Miljø- og Fødevareudvalget 2019-20
MOF Alm.del Bilag 667
Offentligt
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LETTER TO THE DANES ON THEIR PART IN THE OVERUSE OF ESTONIAN FORESTS
Minister
for
Climate,
Energy
Minister for Environment, Lea Wermelin
and
Utilities,
Dan
Jørgensen
Members of the Climate, Energy and Utilities Committee (Folketinget, the Danish Parliament)
Members of the Environment and Food Committee (Folketinget, the Danish Parliament)
The nation of Denmark
Denmark
prides
itself
over
being
among
the
climate
leaders.
However, the Danish government has not "united behind the science" on the question of
woody biomass. The European Commission's own scientific advisory body
limits sustainable
biomass use for energy
to local wood and using wood waste and residues. Denmark is the
largest buyer of wood pellets produced in Estonia. These are not local, and Graanul Invest,
the largest pellet producer in the EU, openly admits that it uses whole trees and
waste/residues in a 1:1 ratio, while the ratio itself has not been verified.
The Estonian Fund for Nature, one of the most well regarded and active Estonian
environmental NGOs has
expressed its opinion
about the supposed sustainability of the pellet
trade:
"The biomass harvest and exports from a country that is losing its carbon sink and is on the
course of decline in forest carbon stock is not sustainable in climate perspective, even if criteria
is met on forest unit level. Nor is it sustainable from the perspective of protecting biodiversity
of forests: Estonian forest bird numbers are in decline and most forest habitat types are in
unfavorable state despite the huge area covered by different existing certification schemes.
These observations apply to certification based on Chain of Custody risk assessment and that
based on a series of detailed management practices descriptions on a forest unit level alike.
Both turn a blind eye on wider problems this new industry brings to forest management in
general."
The Brussels-based sustainable forest policy organization Fern
recently described
the current
Estonian forest policy thus:
"Estonia is logging its forests at a rate that would reduce its forest sink by more than a half."
-
- referring to if the current harvesting levels were maintained over the next decade -- both the
industry's representatives and state's development plans support an even greater volume.
Estonia is, in fact, one of Europe's most intensive forest economies. As the EU Commission
has pointed out that the entire EU-s forest sector is not sustainable neither
climate-
nor
biodiversity-wise,
it follows that in Estonia these problems would be seen most intensively.
And indeed, there has been
over three years
of intense public opposition to the extant forest
policy.
It is widely agreed that the sustainable harvesting level for Estonian forests is around 8 million
cubic meters per year. The Estonian Environmental Agency estimated in 2013 that the
maximum sustainable logging volume (doubles for a climate neutral logging volume in that
equation) for Estonia is 8,4 Mm3. The Estonian forest policy frame document from 1997 states
it as 7,8 Mm3. An impact assessment ordered by the Estonian Ministry of the Environment
MOF, Alm.del - 2019-20 - Bilag 667: Henvendelse af 3/8-20 fra Estonias nyhedsmagasin 'Postimees' om overforbrug af Estonias skove
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and conducted by the Stockholm Environmental Institute Tallinn put it at 8 Mm3, this time
regarding the conservation status of Natura species in Estonia (the impact assessment was
rejected by the Ministry
as 'centered on the aims of protecting the climate and biodiversity’).
However, Estonian logging volumes over the last 10 years have been 10,7 Mm3 on the mean,
reaching 12,5 Mm3 in 2017 and 2018. This is widely regarded as a serious problem in Estonia
on various levels, starting with the locals whose life environment is changed beyond
recognition and ending with purely economic concerns which the unsustainable use of a
sustainable resource brings.
As four million cubic meters of our forest is exported for biomass yearly, and in the recent
years Denmark has been importing over 50% of our pellet produce, this makes Denmark to a
high degree complicit in the destruction of our environment. In fact, the Danish taxpayers’
money is being used to fund it, albeit indirectly, through tax exemptions rather than direct
subsidies, with the effect however being the same - a needlessly carbon and land area
intensive energy policy. We are wholly unsure whether this is really the actual wish and intent
of the majority of Danish citizens.
We urge you to reconsider any funding of woody biomass energy. Estonia is a small country
which is still suffering from its difficult political past. The political support for sustainable
forestry
is weak
due to large influence of the forest sector. The forest industry has subjected
the Ministry to regulatory capture.
Estonia would get on the path of sustainability and good public governance faster with help
from the older members of the democratic family, like Denmark. It would benefit us all.
According to the UN’s Aichi Biodiversity Target 3, also a part of the European Forest Strategy,
all incentives harmful to biodiversity should be eliminated, phased out or reformed in order to
minimize or avoid negative impacts by 2020.