In response to the considerable stir caused by the Ministry of Agriculture with the amendments it has put forward to lower the felling age of trees, we hold a view that we consider sufficiently well argued to set out publicly, to non-governmental organisations and to the executive institutions of the Republic of Latvia.
[In what follows we are speaking about commercial forests in which no restrictions have been placed on economic activity, and where there are no nature reserves, micro-reserves or other limiting factors.]
In our view, in stands where the yield class (a measure of stand productivity) is I or Ia, and where the forest site type (MAAT) is essentially gārša, vēris or damaksnis (accounting for roughly 45% of all registered forest land area in Latvia), a reduction in the felling age as currently drafted by the Ministry of Agriculture would be acceptable for all tree species, because the growing conditions there favour the cultivation of forest stands.
Given the circumstances noted above (forest site type, yield class), even with a reduced felling age and with proper management it would be possible to cultivate stands with substantial growing stock and tree dimensions, from which it would then be possible to obtain a volume of timber and a quality of assortment equal to, or even considerably greater than, that of a mature stand grown in the site types not mentioned here. What is more, this could be done almost twice within a single period, compared with once at present. Recognising all of this, it is hard to stand aside and disregard the contribution such a decision could make to the national economy and to the forestry and timber industries over the long term. At the same time, let us remember that the current Regulations on the Felling of Trees in Forests already permit a stand to be felled in a final felling on the basis of diameter well before the felling age is reached — in some cases by 30 years or more. All that is required is to demonstrate that the mean diameter of the first-storey trees of the dominant stand meets the requirements of the regulations. For industry specialists, and indeed for anyone with the relevant knowledge, this is comparatively easy to do if the stand has been tended beforehand and managed using generally accepted and recognised practices.
Now to the main point. As regards stands with the forest site types not mentioned above and with yield classes II to V, in our view the Ministry of Agriculture's current draft on lowering the felling age should not be applied, and the position should be left as current legislation determines it. We are unanimous in our view that, under the new amendments, stands on the remaining site types and yield classes will not be able to mature to the point where appreciable growing stock and an assortment as commercially valuable as that described in the preceding paragraph could be obtained from them. Moreover, with their current felling-age threshold and the difficulty of reaching the mean diameter class in them because of the poorer growing conditions, these stands will continue to serve as a long-term habitat for fauna and flora, allowing high-quality biotopes to keep forming as well — some of which will most certainly have to be protected in future.
In closing, we should like to add that we are entirely confident this question will return to the Cabinet's agenda sooner or later, and that a compromise between the forestry sector, the timber industry and environmental campaigners will have to be found; that is why we wish to have at least some small influence on the decision that is taking shape. And although at first glance it might seem that the "loser" in our proposal is once again Latvia's environment and its sustainability, that is not quite the case. It must be understood that we, as a whole society, need to be able to balance economic gains against the values of environmental sustainability, thereby also increasing the well-being of our society — and in our view this proposal offers precisely that.