11 November 1998

Dear Mr. Sjostedt

The European Commission is currently discussing a proposal for an EU Forestry Strategy for the European Union. We managed to obtain a draft that is extremely worrisome. Time is short, as it is intended that the Commission adopt the Strategy on November 18, and the Council on November 23-24. Although we have not seen the latest draft (since it is in the process of being re-written), several general aspects of the strategy have given us cause for considerable concern.

We hope that the version we have seen will not become definitive and we would ask for your help in lobbying the EC Cabinets to make sure key environmental issues are included (the individual in charge in Commissioner Bjerregaard’s Cabinet is Mr. Rasmus Kjeldahl). We would also suggest that we assist each other in obtaining a current draft of the Forestry Strategy.

We are extremely concerned about the legal form of the document and the lack of participation in its elaboration. The procedural context of the EU Forestry Strategy is extremely unclear, and has remained cloaked in secrecy. As a consequence, transparency, and public ­ and indeed, Parliamentary ­ participation are flouted. We are extremely concerned that the Strategy, a document of uncertain legal value that is “adopted” without the input of Parliament or concerned NGOs, will nonetheless become a point of reference for decision-makers dealing with all types of forest issues.

The draft EU Forest Strategy that we have seen does not set the context by firmly acknowledging the full spectrum of existing legal instruments applicable to forests. This includes, among other things, international obligations flowing from the UNCED Conventions on Biological Diversity and on Climate Change. Within the EC Treaty, the general requirement to integrate environmental protection requirements into the definition and implementation of other Community policies provides a logical starting point; more specifically the Agriculture and Environment Titles are directly relevant. Finally, attention has not been given to applicable secondary legislation, and specifically the Habitats Directive

The Strategy also fails to address the EU Biodiversity Strategy and the EP Biodiversity Resolution. We draw your attention to the fact that the Biodiversity Strategy states that its forest objectives will be dealt with in the EU Forestry Strategy: no separate forest action plan will be developed, and therefore the text of the proposed EU Forestry Strategy is crucial in terms of conservation of biodiversity in forests. In short, nothing in the draft we have seen will further the objectives of the Community’s Biodiversity Strategy. In this regard, we support the European Parliament’s Resolution on the Biodiversity Strategy(A4-0347/98). Notably, at point 9, the European Parliament “Maintains that protected areas offer insufficient protection for biological diversity and stresses that the Community’s other areas of policy must integrate biodiversity conservation issues; considers that the link between the Community’s nature conservation and agricultural policies is particularly inadequate.”

Balanced consideration is not given to the multiple functions of forests. Much more than mere sources of timber and other forest products, the role of forests as strongholds of biodiversity, as carbon sinks, in maintaining soil and water quality, et cetera, must also be reflected in the Strategy. Consequently, the Strategy must also adequately address the requirements summed up in the UNCED Forest Principle’s formulation “management, conservation and sustainable development”.

The world’s remaining primary forests are under severe threat and continue to disappear at unacceptable rates. At present, the EU Strategy fails to devise means of protecting not only the few remaining sections of primary forests within the EU (i.e., mainly French Guyana, Finland and Sweden) but also the larger areas in third countries that continue to be affected by EU trade and aid relations.

The underlying causes of forest degradation and deforestation and their true costs are not dealt with in the draft EU Forest Strategy we examined: these include intensive forest exploitation, forest fragmentation, industrial/atmospheric pollution, widespread illegal logging in CEEC, ACP and ALA countries, and the failure to develop economic means of properly valuing forests’ biological and genetic resources, and ecological and recreational services.

The Strategy fails to indicate means to address the deficiencies in practical implementation of binding legislation that serves a more protective purpose, namely the problems of designation of Special Protection Areas under the Habitats Directive, in order to establish an ecologically representative network of protected forest areas. This is especially relevant since the possibilities for EU funding for the Natura 2000 network have increased through Parliament voting on the budget.

As drafted, the EU Forest Strategy fails to acknowledge the fact that the FSC system is the only exiting credible operational certification system; instead it appears to endorse only the pan-European certification initiative, which has not yet proven to improve effectively forest management. In order to be credible to consumers and environmental organisations, a certification system must encompass two components: forest auditing, that is on-site inspection of forest management using quantitative and qualitative standards, and product certification incorporating chain-of-custody monitoring of a timber product from the forest to the consumer.

In relations with third countries, the EU Forest Strategy must envisage means of meeting its various obligations related to conservation and sustainable forest management through technology transfer and finance (e.g. under the Convention on Biological Diversity, the Lomé Convention and its Forest Protocol, Agenda 2000). The EU Strategy must propose steps to actively ascertain that such transfers are indeed used for conservation and sustainable management purposes.

Please do not hesitate to contact us if you need further information.

Best regards,

Saskia Ozinga and ChantalMarijnissen, Fern

Stefan Leiner; WWF European Policy Office

Christoph Thies and Nicole Gérard, Greenpeace International