7 February 2024

Within the EU and its Member States, many forest monitoring actions are already undertaken for many decades. Whether lead by national forest inventories (NFIs) or under international processes (e.g. Forest Europe, UNECE/FAO, ICP Forest), work on harmonisation and standardisation are already being carried. The question of a need of EU action and real added value of this proposal thus remains.


Based on real and concrete added value and clear objectives, a forest data collection at EU level should also specify data ownership, possible future interpretations, and uses to answer specific EU policy requirements.


While harmonisation of some forest data collection could be of use, the exact objective of the proposal must be further refined, clarified, and then made coherent with a review of relevant forest data. Indeed, we currently note strong discrepancies been the various objectives laid out in Article 1 and the forest data to be effectively collected according to Article 5 and 8, described further in Annexes I, II, III.


With regards to the Annexes I, II and III, the descriptions of the forest data present several oddities. They make reference to several non-binding or non-commonly agreed upon definitions or methodologies, making them binding, whereas these have not been designed nor developed with this intent. The frequencies in the descriptions are not always coherent with existing EU policy requirements or other relevant processes. Amending the Annexes by Delegated Acts would prevent adequate consultation and consent from Member States for crucial aspects of the legislation. This is especially striking in case of the additional forest data in Article 8. They are unnecessary at this stage and only add further confusion given their lack of description or methodologies.


For all aspects of the proposal, a strong governance will be needed to strengthen the direct links with NFIs and other processes (e.g. Forest Europe, UNECE/FAO, ICP Forest).


In the proposal, the financial aspects, and related risks for duplication of work and increased bureaucracy, linked to a qualitive data collection on forests are overlooked and barely addressed. Indeed, remote sensing data collection require a significant amount of work of validation, verification, and interpretation in close coordination with NFIs and relevant local forest experts. This work is essential to avoid large scale misinterpretation. Field data collection also require significant work from qualified experts, which seems underestimated within the proposal. A clear approach for adequate financing is dearly missed.


With regards to the forest data sharing framework in Article 7, we have strong concerns on the “open access” approach. Collected forest data, especially the spatially explicit ones, may include sensitive information of private property, private ownership, and competitive business-related information. Their adequate and overall protection needs to be addressed. Several of the foreseen forest data might in breach of individuals privacy rights and commercial confidentiality. In this regard, the minimum scale of the “forest unit” will be crucial, would this concept be used to publish data.

For quality control, Article 10, the Commission should not be empowered to adopt delegated acts for accuracy standard and rule on quality assessment. As required for the Member States, the Commission should take appropriate actions to assess the quality of the data it collect and remediate in case of deficiencies.

On Article 13 and the voluntary integrated long-term plans, we do not see their value in the frame of a legally binding instrument.