Comments on Art. 17 reporting procedure for forests habitats in Bulgaria
According to the information provided by the EC on https://nature-art17.eionet.europa.eu/article17/reports2012/habitat/summary/ , the overall assessment of the conservation status of the habitat has changed from U1 (2013 report) to FV (2019 report). Changes are reported regarding parameters “Specific structure and functions (incl. typical species)”, from U1 (2013) to FV (2019), and “Future prospects” from U1 (2013) to FV (2019). It is shown that change between the two reporting periods is due to improved knowledge/more accurate data and the use of different method. This is not true in reality, no improved knowledge/more accurate data is available and no adequate research/monitoring has been implemented (justifications on these considerations are provided below). Something we agree upon with the 2019 country report is that change in the conservation status between 2013 and 2019 are not due to genuine change.
For the purpose of reporting on Art. 17, a manual for determination of habitat conservation status was developed (Zingstra et al. 2009), based on the principles used by more experienced member states. The manual was used by the country for the reporting on Art. 17 in 2013. Methodologies for determination of the conservation status, developed in the manual, require usage of data from the Forest Management Plans (hereinafter referred as FMPs) in combination with data obtained by measurements in the field. This is of key importance as data in the FMPs is only approximate and provides average values, such as average age, average diameter at breast height (DBH) and density, at stand scale. However, according to the methodologies for determination of habitat conservation status in the manual, additional information is needed, such as number/ proportion of larger/ biotope trees, old-growth forest area/ proportion, dead wood quantity/ proportion, and presence of typical grass species for the habitat. As part of the Art. 17 reporting, in 2013, Bulgarian Ministry of Environment and Water (hereinafter referred as MOEW) adopted slight change of the methodologies so that the monitoring of the favourable conservation status of forest habitats regarding parameters “Structure and functions” and “future prospects“ can be entirely based on repeated measurement of relevant stand parameters in representative sample of permanent plots. The monitoring schemes were and are still published on the official MOEW webpage – http://natura2000.moew.government.bg/Home/Reports?reportType=Habitats, accessed on 03.03.2020. From 2013 to 2018 MOEW did absolutely nothing to initialize monitoring based on measurements in permanent sample plots. End of 2018, MOEW assigned the task of reporting to an external contractor. Soon after that, without performing any monitoring activities on the field, Bulgaria submitted Art. 17 report for the period 2013–2019, based mainly on subjective evaluation of few experts. The fact that the reporting under Art. 17 by Bulgaria is misleading and does not reflect the reality is being currently discussed lively in the public space.
Comments on habitat current state
The basis of the environmentally sound forest management is to achieve a balance between timber production and many other ecosystem services that forests provide, such as biodiversity conservation, soil protection, carbon sequestration, watershed and many others. This is the so-called sustainable forest management, which is perceived as a challenge nowadays because it is related to additional measures and sometimes restrictions in the traditional forest management practices. The assessment of the conservation status (hereinafter referred as CS) is based on the achievement of such a balance. The difference in the estimates in the two reports shows that in Bulgaria, in a very short period of 6 years, not only such a balance has been achieved, but even more – the final goal of achieving favourable conservation status has been met?! Changes in forest structure and functions, providing environmentally friendly silvicultural systems are employed, take 50-60 years, or more. Moreover, the reporting for this non-existent change within 5-6 years’ time is absolutely controversial to the fact that in Bulgaria there is a continuous increase in forest harvest (from 7 million cubic meters in 2013 to 8.5 million cubic meters in 2019, as a national estimate) and frequent damages from biotic and abiotic factors.
According to abovementioned manual (Zingstra et al. 2009), the first parameter, which is estimated, determining the CS under "Structure and Functions", is based on the forest cohesion and shows the degree of saturation of the areas with overstorey trees (stand density). As a matter of fact, over the last 20 years, the coppice forests in Bulgaria (more than 95% of forests in this habitat are of coppice origin) have come to the end of their rotation period and have been massively subjected to regeneration fellings. High densities are found only in the young stands, which are the result of logging. Accordingly, it is not logical to report increase of stand density in mature forests for the last six years. Additionally, change of overstorey stand density in time can only be reliably measured/evaluated in a representative sample of permanent plots which have not yet been established in Bulgaria.
Regarding the parameter "Presence of old-growth forests", indeed in 2016 with the issuance of order RD49-421/02.11.2016 by the Ministry of Agriculture and Forest, 10% of state-owned forests of each habitat in the Natura 2000 network was set aside for no management. Nevertheless, coppice forests, even in set-aside areas need decades to acquire some characteristics of old-growthness. Additionally, change of parameters defining an old-growth in time can only be reliably measured/evaluated in a representative sample of permanent plots which have not yet been established in Bulgaria.
The next parameter that cannot change in few years is "Availability of old/biotope trees”. In Bulgaria, forests are traditionally managed by regular shelterwood and stands are mostly homogeneous. With the exception of some coniferous forests, trees in almost all managed stands are of roughly equal age. Although retaining of biotope trees is now a normative obligation, under this parameter, the condition cannot change appreciably for only 5-6 years. Additionally, change of availability of old/biotope trees in time can only be reliably measured/evaluated in a representative sample of permanent plots which have not yet been established in Bulgaria.
Regarding quantity of deadwood, the situation could not change so quickly, especially in the coppice forests that predominate the habitat in question. In fact, in recent years, biotic and abiotic damages have been quite common in forests, but they mainly affect forest plantations that are not natural habitats. The volume of dead wood in natural forests accumulates over a long period of time. In Bulgaria, no national forest inventory is in place, meaning that no measurements are carried out in permanent sample plots and data on the quantities of dead wood and their temporal dynamics in forests in Natura 2000 network is missing. Only partial measurements have been made in connection with performance of other tasks (outside Natura 2000 network). The results of such measurements show that in managed forests, the amounts of dead wood are much less than the requirements for favourable CS.
Due to the coppice origin and management under regular shelterwood system, the forests in the habitat are quite susceptible to climate change (especially droughts). The main species – Quercus frainetto is being replaced by Quercus cerris and partially Carpinus orientalis, Fraxinus ornus and other secondary species. Climate change and succession are major threats on larger areas of the habitat.
One of the essential parameters for determining the habitat CS is the grass vegetation species composition. Reporting the transition from one habitat to another or the conversion of forest types to shrub communities requires a complete description of the species composition of the ground floor. This can only be done during the vegetation season and in a representative sample of permanent plots.
Conclusion
Reporting on Art. 17 regarding habitat in question, for the period 2013–2019, should not be accepted by the EC. The change in the conservation status between the two reporting periods is not due to improved knowledge/more accurate data. In reality, no improved knowledge/more accurate data is available and no adequate research/monitoring has been implemented. There are no substantial changes in the conservation status between 2013 and 2019 due to genuine change. Accordingly, we propose that CS for the habitat is not changed since 2013 reporting and the MOEW is advised to finally start evaluating the CS in a representative sample of permanent plots, to be done by the research institutions in the country. Based on our experience we estimate that at least 300 plots are needed for the habitat in question on national scale.
References:
[1] Zingstra, H. L., et al. 2009. Guidelines for assessing Favourable Conservation Status of NATURA 2000 species and habitat types in Bulgaria. Bulgarian Biodiversity Foundation, BBI/Matra project, beneficiaries Ministry of Environment and Water and State Forest Agency. ISBN: 978-954-9959-49-9.
March 06, 2020
by WWF Bulgaria
2020-03-07 18:53
WWF Bulgaria's comment on the Structure & Functions/Future prospects for the BG assessment changed the EU assessment overall.
The overall CS is now U1, reason for change is nc and T1 results in D no change.
Extract of WWF comment above has been added to the data sheet info.
Comments on Art. 17 reporting procedure for forests habitats in Bulgaria
According to the information provided by the EC on https://nature-art17.eionet.europa.eu/article17/reports2012/habitat/summary/ , the overall assessment of the conservation status of the habitat has changed from U1 (2013 report) to FV (2019 report). Changes are reported regarding parameters “Specific structure and functions (incl. typical species)”, from U1 (2013) to FV (2019), and “Future prospects” from U1 (2013) to FV (2019). It is shown that change between the two reporting periods is due to improved knowledge/more accurate data and the use of different method. This is not true in reality, no improved knowledge/more accurate data is available and no adequate research/monitoring has been implemented (justifications on these considerations are provided below). Something we agree upon with the 2019 country report is that change in the conservation status between 2013 and 2019 are not due to genuine change.
For the purpose of reporting on Art. 17, a manual for determination of habitat conservation status was developed (Zingstra et al. 2009), based on the principles used by more experienced member states. The manual was used by the country for the reporting on Art. 17 in 2013. Methodologies for determination of the conservation status, developed in the manual, require usage of data from the Forest Management Plans (hereinafter referred as FMPs) in combination with data obtained by measurements in the field. This is of key importance as data in the FMPs is only approximate and provides average values, such as average age, average diameter at breast height (DBH) and density, at stand scale. However, according to the methodologies for determination of habitat conservation status in the manual, additional information is needed, such as number/ proportion of larger/ biotope trees, old-growth forest area/ proportion, dead wood quantity/ proportion, and presence of typical grass species for the habitat. As part of the Art. 17 reporting, in 2013, Bulgarian Ministry of Environment and Water (hereinafter referred as MOEW) adopted slight change of the methodologies so that the monitoring of the favourable conservation status of forest habitats regarding parameters “Structure and functions” and “future prospects“ can be entirely based on repeated measurement of relevant stand parameters in representative sample of permanent plots. The monitoring schemes were and are still published on the official MOEW webpage – http://natura2000.moew.government.bg/Home/Reports?reportType=Habitats, accessed on 03.03.2020. From 2013 to 2018 MOEW did absolutely nothing to initialize monitoring based on measurements in permanent sample plots. End of 2018, MOEW assigned the task of reporting to an external contractor. Soon after that, without performing any monitoring activities on the field, Bulgaria submitted Art. 17 report for the period 2013–2019, based mainly on subjective evaluation of few experts. The fact that the reporting under Art. 17 by Bulgaria is misleading and does not reflect the reality is being currently discussed lively in the public space.
Comments on habitat current state
The basis of the environmentally sound forest management is to achieve a balance between timber production and many other ecosystem services that forests provide, such as biodiversity conservation, soil protection, carbon sequestration, watershed and many others. This is the so-called sustainable forest management, which is perceived as a challenge nowadays because it is related to additional measures and sometimes restrictions in the traditional forest management practices. The assessment of the conservation status (hereinafter referred as CS) is based on the achievement of such a balance. The difference in the estimates in the two reports shows that in Bulgaria, in a very short period of 6 years, not only such a balance has been achieved, but even more – the final goal of achieving favourable conservation status has been met?! Changes in forest structure and functions, providing environmentally friendly silvicultural systems are employed, take 50-60 years, or more. Moreover, the reporting for this non-existent change within 5-6 years’ time is absolutely controversial to the fact that in Bulgaria there is a continuous increase in forest harvest (from 7 million cubic meters in 2013 to 8.5 million cubic meters in 2019, as a national estimate) and frequent damages from biotic and abiotic factors.
According to abovementioned manual (Zingstra et al. 2009), the first parameter, which is estimated, determining the CS under "Structure and Functions", is based on the forest cohesion and shows the degree of saturation of the areas with overstorey trees (stand density). As a matter of fact, over the last 20 years, the coppice forests in Bulgaria (more than 95% of forests in this habitat are of coppice origin) have come to the end of their rotation period and have been massively subjected to regeneration fellings. High densities are found only in the young stands, which are the result of logging. Accordingly, it is not logical to report increase of stand density in mature forests for the last six years. Additionally, change of overstorey stand density in time can only be reliably measured/evaluated in a representative sample of permanent plots which have not yet been established in Bulgaria.
Regarding the parameter "Presence of old-growth forests", indeed in 2016 with the issuance of order RD49-421/02.11.2016 by the Ministry of Agriculture and Forest, 10% of state-owned forests of each habitat in the Natura 2000 network was set aside for no management. Nevertheless, coppice forests, even in set-aside areas need decades to acquire some characteristics of old-growthness. Additionally, change of parameters defining an old-growth in time can only be reliably measured/evaluated in a representative sample of permanent plots which have not yet been established in Bulgaria.
The next parameter that cannot change in few years is "Availability of old/biotope trees”. In Bulgaria, forests are traditionally managed by regular shelterwood and stands are mostly homogeneous. With the exception of some coniferous forests, trees in almost all managed stands are of roughly equal age. Although retaining of biotope trees is now a normative obligation, under this parameter, the condition cannot change appreciably for only 5-6 years. Additionally, change of availability of old/biotope trees in time can only be reliably measured/evaluated in a representative sample of permanent plots which have not yet been established in Bulgaria.
Regarding quantity of deadwood, the situation could not change so quickly, especially in the coppice forests that predominate the habitat in question. In fact, in recent years, biotic and abiotic damages have been quite common in forests, but they mainly affect forest plantations that are not natural habitats. The volume of dead wood in natural forests accumulates over a long period of time. In Bulgaria, no national forest inventory is in place, meaning that no measurements are carried out in permanent sample plots and data on the quantities of dead wood and their temporal dynamics in forests in Natura 2000 network is missing. Only partial measurements have been made in connection with performance of other tasks (outside Natura 2000 network). The results of such measurements show that in managed forests, the amounts of dead wood are much less than the requirements for favourable CS.
Due to the coppice origin and management under regular shelterwood system, the forests in the habitat are quite susceptible to climate change (especially droughts). The main species – Quercus frainetto is being replaced by Quercus cerris and partially Carpinus orientalis, Fraxinus ornus and other secondary species. Climate change and succession are major threats on larger areas of the habitat.
One of the essential parameters for determining the habitat CS is the grass vegetation species composition. Reporting the transition from one habitat to another or the conversion of forest types to shrub communities requires a complete description of the species composition of the ground floor. This can only be done during the vegetation season and in a representative sample of permanent plots.
Conclusion
Reporting on Art. 17 regarding habitat in question, for the period 2013–2019, should not be accepted by the EC. The change in the conservation status between the two reporting periods is not due to improved knowledge/more accurate data. In reality, no improved knowledge/more accurate data is available and no adequate research/monitoring has been implemented. There are no substantial changes in the conservation status between 2013 and 2019 due to genuine change. Accordingly, we propose that CS for the habitat is not changed since 2013 reporting and the MOEW is advised to finally start evaluating the CS in a representative sample of permanent plots, to be done by the research institutions in the country. Based on our experience we estimate that at least 300 plots are needed for the habitat in question on national scale.
References:
[1] Zingstra, H. L., et al. 2009. Guidelines for assessing Favourable Conservation Status of NATURA 2000 species and habitat types in Bulgaria. Bulgarian Biodiversity Foundation, BBI/Matra project, beneficiaries Ministry of Environment and Water and State Forest Agency. ISBN: 978-954-9959-49-9.
March 06, 2020
WWF Bulgaria's comment on the Structure & Functions/Future prospects for the BG assessment changed the EU assessment overall.
The overall CS is now U1, reason for change is nc and T1 results in D no change.
Extract of WWF comment above has been added to the data sheet info.
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