Climate Leadership Coalition (CLC) welcomes the Commission’s brief for a Regulation on a monitoring framework for resilient European forests, we view that enhancing the availability and quality of data on forests within the EU is needed. Climate change will lead to increasing stress in forest ecosystems and more frequent hazards like forest fires, pest outbreaks and droughts. This will weaken the ability of the forest ecosystems to sequester carbon from the atmosphere and to provide other ecosystem services. It is very important to have up-to-date information on the state of forests.
When introducing new regulations or incentive systems it is very important that the data is reliable, measurable and verifiable. CLC believes that such data can be produced within the EU, but the data quality is probably not sufficient in all countries at the moment. A high-quality monitoring system that covers all forests and other wooded land in the EU is the first step to address this challenge.
However, in addition to remote sensing tools, land-based measurements are needed to calibrate the remote sensing data. Land-based measurements should be based on the existing National Forest Inventory (NIF) systems. Currently, the NIF systems differ from country to country, and they should be harmonised to support technology-based monitoring with consistent land-based measurements across the EU.
We would also like to emphasize that to ensure clarity, coherence, and cost-effectiveness, the concepts and proposed indicators need to be clearly defined, in alignment with established terminology, current data collection, and reporting systems.
Feedback on the regulation:
1) In addition to remote sensing methods, the proposed framework should be built on well-established ground-based monitoring tools, such as National Forest Inventories to get comprehensive knowledge of the European forests. The National Forest Inventories should be harmonized to get comparable knowledge between different EU member states.
2) Framework to monitor natural disturbances is needed, but this is not enough to achieve resilient forests. Adequate resources should be earmarked for prediction, early detection and stock-taking for all the most common natural disturbances. Also, national forest management practices should be adjusted to support development of more resilient forests.
3) Forest data consistency and comparability both geographically as well as temporally is very important. The data mentioned in Annex 1, (forest area, forest connectivity and tree cover density etc.) is produced mainly using Earth Observation techniques and mostly on an annual basis. On the other hand, the Annex 2 data (growing stock, net annual increment, deadwood, etc…) is based mainly for member states National Forest Inventories. Furthermore, the Annex 2 data needs to be provided on national and regional (NUTS 2) level and some data for "monitoring site level". This data will be produced mostly on 5-year intervals. For the credibility of the monitoring framework, it would be essential to ensure the geographic and temporal comparability of the outputs and define the applicability of the monitoring framework. Plans to utilize the annual outputs of the monitoring framework from stand (or ‘forest unit’) level for national and European wide monitoring seems unrealistic, knowing the technological requirements of the stand level monitoring (which requires detailed information on the 3D structure of the forest, acquired typically by airborne LiDAR). It is unclear how the accuracy and comparability of the annual Earth observation-based mappings would be defined. A trustworthy accuracy assessment would require reference data from random sampling. Effective synergistic utilization of the National Forest Invetory field data in combination with the Earth Observation data should be incorporated into the framework to ensure comparability of the Annex1 and Annex 2 outputs. Limitations of the applicability of the monitoring framework (particularly in spatial context) should be further investigated and scientifically justified.
4) CLC also recommends considering the use of modern tools developed for forestry planning, such as the Tamm and Papyrus for economic modelling tools or ecophysiological models predicting growth changes under changing climate conditions.
