“If the European Commission’s proposals of recent years were or are to be approved in their current draft, very little space would be left for national forest policy; it would be replaced by EU environmental policy,” explains Marko Mäki-Hakola.
Forest policy is one of the areas left to the competence of EU member states, yet the EU is attempting to gain strict control over forest use, for instance by using climate, agricultural and environmental policy. The portal Forest.fi met with Marko Mäki-Hakola, Director of the Forest Sector at the Central Union of Agricultural Producers and Forest Owners (MTK) in Finland, to find out how the EU could influence forest policy.
M. Mäki-Hakola assesses that European Commission projects are characterised by a tendency to improve everything at once, forgetting that achieving one goal may harm others.
“Improving the situation for biodiversity may create obstacles (losses) to forest growth and, consequently, to carbon sinks. Moreover, the Commission apparently does not understand that applying the same rules across all EU member states will affect their forests in very different ways,” he explains.
1. “What the forest sector expected turned into an environmental strategy”
M. Mäki-Hakola begins with the forest strategy adopted last year. It is the third such strategy, and, in M. Mäki-Hakola’s view, it was necessary.
“We (MTK) also wanted a new strategy, but a balanced one, with an understanding of the sector’s needs. We received a protection strategy,” says M. Mäki-Hakola.
“A strategy that took the sector’s needs into account would address various issues, such as forest growth, management and usage objectives, one of which would be replacing fossil raw materials and mitigating climate change. It should certainly also include regional and national economic well-being and EU self-sufficiency, without, of course, forgetting the environment,” lists M. Mäki-Hakola.
The content of the first versions of the forest strategy was also a surprise to M. Mäki-Hakola because it clearly promoted a common EU forest policy, even though both the European Council and Parliament had emphasised only a few weeks earlier that this is not within the EU’s competence.
In defence of the proposal, it was explained that it is only a strategy and is not binding. Nevertheless, its purpose was and is to steer the preparation of forest issues in the EU. “People are constantly referring to it,” explains M. Mäki-Hakola.
2. “Taxonomy – a strange preparatory process”
The taxonomy of sustainable activities is an EU instrument used to direct funding to projects that have a beneficial impact on the climate and environment. M. Mäki-Hakola believes this is good. Instead of banning the funding of any project, the goal of the taxonomy is to help good projects obtain funding on better terms. If the forest sector wants to receive funding in accordance with the taxonomy, it must prove that it sources wood only from forests that are managed accordingly (under the taxonomy).
“Forest owners will be responsible for implementing the taxonomy in forests. However, they will not be able to apply for funding under the taxonomy, and in other respects, compliance with the taxonomy will provide them with only an indirect benefit, if any. Forest owners will do the work and bear the costs,” explains M. Mäki-Hakola.
The climate criteria for the taxonomy were developed in 2021. M. Mäki-Hakola believes that these can be lived with. However, this does not apply to the environmental criteria, the proposal (draft) for which was published at the end of November. MTK believes the proposal is not feasible.
The Commission set three requirements for the taxonomy: it must be based on scientific research, usable, and politically acceptable. M. Mäki-Hakola believes that the latest proposal does not meet any of these requirements.
According to the proposal, 20% of forests meeting the taxonomy’s requirements would have to be excluded from commercial use. Clear-cut sizes would be limited to three hectares in coniferous forests and one hectare in broadleaf forests. A 100-metre strip would have to be left intact between clearings for 40 years.
In broadleaf and mixed forests, 30 cubic metres of deadwood would have to be left per hectare, and 20 cubic metres in coniferous forests, even though this indicator is currently less than five cubic metres per hectare. 90% of the soil in a clear-cut area would have to be left undisturbed.
3. The biodiversity strategy is implementable
The EU biodiversity strategy would also not be binding. According to the proposal, every member state would have to strictly protect 10% of its land and water area by law, and an additional 20% less strictly, possibly through specific agreements.
“This would not cause problems for Finland, unless for some reason we want to exceed EU requirements, as proposed by the Finnish Nature Expert Group. The requirement for strict protection has already been met, and work is currently underway regarding the less strict part to determine how much of such area we already have,” says M. Mäki-Hakola.
Each member state will submit its commitment on this issue to the Commission. The Finns will elect a new parliament in the spring of 2023, so only the next government will make decisions on the strategy.
“We must ensure that decision-making remains in the hands of the member states. We must remember that nature is being protected for the sake of nature, not for the sake of the EU,” M. Mäki-Hakola expresses his position.
4. The Nature Restoration Regulation essentially concerns forest management
M. Mäki-Hakola believes that the Commission’s proposal for the nature restoration regulation is full of problems and requirements that can be interpreted in very different ways.
The proposed regulation, which would apply to nature as a whole, has sparked sharp debate. Regarding forests, it provides for restoration to be carried out in habitats listed in the EU Habitats Directive; namely, 30% of degraded habitat areas should be restored to bring them closer to their natural state.
It is expected that this percentage will be gradually increased so that eventually, restoration measures will cover most of the habitat areas included in the Natura scheme. In Finland, such habitats are northern natural forests, herb-rich forests, esker forests, and mires.
Furthermore, habitats must be restored to match the area they occupied in the early 1950s, which would already be outside the Natura scheme.
“Why must requirements be set for all forest territories? Why are Natura areas not enough? With this proposal, the EU is clearly entering the field of forest management, which is outside its competence,” M. Mäki-Hakola is direct.
The Commission has calculated the costs and benefits this measure will create for member states. M. Mäki-Hakola believes the estimation of benefits very much resembles a pyramid scheme based on entirely abstract things, such as the predicted increase in tourism value or tourist interest. The calculations are based on surveys evaluating the public’s willingness to pay for certain things.
“Let’s assume you own a restored mire. You therefore need an assumption – how many tourists this will attract (in reality – could attract),” explains M. Mäki-Hakola.
5. The Renewable Energy Directive would threaten Finland’s energy policy
The Renewable Energy Directive defines the conditions under which forest-sourced biomass intended for burning can be included in renewable energy quotas. It does not ban the burning of wood, but determines what type of wood can be included in national renewable energy quotas. The EU has set targets for these quotas.
According to the current proposal, wood sourced directly from the forest would not be considered sustainable and would not be included in national quotas. On the other hand, wood sourced from forest industry by-products could be included. The justification states that wood should be recycled as much as possible and – most desirably – into long-lived products, and only as a last resort should it be used for energy.
“That is a great idea, but the facts show that when a tree is felled, some parts of it can only be used for burning. In this case, too, fossil raw materials are being replaced,” says M. Mäki-Hakola.
If any part of a tree has another application, it will inevitably end up there. “Because any other application will be more profitable than burning, it means the seller will get a better price for the wood,” explains M. Mäki-Hakola.
Finland’s renewable energy policy was developed based on the EU legislation in force at the time, and forest biomass holds a significant place in it. If the directive is adopted in the proposed wording, Finland’s policy will collapse.
6. The agreement on the LULUCF regulation is acceptable
The LULUCF regulation concerns how carbon sinks and emissions in land use, land-use change and forestry are taken into account in achieving EU climate goals. An agreement on this was reached quite recently, and M. Mäki-Hakola describes the result as “reasonable, achieved through hard work”.
The greatest confusion regarding forests is caused by the reference (or baseline) level used in calculations, that is, the level against which the actual level of carbon sequestration is compared. If a carbon sink has been created by using forests in the normal way, only a sink that is greater than this level will be accepted in international comparison. A maximum permissible sequestration value has also been set.
If the carbon sink in a member state decreases too much to be calculated, the member state can use allowances set in the Effort Sharing Regulation. If the carbon stock decreases until no allowances are available, it will be considered an emission.
On the other hand, if a forest meets the requirements set for a sink, it can to some extent be used in climate calculations to compensate for emissions created elsewhere.
M. Mäki-Hakola believes that focusing only on carbon sinks can actually harm the climate. There are many reasons why sinks are uncertain, while reducing emissions is based on new technologies and new ways of operating, which means that in most cases it is permanent.
“When it comes to forests, it would be more important to ensure that fossil raw materials are replaced with renewable wood, and to take care of forest growth to maximise the availability of renewable wood,” believes M. Mäki-Hakola.
7. The Deforestation Regulation would be impossible to implement
M. Mäki-Hakola believes that the goal of the proposed regulations on deforestation-free products is good, namely to ensure that products sold in the EU do not cause or stimulate deforestation either in the EU or outside it.
“However... the authors of the regulation have gone too far,” assesses M. Mäki-Hakola.
Forestry in Finland is not linked to deforestation, thanks to legislation that stipulates that a new forest stand must be created after a forest is felled. The regulation proposal provides for more: for every forest product sold, such as toilet paper, it must be possible to prove that the felling of the trees required for its manufacture at the relevant site did not cause (promote, lead to...) deforestation.
This is impossible to do. Wood from different forest parcels, the boards, chips and other intermediate products made from it are mixed in industrial processes, so it is impossible to trace where all the timber used in a particular product comes from.
A continuous flow of less significant proposals
In addition to significant projects related to regulations and directives, the Commission is also working on forest monitoring and carbon certification, to mention only these two of many projects.
The goal of forest monitoring is to create a unified picture and comparable data on EU forests. A consultation with stakeholders was recently concluded, and M. Mäki-Hakola mentions many unclear issues in this regard.
“When I asked what the goal of this Commission project is, the answers were quite vague. I wanted to know what purposes the data will be used for, the answer was not clear. I wanted to know who will be responsible for the costs, but the answer was just as approximate,” lists M. Mäki-Hakola.
“If the project helps forest owners work with forest data and develop opportunities for forest resource research, the end result may be good. But yet again, the project clearly falls under the area of forest policy, which is not within EU competence,” emphasises M. Mäki-Hakola.
The goal of carbon certification is to evaluate how much carbon accumulates in forests and how much of it is there. The certification proposal was published on 30 November.
The Finnish Bioenergy Association believes that certification is necessary to prove that carbon is indeed being removed from the atmosphere. This will allow a credible comparison of the effectiveness of different methods. The proposal does not include plans for financing the system.
“The proposal is linked to many other EU legislative documents, such as the taxonomy, even though initially it was intended that the taxonomy would only apply to investments,” says M. Mäki-Hakola. “The goal is good. We just have to see what comes of it.”