Conservation management established by the Ministry of the Environment does not ensure the preservation of the natural values of the protected forests

3/7/2023 | 11:00 AM

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TALLINN, 7 March 2023 The Environmental Board has issued cutting permits in protected areas without having identified the impact of cutting on the natural values and conservation objectives of the protected area, the audit of the National Audit Office published today reveals. The assessment of the effects of cutting is hindered by the insufficiency and ambiguity of the information gathered about protected forests and the cutting that takes place in them.

“I fully agree with the position presented by the Minister of the Environment in the summer of 2022 that there are problems with data in the environmental area and that data is valuable when it is up-to-date and when we know how to use it,” said Auditor General Janar Holm. “The problem with environmental data was confirmed already in the initial phase of the audit on protected forests in which we tried to get clarity about the accuracy of the surface areas of protected areas. During the audit, it became apparent that a simple question about the surface areas of protected areas can have many different answers, and clarifying the answers creates more confusion than it provides clarity. The area cannot be meaningfully managed without relevant and up-to-date data.”

In order to ensure conservation management, it is important to have an overview of how much forest has been cut down in protected forests. Unfortunately, this information is not gathered in the administrative area of the Ministry of the Environment

The audit also showed that the problems identified in the audit of the National Audit Office 15 years ago regarding the failure to take conservation values under protection, the preparation of management plans and the assessment of the impact of cutting in protected forests continue to be unresolved.

In the opinion of the National Audit Office, the effects of forest cutting have not been sufficiently described or evaluated neither in the protection regulations, management plans, nor in the course of national environmental monitoring. In such a situation, the Environmental Board should assess the effects of cutting separately for each cutting permit, although the combined effects of cutting across the entire protected area cannot be determined by evaluating one cutting. The information available on areas that have already been cut is a few years old and generalised information gathered about all forests is available in the form of a statistical forest inventory, which does not contain separate information about cutting protected forests. Although the Ministry of the Environment believes that this is sufficient for the organisation of forest conservation, the National Audit Office disagrees.

The National Audit Office found that the conservation regulations have been amended, permitting clear cutting also in limited management zones where it was not permitted previously. As at 2022, clear cutting was permitted in 173 of the 189 limited management zones of a protected area with forest.
 Since rotation age, cutting methods and the conditions for regeneration of the adjacent cutting area in protected forests do not differ from other forests, it is possible to clear large areas located close to one another in special conservation areas using different cutting methods, and in such places, the protected area does not fulfil its purpose. In ten cases assessed during the audit, the experts concluded that the natural values of limited management zones and special conservation areas had been damaged due to clear cutting.

The expert assessment carried out during the audit also pointed out cases where cutting permits have been issued in contravention of the conservation objectives and no significant restrictions for the protection of the species or habitat have been specified in them. The cases analysed during the expert assessment show errors, the recurrence of which is not excluded in the future in the case of the current management.

“Unfortunately, the National Audit Office established during the audit that Natura subsidy for private forest is paid for a forest located in the protected area even if the forest is no longer there,” said the Auditor General Janar Holm. “A situation where subsidies are also paid for clear-cut areas and the natural habitat does not have to be preserved is not reasonable."

In the case of cutting in protected forests, the National Audit Office recommends reorganising the forest register in such a way that the owner can and should register cutting. In addition, we recommend permitting cutting in protected forests only if the impact of cutting on natural values has been assessed before the cutting permit is approved. In protected areas, cutting should be planned taking into account the entire area, and the cumulative impact of cutting should be taken into account when granting cutting permits.


According to official data, 51% of Estonia’s forest land and 17.6% of forests are strictly protected. The National Audit Office did not get any clarification about the accuracy of the surface areas of protected areas during the audit.

Based on the definition of the Forest Act, this also includes deforested forest land that has undergone clear cutting and young growing forest. According to a study commissioned by the Ministry of the Environment, forests that are at least 100 years old account for less than half of the forests in strictly protected areas, while the biodiversity of the forest increases as the forest ages.

Protected areas are divided into protection regimes of different strictness: for example, nature reserve, special management zone (natural and maintained), limited management zone, special conservation area, species protection site. Preservation of EU forest habitats is a conservation objective in 335 protected areas.

The surface area-related goals for taking Natura habitats under protection have been met in Estonia, but of the ten protected Natura forest habitat types, the condition of two is poor, the condition of six is insufficient, and the condition of only two is good.[1] The Environmental Agency’s nature conservation yearbook states that large-scale clear cutting has the greatest impact on the decrease of forest biodiversity.

In protected areas where cutting is carried out (special conservation areas, limited management zones, maintained special management zones), cutting activities must be carried out in accordance with the rules of the Forest Act and its statutory acts and the Nature Conservation Act. The goal set by the Forest Act is to be economical in forest management, protecting the ecosystem. According to the Nature Conservation Act, cutting may be carried out in special management zones for nature conservation reasons for the purposes of formative cutting, which is a general term for all types of cutting. Clear cutting is prohibited by law in limited management zones, except in cases where conservation regulations provide for exceptions.

In June 2021, the European Commission initiated an infringement procedure against Estonia in connection with cutting and assessment of its effects in Natura areas. In February 2022, the Environmental Board temporarily suspended cutting in Natura forest habitats located in limited management zones due to infringement proceedings.

Priit Simson
Head of Communications of the National Audit Office of Estonia
+372 640 0102
+372 5615 0280
[email protected]
[email protected]


[1] Condition of habitat types 2019. Ministry of the Environment. Accessed 1 March 2022. Downloadable here:

  • Posted: 3/7/2023 11:00 AM
  • Last Update: 3/7/2023 2:09 PM
  • Last Review: 3/7/2023 2:09 PM

The cumulative impact of cutting should be taken into account when granting cutting permits.

Ireen Trummer

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