Norges Skogeierforbund
NSF
Norges Skogeierforbund (english name: The Norwegian Forest Owners' Federation) represent Norwegian family forestry.
ID: 910486492236-86
Lobbying Activity
Meeting with Sven Gentner (Head of Unit Financial Stability, Financial Services and Capital Markets Union)
22 Apr 2025 · Omnibus Simplification package proposals concerning CSRD and ESRS.
Meeting with Taru Haapaniemi (Cabinet of Commissioner Christophe Hansen) and Maa- ja metsätaloustuottajain Keskusliitto – Central Union of Agricultural Producers and Forest Owners and
19 Mar 2025 · Upcoming EU policy developments around the forest-based bioeconomy, in light of the upcoming strategic initiatives of the Clean Industrial Deal and the new EU Bioeconomy Strategy
Response to Report on the evaluation of the LULUCF Regulation
11 Jul 2024
The Norwegian Forest Owners Federation (NFOF) represents 4 forest cooperatives with approx. 30 000 forest owners. We align our selves with the feedback of MTK, LRF and CEPF. NFOF would like to emphasis that it is essential to have a realistic and ambitious climate policy. The main goal should be to reduce the fossil-based emissions. To substitute fossil-based products, we need to increase the use of biomass. European private forest owners are committed to Sustainable Forest Management (SFM). We would encourage the EU commission to support the use of European produced timber and support the private forest owners in their actions to produce sustainable managed forests. SFM and a strong bioeconomy sector is important for achieving the EU climate targets for 2040. The long-term perspective is important for the boreal forests. Normally, it will take 60-80 years from planting to harvesting. There is no quick fix for increasing the boreal forest as a sink. A newly published article from the Fritjof Nansen Institute in Norway highlight the incoherence between forest and climate policy in short- and long-term perspective. Implementing the EU LULUCF regulation in Norway: Short-term and long-term policy coherence challenges - ScienceDirect. In short term, reaching the LULUCF target might imply rapidly reducing forest harvest, but this would reduce the supply of harvested wood products that could supplant less climate-friendly materials and energy sources. In a long-term perspective, forest management like denser planting, fertilization, harvesting, rejuvenation and a change in tree species from low-productive to high-productive forest might be needed to increase the forest sink capacity (p. 7, conclusions). NFOF will underline that reducing the logging and management of forests to keep forest as a carbon sink can be risky, because unmanaged forest is at higher risk in terms of natural disturbances. Conservation of forest is not considered as a climate action measure in Norway (M519.pdf (miljodirektoratet.no). Managed forests are more resistant to natural disturbances. European timber should be used to substitute fossil-based products, and to make products to store carbon. The forest sink in Norway is equal to about 40% of the national emissions from all other sectors combined. The Forest Reference Level and the accounting categories in LULUCF are very unfavorable to Norway. Norway will not reach the goal in the current LULUCF regulation for 2020-2025, and may have to compensate for that. It is difficult to understand that forestry has to compensate for not reaching the goals when the forest sink is about 40% of the national emissions. We will reiterate that the main goal should be to reduce fossil-based emissions and products. We would like to underline the message in the feedback from MTK: Climate actions by forests are based with long-term processes and careful planning. Therefore, the EU policies should emphasize the role of active management for ensuring forests health and capability in providing multiple forest-based products substituting fossils. In the past years forest disturbances due to the climate change have been accelerating drastically. That is why it should be recognised that the capacity of achieving the climate neutrality should not depend on forests since sinks fluctuate due to natural and humaninduced factors. It is unlikely that forests will be able to maintain the current carbon sink as climate change has a strong influence on forests sink and the forests carbon storage is not permanent. Therefore, high targets for carbon sinks should not be seen as a basis long-term climate policy.
Read full response27 Jun 2024
The Norwegian Forest Owners Federation will underline that the Aarhus convention originally referred to the activities of companies and authorities, not the free activities of individual citizens. If the scope is broadened to all activities, also activities done by individual small-scale foresters and farmers, it will have severe and very damaging consequences for small scale forestry and farming. It will also challenge European property rights. The Norwegian Forest Owners Federations would like to underline some of the views expressed by the Swedish Farmers Union (LRF) reply to the consultation: 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. In connection with a recent initiative to broaden the scope of the Aarhus Convention the rapporteur Mr Christian Doleschal stated the following critique of the proposal based on the findings of ACCC: The Aarhus Convention does, in a number of its provisions, indicate that not all members of the public must have access to the review procedure under its framework. Significantly, in Article 9, the Aarhus Convention makes reference to limiting the range of potential applicants to those that have a sufficient interest and remarks that the public concerned shall be given wide access to justice. To argue that the Aarhus Convention obliges its parties to grant every member of the public unconditional access to the review procedure means to attribute a meaning to the Convention that was not intended by its drafters. The same document shows that it is the activities of companies and authorities that are referred to by the Convention, not the free activities of individual citizens. He emphasized the importance of balancing the rights under the Convention with legal certainty for all parties. The Commissioner Virginijus Sinkevičius (DG ENVI) also expressed himself in a similar way in various contexts. Small scale foresters and farmers in Sweden 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, 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. The Norwegian Forest Owners Federation underline that the strongest part here is not the farmer/forester, but the organizations/persons that asks for the information. We fear that a consequence of broadening the scope will be that foresters/farmers quit their activities, because it will be too burdensome to document and answer all the questions asked. It may increase the expenses and be very time-consuming for a small-scale forester or farmer to fulfill all the questions made from the public. We will need a lot more biomass to reach the climate goals, and an unbalanced implementation of the Aarhus convention can in the end harm this goal. It may also harm food and energy security, economic, social as well as environmental aspects. It can make it more difficult to develop the rural regions. The proposal may also have negative effects on property rights, and on this topic we will refer to the reply from the Swedish Farmers Union (LRF). We give our overall support to their reply, and to the reply from the Central Union of Agricultural Producers and Forest Owners (MTK Finland).
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