Open letter to Diana Buzoianu, the new environment minister

To: Ministry of Environment, Waters and Forests
Bvd. Libertăţii nr. 12, Sector 5, Bucureşti

For the attention of: Ms Diana Buzoianu, Minister

Bucharest, 26 June 2025

Re: Forests in the context of climate change

Climate change is an urgent issue that was excluded from election campaigns over the last year and threatens Romania’s habitability through extreme weather: drought, heatwaves and storms. Our country is among Europe’s most affected, and aridification is accelerating. Urgent measures are therefore needed; they may seem unpopular to sceptics but are necessary, and European legal tools exist for them: the new EUDR anti-deforestation legislation, European biodiversity strategy, restoration legislation, etc. Only 29% of Romania is forested, and more than 80% of Romania’s forest has lost its structure and resilience. Forestry is far too intensive for the country’s real needs, with industry processing more timber than can be sustainably harvested. The last primary and old-growth forests have been rapidly entered, and consequently the classified results of the new National Forest Inventory show that in each of the last 5 years, 35 million m3 have disappeared from Romania’s already disrupted forest, only half with documentation.

A green wall is needed to keep Romania habitable, because forests attract and produce rain, drawing inspiration from Africa’s cross-border “Great Green Wall” project intended to stop the expansion of the Sahara and Sahel. Romania needs a green network of interconnected mixed forests along watercourses in every region, and forest cover must rise to at least 40% of the country, including measures promoting agroforestry methods. Logging must be prohibited on slopes above 20°. At least 10% of the country must be strictly protected, including a mix of forest and non-forest ecosystems and extensive wetlands. National parks, covering just 1.33% of Romania, must be the first to approach 100% strict protection immediately, without wasting more time debating insufficiently ambitious new management plans. Throughout the remaining forests, all current destabilizing cuts, clear-cuts and progressive cuts, must urgently be banned. Only close-to-nature forestry should be practised, maintaining canopy cover over at least 90% of the ground at all times, with a native mixture of species of every age and always including trees at the limits of their longevity. Firewood must be phased out. Heat energy, and in some cases even electricity, is the most polluting energy source. Studies show it is more polluting even than coal. Tree monocultures must be banned because they cause emissions, disease and fires.

Yet we remain far from these ideals that would keep Romania habitable, ideals for which Agent Green has fought for 2 decades. All Agent Green’s work over the last two decades has focused on caring properly for forests as a climate shield, both in protected areas and elsewhere. Here is Agent Green’s vision for Romania’s forest (in Romanian), which we sent you during your first parliamentary term.

We have brought over 400 cases against the ministry you have taken over to expose criminality in this institution, constantly infiltrated by ill-intentioned people, and to prompt the European Commission to initiate the necessary infringement proceedings (in Romanian) following Agent Green’s formal complaint (in Romanian). We achieved small victories through these proceedings, reflected in new national legislation: banning clear-cuts in protected areas and requiring appropriate assessments before approving logging. But the creative forest administration and timber industry found ways around these changes, because their mentality remains rooted in immediate profit and the belief that the forest is infinite.

It is not. Over the last 2 decades, logging has exceeded the forest’s capacity to regenerate. As a result, over 80% of Romania’s forest has lost its structure, resilience and ability to act as a climate shield. Only 1% has been admitted to the national catalogue of virgin forests under a poor definition that includes only climax-stage forests, such as those in Semenic blown down 2 summers ago. The UNESCO-listed forest now has only 2-year-old saplings, yet it is still virgin forest. Hundreds of thousands of hectares have been lost from the catalogue because the definition is poor. We hope to correct it with you to save what can still be saved. The technical commission approving admission to the national catalogue must also be reviewed. Our internationally reputable scientific experts have faced unimaginable humiliation before this commission composed solely of foresters and industry representatives. It must instead comprise natural science specialists.

In 2019, we showed that only 8% of the forest remained primary (in Romanian) and demanded its protection. In 2020, we began dialogue with the prime minister and environment minister so Romania would fulfil its obligation under the then-new European biodiversity strategy to strictly protect a mix of forest and non-forest ecosystems covering 10% of the country. We helped the ministry’s designated team with this 10%, but industry intervened directly or through intermediaries infiltrating entities wrongly called NGOs to redefine strict protection into something allowing environmental aggression. It destroyed the entire methodology underpinning a coherent designation of strict protection over 10% of the country based on networks and connectivity. Consequently, SUMAL data show that 4.7 million m3 of timber were extracted from primary and old-growth forests in the last two years alone, enough to fill trucks stretching from Bucharest to Brussels, during infringement proceedings. An infringement procedure that, for Romania, became more of a reason to cut even more in protected areas, fearing possible strict protection in the near future. These were veritable panic cuts that devastated Natura 2000 sites. Many abusive operations were possible because the ministry did not apply the digitized INSPIRE boundaries (in Romanian) of protected areas. This left room for interpretation by industry, which logged even in reserves in national and natural parks, claiming to be outside protected areas. To demonstrate the error, we sued the company operating in the Royal House’s forests in Bucegi and won definitively.

Nor were national parks spared (in Romanian), although through campaigns including litigation over the last 15 years we have brought their strict protection closer to 75%, though not everywhere. Major problems remain in parks such as Semenic, Cheile Nerei Beușnița and Domogled – Valea Cernei, and the management plans being prepared make a mockery of national parks, whose forests account for just 1% of Romania.

All this serves organized crime structures made necessary because Romania allowed timber processing and consumption facilities with twice the capacity at which the forest can regenerate. Hence the 2018 National Forest Inventory result showing 20.6 million m3 of timber disappearing without a trace. Agent Green declassified this information through an open letter to the country’s president (in Romanian). Following enormous media pressure, the president and the then-minister confirmed our warning a year later.

The newly classified results of the new National Forest Inventory show that over the last 5 years, 35 million m3 have been removed from Romania’s already disrupted forest, only half legally. Much came from the most precious forests industry can still cut: virgin, primary and old-growth forests. We hope you will not try to conceal the IFN data for a year before confirming the scale of illegal logging as your predecessors did, and that you will take responsibility for this situation. If so, let us recognize that the new Forest Code, despite improvements, is overall a failed opportunity that will worsen the forest’s situation because public consultation was insufficiently respected. Public consultation is something we have fought for since the last century. Ratification of the Aarhus Convention in 2001 was the first major success in which we participated, giving everyone access to environmental information, participation in decision-making and the right to sue local and national authorities over environmental crimes. We have used all these rights to the fullest in 25 years of activity, and I expect you to consult more informed opinions in future, especially those most ambitious for Romania’s nature and entirely without financial self-interest.

In reality, the new Forest Code represents the greatest form of aggression achieved by the Scandinavian forestry lobby, which spreads like cancer worldwide and manipulated the new code through its intermediaries. This Scandinavian lobby is well represented by IKEA, which quietly became Romania’s largest private forest owner. It was extraordinarily arrogant: immediately after buying the forests, it began disrupting them through methods foreshadowing the new Forest Code you endorsed. It cut primary and old-growth forests as an emergency measure. It replaced mixed forests with monocultures. Agent Green’s new report, entitled “IKEA – Clever on the outside, rotten on the inside”, presents concrete evidence of the cancer this global corporation has brought to Romania.

We have prepared a detailed analysis of the new Forest Code for you. Here is the complete analysis (PDF in Romanian). We set out the main problems identified by our specialists in this open letter:

Absence of serious reforms and worsening dysfunctions. The new Forest Code does not separate regulatory, management and commercial activities, which all remain under the same unprotective umbrella. This overlap of responsibilities perpetuates conflicts of interest and weakens the entire forestry system.

The national forest estate (FFN), under increasing pressure. Romania is gradually losing substantial forest areas because permissive regulations facilitate their removal from the national forest estate (FFN). Land with forest vegetation outside the FFN, although meeting the definition of forest, is not officially recognized, exposing over 500,000 ha of forests with timber worth at least 15 billion euros to uncontrolled deforestation.

The national afforestation programme drastically reduced. The afforestation target has been reduced 33-fold: from 2 million ha by 2035 (initial plan) to just 60,000 ha by 2030, a decision that increases the risk of aridification and undermines efforts to tackle climate change and restore affected ecosystems.

Regulations that favour abuses, such as:

Clear-cutting disguised as ecological reconstruction.

Construction and facilities in park forests, including night lighting or the planting of invasive exotic species.

Construction of logging roads without proper design and environmental assessments, increasing the risk of soil and forest degradation.

Weakened controls and strict regulations. The changes mean that approval from the forest guard is no longer required for works near the forest edge for projects of national or local interest. Timber marking also continues to depend on a rudimentary instrument, the forestry marking hammer, which has been involved in numerous cases of falsification. This marking hammer can mean both a presumption of guilt against honest foresters and the perfect alibi for thieves.

The integrity of forestry staff remains problematic. Forestry staff remain among the main actors involved in modern timber theft through manipulation of official documents. Increasing their salaries by 25%, without deep reform and integrity assessments, is not a real solution.

Citizens’ free access to forests is an ambiguous victory. Although access is theoretically guaranteed, forest managers can “temporarily” restrict access to large areas, citing reasons such as fire risk, logging or hunting. Such restrictions can be extended abusively throughout the year, preventing free public access.

Matters of extreme concern in the new Forest Code

Reduction of FFN areas for various projects: permanent removal of land from the estate for construction such as cemeteries, places of worship or subsurface extraction, without compensation mechanisms.

Promotion of commercial hunting: Romsilva retains the right to establish fenced hunting complexes, veritable “extermination camps” for wildlife.

Dangerous definitions of ecological reconstruction, allowing clear-cutting in mixed forests of high conservation value under the false pretext of natural restoration.

Positive aspects of the new Forest Code

Agent Green welcomes the introduction of a few useful measures but considers them insufficient and far from compensating for the enormous negative impact of the new Forest Code.

Modern monitoring technologies: real-time access to timber traceability data for authorities.

Limiting clear-cutting in protected areas: exceptions are limited to short-rotation stands such as poplar and willow. This is a victory for Agent Green following the complaint to the European Commission that led to infringement proceedings beginning in February 2020, which will continue until all the problems raised by the organization are resolved.

Regulation of conflicts of interest: the definition of a conflict of interest for forestry staff is extended to include relatives up to the second degree.

Agent Green’s demands

To protect Romania’s forest and prevent its accelerated and irreversible degradation, Agent Green proposes:

Changing the architecture of the forestry system by clearly separating administrative, commercial, regulatory and control functions among different entities.

Establishing a national programme to afforest 40% of the country’s area.

Adapting forestry to climate change through strict protection of 10% of the national forest estate, in line with the EU biodiversity strategy.

Practising close-to-nature forestry in the remaining 90% of Romania’s forest: banning clear-cutting, progressive cuts and salvage cuts. Permanently retaining at least 70% of the native standing timber volume on every forested hectare in Romania.

Creating a legislative framework that guarantees genuinely free public access to forests and combats abuses by managers.

Full digitalization of traceability processes and the monitoring of illegal logging.

Periodic assessment of forestry staff integrity and strict penalties for abuses.

SUMAL and the Inspectorul Pădurii application are another issue in which we have been involved since the first steps in 2008 up to the present. We exposed the ways SUMAL can still be circumvented, and your predecessor did not wish to address every method of theft.

SUMAL was compromised from its launch to keep illegal and undetected logging volumes as high as possible, although we proposed viable, straightforward solutions that could have countered the theft methods exposed in Agent Green’s report.

The methods are not even particularly sophisticated. Hauliers and processors can easily deceive SUMAL through at least ten theft methods, such as teleportation, time travel, evaporation or sublimation. In every case, stolen timber never appears in SUMAL, and its volume exceeds that of legal logging. The public still sees only transports from the last 3 days, limiting its ability to help authorities combat illegal logging actively.

Perhaps the most serious is evaporated transport, invisible in SUMAL, which prevents police, gendarmes and forest guard inspectors from enforcing the law. This method is enabled by SUMAL’s deliberately defective programming in the frequent cases where hauliers carry timber without being checked anywhere along the route, with mobile data switched off. After delivery, they delete the application from their mobile device so offline data never reaches the SUMAL server. They reinstall it an unlimited number of times, for every transport, entering data offline that they would upload only if checked en route.

Any method can be countered if there is the will. Even evaporation, through measures including:

• Supplementing the rules approved by Government Decision 497/2020 to prohibit issuing a new transport document for vehicles with previous journeys not finalized according to legal requirements.

• Reprogramming SUMAL so information on an offline transport remains on the device even after uninstalling and reinstalling the application. It would be transferred to SUMAL servers as soon as the user reinstalls the application and goes online.

• Automatically detecting and blocking operators through the Sumal 2.0 Avize application, whose functions must be developed accordingly.

A substantial administrative penalty under Law 171/2010, together with confiscation of the value of quantities thus disappearing from timber traceability and withdrawal of professional haulier status, would have been a deterrent. Law 171/2010 should also restore physical confiscation when such a transport is found in traffic and empower the Gendarmerie to enforce the law. Among other things, its powers are limited to forest roads and do not cover paved roads, an absurdity that needs correcting.

It is also necessary to require a single transport document per journey/vehicle listing all beneficiaries and their unloading addresses, regardless of their number. For these situations, the Sumal application must provide photographs of the load after every delivery to a beneficiary.”

Other methods involve timber from a different source and date than declared, averaging five hundred transports weekly. Overloading is also very common, but trucks are rarely confiscated by authorities as required by law. Multiple transports with a single set of documents continue because transport documents remain valid unjustifiably long and inspections are insufficiently strict and frequent. Much theft occurs in plain sight of active citizens, who often see photographs in Inspectorul Pădurii in which the load is entirely or partly invisible. SUMAL should never have approved transports with such cropped photographs.

Timber thieves’ creativity can defeat even the most vigilant authorities. Virtual operations create temporary and permanent storage sites, primary landings and timber shipments only fictitiously in the system. The aim is to maintain permanently available virtual reserves. Such actions are very difficult to detect under current conditions. Fictitious transport is a simple game whose hardest part is driving the mobile phone by car, for example between the issuing location and destination, to plot the route on the map.

In conclusion, incomplete SUMAL 2.0 programming and weak enforcement of existing laws make current anti-illegal-logging tools insufficiently agile to rigorously track timber origin and traceability. Timber theft consequently continues at an alarmingly high level. The mechanism systematically devastating national forest ecosystems and causing irreparable harm to the environment, society and the economy persists and grows.

Developing Sumal 2.0 with the functions specified for each method and the legislative changes proposed in Agent Green’s report will undoubtedly lead to a real reduction in these negative phenomena.

The Agent Green team congratulates you on your new position, wishes you every success and assures you of our full support for the necessary, healthy measures for Romania’s nature.

We await your point-by-point reply on every issue raised in this open letter: SUMAL, Inspire, virgin forests, national parks, 10% strict protection, a national restoration plan, 40% forest cover, protection of primary and old-growth forests, and correcting the Forest Code to keep Romania habitable, including agroforestry measures.

Yours sincerely,

Gabriel Păun
President of Agent Green
United Nations Champion of the Earth