Example of Analysis
Calculation of Growing Stock Deficiency
Before the start of management in the next decade, and after the expiration of the old Management Basis, Croatian Forests Ltd are obliged to obtain the approval of the Ministry of Agriculture, and the consent of the Ministry of Energy and Sustainable Development (ex. Ministry of Environmental Protection) for each individual management unit that the Management Basis has been prepared in accordance with the Ecological Network Area Management Plan.
On behalf of the Ministry of Agriculture, the proposal for the new Management Basis is reviewed by a special, expert commission that issues an expert opinion and a proposal for granting approval to the Ministry of Agriculture.
Management Unit Sljeme – Medvedgradske šume
Natura 2000
Nature Park
Zagreb Forest Administration Branch
Forest Office Zagreb
The management unit “Sljeme – medvedgradske šume” is one of the three management units of the Zagreb Forest Office, which is located in the central part of the southern and southwestern side of Medvednica mountain. The validity period of the Management Basis 2008-2017 expired on December 31, 2017. Croatian Forests Ltd were obliged to prepare a new plan – Management Basis, in order to continue to manage the forests and forest lands in a legal manner, based on the prescribed works for the management half-period I / 1, ie. in the period from 1 January 2018 to 31 December 2027.
Croatian Forests Ltd are only on September 17, 2019 received a decision from the Ministry of Agriculture approving a new Management Basis, and it is evident that Croatian Forests Ltd in the period from 1 January, 2018 to 17 Semptember, 2019 managed on the basis of old, invalid Management Basis.
Therefore, in less than two years, Croatian Forests Ltd acted contrary to the positive legal regulations of the Republic of Croatia (Forest Act, Ordinance on forest management, Ordinance on remittance of trees, Law on Nature Protection, etc …).
During the preparation of the Management Basis, the total growing stock in the amount of 675,557 m3 or 288 m3 / ha was established.
Accounting control in the period from from 1 January, 2018 to 31 December, 2027 is presented in the Regulatory Record of Management Basis, with the following data:
The expert commission of the Ministry of Agriculture is trying to explain the enormous shortage of growing stock in the amount of 136,277 m3 in this management unit, determined by the forest inventory during the regular renewal of the Management Basis, by stating that, the volume was incorrectly determined during the preparation of the previous Management Basis, so, as it turns out, the initial state of growing stock from this calculation control is incorrect.
The expert commission of the Ministry, in item 4 of the Minutes, states, inter alia:
“According to the data of the previous Management Program for the economic unit” Sljeme – medvedgradske šume”, the measured state of growing stock in 2008 was 8,3% higher than expected.”
The Green Squad found that the initial balance in 2008 was higher by only 3.13%, as shown by the accounting control for the half-period 1998-2007. The difference of 5.17% that the commission conceals in this case is 42,251 m3.
We also notice that the expert commission is trying to justify the enormous shortage of growing stock by “expert conclusion” that the accounting of the share of lying trees, which is now about 1.5% of the total growing stock should have been included in the accounting control. We remark that the majority of mentioned lying trees are due to the storm that hit the area in 2013 and probably (?!) did not exist before. So, the commission goes with presumption against the established fact.
The best and most accurate indicator of the real actual situation is to express the determined growing stock per hectare for the starting year of the Management Basis and for the year of extraordinary audit. So, in 1998 it was 291 m3 / ha, in 2008 it was 312 m3 / ha, according to the extraordinary audit in 2011 it was 335 m3 / ha, according to the extraordinary audit in 2015 it was 336 m3 / ha, and according to the new Management Basis 288 m3 / ha.
It is evident that after 20 years of managing the management unit “Sljeme-medvedgradske šume”, the growing stock has decreased, and especially the frightening is decline from the 2015 audit to the current Management Basis, from 336 m3 / ha to 288 m3 /Ha!
In the management unit “Sljeme – medvedgradske šume” in the period from 1 January, 2008 to 31 December, 2017 individual types of irevenue are generated as follows:
In the main revenue, the revenue was made on 97% of the prescribed areas, and the execution according to the prescribed volume was only 66%.
We notice a large deviation in the ratio of the area shown as the area of felling and the volume of wood cut on these areas. It is questionable whether the works presented as performed on the prescribed areas were actually performed, or were not performed to the extent required by the regulations of individual sections.
The previous revenue was realized on 94.9% of the prescribed areas, and again we notice a serious deviation because the realized wood volume of only 82.2% of the prescribed felling was executed.
The incidental revenue was 51,708 m3 of growing stock and relates to calamities caused by windbreaks. The President of the Zagreb Forest Administration Branch, Damir Miškulin, reported in the media about the damage caused by the wind in the amount of 40,000 m3, which is a serious difference of 11,708 m3 in relation to the amount shown in the incidental revenue.
In total, 135,567 m3 were cut in the management unit “Sljeme – medvedgradske šume”, of which 38% (51,708 m3) was incidental revenue, which must have been, but to our knowledge has not been reviewed or approved by any decision of the inspection or the relevant Ministry.
For the Management Basis of the Sljeme – medvedgradske šume” Management Unit, Croatian Forests Ltd submitted a request for its approval even before the public inspection and public hearing, which, in addition to obtaining the Consent from the Nature Protection Act, were the basic conditions for submitting a request for approval of the Management Basis. The Management Basis was supposed to be finished for management works starting from the beginning of 2018, but it was approved only on September 17, 2019. Therefore, it is indisputable that for less than two years the management of forests and forest lands was not based on positive legal regulations of the Republic of Croatia, the Forest Act, the Nature Protection Act, the Ordinance on forest management, the Ordinance on remittance of trees, etc …
Producer of the Management Basis, Croatian Forests Ltd does not offer any explanation in its document for the catastrophic shortage of growing stock of 136, 277 m3 or 16.7% in relation to the expected growing stock.
In the analysis, we used the following documents of Croatian Forests Ltd:
1.
Request of Croatian Forests Ltd to the Ministry of Agriculture for approval of the Management Program of the management unit with the Ecological Network Area Management Plan from 21 December, 2018.
2.
Request of Croatian Forests Ltd to the Ministry of Environment and Energy for issuing approval for the draft Management Program of the management unit with the Ecological Network Area Management Plan dated 21 December 2018.
3.
Consent of the Ministry of Environmental Protection and Energy to the draft Management Program of the management unit with the Ecological Network Area Management Plan dated 17 September 2019.
4.
Decision of the Ministry of Agriculture approving the Management Program of the management unit with the Ecological Network Area Management Plan dated 17 September 2019.
5.
Minutes of the Commission of the Ministry of Agriculture on the review of the proposed Management Plan of the management unit dated 30 August 2018.
Minutes of the Commission of the Ministry of Agriculture on the review of the proposed Management Plan of the management unit dated 30 August 2018.
6.
Copy of the table of accounting control from the Regulatory records of the Management Basis for the economic unit ‘Sljeme- Medvedgradske šume’.
