After an initial reading of the proposal for a Regulation (hereafter, ‘the proposal’), European forest owners remain uncertain how the announced objective will be achieved. We also wonder about the real added value of this instrument for our work and for future EU policy making.
Since the earlier stages of the consultation on a possible legislative proposal on ‘EU Forest Observation, Reporting and Data Collection’, European forest owners have raised key considerations[1] to be addressed in the development of the proposal. Many of our concerns remain unfortunately unanswered. Numerous yet unheard-of provisions have been brought forth.
“Data collection should be decided upon and carried for a specific purpose, based on known and effective subsequent use”, said Hélène Koch, Senior Policy Advisor for CEPF. Beyond collecting data, its ownership, validation, and possible future interpretations should be addressed. “European forest owners still wonder about possible silenced uses that this proposal is meant to enable, in particular to frame EU policy making. We are still looking for the intensified dialogue with forest owners announced in Executive Vice-President Šefčovič’s mission letter”, added Ms. Koch. The cosmic ambitions of achieving resilient forests go far beyond the reach of such a framework. Any considered next steps should be clarified and brought forward from the start as to fully understand the scope and implication of the proposal.
Furthermore, a very important element of forest monitoring is approach to data sharing and access to information. Collected forest data may include rather sensitive information of private property, private ownership, and competitive business-related information. In this context, the new concept of “forest unit” and the open access to all data collected is more than questionable. Limiting data sharing of all collected forest data to national or regional level would have contributed to data protection and would avoid any misinterpretation or misuse.
European forest owners trust that the Council and the European Parliament will duly work to improve the proposal with the support of forest experts and in close collaboration with relevant stakeholders. European forest owners stand ready to contribute constructively to this process.
[1] CEPF reply to EC Call for Evidence, 6 May 2022
