registered in accordance with EC Reg. 21/2004 (National System of Identification and Registration of Animals). • - The farms need to have minimum 25 goats or minimum 50 ewes. • - The sheep and goats are defined in accordance with the Art. 100 of EC Regulation 73/2009.

  31. SAPS TO SPS • Calendar of application 1 of January 2014 onwards • First of all by analysing the structure of impelemntation of the direct payments in Romania and the granting posibility for farmers for the national ceilling provided at art. 40 of Regulation 73/2009 we can choose for the right SPS framework. • In 2007-2009 SAPS – granted more than 1.1 million farmers for an area of average 8.44 million hectares, out of 8,716 ha eligibles in the Regulations. • The main serious farmers were from the fields of agricultural production, big crops and the other crops. Nott all the greass lands, speically the comunal ones are not very well represented by farmers. I have also identify many fallow lands, wich is more in the sector of the definition of land not used, on which is no agricultural activity performed. • In that concern we can think of using article 61 and allocate a smaller support for these type of lands, in order to have a bigger margin of allocation for the lands on which is better abd actually performed agriculture. • Further analysys on these lands and farmers using grass lands. Romania can set special objective criteria for granting funds from the national ceilling for grass lands. • Animal sector is well represented by farmers, which have respected the requests for CNDP decoupled on bovines and the coupled support for sheep and goats. • The issue raised by this sector is the “farmers with no land”, they have numerous livestock which not corresponding to the number of hectars or not at all, for sheep and goats farms. • For this situation – Reg 73/2009 and Reg 1121/2009 provides the possibility of granting special entitlements

  32. SAPS To SPS Reg 73 2009, in whch As special payment entitlements were allocated to farmers with so-called ‘landless’ holdings, the application of the hectare-based. Art. Article 60 Farmers with no eligible hectares - A farmer acting in the beef and veal sector, dairy sector or sheepmeat and goatmeat sector who is entitled to receive payment entitlements in accordance with Article 57(3) and Article 59 for which he does not have eligible hectares in the first year of implementation of the single payment scheme shall be allocated special entitlements, not exceeding EUR 5 000 per entitlement, as referred to in Article 44. And art. Article 14 Calculation of livestock units for special entitlements1. For the purposes of Article 44(2)(a) of Regulation (EC) No 73/2009, the agricultural activity carried out in the reference period expressed in livestock units (LU) shall be the one which was calculated in accordance with Article 30 of Regulation (EC) No 795/2004. Discussion on the attached Excel Doc.

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