Forest and Land Owners Association of Lithuania
FOAL
In April 1993 the Forest and Land Owners' Association of Lithuania (FOAL) was founded for the first time in the history of the country with the initiative to represent the interest of forest owners and to develop the institutional framework for the family forestry and subsequently became registered as a public organisation (on 8 June, 1993).
ID: 312771040529-84
Lobbying Activity
Response to Uniform format for national restoration plans
30 Jan 2025
To ensure effective NRR implementation, suggestions aim to refine the uniform format for efficiency, clarity, and flexibility while respecting Member States needs. General Comments The uniform format should remain as simple as possible, strictly adhering to Article 15 of the NRR, with optional fields unrelated to it removed to minimize the administrative burden. NRPs are for planning, not monitoring or reporting, and should not extend beyond Article 15s requirements. The format should allow Member States flexibility in national planning while ensuring compliance. For clarity, each box should reference the corresponding NRR Article and match its wording precisely. SPECIFIC REMARKS: Socio-Economic Impacts Box 4.1.3 should align with Article 15(3)(f), covering both foreseeable socio-economic impacts and estimated benefits, including potential negative impacts. Derogations and Unavoidable Habitat Change The format lacks space to address derogations due to climate change (e.g., boxes 4.2.2. and part 12). If restoration is infeasible due to constraints or overriding public interests (Article 4(12)), the relevant box should not require completion. Indicative Maps of Restoration Areas No indicative maps should be included (e.g., boxes 6.2.2.3, 6.3.2.4, 7.2.3.7, etc.). Even as non-exhaustive, they could imply private land designation without consent, contradicting NRR principles of property rights and stakeholder engagement. Thresholds, Baselines, and Methodology Box 6.2.4.3 should remove the 2% threshold since Article 15(3)(c) does not specify one. Box 6.1.2.4 should allow space to describe methodologies for determining favourable reference areas, including reference years. Box 6.2.1.4 should include at national biogeographical level. Box 12.1.2.3 needs clarification on baseline levels for consistency across sections. Inconsistencies and Unnecessary Elements Sections referencing Article 14 are optional; therefore, box 4.2.8 on agricultural and forestry practices should also be optional. Its reference to Article 15(5) is redundant, as this is already covered in box 4.2.7. Box 12.1.3 should be removed to align with the agriculture section (e.g., box 11.1.3 states this part is inapplicable to the first plan). As NRPs are for planning, not monitoring, sections like 6.2.2 (linked to Article 4(1)(a) but not Article 15) and box 10.1.3.1 (monitoring, already addressed in box 5.1) should be removed. Part C of the format complicates Article 15(3)(c) implementation. Linking each measure to multiple ecosystems with additional details on timing is excessive. Assigning unique measure IDs and requiring standardized descriptions impose disproportionate administrative burdens beyond NRR requirements. Subsidies with Negative Impacts Article 15(3)(v) requires identifying subsidies harmful to biodiversity but does not mandate distinctions between types (e.g., energy/fuel-related vs. other subsidies). Box 4.3.2.1 should not introduce this differentiation without clear necessity.
Read full responseMeeting with Helena Braun (Cabinet of Executive Vice-President Frans Timmermans) and European farmers and
2 Jul 2021 · European Green Deal and the next EU Forest Strategy
Meeting with Camilla Bursi (Cabinet of Commissioner Virginijus Sinkevičius) and European farmers and
2 Jul 2021 · European Green Deal and the next EU Forest Strategy
Response to Guidance on REDII forest biomass sustainability criteria
28 Apr 2021
FOAL comments on the operational guidance to RED II implementation
The reality is, 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 the future very important to fulfill the aims of the Green Deal and the Paris climate agreement.
Forest owners of EU countries, united by CEPF, welcome the operational guidelines suggested by the Commission which are key to implement RED II sustainability criteria.
However, on certain aspects, the implementation guideline goes beyond the Directive’s competence and could therefore raise issues regarding Member States' competencies.
We would emphasize 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 to assess this guidance text.
The regulations should stick to the same definition for forest biomass as the Directive it is meant to 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 forests 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 minimized” 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).
Read full responseResponse to Climate change mitigation and adaptation taxonomy
16 Dec 2020
On the delegated act addressing climate change in taxonomy regulation
Sustainable Forest Management (SFM) principles and criteria/indicators are well defined already (for instance, Forest Europe process - the Ministerial Conference on the Protection of Forests in Europe). That is sound basis usrd to guide forestry practices in EU. Sustainability criteria for forest biomass have already been defined in EU legislation (i.e.Renewable Energy Directive, RED II). Forestry is sustainable and there are systems in place at national and local level to verify it. Unfortunately, the proposed delegated act does not take it into account. And that in unacceptable.
Also unacceptable, that with this delegated act Coomision seems to make attempts to shift away from the principle of subsidiarity (competence on the forestry belongs to MS). In addition, delegated act should not be used to introduce new incompatible concepts to EU legislation. When it comes to forestry, the draft delegated goes beyond the Better Regulation principle that “the delegated act cannot change the essential elements of the law”. The delegated act framework is therefore not appropriate and not correct when seeking to invent new sustainable forest management criteria.
We need a coherent approach which is unattached from the end-use of wood when it comes to sustainability. Forest owners do not separate sustainable forest management planning and activities towards different end-uses. The different levels of ambition in criteria for different purposes could change the demand in the wood markets and thus have an impact in forest owners’ management practices. So forest owners in EU promote the RED II risk-based approach when establishing criteria for forests’ sustainability in Taxonomy Regulation.
Uncertainty in definitions makes the evaluation of the delegated act difficult. In the forest related chapters, the delegated act refers to “improved forest management” – improved compared to what? - “close-to-nature forestry”, “stakeholder consultation for forest management plan” and “afforestation plan”. There is no forest owner who would agree this without prior knowledge on the clear definition of these concepts.
The delegated act proposes an extremely detailed forest management plan to be submitted and audited. This should be analysed and discussed prior of making final decisions for implementation, as the management planning choices belong to forest owners. In addition, such planning is regulated in different ways at national level and can’t be required in a harmonized way at EU level. All in all, this delegated act seems to increase bureaucracy burden, shrink forest owners to reporting units who serve the cause of the financing sector.
Read full responseMeeting with Agne Razmislaviciute-Palioniene (Cabinet of Commissioner Virginijus Sinkevičius) and European farmers and
25 Nov 2020 · Exchange of views on the upcoming EU Forest Strategy
Meeting with Helena Braun (Cabinet of Executive Vice-President Frans Timmermans) and European farmers and
25 Nov 2020 · Exchange of views on the upcoming EU Forest Strategy