Interpellations Authorities: Deforestation in the Snagov Forest Reserve
Illegal logging must not go unpunished. By understanding the laws that protect forests and the institutions that are obliged to ensure their observance, each of us can act and contribute to protecting the environment – for us and for our children.
Snagov Forest Reserve
In the second decade of April I went to Ilfov County, on which occasion I visited the Snagov Forest, where I found numerous tree fellings (ANNEX 1), although part of this forest is a protected area of national interest.
According to an exploitation permit issued by the Snagov Forest District, the cuts in the U.P. BARBOSI, u.a. 187A were executed for conservation (ANNEX 2). But, as it’s well known in Romania, these cuts have nothing to do with conservation, are just a way to justify the exploitation of forests in a protected area.
That is why I considered it necessary to contact the responsible authorities in order to clarify the situation of the deforestation that I had observed directly in the Snagov forest.
National Directorate of Forests – Romsilva – Ilfov Forestry Department – Snagov Forest District
In response to my interpellation, they informed me that the special conservation works in the Snagov Forest had been carried out correctly. According to the Bill of Evidence of the acts of enhancement in 2021, it is expected to carry out special conservation works on an area of 90 ha out of the total area of 9489 ha of forest fund managed by Ocolul Silvic Snagov.
In this sense, 2058 cubic meters of wood material related to a number of 13 enhancement documents will be extracted. (ANNEX 3).
Also, the Snagov Forest District mentions through another answer (ANNEX 4), the fact that the forest management in force does not propose works and have not been carried out in recent years in the Snagov Forest Reserve, as inscribed in Law 5/2000 at no. crt 2561.
Bucharest Forest Guard
She informed me that the Snagov Nature Reserve is located in UP IV Bărboși and has a total area of 11.66 ha of which 3.03 ha are public property of the state, and the difference was returned according to the laws of the land fund. It also overlaps the national forest fund and the Snagov Forest Protected Natural Area, which is established by Law no. 5/2000 an area of 10 ha, forest fund for the conservation of 15 beech trees for scientific research. Following the restitutions according to the laws of the land fund, the current forest fund area, public property of the state, is 4.59 ha and it is located in UP II – Snagov Park. (ANNEX 5)
The situation of the investigations carried out at Ocolul Silvic Snagov by the BUCHAREST FOREST GUARD and the CONTROL BODY OF THE MINISTRY OF WATERS regarding the observance of the forest regime is presented as follows:
- Year 2018: 16 checks – no sanctions
- Year 2019: 14 checks – no sanctions
- Year 2019: 15 checks – a sanction with a fine in the amount of 3000 lei
- Year 2019: 9 checks – 2 sanctions with warning
According to official sources, the Snagov Nature Reserve has been declared a protected area by Law no. 5 of March 6, 2000 on the approval of the National Spatial Planning Plan – Section III – protected areas consisting of two protected natural areas (100 ha of lake and 10 ha of forest) with a total area of 110 ha, as shown from Annex no. I of the aforementioned Law.
However, the initial act by which the Snagov Forest and a portion of Snagov Lake acquire the quality of “Monument of Nature”, is by the Decision of the Council of Ministers no. 894 of 02.06.1952 (in force and at the present date) – ANNEX 6. According to this decision, the Snagov Nature Reserve has an area of 1147.7 ha, of which 967.70 ha of land / forest and 180 ha of Snagov Lake.
The National Institute for Research and Development in Forestry (INCDS) “Marin Drăcea”
The arrangements of the Snagov Forest District were elaborated by the National Institute for Research-Development in Forestry “Marin Drăcea”. I addressed this Institute in order to clarify the situation of the Snagov Nature Reserve. He informed me of the following (ANNEX 7):
- H.C.M no. 894/02.06.1952 was taken into account and implemented in the arrangement developed after the date of publication of this decision.
- H.C.M. no. 894 was not the subject of discussions and analyzes related to the 2020 edition of the forest management nor to its previous editions because the provisions of the decision in question were taken into account and implemented only in the first edition after the publication of this regulation.
- At the subsequent editions, the information from the previous edition was taken over and the newly appeared regulations during the application period of the respective arrangement were implemented as follows:
Snagov’s body, according to Arrangement U.P. II Snagov Park, 1970 edition: * Recreational forests -1460.3 ha / * RSR Academy Reserve- 12.7 ha
Popeşti’s body and the bottom of the sack, according to Arrangement U.P. III Ghermăneşti, 1975 edition: * Popești Body – 98.6 ha / * Fundul Sacului Body – Scientific Reserve of the RSR Academy – 44.4 ha
- Although the above-mentioned arrangements do not mention H.C.M. no. 894 / 02.06.1952, the functional zoning of these forests was carried out in accordance with the instructions of the time, taking into account the ecological and social objectives resulting from H.C.M. no. 894
- In the current arrangement, the two reservations previously classified as RSR Academy Reservations are registered as follows:
* Protected natural area Snagov Forest, from UP II Snagov- surface. 4.59 ha
* Snagov Nature Reserve, from UP IV Barboși, Fundul Sacului body – surface. 11.66 ha
Ministry of Water Environment and Forests
Compared to the above specified by the National Institute for Research and Development in Forestry “Marin Drăcea” there are still obvious surface inaccuracies of this reservation. Thus, as explained by the fact that the Snagov Nature Reserve with an area of 967.70 ha of land / forest remained with an area of 16.25 ha, and this area cannot be corroborated with any legal provision, because of Law no. 5 of March 6, 2000 shows that the Snagov protected natural area has only 10 ha of forest. The Ministry of Water, Forests and Forests is also aware of these inaccuracies.
In the public debate on 22.02.2021, at 10.00, organized by the Ministry of Environment, Waters and Forests, it was decided to analyze new data regarding the potential extension of some sites, and subsequently to include them in a draft normative act. Also at this debate it was decided to update the Approval Report, so as to specify in a much clearer way the overlap with the protected areas of national interest, respectively with the limits of the protected natural areas realized within the Inspire project.
Considering this draft normative act, as well as the uncertainty of the forest area of the Snagov Nature Reserve, I addressed the Ministry in order to obtain more information.
In this regard, the Ministry informed me that the draft normative act refers strictly to the designation of sites of community importance, protected natural areas of community interest. And the Snagov Nature Reserve is a natural area of national interest. So it will not be the object of regulation of the draft order. Thus, the Ministry specified that it is not aware of any surface remediation process for the Snagov Reservation. (ANNEX 8)
National Agency for Environmental Protection
In view of the provisions,
- Article 6 para.(2) of Law no. 5 of March 6, 2000 ”Updating the annexes no. I and II are made by a decision of the Government, at the proposal of the central public environmental authority. “
- Art. 3 of Decision no. 1000 of October 17, 2012 regarding the reorganization and functioning of the National Agency for Environmental Protection and of the public institutions subordinated to it
“The National Agency for Environmental Protection, as the executing and implementing authority, subordinated to the central public authority for environmental protection, has the following functions in the field of environmental protection:
a) the function of technical support for the substantiation of the projects of normative acts, of the sectorial strategies and policies, as well as of the action plans in the field of environmental protection; (…)
d) the position of authority that issues regulatory acts, according to the legal provisions; ”
National Agency for Environmental Protection in order to clarify the situation of the Snagov Reservation
She informed me that she was not aware if HCM no. 894/1952 was the basis of the study prepared for the designation of the Snagov Nature Reserve. He also stated to me that only the National Agency for Protected Natural Areas is the competent authority with the management of protected natural areas and only this institution can change the limits of a protected natural area and implicitly of its surface. (ANNEX 9)
National Agency for Protected Natural Areas
Following my interpellation, the National Agency for Protected Natural Areas communicated to me the following (ANNEX 10):
- by Order of the Minister of Environment, Waters and Forests no. 652 / 31.03.2016, the Management Plan and the Regulation of the Snagov Lake protected natural area are approved. The aforementioned normative act also took into account HCM no. 894/195
- The approved Management Plan “Purpose and category of the protected area” mentions the area of 100 declared by Law no. 5/2000, a natural area whose purpose is the protection and conservation of important habitats and species in terms of floristics, fauna, hydrology. This plan also refers to HCM no. 894/1952 and to the Decree no. 142/1952, through which the lake area of 180 ha, “included an area organized as a swimming pool and beach, and during the summer there were special lands available to the visitors of this locality”.
- Based on the studies carried out within the project “Snagov Lake Protected Natural Area – Adequate Management by revising the Management Plan based on scientific studies, information and awareness”, the conservation of biodiversity, respectively the maintenance of -a favorable condition or restoration of natural habitats and the population of species of wild fauna and flora. As a result of the studies, it resulted that only for the area declared by Law no. 5/2000, the objective regarding the declaration and conservation of biodiversity in the Snagov Lake reservation could be achieved, the difference of 80 ha provided in HCM no. 894/1952, having another regime that impacts the conservation of biodiversity (beach and beach special lands available to visitors)
Information on the Snagov Nature Reserve was also requested from the ROMANIAN ACADEMY – Commission for the Protection of Natural Monuments. She informed me of the following (ANNEX 11):
- In 2015, the SNAGOV FOUNDATION (custodian of the protected area at that time), submitted a request for the extension of the Snagov Lake protected natural area. From 100 ha to 2080.22 ha. CMN expressed its option for the implementation of the optimal scenario for extension of protected area, at 2080.22 ha. He proposed that for the further development of the legal forms, the SNAGOV FOUNDATION to elaborate a more concise, synthetic documentation. And to submit it to the Ministry of Environment, Waters and Forests for legislative promotion.
- In 2005, the Ilfov Environmental Protection Agency requested the modification / extension of the General Urbanism Plan of Snagov commune. CMN requested an environmental impact assessment study focusing on the main components of the nature reserve’s biodiversity.
- In 2007, CMN confirmed to the Ilfov Environmental Protection Agency, the approval of the management plan of the protected natural area Snagov Forest, prepared by the Snagov Forest District, the custodian of the protected area at that time.
- During 2000, there was an intense collaboration between CMN and the Ministry of Environment (including with the Territorial Environmental Protection Agencies). Following this, the list of protected areas of national interest was finalized, later materialized in Annex 1 of Law no. 5 of March 6, 2000 on the approval of the National Spatial Planning Plan – Section III – protected areas. This law was the first centralization at national level, by counties, of all natural and national parks, biosphere reserves and nature reserves. More recently, there have been no requests from the Ministry of Water Environment and Forests regarding the Snagov Reservation.
The initial act of establishing the Snagov Reservation is the Decision of the Council of Ministers no. 894 of 02.06.1952, which, however, was not accompanied by a description of the boundaries of the reservation or a map showing the perimeter of the reservation. Then, the request in 2015, for the extension of the protected area, did not materialize through a legislative act. In these conditions, CMN is obliged to consider the Snagov Reservation with the surface provided in Law no. 5 of March 6, 2000 on the approval of the National Spatial Planning Plan – Section III – protected areas, and for which the Ilfov Environmental Protection Agency had the obligation to draw the boundaries.
The interpellations presented above arose because of the interventions authorized in recent years by O.S. Snagov in the Snagov Forest.
I emphasize that the existence of supporting documents issued by Ocol itself cannot be a valid argument for the correctness of forestry interventions. This in the conditions of the constant diminution over time of the Snagov Forest, as well as through the prism of the field tests (photo annex 1) which demonstrates the cutting of some trees that offer value to the forest. The removal of these trees cannot in any way be beneficial for the forest management or even more so for the population.
In addition, in the context of the massive pollution in the Bucharest-Ilfov area and the growing population in these areas, as well as the infringement proceedings initiated by the European Commission against Romania, both due to pollution of these areas and non-compliance with the Conservation Directive natural habitats and species of wild fauna and flora, the current approach of OS is wrong Snagov for the elimination of developed trees, with immediate ecological utility, with the illusory argument of “releasing” the youngest ones still in the seedling stage.
Such an argument would allow the cutting of large areas of forest, in order to empty the promise of a future forest, unsupported by the current needs of the population in Bucharest Ilfov area, as well as historical evidence showing a constant deforestation following the use of these practices.
- 21.04.2021: Interpellation addressed to the National Forests Authority – Romsilva, Ilfov Forestry Directorate, Snagov Forest District (read the document)
- 09.04.2021: Response from the Ilfov Forestry Directorate (read the document)
- 16.05.2021: Interpellation return addressed to the National Forests Authority – Romsilva, Ilfov Forestry Directorate, Snagov Forest District (read the document)
- 11.06.2021: Return response from the Ilfov Forestry Directorate (read the document)
- 26.05.2021: Interpellation addressed to the National Institute for Research and Development in Forestry “Marin Drăcea” (read the document)
- 01.07.2021: Response from the National Institute for Research and Development in Forestry “Marin Drăcea” (read the document)
- 27.05.2021: Interpellation addressed to the Ministry of Environment, Waters and Forests (read the document)
- 01.07.2021: Response from the Ministry of Environment, Waters and Forests (read the document)
- 02.06.2021: Interpellation addressed to the Bucharest Forest Guard (read the document)
- 30.06.2021: Response from the Bucharest Forest Guard (read the document)
- 02.06.2021: Interpellation addressed to the National Agency for Environmental Protection (read the document)
- 28.06.2021: Response from the National Agency for Environmental Protection (read the document)
- 16.07.2021: Interpellation addressed to the National Agency for Protected Natural Areas (read the document)
- 02.08.2021: Response from the National Agency for Protected Natural Areas (read the document)
- 21.07.2021: Interpellation addressed to the Romanian Academy – Commission for the Protection of Natural Monuments (read the document)
- 16.08.2021: Answer from the Romanian Academy – Commission for the Protection of Natural Monuments (read the document)