Asociația Industriei Lemnului – Prolemn a trimis o scrisoare deschisă Comisiei Europene pe tema estimărilor lipsite de fundamentare științifică ale tăierilor ilegale din România și ale pierderilor economice provocate de acestea. Scrisoarea deschisă reia și dezvoltă argumentele profesioniștilor din industria lemnului și a specialiștilor universitari și solicită Centrului Comun de Cercetare să justifice cifrele publicate în Raportul de țară pentru România. AIL-Prolemn nu neagă tăierile ilegale în România și nici impactul îngrijorător pe care îl au asupra mediului, economiei și comunităților. Intenția noastră este de a stimula dezbaterea rațională pe tema tăierilor ilegale, astfel încât să putem avea o imagine corectă a dimensiunii fenomenului și să putem să luăm măsuri eficiente pentru stoparea acestuia.
Dear Madams, Dear Sirs,
The recent Commission Staff Working Document SWD (2020) 522 final: Country Report Romania 2020 includes worrying estimates of the magnitude of illegal logging in Romania and the economic losses ensued:
Intensive illegal logging of Romanian forests is a recurrent problem, leading to a reduction of the natural carbon sink of forests, a significant loss of biodiversity, an increase in disaster risks, and an economic loss of around 6 billion EUR/year. Romanian forests and woodland have a substantial CO2 uptake, estimated at 25,444,000 tonnes (on the basis of the LULUCF Inventory), which represents 6% of the total forest and woodland CO2 uptake at EU level (JRC, 2019). Illegal logging amounted for about 20 million m3/year during the period 2013-2018, roughly the same volume of wood that is officially cut in Romania. [Commission Staff Working Document SWD (2020) 522 final: Country Report Romania 2020, p. 64. Bold emphasis in the original, italic emphasis ours]
There are no references provided for these estimates. In the course of this open letter, we will show that they completely lack warrant, and are probably hugely overestimated.
This is a matter of grave importance, given that the topic of forests and illegal logging in Romania are emotionally laden and of great interest to the public.
The general public in Romania has an extremely negative view of all wood professionals as thieves, the media publishes alarmistic reports on illegal loggings and illegal wood transports, despite the fact that the State authorities find diminishing quantities each year. The honest professionals of the wood sector are all subject to emotional and verbal abuse, which results in lack of motivation, lower work satisfaction and quality. The issue is made more important still by the appropriation of these estimates in official documents of the Romanian Government, such as the National Plan for Recovery and Resilience.
The Association of Wood Industry – Prolemn is an apolitical, non-governmental organisation of private companies in the wood processing sector, established in 2020 to promote sustainable use of wood, sourced from sustainably managed forests.
We respectfully request that the European Commission, the JRC and the reporting staff offer evidence for these estimates, or otherwise rectify the Country Report for Romania 2020 and subsequent reports.
The estimation of illegal logging in Romania is unwarranted
Concerning the estimation of illegal loggings at 20 million m3 per year, we believe it originates in the mistaken subtraction of the commercial wood harvest, reported by the National Institute of Statistics in Romania (INS) at about 18 million m3 per year, from the total wood drain measured by the National Forest Inventory (IFN) at about 38 million m3 per year during the period 2013-2018. Such differences between total drain and commercial wood are found in all European countries, but the resulting figures are not assimilated to illegal logging. This is a well-known fact.
In Romania, the 20 million m3 difference must be taken in the appropriate context. It is important to keep in mind the following:
- The IFN data refers to the total area of wooded land – almost 7 million hectares. The INS data refers to the commercial volumes, harvested from the forestry fund – recorded at 6.5 million hectares.
- The IFN data refers to the entire volume above ground of the harvest, the INS data refers only to commercial volumes (without tops, branches, stumps). The different dendrometric methods between the two measurements may yield up to 20% difference in results. When the entire harvest (INS) and total drain (IFN) are considered, a 5-7 million m3 difference is to be expected.
- The IFN data includes dead and decomposing wood between two cycles of the inventory. This volume is estimated in scientific literature to be about 1 m3 per hectare per year. Considering the total area of the Romanian forests, we arrive at almost 7 million m3 dead wood, found in situ in a very small proportion, but included in the total drain.
- From forest vegetation outside of the forestry fund (about 500,000 hectares) and from the forests of private owners with small properties, only a small fraction is harvested with an APV (act of valorification), and only this type of harvest is recorded by the INS. This yields at least 3-4 million m3 difference between the INS and IFN data.
Adding all these numbers, at least 16-18 million m3 can be readily explained as a difference in measurement and methodology.
Considering all this, we strongly believe that the assessment of illegal logging in Romania at about 20 million m3 per year is unwarranted.
The estimation of the economic losses is unwarranted
The other important number provided in the Country Report quoted at the beginning is the estimate of economic loss due to illegal logging at 6 billion EUR per year. Again, no reference is provided for the estimate, but it seems to be also overestimated by a huge margin.
The average price of the wood on stump in Romania is 35 EUR/m3. Even if we were to assume a total volume of illegally logged wood at 20 million m3 per year, the result would be 700 million EUR per year, not even close to 6 billion EUR!
In fact, the entire wood processing sector, more than 10,000 companies put together, has a yearly revenue of 6 billion EUR per year, 3.5% of the Romanian GDP [Source]. Given all the efforts from the State and private actors, as well as the strict legislation and the measures such as the SUMAL (Integrated Informational System for Monitoring Wood Material), it really is unbelievable that the illegal logging market equals the national output of the industry.
To stop illegal logging in Romania, a proper estimate of its magnitude is long overdue
When the results of the second cycle of the IFN were published in 2019, a broad consensus emerged among academics and wood professionals in Romania that the two sets of data, reported by the IFN and the INS, are incommensurable, and that the findings must be properly explained. This was the general conclusion of the debates from the 2019 edition of the Forum of the Forests, Wood Industry and Green Economy.
Unfortunately, the media and some influential voices from the general public have taken the 20-million-m3 figure at its face value, and it now has crept into official documents of the European Commission and the Romanian Government – e.g., the National Plan for Recovery and Resilience.
The Association of the Wood Industry – Prolemn has repeatedly asked for clarifications from the authorities of the figures, including most recently in an open letter to Mr. Tánczos Barna, Minister of the Environment, Waters and Forests.
In September 2020, the Association also organized a technical seminar on How to effectively implement timber legality in Romania. Challenges and prospective of the wood processing industries operating in this territory. Eight members of the EC, three MEPs and several members of the JRC attended the seminar, as well as academics, activists, forest owners’ representatives and other private bodies.
This does not mean we deny that illegal logging takes place in Romania, or that its effects on the environment, the economy and the communities aren’t indeed worrying; but until we all agree on how to assess the magnitude of the phenomenon, no appropriate measures can be taken to stop illegal logging. In fact, a huge amount of resources, both public and private, are spent each year on controls which exceed the requirements of the EUTR: checks at the first placement on the market, i.e., at the margin of the forest.
In a recent interview, Mr. Gelu Puiu, State Secretary for Forests with the Ministry of the Environment, Waters, and Forests, expressed a similar concern:
Last year, for example, 82% of the transports of wood materials in Romania were verified by the population using the Inspector of the Forests [app]. 2.2 million transports were interrogated in Romania by the population. What does this show? A fantastic interest of the general population in regards to the forests, and if we think of those that ended with the Police from the 2.2 million, it is clear there’s a huge difference that is in the public sphere as fake news.
The reality is not quite as some present it, with regards to illegal logging in Romania. It exists, we find illegal loggings, we discover between 100,000 and 200,000 m3 of illegally logged [wood] on average each year. But from this to other values and figures, there is a big difference. [English translation ours. Source.]
Conclusions
In the Country Report for Romania 2020, the estimates of illegal logging and its effects in Romania are presented without warrant or justification, and we consider them overestimated by a huge margin. This has serious deleterious effects on the public perception of the wood sector in Romania, on the quality of media reports, and the professionals working in the sector are dispirited and demotivated.
A thorough scientific debate of this topic, involving also political actors, is urgently needed in Romania, in order to obtain a proper estimate of the magnitude and effects of illegal logging.
Until then, we ask the European Commission to revise the figures presented in the Country Report for Romania on scientific grounds, and to provide references for how these were computed.
If you require more information on this topic, we remain at your disposal.
Yours sincerely,
Cătălin Tobescu
President
The Association of the Wood Industry – Prolemn