No recommendation

a)    Demonstrate how the goal of achieving a balance between anthropogenic emissions and removals will be achieved in the second half of the century. Provide qualitative and quantitative information until at least 2050 consistent with the long-term strategy required under Regulation (EU) 2018/1999.

c)    Provide credible and robust evidence for the model to reproduce historical data. Assess if the increasing area of Douglas fir entering the size classes with high annual growth is the sole or key driver for the overall trends in growth and harvest. Provide information on projected growth in light of the projected increase in harvest.

d)    Provide information such as partitioned quantities of tree biomass felled / dead into e.g. dead organic matter, harvested timber, felling residues, fuel wood, industrial roundwood, and the into different product classes including energy wood, or any other class that is appropriate.

e)    Ensure the consistency and comparability of definitions such as 'timber', 'harvest' etc. and the grading of felling in the data sources used for the ratio calculated from these data.

g)    Demonstrate the consistency with the national projections of anthropogenic greenhouse gas emissions reported under Regulation (EU) No 525/2013. Provide explanations for possible differences between national projections and the proposed FRL.

h)    Estimate the FRL based on the area under forest management as indicated in Annex IV, Part B (e) i. Demonstrate the ability of the model used to construct the FRL to reproduce historical data from the national GHG inventory. Demonstrate the consistency between historical data from the national GHG inventory and modelled data for estimating the FRL for the reference period.

a)    Provide an estimate of the FRL with the correct sign. Provide information if and how natural disturbances have been taken into account.

b)    Include the carbon pools and greenhouse gases required by Regulation (EU) 2018/841 in the FRL and the national GHG inventory. Assure consistency for the starting point of projections for all carbon pools, including the HWP pool.

d)    Provide information on harvesting rates for at least one different policy scenario.

e) i    Provide the area under forest management consistent with Table 4.A (“Forest land remaining Forest land”) from the latest national GHG inventory using the year preceding the starting point of the projection.

e) ii    Distribute simulated harvest data into HWP pools. Compare simulated harvests to reported historical harvest data.

e) iii    Provide additional information on the characteristics of the virtual forests used by model and a verification with actual field data in order to improve the confidence on the modelling approach.

e) iv    Provide the historical and future harvesting rates disaggregated between energy and non-energy uses.

1)    Provide information on the continuation of harvest levels by sustainable forest management practices and according to age-dynamics. Justify the reasons for the increase of the harvest during the projected period.

a)    Demonstrate how the goal of achieving a balance between anthropogenic emissions and removals will be achieved in the second half of the century. Provide qualitative and quantitative information until at least 2050 consistent with the long-term strategy required under Regulation (EU) 2018/1999.

c)    Clarify how the values of the actual harvest used for FRL have been produced. Describe data sources of harvests.

e)    Provide a ratio between solid and energy use of forest biomass as documented in the period from 2000 to 2009 used for the estimation of the forest reference level and demonstrate it remains constant throughout the projection.

g)    Demonstrate the consistency with the national projections of anthropogenic greenhouse gas emissions reported under Regulation (EU) No 525/2013. Provide explanations for possible differences between national projections and the proposed Forest Reference Level.

h)    Estimate the FRL based on the area under forest management as indicated in Annex IV, Part B (e) i. Estimate the FRL based on carbon pools and greenhouse gases as indicated in Annex IV, Part B (b). Demonstrate the ability of the model used to construct the FRL to reproduce consistently historical data from the national GHG inventory for the reference period. 

b)    Include the carbon pools and greenhouse gases consistent with those applied in the latest national GHG inventory.

c)    Provide explanations on how harvest from illegal logging is considered in the adopted policies

e) i    Provide the area under forest management consistent with Table 4.A (“Forest land remaining Forest land”) from the latest national GHG inventory using the year preceding the starting point of the projection.

e) iii Provide information about increments by forest management practice and age-class. Clarify how the values for the actual harvest used for the FRL has been produced.

e) iv    Provide historical and future harvesting rates disaggregated between energy and non-energy uses.

No recommendation

a)    Demonstrate how the goal of achieving a balance between anthropogenic emissions and removals will be achieved in the second half of the century. Provide qualitative and quantitative information until at least 2050 consistent with the long-term strategy required under Regulation (EU) 2018/1999.

e)    Provide complete and transparent information on logging residues. Provide information on dataset used and methods applied to assess the use of the logging residues across the entire time series and on the method applied for projecting these quantities beyond 2017.

f)    Provide information on the provisions of the Czech Forest Act on sustainable management and biodiversity conservation together with a table that shows the evolution from 2000 to 2030 of the total forest growing stock.

g)    Demonstrate the consistency with the national projections of anthropogenic greenhouse gas emissions reported under Regulation (EU) No 525/2013. Provide explanations for possible differences between national projections and the proposed FRL.

h)    Estimate the FRL based on the area under forest management as indicated in Annex IV, Part B (e) i. Demonstrate the ability of the model used to construct the FRL to reproduce historical data from the national GHG inventory. Demonstrate the consistency between historical data from the national GHG inventory and modelled data for estimating the FRL for the reference period. Provide information on the changes in the level of agreement in the period 2000-2017 between the projected increment and the actual increment and assess its potential impact on the FRL.

b)    Noting the inclusion of additional carbon pools in the FRL, include those pools in the next submission of the national GHG inventory to ensure consistency between the FRL and the national GHG inventory.

c)    Provide information if the factors used in the national GHG inventory have also been applied to the FRL. Assure that modelling starts the year after describing the state of the forest.

d)    Provide detailed information on how harvesting rates are expected to develop under different policy scenarios.

e) i    Provide the area under forest management consistent with Table 4.A (“Forest land remaining Forest land”) from the latest national GHG inventory using the year preceding the starting point of the projection.

e) ii    Harmonize the information for comparison between table 8 and figure 10.

e) iii    Provide information on the use of the forest age to determine the current annual increment and on how the annual area from an age-class to the following is calculated.

e) iv    Provide information on dataset used and methods applied to assess the use of the logging residues across the entire time series and on the method applied for projecting these quantities.

1)     Clarify which and how the different National Forest Inventory sources (i.e. 2002, 2012 and 2017) were used to develop the FRL; in particular, the time period, data source and method used to generate the survival curves and carbon stocks, and HWP projections could be clarified more clearly. Indicate if data outside the reference period (2000-2009) were used, and if so, provide a justification.

c)    Clarify the period, data source and method used to generate the survival and growth models, in particular the number of national forest inventory cycles used to generate the models. In addition, demonstrate how the energy use of domestic harvest trend line endpoint is representative of the reference period and how consistency is assured in relation to the other elements of the reference period.

d)    Clarify that the method employed to estimate the HWP pool to ensure that this is consistent with the stock change approach applied, and that the total amount of harvest is consistent with the assumptions made for the other pools.

e)    Provide a ratio between solid and energy use of forest biomass as documented in the period from 2000 to 2009 used for the estimation of the forest reference level and demonstrate it remains constant throughout the projection.

g)    Demonstrate the consistency with the national projections of anthropogenic greenhouse gas emissions reported under Regulation (EU) No 525/2013. Provide explanations for possible differences between national projections and the proposed FRL.

h)    Estimate the FRL based on the area under forest management as indicated in Annex IV, Part B (e) i. Use the conversion period for Land converted to forest land (Afforested Land) consistent with the latest national GHG inventory. Demonstrate the ability of the model used to construct the FRL to reproduce consistently historical data from the national GHG inventory for the reference period. 

b)    Noting the inclusion of additional greenhouse gases in the FRL, include those greenhouse gases in the next submission of the national GHG inventory to ensure consistency between the FRL and the national GHG inventory. Assure consistency for the starting point of projections for all carbon pools, including the HWP pool.

d)    Provide information on harvesting rates for at least one different policy scenario.

e) i    Provide the area under forest management consistent with Table 4.A (“Forest land remaining Forest land”) from the latest national GHG inventory using the year preceding the starting point of the projection. Given the use of the dynamic area approach, provide a detailed disaggregated calculation of the managed forest land area at annual time steps for the entire time series since, at least, year 2000. Document and check the Forest Land area in the FRL, including how deforestation is addressed.

e) ii    Explain more clearly the HWP pool computation methodology with respect to the fraction of biomass remaining for bioenergy use.

e) iii    Provide additional information on increments. Document the National Forest Inventory periods employed in the models and correct (see Table 2 of NFAP) the use of age class for stratification.

e) iv    In function of Annex IV, Part B (e) ii, revise historical and future harvesting rates disaggregated between energy and non-energy uses.

1)    Provide qualitative and quantitative description of forest management practices for the period 2000-2009. Demonstrate that forest management practices as documented in the period 2000-2009 are captured by the stock changes measured from 2002 to 2008, in particular those related to natural disturbances. Ensure that changes in forest management practices are not internalized in the determination of the FRL after 2009.

a)    Demonstrate how the goal of achieving a balance between anthropogenic emissions and removals will be achieved in the second half of the century. Provide qualitative and quantitative information until at least 2050 consistent with the long-term strategy required under Regulation (EU) 2018/1999.

d)    Provide FRL by assuming instantaneous oxidation of HWP.

e)    Check and correct the inconsistency about the harvest volume between the value reported at page 10, Annex I of the NFAP of Germany and the value reported in Table 6 of the NFAP of Germany.

f)    Improve the information on the consistency between the FRL and the objective of contributing to the conservation of biodiversity and sustainable use of natural resources, as set out in the EU forest strategy, national forest policies, and the EU Biodiversity Strategy.

g)    Demonstrate the consistency with the national projections of anthropogenic greenhouse gas emissions reported under Regulation (EU) No 525/2013. Provide explanations for possible differences between national projections and the proposed FRL.

h)    Estimate the FRL based on the area under forest management as indicated in Annex IV, Part B (e) i. Demonstrate the ability of the model used to construct the FRL to reproduce historical data from the national GHG inventory. Demonstrate the consistency between historical data from the national GHG inventory and modelled data for estimating the FRL for the reference period.

a)    Clearly explain how the general criteria set out by the Regulation were taken into account in the determination of the FRL.

c)    Provide information on sustainable forest management practices and intensity as used in the determination of the FRL.

e) i    Provide the area under forest management consistent with Table 4.A (“Forest land remaining Forest land”) from the latest national GHG inventory using the year preceding the starting point of the projection. Clarify how the afforestation area less than 20-year transition period is excluded from managed forest land.

e) iii    Provide information on increments and rotation lengths related to forest management activities.

1)    Noting the projected decrease in sink in the compliance period, demonstrate that the approach used in the determination of the FRL ensures the continuation of forest management practices as documented in the period 2000-2009, and revise the FRL if applicable. Clarify that those practices applies to all forest lands including those being subject to privatization. Provide detailed information on the consistency between the actual felling ages and the legally allowed felling ages.

a)    Demonstrate how the goal of achieving a balance between anthropogenic emissions and removals will be achieved in the second half of the century. Provide qualitative and quantitative information until at least 2050 consistent with the long-term strategy required under Regulation (EU) 2018/1999.

e)    Provide a ratio between solid and energy use of forest biomass as documented in the period from 2000 to 2009 used for the estimation of the forest reference level and demonstrate it remains constant throughout the projection.

f)    Provide information on how the projected increase in harvest rates is consistent with the objective of contributing to the conservation of biodiversity, in particular of old-growth forest stands.

g)    Demonstrate the consistency with the national projections of anthropogenic greenhouse gas emissions reported under Regulation (EU) No 525/2013. Provide explanations for possible differences between national projections and the proposed FRL.

h)    Estimate the FRL based on the area under forest management as indicated in Annex IV, Part B (e) i. Estimate the FRL based on carbon pools and greenhouse gases as indicated in Annex IV, Part B (b). Demonstrate the ability of the model used to construct the FRL to reproduce historical data from the national GHG inventory. Demonstrate the consistency between historical data from the national GHG inventory and modelled data for estimating the FRL for the reference period.

b)    Include the greenhouse gases consistent with those applied in the latest national GHG inventory.

e) i    Provide the area under forest management consistent with Table 4.A (“Forest land remaining Forest land”) from the latest national GHG inventory using the year preceding the starting point of the projection.

e) iii    Provide additional information on increments, dynamic age-related forest characteristics, actual management activities, harvesting rates and rotation lengths.

e) iv    Provide historical and future harvesting rates disaggregated between energy and non-energy uses. 

No recommendation

a)    Demonstrate how the goal of achieving a balance between anthropogenic emissions and removals will be achieved in the second half of the century. Provide qualitative and quantitative information until at least 2050 consistent with the long-term strategy required under Regulation (EU) 2018/1999.

c)    Provide more information on the correlation between the reduced harvest levels (i.e.<70% of net growth) and the negative biomass stock changes (Table 19 at page 51 and Table C1 at page 66, NFAP of Ireland) in the period 2020-2025. Provide more information complementing the statement about the robust accounting system (Table 1, page 4, NFAP of Ireland). Provide detailed information of the implemented accounting system, in particular in relation to biomass and instantaneous oxidation assumption, in a dedicated section.

f)    Provide information on the consistency between forest management practices and the objectives set by the European Biodiversity and Forest Strategies. Provide further information on how the biodiversity issues associated with the conversion of grasslands and wetlands into forest land are taken into account.

g)    Demonstrate the consistency with the national projections of anthropogenic greenhouse gas emissions reported under Regulation (EU) No 525/2013. Provide explanations for possible differences between national projections and the proposed FRL. 

h)    Estimate the FRL based on the area under forest management as indicated in Annex IV, Part B (e) i. Use the conversion period for Land converted to forest land (Afforested Land) consistent with the latest national GHG inventory.

b)    Noting the inclusion of additional carbon pools in the FRL, include those pools in the next submission of the national GHG inventory to ensure consistency between the FRL and the national GHG inventory.

c)    Provide a justification for a different starting year of projection than 2010. Provide information on the forest model.

d)    Provide information on harvesting rates for at least one different policy scenario.

e) i    Provide the area under forest management consistent with Table 4.A (“Forest land remaining Forest land”) from the latest national GHG inventory using the year preceding the starting point of the projection. Given the use of the dynamic area approach, provide a detailed disaggregated calculation of the managed forest land area at annual time steps for the entire time series since, at least, year 2000.

e) iii    Provide additional information on increments.

1)    Demonstrate that the approach used in the determination of the FRL ensures the continuation of forest management practices as documented in the period 2000-2009, and revise the FRL if applicable.

2)    Demonstrate how dynamic age-related forest characteristics have been taken into account and revise the FRL, if applicable.

a)    Demonstrate how the goal of achieving a balance between anthropogenic emissions and removals will be achieved in the second half of the century. Provide qualitative and quantitative information until at least 2050 consistent with the long-term strategy required under Regulation (EU) 2018/1999.

c)    Provide a justification for the harvest fraction used as biomass for energy.

d)    Revise the HWP estimates, taking into account also paper and paperboard data for 2000-2009, ensuring consistency with the national GHG inventory estimates

e)    Provide a ratio between solid (HWP) and energy use of forest biomass as documented in the period from 2000 to 2009 used for the estimation of the forest reference level and demonstrate it remains constant throughout the projection.

g)    Demonstrate the consistency with the national projections of anthropogenic greenhouse gas emissions reported under Regulation (EU) No 525/2013. Provide explanations for possible differences between national projections and the proposed FRL.

h)    Estimate the FRL based on the area under forest management as indicated in Annex IV, Part B (e) i. Demonstrate the ability of the model used to construct the FRL to reproduce historical data from the national GHG inventory. Demonstrate the consistency between historical data from the national GHG inventory and modelled data for estimating the FRL for the reference period.

b)    Include the carbon pools required by Regulation (EU) 2018/841 in the FRL and the national GHG inventory.

c)    Justify why best available Forest Management Plans data, as used in national GHG inventory, have not been used in the area assessment for FRL. Demonstrate the validity of the applied modelling framework for the estimation of the increment.

e) i    Provide the area under forest management consistent with Table 4.A (“Forest land remaining Forest land”) from the latest national GHG inventory using the year preceding the starting point of the projection. Explain and justify why the class of “other wooded Land” and “unmanaged forest” is included in the managed forest land area estimate for the FRL.

e) iii    Provide information on forest characteristics, such as increments, rotation lengths and dynamic area characteristics.

e) iv    Provide historical and future harvesting rates disaggregated between energy and non-energy uses.

No recommendation

a)    Demonstrate how the goal of achieving a balance between anthropogenic emissions and removals will be achieved in the second half of the century. Provide qualitative and quantitative information until at least 2050 consistent with the long-term strategy required under Regulation (EU) 2018/1999.

c)    Provide credible and robust evidence for the use of the model for the FRL and revise the FRL, if applicable, including a complete and transparent description of the model, a demonstration of its performance over the period 2010-2017, and an explanation on the discrepancies between projected harvest and historical data.

e)    Provide a ratio between solid (HWP) and energy use of forest biomass as documented in the period from 2000 to 2009 used for the estimation of the forest reference level and demonstrate it remains constant throughout the projection.

g)    Demonstrate the consistency with the national projections of anthropogenic greenhouse gas emissions reported under Regulation (EU) No 525/2013. Provide explanations for possible differences between national projections and the proposed FRL.

h)    Estimate the FRL based on the area under forest management as indicated in Annex IV, Part B (e) i. Demonstrate the ability of the model used to construct the FRL to reproduce historical data from the national GHG inventory. Demonstrate the consistency between historical data from the national GHG inventory and modelled data for estimating the FRL for the reference period.

a)    Correct header information in Tables 14 and 15 of the NFAP (2025 instead of 2015). Provide information if and how natural disturbances have been taken into account.

b)    Include the carbon pools required by Regulation (EU) 2018/841 in the FRL and the national GHG inventory.

c)    Provide a complete and transparent description of the FRL model including a validation during the reference period. Demonstrate how the modelled forest management approach is consistent with the forest management approach observed during the reference period. Provide a full and transparent description of the calibration process and the results. Provide more information on the National Forest Inventory such as the number of sample plots in each maturity class. Explain the unexpected behaviour of harvest early in the historic period. Review the accuracy of the input data to the projection model, in particular for the total biomass in a Eucalyptus plantation at maturity in the northern region. Describe the evolution of growth and harvest across the projected period. Provide evidence that the increase in harvest projected over the commitment period is not influenced by the projected very high harvest in the beginning of the projection period. Clarify if the model takes natural disturbances into account.

e) i    Provide the area under forest management consistent with Table 4.A (“Forest land remaining Forest land”) from the latest national GHG inventory using the year preceding the starting point of the projection.

e) ii    Provide detailed data on the evolution of HWP for the historical and the projection period and on the evolution with time of the harvest rate. Specify the half-life values used for the HWP categories.

e) iii    Provide more information on the modelled increment and harvest.

e) iv    Provide historical and future harvesting rates disaggregated between energy and non-energy uses.

1)    Demonstrate that the approach used in the determination of the FRL ensures the continuation of forest management practices as documented in the period 2000-2009, and revise the FRL if applicable. Demonstrate how dynamic age-related forest characteristics have been taken into account and revise the FRL, if applicable. Specifically, clarify why there is a discrepancy in biomass gain between model output and greenhouse gas inventory for the period 2010-2016. Describe how the model used input data and model calibration, thereby minimizing this gap.

a)    Demonstrate how the goal of achieving a balance between anthropogenic emissions and removals will be achieved in the second half of the century. Provide qualitative and quantitative information until at least 2050 consistent with the long-term strategy required under Regulation (EU) 2018/1999.

c)    Provide data from the reference period to the dataset used for the ex-post adjustment, since this has an impact on the accuracy of the FRL. As France did not use the entire reference period consistently, additional available data from the reference period to the dataset used for the ex-post adjustment should be used.

e)    Provide more detailed documentation of data source(s) used for the ratio between solid and energy use of forest biomass.

g)    Demonstrate the consistency with the national projections of anthropogenic greenhouse gas emissions reported under Regulation (EU) No 525/2013. Provide explanations for possible differences between national projections and the proposed FRL.

h)    Estimate the FRL based on the area under forest management as indicated in Annex IV, Part B (e) i. Demonstrate the ability of the model used to construct the FRL to reproduce historical data from the national GHG inventory. Demonstrate the consistency between historical data from the national GHG inventory and modelled data for estimating the FRL for the reference period.

b)    Ensure consistent modelling of carbon pools, in particular across the time series and between Metropolitan France and Overseas Territories.

c)    Provide complete data on historical and projected harvest levels. Provide more detailed description of sustainable forest management practices used in the determination of the FRL.

e) i    Provide the area under forest management consistent with Table 4.A (“Forest land remaining Forest land”) from the latest national GHG inventory using the year preceding the starting point of the projection. Given the use of the dynamic area approach, provide a detailed disaggregated calculation of the managed forest land area at annual time steps for the entire time series since, at least, year 2000. Provide more complete information regarding managed and unmanaged forest area to guarantee that the same information is used for the FRL and the national GHG inventory.

e) iii    Provide data on increments, dynamic age-characteristics and rotation length. Provide a more detailed description on the share of even and uneven-aged forests and the related information for the strata.

No recommendation

a)    Demonstrate how the goal of achieving a balance between anthropogenic emissions and removals will be achieved in the second half of the century. Provide qualitative and quantitative information until at least 2050 consistent with the long-term strategy required under Regulation (EU) 2018/1999.

g)    Demonstrate the consistency with the national projections of anthropogenic greenhouse gas emissions reported under Regulation (EU) No 525/2013. Provide explanations for possible differences between national projections and the proposed FRL.

h)    Estimate the FRL based on the area under forest management as indicated in Annex IV, Section B (e) i. Estimate the FRL based on carbon pools and greenhouse gases as indicated in Annex IV, Section B (b). Demonstrate the ability of the model used to construct the FRL to reproduce historical data from the national GHG inventory. Compare historical data from the national GHG inventory and modelled data for estimating the FRL for the reference period by using, for information only, the same harvest intensities applied in line with Article 8(4).

b)    Include the greenhouse gases consistent with those applied in the latest national GHG inventory. Include the carbon pools required by Regulation (EU) 2018/841 in the FRL and the national GHG inventory.

e) i    Provide the area under forest management consistent with Table 4.A (“Forest land remaining Forest land”) from the latest national GHG inventory using the year preceding the starting point of the projection.

e) ii    Provide a calculation of GHG emissions and removals during the reference period using harvest intensities as elaborated for the FRL estimation for a fictive no-war scenario and include this assessment in the NFAP.

e) iii    Provide complete information on age-class distribution including an aggregation for country level. Describe the "normal area" concept and its use.

e) iv    Provide detailed information on the historical and future harvesting rate disaggregated between energy and non-energy uses.

1)    Demonstrate how dynamic age-related forest characteristics have been taken into account and revise the FRL, if applicable. Specifically, demonstrate the linkage between biomass density and age-class distribution. Provide additional information on forest management practices, including rotation length and thinning intensity and demonstrate how these have been taken into account.

a)    Demonstrate how the goal of achieving a balance between anthropogenic emissions and removals will be achieved in the second half of the century. Provide qualitative and quantitative information until at least 2050 consistent with the long-term strategy required under Regulation (EU) 2018/1999.

f)    Provide additional information on existing biodiversity goals and strategies, including on protected areas and endangered endemic species.

g)    Demonstrate the consistency with the national projections of anthropogenic greenhouse gas emissions reported under Regulation (EU) No 525/2013. Provide explanations for possible differences between national projections and the proposed FRL.

h)    Estimate the FRL based on the area under forest management as indicated in Annex IV, Section B (e) i. Estimate the FRL based on carbon pools and greenhouse gases as indicated in Annex IV, Section B (b).

b)    Include the carbon pools and greenhouse gases consistent with those applied in the latest national GHG inventory.

e) i    Provide the area under forest management consistent with Table 4.A (“Forest land remaining Forest land”) from the latest national GHG inventory using the year preceding the starting point of the projection.

e) ii    Include a description of imports and exports in the HWP pool and apply changes to the FRL, if applicable. Assure consistency for carbon stock change in living biomass derived from table 6 and final FRL estimates. Correct editorial mistakes in table 7, 36 and 37 of the NFAP. Provide national totals and units in tables of NFAP.

e) iii    Provide information on age-class structure and additional information on rotation length.

1)    Demonstrate that the approach used in the determination of the FRL ensures the continuation of forest management practices as documented in the period 2000-2009, and revise the FRL if applicable. Demonstrate how dynamic age-related forest characteristics have been taken into account and revise the FRL, if applicable. Provide information justifying the use of a constant harvest rate for the reference period in the determination of the FRL.

a)    Demonstrate how the goal of achieving a balance between anthropogenic emissions and removals will be achieved in the second half of the century. Provide qualitative and quantitative information until at least 2050 consistent with the long-term strategy required under Regulation (EU) 2018/1999.

c)    Provide transparent information ensuring that emissions and removals resulting from biomass use are properly accounted for, including those related to natural disturbances.

d)    Provide differentiation of the HWP pool at the level of products’ group. Provide a comparison of the FRL between assuming instantaneous oxidation and applying the first-order decay function and half-life values.

e)    Provide a ratio between solid and energy use of forest biomass as documented in the period from 2000 to 2009 used for the estimation of the forest reference level and demonstrate it remains constant throughout the projection.

f)    Provide further explanation on how non-exploitable forests were considered in the determination of the FRL.

g)    Demonstrate the consistency with the national projections of anthropogenic greenhouse gas emissions reported under Regulation (EU) No 525/2013. Provide explanations for possible differences between national projections and the proposed FRL. 

h)    Estimate the FRL based on the area under forest management as indicated in Annex IV, Part B (e) i. Estimate the FRL based on carbon pools and greenhouse gases as indicated in Annex IV, Part B (b). Demonstrate the ability of the model used to construct the FRL to reproduce historical data from the national GHG inventory. Demonstrate the consistency between historical data from the national GHG inventory and modelled data for estimating the FRL for the reference period.

a)    Provide a description of how the criteria of the Regulation were taken into account. Provide information if and how natural disturbances have been taken into account.

b)    Include the carbon pools and greenhouse gases consistent with those applied in the latest national GHG inventory. Include the carbon pools required by Regulation (EU) 2018/841 in the FRL and the national GHG inventory.

c)    Assure that modelling starts the year after describing the state of the forest. Provide a quantitative description of sustainable forest management practices and intensity. Check and further explain the information provided for carbon stock changes for coniferous species, including harvest (pages 18-19 in the NFAP of Cyprus).

d)    Provide information on how harvest rates are expected to develop under different policy scenarios.

e) i    Provide the area under forest management consistent with Table 4.A (“Forest land remaining Forest land”) from the latest national GHG inventory using the year preceding the starting point of the projection.

e) iii    Provide information on increments, rotation lengths and dynamic age-related characteristics.

e) iv    Provide historical and future harvesting rates disaggregated between energy and non-energy uses.

1)    Demonstrate how dynamic age-related forest characteristics have been taken into account and revise the FRL, if applicable. Demonstrate that the FRL is based on the continuation of sustainable forest management practices from the reference period specifically for harvest rates. Specifically, exclude policy assumptions from the FRL calculation. Explain the change and indicate drivers for living biomass converting from a sink in the reference period to a source during the compliance period. Indicate if data outside the reference period (2000-2009) were used, and if so, provide a justification.

a)    Demonstrate how the goal of achieving a balance between anthropogenic emissions and removals will be achieved in the second half of the century. Provide qualitative and quantitative information until at least 2050 consistent with the long-term strategy required under Regulation (EU) 2018/1999.

c)    Provide a detailed description of forest management practices as documented in the reference period (2000-2009). Exclude policy assumptions from the FRL calculation and revise the FRL accordingly.

e)    Provide a ratio between solid (HWP) and energy use of forest biomass as documented in the period from 2000 to 2009 used for the estimation of the forest reference level and demonstrate it remains constant throughout the projection.

g)    Demonstrate the consistency with the national projections of anthropogenic greenhouse gas emissions reported under Regulation (EU) No 525/2013. Provide explanations for possible differences between national projections and the proposed FRL.

h)    Estimate the FRL based on the area under forest management as indicated in Annex IV, Section B (e) i. Use the conversion period for Land converted to forest land (Afforested Land) consistent with the latest national GHG inventory. Demonstrate the ability of the model used to construct the FRL to reproduce historical data from the national GHG inventory. Demonstrate the consistency between historical data from the national GHG inventory and modelled data for estimating the FRL for the reference period.

a)    Ensure consistency of values throughout the NFAP specifically between table 1 and the text, e.g. on page 6.

b)    Noting the inclusion of additional carbon pools in the FRL, include those pools in the next submission of the national GHG inventory to ensure consistency between the FRL and the national GHG inventory.

c)    Provide additional data on harvest assumptions, specifically on harvest intensity and harvest frequency. Demonstrate the exclusive use of data from the reference period for modelling the FRL.

e) i    Provide the area under forest management consistent with Table 4.A (“Forest land remaining Forest land”) from the latest national GHG inventory using the year preceding the starting point of the projection. Given the use of the dynamic area approach, provide a detailed disaggregated calculation of the managed forest land area at annual time steps for the entire time series since, at least, year 2000. Specifically, provide information on change in area for each age class using sufficiently disaggregated age-classes, e.g. 10-20 years.

e) iii    Provide detailed information on increments, age structure and harvesting rates for estimating the FRL. Exclude policy assumptions on harvests in the reference period to balance age-structure. Avoid contradictions in the NFAP such as between Figures 4 and 5 regarding reference period and harvesting rates or table 7 and Figure 4 regarding the share of harvest.

e) iv    Provide information about the future harvesting rates disaggregated between energy and non-energy uses. Provide additional information on the assumptions used to allocate round wood to each HWP category.

No recommendation

a)    Demonstrate how the goal of achieving a balance between anthropogenic emissions and removals will be achieved in the second half of the century. Provide qualitative and quantitative information until at least 2050 consistent with the long-term strategy required under Regulation (EU) 2018/1999.

c)    Clarify the discrepancies between national GHG inventory data and the projections used to set the FRL or revise the application of the model. Demonstrate that the model's outcomes can capture actual emissions and removals as reported in GHGI in both level and trend.

e)    Provide a ratio between solid and energy use of forest biomass as documented in the period from 2000 to 2009 used for the estimation of the forest reference level and demonstrate it remains constant throughout the projection.

g)    Demonstrate the consistency with the national projections of anthropogenic greenhouse gas emissions reported under Regulation (EU) No 525/2013. Provide explanations for possible differences between national projections and the proposed FRL.

h)    Estimate the FRL based on the area under forest management as indicated in Annex IV, Part B (e) i. Estimate the FRL based on carbon pools and greenhouse gases as indicated in Annex IV, Part B (b). Demonstrate the ability of the model used to construct the FRL to reproduce historical data from the national GHG inventory. Demonstrate the consistency between historical data from the national GHG inventory and modelled data for estimating the FRL for the reference period.

b)    Include the greenhouse gases consistent with those applied in the latest national GHG inventory.

c)    Address the inconsistencies in input data used in setting FRL and the national GHG inventory and provide an explanation for the differences observed in data of the NFAP and those reported in the NIR of 2018.

e) i    Provide the area under forest management consistent with Table 4.A (“Forest land remaining Forest land”) from the latest national GHG inventory using the year preceding the starting point of the projection.

e) iii    Provide more accurate information on the total increment associated with the projected FRL (both for reference and compliance period) and transparently explain how this increment is incorporated in the applied modelling approach.

Provide information on the projected harvests in the compliance period.

e) iv    Provide historical and future harvesting rates disaggregated between energy and non-energy uses.

No recommendation

a)    Demonstrate how the goal of achieving a balance between anthropogenic emissions and removals will be achieved in the second half of the century. Provide qualitative and quantitative information until at least 2050 consistent with the long-term strategy required under Regulation (EU) 2018/1999.

d)    Include the carbon pool of HWP in the FRL, and thereby provide a comparison between assuming instantaneous oxidation and applying the first-order decay function and half-life values in the NFAP.

e)    Provide a ratio between solid and energy use of forest biomass as documented in the period from 2000 to 2009 used for the estimation of the forest reference level and demonstrate it remains constant throughout the projection.

g)    Demonstrate the consistency with the national projections of anthropogenic greenhouse gas emissions reported under Regulation (EU) No 525/2013. Provide explanations for possible differences between national projections and the proposed FRL.

h)    Estimate the FRL based on the area under forest management as indicated in Annex IV, Part B (e) i. Estimate the FRL based on carbon pools and greenhouse gases as indicated in Annex IV, Part B (b). Check (and possibly correct) the sign of the FRL value, noting that in accordance with Regulation (EU) 2018/841 Art 5(1), removals (or sink, in CO2 equivalent) are denoted with a negative sign. Demonstrate the ability of the model used to construct the FRL to reproduce consistently historical data from the national GHG inventory for the reference period.

b)    Include the greenhouse gases required by Regulation (EU) 2018/841 in the FRL and the national GHG inventory. Noting the inclusion of additional carbon pools in the FRL, include those pools in the next submission of the national GHG inventory to ensure consistency between the FRL and the national GHG inventory. Provide an estimation of HWP pool, instead of the current assumption of zero. Provide further justification on the meaning and implications of "Considered with LUC" for litter and SOC on Table 2.1.

c)    Provide information on the biomass module used for the estimation of FRL, including clear descriptions of forest management practices, and demonstrate consistency with national GHG inventory.

e) i    Provide the area under forest management consistent with Table 4.A (“Forest land remaining Forest land”) from the latest national GHG inventory using the year preceding the starting point of the projection.

e) iv    Provide historical and future harvesting rates disaggregated between energy and non-energy uses.

1)    Demonstrate how dynamic age-related forest characteristics have been taken into account. Provide information on modelling of growing stock during the reference period.

a)    Demonstrate how the goal of achieving a balance between anthropogenic emissions and removals will be achieved in the second half of the century. Provide qualitative and quantitative information until at least 2050 consistent with the long-term strategy required under Regulation (EU) 2018/1999.

c)    Provide data and information on all HWP uses.

d)    Provide the FRL by assuming instantaneous oxidation of HWP.

e)    Provide a ratio between solid and energy use of forest biomass as documented in the period from 2000 to 2009 used for the estimation of the forest reference level and demonstrate it remains constant throughout the projection.

g)    Demonstrate the consistency with the national projections of anthropogenic greenhouse gas emissions reported under Regulation (EU) No 525/2013. Provide explanations for possible differences between national projections and the proposed FRL.

h)    Estimate the FRL based on the area under forest management as indicated in Annex IV, Part B (e) i. Estimate the FRL based on carbon pools and greenhouse gases as indicated in Annex IV, Part B (b). Ensure that the model used to construct the FRL is able to reproduce historical data from the national GHG inventory.

b)    Include the carbon pools consistent with those applied in the latest national GHG inventory. Noting the inclusion of additional carbon pools in the FRL, include those pools in the next submission of the national GHG inventory to ensure consistency between the FRL and the national GHG inventory.

e) i    Provide the area under forest management consistent with Table 4.A (“Forest land remaining Forest land”) from the latest national GHG inventory using the year preceding the starting point of the projection. Given the use of the dynamic area approach, provide a detailed disaggregated calculation of the managed forest land area at annual time steps for the entire time series since, at least, year 2000. Check and correct reference in Table 3 (page 21 in the NFAP of Hungary) to Table 6.5.1 in the NIR (2018 submission).

e) iii    Provide additional information on dynamic age-related forest characteristics in the projection period. Provide clarification on the repetition of pattern in annual increment by species in the reference period as reported in Table 8 (page 37 of the NFAP of Hungary). Clarify how forest management practices are distributed by yield class, and with regards to L-FL.

Note: Recommendations on Malta’s NFAP can only partly assess the FRL because Malta’s current GHG inventory does not report emissions of removals for any carbon pool. In addition, Malta’s small forest land does not undergo harvest. Therefore sub-paragraph 2 of Article 8(5), criteria (b) – (e) and (g) of Annex IV, Section A and elements (b), (d), (e) ii and (e) iv of Annex IV, Section B do not apply.

No recommendation

a)    Demonstrate how the goal of achieving a balance between anthropogenic emissions and removals will be achieved in the second half of the century. Provide qualitative and quantitative information until at least 2050 consistent with the long-term strategy required under Regulation (EU) 2018/1999.

h)    Estimate the FRL based on the area under forest management as indicated in Annex IV, Section B (e) i.

e) i    Provide the area under forest management consistent with Table 4.A (“Forest land remaining Forest land”) from the latest national GHG inventory using the year preceding the starting point of the projection. Assure consistency between forest areas reported in Tables 2 and 15 of the NFAP.

No recommendation

a)    Demonstrate how the goal of achieving a balance between anthropogenic emissions and removals will be achieved in the second half of the century. Provide qualitative and quantitative information until at least 2050 consistent with the long-term strategy required under Regulation (EU) 2018/1999.

e)    Demonstrate how harvest statistics, information from the forest inventory, the ratio between energy and solid biomass use and HWP projection were considered in elaborating the NFAP.

g)    Demonstrate the consistency with the national projections of anthropogenic greenhouse gas emissions reported under Regulation (EU) No 525/2013. Provide explanations for possible differences between national projections and the proposed FRL.

h)    Estimate the FRL based on the area under forest management as indicated in Annex IV, Section B (e) i.

c)    Provide a justification for allocating 100% of “unknown management objective” to category “multifunctional”

e) i    Provide the area under forest management consistent with Table 4.A (“Forest land remaining Forest land”) from the latest national GHG inventory using the year preceding the starting point of the projection.

e) iii    Provide additional information on age-class structure and rotation length. Correct editorial changes such as in Table 3.2.

e) iv    Provide explicit information on allocation of future harvest to specific HWP categories. Provide information on import and export of HWP.

No recommendation

a)    Demonstrate how the goal of achieving a balance between anthropogenic emissions and removals will be achieved in the second half of the century. Provide qualitative and quantitative information until at least 2050 consistent with the long-term strategy required under Regulation (EU) 2018/1999.

g)    Demonstrate the consistency with the national projections of anthropogenic greenhouse gas emissions reported under Regulation (EU) No 525/2013. Provide explanations for possible differences between national projections and the proposed FRL.

h)    Estimate the FRL based on the area under forest management as indicated in Annex IV, Part B (e) i. Demonstrate the ability of the model used to construct the FRL to reproduce historical data from the national GHG inventory. Demonstrate the consistency between historical data from the national GHG inventory and modelled data for estimating the FRL for the reference period. Noting the limited information given in the NFAP concerning the interlinked models used to develop the FRL (CALDIS-VB V0.1, YASSO and HWP models), it is recommended that Austria uses consistent models and provides additional information to demonstrate how such models are able to reproduce historical national GHG inventory data for the reference period 2000-2009.

b)    Assure consistency for the starting point of projections for all carbon pools, including the HWP pool.

d)    Provide a table on harvest intensity, for the reference period and as applied for the projection, disaggregated by forest type, growth regions or equivalent.

e) i    Provide the area under forest management consistent with Table 4.A (“Forest land remaining Forest land”) from the latest national GHG inventory using the year preceding the starting point of the projection.

e) iii    Provide additional information on rotation length.

e) iv    Provide historical and future harvesting rates disaggregated between energy and non-energy uses.

1)    Demonstrate that the approach used in the determination of the FRL ensures the continuation of forest management practices as documented in the period 2000-2009, and revise the FRL if applicable.

2)    Document the (quantitative) description of sustainable forest management practices for the period 2000-2009, detailing those parameters used as model input data, so as to demonstrate how dynamic age-related forest characteristics have been taken into account.

a)    Demonstrate how the goal of achieving a balance between anthropogenic emissions and removals will be achieved in the second half of the century. Provide qualitative and quantitative information until at least 2050 consistent with the long-term strategy required under Regulation (EU) 2018/1999.

e)    Clarify that the (constant) ratio between solid and energy use for forest biomass assumed in the modelling of the FRL is the value presented in row 1 (2000-2009) of that Table 12.

g)    Demonstrate the consistency with the national projections of anthropogenic greenhouse gas emissions reported under Regulation (EU) No 525/2013. Provide explanations for possible differences between national projections and the proposed FRL.

h)    Estimate the FRL based on the area under forest management as indicated in Annex IV, Part B (e) i. Demonstrate the consistency between the amount of harvest used as input to calculate the FRL and relevant historical data on harvest, including the reference period 2000-2009.

b)    Noting the inclusion of additional carbon pools in the FRL, include those pools in the next submission of the national GHG inventory to ensure consistency between the FRL and the national GHG inventory.

c)    Provide information on the age structure module, demonstrating age class transition from 2000 to 2020 and 2025 (e.g. in the structure of Table 15 in the NFAP).

e) i    Provide the area under forest management consistent with Table 4.A (“Forest land remaining Forest land”) from the latest national GHG inventory using the year preceding the starting point of the projection.

e) ii    Clarify that HWP is estimated based on managed forest land only, assuming that the FRL is based on managed forest land only (thereby not including afforested land). Clarify any inconsistency between the estimates of HWP in the reference period as reported in the National Inventory Report 2018, under the Convention and KP, and those used for the FRL in the NFAP.

e) iii Provide information on increments, dynamic age characteristics and rotation length. Provide information about growth curves used in NFAP based on WISL (i.e. for each strata actually considered in the model) and a reference for the bark fraction value applied for Poland and clarification what the “bark fraction” includes.

e) iv    Provide historical and future harvesting rates disaggregated between energy and non-energy uses.

1)    Demonstrate that the approach used in the determination of the FRL ensures the continuation of forest management practices as documented in the period 2000-2009, and revise the FRL if applicable. Demonstrate how dynamic age-related forest characteristics have been taken into account and revise the FRL, if applicable.

2)    If no dynamic age characteristics were used, provide evidence that such information has no impact on the FRL and long term carbon sinks will be maintained or enhanced.

a)    Given the absence of age-related characteristics in the FRL modelling, demonstrate how the goal of achieving a balance between anthropogenic emissions and removals will be achieved in the second half of the century. Provide qualitative and quantitative information until at least 2050 consistent with the long-term strategy required under Regulation (EU) 2018/1999.

c)    Provide data on harvest for solid biofuel production, and clarify how wood removals are derived from the industrial roundwood statistics and thus how all harvests are included (i.e. wood removals, solid wood and wood for bioenergy) in the estimate of carbon stock change in the FRL.

e)    Provide a ratio between solid and energy use of forest biomass as documented in the period from 2000 to 2009 used for the estimation of the forest reference level and demonstrate it remains constant throughout the projection. Evaluate whether the HWP pool needs to be recalculated (and subsequently, the FRL).

f)    Confirm the information provided showing that the reference level is consistent with the objective of contributing to the conservation of biodiversity and the sustainable use of natural resources.

g)    Demonstrate the consistency with the national projections of anthropogenic greenhouse gas emissions reported under Regulation (EU) No 525/2013. Provide explanations for possible differences between national projections and the proposed FRL.

h)    Estimate the FRL based on the area under forest management as indicated in Annex IV, Part B (e) i. Demonstrate the ability of the model used to construct the FRL to reproduce historical data from the national GHG inventory. Provide (numerical) information for the period 2010-2016 demonstrating that the modelling approach used to construct the FRL is comparable and consistent (i.e., showing justified differences) with the national GHG inventory.

c)    Explain how the requirement to consider age-class dynamic is considered in the applied approaches, methods and models, and provide explicit information on forest management practices including references to data sources and background information, used for expert judgements cited in the NFAP.

d)    Provide information on harvesting rates for at least one different policy scenario.

e) i    Provide the area under forest management consistent with Table 4.A (“Forest land remaining Forest land”) from the latest national GHG inventory using the year preceding the starting point of the projection. Given the use of the dynamic area approach, provide a detailed disaggregated calculation of the managed forest land area at annual time steps for the entire time series since, at least, year 2000.

e) ii    Clarify the estimation of HWP, the computation of GHG emissions and removals using the production approach and how double counting of harvest is avoided considering that different sources are used for estimating industrial harvest, salvage logging and information related to burned area and forest conversion.

e) iii    Provide additional information on dynamic age-characteristics and rotation length.

e) iv    Provide historical and future harvesting rates disaggregated between energy and non-energy uses.

1)    Demonstrate that the approach used in the determination of the FRL ensures the continuation of forest management practices as documented in the period 2000-2009, including private forests, and revise the FRL if applicable. Provide further information on whether the correction factor used to simulate harvest intensity is based on the continuation of forest management practices as documented in the reference period, and how this correction factor is incorporated in the determination of the FRL. Indicate if data outside the reference period (2000-2009) were used, and if so, provide a justification.

2)    Clarify whether the correction factor is introduced to reflect the need not to unduly constrain forest management intensity. Ensure that the increase in harvest volumes projected in the FRL is in line with Art 8(5), reflecting the evolution of dynamic age-related forest characteristics, and revise the FRL if applicable.

a)    Demonstrate how the goal of achieving a balance between anthropogenic emissions and removals will be achieved in the second half of the century. Provide qualitative and quantitative information until at least 2050 consistent with the long-term strategy required under Regulation (EU) 2018/1999.

c)    Ensure a robust and credible accounting system based on forest management practices documented in the reference period for all managed forest land and without the use of a correction factor.

d)    Provide a specific value for the HWP pool. Provide a comparison of the FRL between assuming instantaneous oxidation and applying the first-order decay function and half-life values.

e)    Provide a ratio between solid and energy use of forest biomass as documented in the period from 2000 to 2009 used for the estimation of the forest reference level and demonstrate it remains constant throughout the projection.

g)    Demonstrate the consistency with the national projections of anthropogenic greenhouse gas emissions reported under Regulation (EU) No 525/2013. Provide explanations for possible differences between national projections and the proposed FRL.

h)    Estimate the FRL based on the area under forest management as indicated in Annex IV, Part B (e) i. Estimate the FRL based on carbon pools and greenhouse gases as indicated in Annex IV, Part B (b). Demonstrate the ability of the model used to construct the FRL to reproduce historical data from the national GHG inventory. Demonstrate the consistency between historical data from the national GHG inventory and modelled data for estimating the FRL for the reference period. In particular, provide explanation of the trends and data about harvest levels (Table 8 in the NFAP of Slovenia) and emissions and removals (Figure 7 in the NFAP of Slovenia), and reduce discrepancies between FRL projections and national GHG inventory estimates (Figure 7 in in the NFAP of Slovenia).

a)    Provide a description of how the criteria of the Regulation were taken into account

b)    Include the greenhouse gases consistent with those applied in the latest national GHG inventory.

d)    Provide information on harvesting rates for at least one different policy scenario.

e) i    Provide the area under forest management consistent with Table 4.A (“Forest land remaining Forest land”) from the latest national GHG inventory using the year preceding the starting point of the projection.

e) ii    Provide further information on historical and future HWP outflows.

e) iii    Provide information on increments, rotation lengths and dynamic age-related characteristics. Provide further information on the use of forest management strata in the FRL, forest management practices, diameter class distribution, and harvest in privately owned forests. Check for consistency between Table 5 figures in the NFAP of Slovenia and the treatment of protected forests.

1)    Provide more detailed information on harvest rates in the compliance period. Describe more thoroughly forest management practices in a disaggregated way and in qualitative terms, describing different forest stands and forest functions.

a)    Demonstrate how the goal of achieving a balance between anthropogenic emissions and removals will be achieved in the second half of the century. Provide qualitative and quantitative information until at least 2050 consistent with the long-term strategy required under Regulation (EU) 2018/1999.

f)    Explain how biodiversity goals and in particular conservation of older forest stands are taken into account in constructing forest reference levels and past management practices. Describe how harvest levels are consistent with EU Nature & Biodiversity policies goals, in particular in National Parks, Nature Reserves, Nature 2000 sites, Sites of Community Interest, Special Protection Areas.

g)    Demonstrate the consistency with the national projections of anthropogenic greenhouse gas emissions reported under Regulation (EU) No 525/2013. Provide explanations for possible differences between national projections and the proposed FRL.

h)    Estimate the FRL based on the area under forest management as indicated in Annex IV, Part B (e) i.

b)    Include the carbon pools required by Regulation (EU) 2018/841 in the FRL and the national GHG inventory.

d)    Include information on harvesting rates for at least one different policy scenario in the revised NFAP. Translate relevant information of studies in Slovak into English.

e) i    Provide the area under forest management consistent with Table 4.A (“Forest land remaining Forest land”) from the latest national GHG inventory using the year preceding the starting point of the projection.

1)    Demonstrate that the approach used in the determination of the FRL ensures the continuation of forest management practices as documented in the period 2000-2009, and revise the FRL if applicable. Demonstrate how dynamic age-related forest characteristics have been taken into account and revise the FRL, if applicable.

2)    Provide information on forest dynamics for/by development classes and demonstrate that the increase in harvest volumes projected in the FRL is in line with Art 8(5), reflecting the evolution of dynamic age-related forest characteristics, and revise the FRL, if applicable.

a)    Demonstrate how the goal of achieving a balance between anthropogenic emissions and removals will be achieved in the second half of the century. Provide qualitative and quantitative information until at least 2050 consistent with the long-term strategy required under Regulation (EU) 2018/1999.

c)    Provide additional information to clarify how future harvests (as presented in Table 12) are related to the existing scenarios presented in Section 2.3.2 of the NFAP.

e)    Provide a ratio between solid (HWP) and energy use of forest biomass as documented in the period from 2000 to 2009 used for the estimation of the forest reference level and demonstrate it remains constant throughout the projection. Present the ratio together with information in Table 12 of the NFAP.

f)    Provide information on how the projected increase in harvest rates is consistent with the objective of contributing to the conservation of biodiversity. Clarify if the projected increase of harvest rates affects northern Finland more than southern Finland (see Table 9 of the NFAP).

g)    Demonstrate the consistency with the national projections of anthropogenic greenhouse gas emissions reported under Regulation (EU) No 525/2013. Provide explanations for possible differences between national projections and the proposed FRL.

h)    Estimate the FRL based on the area under forest management as indicated in Annex IV, Part B (e) i. Demonstrate the consistency between historical data from the national GHG inventory and modelled data for estimating the FRL for the reference period, through the provision of backcasting information from the modelling framework. Demonstrate that the interest rate used by the model can reproduce the harvest documented in the reference period.

c)    Clarify the NIR submission (year) from which data was used for the FRL calculation and the (partial, 2011 to 2016) comparison between the FRL and the national GHG inventory. Provide evidence that the actual management practices of the reference period are equivalent to those described in the Best Practices for Sustainable Forest Management guidelines (e.g. Tapio 2006). Clarify whether earlier versions of the guidelines (e.g. Tapio 2001) and the forest decree 224/1997 are relevant to describe practices in the period 2000-2009. Clarify which forest management practices are used in the model.

e) i    Provide the area under forest management consistent with Table 4.A (“Forest land remaining Forest land”) from the latest national GHG inventory using the year preceding the starting point of the projection. Provide a definition of forest and information on the total area under forest management to resolve inconsistencies in total areas in Table 3 and Table 5 of the NFAP.

e) iii    Provide information concerning: (Stand, category) development classes for time periods comparable to Table 5 (e.g. NFI9 and NFI11); Information on the standing volume per development class in the compliance period in order to relate the area to the standing volume; Documentation on the way the estimate of the interest rate was derived, including more specific references and demonstrating that it is representative for the entire forest area and the reference period; Additional information on the impact of the interest rate in the model outcomes for harvest volume by period; A clarification on the impact of assuming ‘non-declining’ industrial roundwood removals, in relation to Article 8(5) Paragraph 1 of the Regulation.

e) iv    Provide historical and future harvesting rates disaggregated between energy and non-energy uses. Provide information on harvest volume development through periods up to 2060 to improve the understanding of the long-term development, consistent with Table 14 of the NFAP.

1)    Provide transparent documentation of forest management practices in the reference period. Ensure that the approach used in the determination of the FRL reflects the continuation of sustainable forest management practices as documented in the reference period, excluding policy assumptions on harvest rates from the FRL calculation. Provide transparent information on harvest-to-growth ratio from the reference period. In light of 100% harvest rate of net biomass increment applied in the FRL on productive forest land managed for wood supply regardless of age-class distribution, explain how this is applied to modelling of the FRL and revise the FRL accordingly.

2)    Ensure that harvest volumes projected in the FRL are in line with Art 8(5), reflecting the evolution of dynamic age-related forest characteristics, and revise the FRL accordingly.

c)    Justify how the proposed FRL ensures a robust and credible accounting system in light of documented forest management practices during the reference period.

d)    Provide an explanation on the decreasing trend of HWP sink and include the projected shares of different HWP categories while harvests are increasing.

e)    Provide a ratio between solid and energy use of forest biomass as documented in the period from 2000 to 2009 used for the estimation of the forest reference level and demonstrate it remains constant throughout the projection.

f)    Provide more information on the projected development of total forest area of old forest stands (>80 years). Provide additional information on the impact of projected increased harvest on biodiversity.

g)    Demonstrate the consistency with the national projections of anthropogenic greenhouse gas emissions reported under Regulation (EU) No 525/2013. Provide explanations for possible differences between national projections and the proposed FRL.

h)    Estimate the FRL based on the area under forest management as indicated in Annex IV, Part B (e) i. Use the conversion period for Land converted to forest land (Afforested Land) consistent with the latest national GHG inventory. Demonstrate the ability of the model used to construct the FRL to reproduce historical data from the national GHG inventory. Demonstrate the consistency between historical data from the national GHG inventory and modelled data for estimating the FRL for the reference period. Specifically, information is required on 1) the validation of simulated increments for all stands and present values of increment instead of total volume, 2) the demonstration of the modelling framework to reproduce historical harvest data, 3) the bias between measurements and model estimates for mineral soils.

c)    Document sustainable forest management practices in the reference period, including information on harvesting intensities per strata, using consistent sources, definition and units, and apply those to the forest development during the simulation, and subsequently the calculation of the FRL.

e) i    Provide the area under forest management consistent with Table 4.A (“Forest land remaining Forest land”) from the latest national GHG inventory using the year preceding the starting point of the projection, and the future development of the managed forest land area, including afforested and deforested land.

e) iii    Provide information on increments, age-related dynamics and rotation length. Provide the projected increment per strata for historic data and the compliance period.

No recommendation

a)    Demonstrate how the goal of achieving a balance between anthropogenic emissions and removals will be achieved in the second half of the century. Provide qualitative and quantitative information until at least 2050 consistent with the long-term strategy required under Regulation (EU) 2018/1999.

e)    Provide a ratio between solid (HWP) and energy use of forest biomass as documented in the period from 2000 to 2009 used for the estimation of the forest reference level and demonstrate it remains constant throughout the projection.

g)    Demonstrate the consistency with the national projections of anthropogenic greenhouse gas emissions reported under Regulation (EU) No 525/2013. Provide explanations for possible differences between national projections and the proposed FRL.

h)    Estimate the FRL based on the area under forest management as indicated in Annex IV, Part B (e) i. Use the conversion period for Land converted to forest land (Afforested Land) consistent with the latest national GHG inventory. Explain the difference of approximately 2 Mt CO2 between the national GHG inventory and FRL for the reference period (Figure 4.1 in the NFAP). Demonstrate possible impacts of the different age-class structures used in the FRL and national GHG inventory in the reference period and on the trends during the years 2010-2016.

b)    Provide missing information on non-CO2 emissions from drained organic soils for the FRL, which are reported in GHG inventory.

c)    Provide more detailed information on the calculation of the background level for natural disturbances, consistent with Regulation (EU) 2018/841. 

e) i    Provide the area under forest management consistent with Table 4.A (“Forest land remaining Forest land”) from the latest national GHG inventory using the year preceding the starting point of the projection. Given the use of the dynamic area approach, provide a detailed disaggregated calculation of the managed forest land area at annual time steps for the entire time series since, at least, year 2000.

e) iii    Provide additional information on increments.

e) iv    Provide additional information on disaggregation of energy and non-energy uses for historical and future harvesting rates.