EUROPEAN COMMISSION

Brussels, 22.11.2023

SWD(2023) 373 final

COMMISSION STAFF WORKING DOCUMENT

IMPACT ASSESSMENT REPORT

Accompanying the proposal for a

Regulation of the European Parliament and of the Council

on a monitoring framework for resilient European forests

{COM(2023) 728 final} - {SEC(2023) 384 final} - {SWD(2023) 372 final} - {SWD(2023) 374 final}

1Introduction

2Problem definition

2.1What are the problems

2.2What are the problem drivers?

2.3How likely is the problem to persist?

3Why should the EU act?

3.1Legal basis

3.2Subsidiarity: practical need for EU action

4Objectives: What is to be achieved?

4.1General objectives

4.2Specific objectives

5What are the available policy options?

5.1What is the baseline from which options are assessed?

5.2Description of the policy options

5.3Options discarded at an early stage

6What are the impacts of the policy options?

6.1Identification of impacts and stakeholders

6.2Description of the current situation

6.3Economic impacts

6.4Assessment of environmental and social impacts

7How do the options compare?

7.1Effectiveness

7.2Efficiency

7.3Coherence

Preferred option

7.4Choice of option

7.5Proportionality

7.6Legal instrument

7.7Simplification and improved efficiency

8How will actual impacts be monitored and evaluated?

9REFERENCES

Annex 1: Procedural information

Annex 2: Stakeholder consultation

Annex 3: Who is affected and how?

Annex 4: Analytical methods

Annex 5: Background on Forest Monitoring and forest-related Planning

Glossary

1Introduction

Forests and other wooded land cover close to half of the EU’s land surface and play a key role in mitigating and adapting to climate change, preserving and restoring biodiversity and ensuring the supply of woody and non-woody biomass to enable the transition towards a sustainable and circular bioeconomy . Forested land is, by far, the main contributor to the EU carbon sink and will play an essential role in meeting the EU’s ambitious objective of climate neutrality by 2050. At the same time, forests also provide the raw material (wood and non-wood such as food and medical plants) for growing bioeconomy value chains substituting fossil-based or otherwise harmful products. The extended forest-based value chains currently support 4.5 million jobs in the EU 1 .

Forests provide crucial ecosystem services (such as carbon sequestration, oxygen release and air filtering, water regulation and purification, flood and erosion control, habitats for numerous species, urban cooling and opportunities for recreation). The importance of forest multifunctionality is set to increase in the future, with higher demands to serve as provider of raw material for the bio-based industries in support of a sustainable and circular bioeconomy, as stronger and more resilient sustainable carbon sink as agreed by the EU in the Climate law, as biodiversity hotspot and as recreational space.

But Europe’s forests are increasingly stressed by climate change and direct or indirect human use, activity and related land use changes. These pressures pose a threat to the capacity of forests to deliver on their different environmental and socio-economic functions.

In order to address these threats and ensure that forests are able to fulfil the wide variety of demands, it is crucial to have high quality and comparable data on EU forests, making the best use of the twin digital transition and remote sensing capabilities, as well as long-term integrated planning at the level of Member States for the use of their forests, which depends heavily on the availability of data on forests.

However, currently, monitoring and planning tools in the EU are not fit for purpose to ensure evidence-based sector-specific policy-decisions and measures that consider the bigger picture of forest multifunctionality in a changing climate with increasing risks and uncertainties. Certain data on forest have been collected so far through scattered approaches and tools. The fast developments in monitoring tools and technologies, in particular in earth observation (EO) through satellite or aerial means (including drones), provide a unique opportunity to modernise, digitalise and harmonise the monitoring of forests, as a service to all, forest users and authorities notably to effectively tackle tangible risks to forests, while stimulating the EU market growth on those technologies and related new skills, including for SMEs.

As figure 27 in Annex 5 illustrates, there are several EU policy instruments that directly or indirectly affect forests in the fields of environment and biodiversity, climate, energy and the bioeconomy. The successful implementation and evaluation of these policies and the development of sustainable business models depend on or significantly benefit from high quality forest monitoring. A coherent information infrastructure can support evidence-based policy and decision making by land managers and public authorities, research and innovation. Moreover, a forest information system consisting of strengthened ground-based observations complemented by data from EO allows tracking progress towards policy objectives, compliance monitoring and law enforcement.

The need for enhancing forest monitoring has since several years been repeatedly and clearly mentioned by the EU institutions 2 . The New EU Forest Strategy for 2030, consequently, announced a dedicated legislative proposal on EU Forest Observation, Reporting and Data Collection which should also include Strategic Plans for Forests and the forest-based sector prepared by the competent national authorities.

2Problem definition

Europe’s forests need to be in a good, healthy condition in order to continue, or increase, the delivery of crucial ecosystem services. This is reflected in important pieces of EU legislation and policy, which recognize the multi-functionality of forests in the EU 3 . A comprehensive, high-quality EU-level monitoring system is needed to understand and show how well these objectives are achieved and where gaps remain.

Such a monitoring system does not currently exist in the EU. Instead, current forest monitoring in the EU consists of national systems that measure different forest parameters and indicators in different ways (Annex 5.2 informs in details about today’s forest monitoring systems in the Member States).

With a few notable exceptions such as the Copernicus-driven European Forest Fire Information Service (EFFIS) and the Forest High Resolution Layer of the Copernicus Land Monitoring Service, and harmonisation efforts on a few core variables related to forest resources, the available data are not directly comparable. As described in Section 2.1.1, available data on forests are often outdated or have important gaps, hampering effective response by land managers and policy makers. Overall, information about the status of forests in the EU, their social, ecological and economic value, the pressures they face and ecosystem services they provide, is fragmented and patchy, largely heterogeneous, inconsistent, with data gaps and overlaps, and data is provided with significant delay and often only on a voluntary basis. In other words, the EU lacks a common system to collect long-term, consistent, and comparable forest data. 

Insufficient information on the condition and evolution of forests and in particular forest disturbances dynamics impede the continuous provisioning of socio-economic functions and ecosystem services to society, including their climate change mitigation potential. The lack of timely and accurate information in combination with the absence of long-term planning integrating the impacts of climate change hinders the development of adaptive management strategies to increases forest resilience, disaster preparedness and response. This problem does not only affect EU-level decision-makers, with the risk of misinformed or failing EU policies in the climate, environmental, social and economic domains, but also forest planners and managers in many Member States, and players in the private, financial and insurance sectors, who risk taking poor decisions (e.g. on logging or on species to plant) based on incomplete information. This is likely to affect not only the distribution, shape and composition of future forests but also the associated industries and employed workforce.

These problems would already be significant under current conditions. However, the onset of climate change has made comprehensive forest monitoring more urgent and demanding. Dramatic disasters and growing levels of stress-induced loss of forest health show how climate change has started to transform today’s forests. Shifts in forest disturbance regimes are compromising all forest functions and causing significant costs. For instance, the European heatwave and drought event in 2003 resulted in a strong net release of CO2, reversing the effects of four years of net carbon sequestration, and reduced forests’ gross primary productivity by 30% 4 . The drought starting in 2018 caused a forest canopy loss of around 5% and financial losses forests damage of about EUR 18 billion in Germany alone 5 . As climate change progresses, scientists expect further increases in tree mortality, and they estimate more than 60% of the biomass in European forests to be exposed to climate risks 6 . In the light of increased forest disturbances, biodiversity loss and growing demand from the society on forest functions – including biomass 7  and non–timber related resources, the lack of a consistent and comprehensive forest monitoring framework, together with the current absence of harmonised planning instruments that include a long-term perspective and consistently address forest multifunctionality via an integrated approach, hampers the assessment of policy coherence and appropriate policy making.

This situation also makes the prevention and response to illegal logging and biodiversity loss difficult. There are several open infringement procedures against Member States 8 for logging activities in breach of EU legislation, in particular EU nature protection legislation, and the collection of data and evidence, though essential and decisive, has proven challenging and costly.

In conclusion, the absence of complete, harmonised, comparable, and timely data hampers cost-efficient implementation of EU and national/regional policies and targets and increases the risk of drawing wrong conclusions, which could lead to poor decision making from local to EU scale. An increasing number of objectives and targets for urgently needed actions on forest resilience and protection of their essential functions for climate, biodiversity and the bioeconomy will make the lack of knowledge even more apparent.

2.1What are the problems

This impact assessment addresses two specific but interrelated problems:

·lack of data comparability and quality 

·lack of integrated long-term forest planning,

which underpin the general problem of not having adequate and timely information on forests to make effective policy and ensure that forests contribute to multiple EU policy objectives.

2.1.1Lack of data comparability and quality

Forest data and information gathered in the EU varies significantly and is not comparable between Member States. The spatially incomplete and temporarily inconsistent information 9 limits policy and decision making at all levels, making it very difficult to base decisions on evidence and face the growing pressures on forests. 

As an illustration, Maes et al (2020) specified current key data gaps in the areas of forest pressures (e.g. drought, storm damage, over-harvesting) and forest conditions (e.g. defoliation, data on other forest species or structural diversity of forest stands). Avitabile et al. (2023) highlight that information on forest resources such as forest biomass, annual increment or fellings in the EU are currently patchy, imprecise, and updated too slowly. They are derived by a range of methodologies for parameters with different definitions across Member States. The Science for policy report by the abovementioned collective on Biomass production, supply, uses and flows in the European Union provides a comprehensive discussion of the needs for harmonisation of forest data and the inherent uncertainty of the harmonised estimates, e.g., due to the incomplete time series, low temporal frequency and lack of common reporting.

To exemplify the problem with lack of reliable data on a key variable with policy relevance, there were some 98 million cubic metres of fuelwood with a source that was ‘missing’ from reported data in EU-28 in 2013 – something likely attributable to under-reported felling and wood removal 10 . A more recent report found that, despite the abundance of available datasets, there are still large data gaps on the sources and uses of woody biomass for energy, and that most datasets are incomplete or provide insufficient detail 11 .

A generally perceived need for comparable forest information at EU level and for more harmonized information collection methodologies has been highlighted by the Standing Forestry Committee already in 2012 12 . 

The replies to the open public consultation (OPC), further elaborated in Annex 2, reveal that 84% of the respondents consider consistent and comparable forest information across borders as an important or very important improvement of forest monitoring in the EU with no significant differences between stakeholder groups. They highlighted the need for harmonized and timely information on a number of variables, particularly on forest health, disturbances, and climate change impacts and projections (more than 88% of respondents). Likewise, responses to the call for evidence showed high support for consistent and comparable definitions, indicators, and measures of forest status across all Member States. At a Member State and stakeholders workshop hosted by the Czech Council Presidency (second semester 2022), participants stressed the importance of harmonised or standardised information on the state and development of EU forests (Annex 2). Standardisation of core parts of forest inventories between Member States was also mentioned as a possibility in the long-term perspective as one of the conclusions of a subsequent workshop with Member States and stakeholders organised by the Swedish Council Presidency 13 .

Most national forest inventories (NFIs) are geared towards planning wood resources management with a focus only on economic, production-related variables such as volume of growing stock 14 . The current monitoring systems therefore tend to provide insufficient and patchy data on indicators related to biodiversity, forest health and resilience, and non-wood resources, which are priority areas identified in the New EU Forest Strategy for 2030. This is important also because the sustainability and long-term provision of wood resources fully depends on forest biodiversity, health and resilience.

The lack of comparability of the status and trends of forest ecosystems in the EU makes it difficult to track progress towards EU policy objectives and goals. A special report of the European Court of Auditors concluded in 2021 that the current monitoring system for the impacts of Common Agricultural Policy’s (CAP) forestry measures for rural development is lacking, especially in the areas of biodiversity and climate change effects 15 . 

Annex 5.2 provides further information on the current situation - Tables 21 and 22 provide a comprehensive overview of forest indicator coverage in Member States’ monitoring and reporting and show that, on average, forest information is insufficient especially in the areas of forest biodiversity and resilience.

NFIs have evolved in distinct ways in EU Member States with country-specific methodologies, partially serving different purposes and policies (Annex 5.2, Table 20). Even basic concepts and definitions of key forest variables are not consistent between Member States 16 (Annex 5.2, table 18). Many EU countries use different definitions for forest, forest types, and forest available for wood supply 17 , and some EU regulatory frameworks allow Member State-specific forest definitions 18 . Regarding data collection, some Member States (e.g. France and Sweden) sample between 10 and 20% of their observation plots each year, while others such as Germany or Austria sample all plots at once after 5 to 10 years. A few Member States have not conducted ground sampling campaigns for NFIs over the last two decades or more (Table 20 in Annex 5.2). -In several cases national datasets are not compatible with international definitions 19 , available only in local languages 20 , or employ a methodology that is not commonly agreed or transparently documented 21 .

The quality of data sets and indicators varies among the EU Member States 22 . In several cases, more attention is given to socioeconomic quantitative information (e.g., growing stock, increment) over environmental qualitative (health, biodiversity, resilience), which limits the accuracy of certain indicators, notably for biodiversity. Too much reliance on proxy indicators can increase accuracy problems 23 .

Annex 5.2 informs also about specificities of inventory-based in-situ monitoring approaches and the pros and cons compared to forest monitoring by EO. In-situ based inventory systems lack spatial continuity, granularity, timeliness and frequency compared to EO-based approaches. EO may result in ambiguity of automated data interpretation or differences in definitions 24 . An EU-wide platform for the integration of in-situ and remote sensing information is currently lacking, which would allow to create precise, statistically-sound estimates of target variables that correlate well with the remote sensing information using models.

Furthermore, there is a trade-off between continuation and innovation, which affects both in-situ and remote sensing-based monitoring. Emerging techniques may improve the quality of products related to accuracy, certainty, granularity, timeliness and frequency but introduce inconsistency in the time series with regards to data collected in the past 25 . In many cases, techniques can be developed that cater for or prevent such biases and inconsistencies, hence allowing for comparability between historic and new measurements.

The absence of comparable data prevents transparent and integrated monitoring of forests in the EU, for instance, on wood harvesting for different purposes, growing stock, forest management practices, ecosystem health, resilience and related biodiversity 26 . The current forest monitoring landscape in the EU provides a rather ‘static’, patchy picture which fails to provide coherent and up-to-date information on EU forests 27 . This not only leads to inadequate data for informed development and implementation of forest-related legislation and policies on the EU level (see links to EU legislation and strategies in Table 21, Annex 5.2), but is also not cost-efficient and prevents acquiring a holistic view on the state of forest resources in the EU and potentials for their future development. Moreover, Vidal et al. (2016) argue that national differences in definitions, methods and scope of forest monitoring might make EU reporting under international processes such as FAO FRA or UNFCCC inconsistent.

At the level of the forest manager, making data more comparable between Member States, by following common definitions or standards, has the potential to decrease the costs for forest owners deciding to participate in voluntary carbon farming schemes, such as the EU Carbon Removal Certification Framework and would also allow for more informed management decisions and effective communication thereof, with corresponding reputational benefits, to the advantage in particular of SMEs and small forest owners.

Accuracy, timeliness, continuity and transparency of information are key issues for the quality and trustworthiness of forest monitoring, which is crucial for foresters to benefit from emerging payment for ecosystem services schemes. The granularity of data and information is essential to ensure their policy relevance and uptake by all user communities. More accurate and trustworthy forest information was identified as a key need of stakeholders in the OPC. This is valid across all stakeholder groups - although business associations showed the lowest values with only 36 % of respondents considering accuracy and trustworthiness as very important or important, 46% responded with ‘somewhat important’.

Transparent data means access to data and information for all stakeholders (see Annex 3 for details on affected groups). Today, access to official forest data is limited and unequal between the user groups 28 . Even though aggregate data from NFIs is generally publicly accessible, the basic plot level measurements and in particular the geographic location of measurement plots are not disclosed or are blurred, which limits the possibility for comparison. Administrations and organizations responsible for plot-level data collection justify the limited access by highlighting bias in the management of forest where permanent plots are located, compliance with personal data protection and privacy policies, and inter organizational agreements 29 , intellectual property rights, the potential for misuse and misinterpretation, or deliberate interferences on the forest plots 30 . The limited access to basic forest data makes it hard to assess whether these restrictions are fully justified in light of public interest to environmental information and complicates a critical assessment for non-state stakeholders, such as private organizations and NGOs 31 . Among public consultation respondents representing environmental organisations, academic institutions and EU citizens, between 81% and 100% agreed with the need for better open access to forest information.

Efficient and effective data dissemination is important to serve and build trust in different user communities. Forest data is inherently complex with differing definitions and interpretations in various user communities.

Current data interfaces and voluntary tools such as Forest Europe and the Forest Information System for Europe (FISE) only provide basic indicators aggregated at Member State level, such as forest area, growing stock or annual roundwood removals. There is a lack of user-friendly query tools for detailed data and data at the level of parcels or lower administrative units that is required by land managers, particularly smallholders, and researchers.

Consequently, usefulness of the information and the form how information is delivered does not meet the needs of the potential users including civil society, the private sector and academia 32 . Today’s rigid frameworks may also constrain the exchange and acquisition of scientific forest information and cross-sectorial connection, which in consequence slows down the development of NFIs and of EO-based monitoring systems 33 .

2.1.2Lack of integrated long-term forest planning

In order to ensure that forests can deliver on their multiple functions, including those that have been agreed on in EU legislation, long-term planning of forest management is required. Planning horizons in forestry usually stretch over many decades – the time it takes between planting and felling, and for the forest to deliver its full range of bioeconomy functions including vital ecosystem services..

Likewise, several forest-related EU policies take a long-term view. For instance, the core goals of making the EU climate-neutral (EU Climate Law and Land-Use, Land-Use Change and Forests - LULUCF) and climate-resilient (EU Adaptation Strategy), or to maintain and restore European ecosystems (proposed EU Nature Restoration Law -NRL) are to be reached by 2050. Many climate change projections cover the period until the end of this century, including many studies on how forests will react to, and will be impacted by, accelerating climate change.

In sharp contrast to this, the following gaps could be identified:

-most national planning instruments in the EU do not go beyond a 10-year forest planning cycle. Only a few Member States developed a long-term vision for their forests, typically for 2050 (Table 23 in Annex 5);

-several planning instruments only address forests from specific policy perspectives: by way of example, National Energy and Climate Plans and Long-Term Strategies 34  cover carbon sequestration, renewable energy and energy efficiency; national and regional climate adaptation strategies cover climate adaptation needs etc. An overview of existing planning tools, their relevance for sectoral forest policies and their different cycles for reporting and review is included in Table 24 of Annex 5;

-there is a lack of a holistic analysis and integration of policies and societal demands related to forests, which are often not prioritised, also in terms of funding;

-missing coordination and communication, often happening if there is a split in national competences and if there is no cross-sectoral exchange between forest stakeholders and others 35 ;

-the heterogeneity of information covered by the current planning instruments affect their comparability or possible exchange with other Member States, which is key to prepare a rapid and efficient response, particularly for threats with a cross-border dimension such as plant pests or wildfires 36 ;

-planning instruments are furthermore not always fit for purpose to reflect recent policy developments for forests and forestry at EU and national level due to economic and capacity constraints that would require a structured response at strategic and prospective level, also as regards funding opportunities (currently scattered in different instruments);

-presently there is no governance framework nor coordination at EU level to ensure harmonisation of the plans in order to address the abovementioned gaps.

With regard specifically to policy fragmentation in terms of planning, an assessment performed on Member States’ tools along five key thematic areas relating to forestry (forest resource status and trends, biodiversity, forest based economy, ecosystem services and climate change) has identified the following gaps in Member States’ coverage of certain areas:

·The consideration of the bioeconomy (see Table 25 in Annex V) was the most frequently lacking policy area in the EU27. A number of Member States have limited reference to the bioeconomy sector, some of those within other forest-related policies or strategies (BE, EL, LU, SK), or having a bioeconomy policy in place at regional level only (BG).

·Biodiversity and climate change were the two thematic areas where all Member States have either specific strategies in place or have substantially integrated them into their national forest policies or related policies.

·The status and trends of forest resources is generally well reported and considered in national strategies or plans, particularly due to the NFI network and the availability of national forest strategies for most countries.

·Cyprus is the only Member State without strong evidence of planning or consideration for forest ecosystem services. However, for other several Member States it emerged that ecosystem services have a small role within a larger related area and are not specifically provisioned for. Ecosystem services are often nestled into wider biodiversity or climate change plans as they can be secondarily affected by the outcomes of these broader thematic areas.

Policy fragmentation and the lack of a harmonised set of information across the current planning instruments in Member States leads to a risk of setting policy targets or objectives that are mutually exclusive, creating mutual unintended trade-offs and inconsistent policy-making and implementation on the national and consequently EU level. Instead, an integrated, balanced assessment of needs across different sectors is needed to evaluate the overall ambitions and potentials with regard to the provision of various forest ecosystem services. Integrated forest planning based on clearly defined long-term strategic policy needs and forecasting is key to inform the structure of monitoring which in turn will allow to assess planning performance and adapt it if need be. Addressing the lack of a long-term integrated approach in terms of planning, including forecasting, would therefore contribute to further developing forest monitoring. Annex 5.3 includes an EU-wide SWOT analysis synthesising the main existing, missing or contradicting elements of forest planning and strategic documents and an EU-wide gap analysis.

In the OPC, respondents were asked to select among different options of what could be the benefits of strategic forest planning. Respondents most frequently pointed to providing a holistic view on forest status and trends as well as allowing for overall coordination of long-term forest planning (Figure 19 in Annex 2). The issue of policy fragmentation raised above is reflected in the OPC results, as when asked about their level of awareness of the various existing planning instruments, 69% of respondents, with the majority belonging to the stakeholder groups of EU citizens and NGOs, indicated that they know or use national or regional forest strategies, but much less sectoral forest-related instruments (with National Bioeconomy Action Plans ranking the lowest with 27%. .

2.2What are the problem drivers?

Table 1: Specific problems, drivers and objectives to be addressed by the legislative initiative

2.2.1Drivers behind the lack of data comparability and quality

In the absence of a market incentive, there has been no general interest to monitor the environmental impacts of forestry, nor of non-timber-related forest bioeconomy (e.g. hunting licenses, eco-tourism). As a matter of fact, the price of timber resources, just as it is the case for natural resources in general, reflects historically a market where the impact of forestry on biodiversity and climate is generally not taken into account (externalities).

Only recently have data on environmental aspects, such as benefits of forests for climate change mitigation and adaptation and (mostly limited to protected forests) for biodiversity, started to gain attention, though still in a patchy manner. Such data is, however, increasingly important, given the EU’s agreed climate policy and scientific evidence, which demonstrates that the forest resilience, adaptive capacity and capability to provide multiple products and services is dependent on forest ecosystem health and biodiversity.

Member States have developed different approaches for data collection, measurement systems, definitions, statistical processing, and different time frames for collection and dissemination of forest information because many Member States have developed their monitoring frameworks long before joining the EU and EU has not had a regulatory framework for forest monitoring (see Figure 28 in Annex 5.2). The lack of a regulatory framework at EU level has also contributed to the largely uncoordinated developments between Member States. The main argument against applying common standards to NFIs is the potential disruption of the measurement time series, control over measurement plots, the long experience gained with the existing systems 37 .

Some international efforts for harmonization and standardization of NFIs, such as collaboration under the European National Forest Inventory Network (ENFIN) program, including framework contracts with the Joint Research Centre (JRC), have been made over many years with progress on harmonization limited to a few indicators, mainly limited to the areas where cooperation was agreed under international conventions, such as the International Co-operative Programme on Assessment and Monitoring of Air Pollution Effects on Forests (ICP Forests 38 ).

Existing national forest monitoring systems are expensive 39 . Several Member States operate forest-monitoring systems over many decades with data collection ongoing over many years to produce consistent time series 40 (see Figure 28). A change in the data collection, including the inclusion of data from EO to improve spatial granularity or frequency, could imply a temporary extra cost and at least a partial disruption of the time series. Furthermore, not all ecosystem services provided by the forests have been considered important, since the market rewards mainly the selling of timber.

Market and regulatory failures are also behind limited information or restricted access to data. Recent studies also concluded that a major reason for constraining the exchange of forest information is the lack of motivation and unwillingness due to lack of political, social, and/or economic incentives for data collection, processing, provision, and dissemination 41 . In the absence of a regulated monitoring framework, there is an overall concern on the unintentional misuse of data or false interpretation due to the lack of detailed on-site knowledge. In limited form, Member States share some information in the voluntary collaboration under ENFIN and other international projects, which seek improving the forest monitoring and information, however, after years of cooperation, limits of such voluntary efforts in terms of data accuracy and timeliness have been repeatedly reached 42 . The recent EU proposal for certification of carbon removals will provide financial incentives for increasing carbon storage in forests. This will lead to higher needs for information (on carbon removals and related co-benefits, such as higher biodiversity), by stakeholders motivated to obtain these financial incentives, especially SMEs active in the sector.

2.2.2Drivers behind the lack of integrated long-term forest planning

Existing planning instruments in Member States often lack the analysis of forest policy coherence today and for the future with increasing demands and threats. Medium- and long-term forest strategies (e.g. DE, AT) tend to be broader in their scope and have to take more aspects into consideration (climate change, biodiversity, social development etc.) than very short-term demand-driven strategies. Planning often reflects sectoral policies, approaches and priorities, mirroring scattered responsibility among different departments/ministries or administrative levels, particularly in the systems where planning is taking place also at regional level, resulting in difficult coordination and communication among these levels. The existence of EU sectoral but uncoordinated legislation is also a reason behind this situation.

Existing planning documents such as national Forest Strategies and Programmes typically have a 10-year cycle and address primarily the economic value of wood-based bioeconomy, which is the only one reflected in the market price of timber. The lack of market incentives to address climate and biodiversity and non-timber forest bioeconomy results in scarce considerations of these dimensions in planning. Better plans need better data as outlined in the section above. Even if climate mitigation and adaptation or biodiversity are covered to some extent by existing EU and national planning instruments, this is not yet prioritised at sufficient scale neither it is done in an integrated manner. This is for example demonstrated by the fact that spending on forestry measures amounts to only 3% of all rural development spending under the CAP. Moreover, overall funding for forested areas from the EU budget is much lower than for agriculture, representing less that the 1% of the CAP budget 43 . Long term-planning for environmental reasons is often absent (see SWOT and gap analysis in Annex 5.3). Lack of planning for climate and biodiversity threatens the forest-based bioeconomy and ecosystem functions of forests, given the interdependencies. Lack of attention to non-wood forest bioeconomy disregards the importance of sectors, which bring income and jobs to local communities and have often co-benefits with climate and biodiversity objectives.

2.3How likely is the problem to persist?

While forest-related data needs are increasing in several EU policy fields and indicators are defined for monitoring, the state of forests and the demands on forests, the challenges related to consistent and improved information systems including common indicator development and to coherent and streamlined forest planning across policy domains are likely to persist. Details are provided in section 5.1.

3 Why should the EU act? 

3.1Legal basis 

The proposal is based on Article 192(1) of the Treaty on the Functioning of the European Union (TFEU), which gives the Union the right to act in order to achieve objectives of its policy on the environment. The Court of Justice of the European Union has confirmed in Joint Cases C-164 and C-165 that measures, such as those aimed at protecting forest from wildfires and air pollution, inherently form part of the environmental action that the EU competence is founded on, in Article 191(1) TFEU. The objectives of the Union policy on the environment as defined in Article 191(1) of the TFEU include, inter alia, preserving, protecting and improving the quality of the environment; a prudent and rational utilisation of natural resources; and promoting measures at international level to deal with regional or worldwide environmental problems, in particular combating climate change. The Union policy on the environment shall aim at a high level of protection taking into account the diversity of situations in the various regions of the Union. It shall be based on the precautionary principle and on the principles that preventive action should be taken, that environmental damage should as a priority be rectified at source and that the polluter should pay. Pursuant to Article 4 TFEU, in the field of environment, the EU shares competence with its Member States.

The same legal basis underpins Union measures aimed at protecting forest ecosystems from disturbances 44 . A monitoring framework for resilient European forests will provide the data which will enable monitoring the European Green Deal targets related to forests and develop policies to protect forest ecosystems. Given that environment is an area of shared competence between the EU and the Member States, EU action must respect the subsidiarity principle.

3.2Subsidiarity: practical need for EU action 

Necessity of EU action

Forest monitoring is currently patchy and fragmented, which prevents the Union from acting in a timely manner against stressors and threats (with a cross-border dimension), as advocated by the new EU forest strategy and from making the most out of cost-effective technological developments and digital innovation, particularly in the area of EO. The situation has arisen by the Member States developing their national forest monitoring systems in an uncoordinated manner over many years (see Figure 28 in Annex 5.2). While forest ecosystems often stretch across borders, forests are often seen as sovereign entities and no consistent, transnational data gathering approach has been fully developed so far (UWE Bristol, 2021, p. 82). Member States are unlikely to resolve this fragmented situation without EU intervention. The OPC results indicate that respondents expect that EU intervention will result in better scientific knowledge about forests, improve the prevention and response to natural forest disturbances and benefit forest management and planning.

The risks posed to forests by the climate emergency demonstrate the need for a coherent system to monitor and plan for transformations in forests and the forest-based sector as a result of climate change. In addition, the climate and biodiversity crisis require a re-consideration of the role of forests with greater focus on their multifunctionality. In this context adequate and comparable data on forests and is a prerequisite to achieving the climate, biodiversity and sustainable and circular bioeconomy policy objectives stemming directly from the European Green Deal. Providing Member States with instruments to develop long-term planning and make the most of the data at their disposal would also support this goal.

EO is a game changer in monitoring but requires a coordinated approach both at the level of technology development and use (especially satellites) and at the level of the necessary ground-truthing activities, which must be sufficiently harmonized. There is in addition a need to monitor the effects of other policy actions comprehensively and cost-efficiently.

Consequently, intervention at EU level is needed in view of:

(I)the scale and crossborder nature of the problem,

(II)the impacts on citizens across the Union as well as the risks to its economy from growing disturbances, and

(III)the need to monitor the effects of EU policies and legislation and to anticipate the need for policy changes with a view to achieve targets.

Added value of EU action

Taking action at EU level, within the limits of the objectives that cannot be achieved sufficiently or most effectively by the Member States in the absence of an EU framework, would provide a clear added value in terms of consistency and economic efficiency.

Although, together EU Member States spend 50 million EUR annually on their national forest inventories (Maes et al., 2020), often the information is unusable transnationally because countries cannot agree on definitions of parameters, the data are outdated or are too coarse (Nabuurs et al., 2019). Nabuurs et al (2019) also argued that basing forest policies on very little or outdated information might lead to undesirable trade-offs. Maes et al. (2020) make clear that systematically collecting harmonised, spatio-temporal data from across the EU will be an important step towards tracking and preventing pressures at a pan-European level, such as forest pests, droughts or invasive species.

Action in this sense is also supported by respondents to the open public consultation. Across stakeholder groups, more than 60%of respondents agree that data from Member States’ monitoring systems should be better integrated. Split by stakeholder groups, 73% of all respondents from academia and 75% from public authorities agree or somewhat agree. However, this percentage is smaller for business associations (36%). Additionally more than half of respondents think that the EU should operate a single monitoring system. The highest support for a single monitoring system is shown by EU Citizens and Environmental Organisations, with 69% and 67% respectively agreeing or somewhat agreeing, whereas 56% of all responses from the stakeholder group ‘company’ disagree or somewhat disagree. Only 40% of respondents agree that Member States should continue current monitoring systems (business-as-usual). Among the different stakeholder groups, 70% of the environmental and non-governmental organisations and 49% of business associations, company/business organisations and public authorities together support a common approach to monitoring which should build on existing data collection and reporting processes. Key business players expressed clear support for the legislative proposal underlining for example reliable, comparable and science-based data as the foundation for ambitious policy-making and sustainable forest management as well as encouraging National Strategy Plans by all Member States as a useful tool to implement the EU Forest Strategy 2030. Half of those EU Member States that expressed their views on the repartition of competences between the EU and the Member States, during a public debate in the Council on 22 October 2022), also supported a common approach to monitoring, building on existing data collection and reporting processes. A general support was expressed by the Member States experts participating in the technical workshop organised by the Czech Presidency in September 2022 (see section 6.1 or Annex 2 for the full report ) to the importance of reliable, verified harmonized or standardized and up-to-date information and communication on the state and development of EU forests, inter-alia for informed both policy- and decision-making at the EU level.

Standardised, comparable information would allow to check the viability, consistency and sustainability of the many and various forest-related policies at EU level (or to identify trade-offs) in a cost-effective manner. Table 21 contains information on how the forest data considered for the monitoring framework link to specific legislation and policy objectives. Data harmonisation or, where appropriate, applying a standardised approach – particularly by taking advantage of the innovative solutions in the EO field – has the potential to lead to significant cost savings. Freely available satellite data can additionally facilitate compliance verification for national competent authorities and reduce reporting burden for stakeholders with obligations relating to forest land use. Moreover, the development of a more standardised approach to EO-based data collection acts as a strong facilitator for European SMEs related to the digital transition. As seen in the development of similar monitoring technologies for agricultural policy, by applying common approaches for data collection, companies executing this work will enter a developing market and thereby provide better value services (for data collection and processing), which in turn will stimulate more expansive, more regular data collection in a virtuous cycle.

Such a monitoring scheme would also allow identifying the relationship between the condition of forests and anthropogenic stress factors, including climate change, and potential future risks of forest disturbances at a reduced cost compared to a scenario in which each Member State operates its own monitoring scheme. It would also allow to support Member States which would encounter significant needs to improve their forest monitoring (see Table 20 for an overview of Member States’ monitoring).

Increasing disturbance frequency and intensity, for example by bark beetle outbreaks, wildfires or wind storms, result in greenhouse gas emissions, biodiversity loss and market distortions that have a significant crossborder dimension. They may also cause abrupt increases of salvage logging with a direct impact on the market across countries. As an example, the early detection of bark beetle hotspots (to which EO can effectively and efficiently contribute) is essential for reducing the extent of salvage logging, which is liable – when occurring in large scale – to disrupt the timber market, with particularly negative effect on SMEs which are heavily dependent on timber price. In the absence of a clear framework, punctual or sporadic exchange of information between administrations or stakeholders at national level is not sufficient to provide for a systematic coordinated response to these disturbances. Moreover, there is a crossborder long-term dimension due to the fact that the already observed northward migration of agro-climate zones is expected to accelerate significantly in the coming decades 45 , making comparability of long-term datasets across borders a growing asset for forest owners and managers.

Finally, a level playing field for forest products from sustainably produced biomass would reward foresters and land managers who implement land management schemes with co-benefits for the climate, biodiversity and the bioeconomy. The EU is the appropriate actor in this case, as it has a long standing experience in working for the convergence of forest indicators and on data collection methods to obtain comparable and EU-wide data. This is not something that can be tackled at the level of individual Member States. Drawing on existing monitoring systems and emerging science, promotion of EU-wide methodological standards and knowledge sharing will also enable more cost-efficient reporting and monitoring.

With regard to cost effectiveness, a very important aspect in relation to EO is economies of scale. This is self-evident in the case of developing satellite technology, but also in the area of Laser-imaging, Detection and Ranging (LIDAR) monitoring, where the cost per hectare can be considerably reduced, the larger the surface to monitor. Moreover, past frontload investments into Copernicus monitoring services means that these systems are already in place and putting them into practice will contribute to cost-efficient use of this EU investment.

As regards planning, several Member States have planning instruments in place but the information covered is not harmonised at the EU level, affecting comparability and policy-making as aggregated information on national forest-related policies form the knowledge basis for the design of EU policies and strategies. Moreover, having an integrated and long-term approach to planning allows Member State to implement various EU policies relating to forests (LULUCF, Nature Directives, Renewable Energy Directive etc.) and their respective targets and objectives in a coherent manner, addressing potential trade-offs. Member States that have established and well-working planning frameworks would be able to continue their instruments. They would nonetheless have the possibility of entering a coordinated governance system to ensure temporal homogeneity and provision of common information . The added value of EU coordination and governance would be to ensure that plans across the EU have a similar structure for better delivery on forest-related policies at the EU level such us those delivering on forest bioeconomy or climate adaptation.

Comparability and exchange with other Member States was also selected as added value of strategic plans by 52% of all the respondents to the open public consultation without a significant difference across stakeholder groups. Among the options given to choose from, it ranked the third highest shortly after providing a holistic view on forest status and trends (55%) and overall coordination of long-term forest planning (53%). Only 5% of the respondents did not see any added value in strategic plans mostly linked to the concern that the intention would be to establish strategic plans for forests at EU level.

4Objectives: What is to be achieved?

4.1General objectives

The general objective of this initiative is to develop an EU-wide monitoring framework for resilient European forests, which will seek to, as a general objective related to the implementation of Article 191 TFEU, contribute to:

·the EU commitment to combat climate change and achieve sustainability goals; and

·improving the level of preservation, protection and quality of the environment

This will be achieved by ensuring more data-driven decision and policy-making on forests, which is expected to increase public trust in forest management, reduce illegal logging, incentivise and reward more sustainable forest management, and support the adaptation of forests to climate change, therefore contributing to the Commission policy priorities outlined in strategic policy documents such as the EU Biodiversity Strategy, the Adaptation Strategy and the New Forest Strategy for 2030.

It is important to highlight that this initiative is about better data, knowledge and planning but does not impose on forest management policy choices and objectives of the Member States.

4.2Specific objectives

Based on the problem definition and the problem drivers described regarding forest monitoring and integrated forest planning in the EU, the specific objectives of the initiative are described below. It is important to note that the objectives are intrinsically linked to each other since efficient monitoring requires clearly defined strategic policy needs and monitoring provides the evidence base needed for long-term planning that integrates different forest-related policy objectives.

4.2.1Ensure availability of common consistent, comparable, timely and accessible data

In light of the new policy mandates and strategic objectives under the European Green Deal, such as those identified in the Biodiversity Strategy, Adaptation Strategy or the New EU Forest Strategy for 2030, this initiative aims to lay down a set of common indicators and methodologies to ensure that data collected across Member States on forest conditions and management are consistent, comparable, timely, particularly by making the most out of the digitalisation potential, and that they cover the relevant policy data needs on forest. The priority topics are those of climate change mitigation and adaptation, forest health and resilience, biodiversity and ecosystem condition, forest management and forest bioeconomy.

As an example, the production and dissemination of timely data is needed for land managers and policy makers to swiftly assess the current situation, implement corresponding response measures or adjust related policies. The forest data need to be furthermore collected in a transparent way and disseminated so that they are accessible to all relevant stakeholders and data users. EO, including EO data provided by the Commission via the Copernicus programme, combined with ground-truthing provides a significant potential to this end.

4.2.2Facilitate integrated long-term forest planning

The development of a strategic vision of the forests and the forestry sector by Member States will address the problem of insufficient and fragmented long-term planning for forests with limited consistency across policy objectives with relevance to forests and the forest-based sector. A governance framework for integrated forest planning can help to minimise conflicting objectives and maximise synergies across forest policies.

5What are the available policy options?

5.1What is the baseline from which options are assessed?

Under a baseline scenario forest monitoring and planning continues to be based partly on the legal frameworks at the EU level and partly organised separately by each Member State under voluntary international monitoring and reporting frameworks, e.g. Forest Europe’s State of Europe’s Forests (SoEF) and ICP Forests, or country reporting into international frameworks of obligatory nature such as FAO’s Global Forest Resource Assessment (FAO FRA) und greenhouse gas reporting to the UNFCCC. Table 21 and 22 in Annex 5 illustrate the coverage and diversity of forest-related indicator collection in the EU-27.

Considering the latest reporting year in the SoEF 2020 under Forest Europe, forest data availability differs greatly across Europe. Even though certain international frameworks collect information on forest vitality (ICP Forest), fragmentation (CORINE dataset), forest management objectives (FAO FRA) and the occurrence of common forest birds (Pan-European Common Bird Monitoring – PECBMS), data availability for other forest indicators remains scarce. For example, only sixteen Member States provide data on forest disturbances to the SoEF and only nine Member States publish data on threatened forest species. Without a common framework for monitoring, the efforts are likely to remain scattered, incomplete, and insufficient for the purpose of EU-wide assessments (Table 22 in Annex 5). At the same time, pressures on forests will increase, making the lack of consistent, complete and comparable spatio-temporal data an even greater problem in time.

The necessity of addressing challenges related to the integration of EO and ground-based data is increasingly recognised in the EU Member States 46 . This requires interoperability, common definitions, no ambiguity in data interpretation and long and comparable very high-resolution time-series. Current forest products from Copernicus represent a progress but so far limited to the indicators on tree cover density and dominant leave type and with rather limited uptake by state-level stakeholders 47 . Without a common framework and the engagement of stakeholders for building trust and a common understanding, the gap between potential improvements through the uptake of new technologies and available data will inevitably grow, hampering the EU’s ambitions for a digital Europe.

Similarly, without an EU framework for forest monitoring, it will remain challenging to demonstrate that the EU is on the right track in implementing its relevant policies and ambitions, and that the forests can actually deliver on their multiple demands and functions.

The EU legal framework is set to evolve through several legislative proposals by the Commission with relevance to forest monitoring and integrated forest planning, namely on the NRL 48 and an amendment of the European environmental economic accounts Regulation 49  introducing a new forest accounts module. Where adopted, these legislative proposals will establish some mandatory indicators as well as lay down some reporting and monitoring requirements in support of their specific policy objectives (Table 21 in Annex 5). The NRL proposal furthermore provides for the establishment of restoration plans including forest ecosystems where relevant. However, the monitoring and reporting requirements of certain forest-related parameters included in the NRL proposal are designed for restoration purposes and only concern national average value, whereas a comprehensive forest monitoring framework would require broader indicator coverage and a more detailed level of granularity. The NRL proposal includes a certain level of harmonisation for the indicators, while some incentive for the use of EO is foreseen 50 , e.g. for the monitoring of forest connectivity. 

With the provisional agreement between Parliament and Council on a revised LULUCF Regulation, monitoring of annual carbon fluxes in forest land can be expected to improve. The LULUCF reporting approaches and methods, applied by Member States under the Governance Regulation, are proposed as the basis to certify carbon removals under the proposal for an EU-wide voluntary carbon removal certification framework recently adopted by the Commission. Nevertheless, the reporting requirements in the provisional agreement on a revised LULUCF Regulation build on the general reporting guidelines as set out by the Intergovernmental Panel on Climate Change (IPCC), and do not prescribe the exact tools with which data on greenhouse gas emissions and removals are to be collected, e.g. using EO. An EU-wide monitoring framework would therefore support the implementation of LULUCF and better work as enabler for carbon removal certification schemes.

Data collection and reporting at national (and where applicable regional) and EU and international levels would therefore continue to evolve with partial coordination and harmonisation that is mostly achieved at the level of definitions and with only limited success on the level of data collection design and methods 51 . Data quality and data continuity would remain for most indicators in the current state (with quality, continuity and transparency of data accuracy varying across Member States), with some limited exceptions, particularly related to monitoring of forest-based carbon and wood-based industry related indicators, which through the impetus of several large EU research projects 52  are edging closer to EU-wide and repeated data production.

Methods for biodiversity monitoring would mostly continue to rely largely on proxy indicators with the exception of the common forest bird index, with a likely addition of EO-based monitoring of forest structural diversity and tree species – but not as an operational EU-wide monitoring system.

Importantly, there would be no system or requirements for the EU-wide collection of comprehensive, near-time, comparable, high-quality data on the evolution of tree health and forest disturbances under climate change key to ensure forest resilience for example.

The harmonisation of NFI data collection and reporting systems would continue to benefit to a certain extent from EU funded activities such as COST actions 53 , and Horizon Europe and other research and innovation projects that bring NFIs together 54 (via Commission’s JRC, ENFIN or other cooperation modalities) as well as non-EU funded research into harmonisation of forest indicators in Europe 55 . However, actual engagement would differ across Member States and, together with the ad-hoc nature of respective EU funding, would limit longer-term strategic efficiency and progress.

Advances through research and innovation, notably in EO might reduce the existing gap between knowledge availability and needs for EU policy making and implementation. However, the lack of a common framework will likely lead to varying uptake by Member States and access to such information will remain fragmented. 

A lack of oversight and consistency will continue to impede integrated forest planning across the various relevant policy domains. Benchmarking or setting of objectives would unlikely be achieved; and the incentive to streamline and improve EU-wide forest monitoring would depend on sectoral legislation addressing only interests in very specific indicators. Voluntary approaches to harmonise would continue for the majority of indicators. Coordination of forest-related policies would remain at the initiative of the coordinating authority in the Member States.

5.2Description of the policy options

5.2.1Option 1: Streamlined reporting for forest monitoring and integrated forest planning – fully voluntary option

This option aims to achieve a common approach to forest monitoring and integrated planning for coherent delivery of EU objectives and priorities pertaining to forests while leaving maximum flexibility to Member States as how to translate them into their national context.

Voluntary coordination through Commission guidelines and sharing of best practices would aim to harmonise national data collection and strengthen forest planning frameworks and mechanisms to address the problems identified in Section 2. Monitoring obligations under existing (or proposed) legal obligations (Table 21 in Annex 5) would form the starting point for setting priorities while enhanced harmonisation efforts could also concern key selected indicators currently included in existing international monitoring and reporting frameworks such as Forest Europe’s SoEF reporting, forest condition parameters collected in the ICP Forests network or indicators reported under FAO-Global FRA.

The Commission, in the framework of the new Forest Governance being set up pursuant to the new EU Forest Strategy, would make use of dedicated expert groups in order to facilitate coordination and exchange on forest monitoring including harmonisation and integrated planning. Following consultation with theses expert groups, the Commission would issue voluntary guidelines to strengthen consistency and comparability in data collection, promote EO and facilitate the drafting of evidence-based integrated forest planning for example by offering a common set of basic requirements and core elements for consideration by Member States.

The Commission would continue to provide existing EO services through the Copernicus Land Monitoring Service on selected forest data such as phenology and net primary productivity.

The Call for evidence showed wide agreement among stakeholders that an EU-wide forest monitoring network should be based on existing national forest inventory data, in order to reduce the risk of duplicating data. In the OPC, business associations and public authorities tended to be in favour of better integration of Member States’ monitoring systems, but with little changes to monitoring methods. These views are in line with Option 1.

5.2.2Option 2: Monitoring framework for resilient European forests –legislative option

This option would aim to set up an obligatory EU framework for data collection and reporting, advanced use of EO and integrated forest planning with two sub-options on the level of EU intervention.

In order to address the problem of varying level of indicator coverage across Member States, and following a step-wise approach (see Annex 5.2), a set of key mandatory indicators and parameters would be selected for their inclusion in this obligatory EU framework. Their selection would be linked to strategic objectives, such as those identified in the Biodiversity Strategy, Adaptation Strategy or the new EU Forest Strategy and supported by an expert group (see below). Stakeholders identified these indicators also as the most important ones to monitor in the OPC (Figure 22 in Annex 2). The methodology for the selection of the indicators is further described in Section 5.2.1 of Annex 5.

Common to both sub-options, definitions and methods for the mandatory indicators would be harmonised based either on existing definitions and methods or those developed with the support of an expert group (see further down). Standardisation would be suggested for core indicators where the uncertainty of harmonised estimates is too high or where no internationally agreed common definitions and methods currently exist. Common harmonised definitions will be established where currently missin . Sharing of relevant data by Member States will follow the approach to open public data and its re-use of Directive (EU) 2019/1024, mitigating reporting obligations on public administrations.

Further details on indicator harmonisation and standardisation are given in Box 1, Annex 5.

The Commission would ensure that data collected by Member States are regularly reported to and published on Forest Information System for Europe (FISE) as a common platform for forest information.

The use of Earth-Observation (EO), complemented by in-situ monitoring where necessary for data calibration and validation, would be mandatory for indicators and parameters for which the underlying policy needs necessitate data acquisition with higher frequency and spatial resolution, i.e. at a parcel level with roll out over large areas. The Commission would operate the EO-based forest monitoring system, expanding and developing its service to provide data covering the EO mandatory indicators specified in Table 21 in Annex 5. This will lead to a consistent monitoring of such EO-based parameters (e.g. forest area) across the EU.

Member States would be required to develop context-specific long-term plans based on common elements, building on existing planning instruments. These plans should provide a holistic assessment, integrating forest-related policy objectives, targets and risks (related to biodiversity protection, forest ecosystem restoration, forest carbon sink, climate change projections, forest biomass demand for energy and material uses, non-timber uses of forests etc.), and include forecasting via available integrated modelling frameworks to be defined by the expert group. Based on these assessments, the Member States’ plans would develop a vision for forests and the forest-based sector for the next 10, 30 and 50 years. This assessment would need to be underpinned by quantitative and qualitative analyses, forecasting and climate projections, and be developed in an inclusive process with stakeholders. Furthermore, to help ensure coherence between national and Union policies, a governance framework would enable an ongoing dialogue between the Commission and the Member States and, where appropriate, between the Member States. In this context, the Member States would be required review the plans every 10 years in order to ensure their viability, building on the average periodicities for data collection and monitoring in Member States.

Among the OPC responses, stakeholders identified a “holistic view on forest status and trends” and “overall coordination of long-term forest planning” as the most important added values of integrated forest planning. Generally, providers of forest data tended to be more positive towards a comprehensive coverage of issues in such plans, while forest owners tended to be less positive (see Annex 2).

Similar to option 1, a new expert group in the framework of the new Forest Governance would facilitate follow-up and implementation of the regulation. Where not yet available, the expert group would help the Commission developing proposals for common methods for indicator harmonisation and standardisation, dealing with data collection needs and proposing further indicators for policy implementation as relevant. It would further provide a forum for good practice exchange on long-term planning for forests.

Generally, business associations, companies, forest owners and public authorities tend to show a preference for Member States continuing current monitoring systems, while environmental organisations, forest data providers and EU citizens tend to favour better integration of monitoring systems, with standardisation of forest monitoring methods (see Annex 2). Option 2 and its two sub-options represents a balance between these two views.

·Sub-option 2.1– Medium level of intervention 

Member States will be required to report on a targeted set of indicators and parameters related to EU legislation and policy objectives on forests (see Table 21 in Annex 5). The selection would be based on existing EU and relevant international monitoring and reporting systems, such as criteria and indicators used for Forest Europe’s SoEF reporting, forest condition parameters collected in the ICP Forests network, indicators reported under FAO-Global FRA (see 5.2 of Annex 5). Basing the selection of indicators and parameters on those reported under existing frameworks aims to reduce costs related to data collection and harmonisation. The initiative would not introduce any additional reporting requirements for indicators relevant for EU forest policy objectives which are currently collected under international monitoring and reporting schemes and which satisfy identified policy needs (e.g. reporting on forest management plans and management objectives under FAO).

The “opt-in approach” combines EO-based forest monitoring operated by the Commission with the possibility for Member States to enrich the data pool with their sources. Following a specific, clearly documented data management protocol, Member States could upload their measurements, or LIDAR coverages that are currently not available wall-to-wall across the European Union, in Member State specific containers including regionally or nationally available EO-data. Regarding data management, such a system could, for instance label the data as:

“private”: not geo-located (plot location) and not accessible (plot measurement) by other Member States or the public. Only the Member State who provided the data can use it for forest monitoring in their national domain and the Commission can access them for purposes of data quality assessment.

“protected”: not geo-located but accessible by other Member States and the public, i.e. they can benefit from the measurement information without knowing the measurement location.

“public”: geo-located and accessible by other Member States and the public.

This way, Member States’ existing and more advanced monitoring systems could also benefit from an EU monitoring system as a complementary layer of information (and potentially decrease national costs for its operation) without compromising on the quality compared to their current national systems.

Member States will be required to prepare, report and review integrated long-term plans, but the Commission will not make recommendations on these plans.

·Sub-option 2.2 – High level of intervention 

Member States will be required to report on a more comprehensive set of indicators and parameters related to EU legislation and policy objectives extending beyond existing EU and relevant international monitoring and reporting systems. The additional indicators compared to sub-option 2.1 would however still be limited to a small number of indicators essential to underpin the main policy objectives related to forests (see Table 21 in Annex 5).

These new indicators would notably include more detailed information on tree mortality, storm damage, drought damage, or pest outbreaks which - although crucial for making appropriate decisions for adapting forests to climate change and for assessing the related progress under Articles 5 and 6 of the European Climate Law - are currently not monitored under specific EU law or by the international forest monitoring systems mentioned above. Similarly, sub-option 2.2 would include in its scope monitoring of silvicultural regimes in EU forests, use of clear-cutting and the location and extent of primary and old-growth forest, all identified as policy-relevant information essential for the implementation of the new EU Forest and Biodiversity Strategies for 2030. In addition to data harmonisation for existing indicators, data collection will be standardised for the new indicators.

The Commission will develop and operate EO-based forest monitoring on a specific set of indicators (see Table 21), complementary to in-situ data collection carried out by MS, and provide these data for their publishing in FISE. There would be no opt-in possibility for the Member States. The OPC revealed a high level of support for a single monitoring system operated by the EU among environmental organisations and EU citizens, while companies, business associations and public authorities tended to be less positive.

The Commission will review Member States’ integrated plans and, where relevant, issue recommendations on their alignment with specific policy objectives and targets. Whereas recommendations have no binding force, Member States will nevertheless be invited to take account of such recommendations. Contrary to other governance frameworks (for example on National Energy and Climate Plans (NECPs 56 ), Member States will not have to provide and make public the reasons for not addressing the recommendations.

5.2.3Option 3: Obligatory monitoring and voluntary planning - the hybrid option

This option combines core elements described in option 1 and sub-option 2.2.

Monitoring elements would be mandatory to address the problem of varying level of indicator coverage and data collection approaches across Member States following the approach described in sub-option 2.2, while integrated forest planning would be optional for Member States. Reporting would be obligatory for a set of indicators and parameters related to EU legislation and policy objectives beyond existing EU/international requirements with data harmonisation for existing indicators and standardisation for the new indicators. The Commission will develop and operate EO-based forest monitoring, complementary to in-situ data collection, and publish this data into the monitoring system.

Like under Option 1, integrated long-term planning would be voluntary for Member States supported by an expert group for coordination and knowledge exchange for instance for sharing best national practices in drafting such plans. Following consultation with this expert group, the Commission would issue voluntary guidance to facilitate the drafting of evidence-based integrated forest planning for example by defining a common set of basic requirements and core elements for consideration by Member States.

5.3Options discarded at an early stage

5.3.1Option 4- Targeted EU funding for monitoring and integrated long-term planning

Option 4 would seek to address the problems identified by ring-fencing EU funding for forest monitoring and integrated long-term planning activities, either from existing funding programmes or through the creation of a new funding facility.

Common objectives for forest monitoring and integrated planning would be defined together with the requirement to prepare national programmes and a process to decide on what should be funded at EU level and a process for allocating and managing the funds.

A dedicated budget from the EU budget would be assumed based on current costs for in-situ observation in the EU  57 and costs of satellite and airborne measurements by the EU and MS.

A dedicated funding instrument for forest monitoring existed in the past with the Forest Focus Regulation that established an obligation for coordinated EU-level forest monitoring backed by extensive co-funding (EUR 65 Mio over a four-year period for the EU-15). This Regulation strengthened integrated forest monitoring, established a database with aggregated data and information on the state of EU forests, and broadened the scope of forest monitoring to soil and biodiversity. However, its cost-efficiency was limited by the absence of common definitions for indicators, data collection or monitoring protocols. In combination with the complex landscape of beneficiaries of these funds, significant differences of “value for money” among beneficiaries were the result. The assessment of the legal instrument concluded that despite strict control of financial management (external auditing) implementation of forest monitoring in Member States was insufficient 58 . In view of the objective to streamline and consolidate financial instruments, the Forest Focus Regulation was not renewed and was replaced at the end of 2006 by the LIFE+ Regulation. Voluntary in nature and without dedicated focus on forests, clear monitoring targets or obligations for consistency and harmonisation, uncoordinated activities and limited spatial and temporal coverage increased again in light of the high administrative and field costs for forest monitoring.

Given this experience, funding without specific objectives and targets or obligations would not achieve the objectives of this initiative as described above, i.e. Member States would not put in place coherent monitoring frameworks and long-term planning. Therefore, option 4 is not considered suitable as a stand-alone option, but funding is considered a useful add-on for the preferred option (Chapter 8).

5.3.2Option 5: Strengthened international engagement

Option 5 will consider whether a common standard for forest monitoring and integrated long-term planning could be achieved through promoting the development of appropriate international standards and coordination of the delivery of existing international requirements for the EC and Member States.

There are several international or intergovernmental bodies and processes with relevance to forest monitoring and integrated long-term forest planning but none has an overall responsibility. United Nations’ Framework Convention on Climate Change (FCCC) and Convention on Biological Diversity (CBD) specifically address forests and forested land, including in relevant international agreements 59 . Several UN subsidiary and implementing bodies such as the FAO, the UN Forum on Forests and the International Tropical Timber Organization support improving forest-related data, information, and capacities for conservation, sustainable management, and legal harvesting. The EU and its Member States have reporting obligations that require forest information systems towards international schemes such as ICP Forests, the FAO-Global FRA, the UNFCCC and the CBD and the recently adopted “Kunming-Montreal Global Biodiversity Framework” (GBF) 60 . In the framework of FOREST EUROPE (also known as the Ministerial Conference on the Protection of Forests in Europe), Member States report to varying degree on indicators for forests and the forest-based sector on a voluntary basis.

However, none of these international commitments and fora includes an obligation for the EU or its Member States that establishes a common framework for forest monitoring or integrated long-term planning or provide a structured process for doing so. Neither is it likely that such commitments and obligations would emerge in the foreseeable future. Collaboration certainly exists but it is on a voluntary basis and split between many separate arrangements not achieving the required level of harmonisation or standardisation. For example, the experience in Forest Europe shows that the voluntary process on criteria and indicators serves as a structure and framework, but the actual take-up and application of the criteria and indicators varies widely between the various countries as the development and implementation process is complex and can be costly 61 .

While not considered a viable stand-alone option, international engagement should continue and could be considered as part of the preferred option.

6What are the impacts of the policy options?

This chapter identifies specific categories of economic, environmental and social impacts and provides a detailed assessment of those impacts for each of the policy options and sub-options that are still under consideration:

1.Option 1: Streamlined reporting for forest monitoring and integrated long-term forest planning –voluntary option

2.Option 2: EU framework for forest monitoring and integrated long-term forest planning – legislative option

2.1.Medium level of intervention

2.2.High level of intervention

3.Option 3: Obligatory monitoring and voluntary planning - the hybrid option

Table 2: Summary of the key components for each of the options

The identified impacts have components that are unique, but also several components that are similar in nature for each of the assessed policy options and sub-options. To avoid unnecessary repetitions and keep the different sections balanced and of similar length, this chapter is structured by impact category rather than by policy option. In each section assessing a given impact category, all policy options and sub-options are considered, showcasing impacts that are common to all of them and those that are unique.

For the hybrid option (Option 3), provisions regarding monitoring are the same as for the existing policy option 2.2. and for long-term planning the same as for policy option 1. Socio-economic and environmental impacts of Option 3 are therefore not assessed individually but according to its two building blocks together with option 1 for the planning element and option 2.2 for the monitoring element. In light of the intrinsic links between the two elements, internal coherence is added as additional criterium for the comparison of the different options in the following chapter.

6.1Identification of impacts and stakeholders

The following section describes impact categories that are being considered for each of the assessed policy options and sub-options.

Several relevant stakeholder groups have been identified. The table below summarises the main stakeholder groups which are used throughout this chapter, along with a brief description.

Table 3: Overview of most relevant stakeholder groups

6.2Description of the current situation

Costs for monitoring depend to some extent also on the area that needs to be monitored, i.e. the forest area in the respective Member State. The Figure below provides an overview of forest area per Member State.

Source: Eurostat. Own illustration. Detailed data in Annex 4

The Figure shows that there are large differences regarding the relative share of forest area to the overall area of the respective Member State. For example, around 2/3 of the areas of Finland and Sweden are covered by forests. On the other hand, only 1% of Malta and 11% in Ireland are covered in forests.

Consequently, the overall costs for monitoring are likely to be higher in Finland and Sweden. At the same time, the average cost per area can be expected to be lower in countries with large shares of forest areas since the cost for the overall structure of forest monitoring is distributed more widely. Vice versa, while the costs in countries with a small share of forest area will be lower overall, the overhead for governance, education, IT structure, and other enabling factors for forest monitoring, is comparably larger.

In addition to those benefits of scale, it should also be noted that the expected long-term benefits from better monitoring such as reduced biodiversity loss, enhanced resilience and others are higher in those countries than in the ones with little forest.

6.3Economic impacts

6.3.1Public budget

Data harmonization, improvement of existing as well as the set-up of new monitoring and integrated planning systems bear the following economic costs for equipment and personnel that would be borne by the public budget (EU, national, regional, or lower level):

oMonitoring systems: This includes costs related to one-off investments, scientific research and technical analysis, operational roll-out and maintenance.

oHarmonisation and standardisation of data collection and reporting: Data for a given indicator, collected through different methods or different sources, can have various formats. To be able to compare data collected through different methods, the aggregated statistical estimates needs to be harmonized, which is linked to some costs. The development of the definition and methodology for standardization can also be linked to costs as well as its roll out. 

oIntegrated long-term planning: This includes administrative costs related to drafting of the plans, their review and monitoring of progress towards objectives set out in the plan.

6.3.1.1Monitoring systems

It is planned that through the legislative initiative remote sensing will play a greater role in forest monitoring than is currently the case, with positive impacts on the productivity of the sector. Table 4 on the semi-quantitative review of forest monitoring methods provides a comparison of remote sensing as compared to ground-based monitoring or aerial monitoring. The selected attributes are rated in relative terms from + (worst, compared to other methods) to +++ (best, compared to other methods).

Table 4: Semi-quantitative review of forest monitoring methods

The selected attributes are rated in relative terms from + (worst, compared to other methods) to +++ (best, compared to other methods).

* Only considering the per hectare costs of EO image acquisition without the launch/take-off costs, they are lowest for satellite monitoring (0.09 EUR/ha) and higher for airborne technologies, with airplanes being less expensive (1.68 EUR/ha) than drones (43.36 EUR/ha) 62 .

Source: Own compilation

As is shown, satellite data offers many benefits such as frequency, wall-to-wall coverage, transparency of data and many others. From an operational standpoint, remote sensing can provide benefits when replacing ground-based data collection or complementing it when used for monitoring new indicators. The feasibility of satellite-based support systems for land management, including compliance assessment, is demonstrated by the CAP legislation, where its use is prescribed in the legal text 63 . It should be noted that satellites are to date already used for EU wide forest-related monitoring, for example through the EFFIS or high resolution layers on tree cover density and forest type under Copernicus 64 . 

A case study in Sweden assessed the benefits from a situation in which ground-based data collection for forest regeneration after clearcutting has been replaced by satellite-based monitoring 65 . It found that the use of satellite data collection allowed to save between EUR 16 and 21 million per year. Breaking savings further down, the study finds that approximately EUR 9 million of those annual benefits accrue for the public authorities (the Swedish Forest Agency), between EUR 6 and 11 million for private forests owners (from increased compliance with forest management obligations which in the long-term lead to higher return), and approximately EUR 1 million for citizens.

An ex-ante evaluation of Copernicus benefits 66 estimated that if 75% of data needed to produce clear-cut maps by public administrations for monitoring compliance will be produced using free of charge Copernicus data, replacing data currently purchased from commercial satellites, this can bring cumulative savings of anywhere between EUR 28.2 million to 37.6 million by 2035 (not discounted). At the same time, it should be emphasised that the figures only looked at one specific indicator, and that benefits from additional indicators will likely add up. 

Looking at the overall benefits of the Copernicus system for forest monitoring, the ex-ante study estimated that the potential of those cumulative benefits 67 between 2017 and 2035 is between EUR 5 and 13 billion across the EU. However, it should be noted that those numbers are subject to major uncertainties and only partly applicable in this context: they are to a large extent based on extrapolating findings from the abovementioned case study across the whole EU; they assume that commercial data are replaced with free-of-charge Copernicus data at a certain rate; and the ecosystem benefits are based in the assumption that the access to Copernicus data will improve the implementation of the Habitats Directive.

Albeit major investments are needed for providing and maintaining the necessary infrastructure (by public as well as commercial providers), all assessed policy options build on already existing EO technologies, and thus no major costs would be linked to their set-up. Those systems are part of the baseline and do not increase through improved uptake of the forest related data products. It should however be highlighted that those initial investments are substantial; for example, the European EO Programme Copernicus alone had a budget of around EUR 4 billion for the period 2014 to 2020 and is planned to benefit from EUR 5.8 billion for the period 2021 to 2027 I , covering a wide range of domains and applications, with only a part of this budget being relevant for forest monitoring. Monitoring that would purely rely on data from these public satellites would imply that there are no costs for data acquisition. However, depending on which indicators are monitored, costs can occur for the processing of the data and development of the relevant new data products, and those would be borne by the EU.

Table 5 below shows the potential savings by using public satellite data (Sentinel 2) whose data are free of charge. The minimum area price includes data processing costs of image rectification, masking, index calculation and producing output. It should be noted that resolution plays a crucial role in determining the price as well as the further processing that is needed in order to obtain data for a specific indicator.

Table 5: Estimation of costs for selected remote-sensing products

Source: Sozzi et al. 2018

Option 1

Voluntary coordination through guidelines, recommendations, benchmarking and sharing of best practices will lead to low to moderate economic impacts for the public budget of Member States with respect to forest monitoring, which would have the choice on their level of engagement, varying anywhere between the baseline and the most ambitious option, and the related costs they would decide to bear.

It is assumed that Member States will show a slight increase in uptake of remote sensing for their national forest monitoring following the recommendations for the use of publicly available data or producing their own data sets using purchased services.

Common for Option 2

Under both sub-options, Member States will be obliged to report on a mandatory set of indicators and parameters linked to EU legislation and policy objectives on forests. Depending on the indicator, ground-based or EO-based data collection, or both, might be used (see table 21 in Annex 5).

Costs for Member States under this option will depend on whether their current ground-based data collection system (e.g. NFI) meets the minimum requirements defined – specifically the 5 year data collection frequency and the spatial resolution indicated in Table 21 for each indicator and parameter.

The analysis presented in Table 6 based on the current status of NFIs in Member Status shows that Member States can be divided in 3 groups in line with the degree of expected costs which would be required to adapt their current data collection framework to meet the required minimum quality standards, namely a 5-year data collection frequency, and data coverage. For more detailed discussion on the method and the results, see the relevant sections in Annex III.

The costs for those Member States with a current 10-year cycle would likely be considerably less than double of the current costs, since expertise, infrastructure, and equipment would be maintained and incremental cost would only arise from additional staff costs during data collection and analysis.

More significant costs would occur in cases where a new ground-based system with sufficient sampling plot density would need to be established by a Member State with no existing running NFI (Bulgaria, Greece) or those where only one assessment has been carried out (e.g. Croatia) – these costs would relate to investments into new infrastructure (e.g. designing the sampling grid and establishing plots), capacity building (training of personnel), and equipment. In these countries the running costs would decrease for the subsequent exercises.

Table 6: Categorisation on Member States according to potential costs under the preferred option

Legend: For columns showing the variables of forest area, number of NFI plots, NFI plot density and frequency and the number of indicators not monitored (compared to the indicators of Table 21 considered for their inclusion in the legislative proposal under the preferred option), the red colour coding denotes a high effect of this variable on costs under the preferred option, yellow a neutral effect, while green denotes a low effect. Frequency of plot visits is compared to a 5 year benchmark. For the column on the ‘Share of Gross Value Added of Forestry Sector to overall GDP’, green colour denotes higher overall benefit from acquiring additional information on forest to the forest sector. For the column on planning, the orange colouring code denotes moderate costs while yellow denotes limited costs.

Both sub-options come with additional effort needed for the mapping of forest habitats under Habitats Directive (2.1) and primary and old-growth forests (sub-option 2.2), for which field surveys additional to the sample-based forest inventory might be necessary, entailing some further costs to Member States, especially those with large forest areas. Tools such as EO data could be used in the first stage for pre-screening potential areas, in combination with in-situ data and modelling techniques, for improving the cost-efficiency of such an exercise.

While the impact assessment faced in most cases major challenges in identifying information on the costs and budgets of conducting NFI and other forest monitoring activities, such data could be identified in three Member States: Finland, France, and the Netherlands. While this sample is not representative for the whole EU, it nevertheless includes a spread of countries of different size and different share of forest areas. It needs to be noted that the costs include the use of EO for the support of the NFIs and that the NFI frequency ranges from 5 (France and Finland) to 7 years (the Netherlands). The average annual cost of forest monitoring through NFIs in those countries is 42 EUR/km2 of forest area. Bearing in mind the caveats around the non-representativeness of the sample (e.g. France and Finland have above-average indicator coverage of their NFIs, see Table 22) and the assumption around the use of EO, this sum is a rough approximation that countries with no NFI would bear to set up a new system. Countries with lower NFI frequency could bear the additional cost equalling the difference between the abovementioned sum and their current annual costs per km2 of forest area in order to reduce their NFI interval to 5 years.

Development costs for Copernicus would be limited compared to the significant frontload of past investments into the system and its forest-related elements, especially on tree cover density. Still, there would be additional costs for development and continuous updating of new forest data products. Based on the existing contracts by the EEA’s Copernicus Land Monitoring Service 68 , the estimated costs for producing an annual update of an EO-based forest data product is approximately EUR 500 000. Additional costs are expected in relation to acquiring ground data for the validation and calibration of these products, especially relating to forest disturbances or estimation of aboveground forest biomass. These will vary depending on accessibility of existing data collected by NFIs – higher costs are to be expected if the data are not accessible and an alternative ground data framework would need to be funded.

In both sub-options, benefits stemming from a greater role of remote sensing can be expected (see also 6.4).

Option 2 – Sub-option 2.1

Under sub-option 2.1, the Commission will further develop and operate satellite-based forest monitoring for the indicators with foreseen EO obligations, with the possibility for Member States to enrich the data pool via an ‘opt-in’ option. Additional cost would mainly relate to increasing the frequency and quality of existing products, relating to for example tree cover density changes or monitoring of crown condition.

For indicators with foreseen mandatory EO monitoring, the Member State could use data provided by the Commission, or use the ‘opt-in’ option, using either their own existing EO data sets and systems or acquiring new EO data and services. Most costs incurred by the public budget of Member States linked to this sub-option would therefore be linked to the purchase of selected products from existing remote sensing service providers where Member States choose to ‘opt-in’. For satellite data, this would entail related data processing and acquisition costs of the order of magnitude similar to products showcased in table 5 above.

To ensure comparability of data from Member States choosing to ‘opt-in’, the EU institutions might bear the cost of defining minimum product requirements for remote sensing in terms of technical parameters of an indicator, minimum mapping unit, pixel resolution, periodicity between assessments and accuracy. Those could then be calibrated to national circumstances to ensure that the data would be comparable across the EU.

An advantage of a system that is developed centrally but that has the option to be implemented in a distributed manner through ‘opting-in’, is that Member States could realise potential synergies and meet requirements both at EU-level as well as at national, sub-national to local levels. Another advantage is that restrictions on the sharing or use of geo-referenced in-situ plot data – as is currently an issue in several Member States – may be circumvented (as explained in Chapter 5.2.2 for sub-option 2.1). Lastly, higher resolution data might be fed into the satellite-based EU system (e.g. from airborne monitoring), increasing the quality of data provided.

Option 2 – Sub-option 2.2 and Option 3

Under sub-option 2.2 and Option 3, the Commission would develop and operate EO-based forest monitoring complementary to in-situ data collection and report these data to FISE.  69

In addition to impacts described for sub-option 2.1, additional processing costs would be incurred by the Commission by developing new forest data products for indicators and parameters that are not currently produced using Copernicus remote sensing data and the reporting on which would be mandatory (e.g. comprehensive EU forest disturbance monitoring). The costs would overall be comparable to those outlined under sub-option 2.1.

6.3.1.2Harmonisation and standardisation of data collection and reporting

Common to all options

Some moderate costs are expected to occur when developing and applying reference definitions and harmonised methods for the different indicators. An indication of the order of magnitude of data harmonization costs can be found from looking at costs of ongoing initiatives with comparable objectives. The table below provides an overview of such initiatives and their costs.

Table 8: Overview of ongoing and past initiatives aiming at harmonising EU wide forest data

Source: Own compilation

In addition, several specific contracts have been tendered by the Commission’s Joint Research Centre under the framework contract with ENFIN, focusing among other objectives on forest data harmonisation through developing and applying common definitions and conversion methods, for instance on aboveground biomass, area of forest available for wood supply and net annual increment (Specific contract 17, 19, 20 and 21 under the Framework contract 934340) 72 . The total cost for these and other forest data harmonisation exercises under three framework contracts as of 2008 is estimated to be around EUR 1.95 million.

The actual costs for harmonising the data, once the method is implemented, are not considered to be significant. As the necessary scientific and technical background analysis for harmonization is already undertaken, cost per Member State will be limited to operational roll out, which in most cases can be assumed to be an automatized statistical process following an established protocol from the background research. Our internal analysis of three JRC projects showed that the conversion of estimates by applying the harmonised definitions cost up to EUR 10 000 per variable per Member State.

It is expected that most of the process would be automatic, with manual quality assurance procedures in place. As for the QA/QC, the reporting frequency plays an important role for the costs (see Table 21 for data reporting per indicator).

The data will be reported through the existing FISE platform 73 and thus no major IT development costs would occur; those would relate mainly to operational and maintenance costs, which might be slightly higher due to the amount of data to be processed. Maintenance and further development of the platform are currently partly outsourced through a number of contracts with combined costs of around EUR 300 000 annually.

Additional costs would occur for the Commission for developing IT related specifications for data, metadata, data exchange and data sharing protocols. This would e.g. include the development of xml schemas and guidance documents 74  and thus not lead to major costs.

Increasing the efficient use of public resources, the Commission may save costs on accessing and assessing reporting done by Member State authorities where current reporting in formats which cannot easily be automated (e.g. reporting in pdf format) or accessed is replaced by common reporting of the base data to FISE.

Option 1

Voluntary harmonisation and standardisation will lead to low to moderate budgetary impacts for Member States, which would have the choice on their level of engagement, varying anywhere between the baseline and the sub-option 2.2 in terms of the extent of indicators harmonised/standardised, and the related costs they would decide to bear. The voluntary nature could mean that Member States choose to harmonise indicators in the most cost-efficient manner, i.e. choose to target such indicators where harmonisation costs borne by their public administration would be lowest in relation to the estimated utility value of the efforts on the national level.

The order of magnitude of those costs for option 1 should stay below the costs of initiatives listed in Table 6, as it is assumed that the Member State choosing to harmonise will select indicators for which the necessary harmonised definitions and methods have already been developed.

It can be assumed from previous experience that some Member States will “go the extra mile” and transform their locally collected data according to an established protocol into harmonized indicators for the EU in cases where the added value for Member States of such a harmonisation is immediate and demonstrated, in particular for forest risk assessments and collaboration in case of natural disasters. Other Member States could show more reluctance to carry out this additional step for indicators they deem less critical for their own benefit, in particular with regards to biodiversity and forest carbon estimates. Where standardisation is recommended, e.g. because the transformation process does not lead to a statically robust harmonized indicator or because the indicator is new, voluntary engagement by Member States is highly unlikely due to relatively higher costs, unless there is a clear and immediate benefit for them.

Option 2 and monitoring element of Option 3

Obligatory standardization and harmonization of selected mandatory indicators would lead to moderate to significant economic impacts for the public budget of Member States, depending on the current situation in individual Member States.

Similarly as for Option 1, cost of harmonisation for public administrations will be mostly limited to  operational roll out, and, where currently missing, building of new reference definitions and conversion methodologies (i.e. ‘bridges’ 75 ).

In cases where harmonization of estimates is not possible due to a lack of common reference definition or harmonisation methods, or the high inherent uncertainty of the bridging functions leading to harmonised estimates of low quality and accuracy, there would be additional costs as data need to be collected according to a common standard instead. The bulk of costs would be borne by those Member State authorities who have to adapt their current monitoring to the new standards. This can lead to two different situations: on the one hand, MS could give up their current national system and only apply the standardised methodology. This could lead to the loss of national time series. On the other hand, MS could decide to implement two parallel systems (i.e., their national system and the established standard), which would result in increased costs for labour.

Specific costs for the MS for implementing the new standardised methodology depends on the indicator. The cost of standardisation may be close to zero for new easily visually detectable tree-related parameters which require only limited changes in time and skills to detect – this applies for example to standardisation of indicators related to basic tree variables (e.g. growing stock).

For both sub-options of Option 2 and the monitoring element of option 3, there are indicators which are not yet part of the data collection in all Member States (see Table 21 and 22 in Annex 5). In those cases, additional costs would accrue for rolling out the indicators in the country (including staff costs and potentially costs for new equipment). It is not possible to estimate the marginal cost of rolling out additional indicators in Member States where they are not yet measured, because detailed information on monitoring of particular indicators is very sparse and is not openly shared due to various data protection reasons.

In general, adding an indicator to a national monitoring system could come with almost no additional cost if it is calculated on the basis of existing data (e.g., Shannon index for tree species diversity could be calculated based on the already collected data on tree species). On the other hand, it could lead to increased costs if additional training of staff, purchase of equipment, or others are needed – if substantial measurements or additional staff are required (e.g., for non-tree plant diversity), this might increase cost per plot of 30 to 50%. 76 . 

For sub-option 2.2 and monitoring element of Option 3 costs will increase with the additional indicators. Most of these can be assumed not to be gathered by Member States at a significant scale and would thus require standardization. The costs of the obligation of monitoring an additional indicator in the existing NFI is in general limited, although in the case of primary and old-growth forest, it might entail costs related to ground-surveys for their identification and monitoring.

In contrast to option 1, the data to be reported is fully harmonised or standardised across Member States. Thus, the data could be presented in specific maps, graphs, charts or other means in FISE. Within the institutions, it is expected that the integration of additional forest data and indicators would entail further staff days as a one-off expense when extending the contracts, resulting in additional costs compared to the baseline (EUR 300 000 annually through external contracts plus internal resources at the EEA) estimated at max 30%.

6.3.1.3Integrated long-term planning

Option 1 and Option 3

Under options 1 and 3, Member States would not have any obligations related to integrated planning other than those already in place. Limited additional costs specific to integrated planning would be incurred by Member States from the adoption of voluntary guidelines on integrated planning and by the Commission for producing the guidelines and providing means of policy coordination between Member States, such as costs for organising the workshops or costs for developing the guidance materials. Based on the voluntary guidelines, Member States could gradually improve and adapt their national strategy planning system ensuring better comparability at EU level. There is however large uncertainty on whether Member States would follow voluntary guidelines to the extent required to achieve the objectives of this initiative.

Option 2 – Sub-option 2.1

Under this option, Member States would be required to develop long-term plans aligning them to a common structure including forecasting, to report every five years towards the goals set out in the plans and review them every 10 years to ensure their viability. At an expert workshop on costs and benefits hosted by the Commission, most participants agreed that such timeframes were relevant due to the fast moving nature of pressures and policy frameworks, and to be able to adapt the plans in case of rapid changes in forests (see Annex 2).

The actual costs per Member State would to some extent depend on already existing information, structures and expertise in the Member States. Several Member States at least partly develop integrated planning instruments for forests. A mapping done as part of the impact assessment (Table 23, Annex 5) shows that 18 Member States already have or are developing a document which can be considered a national forest strategy fulfilling to some degree the objectives of long-term integrated planning. Requiring those plans to follow a common structure would require limited efforts and low additional costs.

For Member States that do not have partially integrated planning instruments in place or for underpinning existing plans moderate costs would occur, the main cost coming from the preparation of the reports. This would include the following items:

•    One-off costs for developing new or adapting existing methodologies for forecasting,

•    Recurring cost for conducting the forecasting exercise,

•    Recurring cost for target setting (including internal coordination between authorities and conducting stakeholder consultations),

•    Recurring cost for drafting the report.

The direct costs for Member States are very difficult to estimate in advance as these costs depend to a large extent on the national context, capacity, economic situation etc in the Member States and it is not possible to foresee how Member States would work to design their plans.

However, as a reference for the magnitude of the costs the example of Germany can be given which started developing their 2050 strategy in 2015 and spent approximately EUR 600 000 for the development (EUR 500 000 for the preparation of the strategy and EUR 100 000 for dissemination 77 ).

Costs for analysis related to forest carbon can be considered low given previous experiences by Member States with National Forestry Accounting Plans, the National Energy and Climate Plans and the Long-term strategy and biannual reporting obligations on policies, measures and projections. Socio-economic indicators may also be readily available in several Member States. However, for Member States that do not yet include those, cost will occur for sections on climate adaptation, biodiversity and assessing the overall policy coherence. In particular costs for smaller Member States with less experience and Member States with low shares of forest land may be higher than Member States with more experience in forest planning and foresight.

Regarding the costs for drafting the progress reports, by way of example the Fitness check of the Reporting, Planning and Monitoring Obligations in the EU energy acquis 78  surveyed Member States about their costs for policy planning and reporting in relation to several obligations of the Renewable Energy Directive. The results presented in the study include median costs of EUR 4 407 per Member State and year. Those relatively low costs have been found to be largely driven by a standardised template provided by the Commission, which was also found to increase the compliance of Member States with the reporting obligations 79 .

Option 2 – Sub-option 2.2

In addition to requirements described under sub-option 2.1, under sub-option 2.2, the Commission will review Member States’ integrated planning instruments and issue recommendations on their alignment with specific policy goals.

Costs would be of the same order of magnitude as under Sub-option 2.1, but additional costs in Sub-Option 2.2 would arise for any follow up to the Commission’s recommendations.

6.3.2Regulatory burden for SMEs and other businesses

None of the policy options includes any regulatory obligations that would be directly applicable to businesses. Monitoring, reporting and integrated planning would, for all of the policy options, be the responsibility of public authorities.

Data collection for the large majority of indicators, namely those that will rely on satellite data or on a network of monitoring sites to produce statistically relevant information on the national level 80 , would be directly undertaken by competent authorities, with no risk that the burden or costs would be passed down to businesses.

In the case of economic indicators under Options 2.1, 2.2 and in relation to Option 3’s monitoring element related to the bioeconomy, namely on production and use of timber and non-wood forest products, some indirect basic reporting obligations might arise for the forest-based sector to fulfil data needs by competent authorities, but these statistical data are estimated to have negligible additional costs, as they would be collected and reported for industry statistics purposes or for existing international reporting, such as Joint Forest Sector Questionnaire, to which the vast majority of the MS already provide replies.

No major impacts on businesses related to regulatory burden were thus identified for any of the policy options under the ‘SME Test’(see box 1 above). 81  

6.3.3Opportunities for SMEs and other businesses

It is planned that thanks to the legislative initiative the EU will be a global leader for forest monitoring and implementation of sustainable forest management practices, offering numerous opportunities for growth and innovation of European businesses.

Remote sensing will play a greater role in forest monitoring than is currently the case, offering many possibilities to SMEs active in acquiring and processing the satellite imagery, data processing and providing services related to forests and forestry, including advisory services. Promoting EO-based based products under Option 1 or introducing a legal mandate for acquisition of specific forest data under Options 2 and 3 would increase the demand for EO based products in general, which would encourage more companies to enter the market and create new products to meet the increased demand.

A survey 82  from 2020 among countries members of either the EU or ESA has found that for more than 9000 companies EO services are a minority part of their business, with 97% of them being classified as micro, small or medium companies. As it has been the case in agriculture with the revolution brought by remote sensing to precision agriculture, and that opened a new market, offering numerous opportunities for European SMEs and other businesses, it can be assumed that a similar success story could take place in forestry.

The global market for remote sensing products and related data processing and advisory services has been estimated at USD 16.5 billion 83 in 2020, out of which around 40% are held by European businesses 84 . The global market is estimated to grow and reach USD 55.5 billion in 2028. According to the World Economic Forum, the conservation, restoration, and sustainable management of forests could generate EUR 190 billion in business opportunities and 16 million jobs worldwide by 2030 85 . 

The greater role of remote sensing can also bring benefits for forest managers and the forest sector: the case study 86  mentioned in the previous section on monitoring systems estimated annual benefits ranging between EUR 6 and EUR 11 million annually for private forests owners in Sweden from increased compliance with forest management obligations leading to higher returns in the long-term. Building on this study, the ex-ante benefits assessment for Copernicus 87 also concludes on remote sensing and Copernicus’ potential to improve yields thanks to sustainable management practices, increasing the volume and quality of timber in the long term.

Easy access to high quality data will also allow businesses linked to the forest sector to better understand the quality and quantity of ecosystem services forests provide and the costs of inaction. A study from 2021 provided an assessment of the economic costs of climate change in Europe and found that there was low coverage of the forest sector, and a particularly limited number of studies on the evaluation of losses from pests and diseases 88 . A case in point is Czechia, which suffered dramatic decreases in the market value of its wood products due to severe bark beetle attacks requiring salvage logging of large amounts of infected trees. Following a severe 2018 outbreak, timber prices decreased from EUR 56-64 per m3 (2011-2017), to EUR 14-16 per m3 89 .

Understanding the quality and quantity of ecosystem services provided by forests is also a crucial step in view of a future implementation of payments for ecosystem that would compensate and reward forest managers, incentivizing them to enhance or maintain ecosystem services provided by forests. Indicators related to carbon capture and storage would be key to quantify possible payments for climate mitigation, for instance within the framework of the EU Certification of Carbon Removals 90 , while indicators related to biodiversity could allow to quantify possible payments for nature restoration or conservation.

This may also allow forest holdings and the downstream forest-based businesses to foresee changes (e.g. in species composition) and adapt their business practices. This may lead not only to additional jobs in information technology and communication as well as foresters working in the field but also more cost-efficient intervention when field units are guided to areas where the intervention is pertinent.

6.3.4Digitalisation

There are strong synergies between the green and digital transition. 91  The greater role of advanced forest monitoring technologies and reporting systems, using advanced technology, is expected to bring high benefits in terms of digitalisation, in line with the objectives of the Digital Agenda for Europe 92 . This digitalization of forest information will require higher upfront investments followed by moderate costs for operation as discussed in the section on impacts on public budgets.

The benefits accrued in terms of digitalisation can be found mainly under Option 2 and Option 3, where more prominent role is envisioned for reporting of the data collected through a single portal – FISE. A future version of FISE enhanced with up to date in situ data and EO calculated indicators could take part in the Green Deal Data Space eco-system and contribute to a data market economy.

As elaborated in 6.4.1.1, the carbon offset market will most likely have a strong interest for certain Forest indicators made available from the forest monitoring program. Carbon market stakeholders like forest owners will make use of the data to carry out monitoring reporting and verification activities related to carbon capture by their forest projects.

In line with the first objective of the Digital Agenda for Europe, providing better access for consumers and businesses to digital goods and services across Europe, having easy access to the data will reduce the administrative burden for businesses, citizens, and administrations in search of forest-related information. Using FISE as the single portal for data reporting and publication will also be aligned with the ‘once-only’ principle for data use. This principle is also adhered to when Copernicus data are reused for production and monitoring of new indicators.As outlined in section 6.3.3 on Opportunities for SMEs and other businesses, the initiative will contribute to creating the right conditions for digital networks and services to flourish and contribute to maximising the growth potential of the digital economy, which are the second and the third objectives of the Digital Agenda for Europe.

6.4Assessment of environmental and social impacts 

The environmental and social impacts of the initiative are difficult to directly quantify as they are often ‘knock-on’, i.e. indirect benefits of the initiative. As an example, the framework aims to facilitate evidence-based decision-making at the EU level, which will support the implementation (and achievement) of EU policy objectives relating to forests, and more sustainable forest management and enhanced environmental protection of forests. Therefore, general estimations are given in quantitative terms where possible; otherwise qualitative statements based on existing literature are used to illustrate the impact.

6.4.1Environmental impacts

Facilitation of evidence-based decision- and policy-making

Evidence-based decision-making is one of the pillars of EU policy 93 .The availability of high-quality, accurate and continuous datasets that provide a holistic picture on the state of forests provides the evidence base for informed decisions and policies on forests by administrations and forest managers, and facilitates the monitoring of progress towards policy objectives and goals. This is needed for national or EU wide outlooks, scenario building and impact assessments. Moreover, long-term integrated plans that highlight trade-offs between different policy objectives at the national level can contribute to identifying inefficiencies, potential policy incoherencies and conflicting demands on forests that could necessitate a policy review.

The ability of the different policy options to deliver on this is highly dependent on the comprehensiveness of the long-term plans and the type of indicators that are selected and their adequacy to capture the broad range of policy goals and objectives. For policy option 1 and in relation to long-term planning for option 3, it is in general difficult to assess to what extent Member States would adopt monitoring of additional indicators and carry out integrated long-term planning on a voluntary basis. Even though this might bring certain economic benefits (see Section 6.3.1), it can be safely assumed that the indicator coverage and the uptake of long-term plans in Member States will bring about a comparatively lower environmental impact as opposed to the obligatory nature of indicators, EO-based monitoring and integrated planning instruments under Option 2 and Option 3. The means for the Commission to issue recommendations on integrated planning instruments will result in a moderately better environmental impact with regard to matching national projections with overall EU policy and balancing trade-offs between the demands and the potential of forests to supply different ecosystem services.

The following section therefore only addresses the difference between sub-options 2.1 versus 2.2 and Option 3 organized along the different environmental impact categories which would benefit indirectly from improved decision- and policy-making. The following section therefore only addresses the difference between the sub-option 2.1 vs 2.2 and Option 3 organized along the different environmental impact categories which would benefit indirectly from improved decision- and policy-making.

6.4.1.1Climate mitigation

Land based carbon removals will play a key role in the achievement of carbon neutrality by 2050 in the EU, and they will be increasingly needed when negative emissions will be pursued to stabilise the world’s temperature increase 94 . 

Forest land in the EU currently removes about 340 Mt CO2eq yr−1 of carbon from the atmosphere (excluding storage in harvested wood products), and research suggests it should increase to 450 Mt CO2eq yr−1 by 2050 in order to reach the EU target for climate neutrality by 2050 95 . There has been a steady decline in the amount of carbon sequestered with levels of about 410 Mt CO2eq yr−1 in the 2010-2012 period, decreasing to 340 Mt CO2eq yr−1 in the 2016-2020 period 96 . Therefore, the current estimated economic value of the net carbon sink of EU forests is EUR 32.8 billion per year 97 .

Improving the quality and extent of data on forest area, forest carbon stocks and fluxes through integration of remote sensing with ground data and better long-term planning integrating other policy goals with the one of enhancing forest sink can therefore bring additional positive impacts through improved decision- and policy-making. Monitoring is essential to understand where and how to act. Subsequently, more streamlined and efficient monitoring of forest carbon can reduce ‘transaction’ and ‘design’ costs involved in enhancing forest carbon sequestration 98 .

At the EU and national level this concerns mainly improving the monitoring and reporting of emissions and removals of forest land under the LULUCF Regulation 99 . Information at parcel-level is needed for targeted cost-effective implementation of mitigation actions, tracking their progress, and assessing their impacts in different biogeographical settings and socio-economic contexts. Information by EO is a key asset, as such data are cheap, readily available and transparent. This improved knowledge-base of timely and more accurate information may lead to policies and decisions better suited for maintaining and enhancing forest sink, and therefore reaching the national and EU land sink targets of the Regulation. 

Although both sub-options of Option 2 and Option 3 foresee mandatory use of EO for forest carbon indicators, sub-option 2.1 is likely to bring an additional level of accuracy and detail through the ‘opt-in’ option which would allow the EU wide monitoring to be enriched through incorporation of very high spatial resolution data from national monitoring systems such as those collected through LIDAR coverage campaigns, which contain critical information about forest structure. The expert workshop organised for the purposes of this IA 100  concluded that this feature of LIDAR monitoring is especially useful for high-accuracy and spatial resolution monitoring of above-ground biomass and potentially for cost-efficient deadwood volume estimates.

Regarding indicator coverage, Option 2.2 and Option 3 covers a few additional parameters and indicators which would be useful for the purposes of improving the implementation of the LULUCF Regulation and carbon sink management, namely on forest area and biomass volume affected by disturbances.

Concerning the use of the forest data by forest managers and land owners, the initiative has a high potential to benefit land users by providing freely available, reliable and timely data on changes in forest carbon, providing the basis for the quantification of baselines and carbon removals, which are necessary for the issuance of tradable certificates. The availability of this data could support the overall functioning of the EU-wide certification mechanism 101 , and therefore stimulate the adoption and large-scale deployment of sustainable carbon farming practices across the EU, including improved forest management, forest conservation and afforestation 102 . Both sub-options offer a similar level of necessary indicator coverage on forest carbon, although additional data on forest disturbances might improve knowledge on potential emissions that can inform the estimations on the parcel level. 

6.4.1.2Forest health and resilience

Forest disturbances disrupt the composition of forests and compromise the provision of ecosystem services. Disturbances are becoming more frequent and intense. It is important to improve and maintain forest health and vitality as a measure of protection against the pressures faced. Healthier forests exhibit high resilience against both abiotic and biotic stressors, and the need for strengthening forest resilience will increase. 

While land-based insect trap networks and other ground-based monitoring and sampling can provide good information on the various pest species, more wide-spread use of EO-based monitoring could help fostering more rapid or preventive reaction to the disturbances across Member States, potentially resulting in reducing forest degradation. This data may also inform long-term planning of adaptive forest management practices in identified hotspots.

Regarding the role of EO, for certain types of disturbances such as pest attacks which manifest through defoliation or changes in crown condition, optical remote sensing with sufficiently high frequency (at least yearly, ideally monthly) 103 and spatial resolution is of great relevance, potentially allowing earlier detection of the “green” stage within the outbreak cycle which may lead to reduced time lag in appropriate management decisions in line with the Plant Health Legislation (Regulation (EU) 2016/2031), which contains provisions for obligatory surveillance and reporting of outbreaks of Union quarantine pests. Both sub-options’ approaches to EO would therefore likely positively contribute to reducing disturbances caused by pests. However, for detection of smaller scale disturbances, distinguishing certain types of damages (e.g. pest vs drought), having more higher-resolution information from aerial mapping (e.g. aerial photography) is essential. For this, the more flexible ‘opt-in’ approach of sub-option 2.1 brings more benefits.

Concerning monitoring of forest fires and fire risks, compared to the baseline, the current EFFIS would under Options 2 and 3 gain a legal mandate and therefore higher certainty of its continuity. Even though it is hard to quantify the preventive value of the system, it is important to note that some estimates have valued economic damages from forest fires in Europe of approximately EUR 1.5 billion per year in the 1998-2009 period 104 - retaining and improving this information system is likely to have positive economic impacts in as far as it promotes disaster prevention and preparedness.

The enhanced use of LIDAR in EU forest monitoring that is foreseen to be fostered under Options 2 and 3 can contribute to visualise and quantify the impact of forest fires in order to plan for the rehabilitation of the burnt area 105 , and as a result reduce costs to Member States and forest owners through more efficient post-fire management. Land managers and forest owners can use LIDAR data to assess canopy gaps, the success of forest treatments on forest density, individual tree data, and other forest inventory metrics.

6.4.1.3Biodiversity and ecosystem conditions

Preserving and restoring biodiversity is essential to ensuring healthy and resilient forests that can fully deliver on their socio-economic and environmental functions. There are clear gaps in the current knowledge of the state of biodiversity in the forests in the EU 106 , 107 , 108 . EU assessments of forest ecosystems typically include only a limited number of indicators to monitor biodiversity. If the EU is to fulfil the objectives of Biodiversity Strategy for 2030, data collection and monitoring of other important indicators for biodiversity within forests, for example on other plant and animal species, must be undertaken.

An improved EU-wide monitoring framework would allow for better understanding of the impact of forest management decisions on biodiversity and ecosystem service provision, and the detection of biodiversity hotspots. Protection could thus be more accurately and efficiently given to the forest ecosystems by policy- and decision-makers. Equally, better data would feed into long-term planning on national as well as local level by competent authorities, incorporating and tracking of biodiversity-related objectives (e.g. protection of high conservation value forest habitats and species). A significant impact on the potential of forests to foster biodiversity derives from the management practices carried out. More concrete links between management practices and biodiversity effects can be assessed once a clearer overview of forest biodiversity is accessible to different forest stakeholders, particularly forest managers.

In this area, sub-option 2.1 only relies on the limited indicator coverage of existing reporting frameworks such as State of Europe’s Forests, which lacks some of the important indicators related to the implementation of EU strategic objectives on biodiversity. Instead, the additional indicators under Option 2.2 require, for instance, data on EU primary and old-growth forests 109 , and accurate information on areas and impacts of silvicultural regimes and practices supporting biodiversity and resilience such as close-to-nature forestry, as well as those with high risk of negative impacts such as clearcutting. Data collected for these indicators can moreover feed into the integrated long-term plans to safeguard the integrity and health of these important ecosystems.

Regarding the EO element, high resolution data on forests and their structure using air-borne LIDAR could potentially allow monitoring of important biodiversity proxy indicators such as deadwood and habitat trees – as mentioned above, this is better facilitated with the use of ‘opt-in’ approach of sub-option 2.1.

Another important factor exerting negative influence on EU forests are invasive species. The uncontrolled spread of IAS is often a transboundary issue which requires cooperation across various levels and regions of governance. Especially invasive insect species have large damage potential for EU forests. A 2021 study estimated that the cumulative cost of the impact of biological invasions on the forest sector in Europe from 1960 to 2020 was EUR 20.9 billion 110 . 

The trends for the percentage of forest area under pressure from invasive alien species (IAS) are generally unknown due to a lack of information available to monitor these species 111 . 

The existence of an EU-wide framework for reporting and monitoring spatially explicit information on the species type, extent, and density, could greatly reduce this as a threat in the EU by allowing early detection, rapid eradication as well as preventive measures. Member States have an obligation of reporting on IAS of Union concern listed under the Regulation 1143/2014 on their spread and introduction. This is, however, not the case for certain invasive tree species which are cultivated for economic reasons, such as black locust, even though they have significant impact on biodiversity and other ecosystem services in native EU ecosystems 112 .

Both sub-options under options 2 and option 3 consider the inclusion of invasive species, irrespective of the list of IAS of Union concern, as a mandatory monitoring element, as a potential indicator, which would ensure that adequate knowledge is available on their spread to take appropriate measures.

6.4.1.4Countering deforestation and illegal logging 

In order to combat deforestation and illegal logging, a proper monitoring system is essential for quantifying and evaluating the extent of the problem as a first step. The focus on the monitoring of illegal timber generally falls on timber imports from non-EU countries - The Thünen Institute estimate that 6% - 13% of timber imports to the EU in 2009 came from illegal sources 113 . The World bank has estimated the value of forgone tax revenue caused by illegal logging in Europe to be 190 million USD 114 . However, internal EU illegal logging is also economically detrimental to EU forest-based industries.  Illegal timber can be sold for a significantly reduced price, unfairly undercutting the prices of legal timber and forcing legitimate producers to lower their prices to unsustainable and unprofitable levels.

The European Court of Auditors’ report from 2021 115 found that remote sensing is a powerful cost-efficient tool that could strengthen the implementation and enforcement of the EU Timber Regulation 116 to monitor deforestation and illegal logging activities, and recommends to extend the Commission's use of, and promote Member States' use of, geospatial intelligence including remote sensing techniques to better assure compliance with EU requirements concerning forest management and illegal logging.

The creation of an EU-wide forest monitoring framework under option 2 and option 3 includes the EO-based monitoring of key variables such as tree cover, spatially explicit designation of areas by management objective or protection status. This will allow for better identification and prevention of deforestation and illegal logging, thus protecting the forest ecosystem services and allow Member States and forest managers to reduce revenues losses.

It is difficult to estimate the value of this loss prevention, as EU-level estimates on the value of illegal logging are not available. However, using national examples, illegal operations made up around a quarter of all logging in Bulgaria between 2006 and 2013, generating hidden revenue of over EUR 50 million per year 117 . According to a study of a limited set of illegal harvesting methods by the Romanian government an estimated volume of 80 million m3 of timber was cut illegally in Romania between 1990 and 2011. This represents 24% of the total volume of wood cut during this period, a similar share as in Bulgaria. Adequate monitoring and planning will help in reducing deforestation and illegal logging and related costs.

6.4.2Assessment of social and socio-economic impacts

The social and socioeconomic impacts considered in this section are those of ecosystem services provided by forests and are not exhaustive or indicative of the full capabilities of the EU’s forests, or the long-term impacts which improved sustainable forest management and enhanced environmental protection can have. However, these were prioritised and deemed to be the most prominent and important to highlight, based on the extent they are discussed in the literature and the importance given to them in the relevant forest assessment reports. Other impacts besides those discussed here include the support of pollination services for agriculture and otherwise, water purification, flood and soil erosion mitigation.

6.4.2.1Greater trust in forest data from different stakeholders

More accurate and trustworthy forest information was identified as a key need of stakeholders in the public consultation (see Annex II). The adoption of modern technology, common definitions of indicators, harmonisation/standardisation of data collection methodologies, as well as increased transparency relating to data, could improve trust in forest data across the EU and provide reputational benefits to forest owners and managers. Accessible data collected in the context of the monitoring and planning framework can potentially stimulate the additional use of forest data by different stakeholders, beyond traditional users and industries e.g. scientific community, policymakers, certain actors within the forest industries, data-based services, forest owners (Table 3 for stakeholder overview).

More accessible forest data made available on FISE through a new framework can reduce costs for those SMEs in the forestry sector who may have paid for data from private data providers 118 , where publicly available information was not available, or considered unreliable or untrustworthy. . SMEs who may have relied on publicly available data in the past would benefit for their decision-making from increased accuracy and trust in the data on forest resources - 66% of companies and businesses responding to the OPC agree that better access to forest data in general is needed .

In this respect, sub-options under Option 2 and Option 3 bring a more significant positive impact in that they ensure a higher degree of data comparability and consistency, and they make it accessible to the stakeholders as well as wider public through a single portal (FISE).

6.4.2.2Sustainable provision of forest resources and services

Timber provision as an ecosystem service is defined as the contribution of ecosystems to the growth of wood harvested as raw material for different purposes. For 2019, the value of timber provision as an ecosystem service in the EU was estimated at around EUR 16 billion in the INCA study 119 , while the gross-added value of the forestry and logging industry was estimated at around EUR 23 billion by EUROSTAT 120 . To put those estimates in context: the reported value of marketed non-wood forest products in Europe was approximately EUR 4 billion in 2015 121 , and the annual value of regulatory and cultural ecosystem services (i.e. flood control, water purification and recreation for which forests were the main contributor to the total value of nature-based recreation) for the year 2012 was estimated at about EUR 57 billion in the same study 122 . Moreover, forestry and logging employed almost 0.5 million people in the EU27 123 in 2020, with the wider forest-based employment of approximately 3.5 million people 124 . The pulp and paper industry alone provides 1.5 million jobs along the value chain, and bio-based products and biofuels involve 300,000 jobs 125 . The creation of a sound planning framework backed by reliable data can protect future forest resources and establish healthy, long-term forest yields to ensure that the forest-based industry has a viable future. 

The added value of more harmonised, accurate, and timely forest data which this initiative would bring, will contribute to competitiveness and resilience of EU forest-based sector in multiple ways. For instance, timely information on forest risks such as droughts or wildfire risk under Option 2 and 3 can help forest owners, and forestry industries identify potential risks to their management objectives and operations, and take proactive measures to mitigate or adapt to them. Accurate data on tree species composition of EU forests and the distribution of impacts of stresses and disturbances according to the tree species can bring valuable insight into the evolution of timber resources for the timber industry. Moreover, integration of this data into long-term plans can inform more sustainably forest management which benefits both the ecosystem and the forest owners or forest-based industry. The combined effects can contribute to healthy, long-term forest yields to ensure sustainability of wood supply. Secondly, a more secure internal EU-timber yield will reduce the need to import non-EU timber and strengthen the competitiveness of EU timber for European use and for export.

The warming climate in Europe will shift the distribution of forest species and this will have economic consequences. A study on the impact of future temperature increases on 32 tree species in Europe by 2100 found that the expected value of European forest land will reduce due to a predicted decline in economically valuable species 126 . Depending on the scenario and discount rate, this indicated a 28% reduction (with a range of 14% and 50%) in the present value of forest land in Europe, with a cost of several hundred billion Euros. 

In order to protect valuable forest land in the EU, the mandatory set of indicators monitored under Option 2, specifically on the impact of forest disturbances on forest resources, and the harmonisation of the reporting system will facilitate relevant planning by the private and public sector towards mitigating these impacts and financial losses as best as possible. This data can inform specific forest management practices from forest owners and ensure the decisions made are timely and effective.

Where the monitoring and planning framework leads to the adoption of decisions that ensure a more sustainable and forward-looking management of forest resources, this could potentially ensure long-term provision of forest resources in the future, and the ability of forest resource to satisfying the many competing demands on both forest biomass (e.g. solid wood for construction, furniture and other wood and bio-based products, and for energy) and other ecosystem services (e.g. recreation), helping to safeguard existing and create new jobs, particularly in rural or remote areas. Thus, monitoring is needed to collect evidence on the adjusting policies and management decisions that support the sustainable provision of forest resources.

7How do the options compare?

This chapter evaluates the policy options presented and analysed in Chapters 5 and 6 against a set of three key criteria: effectiveness, efficiency and coherence. Based on these criteria, the options are compared to the baseline scenario with “+++” meaning that objectives are fully met, “++” objectives are partly met and “+” slight improvement over baseline. For Option 3 rankings are expressed with two scores reflecting the different levels of intervention between the two main elements of the proposal (mandatory monitoring and voluntary planning).

7.1Effectiveness

This criterion includes contributions to the specific objectives to ensure data comparability and indicator coverage of EU priority topics, quality and transparency of forest data and to establish a holistic forest governance planning framework.

Option 1 would be less effective than sub-option 2.1 and sub-option 2.2 and Option 3 for reaching the objectives related to monitoring. Without a legal framework establishing coherent objectives and standards, data comparability and quality will only improve slightly over the baseline.

Considering the marked differences among monitoring and planning systems, as well as the drivers behind the problems identified (costs, historical preferences, scattered responsibilities), it can be expected that the timing and degree of using voluntary guidance to update or amend national systems for data collection, achieve harmonised international reporting or improve long-term planning would vary widely across Member States. Member States will to a certain extent continue to use a range of definitions, and different means to monitor, process and report on forest indicators, especially those not related to forest timber resources where some harmonisation efforts are expected to continue.

Likewise, existing differences in the definition and use of the term “forest strategies” and the varying degree of including forest information or measures under required planning instruments such as NECPs and adaptation strategies will only be addressed partly.

Data and information access continuing through various channels would continue to hamper transparency. The role of EO would not change significantly without any obligation to use it where pertinent due to path dependencies despite its benefits.

Sub-option 2.1 could score higher in terms of data quality than sub-option 2.2 or Option 3 in case Member States provide LIDAR data via the opt-in approach. These data have a higher spatial resolution than satellite-based data, which will be the basis for the EO-based products provided by the Commission. A similar level of data comparability as for sub-option 2.2 and Option 3 could be achieved for EO data in case of Member State’s ‘opt in’ under sub-option 2.1 if a proper calibration exercise is carried out and quality of the provided data is assessed. However, data comparability overall will be slightly higher under sub-option 2.2 and Option 3 considering higher indicator coverage. Overall scoring is therefore equal for both sub-options under Option 2 and Option 3 (objective partly to fully met) in relation to the data criterion.

Option 1 and Option 3 score the lowest in ensuring a common standard for long-term planning bringing only slight improvements compared to the baseline. Under a voluntary approach, predominantly Member States with already high ambition in terms of strategic planning would join; thus, the overall ambition in the EU would not be raised and the objective of a coherent governance framework would not be achieved. Establishing an obligation for long-term planning with common key elements, Option 2 will ensure integrated planning coverage on a comparable standard across Member States. Among the two sub-option 2.2 will be more effective (fully meeting the objectives) than sub-option 2.1 (partly achieving the objectives) with non-binding recommendations by the Commission expected to support Member States in tackling possibly shortcomings in achieving an integrated approach in forest planning.

7.2Efficiency

This criterion includes contributions to economic benefits, reducing administrative burden and improving regulatory compliance.

Under option 1 and for integrated planning under option 3, cost efficiency will improve slightly or partly compared to the baseline. Economic cost and benefits will not change significantly and will depend on Member States’ willingness to engage in voluntary coordination and align their systems to Commission guidelines on data standardisation and integrated planning. As a result, benefits derived by Member States might be slightly improved compared to the baseline from cost-efficient harmonisation of a limited number of indicators suited for national circumstances and policy needs, and from enhanced use of EO services offered by the Commission. Under sub-options 2.1 and 2.2, economic costs and benefits will be equally higher on average across their different elements – this means that with increasing costs associated with harmonisation and standardisation, their direct and indirect economic benefits are expected to rise proportionally too. This applies also to the monitoring part under option 3. Substantial one-off costs could occur under both sub-options and option 3 if a Member State had to set up a new data collection framework or adapt its current one significantly to meet common quality standards (e.g. in respect of frequency), but may be off-set through indirect benefits accrued on both the EU, national and forest level through improved policy- and decision-making based on the better quality data. Both sub-options under option 2 and option 3 will require some investment costs by public administrations for data harmonisation or standardisation (both their development and application), slightly higher under sub-option 2.2 and option 3 because of the higher number of indicators. Mandatory planning under Option 2 will imply administrative burden for those Member States not yet implementing strategic planning but this may be off-set in the longer-run by reducing the need for ad-hoc responses due to unforeseen events.

In addition to the indirect benefits for decision-making of acquiring more timely and geographically explicit data, EO related benefits relate to the cost reduction from reducing costs for ground-based data collection, mostly related to changes to tree cover extent and condition. These are slightly higher under sub-option 2.1 because the voluntary opt-in approach would allow Member States to choose the most cost-efficient link between their individual national system in place and the EU services while under sub-option 2.2 and option 3, Member States with an own EO system may risk some sunk costs through stranded investment, and therefore have lower overall benefits.

Cost efficiency for integrated long-term planning will be higher under sub-option 2.2 and 2.1 and party met, compared to option 1 and option 3 which will result only in a slight improvement compared to the baseline. Benefits under sub-option 2.2 will derive from an increase in planning over time if recommendations lead to a gradual improvement throughout the iterations, but at the expense of additional administrative burden on the side of the Commission (for review and issuing recommendations) and Member States (for revising the plans).

The Commission would incur limited additional running costs for FISE and more substantial running costs related to developing and continually updating additional EO-based forest data products as foreseen under option 2 and option 3, including a potential need for funding a sample plot network for collection of necessary ground data. On the other hand, the Commission would benefit also from cost savings on accessing and utilising higher quality forest data from common mandatory reporting done by Member States under Option 2 and Option 3, resulting, for instance, from reduced administrative costs on data gap filling exercises currently undertaken by the JRC. Research funding would have to be spent on developing harmonisation methodologies where currently missing or new standards, where deemed necessary. The two options will also entail administrative costs in relation to data quality assurance and control.

The expected benefit from reduced administrative burden by public authorities in Member States for option 1 and for planning under Option 3 will be inversely proportional to the level of engagement by Member States in voluntary coordination in a similar magnitude like either sub-option 2.1 or sub-option 2.2. The burden related to drafting of guidance on data harmonisation and integrated planning is expected to be slightly lower under Option 1 and regarding planning under Option 3 than Option 2, given the expected larger extent of indicators and planning elements covered under the legislative option.

Sub-options 2.1 and 2.2 and option 3 will generate administrative costs to public authorities for ensuring the monitoring systems meet minimum standards in terms of frequency of data collection. Sub-options 2.1 and 2.2 are also linked to costs associated with data harmonisation following a common definition, or data collection according to common standards, and preparation of integrated long-term plans. The actual magnitude will depend on the individual starting point of the Member State and partly incur a one-time investment and thereafter limited running costs where continuous harmonisation of new datasets is needed, thus decreasing on the long-term.

Facilitating a single-portal access to forest information both option 2.1 and option 2.2 and option 3 reduces administrative burden for National authorities, businesses, and citizens. Considering the lower number of indicators under sub-option 2.1 compared to 2.2., the latter scores somewhat higher in efficiency in relation to administrative burden (objectives partly met vs slight improvement compared to the baseline).

Improvement of regulatory compliance requires common progress across all Member States. This will likely not be achieved with option 1 resulting only in a slight improvement compared to the baseline. A voluntary set-up will trigger different responses across Member States. The mandatory set of indicators and the standardisation of data collection and reporting in combination with long-term planning under sub-option 2.1 and more so under sub-option 2.2 will strengthen evidence-based decision-making on forests status and uses and support better control of illegal activities. The objective will therefore be fully met. Under option 3 this will be achieved only partly due to the incoherence in the level of intervention between the monitoring and the planning part.

7.3Coherence 

This initiative relates to several EU policy objectives, initiatives, and instruments. The evaluation of coherence looks at how consistent each option is with these, and it identifies the extent to which it promotes horizontal objectives and facilitates the delivery of relevant key targets. Since the hybrid option combines different levels of intervention (obligatory for monitoring and voluntary with planning), internal coherence is assessed in addition.

7.3.1Coherence with other policies

The coherence with other policies will be the highest with objectives fully met for sub-options 2.2 and the lowest for Option 1. Only slight improvements beyond baseline are expected since coherence will depend on Member States individual level of ambition. This will differ according to National priorities. For EU strategies and policies, it is expected that the coherence objective will be partly met with sub-option 2.1 and fully met with sub-option 2.2 with the wider indicator coverage beyond legal obligations. With option 3 coherence will be fully met for monitoring while only slight improvements can be expected for planning. Overall coherence objectives will therefore partly be met.

Regarding coherence and synergies with other international frameworks, all options aim to minimize reporting burden by aligning, wherever possible, with internationally agreed reference definitions, specifically FAO FRA, while options 2 and 3 aim to limit the introduction of double obligations where current international reporting is deemed sufficient (see Table 21). Harmonised EU reporting aligned with definitions and methods used for reporting to international frameworks like the FAO FRA or UNECE can ensure coherence of the internationally reported EU figures with the sum of national values 127 .

A detailed evaluation is discussed according to individual legislation, strategies and policies in the following table.

7.3.2Coherence between the two main elements of the different options

Based on the assessment of the three previous criteria in sections 7.1-7.3 it can be assumed that the objective that this legislative initiative seeks to achieve, i.e. “A coherent governance framework for reporting and planning is established”, would be partly achieved with option 1 and fully with option 2. The voluntary approach under option 1 risks that the level of ambition for monitoring and planning might not be equal in individual Member States generating mixed results regarding effectiveness and efficiency. This risk is much lower under option 2 setting a mandatory standard for both elements that Member States will have to comply with.

With option 3, the initiative’s objective would most likely not be fully achieved resulting only in slight improvements above the baseline. The monitoring obligations would produce a wide range of high-quality datapoints regarding forests for all Member States. However, data collection is not an end goal in itself, but will be key to benefit other policies and their implementation, not least carbon capture which will be important for the competitiveness of the sector.

The long-term integrated planning would fall under those potential uses of the available data. Not using this data to the best extent possible would not reach the full potential of the legislative proposal. In addition, it could undermine the assessed effectiveness of the monitoring, given that the actual use and benefit of the collected data would depend on individual Member State’s ambition on planning.

Forest monitoring and integrated long-term planning are linked with monitoring crucial to ensure that forest planning is evidence-based and an integrated long-term planning in turn supports targeted and efficient monitoring. Forest monitoring and long-term planning therefore require the same level of a common approach.

Preferred option

7.4Choice of option

The analysis carried out in chapter 6 shows that, even within the constraints due to lack of quantitative criteria for comparing costs and benefits, the benefits of a full legislative approach clearly outweigh those stemming from the voluntary and hybrid options.

The preferred option would be a self-standing instrument that informs or complements existing policies and legal frameworks for three reasons. First, it is unlikely that the required extent of coordination could be achieved through individual amendment considering the sheer number of relevant EU instruments (Figure 27 in Annex 5), their varying level of attention and obligation relevant for monitoring and planning and different competent authorities in the Member States. None of them covers the two specific objectives outlined in Chapter 4.2. Even if this could be achieved, the result would still be a fragmented, non-coherent monitoring system. Second, comprehensive forest monitoring or integrated planning are presently not mandatory under any EU piece of legislation and the establishment of such an obligation consistently across the diversity of legal instruments outlined is unlikely. Third, establishing a common framework through a simple, single instrument would support the need for promoting a holistic and integrated approach to forests, following the narrative of the new EU Forest Strategy for 2030.

The OPC showed a high degree of support for EU-wide harmonized and timely information on a number of variables. More than 88% of respondents were in favour of indicators on issues like forest health, disturbances, and climate change and impacts and projections. The least popular indicators received support from about 40-50% of respondents with only around 20% being directly against.

The preferred option would entail a combination of elements from both sub-options under option 2. The comparison of policy options in Chapter 7 has clearly shown the need for a binding instrument to meet the strategic objectives for data comparability, quality and availability. Therefore, mandatory monitoring and reporting of forest data based on common harmonised or standardised definitions and methods for a set of indicators was identified as the preferred policy measure. To fully cover the priority policy areas of forest health and resilience and biodiversity, a wider selection of indicators than those in current legislation and existing monitoring and reporting frameworks was found to be necessary. Therefore, in relation to common indicator coverage, the preferred option is 2.2.

A step-wise approach would be applied for selecting the mandatory indicators and parameters – a limited list would be first selected for inclusion in the legislative proposal of the basic act. This list of indicators and parameters was identified considering all of the following aspects: their relevance to the priority policy objectives, the need for higher spatial or temporal resolution compared to the existing monitoring and reporting, availability of common definitions and methods, availability of Earth-observation based tools and methods for their monitoring, and current status of monitoring and reporting in the Member States.

The identified indicators and parameters that have not been selected in the first step (i.e. in the legislative proposal) would be considered for inclusion at a later stage through implementing legislation, based on the assessed priority and methodological needs and taking into accounts recommendations by a dedicated expert group.

The collected and reported data would be made available through FISE, as an existing ‘one stop-shop’ platform, which will increase transparency and easy access to cross-sectoral information. This is key to building an integrated understanding on forests, their status and ecosystem services.

Recognizing the diversity in relation to the use of EO across Member States, a mandatory use of EO where suitable with an opt-in option for Member States will strike a balance between ensuring high quality data, while reducing costs and leaving room for manoeuvre for Member States. Development costs would be borne by the Commission in a two-step approach by maximising available EO funds under the current MFF, supplemented by channelling available funding earmarked for biodiversity in the different financial instruments. The ambition will be to ensure coverage of all pertinent indicators with an (close to) agreed methodology for data collection. In a second step, the Copernicus budget would have to be adapted under the future MFF in parallel to establishing harmonised and standardised data collection methods for those EO-based indicators currently missing.

More than 60% of respondents in the OPC agree that data from Member States’ monitoring systems should be better integrated, and more than half of respondents think that the EU should operate a single monitoring system. These averages cover a preference for continuing current monitoring systems among companies and businesses, while environmental organisations tend to be against a business-as-usual option. Respondents representing Member State public authorities expressed moderate support in favour of integration, though not necessarily for a single EU monitoring system. An opt-in approach represents a balance between the views expressed by stakeholders. See Section 3 of Annex 2 for more detailed information on the responses to the OPC.

As explained in section 2.1, a large majority (84%) of respondents highlighted the importance of more consistent, comparable and timely forest information. This statement is also valid when looking at stakeholder groups separately, e.g. 73% of respondents from the stakeholder group ‘business associations’ and 92% of academics indicated consistent, comparable and timely forest information as important or very important. This Impact Assessment has shown that a legislative approach is more likely to bring about such data.

Therefore, in relation to monitoring, the preferred option is 2.1.

Mandatory long-term plans following a common set of basic requirements and core elements in combination with the Commission issuing non-binding recommendations on their development will allow Member States context-specific priority setting, targets and measures while ensuring integrated alignment with EU policies on forest conservation and uses.

Only 14 % of the OPC respondents did not identify an added value of strategic plans for forests. Across all stakeholder groups a holistic view on forest status and trends (55%) as well as allowing for overall coordination of long-term forest planning (53%) were mentioned most often as added value. NGO’s (30%) were the stakeholder group with the highest share of respondents not agreeing on an EU added value.

Therefore, in relation to integrated long-term planning, the preferred option is 2.2.

In addition, the preferred option includes the use of the expert group set-up in the framework of the new EU Forest Governance, for both coordination and guidance as well to support the Commission in developing common definitions and protocols for indicators and data collection and non-binding recommendations on long-term plans. This reflects the shared competence on forest matters and the need for close cooperation between the Commission and the EU Member States.

Table 28 in Annex 5.4 provides an overview of the core elements of the preferred option in relation to problems, drivers and specific objectives.

Funding is considered as possible add-on to the preferred option. Next to providing Copernicus services free of charge, targeted funding could complement the preferred policy option to support the costs for system alignments. Under the current MFF, 30% of EU budget has been earmarked for climate and environmental actions (with specific targets for biodiversity, at least 7,5% for 2024 and 10% for 2026). The Commission could provide guidance and encourage Member States to use respective funding in the mid-term review of relevant funds during the current financial period and further earmark relevant funds under the next financial period. In addition, opportunities under EU R&I framework programme, such as the upcoming partnership “Forests and forestry for a sustainable future”, will further contribute to the development of improved, consistent and up-to-date forest data in Member States.

Furthermore, international engagement should continue as part of the preferred option. One of the aims with this initiative is to build on and maximise synergies with existing international engagement and also provide a structured way of contributing to international efforts therefore contributing to the EU’s ambition as a leader in the world.

7.5Proportionality

The combination of elements selected in the preferred option is proportionate insofar it is clearly limited to those aspects that Member States cannot achieve satisfactorily on their own, and where harmonisation at Union level is needed. Because the scale of the issue at stake and its crossborder dimensions, the EU is the only body that may ensure a consistent monitoring framework bringing together the Member States. As highlighted in chapter 3, common standards for data collection, monitoring and long-term integrated planning cannot be developed at a Member State level.

No option would involve transferring powers from Member States to the EU beyond the necessary monitoring harmonisation (no transfer of powers on the management of forests).

7.6Legal instrument

The principle of proportionality requires that the choice of instrument is as simple as possible and coherent with a satisfactory achievement of the objectives and with effective enforcement.

The choice of a regulation would fit the subject matter of this initiative and its level of precision and would allow to overcome the problems described in this impact assessment report more effectively than a directive, as it would allow to set common standards that are binding and directly applicable across all Member States without the administrative burden of and the delay for transposing the instrument into national law, contributing to the achievement of the objectives of better forest protection and integrated planning by the Member States. Furthermore, it would set the basis for the adoption of implementing legislation with support of the expert group for the development and specification of technical requirements, for example as regards indicator harmonisation and standardisation.

7.7Simplification and improved efficiency

Whilst the preferred option, which would be 2.2 for common indicator coverage, 2.1 for monitoring, and 2.2 for integrated long-term planning, will not require any changes to existing legislation, it will, nevertheless, lead to cost savings or improved compliance in a number of those listed in Figure 27 in Annex 5 and important indirect benefits, ultimately outweighing its costs.

Detailed costs and benefits of the different elements of the initiative, i.e. data harmonization and standardization, the development of enhanced EO for forest management, as well as integrated long-term planning, are discussed in Annex 3. Those include direct administrative and adjustment costs, one-off and recurring, assessed for national authorities, EU institutions and other stakeholders. Direct and indirect benefits of the initiative are also detailed.

8How will actual impacts be monitored and evaluated?

A plan based on a set of milestones will be designed by the Commission to track the implementation of the actions required to achieve the specific objectives against a specific timeframe (e.g. adoption of technical implementation measures on data collection harmonisation and standardisation and on governance framework).

In addition, the Commission will monitor the roll out and impacts of the measures on a regular basis (biannual) based on the following elements:

·Number of indicators with a common definition

·Number of indicators with harmonised or standardised data collection methods

·Data provision by Member States to FISE

·Data access via FISE (average clicks/month)

·National adaptation strategies and risk-assessment and risk-management strategies relying on common indicators

·Evolution of forest digital services market (in particular, number of SMEs)

·Evolution of number of forest-related certification schemes

·Number of long-term integrated plans adopted by Member States

·Level of alignment of integrated long-term plans with common set of basic requirements and core elements

·Use of EU funds in support of monitoring actions

In addition, the Commission will launch an evaluation based on the abovementioned elements, taking into account the Member States’ reports on the integrated long-term plans, which would be presented to Council and Parliament within three years of entry into force of the legal instrument.

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Communication from the Commission to the European Parliament, the Council, the European Economic and Social Committee and the Committee of the Regions [2021] Better regulation: Joining forces to make better laws. COM(2021)219 final.

Communication from the Commission to the European Parliament, the Council, the European Economic And Social Committee and the Committee of the Regions [2021) ‘New EU Forest Strategy for 2030’. COM(2021)572 final.

Communication from the Commission to the European Parliament and the Council [2021] Sustainable Carbon Cycles. COM(2021)800 final.

Commission Staff Working Document ‘Sustainable carbon cycles - Carbon farming Accompanying the Communication from the Commission to the European Parliament and the Council Sustainable Carbon Cycles’. SWD(2021)450 final.

Commission Notice — Technical guidance on the climate proofing of infrastructure in the period 2021-2027 [2021] OJ C/373/1.

Proposal for a Regulation of the European Parliament and of the Council on nature restoration. COM(2022)304 final.

Proposal for a Regulation of the European Parliament and of the Council amending Regulation (EU) No 691/2011 as regards introducing new environmental economic accounts modules. COM(2022)329 final.

Proposal for a Regulation of the European Parliament and of the Council establishing a Union certification framework for carbon removals. COM(2022)672 final

Communication from the Commission to the European Parliament and the Council [2022] 2022 Strategic Foresight Report Twinning the green and digital transitions in the new geopolitical context. COM(2022)289 final.

Annex 1: Procedural information

Lead DG, Decide Planning/CWP references

Organisation and timing

-The initiative has been first announced in the New EU Forest Strategy for 2030 that the Commission adopted in June 2021 128

-The call for evidence was open for consultation between 08 April 2022 and 06 May 2022. 117 replies were received.

-The public consultation was open between 25 August 2022 and 17 November 2022. 311 replies were received.

-The Inter-Service Steering Group (ISG) was consulted in written on the consultation strategy in March 2022 and the draft Impact Assessment Report in December 2022-January 2023 and during meetings of the group on 22 March 2022, 09 December 2022 and 10 January 2023. It was co-chaired by ENV and CLIMA, and the other DGs participating were AGRI, CLIMA, DEFIS, ECHO, ENER, EUSTAT, GROW, JRC, REGIO, RTD, SG, SJ, TRADE and CINEA. The minutes were shared with the members of the ISG and all comments received taken into account.

Consultation of the Regulatory Scrutiny Board (RSB)

-ENV and CLIMA outlined the rationale, scope and draft policy options for the initiative to the Regulatory Scrutiny Board at the upstream meeting on 12 September 2022. Following the meeting, ENV and CLIMA redefined the scope of the initiative, the problem description and the policy options. The evidence-base was strengthened reflecting the diversity of EU forests and existing standards and systems in Member States and careful attention given to policy coherence.

-The draft of the Impact Assessment was submitted to the Regulatory Scrutiny Board on the 18th January 2023.

-On 18th February 2023, the RSB issued a positive opinion subject to amendments of the Impact Assessment. In the Table below, the comments and the subsequent changes responding to the comments are shown.

Evidence, sources and quality

This impact assessment was carried out with the support of a 10-month service contract signed in June 2022. The consortium providing the service consisted of Rambøll Management Consulting A/S (lead), the European Forest Institute (EFI) and the Italian Academy of Forest Sciences (IAFS).

The service contract consisted of 6 main tasks:

·Task 1: Definition of problems, drivers, objectives, and development of policy options

·Task 2: Assessment of the impacts of policy options and comparison of options

·Task 3: Analysis of existing background material and assessment of current forest monitoring frameworks in the EU

·Task 4: Analysis of existing background material and assessment of Strategic Plans for Forests

·Task 5: Organisation of workshops, assistance in meetings and stakeholder consultation analysis

·Task 6: Ad-hoc work

Annex 2: Stakeholder consultation

1. Introduction

The Commission carried out broad consultation activities on the legislative initiative. Consultations started with a Call for Evidence between 08 April 2022 and 06 May 2020 and was followed by an Open Public Consultation between 25 August 2022 and 17 November 2022.

In addition to the Call for Evidence and Open Public Consultation, a series of four thematic expert workshops were also organised in the course of October to November 2022, a dedicated sub-group under the Standing Forest Committee facilitated technical exchange with the Member States through two meetings during November and December 2022, and finally, a thematic workshop was organised by the CZ PRES in which the Commission actively engaged. A summary of the discussions and feedback received is provided in the next sections.

2. Feedback to the Call for Evidence

2.1 Overview of replies