BR :r. Ares(20211337003 - 14/06/2021

 

Warsaw, 11-06-2021
MINISTER OF CLIMATE AND ENVIRONMENT
Michat Kurtyka

DLL-WWM.0730.3.2021.MW
1598497.5363451.4338970

Dear Executive Vice-President.
Dear Commissioners,

With a view to theupcoming EU Forest Strategy after 2020, I would like to draw your attention
to the following issues that are relevant for Poland. The Strategy is the subject of particular concern to
me as I am responsible for climate and environment, including supervising forestry. I do hope that my
opinion will be taken into account as I am representing a country where forests cover nearly 30% ofthe
country's area, biodiversity - mainly in forest areas - is assessed as one of the richest in Europe!,
sustainable forest management has over 100 years of tradition, and the Polish forest sector provides
many jobs.

I gladly note the need for a comprehensive approach to economic development, environment
and climate issues included in the European Green Deal. Forests and the forestry sector are key elements
in the European transformation towards circular economy, supporting rural development while
enhancing biodiversity and preventing climate change. Therefore, in the light of the European Green
Deal, forestry should play an important role not only in achieving climate and biodiversity goals, but
also in many other areas of European policy, primarily those related to green economy. The new EU
Forest Strategy after 2020, currently being developed by the European Commission, should clearly
define the potential of forests and the forest sector in achieving the European Green Deal objectives,
and in particular to use the proven effectiveness of multifunctional forestry in the context of new
challenges in Europe and across the world. At the same time this document should ensure the
continuation of multifunctional and sustainable forest management already confirmed and a holistic
approach to forests and the forestry sector.

I recognize a special role of the Forest Strategy in balancing and reconciliation of various
objectives of individual EU policies and priorities set out in other equally important EU strategies
resulting from the European Green Deal, so that the planned actions do not lead to opposite, unintended
consequences. Proposal of increasing the area of old-growth forests included in the Biodiversity
Strategy, seems to be not exactly in line with the climate goals. In Polish conditions, the capacity of
CO; absorption by forests decreases with the age of the stands. On the other hand, it is worth ensuring
an appropriate share of stands of all age classes, which is conducive to activities aimed at adaptation to
climate change and, at the same time, increases the biological diversity of forests. Introducing strict
protection in forest areas, understood as the lack of human intervention, thus abandoning protective and
sanitary measures, increases the risk of unfavourable large-area processes, also of a transboundary
nature.

! https://www.iucn.org/regions/europe/resources/country-focus/poland

It is crucial in my opinion to ensure the provisions of the new EU Forest Strategy are in line
with the principle of subsidiarity and respect the competences of EU Member States in forest
management, with particular emphasis on local biogeographical conditions and various forms of forest
ownership. Each forest complex has its own peculiarities, therefore Member States should have the right
to implement forest management mode, which is the best from the point of view of maintaining the
sustainability of healthy forests and from the point of view of previous management experience and
local conditions. The Forest Strategy should provide a flexible approach through the possibility of
applying solutions adequate to the forest conditions typical for a given complex, including through the
use ofan appropriate management method. Depending on the climatic and soil conditions, the ownership
structure, as well as historical and cultural conditions and current challenges, an individual approach to
forest management is needed. This approach is implemented in forest management planning, where the
scope of dedicated and necessary management tasks is defined for the forest area.

In Polish conditions, the foundation of multifunctional forest management are forest
management plans which take into account protective tasks, such as protection of forest biodiversity and
restoration of animal populations. The plans are drawn up and implemented systematically over the next
ten-year periods, thanks to which they allowed for an increase of forest resources by about 50% within
30 years, while increasing the area covered by various forms of nature protection and maintaining the
open-access nature of the forest.

Poland's biodiversity, as one of the richest in Europe, is mainly shaped by a relatively large
forest area, i.e. 9.1 million hectares. Thanks to the integration of nature protection, which is one ofthe
key principles of sustainable forest management in Poland, forest ecosystems are the most valuable and
most frequently represented component of all forms of nature protection. Currently, about 57,000
species occur in Poland. Nature reserves cover of 123,500 of hectares, where almost 106,000 of hectares
is located in forests. Such results were achieved thanks to the sustainable forest management conducted
in Poland for many years, which should be continued. The species richness of forest fauna in Poland is
reflected, inter alia, in the game abundance, which has remained at a very high level for several years.
Game management, by shaping the natural environment to improve the living conditions of animals,
contributes to the achievement ofthe appropriate population size ofindividual species while maintaining
the balance of the natural environment. The importance of hunting is noted in activities aimed at
minimizing the threats resulting from the spread of animal diseases, such as ASF.

Activities carried out in Poland as part of sustainable forest management also include increasing
the mitigation and adaptation potential of forests, e.g. by introducing trees to the second floor of the
forest, planting and natural regeneration. Poland expects that the EU Forest Strategy will focus both on
increasing the mitigation potential, through the use of wood as renewable raw material from sustainable
sources, and on increasing the adaptive potential of forests by enhancing forest resilience as a result of
sustainable forest management and a multifunctional approach.

Parallel to their environmental functions, forests in Poland are a source of wood - a sustainable,
renewable raw material, the production of which determines economic development without harming
the environment. Wood and its use represent an significant added value in the bioeconomy, which is an
important element of the European Green Deal. The future Forest Strategy should sanction the crucial
function of forest management and timber harvesting in terms of achieving the objectives of the circular
economy, which is one of the pillars of the European Green Deal, especially when taking into account
the significance ofthe wood sector in the European Union. Implementation ofthe EU energy and climate
goals, in particular with regard to the use of renewable energy sources, makes wood biomass the most
used raw material in renewable energy, the stable supply of which is guaranteed by sustainable forest
management.

Forestry and the timber industry contribute to the development of rural areas by providing
opportunities to maintain and create jobs, thus constituting an important element in the development of
the economy in European Union countries. Forests offer green jobs for people who not only work
directly in the field, but also people employed in the wood, pulp and paper and furniture industries. They
also provide non-wood products, such as mushrooms, berries, medicinal plants and game, which may
be an additional source of income for rural communities. Forests are also a natural place of recreation
and relaxation for society, mainly due to their beneficial effects on human physical and mental health.

Therefore, it is crucial for me as Polish Minister of Climate and Environment that the new EU
Forest Strategy ensures the continuation and strengthening of multifunctional, sustainable forest
management in Europe, in line with the definition developed within the FOREST EUROPE high-level
ministerial process, adopted by the ministers responsible for forests in Europe and by the European
Union at the Ministerial Conference in Helsinki in 1993. The new EU Forest Strategy should therefore
maintain a balance between specific forest functions serving natural and climate goals, but also green
growth and social goals. The Forest Strategy must therefore ensure each of the forest functions
enhancement, as they are all ofthe equally importance.

I would also like to draw your attention to the adopted Council Conclusions on the new Forest
Strategy. which should be taken into account during the Strategy development. The conclusions include,
inter alia, a proposal for actions to strengthen the Forest Strategy and policies related to forests, in
particular with regard to maintaining, enhancing and further promoting sustainable forest management.
They also highlisht an important role of the Standing Forestry Committee as an essential opinion-
forming forum for various policies and initiatives related to forests and forestry sector. I am convinced
that the involvement of Member States in dialogue and cooperation during the elaboration of the new
EU Forest Strategy will allow for the development of a valuable document defining the potential of
forests and the forest sector in achieving the objectives of the European Green Deal.

By presenting the above-mentioned position, hereby I confirm my readiness for further dialogue
on the shape of the future EU Forest Strategy. I would like to highlight that new, much needed solutions
should be based on experiences and achievements ofthe EU countries. Many Member States with high
forest cover, including Poland, have contributed to the preservation of the essential wealth of European
forests through long-term forest management. This wealth should continue to be used in a sustainable
manner, while respecting environmental and social goals and economic activities, thus enabling the
preservation of the forest for future generations.

Sincerely yours,

Michal Kurtyka

Minister Klimatu i $Srodowiska
Ministry of Climate and Environment
/ - digitally signed/

1. Mr. Frans Timmermans, Executive Vice-President of the European Commission
2. Mr. Janusz Wojciechowski, Commissioner for Agriculture

3. Mr. Thierry Breton, Commissioner for Internal Market

4. Ms. Kadri Simson, Commissioner for Energy

5. Mr. Virginijus Sinkevicius, Commissioner for Environment, Oceans and Fisheries