The Białowieża Forest was inscribed on the UNESCO World Heritage List already in 1979, and again, at the joint request of Poland and Belarus in 2014, based on new criteria. The name of the property has also changed (to the Białowieża Forest) and the surface of the protected area has increased to approx. 142 thousand hectares. As a consequence, nearly 73% of the area of three forest districts located in the Białowieża Forest (Białowieża, Browsk and Hajnówka) were excluded from economic activities.
The integrated management plan, which Poland undertook to adopt at the time, regulates all activities at the UNESCO World Heritage site, giving priority to the protection of its "universal value". The fact that Poland has not yet adopted this document means that the draft forest management plans for 2022-2031, which have not been adopted for any of these three forest districts, may be inconsistent with the said integrated management plan. In order to prevent this, NIK filed a request to the Minister of Climate and Environment to take action to ensure consistency of national and international regulations, which Poland declared to comply with.
The most important legal acts regulating the principles of forest management in the Białowieża Forest:
- PUL - forest management plan prepared for 10 years,
- PZO - plan of conservation tasks of the Natura 2000 site. In the case of the Białowieża Forest, it covers approx. 96% of the area of three forest districts: Białowieża, Browsk and Hajnówka,
- UNESCO World Heritage Site. Following the changes in 2014, it covers approx. 73% of the area of three forest districts: Białowieża, Browsk and Hajnówka,
- Decision No. 52 of the Director General of the State Forests of 2016 on detailed rules of forest management within the territorial range of the Białowieża and Browsk Forest Districts,
- Birds Directive 2009/147/EC of the European Parliament and of the Council of 30 November 2009 on the conservation of wild birds,
- Council Environmental Directive 92/43/EEC of 21 May 1992 on the conservation of natural habitats and of wild fauna and flora.
Problem with obeying restrictions
The forests in the Polish part of the Białowieża Forest are managed by the Białowieża National Park (BNP) and the State Forests. Forest management is not carried out in the Park, and outside the Park it is determined by the Forest Act and forest management plans (PUL) developed for 10 years. Due to the unique character of the Białowieża Forest and its natural values, forest management in this area must also take into account the protection of these values. This is governed by national, EU and other regulations related to inscribing the Białowieża Forest on the UNESCO World Heritage List.
A shift in the approach to forest management in the Białowieża Forest was made in 2016. The then Minister of Environment decided to increase the scope of activities carried out in this area, saying they were essential to fight – as he claimed – an unprecedented growth in the population of the European spruce bark beetle. In a ruling of April 2018, the Court of Justice of the European Union (CJEU) stated that logging in the Forest violated the Habitats and Birds Directives, which Poland had declared to observe. The ruling confirms that not only may trees not be cut down there, but also dead trees may not be removed. According to naturalists, they are important for the protection of unique species and natural processes.
Forest management
In the period covered by the NIK audit (from January 2018 to the end of September 2021), forest management in the Białowieża Forest was significantly limited. As a result of the overlapping of various nature protection regimes, some of the areas designated in November 2015 by PZO for economic activities were excluded from them since 23 June 2014 in the light of obligations towards UNESCO. In total, the legal acts governing the rules of forest management in this area eliminated almost 97% of the area of the Białowieża Forest District, over 62% of the Browsk Forest District and over 68% of the Hajnówka Forest District. None of them had analyses at their disposal concerning the impact of these restrictions on forest management.
From 1 January 2012 to 30 September 2021, revenues from the sale of timber in these three forest districts exceeded PLN 86 million, of which as much as approx. PLN 26 million (over 30%) only in 2017. That was the result of the decision of the then Minister of Environment to carry out the so-called sanitation felling related to the fight against the spread of the European spruce bark beetle and the issuance of Decision No. 51 allowing wood to be harvested in tree stands regardless of their age. It was adopted contrary to the plan of conservation tasks of the Natura 2000 site (taking into account the EU Habitats Directive), which prohibited forest management in tree stands over 100 years old.
In total, over 1.9 million m³ of spruce wood colonised by the European spruce bark beetle was designated for felling in the entire audited period, but the forest districts obtained only about 300 thousand m³, which is a bit more than 15%. In the Białowieża Forest, there is over 1.6 million m³ of spruce wood inhabited by the bark beetle with an estimated value of approx. PLN 206.5 million. The main reason for this was the exhaustion of limits on the amount of timber to be harvested in the PUL for the years 2012–2021, but also the bans on forest management in tree stands over 100 years old and in UNESCO active protection zones 1 and 2.
In connection with the sanitation tree felling carried out in the Forest, the then Minister of Environment received 16 complaints, 13 of which demanded that it be suspended. There were also three proposals to expand logging. They said the PUL needed to be adjusted in terms of timber harvesting because it was essential to improve public safety and fire protection. They also said the use of renewable goods, i.e. the sale of firewood, should be enabled.
After 2017, due to the use of the planned timber harvest limits and the CJEU ruling, the three audited forest districts either did not receive any revenues from the sale of timber or these revenues were negligible. In total, they amounted to an average of nearly PLN 1.8 million in each of the four audited years (until 30 September 2021), while in the years 2012–2017 they exceeded PLN 13 million. It needs to be added that in the entire analysed period, forest districts also incurred costs related to forest cultivation and protection, including fire-fighting. They reached almost PLN 26 million, more than half of which was spent by the end of 2017.
According to the NIK audit, in the period from 1 July 2018 to 28 February 2022, the ministers responsible for the environment did not control forest management in the Białowieża Forest. It was also not verified whether the management procedures carried out complied with the requirements of the Habitats and Birds Directives. The basis for the supervision of forest management was the information contained in the PUL of the Hajnówka, Browsk and Białowieża Forest Districts.
Key recommendations:
To the Minister of Climate and Environment to:
- take measures to ensure consistency of domestic law with the international obligations adopted by the Republic of Poland related to the environmental protection in the Białowieża Forest;
- ensure the development of documents specifying the principles of forest management in the Białowieża Forest;
- introduce adequate and effective control mechanisms in the process of verifying documents governing the scope and principles of forest management submitted for approval before their approval;
- issue guidelines governing the principles of forest management until the approval of forest management plans for the years 2022-2031.
To the Director General of the State Forests to:
- ensure compliance with the methodology of the State Environmental Monitoring of inventories and environmental expertise prepared for the purpose of amending plans of conservation tasks of Natura 2000 areas.
