Opinion of the European Economic and Social Committee on the "Proposal for a European Parliament and Council Regulation concerning monitoring of forests and environmental interactions in the Community (Forest Focus)"

(COM(2002) 404 final - 2002/0164 (COD))

(2003/C 85/20)

On 26 July 2002 the Council decided to consult the European Economic and Social Committee, under Article 175 of the Treaty establishing the European Community, on the above-mentioned proposal.

The Section for Agriculture, Rural Development and the Environment, which was responsible for preparing the Committee's work on the subject, adopted its opinion on 13 November 2002. The rapporteur was Mr Kallio.

At its 395th plenary session on 11 and 12 December 2002 (meeting of 12 December), the Economic and Social Committee adopted the following opinion by 98 votes to one, with eight abstentions.

1. Content of the regulation

1.1. The purpose of the Commission's proposal for a European Parliament and Council Regulation is the establishment of a new Community scheme on monitoring of forests and environmental interactions to protect the Community's forests.

1.2. The scheme builds on the achievements of two previous Council Regulations on monitoring the impacts of atmospheric pollution [(EEC) No 3528/86] and forest fires [(EEC) No 2158/92] on forest ecosystems(1). The Commission proposes broadening the scope of the regulation so that in future the monitoring activities covered by the regulation will also address forest biodiversity, soils, climate change and carbon sequestration.

1.3. The Commission justifies the new regulation on the grounds that the proposed monitoring elements are all related to key priorities in the 6th Environmental Action Programme and the Sustainable Development Strategy. EU strategies need better information to identify the nature of risks and uncertainties, so as to provide a basis for solutions and further policy decisions. The Commission proposes Article 175 of the Treaty establishing the European Community as the legal basis for the regulation.

1.4. The scheme will run for six years, from the beginning of 2003 until the end of 2008. An amount of EUR 13 million will be allocated annually for monitoring the effects of air pollution and forest fires on forests, developing new monitoring activities and improving the scheme.

1.5. Under the proposed regulation, co-financing will be provided up to 50 % of the eligible costs arising from monitoring activity and database platforms and for studies, experiments and demonstration projects carried out under Member States' national programmes. The Commission will finance its own activities, such as coordination and evaluation work, studies, experiments and demonstration projects.

2. The existing framework

2.1. The content of sustainable forestry and national powers

2.1.1. According to the EU forestry strategy(2)"... the overall objective should ... be to strengthen sustainable forest development and management as stated in the 'Forest Principles' adopted by the United Nations Conference on Environment and Development and as defined in the resolution adopted at the pan-European Ministerial Conferences on the Protection of Forests" that is "... the stewardship and use of forests and forest lands in such a way, and at a rate, that maintains their biodiversity, productivity, regeneration capacity, vitality and their potential to fulfil, now and in the future, relevant ecological, economic and social functions, at local, national and global levels, and that does not cause damage to other ecosystems". "... This approach should be defined in and implemented through national or subnational forest programmes or equivalent instruments applied by the Member States and, in accordance with the principle of subsidiarity, through action taken by the European Community where there is an added value to be gained therefrom".

2.1.2. The starting point of the forestry strategy is the subsidiarity principle. This means that responsibility for forestry policy and the sustainable use, management and protection of forests lies with Member States. It is important that Member States have as much autonomy as possible with regard to sustainable forestry as this makes it possible to treat forests as an integrated whole, encompassing social and economic aspects as well as ecological considerations. By respecting national powers in this area, differences in the social importance of forestry in individual Member States and local and regional variations in forest ecosystems and species can be better taken into account. For its part, the Community plays a harmonising and coordinating role where needed and within the scope of its competences, as in the case of environmental policy, rural development or protection of biodiversity, for example.

2.2. Existing monitoring activities

2.2.1. Data on biological diversity and carbon sequestration in biomass are already collected and reported within the framework of several international agreements and international and national inventories. These include the FAO's (Food and Agriculture Organisation of the United Nations) Forest Resources Assessment Programme (FRA), the pan-European Ministerial Conferences on the Protection of Forests in Europe (MCPFE), international agreements such as the Convention on Biological Diversity (CBD), the United Nations Framework Convention on Climate Change (UNFCCC) and national forest inventories.

2.2.2. The FAO started to monitor the state of the world's forests through assessments of forest resources as long ago as 1946 and publishes reports on them every few years. In addition to data on forest resources, the assessments contain data on the carbon cycle, the health of the forest ecosystem, biodiversity, forest products and protection impacts. The country reports also contain data on the socio-economic functions of forests.

2.2.3. In the context of the pan-European Ministerial Conferences (MCPFE), six pan-European criteria have been established as points of reference for monitoring the implementation of sustainable forestry. Each criterion is defined in terms of qualitative and quantitative indicators. On the basis of these, European countries have developed national systems for monitoring sustainable forestry. Many stakeholders have utilised the pan-European criteria and indicators in their own definitions of sustainable forestry and in monitoring.

2.2.4. At its sixth meeting held in The Hague in spring 2002, the Conference of the Parties to the Convention on Biological Diversity adopted the Expanded Work Programme for Forest Biological Diversity. The expanded work programme stresses that the conservation and management of forest biological diversity is an element of the implementation of national forest policy and that national authorities are responsible for monitoring implementation. According to a study(3), the implementation and monitoring of programmes on biological diversity have been accorded high or medium priority in virtually all countries. Nearly all the countries which took part in the study already have a biodiversity or equivalent programme. National priorities and regional and national needs and specific features must be taken into account in implementing the work programme. The implementation of action programmes is to be monitored at national level and countries will submit reports to the Conferences of the Parties.

2.2.5. The parties to the Convention on Climate Change (UNFCCC) are required to carry out national greenhouse gas inventories in which each country estimates, lists, reports and regularly updates anthropogenic emissions of greenhouse gases by sources and removals by sinks. Climate policy measures related to forestry [Land-use, land-use change and forestry (LULUCF)] are bound up with both countries' climate strategies and national forest programmes.

2.2.6. National forest resource inventories are used to gather data on forest resources, the condition of forests, soil and flora. In recent years the scope of forest resource inventories has been broadened to include monitoring of biodiversity and the collection of data on carbon stored in trees and the soil. The data collected include e.g. actual data on biodiversity or data on factors contributing to biodiversity, such as understorey vegetation, the range of species and the nutrient quality of soil. In the above-mentioned study, Fischer notes that countries obtain the data they need for monitoring their biodiversity programmes mainly from national forest inventories.

2.3. Standing Forestry Committee

2.3.1. The task of the Standing Forestry Committee, which was set up by Council Decision (89/367/EEC) of 29 May 1989, is to promote cooperation between the Commission and the Member States in the field of forestry and to support forestry policy measures taken in the framework of the Community policies relating to the regulation on rural development. The aim of the Committee is to enhance the exchange of information on the state and development of forestry in Member States and, in particular, to inform the Commission on how Community policies affect the forest sector. The Committee is composed of representatives from the Members States and chaired by a representative of the Commission.

3. Comments

3.1. Forests play an important role in climate regulation, in combating pollution, erosion, flooding or avalanches and landslides and for regulating water resources. They also provide a rich biological environment. They are a key asset, both in environmental and economic terms, because, if well managed, they provide sustainable renewable resources. The forms of forest ownership are varied, but the functions of the forest environment are useful enough to society to warrant protection, and the exploitation of resources must be carefully regulated to promote rural development and the general interest. It is up to the relevant authorities to take appropriate technical and regulatory measures to achieve this, whether it be to prevent forest fires, soil acidification(4) or the depletion of biodiversity, and any other threats to this specific environment which, over thousands of years, has been increasingly affected by human activity as new tools and techniques have been used to exploit it.

3.2. The Committee feels it is important to develop resources for studying and monitoring the forest environment according to the specific situation in each Member State, and to coordinate the information collected so it can be used more rationally to benefit the Community strategy(5). It welcomes the Commission's proposals, subject to the following comments and proposals.

3.3. It is important to develop and continue the present programmes based on the regulations on protecting forests against atmospheric pollution and forest fires in operation for over ten years. It is vital for the comparability of the data collected to keep the main structural elements of the programmes unchanged.

3.4. Developing the monitoring of forest biodiversity, carbon sequestration, soils and the effects of climate change involves tasks which are different from the continuation and development of present schemes, but which are complementary, refer to the same environment and potentially build on the resources and methods already in place. There is no doubt that air pollution(6) and soil acidification are the most serious environmental problems facing forests in the Community and the candidate countries, and that, also in order to comply with international commitments on climate, greenhouse gases and biodiversity, such matters should be addressed jointly at national level and with harmonisation and coordination between the Member States at Community level. This requires appropriate monitoring activities, the need for which should be assessed and an estimate made of the final cost and the availability of all funding so as to ensure maximum cost-benefit efficiency.

3.5. The monitoring costs mentioned in the financial framework do not seem realistic, especially when it is not known how monitoring will be implemented. The methods and resources to be applied and the cost of acquiring reliable data that are suitable for policy decision-making should be evaluated very carefully.

3.6. One study(7) estimates that effective monitoring of biodiversity in the EU area would require some 150000 - 1,5 million observation plots whereas the present network for monitoring the effects of atmospheric pollution comprises about 7000 observation plots. With so much scientific uncertainty, it would be useful to define actual needs more precisely, while also considering the possibility of using new observation technologies such as satellites or automatic observation and reading posts and computerisation, in order to collect usable and reliable information and to draw up statistics to support the Community forestry strategy.

3.7. The new Member States will probably join the Union as early as the beginning of 2004, in which case the Community's total forest area will increase by about 30 million hectares(8). The estimates given do not indicate how much the establishment and maintenance of monitoring schemes in the new Member States will cost. Broadening the scope of monitoring activities to include monitoring of biodiversity, carbon sequestration, soils and the effects of climate change will probably entail a substantial increase in costs. The analysis of the implementation of the regulation should also include an assessment of the capacity of new Member States to carry out more intensive monitoring and of the structural and institutional changes that might be required in these countries to enable effective monitoring.

3.8. It must be borne in mind that Member States have tomonitor the state of biodiversity nationally, partly in accordance with their obligations under the Convention on Biodiversity and in the context of the pan-European Ministerial Conferences. In addition, other international organisations and bodies collect monitoring data on the health of forests, biodiversity and the carbon cycle. Accordingly, the Community authorities will have to make every effort to use all the available data already collected by the Member States and international bodies in order to avoid any duplication and thus to contain the costs of extending the existing schemes and securing consistent procedures. Particular attention will have to be paid in this regard to the implementing arrangements.

3.9. For greenhouse gas emissions and sinks, it is also necessary to avoid any duplication of existing monitoring activities and reporting under Community legislation and other agreements. As regards carbon, it would be better to draw on the guidelines on forest issues to be drawn up by the Intergovernmental Panel on Climate Change (IPCC) and the reports that Member States will be required to provide under the Kyoto Protocol. It would be helpful if these reports were drawn up with full and proper care and accuracy. As regards monitoring soils, reference should be made to the appropriate Commission proposal for legislation.

3.10. Countries have invested heavily in the development and maintenance of national inventories. Cost-effective monitoring is dependent on national schemes and their enhancement. Supporting national monitoring activities will make it possible to maintain continuity in time series and take account of country-specific features without wasting resources on the duplication of schemes while still making the changes required to harmonise national monitoring more effectively with the arrangements in place in the other Member States and to meet additional information needs. The Community's role could be (i) to improve the comparability of data in cooperation with the Member States and, if need be, the appropriate international bodies and forums, (ii) to consolidate the data bearing in mind other sources, (iii) to promote open cooperation and the quest for best practice and (iv) to frame strategic policy proposals or proposals for legislation where necessary.

3.11. The Commission cites Article 175 of the Treaty establishing the European Community as the sole legal basis for the regulation. This article has served as the basis for environment regulations in the past. The resolution on a forest strategy for the European Union adopted by the EU Council of Ministers in 1998 reaffirms the importance for forestry policy of the subsidiarity principle, according to which the Member States have the primary responsibility and obligation for the sustainable management and use of forests and the protection of forests. Similarly, the Community's Sixth Environment Action Programme requires that strategies and measures relating to forests are implemented and developed in line with the EU's forest strategy and the subsidiarity principle, under which powers are assigned to the most appropriate levels in the Member States and the Community, and which is exercised jointly with the proportionality principle.

3.12. Sustainable forestry comprises all aspects of sustainability. Ecological sustainability should be treated in the analysis as an element of sustainability alongside social and economic sustainability. The forest-based and related industries represent one of the most important industrial sectors in the EU and total employment in the forestry and forest-based industries will be about 5 million in the EU after enlargement, roughly a quarter more than at present. The primary responsibility and obligation for the management, use and protection of forests rest with individual countries and are discharged in accordance with the principle of sustainable development. This is a key element of national forest programmes and strategies. Each country is also responsible for ensuring that operators in the sector possess the necessary professional skills for the pursuit of sustainable forestry. Other economic or recreational activities such as the collection of medicinal plants or green tourism may be developed in a forest environment whose traditional features, in particular flora and fauna diversity, must be preserved in a balanced way. In the future, Member States should retain these responsibilities in matters related to the management, use and protection of forests, bearing in mind society's new expectations in terms of sustainable use and environmental protection.

3.13. Action programmes for forests and other natural resources, their associated monitoring schemes and decisions taken on the basis of monitoring activities should pay due regard to the fact that the social importance of forestry and forest-based economic activities varies between countries. It is important that Community legislation take account of developing the operating conditions of forest-based economic activities in Member States.

3.14. The development of information systems is a laudable aim. In developing information systems, attention needs to be paid to improving the availability of information and systems should be expanded to include e.g. exchange of information and experience on best practice. At the same time, however, where information is exchanged and published, the regulation must guarantee adequate protection of personal data, for example to forest owners with regard to their forest property. The proposed regulation should make explicit reference to the Community's 1995 data protection directive.

3.15. The regulation mentions ICP Forests (International Co-operative Programme on Assessment and Monitoring of Air Pollution Effects on Forests), the Scientific Co-ordination Body and the European Environmental Agency as implementing bodies, in addition to the Commission, the Member States and the Standing Forestry Committee. The division of labour between these organisations should be clarified so as to avoid duplication of work and an exponential increase in Member States' reporting obligations under the regulation.

3.16. The Standing Forestry Committee should be given a central role in the implementation and development of the regulation and should act as a regulatory committee in the enforcement of the regulation. In addition, the Standing Forestry Committee should also act as forum for exchange of information and discussion with the general public and stakeholders.

Brussels, 12 December 2002.

The President

of the European Economic and Social Committee

Roger Briesch

(1) EESC opinion, OJ C 80, 3.4.2002, p. 45.

(2) COM(98) 649 final of 18.11.1998 (not published in the OJEC); Committee opinion, OJ C 51, 23.2.2000, pp. 97-104.

(3) Fischer, R., Overview on national biodiversity monitoring activities within some EU/ICP Forest countries, Draft 7 October 2002.

(4) EESC opinion on the Communication on the Strategy for soil protection, opinion on Forest protection/Atmospheric pollution, OJ C 51, 23.2.2000, pp. 24-26.

(5) COM(98) 649 final of 18.11.1998 (not published in the OJEC); Committee opinion, OJ C 51, 23.2.2000, pp. 97-104, point 2.1.2 (EU forestry strategy).

(6) EESC opinion on National emission ceilings for atmospheric pollutants/ozone, OJ C 29, 23.2.2000, pp. 11-17.

(7) Prof. Tomppo, E., Assessing the Biodiversity of Forests at National and Continental Level, 10 September 2002.

(8) Committee opinion, OJ C 149, 21.6.2002, pp. 51-59.