Special Report No 24 // 2014#Is EU support for preventing and restoring damage to forests caused by fire and natural disasters well managed? #(pursuant to Article 287(4), second subparagraph, TFEU)
Date: 2015-02-25
Institutions: European Court of Auditors
Subjects: EU aid, cost-effectiveness analysis, damage, disaster area, environmental risk prevention, fire, fire protection, forest, forest conservation, natural disaster, project evaluation

EN 

2014 

NO 24

Special Report 

Is EU support for 
preventing and restoring 
damage to forests 
caused by fire and natural 
disasters well managed?

EUROPEAN
COURT
OF AUDITORS

 
EUROPEAN COURT OF AUDITORS 
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1615 Luxembourg 
LUXEMBOURG

Tel. +352 4398-1

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Luxembourg: Publications Office of the European Union, 2015

ISBN 978-92-872-1561-1
doi:10.2865/980904

© European Union, 2015
Reproduction is authorised provided the source is acknowledged.

Printed in Luxembourg

EN 

2014 

NO 24

Special Report

Is EU support for 
preventing and restoring 
damage to forests  
caused by fire and natural 
disasters well managed?

(pursuant to Article 287(4), second subparagraph, TFEU)

Contents

02

Paragraph

Abbreviations and glossary

I–IX 

Executive summary

1–16 

Introduction

1–2 

3–7 

4–5 

6–7 

The protective function of forests

Fire and natural disasters

Fire

Other types of disasters

8–10 

The rural development policy: a key instrument for the protection of EU forests

11–16 

The RD support for restoring forestry potential and introducing preventive actions (measure 226)

17–20  Audit scope and approach

21–74  Observations

21–42 

PART I — Preventive actions were not sufficiently targeted

22–29 

The Commission did not have a full overview of needs when approving the RDPs

30–35 

Deficiencies in the selection process at Member State level

36–42 

Funding was not aligned with the identified risks and needs

43–54 

PART II — Actions were found which were not appropriate to achieve the objectives of the measure

43 

By their nature, actions audited generally contributed to the objectives of measure 226, however …

44–47  … support was granted for some forestry actions not linked to natural disasters

48–49 

Key eligibility requirements for some types of operations implemented could not be verified

50–52 

Support was granted for forest roads where the particular benefit for fire prevention was not 
demonstrated …

53–54  … and there could be negative environmental side‑effects without adequate consideration of local 

conditions

 
Contents

03

55–64 

PART III — The cost‑effectiveness of the actions financed was not adequately ensured

55–60 

The reasonableness of costs was not always demonstrated

61–64 

Specific situations presenting a risk of excessive public support

65–74 

PART IV — Monitoring tools do not allow the Commission and the Member States to adequately 
assess the efficiency and effectiveness of the measure

66–67 

The monitoring tools available

68–70 

Insufficient indicators to measure the achievement of objectives

71–72 

Limited usefulness of the mid‑term evaluations

73–74 

The effectiveness of the prevention actions has not been adequately measured

75–81  Conclusions and recommendations

Annex I  —  Allocations of financial resources for measure 226

Annex II  — 

List of operations reviewed

Reply of the Commission

 
 
 
04

1  Article 30 of Commission 

Regulation (EC) No 1974/2006 
of 15 December 2006 laying 
down detailed rules for the 
application of Council 
Regulation (EC) No 1698/2005 
on support for rural 
development by the European 
Agricultural Fund for Rural 
Development (EAFRD) (OJ 
L 368, 23.12.2006, p. 15).

2  Article 48 of Council 

Regulation (EC) No 1698/2005 
of 20 September 2005 on 
support for rural development 
by the EAFRD (OJ L 277, 
21.10.2005, p. 1).

Abbreviations  
and glossary

Axis: A coherent group of measures with specific goals contributing to one or 
more of the objectives of the support for rural development. In the period 2007–
13, measure 226 was part of Axis 2, which aims at improving the environment and 
the countryside.

CAP: common agricultural policy

CMEF: common monitoring and evaluation framework

EAFRD: European Agricultural Fund for Rural Development. The EAFRD is the 
main financial instrument of the rural development (RD) policy. The EAFRD is, 
along with the European Agricultural Guarantee Fund (EAGF), one of the two 
financial instruments of the CAP.

EFFIS: European Forest Fire Information System. A database set up by the 
European Commission that contains information relevant to monitor the 
occurrence and impact of forest fires at EU level. The data serves to produce an 
annual report on forest fires in Europe and neighbouring countries.

EU: European Union

Forest: An area of land spanning more than 0,5 hectares with trees higher 
than 5 metres and a canopy cover of more than 10 %, or trees able to reach 
those thresholds in situ. It does not include land that is predominantly under 
agricultural or urban land use1.

Measure: The basic unit of programme management, consisting of a set of 
similar operations financed through a precisely defined budget.

Measure 226: EAFRD support for restoring forestry potential and introducing 
prevention actions2.

Natural disaster: A naturally occurring event of a biotic or abiotic nature 
that leads to important disturbances in forest structures, eventually causing 
important environmental and economic damage.

Need: An opportunity or difficulty relevant for concerned groups or regions, 
which the public intervention aims to address.

Operation: Project selected according to criteria and implemented by the 
beneficiary, including a number of actions related to the objectives of the 
support.

Abbreviations and glossary 

05

Other wooded land: Land of more than 0,5 hectares not classified as a forest. 
It has a canopy cover of 5 to 10 %, or a cover of trees shrubs and bushes above 
10 %. It does not include land that is predominantly under agricultural or urban 
land use.

RD: rural development

RDP: Rural development programme. A document prepared by a Member State 
or region, and approved by the Commission, to plan the implementation of the 
RD policy.

Executive  
summary

I
European forests are threatened by fire, which is gen‑
erally due to intentional or negligent human action, 
and by natural disasters including abiotic (e.g. wind‑
storms, droughts, floods, avalanches, etc.) or biotic 
(pests, diseases) calamities.

II
The Court examined whether the EAFRD support for 
restoring forestry potential in forests damaged by 
natural disasters and fire and for introducing preven‑
tive actions (‘measure 226’) had been well managed 
and achieved intended results in a cost‑effective way. 
This measure was available in the programming period 
2007–13 under Axis 2, which targeted the sustainable 
use of forestry land as a way to improve the environ‑
ment and the countryside in the EU. At the end of 2012 
the total EAFRD support programmed for measure 226 
amounted to 1,55 billion euro for the period 2007–13.

III
The Court’s audit covered the Commission and 
selected Member States (Austria, France (Aquitaine), 
Italy (Basilicata), Spain (Andalusia) and Slovakia). These 
Member States together accounted for more than 85 % 
of the total expenditure declared as of 31 December 
2012. Most of the support (80 %) was for preventive 
actions, mainly against fire.

IV
The Court concludes that the support was not suf‑
ficiently well managed and that the Commission 
and the Member States cannot demonstrate that the 
intended results were achieved in a cost‑effective way.

06

V
Preventive actions were not sufficiently targeted. The 
Court noted that while measure 226 targets forests 
at medium to high risk of fire, there is no common 
EU definition or criteria to identify them. Selection 
procedures in the Member States were deficient in dif‑
ferent respects, lacking explicit selection criteria or an 
effective evaluation of proposed actions or neglecting 
some areas of risk. The environmental objectives were 
insufficiently prioritised at the selection stage and 
sometimes overlooked during the implementation.

VI
The audit found actions which were not appropriate to 
achieve the objectives of the measure. Even though by 
their nature (firebreaks, thinning, clearing, etc.) many 
of the co‑financed actions reviewed generally contrib‑
uted to the objectives of the support, the Court found 
cases not related to natural disasters or fire, but motiv‑
ated by other economic or environmental objectives. 
For some types of the implemented operations key 
eligibility requirements could not be verified due to 
lack of documentation. The Court also found cases of 
forest roads used for the economic exploitation of the 
forests where the particular benefit for fire prevention 
was not demonstrated. The high density of the roads 
constructed could also have negative environmental 
effects.

VII
The cost‑effectiveness of the actions financed was 
not adequately ensured. The Court found cases where 
the ceiling of public support was frequently modified 
without justification, where standard costs in a region 
were significantly higher than in another for similar 
actions and where manual work was prioritised rather 
than using machines, resulting in higher costs. There 
were also situations presenting risks of excessive 
public support when already completed projects were 
selected, where beneficiaries were able to finance 
operations on their own and where support went to 
agricultural parcels.

Executive summary 

07

VIII
Finally, the monitoring tools in place did not allow the 
Commission and the Member States to adequately 
assess the efficiency and effectiveness of the measure. 
In particular, the performance indicators established 
in the common monitoring and evaluation framework 
(CMEF) were insufficient and the evaluations avail‑
able were of limited usefulness. It was not possible to 
draw conclusions on the effectiveness of the preven‑
tive actions because it had not been measured. The 
weaknesses identified are likely to persist in the period 
2014–20 since the new proposed monitoring tools 
have not improved the monitoring framework for this 
specific support.

IX
With regard to the above conclusions and taking into 
account that the audited support is maintained in the 
programming period 2014–20, the Court recommends 
that:

 — Member States should:

(a)  select the prevention actions based on explicit cri‑
teria aligned with the needs and after a thorough 
and documented evaluation process;

(b)  enhance the environmental protective impact of 

the support by prioritising the actions in the most 
environmentally valuable forests such as Natura 
2000 forest areas;

(c)  ensure that only actions linked to natural disasters 

or fire are supported;

(d)  establish a control system which can ensure ef‑

fective verification of compliance with the terms 
under which support is granted, and maintenance 
of appropriate documents or information;

(e)  pay greater attention to environmental considera‑
tions related to the actions supported, in par‑
ticular by establishing appropriate safeguards to 
prevent environmental counter‑effects;

(f)  ensure that the standard costs established for the 

actions supported are reasonable;

(g)  justify the ceiling for support — and any change 

to it — on the basis of the costs normally incurred 
by the beneficiaries;

(h)  require beneficiaries to clearly demonstrate their 

need for the support under measure 226;

(i) 

report on the effects of the actions carried out in 
terms of reduction of the number of fires/or nat‑
ural disasters and of the area damaged.

 — The Commission should:

(a)  verify, during the approval of the Member States’ 
RDPs concerning the period 2014–20, that the 
needs for preventive actions in the forest areas 
where public support is envisaged are adequately 
described and justified;

(b)  set out common basic criteria to differentiate for‑
est areas to be classified as low, medium and high 
fire risk;

(c)  verify that the Member States have established an 

appropriate control system;

(d)  clarify requirements for the actions to be sup‑
ported under measure 226 to ensure that they 
contribute significantly to the prevention of fire 
and natural disasters, in particular when they are 
part of a profitable economic activity and as such 
could also be financed under Axis 1;

(e)  improve its monitoring of the measure to ensure 
that the Member States implement it in line with 
the specific objectives set.

Introduction

08

3 

’Agriculture, forestry and 
fishery statistics‘, Eurostat 
Pocketbooks, 2013. Save as 
otherwise indicated, the term 
‘forest’ is intended in this 
special report as referring also 
to other wooded areas.

4  COM(2013) 659 final of 

20 September 2013 ‘A new EU 
forest strategy: for forests and 
the forest‑based sector’.

5  COM(2010) 66 final of 

1 March 2010 ‘Green Paper on 
forest protection and 
Information in the EU: 
preparing forests for climate 
change’.

(b)  Forests protect soil. Forest areas 

play an important role in preserv‑
ing landscapes and soil fertility. 
Forests prevent soil erosion and 
desertification especially in moun‑
tainous or semi‑arid areas, mostly 
by limiting run‑off and lowering 
wind speed.

(c)  Forests regulate freshwater supplies. 
Forests play a major role in the 
storage, purification and release of 
water to surface water bodies and 
subsurface aquifers. Their purifica‑
tion role includes breaking down 
or absorbing most air pollutants 
carried by rain.

(d)  Forests conserve biodiversity. For‑

ests are a key component of Euro‑
pean nature and they are home to 
the largest number of vertebrates 
on the continent. Thousands of 
species of insects and inverte‑
brates as well as many plants are 
also confined to forest habitats.

(e)  Forests as sinks of carbon. Forests 
are an essential link in the global 
carbon cycle because of their 
capacity to remove carbon dioxide 
(CO2) from the atmosphere and to 
store it in their biomass and soil.

The protective function of 
forests

01 
In the EU the total area of forests and 
other wooded land accounts for about 
180 million hectares, which is about 
42,4 % of the total EU land area and 
more than the land area used for agri‑
cultural purposes (about 174 million 
hectares)3. Forests are multifunctional, 
serving economic, social and environ‑
mental purposes. The socioeconomic 
importance of forests is high: wood 
production and processing contributes 
to rural development and provides 
millions of jobs, often in medium and 
small rural enterprises4.

02 
For several decades, environmental 
forest functions have attracted increas‑
ing attention mainly in relation to the 
protection of biodiversity and, more 
recently, in the context of climate 
change. Forests play an important 
protective function5:

(a)  Forests protect settlements and 
infrastructure. Many mountain 
areas in Europe would be uninhab‑
itable without forests that protect 
roads, railways, cultivated areas 
and even entire settlements from 
damage or destruction through 
landslides, mudflows, rock falls 
and avalanches.

Introduction

Fire and natural disasters

Fire

03 
European forests are threatened by 
fire, which is generally due to inten‑
tional or negligent human action, and 
by natural disasters including abiotic 
(windstorms, droughts, floods, ava‑
lanches, etc.) or biotic (pests, diseases) 
calamities.

04 
In the period 1983–2012 fires burned 
on average 480 000 ha6 of forest area 
in the EU every year. The average 
burnt area was significantly higher 
during the period 1983–92 than in the 
following decades, during which the 
improvement of forest fire fighting 
means in the Member States played an 
important role (see Graph 1)7.

09

6 

7 

EFFIS statistics on burnt areas 
for the period 1980–2012. The 
average value is based on 
information from 20 EU 
Member States. No 
information was available for 
Belgium, Denmark, Ireland, 
Luxembourg, Malta, the 
Netherlands or the United 
Kingdom. 

Joint report of the JRC and the 
Directorate‑General for the 
Environment, Forest Fires in 
Europe, the Middle East and 
North Africa, 2012. The 
statistical data reported covers 
19 Member States. Data relate 
to the period 1980–2012 for 
southern Member States 
(Greece, Spain, France, Italy 
and Portugal). For all the rest 
(Bulgaria, Czech Republic, 
Germany, Estonia, Cyprus, 
Latvia, Hungary, Austria, 
Poland, Romania, Slovakia, 
Finland and Sweden), data are 
reported for the period 
1990–2012.

1
h
p
a
r
G

Average burnt area (ha) per year from 1983 to 2012

600 000

550 000

500 000

450 000

400 000

350 000

300 000

1983-1992

1993-2002

2003-2012

Source: Joint report of the Joint Research Centre (JRC) and the Directorate‑General for the Environ‑
ment, Forest Fires in Europe, the Middle East and North Africa, 2012.

 
In January 2005 the storm ‘Gudrun’ 
swept through southern Sweden and 
produced 66 million m³ of storm‑ 
damaged wood (roughly equivalent 
to the yearly timber harvest in Swe‑
den). In January 2007, the storm ‘Kyrill’ 
caused extensive damage in central 
Europe, including a forest loss of 
45 million m³ (of which 16 million m³ 
in Germany) of standing timber. In 
January 2009 the storm ‘Klaus’ levelled 
enormous areas of plantation forest in 
France (37 million m³, mainly maritime 
pine), Spain and Italy 10. Besides the 
negative environmental impacts, there 
are social (deaths) and economic (de‑
pressed timber prices) consequences 
linked to releasing on to the market 
such huge quantities of damaged 
timber11.

07 
More frequent and severe droughts 
affect large areas of Europe, causing 
water scarcity and increased pressure 
on water resources. On the other hand, 
several major flood disasters oc‑
curred in Europe in the last few years. 
Such disasters also damage forests, 
although to a more limited extent 
than fire, storms and biotic agents like 
insects (e.g. bark beetles), diseases or 
wildlife and uncontrolled grazing12.

10

8 

EEA Report No 3/2008 
’European forests — 
ecosystem conditions and 
sustainable use’, p. 51.

9  COM(2010) 66 final, p. 12; EEA 
Technical Report No 13/2010 
’Mapping the impacts of 
natural hazards and 
technological accidents in 
Europe’, p. 25.

10  EEA Technical Report 

No 13/2010 ’Mapping the 
impacts of natural hazards and 
technological accidents in 
Europe’, pp. 33–40.  
EFI report from STORMS 
Workshop on ‘Policies for 
forest storm damages 
mitigation and restoration’, 
1 July 2010, Brussels, p. 20.

11  COM(2010) 66 final, p. 12.

12  EEA Technical Report 

No 3/2008 ‘European forests 
— ecosystem conditions and 
sustainable use’, pp. 53‑4: in 
2005 in Sweden around 
2 900 000 hectares of damage, 
largely of young pines (Pinus 
sylvestris) caused by browsing 
moose (Alces alces) and in 
southern Italy almost 
500 000 hectares of damage 
due to extensive grazing by 
livestock.

13  Council Regulation (EEC) 

No 3529/1986 of 
17 November 1986 on 
protection of the Community’s 
forests against fire (OJ L 326, 
21.11.1986, p. 5) and Council 
Regulation (EEC) No 2158/92 of 
23 July 1992 on protection of 
the Community’s forests 
against fire (OJ L 217, 31.7.1992, 
p. 3).

14  Article 30 of Council 

Regulation (EC) No 1257/99 of 
17 May 1999 on support for 
rural development from the 
European Agricultural 
Guidance and Guarantee Fund 
(EAGGF) and amending and 
repealing certain Regulations 
(OJ L 160, 26.6.1999, p. 80).

Introduction

05 
Over 95 % of these fires are caused 
by humans, either deliberately or by 
negligence (for example, fires as‑
sociated with agricultural practices, 
such as straw or shrub burning, forest 
debris burning or pasture renewals, 
cigarettes). About 85 % of the total 
area burned by forest fires is located 
in the Mediterranean region and 
Portugal. Recent forest fires resulted 
in large burnt areas in Portugal in 
2003 and 2005, in Greece in 2007 and 
in Spain in 2006. Seriously affected for‑
ests face a major challenge to recover 
pre‑fire condition, in particular with re‑
gard to biodiversity. The environmen‑
tal impact of forest fires is not limited 
to loss of biodiversity and damage to 
ecosystems. They also result in emis‑
sions of particles and gases (including 
CO2) into the atmosphere, outflow of 
mineral nutrients, destruction of the 
organic layer of the soil and changes in 
the water infiltration rates in the soil, 
which make burnt areas prone to ero‑
sion, soil loss and landslides. Recurrent 
forest fires combined with droughts 
may also lead to desertification8.

Other types of disasters

06 
In the period from 1950 to 2009 wind 
storms were the most damaging 
causes in Europe. Storm losses exceed‑
ed 50 % of all abiotic types of forest‑ 
related damage9. The most destructive 
storms in the most recent period hap‑
pened in 1999, 2005, 2007 and 2009. 
The storms of 1999 (‘Lothar’ and ‘Mar‑
tin’) brought the most catastrophic 
damage to France and central Europe 
with nearly 200 million m³ of damaged 
wood. 

Introduction

The rural development 
policy: a key instrument 
for the protection of EU 
forests

08 
The EU has a long history of contribut‑
ing to forest protection, in particular 
with regard to fire prevention. In 
the period 1986 to 2002 EU forests 
benefited from specific regulations 
devoted to forest fire prevention13 and 
since 2000 forest protection has been 
included in the rural development (RD)
policy14.

09 
The RD policy for the programming 
period 2007–13 focused on three core 
objectives15 to be achieved by a series 
of measures grouped, for each objec‑
tive, in a ‘thematic axis’ financially 
supported through the EAFRD16:

(a)  improving the competitiveness of 
the agricultural and forestry sector 
(Axis 1);

(b)  improving the environment and 

the countryside (Axis 2);

(c) 

improving the quality of life in 
rural areas and encouraging di‑
versification of the rural economy 
(Axis 3).

10 
In the period 2007–13, one forestry‑
specific measure (measure 122: 
‘Improvement of the economic value 
of forests’) was covered by Axis 117 and 
various others by Axis 218.

The RD support for 
restoring forestry 
potential and introducing 
preventive actions 
(measure 226)

11 
In the period 2007–13 EAFRD sup‑
port for restoring forest damaged by 
natural disasters and fire, as well as for 
introducing preventive actions, was 
available through measure 226 ‘Restor‑
ing forestry potential and introducing 
preventive actions’ under Axis 2. This 
measure has been included in 58 rural 
development programmes (RDPs) 
drawn up by 16 Member States19.

12 
At the end of 2012 the total EAFRD 
support planned for actions under 
measure 226 was around 1,55 bil‑
lion euro. EAFRD support covers a part 
of the total public support paid to 
beneficiaries by the national adminis‑
tration responsible. The EAFRD co‑ 
financing rate is set in each RDP. The 
total public support may cover up to 
100 % of the eligible costs incurred by 
the beneficiaries of the measure.

11

15  Article 4 of Council Regulation 

(EC) No 1698/2005.

16  For the period 2014–20, the 

grouping of measures in axes 
has been abandoned. In this 
period each measure financed 
by the EAFRD will have to be 
programmed so as to 
contribute to the achievement 
of one or more of the 
following six ‘Union priorities’ 
(Article 5 of Regulation (EU) 
No 1305/2013 of the European 
Parliament and of the Council 
of 17 December 2013 on 
support for rural development 
by the EAFRD and repealing 
Council Regulation (EC) 
No 1698/2005 (OJ L 347, 
20.12.2013, p. 487)):
(1) 

fostering knowledge 
transfer and innovation;

(2)  competitiveness of all 

types of agriculture and 
farm viability;

(3)  food chain organisation 
and risk management;
(4)  restoring, preserving and 
enhancing ecosystems;
(5)  resource efficiency and 

transition to a low‑carbon 
and climate‑resilient 
economy;

(6)  social inclusion, poverty 
reduction and economic 
development.

17  This measure is the subject of 

the European Court of 
Auditors Special Report 
No 8/2013 ‘Support for the 
improvement of the economic 
value of forests from the 
European Agricultural Fund 
for Rural Development’ (http://
eca.europa.eu).

18  Forestry measures under Axis 
2: 221 — First afforestation of 
agricultural land; 222 — First 
establishment of agroforestry 
systems on agricultural land; 
223 – First afforestation of 
non‑agricultural land; 
224 – Natura 2000 payments; 
225 – Forest environmental 
payments; 226 – Restoring 
forestry potential and 
introducing preventive 
actions; 227 – Non‑productive 
investments.

19  Bulgaria, the Czech Republic, 
Denmark, Germany (5), 
Greece, Spain (17), France (3), 
Italy (20), Cyprus, Latvia, 
Lithuania, Hungary, Austria, 
Poland, Portugal (3) and 
Slovakia. 

Introduction

12

2
h
p
a
r
G

Planned EAFRD support under measure 226 for the period 
2007–13 (million euro)

20  Article 48 of Regulation (EC) 

No 1698/2005 and Article 33 of 
Regulation (EC) No 1974/2006.

700

600

500

400

300

200

100

0

Spain

Italy

France

Slovakia

Poland

Portugal

Austria

Czech Rep.
Cyprus

Bulgaria

Germany

Latvia

Lithuania

Hungary

Denmark

Source: European Commission.

13 
EAFRD payments under the measure 
amounted to around 860 million euro 
as of 31 December 2012. Most of the 
support (80 %) was for preventive ac‑
tions, mainly fire prevention activities 
(see Annex I for details on the alloca‑
tion of financial resources for measure 
226).

14 
Public financial support is available 
both for private and public forests, 
since for measure 226 the EU regula‑
tions do not exclude any ownership 
types. RD support for preventive 

actions against fire may be granted 
only for forests classified by the Mem‑
ber States as high or medium forest 
fire risk according to their forest pro‑
tection plans and may cover the estab‑
lishment of protective infrastructures 
(e.g. forest paths, tracks, water supply 
points, cleared and felled areas and 
firebreaks), preventive forestry prac‑
tices (e.g. vegetation control, thinning, 
diversification of vegetation structure) 
and setting up or improvement of 
fixed forest fire monitoring facilities20. 
In the case of forest firebreaks, eligible 
costs may comprise, beyond the cost 
of establishment, subsequent mainte‑
nance costs for the area concerned.

 
Introduction

13

15 
For other preventive actions, as well 
as for actions aimed at restoring 
forestry potential in forests damaged 
by a natural disaster or fire, the EU 
regulations require that they should be 
disaster‑related, which means linked 
to the occurrence or the risk of the 
occurrence of a natural disaster or fire, 
but do not define any specific eligibil‑
ity conditions, such as a minimum level 
of risk.

16 
The rural development support for ‘re‑
storing forestry potential and introduc‑
ing preventive actions’ is under shared 
management between the Commis‑
sion and the Member States. Member 
States develop RDPs at national or 
regional levels. Once approved by the 
Commission, these programmes are 
implemented by the Member States. 
A ‘common monitoring and evaluation 
framework’ has been set up, based on 
common indicators, annual implemen‑
tation reports by the Member States 
and different types of evaluations.

Audit scope and  
approach

14

17 
The main objective of the audit was 
to assess whether the EAFRD support 
measure for restoring forestry poten‑
tial and introducing preventive actions 
has been well managed and whether 
the Commission and the Member 
States can demonstrate that the sup‑
port achieved its intended objectives 
in a cost‑effective way.

18 
The audit focused on the following 
issues:

(a)  Has the support appropriately 

targeted the needs for prevention 
of natural disaster and fire risks?

(b)  Were the operations financed ap‑

propriate to achieve the objectives 
of the measure?

(c)  Were the operations financed 

cost‑effective?

(d)  Are the monitoring tools adequate 
to assess the efficiency and effec‑
tiveness of the measure?

19 
The audit covered both the Commis‑
sion and selected Member States. At 
the level of the Commission the audit 
work covered the design of the meas‑
ure and the Commission management 
activities, including the approval of the 
RDPs submitted by the Member States 
and the monitoring of the implemen‑
tation of the measure. At the level of 
the Member States, the audit included 
visits to Austria, France (Aquitaine), 
Italy (Basilicata), Slovakia and Spain 
(Andalusia). These Member States to‑
gether accounted for more than 85 % 
of the total declared expenditure for 
measure 226 as of 31 December 2012.

20 
The audit work comprised a review of 
RDPs, national or regional legislation 
and administrative procedures as well 
as interviews with the responsible 
managing authorities in the Member 
States visited. In addition 68 opera‑
tions supported under measure 226 
were audited, 45 of them on the spot, 
to verify the effects of the different 
types of eligible actions carried out 
in the forest areas concerned (see An-
nex II for details).

Observations

15

PART I  
Preventive actions were 
not sufficiently targeted

21 
Adequate targeting of the preventive 
actions21 requires that:

 ο

 ο

 ο

the Commission has an overview 
of the natural disaster and fire risks 
when assessing the RDPs submit‑
ted by the Member States;

the selection process at the Mem‑
ber State level is aligned with the 
needs identified in the RDPs;

as a result, funding coincides with 
the areas of risk.

23 
After the expiration of the above‑
mentioned regulation, the provi‑
sions of Article 48 of Regulation (EC) 
No 1698/2005 stated that preventive 
actions against fires must relate to for‑
ests classified by the Member States as 
high or medium forest fire risk accord‑
ing to their forest protection plans24.

24 
In the absence of common criteria for 
assessing fire risks, Member States 
carry out their fire risk analysis based 
on their own methodology. As a result, 
the criteria used for the classification 
of forest areas as medium or high risk 
vary across the EU.

25 
The European Forest Fire Informa‑
tion System (EFFIS) is a database set 
up by the Commission that contains 
information relevant to monitoring the 
occurrence and impact of forest fires 
at EU level25. The data serves to pro‑
duce an annual report on forest fires in 
Europe and neighbouring countries26. 
It is however not used to assess the 
Member States’ fire risk analyses when 
approving the RDPs. The Commission 
does not issue specific guidelines27 
on fire risk classification in order to 
promote best practices and ensure the 
comparability and reliability of Mem‑
ber States’ fire risk analyses.

The Commission did not 
have a full overview of needs 
when approving the RDPs

No common definition of 
forests at fire risk

22 
Until it expired in 2001, Council 
Regulation (EEC) No 2158/92 on the 
protection of the Community’s forests 
against fire set criteria for classifying 
forest areas as low, medium or high 
fire risk. That regulation required the 
Member States to establish lists of 
areas classified by the degree of fire 
risk and to send them to the Commis‑
sion for approval22. The Commission 
decision establishing the lists of the 
forest areas of high and medium fire 
risk in Greece, Spain, France, Italy and 
Portugal23 has not been updated since 
2001 and consequently Member States 
which entered the Union in 2004 and 
after were not part of this exercise.

21  This part focuses on 

preventive actions for which 
adequate targeting is key for 
their effectiveness. They 
represent around 80 % of the 
financed actions.

22  As stated in Article 2(2) and 
2(3) of Regulation (EEC) 
No 2158/92 only areas situated 
in Portugal, Spain and Greece, 
and in certain French and 
Italian regions where the 
permanent or cyclical risk of 
forest fire presents a serious 
threat to the ecological 
balance and the safety of 
persons and goods or 
constitutes a factor which is 
hastening the process of 
desertification of rural areas 
may be classified as areas of 
high risk. Areas other than 
those may be recognised as 
areas of high risk if the 
Member State submitted 
a substantiated request. Areas 
where the forest fire risk is not 
permanent or cyclical but 
presents a significant threat to 
forest ecosystems may be 
classified as areas of medium 
risk.

23  Commission Decision 

No 1619/1993 of 24 June 1993: At 
that time (EU‑12), 60 million 
hectares of forests, equivalent to 
42 % of the then total forest area, 
had been classified as fire‑risk 
zones, mainly in the 
Mediterranean zone.

24  This requirement has not 

changed for the 2014–20 period 
(see Article 24(2), paragraph 3 of 
Regulation (EU) No 1305/2013).

25 

Information about EU forests at 
risk of fire is elaborated on the 
basis of datasets in EFFIS such as 
meteorological fire danger, fire 
incidence, perimeters of burnt 
areas and datasets on fire events 
provided by the countries, which 
are completed by other ancillary 
information about the extent of 
forest resources such as JRC 
forest maps or the European 
Corine Land Cover Database. Up 
to 22 European countries 
provide data on a voluntary basis 
yearly as no EU regulation 
enforces this data provision after 
2006 (after the expiration of the 
forest focus regulation ((EC) 
No 2152/2003).

26  Joint report of the JRC and the 
Directorate‑General for the 
Environment, Forest Fires in 
Europe, the Middle East and 
North Africa, 2012.

16

27 

In its conclusion on the 
prevention of forest fires 
within the European Union 
(3 010th General Affairs 
Council meeting of 
26 April 2010) the Council 
invited the Commission to 
‘include forest fires in the 
priorities to be addressed in 
the ongoing work on 
exchange of good practice 
and development of 
guidelines on risk assessment 
and mapping and guidelines 
on minimum standards for 
hazard‑specific disaster 
prevention’. The Commission, 
in its Staff Working Paper on 
‘Risk assessment and mapping 
guidelines for disaster 
management’ (21 December 
2010), is not specific 
concerning fire and does not 
advocate any particular risk 
criteria, benchmarks or 
standards, underlines the 
existing gaps in the 
methodologies and explains 
that ‘a catalogue of 
recommended methods and 
standards for risk assessments 
will be developed for a future 
version of these guidelines’.

28  COM(2013) 659 final.

Observations

26 
The example of Slovakia illustrates the 
potential discrepancies that can be 
identified using the data available in 
EFFIS. According to the national system 
for the classification of forest areas 
according to risk of fire, 1,8 million out 
of the total 2 million ha of forest land 
is classified as medium or high fire risk 
area in the country. However, neither 
the historical forest fire figures nor the 
EFFIS database (see Graph 3) supports 
such a high percentage of medium 
and high fire risk areas in the country. 
The Slovak authorities did not provide 
the Court’s auditors with their method 
for classification or the criteria used for 
the classification of forest areas under 
the various levels of fire risk.

The Commission does not have 
comprehensive information on 
other natural disasters affecting 
forests

27 
The audit found that the Commission 
does not have comprehensive informa‑
tion on the historical evolution of the 
occurrence of natural disasters and 
catastrophic events (except for fires). 
No analysis is available to the Commis‑
sion on the scale of the damage to for‑
est areas caused by other abiotic (e.g. 
droughts, wind storms or avalanches) 
or biotic calamities (pest and diseases).

28 
In its communication on ‘A new EU 
forest strategy: for forests and the 
forest–based sector’28 the Commission 
acknowledges as strategic orientations 
(a) the ‘set‑up of the Forest Informa‑
tion System of Europe by collecting 
harmonised Europe‑wide information’ 
and ‘integrating diverse information 
systems (e.g. EFFIS) and data platforms 
…’, (b) the need to ‘align EU forest 
information’, (c) the need to ‘improve, 
make comparable and share forest 
information and monitoring …’ and (d) 
the need to ‘develop modules e.g. on 
forests and natural disturbances like 
fires and pests’.

29 
The Commission does not have com‑
prehensive information on the other 
types of natural disasters affecting 
forests and consequently does not 
have a full overview of the needs for 
disaster prevention when assessing 
plans for measure 226 proposed in the 
RDPs submitted by the Member States.

Deficiencies in the selection 
process at Member State 
level

30 
Managing authorities should set 
priorities for acting in the most valu‑
able forest areas (taking into account 
the multifunctional nature of forests, 
as described in paragraphs 1 and 2) 
for which potential significant risks 
have been previously identified. This 
should be reflected in the selection 
procedure.

17

29  Except in Andalusia, in the 

case of the support allocated 
on the basis of competitive 
calls for investment proposals.

30  EEA Report 

31 

No 5/2012 ‘Protected areas in 
Europe — an overview’, 
pp. 70‑79. The terrestrial 
component of the Natura 
2000 network (768 000 km2) 
—  out of which 46 % is Natura 
2000 forest area — covers 
approximately 17,9 % of the 
EU‑27 land territory. Total 
forest area in the EU‑27 is 
about 1,8 million km2.

It is comprised of special areas 
of conservation (SAC) 
designated by Member States 
under the habitats directive, 
and also incorporates special 
protection areas (SPAs) which 
they designate under the birds 
directive. Natura 2000 is not 
a system of strict nature 
reserves where all human 
activities are excluded. While 
the network will certainly 
include nature reserves, most 
of the land is likely to continue 
to be privately owned and the 
emphasis will be on ensuring 
that future management is 
sustainable.

34 
Austria has put in place a forestry as‑
sistance system. The area under the 
responsibility of a local district forestry 
office is divided among professional 
forest advisers, who are responsible 
for the direct contact with forest 
owners and managers. The advisers 
decide whether the forest managers’ 
proposed forestry actions can be sup‑
ported. This decision is not based on 
explicit selection criteria or on a writ‑
ten evaluation of the forestry action 
proposed (assessment of the technical 
specifications, importance, urgency, 
impact on environment etc.).

… or selection criteria not 
prioritising environmental 
needs

35 
Acting in the most environmentally 
valuable EU forest areas such as Natura 
2000 sites was not always given prior‑
ity29 (see Box 1). It is estimated that 
the Natura 2000 network of forest 
areas covers about 20 % of the total 
EU forest area30. The aim of the Natura 
2000 network of areas is to ensure the 
long‑term survival of Europe’s most 
valuable and threatened species and 
habitats31.

Observations

Lack of effective selection 
procedures…

31 
In Italy (Basilicata) the funds avail‑
able to implement the measure were 
first shared out among associations 
of municipalities in proportion to 
the number of forest workers to be 
employed in the municipalities that 
made up each association. After the 
breakdown of the funds, the associa‑
tions submitted projects and aid ap‑
plications corresponding to the funds 
already allocated to each of them. The 
projects and aid applications then 
went through a formal selection and 
ranking process, but this had no prac‑
tical effect because all the applications 
were accepted with a confirmation of 
the amounts of aid already assigned.

32 
Furthermore, concerning the selection 
of the forest areas supported, there 
was no documentation setting out 
the reasons for the choices made or 
making reference to particular levels of 
risk or other technical priority objec‑
tives (for example: work planned with 
specific deadlines in a municipal forest 
management plan, the need to realise 
or complete operations already per‑
formed in other municipal forests).

33 
In Spain (Andalusia) several selection 
criteria were defined for measure 226. 
A selection procedure was applied and 
documented in the case of competi‑
tive calls for investment proposals. In 
contrast, for actions directly promoted 
by the regional authorities, represent‑
ing more than three quarters of the 
spending, criteria did not prioritise 
actions on the basis of a specific risk 
analysis nor was the selection proce‑
dure documented.

Observations

18

1
x
o
B

Prioritising environmental needs at Member State level

Although a significant percentage of the Slovak forests are classified as protected forests (including Natura 
2000) which have a high environmental value, they were not prioritised during the selection process, limiting 
the potential environmental impact of measure 226.

In France (Aquitaine), restoring actions were designed to maximise the surface of forest supported after 
a storm, without prioritising forests of higher environmental value. Also, the regional rules made no allowance 
for the environmental aspects of removing wood and clearing and restoring damaged areas32. For example, 
they did not require ecological studies in sensitive areas at project level and did not forbid certain operations 
that affect soil protection such as the stripping of large swathes by bulldozer.

32  Compared to the Aquitaine region, the Lorraine region, which also funded investment for the restoration of forest crops damaged in the storm of 

1999, drew up rules for taking into account environmental aspects.

33  According to the 2012 annual 

report on the occurrence of 
harmful agents in forests and 
the prognosis for the next year 
issued by the Slovak National 
Forest Centre.

Funding was not aligned 
with the identified risks and 
needs

36 
Funding should be aligned with the 
identified risks and directed to the 
areas which are most in need.

of public support under measure 
226 was used for forest fire preven‑
tion actions (61 %), mainly to finance 
the construction and maintenance 
of forest roads which were primarily 
used for the exploitation of the forests 
without justifying the particular link to 
fire prevention.

In Slovakia and Austria, funding 
did not match the identified 
risks …

37 
In Slovakia, the allocation of finan‑
cial support under measure 226 was 
not in line with the main potential 
forest‑damaging factors. For example, 
although wind‑related calamities were 
the most significant factor in forest 
damage in the country (80 %), followed 
by snow (12 %) and drought with heat 
stroke (7 %)33, the highest proportion 

38 
In Austria, despite the existence of 
detailed forest management plans and 
hazard zone plans, the ongoing as‑
sessment of the forest protection risk 
performed by the Austrian authorities 
has played a limited role in targeting 
aid. There was no clear correlation be‑
tween the basic forest risk and budget 
spending. For instance, the Bundes‑
land Salzburg, whose 376 000 ha of 
forest rank on the very low to medium 
risk scale, was allocated slightly more 
funds than Kärnten, whose 584 000 ha 
of forest rank medium to very high.

 
Observations

19

… while in Italy (Basilicata) 
and Spain (Andalusia), funding 
went mainly to the public 
owned forests to support 
labour‑intensive activities

39 
The audit found a disproportionately 
high allocation of support to certain 
public bodies (regional or municipal 
authorities) for operations in publicly 
owned forests and also a concentra‑
tion of funds in costly labour‑intensive 
activities.

41 
In Spain (Andalusia), while more than 
70 % of forests are in private hands, 
the expenditure under the measure 
for public forest areas was about three 
times more than for private ones. 
 Neither the RDP nor the ex ante evalua‑
tion provided information that would 
have justified the unequal distribu‑
tion of financial resources, whereas 
the explanation given by the Spanish 
authorities about the lack of profitabil‑
ity of the private forest sector indicates 
a need for public support.

40 
In Italy (Basilicata), measure 226 was 
applied exclusively to municipally 
owned forests, which constitute only 
30 % of the total forest area of the 
region. The fact that a forest area is 
municipally owned does not imply 
that the area in question is at a greater 
risk of fire. In fact, in 2012, the forest 
area affected by fire in Basilicata had 
increased by 93 % as compared to 
2011, and by 231 % as compared to the 
2009–11 period. These fires had mostly 
taken place in areas of privately owned 
forests. The limitation of the support 
to municipal forests was due to the in‑
tention to ensure employment for the 
forest workers recruited every year for 
seasonal work in municipally owned 
forests (see paragraph 31).

42 
Furthermore in the same region, in 
the case of the competitive calls for 
investment proposals in 2008, the 
public support granted under meas‑
ure 226 for clearing of bushes and 
shrub‑covered areas represented six 
times more financial resources than 
the total amount used in the region 
for other specific actions financed for 
fire prevention such as the creation 
and maintenance of firebreaks, or the 
cre ation and maintenance of water 
points. While the clearing of bushes 
and shrub‑covered areas has a positive 
effect in coping with fire spread, they 
are costly labour‑intensive activities. 
The Spanish authorities recognised 
that clearance and thinning had been 
used in many areas where controlled 
burns would have been economically 
and ecologically advisable. They justi‑
fied their choice by the lack of skilled 
personnel and the existence of legal 
(detailed administrative burn orders 
are required) and social obstacles, but 
they plan to develop the use of con‑
trolled burns in the near future.

20

34  DG Agriculture and Rural 

Development report of March 
2009 on implementation of 
forestry measures under 
Regulation (EC) No 1698/2005: 
‘ … Nevertheless, actions 
related to pest management 
can be considered eligible 
under this measure, if linked to 
a natural disaster e.g. windfall, 
floods or forest fires’.

Observations

PART II  
Actions were found which 
were not appropriate to 
achieve the objectives of 
the measure

By their nature, actions 
audited generally contrib‑
uted to the objectives of 
measure 226, however …

43 
Support under measure 226 had to 
be granted only for restoring forestry 
potential in forests damaged by nat‑
ural disasters and fire and for introdu‑
cing preventive actions. Due to their 
nature (firebreaks, thinning, clearing 
etc.) many of the co‑financed actions 
reviewed during the audit generally 
contributed to the objectives of the 
support. Some projects were particu‑
larly relevant because of their high 
protective nature (see Box 2).

… support was granted for 
some forestry actions not 
linked to natural disasters

Pest and disease management

44 
Restoration and preventive actions 
under measure 226 should be disas‑
ter‑related, meaning that they should 
be linked to the occurrence or the risk 
of a natural disaster. Damage caused 
by insect/pests or diseases as such is 
not considered as natural disaster34. 
For that reason, actions related to 
normal pest management should 
not be eligible for funding unless the 
outbreak is a consequence of a nat‑
ural disaster. In Spain (Andalusia) and 
Slovakia, preventive actions related 
to pest management were supported 
under measure 226, even though they 
were not linked to any natural disaster. 
They were considered eligible as there 
was already a pest outbreak in the 
area. However, the limited scale of the 
outbreak did not justify the existence 
of a risk of natural disaster.

2
x
o
B

An example of good practice (projects of high environmental value)

In Austria several projects were financed to prevent avalanches in forests under protection status by perform‑
ing horizontal felling of trees, which also significantly contributes to protecting water springs that feed into 
nearby municipal water systems.

 
Observations

21

Actions transferred from other 
measures

Infrastructure built long after 
the occurrence of the natural 
disaster

45 
In Austria all actions initially launched 
under measures 224, ‘Natura 2000 pay‑
ments’, and 225, ‘Forest‑environment 
payments’, were actually financed 
under measure 226. However, meas‑
ures 224 and 225 concern actions 
aimed at maintaining and improving 
environmental functions of forest 
areas and stands not linked to disaster 
prevention, whilst measure 226 only 
provides for disaster‑related support. 
Similarly, some planting projects, 
initially submitted under measure 122 
intended for ‘improving the economic 
value of forest’, were later approved 
under measure 226, without a clear 
indication of their links to any natural 
disasters.

Increase of the number of tree 
species

46 
Support under measure 226 in Andalu‑
sia included actions aimed at main‑
taining and improving the ecosystems 
of wooded areas by increasing the 
number of tree species in a particular 
zone where there was no deterioration 
or loss of tree cover as a consequence 
of natural disaster or fire. Therefore, 
in Andalusia, the primary objective of 
those actions was not related to the 
objective of measure 226.

47 
Wet timber storage is a technique that 
helps maintain the quality of the wood 
after felling and thus optimises the 
sale price. Stocking timber facilities 
were supported in Austria to prevent 
bark beetle outbreaks in pine tree 
 areas affected by the occurrence of 
nat ural disasters (wind storms). The 
audit found that such facilities, which 
were built long after the occurrence 
of the disaster, were actually used to 
stock beech wood, which is only mar‑
ginally affected by bark beetles.

Key eligibility requirements 
for some types of operations 
implemented could not be 
verified

48 
Article 4(1) of Regulation (EU) 
No 65/2011 provides that, as a general 
principle of control, Member States 
shall establish a control system that 
ensures that all necessary checks are 
carried out for effective verification 
of compliance with the terms under 
which support is granted. Article 
33(2) of the same regulation provides 
that a sufficient audit trail shall be 
maintained.

Observations

22

51 
The creation and maintenance of for‑
est roads used mainly for the extrac‑
tion of wood and other forest prod‑
ucts is not the purpose of measure 
226. For these operations the EAFRD 
provides appropriate support under 
Axis I (measures 122 and 125) which 
aims to improve the competitiveness 
of the forestry sector. While forest 
roads are necessary to fight fires, 
measure 226 should avoid supporting 
projects which are mainly motivated 
by economic objectives, without hav‑
ing a particular benefit for fire preven‑
tion. Several audited projects (5 out of 
the 8 audited involving roads in pri‑
vately owned forests) did not include 
a justification of benefits in relation to 
the fire prevention objectives, so as to 
ensure an effective contribution of the 
support to environmental objectives.

49 
The Court audit found the systemic 
weaknesses set out in Box 3. Because 
of those weaknesses, it was not pos‑
sible to verify compliance with the 
terms under which the support was 
granted due to a lack of documenta‑
tion or information supporting key 
eligibility requirements.

Support was granted for  
forest roads where the 
particular benefit for fire 
prevention was not demon‑
strated …

50 
Measure 226 supported the construc‑
tion and maintenance of forest roads 
and tracks in France (Aquitaine), 
Austria, Slovakia and Spain (Andalusia) 
which were used for extracting wood 
and other forest products (cork barks) 
from productive private forests (see 
Box 4).

3
x
o
B

Examples of insufficient information or documentation related to the granting of 
support under measure 226

In Aquitaine (France), an important eligibility criterion to be verified for all aid applications was the compli‑
ance with the minimum damage threshold fixed by the regional authorities (minimum 40 %). The audit re‑
vealed that there was no administrative information system to identify the forest stands affected by the 1999 
wind storms and the level of damage. As a result it was not possible to verify the accuracy of the applicants’ 
declarations.

In Slovakia, the documentation in the files of the public procurement process was incomplete as only the 
winning bid was kept in the beneficiary file, but not the losing bids. This results in a loss of evidence on the 
effective evaluation of the bids.

 
Observations

23

Example of the economic use of forest roads supported by measure 226 (Aquitaine, 
France)

4
x
o
B

52 
In Austria, for instance, a project 
concerned the construction of a forest 
road, giving access to 25 ha of forests. 
The main purpose of the project was 
to open up the forest for wood extrac‑
tion by its owners. Arguments put 
forth in the project files include the 
mobilisation of unused forest reserves, 
increasing the profitability of timber 
mobilisation and supplying local 
sawmills.

… and there could be 
negative environmental 
side‑effects without ade‑
quate consideration of local 
conditions

53 
The conditions for supporting the 
creation and maintenance of forest 
roads under measure 226 should be 

made clear, so as to ensure an effective 
contribution of the support to environ‑
mental objectives. The EU regulations 
did not define any minimum require‑
ments, such as limitation of access, 
a density not jeopardising the safe‑
guard of ecosystems or compulsory 
certification of projects by local fire 
services, to ensure adequate protec‑
tion of the environment. According to 
the ‘Feasibility study on means of com‑
bating forest dieback in the European 
Union’, a technical report prepared 
for DG Environment  (December 2007), 
‘road construction may contribute 
to forest protection, or may do the 
opposite … Networks of forest roads 
provide access to forest fires and 
therefore help forest fire fighting. In 
contradiction forest roads can lead to 
an increased fragmentation of forests, 
de‑stabilising ecosystem functions 
and therefore leading to an increased 
vulnerability of forests’.

 
24

35  The total forest is classified as 

high fire risk area.

Observations

54 
In Slovakia, for forest roads covered 
by the operations financed under 
measure 226, the RDP approved by the 
Commission provided for an optimum 
density of 20–25 m/ha. The audit 
found that a disproportionately high 
density of forest roads was actually 
supported, which may have a negative 
impact on the ecological status of the 
forests concerned. For example, one 
private beneficiary applied in 2008 for 
four projects related to the creation of 
new forest roads in its forest holding35. 
Before the infrastructural investment, 
the length of forest roads in its forest 
holding was marginal. As a result of 
the investment, approximately 40 km 
of new forest roads were constructed 
resulting in forest road density of 
36 m/ha, which is higher than the opti‑
mum density of 20–25 m/ha indicated 
in the RDP. Another beneficiary built 
3 619 m of forest roads in its forest 
holding of 24,96 ha, achieving a forest 
road density of 145 m/ha, which is very 
high compared either to the Slovak 
average (approximately 10,6 m/ha) or 
to the optimum density of 20–25 m/ha 
indicated in the RDP.

PART III  
The cost‑effectiveness of 
the actions financed was 
not adequately ensured

The reasonableness of 
costs was not always 
demonstrated

55 
Article 24(2)(d) of Commission Regu‑
lation (EU) No 65/2011 implement‑
ing Regulation (EC) No 1698/2005 as 
regards control procedures provides 
that administrative checks on applica‑
tions for support shall include verifica‑
tion of the reasonableness of the costs 
submitted, which should be evaluated 
using a suitable evaluation system, 
such as reference costs, a comparison 
of different offers or an evaluation 
committee.

56 
Deficiencies in the procedures put in 
place in Austria, Slovakia and Italy (Ba‑
silicata) affected the reasonableness of 
the costs of the actions supported (see 
Box 5).

Observations

25

5
x
o
B

Examples of insufficient justification of the standard costs

Example 1

In Austria, the type of interventions and their ceilings (fixed upper limits or lump sums per ha or tree) were de‑
fined every year. However, there was no justification or apparent logic for the establishment of certain ceilings 
which were significantly modified from one year to another:

Afforestation after natural disasters

In Kärnten, the ceiling for afforestation of deciduous forest (> 75 % broadleaves) was initially fixed at 
1 800 euro/ha in 2008, while from 2009 it increased to 2 500 euro/ha. In 2010 the support for afforestation was 
up to 6 000 euro/ha.

Thinning

Also in Kärnten, there was an increase of the ceiling for thinning from 300 euro/ha in 2008 to 400 euro/ha 
in 2009 and in the case of lump sum payments concerning protection of forests from 420 euro/ha to 
560 euro/ha.

In Niederösterreich, the public support for thinning was 350 euro/ha from 2007 to 2009. In 2010 it was in ‑
creased to a maximum amount of 750 euro/ha (if supported by invoices) or 500 euro/ha in case of lump sum 
payments. Both of these amounts were again reduced to 350 euro/ha as from 2011.

Example 2

The standard costs set out in the Basilicata region were significantly higher than in other neighbouring Italian 
regions for the same or similar preventive actions as illustrated below.

Manual clearing work

The standard cost of manual clearing work for creating 1,2 metre‑wide paths in Basilicata was 7,81 euro per 
metre; while the standard cost of a comparable activity — creation of ‘a 1 metre‑wide path in any type of ter‑
rain’ — in the Puglia region was only 3,58 euro per metre.

Restoration of service paths

Regarding restoration of service paths, the standard working time was 35 minutes per metre and the standard 
cost was 6,89 euro per metre in Basilicata. For a similar activity in the Puglia region, the standard working time 
was 9 minutes (including 3 minutes with a strimmer) and the standard cost was 2,15 euro per metre. A similar 
activity was performed in the Campania region at a cost of 2,77 euro per metre.

 
Observations

26

57 
In the Basilicata region the activities 
could have been carried out more eco‑
nomically and efficiently by making 
greater use of machines (as in other re‑
gions) rather than manpower. Because 
of the more extensive use of manual 
labour, in various cases the standard 
costs set out in the Basilicata region 
are much higher than in other regions 
for the same or similar activ ities (see 
Box 6).

58 
In Slovakia all projects are subject 
to public procurement rules which 
should ensure the efficiency in the use 
of public funds. The auditors noted 
that there was no evaluation of the 
reasonableness of any of the invest‑
ment costs claimed by the beneficiar‑
ies even though the projects were 
financed 100 % from public funds. The 
only formal check was to verify that 
the threshold established in the public 
procurement process was not exceed‑
ed by the expenditure claimed by the 
applicant.

6
x
o
B

Example of an activity that is costly due to the use of manual labour

Maintenance of forest roads

The total cost for maintaining 7 253,82 metres of forest road in Basilicata amounted to 337 665,32 euro36 at 
a standard cost of 46,55 euro per metre.

For a similar forest road with the same length in Tuscany the maintenance work performed using both manual 
and mechanical means would cost only 37 828,67 euro as the standard cost in that region is 5,21 euro per 
metre.

36  46,55 euro per metre.

59 
In Andalusia, some actions, represent‑
ing around 13,5 % of the total con‑
tractual price for the performance of 
forestry works in a project concerning 
public forests, had not been carried 
out. On the other hand, some other 
actions had been carried out by the 
contractor at a much higher price 
than that planned in the technical 
project. As the total approved cost of 
the project had not been exceeded, 
the beneficiary had not been required 
to justify either the non‑execution of 
certain actions or the increased cost of 
others.

60 
In France, for certain restoration and 
maintenance interventions, beneficiar‑
ies are required to submit only one 
offer with their application. Present‑
ing several offers would contribute to 
ensuring that the most economically 
advantageous offer is selected.

 
27

37  Article 34 of Council 

Regulation (EC) No 73/2009 of 
19 January 2009 establishing 
common rules for direct 
support schemes for farmers 
under the common 
agricultural policy and 
establishing certain support 
schemes for farmers, 
amending Regulations (EC) 
No 1290/2005, (EC) 
No 247/2006, (EC) No 378/2007 
and repealing Regulation (EC) 
No 1782/2003 (OJ L 30, 
31.1.2009, p. 16) lays down that 
support is granted upon 
activation of a payment 
entitlement per eligible 
hectare. An ‘eligible hectare’ is 
defined in the same article as 
any ‘agricultural area of the 
holding … or, where the area 
is used as well for 
non‑agricultural activities, 
predominantly used for 
agricultural activities’.

63 
In Slovakia two beneficiaries audited, 
receiving support for the construction 
of forest roads, confirmed during the 
on‑the‑spot audit visit that they would 
have carried out the actions even with‑
out the public funding.

64 
In Spain predominantly agricultural 
land (pastures with trees, shrub pas‑
ture and grazing land), which had 
been declared as ‘eligible hectares’ 
for the purpose of activating payment 
entitlements37 and identified as such 
in the Spanish land parcel identifica‑
tion system, was also eligible for the 
purpose of granting forestry support 
under measure 226. Some beneficiar‑
ies received support for clearing of 
shrub and bushes under measure 226, 
as a preventive action against fire, 
while they were already required to 
maintain their parcel as agricultural 
land in good agricultural and environ‑
mental condition (i.e. clear from shrubs 
and bushes).

Observations

Specific situations present‑
ing a risk of excessive public 
support

61 
Giving support in cases where the 
need of the beneficiary is not clearly 
demonstrated (deadweight) under‑
mines the efficiency of the support.

62 
In Austria projects already completed 
were financed under the measure. 
The national implementing regulation 
entered into force in the beginning of 
2008 and consequently the first award 
decisions were only issued in April 
2008. However, potential beneficiar‑
ies were allowed and encouraged to 
submit applications for support from 
January 2007 and to execute the pro‑
jects at their own risk. In total, 3 671 
support claims were submitted in 
2007 out of which at least 444 projects 
were completed before the date of the 
award decision. Regarding the applica‑
tions submitted from 2008 onwards, at 
least 147 projects were executed prior 
to the grant approval, even though the 
implementing regulation in force since 
2008 stated that the project‑related 
costs for projects under measure 226 
are only eligible as from the date of 
the support decision. In these situa‑
tions, the beneficiaries’ initial decisions 
to carry out the projects without the 
aid called into question their need to 
receive public support.

28

38  Articles 80 and 81 of 

Regulation (EC) No 1698/2005.

Observations

PART IV  
Monitoring tools do not 
allow the Commission and 
the Member States to 
adequately assess the 
efficiency and effective‑
ness of the measure

65 
Assessing whether measure 226 has 
been effective requires the use of ap‑
propriate monitoring and evaluation 
tools, enabling the identification of 
necessary improvements to maximise 
the impact of the EU support.

67 
The Commission issued guidelines set‑
ting the following common output in‑
dicators related to the implementation 
of measure 226: (a) number of preven‑
tive/restoration actions; (b) supported 
areas of damaged forest; and (c) total 
volume of investments. In addition to 
these output indicators, the follow‑
ing result indicator was defined in the 
CMEF for measure 226: area under suc‑
cessful land management contributing 
to the improvement of biodiversity 
water and soil quality, and to mitigat‑
ing climate change.’

The monitoring tools 
available

66 
For the period 2007–13, a ‘common 
monitoring and evaluation framework’ 
was drawn up in cooperation between 
the Commission and the Member 
States. The progress, efficiency and 
effectiveness of the implementation 
of the RDPs in relation to their objec‑
tives is measured by means of indica‑
tors relating to the baseline situation, 
financial execution, outputs, results 
and impact of the programmes38.

Insufficient indicators to 
measure the achievement of 
objectives

68 
Although most of the actions financed 
are of a preventive nature, the output 
indicator set for such actions (number 
of preventive actions) was insufficient. 
The output indicator defined as ‘sup-
ported areas of damaged forest’ only 
refers to forest actually damaged by 
disasters, so this indicator is relevant 
only for the restoration actions.

69 
As regards the result indicator relating 
to the improvement of biodiversity, 
water and soil quality and the mitiga‑
tion of climate change, the audit found 
that none of the visited managing 
authorities were able to attribute the 
result of each action to one or the oth‑
er aspect of the indicator and, in fact, 
some reported the same total area as 
the result achieved for each aspect of 
the indicator.

29

39  Commission Implementing 
Regulation (EU) 808/2014 of 
17 July 2014 laying down rules 
for the application of 
Regulation (EU) No 1305/2013 
of the European Parliament 
and of the Council on support 
for rural development by the 
European Agricultural Fund 
for Rural Development 
(EAFRD) (OJ L 227, 31.7.2014, 
p. 18).

Observations

70 
The result indicator set for the new 
programming period 2014–2039 (num‑
ber of agricultural holdings partici‑
pating in risk management schemes) 
does not represent an improvement to 
evaluate the effectiveness of the sup‑
port so the weaknesses identified are 
likely to persist.

Limited usefulness of the 
mid‑term evaluations

71 
The rural development programmes 
are evaluated as to their preparation, 
implementation and completion (ex 
ante, mid‑term and ex post evalua‑
tions). Whilst the ex ante evaluation 
aims at optimising the allocation of 
budgetary resources and improving 
programming quality, the mid‑term 
and ex post evaluations examine the 
degree of utilisation of resources, the 
effectiveness and efficiency of the 
programming of the EAFRD, its socio‑
economic impact and its impact on 
the Union priorities. Regarding meas‑
ure 226, the four evaluation questions 
defined in the CMEF for the period 
2007–13 relate to the extent to which 
the supported actions have contrib‑
uted to: (a) restoring forestry potential 
(damaged forests); (b) maintenance of 
forests (preventive actions); (c) increas‑
ing the sustainable management of 
forestry land; and (d) improving the 
environment.

72 
The audit found that, with regard to 
measure 226, the information obtained 
from the mid‑term evaluations was 
disparate and incomplete. For ex‑
ample, for Basilicata and Aquitaine the 
evaluators did not provide answers to 
any of the questions, in contrast with 
Andalusia. However, although all ques‑
tions were answered for Andalusia, 
the replies were not always useful to 
assess the progress of implementa‑
tion because the same figures (num‑
ber of operations and number of ha) 
were provided both for the questions 
relating to the maintenance of forests 
and the sustainable management of 
forestry land.

The effectiveness of the  
prevention actions has not 
been adequately measured

73 
Fire damage is concentrated in a few 
Member States in the Mediterranean 
region. Statistics at EU level show 
a moderate decrease in total area 
burnt in recent years (see paragraph 4). 
However the trend at Member State 
level is not the same (see Graph 3).

Observations

30

3 Hectares of forest burnt in countries with measure 226 support
h
p
a
r
G

Thousands hectares

1 400
1 300
1 200
1 100
1 000
900
800
700
600
500
400
300
200
100
0

Spain

Portugal

Italy

France

Bulgaria

Poland

Hungary

Cyprus

Latvia

Germany

Slovakia
Czech Republic

Lithuania

Austria

Denmark

1993-1999

2000-2006

2007-2012

Source: EFFIS.

74 
Most of the EAFRD support under 
measure 226 aimed at introducing pre‑
ventive actions, particularly for forest 
fire prevention (see Annex I). Although 
80 % of the EU funds are used for 
financing preventive operations, the 
effectiveness of such operations is not 
measured. Accordingly, the Commis‑
sion has no statistics to confirm the 
effectiveness of the fire prevention 
actions implemented by the Member 
States under measure 226 and has not 
requested any geographical informa‑
tion on the areas where the activities 
supported have been implemented.

 
Conclusions and 
recommendations

31

75 
In the period 2007–13 the EU support 
under RD measure 226 aimed at restor‑
ing forestry potential in forests dam‑
aged by natural disasters and fire, and 
introducing appropriate preventive ac‑
tions. Most of the support (80 %) was 
for preventive actions, mainly against 
fire. The Court has examined whether 
the support has been well managed 
and whether the Commission and the 
Member States can demonstrate that 
the support achieved its intended 
objectives in a cost‑effective way. 
A sample of 68 actions was audited, 
45 of them on the spot with the final 
beneficiary.

76 
The Court concludes that the support 
was not sufficiently well managed and 
that the Commission and the Mem‑
ber States cannot demonstrate that 
the intended results were achieved in 
a cost‑effective way.

77 
With particular regard to the fact that 
such a support is available in the cur‑
rent programming period 2014–2040, 
the Court makes the recommendations 
set out below:

Preventive actions were 
not sufficiently targeted

40  Article 24 of Regulation (EU) 

No 1305/2013.

78 
The Court noted that while measure 
226 targets forests at medium to high 
risk of fire, there is no common EU 
definition or criteria to identify them. 
Selection procedures in the Mem‑
ber States were deficient in different 
respects, lacking explicit selection 
criteria or an effective evaluation of 
proposed actions or neglecting some 
areas of risk. The environmental objec‑
tives were insufficiently prioritised at 
the selection stage and sometimes 
overlooked during the implementation 
(see paragraphs 21 to 42).

Recommendation 1

The Member States should:

—  Select the prevention actions 

based on explicit criteria aligned 
with the needs and after a thor‑
ough and documented evaluation 
process.

—  Enhance the environmental pro‑
tective impact of the support by 
prioritising the actions in the envir‑
onmentally most valuable forests 
such as Natura 2000 forest areas.

The Commission should:

—  Verify, during the approval of the 
Member States’ RDPs concerning 
the period 2014–2020, that the 
needs for preventive actions in the 
forest areas where public sup‑
port is envisaged are adequately 
described and justified.

—  Set out common basic criteria to 
differentiate forest areas to be 
classified as low, medium and high 
fire risk.

Conclusions and recommendations

32

Actions were found which 
were not appropriate to 
achieve the objectives of 
the measure

79 
Even though, due to their nature (fire‑
breaks, thinning, clearing, etc.), many 
of the co‑financed actions reviewed 
generally contributed to the objectives 
of the support, the Court found cases 
not related to natural disasters or fire, 
but motivated by other economic or 
environmental objectives. For some 
types of the implemented operations 
key eligibility requirements could not 
be verified due to lack of documenta‑
tion. The Court also found cases of 
forest roads used for the economic ex‑
ploitation of the forests where the par‑
ticular benefit for fire prevention was 
not demonstrated. The high density of 
the roads constructed could also have 
negative environmental effects (see 
paragraphs 43 to 54).

Recommendation 2

The Member States should:

—  Ensure that only actions linked to 
natural disasters or fire are sup‑
ported and

—  Establish a control system which 

can ensure effective verification of 
compliance with the terms under 
which support is granted, and 
maintenance of appropriate docu‑
ments or information.

—  Pay greater attention to environ‑
mental considerations related to 
the actions supported, in particular 
by establishing appropriate safe‑
guards to prevent environmental 
counter‑effects.

The Commission should:

—  Verify that the Member States have 

established such a system.

—  Clarify requirements for the 

actions to be supported under 
measure 226 to ensure that they 
contribute significantly to the 
prevention of fire and natural 
disasters, in particular when they 
are part of a profitable economic 
activity and as such could also be 
financed under Axis 1.

The cost‑effectiveness of 
the actions financed was 
not adequately ensured

80 
Regarding the costs of the actions sup‑
ported, the Court found cases where 
the ceiling of public support was fre‑
quently modified without justification, 
where standard costs in a region were 
significantly higher than in another 
for similar actions and where manual 
work was prioritised rather than using 
machines, resulting in higher costs. 
There were also situations presenting 
risks of excessive public support when 
already completed projects were se‑
lected, where beneficiaries were able 
to finance operations on their own and 
where support went to agricultural 
parcels (see paragraphs 55 to 64).

Conclusions and recommendations

33

effectiveness of the preventive actions 
because it had not been measured 
(see paragraphs 65 to 74). The weak‑
nesses identified are likely to persist 
in the period 2014–20 since the new 
proposed monitoring tools have not 
improved the monitoring framework 
for this specific support.

Recommendation 4

The Members States should:

—  Report on the effects of the 

actions carried out in terms of 
reduction of the number of fires/
or natural disasters and of the area 
damaged.

The Commission should:

— 

Improve its monitoring of the 
measure to ensure that the Mem‑
ber States implement it in line with 
the specific objectives set.

Recommendation 3

The Member States should:

—  Ensure that the standard costs 
established for the actions sup‑
ported are reasonable.

—  Justify the ceiling for support — 
and any change to it — on the 
 basis of the costs normally in‑
curred by the beneficiaries.

—  Require beneficiaries to clearly 
demonstrate their need for the 
support under measure 226.

Monitoring tools do not 
allow the Commission and 
the Member States to 
adequately assess the 
efficiency and 
effectiveness of the 
measure

81 
In particular, the performance indi‑
cators established in the CMEF were in‑
sufficient and the evaluations available 
were of limited usefulness. It was not 
possible to draw conclusions on the 

This Report was adopted by Chamber I, headed by Mrs Rasa BUDBERGYTĖ, 
Member of the Court of Auditors, in Luxembourg at its meeting of 
17 December 2014.

For the Court of Auditors

Vítor Manuel da SILVA CALDEIRA
President

 
 
 
Annexes

34

I Allocations of financial resources for measure 226
x
e
n
n
A

Public expenditure 
planned in the period 
2007–13 (first RDPs)

Financial execution 
Public expenditure as of 
31.12.2012

Number of actions 
supported

(euro)

Financial execution EAFRD (for NEW 
applications in 2007–13 programming 
period)

Member 
States

Bulgaria

Czech 
Republic

Denmark

Germany

Greece

Spain

France

Italy

Cyprus

Latvia

Lithuania

Hungary

Austria

Poland

Portugal

Slovakia

TOTAL

EAFRD con‑
tribution 
measure 
226

Total 
public ex‑
penditure 
measure 
226

24 224

22 379

3 692

11 005

136 082

468 573

257 364

233 655

2 250

12 974

12 000

8 251

40 934

112 000

119 313

88 281

29 541

28 017

6 712

14 239

179 996

789 950

467 498

431 691

4 500

16 218

15 000

10 736

81 932

140 000

146 077

111 354

EAFRD 
payments

Total public 
payments

Prevention Restoration 

Prevention 
— pay‑
ments

Restora‑
tion — 
payments

Total 
EAFRD 
payments

544

11 068

3 792

11 082

0

342 441

154 768

143 722

1 336

1 676

8 510

1 084

40 959

31 121

19 012

89 844

664

13 835

6 895

13 852

0

543 633

283 910

252 069

2 671

2 104

10 637

1 392

83 018

38 901

21 502

113 396

37

47

0

717

0

18 666

455

1 716

86

13

28

0

12 683

74

237

179

29

264

0

308

0

1 223

5 656

261

30

248

167

4 105

3 842

169

70

186

244

3 189

0

9 112

0

275 944

7 153

131 141

962

1 091

6 215

0

28 866

19 424

14 684

57 104

300

7 879

0

1 970

0

25 486

40 010

9 725

373

584

2 295

1 084

8 180

5 158

4 328

32 740

544

11 068

0

11 082

0

301 430

47 163

140 866

1 336

1 675

8 510

1 084

37 046

24 582

19 012

89 844

1 552 977

2 473 463

860 958

1 388 480

34 938

16 558

555 129

140 113

695 242

 
Annexes

35

I List of operations reviewed
I
x
e
n
n
A

Member 
State

Operation 
Number

Total public 
expenditure 
(euro)

Total EAFRD  
contribution 
(euro)

On‑the‑spot 
visit

Nature of operation

Type of intervention

Prevention

Prevention

Restoration

Restoration

Restoration

Prevention

Firebreaks, fire plan 

Thinning, lane maintenance

Clearing, reforestation

Clearing, thinning

Thinning, lane maintenance

Preventive actions

Prevention and restoration

Prevention and restoration

Thinning, clearing, forest track main­
tenance, densification

Thinning, clearing, reforestation, lane 
construction and maintenance

Prevention

Restoration

Restoration

Prevention

Prevention

Restoration

Thinning, clearing

Thinning, clearing

Clearing

Firebreak construction and 
maintenance 

Firebreaks, fire plan

Forest road and lane maintenance

4 464,30

641 768,30

13 013,61

499 443,40

951 688,65

51 488,59

3 348,23

482 437,85

9 782,18

374 582,55

713 766,49

38 871,67

2 262 163,20

1 741 226,39

1 038 834,14

784 763,11

1 750 955,95

1 313 216,96

60 236,19

209 115,15

45 177,14

165 631,35

278,78

225,00

34 323,01

297 550,92

33 750,00

276 095,98

Prevention and Restoration

Thinning, clearing and reforestation

1 712 450,99

1 314 688,73

Risk prevention

Risk prevention

Risk prevention

Damage restoration

Damage restoration

Damage restoration

Damage restoration

Damage restoration

Damage restoration

Damage restoration

Cleaning, restoration

Access

Infrastructure

Cleaning, restoration

Cleaning, restoration

Restoration

Cleaning, restoration

Cleaning, restoration

Cleaning

Cleaning, restoration

Damage restoration

Cleaning, restoration

5 368,00

44 791,12

140 768,62

113 979,04

178 750,88

4 121,85

11 035,20

14 331,68

63 490,90

34 342,00

18 182,15

9 760,00

81 438,40

255 942,96

207 234,62

325 001,60

7 494,28

20 064,00

26 057,60

115 438,00

62 440,00

33 058,46

Yes

Yes

Yes

Yes

Yes

No

No

No

No

No

No

No

No

No

No

No

No

Yes

Yes

Yes

Yes

Yes

Yes

No

No

No

ES

ES

ES

ES

ES

ES

ES

ES

ES

ES

ES

ES

ES

ES

ES

FR

FR

FR

FR

FR

FR

FR

FR

FR

FR

FR

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

1

2

3

4

5

6

7

8

9

10

11

 
Annexes

36

I
I
x
e
n
n
A

Member 
State

Operation 
Number

Nature of operation

Type of intervention

Total public 
expenditure 
(euro)

Total EAFRD  
contribution 
(euro)

On‑the‑spot 
visit

IT

IT

IT

IT

IT

IT

IT

IT

IT

IT

IT

IT

IT

IT

IT

IT

IT

IT

AT

AT

AT

AT

AT

AT

AT

AT

AT

AT

AT

AT

AT

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

1

2

3

4

5

6

7

8

9

10

11

12

13

Prevention

Prevention

Prevention

Prevention

Prevention

Prevention

Prevention

Prevention

Prevention

Prevention

Prevention

Prevention

Prevention

Prevention

Prevention

Prevention

Prevention

Prevention

Restoration

Prevention

Restoration

Natura 2000

Prevention

Restoration

Restoration

Restoration

Prevention

Prevention

Prevention

Prevention

Prevention

Firebreaks, tracks, clearing

Firebreaks, tracks

Firebreaks, tracks

Firebreaks, tracks, clearing

Firebreaks, tracks

Firebreaks, tracks

Firebreaks, tracks

Firebreaks, tracks, clearing

Firebreaks, tracks

Firebreaks, tracks, clearing

Firebreaks, tracks, clearing

Firebreaks, tracks

Firebreaks, tracks

Firebreaks, tracks

Firebreaks, tracks, clearing

Firebreaks, tracks, clearing

Firebreaks, tracks

Firebreaks, tracks, clearing

Clearing of forest after disaster

Thinning

Planting

Environmentally valuable trees

Horizontal felling, cable extraction

Cable extraction

Cable extraction

Cable extraction

Cable extraction, preparation, planting, 
thinning

Cable extraction, preparation, planting, 
thinning

Control of bark beetle

Forest road

Repair of protection forest, preven­
tion of avalanches, cable extraction, 
planting, etc.

1 192 999,59

1 034 691,15

1 042 459,99

816 808,12

407 399,34

394 524,99

405 571,49

1 244 483,70

625 927,12

616 179,62

1 378 702,24

706 745,31

1 002 850,95

900 440,30

998 533,36

499 266,68

608 695,65

583 960,24

33 800,00

5 840,00

9 001,00

5 080,00

29 029,00

17 058,00

18 500,00

115 883,00

685 974,76

594 947,41

599 414,50

469 664,67

234 254,62

226 851,87

233 203,61

715 578,13

359 908,09

354 303,28

792 753,79

406 378,55

576 639,30

517 753,17

574 156,68

287 078,34

350 000,00

335 777,14

16 413,00

3 041,00

4 371,00

2 646,00

15 118,00

8 283,00

9 008,00

56 273,00

123 698,00

61 994,00

98 538,00

48 250,00

684 810,00

142 415,00

333 434,00

69 342,00

128 062,00

62 250,00

Yes

Yes

Yes

Yes

Yes

Yes

Yes

Yes

Yes

Yes

Yes

Yes

Yes

Yes

Yes

Yes

Yes

Yes

Yes

Yes

Yes

Yes

Yes

Yes

Yes

Yes

Yes

Yes

No

No

No

 
Annexes

37

I
I
x
e
n
n
A

Member 
State

Operation 
Number

Nature of operation

Type of intervention

Total public 
expenditure 
(euro)

Total EAFRD  
contribution 
(euro)

On‑the‑spot 
visit

SK

SK

SK

SK

SK

SK

SK

SK

SK

SK

SK

1

2

3

4

5

6

7

8

9

10

11

Prevention

Prevention

Prevention

Restoration

Restoration

Prevention

Prevention

Prevention

Prevention

Restoration

Restoration

Infrastructure, forest road, water 
reservoir, monitoring

503 619,00

402 895,00

Infrastructure, forest road

404 885,00

222 687,00

Infrastructure, forest road, water 
reservoir

Aerial liming and fertilisation

Reforestation

Infrastructure, forest road

Infrastructure, forest road

Cleaning and maintenance of firefight­
ing strip

Infrastructure, forest road; other cur­
ative measures

903 141,00

722 513,00

633 904,00

204 132,00

778 136,00

79 689,00

507 123,00

163 305,00

622 509,00

63 751,00

371 433,00

297 146,00

504 977,00

403 982,00

Reforestation, forest road

1 495 292,00

1 196 234,00

Reforestation

153 271,00

122 617,00

Yes

Yes

Yes

Yes

Yes

Yes

No

No

No

No

No

 
Reply of the  
Commission

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 2014–20 period, especially as regards the scope 
of the measure and improved guidance.

V
The rural development regulation1 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 
subnational forest programmes or equivalent instru‑
ments provided an appropriate base for targeting 
and prioritisation during selection. 

The Commission analysed the situation of the for‑
est 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 abovementioned forestry strategy cov‑
ers economic, environmental and social aspects of 
sustainable forest management. 

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).

38

As regards the new programming period, the Com‑
mission 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 Commit‑
tee and the Committee of the Regions ‘A new EU for‑
est 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 restoration and remedy works, 
recreation or economic purposes. The creation of 
an appropriate network of forest roads not only 
contributes to 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 socioeconomic interest of forest areas which 
may lead to their abandonment and ultimately to 
an increased fire risk.

As regards the new programming period, guid‑
ance 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 bet‑
ter, if they wish to expand the density of their road 
systems.

3   COM(2013) 659 final: http://ec.europa.eu/agriculture/forest/

strategy/index_en.htm

Reply of the Commission 

39

VII
Under the shared management, the Commission 
adopts the national or regional RDPs, while the 
implementation and ensuring of the cost effective‑
ness and efficiency of the support are under the 
responsibility of the Member States and their man‑
agement 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 meas‑
uring preventive actions it is difficult and hence 
expensive to establish the causality chain. More‑
over, the effectiveness of particular forestry inter‑
ventions can be assessed only after several years or 
even decades. 

As regards the 2014–20 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 indent (b)
The Commission considers that Natura 2000 forests 
represent high environmental values and produce 
important and various ecosystem services. Further‑
more, several Natura 2000 provisions apply to 
all forests across the EU, both within and outside 
Natura 2000 sites and in this respect the role of for‑
ests outside Natura 2000 is also very relevant.

IX First indent (c)
The Commission considers that the new rural 
development regulation includes a revised meas‑
ure 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 sup‑
port for preventive actions concerning pests and 
diseases under the condition that the risk of a rel‑
evant disaster occurrence is supported by scientific 
evidence and acknowledged by scientific public 
organisations.

IX First indent (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 the habitats directive4 
guarantees that any significant deterioration of 
those areas is being avoided. In other areas environ‑
mental impact assessments will also contribute to 
preventing environmental counter‑effects. Finally, 
for all actions to be co‑financed by EU funds, a cer‑
tificate of good environmental practice or sustain‑
able forest management could be required from the 
competent national authorities as a precondition 
for 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. 

IX First indent (f)
The Commission considers that, when standard 
costs are applied in the programmes, the Member 
States/regions shall ensure that the relevant calcula‑
tions 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. 

4  Council Directive 92/43/EEC.

Reply of the Commission 

40

IX First indent (g)
A guidance document on controls and penalties in 
rural development is being prepared and discussed 
with the Member States. Annex I to this document 
contains a checklist for the Member States for the 
assessment of the reasonableness of the costs.

IX Second indent (a)
The Commission is currently implementing the 
recommendation.

The need for an appropriate description of the 
preventive actions is included in the needs ana‑
lysis section in the strategy in the RDP for 2014–20 
and in some cases also at the level of partnership 
agreements. 

The Commission examines the submitted RDPs 
and checks the intervention logic and the need for 
prevention actions during the programme approval 
period and requests that preventive actions are 
based on the protection plan for the area concerned. 

IX Second indent (b)
The Commission accepts the recommendation.

The Commission will examine with national author‑
ities the possibility of the appropriate level of action 
in the field of common basic criteria to differenti‑
ate forest areas to be classified as low, medium and 
high fire risk.

IX Second indent (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 ana‑
lysis. 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 
was audited in 2014 and will be audited in 2015.

IX Second indent (d)
The Commission is currently implementing this 
recommendation through the legal framework for 
RDPs and additional guidance.

The new measure covers a 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 meas‑
ures specially targeted to increase the economic 
value of the forests. 

IX Second indent (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 2014–20 
CMES. 

In order to get valuable evaluation results earlier, 
an enhanced annual implementation report will be 
introduced in 2019. This enhanced AIR will provide 
an assessment of programme results and, when 
possible, an assessment of impacts.

Reply of the Commission 

41

Introduction

Observations

01
The Commission considers that since forests are 
multifunctional and serve economic, social and 
environmental purposes by providing vital eco‑
system 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 charac‑
ter of forestry processes should be considered dur‑
ing the design, management and control of forestry 
measures. 

04 The decrease in 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 does not 
mean that there is no increasing threat of forest fire 
and other calamities.

05
Forest fires also have an important socioeconomic 
impact, affecting livelihoods dependent on forests 
and creating distortions in the wood markets and 
causing casualties.

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 con‑
sultation and information platform with the Member 
States provides appropriate information to the Com‑
mission on forest fires and other calamities, including 
pests and diseases. Submitted RDPs include a chapter 
on the description of forests and the environmental 
situation and this information supports the assess‑
ment of the programme proposals.

In addition, the establishment of the Forest Disturb‑
ances module of the Forest Information System for 
Europe (FISE), following the recent communication on 
the EU forest strategy, will reinforce the overview of 
forest‑related natural disasters.

21 Second bullet
The RDPs include a 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 biogeographical and climate‑ 
related differences in the Member States, from the 
Nordic Circle to the Indian Ocean (Réunion , France), 
and so the forest fire classification should reflect 
the characteristics of the region under fire risk. 

Regulation No 2158/92 requested that this classifi‑
cation should be proposed by the Member States 
and approved by the Commission. 

Reply of the Commission 

42

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 For‑
est Fires and cooperate in the activities of the EFFIS. 
Information on forest fires is thus available. These pro‑
visions indicate the common intention of the Com‑
mission and the Member States to keep the forest 
fire prevention measures targeted and coherent as 
far as possible, taking into account significant differ‑
ences between the Member States’ biogeographical 
conditions.

One of the objectives in the establishment of the 
European Forest Fire Information System is to have 
harmonised information on forest fires across Europe. 
This information is essential in activities of mutual col‑
laboration 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 the EFFIS. However, additional 
work is needed, in collaboration with the Member 
States, to derive a harmonised forest fire risk map of 
Europe. 

26
The Commission has invited the Slovak authorities 
to substantially review the methodology of clas‑
sification of forest areas at fire risk in the observa‑
tion letter addressed during the negotiation of the 
RDP 2014–20.The Commission will closely examine 
with the Slovak authorities the establishment of the 
needs for the period 2014–20 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 comprehen‑
sive information on the historical evolution and the 
projected evolution of 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 change5 
or other studies on calamities6). However, that infor‑
mation is not yet harmonised across Member States. 
The Commission also follows the requests of Member 
States for activation of the European Solidarity Fund 
after major disasters and their requests for modifica‑
tion of the rural development programmes. More‑
over, Member States regularly inform the Standing 
Forestry Committee about 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 appro‑
priate 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 ongoing work of the Standing Forestry 
Committee and FISE.

30
Considering that 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.

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

Reply of the Commission 

43

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 plan‑
ning instruments for forests. This ensures a certain 
quality in the operations selected and priority is 
given to interventions in areas with a higher risk of 
forest fires.

Moreover, as regards forest fire prevention pro‑
grammes supported by EU funds since 1992, Member 
States have considerable expertise in the prioritisa‑
tion of projects.

At the regional/Member State level the forest protec‑
tion plans contain the information on how to treat 
forest fires and other calamities. Information is also 
available at the administrative level of provinces 
(NUTS 3 level) on the location, size and cause of 
forest fires. 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 three ‑
step approach built on the eligibility conditions as 
described in the measures, additional national legal 
provisions and, if relevant, more detailed criteria. 
This new system should ensure a high level of 
quality of the operations selected for the 2014–20 
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 financ‑
ing period these PAFs will represent a most useful 
tool for prioritising actions in Natura 2000 sites. The 
Commission will make sure that the actions pro‑
posed for Natura 2000 sites in line with the respec‑
tive 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 multi‑
functional 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
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 2014–20. 

As regards specific interventions in France, they 
should be selected according to the local condi‑
tions. In the case of dry sandy soil with very limited 
organic content in the top layer, the utilisation of 
bulldozers could be considered appropriate and 
may provide a quick solution for the restoration of 
the damaged area. In certain areas, regarding their 
specific biogeographical conditions, an appropri‑
ate quick reaction is necessary for the prevention 
of proliferation of pests and diseases (which could 
have negative effects on non‑damaged or pro‑
tected forests), decreasing the forest fire risk and 
avoiding desertification should be a high priority. 

Reply of the Commission 

44

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 pro‑
grammes 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 pest outbreaks) and with the help 
of the proper access the soil disturbance was mini‑
mised, which saved the organic matter in 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 preven‑
tion. The prevention actions are never linked to the 
abiotic damages that have occurred, but rather to 
prevent them. Therefore, the proportion of public 
support for prevention actions against fire cannot be 
directly linked to the damage caused by fire.

See also the reply to paragraph 50.

38
The assessments of risks to forests are financed 
by EU and national funds. Austria attributes cer‑
tain amounts (quotas) of EU funds to the different 
regions. The rest is financed by national funds.

Common reply to points 39–41
The budget for measure 226 is available for all types 
of forests, private and public. Although during the 
implementation of the programme public forests 
received 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 Mem‑
ber States and management authorities to select 
the best projects taking into account their socioeco‑
nomic 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 condi‑
tions and 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 con‑
ditions can also be declared as natural disasters, some 
programmes introduced actions against ‘secondary 
damages’: pests and diseases preventing a larger 
scale of proliferation of damages causing serious 
environmental and socioeconomic consequences. 
Therefore, it can be considered that interventions 
supported through rural development measures suc‑
cessfully contributed to the objective of the measure 
and the respective programmes. 

Reply of the Commission 

45

45
The Commission realised that in the course of the 
programming period, Austria faced problems with 
implementation of 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 measure 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 climate change adaptability. These diversi‑
fications 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 
strength of extreme meteorological events is fore‑
seen by the IPCC report7, the Commission considers 
that this measure is appropriate to provide prompt 
responses to future calamities. 

As regards beech wood, not only insects but also 
various funguses can damage the wood, causing 
significant value lossesand spreading the risk of 
pests and disease to undamaged forests, which is 
detrimental to previously healthy ecosystems. 

The specific case identified by the Court will be 
examined by the Commission.

7   https://www.ipcc.ch/pdf/special‑reports/srex/SREX_FD_SPM_

final.pdf

Box 3
The situation has been remedied. In Aquitaine 
satellite images are now used for tracking the dam‑
aged areas. Every damaged plot is checked by an 
expert who verifies the scale of the damage before 
requesting the compensation. The state services 
then 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 rele‑
vant 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 paragraph 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 are an impor‑
tant part of forest fire prevention measures. The 
roads are also used for wood transportation as part 
of the necessary preventive activities. Altogether 
the multiple use of these roads increases the cost‑
efficiency of the investment.

Reply of the Commission 

46

52
The use of forest roads for economic purposes may 
not compromise their capacity to serve forest disas‑
ter prevention purposes.

53
The Commission considers that due to the fact that 
local forests, biogeographical, geological and eco‑
logical 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 sus‑
tainable economic valuation of forest resources in 
many regions. This is often necessary to avoid the 
complete loss of socioeconomic interest in  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 biogeographical 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 the 
2014–20 RDPs, the Commission invited the Slovak 
authorities to include, as one of the selection crit‑
eria, the road density in the area.

Box 5 
Floating aid rates were not excluded in the past pro‑
gramming period. However, they are not allowed in 
the new programming period.

Example 2
See reply to paragraph 57.

57
The support for labour‑intensive activities can be 
linked to the characteristics of the terrain (oro‑
graphy, 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 socioeconomic benefits, 
which is also one of the objectives of rural develop‑
ment policy.

Box 6
Costs' levels may vary due to various eco‑geo‑
graphical 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 the Slovak authorities 
to include a verification of the reasonableness of 
the costs within 2014–20 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 ensur‑
ing that the investment takes place only after the 
application for support or the granting of the sup‑
port. Otherwise, the assessment of the deadweight 
might become quite subjective and lead to unequal 
treatment among applicants.

Reply of the Commission 

47

62
For the 2014–20 period, in respect of invest‑
ment projects, only expenditure which has been 
incurred after an application has been submitted 
by the bene ficiary shall be eligible, according to 
Art icle 60(2) of Regulation No 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 inves‑
tigated 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 activat‑
ing payment entitlements may contain some trees, 
shrubs or bushes.

68
For the sake of proportionality, the 2007–13 CMEF 
included a set of common output indicators which 
ensure aggregation and comparison across RDPs 
and which are designed to be relevant in a signifi‑
cant majority of cases. To illustrate specificities, 
additional indicators can be used by Member States 
when appropriate. 

The indicator ‘area supported’ for preventive action 
will be collected in the 2014–20 CMES. This will fill 
in the gap identified in the 2007–13 CMEF.

69
The observations demonstrate that, due to the com‑
plexity and an existing cross‑connection of differ‑
ent 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 
2014–20 programming period to assess the results 
at the focus area level.

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.

70
This indicator is one of the elements of the evalua‑
tion system. The new evaluation system should be 
considered globally.

Common reply to paragraphs 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, for‑
est disaster prevention measures should be seen 
in a wider context of rural development and in 
a long‑term time horizon. The Member States’ for‑
est invent ories, which could be repeated in 10 to 
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.

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 2014–20.

72
See replies to paragraphs 69 and 71.

Reply of the Commission 

48

73
Although the average burnt area in the EU is not 
increasing, often yearly fire damages are concen‑
trated in very few countries. These countries vary 
from year to year (e.g. Portugal and Spain in 2003, 
Portugal in 2005, Italy and Greece in 2007 and Spain 
in 2012). 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 condi‑
tions 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 pro‑
grammes have been supported by EU funds and 
several studies and research projects have been 
conducted during the last 20 years. 

8   San‑Miguel‑Ayanz, J., Moreno, J. M. and Camia, A., ‘Analysis 

of large fires in European Mediterranean landscapes: Lessons 
learned and perspectives’, Forest Ecology and Management, 294, 
2013, pp. 11–22.

Conclusions and recommendations

76
The Commission considers that in general forest 
disaster prevention measures successfully contrib‑
uted 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 rela‑
tion to the 2014–20 period, especially as regards the 
scope of the measure and improved guidance.

78
The rural development regulation9 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 instru‑
ments provided an appropriate base for targeting 
and prioritisation during selection. 

The Commission analysed the situation of the for‑
est 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 abovementioned forestry strategy cov‑
ers economic, environmental and social aspects of 
sustainable forest management. 

9  Council Regulation (EC) No 1698/2005).

Reply of the Commission 

49

As regards the new programming period, the Com‑
mission 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 Com‑
mittee and the Committee of the Regions ‘A new 
EU forest strategy: for forests and the forest‑based 
sector.’10 

Recommendation 1 — The Commission 
should — Second indent
The Commission accepts the recommendation.

The Commission will examine with national com‑
petent 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.

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. Fur‑
thermore, several Natura 2000 provisions apply to 
all forests 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.

Recommendation 1 — 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 ana‑
lysis section in the strategy in the RDP for 2014–20 
and in some cases also at the level of partnership 
agreements. 

The Commission examines the submitted RDPs 
and checks the intervention logic and the need for 
prevention actions during the programme approval 
period and requests that preventive actions are 
based on the protection plan of the area concerned. 

10   COM(2013) 659 final: http://ec.europa.eu/agriculture/forest/

strategy/index_en.htm

79
As part of the sustainable forest management prac‑
tices, forest roads (or other investments) built pri‑
marily for prevention purposes against fires can also 
be used for preventive actions against other risks as 
well as for restoration and remedy works, recreation 
or economic purposes. The creation of an appropri‑
ate network of forest roads not only contributes to 
a better protection of forests against fire, but also 
to making a sustainable economic valuation of for‑
est resources in many regions. Often, these actions 
need to be done in order to avoid complete loss of 
socioeconomic interest of forest areas which may 
lead to their abandonment and ultimately to an 
increased fire risk.

As regards the new programming period, guid‑
ance fiches have been prepared in order to ensure 
that the Member States/regions use the measure 
correctly. Moreover, the Member States/regions 
will have to specify their needs and reasons bet‑
ter, if they wish to expand the density of their road 
systems.

Reply of the Commission 

50

Recommendation 2 — The  Member 
States should — First indent
The Commission considers that the new rural 
development regulation includes a revised meas‑
ure 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 sup‑
port for preventive actions concerning pests and 
diseases under the condition that the risk of a rel‑
evant disaster occurrence is supported by scientific 
evidence and acknowledged by scientific public 
organisations.

Recommendation 2 — The  Member 
States should — Third indent
It is the Commission’s 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 Art‑
icle 6.2 and 6.3 of the habitats directive guarantees 
that any significant deterioration of those areas 
is being avoided. In other areas environmental 
impact assessments will also contribute to prevent‑
ing envir onmental 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 precondition 
for 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. 

Recommendation 2 — 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. Meas‑
ure 226 was audited in 2014 and will be audited in 
2015.

Recommendation 2 — The Commission 
should — Second indent
The Commission is currently implementing this 
recommendation through the legal framework for 
RDPs and additional guidance.

The new measure covers a 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 meas‑
ures specially targeted to increase the economic 
value of the forests. 

80
Under the shared management, the Commission 
adopts the national or regional RDPs, while the 
implementation and ensuring of the cost effective‑
ness and efficiency of the support are under the 
responsibility of the Member States and their man‑
agement authorities.

Reply of the Commission 

51

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 2014–20 
CMES. This will fill the gap identified in the 2007–13 
CMEF.

In order to get valuable evaluation results earlier, 
an enhanced annual implementation report will be 
introduced in 2019. This enhanced AIR will provide 
an assessment of programme results and, when 
possible, an assessment of impacts.

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 calcula‑
tions 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.

Recommendation 3 — The Member 
States should — Second indent
A guidance document on controls and penalties in 
rural development is being prepared and discussed 
with the Member States. Annex I to 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 meas‑
uring 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 2014–20, 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 the first results on the effi‑
ciency of the RDP will be provided.

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In the 2007–13 programming period, the European 
Agricultural Fund for Rural Development (EAFRD) provided 
support for restoring forestry potential in forests damaged 
by natural disasters and fire, as well as for preventive 
actions. The Court’s audit concludes that the support was 
not sufficiently well managed and that the Commission and 
the Member States cannot demonstrate that the intended 
results were achieved in a cost-effective way. 
Preventive actions were not sufficiently targeted. The audit 
found actions which were not appropriate to achieve the 
objectives of the measure. The cost-effectiveness of the 
actions financed was not adequately ensured. Finally, the 
monitoring tools in place did not allow the Commission and 
the Member States to adequately assess the efficiency and 
effectiveness of the measure.

EUROPEAN
COURT
OF AUDITORS