Frans Timmermans Executive Vice-President for the European Green Deal

Thierry Breton Commissioner for Internal Market

Kadri Simson Commissioner for Energy

Virginijus Sinkevičius Commissioner for Environment, Oceans and Fisheries

Jutta Urpilainen Commissioner for International Partnerships

Brussels, 28th June 2021

Dear Vice-President, dear Commissioners,

The EU-Commission is currently in the process of adoption of the EU Forest Strategy.

We would like to underline that the Commission proposal is in number of crucial parts well- aligned with the calls of the .

In the adopted Resolution on Biodiversity Strategy from 9th June 2021 the European Parliament endorses the binding restoration targets for forests1 , and asks for strict protection for all remaining old-growth and primary forests2.

If we want to successfully address both, the climate and biodiversity crisis, we need to adjust the way forests are currently managed and we also need to plan the forests of the future. In this context, it is essential, besides strengthening the protection for forests, to step up effort to enhance sustainable forest management and improve the planning and monitoring of EU forests by way of a further legislative initiative. This is a precondition for ensuring more resilient forest ecosystems, which is crucial in light of current impacts of climate change. Acting within its competence, it is very timely that the EU is coming up with the proposed legal initiative as one

1 par.39 of the adopted Resolution ‘’ Strongly highlights the importance of fully integrating the EU’s nature restoration objectives into other related policies and strategies; reiterates its call for binding targets on the restoration of forests , including to increase and restore connectivity between forests..’’ 2 par 15 of the adopted Resolution ‘’ Expresses strong support for the EU targets of protecting at least 30 % of the EU’s marine and terrestrial areas, covering a diverse range of ecosystems such as forests, wetlands, peatlands, grasslands and coastal ecosystems, and of strictly protecting at least 10 % of the EU’s marine and terrestrial areas, including all remaining primary and old-growth forests.’’

of the deliverable of the EU Green Deal, in close cooperation with Member States and forest stakeholders. We therefore would like to express our solid support the Commission’s ambition and plans in the draft EU Forest Strategy.

The mentioned EP resolution, together with the Soil Protection Resolution from 28th April 2021, also underlines the problematic features of clear-cut forest management3,4. Contrary to what some argue, clear cuts do not mimic natural disturbances. On the contrary, the practice of clear-cutting is a disaster from an ecological point of view: It destroys the symbiotic interdependent network of trees with fungi, which represents the single most important mechanism of accumulation of soil organic matter and is thus crucial in the global carbon cycle5. The exposure to light after clear-cutting causes drought and accelerates humus decomposition. Heavy harvesting machines compact and destroy the forest soil and massively restrict the percolation of rainwater.

The recently published joint report of the IPBES and IPCC confirms that unprecedented changes in climate and biodiversity, driven by human activities, have combined and increasingly threaten nature, human lives, livelihoods and well-being around the world. The report stresses that stopping the loss and degradation of carbon- and species-rich ecosystems on land and in the ocean, among them specifically forests, is of utmost importance. Biodiversity loss and climate change are both driven by human economic activities and mutually reinforce each other. Neither will be successfully resolved unless both are tackled together.

Further, similarly to the Commission’s EU Forest Strategy proposal, the European Parliament has become increasingly aware of the pressure posed by the use of round-wood as biomass for energy purposes and asked for a revision of the Renewable Energy Directive both in the Biodiversity Strategy Resolution6 as well as in the Resolution on Protection of World Forests7 adopted on 16th September 2020.

Finally, we ask the Commission to re-evaluate the proposed contribution by harvested wood products to climate change mitigation. While use of wood for long-lived harvested wood products certainly has a place in the circular economy action of the EU and in climate action,

3 paragraph AO of the adopted Resolution ‘’ whereas forests account for 43 % of the EU’s land area and contain 80 % of its terrestrial biodiversity1 ; whereas forestry activities are the second largest reported pressure category for species2 , affecting in particular arthropods, mammals and nonvascular plants; whereas many forest-dependent species are negatively affected by the removal of dead, dying and old trees3 , reduction of old-growth forests and certain forest management methods such as clear-cutting’’ 4 par. 28 of the adopted Resolution ‘’ reiterates that clearcutting does not mimic natural disturbance by wildfire as unlike a clearcut site a site disturbed by wildfire is characterised by a very high amount of deadwood and soil open for colonisation of species;’’ 5 K. E. Clemmensen et al., 2013: Roots and Associated Fungi Drive Long-Term Carbon Sequestration in Boreal Forest. Science 339, 1615 (2013) 6 par. 100 of the adopted Resolution ‘’ Underlines the need to revise and align EU rules on the use of biomass for energy production with the objectives of the Biodiversity Strategy for 2030 and the European Climate Law, notably as part of the Renewable Energy Directive and the delegated acts under the Taxonomy Regulation’’ 7 par 41 of the adopted Report ‘’.. calls on the Commission, therefore, to fundamentally reform EU bioenergy policies, namely by revising the Renewable Energy Directive’’, as well as par 38 and 39, J, K and L of the same Report

we consider it is wrong to claim that the carbon removal period can be significantly extended when transforming woody biomass into wood materials and products with a long-life cycle.

The half-life of decay values are applicable for these products and expand to a few decades, but cannot be significantly extended, and it is not longer than storage of carbon in deadwood and coarse woody debris, which enriches as well the forest soils and biodiversity. However, the document of the EU-Commission gives more positive role to harvested wood products than to elements of the forest ecosystems. This we cannot agree to as it could also give way to dangerous and false solutions, similarly to the ‘’gold-rush’’ caused by the biofuel policy. The circular bioeconomy is a solution to the extent where it does not compromise on the services provided by forest ecosystems and on the ecosystems themselves and not further. This is highlighted, again, in the Biodiversity Strategy Resolution8 adopted by the European Parliament this month.

We, the undersigned MEPs, ask the Commission to adopt the document and maintain all the abovementioned elements, which we consider essential for a future of healthy forest ecosystems and forestry in the EU, with revision of this, latter, element of the Strategy.

Sincerely,

Vladimír Bilčík (EPP) (S&D) Katalin Cseh (Renew) Anna Deparnay-Grunenberg (Greens/EFA) Anna Donáth (Renew) Sven Giegold (Greens/EFA) Martin Häusling (Greens/EFA) Martin Hojsík (Renew) Javi López (S&D) César Luena (S&D) Luděk Niedermayer (EPP) (S&D) Grace O’Sullivan (Greens/EFA) Stanislav Polčák (EPP) Soraya Rodríguez (Renew) Sándor Rónai (S&D) Nicolae Ștefănuță (Renew) Michal Šimečka (Renew) Róża Maria Gräfin von Thun und Hohenstein (EPP) (Greens/EFA) Michal Wiezik (EPP)

8 par 95 of the adopted resolution: Underlines the role of forests in contributing to the EU’s climate targets; considers that the circular and cascading use of forest and other biomass resources that does not compromise on scientifically underpinned protection and restoration action and climate action should be prioritised