Ho-hum, another week, and another predictably anti-science statement by the Brussels office of the European State Forest Association (EUSTAFOR). Have they totally forgotten they are supposed to represent the public and publicly owned lands? This time, they’re arguing against having the EU Forest Monitoring Law (FML) promote the use of modern high-quality satellite technologies to monitor forests and optimize the accuracy of forest data collected on the ground. Instead, they want to continue relying on the aged, fragmented forest monitoring approach employing aggregated statistics and sampling. The problem is, this old approach can’t provide timely and comprehensive information on the real state of our forests, which are in a bad condition, showing steep declines in the forest carbon sink and loss of ecosystem integrity.
EUSTAFOR’s associations manage the one-third of EU forests that are publicly owned. Yet instead of prioritizing protection and restoration of forest ecosystems for the public benefit, EUSTAFOR’s latest lobbying letter proclaims they care most about preserving the status quo: “It is EUSTAFOR’s first and utmost priority that the expertise of local forest managers, as well as the existing infrastructure, is maintained.”
We think they’re afraid – afraid that remote sensing data will reveal that the forests they manage are in bad shape – and that the current monitoring approach, which is based not on maps but on repeat measurements of secret forest plots noted on spreadsheets, isn’t accurate enough. They clearly fear accountability, arguing that “To protect the privacy of forest owners, managers and businesses, it is important that the data cannot be traced back to the holdings.” In fact, the FML has never proposed to show property boundaries in its mapping, but anyway, hold on – why is EUSTAFOR so concerned about private landowners? Let organisations representing private landholders raise their own concerns. EUSTAFOR, which represents state-owned companies, should support full data transparency, because the public deserves to know the condition of its forests.
EUSTAFOR wants member states to be able to reject use of satellite data for monitoring, so that they can continue to rely solely on National Forest Inventories, the methods for which were developed decades ago and are certainly not fit-for-future. National forest inventories are important, of course. But they’re based on repeat measurements of sampling plots that are supposed to represent what’s going on in forests as a whole. Beyond all the problems associated with such a labor-intensive sampling approach, if the plots no longer represent the landscape, the statistics on forests are no longer valid.
And there are signs the system is breaking down. For example, an investigation in Estonia revealed that the locations of many inventory plots are known, so the forest industry just logs around them. This kind of thing makes “monitoring” a joke.
Forest monitoring plot in Estonia that was left standing as the surrounding forest was clearcut; blue paint on trees in monitoring plots means their locations are easily discovered.
The European Commission proposed the FML because existing monitoring programmes have big gaps, with little to no information collected on carbon stocks, biodiversity, and habitat, factors that are essential to the future of forests and society. A strong and effective FML will also open up opportunities for forest owners and managers to receive funding, for example through carbon farming certification schemes. The FML should be a one-stop shop that fills these gaps and reinforces and streamlines reporting on other critical laws, including the Deforestation Regulation, the Nature Restoration Regulation, and the Habitats Directive. Importantly, it can help meet new requirements for mapping of primary and old growth forests that the RED3 puts off limits for biomass harvesting and the EUDR seeks to protect. Most member states have not even specified where their primary and old-growth forests are, so in some cases they continue to be logged at alarming rates.
Apart from their dependence on sampling and statistical inference, National Forest Inventories are only conducted every five to ten years, and not in all Member States. This means countries often have to retroactively correct the record as new data come in, leading to situations where it turns out that a country had steep declines in its forest carbon sink years previously, but this wasn’t noted in a timely way because the inventory hadn’t been updated in so long. Further, the slow pace of plot-level data collection means the system isn’t adequate for documenting impacts of swift-moving phenomena like drought, pests and fire. Here, however, EUSTAFOR still argues for the “old ways” – that monitoring should continue at only five/ten-year intervals, instead of the close to real-time monitoring that remote sensing can permit.
NFI plot-level data collection methods have barely changed since the 1950s, and yet EUSTAFOR talks up the NFI system, arguing “ They have been honed to most efficiently and accurately monitor the forests and forestry sector in their respective geographical areas.” But “respective geographical areas” simply means the inventories differ from country to country. That’s a bug, not a feature. Only a European-wide remote sensing approach can provide the kind of coverage that modern era requires.
EUSTAFOR’s position is effectively the logging industry has things just the way we like it, don’t rock the boat. They want the FML to incorporate notoriously weak “standards” such as the sustainable management criteria of Forest Europe. While the FE criteria are apparently being revised, the existing criteria don’t set thresholds and don’t require verification, so anyone and everyone duly claim to be doing “sustainable forest management”. In any case, it’s not appropriate for an EU law to rely on an externally developed standard such as the Forest Europe criteria.
EUSTAFOR argues that innovation should happen at the “relevant level,” and that member states should continue to be responsible for monitoring, assessment, verification, and reporting. But forests fall under shared EU competence through environmental, agricultural, energy and civil protection legislation, and what happens in the forests of one country can be highly relevant to others. Forests are transnational in every sense, and key to EU legislation from the Nature Directives to LULUCF to RED – making it essential to have modern EU-level monitoring.
Predictably, EUSTAFOR doesn’t want anything in the FML to be truly binding, either, arguing against delegated acts in favor or implementing regulations to be developed with the member states. That’s a recipe once again for the lowest common denominator.
EUSTAFOR seeks to consolidate forestry interest control over the entire process, recommending relying on existing platforms like the Standing Forestry Committee as a forum for experts to exchange information. But stacking oversight with foresters excludes full consideration of nature conservation and the vital, life-sustaining functions of forests. Policymakers should ensure that forest policy is not dictated solely by the industry that profits from logging.
No one is suggesting abandoning NFIs, which do indeed provide a long and invaluable record of data. However, the challenges of climate change and increasing pressure on forests require harmonizing definitions and methodologies and adding modern tools for earth observation. For example, a recent study in Hungary merged national datasets with satellite imagery from Global Forest Watch and found that logging appears to be happening at the same rate both outside and inside supposedly “protected” Natura 2000 sites. That kind of information can inform conservation efforts and lead to smarter forest management.
For EUSTAFOR to be opposing a strong FML and widespread use of satellite data shows once again, the association has lost its way, advocating for the narrow interests of the extractive industries, rather than managing public forests for the public good. Policymakers need to reject this reactive “back to the 1950’s” approach, and work for a strong and modern approach to forest monitoring in the FML.
This piece represents the stance of PFPI, which is solely responsible for its content.
