Posted on 13 December 2019
A radical change of the wood selling system is required together with an associated system of combatting illegal logging.
21 November 2019 (Bucharest) -
WWF-Romania requests a clear, official analysis of the information contained in the National Forest Inventory (NFI). The NFI does not provide a figure for illegal logging. In the last few years, different figures have been made public regarding the volume of illegally harvested wood. The divergent data from different institutional reports and independent studies has generated much controversy and questions about their scientific justification. An unsubstantiated claim that 20 million m3
of illegally harvested wood go “missing” annually from Romanian forests has recently made both national and global headlines. However, that figure was never officially mentioned until the Ministry of Environment announced it on November 15 without proper analysis and understanding. The number has somehow been arrived at to explain discrepancies in data between the two inventory periods (2008-2012 and 2013-2018). In WWF's opinion, this is contrary to scientific practice. Since the Romanian Government ordered an NFI from the Forest Research Institute, both the Institute and Government must explain the method for gathering data and declare the official numbers. The Romanian Academy of Agriculture and Forest Sciences and the Romanian Forest Research Institute have both presented a similar position to that of WWF on this question.
“It is wrong to interpret that the “missing” volume represents the total volume of illegal logging. It must be understood that the National Forest Inventory reports largely present the situation in the field before October 2014, 7 years before the introduction of SUMAL. In the absence of a rigorous analysis of the NFI results, erroneous interpretation may occur, which could position development of Romania’s forest policy in a wrong direction -- and our forests and society will be left to pay for the lack of clear information regarding the real current situation.”
- Radu Vlad, Forest Coordinator, WWF-Romania
Aquila non capit muscas (“the eagle does not catch flies”) – in the same way, the NFI was not designed or commissioned to determine the volume of illegal logging.
NFI is a tool that inventories national forest resources. As such, it offers statistical information regarding the development, area and structure of the nation’s forests; the volume of standing wood (meaning the living trees in the forest); current annual forest increase; levels of dead wood, etc. Considering that the NFI is based on a statistic processing of filed data and does not represent a census of all trees in Romania, it is extremely important to have information on the data for which there is statistic coverage. Moreover, interpretation of the data must take standard associated errors into consideration.
Until now, decision-makers have relied on different reports and analysis which only state the relevance and immediacy of illegal logging. No rigorous, scientifically targeted analysis has ever been aimed at quantifying the level of illegal logging at the national level. Both the competent authority and the representatives of the Romanian National Institute for Forest Research and Development (INCDS) have stated that an NFI cannot identify the volume of illegal logging, only that it can confirm that it is still a relevant problem.
NFI confirms the relevance of the principles and direction for fighting illegal logging
WWF-Romania proposes a system of monitoring and control at the point where wood is placed on the market. The current system of selling wood as standing timber without verification of wood products as they are placed on the market (as they exit the forest) constitutes the main cause of the illegal logging controversy in Romania. Foresters record transported volumes using numbers having two decimal places, while the legally permissible error for tree measurement in the forest exceed 20%. Less than 1% of the wood transports are verified as they leave the forest. The current legal framework (wood selling regulation, norms regarding the circulation of wood materials, forest protection regulations, the statute for forestry personnel, etc.) has imposed this inefficient, costly and dangerous (for control personnel) system.
A radical change of the wood selling system is required
together with an associated system of combatting illegal logging
. The integrated solutions to address illegal logging proposed and supported by WWF-Romania are found here
Methods, numbers, standard errors and many other questions regarding the NFI results
WWF-Romania has repeatedly
requested official clarifications regarding the method of collecting field data, and the methodology used to analyse and interpret information regarding forestry resources. Unfortunately, no answer has ever been received, and the partial results have not been communicated properly by either the institution performing the inventory (INCDS) or by the competent ministry as a beneficiary. Thus, an opportunity for different interpretations has been created which has generated much confusion.
Questions regarding NFI results:
- How is the “missing wood volume” explained?
The missing volume estimated by NFI clearly includes a degree of illegal logging, however, it is absolutely incorrect and irresponsible to assign it the entire number. In all the countries which have ever implemented a National Forest Inventory, there has always been a missing volume between cycles that must be explained. Unfortunately, certain stakeholders in Romania have jumped the gun and found correlations with illegal logging when the authorities and inventory authors have not yet explained publicly how this result should be understood. For example, does the missing volume appear due to the comparison of some data obtained for different purposes, or by using different methods and sources?
- What percentage of the missing wood volume relates to the approximately 400,000 hectares of forests belonging to private owners included in the National Forest Fund (NFF), and for which no forestry services are included?
Over 8% of the national forestry fund is owned by over 300,000 private individual owners of areas between 0.1-10.0 ha. There are no clear ownership documents for a good percentage of these areas. For administrative and financial reasons, these forests have not yet been adopted into any kind of forestry structure.
- What percentage of the missing wood volume relates to the approximately 500,000 hectares of forests outside of National Forest Fund (wooded meadows or pastures for which wood cutting and even deforestation is legally at the owner’s discretion)?
WWF evaluations demonstrate that over 25% of the national “tree cover loss”
is represented by areas outside of National Forest Fund. Illegal deforestation of these forest areas was even financially stimulated through direct agriculture subsidies beginning in 2008.
- If and how much deadwood is found in the missing wood volume?
The NFI results (Cycles I. and II.) regarding the standing and fallen deadwood are incompletely presented. According to the definition, a certain amount of deadwood may be found in this missing volume. However, the published NFI results do not communicate the calculation of these quantities or the method of field data collection. Starting in 2012, Romania has FSC certified (Forest Stewardship Council
) over 2.5 million ha of forests, and approximately 40% of the forests have been included as Natura 2000 sites where the environmental conditions regarding the conservation of deadwood are imposed by law or voluntarily assumed. Since deadwood is a very relevant indicator for biodiversity conservation in our forests, the National Forestry Inventory should communicate how the quantity of deadwood was determined.
- What is the proportion of the sample areas that offers an image of the real wood harvesting levels between 2008 and 2014 (before SUMAL was implemented) which influenced the final NFI results published in 2018?
The estimated “missing” volume in the first NFI cycle was estimated at 8.6 million m3
and in the second cycle (for the period 2013-2018) the missing volume appears to be 20 million m3
/year. What is the contribution during the 2008-2014 period to the estimation of the "missing" volume? Is it possible that the volume of illegal logging has doubled even after acknowledging that the conditions making illegal logging more difficult have significantly strengthened in the last 4 years?!
- What is the actual work methodology, and what estimation techniques are employed?
The National Forestry Inventory website presents results which could not have been obtained in a correct and complete manner if the published methodology had been followed. When evaluating the degree of naturalness or determining virgin and quasi-virgin forests, the indicators approved by law could not have been completely taken into consideration (i.e. the criterion of form and area). In communicating the results, terms are used which are not clearly defined and which, in all likelihood, have different meanings in comparison to the terms defined by law. We request the publication of the work methodology and the guidebook used for collecting field data.
- How can it be explained that some of the results published together with the associated sampling errors do not correspond to the official recordings?
Evidence of the functional type category for approximately 7 million ha of forest is offered, but the forest management plans cover less than 6 million ha (the division by functional type category is only recorded in valid forest management plans). Therefore, we must ask how this classification was made. For example, in areas which fall within functional Type I – strict protection, it may be possible that the data does not correspond to reality.
About the National Forest Inventory’s role
- What is the distribution according to age classes of the forest fund for which the production process is regulated (functional types TIII-TVI)? And for areas included in TI-TII? How has the age of the trees and of forest stands (the forest) been determined?
- For the interpretation of NFI results and their comparison with official records, should the standard errors generated by the dendrometric method and the measurement errors be considered as well? If yes, what are these errors?
The agency’s website presents a positive picture of Romanian forestry to the world. The forests of Romania are increasing; they represent considerable accumulations of biomass, predominantly with natural composition and regeneration.
The project must continue, to provide more information of general interest (including for biodiversity conservation) in the future, and clear and transparent interpretation of the results must form the basis of a national forestry policy for sustainable forest management.