Until December 18 is the deadline for opinions on changes to the Logging Ordinance. The proposals are to facilitate entry with heavy machines for industrial logging, in contradiction to the peculiarities of the landscape in Bulgaria and the European regulations for the protection and restoration of forests. From “Green Laws“ clarify the issues and call on citizens to participate by saying “no“ of bare logging in the Bulgarian forests.
Bulgarian forests are facing the greatest danger that has faced them in the last quarter of a century. The state, under pressure from logging companies, is preparing to ease logging rules by easing the use of large machines (harvesters and forwarders). They are a mechanized technique designed for felling in the taiga and northern forests, where it is cut exclusively bare - i.e. the forest is completely removed - and reforested after logging the bare area. This contradicts the traditional forestry in Bulgaria and is not in accordance with the climate and relief in which the Bulgarian forests grow.
In mid-November, the Ministry of Agriculture and Food and the Forestry Executive Agency announced public consultations on Draft Ordinance amending and supplementing Ordinance No. 8 of 2011. on logging in forests and Draft Ordinance on amendment of Ordinance No. 5 of 2014 for construction in forest areas without changing their purpose .
The main goal of the two projects is “creating conditions for the introduction and use of mechanized forest equipment - harvesters and forwarders”. These machines are mainly intended for the northern countries, where a completely different type of forestry is practiced than the Bulgarian one, and they are mainly used on flat terrains, where bare felling is mainly carried out. The main advantage of the applied technology is productivity - more wood. Such machines were purchased by some large logging companies and state-owned enterprises in an attempt to solve the problem of labor shortages, without considering that they could not be used under the current regulatory framework. A problem that is related to the lack of training and adequate pay in the sector, not to the need for more machines for bare logging.
In order to be able to use the purchased machines and with the aim of allowing by government regulation their use in Bulgaria, the mentioned changes are also proposed to allow wider and more clearings, as well as to remove the restrictions on the size of the areas, on which can be completely removed from the forest. The new clearings will be managed as part of the forest plantations.
What do the changes provide?
It is regulated that up to 17% of the area of forest plantations can be clearings;
It is proposed to reduce the distance between clearings for temporary forest roads from the current 40 m. distance between them, 20 m., 25 m. or 30 m., allowing this distance to be further reduced when using harvesters and forwarders;
Removed the maximum size of cauldrons on gradual-cauldron cuts, which will allow to simply take 30% at once as a single cauldron.
The proposed amendments allow cutting down, under certain conditions, up to 90% of the plantation at once - if the density of the mature stand between the boilers is below 0.6 (so far 0.3) and there is a sufficient amount of strengthened undergrowth;
Increases the slope of the terrain, where schematic cuts can be applied from 25 to 30 degrees;
It is regulated that during felling, the volume of marked wood from clearings for the construction of temporary forest roads, temporary ropeways and wood warehouses should not be included when determining the intensity of felling and in the permissible amount of use for the plantation.
The requirement for a longer regeneration period for forests in the European network “Natura 2000” is abolished, changing from 30 years. on 20 years, and the period between individual forestry interventions becomes 5 years.
In the case of bare felling with subsequent afforestation, it is possible to completely cut down the tree stand, without preserving valuable tree species.
It is possible to fence off rehabilitated areas until the plantations are assembled and restrict people's access to them
Makes it possible for the marking of the trees that are cut to be dropped and only the marking of the trees that are not cut remains. This possibility is for sanitary and forced logging.
The percentage at which felling is not allowed in old-growth forests is being changed, with an exception being made for cases of damage over 30% of the plantation area, as opposed to the previous 50%
Cutting in forest protection belts is facilitated.
What can we expect if these changes are adopted?
First of all, this means the fragmentation of Bulgarian forests by extremely close clearings and roads. Increasing fragmentation is associated with increased erosion, siltation of rivers and dams, ease of poaching, destruction of the landscape, ease of entry of aggressive introducers, deterioration of health.
To get an idea of what would happen if 17% clearing and 20% logging were combined, you can see this image from Google Maps.
Bulgaria has about 3.7 million hectares of forests and 300 thousand hectares of unforested forest territories. If 17% of the forests are converted into clearings and roads, this means the loss of 600 thousand hectares of forest, or as much as five Strandzha parks or two mountains like Rila.
The biggest threats:
For oak and pine forests: For them, the amendments will allow up to 90% of the forest to be felled with two fellings within 5 years. This is practically a return to the policy of single-age plantations and a refusal to create forests with diversity in age and structure.
Exceptions: The volume of wood harvested from clearings for the construction of forest roads, ropeways and wood storage facilities does not need to be included when determining the intensity of felling and in the allowable amount of use for the plantation , means that quantities of wood will be harvested that were not discussed when approving the forestry plans and programs, were not assessed in the environmental assessment and evaluation procedures for compatibility with the objectives of “Natura 2000”. The additional yield of wood from clearings alone can reach up to 1 million cubic meters.
Not a forest, but fields for wood: Regulating that during felling in poplar, willow and acacia forests with subsequent afforestation, the entire stand can be cut down without preserving valuable tree species, will alleviate logging and afforestation, but will lead to loss of biodiversity and create “green deserts”, eliminating the possibility that these terrains will ever be populated by native tree species.
About the forest protection belts: Facilitating logging in the forest protection belts in Dobrudja will support logging, but will lead to the loss of their beneficial functions of reducing wind erosion and conserving soil moisture. This will happen against the background of the decreasing rainfall in the growing season of agricultural crops and the intensified process of desertification of the Black Sea Dobrudja.
“Natura 2000” areas remain unprotected: The proposals aim to ease the logging of forests in “Natura 2000” protected areas, equating them with commercial forests. They will lead to a reduction in the benefit of their ecosystem functions, incl. moisture-retaining and water-regulating, as well as to the loss of biological diversity. For over a decade, Bulgarian citizens have been in a water crisis. For the year 2024, more than 650 settlements were in water regime. Instead of directing forestry towards management that favors the retention of water from forests, these proposals do the exact opposite - reduce their useful functions for water.
Again no environmental procedures
And in these proposals, the practice of the Ministry of Agriculture and the Forestry Executive Agency of not subjecting to an ecological assessment and an assessment of compatibility with the goals of “Natura 2000” its drafts for the amendment of normative acts. This is a breach of the Strategic Environmental Assessment Directive, the Habitats Directive and environmental and biodiversity laws.
The adoption of these amendments will also make it impossible to achieve the objectives set by the Nature Restoration Regulation [3], namely increasing the share of forests with an uneven age structure, forest connectivity, organic carbon stocks, the forests in which local tree species predominate and of the diversity of tree species.
What can you do to stop this threat to Bulgarian forests?
From Green Laws, we appeal to everyone who loves Bulgarian forests and Bulgarian nature - now is the time for action. You can help stop this massive threat together by doing one or more of the following:
Write an opinion by December 18 and send it to the Forestry Executive Agency at [email protected] - indicating that you do not agree with the proposed amendments to Ordinance No. 8 of 2011. on forest felling and Regulation No. 5 of 2014. for construction in forest areas without changing their purpose. You can motivate it if you like with the threats of forest fragmentation, increasing erosion, silting up dams and water bodies, disrupting the landscape, opening up large bare areas, easing poaching, making it harder to control logging, making it easier for aggressive introducers, reduction of biological diversity.
Write a request to the Minister of the Environment and Waters to order to carry out the procedures for ecological assessment in accordance with the Environmental Protection Act and for assessment of compatibility with the objectives of Natura 2000 of the projects to amend Ordinance No. 8 of 2011 Mr. on forest felling and Regulation No. 5 of 2014. for construction in forest areas without changing their purpose. You can send your letter by e-mail to: [email protected].
Send a letter of protest to the Prime Minister of the Republic of Bulgaria ([email protected]) and the Minister of Agriculture and Food ([email protected]);
Write a negative opinion against the changes in the Public Consultation Portal of the Council of Ministers on the two pages where the changes to the regulations are discussed:
https://www.strategy.bg/ PublicConsultations/View.aspx?lang=bg-BG&Id=8699
https://www.strategy.bg/PublicConsultations/View .aspx?lang=bg-BG&Id=8706
5. Contact your national representative and explain to him the threat to Bulgaria's forests;
6. Talk to relatives and friends and introduce them to what the Ministry of Agriculture is preparing;
7. Write about the topic in social networks and express your disagreement with the proposed changes by marking with “tag“ The Ministry of Agriculture and the Forestry Executive Agency.