REPLIES OF THE COMMISSION TO THE SPECIAL REPORT OF THE EUROPEAN COURT OF AUDITORS "IS EU SUPPORT FOR PREVENTING AND RESTORING DAMAGE TO FORESTS CAUSED BY FIRE AND NATURAL DISASTERS WELL MANAGED?"
Date: 2015-01-21
Institutions: European Commission
Subjects: EU programme, environmental risk prevention, financial aid, financial management, fire, forest conservation, management of resources, natural disaster, protected area, rural development, silviculture







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EUR-Lex - 52015DC0032 - EN











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52015DC0032

REPLIES OF THE COMMISSION TO THE SPECIAL REPORT OF THE EUROPEAN COURT OF AUDITORS "IS EU SUPPORT FOR PREVENTING AND RESTORING DAMAGE TO FORESTS CAUSED BY FIRE AND NATURAL DISASTERS WELL MANAGED?" /* COM/2015/032 final - 2014/ () */









REPLIES OF THE
COMMISSION TO THE SPECIAL REPORT OF THE EUROPEAN COURT OF AUDITORS
"IS EU SUPPORT
FOR PREVENTING AND RESTORING DAMAGE TO FORESTS CAUSED BY FIRE AND NATURAL
DISASTERS WELL MANAGED?"

Executive summary

IV. The Commission
considers that in general forest disaster prevention measures contributed to
the objectives of the rural development programmes. Concrete results have been
achieved and fewer
occurrences of fire took place.
Moreover, lessons have been learned which are applied in relation to the
2014-2020 period, especially as regards the scope of the measure and improved
guidance.
V. The Rural
Development Regulation[1] provides that
preventive actions against fires should cover areas classified by Member States
as high and medium fire risk according to their protection plans. These forest
protection plans and the Member States national or sub-national forest
programmes or equivalent instruments provided appropriate base for targeting
and prioritisation during selection. 
The Commission
analysed the situation of the forest sector including forest disaster prevention
and monitoring aspects in the 2005 Commission Staff Working Document which
formed an annex to the Communication on the implementation of the EU Forestry
Strategy[2]. The Rural Development
Regulation requested that forestry measures should contribute to the
implementation of the Community Forestry Strategy. The above mentioned Forestry
Strategy covers economic, environmental and social aspects of sustainable
forest management. 
As regards the new
programming period, the Commission analysed the situation of the forest sector
in the 2013 Commission Staff Working Document, which formed an annex to the
Communication from the Commission to the European Parliament, the Council, the
European Economic and Social Committee and the Committee of the Regions:
"A new EU Forest Strategy: for forests and the forest-based sector."[3]
VI. As part of the
sustainable forest management practices, forest roads (or other investments)
built primarily for prevention purposes against fires can also be used for
preventive actions against other risks as well as for the restoration and
remedy works, recreation or economic purposes. The creation of an appropriate
network of forest roads not only contributes to a better protection of forests
against fire, but also to a sustainable economic valuation of forest resources
in many regions. Often, these actions need to be done in order to avoid
complete loss of socio-economic interest of forest areas which may lead to
their abandonment and ultimately to an increased fire risk.
As regards the new
programming period, guidance fiches have been prepared in order to ensure that
the Member States / Regions use the measure correctly. Moreover, the Members States / Regions will have to specify their needs and reasons better, if they wish
to expand the density of their road systems.
VII. Under the share
management, the Commission
adopts the national or regional RDPs, while the implementation and ensuring of
the cost effectiveness and efficiency of the support are under the
responsibility of the Member States and their Management Authorities.
As regards the use of
manual work instead of machinery, sometimes such choices can be linked to the
characteristics of the terrain (orography, environmental aspects etc.) and
should be seen in a wider rural development context.
VIII. A careful
balance needs to be made between the costs of the monitoring and evaluation and
their potential benefits.  Especially, in the case of measuring preventive
actions it is difficult and hence expensive to establish the causality chain.
Moreover, the effectiveness of particular forestry interventions can be
assessed only after several years or even decades. 
As regards the
2014-2020 period, improvements have been introduced.  For instance, a new 'area
supported' indicator for preventive actions will be collected in the CMES.
Moreover, in order to get valuable evaluation results, an enhanced Annual
Implementation Report is foreseen in 2019. In the framework of this report, an
evaluation of the RDP will be carried out and first results on the efficiency
of the RDP will be provided.
IX. 
First alinea
(b) The Commission considers that
Natura 2000 forests represent high environmental values and produce important
and various ecosystem services.  Furthermore, several Natura 2000 provisions
apply to all forest across the EU, both within and outside Natura 2000 sites
and in this respect the role of forests outside Natura 2000 is also very
relevant.
(c) The Commission
considers that the new Rural Development Regulation includes a revised measure
concerning forest protection and restoration. The new measure can provide
support for actions related to prevention and restoration of damage to forests
from forest fires and natural disasters and catastrophic events and may also
provide support for preventive actions concerning pests and diseases under the
condition that the risk of a relevant disaster occurrence is supported by
scientific evidence and acknowledged by scientific public organisations.
(e) A number of
environmental safeguards are already available with regard to the supported
actions. For example in Natura 2000 the protection regime under Article 6.2 and
6.3 of Habitats Directive[4] guarantees that any
significant deterioration of those areas is being avoided. In other areas
environmental impact assessments will also contribute to preventing
environmental counter-effects. Finally, for all actions to be co-financed by EU
funds, a certificate of good environmental practice or sustainable forest
management could be required from the competent national authorities as a
pre-condition to EU co-financing.
In the new programming
period, the environmental performance of the beneficiaries is at the forefront
of the implementation of the different measures. 
(f)
The Commission considers that, when
standard costs are applied in the programmes, the Member States/Regions shall
ensure that the relevant calculations are adequate and accurate and established
in advance in a fair, equitable and verifiable manner. An independent body
should be designated to make the calculations for all the standard costs or to
confirm the adequacy of the calculations. 
(g) A guidance
document on controls and penalties in rural development is being prepared and
discussed with the Member States. The Annex I of this document contains a
checklist for the Member States for the assessment of the reasonableness of the
costs.
Second alinea
(a)
The Commission is currently implementing the recommendation.
The
need for an appropriate description of the preventive actions is included in
the Needs Analysis section in the Strategy in the RDP for 2014-2020 and in some
cases also at the level of Partnership Agreements. 
The
Commission examines the submitted RDPs and checks the intervention logic and
the needs for prevention actions during the program approval period and
requests that preventive actions are based on the protection plan of the area
concerned. 
(b)
The Commission accepts the recommendation.
The
Commission will examine with national authorities the possibility of the
appropriate level of action in the field of common basic criteria to
differentiate forest areas to be classified as low, medium and high fire risk.
(c) The Commission is
currently implementing the recommendation.
The Commission carries
out conformity audits in the Member States to verify that the expenditure paid
is in compliance with the rules. If during the audit weaknesses are found,
financial corrections are applied. 
The measures and the
paying agencies to be audited are determined on the basis of a risk analysis.
The financial importance plays a major role in the quantification of the
exposure to risk. It means that an audit area with high expenditure is more
likely to be highly ranked and audited. Measure 226 has been audited in 2014
and will be audited in 2015.
(d) The Commission is
currently implementing this recommendation through the legal framework for
RDP's and additional guidance.
The new measure covers
broader scale of risks and damages. For the period 2014-20 the relevant measure
fiche as a guidance document includes detailed requirements and clarifications
and as such may serve as a helping tool for the Member State for appropriate
design of the measure. 
The attention of the
Member States/Regions was drawn that in the event of uncertainties concerning
the purpose of the actions, there are other measures specially targeted to
increase the economic value of the forests. 
(e) The Commission accepts the
recommendation.
Some adaptations have already
been introduced: for instance, the 'area supported' indicator for preventive
action will be collected in the 2014-2020 CMES. 
In order to get valuable
evaluation results earlier, an enhanced Annual Implementation Report will be
introduced in 2019. This enhanced AIR provides an assessment of programme
results and, when possible, an assessment of impacts.

Introduction

1. The Commission considers that
since forests are multifunctional and serve economic, social and environmental
purposes by providing vital ecosystem services, their functions cannot be
entirely separated. Therefore, forestry measures targeting primarily economic
purposes may also serve social or environmental objectives. Primarily
protective interventions may also have social, economic and other environmental
benefits. The specific character of forestry processes should be considered
during the design, management and control of forestry measures. 
4. The decrease of the burnt area
can be due to good implementation of the forest fire preventive systems facilitated
by the measure. 
The statistics might show that
the burnt area is more or less at a stable level now, which doesn't mean that
there is no increasing threat of forest fire and other calamities.
5. Forest fires have also an
important socioeconomic impact, affecting livelihoods dependent on forests and
creating distortions in the wood markets and causing casualties.

OBSERVATIONS

21. 
First bullet: The
Commission considers that the ongoing work of the European Commission's Forest
Fire Expert Group and the Standing Forestry Committee acting as a consultation
and information platform with the Member States provides appropriate
information to the Commission on forest fires and other calamities, including
pests and diseases. Submitted RDPs include a chapter on description of forests
and environmental situation and this information supports the assessment of the
programme proposals.
In addition, the
establishment of the Forest Disturbances module of the Forest Information
System for Europe (FISE), following the recent Communication on the EU Forest
Strategy, will reinforce the overview of the forest related natural disasters.
Second bullet: The
RDPs include the SWOT analysis which guides the Member States and regions to make
strategic choices regarding the priorities, objectives and measures to be
included in the programme and should also establish the baseline for monitoring
and evaluation of the programme.
Common reply 22-24:
There are significant
bio-geographical and climate- related differences in the Member States from the
Nordic Circle to the Indian Ocean (Reunion island FR), therefore the forest
fire classification should reflect the characteristics of the region under fire
risk. 
Regulation No. 2158/92 requested
that this classification should be proposed by the Member States and approved
by the Commission. 
In the current EAFDR, Member
States do not need to propose the designation of areas at different fire risk
levels to the Commission. It is the competence of the Member States to
designate such areas.  All the new Member States are in the Expert Group on
Forest Fires and co-operate in the activities of the EFFIS. Information on
forest fires is thus available. These provisions indicate the common intention of
the Commission and the Member States to keep the forest fire prevention
measures targeted and coherent as far as possible, taking into account
significant differences between the Member States bio-geographical conditions.
One of the objectives in the
establishment of the European Forest Fire Information System is to have
harmonized information on forest fires across Europe. This information is
essential in activities of mutual collaboration on forest fire prevention and
fighting.
25. The Commission services are
aware of the general forest fire risk of a Member State or a region when
analysing the RDPs. 
The Commission has proposed a
methodology for the assessment of forest fire risk in the context of the
activities of EFFIS. However, an additional work is needed, in collaboration
with the MS, to derive a harmonized forest fire risk map of Europe. 
26. The Commission has invited
the Slovak authorities to substantially review the methodology of
classification of forest areas at fire risk in the Observation Letter addressed
during the negotiation of the RDP 2014-2020.The Commission will closely examine
with the Slovak authorities the establishment of the needs for the period
2014–2020 taking into account the long-term data on the occurrence of fires and
the proportionality of funding with prevention.
27. The Commission considers that
it has comprehensive information on the historical evolution and the projected
evolution of the natural disasters and other catastrophic events, potential
development of pests and diseases in the context of FISE and through studies
(e.g. on forest adaptation to climate change[5] or other studies on
calamities[6]). However, that information is
not yet harmonised across Member States. The Commission also follows the
requests of Member States for activation of the European Solidarity Funds after
major disasters and their requests for modification of the rural development
programmes. Moreover, Member States regularly inform the Standing Forestry
Committee on major extreme events. 
28. The Commission is currently
working on the establishment of the Forest Information System for Europe
(FISE). A prototype of the system will be available and presented to the
Standing Forestry Committee in December 2014.
29. The Commission considers that
it has an appropriate level of knowledge on the types of natural disasters
affecting forests and also on the needs for disaster prevention for the
analysis of the RDPs through direct contacts with the Member States and
regions, regular EU Forest Directors meetings and the on-going work of the
Standing Forestry Committee and FISE.
30. Considering, there is no
common definition of the "most valuable forest areas", the Commission
would
support the establishment of some kind of 'priority action framework' for EU
co-financing, similar to what already exists in all Member States for the
financing of Natura 2000 by the different EU funds. Member States' priorities
as formulated in that framework would then be reflected in the selection.  
Common reply to 31 – 33:
One of the criteria fixed by the
Managing Authority for the selection of the operations is the coherence with
the Regional Forestry Plan, and with other planning instruments for forests.
This ensures a certain quality of the operations selected and priority is given
to interventions in areas with higher risk of forest fires.
Moreover, as regards forest fire
prevention programmes supported by EU funds since 1992, Member States have
considerable expertise in the prioritisation of projects.
At the regional/MS level the
forest protection plans contain the information how to treat forest fire and
other calamities. Information is also available at the administrative level of provinces
(NUTS-3 level) on the location, size and cause of forest fire. In the new
programming period, the Commission requested that in the Rural Development
Programmes the prevention and protection needs should be enforced by the forest
protection plan.
34. Austria established a system
for the selection of projects which was approved by the Monitoring Committee on
19 June 2014. The system is a 3-step approach built on the eligibility
conditions as described in the measures, additional national legal provisions
and, if relevant, on more detailed criteria. This new system should ensure a
high level of quality of the operations selected for the 2014-2020 programming
period. 
35. Member States have been
establishing the Priority Action Frameworks (PAFs) for the financing of their
Natura 2000 networks since 2012. In the new financing period these PAFs will
represent a most useful tool for prioritizing actions in Natura 2000 sites. The
Commission will make sure that the actions proposed for Natura 2000 sites in
line with the respective member States' PAFs, but also actions in other
environmentally valuable areas such as for example national parks will be given
adequate priority.
The Commission considers that
forests are multifunctional and environmental values should be seen in the
right context. Therefore, the selection criteria developed by the programmes
should also involve other aspects of sustainable forest management. 
Furthermore, several Natura 2000
provisions apply to all forest across the EU, both within and outside Natura
2000 sites.
Box 1 –
Prioritising environmental needs at Member States’ level
The
Slovak authorities have proposed to include environmental criteria among the
selection criteria of sub-measures 8.3 and 8.4 (prevention and restoration of
damages in forests) under the RDP 2014-2020. 
As
regards specific interventions in France, they should be selected according to
the local conditions. In the case of dry sandy soil with very limited organic
content in the top layer the utilization of bulldozers could be considered
appropriate and may provide a quick solution for the restoration of the damaged
area. In certain areas, regarding to their specific bio-geographical
conditions, an appropriate quick reaction is necessary for the prevention of
proliferation of pests and diseases (which could have negative effects on
non-damaged or protected forests), decreasing the forest fire risk and avoiding
desertification should be a high priority. 
37. Forest roads serving fire prevention
objectives can also be used for other purposes. They play an important role in
the restoration and prevention of negative effects of calamities. Furthermore
building two types of roads, one for forest fire prevention and another one for
other purposes, would lead to an ineffective and high-cost investment. 
In Slovakia forest roads built
for forest fire prevention in the framework of the rural development programmes
were efficiently used for quick restoration actions after the current storms
and windfalls. The improved access helped minimise the risk of further
calamities (fires or pests outbreaks) and with the help of the proper access
the soil disturbance was minimized which saved the organic matters of the soil
and was beneficial to the flora and the soil fauna. 
There are no efficient mechanisms
for protection of forests from calamities caused by wind or snow. Therefore,
actions mainly focus on forest fire prevention. The prevention actions are
never linked to the occurred abiotic damages, but to prevent them. Therefore,
the proportion of public support on prevention actions against fire cannot be
directly linked to the damage caused by fire.
See also reply to point 50.
38. The assessments of risks to
forests are financed by EU and national funds. Austria attributes certain
amounts (quotas) of EU funds to the different regions. The rest is financed by
national funds.

Common reply to points 39 - 41: 

The
budget of measure 226 is available for all types of forests, private and
public. Although during the implementation of the program public forests
received a higher financial support, this is neutralised in terms of hectares
supported. According to the 2013 annual progress report for Andalusia, 78 % of
the forest area supported was private.

The Commission considers that
it is up to the Member States and Management Authorities to select the best
projects taking into account their socio-economic and geographical conditions
and to justify the appropriateness of the calculation of the applied costs.

The support for labour-intensive
activities can be linked to the characteristics of the terrain (orography,
environmental aspects etc.) and should be seen in a wider rural development
context. 
42. The Commission considers that
burning, as a method of clearing areas is a very risky operation. It is subject
to very restrictive administrative conditions and it is not socially accepted. 
44. The Commission considers that
due to the increased frequency and strength of heat waves and prolonged
droughts ("primary cause"), which under certain conditions can also
be declared as natural disasters, some programmes introduced actions against
"secondary damages" (pests and diseases) preventing larger scale of
proliferation of damages causing serious environmental and socio-economic
consequences. Therefore, it can be considered that interventions supported
through rural development measures successfully contributed to the objective of
the measure and the respective programmes. 
45. The Commission realised that
in the course of the programming period, Austria faced problems with
implementation of the measures 224 and 225. In spite of constant encouragement,
these measures failed to be successfully implemented. For this reason Austria approved projects aiming at the prevention of forestry potential also under M 226. 
46. The Commission considers that
based on the available knowledge on forest – climate interaction, the
diversification of forests and introduction of various tree species may improve
the resilience of forests against many disasters and fire and may also improve
the climate change adaptability. These diversifications should be introduced
before the disasters occur, based on expert opinions, forest protection plans
and long-term forest or climate adaptation strategies.
47. Due to the fact that the
increase of the frequency or strengths of extreme meteorological events is
foreseen by the IPCC report[7] the Commission
considers that this measure is appropriate to provide prompt response to future
calamities. 
As regards beech wood, not only
insects but also various funguses can damage the wood causing significant value
losses and spreading the risk of pests and diseases to undamaged forests which
is detrimental to previously healthy ecosystems. 
The specific case identified by
the Court will be examined by the Commission.
Box 3 – Examples of
insufficient information or documentation related to the granting of support
under measure 226
The
situation has been remedied. In Aquitaine satellite images are now used for
tracking the damaged areas. Every damaged plot is checked by an expert who
verifies the scale of the damage before requesting the compensation. Then, the
state services process the applications and conduct on the spot checks based on
sampling before providing the compensation.
The
Slovak authorities admitted an administrative error and informed the Commission
that the relevant internal procedures had already been updated.
50. Forest roads may serve multiple
purposes: facilitate the access in case of forest fires, provide access for
preventive operations against fires, as well as extract wood and other forest
products.
The Commission is of the opinion
that forest roads built for the purpose of fire prevention may also serve other
purposes, provided that their original function is not hindered by an
alternative use. 
See also reply to point 51.
51. The use of forest roads for
economic purposes does not compromise their role in forest fire prevention.
Thinning and the removal of biomass is an important part of forest fire
prevention measures. The roads are also used for wood transportation as part of
the necessary preventive activities. Altogether the multiple us of these roads
increases the cost-efficiency of the investment.
52. The use of forest roads for
economic purposes may not compromise their capacity to serve forest disaster prevention
purposes.
53. The Commission considers that
due to the fact that local forests, bio-geographical, geological and ecological
conditions vary significantly throughout the EU, setting up EU- level criteria
concerning minimum requirements could be problematic. Such minimum requirements
should be set at the most appropriate level. 
Moreover, the creation of an
appropriate network of forest roads will not only contribute to better
protection of forests against fire, but also to a sustainable economic
valuation of forest resources in many regions. This is often necessary to avoid
complete loss of socio-economic interest of forest areas which may lead to
their abandonment and ultimately also to an increased fire risk.
54. The Commission considers that
the density of forest roads could be higher or lower depending on the local
bio-geographical and geological conditions. Moreover, forest roads may serve
several areas and holdings and it may happen that some sections of a forest
road cover areas where there already is an appropriate level of road density.
Within 2014-2020 RDPs, the Commission invited Slovak authorities to include, as
one of the selection criteria, the road density in the area.
Box 5 –
Examples of insufficient justification of the standard costs 
Floating
aid rates were not excluded in the past programming period. However, they are
not allowed in the new programming period.
Example
2
See
reply to point 57
57. The support for
labour-intensive activities can be linked to the characteristics of the terrain
(orography, environmental aspects etc.) and should be seen in a wider rural
development context. The
use of manpower could imply more eco-friendly methods and important
socio-economic benefits which is also one of the objectives of rural
development policy.
Box 6 – Example of a costly
activity due to the use of manual labour
Costs'
levels may vary due to various eco-geographical and geological conditions as
well as other factors. There might also be reasons that make it impossible to
use machinery altogether or to use more expensive machinery due to e.g. the
existence of slopes, difficult access, environmental rules etc.
58. The Commission has invited
Slovak authorities to include verification of the reasonableness of the costs
within 2014-2020 RDPs.
60. In some areas there is a
limited number of service providers for some specific tasks.
61. The Commission considers that
the Managing Authorities are the responsible bodies to ensure the efficiency of
the support at the project level. 
Deadweight as such should be
prevented by ensuring that the investment takes place only after the
application for support or the granting of the support. Otherwise, the
assessment of the deadweight might become quite subjective and lead to unequal
treatment among applicants.
62. For the 2014-2020 period, in
respect of investment projects, only expenditure which has been incurred after
an application has been submitted by the beneficiary shall be eligible,
according to Article 60(2) of Regulation 1305/2013. Member States can even
impose a later moment in time such as the grant decision.
63. The Commission is of the
opinion that the reply of the beneficiary would have to be further investigated
to clarify under what conditions and how effectively such an investment would
have been made and whether the original objective could have been achieved at
all without the support through this measure.  
64. Within certain limits, an
"eligible hectare" for activating payment entitlements may contain
some trees, shrubs or bushes.
The limitation of the excessive
development of those trees, shrubs or bushes may reduce the risk of forest
fires in the parcel in the surrounding forest zones.
Common reply to points 65 – 67:
The Commission considers that due
to the fact that natural processes in forests are complex and that measurable
effects of certain interventions may occur only after several years or decades,
forest disaster prevention measures should be seen in a wider context of rural
development and in a long-term time horizon. The Member States' forest
inventories which could be repeated in 10-20 years and other forest monitoring
programmes may provide information on the changes. Forestry measures are
designed and implemented based on information and experiences gained through
long lasting, 100-150 year-long forest management model experiences managed by
Member States' forestry institutes and universities.
68. For the sake of
proportionality, 2007-2013 CMEF included a set of common output indicators
which ensure aggregation and comparison across RDP and which are designed to be
relevant in a significant majority of cases. To illustrate specificities, additional
indicators can be used by MS when appropriate. 
The indicator 'area supported'
for preventive action will be collected in the 2014-2020 CMES. This will fill
in the gap identified in the 2007-2013 CMEF.
69. The observations demonstrate
that, due to the complexity and an existing cross-connection of different
actions, in many cases, it is not meaningful to break down the result
indicators to a too detailed level For this reason the Commission has chosen in
the monitoring and evaluation framework for the 2014-2020 programming period to
assess the results at the focus area level.
70. This indicator is one of the
elements of the evaluation system. The new evaluation system should be
considered globally.
71. The Commission has
acknowledged that in the context of the RDPs, the mid-term evaluation had
limited added value.  Hence the requirement of doing a mid-term evaluation has
been abolished for the programming period 2014-2020.
72. See replies to 69 and 71.
73. Although the average burnt
area in the EU is not increasing, often yearly fire damages are concentrated in
very few countries. These countries vary from year to year (e.g. Portugal &
Spain 2003, Portugal 2005, Italy & Greece 2007, Spain 2012, etc.) Each
year, extreme fire danger due to local hot and dry weather coupled with strong
winds, may occur in specific regions. Specific countries may thus face in given
years extreme fire activity, driven by predominant meteorological fire danger
conditions in areas of the Mediterranean basin or elsewhere in Europe. 
At a Member State level, the
observed differences in trends are often due to extreme fire danger conditions
occurred at given years within the time series examined, as it is evident when
analysing the data on a yearly basis against meteorological fire danger
indicators.[8]
74. The Commission considers that
there is a significant experience in relation to the nature of preventive
measures including knowledge on their efficiency and effectiveness per
programme area. A number of forest disaster prevention projects and programmes
have been supported by EU funds and several studies and research projects have
been conducted during the last 20 years. 

ConClusions and recommendations

76. The Commission
considers that in general forest disaster prevention measures successfully
contributed to the objectives of the rural development programmes. Concrete results have
been achieved and fewer
occurrences of fire took place.
Moreover, lessons have been learned which are applied in relation to the
2014-2020 period, especially as regards the scope of the measure and improved
guidance.
78. The Rural
Development Regulation[9] provides that preventive actions
against fires should cover areas classified by Member States as high and medium
fire risk according to their protection plans. These forest protection plans
and the Member States national or sub-national forest programmes or equivalent
instruments provided appropriate base for targeting and prioritisation during
selection. 
The Commission
analysed the situation of the forest sector including forest disaster prevention
and monitoring aspects in the 2005 Commission Staff Working Document which
formed an annex to the Communication on the implementation of the EU Forestry
Strategy. The Rural Development Regulation requested that forestry measures
should contribute to the implementation of the Community Forestry Strategy. The
above mentioned Forestry Strategy covers economic, environmental and social
aspects of sustainable forest management. 
As regards the new
programming period, the Commission analysed the situation of the forest sector
in the 2013 Commission Staff Working Document, which formed an annex to the
Communication from the Commission to the European Parliament, the Council, the
European Economic and Social Committee and the Committee of the Regions:
"A new EU Forest Strategy: for forests and the forest-based sector."[10]
Recommendation 1
The Member States should:
Second indent: The Commission
considers that Natura 2000 forests represent high environmental values and
produce important and various ecosystem services.  Furthermore, several Natura
2000 provisions apply to all forest across the EU, both within and outside
Natura 2000 sites and in this respect, the role of forests outside Natura 2000
is also very relevant.
The Commission should:
First indent: The Commission is
currently implementing the recommendation.
The need for an appropriate
description of the preventive actions is included in the Needs Analysis section
in the Strategy in the RDP for 2014-2020 and in some cases also at the level of
Partnership Agreements. 
The Commission examines the
submitted RDPs and checks the intervention logic and the needs for prevention
actions during the program approval period and requests that preventive actions
are based on the protection plan of the area concerned. 
Second indent: The Commission
accepts the recommendation.
The Commission will examine with
national competent authorities the possibility of the appropriate level of
action in the field of common basic criteria to differentiate forest areas to
be classified as low, medium and high fire risk.
79. As part of the
sustainable forest management practices, forest roads (or other investments)
built primarily for prevention purposes against fires can also be used for
preventive actions against other risks as well as for the restoration and
remedy works, recreation or economic purposes. The creation of an appropriate
network of forest roads not only contributes to a better protection of forests
against fire, but also to making sustainable economic valuation of forest
resources in many regions. Often, these actions need to be done in order to
avoid complete loss of socio-economic interest of forest areas which may lead
to their abandonment and ultimately to an increased fire risk.
As regards the new
programming period, guidance fiches have been prepared in order to ensure that
the Member States / Regions use the measure correctly. Moreover, the Members States / Regions will have to specify their needs and reasons better, if they wish
to expand the density of their road systems.
Recommendation 2
The Member States
should:
First indent: The
Commission considers that the new Rural Development Regulation includes a
revised measure concerning forest protection and restoration. The new measure
can provide support for actions related to prevention and restoration of damage
to forests from forest fires and natural disasters and catastrophic events and
may also provide support for preventive actions concerning pests and diseases
under the condition that the risk of a relevant disaster occurrence is
supported by scientific evidence and acknowledged by scientific public
organisations.
Third indent: It is
the Commission opinion that a number of environmental safeguards are already
available with regard to the supported actions. For example in Natura 2000 the
protection regime under Article 6.2 and 6.3 of Habitats Directive[1] guarantees that any
significant deterioration of those areas is being avoided. In other areas
environmental impact assessments will also contribute to preventing
environmental counter-effects. Finally, for all actions to be co-financed by EU
funds, a certificate of good environmental practice or sustainable forest
management could be required from the competent national authorities as a
pre-condition to EU co-financing.
In the new programming
period, the environmental performance of the beneficiaries is at the forefront
of the implementation of the different measures. 
The Commission should:
First indent: The
Commission is currently implementing the recommendation.
The Commission carries
out conformity audits in the Member States to verify that the expenditure paid
is in compliance with the rules. If during the audit weaknesses are found,
financial corrections are applied. 
The measures and the
paying agencies to be audited are determined on the basis of a risk analysis.
The financial importance plays a major role in the quantification of the
exposure to risk. That means that an audit area with high expenditure is more
likely to be highly ranked and audited. Measure 226 has been audited in 2014
and will be audited in 2015.
Second indent: The
Commission is currently implementing this recommendation through the legal
framework for RDP's and additional guidance.
The new measure covers
broader scale of risks and damages. For the period 2014-2020, the relevant
measure fiche as a guidance document includes detailed requirements and
clarifications and as such may serve as a helping tool for the Member State for appropriate design of the measure. 
The attention of the
Member States/Regions was drawn that in the event of uncertainties concerning
the purpose of the actions, there are other measures specially targeted to
increase the economic value of the forests. 
80. Under the share
management, the Commission
adopts the national or regional RDPs, while the implementation and ensuring of
the cost effectiveness and efficiency of the support are under the
responsibility of the Member States and their Management Authorities.
As regards the use of manual work
instead of machinery, sometimes such choices can be linked to the
characteristics of the terrain (orography, environmental aspects etc.) and
should be seen in a wider rural development context.
Recommendation 3
The
Member States should:
First indent: The Commission
considers that, when
standard costs are applied in the programmes, the Member States/Regions shall
ensure that the relevant calculations are adequate and accurate and established
in advance in a fair, equitable and verifiable manner. An independent body
should be designated to make the calculations for all the standard costs or to
confirm the adequacy of the calculations.
Second indent: A guidance
document on controls and penalties in rural development is being prepared and
discussed with the Member States. The Annex I of this document contains a
checklist for the Member States for the assessment of the reasonableness of the
costs.
81. A careful balance
needs to be made between the costs of the monitoring and evaluation and their
potential benefits.  Especially, in the case of measuring preventive actions it
is difficult to establish the causality chain. Moreover, the effectiveness of
particular forestry interventions can be assessed only after several years or
even decades. 
As regards the period
2014-2020, improvements have been introduced.  For instance, a new 'area
supported' indicator for preventive actions will be collected in the CMES.
Moreover, in order to get valuable evaluation results, an enhanced Annual
Implementation Report is foreseen in 2019. In the framework of this report, an
evaluation of the RDP will be carried out and first results on the efficiency
of the RDP will be provided.
Recommendation 4
The Commission should:
The Commission accepts the
recommendation.
Some adaptations have already
been introduced: for instance, the 'area supported' indicator for preventive
action will be collected in the 2014-2020 CMES. This will fill in the gap
identified in the 2007-2013 CMEF.
In order to get valuable
evaluation results earlier, an enhanced Annual Implementation Report will be
introduced in 2019. This enhanced AIR provides an assessment of programme
results and, when possible, an assessment of impacts.
[1]          Council
Regulation (EC) No 1698/2005)
[2]         Commission staff working document - Annex
to the :Communication on the implementation of the EU Forestry Strategy
{COM(2005) 84 final} /* SEC/2005/0333 */ http://ec.europa.eu/agriculture/forest/1998-strategy-2006-action-plan/sec-2005-333_en.pdf
[3]          COM(2013)
659 final:
http://ec.europa.eu/agriculture/forest/strategy/index_en.htm
[4]         Council Directive 92/43/EEG
[5]         Impacts
of Climate Change on European Forests and Options for Adaptation http://ec.europa.eu/agriculture/analysis/external/euro_forests/index_en.htm
[6]         http://ec.europa.eu/environment/forests/studies.htm
[7]         https://www.ipcc.ch/pdf/special-reports/srex/SREX_FD_SPM_final.pdf
[8]         San-Miguel-Ayanz,
J., Moreno, J.M., Camia, A. (2013) Analysis of large fires in European
Mediterranean landscapes: Lessons learned and perspectives. Forest Ecology and
Management, 294, pp. 11-22
[9]         Council
Regulation (EC) No 1698/2005)
[10]       COM(2013)
659 final:
http://ec.europa.eu/agriculture/forest/strategy/index_en.htm