European forest owners call the co-legislators for a realistic approach of the diversity of European soils to identify the real added value for a soil monitoring framework and its practical implications.
To do so, the Confederation of European Forest Owners (CEPF) would like to reiterate the significance of the subsidiarity principle when it comes to any political consideration dealing with the use and management of soil. CEPF emphasises especially the high importance of due considerations for the following aspects, which are hereafter elaborated upon:
- privacy rights and data protection;
- the diversity and nuances of different land uses and land management;
- use of pre-existing administrative and monitoring structures and adequate flexibility to enable their use;
- risks of “one out all out” monitoring;
- the limited added value of a new soil health certification scheme;
- the flexibility and practical approaches required for the sustainable soil management practices that would not hamper sustainable forest management.
Firstly, CEPF would like to bring attention to the importance of privacy rights and data protection. On many occasions, the raw data gathered is information linked to specific private property. Access to data should be granted only in an aggregated and anonymised form with the prior and informed consent of the forest owners in order to ensure the integrity of the data as well as the essential privacy of the forest owners. Thus, CEPF supports the Parliament’s proposal that emphasises strong protection of privacy and data protection.
As the Commission proposed it, this regulation would apply to all soils in the same way, regardless of land use. Although the proposal divided the land into convenient categories of natural, semi-natural and artificial land, it still lacks nuance with different land uses, which are either not considered or clearly delineated. Forest soils are highly diverse throughout Europe. Encompassing them within a single category would already ignore regional differences. Even though, forest soil is not the same as agricultural soil or urban soil, and different soil management practices are needed to maintain and restore healthy soils under different land uses. Thus, CEPF supports the Parliament’s proposal of taking land use into account in its definition of soil health on top of the Commission’s land categorisation.
Secondly, a one-size-fits-all approach regarding any natural resource in the diverse European landscapes is widely agreed to be problematic and unrealistic. This connects to the importance of avoiding a “one out all out” kind of monitoring to ensure realistic results, and subsequently well-tailored measures for addressing soil health. For this reason, it is important that the soil districts and the possible soil units allow taking land use into account and support the use of pre-existing administrative and monitoring structures. These structures are also made for the level of specificity that the authorities need the information on. Soil monitoring on the level so specific as an individual stand is rarely useful to the forest owner, and can on the contrary present dire privacy concerns, which is why the importance of aggregated and anonymised data must be emphasised. Regards to the one-size-fits all, adequate amount of flexibility is needed for the indicators. The Commission has proposed a certain set of indicators with threshold which only partially mirror the differences of soils both in fields and forests. Some indicators might not be relevant in certain soils or soil types and thus flexibility on choosing the right indicators is needed.
Thirdly, CEPF never saw the added value of a new soil health certification scheme, as suggested by the Commission. Creating a new certification system is onerous, possibly brings more bureaucracy for forest owners, and even when successfully adopted, presents the risk of leaving behind those that don’t have the technical or financial means to participate. CEPF would like to remind that the impact assessment called for limited restoration measures in order to curb the burden on the Member States, land and forest owners and land managers. In this regard, it is also necessary to address the Sustainable Soil Management (SSM) principles, which in their original form and intensity might greatly hinder the sustainable use and management of forests. CEPF supports the Parliament’s proposal of offering support to landowners and managers in the form of a SSM toolbox, including recommendations and new research knowledge. Additionally, SSM principles and their future development should not be left to be defined as delegated acts as it brings a lot of uncertainties for forest owners.
European forest owners expect their hopes and concerns to be heard in the negotiations, to ensure that the continuation of sustainable use of forests benefitting soils and society remains possible.
