ForestCom Initiates the Development of a Methodology for Differentiating Stumps of Illegal Logging

The Problem

Matching the actually felled trees with the volumes documented in harvesting permits is a crucial step in investigating illegal logging. Many illegal logging cases occur in this gray zone of semi-legitimacy: overall, the harvesting site has official authorization, but some trees are felled legally, while others are “accidentally” cut beyond the permitted volume.

When control authorities conduct inspections, significant discrepancies often emerge between field and verification documentation. One reason is the different diameter measurement intervals used in field and inspection records. Depending on the tree species, natural features, and trunk shapes, measurement intervals may vary — 1 cm, 2 cm, or 4 cm.

Such inconsistencies in methodology lead to several problems:

• inability to accurately determine the legality of felling for individual stumps;

• difficulty conducting forensic examinations and court proceedings, as it is impossible to reliably confirm whether a stump belongs to a tree designated for cutting;

• risk of subjective evaluation of timber quality* by environmental inspectors due to the lack of a standardized approach;

• challenges in building an evidence base for criminal and administrative cases;

• grounds for abuse of authority by forestry officials;

• corruption risks in environmental inspection activities.

The Solution

The core mission of NGO ForestCom is to drive effective change in Ukraine’s forestry sector. As part of the project “Advocacy for Eliminating Legislative Barriers to Improve Forest Protection Efficiency Against Illegal Logging,” the organization initiated a roundtable discussion titled “Developing a Joint Action Plan to Enhance the Effectiveness of Combating Illegal Logging and the Circulation of Illegally Harvested Timber.”

During the discussion, a representative of the State Environmental Inspectorate highlighted the legal gap described above. How do we see a potential solution?

First of all, the issue requires careful expert work — for instance, the creation and official approval of a Methodology for Converting Tree Diameters to Stump Heights, which would include scientifically grounded tables for converting stump diameters into tree diameters (and vice versa).

To achieve this, it is necessary to:

• engage experts in dendrology and forest inventory;

• conduct experimental measurements considering tree species, age groups, and forest site conditions;

• define permissible measurement errors and trunk diameter gradations.

The next step would be to align the methodology with the Instruction on Allocation and Taxation of Felling Areas, approved by the Ministry of Economy. In developing the methodology, it is crucial to consider practical risks of tree damage during selective logging and the real conditions of field measurements. This will ensure the reliability and reproducibility of results during inspections.

Proposals

Based on these considerations, in an official appeal to the Ministry of Economy, the Ministry of Environmental Protection and Agriculture of Ukraine, the State Forest Resources Agency, and the State Environmental Inspectorate of Ukraine, the Executive Director of NGO ForestCom proposed:

• to develop a Methodology for Converting Tree Diameters to Stump Heights, containing scientifically based conversion tables (stump-to-tree and tree-to-stump), to ensure comparability between harvesting allocation data and the verification records of controlling authorities.

We hope for readiness to cooperate and for a shared commitment to meaningful change.

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The publication is produced by NGO ForestCom with the support of the Askold and Dir Fund as a part of the Strong Civil Society of Ukraine –  a Driver towards Reforms and Democracy project, implemented by ISAR Ednannia, funded by Norway and Sweden. The contents of this publication are the sole responsibility of NGO «ForestCom» and can in no way be taken to reflect the views of the Government of Norway, the Government of Sweden and ISAR Ednannia.

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