Dear President Santer,

We are writing to you to express our concern regarding the evolution of the European Union Forest Strategy. As you are aware, once adopted, this document will become the reference point for European Union work related to forests, and their management and conservation. Therefore, an even-handed approach to the complex issues surrounding forests must be chosen and extreme care taken in selecting priorities. We respectfully ask that you consider incorporating the following points.

1. An EU Forest Strategy must set the context by firmly acknowledging the existing legal framework 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 must be given to applicable secondary legislation, and specifically the Habitats Directive.

2. Balanced consideration must be 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 related to these various functions, frequently summed up in the UNCED Forest Principle’s formulation “management, conservation and sustainable development”. The Strategy must also address the forest objectives outlined in the Thomas Report and the EC Biodiversity Strategy.

3. The world’s remaining primary forests are under severe threat and continue to disappear at unacceptable rates. The EU Strategy must devote specific attention to this problem and 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.

4. The underlying causes of forest degradation and deforestation, and their true costs, must be dealt with in an EU Forest Strategy: these include intensive forest exploitation, forest fragmentation, industrial/atmospheric pollution, parasites and disease, forest fires, 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. In this regard the EEA is a source of data that must not be overlooked.

5. The unacceptable rate of forest degradation and deforestation illustrates that the EU Forest Strategy cannot rest content with existing EU measures. The Strategy must recognise the limited purpose of rules relating to forest fires and atmospheric pollution and the limitations of the proposed regulation on EAGGF support for rural development. The Strategy must also 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.

6. 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. Currently the FSC is the only forest certification system meeting these criteria.

7. 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 actively to ascertain that such transfers are indeed used for conservation and sustainable management purposes.

                                                                                                Yours sincerely,

Christoph Thies and Nicole Gérard, Greenpeace International

Saskia Ozinga and Chantal Marijnissen, Fern

Stefan Leiner, WWF