We call for a transparent and participatory reform for RNP Romsilva, aligned with the provisions of the National Forest Strategy (SNP30), in order to promote a unitary and sustainable forest management for the State forests. It is imperative for Romsilva to remain a public enterprise under the authority of the state, dedicated to the public interest of society, with a long-term vision, and not an entity guided only by immediate commercial interests.
WWF-Romania expresses its concern about the „Letter of expectation” recently launched for consultation by the Ministry of Environment, which is the nodal point of the reform of RNP Romsilva. The document, which sets out Romsilva's public service obligations, specific objectives and performance indicators, contradicts the principle that „The Forest is More Than Just Timber„. The reform must prioritise the balance between economic, social and environmental objectives, with a focus on conserving biodiversity, increasing forest resilience, ensuring fair access to resources, increasing the socio-economic contribution of the forest sector to the sustainable development of local communities and improving the system for combating illegal logging in order to strengthen a competitive economic environment.
Providing only 5 days for submitting comments is not enough time to ensure effective stakeholder participation. This simplified approach undermines the decision-making process by failing to consider all legitimate interests, without which a sustainable outcome cannot be guaranteed.
Main proposals for the RNP Romsilva reform process
(1) Establishing a participatory process to ensure the reform’s success and legitimacy
We call for compliance with Law no. 52/2003 on the transparency of decision-making in public administration and alignment of the reform with the National Forest Strategy (Objective 11.5). The imminent reform of ROMSILVA, which is underway, represents a crucial change in the management of state-owned forests, with a direct impact on the environment, local communities and the national economy.
The final target is to ensure that the state-owned enterprise under the control of the public authority is managed in the best interests of citizens and society. Given the complexity of the implications and the scale of their impact, we call for a public debate to be organised to allow the widest possible range of stakeholder expertise to be involved.
(2) Sustainable management of state forests should not be limited to commercial purposes
The main objective in this process must be to harmonize the economic, social, and environmental expectations of the society while continuously improving the state of forests, which is what we must look towards when assessing the performance of state forest management.
The „Letter of expectation” sent by the authorities raises concerns about the limitation of public service obligations[1] to the management of equine industry and the guarding of privately owned forests for which there is no management and the owner cannot be identified. Such an interpretation risks reducing the essential activities necessary for the sustainable management of state forests into mere economic activities for commercial purposes. In this context, it creates uncertainty as to the application of best close-to-nature silvicultural practices, which would become voluntary rather than mandatory. Furthermore, public enterprise administrators are being directed to focus on maximizing immediate profits, neglecting other non-financial indicators that are essential for society as a whole.
In fact, this interpretation contradicts the very vision expressed in the same „Letter of expectation”, where Romsilva's objectives are specified. In this respect, we give examples of just a few of these tasks (Chapter IV), which a private enterprise would not assume from an economic point of view in the normal course of its business: the conservation and enhancement of biodiversity through the proper management of protected natural areas; the exercise of the State's right of pre-emption on the sale of forest land; fair access to firewood and timber for the population or public actions to popularise and educate the public on the role and importance of forests.
The National Forest Strategy, developed through a transparent and participatory process over three years, clearly sets out what we want from Romania's forests, especially from state-owned forests. Unfortunately, the authorities' ‘Letter of Expectations' is not fully in line with this ‘red line' that Romania has undertaken to follow for 2030. Moreover, the arbitrary interpretation of ‘public service obligations' risks transferring these services of national interest and, above all, national security, to the ‘private sector', which will have neither the obligation nor the interest to fulfil them.
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- [1] GO . 109 /2011, Art. 2 , alin (29) – Public service obligations – a set of special duties performed by public enterprises, which a private enterprise would not assume from an economic point of view in the normal course of its activity and which are assigned to these enterprises by legal rules, in order to perform, in an organised and continuous manner, a public service within the meaning of Article 5 lit. kk) of Government Emergency Ordinance no. 57/2019 on the Administrative Code, with subsequent amendments and additions
(3) Aligning „expectations” with the National Forest Strategy
While claiming alignment with the National Forest Strategy (SNP30), the document does not summarise financial and non-financial expectations in line with this strategy. We consider that the proposed performance indicators are rather an arbitrary selection, with an emphasis on those expectations that focus on timber production or procedural obligations rather than the achievement of outcome targets.
We highlight that a number of the outcome objectives set out in SNP30, or in the new Forest Code, are not adequately reflected in the list of performance indicators that should be prioritised for state forest management.
- There are no direct mechanisms to incentivise the increased contribution of the forest sector to the sustainable socio-economic development of local communities through vertical value chains of higher processing value, relative to the forest resource consumed (Ob. 3.1, Ob. 3.2). No indicator is established to quantify/promote the contribution to the socio-economic development of local communities through the system of valorisation of wood from state forests. This lack will result in a race to maximise immediate profit, often at the expense of higher timber valorisation and cascading timber use. However, the expectation from the state forest manager is to support the strengthening of a sustainable forest bio-economy downstream of the forest.
- There is also no indicator in place to quantify the effectiveness of the mechanisms adopted for high-value added use of wood, support rural development through local wood processing, ensure competitive conditions on the timber market or minimise the impacts of timber harvesting, in line with the objectives set by the new Forest Code (Ob. 3.2, Ob. 3.3, Ob. 6.6);
- The effort of Romsilva to increase the protected area of forest ecosystems of high conservation value in the state-owned forest fund in order to implement the EU Biodiversity Strategy (Ob. 5.3) is not reflected.
- Considering the increasing frequency of disturbances, including in the context of climate change, there are no indicators reflecting actions taken to prevent and mitigate the effects of natural hazards (e.g. risk assessment mechanisms, prevention of windthrow and snow breakage – improvement of height-to-diameter ratios through silvicultural tending operations; development of infrastructure to prevent forest fires etc.) (Ob. 6.1). There are no monitoring indicators to measure the effectiveness of the system adopted to combat illegal logging at the first placing on the market level (Ob. 13.1).
There are no indicators reflecting the equitable integration of forest ecosystem restoration measures necessary to enhance biodiversity and forest resilience, as required by Regulation (EU) 2024/1991 on Nature Restoration (Ob. 6.4, Ob. 14.1).
We welcome the fact that, at last, the Romsilva reform has taken center stage in the political agenda and that the „Letter of expectation” is being revised. In our view, the ongoing discussions regarding the institutional architecture and personnel structure, should be the final step in this reform—only after depoliticisation and ensuring a competitive and transparent process for the appointment of administrators.