As the work of the European Commission (EC) on the review of the EU Forest Strategy for 2030 (EUFS) is in progress, and ahead of the joint meeting organised by the EC on 10 December on this topic, the undersigned organisations, representing European forest owners and managers, would like to call for the review process to go beyond assessing progress towards objectives set in the past. It needs also to assess present relevance and usefulness of actions not yet implemented, and whether further actions are needed to maintain multifunctional and climate-resilient forests through sustainable and active forest management. This is essential for forest owners and managers to continue to manage their forests so that they provide timber and other renewable raw materials, protect biodiversity, support rural livelihoods and deliver wider benefits for society, today and in the future. The review should ensure this is duly enshrined in all the future actions and is included in the main objectives of the EUFS.
Current framework and implementation of the EUFS
When the EUFS was published in 2021, European forest owners and managers shared their strong concerns1 warning that the proposed Strategy was repeating other policies’ objectives and targets rather than responding to the actual forest and forestry needs. They regretted that it did not provide a framework for sufficient coordination among the EU and Member States' policies and priorities of EU forest owners and managers.
These considerations were due to the lack of reflection of ground realities, especially the unsatisfactory consideration of the economic viability of forest and forest-based sector. This, in turn, led to subsequent loss of focus on forest multifunctionality and on the overall competitiveness of the sector. Additionally, the EUFS did not carry out a complete assessment of cumulative impacts of the proposed actions to the forest and forest-based sector.
Four years later, these concerns remain. The unbalanced approach taken by the EUFS, being primarily anchored in the EU Biodiversity Strategy, did not allow for addressing forest management in a holistic way in line with the three pillars of sustainability. Therefore, the EUFS is still not concretely supporting the forest sector to enable its contribution to the overall EU climate neutrality targets whilst maintaining and improving forest health and resilience as well as to ensure forest multifunctionality.
As an example, the growing recurrence of large forest fires such as the ones occurred this summer in France, Portugal and Spain make it apparent that the current EUFS’s approach and goals are not meeting the sectors’ needs neither addressing the actual forest issues.
This situation stems from the absence of open and inclusive dialogue throughout the EUFS development process. From the outset, the perspectives of forest owners and managers were not adequately considered, despite their active efforts to contribute with valuable input. Therefore, the strategy is not playing a role to serve as a bridge between EU forest related policies and national or regional forest legislation. Some clear examples are the lack of proper inclusion of forest-based bioeconomy, of the economic and social aspects related to rural development, or of the economic growth of the forest-based value chain at large.
As far as implementation is concerned, one concrete example lies with the three guidelines published by the EC2, which are falling short to respond to the local and regional needs, despite active contributions from European forest managers and owners. The guidelines are not taking sufficiently into account existing national legislation and provisions, local expertise and management practices, as well as ecosystems’ specificities, therefore making them not fit for their purpose or unimplementable.
Another challenge the EUFS brings is related to the concept of “sustainable forest management” and how it has been framed as not sufficient to meet today’s challenges. Originally developed and endorsed by European governments at the pan-European level (FOREST EUROPE)3, the consensual approach has been disregarded, and instead, the new “closer-to-nature forestry practices” concept was established by the EC. This dichotomous approach cannot result in success when it comes to addressing the complexity of forest management.
Looking ahead
At a time when the work on the review of the EUFS is starting, European forest owners and managers strongly suggest taking due regard of the following points within the EUFS review:
- The current EC Work Programme with simplification, competitiveness, resilience, and autonomy as high priorities.
- Multifunctionality and forest resilience, as well as the need for active and sustainable forest management to ensure the provision of all benefits provided by forest such as forests fire prevention, disaster and risk management, climate mitigation, rural development, water provision, rural jobs.
- The new policy developments, which address forests and forestry in a more balanced and realistic approach. These include the new EU Bioeconomy Strategy, the uncertainty of climate change impacts on forests in the LULUCF Regulation, the European Climate Resilience Framework and the resilient landscapes guidelines or the nature credits initiatives.
- The strong signal sent by EU co-legislators on the legislative proposal on the EU forest monitoring law, with regards to the acknowledgement and respect of existing work at national level and appropriate level of intervention when it comes to forest-related policies. The respect of national competence on forestry and the need to define policies that are coherent and avoid duplication, must guide the review of the EUFS.
- The EU current and future financing for investments, research and innovation in the forest and forest-based sector.
All these aspects deserve proper analysis and consideration in the revised Strategy. European forest owners and managers strongly recommend that the review should go beyond assessing progress and must also assess whether further actions are needed to meet its objectives. The EC should also assess the relevance and usefulness of actions not yet implemented as well as the need for a much more balanced approach, following the 5 points above, to be included in the main objectives. The EC should therefore ask the question whether the EUFS is today fit for purpose with regards to needs of the forest sector and with regards growing challenges of today's world and thus of society: moving away from fossil fuels, climate protection, housing with sustainable materials, and the provision of all services, which will only be possible with a competitive forest sector and sustainable and active forest management.
European forest owners and managers are eager to contribute to reaching EU sustainability and climate neutrality objectives. They work daily to manage forests, including adapting them to climate change (exchange of best practices, scientific support), to deliver on all expectations and needs from society, and are a central pillar of a renewable and competitive bioeconomy. They are ready to contribute to the review of the EUFS in an open and constructive way.
Signatories:
CEPF - Confederation of European Forest Owners
Copa-Cogeca - European Farmers and Agri-Cooperatives ELO - European Landowners’ Organization
EUSTAFOR - European State Forest Association FECOF - European Federation of Forest Municipalities UEF - Union of European Foresters
USSE - Union of Foresters of Southern Europe
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1 4 October 2021, The New EU Forest Strategy for 2030 - Position of European Forest Owners and Managers
2 (1) Guidelines on Biodiversity-Friendly Afforestation, Reforestation and Tree Planting; (2) Guidelines for defining, mapping, monitoring and strictly protecting EU primary and old-growth forests; (3) Guidelines on Closer-to-Nature Forest Management
3 Forest Europe - Sustainable Forest Management, SFM
