"I agree wholeheartedly with the minister of the environment's position in the summer of 2022, that there are issues with environmental data collection and that such data is valuable when it is up-to-date and we know how to use it," Auditor General Janar Holm said.

"The issue with environmental data was already apparent during the initial phase of the audit on protected forests, when we tried to get clarity about the surface area of protected sites," he said.

"During the audit, it became clear that a simple question about the surface areas can have a variety of answers and that attempts at explaining create more uncertainty than they resolve," he said.

To manage nature conservation it is important to have a precise understanding of how much forest has been removed from protected areas; however, the environment ministry does not collect this data.

In addition, the audit revealed that the issues identified by the Estonian National Audit Office (Riigikontroll) 15 years ago regarding the failure to maintain conservation values, establish management plans and evaluate the impact of logging in protected forests remain unresolved.

The impact of logging in protected forests not documented or assessed

The National Audit Office reported that impacts of forest logging have not been adequately documented or assessed for state forest protection regulations and management plans, or for the purpose of national environmental monitoring.

In these situations, the Environmental Board should consider the consequences of felling for each permit individually, notwithstanding the fact that the cumulative effect of felling across the entire protected area is not equivalent to the sum of the effects from each site evaluated separately.

The available information on previously logged areas is several years old, while statistical forest inventory of Estonian forests does not include separate information on protected areas. National Audit Office disagreed with the ministry of environment's assessment that this approach is adequate for forest conservation management purposes.

Large scale clear cutting in protected forests allowed in adjacent locations

Moreover, the National Audit Office discovered that conservation standards had been changed to allow clear cutting in "limited management zones," which had previously been prohibited.

In 2022, 173 out of 189 application for clear cutting in limited management zones had been approved.

On the grounds that such broad metrics as rotation age, cutting methods, and regeneration conditions do not differ between protected and unprotected forests, the decision has been made to allow clear cutting of large areas within "special conservation sites" that are adjacent to one another (with the requirement of using different cutting methods). The protected area no longer serves its intended purpose in such circumstances.

In addition, the investigation uncovered instances in which cutting licenses were issued in violation of conservation goals and without specifying guidelines for the protection of the species or habitat.

It is hard to rule out a re-occurrence of these errors with the current management strategy, the report stated.

"Unfortunately, the National Audit Office's examination revealed that Natura subsidies for private woods located in protected areas were paid out even when the forests no longer existed," Holm said. "It is unreasonable to give subsidies for clear-cut sites where the natural environment does not have to be conserved."

In the case of logging in protected forests, the National Audit Office recommends reorganizing the forest registry so that the landowner must document it.

Furthermore, the report suggested that felling in protected forests should be permitted only if the impact of cutting on natural values has been assessed prior to the issuance of a felling license. Logging activity must be planned with the entire area in mind and the cumulative impact of felling must be considered when issuing licenses.

Background

According to official data, 51 percent of Estonia's forest land and 17.6 percent of its forests are strictly protected. During the audit, the National Audit Office gained no clarification whether the stipulated surface areas of nature reserves were correct.

According to the Forest Act, this area includes deforested land that has undergone clear cutting, as well as young growing forest. A study commissioned for by the ministry of the environment found that less than half of the forests in strictly protected areas are over 100 years old, even though the number of species in a forest grows as it ages.

Protected areas include nature reserves, special management zones, limited management zones, special conservation and species protection sites.

Although the surface area-based targets for protecting Natura habitats in Estonia have been met, two of the 10 protected Natura forest habitat types are in poor condition, six are insufficient, and only two are in good condition.

According to the Environment Agency's yearly report on nature conservation, large-scale clear cutting has the greatest impact on the reduction of forest biodiversity.

Cutting activities in protected areas (special conservation cites, limited management zones, and maintained special management zones) must comply with the Forest Act, its statutory acts, and the Nature Conservation Act. Clear cutting is prohibited by law in limited management zones, except in cases where conservation regulations provide for exceptions.

The European Commission began an infringement case against Estonia in June 2021 in relation to cutting and the assessment of its consequences in Natura areas.

In February 2022, as a result of infringement proceedings, the Environmental Board temporarily suspended logging in Natura forest habitats located in limited management zones.

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