When forest transformation fellings become a tool for violations

Forest transformation fellings are currently at the center of lively debates among forestry experts in Ukraine. On the one hand, they are an ecologically sound tool of close-to-nature forestry. On the other hand, they are often used as a cover for large-scale illegally assigned logging. In this short publication, we would like to share our expert opinion for law enforcement, foresters, and government officials who need a clearer understanding of the mechanisms of such abuses.

What are forest transformation fellings?

According to the current Rules for Improving the Quality Composition of Forests, transformation fellings are complex logging aimed at the gradual conversion of stands that do not correspond to the target types of forest into uneven-aged, mixed, multi-layered stands. They are carried out in stages, through several interventions, by removing individual trees or small groups of trees, while simultaneously promoting natural regeneration under the condition of the forest’s continuous existence.

Key features of legal transformation fellings in accordance with Ukrainian legislation:

• Intensity not exceeding 25% of the stand’s growing stock (up to 35% in deciduous stands of production forests)
  
  

• Logging is carried out only in places with viable regeneration
  
  

• Mandatory staged approach and long-term process
  
  

• Preservation of continuous forest cover
  
  

Ecological purpose and benefits

When carried out correctly, transformation fellings have significant ecological potential. Their goal is to create climate-resilient forest ecosystems by gradually replacing artificial monocultures and even-aged stands with natural uneven-aged mixed forests, complex in species and age structure as well as in vertical and horizontal layering.

Proven benefits include doubling timber increment, increasing stand stability, improving soil fertility, and reducing the need for sanitary cuttings. Experimental application in the Carpathian region saved more than 1,000 hectares of forest from clear-cutting.

Specifics in monocultures and even-aged stands

In artificial monocultures, particularly spruce stands below their natural altitudinal range, transformation fellings are especially justified. Such stands are massively dying off due to climate change and pest attacks. Transformation allows for their gradual replacement with mixed stands involving beech, fir, and other native species.

In even-aged stands of natural origin, transformation is permissible only when non-dominant species account for no more than 30%. In such cases, an uneven-aged structure is created through the staged removal of trees from different age groups while maintaining permanent forest cover.

How transformation fellings are misused to cover illegal logging

Unfortunately, practice shows systematic abuses of this tool. The main schemes of violations include:

• Wrong locations. Transformation fellings are carried out in natural, uneven-aged mixed forests where they are unnecessary. Example: the “Zelemin” landscape reserve, where a healthy beech-fir forest was declared “unsuitable” and, under the guise of transformation, the most valuable trees were cut.
  
  

• Exceeding regulations. Felling should not exceed 25% of the stand’s stock, or 35% in deciduous stands of production forests. In 2023, the state enterprise Forests of Ukraine conducted 204 illegal transformation fellings, obtaining 62,000 m³ of unlawful timber.
  
  

• Document falsification. Misclassifying natural mixed forests as monocultures, assigning fellings without proper scientific justification, and ignoring requirements for sufficient regeneration.
  
  

• Ignoring the staged approach. Conducting intensive fellings without respecting the multi-year staged process, failing to monitor the results of previous interventions.
  
  

• Removing the most valuable trees under the pretext of “improving conditions for regeneration.”
  
  

How to recognize abuses: recommendations for professionals

For law enforcement (with expert support):

• Verify whether the stand truly corresponds to the declared characteristics - is it really a monoculture or even-aged stand?
  
  

• Determine actual felling intensity - does it comply with regulations?
  
  

• Check for the presence and viability of natural regeneration.
  
  

• Ensure compliance with requirements on retaining habitat trees.
  
  

For forestry workers:

• Conduct regular training for staff responsible for assigning transformation fellings.
  
  

• Carry out detailed commission-based inspections before assigning fellings.
  
  

• Document regeneration presence and species composition.
  
  

• Adhere to a staged approach — each subsequent intervention only if the results of the previous one are achieved.
  
  

• Involve independent scientific experts in field inspections.
  
  

For government representatives:

• Strengthen control over assigning forest transformation fellings, especially in natural, mixed, and deciduous forests.
  
  

• Establish clearer quantitative criteria for determining the need for transformation.
  
  

• Provide proper training for forestry personnel.
  
  

• Ensure mandatory public discussion of felling plans.
  
  

• Publicly communicate strict sanctions applied for identified abuses.
  
  

Key “red flags”

• Assigning forest transformation fellings in natural-origin, mixed-species, or uneven-aged forests.
  
  

• Lack of sufficient regeneration in areas designated for transformation.
  
  

• Felling intensity exceeding 25-35% of the stand’s stock.
  
  

• Cutting the most economically valuable and largest trees.
  
  

• Lack of scientific justification for the need to assign stands for transformation.
  
  

It is worth noting that forest transformation fellings have great potential to create the resilient natural forests of the future. However, only through strengthened control by all stakeholders - from foresters to law enforcement - can abuses be stopped, and this tool restored to its true purpose.

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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.