Norra Skog
Norra Skogs huvudsakliga uppdrag är att företräda det privata enskilda skogsbruket i norra Sverige, bland annat genom att verka för en tryggad avsättning av medlemmarnas skogsråvara.
ID: 433966740561-68
Lobbying Activity
Meeting with Erik Bergkvist (Member of the European Parliament)
10 Nov 2022 · Möte
Meeting with Emma Wiesner (Member of the European Parliament)
9 Nov 2022 · Diskussion om Naturrestaureringslagen & avskogningsdirektivet,
Response to Climate change mitigation and adaptation taxonomy
18 Dec 2020
Norra Skog would like to provide the following comments on behalf of the 27 000 northern Swedish forest owners who we represent. We welcome “green investments” within EU, however we have observed that the proposed Taxonomy document has several shortcomings which all could be contra productive if implemented.
We consider that it 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 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 (see Appendix). 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 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.
Read full responseResponse to Access to Justice in Environmental matters
9 Dec 2020
Norra Skog would like to provide the following comments on behalf of the 27 000 northern Swedish forest owners who we represent. We response to the Proposal for a Regulation of the European Parliament and of the Council on 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, Norra Skog 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 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.
Norra Skog 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.
The Proposal would, in addition to socioeconomic costs, lead to far reaching and negative consequences for individuals and small enterprises. 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. As example, members of the Federation of Swedish Farmers have experienced the development of a very extensive access to court proceedings for NGOs due to the AC, the Swedish environmental Code, other relevant Swedish legislation as well as precedential court decisions.
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.
Norra Skog 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. We strongly request a thorough analysis of the consequences for these parties as well as the society as such. Norra Skog 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.
Read full responseResponse to EU Forest Strategy
4 Dec 2020
Norra Skog´s reply to EC Roadmap on the new EU Forest Strategy
Norra Skog would like to provide the following comments on behalf of the 27 000 northern Swedish forest owners who we represent. We strongly support the following elements in the Roadmap:
The strategy will build on the principles of Sustainable Forest Management (SFM). The aim for a comprehensive strategy to ensure that forests are addressed in a consistent manner across the different EU policies. The recoqnition of the importance that forest sector has in rural communities in creating welfare and spurring growth. The strong focus on training, skills, and jobs. The emphasis on research, innovation, and promotion of new products that replace fossil-based materials and effectively contribute to a new climate neutral society. The focus on adaptation of forests to climate change and on strengthening their resilience. Improve communication and dialogues on forests and their roles, considering the rural/urban interface.
Important elements that are missing in the Roadmap:
The strategy SFM in Europe should be based on the work of Forest Europe, in which EU is one of the signatories. Therefore, a reference to Forest Europe SFM definition, criteria and indicators should be added to the strategy. The key objectives of the strategy should form a holistic approach to EU forests. The key objectives mentioned in the Roadmap (afforestation, restoration and preservation) are limited in scope and do not reflect the many challenges for EU forests and forest sector nor the full potential of services forest provide for the society. Such a limited scope does not provide for a consistent approach between the domestic policies that the roadmap calls for and it also seems to lack strong economic dimension, including the development of circular bioeconomy.
The strategy should be the key tool to make policies that impact forests work in the same direction. It should create conditions that do not hamper the implementation of SFM at national level and respect distribution of competences between the EU and Member States.
The strategy needs to highlight the importance of maintaining and strenghthening motivation of forest owners and managers to manage their forests. It also needs to address the need to work and progress on implementing payment of ecosystem services (PES) especially in the field of climate protection and when SFM is subject to policy restrictions.
Important clarifications that are needed:
Definition for “last remaining primary and old growth forests who may need strict protection” should be provided. Clarification for what ”to strive to decrease the loss of forest coverage” means given that land covered by forests in EU has been increasing for decades. We are concerned about the call “to foresee measures to avoid or correct unsustainable practices”. Definition for ”unsustainable practices” that is based on sound information needs to be provided.
We support the views of European Parliament and Member States:
The strategy should build on Council conclusions (11/11/20) European Parliament. Resolution (8/10/20) which call to take a holistic approach to address forests and their multifunctionality and to build on SFM as defined under Forest Europe.
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