Nordic forest owner organisations reaction tothe Commission proposal for a Council regulation on support for rural development by the European Agricultural Fund for Rural Development (EAFRD).
General views:
1. It is important to ensure that the rural development programs focuses on broader EU priorities and is complementary with other EU policies, and we welcome therefore the Commissions effort in this respect. The new direction for the rural development policy should be built on the Lisbon conclusions emphasising sustainable economic growth and competitiveness as well as take into consideration the Gothenburg conclusions highlighting sustainable development and protection of environment.
2. There is a need to guarantee a high level of synergy between the future rural development policy and the implementation of a coming regional and cohesion policy.
3. The guiding principles of the EU Forestry Strategy must be recognised when enhancing the contribution of forests and forestry in terms of rural development. It is stated in the EU Forestry Strategy that the rural development programmes will enable community support for the implementation of national or sub-national forest programmes or equivalent instruments in line with the objectives of rural development and that they are in accordance with the principle of subsidiarity.
4. We appreciate that forests and forestry are recognised as an integral part of rural development. As stated in the proposal, private forests play an important role in economic activity in rural areas, and it is important that their role is truly taken into account when deciding on the policies and measures promoting a balanced and sustainable rural development.
5. The role of forestry as an independent market-oriented economic activity should be respected. Any measures distorting competition or causing distortion to markets must be avoided.
6. We welcome the more efficient and coherent rural development policy with a single funding and programming framework.
7. It is important that there is enough flexibility for the Member States to define their national priorities within the national rural development policies and programmes. The proposal concerning minimum amounts for the priority axes runs counter to the subsidiarity principle and the need for the leading EU priorities to be adjusted regionally.
Specific comments by axis:
Axis 1: Improving the competitiveness of the agricultural and forestry sector
8. Forestry is a market-oriented economic activity. Any support to normal operations of commercial forestry might severely distort competition between countries, regions or owner-groups.
9. Support for enhancing the level playing field for forestry is justified, but support should not be available for market based primary forestry production.
10. Promotion of wood and wood-based products is one of the key elements to strengthen the economical viability of forestry. Therefore should development of new, innovative products and solutions be eligible for support from the rural development programmes.
11. The support for establishment and development of forest owners associations should be reinforced in the regulation. Forest owner associations are probably the most important structural mechanism to overcome the fragmentation of forest ownership in most European countries. It is mainly the co-operation through a forest owner association that enables the individual family forest owner to participate actively in the wood market and capacity building. Without the consolidation of logistics and harvesting operations, the majority of family forest owners would not have the capacity to invest in the sustainable management of their forests.
13. Support to education and training for forest owners is also essential.
14. Any forest related support should primarily be directed to the private forest owners and their associations. All forest owners, farmers and non-farmers, should have equal access to the existing support. Support for the development of public organisations or institutions should only be granted if the main task or aim of the organisation is the training of private forest owners (i.e. organisations clearly separated from state bounded regulatory and law enforcement functions).
Axis 2: Land management
15. Regarding afforestation we can not agree on supporting the establishment of fast growing, short rotation plantations. Cultivation of fast-growing species is part of a economically viable market-based activity. In addition, in most cases cultivation of fast-growing species does not fulfil the environmental requirements for enhancement of the biological diversity of forests.
16. Support to cover loss of income should be granted only if the land was used for agricultural production during the preceding years. When it comes to abandoned land, compensation should only be granted, when it can be proved that no agricultural income is derived from that particular land area.
17. Afforestation on state owned land should not be eligible for support.
18. Only voluntary agreements with forest owners should be considered. Compulsory measures, e.g. compulsory forest protection, should exclusively be funded by national funds in accordance with national legislation.
19. An independent financing instrument for compensation payments in respect of constraints imposed by Natura 2000 should be established. EU should demand national allocation of compensation payments for the Natura 2000 sites.
20. Rural development funds that are meant to support activities to enhance economic, social and ecological stability should not be used in withdrawing natural resources from their potential and sustainable use. It can not be part of the rural development scheme that public authorities can introduce legislation, e.g. in form of preservation or protection orders, to achieve a specific type of natural environment.
21. Only management measures within Natura 2000 areas carried out by farmers and forest owners/holders should be eligible for support, in terms of financing of Natura 2000 from the rural development budget.
22. Support for protecting functions of forests and their ecological stability should be based on clearly defined and targeted projects, which enhance and develop the economic activities and employment in the target area. Costs incurred and income foregone must be included in the payment to the forest owners. The management of the site should be based on a written agreement between the forest owner and appropriate authorities.
23. Land-owners should be able to produce environmental values, benefits and products to society on ordinary market conditions. Payments for these values to land-owners should not be subsidies but a price of a value/commodity produced. The important advantages are that the society in this case achieves maximum value for the funds spent and landowners become active players in the projects.
Axis 3: Diversification of the rural economy and the quality of life in rural areas
24. It is important that forest owners and managers have the possibility to participate in measures aiming at a wider rural development.