A year ago, International charitable organization “Environment-People-Law” wrote about a new scheme of legal felling of protected forests – forest regeneration felling.
Unfortunately, the leadership of the State Agency of Forest Resources of Ukraine has not made any conclusions regarding the situation around sanitary felling and instead of making order with forest regeneration felling it pretends that there is no problem.
What is forest regeneration felling?
According to the “Rules for improving the qualitative composition of forests”, forest regeneration felling is complex felling that combines the elements of final felling and regeneration felling for restoration of general protective, water protective and other useful features of forests, biodiversity preservation, maintenance and formation of complex tiered and age structure of forest stands.
Such felling is carried out in ripe and old-growth uneven-aged multi-tiered forest stands and stands of a simple structure for the restoration of valuable tree species in forests where final felling is prohibited. These are protective, recreational, nature protection forests.
Such felling is authorized by forest evaluators, based on forest management materials.
If sanitary felling is carried out in accordance with the Resolution of the Cabinet of Ministers of Ukraine “On Approval of Sanitary Rules in the Forests of Ukraine”, according to the response provided by the State Agency of Forest Resources of Ukraine to People’s Deputy Ostap Yednak, the only document that regulates forest regeneration felling is the instruction letter from the State Agency of Forest Resources of Ukraine dated 2011.
The instruction letter from the State Agency of Forest Resources of Ukraine regarding forest regeneration felling
The lack of clear rules for appointing and conducting forest regeneration felling leaves abundant opportunities for abuse.
“Ukrainian style of forest regeneration“
According to the register of forest felling tickets from the site of the State Agency of Forest Resources of Ukraine , in 2017 forest regeneration felling was carried out in the Volyn region (1 forestry), Zhytomyr region (2), Cherkassy (1), Kherson (1), Odesa (1), Poltava (1), Zakarpattia (4), Lviv (6), Rivne (3), Sumy (3), Ternopil (4), Chernihiv (1), Khmelnytsky (1), Kirovohrad (6), Chernivtsi (6). In Ivano-Frankivsk region, all 15 forestry enterprises of the region carry out forest regeneration felling.
Analysis by EPL’s team of openly available materials and answers from forestry companies revealed the following features of conducting forest regeneration felling:
1) Forest regeneration felling is carried out on the basis of annual materials of continuous forest management, which are approved by the Ministry of Environment and Natural Resources of Ukraine.
2) Forestries in the plain part of Ukraine carry out forest regeneration felling mainly for low value artificial (acacia, poplar, etc.) forests.
3) Forest-regeneration felling in the Carpathian region is de facto hidden final felling and hidden continuous sanitary felling.
For example, the state enterprise “Gryniavske forest company” of Ivano-Frankivsk region receives more wood from forest regeneration felling than from the final felling! This year most of forest regeneration felling in Gryniavskyi forestry is continuous felling of low density fir trees in protective forest. Their density was preliminary reduced either by the first stage of forest regeneration felling or by conducting selective sanitary
The list of land lots where forest regeneration felling were conducted in Gryniavske foresty company
The same situation is in the state enterprise “Tiachivskyi forestry” in Zakarpattia region
The list of forest regeneration logging in the state company “Tiachivskyi forestry” by taxation characteristics
It is clear that clear felling in protective forests contradicts the very idea of protective forests, particularly regarding the Carpathian mountains.
The state enterprise “Bolekhiv forestry” conducts forest regeneration felling also in natural old-growth beech forests that can exist and perform their nature protection and recreational functions without any human interference.
The list of forest regeneration felling of the state enterprise “Bolekhiv forestry”
The wood production function of forest regeneration felling is proved by the amounts of wood produced. In the previous years, enterprises of Ivano-Frankivsk regional administration of forestry and hunting produced 10% of all amount of wood as result of forest regeneration felling.
Preliminary analysis performed by EPL environmental scientists makes us think that this year the number will be no smaller.
The list of forest regeneration felling by the state enterprise “Vyhodske forestry”
We remind that forest-regeneration felling is allowed only in those forests where final felling is prohibited. That is, it is allowed only in the most valuable forests that are under special protection and which are not intended for the commercial harvesting of wood in them.
Therefore, we have to state that initially good idea of forest regeneration felling unfortunately in Ukrainian turned into another scheme of legal commercial forest felling in non-industrial forests. And this is inadmissible.
What is to be done?
According to EPL, the root cause of this problem is the lack of state funding for the forest industry. Forestry enterprises self-finance their functioning and their income is directly proportional to the amount of wood sold. In the Carpathians where non-industrial forests can form the majority of the territory of a forestry, forest-regeneration felling is one of the legal opportunities to increase the amount of felling and, accordingly, the income of enterprises.
Nevertheless, EPL believes that this is not a reason to massively cut valuable forests that perform environmental, water protection, protective and recreational functions!
The State Agency of Forest Resources and its subordinate enterprises, instead of seeking new “schemes” of legalization of forest felling, should initiate a national discussion of the possibility to ensure state funding for the forest industry.
In many highly developed countries of the world it is generally recognized that ecosystem services of forests generate much more funding than the sale of wood. For example, the US forestry sector receives about $ 6 billion of budget funding every year while only a minimal estimate of the cost of ecosystem services provided by the state forests gives 16 times higher number, 96.5 billion dollars!
Meanwhile, in order to solve the problem of forest felling, the management of the State Agency of Forest Resources should initiate the development and approval of the rules of conducting forest regeneration felling, as it is done for other types of felling. Until such rules are approved, the amount of forest regeneration felling should be limited and conducted only after inspection by the commission with the participation of representatives of regional state administrations. Otherwise, we will have the same situation we had with sanitary felling that are discredited so much that they cannot be carried out in a timely manner even in those places where they are expedient!
For further information please contact:
Petro Testov, EPL environmental scientist
email: firstname.lastname@example.org, email@example.com