Preliminary NGO comments regarding the draft EU Forest Strategy

 

The European Commission has adopted a communication to the Council and the European Parliament on a Forestry Strategy for the European Union. The draft document is very worrisome in several respects, which include:

 

I. Procedure:

The procedural context of the EU Forestry Strategy is unclear and we are extremely concerned about the lack of participation in its elaboration. The Strategy, a document of uncertain legal value, will nonetheless become a point of reference for decision-makers dealing with all types of forest issues and must therefore be the result of a democratic and transparent procedure.

 

II. Substance:

a. Legal Framework:

The draft EU Forest Strategy generally fails to acknowledge the relevance of EU environmental competence in forest issues. That the existing legal framework applicable to forests includes international obligations flowing from the UNCED Conventions on Biological Diversity and on Climate Change is hardly recognised. 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 that is nonetheless never mentioned explicitly.

 

b. Priorities and objectives:

The Strategy fails to fulfil the objectives of the the EC Biodiversity Strategy and the EP Biodiversity Resolution (A4-0347/98), despite the fact that it was originally intended to give substance to the Biodiversity Strategy. Biodiversity objectives are now linked to an eventual review of unspecified "measures proposed by the Commisison in Agenda 2000" and, in particular, of the not-yet-adopted support for rural development proposal (draft p.22). The Commission proposals on Agenda 2000 do not include measures adequate to fulfil this purpose.

 

Moreover, throughout the document, the priorities are skewed towards rural development and exploitation; 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 appropriately reflected in the Strategy. Therefore the one-sided production focus (e.g. the foremost function of forests is considered to be their use as a regenerative source of timber and other products, at point I.2.) is not justifiable. Studies have demonstrated that, even in economic terms, the social and environmental functions of forests have a much higher value than production. In this respect, see for instance a recent general study of the economic consequences of timber exploitation by Janet Abramovitz, "Taking a Stand: Cultivating a New Relationship with the World’s Forests," Worldwatch Institute, 1998; for a study evaluating the economic value of forest functions in Switzerland, see Kissling-Naf, Grosser Wert und wenig Geld? ZfU 3/98, at pp.373-397.

c. Logical deficiencies and omissions:

Primary Forests: The world’s remaining primary forests, the richest terrestrial reservoirs of biodiversity, are under severe threat and continue to disappear at unacceptable rates. Yet the EU Forestry Strategy omits 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.

 

Establishing a network of fully protected areas: The EU Forestry Strategy fails to indicate means to address the deficiencies in practical implementation surrounding the designation of special protection areas under the Habitats Directive; this notoriously poorly implemented directive could be a crucial tool in establishing an ecologically representative network of fully protected forest areas. Such an omission is especially serious in light of the fact that the possibilities for EU funding for the Natura 2000 network have increased through Parliament voting on the budget.

 

Proposed v existing measures: The Strategy makes repeated reference to the proposed regulation on support for rural development, asserting on several occasions that this proposed regulation fulfils environmental functions that it simply does not. The logic behind reliance on this proposal cannot be upheld since, as a mere proposal, its eventual contents or even its adoption cannot be guaranteed. Nor does the draft Strategy explain why existing binding legislation such as the Habitats Directive is virtually ignored while this proposal is emphasised – including during the discussion of Biodiversity (section III.D.1).

 

Underlying causes of degradation/destruction: The draft Strategy fails to address the underlying causes of forest degradation and deforestation and their true costs, ignoring the findings of the EEA: "forest habitats are changing through intensification of management, increasing uniformity and fragmentation, widespread use of exotic species, introduction or maintenance of animal species for hunting, drainage and air pollution (acidification, eutrophication); EEA: Europe’s Environment – The Second Assessment (Dobris+3), pp.144, 163-164, 167-168, 174.

 

The failure to address underlying causes is particularly notable in the section on accession countries, where threats include uncontrolled privatisation, illegal logging, unsustainable infrastructural development, lack of biodiversity assessment and mapping. The proposed Council Regulation on Community support for pre-accession measures for agriculture and rural development in the accession countries is also inadequate in this respect, failing to propose concrete measures. Simply requiring the acquis communautaire to be adopted without substantial practical preparation measures could result in an increase in forest destruction.

 

The failure to develop economic means of properly valuing forests’ biological and genetic resources, and ecological and recreational services is a further underlying cause that is not addressed. Notably, the UNCED Forest Principles recommend the "comprehensive assessment of economic and non-economic values of forest goods and services and of the environmental costs and benefits" (Principle 6 c), and the "incorporation of environmental costs and benefits into market forces and mechanisms" (Principle 13 c).

 

Negative impact of EU policies: Furthermore, the EU Forestry Strategy does not mention – still less, discuss – the negative impact of certain existing EU forestry measures, such as the total landscape destruction in Ireland as a result of widespread sitka spruce monoculture plantation, promotion of unsustainable forest management, negative competition with agri-environmental measures, etc.

 

Restoration programme: The Strategy fails to propose a semi-natural forest restoration programme in order to reverse the continuing losses of old natural and semi-natural woodlands, loss of forest authenticity and biodiversity, losses of forest habitats such as riparian forests (see Dobris + 3).

 

Relations with third countries: 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 practical steps to ascertain actively that such transfers are indeed used for conservation and sustainable management and development purposes. It should be developed in simbiosis with the draft communication on tropical forest development cooperation and bioth documents should be present as at the same time as a whole. In this section there is a great need to focus on communities their needs and interactions with forest resources.

 

d. Coherence:

The draft strategy refers to "upcoming" communications on other important issues like development co-operation and industry, or proposes possible further action in future e.g. on biodiversity and certification. A truly holistic Strategy, as required by the EP Resolution (A4-0416/96) on the forest strategy Thomas Report) would imply the inclusion of these measures into one coherent EC strategy.

 

Likewise, while the EU Forestry Strategy gives some attention to the impact of forestry on other policies, it fails to explores the actual or potential impact EU activities outside forestry on forests (e.g. EC Acidification Strategy, a potential CO2 tax, infrastructural development, CAP, ...).

 

e. Certification:

The EU Forest Strategy must refrain from endorsing any system of certification that fails to achieve two objectives: it must improve forest management and ensure market access for certified wood products. 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. However, the draft EU Forest Strategy fails to acknowledge that the FSC is currently the only forest certification system meeting these criteria; instead it refers only the to pan-European certification initiative, which has not yet proven to improve effectively forest management.