New investigation identifies unjustified "sanitary logging" as key mechanism behind destructive logging in Ukraine –
First in-depth local case study details abusive practices in two State Forestry Enterprises in the Ukrainian Carpathians
that are exporting large amounts of timber to the European Union
(KYIV / BRUSSELS / BASEL) A new investigation focussing on the role of Ukrainian forest authorities in the rapid
destruction of Ukraine's natural forests has been released today by Ukraine's Free Svydovets Group in collaboration with
a European NGO support group, comprising the Bruno Manser Fonds, Longo Maï and FERN.
86% of forests in Ukraine are state-owned and managed by State Forestry Enterprises, independent regional entities
within the State Forestry Agency of Ukraine. Two out of some 300 State Forestry Enterprises - Brusturyansky and
Yasinyansky in the Transcarpathia region of Ukraine – were chosen as case studies in order to understand the mechanism
causing the rapid and often illegal destruction of the Carpathian forests. Both State Forestry Enterprises export large
amounts of timber to the European Union, with Brusturyansky being the second largest wood exporter in Ukraine.Conflict of interest in the State Forestry Agency
The new 58-page report "Trees Cannot Scream" identifies massive failures in the management of the Carpathian forests and
criticizes systemic conflict of interest with the State Forestry Agency of Ukraine. This government agency sets not only
the rules for logging and conducts logging but it is also in charge of controlling the legality of logging operations.
"Conflict of interest in the State Forestry Agency is one of the main reasons for unsustainable and illegal logging in
Ukraine", the report concludes.
Specifically, the report criticizes that vast tracts of protection forests – which should protect against erosion and
natural disasters such as mudslides and floods – are being clear-cut. The mountainous region where Brusturiansky State
Forest Enterprise is located has repeatedly been hit by floods, 3.7% of protection forests were clear-cut between 2017
and 2019 alone. This figure exceeds the cutting rate of commercial forests in the region.Sanitary logging as a key mechanism to circumvent logging regulations
A key mechanism to circumvent the legal logging quotas is sanitary logging. In theory, such logging is intended to
prevent the spread of pests and diseases. But it is regularly abused to exceed logging regulations and to harvest timber
in plots where commercial harvesting is not foreseen. In both State Forestry Enterprises, plots of sanitary logging were
examined on the ground and found to illegally extend to healthy forest. In Brusturyansky, eight cases were examined and
all involved the cutting of healthy forest. In Yasinansky, four out of seven examined plots did not contain weak or
damaged trees despite the State Forestry Enterprise having the necessary documentation and permits for sanitary
clearcuts.
Another advantage of sanitary logging is that it can be carried out any time, irrespective of forest management plans,
is not limited in its area and can be conducted in any type of forests, except for strict nature reserves. According to
official data, 47% of the total wood harvested in Ukraine in 2019 came from sanitary logging while in the two State
Forestry Enterprises the respective figures were even higher with 65% (Yasininasnky) and 71% (Brusturiansky). The annual
amount of wood harvested in the two State Forestry Enterprises amounts to 95'000 cubic meters (Yasiniansky) and 200'000
cubic meters (Brusturyansky) most of which is spruce (Picea abies).Corruption and poor legislation as a root cause of destructive logging practices
Virgin forests – forests practically unaffected by human activity – have been protected by law in Ukraine since 2017 in
recognition of their unique natural and cultural value. Despite this ban, official documents suggest that, in 2018-2019,
about 50 hectares of virgin forest were destroyed in the Brusturyansky and Yasinyansky State Forestry Enterprises. In
the same two years, the Yasinyansky State Forestry Enterprise illegally felled more than 51 hectares of forest, ignoring
the mandatory environmental impact assessment procedure. Numerous other unsustainable forestry practices were
discovered.
One of the key drivers of the illegal and unsustainable logging by state authorities in Ukraine appears to be
corruption. Dozens of possibilities exist that allow corrupt officials to breach logging regulations, such as fraudulent
accounting practices (such as writing-off of wood that allegedly has lost its quality), abusive sub-contracting of
operations to circumvent labour laws and safety rules, false reporting of the amount of wood felled at a certain forest
plot or harvesting beyond the boundaries of the approved logging site.
The other driver is poor legislation that makes unsustainable forestry operations legal or even mandatory, while leaving
a lot of room for corruption.Call for the European Union to take action
Consumers of such illegal and unsustainable timber are often in the European Union which relies too heavily on the FSC
(Forest Stewardship Council) timber certification system, a system that fails to adequately address the shortcomings in
the Ukrainian timber sector - both the Yasinyansky and Brusturyansky State Forestry Enterprises sold their timber until
recently under the FSC label.
In 2019, the Yasinyansky and Brusturyansky State Forestry Enterprises exported about 137,000 m3 of timber to the
European Union, with customers in Hungary - and to a lesser extent Romania and Slovakia - being the main destinations.
It appears that a significant amount of the shipped timber is of illegal and / or of unsustainable origin and that the
European Timber Regulation (EUTR) fails to properly address the underlying issues.
"You might think that Yasinyansky and Brusturyansky SFEs are just bad examples. But in reality these are practices
affecting all over the country. Ukraine's forest sector needs a complete and systemic reform, including a complete
overhaul of legislation and governance,” said Yehor Hrynyk, one of the authors of the investigation and a forest expert at the Ukrainian Nature Conservation
Group.
Lukas Straumann, Director of the Bruno Manser Fonds, called for the EU Commission to condition further financial
assistance to Ukraine on a reform of the forest sector and improved environmental governance. In particular, Ukraine
should be pressured to stop the abuse of sanitary logging and Ukrainian timber shipments to the European Union should be
better monitored.
Kelsey Perlman, Forest and Climate campaigner with FERN in Brussels, said “What is happening in Ukraine is not just
appalling, it is illegal according to its own laws. This means the EU is directly implicated, because we have laws that
only allow wood that is legally obtained to be traded on the market. The Carpathians are a shared EU-Ukrainian heritage
with cultural and biological diversity we cannot afford to lose. The EU has a clear mandate to act now."