COMMISSION STAFF WORKING DOCUMENT IMPACT ASSESSMENT REPORT Accompanying the proposal for a Regulation of the European Parliament and of the Council on a monitoring framework for resilient European forests
Date: 2023-11-22
Institutions: Directorate-General for Environment, European Commission
Subjects: European forestry policy, adaptation to climate change, environmental monitoring, exchange of information, forest, forest conservation, forestry development, forestry economics, sustainable forest management, wooded area

EN 

  EN 

   EUROPEAN COMMISSION  Brussels, 22.11.2023  SWD(2023) 373 final  COMMISSION STAFF WORKING DOCUMENT  IMPACT ASSESSMENT REPORT  Accompanying the proposal for a   Regulation of the European Parliament and of the Council on a monitoring framework for resilient European forests {COM(2023) 728 final} - {SEC(2023) 384 final} - {SWD(2023) 372 final} - {SWD(2023) 374 final}  
 
 
1 

2 

INTRODUCTION ................................................................................................................................ 4 

PROBLEM DEFINITION .................................................................................................................... 5 

2.1  What are the problems ....................................................................................... 6 
2.2  What are the problem drivers? ........................................................................ 12 
2.3  How likely is the problem to persist? .............................................................. 15 

3  WHY SHOULD THE EU ACT? ........................................................................................................ 15 

3.1  Legal basis ....................................................................................................... 15 
3.2  Subsidiarity: practical need for EU action ....................................................... 15 

4 

OBJECTIVES: WHAT IS TO BE ACHIEVED? ............................................................................... 19 

4.1  General objectives ........................................................................................... 19 
4.2  Specific objectives ........................................................................................... 19 

5  WHAT ARE THE AVAILABLE POLICY OPTIONS? .................................................................... 20 

5.1  What is the baseline from which options are assessed? .................................. 20 
5.2  Description of the policy options .................................................................... 22 
5.3  Options discarded at an early stage ................................................................. 26 

6  WHAT ARE THE IMPACTS OF THE POLICY OPTIONS? ........................................................... 28 

Identification of impacts and stakeholders ...................................................... 29 
6.1 
6.2  Description of the current situation ................................................................. 30 
6.3  Economic impacts ........................................................................................... 31 
6.4  Assessment of environmental and social impacts ........................................... 44 

7 

HOW DO THE OPTIONS COMPARE? ............................................................................................ 52 

7.1  Effectiveness .................................................................................................... 52 
7.2  Efficiency ........................................................................................................ 53 
7.3  Coherence ............................................................................................................  

PREFERRED OPTION ................................................................................................................................ 60 

7.4  Choice of option .............................................................................................. 60 
7.5  Proportionality ................................................................................................. 62 
7.6  Legal instrument .............................................................................................. 62 
7.7  Simplification and improved efficiency .......................................................... 63 

8 

9 

HOW WILL ACTUAL IMPACTS BE MONITORED AND EVALUATED? .................................. 63 

REFERENCES .................................................................................................................................... 64 

ANNEX 1: PROCEDURAL INFORMATION ............................................................................................ 70 

ANNEX 2: STAKEHOLDER CONSULTATION ....................................................................................... 75 

ANNEX 3: WHO IS AFFECTED AND HOW? ........................................................................................ 100 

ANNEX 4: ANALYTICAL METHODS .........................................................................................................  

ANNEX 5: BACKGROUND ON FOREST MONITORING AND FOREST-RELATED PLANNING ........  

 
 
 
 
 
Glossary 

ALS 

BDS 

EFFIS 

ENFIN 

EO 

EUFS 

FAO 

Air-borne Laser Scanning 

Biodiversity Strategy 

European Forest Fire Information System 

European National Forest Inventory Network  

Earth-Observation 

European Forest Strategy 

Food and Agriculture Organisation 

FAO-Global FRA 

FAO’s Global Forest Resource Assessment 

FISE 

Forest Information System for Europe 

ICP Forests 

International  Co-operative  Programme  on  Assessment 
and Monitoring of Air Pollution Effects on Forests 

IPCC 

LIDAR 

LUCAS 

Intergovernmental Panel on Climate Change 

Laser-imaging, Detection and Ranging 

Land Use and Land Use Survey 

LULUCF 

Land-Use, Land-Use Change and Forestry 

NFI 

NRL 

OPC 

RED 

National Forest Inventory 

Nature Restoration Law 

Open Public Consultation 

Renewable Energy Directive 

 
 
SoEF 

SHL 

UN CBD 

UN FCCC 

State of Europe’s Forests 

Soil Health Law 

United Nation Convention on Biological Diversity 

United  Nations  Framework  Convention  on  Climate 
Change 

 
 
 
1 

INTRODUCTION 

Forests and other wooded land cover close to half of the EU’s land surface and play a key role in 
mitigating and adapting to climate change, preserving and restoring biodiversity and ensuring the 
supply of woody and non-woody biomass to enable the transition towards a sustainable and circular 
bioeconomy . Forested land is, by far, the main contributor to the EU carbon sink and will play an 
essential role in meeting the EU’s ambitious objective of climate neutrality by 2050. At the same 
time, forests also provide the raw material (wood and non-wood such as food and medical plants) for 
growing  bioeconomy  value  chains  substituting  fossil-based  or  otherwise  harmful  products.  The 
extended forest-based value chains currently support 4.5 million jobs in the EU1. 

Forests  provide  crucial  ecosystem  services  (such  as  carbon  sequestration,  oxygen  release  and  air 
filtering, water regulation and purification, flood and erosion control, habitats for numerous species, 
urban cooling and opportunities for recreation). The importance of forest multifunctionality is set to 
increase in the future, with higher demands to serve as provider of raw material for the bio-based 
industries  in  support  of  a  sustainable  and  circular  bioeconomy,  as  stronger  and  more  resilient 
sustainable  carbon  sink  as  agreed  by  the  EU  in  the  Climate  law,  as  biodiversity  hotspot  and  as 
recreational space.  

But Europe’s forests are increasingly stressed by climate change and direct or indirect human use, 
activity and related land use changes. These pressures pose a threat to the capacity of forests to deliver 
on their different environmental and socio-economic functions.  

In order to address these threats and ensure that forests are able to fulfil the wide variety of demands, 
it is crucial to have high quality and comparable data on EU forests, making the best use of the twin 
digital transition and remote sensing capabilities, as well as long-term integrated planning at the level 
of Member States for the use of their forests, which depends heavily on the availability of data on 
forests.  

However,  currently,  monitoring  and  planning  tools  in  the  EU  are  not  fit  for  purpose  to  ensure 
evidence-based  sector-specific  policy-decisions  and  measures  that  consider  the  bigger  picture  of 
forest multifunctionality in a changing climate with increasing risks and uncertainties. Certain data 
on forest have been collected so far through scattered approaches and tools. The fast developments 
in monitoring tools and technologies, in particular in earth observation (EO) through satellite or aerial 
means (including drones), provide a unique opportunity to modernise, digitalise and harmonise the 
monitoring of forests,  as a service to  all,  forest  users and  authorities notably  to  effectively  tackle 
tangible risks to forests, while stimulating the EU market growth on those technologies and related 
new skills, including for SMEs.  

As figure 27 in Annex 5 illustrates, there are several EU policy instruments that directly or indirectly 
affect forests in the fields of environment and biodiversity, climate, energy and the bioeconomy. The 
successful  implementation  and  evaluation  of  these  policies  and  the  development  of  sustainable 
business models depend on or significantly benefit from high quality forest monitoring. A coherent 
information infrastructure can support evidence-based policy and decision making by land managers 
and public authorities, research and innovation. Moreover, a forest information system consisting of 
strengthened ground-based observations complemented by data from EO allows tracking progress 
towards policy objectives, compliance monitoring and law enforcement.  

1 Robert et al. 2020 

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The  need  for  enhancing  forest  monitoring  has  since  several  years  been  repeatedly  and  clearly 
mentioned by the EU institutions2. The New EU Forest Strategy for 2030, consequently, announced 
a  dedicated  legislative  proposal  on  EU  Forest  Observation,  Reporting  and  Data  Collection  which 
should also include Strategic Plans for Forests and the forest-based sector prepared by the competent 
national authorities.  

2  PROBLEM DEFINITION 

Europe’s forests need to be in a good, healthy condition in order to continue, or increase, the delivery 
of  crucial  ecosystem  services.  This  is  reflected  in  important  pieces  of  EU  legislation  and  policy, 
which recognize the multi-functionality of forests in the EU3. A comprehensive, high-quality EU-
level monitoring system is needed to understand and show how well these objectives are achieved 
and where gaps remain. 

Such a monitoring system does not currently exist in the EU. Instead, current forest monitoring in the 
EU consists of national systems that measure different forest parameters and indicators in different 
ways (Annex 5.2 informs in details about today’s forest monitoring systems in the Member States). 

With  a  few  notable  exceptions  such  as  the  Copernicus-driven  European  Forest  Fire  Information 
Service (EFFIS) and the Forest High Resolution Layer of the Copernicus Land Monitoring Service, 
and harmonisation efforts on a few core variables related to forest resources, the available data are 
not directly comparable. As described in Section 2.1.1, available data on forests are often outdated 
or have important gaps, hampering effective response by land managers and policy makers. Overall, 
information about the status of forests in the EU, their social, ecological and economic value, the 
pressures  they  face  and  ecosystem  services  they  provide,  is  fragmented  and  patchy,  largely 
heterogeneous, inconsistent, with data gaps and overlaps, and data is provided with significant delay 
and often only on a voluntary basis. In other words, the EU lacks a common system to collect long-
term, consistent, and comparable forest data.  

Insufficient information on the condition and evolution of forests and in particular forest disturbances 
dynamics impede the continuous provisioning of socio-economic functions and ecosystem services 
to  society,  including  their  climate  change  mitigation  potential.  The  lack  of  timely  and  accurate 
information in combination with the absence of long-term planning integrating the impacts of climate 
change  hinders  the  development  of  adaptive  management  strategies  to  increases  forest  resilience, 
disaster preparedness  and response. This  problem  does not only  affect  EU-level  decision-makers, 
with the risk of misinformed or failing EU policies in the climate, environmental, social and economic 
domains, but also forest planners and managers in many Member States, and players in the private, 
financial and insurance sectors, who risk taking poor decisions (e.g. on logging or on species to plant) 
based  on  incomplete  information.  This  is  likely  to  affect  not  only  the  distribution,  shape  and 
composition of future forests but also the associated industries and employed workforce. 

These problems would already be significant under current conditions. However, the onset of climate 
change has made comprehensive forest monitoring more urgent and demanding. Dramatic disasters 
and growing levels of stress-induced loss of forest health show how climate change has started to 
transform today’s forests. Shifts in forest disturbance regimes are compromising all forest functions 
and causing significant costs. For instance, the European heatwave and drought event in 2003 resulted 
in a strong net release of CO2, reversing the effects of four years of net carbon sequestration, and 

2 For instance COM(2013)659 final, Council Conclusions 12695/1/20, European Parliament Resolution 2019/2157(INI), 
COM/2021/572 final. 
3 For instance COM(2021) 572, Regulation (EU) 2018/1999. 

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reduced forests’ gross primary productivity by 30%4. The drought starting in 2018 caused a forest 
canopy loss of around 5% and financial losses forests damage of about EUR 18 billion in Germany 
alone5. As climate change progresses, scientists expect further increases in tree mortality, and they 
estimate more than 60% of the biomass in European forests to be exposed to climate risks6. In the 
light  of  increased  forest  disturbances,  biodiversity  loss  and  growing  demand  from  the  society  on 
forest functions – including biomass7 and non–timber related resources, the lack of a consistent and 
comprehensive  forest  monitoring  framework,  together  with  the  current  absence  of  harmonised 
planning  instruments  that  include  a  long-term  perspective  and  consistently  address  forest 
multifunctionality  via  an  integrated  approach,  hampers  the  assessment  of  policy  coherence  and 
appropriate policy making.  

This situation also makes the prevention and response to illegal logging and biodiversity loss difficult. 
There  are  several  open  infringement  procedures  against  Member  States8  for  logging  activities  in 
breach of EU legislation, in particular EU nature protection legislation, and the collection of data and 
evidence, though essential and decisive, has proven challenging and costly. 

In  conclusion,  the  absence  of  complete,  harmonised,  comparable,  and  timely  data  hampers  cost-
efficient implementation of EU and national/regional policies and targets and increases the risk of 
drawing wrong conclusions, which could lead to poor decision making from local to EU scale. An 
increasing  number  of  objectives  and  targets  for  urgently  needed  actions  on  forest  resilience  and 
protection of their essential functions for climate, biodiversity and the bioeconomy  will make the 
lack of knowledge even more apparent.  

2.1  What are the problems 

This impact assessment addresses two specific but interrelated problems: 

• 

• 

lack of data comparability and quality  

lack of integrated long-term forest planning,  

which  underpin  the  general  problem  of  not  having  adequate  and  timely  information  on  forests  to 
make effective policy and ensure that forests contribute to multiple EU policy objectives. 

2.1.1  Lack of data comparability and quality 

Forest data and information gathered in the EU varies significantly and is not comparable between 
Member States. The spatially incomplete and temporarily inconsistent information9 limits policy and 
decision  making  at  all levels,  making  it  very  difficult  to  base  decisions  on  evidence  and  face  the 
growing pressures on forests.  

As an illustration, Maes et al (2020) specified current key data gaps in the areas of forest pressures 
(e.g. drought, storm damage, over-harvesting) and forest conditions (e.g. defoliation, data on other 
forest  species  or  structural  diversity  of  forest  stands).  Avitabile  et  al.  (2023)  highlight  that 
information on forest resources such as forest biomass, annual increment or fellings in the EU are 
currently patchy, imprecise, and updated too slowly. They are derived by a range of methodologies 

4 Ciais. et al. 2005  
5 Thonfeld et al. 2022 
6 Allen et al. 2015; Forzieri et al. 2021 ; Lloret and Batllori 2021 
7 Ceccherini et al. 2020 
8 Notably against Poland, Romania, Slovakia and Estonia. 
9 Diabolo project 2016; Gschwantner et al. 2022; Linser and Wolfslehner 2022 

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for parameters with different definitions across Member States. The Science for policy report by the 
abovementioned collective on Biomass production, supply, uses and flows in the European Union 
provides a comprehensive discussion of the needs for harmonisation of forest data and the inherent 
uncertainty  of  the  harmonised  estimates,  e.g.,  due  to  the  incomplete  time  series,  low  temporal 
frequency and lack of common reporting.  

To exemplify the problem with lack of reliable data on a key variable with policy relevance, there 
were some 98 million cubic metres of fuelwood with a source that was ‘missing’ from reported data 
in EU-28 in 2013 – something likely attributable to under-reported felling and wood removal10. A 
more recent report found that, despite the abundance of available datasets, there are still large data 
gaps on the sources and uses of woody biomass for energy, and that most datasets are incomplete or 
provide insufficient detail11. 

A generally perceived need for comparable forest information at EU level and for more harmonized 
information  collection  methodologies  has  been  highlighted  by  the  Standing  Forestry  Committee 
already in 201212.  

The replies to the open public consultation (OPC), further elaborated in Annex 2, reveal that 84% of 
the  respondents  consider    consistent  and  comparable  forest  information  across  borders  as  an 
important  or  very  important  improvement  of  forest  monitoring  in  the  EU  with  no  significant 
differences  between  stakeholder  groups.  They  highlighted  the  need  for  harmonized  and  timely 
information on a number of variables, particularly on forest health, disturbances, and climate change 
impacts and projections (more than 88% of respondents). Likewise, responses to the call for evidence 
showed high support for consistent and comparable definitions, indicators, and measures of forest 
status across all Member States. At a Member State and stakeholders workshop hosted by the Czech 
Council Presidency (second semester 2022), participants stressed the importance of harmonised or 
standardised information on the state and development of EU forests (Annex 2). Standardisation of 
core parts of forest inventories between Member States was also mentioned as a possibility in the 
long-term perspective as one of the conclusions of a subsequent workshop with Member States and 
stakeholders organised by the Swedish Council Presidency13. 

Most national forest inventories (NFIs) are geared towards planning wood resources management 
with a focus only on economic, production-related variables such as volume of growing stock14. The 
current monitoring systems therefore tend to provide insufficient and patchy data on indicators related 
to  biodiversity,  forest  health  and  resilience,  and  non-wood  resources,  which  are  priority  areas 
identified in the New EU Forest Strategy for 2030. This is important also because the sustainability 
and long-term provision of wood resources fully depends on forest biodiversity, health and resilience.  

The lack of comparability of the status and trends of forest ecosystems in the EU makes it difficult 
to track progress towards EU policy objectives and goals. A special report of the European Court of 
Auditors  concluded  in  2021  that  the  current  monitoring  system  for  the  impacts  of  Common 
Agricultural  Policy’s  (CAP)  forestry  measures  for  rural  development  is  lacking,  especially  in  the 
areas of biodiversity and climate change effects15.  

10 Avitabile & Camia et al. 2018 
11 Camia et al. 2021 
12 Standing Forestry Committee 2012 
13 Swedish Presidency of the Council of the European Union 2023.  
14 Diabolo project 2017 
15 European Court of Auditors 2021 

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Annex  5.2  provides  further  information  on  the  current  situation  -  Tables  21  and  22  provide  a 
comprehensive overview of forest indicator coverage in Member States’ monitoring and reporting 
and  show  that,  on  average,  forest  information  is  insufficient  especially  in  the  areas  of  forest 
biodiversity and resilience.  

NFIs  have  evolved  in  distinct  ways  in  EU  Member  States  with  country-specific  methodologies, 
partially  serving  different  purposes  and  policies  (Annex  5.2,  Table  20).  Even  basic  concepts  and 
definitions of key forest variables are not consistent between Member States16 (Annex 5.2, table 18). 
Many EU countries use different definitions for forest, forest types, and forest available for wood 
supply17,  and  some  EU  regulatory  frameworks  allow  Member  State-specific  forest  definitions18. 
Regarding data collection, some Member States (e.g. France and Sweden) sample between 10 and 
20% of their observation plots each year, while others such as Germany or Austria sample all plots 
at once after 5 to 10 years. A few Member States have not conducted ground sampling campaigns 
for NFIs over the last two decades or more (Table 20 in Annex 5.2). -In several cases national datasets 
are not compatible with international definitions19, available only in local languages20, or employ a 
methodology that is not commonly agreed or transparently documented21.  

The quality of data sets and indicators varies among the EU Member States22. In several cases, more 
attention is given to socioeconomic quantitative information (e.g., growing stock, increment) over 
environmental  qualitative  (health,  biodiversity,  resilience),  which  limits  the  accuracy  of  certain 
indicators, notably for biodiversity.  Too much reliance on proxy indicators can increase accuracy 
problems23.  

Annex 5.2 informs also about specificities of inventory-based in-situ monitoring approaches and the 
pros and cons compared to  forest  monitoring by  EO. In-situ based inventory systems  lack spatial 
continuity, granularity, timeliness and frequency compared to EO-based approaches. EO may result 
in ambiguity of automated data interpretation or differences in definitions24.  An EU-wide platform 
for the integration of in-situ and remote sensing information is currently lacking, which would allow 
to create precise, statistically-sound estimates of target variables that correlate well with the remote 
sensing information using models.  

Furthermore, there is a trade-off between continuation and innovation, which affects both in-situ and 
remote sensing-based monitoring. Emerging techniques may improve the quality of products related 
to accuracy, certainty, granularity, timeliness and frequency but introduce inconsistency in the time 
series with regards to data collected in the past25. In many cases, techniques can be developed that 
cater  for  or  prevent  such  biases  and  inconsistencies,  hence  allowing  for  comparability  between 
historic and new measurements.  

16 Baycheva-Merger and Wolfslehner 2016 
17 Baycheva-Merger et al. 2018; Xinqi et al. 2019 
18 E.g. Regulation (EU) 2018/841 
19 Avitabile and Camia 2018; Diabolo project 2017; Tomppo et al. 2010 
20 Schueler et al. 2020 
21 Baycheva-Merger and Wolfslehner 2016; Diabolo project 2017 
22 European Environment Agency 2015; Nilsson 2022 
23 Linser and Wolfslehner 2022 
24  European  Commission,  Directorate-General  for  Environment  et  al.  2020;  van  Brusselen  et  al.  2021;  EEA  2015; 
Avitabile and Camia 2018;  
25 Diabolo project 2017; Tomppo et al. 2010 

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The absence of comparable data prevents transparent and integrated monitoring of forests in the EU, 
for instance, on wood harvesting for different purposes, growing stock, forest management practices, 
ecosystem health, resilience and related biodiversity26. The current forest  monitoring landscape in 
the  EU  provides  a  rather  ‘static’,  patchy  picture  which  fails  to  provide  coherent  and  up-to-date 
information on EU forests27. This not only leads to inadequate data for informed development and 
implementation of forest-related legislation and policies on the EU level (see links to EU legislation 
and strategies in Table 21, Annex 5.2), but is also not cost-efficient and prevents acquiring a holistic 
view on the state of forest resources in the EU and potentials for their future development. Moreover, 
Vidal  et  al.  (2016)  argue  that  national  differences  in  definitions,  methods  and  scope  of  forest 
monitoring might make EU reporting under international processes such as FAO FRA or UNFCCC 
inconsistent.  

At  the  level  of  the  forest  manager,  making  data  more  comparable  between  Member  States,  by 
following common definitions or standards, has the potential to decrease the costs for forest owners 
deciding  to  participate  in  voluntary  carbon  farming  schemes,  such  as  the  EU  Carbon  Removal 
Certification  Framework  and  would  also  allow  for  more  informed  management  decisions  and 
effective  communication  thereof,  with  corresponding  reputational  benefits,  to  the  advantage  in 
particular of SMEs and small forest owners.  

Accuracy, timeliness, continuity and transparency of information are key issues for the quality and 
trustworthiness of forest monitoring, which is crucial for foresters to benefit from emerging payment 
for ecosystem services schemes. The granularity of data and information is essential to ensure their 
policy  relevance  and  uptake  by  all  user  communities.  More  accurate  and  trustworthy  forest 
information  was  identified  as  a  key  need  of  stakeholders  in  the  OPC.  This  is  valid  across  all 
stakeholder  groups  -  although  business  associations  showed  the  lowest  values  with  only  36  %  of 
respondents considering accuracy and trustworthiness as very important or important, 46% responded 
with ‘somewhat important’.  

Transparent data means access to data and information for all stakeholders (see Annex 3 for details 
on affected groups). Today, access  to  official  forest  data is  limited and  unequal  between the user 
groups28. Even though aggregate data from NFIs is generally publicly accessible, the basic plot level 
measurements and in particular the geographic location of measurement plots are not disclosed or are 
blurred, which limits the possibility for comparison. Administrations and organizations responsible 
for plot-level data collection justify the limited access by  highlighting bias in the management of 
forest  where  permanent  plots  are  located,  compliance  with  personal  data  protection  and  privacy 
policies, and inter organizational agreements29, intellectual property rights, the potential for misuse 
and misinterpretation, or deliberate interferences on the forest plots30. The limited access to basic 
forest  data  makes  it  hard  to  assess  whether  these  restrictions  are  fully  justified  in  light  of  public 
interest  to  environmental  information  and  complicates  a  critical  assessment  for  non-state 
stakeholders,  such  as  private  organizations  and  NGOs31.  Among  public  consultation  respondents 
representing environmental organisations, academic institutions and EU citizens, between 81% and 
100% agreed with the need for better open access to forest information. 

26 Diabolo project 2016, 2017 and 2019; Linser and Wolfslehner 2022; Schueler et al. 2020 
27 Avitabile et al. 2023 
28 Baycheva-Merger et al. 2018; Nabuurs et al. 2022 
29 Baycheva-Merger et al. 2018; 
30 Avitabile and Camia 2018; Baycheva-Merger et al. 2018; 
31 Diabolo project 2017 

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Efficient  and  effective  data  dissemination  is  important  to  serve  and  build  trust  in  different  user 
communities.  Forest  data  is  inherently  complex  with  differing  definitions  and  interpretations  in 
various user communities.  

Current data interfaces and voluntary tools such as Forest Europe and the Forest Information System 
for Europe (FISE) only  provide basic indicators aggregated at Member State level, such as forest 
area, growing stock or annual roundwood removals. There is a lack of user-friendly query tools for 
detailed data and data at the level of parcels or lower administrative units that is required by land 
managers, particularly smallholders, and researchers. 

Consequently, usefulness of the information and the form how information is delivered does not meet 
the needs of the potential users including civil society, the private sector and academia32. Today’s 
rigid frameworks may also constrain the exchange and acquisition of scientific forest information 
and cross-sectorial connection, which in consequence slows down the development of NFIs and of 
EO-based monitoring systems33. 

2.1.2  Lack of integrated long-term forest planning 

In order to ensure that forests can deliver on their multiple functions, including those that have been 
agreed on in EU legislation, long-term planning of forest management is required. Planning horizons 
in forestry usually stretch over many decades – the time it takes between planting and felling, and for 
the forest to deliver its full range of bioeconomy functions including vital ecosystem services..  

Likewise, several forest-related EU policies take a long-term view. For instance, the core goals of 
making the EU climate-neutral  (EU Climate Law and Land-Use, Land-Use Change and Forests  - 
LULUCF)  and  climate-resilient  (EU  Adaptation  Strategy),  or  to  maintain  and  restore  European 
ecosystems (proposed EU Nature Restoration Law -NRL) are to be reached by 2050. Many climate 
change projections  cover the period until  the end of this century, including  many studies on how 
forests will react to, and will be impacted by, accelerating climate change. 

In sharp contrast to this, the following gaps could be identified: 

- 

-  most  national  planning instruments  in  the EU  do not  go beyond a 10-year forest  planning 
cycle. Only a few Member States developed a long-term vision for their forests, typically for 
2050 (Table 23 in Annex 5); 
several planning instruments only address forests from specific policy perspectives: by way 
of example, National  Energy and Climate Plans  and Long-Term Strategies34 cover  carbon 
sequestration,  renewable  energy  and  energy  efficiency;  national  and  regional  climate 
adaptation strategies cover climate adaptation needs etc. An overview of existing planning 
tools, their relevance for sectoral forest policies and their different cycles for reporting and 
review is included in Table 24 of Annex 5; 
there is a lack of a holistic analysis and integration of policies and societal demands related 
to forests, which are often not prioritised, also in terms of funding; 

- 

32 Baycheva-Merger et al. 2018; Baycheva-Merger and Wolfslehner 2016; Diabolo project 2017; Requardt 2007 
33 Nabuurs et al. 2022; Janse 2006, 2007 and 2008; Wulder and Coops 2014; 
34 Regulation (EU) 2018/1999 

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-  missing  coordination  and  communication,  often  happening  if  there  is  a  split  in  national 
competences  and  if  there  is  no  cross-sectoral  exchange  between  forest  stakeholders  and 
others35; 
the  heterogeneity  of  information  covered  by  the  current  planning  instruments  affect  their 
comparability or possible exchange with other Member States, which is key to prepare a rapid 
and efficient response, particularly for threats with a cross-border dimension such as plant 
pests or wildfires36; 

- 

-  planning  instruments  are  furthermore  not  always  fit  for  purpose  to  reflect  recent  policy 
developments for forests and forestry at EU and national level due to economic and capacity 
constraints that would require a structured response at strategic and prospective level, also as 
regards funding opportunities (currently scattered in different instruments); 

-  presently  there  is  no  governance  framework  nor  coordination  at  EU  level  to  ensure 

harmonisation of the plans in order to address the abovementioned gaps. 

With regard specifically to policy fragmentation in terms of planning, an assessment performed on 
Member States’ tools along five key thematic areas relating to forestry (forest resource status and 
trends, biodiversity, forest based economy, ecosystem services and climate change) has identified the 
following gaps in Member States’ coverage of certain areas: 

•  The consideration of the bioeconomy  (see Table  25 in  Annex V)  was the most frequently 
lacking policy area in the EU27. A number of Member States have limited reference to the 
bioeconomy sector, some of those within other forest-related policies or strategies (BE, EL, 
LU, SK), or having a bioeconomy policy in place at regional level only (BG).    

•  Biodiversity and climate change were the two thematic areas where all Member States have 
either  specific  strategies  in  place  or  have  substantially  integrated  them  into  their  national 
forest policies or related policies.  

•  The status and trends of forest resources is generally well reported and considered in national 
strategies or plans, particularly due to the NFI network and the availability of national forest 
strategies for most countries.   

•  Cyprus is the only Member State without strong evidence of planning or consideration for 
forest  ecosystem  services.  However,  for  other  several  Member  States  it  emerged  that 
ecosystem  services  have  a  small  role  within  a  larger  related  area  and  are  not  specifically 
provisioned  for.  Ecosystem  services  are  often  nestled  into  wider  biodiversity  or  climate 
change plans as they can be secondarily affected by the outcomes of these broader thematic 
areas. 

35 An indicator is the presence/absence of an overarching forum for discussing forest strategic planning issues beyond 
forestry boundaries. There are good examples acting for bringing different sectoral aspects, stakeholders and responsible 
bodies together (e.g. AT, FI, SE, DE), while in other countries there are similar, but not formal processes (e.g. ITA, DE, 
ES, PL), or none (e.g. EST, NL). The Mutual Learning Exercise carried out in the preparation of the report Deploying 
the bioeconomy in the EU (2021) highlighted the gaps and needs relating to strengthening inter-ministerial dialogue in 
preparing holistic policies and strategies.  
36  Many  response  cooperations  -  especially  bilaterally  -  exist  (e.g.  CZ-SVK,  AT-ITA).  Despite  that,  an  overarching 
concept  for  a  Europe-wide  cooperation  is  still  lacking.  The  development  of  a  Forest  Risk  knowledge  mechanism  in 
FOREST  EUROPE  is  a  strong  indication  by  countries  that  they  need  better  cooperation  with  an  additional  focus  on 
prevention and coordination of prepared action.  

11 

 
 
 
Policy fragmentation and  the lack of a harmonised set  of  information  across  the  current  planning 
instruments in Member States leads to a risk of setting policy targets or objectives that are mutually 
exclusive, creating mutual unintended trade-offs and inconsistent policy-making and implementation 
on  the  national  and  consequently  EU  level.  Instead,  an  integrated,  balanced  assessment  of  needs 
across different sectors is needed to evaluate the overall ambitions and potentials with regard to the 
provision of various forest ecosystem services. Integrated forest planning based on clearly defined 
long-term strategic policy needs and forecasting is key to inform the structure of monitoring which 
in turn will allow to assess planning performance and adapt it if need be. Addressing the lack of a 
long-term integrated approach in terms of planning, including forecasting, would therefore contribute 
to further developing forest monitoring. Annex 5.3 includes an EU-wide SWOT analysis synthesising 
the main existing, missing or contradicting elements of forest planning and strategic documents and 
an EU-wide gap analysis. 

In the OPC, respondents were asked to select among different options of what could be the benefits 
of  strategic  forest  planning.  Respondents  most  frequently  pointed  to  providing  a  holistic  view  on 
forest  status  and  trends  as  well  as  allowing  for  overall  coordination  of  long-term  forest  planning 
(Figure 19 in Annex 2). The issue of policy fragmentation raised above is reflected in the OPC results, 
as when asked about their level of awareness of the various existing planning instruments, 69% of 
respondents,  with  the  majority  belonging  to  the  stakeholder  groups  of  EU  citizens  and  NGOs, 
indicated that they know or use national or regional forest strategies, but much less sectoral forest-
related instruments (with National Bioeconomy Action Plans ranking the lowest with 27%. .  

2.2  What are the problem drivers? 

Table 1: Specific problems, drivers and objectives to be addressed by the legislative initiative 

(Interlinked) Problems 

Problem drivers 

Specific objectives 

quality 

and 
Data 
comparability:  Data 
is 
incomplete,  inconsistent  and 
not comparable across the EU 

Regulatory  failure:  Existing  rules 
relating  to  forests  at  EU  level  do  not 
provide 
comprehensive 
a 
monitoring  of  biodiversity,  carbon 
storage,  health  and  resilience  and 
accessibility to collected data.  

for 

common  
Ensure 
digitalised, 
consistent, 
comparable,  timely  and 
accessible  data  on  the 
state of EU forests. 

Market  failure:  Prices  of  forestry 
products  do  not  necessarily  reflect  the 
impact  of  forestry  on  biodiversity  and 
climate; 
indicators  are  historically 
biased towards timber production.  

Insufficient  exchange  of  information 
amongst  actors  involved  in  forestry 
undermines  the  quality  and  coherence 
of forest planning. 

12 

 
 
 
 
Quality of planning: Lack of 
policy 
and 
integrated  planning  with  a 
long-term vision. 

coherence 

Regulatory  failure  due  to  scattered 
responsibilities 
public 
authorities with different objectives. 

between 

Regulatory  failure  due  to  lack  of 
cross-sectoral  coordination  leading  to 
scarce  prioritisation  of  non-timber 
forest uses.  

Give the possibility to all 
Member States to deliver 
long-term 
integrated 
forest  plans  based  on 
high-quality  monitoring 
information 
to 
policy 
relevant 
objectives. 

related 

EU 

2.2.1  Drivers behind the lack of data comparability and quality  

In the absence of a market incentive, there has been no general interest to monitor the environmental 
impacts of forestry, nor of non-timber-related forest bioeconomy (e.g. hunting licenses, eco-tourism). 
As a matter of fact, the price of timber resources, just as it is the case for natural resources in general,   
reflects historically a market where the impact of forestry on biodiversity and climate is generally not 
taken into account (externalities). 

Only  recently  have  data  on  environmental  aspects,  such  as  benefits  of  forests  for  climate  change 
mitigation and adaptation and (mostly limited to protected forests) for biodiversity, started to gain 
attention, though still in a patchy manner. Such data is, however, increasingly important, given the 
EU’s agreed climate policy and scientific evidence, which  demonstrates that  the forest  resilience, 
adaptive  capacity and capability to  provide multiple products  and services is  dependent  on  forest 
ecosystem health and biodiversity.  

Member  States  have  developed  different  approaches  for  data  collection,  measurement  systems, 
definitions, statistical processing, and different time frames for collection and dissemination of forest 
information because many Member States have developed their monitoring frameworks long before 
joining the EU and EU has not had a regulatory framework for forest monitoring (see Figure 28 in 
Annex  5.2).  The  lack  of  a  regulatory  framework  at  EU  level  has  also  contributed  to  the  largely 
uncoordinated developments between Member States. The main argument against applying common 
standards  to  NFIs  is  the  potential  disruption  of  the  measurement  time  series,  control  over 
measurement plots, the long experience gained with the existing systems37. 

Some international efforts for harmonization and standardization of NFIs, such as collaboration under 
the European National Forest Inventory Network (ENFIN) program, including framework contracts 
with  the  Joint  Research  Centre  (JRC),  have  been  made  over  many  years  with  progress  on 
harmonization limited to a few indicators, mainly limited to the areas where cooperation was agreed 
under international conventions, such as the International Co-operative Programme on Assessment 
and Monitoring of Air Pollution Effects on Forests (ICP Forests38). 

Existing national forest monitoring systems are expensive39. Several Member States operate forest-
monitoring systems over many decades with  data collection ongoing  over many years to  produce 

37 Ståhl et al. 2012 
38  International  Co-operative  Programme  on  Assessment  and  Monitoring  of  Air  Pollution  Effects  on  Forests  (ICP 
Forests), launched in 1985 under the Convention on Long-range Transboundary Air Pollution (Air Convention, formerly 
CLRTAP) of the United Nations Economic Commission for Europe (UNECE). 
39  For  instance,  in  metropolitan  France,  the  national  forest  inventory  directly  mobilizes  about  91  full-time  jobs  and 
represents an estimated budget between EUR 8.2 and 10.4 million (2020 campaign). Source: Commission Territories of 
the National Council for Statistical Information 2021 

13 

 
 
 
 
consistent time series40 (see Figure 28). A change in the data collection, including the inclusion of 
data from EO to improve spatial granularity or frequency, could imply a temporary extra cost and at 
least a partial disruption of the time series. Furthermore, not all ecosystem services provided by the 
forests have been considered important, since the market rewards mainly the selling of timber.  

Market and regulatory failures are also behind limited information or restricted access to data. Recent 
studies also concluded that a major reason for constraining the exchange of forest information is the 
lack of motivation and unwillingness due to lack of political, social, and/or economic incentives for 
data collection, processing, provision, and dissemination41. In the absence of a regulated monitoring 
framework, there is an overall concern on the unintentional misuse of data or false interpretation due 
to the lack of detailed on-site knowledge. In limited form, Member States share some information in 
the voluntary collaboration under ENFIN and other international projects, which seek improving the 
forest  monitoring  and  information,  however,  after  years  of  cooperation,  limits  of  such  voluntary 
efforts  in  terms  of  data  accuracy  and  timeliness  have  been  repeatedly  reached42.  The  recent  EU 
proposal for certification of carbon removals will provide financial incentives for increasing carbon 
storage in forests. This will lead to higher needs for information (on carbon removals and related co-
benefits, such as higher biodiversity), by stakeholders motivated to obtain these financial incentives, 
especially SMEs active in the sector. 

2.2.2  Drivers behind the lack of integrated long-term forest planning 

Existing planning instruments in Member States often lack the analysis of forest policy coherence 
today and for the future with increasing demands and threats. Medium- and long-term forest strategies 
(e.g. DE, AT)  tend to  be broader in  their scope and have to  take more  aspects  into consideration 
(climate  change,  biodiversity,  social  development  etc.)  than  very  short-term  demand-driven 
strategies.  Planning  often  reflects  sectoral  policies,  approaches  and  priorities,  mirroring  scattered 
responsibility  among  different  departments/ministries  or  administrative  levels,  particularly  in  the 
systems where planning is taking place also at regional level, resulting in difficult coordination and 
communication among these levels. The existence of EU sectoral but uncoordinated legislation is 
also a reason behind this situation.  

Existing planning documents such as national Forest Strategies and Programmes typically have a 10-
year cycle and address primarily the economic value of wood-based bioeconomy, which is the only 
one reflected in  the market  price of timber.  The  lack of market  incentives to  address  climate and 
biodiversity and non-timber forest bioeconomy results in scarce considerations of these dimensions 
in planning. Better plans need better data as outlined in the section above. Even if climate mitigation 
and  adaptation  or  biodiversity  are  covered  to  some  extent  by  existing  EU  and  national  planning 
instruments, this is not yet prioritised at sufficient scale neither it is done in an integrated manner. 
This is for example demonstrated by the fact that spending on forestry measures amounts to only 3% 
of all rural development spending under the CAP. Moreover, overall funding for forested areas from 
the EU budget is much lower than for agriculture, representing less that the 1% of the CAP budget43. 
Long term-planning for environmental reasons is often absent (see SWOT and gap analysis in Annex 
5.3).  Lack  of  planning  for  climate  and  biodiversity  threatens  the  forest-based  bioeconomy  and 
ecosystem functions of forests, given the interdependencies. Lack of attention to non-wood forest 

40 Gschwantner et al. 2022 
41 Baycheva-Merger et al. 2018 
42 Avitabile et al. 2023 
43 European Court of Auditors 2021 

14 

 
 
 
bioeconomy disregards the importance of sectors, which bring income and jobs to local communities 
and have often co-benefits with climate and biodiversity objectives. 

2.3  How likely is the problem to persist? 

While forest-related data needs are increasing in several EU policy fields and indicators are defined 
for monitoring, the state of forests and the demands on forests, the challenges related to consistent 
and improved information systems including common indicator development  and to  coherent and 
streamlined forest planning across policy domains are likely to persist. Details are provided in section 
5.1. 

3 

 WHY SHOULD THE EU ACT?  

3.1  Legal basis  

The proposal  is  based on Article 192(1) of the Treaty  on the Functioning of the European Union 
(TFEU), which gives the Union the right to act in order to achieve objectives of its policy on the 
environment. The Court of Justice of the European Union has confirmed in Joint Cases C-164 and 
C-165  that  measures,  such  as  those  aimed  at  protecting  forest  from  wildfires  and  air  pollution, 
inherently form part of the environmental action that the EU competence is founded on, in Article 
191(1) TFEU. The objectives of the Union policy on the environment as defined in Article 191(1) of 
the TFEU include, inter alia, preserving, protecting and improving the quality of the environment; a 
prudent and rational utilisation of natural resources; and promoting measures at international level to 
deal with regional or worldwide environmental problems, in particular combating climate change. 
The Union policy on the environment shall aim at a high level of protection taking into account the 
diversity  of  situations  in  the  various  regions  of  the  Union.  It  shall  be  based  on  the  precautionary 
principle and on the principles that preventive action should be taken, that environmental damage 
should as a priority be rectified at source and that the polluter should pay. Pursuant to Article 4 TFEU, 
in the field of environment, the EU shares competence with its Member States. 

The  same  legal  basis  underpins  Union  measures  aimed  at  protecting  forest  ecosystems  from 
disturbances44. A monitoring framework for resilient European forests will provide the data which 
will enable monitoring the European Green Deal targets  related to forests and develop policies to 
protect forest ecosystems. Given that environment is an area of shared competence between the EU 
and the Member States, EU action must respect the subsidiarity principle. 

3.2  Subsidiarity: practical need for EU action  

Necessity of EU action 

Forest monitoring is currently patchy and fragmented, which prevents the Union from acting in a 
timely manner against stressors and threats (with a cross-border dimension), as advocated by the new 
EU forest strategy and from making the most out of cost-effective technological developments and 
digital  innovation,  particularly  in  the  area  of  EO.  The  situation  has  arisen  by  the  Member  States 
developing their national forest monitoring systems in an uncoordinated manner over many years 
(see Figure 28 in Annex 5.2). While forest ecosystems often stretch across borders, forests are often 
seen as sovereign  entities and no consistent, transnational  data gathering  approach has been  fully 

44 C-164/97 and C-195/97, in particular points 13 and 16. 

15 

 
 
 
developed so far (UWE Bristol, 2021, p. 82).  Member States are unlikely to resolve this fragmented 
situation  without  EU  intervention.  The  OPC  results    indicate  that  respondents  expect  that  EU 
intervention  will  result  in  better  scientific  knowledge  about  forests,  improve  the  prevention  and 
response to natural forest disturbances and benefit forest management and planning. 

The risks posed to forests by the climate emergency demonstrate the need for a coherent system to 
monitor  and  plan  for  transformations  in  forests  and  the  forest-based  sector  as  a  result  of  climate 
change. In addition, the climate and biodiversity crisis require a re-consideration of the role of forests 
with greater focus on their multifunctionality. In this context adequate and comparable data on forests 
and is a prerequisite to achieving the climate, biodiversity and sustainable and circular bioeconomy 
policy objectives stemming directly from the European Green Deal. Providing Member States with 
instruments to develop long-term planning and make the most of the data at their disposal would also 
support this goal. 

EO  is  a  game  changer  in  monitoring  but  requires  a  coordinated  approach  both  at  the  level  of 
technology  development  and  use  (especially  satellites)  and  at  the  level  of  the  necessary  ground-
truthing activities, which must be sufficiently harmonized. There is in addition a need to monitor the 
effects of other policy actions comprehensively and cost-efficiently.  

Consequently, intervention at EU level is needed in view of:  

(i) 
(ii) 

(iii) 

the scale and crossborder nature of the problem,  
the impacts on citizens across the Union as well as the risks to its economy from growing 
disturbances, and  
the need to monitor the effects of EU policies and legislation and to anticipate the need 
for policy changes with a view to achieve targets. 

Added value of EU action  

Taking action at EU level, within the limits of the objectives that cannot be achieved sufficiently or 
most effectively by the Member States in the absence of an EU framework, would provide a clear 
added value in terms of consistency and economic efficiency.  

Although,  together  EU  Member  States  spend  50  million  EUR  annually  on  their  national  forest 
inventories (Maes et al., 2020), often the information is unusable transnationally because countries 
cannot agree on definitions of parameters, the data are outdated or are too coarse (Nabuurs et al., 
2019).  Nabuurs  et  al  (2019)  also  argued  that  basing  forest  policies  on  very  little  or  outdated 
information might lead to undesirable trade-offs. Maes et al. (2020) make clear that systematically 
collecting harmonised, spatio-temporal data from across the EU will be an important step towards 
tracking and preventing pressures at a pan-European level, such as forest pests, droughts or invasive 
species.  

Action  in  this  sense  is  also  supported  by  respondents  to  the  open  public  consultation.  Across 
stakeholder groups, more than 60%of respondents agree that data from Member States’ monitoring 
systems  should  be  better  integrated.  Split  by  stakeholder  groups,  73%  of  all  respondents  from 
academia and 75% from public authorities agree or somewhat agree.  However, this percentage is 
smaller for business associations (36%). Additionally  more than half of respondents think that the 
EU should operate a single monitoring system. The highest support for a single monitoring system is 
shown by EU Citizens and Environmental Organisations, with 69% and 67% respectively  agreeing 
or somewhat agreeing, whereas 56% of all responses from the stakeholder group ‘company’ disagree 

16 

 
 
or somewhat disagree. Only 40% of respondents agree that Member States should continue current 
monitoring  systems  (business-as-usual).  Among  the  different  stakeholder  groups,  70%  of  the 
environmental  and  non-governmental  organisations  and  49%  of  business  associations, 
company/business  organisations  and  public  authorities  together  support  a  common  approach  to 
monitoring  which  should  build  on  existing  data  collection  and  reporting  processes.  Key  business 
players  expressed  clear  support  for  the  legislative  proposal  underlining  for  example  reliable, 
comparable and science-based data as the foundation for ambitious policy-making and sustainable 
forest management as well as encouraging National Strategy Plans by all Member States as a useful 
tool to implement the EU Forest Strategy 2030. Half of  those EU Member States that expressed their 
views  on the repartition of competences  between the EU and the Member States,  during  a public 
debate  in  the    Council  on    22  October  2022),  also  supported  a  common  approach  to  monitoring, 
building on existing data collection and reporting processes. A general support was expressed by the 
Member States experts participating in the technical workshop organised by the Czech Presidency in 
September 2022 (see section 6.1 or Annex 2 for the full report ) to the importance of reliable, verified 
harmonized  or  standardized  and  up-to-date  information  and  communication  on  the  state  and 
development of EU forests, inter-alia for informed both policy- and decision-making at the EU level. 

Standardised,  comparable  information  would  allow  to  check  the  viability,  consistency  and 
sustainability of the many and various forest-related policies at EU level (or to identify trade-offs) in 
a cost-effective manner.  Table 21 contains  information  on  how the forest data  considered for  the 
monitoring  framework  link  to  specific  legislation  and  policy  objectives.  Data  harmonisation  or, 
where  appropriate,  applying  a  standardised  approach  –  particularly  by  taking  advantage  of  the 
innovative solutions  in  the EO field  – has  the potential  to  lead to  significant  cost  savings.  Freely 
available  satellite  data  can  additionally  facilitate  compliance  verification  for  national  competent 
authorities and reduce reporting burden for stakeholders with obligations relating to forest land use.   
Moreover, the development of a more standardised approach to EO-based data collection acts as a 
strong facilitator for European SMEs related to the digital transition. As seen in the development of 
similar  monitoring  technologies  for  agricultural  policy,  by  applying  common  approaches  for  data 
collection, companies executing this work will enter a developing market and thereby provide better 
value services (for data collection and processing), which in turn will stimulate more expansive, more 
regular data collection in a virtuous cycle.  

Such a monitoring scheme would also allow identifying the relationship between the condition of 
forests and anthropogenic stress factors, including climate change, and potential future risks of forest 
disturbances at a reduced cost compared to a scenario in which each Member State operates its own 
monitoring scheme. It would also allow to support Member States which would encounter significant 
needs  to  improve  their  forest  monitoring  (see  Table  20  for  an  overview  of  Member  States’ 
monitoring). 

Increasing disturbance frequency and intensity, for example by bark beetle outbreaks, wildfires or 
wind storms, result in greenhouse gas emissions, biodiversity loss and market distortions that have a 
significant crossborder dimension. They may also cause abrupt increases of salvage logging with a 
direct  impact  on  the  market  across  countries.  As  an  example,  the  early  detection  of  bark  beetle 
hotspots (to which EO can effectively and efficiently contribute) is essential for reducing the extent 
of salvage logging, which is liable – when occurring in large scale – to disrupt the timber market, 
with  particularly  negative  effect  on  SMEs  which  are  heavily  dependent  on  timber  price.  In  the 
absence of a clear framework, punctual or sporadic exchange of information between administrations 
or stakeholders at national level is not sufficient to provide for a systematic coordinated response to 
these  disturbances.  Moreover,  there  is  a  crossborder  long-term  dimension  due  to  the  fact  that  the 

17 

 
 
already observed northward migration of agro-climate zones is expected to accelerate significantly 
in the coming decades45, making comparability of long-term datasets across borders a growing asset 
for forest owners and managers. 

Finally, a level playing field for forest products from sustainably produced biomass would reward 
foresters  and  land  managers  who  implement  land  management  schemes  with  co-benefits  for  the 
climate, biodiversity and the bioeconomy. The EU is the appropriate actor in this case, as it  has a 
long standing experience in working for the convergence of forest indicators and on data collection 
methods to obtain comparable and EU-wide data. This is not something that can be tackled at the 
level of individual Member States. Drawing on existing monitoring systems and emerging science, 
promotion of EU-wide methodological standards and knowledge sharing will also enable more cost-
efficient reporting and monitoring. 

With regard to cost effectiveness, a very important aspect in relation to EO is economies of scale. 
This  is  self-evident  in  the  case  of  developing  satellite  technology,  but  also  in  the  area  of  Laser-
imaging, Detection and Ranging (LIDAR) monitoring, where the cost per hectare can be considerably 
reduced,  the  larger  the  surface  to  monitor.  Moreover,  past  frontload  investments  into  Copernicus 
monitoring services means that these systems are already in place and putting them into practice will 
contribute to cost-efficient use of this EU investment. 

As regards planning, several Member States have planning instruments in place but the information 
covered is not harmonised at the EU level, affecting comparability and policy-making as aggregated 
information on national forest-related policies form the knowledge basis for the design of EU policies 
and strategies. Moreover, having an integrated and long-term approach to planning allows Member 
State to implement various EU policies relating to forests (LULUCF, Nature Directives, Renewable 
Energy Directive etc.) and their respective targets and objectives in a coherent manner, addressing 
potential trade-offs.  Member States that have established and well-working planning frameworks 
would be able to continue their instruments. They would nonetheless have the possibility of entering 
a  coordinated  governance  system  to  ensure  temporal  homogeneity  and  provision  of  common 
information  . The added value of  EU coordination  and governance would be to  ensure that plans 
across the EU have a similar structure for better delivery on forest-related policies at the EU level 
such us those delivering on forest bioeconomy or climate adaptation. 

Comparability and exchange with other Member States was also selected as added value of strategic 
plans by 52% of all the respondents to the open public consultation without a significant difference 
across  stakeholder  groups.  Among  the  options  given  to  choose  from,  it  ranked  the  third  highest 
shortly after providing a holistic view on forest status and trends (55%) and overall coordination of 
long-term forest planning (53%). Only 5% of the respondents did not see any added value in strategic 
plans mostly linked to the concern that the intention would be to establish strategic plans for forests 
at EU level. 

45 Ceglar et al. 2019; Gallardo et al. 2013 

18 

 
 
 
4  OBJECTIVES: WHAT IS TO BE ACHIEVED? 

4.1  General objectives 

The general objective of this initiative is to develop an EU-wide monitoring framework for resilient 
European forests, which will seek to, as a general objective related to the implementation of Article 
191 TFEU, contribute to: 

• 
• 

the EU commitment to combat climate change and achieve sustainability goals; and 
improving the level of preservation, protection and quality of the environment 

This will be achieved by ensuring more data-driven decision and policy-making on forests, which is 
expected to increase public trust in forest management, reduce illegal logging, incentivise and reward 
more  sustainable  forest  management,  and  support  the  adaptation  of  forests  to  climate  change, 
therefore contributing to the Commission policy priorities outlined in strategic policy documents such 
as the EU Biodiversity Strategy, the Adaptation Strategy and the New Forest Strategy for 2030. 

It is important to highlight that this initiative is about better data, knowledge and planning but does 
not impose on forest management policy choices and objectives of the Member States. 

4.2  Specific objectives 

Based on the problem definition and the problem drivers described regarding forest monitoring and 
integrated forest planning in the EU, the specific objectives of the initiative are described below. It 
is important to note that the objectives are intrinsically linked to each other since efficient monitoring 
requires clearly defined strategic policy needs and monitoring provides the evidence base needed for 
long-term planning that integrates different forest-related policy objectives. 

4.2.1  Ensure availability of common consistent, comparable, timely and accessible data 

In light of the new policy mandates and strategic objectives under the European Green Deal, such as 
those identified in the Biodiversity Strategy, Adaptation Strategy or the New EU Forest Strategy for 
2030, this initiative aims to lay down a set of common indicators and methodologies to ensure that 
data  collected  across  Member  States  on  forest  conditions  and  management  are  consistent, 
comparable, timely, particularly by making the most out of the digitalisation potential, and that they 
cover  the  relevant  policy  data  needs  on  forest.  The  priority  topics  are  those  of  climate  change 
mitigation and adaptation, forest health and resilience, biodiversity and ecosystem condition, forest 
management and forest bioeconomy.  

As an example, the production and dissemination of timely data is needed for land managers and 
policy makers to swiftly assess the current situation, implement corresponding response measures or 
adjust related policies.  The forest  data need to  be furthermore  collected  in a transparent  way and 
disseminated so that they are accessible to all relevant stakeholders and data users. EO, including EO 
data provided by the Commission via the Copernicus programme,  combined with ground-truthing 
provides a significant potential to this end. 

4.2.2  Facilitate integrated long-term forest planning 

The development of a strategic vision of the forests and the forestry sector by Member States will 
address  the  problem  of  insufficient  and  fragmented  long-term  planning  for  forests  with  limited 
consistency  across  policy  objectives  with  relevance  to  forests  and  the  forest-based  sector.  A 

19 

 
 
governance framework for integrated forest planning can help to minimise conflicting objectives and 
maximise synergies across forest policies. 

5  WHAT ARE THE AVAILABLE POLICY OPTIONS? 

5.1  What is the baseline from which options are assessed? 

Under a baseline scenario forest monitoring and planning continues to be based partly on the legal 
frameworks at the EU level and partly organised separately by each Member State under voluntary 
international monitoring and reporting frameworks, e.g. Forest Europe’s State of Europe’s Forests 
(SoEF) and ICP Forests, or country reporting into international frameworks of obligatory nature such 
as  FAO’s  Global  Forest  Resource  Assessment  (FAO  FRA)  und  greenhouse  gas  reporting  to  the 
UNFCCC. Table 21 and 22 in Annex 5 illustrate the coverage and diversity of forest-related indicator 
collection in the EU-27.  

Considering the latest reporting year in the SoEF 2020 under Forest Europe, forest data availability 
differs greatly across Europe. Even though certain international frameworks collect information on 
forest vitality (ICP Forest), fragmentation (CORINE dataset), forest management objectives (FAO 
FRA)  and  the  occurrence  of  common  forest  birds  (Pan-European  Common  Bird  Monitoring  – 
PECBMS),  data  availability  for  other  forest  indicators  remains  scarce.  For  example,  only  sixteen 
Member States provide data on forest disturbances to the SoEF and only nine Member States publish 
data on threatened forest species. Without a common framework for monitoring, the efforts are likely 
to remain scattered, incomplete, and insufficient for the purpose of EU-wide assessments (Table 22 
in  Annex  5).  At  the  same  time,  pressures  on  forests  will  increase,  making  the  lack  of  consistent, 
complete and comparable spatio-temporal data an even greater problem in time.  

The  necessity  of  addressing  challenges  related  to  the  integration  of  EO  and  ground-based  data  is 
increasingly  recognised  in  the  EU  Member  States46.  This  requires  interoperability,  common 
definitions, no ambiguity in data interpretation and long and comparable very high-resolution time-
series.  Current  forest  products  from  Copernicus  represent  a  progress  but  so  far  limited  to  the 
indicators on tree cover density and dominant leave type and with rather limited uptake by state-level 
stakeholders47. Without a common framework and the engagement of stakeholders for building trust 
and a common understanding, the gap between potential improvements through the uptake of new 
technologies  and  available  data  will  inevitably  grow,  hampering  the  EU’s  ambitions  for  a  digital 
Europe. 

Similarly, without an EU framework for forest monitoring, it will remain challenging to demonstrate 
that the EU is on the right track in implementing its relevant policies and ambitions, and that the 
forests can actually deliver on their multiple demands and functions. 

The EU legal framework is set to evolve through several legislative proposals by the Commission 
with  relevance  to  forest  monitoring  and  integrated  forest  planning,  namely  on  the  NRL48  and  an 

46 Almost 60% of OPC respondents identify data integration with ground or in situ data as a major or minor technical 
challenge. Recommendations from CZ PRES workshop on Forest Monitoring highlights the need of combining remote 
sensing and field-collected data for improving information on forests, and the need for mutual and timely exchange of 
both kinds of data 
47 At the first meeting of the SFC sub-group on forest monitoring and integrated long-term planning 8 out of 9 MS that 
spoke on this point indicated they are not using Copernicus for National Forest Monitoring 
48 COM(2022)304 final 

20 

 
 
 
amendment of the European environmental economic accounts Regulation49 introducing a new forest 
accounts  module.  Where  adopted,  these  legislative  proposals    will  establish  some  mandatory 
indicators as well as lay down some reporting and monitoring requirements in support of their specific 
policy  objectives  (Table  21  in  Annex  5).  The  NRL  proposal  furthermore  provides  for  the 
establishment  of  restoration  plans  including  forest  ecosystems  where  relevant.  However,  the 
monitoring  and  reporting  requirements  of  certain  forest-related  parameters  included  in  the  NRL 
proposal are designed  for restoration purposes and only concern national average value, whereas a 
comprehensive forest monitoring framework would require broader indicator coverage and a more 
detailed  level  of  granularity.  The  NRL  proposal  includes  a  certain  level  of  harmonisation  for  the 
indicators, while some incentive for the  use of  EO is  foreseen50, e.g. for  the monitoring of forest 
connectivity.  

With the provisional agreement between Parliament and Council on a revised LULUCF Regulation, 
monitoring  of  annual  carbon  fluxes  in  forest  land  can  be  expected  to  improve.  The  LULUCF 
reporting approaches and methods, applied by Member States under the Governance Regulation, are 
proposed as the basis to certify carbon removals under the proposal for an EU-wide voluntary carbon 
removal certification framework recently adopted by the Commission. Nevertheless, the reporting 
requirements in the provisional agreement on a revised LULUCF Regulation build on the general 
reporting guidelines as set out by the Intergovernmental Panel on Climate Change (IPCC), and do 
not prescribe the exact tools with which data on greenhouse gas emissions and removals are to be 
collected,  e.g.  using  EO.  An  EU-wide  monitoring  framework  would  therefore  support  the 
implementation of LULUCF and better work as enabler for carbon removal certification schemes. 

Data collection and reporting at national (and where applicable regional) and EU and international 
levels would therefore continue to evolve with partial coordination and harmonisation that is mostly 
achieved at the level of definitions and with only limited success on the level of data collection design 
and methods51. Data quality and data continuity would remain for most indicators in the current state 
(with quality, continuity and transparency of data accuracy varying across Member States), with some 
limited exceptions, particularly related to monitoring of forest-based carbon and wood-based industry 
related indicators, which through the impetus of several large EU research projects52 are edging closer 
to EU-wide and repeated data production. 

Methods for biodiversity monitoring would mostly continue to rely largely on proxy indicators with 
the exception of the common forest  bird index, with  a likely addition  of  EO-based monitoring of 
forest structural diversity and tree species – but not as an operational EU-wide monitoring system.   

Importantly, there would be no system or requirements for the EU-wide collection of comprehensive, 
near-time, comparable, high-quality data on the evolution of tree health and forest disturbances under 
climate change key to ensure forest resilience for example. 

The harmonisation of NFI data collection and reporting systems would continue to benefit to a certain 
extent from EU funded activities such as COST actions53,  and Horizon Europe and other research 

49 COM(2022)329 final 
50 The NRL proposal already contains a requirement that Member States should “maximise the access and use of data 
and services from remote sensing technologies, earth observation (Copernicus services)” and others.  
51 See Forest Europe 2020 (Annex I on limitations in harmonisation) and FAO 2020 
52 For instance Horizon 2020 project BioMonitor 
53 For instance COST Action E43 

21 

 
 
 
and  innovation  projects  that  bring  NFIs  together54  (via  Commission’s  JRC,  ENFIN  or  other 
cooperation modalities) as well as non-EU funded research into harmonisation of forest indicators in 
Europe55. However, actual engagement would differ across Member States and, together with the ad-
hoc nature of respective EU funding, would limit longer-term strategic efficiency and progress. 

Advances through research and innovation, notably in  EO might reduce the existing gap between 
knowledge availability and needs for EU policy making and implementation. However, the lack of a 
common  framework  will  likely  lead  to  varying  uptake  by  Member  States  and  access  to  such 
information will remain fragmented.  

A lack of oversight and consistency will continue to impede integrated forest planning across the 
various relevant policy domains. Benchmarking or setting of objectives would unlikely be achieved; 
and the incentive to streamline and improve EU-wide forest monitoring would depend on sectoral 
legislation addressing only interests in very specific indicators. Voluntary approaches to harmonise 
would continue for the majority of indicators. Coordination of forest-related policies would remain 
at the initiative of the coordinating authority in the Member States. 

5.2  Description of the policy options 

5.2.1  Option 1: Streamlined reporting for forest monitoring and integrated forest planning – fully 

voluntary option 

This option aims to achieve a common  approach to forest monitoring and integrated planning for 
coherent  delivery  of  EU  objectives  and  priorities  pertaining  to  forests  while  leaving  maximum 
flexibility to Member States as how to translate them into their national context.  

Voluntary coordination through Commission guidelines and sharing of best practices would aim to 
harmonise national data collection and strengthen forest planning frameworks and mechanisms to 
address the problems identified in Section 2. Monitoring obligations under existing  (or proposed) 
legal  obligations  (Table  21  in  Annex  5)  would  form  the  starting  point  for  setting  priorities  while 
enhanced  harmonisation  efforts  could  also  concern  key  selected  indicators  currently  included  in 
existing international monitoring and reporting frameworks such as Forest Europe’s SoEF reporting, 
forest condition parameters collected in the ICP Forests network or indicators reported under FAO-
Global FRA. 

The Commission, in the framework of the new Forest Governance being set up pursuant to the new 
EU Forest Strategy, would make use of dedicated expert groups in order to facilitate coordination 
and  exchange  on  forest  monitoring  including  harmonisation  and  integrated  planning.  Following 
consultation  with  theses  expert  groups,  the  Commission  would  issue  voluntary  guidelines  to 
strengthen consistency and comparability in data collection, promote EO and facilitate the drafting 
of  evidence-based  integrated  forest  planning  for  example  by  offering  a  common  set  of  basic 
requirements and core elements for consideration by Member States. 

54 Examples of such projects are PathFinder or ForestNavigator, both having as one of their objectives the strengthening 
of forest monitoring and harmonised forest data in the EU.  
55 E.g. through ENFIN, or other research such as Gschwantner et al 2019, Gschwantner et al 2022 or Vauhkonen et al 
2019 

22 

 
 
 
The  Commission  would  continue  to  provide  existing  EO  services  through  the  Copernicus  Land 
Monitoring Service on selected forest data such as phenology and net primary productivity.  

The Call for evidence showed wide agreement among stakeholders that an EU-wide forest monitoring 
network should be based on existing  national  forest  inventory data, in  order to  reduce the risk of 
duplicating data. In the OPC, business associations and public authorities tended to be in favour of 
better  integration  of  Member  States’  monitoring  systems,  but  with  little  changes  to  monitoring 
methods. These views are in line with Option 1. 

5.2.2  Option 2: Monitoring framework for resilient European forests –legislative option 

This  option  would  aim  to  set  up  an  obligatory  EU  framework  for  data  collection  and  reporting, 
advanced  use  of  EO  and  integrated  forest  planning  with  two  sub-options  on  the  level  of  EU 
intervention. 

In order to address the problem of varying level of indicator coverage across Member States, and 
following a step-wise approach (see Annex 5.2), a set of key mandatory indicators and parameters 
would  be  selected  for  their  inclusion  in  this  obligatory  EU  framework.  Their  selection  would  be 
linked  to  strategic  objectives,  such  as  those  identified  in  the  Biodiversity  Strategy,  Adaptation 
Strategy or the new EU Forest Strategy and supported by an expert group (see below). Stakeholders 
identified these indicators also as the most important ones to monitor in the OPC (Figure 22 in Annex 
2). The methodology for the selection of the indicators is further described in Section 5.2.1 of Annex 
5.  

Common  to  both  sub-options,  definitions  and  methods  for  the  mandatory  indicators  would  be 
harmonised based either on existing definitions and methods or those developed with the support of 
an expert group (see further down). Standardisation would be suggested for core indicators where the 
uncertainty  of  harmonised  estimates  is  too  high  or  where  no  internationally  agreed  common 
definitions and methods currently exist. Common harmonised definitions will be established where 
currently missin . Sharing of relevant data by Member States will follow the approach to open public 
data  and  its  re-use  of  Directive  (EU)  2019/1024,  mitigating  reporting  obligations  on  public 
administrations.   

 Further details on indicator harmonisation and standardisation are given in Box 1, Annex 5. 

The Commission would ensure that data collected by Member States are regularly reported to and 
published  on  Forest  Information  System  for  Europe  (FISE)  as  a  common  platform  for  forest 
information.  

The use of Earth-Observation (EO), complemented by in-situ monitoring where necessary for data 
calibration  and  validation,  would  be  mandatory  for  indicators  and  parameters  for  which  the 
underlying policy needs necessitate data acquisition with higher frequency and spatial resolution, i.e. 
at a parcel level with roll out over large areas. The Commission would operate the EO-based forest 
monitoring system, expanding and developing its service to provide data covering the EO mandatory 
indicators specified in Table 21 in Annex 5. This will lead to a consistent monitoring of such EO-
based parameters (e.g. forest area) across the EU.  

23 

 
 
 
Member  States  would  be  required  to  develop  context-specific  long-term  plans  based  on  common 
elements,  building  on  existing  planning  instruments.  These  plans  should  provide  a  holistic 
assessment,  integrating  forest-related  policy  objectives,  targets  and  risks  (related  to  biodiversity 
protection,  forest  ecosystem  restoration,  forest  carbon  sink,  climate  change  projections,  forest 
biomass  demand  for  energy  and  material  uses,  non-timber  uses  of  forests  etc.),  and  include 
forecasting via available integrated modelling frameworks to be defined by the expert group. Based 
on these assessments, the Member States’ plans would develop a vision for forests and the forest-
based sector for the next 10, 30 and 50 years. This  assessment  would  need to be underpinned by 
quantitative  and  qualitative  analyses,  forecasting  and  climate  projections,  and  be  developed  in  an 
inclusive  process  with  stakeholders.  Furthermore,  to  help  ensure  coherence  between  national  and 
Union policies, a governance framework would enable an ongoing dialogue between the Commission 
and  the  Member  States  and,  where  appropriate,  between  the  Member  States.  In  this  context,  the 
Member States would be required  review the plans every 10 years in order to ensure their viability, 
building on the average periodicities for data collection and monitoring in Member States.  

Among the OPC responses, stakeholders identified a “holistic view on forest status and trends” and 
“overall coordination of long-term forest planning” as the most important added values of integrated 
forest  planning.  Generally,  providers  of  forest  data  tended  to  be  more  positive  towards  a 
comprehensive coverage of issues in such plans, while forest owners tended to be less positive (see 
Annex 2). 

Similar  to  option  1,  a  new  expert  group  in  the  framework  of  the  new  Forest  Governance  would 
facilitate follow-up and implementation of the regulation. Where not yet available, the expert group 
would help the Commission developing proposals for common methods for indicator harmonisation 
and standardisation, dealing with data collection needs and proposing further indicators for policy 
implementation as relevant. It would further provide a forum for good practice exchange on long-
term planning for forests. 

Generally,  business  associations,  companies,  forest  owners  and  public  authorities  tend  to  show  a 
preference  for  Member  States  continuing  current  monitoring  systems,  while  environmental 
organisations, forest data providers and EU citizens tend to favour better integration of monitoring 
systems, with standardisation of forest monitoring methods (see Annex 2). Option 2 and its two sub-
options represents a balance between these two views.  

•  Sub-option 2.1– Medium level of intervention  

Member States will be required to report on a targeted set of indicators and parameters related to EU 
legislation and policy objectives on forests (see Table 21 in Annex 5). The selection would be based 
on  existing  EU  and  relevant  international  monitoring  and  reporting  systems,  such  as  criteria  and 
indicators used for Forest Europe’s SoEF reporting, forest condition parameters collected in the ICP 
Forests  network,  indicators  reported  under  FAO-Global  FRA  (see  5.2  of  Annex  5).  Basing  the 
selection of indicators and parameters on those reported under existing frameworks aims to reduce 
costs related to data collection and harmonisation. The initiative would not introduce any additional 
reporting requirements  for indicators relevant  for EU forest  policy objectives  which are currently 
collected under international monitoring and reporting schemes and which satisfy identified policy 
needs (e.g. reporting on forest management plans and management objectives under FAO).  

The “opt-in approach” combines EO-based forest monitoring operated by the Commission with the 
possibility for Member States to enrich the data pool with their sources. Following a specific, clearly 

24 

 
 
documented data management protocol, Member States could upload their measurements, or LIDAR 
coverages that are currently not available wall-to-wall across the European Union, in Member State 
specific  containers  including  regionally  or  nationally  available  EO-data.  Regarding  data 
management, such a system could, for instance label the data as: 

“private”:  not  geo-located    (plot  location)  and  not  accessible  (plot  measurement)  by  other 
Member States or the public. Only the Member State who provided the data can use it for 
forest monitoring in their national domain and the Commission can access them for purposes 
of data quality assessment. 

“protected”: not geo-located but accessible by other Member States and the public, i.e. they 
can benefit from the measurement information without knowing the measurement location. 

“public”: geo-located and accessible by other Member States and the public. 

This way, Member States’ existing and more advanced monitoring systems could also benefit from 
an EU monitoring system as a complementary layer of information (and potentially decrease national 
costs  for  its  operation)  without  compromising  on  the  quality  compared  to  their  current  national 
systems. 

Member  States  will  be  required  to  prepare,  report  and  review  integrated  long-term  plans,  but  the 
Commission will not make recommendations on these plans.  

•  Sub-option 2.2 – High level of intervention  

Member States will be required to report on a more comprehensive set of indicators and parameters 
related  to  EU  legislation  and  policy  objectives  extending  beyond  existing  EU  and  relevant 
international monitoring and reporting systems. The additional indicators compared to sub-option 2.1 
would however still be limited to a small number of indicators essential to underpin the main policy 
objectives related to forests (see Table 21 in Annex 5).  

These  new  indicators  would  notably  include  more  detailed  information  on  tree  mortality,  storm 
damage, drought damage, or pest outbreaks which - although crucial for making appropriate decisions 
for adapting forests to climate change and for assessing the related progress under Articles 5 and 6 
of  the  European  Climate  Law  -  are  currently  not  monitored  under  specific  EU  law  or  by  the 
international forest monitoring systems mentioned above. Similarly, sub-option 2.2 would include in 
its scope monitoring of silvicultural regimes in EU forests, use of clear-cutting and the location and 
extent of primary and old-growth forest, all identified as policy-relevant information essential for the 
implementation  of  the  new  EU  Forest  and  Biodiversity  Strategies  for  2030.  In  addition  to  data 
harmonisation for existing indicators, data collection will be standardised for the new indicators. 

The Commission will develop and operate EO-based forest monitoring on a specific set of indicators 
(see Table 21), complementary to in-situ data collection carried out by MS, and provide these data 
for their publishing in FISE. There would be no opt-in possibility for the Member States. The OPC 
revealed  a  high  level  of  support  for  a  single  monitoring  system  operated  by  the  EU  among 
environmental  organisations  and  EU  citizens,  while  companies,  business  associations  and  public 
authorities tended to be less positive. 

The  Commission  will  review  Member  States’  integrated  plans  and,  where  relevant,  issue 
recommendations  on  their  alignment  with  specific  policy  objectives  and  targets.  Whereas 
recommendations have no binding force, Member States will nevertheless be invited to take account 

25 

 
 
of  such  recommendations.  Contrary  to  other  governance  frameworks  (for  example  on  National 
Energy and Climate Plans (NECPs56), Member States will not have to provide and make public the 
reasons for not addressing the recommendations. 

5.2.3  Option 3: Obligatory monitoring and voluntary planning - the hybrid option 

This option combines core elements described in option 1 and sub-option 2.2.  

Monitoring  elements  would  be  mandatory  to  address  the  problem  of  varying  level  of  indicator 
coverage and data collection approaches across Member States following the approach described in 
sub-option  2.2,  while  integrated  forest  planning  would  be  optional  for  Member  States.  Reporting 
would  be  obligatory  for  a  set  of  indicators  and  parameters  related  to  EU  legislation  and  policy 
objectives  beyond  existing  EU/international  requirements  with  data  harmonisation  for  existing 
indicators and standardisation for the new indicators. The Commission will develop and operate EO-
based  forest  monitoring,  complementary  to  in-situ  data  collection,  and  publish  this  data  into  the 
monitoring system. 

Like under Option 1, integrated long-term planning would be voluntary for Member States supported 
by an expert group for coordination and knowledge exchange for instance for sharing best  national 
practices  in  drafting  such  plans.  Following  consultation  with  this  expert  group,  the  Commission 
would issue voluntary guidance to facilitate the drafting of evidence-based integrated forest planning 
for example by defining a common set of basic requirements and core elements for consideration by 
Member States. 

5.3  Options discarded at an early stage 

5.3.1  Option 4- Targeted EU funding for monitoring and integrated long-term planning 

Option  4  would  seek  to  address  the  problems  identified  by  ring-fencing  EU  funding  for  forest 
monitoring and integrated long-term planning activities, either from existing funding programmes or 
through the creation of a new funding facility. 

Common objectives for forest monitoring and integrated planning would be defined together with 
the requirement to prepare national programmes and a process to decide on what should be funded at 
EU level and a process for allocating and managing the funds.  

A  dedicated  budget  from  the  EU  budget  would  be  assumed  based  on  current  costs  for  in-situ 
observation in the EU 57 and costs of satellite and airborne measurements by the EU and MS.  

A  dedicated  funding  instrument  for  forest  monitoring  existed  in  the  past  with  the  Forest  Focus 
Regulation  that  established  an  obligation  for  coordinated  EU-level  forest  monitoring  backed  by 
extensive  co-funding  (EUR  65  Mio  over  a  four-year  period  for  the  EU-15).  This  Regulation 
strengthened  integrated  forest  monitoring,  established  a  database  with  aggregated  data  and 
information  on  the  state  of  EU  forests,  and  broadened  the  scope  of  forest  monitoring  to  soil  and 

56 See Article 9 of Regulation (EU) 2018/1999. 
57  This  would  include  financial  support  for  extending  and  strengthening  the  existing  international  monitoring  and 
reporting frameworks (e.g. ICP Forests or LUCAS) or national forest inventory programmes.   

26 

 
 
 
 
 
biodiversity.  However,  its  cost-efficiency  was  limited  by  the  absence  of  common  definitions  for 
indicators, data collection or monitoring protocols. In combination with the complex landscape of 
beneficiaries of these funds, significant differences of “value for money” among beneficiaries were 
the result. The assessment of the legal instrument concluded that despite strict control of financial 
management  (external  auditing)  implementation  of  forest  monitoring  in  Member  States  was 
insufficient58. In view of the objective to streamline and consolidate financial instruments, the Forest 
Focus Regulation was not renewed and was replaced at the end of 2006 by the LIFE+ Regulation. 
Voluntary in nature and without dedicated focus on forests, clear monitoring targets or obligations 
for  consistency  and  harmonisation,  uncoordinated  activities  and  limited  spatial  and  temporal 
coverage increased again in light of the high administrative and field costs for forest monitoring. 

Given  this  experience,  funding  without  specific  objectives  and  targets  or  obligations  would  not 
achieve the objectives of this initiative as described above, i.e. Member States would not put in place 
coherent  monitoring  frameworks  and  long-term  planning.  Therefore,  option  4  is  not  considered 
suitable as a stand-alone option, but funding is considered a useful add-on for the preferred option 
(Chapter 8).  

5.3.2  Option 5: Strengthened international engagement 

Option 5 will consider whether a common standard for forest monitoring and integrated long-term 
planning  could  be  achieved  through  promoting  the  development  of  appropriate  international 
standards  and  coordination  of  the  delivery  of  existing  international  requirements  for  the  EC  and 
Member States. 

There are several international or intergovernmental bodies and processes with relevance to forest 
monitoring and integrated long-term forest planning but none has an overall responsibility. United 
Nations’  Framework  Convention  on  Climate  Change  (FCCC)  and  Convention  on  Biological 
Diversity  (CBD) specifically address  forests and forested land, including in  relevant  international 
agreements59. Several UN subsidiary and implementing bodies such as the FAO, the UN Forum on 
Forests and the  International Tropical Timber Organization support improving forest-related data, 
information, and capacities for conservation, sustainable management, and legal harvesting. The EU 
and its Member States have reporting obligations that require  forest  information  systems  towards 
international schemes such as ICP Forests, the FAO-Global FRA, the UNFCCC and the CBD and 
the  recently  adopted  “Kunming-Montreal  Global  Biodiversity  Framework”  (GBF)60.  In  the 
framework of FOREST EUROPE (also known as the Ministerial Conference on the Protection of 
Forests in Europe), Member States report to varying degree on indicators for forests and the forest-
based sector on a voluntary basis. 

However, none of these international commitments and fora includes an obligation for the EU or its 
Member States that establishes a common framework for forest monitoring or integrated long-term 
planning or provide a structured process for doing so. Neither is it likely that such commitments and 
obligations  would  emerge  in  the  foreseeable  future.  Collaboration  certainly  exists  but  it  is  on  a 
voluntary basis and split between many separate arrangements not achieving the required level of 

58 Freer-Smith et al. 2006 
59 Paris Agreement, Kyoto Protocol, Montreal Agreement. 
60 Target 21 aims to ensure that the best available data, information and knowledge, are accessible to decision makers, 
practitioners and the public to guide effective and equitable governance, integrated and participatory management of 
biodiversity,  and  to  strengthen  communication,  awareness-raising,  education,  monitoring,  research  and  knowledge 
management […].  

27 

 
 
 
harmonisation  or  standardisation.  For  example,  the  experience  in  Forest  Europe  shows  that  the 
voluntary process on criteria and indicators serves as a structure and framework, but the actual take-
up and application of the criteria and indicators varies widely between the various countries as the 
development and implementation process is complex and can be costly61.  

While  not  considered  a  viable  stand-alone  option,  international  engagement  should  continue  and 
could be considered as part of the preferred option.  

6  WHAT ARE THE IMPACTS OF THE POLICY OPTIONS? 

This  chapter  identifies  specific  categories  of  economic,  environmental  and  social  impacts  and 
provides a detailed assessment of those impacts for each of the policy options and sub-options that 
are still under consideration: 

1.  Option 1: Streamlined reporting for forest monitoring and integrated long-term forest planning –

voluntary option 

2.  Option  2:  EU  framework  for  forest  monitoring  and  integrated  long-term  forest  planning  – 

legislative option 

2.1. Medium level of intervention 

2.2. High level of intervention 

3.  Option 3: Obligatory monitoring and voluntary planning - the hybrid option 

Table 2: Summary of the key components for each of the options 

Reporting 
obligation for 
indicators 

Data 
harmonisation 
and 
standardisation 

Role of Earth 
Observation 
(EO) 

Dedicated Group 
for implementation 
support 

Long-term plans 
obligations 

Policy 
Option 
1 

No additional 
indicator 
obligations 

Voluntary, 
based on 
Commission 
guidance 

EC offers 
existing EO 
services to MS – 
i.e. baseline 

Yes, focus on 
coordination, 
guidelines and 
knowledge exchange 

No 

Mandatory 
harmonisation, 
standardisation 
where statistical 
accuracy cannot 
be achieved 

EO mandatory 
where pertinent; 
EU further 
developed EO 
services with 
MS ‘opt-in’ 
possibility 

Yes, supporting 
development of 
common methods for 
monitoring 

Yes, with mandatory 
common structure 
and elements 

Policy 
sub-
Option 
2.1 

Yes, based on 
indicators 
gathered in 
existing EU 
and 
international 
frameworks 

Easy data 
access via 
FISE 

61 Linser and Wolfslehner 2022 

28 

 
 
 
 
Mandatory 
harmonisation 
and 
standardisation 

EO mandatory 
where pertinent; 
EU operated 

Yes, supporting 
development of 
common methods for 
monitoring and 
recommendations 

Yes, with mandatory 
common structure 
and elements 

Commission issues 
non-binding 
recommendations 

Mandatory 
harmonisation 
and 
standardisation 

EO mandatory 
where pertinent; 
EU operated 

Yes, focus on 
coordination, 
guidelines and 
knowledge exchange 

No 

Policy 
sub- 
Option 
2.2 

Policy 
Option 
3 

Yes, also 
beyond 
existing 
monitoring 
EU and 
international 
frameworks 

Easy data 
access via 
FISE 

Yes, also 
beyond 
existing 
monitoring 
EU and 
international 
frameworks 

Easy data 
access via 
FISE 

The identified impacts have components that are unique, but also several components that are similar 
in nature for each of the assessed policy options and sub-options. To avoid unnecessary repetitions 
and keep the different sections balanced and of similar length, this chapter is structured by impact 
category rather than by policy option. In each section assessing a given impact category, all policy 
options and sub-options are considered, showcasing impacts that are common to all of them and those 
that are unique.  

For the hybrid option (Option 3), provisions regarding monitoring are the same as for the existing 
policy option 2.2. and for long-term planning the same as for policy option 1. Socio-economic and 
environmental impacts of Option 3 are therefore not assessed individually but according to its two 
building blocks together with option 1 for the planning element and option 2.2 for the monitoring 
element.  In  light  of  the  intrinsic  links  between  the  two  elements,  internal  coherence  is  added  as 
additional criterium for the comparison of the different options in the following chapter. 

6.1 

Identification of impacts and stakeholders 

The following section describes impact categories that are being considered for each of the assessed 
policy options and sub-options.  

Several  relevant  stakeholder  groups  have  been  identified.  The  table  below  summarises  the  main 
stakeholder groups which are used throughout this chapter, along with a brief description. 

29 

 
 
 
 
 
 
Table 3: Overview of most relevant stakeholder groups 

Group 
EU institutions 

MS public 
authorities 

Description 

•  The EU level institutions develop and coordinate policy and oversee its 
implementation. They use data for policy monitoring and reviews. 

•  Those include the relevant ministries, agencies, and other public institutions in the MS. 
They organise and implement (or procure) data collection activities and are in charge 
of integrated long-term planning. They use data and information to help the 
monitoring of policy implementation and policy making (including for forest 
management purposes) and to fulfil international reporting obligations. This may 
include disaster risk management agencies and services. 

Data providers 

•  Those include organisations responsible for national forest inventories, organisations 

responsible for preparing and or collecting information on forest management 
planning, as well as organisations involved in the mid- to down-stream development of 
forest monitoring services in programmes such as Copernicus. 
Those include a wide range of stakeholders which use forest data, for example: 

•  Forest owners: Those who own forests and may or may not use them for economic 

Other users of 
forest data 

purposes. 

•  Forest industries: Forest industries can use information on forest resources to plan 
their resourcing strategies and to plan the feasibility of possible investments 

•  Service providers: forest management services, carbon trade services, 

environment/green services; financial services/insurances; recreation and health, 
nature-based tourism, but also other types of service business - data applications on 
natural sites, non-wood products and services, and any other data-based business 

•  Non-governmental organisations: Accurate and timely information will support 

Society 
6.2  Description of the current situation 

transparency and participation of non-governmental organisation 
•  Users of forest products, beneficiaries of healthy forests, general public 

Costs for monitoring depend to some extent also on the area that needs to be monitored, i.e. the forest 
area  in  the  respective  Member  State.  The  Figure  below  provides  an  overview  of  forest  area  per 
Member State. 

Figure 1: Share of forest areas in the EU Member States 

Figure 2: Share of gross value added of forestry and logging of national GDP 

Source: Eurostat. Own illustration. Detailed data in Annex 4 

30 

 
 
 
 
The Figure shows that there are large differences regarding the relative share of forest area to the 
overall area of the respective Member State. For example, around 2/3 of the areas of Finland and 
Sweden are covered by forests. On the other hand, only 1% of Malta and 11% in Ireland are covered 
in forests. 

Consequently, the overall costs for monitoring are likely to be higher in Finland and Sweden. At the 
same time, the average cost per area can be expected to be lower in countries with large shares of 
forest areas since the cost for the overall structure of forest monitoring is distributed more widely. 
Vice versa, while the costs in countries with a small share of forest area will be lower overall, the 
overhead for governance, education, IT structure, and other enabling factors for forest monitoring, is 
comparably larger. 

In addition to those benefits of scale, it should also be noted that the expected long-term benefits 
from better monitoring such as reduced biodiversity loss, enhanced resilience and others are higher 
in those countries than in the ones with little forest. 

6.3  Economic impacts 

6.3.1  Public budget 

Data harmonization, improvement of existing as well as the set-up of new monitoring and integrated 
planning systems bear the following economic costs for equipment and personnel that would be borne 
by the public budget (EU, national, regional, or lower level): 

o  Monitoring systems: This includes costs related to one-off investments, scientific research and 

technical analysis, operational roll-out and maintenance. 

o  Harmonisation and standardisation of data collection and reporting: Data for a given indicator, 
collected through different methods or different sources, can have various formats. To be able to 
compare data collected through different methods, the aggregated statistical estimates needs to 
be  harmonized,  which  is  linked  to  some  costs.  The  development  of  the  definition  and 
methodology for standardization can also be linked to costs as well as its roll out.  

o  Integrated long-term planning: This includes administrative costs related to drafting of the plans, 

their review and monitoring of progress towards objectives set out in the plan. 

6.3.1.1  Monitoring systems 

It is planned that through the legislative initiative remote sensing will play a greater role in forest 
monitoring than is currently the case, with positive impacts on the productivity of the sector. Table 4 
on  the  semi-quantitative  review  of  forest  monitoring  methods  provides  a  comparison  of  remote 
sensing as  compared to  ground-based monitoring or aerial monitoring.  The selected attributes are 
rated in relative terms from + (worst, compared to other methods) to +++ (best, compared to other 
methods). 

31 

 
 
 
Table 4: Semi-quantitative review of forest monitoring methods 

s
s
e
n
i
l
e
m

i
t

a
t
a
D
+ 

d
o
h
t
e

M
Ground-
based  data 
collection 

y
t
i
l
i
b
i
s
s
e
c
c
a
a
t
a
D
+ 

n
o
i
t
u
l
o
s
e
R
+ 

*
s
t
s
o
C
+ 

++ 

+++  

Airborne 
data 
collection 

to  ++ 

+ 
depending 
on 
project 

the 

to  ++ 

+ 
depending 
on 
project 

the 

+++ 

Satellite 
data 
collection 

++  to  +++ 
based on the 
product 
used 

+++ 

+++ 

s
h
t
g
n
e
r
t
S
Direct observation in the field; 
source of official statistics; long 
tradition  of  methods;  strong 
statistical 
soundness;  
possibility  to  collect  detailed 
biodiversity and habitat related 
information on the plot level 

Airborne  Laser  Scanning  and 
optical imagery can be used for 
and 
precise 
compositional  mapping;  good 
biomass/carbon 
stock 
monitoring;  

structural 

information; 
Wall-to-wall 
capable of acquiring changes in 
near  real 
time  (e.g.,  forest 
disturbance);  large  public  and 
open-access  databases;  pan-
European  monitoring  process 
or 
operational/demonstrated 
developed 
forest 
indicators 

for  many 

s
e
s
s
e
n
k
a
e
W
Lack  of  harmonisation  on 
definitions 
and  methods; 
expensive;  raw  geodata  not 
available;  unable 
to  detect 
quick changes in near real time;  
estimates only valid at national 
or macro-regional levels 

Cost; geographical coverage 

Need  for  processing  capacity; 
data  quality  related  to  climatic 
conditions;  need  of  ground-
for  modelling, 
based  data 
calibration 
accuracy 
and 
assessment 

The selected attributes are rated in relative terms from + (worst, compared to other methods) to +++ (best, compared to other methods). 
* Only considering the per hectare costs of EO image acquisition without the launch/take-off costs, they are lowest for satellite monitoring (0.09 
EUR/ha) and higher for airborne technologies, with airplanes being less expensive (1.68 EUR/ha) than drones (43.36 EUR/ha)62.  
Source: Own compilation 

As  is  shown,  satellite  data  offers  many  benefits  such  as  frequency,  wall-to-wall  coverage, 
transparency of data and many others. From an operational standpoint, remote sensing can provide 
benefits when replacing ground-based data collection or complementing it when used for monitoring 
new indicators.  The  feasibility  of satellite-based  support systems  for land management, including 
compliance assessment, is demonstrated by the CAP legislation, where its use is prescribed in the 
legal  text63.  It  should  be  noted  that  satellites  are  to  date  already  used  for  EU  wide  forest-related 
monitoring, for example through the EFFIS or high resolution layers on tree cover density and forest 
type under Copernicus64.  

A case study in Sweden assessed the benefits from a situation in which ground-based data collection 
for forest regeneration after clearcutting has been replaced by satellite-based monitoring65. It found 
that the use of satellite data collection allowed to save between  EUR 16 and 21 million per year. 
Breaking savings further down, the study finds that approximately EUR 9 million of those annual 
benefits accrue for the public authorities (the Swedish Forest Agency), between EUR 6 and 11 million 

62 Sozzi et al 2021 
63 See Recitals 58 and 100, and Articles 7, 25, 65 and 83 of Regulation (EU) 2021/2116. 
64 https://effis.jrc.ec.europa.eu, https://land.copernicus.eu/pan-european/high-resolution-layers/forests  
65 Geoff et al. 2016 

32 

 
 
 
 
 
 
 
 
 
 
 
 
 
for private forests owners (from increased compliance with forest management obligations which in 
the long-term lead to higher return), and approximately EUR 1 million for citizens.  

An ex-ante evaluation of Copernicus benefits66 estimated that if 75% of data needed to produce clear-
cut maps by public administrations for monitoring compliance will be produced using free of charge 
Copernicus  data,  replacing  data  currently  purchased  from  commercial  satellites,  this  can  bring 
cumulative savings of anywhere between EUR 28.2 million to 37.6 million by 2035 (not discounted). 
At the same time, it should be emphasised that the figures only looked at one specific indicator, and 
that benefits from additional indicators will likely add up.  

Looking  at  the  overall  benefits  of  the  Copernicus  system for  forest  monitoring,  the  ex-ante  study 
estimated that the potential of those cumulative benefits67 between 2017 and 2035 is between EUR 5 
and 13 billion across the EU. However, it should be noted that those numbers are subject to major 
uncertainties  and  only  partly  applicable  in  this  context:  they  are  to  a  large  extent  based  on 
extrapolating findings from the abovementioned case study across the whole EU; they assume that 
commercial data are replaced with free-of-charge Copernicus data at a certain rate; and the ecosystem 
benefits  are  based  in  the  assumption  that  the  access  to  Copernicus  data  will  improve  the 
implementation of the Habitats Directive.  

Albeit major investments are needed for providing and maintaining the necessary infrastructure (by 
public as well as commercial providers),  all assessed policy options build on already existing  EO 
technologies, and thus no major costs would be linked to their set-up. Those systems are part of the 
baseline and do not increase through improved uptake of the forest related data products. It should 
however be highlighted that those initial investments are substantial; for example, the European EO 
Programme Copernicus alone had a budget of around EUR 4 billion for the period 2014 to 2020 and 
is planned to benefit from EUR 5.8 billion for the period 2021 to 2027i, covering a wide range of 
domains  and  applications,  with  only  a  part  of  this  budget  being  relevant  for  forest  monitoring. 
Monitoring that would purely rely on data from these public satellites would imply that there are no 
costs for data acquisition. However, depending on which indicators are monitored, costs can occur 
for the processing of the data and development of the relevant new data products, and those would 
be borne by the EU. 

Table 5 below shows the potential savings by using public satellite data (Sentinel 2) whose data are 
free  of  charge.  The  minimum  area  price  includes  data  processing  costs  of  image  rectification, 
masking, index calculation and producing output. It should be noted that resolution plays a crucial 
role in determining the price as well as the further processing that is needed in order to obtain data 
for a specific indicator. 

66 PWC 2017 
67 Coming from a) cost reduction in monitoring compliance to forest management best practices; b) improved yields in 
forest industry thanks to sustainable management; c) improved and preserved forest ecosystems and green infrastructures 

33 

 
 
 
Table 5: Estimation of costs for selected remote-sensing products 

Source: Sozzi et al. 2018  

Option 1  

Voluntary  coordination  through  guidelines,  recommendations,  benchmarking  and  sharing  of  best 
practices will lead to low to moderate economic impacts for the public budget of Member States with 
respect  to  forest  monitoring,  which  would  have  the  choice  on  their  level  of  engagement,  varying 
anywhere  between  the  baseline  and  the  most  ambitious  option,  and  the  related  costs  they  would 
decide to bear.  

It is assumed that Member States will show a slight increase in uptake of remote sensing for their 
national forest monitoring following the recommendations for the use of publicly available data or 
producing their own data sets using purchased services.  

Common for Option 2 

Under both sub-options, Member States will be obliged to report on a mandatory set of indicators 
and parameters linked to EU legislation and policy objectives on forests. Depending on the indicator, 
ground-based or EO-based data collection, or both, might be used (see table 21 in Annex 5).  

Costs for Member States under this option will depend on whether their current ground-based data 
collection system (e.g. NFI) meets the minimum requirements defined – specifically the 5 year data 
collection frequency and the spatial resolution indicated in Table 21 for each indicator and parameter. 

The analysis presented in Table 6 based on the current status of NFIs in Member Status shows that 
Member States can be divided in 3 groups in line with the degree of expected costs which would be 
required  to  adapt  their  current  data  collection  framework  to  meet  the  required  minimum  quality 
standards, namely a 5-year data collection frequency, and data coverage. For more detailed discussion 
on the method and the results, see the relevant sections in Annex III.  

The costs for those Member States with a current 10-year cycle would likely be considerably less 
than double of the current costs, since expertise, infrastructure, and equipment would be maintained 
and incremental cost would only arise from additional staff costs during data collection and analysis. 

More  significant  costs  would  occur  in  cases  where  a  new  ground-based  system  with  sufficient 
sampling plot density would need to be established by a Member State with no existing running NFI 
(Bulgaria, Greece) or those where only one assessment has been carried out (e.g. Croatia)  – these 
costs  would  relate  to  investments  into  new  infrastructure  (e.g.  designing  the  sampling  grid  and 
establishing plots), capacity building (training of personnel), and equipment.  In these countries the 
running costs would decrease for the subsequent exercises. 

34 

 
 
 
 
 
Table 6: Categorisation on Member States according to potential costs under the preferred option  

Legend: For columns showing the variables of forest area, number of NFI plots, NFI plot density and frequency and the number  of indicators not monitored (compared to the 
indicators of Table 21 considered for their inclusion in the legislative proposal under the preferred option), the red colour coding denotes a high effect of this variable on costs 
under the preferred option, yellow a neutral effect, while green denotes a low effect. Frequency of plot visits is compared to a 5 year benchmark.  For the column on the ‘Share 
of Gross Value Added of Forestry Sector to overall GDP’, green colour denotes higher overall benefit from acquiring additional information on forest to the forest sector. For 
the column on planning, the orange colouring code denotes moderate costs while yellow denotes limited costs.

35 

Bulgaria38,930 km20.40%No NFIn/an/aNo information52Croatia19,391 km20.40%6,2320.3only 1 assessment262Cyprus1,725 km20.01%3200.2only 1 assessmentNo information123Greece39,018 km20.03%2,7440.1only 1 assessment392Malta5 km20.00%No NFIn/an/aNo information182Austria38,992 km20.24%11,0000.33352Belgium6,893 km20.02%11,0001.65442Czechia26,771 km20.52%19,7270.75353Denmark6,284 km20.09%9,5581.55263France172,530 km20.14%33,5000.25253Germany114,190 km20.08%78,0000.710252Hungary20,530 km20.19%7,4250.45262Ireland7,820 km20.01%1,9320.25262Italy95,661 km20.11%7,0000.110242Lithuania22,010 km20.50%5,7370.35342Luxembourg887 km20.03%1,2001.410No information63Netherlands3,695 km20.02%3,1900.94472Poland94,830 km20.36%30,7220.35293Portugal33,120 km20.44%12,0000.410352Romania69,291 km20.63%24,0000.35No information72Slovakia19,259 km20.54%1,4860.110363Slovenia12,378 km20.60%7610.110463Spain185,722 km20.08%95,3270.510342Estonia24,384 km21.16%27,5001.15262Finland224,090 km21.70%60,0000.35132Latvia34,108 km21.70%No informationn/a5353Sweden279,800 km20.73%No informationn/a5152Extent to which MS already have forest strategic planning  in placeForest areaShare of GVA of forestry sector overall GDPNumber of NFI forest monitoring plotsMonitoring plotsNFI monitoring plots per km2 of forest areaCurrent time interval between subsequent plot visitsGroup 3Extent to which EO is currently integrated in forest monitoring programs Overall number of indicators NOT monitored yetGroup 1Group 2MS 
 
 
Both sub-options come with additional effort needed for the mapping of forest habitats under Habitats 
Directive  (2.1)  and  primary  and  old-growth  forests  (sub-option  2.2),  for  which  field  surveys 
additional to the sample-based forest inventory might be necessary, entailing some further costs to 
Member States, especially those with large forest areas. Tools such as EO data could be used in the 
first  stage  for  pre-screening  potential  areas,  in  combination  with  in-situ  data  and  modelling 
techniques, for improving the cost-efficiency of such an exercise.  

While the impact assessment faced in most cases major challenges in identifying information on the 
costs  and  budgets  of  conducting  NFI  and  other  forest  monitoring  activities,  such  data  could  be 
identified in three Member States: Finland, France, and the Netherlands. While this sample is not 
representative for the whole EU, it nevertheless includes a spread of countries of different size and 
different share of forest areas. It needs to be noted that the costs include the use of EO for the support 
of  the  NFIs  and  that  the  NFI  frequency  ranges  from  5  (France  and  Finland)  to  7  years  (the 
Netherlands). The average annual  cost of forest  monitoring through NFIs in those countries is 42 
EUR/km2 of forest area. Bearing in mind the caveats around the non-representativeness of the sample 
(e.g. France and Finland have above-average indicator coverage of their NFIs, see Table 22) and the 
assumption  around  the  use  of  EO,  this  sum  is  a  rough  approximation  that  countries  with  no  NFI 
would bear to set up a new system. Countries with lower NFI frequency could bear the additional 
cost equalling the difference between the abovementioned sum and their current annual costs per km2 
of forest area in order to reduce their NFI interval to 5 years.  

Development costs for Copernicus would be limited compared to the significant  frontload of past 
investments into the system and its forest-related elements, especially on tree cover density. Still, 
there would be additional costs for development and continuous updating of new forest data products. 
Based on the existing contracts by the EEA’s Copernicus Land Monitoring Service68, the estimated 
costs for producing an annual update of an EO-based forest data product is approximately EUR 500 
000.  Additional  costs  are  expected  in  relation  to  acquiring  ground  data  for  the  validation  and 
calibration of these products, especially relating to forest disturbances or estimation of aboveground 
forest biomass. These will vary depending on accessibility of existing data collected by NFIs – higher 
costs are to be expected if the data are not accessible and an alternative ground data framework would 
need to be funded.  

In both sub-options, benefits stemming from a greater role of remote sensing can be expected (see 
also 6.4).  

Option 2 – Sub-option 2.1 

Under  sub-option  2.1,  the  Commission  will  further  develop  and  operate  satellite-based  forest 
monitoring for the indicators with foreseen EO obligations, with the possibility for Member States to 
enrich  the  data  pool  via  an  ‘opt-in’  option.  Additional  cost  would  mainly  relate  to  increasing  the 
frequency  and  quality  of  existing  products,  relating  to  for  example  tree  cover  density  changes  or 
monitoring of crown condition.  

For indicators with foreseen mandatory EO monitoring, the Member State could use data provided 
by  the  Commission,  or  use  the  ‘opt-in’  option,  using  either  their  own  existing  EO  data  sets  and 
systems or acquiring new EO data and services. Most costs incurred by the public budget of Member 
States linked to this sub-option would therefore be linked to the purchase of selected products from 
existing remote sensing service providers where Member States choose to ‘opt-in’. For satellite data, 

68 https://ted.europa.eu/udl?uri=TED:NOTICE:163863-2019:TEXT:EN:HTML 

36 

 
 
 
this would entail related data processing and acquisition costs of the order of magnitude similar to 
products showcased in table 5 above. 

To ensure comparability of data from Member States choosing to ‘opt-in’, the EU institutions might 
bear the cost of defining minimum product requirements for remote sensing in terms of technical 
parameters of an indicator, minimum mapping unit, pixel resolution, periodicity between assessments 
and accuracy. Those could then be calibrated to national circumstances to ensure that the data would 
be comparable across the EU. 

An advantage of a system that is developed centrally but that has the option to be implemented in a 
distributed manner through ‘opting-in’, is that Member States could realise potential synergies and 
meet  requirements  both  at  EU-level  as  well  as  at  national,  sub-national  to  local  levels.  Another 
advantage is that restrictions on the sharing or use of geo-referenced in-situ plot data – as is currently 
an issue in several Member States – may be circumvented (as explained in Chapter 5.2.2 for sub-
option 2.1). Lastly, higher resolution data might be fed into the satellite-based EU system (e.g. from 
airborne monitoring), increasing the quality of data provided.  

Option 2 – Sub-option 2.2 and Option 3 

Under sub-option  2.2  and Option  3, the Commission  would develop  and operate EO-based forest 
monitoring complementary to in-situ data collection and report these data to FISE. 69 

In addition to impacts described for sub-option 2.1, additional processing costs would be incurred by 
the Commission by developing new forest data products for indicators and parameters that are not 
currently  produced  using  Copernicus  remote  sensing  data  and  the  reporting  on  which  would  be 
mandatory  (e.g.  comprehensive  EU  forest  disturbance  monitoring).  The  costs  would  overall  be 
comparable to those outlined under sub-option 2.1.   

6.3.1.2  Harmonisation and standardisation of data collection and reporting 

Common to all options 

Some moderate costs are expected to occur when developing and applying reference definitions and 
harmonised  methods  for  the  different  indicators.  An  indication  of  the  order  of  magnitude  of  data 
harmonization  costs  can  be  found  from  looking  at  costs  of  ongoing  initiatives  with  comparable 
objectives. The table below provides an overview of such initiatives and their costs. 

Table 8: Overview of ongoing and past initiatives aiming at harmonising EU wide forest data 

Name 

Type 

Overall budget  

PathFinder Towards an Integrated Consistent  European LULUCF 
Monitoring and Policy Pathway Assessment Framework 

Horizon 
research project 

Europe 

 6.3m EUR 

Estimated  share  of  the 
overall 
for 
harmonisation 
5-10 % 

budget 

ForestPaths  Co-designing  Holistic  Forest-based  Policy  Pathways 
for Climate Change Mitigation 
DIABOLO  Distributed, 
Information for Bioeconomy Outlooks70 

Integrated  and  Harmonized  Forest 

Europe 

Horizon 
research project 
Horizon 
research project 

2020 

 6m EUR 

5m EUR 

14%  (10  indicators  –  EUR 
840.000 per indicator) 
60 %  

69 See Recitals 58 and 100, and Articles 7, 25, 65 and 83 of Regulation (EU) 2021/2116. 
70 More details in these projects see https://cordis.europa.eu/  

37 

 
 
 
 
Name 

Type 

Overall budget  

Harmonisation of  National  Inventories in  Europe: Techniques  for 
Common Reporting71 

Cost action 

570k EUR 

Source: Own compilation 

Estimated  share  of  the 
overall 
for 
harmonisation 
100% 

budget 

In addition, several specific contracts have been tendered by the Commission’s Joint Research Centre 
under  the  framework  contract  with  ENFIN,  focusing  among  other  objectives  on  forest  data 
harmonisation through developing and applying common definitions and conversion methods, for 
instance on aboveground biomass, area of forest available for wood supply and net annual increment 
(Specific contract 17, 19, 20 and 21 under the Framework contract 934340)72. The total cost for these 
and other forest data harmonisation exercises under three framework contracts as of 2008 is estimated 
to be around EUR 1.95 million.  

The actual costs for harmonising the data, once the method is implemented, are not considered to be 
significant.  As  the  necessary  scientific  and  technical  background  analysis  for  harmonization  is 
already undertaken, cost per Member State will be limited to operational roll out, which in most cases 
can be assumed to be an automatized statistical process following an established protocol from the 
background  research.  Our  internal  analysis  of  three  JRC  projects  showed  that  the  conversion  of 
estimates by applying the harmonised definitions cost up to EUR 10 000 per variable per Member 
State.  

It is expected that most of the process would be automatic, with manual quality assurance procedures 
in place. As for the QA/QC, the reporting frequency plays an important role for the costs (see Table 
21 for data reporting per indicator). 

The data will be reported through the existing FISE platform73 and thus no major IT development 
costs would occur; those would relate mainly to operational and maintenance costs, which might be 
slightly higher due to the amount of data to be processed. Maintenance and further development of 
the platform are currently partly outsourced through a number of contracts with combined costs of 
around EUR 300 000 annually.  

Additional costs would occur for the Commission for developing IT related specifications for data, 
metadata, data exchange and data sharing protocols. This would e.g. include the development of xml 
schemas and guidance documents74 and thus not lead to major costs.  

Increasing the efficient use of public resources, the Commission may save costs on accessing and 
assessing  reporting  done  by  Member  State  authorities  where  current  reporting  in  formats  which 
cannot easily be automated (e.g. reporting in pdf format) or accessed is replaced by common reporting 
of the base data to FISE. 

Option 1 

Voluntary  harmonisation  and  standardisation  will  lead  to  low  to  moderate  budgetary  impacts  for 
Member  States,  which  would  have  the  choice  on  their  level  of  engagement,  varying  anywhere 

71 https://www.cost.eu/actions/E43/  
72 https://ted.europa.eu/udl?uri=TED:NOTICE:45302-2018:TEXT:EN:HTML  
73 Developed in a partnership between the Commission and the EEA, and set up under the 2013 EU Forest Strategy, FISE 
is an entry point for sharing information and data on Europe’s forests.  
74 See e.g. this example of the respective files for reporting under the Drinking Water Directive 

38 

 
 
 
the  baseline  and 

the  sub-option  2.2 

between 
indicators 
harmonised/standardised, and the related costs they would decide to bear. The voluntary nature could 
mean  that  Member  States  choose  to  harmonise  indicators  in  the  most  cost-efficient  manner,  i.e. 
choose  to  target  such  indicators  where  harmonisation  costs  borne  by  their  public  administration 
would be lowest in relation to the estimated utility value of the efforts on the national level.  

the  extent  of 

terms  of 

in 

The order of magnitude of those costs for option 1 should stay below the costs of initiatives listed in 
Table 6, as it is assumed that the Member State choosing to harmonise will select indicators for which 
the necessary harmonised definitions and methods have already been developed.  

It can be assumed from previous experience that some Member States will “go the extra mile” and 
transform their locally collected data according to an established protocol into harmonized indicators 
for the EU in cases where the added value for Member States of such a harmonisation is immediate 
and  demonstrated,  in  particular  for  forest  risk  assessments  and  collaboration  in  case  of  natural 
disasters.  Other  Member  States  could  show  more  reluctance  to  carry  out  this  additional  step  for 
indicators they deem less critical for their own benefit, in particular with regards to biodiversity and 
forest  carbon  estimates.  Where  standardisation  is  recommended,  e.g.  because  the  transformation 
process  does  not  lead to a statically  robust harmonized indicator or because the indicator is  new, 
voluntary engagement by Member States is highly unlikely due to relatively higher costs, unless there 
is a clear and immediate benefit for them.  

Option 2 and monitoring element of Option 3 

Obligatory  standardization  and  harmonization  of  selected  mandatory  indicators  would  lead  to 
moderate to significant economic impacts for the public budget of Member States, depending on the 
current situation in individual Member States.  

Similarly as for Option 1, cost of harmonisation for public administrations will be mostly limited to  
operational  roll  out,  and,  where  currently  missing,  building  of  new  reference  definitions  and 
conversion methodologies (i.e. ‘bridges’75). 

In  cases  where  harmonization  of  estimates  is  not  possible  due  to  a  lack  of  common  reference 
definition  or  harmonisation  methods,  or  the  high  inherent  uncertainty  of  the  bridging  functions 
leading to harmonised estimates of low quality and accuracy, there would be additional costs as data 
need to be collected according to a common standard instead. The bulk of costs would be borne by 
those Member State authorities who have to adapt their current monitoring to the new standards. This 
can lead to two different situations: on the one hand, MS could give up their current national system 
and only apply the standardised methodology. This could lead to the loss of national time series. On 
the other hand, MS could decide to implement two parallel systems (i.e., their national system and 
the established standard), which would result in increased costs for labour. 

Specific  costs  for  the  MS  for  implementing  the  new  standardised  methodology  depends  on  the 
indicator. The cost of standardisation may be close to zero for new easily visually detectable tree-
related parameters which require only limited changes in time and skills to detect – this applies for 
example to standardisation of indicators related to basic tree variables (e.g. growing stock).  

For both sub-options of Option 2 and the monitoring element of option 3, there are indicators which 
are not yet part of the data collection in all Member States (see Table 21 and 22 in Annex 5). In those 
cases, additional costs would accrue for rolling out the indicators in the country (including staff costs 
and potentially costs for new equipment). It is not possible to estimate the marginal cost of rolling 

75 Ståhl et al. 2012 

39 

 
 
 
out  additional  indicators  in  Member  States  where  they  are  not  yet  measured,  because  detailed 
information  on  monitoring  of  particular  indicators  is  very  sparse  and  is  not  openly  shared  due  to 
various data protection reasons. 

In general, adding an indicator to a national monitoring system could come with almost no additional 
cost if it is  calculated on the basis of  existing data (e.g., Shannon index for tree species diversity 
could be calculated based on the already collected data on tree species). On the other hand, it could 
lead to increased costs if additional training of staff, purchase of equipment, or others are needed – 
if substantial measurements or additional staff are required (e.g., for non-tree plant diversity), this 
might increase cost per plot of 30 to 50%.76.  

For  sub-option  2.2  and  monitoring  element  of  Option  3  costs  will  increase  with  the  additional 
indicators. Most of these can be assumed not to be gathered by Member States at a significant scale 
and  would  thus  require  standardization.  The  costs  of  the  obligation  of  monitoring  an  additional 
indicator in the existing NFI is in general limited, although in the case of primary and old-growth 
forest, it might entail costs related to ground-surveys for their identification and monitoring. 

In contrast to option 1, the data to be reported is fully harmonised or standardised across Member 
States. Thus, the data could be presented in specific maps, graphs, charts or other means in FISE. 
Within the institutions, it is expected that the integration of additional forest data and indicators would 
entail further staff days as a one-off expense when extending the contracts, resulting in additional 
costs  compared  to  the  baseline  (EUR  300  000  annually  through  external  contracts  plus  internal 
resources at the EEA) estimated at max 30%. 

6.3.1.3  Integrated long-term planning 

Option 1 and Option 3 

Under options 1 and 3, Member States would not have any obligations related to integrated planning 
other than those already in place. Limited additional costs specific to integrated planning would be 
incurred by Member States from the adoption of voluntary guidelines on integrated planning and by 
the Commission for producing the guidelines and providing means of policy coordination between 
Member  States,  such  as  costs  for  organising  the  workshops  or  costs  for  developing  the  guidance 
materials. Based on the voluntary guidelines, Member States could gradually improve and adapt their 
national strategy planning system ensuring better comparability at EU level. There is however large 
uncertainty on whether Member States would follow voluntary guidelines to the extent required to 
achieve the objectives of this initiative. 

Option 2 – Sub-option 2.1 

Under this option, Member States would be required to develop long-term plans aligning them to a 
common structure including forecasting, to report every five years towards the goals set out in the 
plans and review them every 10 years to ensure their viability. At an expert workshop on costs and 
benefits hosted by the Commission, most participants agreed that such timeframes were relevant due 
to the fast moving nature of pressures and policy frameworks, and to be able to adapt the plans in 
case of rapid changes in forests (see Annex 2). 

The actual costs per Member State would to some extent depend on already existing information, 
structures  and  expertise  in  the  Member  States.  Several  Member  States  at  least  partly  develop 
integrated planning instruments for forests. A mapping done as part of the impact assessment (Table 
23, Annex 5) shows that 18 Member States already have or are developing a document which can be 

76 An estimate based on an assessment by NFI experts interviewed by a contractor  

40 

 
 
 
considered a national forest strategy fulfilling to some degree the objectives of long-term integrated 
planning. Requiring those plans to follow a common structure would require limited efforts and low 
additional costs.  

For  Member  States  that  do  not  have  partially  integrated  planning  instruments  in  place  or  for 
underpinning existing plans moderate costs would occur, the main cost coming from the preparation 
of the reports. This would include the following items: 

• 

• 

One-off costs for developing new or adapting existing methodologies for forecasting, 

Recurring cost for conducting the forecasting exercise, 

Recurring  cost  for  target  setting  (including  internal  coordination  between  authorities  and 

• 
conducting stakeholder consultations), 

• 

Recurring cost for drafting the report. 

The direct costs for Member States are very difficult to estimate in advance as these costs depend to 
a large extent on the national context, capacity, economic situation etc in the Member States and it is 
not possible to foresee how Member States would work to design their plans.  

However, as a reference for the magnitude of the costs the example of Germany can be given which 
started  developing  their  2050  strategy  in  2015  and  spent  approximately  EUR  600  000  for  the 
development (EUR 500 000 for the preparation of the strategy and EUR 100 000 for dissemination77). 

Costs  for  analysis  related  to  forest  carbon  can  be  considered  low  given  previous  experiences  by 
Member States with National Forestry Accounting Plans, the National Energy and Climate Plans and 
the  Long-term  strategy  and  biannual  reporting  obligations  on  policies,  measures  and  projections. 
Socio-economic indicators may also  be  readily available in  several  Member States. However,  for 
Member  States  that  do  not  yet  include  those,  cost  will  occur  for  sections  on  climate  adaptation, 
biodiversity and assessing the overall policy coherence. In particular costs for smaller Member States 
with less experience and Member States with low shares of forest land may be higher than Member 
States with more experience in forest planning and foresight. 

Regarding the costs for drafting the progress reports, by way of example the Fitness check of the 
Reporting, Planning and Monitoring Obligations in the EU energy acquis78 surveyed Member States 
about their costs for policy planning and reporting in relation to several obligations of the Renewable 
Energy Directive. The results presented in the study include median costs of EUR 4 407 per Member 
State and year. Those relatively low costs have been found to be largely driven by a standardised 
template provided by the Commission, which was also found to increase the compliance of Member 
States with the reporting obligations79. 

Option 2 – Sub-option 2.2 

In addition to requirements described under sub-option 2.1, under sub-option 2.2, the Commission 
will  review  Member  States’  integrated  planning  instruments  and  issue  recommendations  on  their 
alignment with specific policy goals. 

77 Bundesfinanzministerium 2015 
78 Trinomics 2016  
79 SWD/2016/0416 final  

41 

 
 
 
 
Costs would be of the same order of magnitude as under Sub-option 2.1, but additional costs in Sub-
Option 2.2 would arise for any follow up to the Commission’s recommendations.   

6.3.2  Regulatory burden for SMEs and other businesses 

None of the policy options includes any regulatory obligations that would be directly applicable to 
businesses. Monitoring, reporting and integrated planning would, for all of the policy options, be the 
responsibility of public authorities.  

Data collection for the large majority of indicators, namely those that will rely on satellite data or on 
a network of monitoring sites to produce statistically relevant information on the national level80, 
would be directly undertaken by competent authorities, with no risk that the burden or costs would 
be passed down to businesses.  

In the case of economic indicators under Options 2.1, 2.2 and in relation to Option 3’s monitoring 
element related to the bioeconomy, namely on production and use of timber and non-wood forest 
products, some indirect basic reporting obligations might arise for the forest-based sector to fulfil 
data  needs  by  competent  authorities,  but  these  statistical  data    are  estimated  to  have  negligible 
additional  costs,  as  they  would  be  collected  and  reported    for  industry  statistics  purposes  or  for 
existing international reporting, such as Joint Forest Sector Questionnaire, to which the vast majority 
of the MS already provide replies.  

80 See Table 21 for an overview of those already monitored by NFIs.  

42 

 
 
 
Box 1: SME Test  

In the first step of the SME Test it has to be determined ‘to what extent is the initiative relevant 
for  SMEs  (not  relevant,  relevant,  highly  relevant)?’  with  the  help  of  the  following  guiding 
questions:  

•  Are  SMEs  within  the  scope  of  the  legislative  initiative?  Does  the  initiative  specifically 

target SMEs? 

The scope of the assessed initiative does not include any obligations towards the SMEs, neither 
in the forestry and logging sector, nor on the side of industry. Therefore it can be concluded that 
SMEs are not specifically targeted by the initiative.  

•  Will the SMEs be significantly impacted directly or indirectly by the legislative initiative? 
Are SMEs impacts likely to be more substantial than on other companies, for example in 
terms of adverse effects? 

Based on the questions  above, no direct impact  on the SMEs is expected. On-the-ground data 
collection on forest  resources  and  condition  will not  be done by individual forest  owners, but 
through a sample-based approach by forest inventory networks funded by public authorities, as is 
the case in every MS with an established monitoring system.   

Nevertheless, some indirect impacts on wood-based industries cannot be excluded if reporting on 
the production and use of timber products is passed onto the forest-based industries. However, 
additional  costs  are  considered  to  be  limited  as  such  reporting  already  largely  exists  for  other 
purposes (see below).   

Based on the questions above, the first step of the SME Test can conclude that the initiative is not 
relevant for SMEs in terms of its potential negative impacts and therefore no further analysis is 
needed.  

No major impacts on businesses related to regulatory burden were thus identified for any of the policy 
options under the ‘SME Test’(see box 1 above).81  

6.3.3  Opportunities for SMEs and other businesses 

It is planned that thanks to the legislative initiative the EU will be a global leader for forest monitoring 
and implementation of sustainable forest management practices, offering numerous opportunities for 
growth and innovation of European businesses. 

Remote sensing will play a greater role in forest monitoring than is currently the case, offering many 
possibilities to SMEs active in acquiring and processing the satellite imagery, data processing and 
providing services related to forests and forestry, including advisory services. Promoting EO-based 
based products under Option 1 or introducing a legal mandate for acquisition of specific forest data 
under Options 2 and 3 would increase the demand for EO based products in general, which  would 

81 Based on tool 23 in European Commission 2021 

43 

 
 
 
   
  
 
encourage  more  companies  to  enter  the  market  and  create  new  products  to  meet  the  increased 
demand.  

A survey82 from 2020 among countries members of either the EU or ESA has found that for more 
than  9000  companies  EO  services  are  a  minority  part  of  their  business,  with  97%  of  them  being 
classified  as  micro,  small  or  medium  companies.  As  it  has  been  the  case  in  agriculture  with  the 
revolution brought by remote sensing to precision agriculture, and that opened a new market, offering 
numerous opportunities for European SMEs and other businesses, it can be assumed that a similar 
success story could take place in forestry. 

The global market for remote sensing products and related data processing and advisory services has 
been  estimated  at  USD  16.5  billion83  in  2020,  out  of  which  around  40%  are  held  by  European 
businesses84. The global market is estimated to grow and reach USD 55.5 billion in 2028. According 
to the World Economic Forum, the conservation, restoration, and sustainable management of forests 
could generate EUR 190 billion in business opportunities and 16 million jobs worldwide by 203085.  

The greater role of remote sensing can also bring benefits for forest managers and the forest sector: 
the case study86 mentioned in the previous section on monitoring systems estimated annual benefits 
ranging between EUR 6 and EUR 11 million annually for private forests owners in Sweden from 
increased compliance with forest management obligations leading to higher returns in the long-term. 
Building on this study, the ex-ante benefits assessment for Copernicus87 also concludes on remote 
sensing  and  Copernicus’  potential  to  improve  yields  thanks  to  sustainable  management  practices, 
increasing the volume and quality of timber in the long term. 

Easy  access  to  high  quality  data  will  also  allow  businesses  linked  to  the  forest  sector  to  better 
understand the quality and quantity of ecosystem services forests provide and the costs of inaction. 
A study from 2021 provided an assessment of the economic costs of climate change in Europe and 
found that there was low coverage of the forest sector, and a particularly limited number of studies 
on  the  evaluation  of  losses  from  pests  and  diseases88.  A  case  in  point  is  Czechia,  which  suffered 
dramatic  decreases  in  the  market  value  of  its  wood  products  due  to  severe  bark  beetle  attacks 
requiring  salvage  logging  of  large  amounts  of  infected  trees.  Following  a  severe  2018  outbreak, 
timber prices decreased from EUR 56-64 per m3 (2011-2017), to EUR 14-16 per m389. 

Understanding the quality and quantity of ecosystem services provided by forests is also a crucial 
step in view of a future implementation of payments for ecosystem that would compensate and reward 
forest managers, incentivizing them to enhance or maintain ecosystem services provided by forests. 
Indicators  related  to  carbon  capture  and  storage  would  be  key  to  quantify  possible  payments  for 
climate mitigation, for instance within the framework of the EU Certification of Carbon Removals90, 

82 EARSC 2020 
83 Statistics Market Research Consulting 2021 
84 European Union Agency for the Space Programme 2022 
85 World Economic Forum 2020  
86 Geoff at al. 2016 
87 PWC 2017 
88 COACCH 2018 
89 Hlásny et al. 2019 
90 https://climate.ec.europa.eu/eu-action/sustainable-carbon-cycles/carbon-removal-certification_en 

44 

 
 
 
 
 
 
 
 
while  indicators  related  to  biodiversity  could  allow  to  quantify  possible  payments  for  nature 
restoration or conservation. 

This may also allow forest holdings and the downstream forest-based businesses to foresee changes 
(e.g. in species composition) and adapt their business practices. This may lead not only to additional 
jobs in information technology and communication as well as foresters working in the field but also 
more  cost-efficient  intervention  when  field  units  are  guided  to  areas  where  the  intervention  is 
pertinent. 

6.3.4  Digitalisation 

There are strong synergies between the green and digital transition.91 The greater role of advanced 
forest  monitoring  technologies  and  reporting  systems,  using  advanced  technology,  is  expected  to 
bring high benefits in terms of digitalisation, in line with the objectives of the Digital Agenda for 
Europe92. This digitalization of forest information will require higher upfront investments followed 
by moderate costs for operation as discussed in the section on impacts on public budgets.  

The benefits accrued in terms of digitalisation can be found mainly under Option 2 and Option 3, 
where more prominent role is envisioned for reporting of the data collected through a single portal – 
FISE. A future version of FISE enhanced with up to date in situ data and EO calculated indicators 
could take part in the Green Deal Data Space eco-system and contribute to a data market economy.  

As elaborated in 6.4.1.1, the carbon offset market will most likely have a strong interest for certain 
Forest indicators made available from the forest monitoring program. Carbon market stakeholders 
like  forest  owners  will  make  use  of  the  data  to  carry  out  monitoring  reporting  and  verification 
activities related to carbon capture by their forest projects. 

In  line  with  the  first  objective  of  the  Digital  Agenda  for  Europe,  providing  better  access  for 
consumers and businesses to digital goods and services across Europe, having easy access to the 
data will reduce the administrative burden for businesses, citizens, and administrations in search of 
forest-related information. Using FISE as the single portal for data reporting and publication will also 
be  aligned  with  the  ‘once-only’  principle  for  data  use.  This  principle  is  also  adhered  to  when 
Copernicus data are reused for production and monitoring of new indicators.As outlined in section 
6.3.3 on Opportunities for SMEs and other businesses, the initiative will contribute to creating the 
right conditions for digital networks and services to flourish and contribute to maximising the growth 
potential of the digital economy, which are the second and the third objectives of the Digital Agenda 
for Europe. 

6.4  Assessment of environmental and social impacts  

The environmental and social impacts of the initiative are difficult to directly quantify as they are 
often  ‘knock-on’,  i.e.  indirect  benefits  of  the  initiative.  As  an  example,  the  framework  aims  to 
facilitate evidence-based decision-making at the EU level, which will support the implementation 
(and  achievement)  of  EU  policy  objectives  relating  to  forests,  and  more  sustainable  forest 
management and enhanced environmental protection of forests. Therefore, general estimations are 

91 COM(2022)289 final  
92 European Parliament 2022 

45 

 
 
 
 
 
given  in  quantitative  terms  where  possible;  otherwise  qualitative  statements  based  on  existing 
literature are used to illustrate the impact. 

6.4.1  Environmental impacts 

Facilitation of evidence-based decision- and policy-making  

Evidence-based decision-making is one of the pillars of EU policy93.The availability of high-quality, 
accurate and continuous datasets that provide a holistic picture on the state of forests provides the 
evidence base for informed decisions and policies on forests by administrations and forest managers, 
and facilitates the monitoring of progress  towards policy objectives and goals. This is  needed for 
national  or  EU  wide  outlooks,  scenario  building  and  impact  assessments.  Moreover,  long-term 
integrated plans that highlight trade-offs between different policy objectives at the national level can 
contribute to identifying inefficiencies, potential policy  incoherencies and conflicting demands on 
forests that could necessitate a policy review.  

The  ability  of  the  different  policy  options  to  deliver  on  this  is  highly  dependent  on  the 
comprehensiveness  of  the  long-term  plans  and  the  type  of  indicators  that  are  selected  and  their 
adequacy to capture the broad range of policy goals and objectives. For policy option 1 and in relation 
to long-term planning for option 3, it is in general difficult to assess to what extent Member States 
would adopt monitoring of additional indicators and carry out integrated long-term planning on a 
voluntary basis. Even though this might bring certain economic benefits (see Section 6.3.1), it can be 
safely assumed that the indicator coverage and the uptake of long-term plans in Member States will 
bring  about  a  comparatively  lower  environmental  impact  as  opposed  to  the  obligatory  nature  of 
indicators, EO-based monitoring and integrated planning instruments under Option 2 and Option 3. 
The means for the Commission to issue recommendations on integrated planning instruments will 
result in a moderately better environmental impact with regard to matching national projections with 
overall EU policy and balancing trade-offs between the demands and the potential of forests to supply 
different ecosystem services.  

The following section therefore only addresses the difference between sub-options 2.1 versus 2.2 and 
Option  3  organized  along  the  different  environmental  impact  categories  which  would  benefit 
indirectly  from  improved  decision-  and  policy-making.  The  following  section  therefore  only 
addresses the difference between the sub-option 2.1 vs 2.2 and Option 3 organized along the different 
environmental impact categories which would benefit indirectly from improved decision- and policy-
making. 

6.4.1.1  Climate mitigation  

Land based carbon removals will play a key role in the achievement of carbon neutrality by 2050 in 
the EU, and they will be increasingly needed when negative emissions will be pursued to stabilise 
the world’s temperature increase94.  

Forest land in the EU currently removes about 340 Mt CO2eq yr−1 of carbon from the atmosphere 
(excluding storage in harvested wood products), and research suggests it should increase to 450 Mt 
CO2eq yr−1 by 2050 in order to reach the EU target for climate neutrality by 205095. There has been 
a steady decline in the amount of carbon sequestered with levels of about 410 Mt CO2eq yr−1 in the 

93 COM(2021)219 final  
94 COM(2021)800 final 
95 Pilli et al. 2022 

46 

 
 
 
2010-2012  period,  decreasing  to  340  Mt  CO2eq  yr−1  in  the  2016-2020  period96.  Therefore,  the 
current estimated economic value of the net carbon sink of EU forests is EUR 32.8 billion per year97.  

Improving  the  quality  and  extent  of  data  on  forest  area,  forest  carbon  stocks  and  fluxes  through 
integration of remote sensing with ground data and better long-term planning integrating other policy 
goals with the one of enhancing forest sink can therefore bring additional positive impacts through 
improved decision- and policy-making. Monitoring is essential to understand where and how to act. 
Subsequently, more streamlined and efficient monitoring of forest carbon can reduce ‘transaction’ 
and ‘design’ costs involved in enhancing forest carbon sequestration98.  

At  the  EU  and  national  level  this  concerns  mainly  improving  the  monitoring  and  reporting  of 
emissions and removals of forest land under the LULUCF Regulation99. Information at parcel-level 
is needed for targeted cost-effective implementation of mitigation actions, tracking their progress, 
and  assessing  their  impacts  in  different  biogeographical  settings  and  socio-economic  contexts. 
Information  by  EO  is  a  key  asset,  as  such  data  are  cheap,  readily  available  and  transparent.  This 
improved  knowledge-base  of  timely  and  more  accurate  information  may  lead  to  policies  and 
decisions better suited for maintaining and enhancing forest sink, and therefore reaching the national 
and EU land sink targets of the Regulation.  

Although both sub-options of Option 2 and Option 3 foresee mandatory use of EO for forest carbon 
indicators, sub-option 2.1 is likely to bring an additional level of accuracy and detail through the ‘opt-
in’ option which would allow the EU wide monitoring to be enriched through incorporation of very 
high spatial resolution data from national monitoring systems such as those collected through LIDAR 
coverage campaigns, which contain critical information about forest structure. The expert workshop 
organised for the purposes of this IA100 concluded that this feature of LIDAR monitoring is especially 
useful for high-accuracy and spatial resolution monitoring of above-ground biomass and potentially 
for cost-efficient deadwood volume estimates.  

Regarding  indicator  coverage,  Option  2.2  and  Option  3  covers  a  few  additional  parameters  and 
indicators which would be useful for the purposes of improving the implementation of the LULUCF 
Regulation  and  carbon  sink  management,  namely  on  forest  area  and  biomass  volume  affected  by 
disturbances.  

Concerning the use of the forest data by forest managers and land owners, the initiative has a high 
potential to benefit land users by providing freely available, reliable and timely data on changes in 
forest carbon, providing the basis for the quantification of baselines and carbon removals, which are 
necessary  for  the  issuance  of  tradable  certificates.  The  availability  of  this  data  could  support  the 
overall functioning of the EU-wide certification mechanism101, and therefore stimulate the adoption 

96 UNFCCC 2022 
97 Calculated based on the current figure of 360 Mt CO2eq referenced above and the EIB 2022 shadow cost of carbon. 
See Commission Notice — Technical guidance on the climate proofing of infrastructure in the period 2021-2027. 
98 OECD, 2021. A Global Analysis of the Cost-Efficiency of Forest Carbon Sequestration. Environment Working Paper 
No. 185. 
99 COM(2021)554 final  
100 The workshop took place online on 23 November 2022 with the participation of invited national forest inventory and 
EO experts.  
101 The Commission proposal for a first EU-wide voluntary framework to reliably certify high-quality carbon removals 
[COM(2022)672 final]  specifies that “all land managers should have access to verified emission and removal data to 
measure carbon farming practices, and all CO2 captured, transported, used and stored through industrial activities should 
be reported and accounted”. 

47 

 
 
 
and  large-scale  deployment  of  sustainable  carbon  farming  practices  across  the  EU,  including 
improved  forest  management,  forest  conservation  and  afforestation102.  Both  sub-options  offer  a 
similar  level  of  necessary  indicator  coverage  on  forest  carbon,  although  additional  data  on  forest 
disturbances might improve knowledge on potential emissions that can inform the estimations on the 
parcel level.  

6.4.1.2  Forest health and resilience 

Forest disturbances disrupt the composition of forests and compromise the provision of ecosystem 
services.  Disturbances  are  becoming  more  frequent  and  intense.  It  is  important  to  improve  and 
maintain forest health and vitality as a measure of protection against the pressures faced. Healthier 
forests exhibit high resilience against both abiotic and biotic stressors, and the need for strengthening 
forest resilience will increase.  

While land-based insect trap networks and other ground-based monitoring and sampling can provide 
good information on the various pest species, more wide-spread use of EO-based monitoring could 
help fostering more rapid or preventive reaction to the disturbances across Member States, potentially 
resulting in reducing forest degradation. This data may also inform long-term planning of adaptive 
forest management practices in identified hotspots.  

Regarding  the  role  of  EO,  for  certain  types  of  disturbances  such  as  pest  attacks  which  manifest 
through  defoliation  or  changes  in  crown  condition,  optical  remote  sensing  with  sufficiently  high 
frequency (at least yearly, ideally monthly)103 and spatial resolution is of great relevance, potentially 
allowing earlier detection of the “green” stage within the outbreak cycle which may lead to reduced 
time lag in appropriate management decisions in line with the Plant Health Legislation (Regulation 
(EU) 2016/2031), which contains provisions for obligatory surveillance and reporting of outbreaks 
of  Union  quarantine  pests.  Both  sub-options’  approaches  to  EO  would  therefore  likely  positively 
contribute  to  reducing  disturbances  caused  by  pests.  However,  for  detection  of  smaller  scale 
disturbances,  distinguishing  certain  types  of  damages  (e.g.  pest  vs  drought),  having  more  higher-
resolution information from aerial mapping (e.g. aerial photography) is essential. For this, the more 
flexible ‘opt-in’ approach of sub-option 2.1 brings more benefits.  

Concerning monitoring  of forest  fires  and fire  risks,  compared to  the baseline, the current  EFFIS 
would under Options 2 and 3 gain a legal mandate and therefore higher certainty of its continuity. 
Even though it is hard to quantify the preventive value of the system, it is important to note that some 
estimates  have  valued  economic  damages  from  forest  fires  in  Europe  of  approximately  EUR  1.5 
billion per year in the 1998-2009 period104 - retaining and improving this information system is likely 
to have positive economic impacts in as far as it promotes disaster prevention and preparedness.  

The enhanced use of LIDAR in EU forest monitoring that is foreseen to be fostered under Options 2 
and  3  can  contribute  to  visualise  and  quantify  the  impact  of  forest  fires  in  order  to  plan  for  the 
rehabilitation of the burnt area105, and as a result reduce costs to Member States and forest owners 
through more efficient post-fire management. Land managers and forest owners can use LIDAR data 

102 SWD/2021/450 final  
103 EO expert workshop, November 2022.  
104 European Environment Agency 2010 
105 Goetz, S.J., Sun, M., Baccini, A. and Beck, P.S., 2010. Synergistic use of spaceborne lidar and optical imagery for 
assessing forest disturbance: An Alaska case study. Journal of Geophysical Research: Biogeosciences, 115(G2). 

48 

 
 
 
 
to assess canopy gaps, the success of forest treatments on forest density, individual tree data, and 
other forest inventory metrics.  

6.4.1.3  Biodiversity and ecosystem conditions  

Preserving and restoring biodiversity  is essential to  ensuring healthy and  resilient forests that can 
fully deliver on their socio-economic and environmental functions. There are clear gaps in the current 
knowledge of the state of biodiversity  in  the  forests in  the EU106,107,108.  EU assessments  of forest 
ecosystems typically include only a limited number of indicators to monitor biodiversity. If the EU 
is to fulfil the objectives of Biodiversity Strategy for 2030, data collection and monitoring of other 
important indicators for biodiversity within forests, for example on other plant and animal species, 
must be undertaken. 

An improved EU-wide monitoring framework would allow for better understanding of the impact of 
forest management decisions on biodiversity and ecosystem service provision, and the detection of 
biodiversity  hotspots. Protection could  thus  be more accurately  and efficiently given to  the forest 
ecosystems by policy- and decision-makers. Equally, better data would feed into long-term planning 
on national as well as local level by competent authorities, incorporating and tracking of biodiversity-
related  objectives  (e.g.  protection  of  high  conservation  value  forest  habitats  and  species).  A 
significant  impact  on  the  potential  of  forests  to  foster  biodiversity  derives  from  the  management 
practices carried out.  More concrete links between management practices  and biodiversity  effects 
can  be  assessed  once  a  clearer  overview  of  forest  biodiversity  is  accessible  to  different  forest 
stakeholders, particularly forest managers.  

In  this  area,  sub-option  2.1  only  relies  on  the  limited  indicator  coverage  of  existing  reporting 
frameworks such as State of Europe’s Forests, which lacks some of the important indicators related 
to the implementation of EU strategic objectives on biodiversity. Instead, the additional indicators 
under Option 2.2 require, for instance, data on EU primary and old-growth forests109, and accurate 
information on areas and impacts of silvicultural regimes and practices supporting biodiversity and 
resilience such as close-to-nature forestry, as well as those with high risk of negative impacts such as 
clearcutting. Data collected for these indicators can moreover feed into the integrated long-term plans 
to safeguard the integrity and health of these important ecosystems.  

Regarding the EO element, high resolution data on forests and their structure using air-borne LIDAR 
could potentially allow monitoring of important biodiversity proxy indicators such as deadwood and 
habitat trees – as mentioned above, this is better facilitated with the use of ‘opt-in’ approach of sub-
option 2.1.  

Another  important  factor  exerting  negative  influence  on  EU  forests  are  invasive  species.  The 
uncontrolled spread of IAS is often a transboundary issue which requires cooperation across various 
levels and regions of governance. Especially invasive insect species have large damage potential for 

106 Maes et al. 2020 
107 Forest Europe 2020 
108 Table 21 and 22 in Annex 5.2.1 
109 Under the European Green Deal and the Biodiversity Strategy for 2030, old-growth and primary forests are recognised 
for their superior ability to store carbon, regulate the climate, and act as important habitats, and are to be protected. 

49 

 
 
 
EU forests. A 2021 study estimated that the cumulative cost of the impact of biological invasions on 
the forest sector in Europe from 1960 to 2020 was EUR 20.9 billion110.  

The  trends  for  the  percentage  of  forest  area  under  pressure  from  invasive  alien  species  (IAS)  are 
generally unknown due to a lack of information available to monitor these species111.  

The existence of an EU-wide framework for reporting and monitoring spatially explicit information 
on the species type, extent, and density, could greatly reduce this as a threat in the EU by allowing 
early detection, rapid eradication as well as preventive measures. Member States have an obligation 
of reporting  on IAS  of Union  concern listed under the Regulation  1143/2014 on their spread and 
introduction. This is, however, not the case for certain invasive tree species which are cultivated for 
economic reasons, such as black locust, even though they have significant impact on biodiversity and 
other ecosystem services in native EU ecosystems112.  

Both sub-options under options 2 and option 3 consider the inclusion of invasive species, irrespective 
of the list  of IAS  of Union concern,  as a mandatory monitoring element, as  a potential indicator, 
which  would  ensure  that  adequate  knowledge  is  available  on  their  spread  to  take  appropriate 
measures. 

6.4.1.4  Countering deforestation and illegal logging  

In  order  to  combat  deforestation  and  illegal  logging,  a  proper  monitoring  system  is  essential  for 
quantifying and evaluating the extent of the problem as a first step. The focus on the monitoring of 
illegal  timber  generally  falls  on  timber  imports  from  non-EU  countries  -  The  Thünen  Institute 
estimate that 6% - 13% of timber imports to the EU in 2009 came from illegal sources113. The World 
bank has estimated the value of forgone tax revenue caused by illegal logging in Europe to be 190 
million USD 114. However, internal EU illegal logging is also economically detrimental to EU forest-
based industries.  Illegal timber can be sold for a significantly reduced price, unfairly undercutting 
the prices of legal timber and forcing legitimate producers to lower their prices to unsustainable and 
unprofitable levels.  

The European Court of Auditors’ report from 2021115 found that remote sensing is a powerful cost-
efficient  tool  that  could  strengthen  the  implementation  and  enforcement  of  the  EU  Timber 
Regulation116 to monitor deforestation and illegal logging activities, and recommends to extend the 
Commission's use of, and promote Member States' use of, geospatial intelligence including remote 
sensing techniques to better assure compliance with EU requirements concerning forest management 
and illegal logging.  

The creation of an EU-wide forest monitoring framework under option 2 and option 3 includes the 
EO-based monitoring of key variables such as tree cover, spatially explicit designation of areas by 
management objective or protection status. This will allow for better identification and prevention of 

110 Haubrock et al. 2021 
111 Maes et al. 2020 
112 Sitzia et al. 2016 
113 Dieter M, Englert H, Weimar H, 2012. Holz aus illegalem Einschlag in Deutschland und der EU: Status-Quo-Bericht 
zum Inkrafttreten des Holzhandels-Sicherungs-Gesetz (Holz-SiG). Holz Zentralbl 137(10):257-259 
114 World Bank 2019 
115 European Court of Auditors 2021 
116 Regulation (EU) 995/2010  

50 

 
 
 
deforestation and illegal logging, thus protecting the forest ecosystem services and allow Member 
States and forest managers to reduce revenues losses. 

It is difficult to estimate the value of this loss prevention, as EU-level estimates on the value of illegal 
logging are not available. However, using national examples, illegal operations made up around a 
quarter of all logging in Bulgaria between 2006 and 2013, generating hidden revenue of over EUR 
50 million per year117. According to a study of a limited set of illegal harvesting methods by the 
Romanian government an estimated volume of 80 million m3 of timber was cut illegally in Romania 
between 1990 and 2011. This represents 24% of the total volume of wood cut during this period, a 
similar share as in Bulgaria. Adequate monitoring and planning will help in reducing deforestation 
and illegal logging and related costs. 

6.4.2  Assessment of social and socio-economic impacts 

The  social  and  socioeconomic  impacts  considered  in  this  section  are  those  of  ecosystem  services 
provided by forests and are not exhaustive or indicative of the full capabilities of the EU’s forests, or 
the long-term impacts which improved sustainable forest management and enhanced environmental 
protection  can  have.  However,  these  were  prioritised  and  deemed  to  be  the  most  prominent  and 
important to highlight, based on the extent they are discussed in the literature and the importance 
given to them in the relevant forest assessment reports. Other impacts besides those discussed here 
include the support of pollination services for agriculture and otherwise, water purification, flood and 
soil erosion mitigation. 

6.4.2.1  Greater trust in forest data from different stakeholders 

More accurate and trustworthy forest information was identified as a key need of stakeholders in the 
public  consultation  (see  Annex  II).  The  adoption  of  modern  technology,  common  definitions  of 
indicators,  harmonisation/standardisation  of  data  collection  methodologies,  as  well  as  increased 
transparency  relating  to  data,  could  improve  trust  in  forest  data  across  the  EU  and  provide 
reputational benefits to forest owners and managers. Accessible data collected in the context of the 
monitoring and planning framework can potentially stimulate the additional use  of forest  data by 
different  stakeholders,  beyond  traditional  users  and  industries  e.g.  scientific  community, 
policymakers, certain actors within the forest industries, data-based services, forest owners (Table 3 
for stakeholder overview).  

More accessible forest data made available on FISE through a new framework can reduce costs for 
those SMEs in the forestry sector who may have paid for data from private data providers118, where 
publicly available information was not available, or considered unreliable or untrustworthy. . SMEs 
who may have relied on publicly available data in the past would benefit for their decision-making 
from increased accuracy and trust in the data on forest resources - 66% of  companies and businesses 
responding to the OPC agree that better access to forest data in general is needed . 

117 WWF 2015 
118 16% of companies and businesses responding to the OPC stated that they used private data providers as a source for 
forest information.  

51 

 
 
 
In this respect, sub-options under Option 2 and Option 3 bring a more significant positive impact in 
that they ensure a higher degree of data comparability and consistency, and they make it accessible 
to the stakeholders as well as wider public through a single portal (FISE).  

6.4.2.2  Sustainable provision of forest resources and services  

Timber provision as an ecosystem service is defined as the contribution of ecosystems to the growth 
of wood harvested as raw material for different purposes. For 2019, the value of timber provision as 
an ecosystem service in the EU was estimated at around EUR 16 billion in the INCA study119, while 
the gross-added value of the forestry and logging industry was estimated at around EUR 23 billion 
by EUROSTAT120. To put those estimates in context: the reported value of marketed non-wood forest 
products in Europe was approximately EUR 4 billion in 2015121, and the annual value of regulatory 
and cultural ecosystem services (i.e. flood control, water purification and recreation for which forests 
were  the  main  contributor  to  the  total  value  of  nature-based  recreation)  for  the  year  2012  was 
estimated at about EUR 57 billion in the same study122. Moreover, forestry and logging employed 
almost  0.5  million  people  in  the  EU27123  in  2020,  with  the  wider  forest-based  employment  of 
approximately 3.5 million people124.  The pulp  and paper industry alone provides 1.5 million jobs 
along the value chain, and bio-based products and biofuels involve 300,000 jobs125. The creation of 
a sound planning framework backed by reliable data can protect future forest resources and establish 
healthy, long-term forest yields to ensure that the forest-based industry has a viable future.  

The added value of more harmonised, accurate, and timely forest data which this initiative would 
bring, will contribute to competitiveness and resilience of EU forest-based sector in multiple ways. 
For instance, timely information on forest risks such as droughts or wildfire risk under Option 2 and 
3  can  help  forest  owners,  and  forestry  industries  identify  potential  risks  to  their  management 
objectives and operations, and take proactive measures to mitigate or adapt to them. Accurate data 
on tree species composition of EU forests and the distribution of impacts of stresses and disturbances 
according to the tree species can bring valuable insight into the evolution of timber resources for the 
timber industry.  Moreover, integration of this data into long-term plans can inform more sustainably 
forest management which benefits both the ecosystem and the forest owners or forest-based industry. 
The combined effects can contribute to healthy, long-term forest yields to ensure sustainability of 
wood supply. Secondly, a more secure internal EU-timber yield will reduce the need to import non-
EU timber and strengthen the competitiveness of EU timber for European use and for export.  

The  warming  climate  in  Europe  will  shift  the  distribution  of  forest  species  and  this  will  have 
economic consequences. A study on the impact of future temperature increases on 32 tree species in 
Europe by 2100 found that the expected value of European forest land will reduce due to a predicted 
decline  in  economically  valuable  species126.  Depending  on  the  scenario  and  discount  rate,  this 

119 European Union 2021  
120 Eurostat 2022 
121 Forest Europe 2020 
122 European Union 2021  
123 European Union 2022 
124 Sincere Project 2022 
125 Mubareka, S., Jonsson, R., Rinaldi, F., Azevedo, J. C., de Rigo, D., Sikkema, R., 2016. Forest bio-based economy in 
Europe. In: San-Miguel-Ayanz, J., de Rigo, D., Caudullo, G., Houston Durrant, T., Mauri, A. (Eds.), European Atlas of 
Forest Tree Species. Publ. Off. EU, Luxembourg, pp. e01a52d+ 
126 Hanewinkel et al. 2013 

52 

 
 
 
indicated  a  28%  reduction  (with  a  range  of  14%  and  50%)  in  the  present  value  of  forest  land  in 
Europe, with a cost of several hundred billion Euros.  

In order to protect valuable forest land in the EU, the mandatory set of indicators monitored under 
Option 2, specifically on the impact of forest disturbances on forest resources, and the harmonisation 
of  the  reporting  system  will  facilitate  relevant  planning  by  the  private  and  public  sector  towards 
mitigating these impacts and financial losses as best as possible. This data can inform specific forest 
management practices from forest owners and ensure the decisions made are timely and effective.  

Where the monitoring and planning framework leads to the adoption of decisions that ensure a more 
sustainable and forward-looking management of forest resources, this could potentially ensure long-
term provision of forest resources in the future, and the ability of forest  resource to satisfying the 
many competing demands on both forest biomass (e.g. solid wood for construction, furniture and 
other wood and bio-based products, and for energy) and other ecosystem services (e.g. recreation), 
helping  to  safeguard  existing  and  create  new  jobs,  particularly  in  rural  or  remote  areas.  Thus, 
monitoring is needed to collect evidence on the adjusting policies and management decisions that 
support the sustainable provision of forest resources.  

7  HOW DO THE OPTIONS COMPARE? 

This chapter evaluates the policy options presented and analysed in Chapters 5 and 6 against a set of 
three key criteria: effectiveness, efficiency and coherence. Based on these criteria, the options are 
compared to the baseline scenario with “+++” meaning that objectives are fully met, “++” objectives 
are partly met and “+” slight improvement over baseline. For Option 3 rankings are expressed with 
two  scores  reflecting  the  different  levels  of  intervention  between  the  two  main  elements  of  the 
proposal (mandatory monitoring and voluntary planning). 

7.1  Effectiveness 

This  criterion  includes  contributions  to  the  specific  objectives  to  ensure  data  comparability  and 
indicator coverage of EU priority topics, quality and transparency of forest data and to establish a 
holistic forest governance planning framework.  

Option 1 
Voluntary 

Sub-option 2.1  
Legislative -
Medium 

Sub-option 2.2  
Legislative- 
High 

Option 3 

Hybrid 

+ 

+ 

+++ 

++ 

+++ 

+++ 

+++ 

+ 

Effectiveness 

Data comparability and 
quality 

Holistic forest governance 
planning framework 

Option 1 would be less effective than sub-option 2.1 and sub-option 2.2 and Option 3 for reaching 
the objectives related to monitoring. Without a legal framework establishing coherent objectives and 
standards, data comparability and quality will only improve slightly over the baseline.  

53 

 
 
 
 
 
 
 
 
Considering the marked differences among monitoring and planning systems, as well as the drivers 
behind  the  problems  identified  (costs,  historical  preferences,  scattered  responsibilities),  it  can  be 
expected that the timing and degree of using voluntary guidance to update or amend national systems 
for data collection, achieve harmonised international reporting or improve long-term planning would 
vary widely across Member States. Member States will to a certain extent continue to use a range of 
definitions, and different means to monitor, process and report on forest indicators, especially those 
not related to forest timber resources where some harmonisation efforts are expected to continue.  

Likewise, existing differences in the definition and use of the term “forest strategies” and the varying 
degree  of  including  forest  information  or  measures  under  required  planning  instruments  such  as 
NECPs and adaptation strategies will only be addressed partly.  

Data  and  information  access  continuing  through  various  channels  would  continue  to  hamper 
transparency. The role of EO would not change significantly without any obligation to use it where 
pertinent due to path dependencies despite its benefits. 

Sub-option 2.1 could score higher in terms of data quality than sub-option 2.2 or Option 3 in case 
Member  States  provide  LIDAR  data  via  the  opt-in  approach.  These  data  have  a  higher  spatial 
resolution than satellite-based data, which will be the basis for the EO-based products provided by 
the Commission. A similar level of data comparability as for sub-option 2.2 and Option 3 could be 
achieved for EO data in case of Member State’s ‘opt in’ under sub-option 2.1 if a proper calibration 
exercise  is  carried  out  and  quality  of  the  provided  data  is  assessed.  However,  data  comparability 
overall  will  be  slightly  higher  under  sub-option  2.2  and  Option  3  considering  higher  indicator 
coverage.  Overall  scoring  is  therefore  equal  for  both  sub-options  under  Option  2  and  Option  3 
(objective partly to fully met) in relation to the data criterion. 

Option  1  and  Option  3  score  the  lowest  in  ensuring  a  common  standard  for  long-term  planning 
bringing  only  slight  improvements  compared  to  the  baseline.  Under  a  voluntary  approach, 
predominantly Member States with already high ambition in terms of strategic planning would join; 
thus, the overall ambition in the EU would not be raised and the objective of a coherent governance 
framework would not be achieved. Establishing an obligation for long-term planning with common 
key elements, Option 2 will ensure integrated planning coverage on a comparable standard across 
Member States. Among the two sub-option 2.2 will be more effective (fully meeting the objectives) 
than  sub-option  2.1  (partly  achieving  the  objectives)  with  non-binding  recommendations  by  the 
Commission expected to support Member States in tackling possibly shortcomings in achieving an 
integrated approach in forest planning. 

7.2  Efficiency 

This  criterion  includes  contributions  to  economic  benefits,  reducing  administrative  burden  and 
improving regulatory compliance. 

54 

 
 
Option 1 
Voluntary 

Sub-option 2.1  
Legislative -
Medium 

Sub-option 2.2  

Option 3 

Legislative- High 

Hybrid 

Efficiency 

Economic cost and 
benefits 

Reducing 
administrative burden  

Improving regulatory 
compliance 

+ 

++ 

+ 

++ 

++ 

+++ 

++ 

+ 

+++ 

++ 

+ 

++ 

Under option 1 and for integrated planning under option 3, cost efficiency will improve slightly or 
partly compared to the baseline. Economic cost and benefits will not change significantly and will 
depend on Member States’ willingness to engage in voluntary coordination and align their systems 
to  Commission  guidelines  on  data  standardisation  and  integrated  planning.  As  a  result,  benefits 
derived by Member States might be slightly improved compared to the baseline from cost-efficient 
harmonisation of a limited number of indicators suited for national circumstances and policy needs, 
and from enhanced use of EO services offered by the Commission. Under sub-options 2.1 and 2.2, 
economic costs and benefits will be equally higher on average across their different elements – this 
means that with increasing costs associated with harmonisation and standardisation, their direct and 
indirect economic benefits are expected to rise proportionally too. This applies also to the monitoring 
part under option 3. Substantial one-off costs could occur under both sub-options and option 3 if a 
Member State had to set up a new data collection framework or adapt its current one significantly to 
meet common quality standards (e.g. in respect of frequency), but may be off-set through indirect 
benefits accrued on both the EU, national and forest level through improved policy- and decision-
making based on the better quality data. Both sub-options under option 2 and option 3 will require 
some investment costs by public administrations for data harmonisation or standardisation (both their 
development and application), slightly higher under sub-option 2.2 and option 3 because of the higher 
number of indicators. Mandatory planning under Option 2 will imply administrative burden for those 
Member States not yet implementing strategic planning but this may be off-set in the longer-run by 
reducing the need for ad-hoc responses due to unforeseen events.  

In addition to the indirect benefits for decision-making of acquiring more timely and geographically 
explicit data, EO related benefits relate to the cost reduction from reducing costs for ground-based 
data collection, mostly related to changes to tree cover extent and condition. These are slightly higher 
under sub-option 2.1 because the voluntary opt-in approach would allow Member States to choose 
the most cost-efficient link between their individual national system in place and the EU services 
while under sub-option 2.2 and option 3, Member States with an own EO system may risk some sunk 
costs through stranded investment, and therefore have lower overall benefits. 

Cost efficiency for integrated long-term planning will be higher under sub-option 2.2 and 2.1 and 
party met, compared to option 1 and option 3 which will result only in a slight improvement compared 
to the baseline. Benefits under sub-option 2.2 will derive from an increase in planning over time if 
recommendations  lead  to  a  gradual  improvement  throughout  the  iterations,  but  at  the  expense  of 
additional  administrative  burden  on  the  side  of  the  Commission  (for  review  and  issuing 
recommendations) and Member States (for revising the plans). 

55 

 
 
 
 
 
 
 
 
The Commission would incur limited additional running costs for FISE and more substantial running 
costs  related  to  developing  and  continually  updating  additional  EO-based  forest  data  products  as 
foreseen under option 2 and option 3, including a potential need for funding a sample plot network 
for collection of necessary ground data. On the other hand, the Commission would benefit also from 
cost savings on accessing and utilising higher quality forest data from common mandatory reporting 
done  by  Member  States  under  Option  2  and  Option  3,  resulting,  for  instance,  from  reduced 
administrative costs on data gap filling exercises currently undertaken by the JRC. Research funding 
would have to be spent on developing harmonisation methodologies where currently missing or new 
standards, where deemed necessary. The two options will also entail administrative costs in relation 
to data quality assurance and control.  

The expected benefit from reduced administrative burden by public authorities in Member States for 
option 1 and for planning under Option 3 will be inversely proportional to the level of engagement 
by Member States in voluntary coordination in a similar magnitude like either sub-option 2.1 or sub-
option 2.2. The burden related to drafting of guidance on data harmonisation and integrated planning 
is expected to be slightly lower under Option 1 and regarding planning under Option 3 than Option 
2, given the expected larger extent of indicators and planning elements covered under the legislative 
option.  

Sub-options  2.1  and  2.2  and  option  3  will  generate  administrative  costs  to  public  authorities  for 
ensuring the monitoring systems meet minimum standards in terms of frequency of data collection. 
Sub-options  2.1  and  2.2  are  also  linked  to  costs  associated  with  data  harmonisation  following  a 
common definition, or data collection according to common standards, and preparation of integrated 
long-term plans. The actual magnitude will depend on the individual starting point of the Member 
State and partly incur a one-time investment and thereafter limited running costs where continuous 
harmonisation of new datasets is needed, thus decreasing on the long-term.  

Facilitating a single-portal access to forest information both option 2.1 and option 2.2 and  option 3 
reduces  administrative  burden  for  National  authorities,  businesses,  and  citizens.  Considering  the 
lower number of indicators under sub-option 2.1 compared to 2.2., the latter scores somewhat higher 
in  efficiency  in  relation  to  administrative  burden  (objectives  partly  met  vs  slight  improvement 
compared to the baseline). 

Improvement of regulatory compliance requires common progress across all Member States. This 
will likely  not  be achieved with  option 1  resulting  only  in  a slight  improvement compared to  the 
baseline. A voluntary set-up will trigger different responses across Member States. The mandatory 
set of indicators and the standardisation of data collection and reporting in combination with long-
term planning under sub-option 2.1 and more so under sub-option 2.2 will strengthen evidence-based 
decision-making  on  forests  status  and  uses  and  support  better  control  of  illegal  activities.  The 
objective  will therefore  be fully met.  Under option 3 this will be achieved only  partly  due to  the 
incoherence in the level of intervention between the monitoring and the planning part. 

7.3  Coherence  

This initiative relates to several EU policy objectives, initiatives, and instruments. The evaluation of 
coherence looks at how consistent each option is with these, and it identifies the extent to which it 
promotes horizontal objectives and facilitates the delivery of relevant key targets. Since the hybrid 

56 

 
 
 
 
 
 
 
 
option  combines  different  levels  of  intervention  (obligatory  for  monitoring  and  voluntary  with 
planning), internal coherence is assessed in addition. 

Option 1 
Voluntary 

Sub-option 2.1  
Legislative -
Medium 

Sub-option 2.2 

Legislative- 
High 

Option 3 

Hybrid- 

Coherence 

Existing 
proposed 
legislation 

Existing 
proposed 
strategies 
policies 

Internal 
coherence 

+ 

and 
EU 

+ 

and 
EU 
and 

+++ 

+++ 

++ 

+++ 

++ 

++ 

++ 

+++ 

+++ 

+ 

7.3.1  Coherence with other policies 

The coherence with other policies will be the highest with objectives fully met for sub-options 2.2 
and the lowest for Option 1. Only slight improvements beyond baseline are expected since coherence 
will depend on Member States individual level of ambition. This will differ according to National 
priorities. For EU strategies and policies, it is expected that the coherence objective will be partly 
met with sub-option 2.1 and fully met with sub-option 2.2 with the wider indicator coverage beyond 
legal  obligations.    With  option  3  coherence  will  be  fully  met  for  monitoring  while  only  slight 
improvements can be expected for planning. Overall coherence objectives will therefore partly be 
met.  

Regarding coherence and synergies with other international frameworks, all options aim to minimize 
reporting burden by aligning, wherever possible, with internationally agreed reference definitions, 
specifically  FAO  FRA,  while  options  2  and  3  aim  to  limit  the  introduction  of  double  obligations 
where current international reporting is deemed sufficient (see Table 21). Harmonised EU reporting 
aligned with definitions and methods used for reporting to international frameworks like the FAO 
FRA or UNECE can ensure coherence of the internationally reported EU figures with the sum of 
national values127.  

A detailed evaluation is discussed according to individual legislation, strategies and policies in the 
following table. 

127 Vidal et al. 2016 

57 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
EU initiative 

Key considerations on policy coherence 

The EUFS is based on enhanced ambition, in line with the EGD, 
particularly on climate and biodiversity. A comprehensive set of 
harmonized/standardized indicators as in sub-option 2.2, with a strong EO 
component as in sub-options 2.1 or 2.2 and option 3 maximises the 
coherence with these targets. Concerning integrated long-term planning, 
coherence with the EUFS is the highest where Member States provide 
integrated comparable plans (sub-option 2.2) and the lowest for option 1 and 
3  
The BDS sets ambitious targets to halt biodiversity loss. It calls for strict 
protection of the remaining primary and old-growth forests, for which 
common indicators do not yet exist. Sub-option 2.2 and Option 3 on 
common indicators maximised the coherence with the policy objectives of 
the BDS. EO will be an important tool for biodiversity monitoring.  
Healthy forest, providing essential ecosystems, contribute to air and water 
quality and to nature protection. Sub-option 2.2 and Option 3 (for 
indicators) maximises the synergies with nature protection legislation and in 
particular the data provided by Member States under Article 17. The EU 
monitoring framework would allow to complement this information, for 
instance by making available spatially characterised data, allowing for the 
production of ecosystems maps. Concerning integrated long-term planning, 
coherence with the EUFS is the highest where Member States provide 
integrated comparable plans (sub-option 2.2). The voluntary approach under 
option 1 and Option 3 would not be coherent with the mandatory reporting 
requirements of the nature protection legislation.  
The monitoring of forest soil will be dealt with by the SHL proposal. In this 
sense, there is no overlap between the two proposals. However, since the 
SHL proposes mandatory monitoring of forest soil parameters, the 
consistency would be maximised by sub-options 2.1 and especially 2.2. and 
Option 3 

New EU Forest 
for 
Strategy 
2030 (EUFS) 

Biodiversity 
Strategy 
2030 (BDS)  

for 

Air, Water and 
Nature 
Directives 

on 
Health 
(SHL-  

Legislative 
initiative 
Soil 
Law 
adoption 
planned 
July 2023) 

for 

for 

Proposal 
Nature 
Restoration 
Law (NRL) 

The NRL proposal refers to six forest-related indicators that need to be 
monitored at least every three years and possibly every year. The coherence 
with this initiative is maximised by sub-options 2.1 and especially 2.2 and 
Option 3 (higher number of biodiversity indicators). The voluntary approach 
under option 1 would not be coherent with the mandatory reporting 
requirements of the NRL 

58 

 
 
As  the  voluntary  approach  under  option  1  would  not  be  coherent  with  the 
mandatory reporting requirements of the revised LULUCF and Governance 
Regulations,  options  2  and  3  would  ensure  that  such  requirements  are 
respected.  However,  both  sub-options,  2.1  and  2.2  and  option  3  would  go 
beyond LULUCF requirements. 

By  enabling  the  development  of  quality  forest  data,  option  2  and  option  3 
would  facilitate  the  achievement  of  the  policy  objectives  underlying  the 
proposal  for  the  certification  of  carbon  removals  under  the  EU-wide 
voluntary  framework,  which  would  not  be  supported  by  the  voluntary 
approach under option 1. 

Sub-option 2.2 and option 3 would also provide the greatest capacity to assess 
progress in climate adaptation at both Member State and EU level, as required 
under  Article  6  of  the  European  Climate  Law.  Option  2.1  would  be  less 
effective because it would omit some important indicators. 

Integrated planning with Commission recommendations as in sub-option 2.2 
is particularly important in relation to LULUCF which requires long-term 
planning of forest resources and this would not be ensured under option 1, 
sub-option 2.1 and option 3.  
The RED II Directive sets criteria for ensuring the sustainability of sourcing 
for the purpose of biomass use for energy. A set of additional common 
indicators (as in sub-option 2.2 and option 3) specifically on biodiversity is 
fully coherent with the objectives of RED, specifically the sustainability 
criteria of its Article 29 (6). The integrated long-term planning of forest 
resources will aim to ensure coherence of national bioenergy policies under 
the RED with other forest-related policy objectives on the EU and national 
level. 
The forest accounts module proposed by the Commission on 11.7.2022 to 
amend Reg. 691/2011 on European environmental economic accounts 
explicitly supports the EU forest strategy for 2030 and the future forest 
monitoring initiative and connects forest policies with policies on climate, 
energy and the bioeconomy. Coherence is maximised by sub-options 2.1 
and 2.2 as well as option 3.  

Forest monitoring can capitalise on the infrastructure and services in place 
provided by Copernicus in other areas. A strong EO component of forest 
monitoring as in sub-options 2.1, 2.2 and option 3 can positively contribute 
by providing specific needs not addressed with today’s Copernicus data, to 
be taken into account in Copernicus evolutions.  
FISE is the one-stop shop for forest-related data. An enhanced monitoring 
framework channelling data through FISE is fully coherent with the 
objectives of FISE. The more the common/harmonized/standardized 
indicators, the better the coherence with FISE.  
A coherent set of indicators on forest health and condition is in line with the 
objective of the new reg. of deforestation, in particular as regards the non-

EU climate 
policy 
(European 
Climate Law, 
LULUCF 
Regulation, 
Carbon 
Removal 
Certification 
Framework, 
EU 
Adaptation 
Strategy, 
Governance 
Regulation ) 

Renewable 
Energy 
Directive 
(RED) 

on 

Proposal 
amending 
European 
Environmental 
Economic 
Accounts 

Copernicus 
Programme 

FISE 

Deforestation 
Regulation 
proposal 
Observatory 

/EU 

59 

 
 
 
on 
deforestation 
and 
degradation 

forest 

Plant  Health 
Legislation  

Europe’s 
Digital Agenda 
drone 
and 
strategy 2.0  

Civil 

Union 
Protection 
Mechanism 
(UCPM) 

degradation objective. Coherence is maximised by sub-options 2.1, 2.2 and 
option 3.  

The initiative will also be fully consistent with the EU observatory, whose 
findings as regards EU forests will also be channelled to FISE. 

The Plant Health Legislation contains provisions for obligatory surveillance 
and reporting of outbreaks of Union quarantine pests. For certain types of 
pest attacks which manifest through defoliation or changes in crown 
condition, optical remote sensing with sufficiently high and spatial 
resolution would allow earlier detection within the outbreak cycle which 
may lead to reduced time lag in appropriate management decisions. Sub-
options 2.1 and especially 2.2 as well as Option 3 would maximise 
coherence 
The greater the use and uptake of digital services related to forest 
monitoring, the greater the synergy and coherence with the digitalisation 
agenda. The drone strategy 2.0 has as one of the objectives that by 2030 
drones and their required eco-system will have become an accepted part of 
the life of EU citizens. Air-transported LIDAR offers significant 
opportunities for developing the market and become a leader on forest 
monitoring applications.  
Under the UCPM, the Commission and the Member States are working 
towards achieving a higher level of protection against disasters, including 
wildfires. The EU response capacity to wildfires will continue to be 
strengthened. Prevention and preparedness efforts will be stepped up, and 
improved EU forest monitoring will greatly contribute to improved early 
warning tools for wildfires and other disasters, more accurate risk 
assessments, and overall improved preparedness capacity to deal with future 
disasters. Sub-options 2.1 and 2.2 as well as option 3 will contribute to 
achieving these objectives.  

7.3.2  Coherence between the two main elements of the different options 

Based on the assessment of the three previous criteria in sections 7.1-7.3 it can be assumed that the 
objective that this legislative initiative seeks to achieve, i.e. “A coherent governance framework for 
reporting and planning is established”, would be partly achieved with option 1 and fully with option 
2. The voluntary approach under option 1 risks that the level of ambition for monitoring and planning 
might not be equal in individual Member States generating mixed results regarding effectiveness and 
efficiency. This risk is much lower under option 2 setting a mandatory standard for both elements 
that Member States will have to comply with. 

With option 3, the initiative’s objective  would most likely not be fully achieved resulting only in 
slight improvements above the baseline. The monitoring obligations would produce a wide range of 
high-quality datapoints regarding forests for all Member States. However, data collection is not an 
end goal in itself, but will be key to benefit other policies and their implementation, not least carbon 
capture which will be important for the competitiveness of the sector. 

The long-term integrated planning would fall under those potential uses of the available data. Not 
using this data to the best extent possible would not reach the full potential of the legislative proposal. 

60 

 
 
 
In addition, it could undermine the assessed effectiveness of the monitoring, given that the actual use 
and benefit of the collected data would depend on individual Member State’s ambition on planning.  

Forest monitoring and integrated long-term planning are linked with monitoring crucial to ensure that 
forest planning is evidence-based and an integrated long-term planning in turn supports targeted and 
efficient monitoring. Forest monitoring and long-term planning therefore require the same level of a 
common approach. 

PREFERRED OPTION 

7.4  Choice of option 

The analysis carried out in chapter 6 shows that, even within the constraints due to lack of quantitative 
criteria for comparing costs and benefits, the benefits of a full legislative approach clearly outweigh 
those stemming from the voluntary and hybrid options.  

The  preferred  option  would  be  a  self-standing  instrument  that  informs  or  complements  existing 
policies  and  legal  frameworks  for  three  reasons.  First,  it  is  unlikely  that  the  required  extent  of 
coordination  could  be  achieved  through  individual  amendment  considering  the  sheer  number  of 
relevant  EU  instruments  (Figure  27  in  Annex  5),  their  varying  level  of  attention  and  obligation 
relevant for monitoring and planning and different competent authorities in the Member States. None 
of them covers the two specific objectives outlined in Chapter 4.2. Even if this could be achieved, 
the  result  would  still  be  a  fragmented,  non-coherent  monitoring  system.  Second,  comprehensive 
forest  monitoring  or  integrated  planning  are  presently  not  mandatory  under  any  EU  piece  of 
legislation  and  the  establishment  of  such  an  obligation  consistently  across  the  diversity  of  legal 
instruments outlined is unlikely. Third, establishing a common framework through a simple, single 
instrument  would  support  the  need  for  promoting  a  holistic  and  integrated  approach  to  forests, 
following the narrative of the new EU Forest Strategy for 2030.  

The OPC showed a high degree of support for EU-wide harmonized and timely information on a 
number of variables. More than 88% of respondents were in favour of indicators on issues like forest 
health, disturbances, and climate change and impacts and projections. The least popular indicators 
received support from about 40-50% of respondents with only around 20% being directly against.  

The preferred option would entail a combination of elements from both sub-options under option 2. 
The comparison of policy options in Chapter 7 has clearly shown the need for a binding instrument 
to meet the strategic objectives for data comparability, quality and availability. Therefore, mandatory 
monitoring and reporting of forest data based on common harmonised or standardised definitions and 
methods for a set  of  indicators was  identified as  the preferred  policy measure. To fully  cover the 
priority policy areas of forest health and resilience and biodiversity, a wider selection of indicators 
than those in current legislation and existing monitoring and reporting frameworks was found to be 
necessary.  Therefore, in relation to common indicator coverage, the preferred option is 2.2. 

A step-wise approach would be applied for selecting the mandatory indicators and parameters – a 
limited list would be first selected for inclusion in the legislative proposal of the basic act. This list 
of indicators and parameters was identified considering all of the following aspects: their relevance 
to the priority policy objectives, the need for higher spatial or temporal resolution compared to the 
existing monitoring and reporting, availability of common definitions and methods, availability of 
Earth-observation based tools and methods for their monitoring, and current status of monitoring and 
reporting in the Member States.   

61 

 
 
The  identified  indicators  and  parameters  that  have  not  been  selected  in  the  first  step  (i.e.  in  the 
legislative  proposal)  would  be  considered  for  inclusion  at  a  later  stage  through  implementing 
legislation,  based  on  the  assessed  priority  and  methodological  needs  and  taking  into  accounts 
recommendations by a dedicated expert group.  

The collected and reported data would be made available through FISE, as an existing ‘one stop-
shop’ platform, which will increase transparency and easy access to cross-sectoral information. This 
is key to building an integrated understanding on forests, their status and ecosystem services.  

Recognizing the diversity in relation to the use of EO across Member States, a mandatory use of EO 
where suitable with an opt-in option for Member States will strike a balance between ensuring high 
quality data, while reducing costs and leaving room for manoeuvre for Member States. Development 
costs would be borne by the Commission in a two-step approach by maximising available EO funds 
under the current MFF, supplemented by channelling available funding earmarked for biodiversity 
in  the  different  financial  instruments.  The  ambition  will  be  to  ensure  coverage  of  all  pertinent 
indicators with an (close to) agreed methodology for data collection. In a second step, the Copernicus 
budget would have to be adapted under the future MFF in parallel to establishing harmonised and 
standardised data collection methods for those EO-based indicators currently missing. 

More than 60% of respondents in the OPC agree that data from Member States’ monitoring systems 
should be better integrated, and more than half of respondents think that the EU should operate a 
single  monitoring  system.  These  averages  cover  a  preference  for  continuing  current  monitoring 
systems among companies and businesses, while environmental organisations tend to be against a 
business-as-usual  option.  Respondents  representing  Member  State  public  authorities  expressed 
moderate support in favour of integration, though not necessarily for a single EU monitoring system. 
An opt-in approach represents a balance between the views expressed by stakeholders. See Section 
3 of Annex 2 for more detailed information on the responses to the OPC.  

As explained in  section  2.1, a large majority (84%)  of respondents  highlighted the importance of 
more consistent, comparable and timely forest information. This statement is also valid when looking 
at  stakeholder  groups  separately,  e.g.  73%  of  respondents  from  the  stakeholder  group  ‘business 
associations’ and 92% of academics indicated consistent, comparable and timely forest information 
as important  or very important.  This  Impact  Assessment  has  shown that  a  legislative  approach is 
more likely to bring about such data. 

Therefore, in relation to monitoring, the preferred option is 2.1. 

Mandatory  long-term  plans  following  a  common  set  of  basic  requirements  and  core  elements  in 
combination with the Commission issuing non-binding recommendations on their development will 
allow Member States context-specific priority setting, targets and measures while ensuring integrated 
alignment with EU policies on forest conservation and uses. 

Only 14 % of the OPC respondents did not  identify an added value of strategic plans for forests. 
Across all stakeholder groups a holistic view on forest status and trends (55%) as well as allowing 
for overall  coordination  of long-term forest  planning  (53%) were mentioned most often as  added 
value. NGO’s (30%) were the stakeholder group with the highest share of respondents not agreeing 
on an EU added value.  

Therefore, in relation to integrated long-term planning, the preferred option is 2.2. 

62 

 
 
In addition, the preferred option includes the use of the expert group set-up in the framework of the 
new EU Forest Governance, for both coordination and guidance as well to support the Commission 
in developing common definitions and protocols for indicators and data collection and non-binding 
recommendations on long-term plans. This reflects the shared competence on forest matters and the 
need for close cooperation between the Commission and the EU Member States. 

Table 28 in Annex 5.4 provides an overview of the core elements of the preferred option in relation 
to problems, drivers and specific objectives. 

Funding  is  considered  as  possible  add-on  to  the  preferred  option.  Next  to  providing  Copernicus 
services free of charge, targeted funding could complement the preferred policy option to support the 
costs  for  system  alignments.  Under  the  current  MFF,  30%  of  EU  budget  has  been  earmarked  for 
climate and environmental actions (with specific targets for biodiversity, at least 7,5% for 2024 and 
10%  for  2026).  The  Commission  could  provide  guidance  and  encourage  Member  States  to  use 
respective funding in the mid-term review of relevant funds during the current financial period and 
further earmark relevant funds under the next financial period. In addition, opportunities under EU 
R&I framework programme, such as the upcoming partnership “Forests and forestry for a sustainable 
future”, will further contribute to the development of improved, consistent and up-to-date forest data 
in Member States. 

Furthermore, international engagement should continue as part of the preferred option. One of the 
aims with this initiative is to build on and maximise synergies with existing international engagement 
and also provide a structured way of contributing to international efforts therefore contributing to the 
EU’s ambition as a leader in the world. 

7.5  Proportionality 

The combination  of elements  selected in  the  preferred option is  proportionate insofar it is  clearly 
limited to those aspects that Member States cannot achieve satisfactorily on their own, and where 
harmonisation at Union level is needed. Because the scale of the issue at stake and its crossborder 
dimensions, the EU is the only body that may ensure a consistent monitoring framework bringing 
together  the  Member  States.  As  highlighted  in  chapter  3,  common  standards  for  data  collection, 
monitoring and long-term integrated planning cannot be developed at a Member State level. 

No option would involve transferring powers from Member States to the EU beyond the necessary 
monitoring harmonisation (no transfer of powers on the management of forests).  

7.6  Legal instrument 

The principle of proportionality requires that the choice of instrument is as simple as possible and 
coherent with a satisfactory achievement of the objectives and with effective enforcement. 

The choice of a regulation would fit the subject matter of this initiative and its level of precision and 
would allow to overcome the problems described in this impact assessment report more effectively 
than a directive, as it would allow to set common standards that are binding and directly applicable 
across  all  Member  States  without  the  administrative  burden  of  and  the  delay  for  transposing  the 
instrument  into  national  law,  contributing  to  the  achievement  of  the  objectives  of  better  forest 
protection and integrated planning by the Member States. Furthermore, it would set the basis for the 
adoption  of  implementing  legislation  with  support  of  the  expert  group  for  the  development  and 

63 

 
 
 
specification  of  technical  requirements,  for  example  as  regards  indicator  harmonisation  and 
standardisation. 

7.7  Simplification and improved efficiency 

Whilst the preferred option, which would be 2.2 for common indicator coverage, 2.1 for monitoring, 
and 2.2 for integrated long-term planning, will not require any changes to existing legislation, it will, 
nevertheless, lead to cost savings or improved compliance in a number of those listed in Figure 27 in 
Annex 5 and important indirect benefits, ultimately outweighing its costs. 

Detailed  costs  and  benefits  of  the  different  elements  of  the  initiative,  i.e.  data  harmonization  and 
standardization, the development of enhanced EO for forest management, as well as integrated long-
term planning, are discussed in Annex 3. Those include direct administrative and adjustment costs, 
one-off and recurring, assessed for national authorities, EU institutions and other stakeholders. Direct 
and indirect benefits of the initiative are also detailed. 

8  HOW WILL ACTUAL IMPACTS BE MONITORED AND EVALUATED? 

A plan based on a set of milestones will be designed by the Commission to track the implementation 
of the actions required to achieve the specific objectives against a specific timeframe (e.g. adoption 
of technical implementation measures on data collection harmonisation and standardisation and on 
governance framework).  

In addition, the Commission will monitor the roll out and impacts of the measures on a regular basis 
(biannual) based on the following elements: 

•  Number of indicators with a common definition 

•  Number of indicators with harmonised or standardised data collection methods 

•  Data provision by Member States to FISE 

•  Data access via FISE (average clicks/month) 

•  National  adaptation  strategies  and  risk-assessment  and  risk-management  strategies  relying  on 

common indicators 

•  Evolution of forest digital services market (in particular, number of SMEs) 

•  Evolution of number of forest-related certification schemes 

•  Number of long-term integrated plans adopted by Member States 

•  Level of alignment of integrated long-term plans with common set of basic requirements and core 

elements 

•  Use of EU funds in support of monitoring actions  

In addition, the Commission will launch an evaluation based on the abovementioned elements, taking 
into account the Member States’ reports on the integrated long-term plans, which would be presented 
to Council and Parliament within three years of entry into force of the legal instrument. 

64 

 
 
65 

 
 
 
 
 
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(EU) 2015/652 and repealing Regulation (EU) No 525/2013 of the European Parliament and of the Council (Text 
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Communication  from  the  Commission  to  the  European  Parliament,  the  Council,  the  European  Economic  and  Social 
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our lives. COM(2020)380 final. 

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(2019/2157(INI)) OJ C 395, p. 37–49. 

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Conclusions (10 November 2020) 12695/1/20.  

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Climate Law’) [2021] OJ L243/1. 

Regulation  (EU)  2021/2116  of  the  European  Parliament  and  of  the  Council  of  2  December  2021  on  the  financing, 
management  and  monitoring  of  the  common  agricultural  policy  and  repealing  Regulation  (EU)  No  1306/2013 
[2021] OJ L 35/187. 

Proposal for a Regulation of the European Parliament and of the Council amending Regulations (EU) 2018/841 as regards 
the scope, simplifying the compliance rules, setting out the targets of the Member States for 2030 and committing 
to the collective achievement of climate neutrality by 2035 in the land use, forestry and agriculture sector, and (EU) 
2018/1999  as  regards  improvement  in  monitoring,  reporting,  tracking  of  progress  and  review.  COM(2021)554 
final. 

Communication  from  the  Commission  to  the  European  Parliament,  the  Council,  the  European  Economic  And  Social 
Committee and the Committee of the Regions [2021] Forging a climate-resilient Europe - the new EU Strategy on 
Adaptation to Climate Change. COM(2021)82 final. 

Communication  from  the  Commission  to  the  European  Parliament,  the  Council,  the  European  Economic  and  Social 
Committee  and  the  Committee  of  the  Regions  [2021]  Better  regulation:  Joining  forces  to  make  better  laws. 
COM(2021)219 final.  

Communication  from  the  Commission  to  the  European  Parliament,  the  Council,  the  European  Economic  And  Social 

Committee and the Committee of the Regions [2021) ‘New EU Forest Strategy for 2030’. COM(2021)572 final. 

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COM(2021)800 final. 

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from the Commission to the European Parliament and the  Council Sustainable Carbon Cycles’. SWD(2021)450 
final. 

Commission Notice — Technical guidance on the climate proofing of infrastructure in the period 2021-2027 [2021] OJ 

C/373/1. 

Proposal for a Regulation of the European Parliament and of the Council on nature restoration. COM(2022)304 final. 

Proposal for a Regulation of the European Parliament and of the Council amending Regulation (EU) No 691/2011 as 

regards introducing new environmental economic accounts modules. COM(2022)329 final. 

Proposal for a Regulation of the European Parliament and of the Council establishing a Union certification framework 

for carbon removals. COM(2022)672 final 

Communication  from  the  Commission  to  the  European  Parliament  and  the  Council  [2022]  2022  Strategic  Foresight 

Report Twinning the green and digital transitions in the new geopolitical context. COM(2022)289 final. 

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ANNEX 1: PROCEDURAL INFORMATION 

Lead DG, Decide Planning/CWP references 

Lead DG 

Decide Reference 

CWP Reference 

Planned Adoption 
by Commission 

Directorate General 
for Environment 
DG ENV 

Directorate General 
for Climate Action 
DG CLIMA 

PLAN/2022/205 

Legislative proposal 
for an EU 
Framework for 
Forest Monitoring 
and Strategic Plans 

Organisation and timing 

n/a 

Q2 2022 

−  The  initiative  has  been  first  announced  in  the  New  EU  Forest  Strategy  for  2030  that  the 

Commission adopted in June 2021128 

−  The call for evidence was open for consultation between 08 April 2022 and 06 May 2022. 117 

replies were received. 

−  The public consultation was open between 25 August 2022 and 17 November 2022. 311 replies 

were received. 

−  The Inter-Service Steering Group (ISG) was consulted in written on the consultation strategy in 
March 2022 and the draft Impact Assessment Report in December 2022-January 2023 and during 
meetings of the group on 22 March 2022, 09 December 2022 and 10 January 2023. It was co-
chaired  by  ENV  and  CLIMA,  and  the  other  DGs  participating  were  AGRI,  CLIMA,  DEFIS, 
ECHO,  ENER,  EUSTAT,  GROW,  JRC,  REGIO,  RTD,  SG,  SJ,  TRADE  and  CINEA.  The 
minutes were shared with the members of the ISG and all comments received taken into account. 

Consultation of the Regulatory Scrutiny Board (RSB) 

−  ENV and CLIMA outlined the rationale, scope and draft policy options for the initiative to the 
Regulatory  Scrutiny  Board  at  the  upstream  meeting  on  12  September  2022.  Following  the 
meeting, ENV and CLIMA redefined the scope of the initiative, the problem description and the 
policy options. The evidence-base was  strengthened  reflecting the diversity of EU forests and 
existing standards and systems in Member States and careful attention given to policy coherence.  
−  The draft of the Impact Assessment was submitted to the Regulatory Scrutiny Board on the 18th 

January 2023. 

−  On 18th February 2023, the RSB issued a positive opinion subject to amendments of the Impact 
Assessment.  In the Table below, the comments  and the subsequent changes responding to the 
comments are shown.  

128 COM(2021)572 final 

72 

 
 
 
 
 
COMMENTS RSB  

The report is not clear about the gaps to be 
filled and the added value of EU action, in 
particular regarding long-term forest 
planning. It is also not clear on the  proposed 
level of EU intervention  on  long-
term  forest  planning of the Member States.  

The report does not present all key policy 
options, including “hybrid” options.  

HOW THE IMPACT ASSESSMENT 
HAS RESPONDED   
See key observations 2 and 3 below.    
A more detailed analysis of the existing 
monitoring systems in the Member States 
has been added in Annex 5.2 and in section 
2.  Comparative tables have been added on 
the availability of plot-level and tree-level 
information, on definitions used for 
monitoring and on integration of Earth 
Observation in monitoring systems.  Further 
information has been added on data 
collection frequency and accessibility.  The 
necessity for EU action (section 3) has also 
been revised with further examples and 
literature references.  
A hybrid option combining mandatory 
monitoring elements and optional integrated 
forest planning has been developed and 
assessed.  

The option entails obligatory reporting for a 
set of indicators and parameters related to 
EU legislation and policy objectives beyond 
existing EU/international requirements with 
data harmonisation for existing indicators 
and standardisation for the new indicators. 
The Commission will develop and operate 
EO-based forest monitoring, complementary 
to in-situ data collection, and provide these 
data and indicators to Member States for 
their reporting.   

Voluntary integrated long-term planning 
would be supported by an expert group for 
coordination and exchange. Following 
consultation with this expert group, the 
Commission would issue voluntary guidance 
to facilitate the drafting of evidence-based 
integrated forest planning for example by 
offering a common set of basic requirements 
and core elements for consideration by 
Member States.   

As the hybrid option combines elements 
from other options (monitoring from the 
legal option and planning from the voluntary 
option) it is assessed according to its two 
building blocks together with these other 

73 

 
 
    
  
  
  
  
  
1  

2  

The report should be clear about the 
intervention logic. As regards monitoring, 
the report should clarify whether its main 
goal is to provide Member States with 
support in using Earth Observation 
technology. The report should also clarify 
how the envisaged monitoring measures will 
allow Member States to integrate them in 
their current monitoring and reporting.  

The report should clearly analyse and discuss 
the proposed additional obligations for 
Member States regarding long-term planning 
and explain why, and to what extent, a 
governance framework for long-term 
planning is considered necessary to support 
the monitoring framework, and why it is 
needed at EU level.  

options. Combining different levels of 
intervention internal coherence is assessed in 
addition.  
Chapters 2 to 4 have been amended to 
further clarify the need for intervention 
(problems and drivers) and the objectives. 
Detailed additional information on the 
current monitoring systems in the Member 
States  and their specificities has been 
included in Annex 5.2, showing in particular 
the patchy and non-harmonized monitoring. 
This information is also summarized in 
Chapter 2.1 of the main report. A description 
of how the new measures will link to 
existing monitoring frameworks in Member 
States and how the Commission will support 
Member States has been included in Chapter 
5.2.2, while the link to existing international 
reporting obligation was strengthened in 
7.3.1  
Section 3.2 on the need for EU action has 
been revised by underlining that although 
Member States have planning instruments in 
place, the lack of harmonized 
information  covered by such plans and of a 
coordinated governance system affects their 
comparability, temporal homogeneity and 
ultimately policy-making at national and EU 
level. Subsidiarity would be ensured as 
Member States with established and well-
working planning frameworks would be able 
to continue their instruments, but the added 
value of EU coordination and governance 
would be to ensure that plans across the EU 
have a similar structure for better delivery on 
forest-related policies. Further, section 5.2.2 
now spells out more clearly the added value 
of a governance framework to achieve 
coherence between national and EU policies 
and enable dialogue between the 
Commission and Member States.   
This information is supplemented by further 
and revised information on potential 
obligations and costs in section 6.3.1.3 and 
new table 6 that reflects the variety of 
scenarios in terms of planning and related 
costs across Member States.  

74 

 
 
  
As regards monitoring, sections 2 and 3 and 
Annex 5.2 have been integrated in order to 
further clarify the harmonization needs.   
As regards planning, section 2 has been 
integrated by more clearly highlighting the 
gaps that are currently present across 
existing planning instruments. In particular 
with regard to policy fragmentation, the 
report now presents the result of an 
assessment performed on Member States’ 
tools along the key thematic areas of forest 
resource status and trends, biodiversity, 
bioeconomy, ecosystem services and climate 
change.  
Annex 5 has been further completed with a 
table showing which forest planning tools 
are used at present, indicating the 
heterogeneity of their scope, time reporting, 
the type of EU action required on them and 
MS coverage, to support the problem 
definition as described in revised section 2.   
The report highlights across the problem 
definition and description of policy options 
the need for integrated and harmonised 
monitoring and planning frameworks to 
deliver on policy objectives and targets, such 
as under LULUCF and Habitats Directive. 
Furthermore, section 5.2.2 has been revised 
in order to specify that recommendations 
will be used only where this is relevant for 
the alignment of Member States plans with 
specific policy goals, objectives and targets 
and will not require Member States to 
provide the reasons of not addressing the 
recommendations, thus respecting the 
subsidiarity and proportionality principles.  
Stakeholder and Member State views on the 
distribution of competence has been included 
in section 3.2 building on the feedback 
received on related questions in the open 
public consultation and as expressed by 
Member States in relation to the initiative at 
the AGRI FISH Council.   
See key observation 2.  

3  

4  

Considering the heterogeneity of forest 
across Member States as well as the 
monitoring and planning already in place, the 
report should better justify the EU added 
value of the initiative. It should present clear 
evidence that Member States cannot solve 
the identified problems on their own. In 
particular, it should justify why long-term 
integrated planning cannot be developed at 
Member State level, what the gaps identified 
in current existing planning activities by 
Member States are, and what the 
implications would be for national and local 
authorities and for forest owners.  

The report should set out clearly the division 
of competences between Member States and 
the EU level and discuss how this initiative 
will respect these boundaries. As regards the 
proposed recommendations the Commission 
would give on the national plans, the report 
should demonstrate current deficiencies in 
terms of Member States’ capacity to comply 
with EU policies and targets which would 
necessitate not only a common framework 
but also the use of recommendations. It 
should indicate clearly how this would 
respect both subsidiarity and proportionality. 
Stakeholder and Member State views on the 
distribution of competences should be 
presented.  

5   Options should be constructed to highlight 
the specific issues on which policy choices 
are to be made, as regards both monitoring 
and planning. The report should treat the 
“hybrid” option (obligatory monitoring and 
voluntary planning) as a genuine policy 

75 

 
 
6  

7  

option, assess and compare it along with the 
other options proposed.   
Provide clear evidence on the need for 
harmonization.  

The report should present the distributional 
impacts across the Member States, given that 
some Member States are more advanced than 
others. Clarify the additional resources and 
capacities that the different Member States 
would need to mobilise for the 
implementation of this initiative.  

Additional information was provided on the 
disparity of data collection and definition 
used in Annex 3 and 5.2. Further 
consequences of inadequate data 
harmonization were explained in the 
problem definition part of Section 2.1.1. and 
in Section 3.2 explaining the added value of 
EU action.    
The Impact Assessment now includes Table 
6 which provides an assessment of the 
distributional impacts of the proposal on 
Member States, grouped into three categories 
based on their current forest monitoring 
capabilities.  

8  

The comparison of options, which is mainly 
qualitative, should explain the scoring 
methodology used.  

Additional information and a finer level of 
detail was provided on the types of costs in 
Section 6.   
The scoring methodology has been outlined 
in chapter 7 and consistent use of the 
terminology used ensured throughout the 
chapter. A set of three key criteria 
(effectiveness, efficiency and coherence) has 
been used for the comparison. Based on 
these criteria, the options are compared to 
the baseline scenario with “+++” meaning 
that objectives are fully met, “++” objectives 
are partly met and “+” slight improvement 
over baseline.    

Evidence, sources and quality 

This impact assessment was carried out with the support of a 10-month service contract signed in 
June 2022. The consortium providing the service consisted of Rambøll Management Consulting A/S 
(lead), the European Forest Institute (EFI) and the Italian Academy of Forest Sciences (IAFS).  

The service contract consisted of 6 main tasks:  

•  Task 1: Definition of problems, drivers, objectives, and development of policy options 
•  Task 2: Assessment of the impacts of policy options and comparison of options  
•  Task 3: Analysis of existing background material and assessment of current forest monitoring 

frameworks in the EU 

•  Task 4: Analysis of existing background material and assessment of Strategic Plans for Forests 
•  Task 5: Organisation of workshops, assistance in meetings and stakeholder consultation analysis  
•  Task 6: Ad-hoc work 

76 

 
 
  
 
 
ANNEX 2: STAKEHOLDER CONSULTATION  

1. Introduction  

The Commission carried out broad consultation activities on the legislative initiative. Consultations 
started with a Call for Evidence between 08 April 2022 and 06 May 2020 and was followed by an 
Open Public Consultation between 25 August 2022 and 17 November 2022. 

In addition to the Call for Evidence and Open Public Consultation, a series of four thematic expert 
workshops were also organised in the course of October to November 2022, a dedicated sub-group 
under the Standing Forest Committee facilitated technical exchange with the Member States through 
two meetings during November and December 2022, and finally, a thematic workshop was organised 
by  the  CZ  PRES  in  which  the  Commission  actively  engaged.  A  summary  of  the  discussions  and 
feedback received is provided in the next sections. 

2. Feedback to the Call for Evidence 

2.1 Overview of replies 

In total there were 116 responses submitted, across 21 countries and 9 stakeholder types.  

Figure 3 : Proportion of responses per stakeholder category and geographic distribution 

STAKEHOLDER CATEGORY & COUNTRY OF 
ORIGIN

Academic/research institution
Business association
Environmental Organisation
Company/Business organisation
EU citizen
NGO (Non-governmental organisation)
Public authority
Trade union
Other

77 

 
 
 
 
 
The analysis showed a small cluster of three responses where coordination between the respondents 
was likely. As the number of coordinated responses was low (2.6% of total), they did not have a 
substantial effect on the overall results. Therefore, they were included in the analysis. 

2.2 Overview of results 

The responses to the call for evidence generally regarded either: (1) the scope of the initiative, (2) 
data collection content and methodology, (3) monitoring and reporting of data, (4) resource allocation 
and use, and (5) legislation.  

Considering all submissions, the overall support rate for the initiative of an EU Framework on Forest 
Monitoring  and  Strategic  Plans  was  76%.  Academic  research  institutions,  environmental 
organisations, and trade unions were all 100% in favour of the establishment of such a framework, 
closely  followed  by  business  associations  (92%),  NGOs  (90%),  company/business  organisations 
(89%), others  (86%),  and public authorities (80%). EU citizens were the only  set  of stakeholders 
where  a  majority  were  not  in  favour  of  the  framework,  with  only  43%  in  support.  The  primary 
concern expressed is that increased centralisation by this initiative would lead to unnecessary burdens 
for  existing  national  forest  monitoring,  and  that new  legislation  may  disrupt  current  management 
practices in use by forest owners. 

2.3 Scope 

The  most  prevalent  sub-topic  addressed  regarding  the  scope  of  the  initiative  was  the  demand  for 
consistent and comparable definitions, indicators, and measures of forest status across all Member 
States. This includes harmonised definitions of ‘forests’ and sustainability, among others, developed 
in  cooperation  with  ones  already  set  out  and  in  use  by  current  monitoring  programs  from  Forest 
Europe  and  the  FAO,  for  example.  NGOs  specifically  raised  this  issue  the  most  often,  closely 
followed by public authorities. The latter was the group most in favour of setting a strong basis for 
the initiative by clarifying the need for the framework itself and by identifying the current gaps in 
forest monitoring and data sharing, thus identifying the long-term goals of the legislation. 

Figure 4: Sub-themes on the scope of the initiative 

Socio-economic factors

2

1

1

1

Protection of biodiversity

4

Harmonised definitions,
indicators & measures

2

1

1

3

3

3

2

4

2

Explicitly mention climate
effects & indicators

2

1

1

2

1

4

2

7

5

2

Clarify purpose & gaps

2

4

7

1

3

0

5

10

15

Academic/research institution
Environmental Organisation
EU citizen
Public authority
Other

…

Business association
Company/Business organisation
NGO (Non-governmental organisation)
Trade union

20
25
No. of mentions

78 

 
 
 
Stakeholders specifically mentioned the need to clarify the added value of strategic plans prior to 
taking any further actions. Other common requests from stakeholders in establishing the scope of the 
initiative  were  to  explicitly  mention  the  monitoring  of  climate  effects  and  mitigation  potential  of 
forests  through  the  use  of  holistic  indicators,  e.g.,  old-growth  forests;  to  consider  biodiversity 
conservation  through  special  management  on  Natura  2000  sites;  and  to  take  into  account 
socioeconomic  factors  and  the  contribution  of  forests  to  the  EU  economy  through  wood-based 
products and renewable energy.  

2.4 Data collection methods 

A large proportion of each of the academic/research institutions, business associations, NGOs, and 
public authorities commented on the importance of the use of complementary data sources, namely 
remote sensing or EO, in combination with ground observation and the utilisation of ENFIN129. They 
noted that once sound statistical principles are used in combination, this allows for cross-referencing 
and will result in improved data quality and overall harmonisation. In contrast, a key issue raised is 
the danger of relying on remote sensing alone, which is not feasible, as many indicators and measures 
cannot  be  assessed  without  in-situ,  ground-based  monitoring.  Similarly,  without  consistent  and 
uniformly high-quality resolution across the technologies used to collect data in different Member 
States, stakeholders are concerned that data collection might be ineffective or inaccurate. However, 
remote sensing was praised for its ability to rapidly monitor catastrophic events, such as forest fires. 
It was also mentioned that in a transboundary capacity where the event may be multi-jurisdictional, 
the  ability  to  cooperate  on  early  warning  systems  will  be  vital  with  the  increasing  frequency  of 
extreme weather events due to climate change.  

Figure 5: Sub-themes on the data collection methods 

Data quality & harmonisation

3

1

1

1

1

Data privacy

1

1

1

1

1

Remote sensing: lacks accuracy?

1

1

1

2

3

Harmonisation of overlapping
data sources

Open-access & transparent data

Can't rely on remote sensing alone

5

4

2

3

6

5

1

2

2

2

4

1

3

7

1

1

2

2

2

1

1

Unified data collection
framework/reporting format

1

2

1

9

0

5

10

Academic/research institution
Business association
Environmental Organisation
Company/Business organisation

3

4

15

20

25

30
No. of mentions

129 ENFIN is the European-wide network which aims to promote NFIs (National Forest Inventories), harmonise forest 
information, and support forest policy. 

79 

 
 
 
 
50% of NGOs explicitly mentioned the need for a unified data collection framework and reporting 
format which can be easily compared across Member States, which was once again echoed by public 
authorities. Some specified that the framework for reporting should be open for public submissions 
and  that  the  data  should  subsequently  be  analysed  by  professionals  or  experts  in  the  field. 
Environmental organisations, EU citizens, and NGOs emphasised that the data within the framework 
should  be  open-access,  easily  and  freely  available,  user-friendly,  and  transparent  in  line  with  the 
principles of the Aarhus Convention.130 Academic/research institutions were the primary advocates 
for  the  quality  control  of  data  and  harmonisation  in  its  formatting.  Similarly,  several  different 
stakeholder groups raised concerns over data privacy and how GDPR will be addressed in an EU-
wide data sharing network. EU citizens specifically argued the right to not allow shared access to 
information on privately owned forested land, while a public authority linked the matter to that of 
protecting national security and the principles of subsidiarity when considering the use of satellite 
imagery. 

2.5 Monitoring and reporting 

All stakeholder groups, except for EU citizens, expressed the importance of building the EU-wide 
forest monitoring network based on existing national forest inventory data, e.g., ICP Forests, NFIs. 
This  would reduce the risk of wasting resources  and unnecessarily duplicating data. Stakeholders 
who were generally not in favour of the initiative questioned the added value of a new framework 
compared  to  these  existing  reporting  systems,  and  as  mentioned  previously,  they  requested 
clarification of what  the current  shortcomings are that need to  be addressed when creating a new 
framework. Several stakeholders suggested that the EU should focus on capacity building in Member 
States before implementing a novel system. 

Figure 6: Sub-themes on monitoring and reporting 

Role of widespread/long-term
observational networks

4

3

1

2

Build on existing national
forest inventory data

8

6

2

4

2

7

1

5

Differentiate by ecosystem type

2

1

5

0

10
Academic/research institution
Business association
Environmental Organisation
Company/Business organisation
EU citizen

15

20

25

30

35

40
No. of mentions

Several  academic/research  institutes  and  company/business  organisations  highlighted  the  need  to 
further emphasize the value and role of having a widespread and long-term network of observational 

130 The Aarhus Convention (signed in 1998) gives a number of rights to the public regarding the environment including 
access to environmental information, public participation in environmental decision-making, and access to justice. 

80 

 
 
 
 
 
sites and ESFRI131 infrastructures, for example, cross-country NFI harmonisation and J1, and EU-
wide satellite imagery from Copernicus-Sentinel1. Additionally, these networks can be supplemented 
with the help of commercial EO, according to a company/business organisation. 

2.6 Resource use 

A  variety  of  stakeholder  types,  but  mainly  business  organisations,  highlighted  the  importance  of 
ensuring a long-term source of funding to support Member States to create a stable framework for 
forest  monitoring  and  reporting.  This  would  involve  access  to  additional  monetary  resources  for 
countries with currently inadequate national frameworks. It was suggested by a public authority that 
the implementation of any new data collection systems should be progressive depending on Member 
State  resources.  This  would  allow  a  greater  consideration  for  delays  in  data  collection  or 
discrepancies in data quality due to the varying technical equipment used for data collection from 
national to local levels and between countries. 

Unnecessary costs for
well monitored countries

2

1

2

3

1

Long-term access to
resources

2

5

1

2

1

1

1

0

2

4

6

8

10

12

14

Academic/research institution

Business association

No. of mentions

Environmental Organisation

Company/Business organisation

EU citizen

Public authority

Other

Figure 7 sub themes on resource use 

NGO (Non-governmental organisation)

Trade union

In contrast to this issue, many stakeholders, mostly public authorities, followed by academic/research 
institutes  and  NGOs,  raised  the  issue  of  potential  costly  overlaps  for  some  Member  States.  As 
previously  recognised,  some  Member  States  have  well  established  NFIs  and  national  monitoring 
frameworks. Stakeholders were not in favour of an initiative which will create superfluous monetary 
burdens for countries which are already successfully monitoring and reporting in the forestry sector. 
Proportionality  was  identified  by  respondents  as  important  in  this  context  when  ensuring  no 
redundant or parallel inventory systems are being created.  

2.7 Legislation 

131 The ESFRI (European Strategy Forum on Research Infrastructures) supports Environmental Research Infrastructures 
catering to scientific communities and the environmental monitoring activities of European agencies, e.g. ESFRI project 
‘eLTER RI’ handles a range of ecological challenges based on observations. 

81 

 
 
 
  
 
A  large  number  of  stakeholders,  particularly  business  associations  and  public  authorities,  drew 
attention to the absence of an EU common forest policy. They outlined how new EU legislation must 
be incorporated into long-term national-level scenarios, rather than via a top-down approach. Many 
expressed that strategic forest planning should be addressed at the national level, in line with the EU 
subsidiarity principle. Subsidiarity was explicitly mentioned by mostly business associations, public 
authorities, and other stakeholders where many agreed that EU level  initiatives should aim at  the 
tactical or strategic level and not at the operational or stand level. To this end, stakeholders requested 
that  the  initiative  should  include  a  “proposal  and  legal  bases  allowing  for  the  control  of  the  data 
provided at national level”. The EU would continue to support them in their NFIs while giving control 
to managers and national authorities, respecting the concept of forestry as a national competence. For 
the stakeholders who encouraged the harmonisation of EU-wide reporting, they maintained that it 
shouldn’t affect national reporting. 

Figure 8: Sub-themes on legislation 

Identification of specific
objectives for policy making

2

1

1

Principle of subsidiarity

Forestry is not EU common
policy

Cooperation with national
forestry authorities

EU should  aim at tactical/
strategic level

Proposal/legal bases for
data…

2

1

1

1

1

3

1

2

2

3

1

1

4

1

1

2

2

3

2

1

4

6

1

4

5

1

1

2

1

3

2

1

3

1

2

0

5

10

15

20

Academic/research institution
Environmental Organisation
EU citizen
Public authority
Other

Business association
Company/Business organisation
NGO (Non-governmental organisation)
Trade union

No. of mentions

Similar to the call for reduced financial burdens on Member States, stakeholders would equally like 
to minimise any administrative burdens by ensuring the EU closely cooperates with national forestry 
authorities and build capacity for their autonomous forest management. 

A variety of stakeholders, including NGOs and public authorities, considered the identification of 
specific objectives for policy making as a key factor of the new legislation. They proposed to monitor 
the effectiveness of policy interventions by integrating specific indicators, e.g., for nature restoration. 
They outline how the policy goals of the initiative should be linked to the indicators to be clarified  

3 Feedback to the OPC 

The objective of the OPC was to collect inputs from all relevant stakeholders on the most effective 
ways  to  assess  and  monitor  the  state  of  European  forests  and  to  develop  strategic  plans  for  their 
development. The questionnaire included 14 mandatory questions in the “About you” section and 20 
substantive  questions  across  four  main  blocks  of  the  survey:  Use  of  forest  information,  Need  for 
forest information, Strategic plans for forests, and Forest indicators.  

82 

 
 
  
 
3.1 Respondents 

The OPC survey received 315 contributions in total. The survey data was cleaned and processed and 
only  one  contribution  was  identified  as  a  duplicate  and  therefore  deleted.  The  resulting  314 
contributions came from respondents in 29 countries. The greatest number of responses came from 
Germany (80), a result likely tied to an identified campaign consisting of 23 contributions of almost 
identical sets of answers and almost identical comments to the open-text comments. As the share of 
these  responses  is  very  small  (7%),  and  following  the  Better  Regulation  Guidelines,  these 
contributions  were  not  deleted.  Instead,  the  analysis  below  takes  into  account  this  campaign  and 
presents the PC results with and without these contributions. Table 9 below shows the full distribution 
of country of origin for all respondents. 

Table 9: Country of Origin 

Country of origin 

Count  Share  Country of origin 

Count  Share 

Austria 

Belarus 

9 

1 

2.90% 

Ireland 

0.30% 

Italy 

Belgium 

21 

6.70% 

Latvia 

Bulgaria 

Croatia 

Cyprus 

Czechia 

Denmark 

Finland 

1 

2 

1 

3 

2 

9 

0.30% 

Lithuania 

0.60%  Netherlands 

0.30%  Norway 

1.00% 

Poland 

0.60% 

Portugal 

2.90%  Romania 

France 

29 

9.20% 

Slovakia 

1 

14 

1 

1 

7 

1 

29 

5 

11 

37 

0.30% 

4.50% 

0.30% 

0.30% 

2.20% 

0.30% 

9.20% 

1.60% 

3.50% 

11.80% 

France  Overseas  
Territories 

2 

0.60% 

Spain 

15 

4.80% 

Germany 

80 

25.50%  Sweden 

13 

4.10% 

Greece 

Hungary 

2 

9 

0.60%  United Kingdom 

2.90%  United States 

6 

2 

1.90% 

0.60% 

Total 

314 

100% 

Of the 314 respondents, 51 are providers of forest data, 85 are forest owners (29 of them own forests 
of less than 5 hectares, 56 of them own forests of more than 5 hectares), whilst the remaining 178 
respondents are neither forest owners nor forest data providers. 

83 

 
 
 
 
 
 
Figure  9  below  shows  that  distribution  of  stakeholder  types;  EU  citizens,  non-governmental 
organisations and companies/business organisations are the three most represented categories. 

Figure 9: Stakeholder types (N=314)  

1

24

26

23

22

57

34

12

115

Academic/research institution

Business association

Company/business organisation

Environmental organisation

EU citizen

Other

Trade union

Non-governmental organisation (NGO)

Public authority

3.2 Use of forest information 

The first set of questions asked stakeholders about the sources of information they consult and for 
what  purposes  and/or  sectors.  PC  respondents  consult  forest  information  most  often  regarding 
forestry  and  wood  production  (almost  70%  of  respondents),  biodiversity  (58%  of  respondents), 
climate  adaptation  (57%  of  respondents)  and  climate  mitigation  purposes  (almost  53%  of 
respondents).  They  consult  forest  information  the  least  for  information  on  air  quality  (13%  of 
respondents). See Figure 10. 

Figure 10: Sector(s) and purpose(s) for which respondents consult forest information 

84 

 
 
 
 
 
 Air quality

24

41

 Hydrology (e.g. water quality or quantity)

 Soil science (quality, erosion, nutrients)

 Other bioeconomy sectors

 Education

 Climate adaptation

Forestry and wood production

75
80
85
88
90
91

97

105

166

179
183

219

Note: Question asked: For which sector(s) or purpose(s) do you consult forest information? Respondents could select more than one option. 

0

50

100

150

200

250

Government publications and websites are the most often consulted sources by respondents (72% of 
respondents),  followed  by  forest  sector  organisation  and  media  (66%  of  respondents),  and 
publications by academics, such as research centres, universities and research projects (almost 66% 
of respondents). Private data providers, such as companies, business associations and individuals are 
the least consulted (34% of respondents). 

3.3 Need for forest information 

The second set of questions asked stakeholders about the need for forest monitoring – information 
needs,  challenges  to  data  collection  and  use,  preferred  use  of  monitoring  technologies,  preferred 
policy options on forest monitoring systems and financing options for such systems. 

More than 92% of respondents agree or somewhat agree that there is need for EU-wide harmonised 
and timely information on forest health, forest disturbances (e.g., pests, wildfires), climate change 
impacts on forests, and climate change projections for forests. And more than 80% of respondents 
agree or somewhat agree that there is need for EU-wide harmonised and timely information on forest 
biodiversity, wood production and forest carbon stocks and flows. See Figure 11. 

The majority of both forest owners and providers of forest data agree or somewhat agree that there 
is need for harmonised data on forest health, forest disturbances, climate change impacts on forests, 
climate  change  projections  for  forests.  Only  about  half  of  forest  owners,  however,  agree  that 
harmonised information is needed on forest biodiversity, wood production, forest carbon stocks and 
floes,  other  forest  ecosystem  services,  forest  management,  and  non-wood  products  and  services, 
including recreation. Between 80-100% of forest data providers agree that such data is needed. 

85 

 
 
 
Figure 11: Forest information needs (N=314)  

…non-wood products and services, including recreation

…forest management

…other forest ecosystem services

…forest biodiversity

…forest carbon stocks and flows

…wood production

…climate change projections for forests

…climate change impacts on forests

…forest health

…forest disturbances (e.g. pests, wildfires)

Agree

Somewhat agree

Somewhat disagree

Disagree

No opinion

Blank

0% 10% 20% 30% 40% 50% 60% 70% 80% 90% 100%

Note: Question asked: To what extend do you agree with the following statement: We need EU-wide harmonised and timely information on… 

In terms of the needed improvements to forest monitoring in the EU, 86% of respondents find more 
consistent and comparable forest information across borders to be very important or important. This 
aspect was consider highly relevant among all stakeholder groups, e.g. 73% of respondents from the 
stakeholder group ‘business associations’ and 92% of ‘academics’ indicated consistent, comparable 
and timely forest information as important or very important. More than 66% of respondents find 
better thematic data on forests (e.g., more thematic data layers, less generalisation), better and easier 
access  to  forest  information  (e.g.,  data  portals,  search  functions,  APIs,  one-stop  shop)  and  more 
accurate and trustworthy forest information (e.g., through the use of modern technology, common 
definitions and increased transparency) to be very important or important improvements (See Figure 
12).  

Some  respondents  used  the  open-ended  comments  to  point  out  that  the  frequency  of  monitoring 
entirely depends on the type of data that is being monitored. E.g., whilst yearly reports are sufficient 
for  most  data,  respondents  suggest  that  forest  disturbances  need  a  near-real  time  reporting.  In 
addition, several respondents strengthen the fact that any EU effort to increase monitoring should 
build up on existing monitoring mechanisms, and that it should bear clear links with existing EU 
instruments. 

86 

 
 
 
Figure 12: Possible improvements to forest monitoring in the EU (N=314)  

Higher granularity of forest information, e.g. land parcel
level, grid-cell, resolution

More frequent forest information, e.g. monthly or yearly
instead of multi-annual data

More timely forest information, e.g. data will be
available days after data collection instead of months…

Better thematic data on forests e.g. more thematic data
layers, less generalisation

More accurate and trustworthy forest information, e.g.,
through the use of modern technology, common…

Better and easier access to forest information, e.g., data
portals, search functions, APIs, one-stop shop

More consistent and comparable forest information
across borders

Very important

Important

Somewhat important

Not important

No opinion

Blank

0% 10% 20% 30% 40% 50% 60% 70% 80% 90% 100%

Note: Question asked: Please indicate how important you consider the following possible improvements to forest monitoring in the EU. 

Respondents were asked to rank the main current challenges to ensuring EU-wide forest information 
that is detailed, accurate, regular, timely, comparable and openly accessible. PC respondents ranked 
data availability as the key challenge, followed closely by the limited comparability of data due to 
lack  of  standardised  national  forest  inventories.  Insufficient  uptake  of  information  derived  from 
remote sensing was ranked last among the provided options. See Figure 13 below. Under “Other”, 
respondents  suggested  a  series  of  challenges  that  currently  impair  detailed  and  accurate  EU-wide 
forest information. The most popular answers include the lack of clear attributions of responsibility 
between  the  EU  and  Member  States  for  collecting  information,  the  absence  of  pan-European 
definitions, the difference between indicators used, the lack of harmonized methods for collecting 
data by Member States and the need to link monitoring with existing EU legal instruments. Some 
respondents also highlighted the need to clarify, at the outset, the purpose of data collection and what 
sort of data should be gathered and monitored. 

87 

 
 
 
Figure 13: Main current challenges to EU-wide forest information  

Note: Question asked: In your view, what are the main current challenges to ensuring EU-wide forest information that is detailed, accurate, regular, 
timely, comparable and openly accessible? Respondents were asked to rank the six options. The results were calculated by assigning six points to 
each respondent’s first choice, five points to their second option, etc. The figure shows the total sum of points the option has received. 

When asked about the need for better open access to forest information, 68% of respondents agreed, 
particularly among environmental organisations, academic/research institutions and EU citizens. 

Respondents were asked a series of questions about their preferences on monitoring technologies. 
Almost  all respondents  (92%)  agree or somewhat  agree that monitoring systems  should integrate 
both field data and remote sensing, with academic/research institutions, environmental organisations, 
public authorities and trade unions completely in favour (100% of respondents for all four categories). 
See  Figure  14.  Among  those  who  ticked  the  “Other”  option,  the  large  majority  believe  that  field 
observations  still  represent  the  most  appropriate  method  to  collect  forest  data.  Some  respondents 
suggest  a  combination  of  field  observations  and  remote  sensing,  however  no  respondents  deem 
remote-sensing  to  be  sufficient  in  itself.  In  addition,  some  respondents  would  like  to  see  a  better 
inclusion of new technologies such as AI in data collection techniques. They also sustain that while 
new technologies may not be cost-efficient at first, they would prove highly beneficial in the long-
run. 

88 

 
 
 
Figure 14: Monitoring technologies (N=314)  

Where applicable, monitoring systems should mainly
build on remote-sensing technologies

Monitoring systems should mainly build on field
observations

Monitoring systems should make use of the most cost-
efficient technologies

Monitoring systems should integrate both field data
and remote-sensing

Agree

Somewhat agree

Somewhat disagree

Disagree

No opinion

Blank

0% 10% 20% 30% 40% 50% 60% 70% 80% 90% 100%

Note: Question: To what extent do you agree with the following statements? 

More than 60% of respondents agree that data from Member States’ monitoring system should be 
better integrated - split by stakeholder groups, 73% of all respondents from academia and 75% from 
public  authorities  agree  or  somewhat  agree.    However,  this  percentage  is  smaller  for  business 
associations  with  only  36%.  Half  of  all  respondents  (51%)  agree  that  data  from  Member  States’ 
monitoring systems should be better integrated, but with little change to monitoring methods. The 
highest support for a single monitoring system is shown by EU citizens with 69% and environmental 
organisations with 67%  agreeing or somewhat agreeing. Conversely, 56% of all respondents from 
the stakeholder group ‘companies’ disagree or somewhat disagree. More than half of respondents 
think that the EU should operate a single monitoring system. Finally, 40% of respondents agree that 
Member  States  should  continue  current  monitoring  systems  (business-as-usual).  Business 
associations  and  company/business  organisations  show  a  preference  for  business-as-usual,  while 
environmental organisations tend to be against it. 

89 

 
 
 
Figure 15: Policy options: Monitoring (N=314) 

Member States should continue current
monitoring systems (business-as-usual)

Data from Member States’ monitoring 
systems should be better integrated, but 
with little change to monitoring methods

The EU should operate a single monitoring
system

Data from Member States’ monitoring 
systems should be better integrated

Agree

Somewhat agree

Somewhat disagree

Disagree

No opinion

Blank

0%

20%

40%

60%

80%

100%

Note: Question: To what extent do you agree with the following policy options? 

Respondents were asked to rank the main benefits of creating an EU-wide forest monitoring system 
with detailed, accurate, regular, timely, comparable and openly accessible information. The highest 
rank benefit is Better scientific knowledge, followed by Better preparedness to prevent and respond 
to natural disturbances. 

90 

 
 
 
 
Figure 16: Main benefits from creating an EU-wide forest monitoring system with detailed, accurate, regular timely, comparable and 

openly accessible information  

2028

1991

1919

1801

1789

1768

1415

1389

1337

788

2000

1500

1000

500

0

Note: Question: What are the main benefits from creating an EU-wide forest monitoring system with detailed, accurate, regular, timely, comparable 
and openly accessible information? Respondents were asked to rank the ten options. The results were calculated by assigning ten points to each 
respondent’s first choice, nine points to their second option, etc. The figure shows the total sum of points the option has received. 

The survey asked stakeholders about the financing policy options they prefer. 68% of respondents 
believe that financing should be provided through a combination of Member States, private and EU 
resources, with more than 84% respondents from academic/research institutions and environmental 
organisations in favour of this policy option. See Figure 17.  

Figure 17: Policy options: Financing (N=314)  

Financing should be provided only through resources
from relevant private sectors

Financing should be provided only through Member 
States’ resources

Financing should be provided only through existing EU
financial programmes, e.g., Copernicus, Horizon Europe

Financing should be provided through a combination of
Member State, private and EU resources

Agree

Somewhat agree

Somewhat disagree

Disagree

No opinion

Blank

0% 10% 20% 30% 40% 50% 60% 70% 80% 90% 100%

91 

 
 
 
 
3.4 Strategic plans for forests  

In  terms  of  level  of  awareness  and  usage  of  different  strategies  and  planning  tools,  71%  of 
respondents know and use national or regional forest programs. These programs are mostly used by 
providers of forest data (81% of respondents for this category). At the other end of the spectrum, 27% 
of respondents know and use National Bioeconomy Action Plans. 

Figure 18: Awareness of strategies and planning tools (N=314)  

Other key document

National Bioeconomy Action Plans

Prioritised Action Frameworks

Disaster-risk reduction strategies/documents

National reports to Forest Europe

National Forestry Accounting Plans

National Forest Risk Assessment Plans

National Ecosystem Assessments

Strategic Plans for the Common Agriculture Policy

Long-term Strategies for the climate

National or regional Climate Adaptation Strategies

National Energy and Climate Plans

National Biodiversity Strategies

Management plans of Natura 2000 sites

National/regional forest management plans

National or regional forest programs, plans or strategies

I use them or work with them

I know them

I have heard of them

I don’t know them

Blank

0% 10% 20% 30% 40% 50% 60% 70% 80% 90% 100%

Note: Question: How well do you know the following strategies and planning tools? 

Respondents  were  asked  to  select  among  different  options  of  what  could  be  the  added  value  of 
Strategic Plans for Forests. Providing a holistic view on forest status and trends, Overall coordination 
of  long-term  forest  planning,  and  comparability  and  exchange  with  other  Member  States  are  the 
added values selected by the greatest number of PC respondents. Better policy design was selected 
by the fewest number of respondents. See Figure 19. 

92 

 
 
 
 
Figure 19: Added value of Strategic Plans for Forests 

 None

5

 Other

24

 Better policy design

 Better policy coherence

 Better management of forest use and future forest…

Better disaster assessment and preparedness

 Comparability and exchange with other Member States

 Overall coordination of long-term forest planning

 Providing a holistic view on forest status and trends

103

121

136

142

156

160

167

Note: Question: In your view, what could be the added value of Strategic Plans for Forests? Respondents could select more than one option. 

0

50

100

150

200

In terms of the issues that respondents think the Strategic Plans for Forests should cover, there is 
relatively  high  agreement  that  all  of  the  five  presented  issues  should  be  covered  (see  Figure  20). 
Generally speaking, providers of forest data tend to be positive towards covering each issue, while 
forest owners tend to represent the lowest share of agreement. Public authorities partly underlined 
National competence on forest planning and questioned the added value of including planning in the 
legislative proposal. 

Figure 20: Issues to be covered by Strategic Plans for Forests (N=314)  

Policy monitoring

Policy integration and consistency

Changes in forest management

Policy planning

Forest disturbance/disaster prevention and
preparedness

0% 10% 20% 30% 40% 50% 60% 70% 80% 90% 100%

Agree

Somewhat agree

Somewhat disagree

Disagree

No opinion

Blank

Note: Question: Do you agree that Strategic Plans for forest should tackle/cover the following issues? 

3.5 Forest indicators 

The last section of the PC survey asked respondents a series of questions on forest indicators.  

93 

 
 
 
 
In terms of relevant forest indicators, 86% of respondents find pest and disease outbreaks (number, 
area and volume affected, type of pest diseases etc.) to be an important forest indicator to monitor. 
More than 77% of respondents believe that forest/tree cover, tree species/composition, forest fires 
(number, area and volume burnt, etc.), are three important forest indicators that should be monitored.  

Forest  biomass,  storms  (number,  area  and  volume  affected,  etc.),  forest/tree  cover  change  (gains, 
losses) and forest growth are considered to be important forest indicators to monitor by more than 
73% of respondents.  

More  than  67%  of  respondents  deem  tree  age,  forest  soil  properties  (carbon,  compaction,  soil 
biodiversity),  presence  of  red-listed  species,  tree  age  diversity,  main  management  objectives 
(production, conservation, protection), forest type, forest structural diversity, diversity and share of 
forest habitats, volume of wood harvested, ratio of annual fellings to annual increment, employment 
in the forest sector, forest carbon (as far as possible separated among carbon pools) to be important 
forest indicators to monitor.  

foliage,  deadwood 

forest 
Forest 
connectivity/fragmentation, silvicultural system, areas of primary and old-growth forests and forest 
areas covered by a management plan are deemed to be relevant forest indicators to monitor by more 
than 61% of respondents.  

type,  diversity),  other 

forest  disturbances, 

(volume, 

More than 56% of respondents believe that abundance of common forest birds, forest ancientness 
(length of time without land-use change), forest revenues (timber and non-timber) and price of wood 
and wood products should be monitored.  

More than 49% of respondents identify canopy height and forest areas with independent certification 
to be important forest indicators to monitor.  

Finally, more than 44% of respondents believe that frequency of forest visits, together with other 
general indicators specified by respondents, should be monitored (Figure 21). Providers of forest data 
broadly  follow  the  general  pattern  described  above.  Forest  owners,  on  the  other  hand,  find  most 
indicators  much  less  important  than  the  average  respondent.  An  exception  are  the  following 
indicators,  which  forest  owners  find  important  to  monitor  to  similar  extent  as  the  average 
respondents: Forest fires, Storms, Pests and disease outbreaks, Employment in the forest sector, and 
Frequency of forest visits. 

94 

 
 
Figure 21: Important indicators to monitor (N=314)  

Frequency of forest visits

Canopy height

Forest areas with independent certification

Price of wood and wood products

Forest revenues (timber and non-timber)

Forest ancientness (length of time without land-use…

Abundance of common forest birds

Other forest disturbances

Forest foliage/phenology/anomalies

Deadwood (volume, type, diversity)

Silvicultural system

Areas of primary and old-growth forests

Forest connectivity/fragmentation

Forest areas covered by a management plan

Presence of red-listed species

Employment in the forest sector

Main management objectives (production,…

Tree age

Volume of wood harvested

Forest type

Diversity and share of forest habitats

Forest structural diversity

Forest soil properties (carbon, compaction, soil…

Ratio of annual fellings to annual increment

Tree age diversity

Forest carbon (as far as possible separated among…

Forest biomass

Storms (number, area and volume affected, etc.)

Forest/tree cover change (gains, losses)

Forest growth

Tree species diversity

Tree health

Tree species/composition

Forest/tree cover

Forest fires (number, area and volume burnt, etc.)

Pest and disease outbreaks (number, area and volume…

Very important

Important

Somewhat important

Not important

No opinion

Blank

0% 10% 20% 30% 40% 50% 60% 70% 80% 90% 100%

Note: Question: In your view, how important is it to monitor the following forest indicators? 

Respondents were also asked to rate the monitoring of a series of forest indicators (e.g., forest/tree 
cover,  forest  biomass,  tree  age,  etc.)  in  their  country.  More  than  half  of  the  respondents  find  the 
monitoring  of  the  following  indicators  to  be  excellent  or  good:  Tree  species/composition;  Forest 
growth; Forest type; Volume of wood harvested; and Forest/tree cover. At the opposite end of the 

95 

 
 
 
spectrum, the monitoring of the following forest indicators is rated the worst: Frequency of forest 
visits; Forest disturbances; Storms (number, area and volume affected, etc.); Forest soil properties 
(carbon,  compaction,  soil  biodiversity);  Forest  carbon;  Forest  foliage/phenology/anomalies;  and 
Forest revenues (timber and non-timber). See Figure 22 for details. 

Figure 22: Quality of monitoring of forest indicators (N=314)  

Frequency of forest visits
Other forest disturbances

Forest ancientness (length of time without land-use…
Storms (number, area and volume affected, etc.)

Forest soil properties (carbon, compaction, soil…

Areas of primary and old-growth forests

Forest carbon (as far as possible separated among…

Forest revenues (timber and non-timber)
Forest foliage/phenology/anomalies
Canopy height
Abundance of common forest birds
Presence of red-listed species
Forest connectivity/fragmentation
Silvicultural system
Deadwood (volume, type, diversity)
Forest areas covered by a management plan
Diversity and share of forest habitats
Forest structural diversity
Employment in the forest sector
Price of wood and wood products
Forest areas with independent certification

Pest and disease outbreaks (number, area and volume…
Main management objectives (production,…

Tree health
Forest biomass
Tree age diversity
Ratio of annual fellings to annual increment
Tree age
Forest fires (number, area and volume burnt, etc.)
Forest/tree cover change (gains, losses)
Tree species diversity
Volume of wood harvested
Forest growth
Tree species/composition
Forest type
Forest/tree cover

0% 10% 20% 30% 40% 50% 60% 70% 80% 90% 100%

Excellent

Good

Fair

Deficient

No opinion

Blank

Note: Question: How would you rate the monitoring of the following forest indicator currently monitored in the chosen country? 

When asked about the technical challenges to delivering an improved forest monitoring in the EU in 
terms of ground or in situ data, more than 67% of respondents identify data access, data availability 
and collection frequency as either a major or minor challenge. While providers of forest data present 
the highest share of agreement with  the abovementioned three  challenges (approximately 80% of 

96 

 
 
 
respondents agree with these challenges), forest owners have a lower share of agreement (54%). More 
than 56% of respondents consider ground or in situ data sampling design and spatial sampling density 
to constitute challenges for improved EU forest monitoring, with providers of forest data presenting 
the highest share of agreement with  these challenges (approximately 63% of respondents  for this 
category), and forest owners presenting the same share of agreement with both challenges (44% for 
forest owners with less than five hectares of forest, and 50% for forest owners with more than five 
hectares of forest). See Figure 23. 

Figure 23: Technical challenges for ground or in situ data  

...sampling design

...spatial sampling density

... access

...availability

...collection frequency

0%

10%

20%

30%

40%

50%

60%

70%

80%

90%

100%

Major challenge

Minor challenge

Not a challenge

No opinion

Blank

Note: Question: What do you see as technical challenges for an improved forest monitoring in the EU? Ground or in situ data…  

As for remote-sensing data, almost 60% of respondents identify data integration with ground or in 
situ  data  as  a  major  or  minor  technical  challenge  for  an  improved  EU  forest  monitoring,  with 
providers  of  forest  data  presenting  the  highest  share  of  agreement  (84%  of  respondents  for  this 
category). More than 60% of respondents believe that remote-sensing data access, availability and 
comprehensiveness are either a major or minor technical challenges, with forest owners of less than 
five  hectares  of  forest  presenting  the  highest  share  of  agreement  (56%  of  respondents  agree  with 
these challenges). Finally, more than 56% of respondents agree that remote-sensing data collection 
frequency and spatial resolution represent technical challenges for EU improved forest monitoring, 
with providers of forest data presenting the highest share of agreement with these challenges (62% 
of respondents for this category), and forest owners with less than five hectares of forest presenting 
the  lowest  share  of  agreement  with  these  challenges  (approximately  38%  of  respondents  for  this 
category). See Figure 24. 

97 

 
 
 
Figure 24: Technical challenges for remote sensing data  

...collection frequency

...spatial resolution

...access

...comprehensiveness

...availability

...integration with ground or in situ data

0%

10% 20% 30% 40% 50% 60% 70% 80% 90% 100%

Major challenge

Minor challenge

Not a challenge

No opinion

Blank

Note: Question: What do you see as technical challenges for an improved forest monitoring in the EU? Remote-sensing data… 

4. Feedback from thematic expert workshop organised by the Commission 

The  Commission  organised  three  workshops  in  order  to  facilitate  discussions  among  experts  and 
receive detailed input on different topics. These inputs were taken into account in the drafting of this 
Impact Assessment. 

The first workshop, labelled “Strategic plans for forests”, took place on 24 October 2022. Discussions 
revolved around the different administrative levels and spatial scales at which forest planning take 
place,  the  types  of  monitoring  provisions  needed  in  strategic  frameworks,  as  well  as  specific 
particularities for small-scale forest owners. 

The second workshop, labelled “Present and future possibilities of Earth Observation for operational 
forest  monitoring”,  took  place  on  25  October  2022.  Discussions  revolved  around  the  appropriate 
scales  of  spatial  resolution  and  in  time,  the  merits  of  using  EO  for  collecting  data  on  different 
indicators, existing EO-based monitoring of forests in the EU and beyond, as well as the role of in-
situ data in an EO-based monitoring system. 

The third workshop, labelled “Benefits and costs of forest monitoring”, took place on 30 November 
2022. During the workshop, expert participants discussed and identified main benefits and costs of a 
number of elements: more harmonised forest monitoring, strategic planning, a greater role of remote 
sensing in forest monitoring, as well as environmental, social and macro-economic benefits. 

5. Discussions in the SFC sub-group  

Four meetings of the Standing Forestry Committee’s sub-working group on Forest Monitoring and 
Strategic plans took place on 10 November and 20 December 2022, and 30 January and 26 May 2023 
respectively.  The meetings were opportunities for Member States to  exchange views on, e.g., the 
discussions taken place in the expert workshops (see above), a preliminary list of forest indicators, 
the OPC results and the added value of long-term integrated planning at EU level. These inputs were 
taken into account in the drafting of this Impact Assessment. 

98 

 
 
 
6.1 Recommendations from CZ PRES workshop 

The CZ presidency of the Council hosted a workshop on 14-16 September 2022 in Kutná Hora, Czech 
Republic,  named  “Towards  harmonised  Forest  Observation,  Reporting  and  Data  Collection 
Framework – are we there yet?” in which the Commission actively engaged. The workshop covered 
discussions on technical aspects as well as governance of EU a forest monitoring system and was 
structured around presentations from Commission services and panel discussions. 

Participants of the workshop: 

1. stressed the importance of reliable, verified harmonized or standardized and up-to-date information 
and communication on the state and development of EU forests, inter-alia for informed both policy- 
and decision-making at the EU level;  

2.  reiterated  the  irreplaceable  role  of  field-collected  data  for  ensuring  reliability,  accuracy  and 
comprehensiveness of derived information;  

3. acknowledged fast development of new and innovative technologies in data acquisition, especially 
in the area of remote sensing, as well as in their processing;  

4.  stressed  the  importance  of  combining  remote  sensing  and  field-collected  data  for  improving 
information on forests, and the need for mutual and timely exchange of both kinds of data;  

5. acknowledged the importance of international processes steered by e.g. FAO, UNECE and Forest 
Europe for further development of existing sets of forest-related indicators;  

6. stressed the importance of relevant tools to communicate information on forests, such as FISE, 
FRA platform and INForest;  

7. welcomed the results of previous efforts on harmonization and evaluation carried out by ENFIN , 
ICP Forests, the scientific community, and others;  

8. noted that different types of information on forests serve different purposes, and therefore has to 
be communicated clearly to safeguard the credibility and coherence of forest information systems;  

9. noted the joint efforts towards a harmonized Forest Observation, Reporting and Data Collection 
framework (Framework);  

10. emphasized the role of national and international experts in the interpretation and validation of 
the results of the Framework.  

The participants encouraged the European Commission and other relevant decision-makers to: 

11. further clarify objectives of the future Framework including forest strategic planning as well as 
interlinkages with EU policies and legislation;  

12. prepare together with the Member States and in consultation with relevant stakeholders the list 
of indicators to be covered by the Framework based on clear principles, taking into account existing 
data sources, reporting demands and the cost-effectiveness of the whole process notably within the 
proposal impact assessment;  

13. build on the available knowledge and create further synergies in collecting forest-related data and 
indicators;  

99 

 
 
14. promote further harmonization or standardization of forest-related information;  

15.  support  further  development  of  widely  available  tools  for  estimating  the  above-mentioned 
indicators  (see  paragraph  12)  based  on  synergistic  use  of  existing  field  data,  remote  sensing  data 
relying on an unbiased statistically rigorous inference; in these efforts to respect the legal limitations 
and ensure the integrity of the national monitoring systems;  

16. work together with the Member States to ensure the consistency of forest-related information at 
national and EU levels to safeguard its credibility. 

They also encouraged Member States to:  

17.  support  further  development  and  implementation  of  spatially  and  temporally  harmonized  or 
standardized  national  forest  inventory  and  monitoring  methods,  designs  and  analytical  tools 
combining ground based and remotely sensed data;  

18. participate actively in the development of the Framework, including sharing of national expertise 
on combining field data and remote sensing.  

6.2 Summary from SE PRES workshop 

The SE presidency of the Council hosted a workshop on 1-2 February 2023, Uppsala, Sweden, named 
“Towards harmonised forest monitoring and reporting for the EU” in which the Commission actively 
engaged. The meeting built on the outcomes of the workshop held by the CZ Presidency (see 6.1). 
The  workshop  focused  on  three  areas:  (i)  users,  areas  of  uses,  and  ways  of  presenting  forest 
information,  (ii)  components  and  governance  of  a  forest  information  system  for  the  EU,  and  (iii) 
relevant monitoring methods.  

The main observations from the workshop are as follows:  

•  Several  areas  of  uses  and  users  of  forest  information  at  EU  level  derive  directly  from  existing 
legislation (e.g., the LULUCF regulations and the Habitats Directive).  

• Information should be tailored for specific users and areas of uses. A main objective would be to 
guide EU-level policy implementation and development, but EU level forest information could also 
serve other stakeholders and actor needs.  

• New EU legislation and several EU strategies could benefit from a common core set of indicators. 
Further analysis is needed to specify these indicators and their definitions. Coordination with Forest 
Europe, FAO/FRA, ENFIN and ICP Forests, as well as Eurostat, EEA, CBD, and UNFCCC would 
secure consistency with existing definitions and other established, international processes.  

• Coherent information between EU and Member State levels is important to avoid confusion, when 
information on the same features originate from different sources.  

• A stepwise approach could be recommended for building a forest information system for the EU, 
where  the  vast  amounts  of  data  and  information  available  from  existing  national  and  multilateral 
programmes would be the foundation. Cost-efficiency is important to take into account, as well as 
financing.  

100 

 
 
• Increased harmonisation of results from existing inventories could be needed. Efforts to standardise 
core parts of forest inventories between Member States could possibly be considered in the long-term 
perspective.  

• Building trust is imperative - through openness, transparency, and data availability for research. 
Strict procedures for quality assurance and quality control should be adopted in all parts of a future 
EU forest information system, e.g. through local level validation. 

101 

 
 
 
 
ANNEX 3: WHO IS AFFECTED AND HOW? 

Practical implications of the initiative 

This section reports potential costs and benefits from this initiative for the most pertinent actors: EU 
institutions, National authorities and other stakeholders, notably businesses including forest owners. 

Table 10: Summary of benefits 

I. Overview of Benefits – Preferred Option 

Harmonisat
ion/ 
standardisa
of 
tion 
forest 
monitoring 

Forest 
monitoring 
systems 
including 
enhanced 
remote 
sensing 

Direct benefits 

European institutions 

•  Cost savings from having access to and utilising higher quality forest data acquired 
from and for all the Member States through common mandatory reporting. This will 
result  in  reduced  administrative  costs  for  data  gap  filling  exercises  currently 
undertaken by the JRC. 

National authorities 

•  Potential cost savings if the current Earth Observation (EO) activities at Member 
State level are complemented or replaced by EU level monitoring. Savings depend 
on the current EO-based monitoring activities in Member States. 

•  Benefits from replacing ground-based data collection with remote sensing. 

Extrapolated results from a case study on replacing a single indicator (ground-
based mapping of clear-cuts) with Copernicus satellite-data shows potential 
cumulative benefits of between EUR 28 million to 38 million by 2035 across all 
MS. 

Forest managers 

•  Cost-free EO data available to forest owners and managers which will facilitate 

acquisition of timely and accurate information on carbon stocks and fluxes in their 
forest for the purposes of certification of carbon removals - can replace costs 
linked to baseline-setting, monitoring and verification of such data through other 
methods.  

•  In a case study in Sweden, the greater role of EO was estimated to bring annual 

benefits ranging between EUR 6 and EUR 11 million annually for private forests 
owners from increased compliance with forest management obligations, leading to 
higher returns in the long-term. 

Forest-based industry  

•  Comparable information on forests allows for planning investments at larger 

scale than national and opens up investment opportunities.  

Indirect benefits 

102 

 
 
 
 
Most benefits of the initiative are indirect since it creates the conditions for environmental, economic 
and social benefits to be achieved through more targeted and evidence-based actions by policy- and 
decision-makers, including forest managers.  

•  Easy access to forest data through a single digital platform, reducing the administrative burden 
for businesses, citizens, and administrations in search of forest-related information, in line with 
the EU Digital Agenda. 

•  Greater  trust  in  forest  data  and  enhanced  use  from  different  stakeholders,  stimulating  the 
additional  use  of  forest  data  beyond  traditional  users  such  as  policymakers,  e.g.  scientific 
community, , certain actors within the forest industries, data-based services, financial sector. 
•  Better information on the quality and quantity of ecosystem services provided in view of a 
future implementation of payments for ecosystem services that would compensate and reward 
forest managers, incentivizing them to  enhance or maintain ecosystem services provided by 
forests,  for instance  within  the framework of the EU Certification of Carbon Removals or the 
Sustainable Finance Taxonomy Regulation (Climate Delegated Act). 

•  Higher  climate  change  mitigation  potential  of  forests  through  enhanced  carbon  storage  and 
sequestration. The economic value of the EU forest area’s net carbon sink can be estimated at 
€32.8 billion.  EU forests and wood products currently remove approximately 380 MtCO2 eq per 
year. Improved and timely data on forest-based removals through this initiative could stimulate 
further adoption of sustainable carbon farming practices across the EU and better forest mitigation 
policies. 

•  Better control of illegal logging: A solid evidence base for illegal logging activities through EO 
monitoring  of  key  variables  such  as  tree  cover,  spatially  explicit  designation  of  areas  by 
management  objective  or  protection  status  could  help  combat  illegal  logging.  Using  national 
examples, illegal operations made up around a quarter of all logging in Bulgaria between 2006 
and 2013, generating hidden revenue of over EUR 50 million per year.  

•  Reduced  forest  disturbances  and  enhanced  resilience  of  forests:  Forest  damage  from 
disturbances can have large economic consequences. For example,  forest fires caused damages 
worth approximately €1.5 billion per year in Europe in the 1998 to 2009 period and biological 
invasions  in  European  forests  were  estimated  to  cost  €20.9  billion  over  a  60-year  period.  The 
impact of future temperature increases on 32 tree species in Europe by 2100 is expected to reduce 
the value of European forest  land by 27%  due to a predicted decline in  economically valuable 
species.  The  existence  of  an  EU-wide  framework  for  timely  EO  monitoring  and  long-term 
planning will improve early and rapid detection of forest disturbances and adaptation of forests 
and the forest-based sector to the changing climate. 

•  More  sustainable  provision  of  economic,  social  and  cultural  forest  resources:  Timber 
provision was estimated at around EUR 16 billion in 2021 and the value of regulatory and cultural 
ecosystem services (i.e. flood control, water purification and recreation for which forests were the 
main contributor to  the total  value of nature-based recreation)  was estimated at  about  EUR 57 
billion.  

The most relevant and quantifiable costs additional to baseline are indicated in Table 11 below. The 
baseline  is  built  on  data  collection  in  all  Member  States  to  assess  the  extent  to  which  relevant 
activities are already conducted in Member States. Based on this baseline, cost in Member States can 
vary widely, depending on the extent to which they already collect data on relevant indicators, already 
use EO, or already develop integrated plans. 

103 

 
 
 
Table 11: Overview of Costs 

I. Overview of Costs – Preferred Option 

Harmonisati
on/standardi
sation 
and 
reporting 

Forest 
monitoring 
systems 
including 
enhanced 
remote 
sensing 

Stakeholders 

One-off 

Recurrent 

(Administrative costs) 

(Administrative costs) 

EU institutions 

EU institutions 

•  Costs 

from 

development 

of 
harmonisation methodologies based on 
group 
internal 
recommendations 
through 
financing research and projects;  

expert 
and 

expertise, 

•  Inclusions  of  additional  knowledge 
products  on 
the  FISE  platform 
(additional  ca  30%  of  the  current 
running annual costs for contracts). 

MS national authorities 

human 

resources 

•  One-off 

for 
contributing  to  the  development  of 
harmonised methodologies in an expert 
group  
•  Human 

for 
resources-related  costs 
training  and/or  hiring  of  staff 
to 
harmonise  data,  and  collect  data 
according to a new standard 

•  Quality assurance and quality control 
of  the  reported  data  from  Member 
States  

MS national authorities 

•  Harmonisation:  Limited  costs  for 
application of harmonised definitions 
and  methods  to  existing  data  sets 
(approximately  EUR  10  000  per 
indicator) and to existing ground data 
collection 

cost 

•  Standardisation:  The 

of 
standardised  data  collection  will 
depend on the variable measured (i.e. 
whether  new  expertise  and  tools  are 
needed) 

•  Recurring  limited  costs  for  human 
and 

processing 

resources 
for 
reporting of data 

EU institutions 

EU institutions 

•  One-off  costs  for  developing  EO  data 
products  for  the  pertinent  indicators 
and its technical specifications 

•  No major additional costs linked to set-
up  of  EO  technologies  as  building  on 
already  existing  EO  systems  (namely 
Copernicus’ Sentinel I and II satellites) 
for  establishing  a 
network 
for 
ground 
measurements related to validation and 
calibration of EO data.  

•  Potential  costs 

plots 

of 

•  No  additional  costs 

to 
operation  of  EO  technologies  as 
building  on  already  existing  EO 
systems (Copernicus) 

linked 

•  Data processing costs for EO-based 
indicators that are not currently 
produced by Copernicus Land 
Monitoring Service and additional 
costs in case of increased frequency 
for existing ones - around EUR 500 
000/year per an EO-based indicator 

104 

 
 
 
 
 
 
 
 
MS national authorities  

MS national authorities 

indicators  already 
(Costs  depending  on 
measured 
in  MS, 
adequateness  of  existing  sampling  grid, 
number of indicators, reporting frequency) 

forest  area 

in  MS, 

•  Designing 

and 

establishing  new 

sampling plot network (if needed)  
•  Hiring/training of staff and capital costs 
for 

(i.e. 
measuring new indicators (if needed) 

equipment 

tools) 

and 

•  Human 

resources 

for  developing 
workflows  for  new  data  collection 
obligations 

•  Possibility 

to  shift  costs 

to  EU 
institutions if using data provided by 
EU and not using the ‘opt-in’. 

•  Additional  average  annual  cost  for 
operating a National Forest Inventory 
is 42 EUR/km2 of forest area (based 
on three Member States NFI costs  – 
interval  and  use  of  EO 
5-year 
included. Only considered additional 
cost  if  no  running  NFI  currently 
present).  

Businesses 

•  No  major  impacts  on  businesses 
related  to  regulatory  burden  were 
thus identified under the ‘SME Test’ 
- data collection for the large majority 
of 
indicators  would  be  directly 
undertaken  by  public  authorities, 
with no risk that the burden or costs 
would be passed down to businesses.   
•  Economic 
indicators  based  on 
statistical 
as 
information 
production  and  uses  of  timber  and 
non-timber  products,  some  basic 
reporting  obligations  might  arise  for 
forest  owners 
forest-based 
industries,  but  they  are  estimated  to 
have  negligible  costs  as  they  are 
based on existing datasets. 

such 

and 

Integrated 
long-term 
planning 

MS national authorities 

EU institutions 

•  Limited  costs  depending  on  already 
existing  information,  structures  and 
expertise in the MS 

•  Where  no  comparable  information, 
structures and expertise is in place yet, 
one-off  costs  for  developing  new  or 
adaption 
multisectoral 
stakeholder dialogue; one-off costs for 
developing  new  or  adapting  existing 
methodologies for forecasting 

existing 

•  Case  study:  Germany  spent  EUR  500 
000  for  the  preparation  of  their  2050 

•  Limited 

costs 
recommendations 

for 

issuing 

MS national authorities 

•  Limited costs for reporting depending 
whether MS already have something 
comparable in place 

•  Recurring  costs  for  conducting  the 

forecasting exercise 

•  Recurring  costs  for  conducting  the 
stakeholder consultation exercise 
•  Recurring costs for drafting the report 

105 

 
 
 
 
forest  strategy  and  EUR  100  000  for 
dissemination 

Costs related to the ‘one in, one out’ approach 

Citizens/Consumers 

Businesses 

Administrations 

One-off 

Recurrent 

One-off 

Recurrent 

One-off 

Recurrent 

Total   

Direct 
adjustment costs  

Indirect 
adjustment costs 

Administrative 
costs (for 
offsetting) 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

On  the  costs  related  to  the  ‘one  in,  one  out’  approach,  overall  the  initiative  should  generate 
insignificant  administrative  costs  to  businesses  and  citizens  compared  to  the  baseline  since  the 
initiative does not introduce new direct administrative requirements applicable to these groups (s. 
section 6.3.2.)  

Relevant Sustainable Development Goals 

Table 12: Overview of SDG relevance 

Relevant SDG 

Expected progress towards the Goal 

Comments  (possible  synergies  and 
trade-offs between specific SDGs) 

SDG  no.  3  –  Good 
health  and  well-
being 

The physical and mental health benefits associated 
with  healthier  forests  could  contribute  to  SDG  3 
through  targets  3.4132  (e.g.  as  mental  health 
and 
improvements 
recreation, or from reduced obesity) and 3.9133 (as 
reduced  mortalities  from  the  reduction  of  air 
pollution). 

forest  visitation 

from 

SDG no. 6 – Clean 
water 
and 
sanitation 

The  potential  of  this  initiative  to  restore  forests 
(which  are  important  water-related  ecosystems) 
and improve their health, could contribute to water 
purification  and  water  availability  through  the 
filtration of sediments and harmful pollutants, as 
well  by  maintaining  the  physical  structure  and 
integrity of water sources such as rivers and lakes.  

132 By 2030, reduce by one third premature mortality from non-communicable diseases through prevention and treatment and promote mental health 
and well-being 
133 Achieve universal health coverage, including financial risk protection, access to quality essential health-care services and access to safe, effective, 
quality and affordable essential medicines and vaccines for all 

106 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
SDG  no. 
Affordable 
clean energy 

7 

– 
and 

SDG no. 8 – Decent 
work 
and 
economic growth 

these 

Overall, 
services  alleviate  additional 
pressures  on  water  treatment  facilities  and  can 
for  suppliers  and  consumers. 
reduce  costs 
Therefore, this initiative could contribute to targets 
6.1134, 6.3135, and 6.6136. 

Under  the  assumption  that  this  initiative  can 
facilitate  more  sustainable  management  of  forest 
resources, there is potential for a greater or more 
long-term provision of biomass for bioenergy into 
the  future.  As  a  renewable  energy  source,  this 
would contribute towards target 7.2137. 

forest 

resources  and  also  supports 

A  monitoring  and  planning  framework  which 
contributes to the sustainable long-term provision 
of 
the 
development  of  new  bioeconomic  activities  and 
employment 
forest 
ecosystems  (e.g.  eco-tourism)  can  contribute  to 
SDG 8, specifically target 8.9138. 

opportunities 

around 

A potential trade-off of an increased use of 
biomass for bioenergy is the over-harvesting 
of 
ecosystem 
degradation, which could conflict with SDGs 
13 and 15. 

resulting 

forests 

in 

Important  trade-offs  may  be  the  shift  in 
employment 
traditionally 
from 
unsustainable  forest  sectors  to  emerging  or 
existing sustainable forest industries, or the 
natural decline of  some  forest  sectors.  This 
may have trade-off effects on SDG 8 target 
8.1  on  sustaining  economic  growth 
if 
typically  more  profitable  industries  are  in 
decline. 

SDG  no.  12  – 
Responsible 
consumption  and 
production 

The 
facilitation  of  evidence-based  decision 
making,  and  more  informed  forest  management 
decisions  can  contribute  to  more  sustainable 
consumption and production of forests resources, 
as is specified under SDG 12.  

SDG  no.  13  – 
Climate action 

As  a  natural  resource  with  high  natural  capital 
value,  the  sustainable  management  and  efficient 
use of forest resources could greatly contribute to 
target  12.2139.  Sustainable  management  within 
agroforestry could lead to reduced food losses in 
the  production  chain  as  specified  under  target 
12.3140. 

Healthier  forests  as  a  potential  benefit  of  this 
initiative  can  contribute  to  combatting  climate 
change and its impacts. Forest ecosystems can act 
as sinks to store carbon, as well as remove carbon 
from the atmosphere through sequestration. 

Healthier  forests  are  more  resilient  to  climate-
related or exacerbated disturbances such as fires, 
flooding, droughts, and pest and disease outbreaks. 
Therefore, this can contribute to target 13.1141 to 
strengthen  resilience  to  climate-related  hazards 
and natural disasters. 

SDG  no.  15  –  Life 
on land 

An EU-wide framework for forest monitoring and 
integrated  long-term  planning  could  facilitate 
better management decisions and policymaking to 

134 By 2030, achieve universal and equitable access to safe and affordable drinking water for all 
135 By 2030, improve water quality by reducing pollution, eliminating dumping and minimizing release of hazardous chemicals and materials, halving 
the proportion of untreated wastewater and substantially increasing recycling and safe reuse globally 
136 By 2020, protect and restore water-related ecosystems, including mountains, forests, wetlands, rivers, aquifers and lakes 
137 By 2030, increase substantially the share of renewable energy in the global energy mix 
138 By 2030, devise and implement policies to promote sustainable tourism that creates jobs and promotes local culture and products 
139 By 2030, achieve the sustainable management and efficient use of natural resources 
140 By 2030, halve per capita global food waste at the retail and consumer levels and reduce food losses along production and supply chains, including 
post-harvest losses 
141 Strengthen resilience and adaptive capacity to climate-related hazards and natural disasters in all countries 

107 

 
 
 
 
 
 
ensure  forest  ecosystems  are  protected,  restored, 
and sustainably managed, all important factors of 
SDG 15.  

loss, 

reduced 

sustainable 

Better 
forest  management  and 
improved  monitoring  of  the  state  of  forests  can 
contribute  to  healthier  forests  in  the  EU  through 
reduced  biodiversity 
forest 
disturbances  and  enhanced  resilience  to  climate 
change.  Equally  the  initiative  could  lead  to 
reduced  deforestation;  reduced  land  and  soil 
degradation; control of invasive species; and could 
and 
for 
inform 
afforestation,  as  a  part  of  targets  15.1142  15.2143, 
15.3144, 15.4145, 15.8146, and 15.9147. 

reforestation 

planning 

142 By 2020, ensure the conservation, restoration and sustainable use of terrestrial and inland freshwater ecosystems and their services, in particular 
forests, wetlands, mountains and drylands, in line with obligations under international agreements 
143 By 2020, promote the implementation of sustainable management of all types of forests, halt deforestation, restore degraded forests and substantially 
increase afforestation and reforestation globally 
144 By 2030, combat desertification, restore degraded land and soil, including land affected by desertification, drought and floods, and strive to achieve 
a land degradation-neutral world 
145 By 2020, ensure the conservation, restoration and sustainable use of terrestrial and inland freshwater ecosystems and their services, in particular 
forests, wetlands, mountains and drylands, in line with obligations under international agreements 
146 By 2020, introduce measures to prevent the introduction and significantly reduce the impact of invasive alien species on land and water ecosystems 
and control or eradicate the priority species 
147 By 2020, integrate ecosystem and biodiversity values into national and local planning, development processes, poverty reduction strategies and 
accounts 

108 

 
 
 
 
 
ANNEX 4: ANALYTICAL METHODS 

Introduction 

This Annex describes the analytical methods used in the impact assessment. It is structured around 
different steps of the impact assessment, namely 

• 
• 

Identification of problems and objectives 
Identification and analysis of impacts 

In addition, it explains the method for developing the country fiches developed as part of the impact 
assessment. 

Identification of problems and objectives 

The purpose was to clearly identify the problems and drivers that constitute the starting point (and 
raison  d'être)  for  the  new  Legislative  proposal  for  an  EU  Framework  on  Forest  Monitoring  and 
Integrated Long-Term Forest Planning, as well as to defining the general and specific objectives that 
the proposed policy options could aim to deliver on. The work was organised along the following 
stages:  

•  1.1 where problems and problem drivers regarding forest monitoring and forest planning in the 

EU were described;  

•  1.2 where requirements for an EU monitoring system and integrated planning were formulated; 

and  

•  1.3 where a set of preliminary policy options for consideration were developed. 

Stage 1.1: Describe and define problems and problem drivers regarding forest monitoring and 
forest planning in the EU.  

Step 1: Gather information 

Subtask 1.1 target was to gather information and conduct a detailed overview of problems and their 
drivers  concerning the forest  monitoring systems  and  forest  planning  in  the EU. The overview is 
preliminarily based on literature review and expert knowledge as well as to some extent stakeholder 
views.  Stakeholder  views  were  collected  by  participating  in  recent  forums  discussing  the  forest 
monitoring in Europe.  

For the literature review, around 60 sources such as books, scientific papers, projects reports, EU 
support documents were reviewed. The review focused on screening relevant sources, which covered 
a  critical  assessments  of  monitoring  options  and  related  topics,  for  mentions  of  problems  and 
drawback of the current forest monitoring system in EU. All references are listed in chapter 9 of this 
report. 

Step 2: Draft the problem descriptions 

From the 60 references that were reviewed, altogether 178 problems were identified as key obstacles 
on  the  roadmap  towards  forest  monitoring  in  the  European  Union.  Aiming  to  have  a  clear 
understanding of the collected data, two consecutive categorisation approaches were performed. 

109 

 
 
In a first categorisation approach, two category levels were developed. Based on the description of 
the  identified  problems,  five  different  categories  were  created,  and  the  problems  were  distributed 
among these categories according to their scope.  

After  this  step,  the  problems  inside  each  one  of  the  five  categories  were  further  divided  into  a 
secondary  category  level  to  provide  additional  information  and  obtain  a  better  overview  of  the 
identified problems.  

The results of this exercise are presented in the following Figure. 

Figure 25: Problem categorisation 

Source: Own illustration 

The results made it possible to recognise that part of the identified problems shared, to some degree, 
the same main drivers and consequences. 

Therefore, a second categorisation approach was performed, where not only the main subject of the 
problems  was  considered,  but  also  the  roots  and  consequences  of  the  problems.  This  approach 
allowed the identified problems and drawbacks of the current forest monitoring system in the EU to 
be summarised into five main areas (next Figure) grouped  

110 

 
 
 
Figure 26: Main problem areas 

Conforming to the five main identified areas, upon (i) identifying the problems, the problem analysis 
was further refined by (ii) estimating the scale of the problem; (iii) analysing its causes/drivers; (iv) 
identifying stakeholders in a sense of who own and/or can solve a problem and; (vi) assessing the 
likelihood that the problem may persist. 

As a result the five main problem areas where then grouped into two main problems: 

• 

lack of data comparability and quality (including insufficient indicator coverage and limited 
accessibility) 

• 

lack of integrated long-term forest planning 

According to the Better Regulation Tool #14 guidelines, a detailed formulation of the main problems 
elements was carried out (Table 13). 

Table 13: Overview of main problem elements 

Category 

Function 

Description  

General description 

Indicating nature 

Qualitative  overall  description  of 
problem. 

the 

Scale 

Indicating relevance 

and, 

Quantification 
feasible, 
monetisation  of  the  extent  to  which  the 
defined problem affects the attainment of the 
Regulation´s goals. 

were 

Main drivers 

Indicating causes 

Consequences 

Indicating consequences 

Indicating  which  factors  have  caused  the 
problem and influence the identified trends. 

Main  health,  environmental,  economic, 
political and social effects which are likely to 
occur under no-policy change scenario. 

No-policy change scenario 
including trends 

Stakeholders 

Indicating baseline scenario  Description of the policy measures currently 
in place. Possible paths of development of the 
problem,  bearing  in  mind  its  drivers  and 
consequences. 

Indicating actors (to be) 
involved 

Political, economic and societal actors which 
are affected by/concerned with the identified 
problem. 

111 

 
 
 
 
 
Step 3: Development of problem trees 

As a next step of the analysis the problem descriptions were illustrated in problem trees of the main 
problems areas, including their underlying drivers and impacts. As already pointed out, the drivers 
as well as impacts of the problem areas are interlinked. Data was condensed into one problem tree 
for structuring the legislative initiative as a whole: establishing what the problem is, what its negative 
consequences are, and identifying the issues that might have to be addressed by an EU intervention.  

At  this  step  also  the  problem  drivers  were  further  scrutinized  –  including  additional  material  for 
describing  the  exogenous  drivers,  e.g.,  the  EU  Strategic  foresight  reports  and  the  trends  in  key 
questions about forests in the EU.  

Stage 1.2: Formulate requirements for an EU monitoring system and Integrated Long-Term 
Forest Planning according to the EU Forest Strategy.  

This step includes defining the scope of parameters and information products that will be part of the 
monitoring  system,  defining  the  characteristics  of  the  monitoring  system,  as  well  as  the 
characteristics of the integrated forest plans. 

Based  on  the  description  and  definition  of  the  problems  and  problem  drivers  regarding  forest 
monitoring and forest planning in the EU, requirements for an EU monitoring system and integrated 
forest plans are defined. In addition to those requirements outlined by the forest strategy, problems 
and needs identified in the first step (stage 1.1) will be translated into possible requirements towards 
the monitoring system. This includes defining the scope of parameters and information products that 
will be part of the monitoring system, defining the characteristics of the monitoring system, as well 
as the characteristics of the integrated forest plans. Purpose, specific and operational objectives for 
an EU monitoring system and integrated forest plans are described. 

Stage 1.3 - Develop preliminary policy options 

Step 1: Construct a baseline “no-policy-change” scenario  

A draft “no-policy-change” scenario was developed, in  line with  the Better Regulation  Tool #16. 
Currently no legislative framework on forest monitoring exists in Europe and the “no-policy-change” 
scenario builds on the assumption that no proposal on the EU Framework on Forest Monitoring and 
Integrated Long-Term Forest Planning is adopted (i.e. “no action” scenario).   

The “no-policy-change” scenario is the counterfactual against which the impact of the different policy 
options are compared. This scenario covers the evolution of the legal framework considering relevant 
external  factors  and  elements,  such  as  EU-level  and  international  policies  which  are  assumed  to 
remain  in  force,  and  the  foreseen  policy  and  socio-economic  development  that  will  influence  the 
problem drivers and solution drivers.  

The no-policy-change scenarios are described in view of the specific objectives. 

Step 2: Compile a wide range of alternative policy options 

Development of the policy options was an iterative process, starting with a long-list of policy options. 
In reviewing the long-list of options, three thematic strands were developed, and the more detailed 
policy  options  were  developed  along  these  core  policy  elements:  (1)  the  Standardisation  of  data 
collection,  (2)  the  further  development  of  remote  sensing-based  monitoring  systems  and  (3)  the 
development  of  integrated  forest  plans.  A  set  of  policy  options  will  consider  as  many  realistic 
alternatives as possible.  

112 

 
 
Step 3: Identify most viable policy options and measures 
With the set of policy options produced, the next step is to reduce the number of policy options that 
will be subjected to a more in-depth analysis of impacts. The aim of the screening of policy options 
is to arrive at a shortlist of the most promising options.  

Identification and analysis of impacts 

Identification of impacts 

First,  the  most  significant  impacts  from  the  selected  policy  options  were  identified  following  the 
methodology  outlined  in  the  Better  Regulation  Toolbox  (see  Table  14  below).  Impacts  include 
social/environmental/economic, positive/negative as well as direct/indirect. They have been assessed 
the  based  on  the  expected  significance  in  terms  of  changes  relative  to  the  baseline  (i.e.,  the 
incremental changes). To this end, data collected from the country fiches were an important input. 
Then, the most important impacts were identified and further assessed in Section 6. 

Table 14: Impact Categories 

Key 
Impacts  

Description of the impact  

Climate  

Quality of 
natural 
resources (soil, 
water  

Biodiversity, 
including flora, 
fauna, 
ecosystems, 
and 
landscapes  

Land Use  

Having better quality and more timely information on the respective 
relevant forest indicators, and long-term integrated forest planning 
integrating these policy areas will have the indirect impact of enabling 
better national and EU policy- and decision-making in these impact 
areas  

The likelihood 
and scale of 
environmental 
risks (forest 
fires, droughts, 
biological 
agents etc.)  

Impact categories  

Environmental  Economic   Social  

x 

x 

x 

x 

x 

x 

x 

x  

x 

x 

x 

Efficient use of 
resources  

Improving awareness of forest-based industries on the availability of 
primary and secondary forest resources  

x 

x 

113 

 
 
 
 
  
 
 
 
 
 
SMEs and 
Conduct of 
Business  

Improving the knowledge base of small and medium forest holdings 
and forest-based industries which may improve their business decisions  

Bringing new opportunities to companies offering EO-services  

Public 
authorities and 
budgets  

Both costs and avoided costs to national public administrations. Costs 
would result mainly from additional monitoring, reporting and 
planning, while avoided costs mainly from the use of Commission-
operated EO  

Digitalisation 
and 
innovation  

Where appropriate, the initiative will aim to reuse existing data 
produced by Copernicus or Eurostat and make it accessible to data 
users through a single portal (FISE).  

By putting emphasis on EO as a basis of the EU monitoring system, the 
initiative will be a potential driver of innovation for the use of remote-
sensing monitoring technologies.  

x 

x 

x 

Comparison of policy options 

Once the impacts of each of the policy options have been identified and analysed, they were compared 
based  on  their  relative  strengths  and  weaknesses.  This  was  done  by  listing  and  summarising  the 
impact of each option in tabular form. Table 15 below presents a list of relevant criteria (compared 
to baseline scenario so that their added value can be clearly identified) to compare the options. 

Table 15: Overview of criteria for comparison 

Criterion 
Impacts per 
stakeholder 
group 
Effectiveness 
(coverage of 
identified 
requirements) 
Efficiency 

Coherence 

Definition 
An overview of the extent to which 
differ stakeholder groups are 
affected and how.  
The extent to which different 
options would achieve the general 
objective of the initiative. 

An analysis of the net benefits of the 
impacts, i.e. comparing the benefits 
and the costs 

An analysis of the coherence with 
other EU legislation and policies. 
Internal coherence is analysised in 
addition where different levels of 
intervention are combined. 

Data source 

•  Outcome  of  assessment  of  environmental, 

social and economic impacts. 

•  Outcome  of  assessment  of  environmental, 

social and economic impacts. 

•  Outcome  of  assessment  of  economic 
impacts,  as  well  as  the  estimates  of 
administrative burden.  

•  Outcome  of  assessment  of  environmental, 

social and economic impacts. 

Using those criteria, the policy options were compared in a comparison table for each criterion using 
a simple sign framework as outlined in the following Table. 

Legend of signs to be used in the comparison table 

Sign 
++ 

Legend 
Objectives are partly met 

114 

 
 
  
 
 
 
 
 
  
 
 
 
Sign 
+ 

Legend 
Slight improvment over baseline 

Method for developing the country fiches 

After agreeing on templates for the country fiches on the existing monitoring frameworks as well as 
strategic planning frameworks, the fiches were filled for each MS, based on an extensive literature 
review. 

This resulted in a set of draft fiches for each MS. Those draft fiches were then shared with relevant 
stakeholders in each Member State for feedback and revisions. 

Based on the feedback, the fiches were revised, and a final version was created for each. 

Raw data used for figures 

Figures 1 and 2 in chapter 6 have been created based on the below data. (Source: Eurostat 2021) 

Table 16: Data Overview for Figures 1 and 2 

Country 

Area 

total area 

forest area 

Share 
of 
total 

GDP (average 
2016 - 2020) 

Austria 
Belgium 
Bulgaria 
Croatia 
Cyprus 
Czechia 
Denmark 
Estonia 
Finland 
France 
Germany 
Greece 
Hungary 
Ireland 
Italy 
Latvia 
Lithuania 
Luxembourg 
Malta 
Netherlands 
Poland 
Portugal 
Romania 
Slovakia 
Slovenia 
Spain 
Sweden 

83,882 km2 
30,665 km2 
110,995 km2 
56,594 km2 
9,253 km2 
78,870 km2 
42,926 km2 
45,336 km2 
338,441 km2 
638,474 km2 
357,568 km2 
131,692 km2 
93,013 km2 
69,946 km2 
302,073 km2 
64,586 km2 
65,286 km2 
2,595 km2 
315 km2 
37,368 km2 
311,928 km2 
92,226 km2 
238,397 km2 
49,035 km2 
20,273 km2 
505,983 km2 
447,424 km2 

38,992 km2 
6,893 km2 
38,930 km2 
19,391 km2 
1,725 km2 
26,771 km2 
6,284 km2 
24,384 km2 
224,090 km2 
172,530 km2 
114,190 km2 
39,018 km2 
20,530 km2 
7,820 km2 
95,661 km2 
34,108 km2 
22,010 km2 
887 km2 
5 km2 
3,695 km2 
94,830 km2 
33,120 km2 
69,291 km2 
19,259 km2 
12,378 km2 
185,722 km2 
279,800 km2 

378,091 Million € 
454,732 Million € 
56,145 Million € 
51,228 Million € 
21,214 Million € 
204,792 Million € 
300,307 Million € 
25,349 Million € 
231,035 Million € 
2,328,556 Million € 
3,329,208 Million € 
175,942 Million € 
132,738 Million € 
324,828 Million € 
1,732,208 Million € 
28,496 Million € 
45,072 Million € 
60,331 Million € 
12,554 Million € 
766,011 Million € 
489,633 Million € 
200,503 Million € 
200,926 Million € 
88,732 Million € 
44,977 Million € 
1,168,855 Million € 
474,878 Million € 

46% 
22% 
35% 
34% 
19% 
34% 
15% 
54% 
66% 
27% 
32% 
30% 
22% 
11% 
32% 
53% 
34% 
34% 
1% 
10% 
30% 
36% 
29% 
39% 
61% 
37% 
63% 

115 

Economics 
Gross 
economic 
value added 
from forestry 
and logging 
(average 
2016-2020) 
2,044 Million € 
406 Million € 
676 Million € 
325 Million € 
4 Million € 
2,680 Million € 
624 Million € 
824 Million € 
5,414 Million € 
6,515 Million € 
7,681 Million € 
75 Million € 
535 Million € 
167 Million € 
2,411 Million € 
1,219 Million € 
514 Million € 
27 Million € 
0 Million € 
312 Million € 
5,331 Million € 
1,290 Million € 
2,331 Million € 
1,199 Million € 
539 Million € 
1,983 Million € 
9,291 Million € 

Share of 
forestry 
and 
logging of 
overall 
GDP 

0.54% 
0.09% 
1.20% 
0.63% 
0.02% 
1.31% 
0.21% 
3.25% 
2.34% 
0.28% 
0.23% 
0.04% 
0.40% 
0.05% 
0.14% 
4.28% 
1.14% 
0.05% 
0.00% 
0.04% 
1.09% 
0.64% 
1.16% 
1.35% 
1.20% 
0.17% 
1.96% 

 
 
 
 
  
 
Further discussion on the costs of the preferred option on Member States  

This section provides further information and a discussion on the methodology and results presented 
in Table 6 found in Section 6.3.1.  

Current baseline of importance of forestry sector and implications 

In Estonia, Finland, Latvia and some extent Sweden, the forest-based sector plays a larger economic 
role compared to other countries, which seems to have contributed overall positively to their current 
baseline  regarding  plot  number  and  density,  integration  of  EO  and  number  of  indicators  that  are 
currently  monitored.  Those  countries  are  expected  to  face  the  lowest  cost  (or  even  save  cost)  as 
compared to other Member States. Given the economic importance of the sector which is predicted 
to be positively influenced through this initiative due to increased long-term sustainability of forest 
resources, it can be expected that these Member States benefit economically in the long term. This is 
in  addition  to  the  wider  benefits  from  better  forest  health  which  are  described  in  the  impact 
assessment report. 

At the other end of the spectrum, there are Member States where the forest-based sector plays little 
or no role, such as Cyprus, Greece, and Malta. In these Member States there are also limited forest 
monitoring provisions in place regarding plot density, integration of EO, and indicators monitored. 
At the same time, Cyprus and Malta, and to a limited extent also Greece, have a comparably small 
area of wooded land in their territories. In light of the high number of additional indicators which 
would  become  obligatory  through  this  initiative,  a  significant  cost  would  arise,  while  the  direct 
economic benefits would be limited (although wider environmental and social benefits from better 
forest health would still apply). 

Current baseline of number of observation plots and implications 

Finland,  Germany,  Spain,  and  to  some  extent  also  Poland  and  France,  have  a  high  number  of 
monitoring  plots  already  in  place.  In  those  countries  this  leads  to  a  comparably  high  density  of 
monitoring plots at or above the EU median. Thus, the monitoring of additional indicators could lead 
to relatively higher costs since they have to are measured throughout more plots. At the same time, 
there is a strong likelihood that no additional monitoring plots would need to be created., since their 
monitoring plot density is at or above the EU median. 

On the other hand, Greece, Italy, Slovenia and Slovakia have a relatively low number of monitoring 
plots currently in place, leading to a low density of plots. As discussed earlier in this report, this might 
lead to the need to create additional plots in order to assure EU wide harmonisation of data.  

Current baseline of number of time interval between subsequent plot visits and implications 

Regarding the current time interval between subsequent plot visits, there are two major groups within 
the MS, which conduct observations every 5 or every 10 years, respectively. Given the assumption 
that data collection would be required to happen at least every 5 years under this legislative initiative, 
this would lead to additional costs for those MS which currently conduct the assessments every 10 
years.  

The costs for Member States with a current 10-year cycle would likely be considerably lower than 
double  the  current  costs,  since  expertise,  infrastructure,  and  equipment  had  to  be  maintained  and 
incremental cost would only arise from hiring additional staff during data collection and analysis. 

116 

 
 
On the other hand, considerable costs can be expected for the countries Croatia, Cyprus, and Greece 
where thus far only one assessment has been conducted; or Malta and Bulgaria, where no structured 
assessment has yet been conducted. In those cases there would be – in addition to the staff costs for 
collection and analysis of data - costs for training and equipment. 

Explanation of the categorisation in Table 6 

Group 1- Facing high costs  

This group includes countries for which high costs can be expected. The main driver of this is the 
absence of regular NFI. There are high one-off costs to be expected from developing and putting in 
place the system, such as training of staff, purchase of equipment, and others. Within this category 
countries like Greece and Cyprus also have the lowest numbers of the potential indicators already 
monitored.  

This category also entails two countries with small forest size (CY, MT). While in theory this means 
that they thus face less overall cost for monitoring, on the other hand this also means that their costs 
per area for monitoring and strategic planning would likely be much higher than for other countries, 
since the overheads for the organisation, planning, training etc. are spread over a smaller area. 

Group 2 – Medium cost 

This is the largest group of countries. The group includes countries which already have NFIs in place 
(though often at a lower frequency), and/or where forestry might not play a very strong role. 

Group 3 – High economic interest and lower expected costs 

These are the countries in which forestry plays a big role. They thus typically already have a well-
functioning monitoring and planning in place, and all organise their assessments every 5 years and 
would thus face little to no additional costs from the planned 5-year frequency. 

117 

 
 
 
 
ANNEX 5: BACKGROUND ON FOREST MONITORING AND FOREST-
RELATED PLANNING 

5.1 EU Forests and their Governance at EU level 

The carbon sink capacity, biodiversity, economic potential and vital ecosystems services 
of forests all depend on the health, resilience and adaptiveness of forest ecosystems and 
related biodiversity preservation and restoration needs.  

In contrast to other ecosystems such as grasslands and croplands with annual plants, forests 
are particularly challenged by such pressures, because they adapt only with delay and after 
deep transformations e.g. of their species composition. Tree mortality has accelerated in 
the last decade, because of extreme weather events and harvesting for different economic 
purposes  has  gone  up.  Climate  change  projections  leave  little  doubt  that  increasingly 
frequent  and  severe  heat  waves,  droughts,  wildfires,  and  insect  and  pest  outbreaks  will 
have serious impacts on many forests in Europe.  
The European Green Deal148 called for action to improve the quantity and quality of the 
forested  area  in  the  EU  and  to  enhance  the  resilience  of  forests  for  reaching  climate 
neutrality, a higher biodiversity ambition, a healthy environment, to improve human health 
and  well-being  and  to  promote  the  circular  bioeconomy.  The  ensuing  EU  Biodiversity 
Strategy for 2030149 sets out a comprehensive, systemic, and ambitious long-term plan for 
protecting nature and restoring essential functions, reversing the degradation of ecosystems 
including forests. Building on the EU Biodiversity Strategy, the New EU Forest Strategy 
for 2030150 recognises the multifunctional role of forests, including the contribution of the 
entire forest-based value chain for achieving a sustainable and climate neutral economy by 
2050. Building on these premises, the Forest Strategy sets out a vision and defines concrete 
actions to improve the quantity and quality of EU forests and strengthen their protection, 
restoration  and  resilience.  Finally,  reflecting  the  requirement  set  out  in  the  European 
Climate  Law151  to  ‘ensure  continuous  progress  in  enhancing  adaptive  capacity, 
strengthening resilience and reducing vulnerability to climate change’, the EU Adaptation 
Strategy152 sets out to make adaptation smarter, more systemic and faster – including for 
forests. More adaptive and resilience-enhancing forest management is needed to ensure the 
continued delivery of forest’s socioeconomic functions and to ensure vibrant rural areas.  

Forest Governance is cross-cutting several EU policies. Figure 27 in this Annex provides 
an  overview  of  main  EU  policy  fields  and  instruments  affecting  forests.  Legislative 
instruments are highlighted in bold, proposals adopted (or announced, in the case of the 
Soil Health Law) by the Commission lighter in shading. The new EU Forest Strategy 2030 
is  included  in  the  overview  in  the  same  colour  as  the  legislative  initiative  on  forest 

148 COM(2019)640 final 
149 COM(2020)380 final 
150 COM(2021)572 final 
151 Regulation (EU) 2021/1119 
152 COM(2021)82 final 

118 

 
 
 
 
monitoring and integrated strategic planning since it provides for the legislative initiative 
but also benefits from it.  

Figure 27: Overview of EU policy relevant for Forest Monitoring and Integrated Long-Term Forest Planning 

As laid out in the New EU Forest Strategy for 2030, today the information concerning the 
status of forests in the EU, their social and economic value, as well as the pressures they 
face and ecosystem services they provide, is patchy. Since 2006, when the Forest Focus 
Regulation expired, no comprehensive reporting requirements exist. In addition, there are 
challenges related to the use of remote sensing data together with ground-based data (i.e. 
lack of interoperability, common definitions, ambiguity in data interpretation, lack of long 
and comparable very high resolution time-series, limitations of the current standard forest 
products from Copernicus).  

Also, there is insufficient planning for the forests, which would address in a coordinated 
manner and provide a comprehensive picture of the multifunctionality of forests in the EU, 
especially  regarding  climate  mitigation  and  adaptation,  ecological  condition  of  forests, 
forest damage prevention and control, and forest biomass demand and supply for different 
socio-economic purposes.  

119 

 
 
 
 
Combined with the need for more detailed sustainable forest management indicators and 
thresholds on certain climate and biodiversity aspects, this leads to a situation where, on 
the one hand, Member States have agreed at EU level to rely to a great extent on forests 
and forest-based bioeconomy in the EU’s transition to a climate-neutral economy. On the 
other  hand,  there  are  several  scattered  monitoring  and  reporting  mechanisms,  but  no 
strategic  framework,  which  would  bring  these  together  and  make  it  possible  to 
comprehensively and jointly with Member States demonstrate that the EU is on the right 
track and that the forests can actually deliver on their multiple demands and functions.” 

5.2 Forest monitoring in the EU  

The  first  EU  regulatory  instruments  on  forest  monitoring  were  adopted  in  1986153  to 
monitor  the  effects  of  atmospheric  pollution  and  wildfires.  Further  provisions  detailing 
forest  monitoring  requirements  in  relation  to  forest  fires  were  developed  in  separate 
Regulations in 1992 and 1994154. In 2003 these schemes converged in the Forest Focus 
Regulation155, which also addressed the need to monitor forest condition and the effects of 
climate  change.  At  the  end  of  2006,  based  on  simplification  grounds,  the  Forest  Focus 
Regulation was repealed by the LIFE+ regulation156 providing a single financial instrument 
for  the  environment  and  functioning  on  the  basis  of  repeated  open  calls.  One  of  the 
consequences of this simplification/consolidation was that there was no longer a dedicated 
financial  support  scheme  (and  related  requirements  on  Member  States)  on  forest 
monitoring.  Therefore,  there  have  been  no  comprehensive  monitoring  requirements  for 
forests at European level since, apart from certain information collected by EUROSTAT157 
and for emissions and removals in the LULUCF sector158 . The repeal of the Forest Focus 
Regulation in 2006 and the Green Paper on Forest Protection and Information in the EU 
of 2010159, however, highlighted the need for a continuous assessment and monitoring of 
the state, dynamics and future evolution of European forests.  

During  the past  decades, remote sensing-based data collection, processing methods  and 
data storage capacities have been evolving significantly and nowadays many countries and 
private companies operate satellites with EO capacities. On the European side, the EU EO 
Copernicus program has been a major game changer and plays a leading role globally with 
high quality instruments providing data and information services operationally under a free 
and  open  data  policy.  Besides  the  advancement  of  space-borne  technologies,  data 
collection via airborne technologies - airplanes or drones for digital photographs, scanning 
systems, or ranging instruments such as  LIDAR - play a crucial and increasing role for 
forest monitoring including on biomass estimates and forest species and forest composition 
monitoring. Technology is also evolving for ground monitoring, which remains crucial for 
the development of EO techniques.  

153 Council Regulation (EEC) No 3528/86; Council Regulation (EEC) No 2158/92  
154 https://effis.jrc.ec.europa.eu/about-effis/legal-background  
155 Regulation (EC) No 2152/2003  
156 Regulation (EC) No 614/2007  
157 Annual statistics on the area and value of wooded land, the quantity and value of timber, the economic 
activities of forestry and logging, and employment in the sector. There is currently no official data collection 
that provides quantitative information about environmental functions of forests. 
158 Such as forest area, emissions and wood volumes.  
159 COM(2010) 66 final. 

120 

 
 
 
In  contrast  to  existing  EU  legal  obligations  and  the  indisputable  advancement  of 
technologies  potentially  enabling  to  collect  a  wealth  of  information  for  forests,  several 
problems are currently in the way of a comprehensive and consistent forest monitoring in 
Europe. This is clear from studies that have analysed the ability of countries to report with 
sufficient quality and complete data to international processes such as Forest Europe160,161 
and  other  studies  that  looked  at  data  availability  and  potential  for  harmonisation  or 
standardisation  of  forest  information  at  national  level162  or  in  context  of  forest 
monitoring163,164. Also, above-mentioned progress in data collection technologies does not 
automatically turn into better accessibility to collected data. 

At present, the most common forest monitoring framework adopted by MS is based on 
National  Forest  Inventories  (NFIs).  These  are  rolling  national  forest  data  collection 
programmes, whereby the frequency of data collection, the data collection and processing 
methods, and the measured forest parameters vary greatly from one country to another. 
Usually,  data  provided  by  NFIs  from  different  countries  are  therefore  not  directly 
comparable. Initially motivated by a fear of forest over-exploitation and hence designed to 
monitor  timber  resources,  many  NFIs  have  gradually  evolved  to  provide  answers  to  a 
broader range of questions. They are typically based on ground measurements taken from 
a grid of forest plots, which are then surveyed and extrapolated to obtain a statistical figure 
for the whole region or country, and the sample plots and schemes were not developed to 
be  linked  with  remotely  sensed  forest  information.  The  operation  of  a  measurement 
network such as NFIs is very expensive. Sites need to be re-visited at specific intervals 
which requires field units, transport and mission costs, in addition to in-office QA/QC and 
data post-processing.  

Not all Member States have NFIs, and the sum of NFIs is far from constituting a coherent 
monitoring  system.  Each  NFI  in  the  MS  has  specific  characteristics,  with  different 
temporal cycles, data accessibility, degrees of international standardization/harmonization 
and integration with remote sensing. These are presented in the following as a gap analysis 
towards a consistent EU monitoring framework. 

Time frame 

The  time  interval  between  two  subsequent  field  revisits  varies  within  different  NFIs. 
Across Europe, most MSs adopt a five-year revisit cycle (i.e., Belgium, Czech Republic, 
Denmark, Estonia, Finland, France, Hungary, Ireland, Latvia, Lithuania, Poland, Romania, 
and  Sweden),  while  a  10-year  cycle  occurred  in  Germany,  Spain,  Italy,  Luxembourg, 
Portugal, Slovenia, and Slovakia. Other MS either does not have a planned NFI (i.e., Malta, 
Bulgaria), or only happened once (i.e., Croatia, Cyprus, Greece). Lastly, Austria and the 
Netherlands adopted a specific time span between the measurement of subsequent NFI, the 
first every three years (where one-third of the sampling plots were surveyed every year) 
while the latter has a planned cycle of four years.  

160 Baycheva-Merger and Wolfslehner 2016  
161 Linser and Wolfslehner 2022 
162 Diabolo project 2019 
163 European Commission, Directorate-General for Environment et al. 2020 
164 Van Brusselen et al. 2021 

121 

 
 
 
 
For gap filling the solution would be to have annual estimates produced by the NFI on the 
basis of permanent monitoring system where every year a proportion of 1/n plots (where n 
= years of the NFI rotation, most frequently 5 years) are visited in the field. 

Data accessibility 

One  of  the  possibilities  to  create  pan-European  estimates  of  forest  variables  is  to  re-
elaborate raw plot level (or even tree level) data acquired by the NFIs, in conjunction with 
remotely sensed data. Many such hybrid systems exist in literature. To do so the NFI data 
should be accessible. 

The traditional way the NFIs produce their results is with design-based estimates for large 
aggregated  regions  and  published  on  the  national  websites  in  the  form  of  reports. 
Nowadays,  some  MSs  upload  plot  and  tree-level  information  surveyed  during  NFIs  in 
openly  accessible  form.  This  is  the  case  of  Germany,  Italy  and  the  Netherlands.  For 
research purposes, MSs could provide plot-level information (as in Pucher, Neumann and 
Hasenauer, 2022). On the other hand, public access to aggregated NFI data exists in most 
MSs.  

None of the MSs publish open access the real coordinates of all the plots, but for scientific 
purposes, these data can be obtained upon request, as in Sweden, Finland, and Germany. 
Moreover,  Sweden  provides  an  openly  accessible  database  where  the  coordinates  of 
temporary sample plots - along with the forest information surveyed in them - are reported 
from 2007 to 2021. Indeed, these temporary plots were only surveyed once within each 
Swedish NFI campaign. 

The  availability  of  publicly  accessible  NFI  data  is  not  reported  for  Greece,  Denmark, 
Latvia, and the Netherlands (SoEF, 2020). 

Table 17: Availability of plot-level and tree-level information.  

MS 

AT 

BE 

BG 

CY 

CZ 

DE 

DK 

Plot-level data 
availability 

Upon request 

Upon request 

- 

- 

- 

Public 

- 

Tree-level data availability  Language 

- 

- 

- 

- 

Public 

- 

122 

Local 

 
 
 
      
      
 
 
 
 
 
EE 

ES 

FI 

FR 

GR 

HR 

HU 

IE 

IT 

LT 

LU 

LV 

MT 

NL 

PL 

PT 

RO 

SE 

SK 

SL 

Upon request 

Public 

Upon request 

Upon request 

- 

Upon request 

- 

- 

Local 

- 

- 

- 

- 

Public 

Public 

Local - EN 

- 

- 

- 

- 

Public 

Public 

Local 

Upon request 

Upon request 

Public (for temporary 
plots) 

Public 

- 

- 

- 

- 

- 

- 

Local 

Different definitions and methods 

To  ensure  the  specific  objective  of  data  comparability,  forest  variables  across  the  EU 
should be based on common definitions. For some variables also the standardization of 
methods is needed, especially for biodiversity indicators that are sensible to the size of the 
sampling  unit.  In  Europe,  NFIs  adopted  different  basic  definitions  and  methodologies, 
leading  to  inconsistencies  and  lack  of  comparable  data.  In  this  context,  the  need  for 

123 

 
 
 
 
 
 
 
      
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
harmonization  among  MSs  reporting,  especially  regarding  the  definition  of  forests,  is 
pivotal. In fact, even if all countries based their national definition on the extent, percentage 
of tree crown cover and tree height, a difference exists between member states on these 
criteria (when reporting is available). According to the FAO – FRA standard definition, 
forest is defined as “land spanning more than 0.5 hectares with trees higher than 5 meters 
and a canopy cover of more than 10 percent, or trees able to reach these thresholds in situ. 
It does not include land that is predominantly under agricultural or urban land use.”  

A minimum height of 5 meters is used in the majority of MSs. Indeed, 20 MSs use this 
threshold (74%), while 6 MSs (22%) uses a minimum height of 2 meters, and just one MS 
use a minimum height of 3 meters (4%). On the other hand, the criterium used for minimum 
size area is further diverse. 10 MSs (37%) uses the same criterion as FAO – i.e., 0.5 ha - 
while 7 MSs (26%) uses a minimum size of 0.1 ha. The remaining MS uses a minimum 
size of 0.3 ha (11%), 1 ha (11%), 0.25 ha (7%) or 0.05 ha (4%) respectively. Finland uses 
both 0.25 ha and 0.5 ha. Lastly, approximately half of MSs use a minimum crown cover 
of 10% as a criterion (48% - 13 MSs), while the rest uses higher percentage, namely 20% 
(26% - 7 MSs), 30% (22% - 6 MSs), and 25 (4% - 1 MS), of crown coverage. Totally, 6 
MSs  use  the  same  forest  definition  as  FAO  –  FRA  (22%),  namely  Denmark,  Finland, 
France, Italy, Lithuania and Sweden. In particular, Finland and Sweden adopted a second 
national definition of forest. Here, forest is also defined as “a land capable of producing an 
annual increment of volume growing stock of at least 1 m3 per ha per year over the rotation 
under the most favorable tree species composition, and not used for any other purpose than 
forestry or forestry related purposes”.  

Table 18: Summary of Member States forest definition criteria.  

MS 

Crown cover (%) 

Height (m) 

Area (ha) 

FAO-FRA 
harmonization 

FAO – 
FRA 

10 

5 

0.5 

- 

AT 

BE 

BG 

CY 

CZ 

DE 

DK 

EE 

ES 

FI 

30 

20 

10 

10 

20 

10 

10 

30 

20 

10 

2 

5 

5 

5 

5 

5 

5 

2 

3 

5 

124 

0.05 

0.5 

0.1 

0.3 

0.5 

0.1 

0.5 

0.5 

1 

0.25/0.5 

X 

X 

 
 
 
 
 
 
 
 
 
 
FR 

GR 

HR 

HU 

IE 

IT 

LT 

LU 

LV 

MT 

NL 

PL 

PT 

RO 

SE 

SK 

SL 

10 

25 

10 

30 

20 

10 

30 

10 

20 

30 

20 

10 

10 

10 

10 

20 

30 

5 

2 

2 

5 

5 

5 

5 

5 

5 

5 

5 

2 

5 

5 

5 

5 

2 

X 

X 

X 

X 

0.5 

0.3 

0.1 

0.5 

0.1 

0.5 

0.1 

0.5 

0.1 

1 

0.5 

0.1 

1 

0.25 

0.5 

0.3 

0.25 

Currently, the only variable that could possibly achieve a good level of harmonization at 
the European level is forest area. For other forest variables, such as growing stock volume, 
biomass, deadwood, or carbon content, much work is still necessary to clarify definitions 
so  that  estimates  can  be  directly  compared  or  aggregated  for  international  reporting 
(Rondeux et al., 2012, Gschwantner et al., 2019, Gschwantner et al., 2022). Hence, while 
the  FAO  had  some  success  in  harmonizing  definitions  for  their  reports,  only  MS-level 
totals are published. 

To eliminate this gap standardization or harmonization procedures can be applied, both of 
them are based on common agreed definitions at international level. If common definitions 
are not agreed, then the only solution is to acquire the data with multiple definitions. A 
typical example is Finland where the NFI uses both a national  forest definition and the 
FAO standard definition. In this way, the NFI can provide estimates on the basis of both 
definitions.  

125 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Integration of Earth Observation  

Differences among MSs forest monitoring frameworks relate also to the use of EO within 
NFIs. Indeed, while most countries currently implement Earth Observation sensing within 
their  forest  monitoring  frameworks,  along  with  fieldwork,  eight  MSs  have  not 
implemented it yet. This is the case of Bulgaria, Croatia, Cyprus, Estonia, Germany, Malta, 
Romania and Slovakia. 

On the other hand, these countries could benefit from external research combining earth 
observation  with  ground  data  acquisition,  mostly  occurring  at  test  sites.  Here,  the  EO 
methods used are related to the analysis of satellite imagery, aerial photogrammetry and 
Airborne Laser Scanning (ALS) data. In this context, Sweden and Finland provide virtuous 
examples of  efficient integration between  NFI and EO, where the databases are openly 
accessible,  and  up-to-date  maps  and  results  are  provided.  Thus,  in  Finland,  two  forest 
inventory systems are used, the NFI - conducted by the Natural Resources Institute Finland 
(LUKE) every 5-10 years, collects information on national and regional forest resources - 
and  the  remote-sensing  based  inventory  carried  out  by  the  Finnish  Forest  Centre 
(Metsäkeskus)  that  implement  laser  scanning  to  assess  forest  stock  and  management 
activities. On the other hand, many MS currently cannot benefit from this integration, even 
if progresses have been made. This is the case of France and Denmark. Here, NFI provides 
maps that are usually only visible in GIS online, and countries could benefit from national 
research activities frameworks, which are much more advanced than in other countries. 
Similar situations occurred in Italy, Poland, Germany and Ireland, where research activities 
are currently carried out to develop maps based on NFI data at national level. Many other 
MS  –  Spain,  Portugal,  Slovakia,  Czech  Republic,  Austria,  Lithuania,  Latvia,  Greece, 
Belgium, Slovenia and the Netherlands – are currently conducting research at test areas, 
developing  maps  mostly  related  to  species  composition.  On  the  other  hand,  no  further 
information on the integration of EO and NFI, or on related research activities, has been 
available for Luxemburg, Malta, Cyprus, Romania, and Bulgaria. 

Table 19: Summary - how is EO currently integrated in forest monitoring programs in the 
different EU countries? 

Integration 
NFI - EO 

done 

Classes 

Countries 

the  NFIs 

The  NFI  is  fully  integrated  with 
multisource remote sensing, a long list 
of  multiple  spatial  products  are 
available,  full  open  access  policy 
adopted, long research track. The link 
between 
forest 
disturbance monitoring, especially for 
forest  logging  mapping,  is  relatively 
less  evident  and  relevant  data  is  not 
integrated  in  the  NFI.  The  Finnish 
maps from the NFI are more difficult 
to access and are mainly available in 
local language only. 

and 

Sweden, Finland 

126 

 
 
 
The NFI provides maps, usually only 
visible  in  GIS  on  line,  research 
activities in the country are advanced 
and carried out at national level 

The NFI does not provide maps but 
research  activities  in  the  country  are 
advanced  and  carried  out  at  national 
level 

The  NFI  provides  maps  only  for 
species 
Research 
composition. 
activities  still  do  not  demonstrate 
examples  of  country  level  wall-to-
wall  spatial  estimation  of  forest 
variables.  

The  NFI  does  not  provide  maps, 
research is mainly in test areas 

No information available 

France, Denmark, Germany 

ready 

Italy, , Ireland, Poland 

Spain, Portugal, Slovakia, Czech 
Republic,  Austria,  Lithuania, 
Latvia, Greece 

Advanced 

Belgium, Slovenia, Nederlands 

not yet ready 

Luxemburg,  Malta,  Cyprus, 
Romania, Bulgaria 

Summing up, table 20 informs about today’s survey-based forest monitoring systems. 

Table 20: National Forest Inventories in the EU 

MS 

Indicators 

NFI interval 

AT 

21 

BE 

31 

The  field  measurement  period  lasted  for  3 
years.  The  sampling  grid 
is  systematically 
divided into three parts so that each year one 
third of the grid (covering the whole country) is 
inventoried.  

According to the current sampling design, half 
of  the  plots  visited  annually  are  re-measured 
after  5  years  to  assess 
increments;  the 
remaining  plots  are  re-measured  after  15 
years. 

1x0.5 

BG 

CY 

CZ 

DE 

/ 

/ 

23 

20 

Until  now,  due  to  the 
resources, Bulgaria has not started a NFI. 

lack  of  financial 

The NFI occurred once 

/ 

/ 

In 2016, the third cycle began on a continuous 
basis with a five year re-measurement period. 

2x2 

The  programmed 
successive cycles is 10 years.  

interval  between 

two 

4x4 

127 

NFI 
density (km) 

sampling 

NFI-
based EO 

EO method(s) - including 
external research 

3.889 x 3.889 

x 

•  Aerial 

photogrammetry 
•  Satellite imagery 
•  LIDAR 

•  Aerial 

photogrammetry 
•  Satellite imagery 
•  ALS 

•  Satellite imagery 

•  Satellite imagery 

•  Aerial 

photogrammetry 
•  Satellite imagery 

•  Satellite imagery 

x 

/ 

/ 

x 

/ 

 
 
 
 
 
 
MS 

Indicators 

NFI interval 

NFI 
density (km) 

sampling 

NFI-
based EO 

EO method(s) - including 
external research 

DK 

17 

Approximately  one-third  of  the  plots  are 
permanent  and  are  re-measured  in  every  5-
years cycle 

EE 

15 

The Estonian NFI is based on a grid of sample 
plots, covering the entire country, a quarter of 
which  is  permanent  and  re-measured  every 
five years 

2x2 

5x5 

EL 

20  

No  further  NFI  campaign  were  carried  out  in 
Greece after 1992. 

Random  process 
of  selection  on 
95220 photo-plots 

ES 

FI 

21 

19 

The  programmed 
successive cycles is 10 years.  

interval  between 

two 

1x1 

Starting from the 10th NFI (2004–2008) a five-
year  rolling  system,  so  called  “panel  system” 
has  been  used,  meaning  that  one  fifth  of  NFI 
plots are measured each year over the whole 
country, and the whole sample is measured in 
five years. 

6x6 - 7x7 - 10x10 

x 

FR 

22 

Since 2010, the sampling strategy is composed 
of  point  systematically  revisited  5  years  after 
the first visit 

1x1 

4x4 

HR 

15 

HU 

IE 

IT 

17 

22 

17  

LT 

21 

LU 

LV 

MT 

NL 

20 

15 

/ 

20 

The planned time interval between inventories 
is 10 years and the period for field assessments 
of  the  entire  area  of  the  Republic  of  Croatia 
should  take  no  more  than2  years.  Currently, 
the NFI in Croatia was carried once 

The full cycle was completed by sampling 1/5 
of the nodes each year in a cycle of 5 years.   

4x4 

Ireland NFI occurs on a 5-years basis, between 
the starting date of cycles. 

2x2 

The  programmed 
successive cycles is 10 years.  

interval  between 

two 

1x1 

Since  the  beginning  in  1998  (1998-2002)  the 
NFI  has  been  implemented  on  a  continuous 
basis  with 
years 
remeasurement cycle 

interval  of 

an 

5 

4x4 

The  programmed 
successive cycles is 10 years.  

interval  between 

two 

1x0.5 

The  programmed 
successive cycles is 5 years.  

interval  between 

two 

4x4 

No NFI 

time 

current 

the 
The 
measurements of the NFI5 and NFI6 is 7 years, 
but the planned cycle is 4 years 

span  between 

/ 

1x1 

128 

x 

/ 

x 

x 

x 

/ 

x 

x 

x 

x 

x 

x 

/ 

x 

•  Aerial 

photogrammetry 
•  Satellite imagery 
•  ALS 
•  Aerial 

photogrammetry 
•  Satellite imagery 
•  ALS 

•  Satellite imagery 

•  Aerial 

photogrammetry 

•  ALS 

•  Aerial 

photogrammetry 
•  Satellite imagery 
•  ALS 

•  Aerial 

photogrammetry 
•  Satellite imagery 
•  ALS 
•  Aerial 

photogrammetry 
•  Satellite imagery 

•  Satellite imagery 

•  Satellite imagery 

•  Aerial 

photogrammetry 
•  Satellite imagery 
•  ALS 
•  Satellite imagery 

•  Aerial 

photogrammetry 

•  ALS 

•  Satellite imagery 
•  ALS 

•  / 

•  Aerial 

photogrammetry 

•  ALS 

 
 
MS 

Indicators 

NFI interval 

NFI 
density (km) 

sampling 

NFI-
based EO 

EO method(s) - including 
external research 

PL 

PT 

RO 

SE 

SI 

SK 

14 

21 

17 

19 

22 

15 

Each  tract  located  in  forest  area  is  revisited 
after 5 years. 

4x4 

The  programmed 
successive cycles is 10 years.  

interval  between 

two 

2x2 

The Romanian NFI is designed as a continuous 
forest inventory with a five-year cycle. 

2x2 

Annual  NFI  plots'  assessment.  Permanent 
clusters  are  re-inventoried  with  five-year 
intervals 

Permanent cluster 
[squares]:  300m-
800m-1000m-
1200m; 
Temporary cluster 
[rectangular/squa
re]:  300x600m  - 
400x800m 
- 
1500m - 1800  

The inventorying is to be caried out periodically 
(5-10 years)  

4x4 

The  programmed 
successive cycles is 10 years.  

interval  between 

two 

4x4  

x 

x 

/ 

x 

x 

/ 

•  Satellite imagery 
•  ALS 

•  Aerial 

photogrammetry 

•  Satellite imagery 

•  Aerial 

photogrammetry 

•  ALS 

•  Aerial 

photogrammetry 

•  ALS 
•  Aerial 

photogrammetry 

•  ALS 

Figure 28: Historical timeline of sample-based NFIs in 23 European countries over time as presented by Gschwantner et al 

(2022).  

What kind of EO data? 

129 

 
 
 
 
For the NFIs, and in general for forest monitoring, the most useful type of remotely sensed 
data is Airborne Laser Scanning (ALS). Based on LiDAR point data, it is in fact possible 
to develop very accurate models for estimating many forest variables, not just those based 
on species composition, or to volume/biomass/carbon, but also those related to structural 
diversity,  under  canopy  vegetation,  etc.  ALS  is  in  general  acquired  not  specifically  for 
forest applications and thus the moment and characteristics of the acquisition are frequently 
not optimized for forest applications. Moreover, depending on scale economies, it can be 
expensive and the raw point clouds over large areas are still very large dataset that cannot 
be easily manipulated in a fast way. As a result, ALS cannot yet be acquired with the same 
frequency of satellite data.  

GEDI  data,  acquired  by  LiDAR  on  board  of  the  International  Space  Agency  is  an 
interesting source of information but their use is still related to research activities. Future 
possible Satellite Laser Scanning missions could become a relevant source of information 
for forest applications. 

In second position we have a more traditional source of information provided by optical 
sensors, with multiple bands acquired in the visible and infrared wavelengths. The most 
used satellite for such applications was Landsat. With a 30 m resolution, a 16 day revisit 
time, 7 bands, and an uninterrupted time series dating back to 1972, Landsat images were 
the most common source of information for estimating forest variables until the advent in 
2015 of Sentinel-2 images. Operated by ESA in the framework of the Copernicus system, 
the EU EO program, Sentinel-2 satellites have more bands, a higher frequency (5 days) 
and  a  smaller  pixel  (10  m).  Sentinel-2  images  can  be  considered  nowadays  the  most 
important  satellite  source  of  information  for  monitoring  EU  forests.  The  main  limiting 
issues  for  optical  imagery  are  related  to  cloud  coverage  and  to  the  so  call  “saturation 
effect”.  When  the  top  canopy  cover  is  full,  additional  changes  in  the  amount  of  wood 
volume/biomass cannot be easily detected. A long list of other optical data was used as an 
alternative or in conjunction to Landsat imagery, especially before the advent of Sentinel-
2, including but not limiting to SPOT and ASTER imagery.  

In third position microwave data acquired by Synthetic Aperture Radar (SAR) satellites. 
They have the major advantage of being able to operate also in adverse meteorological 
conditions. Different applications exist for L, C and X bands but most usually this data 
complement ALS or optical imagery. 

5.2.1 Further information on indicators 

Methodology 

The  first  step  in  the  selection  of  indicators  and  parameters  for  Table  21  was  a 
comprehensive screening exercise to identify all relevant indicators and forest data being 
currently monitored or and/reported in existing forest monitoring and reporting schemes 
and frameworks. The main  identified reporting frameworks were  SoEF report165, FAO-

165 Forest Europe 2020 

130 

 
 
 
 
 
Global  FRA166  and  forest  and  forestry  data  collected  by  EUROSTAT167.  Other 
international monitoring frameworks considered were ICP Forests, while on the EU level 
the  Copernicus-based  EFFIS  and  other  forest  data  gathered  by  the  Copernicus  Land 
Monitoring  Service  were  included  in  the  overview.  The  overall  overview  similarly 
includes  indicators  whose  monitoring  and  reporting  is  obliged  under  existing  EU 
legislation, mainly the LULUCF Regulation and Habitats Directive, and those which are 
part  of  legislative  proposals  adopted  by  the  Commission,  namely  the  proposal  for  a 
Regulation on Nature Restoration168 and the proposed amendment of Regulation (EU) No 
691/2011, introducing Forest and Ecosystems Accounts169.  

As next step, this wider selection of indicators was compared against forest monitoring 
needs as identified in: 

• 

• 

the report of the Standing Forestry Committee’s Ad hoc working group on forest 
information 170;  

the views  of the stakeholders expressed in  the  OPC (see Annex  II) on both  the 
perceived importance of monitoring a specific indicator  and their assessment of 
the current quality of the; and 

•  an internal analysis of new policy needs stemming from the objectives of recently 
adopted strategic documents such as EU Biodiversity Strategy for 2030 and the 
new  EU  Forest  Strategy,  as  well  as  needs  to  strengthen  the  implementation  of 
existing legislation such as the Habitats Directive and the LULUCF Regulation.  

These indicators were then categorised into four broad categories: Biomass resources and 
management, Forest bioeconomy, Forest health and resilience, and Forest protection and 
biodiversity.  

Taking this selection of indicators and forest data and following the step-wise approach 
suggested by Policy Option 2, the list further specifies key indicators which would most 
likely  be  considered  for  their  inclusion  already  in  the  proposal  of  the  basic  act.  This 
selection was based in considering all four of the following aspects: links to priority policy 
and strategic objectives, availability of common definitions and methods for the relevant 
indicator, current status of monitoring and reporting in the Member States, and the need 
for higher spatial or temporal resolution compared to the existing monitoring and reporting.  

The remaining indicators in the list would be considered potential candidates for inclusion 
within the monitoring system at a later stage, depending on the evolution of policy needs 
and advice of the expert group envisioned to be set up under all policy options. 

Where  no  additional  requirements  are  foreseen  in  terms  of  higher  spatial  resolution  or 
frequency of data collection for indicators that are  reported under legislative obligations 
are monitored by or reported to the Commission services or the EEA without a legislative 
framework (e.g. forest fire-related indicators under EFFIS) or are reported to international 

166 FAO 2020 
167 https://ec.europa.eu/eurostat/web/forestry  
168 COM/2022/304 final  
169 COM/2022/329 final  
170 Standing Forestry Committee 2012 

131 

 
 
 
 
frameworks such as FAO FRA or Forest Europe , such indicators are not considered to be 
within the scope of the proposed legislation. A non-exhaustive list of these indicators is 
shown in the last part of Table 21.  

Where, on the contrary, additional requirements are foreseen to complement existing legal 
monitoring obligations, the indicator is included within the scope of the proposal. 

Forest soil-related indicators which could be within the scope of the upcoming Soil Health 
Law proposal are not included in the table because the present initiative does not foresee 
to impose additional reporting requirements on such indicators.  

The choice of including an EO requirement for the monitoring of certain indicators was 
based on information acquired both from external experts in two technical workshops171 as 
well as an internal  analysis by the JRC which identified indicators for which EO-based 
monitoring brings clear benefits in terms of the required data quality. This was analysed 
against the frequency and spatial resolution requirements of each indicator in order to fulfil 
their expected role in policy- and decision-making.  

For  instance,  EO  was  considered  an  essential  monitoring  method  for  meeting  the  data 
requirements of monitoring disturbances, for which high frequency and spatial resolution 
is important to provide useful information for the purposes of early warning and timely 
forest management interventions – hence the indicated EO obligation. 

Regarding the spatial and temporal data resolution, expected needs were identified for most 
indicators  to  be  considered  for  the  legislative  proposal  of  the  basic  act  based  on  a 
preliminary  analysis  and  expert  advice  acquired  in  the  workshops  organised  for  the 
purposes of the Impact Assessment.  

As the last step, a mapping exercise was done per indicator on their coverage in Member 
States, looking at whether each indicator was either reported in the SoEF 2020 report or 
monitored in Member States’ NFI, as shown in the analysis of national monitoring systems 
that is available in the final report172.  

In  order  to  report  information  for  the  SoEF  reports,  many  countries  use  the  forest  data 
collected during the NFI process. However, this is not always the case. In many Eastern 
European  countries,  particularly for older  reporting periods, forest  management records 
(stand-level  inventories)  were  used  for  reporting  to  SoEF  –  e.g.  forest  regeneration, 
invasive species, forest damages, naturalness. While most countries now have developed 
NFIs, still for some indicators data may be a combination of NFI and forest management 
records or even solely based on such records. Hence, differences between the data collected 
in NFI and the data presented in the SoEF report for some of the indicators can be explained 
by the fact that the SoEF is not exclusively based on the NFI data.

171 The workshops were organised with the help of external consultants and took place online on 25 October 
and 30 November 2022. See the final report [to be published with the IA] 
172 See the final report [to be published with the IA] 

132 

 
 
 
Table 21: Overview of indicator and parameters  

Indicators and 
parameters 
and their key policy 
areas 

Inclusion in 
the proposal 
of the basic 
act  

EO requirement 
included in the 
proposal 

Data Resolution 
needs (spatial 
and temporal) 

Current Monitoring and 
Reporting  

Existing or proposed 
legal obligations  

Data availability 
SoEF  

Data availability 
NFI  

Link to policy objectives 

Biomass resources and 
management  

Forest bioeconomy  

Forest health and 
resilience  

Forest protection and 
biodiversity  

Marked 
indicators to 
be considered 
for their 
inclusion in the 
proposal of the 
basic act  

Marked 
indicators to be 
considered for a 
mandatory EO 
monitoring in the 
legal proposal  

Needs identified 
for the legislative 
proposal  

Frameworks in which the 
indicator is already being 
reported 

x - in force  
(x) - proposed by COM  

Reported by EU27 
countries [number 
of reporting 
countries for the 
latest reporting 
year in 
SOEF2020]  

Number of countries 
monitoring a given 
indicator as 
identified in the 
analysis of NFIs 

Link to a legal obligation 
or a strategic policy 
target 

Indicators and parameters included under sub-option 2.1 

Forest area (and annual 
changes)  

X 

X 

Annual updates 

Copernicus-
HRL/CLC/SoEF/Eurostat 

x  

LULUCF Regulation  
--------------------------------
-- 
(x) 
Forest and Ecosystem 
Accounts proposed 

26 

Informs reporting on land 
use change under LULUCF 
Regulation 

26 

AT BE BG CY CZ DE 
DK EE EL ES FI FR HR 
HU IE IT LT LU LV NL 
PL PT RO SE SI SK 

Regulation on 
deforestation free 
products (identifying 
deforested areas) 

133 

 
 
 
 
 
 
 
  
  
 
  
 
 
under amendment of 
Regulation (EU) No 
691/2011 

(x)  

Forest and Ecosystem 
Accounts proposed 
under amendment of 
Regulation (EU) No 
691/2011 

Regulation on 
deforestation free 
products (link to forest 
degradation)  

26 

DK EE EL AT BE BG 
CY CZ DE ES FI HR IE 
IT LT LU LV NL PL PT 
SE SI RO SK HU FR 

LULUCF regulation – 
information on tree cover 
changes to inform 
estimates of carbon stock 
changes on forest land 

Renewable Energy 
Directive – link to 
sustainability criteria 
relating to minimising 
clearcuts  
Habitats Directive – the 
EEA typology is aligned 
with Annex I habitats 
categorisation  

Allows stratification of 
forest data according to 
forest type -  informs 
implementation of 
Adaptation Strategy on 
climate impacts across 
the types 

26   

- 

Tree cover density  

X 

X 

Annual updates  

Copernicus – High 
Resolution Layers (3 year 
cycle)  

Forest type (EEA 
typology) 

X 

Plot level data   

SoEF/Copernicus HRL 
Forests/Corine Land 
Cover – only 3 to 4 forest 
types 

ICP Forests Level I – EEA 
typology 

134 

 
 
  
 
 
 
 
 
 
   
 
 
Growing stock (volume) 

X 

X 

Structure (dbh classes) 

X 

Aboveground Biomass   

X 

X 

Plot level data 

5 year monitoring  
frequency  

SoEF/ FAO FRA  

(x)  

Forest and Ecosystem 
Accounts proposed 
under amendment of 
Regulation (EU) No 
691/2011 

Plot level data; 

5 year monitoring  
frequency  

SoEF  

(x)  

Nature Restoration 
Regulation Proposal  

Annual updates, 
integration of 
areal laser-
scanning data 
with ground 
observation   
required  

LULUCF/SoEF/ESA 
Biomass Climate Change 
Initiative 

x  

LULUCF Regulation  

Net annual increment 
of growing stock 
volume (on all forest)  

X 

Reporting based 
on the latest NFI  

SoEF  

(x)  

Forest and Ecosystem 
Accounts proposed 
under amendment of 
Regulation (EU) No 
691/2011 

22  

20  

22  

18  

24 

AT BE BG CZ DE DK 
EE EL ES FI FR HR HU 
IE IT LT LU LV NL PT 
RO SE SI SK  

25 

AT BE BG CZ DE DK 
EE EL ES FI FR HR HU 
IE IT LT LU LV NL PL 
PT RO SE SI SK 

21 

AT BE BG CZ DE DK 
EE EL FI FR HR HU IE 
IT LT LU LV PT RO SE 
SI  

18 

AT BE BG CZ DE EE 
ES FI FR HU IE IT LT 
LU LV NL PT SE  

Evolution of EU timber 
resource important for 
the implementation of 
the Bioeconomy Strategy  

Informs carbon stock 
change reporting under 
LULUCF Regulation  
Data on forest structure 
allows assessments 
related to forest 
resilience (Adaptation 
Strategy), biodiveristy 
(nature restoration 
Proposal) and carbon 
stocks (LULUCF) 

Informs reporting under 
LULUCF Regulation on 
carbon stock changes  

LULUCF Regulation – NAI 
as an indicator for forest 
growth and carbon sink 

Adaptation Strategy – 
indicator of forest health 
and resilience 

135 

 
 
 
 
 
 
 
  
 
 
  
 
 
  
 
 
Roundwood removals  

X 

X 

Annual 

ESTAT (JFSQ) 

Main management 
objective (production/ 
protection of soil and 
water/biodiversity 
conservation/social 
services/multiple use) 

EU supply,uses and 
trade of woody biomass 
(energy and material) 

Wood energy - 
feedstock sources 
(primary/secondary 
biomass)  

Harvested quantity and 
market value of non-
wood forest products 

X 

X 

X 

18 

26  

EE AT BG CZ DE ES FI 
IE LT LV NL PT SE SI 
RO SK HU FR 

25 

AT BE BG CZ DE DK 
EE EL ES FI FR HR HU 
IE IT LT LU LV NL PL 
PT RO SE SI SK  

LULUCF Regulation – 
informs reporting on 
emissions from 
harvesting 

Bioeconomy Strategy – 
links to the objective of 
‘managing natural 
resources sustainably’ 

Forest Strategy – informs 
on progress towards the 
objective of 
multifunctionality of 
forests 

Bioeconomy Strategy – 
improving knowledge on 
the current forest 
biomass supply and 
demand  
Renewable Energy 
Directive – improves 
knowledge basis on the 
application of the 
cascading principle 
Forest Strategy – informs 
on progress towards the 
objective of 
multifunctionality of 
forests 

Geographically 
explicit data on 
location  

FAO FRA   

Annually 

ESTAT (JFSQ and JWEE) 

Annually 

ESTAT (JFSQ and JWEE) 

X 

Governance Regulation 
 (EU) 2018/1999  

17  

2 

DK LV  

SoEF/FRA 

22 

/ 

136 

 
 
 
 
 
 
 
   
   
 
 
   
 
 
 
 
 
 
 
 
Value of marketed 
forest services 

Defoliation  

Forest Habitat types 
location (Annex I of 
Habitats Directive)  

Tree species richness 
and composition  

Naturalness  

x 

X 

X 

X 

SoEF/INCA 

12 

Forest Strategy – informs 
on progress towards the 
objective of 
multifunctionality of 
forests 

/ 

24 

x 

More frequent 
than monthly 
updates   

ICP Forest/Copernicus   

x  

CLRTAP 

X 

ICP Forests  

BE BG CY CZ DE DK 
EE EL ES FI FR HR HU 
IE IT LT LU LV MT NL 
PL PT SI SK 

Adaptation Strategy – 
information on climate 
impacts on forests 

Geographically 
explicit data on 
location 
(improved 
granularity) 

Plot level data 

5-10 years 

Spatially explicit 
information on 
the location of 
the forest areas 
divided into 

Habitats Directive 

 Annex I of Habitats 
Directive 

SoEF  

20  

26 

AT BE BG CY CZ DE 
DK EE EL ES FI FR HR 
HU IE IT LT LU LV NL 
PL PT RO SE SI SK 

  x 

Regulation on 
deforestation free 
products 

23 (using a 
different 
definition of 
naturalness than 

4 

BE CZ LT RO 

SoEF  

137 

Habitats Directive – 
improved 
implementation through 
monitoring of the 
habitats 
Allows stratification of 
forest data according to 
dominant tree species -  
informs implementation 
of Adaptation Strategy on 
climate impacts across 
different forest types 

Information on the 
presence of invasive 
species (IAS Regulation)  
Informs the 
implementation of the 
Regulation on 
deforestation free 
products  

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
  
 
 
 
 
 
 
naturalness 
classes  

intended for the 
legal proposal) 

21  

19 

16  

Introduced tree species  

SoEF  

Deadwood - volume 
and type 
(standing/lying)  

Threatened forest 
species  

Invasive forestspecies  

X 

x 

x 

Plot level data 

CBD/ SoEF  

SoEF, Habitat Directive 
Reporting if in Annex II  

Geographically 
explicit data on 
invasive forest 
species 

  Surveillance system 
under Article 14 of the 
IAS Regulation 

(x)  
Nature Restoration 
Regulation Proposal    

X 

Habitats and Birds 
Directive 
x 

Invasive Alien Species 
(IAS) Regulation   

Additional indicators and parameters included under sub-option 2.2 

Silvicultural regime 
(Clear-cutting/ 
continuous 
cover/coppice etc.)  

X 

X 

Aggregate 
national data on 
forest area per 

138 

(Using a different 
definition of 
naturalness than 
intended for the 
legal proposal) 
3 

ES FI RO  

25 

DK EE EL AT BE BG 
CZ DE ES FI HR IE IT 
LT LU LV NL PL PT SE 
SI RO SK HU FR 

10 

BE BG ES FI LU LV PT 
SE SK FR  

3 

ES FI RO  

- 

Informs on progress 
towards the proposed 
nature restoration targets 

Informs reporting on the 
Deadwood carbon pool 
udner the LULUCF 
Regulation   
Informs on the presence 
of Annex II species of 
Habitats Directive in 
forest ecosystems 
IAS Regulation- 
Information on the 
presence of invasive 
species  

25 

AT BE BG CZ DE DK 
EE EL ES FI FR HR HU 

Tracking the 
implementation of the 
Forest Strategy’s goal of 

 
 
 
 
 
   
 
 
 
 
 
 
 
 
 
 
 
 
   
   
   
 
silvicultural 
regime 

Plot level data 

IE IT LT LU LV NL PL 
PT RO SE SI SK  

promoting close-to-
nature forestry 

Renewable Energy 
Directive – link to 
sustainability criteria 
relating to minimising 
clearcuts  

LULUCF regulation – 
information on tree cover 
changes to inform 
estimates of carbon stock 
changes on forest land 

Adaptation Strategy – 
informs on climate 
impacts on forests and 
facilitates risk 
preparedness, 
assessment of forest 
resilience and adaptation 
needs 

Forest disturbance  
recorded in terms of 
area size and volume 
distinguished by:  

regular harvest; 

storm; 

drought; 

fire;  

biological agents;  

Forest degradation  

X 

X 

For early warning 
through EO – at 
least monthly 
updates 

For aggregated 
datasets with 
disturbance agent 
attribution – 
annual updates  

EFFIS (for wildfires) and 
Drought Observatory 

 SoEF and FAO FRA  

16  

22 

AT BE BG CY CZ DE 
DK ES FI FR HR HU IE 
IT LT LU LV NL PT SE 
SI SK  

No, instead 
including 
forest 
naturalness 
classes as 
defined in the 
Regulation on 

6  

- 

139 

 
 
 
 
 
  
  
 
 
 
 
 
   
 
 
 
 
 
   
   
   
deforestation 
free products   

Tree mortality  

Old growth and primary 
forest area  

X 

Geographically 
explicit data on 
location 

Diversity of non-tree 
plant species  

x 

Plot level data  

18 

AT BE BG CZ DE EE 
ES FI FR HU IE IT LT 
LU LV NL PT SE  

- 

Linked to the ambition of 
the Biodiversity Strategy 
to map and protect all 
remaining primary and 
old-growth forests in the 
EU 

12 

BE BG CZ DE FI 
FR HR LU LV PT SE SK  

Renewable Energy 
Directive – link to 
sustainability criteria 
relating to no-go areas in 
primary and old-growth 
forests 

5 

AT BE ES IE LT  

Reported data may 
inform benchmarking 
related to assessment of 
sustainable forest 
management (Forest 
Strategy)   

Relevant indicators and parameters where no additional monitoring requirement was identified 

140 

 
 
 
 
 
   
   
 
 
 
 
 
 
 
 
 
   
   
   
 
 
Forest Area 
available/not available 
for Wood supply  

Forest management 
plan (share of forest 
area)  

Third-party certification 
(share of forest area) 

Gross value added of 
forest sector 

Net revenue 

Investments in forests 
and forestry 

Forest Sector 
employment 

Regeneration type  

ESTAT/SoEF/FAO FRA  
JRC FAWS mapping  

(x)  

Forest and Ecosystem 
Accounts proposed 
under amendment of 
Regulation (EU) No 
691/2011 

FAO FRA/FRA   

SoEF/UNECE/FAO 

SoEF/ESTAT 

SoEF/ESTAT 

SoEF 

SoEF/ESTAT 

SoEF  

141 

25  

24 

27 

22 

19 

25 

22 

18 
AT BE BG CZ DE EE 
EL ES HR HU IT LU LV 
PL PT SE SI SK  

5 

BG HU RO NL LV  

 
 
 
 
 
 
   
 
 
 
 
   
   
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
   
 
 
Burnt areas (size)  

Active fires (number)  

x 

x 

Wildfire risk  

Deposition and 
concentration of air 
pollutants   

Soil condition (pH, CEC, 
N, C, …) -C/N ratio, 
nitrate, nitrate leaching  

EFFIS  

EFFIS  

EFFIS  

ICP Forest  

ICP Forest  

Common forest bird 
species  

x 

PECBM/Birds Directive 
Reporting  

142 

/ 

/ 

25 

AT BE BG CY CZ DE 
DK EE EL ES FI FR HR 
IE IT LT LU LV MT NL 
PL PT SE SI SK 
22 

BE BG CY CZ DE DK 
EE EL ES FI FR IE LT 
LU LV MT NL PL PT 
RO SI SK  

12 

N/A 

BE BG CZ ES FI IT LU 
LV NL PT SE FR 

x  

CLRTAP 

x  

CLRTAP 

X  

Birds Directive 
----------------------------- 
(x)  

Nature Restoration 
Regulation Proposal  

 
 
  
 
 
  
 
 
 
  
 
 
  
 
 
 
 
 
 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Protected forests  

Geographically 
explicit data  

SoEF/ESTAT/Natura 
2000/EEA GIS Map  

Forest connectivity  

x 

 SoEF/JRC 

x  

Habitats and Birds 
Directives (Special 
Areas of Conservation 
and Special Protection 
Areas)  
(x)  
Nature Restoration 
Regulation Proposal    

17 

17  

EE AT BE BG CZ DE 
ES FI IT LT LU LV PT 
SE SI MT HU 

143 

 
 
 
 
 
  
 
 
 
 
 
   
 
Based on the analysis carried out in the Table 21, we were able to determine the overall 
indicator  coverage  of  the  different  policy  areas  in  each  Member  State,  considering  all 
indicators and parameters. Table 22 below shows the relative coverage.  

Table 22: Indicator coverage per MS across different policy areas 

Biomass 
resources and 
management 

Forest 
bioeconomy 

Forest health 
and resilience 

Forest 
protection and 
biodiversity 

Austria 

Belgium 

Bulgaria 

Cyprus 

Czechia 

Germany 

Denmark 

Estonia 

Greece 

Spain 

Finland 

France 

Croatia 

Hungary 

Ireland 

Italy 

Lithuania 

Luxembourg 

Latvia 

Malta 

Netherlands 

Poland 

Portugal 

Romania 

Sweden 

Slovenia 

Slovakia 

92% 

92% 

92% 

33% 

92% 

92% 

83% 

92% 

83% 

92% 

83% 

83% 

92% 

92% 

83% 

92% 

83% 

83% 

92% 

8% 

83% 

83% 

92% 

83% 

92% 

92% 

92% 

100% 

78% 

78% 

100% 

89% 

89% 

89% 

89% 

56% 

56% 

100% 

100% 

100% 

67% 

56% 

67% 

89% 

56% 

89% 

33% 

67% 

89% 

89% 

78% 

100% 

100% 

100% 

50% 

100% 

83% 

67% 

83% 

83% 

100% 

83% 

50% 

83% 

100% 

83% 

83% 

50% 

100% 

67% 

83% 

83% 

83% 

50% 

83% 

67% 

83% 

50% 

67% 

67% 

83% 

62% 

77% 

62% 

8% 

69% 

46% 

54% 

54% 

15% 

77% 

69% 

62% 

62% 

54% 

46% 

54% 

62% 

54% 

69% 

8% 

62% 

54% 

54% 

46% 

62% 

54% 

54% 

5.2.2 Harmonisation and standardization  

In order to ensure the specific objective of data comparability, forest indicators across the 
EU  should  be  based  on  common  definitions  and  approaches.  This  objective  can  be 
achieved 
two  different  ways:  harmonisation  or  standardisation.  While  data 
harmonisation  is  concerned  with  making  data  from  different  sources  compatible  and 
comparable, data standardisation is concerned with establishing and enforcing standards 
for  data  to  ensure  its  quality  and  consistency  (Box  1).  Depending  on  the  existence  and 

in 

144 

 
 
  
 
quality  of  data  for  individual  indicators,  harmonisation  or  standardisation  may  be  the 
appropriate approach. 

Box 2: Harmonisation and standardisation 

Harmonisation utilises available data and translates them into an agreed system, in order that data collected 
and derived through different methods become comparable. The process typically involves identifying and 
resolving  differences  in  the  definitions,  structures,  formats,  or  meanings  of  the  data.  The  goal  of  data 
harmonisation is to make it easier to work with data from different sources, and to enable the integration of 
data  from  multiple  sources  to  provide  a  more  comprehensive  view  of  a  subject  or  phenomenon.  Data 
harmonisation can be time consuming and resource intensive, and in some instances it can be challenging to 
resolve differences between different data sources. 

Standardisation refers to the process of establishing and implementing standards for data, in order to ensure 
that data is collected, stored, and used consistently and accurately. It defines a common standard and forces 
pertinent systems to adopt this standard. Data standards can include rules or guidelines for data formats, data 
quality, metadata, and other aspects of data management. The goal of data standardisation is to improve the 
interoperability, reliability, and usability of data, and to facilitate the exchange and sharing of data between 
different organisations or systems. Data standardisation may require the development of new tools or methods, 
and it may be challenging to reach consensus on data standards. 

5.3 Forest-related planning in the EU 

A  National  Forest  Strategy  is  a  strategic  document  that  defines  the  overall  direction  of 
forest policy and planning (in the absence of a strategy, a legal instrument such as a forest 
law or code might be seized). 

A  National  Forest  Programme  is  an  instrument  that  includes  a  suite  of  measures  to 
implement  a  strategy  on  national  level  (e.g.  research  initiative,  funding  instrument, 
communication campaign). 

A Forest Management Plan addresses the operational level, i.e. concrete actions how to 
manage forests on sub-national level (not to be mistaken with planning instruments at the 
level of the undertaking). 

The table below provides an overview of current forest strategies or equivalent instruments 
in the EU, which have been categorised according to their official labelling to the extent 
possible. 

Table 23: Forest strategies or equivalent instruments in the EU 

Planning Instrument 

Austria 

National  Forest  Strategy  or 
other  document  if  NFS  is 
lacking 

National  Forest  Strategy 
2020+ 

(a) National Forest 
Programme  

(b) Forest Management Plan 
(c) Other planning instrument 
(a)Created in 2005 

145 

 
 
 
Planning Instrument 

National  Forest  Strategy  or 
other  document  if  NFS  is 
lacking 

No National Forest Strategy 

(a) National Forest 
Programme  

(b) Forest Management Plan 
(c) Other planning instrument 
(c)Regional long-term visions 
(Flanders 2017/2018) 

Belgium 

Bulgaria 

Croatia 

Cyprus 

Czech Republic 

Denmark 

Estonia 

Finland 

France 

Germany  

Greece 

Hungary 

National  Forest  Strategy 
2013-2020  

No  programme  or  similar 
instrument could be identified 

National  Forest  Strategy 
published in 2003 

(b)Every 10 years 

No  National  Forest  Strategy, 
but Forest Law of 2012 

(c)Forest  Policy  Statement, 
2013 

National  Forest  Policy  up  to 
2035;  National  Forest  Act  of 
1995 amended in 2021 

(a)for the period of 2013, still 
under implementation 

Danish  Forest  Act  of  2004 
amended in 2019 

(a)Created in  2002, amended 
in 2018 

The  process  to  develop  a 
forest strategy until 2030 was 
launched  in  2019;  currently: 
Forest Policy 1997 

(a)Programme 
2016-2020, 
evolved from National Forest 
Act 2013, formerly 2006 

National Forest Strategy 2025   (a)&(b) regularly revised 

Forest  Code;  Law  for  the 
future of food, agriculture and 
forests enacted in 2016 

National  Forest  Strategy 
2050, before: National Forest 
Strategy 2020 

National  Forest  Strategy 
2018-2038 

(a)National Forest and Wood 
Program (2016-2026) 

(a)Set-up  1999-2006,  but  no 
definite endpoint of activities 

Forest  Management  Plans 
Forest 
National 
and 
Programme for forest fires. 

National  Forest  Strategy 
2016-2030 

(a)&(b) existing 

146 

 
 
Planning Instrument 

Ireland 

Italy 

Latvia 

Lithuania 

Luxembourg 

Malta 

Netherlands 

Poland 

Portugal 

National  Forest  Strategy  or 
other  document  if  NFS  is 
lacking 

National  Forest  Strategy 
draft 
2014-2020. 
National Forest Strategy 2022 
– 2030 published 

New 

(a) National Forest 
Programme  

(b) Forest Management Plan 
(c) Other planning instrument 
(a)NFP as basis for NFS 

National  Forest  Strategy 
2014-2020 

(a)New  Programme  as  of 
2019, valid for 20 years 

No  National  Forest  Strategy; 
but  National  Forest  Policy 
amended  in  1998  &  Law  on 
forests 

(c)National  Forest  Policy 
amended  in  1998  &  Law  on 
forests  responsible  for  forest 
management 

Amendment  of  the  Law  on 
Forest  (last  amendment  in 
2018);  new  National  Forest 
Sector  Strategic  document  is 
under preparation 

A draft law on a New Forest 
Code  was  placed  before 
Parliament in January 2018 

strategy 

for 
Outline 
implementation  of  a  national 
restoration  and  afforestation 
project 

National  Forest  Strategy  for 
2030 was launched in 2020 

(a)Forestry 
Sector 
Development Programme for 
2012-2020 

(a)Programme 
&(b)Management Plan 

of 

2003 

No  Programme  or  similar 
could be identified 

(b)Although 
forest 
management  plans  are  not 
required  by 
is 
generally presumed that most 
forest areas are included in a 
long-term management plan 

law, 

it 

No  National  Forest  Strategy 
could  be 
identified,  but 
Forestry  Act  of  1991  and 
national forest policy, 1997 

(b) existing 

National Forest Strategy 2015  (b)  & 

(c)regional 

forest 

programmes 

147 

 
 
Planning Instrument 

Romania 

Slovakia 

Slovenia 

Spain 

Sweden 

National  Forest  Strategy  or 
other  document  if  NFS  is 
lacking 

National  Forest  Strategy 
2018-2027 

(a) National Forest 
Programme  

(b) Forest Management Plan 
(c) Other planning instrument 
(a) existing 

Forest Act amended in 2018 

(a)approved in 2007 & (b) 

No  National  Forest  Strategy 
could be identified 

(a) Programme of 2007 & (b) 
existing 

Forest  Act  of  1993  serves  as 
reference 

Spanish  Forestry  Plan  2002-
2032 and Forestry Law lastly 
modified in 2015 

process 

(a)A  NFP 
has 
resulted in a Spanish Forestry 
Plan 2002-2032 

National  Forest  Programme 
of 2018 based on Forestry Act 
with  the  most  recent  major 
amendments in 2014 

(a)National 
Forest 
Programme launched in 2018 
& (b) existing 

148 

 
 
Currently, several planning instruments address forests from specific policy perspectives, without coordination and communication among departments 
and services involved. Moreover, these instruments often do not have same reporting cycles nor duration making comparability of relevant information 
difficult.  

The table below presents an overview of current forest planning instruments in the EU. 

Table 24: forest planning instruments in the EU 

Planning instrument 

Forest-related dimension 

Reporting/reviewing  interval 

Commission action (approval, 
recommendation, acknowledgement) 

MS that have 
submitted the plans 
(latest applicable 
round) 

National  Forestry  Accounting 
Plans  

Forest  Reference  Level  in  the 
context of LULUCF 

Once  for  the  period  from  2021  to 
2025 

Technical assessment 

All EU MS 

National  or  regional  adaptation 
strategies  

Forestry (sector) 

compliance 

5-year 
comprehensive  review  process 
2027 and 2032 

check:  
in 

Comprehensive review by EEA 

All EU MS 

National  Energy  and  Climate 
Plans  

Decarbonisation, 
energy and energy efficiency 

renewable 

10-year  long  cycle,  update  at  5-year 
and  progress  reports  on  a  biennial 
basis 

Assessment 
recommendations  

and 

country-specific 

All EU MS 

Long-Term Strategies 

CAP Strategic Plans 

Decarbonisation, 
energy and energy efficiency  

renewable 

Every 10 years; update every 5 years, 
where  necessary.  At  least  30  years 
perspective 

Assessment 

Financial  instrument  to  support 
(afforestation, 
investments 
agroforestry,  prevention 
and 
restoration of damage, provision 
services  etc), 
of  ecosystem 

From  2023  to  2027.  One  yearly 
amendment possibility 

Formal approval 

All  EU  MS  ex.  IE,  PL, 
RO 

All  EU  MS 
have 
submitted  the  CAP  SP 
(FI,  IE,  LU,  NL,  SE 
forestry 
no 
foresee 

149 

 
 
Planning instrument 

Forest-related dimension 

Reporting/reviewing  interval 

Commission action (approval, 
recommendation, acknowledgement) 

management  commitments  and 
horizontal  measures  (advisory 
services, cooperation etc) 

Circular  economy  and  waste 
management;  biodiversity  and 
natural capital; climate action 

Overview  of  the  measures  and 
financing  that  are  needed  to 
implement  the  EU-wide  Natura 
2000  network  –  including  for 
significant area covered by forest 
habitats 

Variable 
forest-related 
dimension depending on country 
circumstances 

Environmental  Implementation 
Reviews 

Prioritised  Action  Frameworks 
for Natura 2000 

National  Biodiversity  Strategies 
or Action Plans 

MS that have 
submitted the plans 
(latest applicable 
round) 

measures  with  CAP 
funds);  

BE  has 
plans 

two  regional 

First in 2016, previous EIR in 2019, 
latest review by COM in 2022 

Review/recommendation 

All EU MS ex. HR, LU 

Financing  programmes,  the  present 
one  2021-2027  was  due  by  end  of 
as 
2021 
deemed appropriate by MS 

(previous  2014-2020); 

Assessment 

N.A. 

Reporting  intervals  varying  between 
5 and 10 years, depending on MS and 
consecutive  submissions  (EU  BDS: 
revised NBSAP by end of 2021, or as 
min.  submit  national  commitments 
for the most important targets + there 
should be regular review cycle) 

150 

All  EU  MS  except  DK 
(Jan.2022 situation)  

and 

All  EU  MS,  except  LT 
in 
(chapter 
policy 
environmental 
guidelines) 
SE 
(integrated 
environmental  policy);  
2030-strategies 
in  NL 
and PT, updates ongoing 
(AT,  BG,  DE,  FI,  FR, 
HU, IE, IT, SK) 

 
 
Planning instrument 

Forest-related dimension 

Reporting/reviewing  interval 

Commission action (approval, 
recommendation, acknowledgement) 

MS that have 
submitted the plans 
(latest applicable 
round) 

National Ecosystem Assessments  Ecosystem  services  (state  and 

Irregular at country initiative 

N.A. 

Management  plans  of  Natura 
2000 sites 173 

N2K – Article 17 reporting 

trends) 

plans, 
Forest  management 
integration 
conservation 
of 
objectives and measures (such as 
deadwood, old  trees,  old-growth 
forests  and  a  diverse  structure) 
for  the  purposes  Habitats  and 
Birds and Birds Directives 

Conservation status and trends in 
forest habitats, restoration needs, 
status  and  trends  in  forest  bird 
species;  pressures  for  habitats 
and species 

Planning  obligation  depends  on  MS 
and can be also varying by region 

N.A. 

Every  6  years  (2001,  2007,  2013, 
2019, next planned for 2026) 

Assessment (EEA) 

National  Bioeconomy  Strategies 
and Action Plans  

Biomass 
bioresources, 

production, 
bioproducts, 

N.A. 

N.A. 

173 https://ec.europa.eu/environment/nature/natura2000/management/docs/conservation%20measures-Annex%202.pdf 

151 

BG, CZ, DE, ES, IT, NL, 
PL, PT, FI,  

Countries where national 
obligation  are  in  place: 
CZ, DK, EE, ES, FR, IE, 
LT, LU, NL, PL, SE, SI 

Countries  where  sub-
national  obligations  are 
in place: AT, BE, DE 

ES,  EE,  DK,  DE,  CZ, 
CY, BG, BE, AT, SK, SI, 
SE,  RO,  PT,  PL,  NL, 
MT, LV, LU, LT, IT, IE, 
HU, HR, GR, FR, FI 

All  EU  MS 
have 
Bioeconomy  Strategy  at 

 
 
 
 
 
Planning instrument 

Forest-related dimension 

Reporting/reviewing  interval 

Commission action (approval, 
recommendation, acknowledgement) 

bioenergy  (emphasis  given  to 
dimensions, 
sustainability 
ecosystem 
for 
example,  biodiversity  varies); 
innovation 
RTDI, 
biotechnological solutions 

services  or, 

reduction 
Disaster-risk 
strategies  (Sendai  Framework 
2015-2030  UNDRR.org) 

forest 
Variable  attention 
depending on the significance of 
forest related risks 

to 

yearly 

National Forest Risk assessment 
Plans 

To identify and evaluate risks to 
forests,  including  natural  (biotic 
and  abiotic)  disturbances,  and 
detrimental impacts from climate 
change or human activities 

N.A. 

N.A. 

N.A. 

MS that have 
submitted the plans 
(latest applicable 
round) 

national  level,  ex.  EE, 
DE,  BE,  SL,  GR,  BG, 
RO  which  have  other 
initiatives 
policy 
dedicated to bioeconomy 

Variable 
criterion 

number 

by 

No EU-level requirement 

National 
Europe  

reports 

to  Forest 

6  criteria  and  35  quantitative 
indicators  (describing  the  forest 
status and changes) as well as 17 
qualitative indicators (describing 
forest  policies, 
the  national 
institutions 
instruments 
towards SFM) 

and 

Approx. 5 yearly 

Not Applicable 

All EU MS 

152 

 
 
 
 
 
 
 
Table 25: planning instruments and initiatives regarding bio-economy in the EU 

Country 

Austria 

Forest bioeconomy (main 
documents) 
National Bioeconomy Strategy 
National Forest Strategy 

Level 

Elements covered  

national 

Optimised tree species 

Several mentions 

Belgium 

Bioeconomy Strategy in Flanders 

regional 

Forests mentioned as sources of biomass & in relation to sustainable resource use 

Bulgaria 

Croatia 

Cyprus 

Czechia 

Bioeconomy strategy for the Stara 
Gora region 
National Forest Policy and Strategy 
2020 
no indication of substantial plans or 
strategies relating to the forest 
bioeconomy 
Ministry of Agriculture, 
Bioeconomy Concept 

regional 

national 

Information about the use of forest for purposes of  bioeconomy and overall goal to sustainably manage 
forests 
Sustainable climate-neutral development; Using bioneric raw-material for sustainable, circular economy 

national 

Agroforestry & bioeconomy as a tool to reinsure the sustainable use of natural resources, incl. forestry 

National Forest Policy up to 2035 

Proper recognition to wood as a renewable strategic material and its use in bioeconomy 

Bioeconomy Platform of the Czech 
Republic 

Denmark 

Energy Political Agreement 2018 

national 

Estonia 

Promotion of Renewable Energy 
Act 2018 
General Principles of Climate 
Policy until 2050 
Climate Change Adaptation 
Development Plan until 2030 

Objectives of the Platform are to deepen knowledge in the respective fields of bioeconomy by means of 
research  and  education  and  to  promote  their  use  in  practice  at  the  level  of  enterprises  and  public 
administration while respecting principles of sustainable development 
Speed up the transition from coal-based heat and power to biomass-based platforms allows for grants to 
be provided for biomass-based production of electricity. The Political Agreement was updated in 2018 
Promote the use of renewable energy sources, which includes, a.o., biomass energy sources 

national 

Promotes SFM and the positive effect it has on the carbon stock 

The  use  of  wood  is  continuously  promoted  and  the  carbon  stock  in  wood  products  and  buildings  is 
increased, thereby replacing the use of non-renewable natural resources 

153 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Forest bioeconomy (main 
documents) 
Estonian Forestry Development 
Programme until 2020 

Level 

Elements covered  

Country 

Finland 

France 

Germany 

National Forest Strategy 2025 
The Finnish Bioeconomy Strategy 

national 

National Forest and Wood Program 
National low carbon strategy 
The National Bioeconomy Strategy 
BMEL Forest Report 
Forest Strategy 2050 

national 

national 

Greece 

National Bioeconomy Strategy 
National Forest Strategy 

Hungary 

Ireland 

National Forest Strategy 
Presentation on bioeconomy 
“Power4Bio” 
National Forest Programme 

National Policy Statement on the 
Bioeconomy 

national 

national 

national 

Italy 

National Forest Strategy 

national 

Sets the objectives to use wood as a renewable resource in industry and energy sector up to the amount of 
annual  increment.  Wood  industry  is  inclining  towards  long  term-wood  products  incl  wooden  houses. 
Proportion of wood fuels as resource of primary energy has been ca 16% annually. Transformation of 
fossil fuel boiler houses into wood fuel ones has been publicly supported 
The role of forests, sustainable forest management and forest-based bioeconomy 
Forest Strategy as foundation for the Bioeconomy Strategy, from which the marginal conditions related to 
the availability and growth of Finnish forest biomass can be determined 
Reference to the National Bioeconomy Strategy and to the uses of wood 

Several references about variety of uses of biomass and new materials 
Long-lasting wood products, cascading use of wood, substitution of non-renewable materials 
Information and goals until 2030: The cultivation of site-appropriate tree species is further supported; The 
Charter for Wood 2.0 dialogue process is strengthened; The wood construction rate is increased; Resource 
policy with wood is expanded; The knowledge about wood production and use is strengthened; Regional 
value-added and supply chains of the resource wood are strengthened; Resource-efficient wood utilization 
is strengthened 
Sustainable climate-neutral development; Using bioneric raw-material for  sustainable, circular economy 
Recognition of the value and enhancement of the contribution of forest ecosystems to the bio-economy 
and the circular economy 

Role of forests in bioenergy is emphasized 
Overview and objectives of the Hungarian bioeconomy strategy 

Priority 5c: Facilitating the supply and use of renewable sources of energy, of by products, wastes, residues 
and other non-food raw material for purposes of the bio-economy 
Several mentions of forestry as one of the sources for the bioeconomy, e.g. on p. 7 of the Statement it says: 
“Approximately 10.7% of Ireland is under forests which produce 3.2 million cubic metres of material each 
year and this is forecasted to increase to 8 million by 2035.” 
Improve  resource  use  efficiency  by  optimizing  the  multifunctional  contribution  of  forests  to  the 
development of the bioeconomy and forest economies and rural and inland areas interior of the country, 

154 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Country 

Forest bioeconomy (main 
documents) 

Level 

Elements covered  

Latvia 

National Bioeconomy Strategy 
National Bioeconomy Strategy 

national 

Lithuania 

Lithuanian Bioeconomy Strategy 

national 

also promoting the expansion and enhancement of forests in urban and suburban settings to improve well-
being and environmental quality 
Forestry as part of the biodiversity strategy 
The vision of the Latvian bioeconomy development strategy  – the bioeconomy industries in Latvia are 
innovation leaders in maintaining, increase, effective and  sustainable use of natural capital value in the 
Baltic States. The goal of the strategy is to keep employment in the traditional sectors of the bioeconomy 
in  2030  at  the  level  of  2015,  i.e.,  128  thousand  people.  Forest  sector  as  important  part  of  Latvia’s 
bioeconomy can contribute with potential to increase the economic value of the forest and higher added 
value product production in wood working sector 
Exploration of the potential of the forest and forest-based sector 

Forestry Sector Development 
Programme for 2012-2020 

Forest as source for biofuels 

Luxembourg  National Forest Programme 
Malta 

no indication of substantial plans or 
strategies relating to the forest 
bioeconomy 
National Forest Strategy 

Netherlands 

Climate Agreement 2019 

The Transition Agenda, 2018 

Poland 

no indication of substantial plans or 
strategies relating to the forest 
bioeconomy 

national 

Wood Production and Carbon Storage 

national 

Aim to stimulate high-quality use of wood and reduce its use for energy, in line with efforts to stimulate 
bio-based construction in the context of the circular economy and the sustainable sequestration of carbon 
in materials 
Stimulate  the  use  of  wood  and  other  natural  products  for  construction  and  renewable  energy.  Balance 
emission of GHG on the one hand and the sequestration of greenhouse gases and production of renewable 
energy and biomass on the other hand 
Five  roadmaps  for  different  industries  (including  construction  and  biomass  and  food)  setting  out  the 
agenda for these industries to become circular by 2050. Promoting the use of bio-based material such as 
wood 

155 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Country 

Portugal 

Forest bioeconomy (main 
documents) 
Action Plan for Sustainable 
Bioeconomy – Horizon 2025 
(Government Order 183/2021) 

Romania 

National Forest Strategy 

Slovakia 

Slovenia 

CELEBio bioeconomy dossier (Bio 
Based Industries Joint Undertaking 
under the EU Horizon 2020 under 
grant agreement No 838087) 
National Forest Programme 

Overview of state of play on 
bioeconomy in Slovenia (Ministry 
of Agriculture, Forestry and Food) 

Level 

Elements covered  

national 

national 

national 

national 

Promotion of active sustainable forest management; 
Scale up the unity of management areas (ex: from Integrated areas of Landscape Management to Forest 
Management Unities & land tenure reform); 
Strengthening research, development & Innovation, envisaging the sustainability of raw materials supply 
and along the value chains, is too considered of outmost relevance to promote bioeconomy based on forests 

Increasing the competitiveness and sustainability of forest-based industries, bioenergy and the bioeconomy 
as a whole 
Biomass supply from forestry 

Promote the use of lower quality wood, wood residues, waste wood and waste wood products for energy 
and biofuels, including second-generation biofuels, in compliance with environmental standards 
Overview of strategic documents and target sectors 

Spain 

Sweden 

Spanish Bioeconomy Strategy 
Spanish forest strategy 

Sweden`s National Forest 
Programme 

national 

national 

The Swedish bioeconomy strategy 
– work in progress 
National forestry accounting plan 
for Sweden 

Description of benefits and best practices for forestry-related production 
Timber as a source of bio-energy - Reference to EU energy policy & exploration of possibilities Promotion 
of the use of forest products, extensive livestock and forest tourism 
Sweden`s  forest  industry  to  become  a  world  leader  in  creating  and  utilizing  innovation,  sustainably 
producing processed forest products for a growing bioeconomy, and satisfying the demand for sustainable, 
fossil-free products and services in global markets 
An  inquiry  on  a  national  bioeconomy  strategy  is  ongoing.  It  will  present  its  suggestion  for  a  national 
bioeconomy strategy by 31 October 2023 
Forests  as  “green  gold”  to  contribute  to  employment  and  sustainable  growth;  main  aim:  LULUCF 
Reporting 

156 

 
 
 
 
 
 
 
 
 
 
 
 
157 

 
 
 
5.3 - SWOT Analysis for integrated long-term forest planning in the EU174 

A SWOT provides a structure for a systematic analysis of factors relating to a new product, 
technology,  management,  or  planning;  and  includes  both,  internal  factors  (strength  and 
weakness)  and  external  factors  (opportunities  and  threats).  The  influence  of  an  internal 
factor entirely derives from the study object, whereas external factors originate from the 
outside the object and can either be positive (opportunities) or negative (threats). In the 
context of this analysis, ‘internal’ is defined as national level, while ‘external’ refers to 
interplay between EU and Member States. 

To operationalise the general SWOT structure, for each of the four elements (strengths, 
weaknesses, opportunities, and threats) a number of factors are defined along which the 
analysis is then structured (Table 26).  

Table 26: Overview of the SWOT factors for integrated forest plans 

Positive 

Strengths  

Negative 

Weaknesses 

Comprehensive  national  policies  and 
instruments  that  can  create  synergies 
and  help  further  develop  integrated 
forest plans  

National policies and instruments that 
are  missing  or  likely  to  hamper 
further 
synergies 
and 
forest 
development  of 
plans  

the 
integrated 

t
n
e
m
n
o
r
i
v
n
E

Opportunities 

Threats 

institutional, 
technological 

social, 
Political, 
economic, 
and/or 
sectoral  and  cross-sectoral  features 
which  create  positive  potential  for 
further uptake of integrated forest plans 

institutional, 
technological 

social, 
Political, 
economic, 
and/or 
sectoral  and  cross-sectoral  features 
which  create  negative  potential  for 
further  uptake  of  integrated  forest 
plans 

l
a
n
r
e
t
n
I

t
n
e
m
n
o
r
i
v
n
e

l
a
n
r
e
t
x
E

SWOT analysis 

The SWOT analysis is to identify a list of key issues that are relevant for the development 
of integrated long-term forest plans (IFPs) from national and EU’s perspectives. As this 
relates to all 27 EU Member States in summary, not every element is valid for each country, 
but tries to identify certain patterns, that might be considered for the set-up of IFPs. 

174 Based on the Study on Member States country fiches on forest monitoring and planning instruments (to 
be published...).  

158 

 
 
 
 
 
 
 
 
 
Table 27: Overview of SWOT factors for integrated forest plans 

Positive 

Strengths  

Negative 

Weaknesses 

t
n
e
m
n
o
r
i
v
n
E

•  Comprehensiveness  of  planning 

documents 

•  Lacking strategies responding to 
major forest-related EU topics 

•  Existing  national  expertise  as  key 

•  Incoherence of planning 

for forest planning 

instruments 

•  Established stakeholder networks 
•  National Forest Programmes 

Opportunities 

•  Missing coordination and 

communication 

•  Too many emerging issues 
Threats 

•  Further 
schemes 

develop 

monitoring 

•  Planning 

as 

part 

of 

the 

subsidiarity 

•  Harmonise funding schemes 
•  Guidance  for  connecting  different 

•  Lack  of 

trust 

in  new  EU 

instruments 

objectives 

•  Improve clarity on impacts of new 

•  Uncertainty for forest owners 
•  Unclarity on impacts of integrated 

EU instruments 

forest plans 

l
a
n
r
e
t
n
I

t
n
e
m
n
o
r
i
v
n
e

l
a
n
r
e
t
x
E

Outline of factors 

Strengths 

•  Comprehensiveness of planning documents 

In most countries, there is long history of planning of forest management and other 
forest-related issues (e.g. water, biodiversity). These instruments have been constantly 
modernized, yet they are not always intertwined. For IFPs these sources provide a good 
starting  point  in  many  countries  as  regards  data,  objectives,  and  implementation 
instruments. 

•  National expertise as key forest planning 
  National forest expertise is widely perceived as key asset for forest planning. There are 
long-lasting  structures,  proven  interrelations  between  administration  and  forest 
owners/managers,  and  function  control  mechanisms  in  place.  IFPs  will  require 
involvement  of  national  experts  and  making  use  of  national  governance  and 
communication structures as well as bottom-up initiatives. 

•  Established stakeholder networks 

Stakeholder organisations and associations are set up in most countries and build an 
essential  backbone  in  forest  governance  and  in  connection  policy  and  practice. 
Participatory stakeholder involvement is one of the key success factors for strategic 

159 

 
 
 
 
 
 
 
 
 
 
 
 
processes,  and  SPs  bear  the  opportunity  to  broaden  the  gathering  beyond  sectoral 
boundaries. 

•  National forest programmes 
  National forest programmes exist in many countries and are proven tools for a multi-
stakeholder dialogue. Ideally, they are also adaptive to bringing new strategic issues 
together.  IFPs  could  build  on  such  processes  where  existent,  and  demonstrate  good 
practices on how strategic planning can be performed combining both EU goals and 
national competences. 

Weaknesses 

•  Lacking strategies responding to major forest-related EU topics 
  Currently,  the  forest  policy  arena  is  developing  dynamically.  Since  forest-related 
policies are a cross-cutting matter it is difficult to find comprehensive and long-term 
collection  for  implementation  of  EU  instruments,  even  on  national  levels.  This 
phenomenon  might  also  be  referred  to  as  policy  fragmentation.  IFPs  might  be  an 
instrument to overcome this fragmentation. 

•  Incoherence of planning instruments  

Forests are directly or indirectly subject to a variety of planning instruments, also on 
national level. This can lead to horizontal incoherence among instruments both in terms 
of goals, content, competences, terminology and planning horizon, and may hamper 
their implementation in actual forest management. 

•  Missing coordination and communication 
  Missing coordination happens often if both there is a split/partial overlap in national 
competences,  and  if  there  is  no  cross-sectoral  exchange  or  conflict  between  forest 
stakeholders and others. IFPs might be platform that stipulates such exchange between 
authorities, administrations, and stakeholders. 

•  Too many emerging issues 

In recent years, things around forests and forestry changed quickly. For both forests 
and  administration,  this  makes  it  difficult  to  move  due  too  economic  and  capacity 
constraints. IFPs would need to lift such issues that first require tactical response to a 
strategic and prospective level. 

Opportunities 

•  Further develop monitoring schemes 

An EU-wide forest monitoring instrument can build on a variety of national monitoring 
instruments as a solid ground for further development. In addition, synergies should be 
sought with other reporting schemes (e.g. global forest reporting). Currently, there are 
a lot of activities and funding ongoing for further developing forest monitoring, which 
will give new impetus and grounding to IFPs. 

•  Harmonise funding schemes 

160 

 
 
 
 
 
 
 
 
 
  EU forest funding is often less prioritised compared to other sectors. It is an opportunity 
to harmonise and substantiate funding on the basis of IFPs. This entails aspects such 
as, conservation, carbon sequestration, and provision of other ecosystem services. 

•  Guidance for connecting different objectives 
  The EU Forest Strategy contains a certain level of complexity, as does forest-related 
policy in general. Guidance in wake of IFPs on how to balance the different objectives, 
create synergies in forest management and handle trade-offs would make the outcome 
of the process more tangible. 

•  Improve clarity on impacts of new EU instruments 
  Creating clarity on the wealth of new instruments that have a connection to forests (e.g. 
taxonomy, zero deforestation) and how they are interrelated or should incorporated in 
IFPs might be an asset. 

Threats 

•  Planning as part of the subsidiarity 

Forest Planning is widely seen as clear competence of the Member States according to 
their national priorities, and especially forest-rich countries with a highly developed 
forest sector either don’t see the need for a new instrument or are in opposition. The 
success of IFPs will depend on untangling this situation. 

•  Lack of trust in new EU instruments 

There is a certain level of mistrust by many countries on turning things upside down in 
forestry domain with a wealth of new instruments, especially legal ones. Lack of trust 
is a clear threat to the uptake and implementation of IFPs. 

•  Uncertainty for forest owners 

Additional legal frameworks may increase the uncertainty of forest owners about the 
background of a new instrument on monitoring and integrated long-term planning and 
the interference with their management practices (e.g. whether it is used to control their 
actual management). It requires strong communication to explain the objectives and 
non-objectives of IFPs, and the system boundaries of their application. 

•  Unclarity on impacts of strategic plans 

Unclarity about the instrument of IFPs and its potential impact on forest management 
might hamper its acceptance and implementation, and create dynamics that undermine 
the instrument. Incoherence between EU- and national instruments, or parallel forest 
policy systems might threaten acceptance of IFPs. 

GAP Analysis 

161 

 
 
 
 
 
 
 
 
This Gap Analysis175 tackles a conglomerate of key forestry issues as regards:  

•  Governance aspects 
•  Status of forests 
•  Development goals 
•  Forest-based economy aspects 
•  Supply and demand, import and export of goods 
•  Potential of ecosystem services 

An integrated long-term forest plan should serve as an instrument that is able to cover a 
heterogeneity of different planning aspects. In this exercise, a gap is considered not only 
an issue that is missing, but also issues that are open, unclear or where new challenges are 
arising. 

While  it  is  difficult  to  summarise  EU-27  countries,  some  patterns  of  gap  issues  can  be 
identified: 

•  There is no homogeneous approach towards National Forest Programmes (NFP) in 
the countries. NFP can be seen as a potent starting base for integrated forest plans, 
as they are designed as major strategic and participatory process on forest topics. It 
might be an idea to look into good practice examples for NFPs, and how they stand 
in relation to integrated forest plans. For instance, in Austria has been a continuous 
process  on  a  dialogue  on  forests,  generating  a  forest  programme  and  a  set  of 
national indicators with target values. 

•  There have been good efforts in further developing and harmonising monitoring 
instruments in the past decades, but the status still varies. This has also historical 
reasons,  because  e.g.  Eastern  European  countries  had  to  set-up  completely  new 
systems. Monitoring efforts by the EC and in numerous research projects are likely 
to improve this gap. 

•  A big issue is still lacking cross-sectoral coordination beyond the forestry sector. 
This  might  lead  to  non-harmonised  and  diverging  planning  and  incentives. 
Umbrella  strategies 
(e.g.  a  biodiversity  strategy)  need  more  specific 
implementation strategies for the forestry sector. 

•  Creating planning instruments while having to reach out to forest owners depends 
a  lot  on  the  forest  governance  regime  in  countries.  For  instance,  in  Eastern 
European  countries  forest  management  planning  is  strongly  tied  to  state 
administration, while in most Western European countries state administration is 
mostly  checking  legality  of  management  and  providing  advisory  services. 

175 Based on the Study on Member States country fiches on forest monitoring and planning instruments (to 
be published...). 

162 

 
 
 
 
 
Integrated  forest  plans  thus  have  to  reflect  this  dichotomy  between  strategic 
elements and practical implementation in different set-ups. 

•  A  variety  of  new  emerging  issues  in  forests  (e.g.  climate  change  –  large  scale 
disturbances, markets) brought new dynamic and particular new uncertainties into 
strategic  planning  of  forests.  Clearly,  many  countries  are  at  a  stage  of 
responsiveness rather than strategic planning. It will need a balanced consideration 
in  the  integrated  forest  plans  on  how  to  deal  with  uncertainties,  risks,  and  to 
implement the mid- to long-term political goals for forests in times where there is 
a lot of concerns about the future of forests and forestry. 
In many country, disturbances are the elemental driver for the future of forests (e.g. 
forest fires in Southern Europe). So, it requires safeguarding fundamental basics in 
forest  management  and  planning  before  enlarging  the  strategic  scope.  A  first 
strategic element might be how to maintain the existence of forests in such areas, 
and support this respectively e.g. via a priority plan. 

• 

•  Little evidence was found on how the inherent trade-offs are dealt with that origin 
from the dichotomy between fostering a bio-economy in parallel with conservation 
and carbon sequestration. Integrated forest plans have the potential to address and 
guide this, because this remains a major gap so far. 

•  Ecosystem  services  and  how  to  make  them  contribute  to  a  viable  forest 
management is often mentioned by countries, while instruments to do so are mostly 
not fully developed. Integrated forest plans can hence bring together elements from 
other EU policy processes that address this issue (e.g. taxonomy). 

The table below gives an overview on the major forest-related issues in EU-27 as identified 
in the analysis of current strategies and instruments176. 

Table 28: Major forest-related issues in EU-27 

Country 

Major issues identified 

Austria 

•  Resolution of interest conflicts arising out of an increasingly urbanised 

society with shifting demands on forests 

•  The dialogue between foresters and hunters on minimizing browsing is still 

ongoing, but didn’t solve the problems sufficiently yet  

•  The recent calamities had big impact on forest owners and the value 

development of their forests, which is particular difficult for small-scale 
owners to handle. There is the danger that forest owners lose motivation, 
which would lead larger areas of unmanaged forests 

Belgium 

•  Forest management plans are compulsory in Brussels, but only partially in 

Flanders and Wallonia 

176 Evidence is strongly built on national planning documents and country reports to different processes e.g. 
Forest Europe, FAO FRA, Natura 2000 reports. 

163 

 
 
 
 
•  High forest fragmentation 
•  Neither National Forest Programme or Strategy, or similar instrument, 

Bulgaria 

• 

could be found 
Insufficient finance and institutional capacities to implement the new 
policies  

Croatia 

Cyprus 

•  Maintaining stable and sustainable financing for forest ecosystems 
•  Large forested areas are still contaminated by landmines from the 
Homeland war. This makes the areas inaccessible for SFM  

•  Additional efforts (such as further digitalisation) is needed to improve the 

traceability of wood/timber  

•  Only a National Forestry Policy and Strategy from 2003, no later version, 
nor National Forest Programme or similar instrument could be found  

•  Forest fires (prevention and management of)  
•  19,54 % of state forests is found in the area of Cyprus beyond the control 

of the Government  

•  High dependence on fossil fuels (and thus imports thereof). Need and 

urgency to develop renewable energy sources  

•  Only a Draft Integrated National Energy and Climate Plan for the period 

2021-2030 could be found 

•  Neither a National Forest Programme, nor Forest Strategy or similar 

instrument could be found 

•  Forest certification, since no forests are under third party certification 

scheme 

Czech 
Republic 

•  Strategies need to be developed to mitigate the increasing demands on 

forests from society and climate change pressures  

•  The economic situation of the forest owners needs to be considerably 

improved 

Denmark  

•  Reliance on imports to satisfy wood and wood-based products demand. 

Challenge to create the obligation to ensure that such imports are produced 
sustainably  

•  Grant schemes prioritize only a few services, which might hinder 

incentives for multifunctional services 

•  A National Forest Programme 2018 and Forest Act 2018 were found, but 

no Forest Strategy 

•  An Energy Political Agreement 2018 and Promotion of Renewable Energy 

Act 2018 exist, but no National Bioeconomy Strategy was found 

Estonia 

•  No National Forest Programme/Plan nor forest Strategy could be found 

Finland 

More efforts should be made to use wood in construction and for bio-based 
energy  

•  The continuing fragmentation and loss of characteristic habitat types and 

populations of important species and their habitats is problematic  

•  Private forest owners need support, also from forest experts 
•  Balancing the various aspects of SFM, including climate change mitigation 
•  Work still remains to be done on boosting the production and profitable 

commercialisation of non-timber forest products. This is emphasized in the 
revised National Forest Strategy 2025 

164 

 
 
France  

•  Easy access to on-line platforms providing mapping data and designing 

Germany  

Greece 

Hungary 

Ireland 

Italy 

Latvia 

Lithuania 

Luxembourg  

new monitoring indicators is needed 

•  No National Forest Programme could be found, however French National 
Forest Strategy, Bioeconomy and Biodiversity strategies were found 
•  Transformation from coniferous to stable deciduous and mixed forest is 

needed to make the forests more resilient against climate change and less 
prone to calamities, such as bark beetle invasions or draughts  

•  There is still high uncertainty about the magnitude of climate change 
impacts on regional and local scale which is needed for optimizing 
decisions on active adaptation measures. Efforts are needed to make 
projections more reliable 

•  Certification of forests is not developed  
•  Completion of forest maps 
•  Shared common ownership of forest area is a challenge for management 
•  High proportion of forestry area covered with non-native tree species 

(36%) requires regulation 
•  Certification of private forests 
• 
• 
• 
•  Better adaptation of sustainable forest management practices, particularly 

Increase efforts at biodiversity conservation 
Increase the forest area through sustainable afforestation 
Improve forest adaptation to climate change 

for the Mediterranean area 

•  Promoting communication actions and awareness of the public opinion on 

the role of forest and forest products 

•  No National Forest Strategy could be found 
•  No national biodiversity strategy and action plan 
• 
• 
• 
• 

Integration of biodiversity targets into the national forest strategy 
Increasing competitiveness of Latvian forest industry 
Increasing the level of skill among people working in the forest sector 
Improvement of forest management regimes, as the current system does 
not completely ensure the protection important forest habitats and is not 
adjusted to the small-scale private forest holdings  

•  Competing needs of society for forests – there is a need to find a new 

balance  

•  Growing demand for non-timber forest services needs to be accounted for  
•  The conflict between the aspirations of better nature conservation and 

more rational forest use needs to be addressed  

•  Spruce monocultures representing 10% of the forest cover are severely 
endangered by climate change and need to be restored to mixed forest 
stands over the next 2-3 decades  

Malta 

•  Safeguard existing habitat areas and explore the possibility of extending 

the network of green areas through tree planting initiatives 

Netherlands 

•  Transformation from coniferous to stable deciduous and mixed forest is a 

key action. This has partly been pushed by the major drought damage to 
Norwegian Spruce and bark beetle attacks on Larch  

•  The trade-offs in values and interests related to forest use need to be 

addressed. e.g., through zoning 

•  No National Forest Programme could be found, but National Forest 

strategy 2020 addresses most crucial aspects 

165 

 
 
Poland 

•  Enhancing expertise & capacities of private forest owners 
•  Research on expected changes in forests due to climate change & their 

mitigation through forests 

•  Promotion and support regarding carbon storage in forest products and 

substitution of non-renewable materials need to be intensified  

•  More detailed regulations and removing legal gaps concerning forests in 

urban areas in order to promote their protection and maintenance 
•  Drafting and implementation of a future National Forest Programme 
•  Promote forest environmental and social services among the population 
•  Engage stakeholders to contribute to sustainable forest management and 

participation & prevent forest risks, mainly fire and pests 

Portugal 

Romania 

•  Forest restitution process in Romania is problematic which results in large 

Slovakia 

Slovenia 

Spain 

areas of disputed and mismanaged forestlands 

•  No national forest strategy could be found 
•  Optimizing legislation on Sustainable Forest Management 
•  Optimizing financing of Sustainable Forest Management 
•  Generally improving Forest Management 
•  Ownership structure (large number of owners - 431,000 and co-owners) 
hinders intensification of forest management. Some owners are not 
interested in income from forests because of small properties, which 
results in low cutting rates. The level of technology applied in harvesting 
in private sector is relatively low. Marketing of timber of small quantities 
is not optimal 

•  Difficult regeneration of forests due to an overabundance of wild animals 

(deer, roe deer) in the forests 
Increased frequency and intensity of natural disasters:  

• 

o 
o 
o 

droughts and ice break following by bark beetle gradations;  
blowdown of trees;  
forest fires 

Improve measures to prevent forest fires 

• 
•  Forest abandonment and depopulation of rural areas is a challenge 
•  Promotion of the use of timber and non-wood forest products among the 

population 

Sweden 

•  Contribute to a rise in the added value of forest products 
•  To maintain and develop a skilled and diverse work force and forest 

owners in an urbanized society 

•  Developing a better understanding of ecosystem services, as seven 

ecosystem services have been identified as having an inadequate status. 
Ecosystem services with an inadequate status were primarily found among 
the regulating and supporting services, but also among some of the 
provisioning services. 

5.4 Further information on the preferred policy option 

Table 29: Problems, drivers, objectives and how these relate to the preferred option 

(Interlinked) 
Problems 

Problem drivers 

Specific objectives 

Preferred 
option  

policy 

166 

 
 
 
Reporting 
obligation  of  data 
collection,  based  on 
common  definitions 
and a common set of 
indicators  reflecting 
needs 
the 
beyond 
existing 
monitoring  EU  and 
international 
frameworks. 
Harmonization 
standardisation  

policy 

and 

Developing  an  EU 
monitoring 
framework with and 
“opt-in” 
EO 
and 
component 
ensure  public  access 
to  timely  and  cost-
efficient  information 
for 
land  managers 
and  owners,  policy 
makers 
and 
stakeholders. 

Common  structure. 
Commission 
issues 
non-binding 
recommendations 

Data quality: Data is 
incomplete, 
inconsistent  and  not 
comparable across the 
EU 

Quality of planning: 
policy 
Lack 
of 
coherence 
and 
planning 
integrated 
long-term 
a 
with 
vision. 

Ensure 
common 
modern,  digitalised, 
consistent, 
comparable, 
timely 
and  accessible  data 
on  the  state  of  EU 
forests. 

Ensure  all  Member 
States  deliver  high-
long-term 
quality 
forests 
for 
plans 
high-
on 
based 
quality  monitoring 
information  related 
to 
EU 
relevant 
policy objectives. 

for 

Regulatory 
failure: 
Existing  rules  relating 
to forests at EU level do 
not  provide 
a 
comprehensive 
monitoring 
biodiversity, 
storage,  health 
resilience 
accessibility 
collected data.  

of 
carbon 
and 
and 
to 

Market failure: Prices 
of forestry products do 
not  necessarily  reflect 
the  impact  of  forestry 
on  biodiversity  and 
climate;  indicators  are 
biased 
historically 
towards 
timber 
production.  

Imperfect  information 
actors 
amongst 
involved 
forestry 
in 
undermines  the  quality 
and coherence of forest 
planning. 

Regulatory  failure  of 
different 
planning-
related  instruments  to 
establish  a  coordinated 
approach at EU level. 

to 

failure 
Regulatory 
due 
scattered 
responsibilities  across 
national ministries with 
different objectives. 

167