Lobbying by Federation of Swedish Family Forest Owners

Federation of Swedish Family Forest Owners

LRF Forest

Arbeta för bra förutsättningar för Familjeskogsbruket och familjeskogsägarna i EU.

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ID: 878186914678-56

Lobbying Activity

Response to Report on the evaluation of the LULUCF Regulation

11 Jul 2024

The Federation of Swedish Farmers and Family Forest Owners (LRF) represent a majority of Swedish farmers and family forest owners. We align our selves with the feed-back of CEPF and Copa Cogeca. The forests in EU (and all around the globe) mitigate climate change in three general ways. They sequester carbon through the photosynthesis, they store carbon in products and the substitute fossil products and energy. So far, the LULUCF-regulation does not cover the full potential of forests and bioeconomy. LRF would like the current LULUCF-regulation to develop to also include the substitution effect. LRF is greatly concerned about the prevailing narrative of quick fix solution to view forests as a static carbon sink. Not considering the full benefit of forests will lead to misleading policies. For example, decreasing harvest levels to reach the 310 million ton goal in 2030 might increase the risk of forest damages, including increased outbreaks of pests and diseases as well as forest fires. At the same time, the spillover effects might also lead to increase our dependency on fossil materials and energy unless we drastically deal with our unsustainable consumption in EU and globally. The ambitions set out in the current LULUCF are extremely challenging to meet for most countries, including Sweden. The difficulties in other GHG emitting sectors to meet their targets (i.e., transportation sector) is also increasing the pressure on forests to be either a carbon sink or deliver fossil free transportation biofuel. The sheer measuring of the expansion of the forest carbon sink and limitation of the harvest of sustainably managed forests destine climate change mitigation goals to come short of societal expectations and legally defined goals. LRF welcomes that the current LULUCF-regulation acknowledges the substitution effect of harvested wood products (HWP), sourced from sustainably managed forests. This leads the way forward and acts as a driver and an enabler of the European circular bioeconomy and the New European Bauhaus. Quantification methods need to be transparent and storage mechanisms must be clearly defined in the revised Regulation. The substitution effect must have strong recognition and not only focus on HWP. For LRF, the collective architecture of the EUs future climate change mitigation policy framework is key going forward. The LULUCF Regulation needs to continue being the principal instrument for the land-use sector. However, connection to other important climate frameworks needs to be clarified, including the carbon removal certification framework. Moreover, both technical sinks like BECCS and framework on carbon removal needs to be handled in the upcoming climate policy architecture. For LRF a dynamic approach is essential, where climate change mitigation includes all parts of the circular bioeconomy. Our economys shift away from fossil resources needs viable, sustainable alternatives, sourced from domestic, European renewable resources as much as possible. LRF views forests as EU strategic raw material. The widening horizon of sustainably sourced biobased materials shows that the European Union can find feasible and promising alternative materials for its economy, while strengthening its strategic autonomy and increasing its competitiveness at the same time.

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Response to Update of State aid procedural rules, considering the EU’s international commitments, recent practice and case law

27 Jun 2024

Concerns regarding the development of the Aarhus Convention and EU state aid: Several of the recent findings put forward by the ACCC lack support in any primary source of law. The scope of the recent initiatives in this area clearly contains redefinitions and re-interpretations far beyond the original scope of the Convention. This also applies to the current initiative regarding EU state aid policy. With reference to the Aarhus convention, Swedish farmers and family forests owners have already experienced the development of a very extensive access to court proceedings for NGOs and members of the public to initiate legal processes in matters with negligible environmental impact such as ongoing and small-scale forestry and farming. These are matters that were never in the scope of the Convention. The development has resulted in an unbalanced implementation that leads to negative consequences for individuals, small enterprises, authorities and a sustainable development. Individuals and NGOs are becoming opponents by the broad use of access to court proceedings that hinder development in rural areas with limited possibilities of outcome for the local population. We have already seen how the perception of environmental organizations has changed, many of them now well-funded by taxpayers money while working against the interest of the general public in terms of the local populations. The question of EU state aid rules in relation to the Aarhus Convention, especially in connection with Article 9.3, has been the subject of several investigations and legal trials in Sweden in recent years. It has been used to limit the compensation that plays a major role in the protection of property rights, mainly by NGOs in connection with species protection where small-scale farmers and forest owners have had their property rights challenged and/or infringed. Rights that are free under national law, protected by the constitution and due to compensation when infringed. Until now, the efforts to challenge these rights to compensation, by the argumentation of EU environmental and State aid law, have not succeeded. The agenda has been pushed hard both in the EU and at national level by representatives of the ACCC, the Task Force for Access to Justice and some NGOs. This initiative opens for a dangerous change in that aspect and may even be the main, but concealed, purpose. The right to compensation exists as part of the protection of property rights in national legal systems as well as in the ECHR and the EU Charter of fundamental rights. The negative effects of weakening the property rights of the European farmers and forest owners cannot be covered in this document but would be vast for both individuals as well as most aspects of society as a whole considering both food and energy security, economic, social as well as environmental aspects. For some reason it has been communicated by the Commission that status quo is not an option and therefore no impact assessments would be necessary. This is, in all regards, an outrageous claim in matters of such profound importance for the citizens of the EU. This initiative is a result of a juridical argumentation for political purposes. The wording of the convention is clearly distorted and mixed up with political objectives regardless of the democratic systems set up as well as of consequences. We strongly request a political discussion as well as thorough analysis of the grounds of the proposed changes as well as the recent development of the implementation of the Convention. We also call for a thorough due diligence of the participants, work and aims of the ACCC and other parties behind these initiatives.

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Response to New EU Forest Monitoring and Strategic Planning Framework

7 Feb 2024

Nordic countries have a long history of collecting forest information. For more than 100 years Nordic countries have been collecting forest data that has strategically guided and helped optimize our forest management at local and national level. The Alliance of Nordic Family Forestry (NSF), which LRF is a member of has developed jointly this feedback. LRF also support feedback provided by CEPF and Copa Cogeca. In addition, LRF's in-depth analysis attached, note it is in Swedish. 1) Clarification on the purpose and needs of the regulation. NSF believes that the current purpose of resilience and monitoring needs around cross-border forest disturbance does not justify such a comprehensive EU framework on forest monitoring. NSF calls for the Commission to clarify the needs, purposes, and policy objectives of forest data, both in short and long term. No data should be collected for good-to-know purposes as it is not cost-efficient. What is the added value of this instrument? What are the specific purposes? What are the future interpretations and uses of the data since a stepwise approach for additional data is also foreseen? Part of the future use of the regulation, forest management plans should not be developed on an EU level as forest management methods are to be developed part of national forest strategies (see point 3). 2) Forest monitoring at forest holding-level is a no go area. NSF firmly says no to EU monitoring at a detailed level, such as forest holding-level. The definitions on the reporting level are conflicting and hard to understand. The data level (forest unit) is very detailed and challenging to implement in practice. Holding-level information, or the closely related forest unit-level should not be covered as the ownership of the data needs to be fully considered. To give meaningful and cost-efficient information on trends in EU forest development, the outcomes of the forest data collection should at the lowest be at regional level (NUTS-2). Also, the mandate to data openness is troublesome due to privacy issues. 3) Consider legal basis & subsidiarity for voluntary integrated long-term plans. Forest management practices vary a lot across the EU, NSF emphasize that integrated long-term planning related to forest management practices should not be part of the proposal. Forest management practices are always chosen based on the best available knowledge on a local and regional level. Forestry is a national competence, and the subsidiarity principle must be fully respected. 4) Minimize overlaps of data collection. NSF would like to see minimum overlap in reporting in order to reduce the reporting burden, not least for forest owners. NSF claims that forest monitoring should be based on existing reporting systems, especially national inventory systems but also regional systems such as Forest Europe and UNECE and globally through FAO's FRA. 5) Data quality at heart. NSF believes that field inventories are the most accurate and reliable data source for forest monitoring. Remote sensing should be seen as a complement. NSF is reluctant to rely too heavily on EU satellite data. Also, the Commission also does not have the necessary tools and expertise to interpret the national data. Therefore, adequate support from Member States must be reinforced. 6) Increased cooperation between NFIs. NSF welcomes increased cooperation between national forest inventories such as the European National Forest Inventory Network (ENFIN). NSF can see a role for the European Commission to assist with support within the framework of existing EU funds through, among other things, capacity building and peer learning. 7) Delegated Acts are not supported as they do not bring the needed flexibility for Member States.

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Meeting with Brian Synnott (Cabinet of Commissioner Ylva Johansson)

17 Dec 2021 · COREPER discussions on taxonomy debate.

Meeting with Asa Webber (Cabinet of Commissioner Ylva Johansson), Brian Synnott (Cabinet of Commissioner Ylva Johansson)

2 Dec 2021 · Taxonomy and climate

Response to Guidance on REDII forest biomass sustainability criteria

28 Apr 2021

Federation of Swedish Family Forest Owners, LRF Forest comments on the operational guidance to RED II implementation Federation of Swedish Family Forest Owners, LRF Forest, points out the fact that forest biomass is the most important renewable energy source in the EU27 (Eurostat) and the effective utilization of sustainably managed forests in the EU will be in future very important to fulfill the aims of the Green Deal and the Paris climate agreement. LRF Forest welcomes the operational guidelines suggested by the Commission which are key to implement RED II sustainability criteria. LRF Forest acknowledges the time pressure which the Commission is working with when looking ahead for July 2021, the start of the RED II implementation. However, on certain aspects the implementation guideline goes beyond the Directive’s competence and could therefore raise issues regarding Member States competences. We would emphasize the minimizing additional administrative burdens on forest owners and ensuring stable framework conditions for necessary investments in the bioenergy sector in order to meet the ambitious energy and climate goals. During 2020 the RED II BIO project report was under public consultation. It contained an analysis of national level compliance for EU MS and some other countries. We regret that this report was not published in time to provide stakeholders background information which would help assessing this guidance text. The regulations should stick to the same definition for forest biomass as the Directive it is meant explain. The regulation differentiates between “primary biomass from forests” and “secondary biomass from forests” while the directive uses “forest biomass” and “residue”. The regulation refers to in art 3 to four different forest categories: primary forests, natural forests, semi-natural forests, plantation forests. Only the last 3 are defined. It is not clear where these specific definitions come from. If it is expected that all forest can be classified in these types, the requirement in art 3 para 1.b.ii will be limiting for forest regeneration. We recommend using FAO definitions forest types. Please avoid mixing up “plantation forests” with “planted forests”. The implementation regulations should stick to the five sustainability requirements set in point (a) of Article 29 (6) of Directive (EU) 2018/2001. Especially we have trouble with art 3, para 1.b.ii and art 3 para 1.b.iv. See attachment for rationale and suggestion. The article 29, 6 a ii of the RED II refers to “forest regeneration of harvested areas” and relates only to the re-establishment of a forest stand by natural or artificial means following the removal of the previous stand by felling or as a result of natural causes, including fire or storm. Adding the requirement above in para 1.b.ii is adding a biodiversity angle, which is not the intention in the directive, The article 29, para 6.a.iv of the RED II refers to “maintenance of soil quality and biodiversity with minimizing negative impacts”. Adding regulation of the removal of stumps, roots, deadwood and where appropriate, needles or leaves to this regulation is too detailed. For both points the above-mentioned provisions of the guidance are going very much deeper level than in the RED II regulation text and is jeopardizing the role of Member States to explain and show how RED II requirements are covered by national legislation. Such details are rather subject to practices and operational guidelines. We would therefore suggest deleting these detailed level texts. It is unclear what “clear-cuts are minized” under art 4 1.b.iv. means (the amount, the area, the size, the responsibility to define what “minimization” means). This minimization and falling of the A-level assessment may paralyze the harvesting operations where bioenergy collection is a side product. We are concerned that this is a result of the toxification of the renewable energy debate (JRC report).

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Response to EU strategy for sustainable textiles

2 Feb 2021

Federation of Swedish Family Forest Owner’s, LRF Forestry, views on the road map for an EU strategy for sustainable textiles One of three Family Forest Associations in Sweden is Södra Family Forest Association. They have 53,000 family forest owners in southern Sweden. For more than 80 years, they have been working together to build an international forestry group that uses every part of a tree to generate value for forest owners. Wood raw material is used to make softwood, hardwood and dissolving pulp, sawn timber, cross-laminated timber, engineered wood products for construction, as well as energy products and biomass for liquid biofuels. The production process also generates large amounts of excess renewable energy, which is sold to electricity and district-heating grids. The operations are virtually fossil-free and one of Södra’s sustainability targets is fossil-free transportation by 2030. Södra’s climate impact report shows that the forest management carried out by its members, combined with Södra’s mills and products, generates a climate-positive outcome corresponding to 20 percent of Sweden’s reported GHG emissions. This is because growing trees absorb large amounts of CO₂, and because our forest products are replacing fossil-fuel materials and fossil-fuel energy in the market. From linear to circular Södra has created the world’s first large-scale process for textile recycling. They combine cellulose from wood with used textiles to make a dissolving pulp that is ready for use in the production of new textile products. One of the biggest challenges to recycling is that some fabrics are made from blended fibres. The process can separate the cotton and polyester fibres in polycotton, which is one of the most widely used fabrics in the world. In our view, they are on the brink of many solutions and technical breakthroughs in the textile industry that will enable circular flows, and that could be accelerated and strengthened with policy instruments. Over time, natural resources will not be able to meet the growing demand for virgin fibre. Clear extended producer responsibility for textiles is part of the transition to a circular economy, but additional policy instruments and initiatives are also needed – political, sector-wide and cross-sector, as well as consumer-driven. The goal must be to reduce the inflow of new fibre in textile supply chains. We therefore need a regulatory framework that disengages linear textile flows and connects circularity with profitability. Against this background, LRF Forestry would like to present the following views in connection with the road map for an EU strategy for sustainable textiles: - The EU could lead the way globally by promoting wood-based textile fibres, which are currently available in the form of viscose, modal and lyocell. These fibres are derived from sustainable sources. Approximately 1.8 million tonnes of dissolving pulp are currently produced within the EU. Only 600,000 tonnes of that pulp are used for textiles in the internal market. The right policy instruments could increase that amount. - Not all materials are the same from a climate and environmental perspective. Non-biodegradable materials cause harm to marine life, wildlife and the natural environment. A bonus-malus system should be introduced to support the use of biodegradable fibres and reduce the use of non-biodegradable materials. - Set step-by-step goals for ensuring that all textiles in the EU market are reused or recycled. New production accounts for 80 percent of total GHG emissions from textiles. There is no doubt, therefore, that the greatest environmental benefits and climate-positive effects are created by reusing or recycling existing textile fibres instead of sending them to landfill or incineration. For this to be possible, it also means that garments that are put on the market must be recyclable, which should be rewarded. - Due to clearer extended producer responsibility combined with poli

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Response to Climate change mitigation and adaptation taxonomy

18 Dec 2020

The Federation of Swedish Family Forest Owners, LRF Forestry, welcomes “green investments” within EU, however we have observed that the proposed Taxonomy document has several shortcomings which all could be contra productive if implemented. LRF Forestry consider that is of outmost importance that a steering document should be based on science. This is not the case regarding sustainability of the Nordic forest management systems, the uptake of CO2 in managed forests, or bioenergy systems. A Taxonomy must also be in line with existing EU legislation, as the recently decided RED II, as well as national, environmental legislation. Moreover, the use of national statistics about CO2 balances in land use is the best way to judge the forest and agriculture sectors climate impact. The Taxonomy aims at the financial market, but the negative consequences for the SMEs farm and forest owners could be significant. The proposal, as we understand it, means that investments in agriculture and forestry would be considered non-sustainable. This is incorrect and would significantly restrict financing and increase investment costs in these sectors and the expansion of a long-term sustainable Bioeconomy. Proposed criteria for forest management include approval and checks by authorities. Carbon (C) balance measurement before forest action will have a significant negative impact on property rights and local owner’s engagement. It will be a very costly C inventory on millions of sites compared with the RED II more statistically accurate CO2 data obtained nationally. Likewise, the proposed criteria for agriculture management will give similar problems which goes in the opposite direction of the Commissions work within the Fit for Future Platform in the new CAP. The description that bioenergy is a transitional activity is not grounded in scientific knowledge. There exist a significant amount of scientific research confirming the long-term sustainability, including biodiversity and C efficiency, of bioenergy systems (see Appendix). The utilisation of forest residues and by-products replacing fossil fuels has led to a more than 50% reduction of the Swedish CO2 emissions since 1970, not harming other sustainability criteria. Residues and by-products from the forest and agriculture sector are utilised with increasingly resource efficiency co-producing heat, power, biofuels and bio-products by advanced technologies, which is a prerequisite to reach fossil-free energy systems. The Nordic forestry based production systems provides major positive environmental effects and should be open for green investments in its present form. The substitution of fossil based products by Swedish forest based, and their cascading use, is estimated to an annual CO2 reduction of some 42 Mton today. In addition, the annual net increase in national carbon stocks corresponds to some 40 Mton CO2 (eq. to 70% of Sweden’s total emissions), due to well-developed forestry management schemes and high productivity. The potential of BioCCS further improves the systems’ C mitigation. There is an obvious risk that the complexity of the criteria regarding improved forest management and regeneration has adverse effect on C mitigation, and there is today no mutual conclusion among researchers concerning best mitigation measures (see Appendix). The detailed forest management plans might be contra productive due to (i) the planning horizon (10-20 years) is too short for boreal forests where research suggest 100-200 years, (ii) increased bureaucracy reduces profitability for forests owners (330 000 private in Sweden) and their interest for silviculture, and (iii) measures increasing ecosystem C stock are not included e.g. (N)fertilization. Thus, it is unlikely that the regulation will lead to increased forest growth and mitigation. Finally, a clear and scientifically-based definition of “Close-to-nature forestry” is a prerequisite before including in the Taxonomy.

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Response to Access to Justice in Environmental matters

10 Dec 2020

The Federation of Swedish Family Forest Owners, LRF Forestry, response to the Proposal for an amending Regulation (EC) No 1367/2006 of the European Parliament and of the Council of 6 September 2006 on the application of the provisions of the Aarhus Convention The general principles of the Aarhus Convention (AC) are important. However, LRF Forestry has not found support in the AC’s background papers or any primary source of law for the interpretation persistently put forward by the Aarhus Convention Compliance Committee (ACCC) which implies a right for basically anyone or any group, that identifies themselves as being a stakeholder, to take part in administrative processes, judicial reviews as well as court proceedings in almost all matters with a possible environmental aspect at both national and EU levels. The Proposal made, if validated, would give anyone, even those without actual environmental concerns, the possibility of attacking and preventing operations which would be contrary to their own interests without taking into account the general societal interest. The scope the Proposal clearly contains redefinitions and re-interpretations far beyond the original scope of the AC as it aims to extend it to apply to other acts than those under environmental law as well as to acts of general scope. It is also suggested that existing deadlines are too short for procedures under the Aarhus Regulation. This suggestion would leave the field open for law fare on small scale forest owners, from any groups that operate according to their convictions. This was not the original intention of the AC. The views put forward by the ACCC does not reflect minimum standard set up by the AC nor its scope. CEPF calls for a more balanced and objective approach which clarifies the wide possibilities for the Member States to implement the standards of the AC adjusted to their national administrative and legal system. In the Proposal, the ACCC has shown an unreasonable far-reaching interpretation of the obligations laid down by the AC. Based on its role and composition, the ACCC continuously strives to extend the scope of the AC beyond what was intended. The Proposal would, in addition to socioeconomic costs, lead to far reaching and negative consequences for individuals and small enterprises. This development can also be negative for the intent of the AC, and above all, negative for crucial overall goals such as mitigation climate change, shift towards bioeconomy and sustainable jobs’ creation. The Proposal shows no evidence of how the environment would benefit from the proposed amendments. The Proposal clearly lack in analysing the overall effect of the proposed amendments. The consequences of this are unforeseeable delays and large costs for lawsuits for individuals and small enterprises. This also affects the initiative and the standard procedure of enforcement which is the competent authorizing authorities’ responsibility. That initiative is transferred to NGOs, which have no responsibilities or liabilities. Their priorities are not an act of balance with the broader societal interest in focus. LRF Forestry calls for a discussion on how to implement the AC in a more balanced manner where/if it is needed to strengthen the public, without putting important development for the society’s efficient functioning, individual’s ownership rights or small enterprises such as forest and investments economic predictability at risk. LRF Forestry also calls for a thorough due diligence of the participants, work and aims of the ACCC. The very broad interpretation of the AC which is developing in terms of the current misinterpretation of Article 9 (9:2-3), is not in line with the original intentions. The consequences will be unforeseeable delays and large costs for lawsuits for individuals and very small enterprises. It thereby leads to an unwanted “juridification” of policy.

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Response to EU Forest Strategy

3 Dec 2020

Reply to EC Roadmap on the new EU Forest Strategy from the Federation of Swedish Family Forest Owners (LRF Forest) LRF Forest would like to provide the following comments on behalf of the 16 million European forest owners who we represent. 1. From Family Forestry view we want to emphasise - The EUFS will build on Sustainable Forest Management (SFM) - The strong economic dimension that the EUFS will have to have - The very important role forest management play in Climate change mitigation by sequestrating CO2 in growing forests and that forest products substitute fossil material and energy - The recognition of the need for a comprehensive strategy to ensure that forests are addressed in a consistent manner across the different policies - The fact that the EUFS will have to lay the foundations for innovation and promotion of new products that replace fossil-based materials and effectively contribute to a new climate neutral society - The role of the forest sector can provide in EUs economic recovery 2. Our views on the key objectives announced: afforestation, restoration and preservation The scope of these objectives is too limited and does not reflect the whole picture of the many challenges for EU forests nor the full potential of services forest already provide for the society. Such scope is not enough to secure a consistent approach between the EU’s domestic policies that the roadmap calls for and is missing consideration and support to dynamic SFM framework. It also does not seem compatible with the strong economic dimension, including the development of circular bioeconomy, that the EUFS will have to have. Regarding the restoration and preservation obj, the purpose and rationale should be clarified. 3. What we think is missing The EUFS should be the key tool to make forest impacting policies work in the same direction. It should create an enabling framework conditions that does not hamper the implementation of sustainable forest management at national level which is a national competence. The Roadmap is ambitious and it has many objectives. However, the legal basis for so many miscellaneous objectives is unclear. In the “problem that the initiative aims to tackle”, the roadmap does not mention directly forests as the producer of wood, which is the most climate friendly raw material. We believe that SFM in Europe should build on the work of Forest Europe. Therefore, a reference to Forest Europe SFM definition, criteria and principles should be added. The roadmap does not highlight the importance to maintain and strengthen motivation of forest owners and managers to manage their forests furthermore. Finally risk management should be incorporated in the management of forest areas. 4. Important clarifications that we need We have strong concerns about the call “to foresee measures to avoid or correct unsustainable practices » which implies that forests are not sustainably managed. Clear definition of “unsustainable practices” based on sound information should be provided before making such call. We do not understand the call “to strive to decrease the loss of forest coverage” given that EU forest coverage has been increasing for decades A definition of “last remaining primary and old growth forests who may need strict protection” should be provided 5. We support the views of European Parliament and Member States We are calling the Commission to build on Council conclusions (11/11/20) European Parliament Resolution (8/10/20) which are calling to take a holistic approach to address forests and their multifunctionality, to build on SFM as defined under Forest Europe and to respect the distribution of competences between the EU and Member States From forest owners views, it is important that SFM and forests multifunctionality are the main guiding principle in the new EUFS

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Response to Revision of the Renewable Energy Directive (EU) 2018/2001

21 Sept 2020

The Federation of Swedish Family Forest Owners (LRF Forest) welcomes the EC initiative to possibly review the EU renewable energy rules in order to contribute to higher climate ambition as part of the European Green Deal and in support to the objectives of the EU Climate Law and 2030 Climate Target Plan. We do want to note some remarks and concerns regarding the content of the options described in the inception impact assessment and their possible impacts on the use of forest-based renewable energy. The production and use of renewable forest-based energy have important local and regional level impacts in the recovery of the rural areas after the COVID-19, economically as well as socially. 88 % of bioenergy plants are small and medium scale plants located across EU. We support the option to explore the possibility for a higher target in share of renewable energy consumption. All forms of renewable energy sources should contribute to the 2050 EU climate ambitions and should be supported. Climate Target 2050 cannot be reached without phasing out fossil fuels. The energy derived from biomass answers today to almost 60 % out of the total renewable energy production in EU and projections show that bioenergy wil contribute to the achivement of the the EU 2050 climate neutrality objective. Regarding the Option 4 we do not find it reasonable to amend the articles 29-31 in the REDII at this point of policy development. The implementing guidelines for REDII are almost finalized and the implementation of the REDII is just beginning. Possible amendments of these rules should only be considered after the implementation of the current regulation has been in place and evaluation results are available. We also emphasize the importance of stable policy environment in order to engage the stakeholders in implementation. Regarding the sentence: "The risk of unintended incentives for using unsustainable biomass will be assessed and minimised through appropriate safeguards.", the terminology “unsustainable biomass” is worth being clarified. The REDII regulation and its articles 29-31 are especially developed to ensure that the biomass used for energy purposes is sustainable. Also, as indicated above, CEPF is of the views that this regulatory system should be implemented before considering possible changes. Lastly, The Federation of Swedish Family Forest Owners would like to remind that bioenergy developments can support forest owners in sustainably managing their forests through providing them an opportunity to get a revenue from management operations on co-products or low-quality wood. These management operations are essential to produce high value timber. EU policy framework stability and predictability regarding bioenergy developments is therefore important for the forest-based sector as a whole.

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Response to EU Strategy on Adaptation to Climate Change

30 Jun 2020

The Federation of Swedish Family Forest Owners welcomes the EC initiative to propose a new and more ambitious EU Adaptation Strategy as part of the European Green Deal and in support to the objectives of the EU Climate Law. Under on-going changing climatic conditions, forests suffer from extreme weathers. It is projected that the occurrence and scale of natural disturbances, biotic or abiotic, will further increase, and it is thus essential to organise the paths towards stimulating forest health and resilience. Climate change already influences the life and work of forest owners in Sweden, who report significantly increased pressures on forest ecosystems. Building up the resilience of Swedish forests to climate change is a key feature of the policy considerations on climate change adaptation, as reflected in the Blueprint. In this view, we see the consideration of including in the Strategy actions that would provide more support to the resilience of forests and other ecosystems as a step in the right direction. Increased resilience of EU forests through their adaptation to climate change must be suitable to local conditions and consider all available tools (e.g. biological diversity and genetic resilience, risk management and prevention, restoration of forests degraded by natural disasters, or forest management plans). The future Adaptation Strategy should promote a flexible and dynamic approach of resilience. The long-term nature of forestry implies that selection of tree species should be forward-looking: they must remain adapted to site and climatic conditions foreseen by climate modelling. To meet a holistic approach of multifunctional forestry, species should also continue to produce the products and services for which they are valued. We believes that the EU Adaptation Strategy should be greatly oriented towards improving the knowledge of the scope and scale of climate change impacts on Swedish and European forests, as well as to increase knowledge on ways to tackle, to prevent and to better adapt forests to these changes. Better access to knowledge with up-to-date scientific research, operational and user-friendly tools, and long-term data series, taking into consideration existing best examples of forest monitoring at regional level as well as improved outreach, trainings and exchange of good practices will be needed to secure active involvement and participation of forest owners. In addition, European forests today carry a great climate mitigation potential that provides major climate benefits. Management of EU forests in a sustainable and active way contributes to enhanced absorption of CO2 from the atmosphere and at the same time provide renewable and climate-friendly raw material which store carbon and can substitute fossil-based materials and fuels. Thus, it will be important to create synergies between climate change mitigation, adaptation needs and the EU climate neutrality goal. Reaching the objectives of the Strategy will require concrete and appropriate funding sources and opportunities provided in an unbureaucratic way. Other financial instruments to manage exposure to risk in forests should be explored and assessed, such as more concrete opportunities and utilization of forest insurances in the EU, including of greater areas, so to decrease exposure to risk in risk prone areas. Finally, we supports further and reinforced mainstreaming of adaptation considerations in EU policies and instruments. Adaptation is key to maintain our forest, thus, opportunities should not be prevented by limitations on forest management. CEPF also sees the need to establish a firm reference in the Strategy with the new EU Forest Strategy, which should act as the main policy framework for forest issues. We believes the above-mentioned issues should be considered when developing action and policies required for EU adaptation to climate change and is looking forward to contributing to the next steps of the process.

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Meeting with Asa Webber (Cabinet of Commissioner Ylva Johansson), Brian Synnott (Cabinet of Commissioner Ylva Johansson)

19 Feb 2020 · Green Deal

Response to EU implementation of the Aarhus Convention in the area of access to justice in environmental matters

4 Jun 2018

Datum 4th of June 2018 Federation of Swedish Family Forest Owners Lennart Ackzell Åsa Hill Response to the Roadmap on the Inception Impact Assessment on the Aarhus Convention The Aarhus convention and how an excessive interpretation affects small scale forestry and farming The Commission published on 8 May 2018 an impact assessment initiative on “EU implementation of the Aarhus Convention in the area of access to justice in environmental matters”. The inception impact assessment is open for feedback until 5 June2018. General comments The general principles of the Aarhus Convention are important, but the very broad interpretation of the convention which is developing is not in line with the original intentions. The development is a result of a juridical argumentation for political purposes. The minimum requirements according to the convention is distorted and mixed up with the political objective to extend the possibilities for some parties to initiate court proceedings regardless of the consequences for others. This development can result in an unbalanced implementation that leads to negative consequences for individuals, small enterprises, authorities and a sustainable development for the society as such. Instead of strengthening individuals and environmental NGOs in relation to the authorities or large enterprises these parties risk becoming opponents when all matters, however small the impact is on the environment, if any, that someone argues to be related to the environment, should be subject to court proceedings This development is unhealthy for the reasons mentioned above and can also have a seriously negative affect on the possibilities to take the challenging and wise decisions that are necessary to manage climate change and sustainable development considering both economic, social and environmental aspects. The regulation of both the EU and in the Member States must maintain the rule of law also in environmental matters. This will not be the case if the opinion of the Aarhus Compliance Committee is implemented as EU law. Major consequences for individuals and small enterprises The consequences of this is unforeseeable delays and large costs for lawsuits for individuals and very small enterprises. This also affects the initiative and the standard procedure of enforcement which is the competent authorizing authorities’ responsibility. That initiative is transferred to NGOs, which have no responsibilities or liabilities. Their priorities are unforeseeable, random and not an act of balance with the broader societal interest in focus. History and the general principles of the Aarhus Convention The purpose of the Convention is to provide access to information, public participation and access to administrative or judicial procedures for decisions with major impact on the environment. Article 9 regulates the access to justice for the public in permit procedures concerning e.g. nuclear power stations, mineral industry or waste management (annex I), i.e. installations with a major environmental impact and decisions that effects many people. Article 9 (2) is carefully designed to regulate the access to information, participation and access to justice in permit proceedings for large scale activities listed in an annex. Therefore, it is highly unlikely that 9 (3) should be given an interpretation thathat overthrows everything in the previous article, i.e. that every decision (or non-decision) that someone argues to be related to the environment, should be subject for almost anyone to oppose by initiating a lawsuit. We have not found evidence that supports this interpretation in the documentation of the negotiations of the convention and this is not an interpretation that any of the persons who we have contacted and who participated in the negotiations can relate to.

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