’If the Commission’s proposals from recent years had been or will be approved as written, there’d be very little space left for national forest policy, which would be replaced by EU environmental policy,’ says Forest Director Marko Mäki-Hakola.
Forest policy is one of the areas within national competence in the EU, but the Union is attempting to get a strong grip on the use of forests via its climate, agricultural and environmental policies, for example. Forest.fi met with Marko Mäki-Hakola, Forest Director at the Central Union of Agricultural Producers and Forest Owners MTK, to review seven examples of how the EU could impact forest policy.
Mäki-Hakola says that the Commission’s projects are characterized by a strive to improve everything at once, forgetting that going after one goal may be detrimental to others.
’Improving biodiversity may cause losses to forest growth and consequently to carbon sinks. Also, the Commission apparently fails to understand that applying the same rules in all member states will affect their forests in completely different ways,’ says Mäki-Hakola.
1. ’What we expected to be about industry turned into environmental strategy’
Mäki-Hakola begins with the forest strategy adopted last year. It is the third in line and, according to Mäki-Hakola, was necessary in itself.
’MTK also wanted a new strategy, but one that was balanced and understood the requirements of industries. What we got was a protection strategy,’ Mäki-Hakola says.
’A strategy that took account of the needs of industries would deal with such things as forest growth, management and purposes of use, one of which would be the replacement of fossil raw materials and combating climate change. Other things included would be the well-being of regional and national economies and the self-sufficiency of the EU, naturally not forgetting the environment,’ Mäki-Hakola lists.
The content of the first version of the forest strategy was a surprise to Mäki-Hakola, among other things because it obviously promoted a joint forest policy, despite the fact that both the Council and the Parliament had, just a few weeks before, stressed that this is not within the EU competence.
In defence of the proposal it was said that it is just a strategy and thus not binding. However, its purpose was, and is, to steer the preparation of forest issues in the EU.
’And that’s why people constantly make references to it,’ Mäki-Hakola says.
2. ’Taxonomy – strange preparation process’
The taxonomy for sustainable activities is an EU instrument for steering funding to projects that benefit the climate and environment. Mäki-Hakola finds this a good thing. Rather than prohibiting the funding of any project, the taxonomy is meant to help good projects to acquire funding on better terms. If the forest industry wants to acquire funding in line with the taxonomy, it must prove that it is only procuring wood from forests managed in line with the taxonomy.
’As regards forests, implementing the taxonomy will thus be the responsibility of the forest owners. They, however, will not be eligible for funding in line with the taxonomy, and in other respects, too, compliance will only benefit them indirectly, if at all. The forest owners will do the work and pay for the cost,’ Mäki-Hakola explains.
The climate criteria in the taxonomy were finalised in 2021. Mäki-Hakola says that one can live with them.
This is not the case with the nature criteria, the proposal for which was published at the end of November. At this stage, MTK considers the proposal to be unfeasible.
The Commission set three requirements for the taxonomy: it is to be based on scientific research, usable an politically acceptable. In Mäki-Hakola’s opinion, none of these are met in the latest proposal.
According to the proposal, 20 percent of forest that meets the taxonomy requirements should be excluded from commercial use. The size of clear-felling sites would be limited to three hectares in conifer forests and to one in broadleave forests. A 100-metre strip should be left untouched between felling sites for 40 years.
The amount of decayed wood should be 30 cubic metres per hectare in broadleave and mixed forests, and 20 cubic metres in conifer forests, while the current figure is below five. Of the soil on the felling site, 90 percent should be left untouched.
3. ’Biodiversity strategy is manageable’
The EU’s biodiversity strategy would also be non-binding. According to the proposal, each member state should protect, strictly and by law, ten percent of its land and water area and, in addition, 20 percent less strictly and possibly by agreements.
’As such, this is not a problem for Finland, unless we wish to exceed the EU requirements for some reason, as has been proposed by the Finnish Nature Panel. The requirement for strict protection has been met already, and as for the less strict part, work is currently under way to see how much we already have,’ says Mäki-Hakola.
Each member state will make a commitment on this to the Commission. Finns are electing a new parliament next spring, and so the decisions regarding the strategy will only be taken by the next government.
’We should see to it that the means of decision-making remain with national organs and also remember that nature is protected because of nature, not because of the EU,’ Mäki-Hakola says.
4. ’Nature restoration regulation actually deals with forest management’
Mäki-Hakola finds the Commission’s proposal for a Regulation for nature restoration full of problems and requirements that can be interpreted in several ways.
The proposed regulation, which would be applied to nature in its entirety, has caused a hectic debate. As regards forests, it requires restoration to be undertaken on habitats listed in the EU’s Natural habitats conservation directive. 30 percent of the area of deteriorated habitats should be restored to be closer to their natural state.
The share would increase gradually so that ultimately, the restoration activity would apply to most of the area covered by habitats under the Natura scheme. In Finland, examples of such habitats are northern natural forests, herb-rich forests, forests on eskers, and mires.
In addition, habitats should be restored to correspond to the area that they covered at the beginning of the 1950s, which would be beyond the scope of the Natura scheme.
’Why must there be requirements for all forests? Why aren’t the Natura sites enough? With this proposal the EU clearly enters the domain of forest management, which is beyond its competence, says Mäki-Hakola.
The Commission has also estimated the cost and benefit of this exercise to the member states. In Mäki-Hakola’s opinion, the benefit estimate is a pyramid scam, based on such things as the assumed growth of touristic value. The estimates are based on surveys mapping the willingness to pay for certain things in countries with no everyone’s rights.
’Say you’ve got a restored mire, so how many tourists can you assume to attract to it,’ asks Mäki-Hakola.
5. Energy directive would jeopardize Finland’s energy policy
The renewable energy directive defines the conditions under which biomass derived from forests for burning can be included in the renewable energy quota. It does not prohibit the burning of wood as such, but it does say what sort of wood can be included in the national quota for renewable energy. The Union has set targets for this quota.
According to the current proposal, wood taken directly from the forest would not be considered sustainable, which would exclude it from the national quota. On the other hand, wood from forest industry sidestreams could be included. The rationale is that wood should be processed as far as possible and for as long-lived products as possible, and only be used for energy as the last resort.
’It’s a great thought, but it’s a fact that when you fell a tree, some parts of it can only be used for burning. But even in that case they replace fossil raw materials,’ says Mäki-Hakola.
If there is another use for any part of the tree, that is where it will inevitably land.
’Simply because any other use will be more profitable than burning, which means that the seller will get a better price for the wood,’ Mäki-Hakola explains.
Finland’s renewable energy policy was designed on the basis of current EU legislation, and forest biomass plays an important part in it. If the directive is adopted in its proposed form, the Finnish policy will collapse.
6. ’Agreement on LULUCF regulation is acceptable’
The LULUCF regulation deals with how the carbon sinks and emissions in land use, land use change and forestry are taken into account in EU’s climate goals. This has been agreed on quite recently, and Mäki-Hakola characterises the result as ’reasonable, but it was tough going’.
The matter causing the greatest puzzlement as regards forests is the reference level used in the calculations; that is, the level with which the actual carbon sink is compared. The idea is that if the carbon sink has been generated through the normal use of forests, then only a sink that is greater than this will be accepted in international comparison. A maximum value has also been set for acceptable sinks.
If the carbon sink in a member state diminishes too much for the calculation, the member state can use . allocations defined in the Effort Sharing Regulation. If the sink diminishes until no allocations are available, it will be treated as an emission.
Then again, if a forest meets the requirements for a sink, to a certain extent it can be used in the climate calculations to compensate for emissions from somewhere else.
Mäki-Hakola finds that focusing exclusively on carbon sinks may actually be detrimental to the climate. There are many reasons why sinks are uncertain, whereas emission reductions are based on new technology and new modes of operation, which means that in most cases they are permanent.
’As regards forests, it would be more important to make sure that fossil raw materials are replaced by renewable wood, and to look after forest growth, in order to maximise the availability of that renewable wood,’ considers Mäki-Hakola.
7. Deforestation regulation would be impossible to implement
Mäki-Hakola considers that the aim of the proposed Regulation on deforestation-free products is good. The aim is that products sold in the EU should not cause deforestation either in the EU or outside it.
’But beyond that, it just goes too far,’ Mäki-Hakola says.
Forestry causes no deforestation in Finland, thanks to legislation that requires a new stand to be established after a felling. The regulation proposal, however, requires more than this: it must be possible to show for every forest product sold, say a toilet roll, that felling the trees for it has not caused deforestation on the site.
This cannot be done. Wood from different forest compartments, as well as the boards, chips and other intermediate products made from it, are mixed with each other in industrial processes, making it impossible to trace the origin of all wood used in a given product.
Continuous flow of less significant proposals
In addition to substantial projects related to regulations and directives, the Commission is also working with forest monitoring and carbon certification, to name just two of the many.
The purpose of monitoring is to generate a unified picture and comparable data of forests in the EU. Stakeholder consultation for this has just been completed, but Mäki-Hakola lists many puzzling points related to the project.
’I asked what the Commission’s objective with the project was, but the replies were pretty vague. I wanted to know what the data would be used for, but the reply was not very clear. I also wanted to know who would be responsible for the cost, but the reply was equally unhelpful,’ Mäki-Hakola lists.
’Though if the project helps forest owners to develop forest data and tools for examining forest resources, the end result may be good. Still, the project clearly comers under forest policy, and that’s not within the EU’s competence,’ Mäki-Hakola says.
The purpose of carbon certification is to create a basis for estimating the amount of carbon accumulating in forests and the amount that is found there. The certification proposal was published on 30 November.
According to the Bioenergy Association of Finland, certification is needed in order to prove that carbon is actually being removed from the atmosphere. It will also enable reliable comparisons of the efficacy of different methods.
The proposal does not include plans for funding the system.
’The proposal is linked to many other documents in EU legislation, such as taxonomy, even though that was originally supposed to only apply to investments,’says Mäki-Hakola. However, he does not condemn the project outright.
’The aim is good. We’ll just have to see what becomes of it,’ says Mäki-Hakola.