Monitoring Trees Outside Forests in the EU

Policy Briefing #15 (v4) shows that Trees outside Forests (ToF) are greatly under-reported in EU and FAO statistics, and regrets that they were not mentioned in the EU Forest Monitoring Regulation (FMR).  ToF comprises 20-30% of tree-cover in the EU, and there is a need for consistent reporting of areas of copses, hedges, lines of trees and isolated trees in inventories of EU tree, timber and energy resources, and for integrated reporting of Greenhouse Gas emissions from the land sector as a whole (i.e. “Agriculture, Forestry and Other Land Use”).   This requires clear  national forest definitions and reliable rural-cadastres, to distinguish forest land from agricultural land.  It does not require a unified definition of "forest" to be applied across Europe.   Insistence in the draft Forest Monitoring Regulation on this single definition ignores the existing Forest Laws of most Member States, and the thresholds provided to the UNFCCC Secretariat. It also neglects the flexibility negotiated in the UNFCCC 2001 Marrakesh Accords.  Forcing MS to have a single definition will hinder accurate GHG reporting by creating confusion on the boundary between forestry and agriculture.  It also contradicts the existing EU acquis - expressed in Annex II of the LULUCF Regulation (2018/841). The FMR should therefore be amended to refer to forest definition in the 2018 LULUCF Regulation.