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In order to demonstrate that the implementation of the action plan had been inadequate, the Commission made the following statements in recitals 3 to 7 of the contested decision: ‘(3) … A Commission audit carried out in March 2015 confirmed that significant deficiencies persisted as regards the implementation of the action plan. (4) Consequently, pursuant to the fourth subparagraph of Article 41(2) of Regulation … No 1306/2013, the Commission informed France by letter of 13 April 2015 of its intention to reduce or suspend the monthly payments if no additional information was received or if the additional information was not satisfactory. France replied by letter of 7 May 2015, indicating that corrective steps had been taken successfully with the aim of finalising the action plan in 2015. (5) The deficiencies referred to in the letter of 13 April 2015 concerned, inter alia, the manner in which France had established the pro-rata system to assess the maximum eligible area under permanent grassland in accordance with Article 10 of … Delegated Regulation … No 640/2014 …, which was not in compliance with the recommendations contained in the Commission’s guidelines and which presented significant risks in terms of management and control; determining the eligibility of certain types of areas, in particular those with a high density of trees and/or low-grade grazing resources, e.g. chestnut groves, bracken or parcels with a pro-rata lower than 50%; the manner in which France would be able to handle anomalies related, for example, to determining a pro-rata for the eligibility of permanent grassland and to establishing Ecological Focus Areas (EFA) as part of the greening process. In general, it was found that the action plan was still not being implemented on the grounds that the areas recorded in the LPIS did not all include a total maximum eligible area established in accordance with regulatory requirements. The French authorities were asked to address all the points set out in the letter before 16 October 2015. (6) All of the above factors, in particular the delays and shortcomings in updating and improving the LPIS in France, have in fact had significant negative consequences for the management of aid applications in respect of 2015, in particular as regards providing the beneficiary with the required information on the maximum eligible area and non-agricultural areas, including the EFAs. (7) A follow-up report sent by France on 9 October 2015 and a new audit carried out by the Commission during the week of 30 November 2015 concluded that there were still important delays as regards the administrative processing of the applications for aid, the notification to operators of the data from their statements, the calculation of eligible areas and of the EFAs, the handling of irregularities resulting from the administrative and on-the-spot checks, rapid field visits to assess the eligibility of permanent grassland and on-the-spot checks. These delays were subsequently confirmed by an audit carried out by the Commission from 11 to 15 April 2016. Therefore, the on-the-spot checks would not be finalised until July 2016 at the earliest, which affects their effectiveness and consequently also their useful effect, in particular in case of doubt as to the eligibility of areas or compliance with the requirements for the diversification of crops in the context of greening. This confirms that it will not be possible to achieve the objectives of the action plan in the immediate future, which, in turn, does not offer the reasonable assurance required for proper administration of the aid and for the legality and regularity of the payments in respect of the year 2015. Furthermore, these delays also affect the establishment of the definitive value of payment entitlements, which should have been set by 1 April 2016 at the latest, in accordance with Article 18 of … Delegated Regulation … No 639/2014 …, as well as the execution of the payments themselves. Payments should therefore be suspended.’