Revision of the EU Framework Strategy for forests put to a vote

Commissioner Adina Ioana Vălean’s vote is crucial

Bucharest, Brussels, 29 June 2021 – The EU Forest Strategy has been published and will be put to a vote by EU commissioners in July. Agent Green, a member of the Forest Defenders Alliance, has analysed its positive aspects and the shortcomings in the publicly released document that must be improved to achieve a forest strategy that supports rather than undermines efforts to mitigate the climate and biodiversity crises.

Draft EU Forest Strategy

https://forestdefenders.eu/wp-content/uploads/2021/06/Forest-Strategy-leaked-draft-JUNE-8.pdf

What must change in the framework strategy

The framework strategy’s context is a recent briefing1 from the JRC, the European Commission’s Joint Research Centre. It states that while an overall increase in forest sinks will be needed to meet European Green Deal objectives and reduce greenhouse gases in the medium term (2050), current harvesting trends and projections indicate a declining sink. The JRC warns that “reversing this trend would require an extraordinary and urgent increase in the annual net growth rate of forests, primarily through forest management practices and new forest area.”

The framework strategy’s main problem is thus the naivety with which it continues to treat the bioeconomy as a means of mitigating climate change, without recognising the fundamental incompatibility between ensuring an “extraordinary and urgent increase in annual net forest growth” and intensifying logging.

The framework strategy reveals an acceptance that replacing carbon-based materials with wood will reduce emissions, stating, for example, that “the most important role of wood products is to help turn the construction sector from a source of greenhouse gas emissions into a carbon sink, as envisaged in the Renovation Wave Strategy for Europe and the new European Bauhaus Initiative. There is still much room for improvement, as wood products, with a market share below 3%, remain only a tiny proportion of construction materials used in Europe, which are still largely dominated by energy-intensive fossil-based materials.” (page 11 of the EU strategy).

However, the science for harvested wood products as a source of climate change mitigation is not developed. JRC staff produced a modelling paper cited in their recent briefing, finding that while a 20% increase in harvesting by 2030 compared with 2000–2012 levels would increase annual carbon stored in harvested wood products by 8%, it would reduce the much larger forest carbon sink by 37%. This is a shockingly large decline in the forest carbon sink for a negligible increase in the harvested wood product sink. The model found that only reducing harvesting by 20% would allow the forest carbon sink to increase. In general, the JRC briefing cites several studies concluding that in the short to medium term, apparently meaning until 2050, “the additional mitigation potential from material substitution is unlikely to compensate for the reduction in the carbon sink in forest ecosystems affected by increased harvesting.” However, as the briefing points out, another way to increase net carbon stored in harvested wood products is to “change how harvested wood, industrial wood residues and secondary wood are used for different goods. A transition from longer-lived wood products, for example from paper to construction timber, would slow production and help conserve or increase the growth of harvested wood products while maintaining a stable harvest over time.”

The framework document reveals other gaps in recognising harvested wood products as a mitigation factor, stating that “Harvested wood products in the EU represent an active net carbon sink of approximately -40 MtCO2e/year, also providing climate benefits through a material substitution effect of between -18 and -43 MtCO2e/year.

” However, harvested wood products are not an “active” carbon sink. As the IPCC carbon accounting protocol shows, harvested wood products do not directly sequester carbon from the atmosphere; they create a carbon stock initially sequestered by the above-ground biomass of forests and other wooded land.3 More importantly, the substitution effect itself is largely an illusion, because it truly operates if the total amount of material used is capped; otherwise, use of both the original materials and the wood “substitute” is free to keep growing. 4

In general, the framework strategy must be rewritten to recognise that, given the Commission’s objective not only to build a forest carbon stock for climate change mitigation but also to restore ecosystems and reverse the frightening, rapidly advancing biodiversity decline, the priority must be protecting, regenerating and rewilding forests, rather than intensifying harvesting, even for long-lived wood products.

Plans and opportunities for increasing accountability

The framework strategy discusses plans for monitoring, governing and certifying forests and forestry. To succeed, these initiatives must rely on rigorous science and strong representation of scientists and NGOs on oversight bodies. Here we comment on these initiatives, particularly the Forest Strategy.

1. A common definition of primary and ancient forests and their protection regime, with Member States committing “urgently” to mapping and monitoring; they should ensure no deterioration occurs until they begin applying the protection regime. (p. 4).

   • Yes, but stronger measures are needed to help urgently halt the alarming growth in illegal harvesting and legal logging of mature forests, including for bioenergy. Resources must also be allocated immediately to map and protect forests that could become future ancient forests.

2. A future EU legislative proposal on forest planning and monitoring that includes additional indicators and thresholds/ranges for “sustainable forest management”, focusing on ecosystem health, biodiversity and climate objectives. (p. 5)

   • One need only observe the overuse of “sustainability” to describe the EU’s most damaging and degrading forestry practices to see how meaningless the word becomes. If the EU wants this word to mean anything, it must be backed by truly rigorous standards and implementation. Meanwhile, we must not wait for future legislation to recognise immediately that the RED II biomass “sustainability” criteria come nowhere near the definition of sustainability set out in the framework strategy (p. 5). For example, forest clearance is “sustainable” under the RED as long as trees keep growing elsewhere to ensure felling does not exceed forest growth regionally or even nationally. Ignoring what happens at parcel level and focusing instead on landscape-level “sustainability” is what increases forest degradation in the EU and exploitation of forests for biomass fuel outside it. The new sustainability concept must apply at every scale of forest management to make a difference, because forests consist of these “parcels.”

• Rüter, , et al. (2019). Volume 4: Agriculture, Forestry and Other Land Use, Chapter 12: Harvested Wood Products. 2019 Refinement tothe 2006 IPCC Guidelines for National Greenhouse Gas Inventories. https://www.ipcc-nggip.iges.or.jp/public/2019rf/index.html

• Leturcq, (2020). “GHG displacement factors of harvested wood products: the myth of substitution.” Scientific Reports 10(1): 20752.https://doi.org/10.1038/s41598-020-77527-8

• For mapping and monitoring, field data are needed for site-specific indicators and calibration, but accurate geospatial data are equally important. The ability to assess forest carbon density through remote sensing is increasing and can help harmonise national datasets and provide a baseline for checking the reality on the ground. Remote sensing and tracking must also be used more extensively to help stop illegal logging.

• The document and resulting plans must recognise that the EU’s hunger for natural resources continues to drive forest degradation and deforestation, for example by promoting forest biomass as renewable energy, which encourages harvesting in the EU, North America, Russia and elsewhere. There must be a plan to reverse this trend.

3. A common voluntary “closer to nature” forestry certification scheme.
   • Yes, but give it stronger powers and real incentives, including access to certain markets and benefits available only with certification. Otherwise, business as usual will continue in forestry, all too often falsely labelled “sustainable”,
   • The European Commission should impose minimum audit requirements for all public and private certification schemes. These schemes have many gaps, including appearing unable to ensure the legality of wood supplies in the EU.
4. The proposal to increase uptake of rural development funds relevant to the Forest Strategy (p.8).
   • We note that the current allocation of 6.7 billion euros under the CAP for forestry measures could be doubled by ending subsidies for burning forest biomass for energy. Paying people to grow forests is justified, rather than paying them to harvest and burn forests for energy.
5. Assessing harvested wood products: It is indeed important to develop “a standard, robust and transparent methodology to quantify the climate benefits of wood construction products and other construction materials.” (page 11).
   • However, we would have more confidence in its integrity if the framework strategy had not already promoted harvested wood products even without such a methodology.
6. Developing an action plan for the certification scheme and carbon sequestration for carbon removal
   • Clear guidance is needed to prevent monoculture plantations. The “regulatory framework for certification of carbon removals” to be developed must guarantee that monoculture plantations do not qualify for carbon removal.
7. The 3 billion trees initiative and its monitoring: This action must be based on ecological criteria, and additional tree planting for energy plantations must be supported. It is a good idea to involve citizens and communities in monitoring “trees planted as a contribution to ensuring at least another 3 billion trees by 2030.”

What is positive in the framework strategy

Calls for protecting and regenerating forests

8. Recognises the need for “larger, healthier and more diverse forests than we have today, particularly for carbon storage and sequestration and halting habitat and species loss. To get there, we will need to reverse negative trends, improve monitoring to better identify the condition of our forests and step up our efforts to protect and regenerate forest biodiversity and thus ensure forest resilience.” (p. 2)
9. “Primary and ancient forests in particular must be strictly protected.” (p. 3)
10. “To allow nature to recover, the EU Biodiversity Strategy for 2030 proposed a target to protect at least 30% of the EU’s land area, of which 10% will be placed under a strict regime of effective management and legal protection. Forest ecosystems must also contribute to achieving this target.” (p. 3)

Recognises that current forestry destroys forest ecosystems and reduces resilience

11. “Forest management practices that conserve and regenerate biodiversity increase forest resilience. All forests must therefore be better managed to be sufficiently biodiverse, taking account of differences in natural conditions, biogeographical regions and forest typology.” (p. 4)
12. “Climate change continues to affect Europe’s forests negatively, especially in areas with single-species and ageing forests.” (p. 1)

Calls for changing forestry practices, including ending forest clearance

13. “In this context, management practices supporting biodiversity and resilience are essential, such as creating or maintaining functionally diverse, mixed-species forests, especially with more broadleaves and species with different biotic and abiotic sensitivities and recovery mechanisms after disturbances, instead of monoculture plantations.” (page 4)
14. “Other practices must be avoided. One such forestry practice is forest clearance, unless proven necessary for environmental or ecosystem health reasons. Besides destroying above-ground biodiversity, forest clearance causes carbon loss from roots and some soil carbon. This practice is already banned or restricted in many countries. Removal of stumps and roots, which must be left in the forest, must also be avoided, as must intensive clearances during the nesting season.” (page 4)
15. “Thus, soil properties and soil ecosystem services must be protected as the foundation of healthy and productive forests, and unjustified use of heavy machinery causing soil compaction, for example, must be avoided.” (page 4)

Calls for prioritising long-lived harvested wood products and minimising wood use for biomass energy

(These statements are compatible with removing forest biomass from the Renewable Energy Directive (RED) and allowing only secondary woody biomass to qualify as “renewable energy”. Even though this is a poor use of many materials that could instead be used for durable products).

16. “Given the growing and sometimes competing demands on forests, we must also ensure that wood is used optimally according to the cascading principle, so that most wood is used for durable materials and products with the greatest value for a circular, climate-neutral economy, while minimising its use for short-lived products and energy production.” (page 2).

17. “It is essential, when building a sustainable, climate-neutral economy, to ensure optimal wood use according to the cascading principle. This means using most wood for durable materials and products. Wood use for short-lived products and energy production must be minimised, and secondary woody biomass such as sawmill by-products, residues and recycled materials must be used.” (p.10)

18. “Negative externalities in bioenergy use, such as air pollution, must also be minimised. Prioritising residues and cascading wood use must remain a key general principle to maximise bioenergy’s positive climate impact.” (p. 12)

19. “The focus must therefore be on a drastic shift from short-term uses to durable wood uses, such as buildings and furniture, including through better reuse and recycling of wood products from construction and demolition sites. This measure is also compatible with the EU’s new Circular Economy Action Plan, which commits to reducing packaging and further limiting single-use products. These short-lived products are also made from wood-based materials, among others.” (page 10)

Recognises the need for economic incentives to change landowners’ behaviour

20. “Forest owners and managers need encouragement and financial incentives to provide ecosystem services through protecting and regenerating forests and to increase forest resilience by adopting forest management practices more favourable to climate and biodiversity.” (p. 7)
21. “Other benefits, especially providing ecosystem services, are rarely or never rewarded. This must change. Forest owners and managers need encouragement and financial incentives to provide ecosystem services through protecting and regenerating forests and to increase their forests’ resilience by adopting forest management practices more favourable to climate and biodiversity.” (p. 7)
22. Encourages increasing “…economic activities in the forest sector that are not based on extracting wood resources, to diversify local economies and employment in rural areas”, (p. 2), including ecotourism, non-wood forest products and providing ecosystem services.

Offers a broader definition of sustainability than the RED

23. Provides that “Sustainable forest management means the stewardship and use of forest land in a way and at a rate that maintains its biodiversity, productivity, regeneration capacity, vitality and potential to fulfil, now and in the future, ecological, economic and social functions at local, national and global levels, without adversely affecting other ecosystems.” (p. 5). The Commission also rightly aims to identify indicators covering ecosystem health and resilience, biodiversity and climate. It must be remembered that the RED’s “sustainability”, which classifies biomass as “renewable energy”, does not fit this definition.

• https://publications.jrc.ec.europa.eu/repository/handle/JRC124374
• Pilli, , et al. (2017). “The European forest sector: Past and future carbon budget and fluxes under different managementscenarios.” 14: 2387-2405.