snv montenegro forestry programme preparatory mission report, 2008

SNV Montenegro Forestry Programme Preparatory Mission Report

23 Jun to 11 July, 2008

Franc Ferlin,

Forestry consultant

Ljubljana, August 30, 2008

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LIST OF CONTENTS

Introduction

Results, conclusions and recommendations

Contribution to development of Montenegrin national forest programme (NFP) / sector reform

Forest and Forest Land Administration Policy status

NFP Content issues

NFP Process issues

Promotion of private forest owners’ associations (PFOAs) Current situation regarding private forest owners’ associations

NPFOA Promotion workshops

Decision for establishing NPFOA

SNV’s Programme of support to PFOAs

Support to new Forest Law (FL) development General approach to FL development

The process of new FL development

Consultants’ analytical work done

Concept of Montenegrin forestry planning and programming

General aspects

Proposal of forest planning concept (summary)

Proposal of forest sector programming concept (summary)

SNV (G2G) Project proposal on municipal level forest management

planning

FODEMO Proposal of forest management unit planning strategy

FODEMO Proposal for NFI Project coordinator employment (Terms

of reference)

Other relevant forestry issues

7-Months draft Work plan for SNV Forestry sector General background Planned assignments and activities Human resources needed Memorandums of understanding and assignment-agreements

Summary recommendations

Contribution to development of Montenegrin national forest programme / forest sector reform

Support to new Forest Law development


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LIST OF ABBREVIATIONS

FA Forest Administration

FFLAP Forest and Forest Land Administration Policy

FL Forest Law

FMDP Forest Master Development Plan

FMU Forest Management Unit

FODEMO Forest Sector Development in Montenegro

FSDP Forest Sector Development Programme

FSDSP Forest Sector Development Strategy and Programme

LCB Local Capacity Builder

MAFWM Ministry of Agriculture, Forestry and Water Management

NFP national forest programme

NFC National Forest Council

NFPCC National Forest Programme Coordination Committee

NFPS National Forest Programme Secretariat

NFS National Forestry Strategy

NFI National Forest Inventory

NTFP Non Timber Forest Products

NPFOA National Private Forest Owners’ Association

PFOAs Private Forest Owners’ Associations

SFM Sustainable Forest Management

ToR Terms of Reference

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Introduction

This mission was arranged between SNV Montenegro and the Consultant -

future SNV Senior Forestry Advisor and Content Leader - to assist the

Podgorica portfolio team in the positioning choice forestry, i.e. to its legal and

strategic framework, forest organization, governance and management, forest

products harvesting, marketing and use including related value chains and

business, all of them particularly related to private forest sector. The core of the

assignment was geared around the preparation and implementation of client

work with the Ministry of Agriculture, Forestry and Water Management

(MAFWM) and its Forestry Sector, the Forest Administration (FA) with its

municipal units, the Private Forest Owners’ Associations (PFOAs) with their

future national association, and a Local Capacity Builder (LCB).

From substantial aspects, the assignment was mainly devoted to brief

assessment of main current outcomes, concepts and proposals of the

Montenegrin national forest programme, i.e. forest sector reform, to sharing of

experiences and advising on most appropriate next steps’ in mutual planning

and development of the reform elements, as well as to own implementation of

certain promotion, e.g. forest owners’ associating, activities in practice.

During the mission, the tasks and anticipated outputs of the Consultant have

also dynamically being adapted (with respect to its primary definition) to actual

Montenegrin national forest programme / reform developments and needs, in

agreement with SNV Portfolio Coordinator, taking particularly the objectives,

outcomes and planned activities of the Forest Sector Development in

Montenegro (FODEMO) project into account. Consequently, the assignment

consisted of the following specific tasks and deliverables:

1) Facilitation of common understanding on concept and process of national

forest programme / forest sector reform development, by presentation of

Consultants’ experiences and views, and by his contribution to

adaptation of its draft framework plan.

2) Co-facilitation of first workshop for and further SNV’s support activities to

Private Forest Owners’ Associations (PFOAs), by presentation of

general, Pan-European and Slovenian experiences in organising and

functioning of PFOAs, particularly at national level, and by his advisory

role in preparation of their joint work programme of activities (as a key

element of the Statute) which they would like to realize under their future

national association.

3) Agreeing on the approach and process of development of new Forest

Law (FL), and the future SNV role in it, providing expert comments and

recommendations to currently proposed law changes as well as to new

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law development concept, and by providing corresponding proposal for

finalization of the work plan of Legal Commission (LC).

4) Contribution to development of a new concept of forestry strategic,

developmental, particularly the municipality-level, and management-level

planning, taking into consideration corresponding Forest and Forest Land

Administration Policy (FFLAP) guidelines, the project proposal on

Integral forest management planning in Montenegro (so called

Government to Government or G2G proposal) and ongoing work on

development of forest management unit planning strategy (in preparation

by FODEMO).

5) Considering of, and contributing to other relevant forestry issues put

forward by the MAFWM and/or FODEMO.

6) Preparing a comprehensive draft 6-months Work plan (WP) of activities

for SNV Forestry team, based on Montenegrin national forest programme

/ reform priorities and needs and the current SNV forestry strategy for

Montenegro, taking into account current SNV forestry activities,

capacities and visions and experiences from neighbouring countries

(based on the SNV forestry meeting in Tirana).

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Results, conclusions and recommendations


Forest and Forest Land Administration Policy status

In order to contribute to the concept, process as well as to further development

of Montenegrin national forest programme / forest sector reform, the Consultant

analysed the Forest and Forest Land Administration Policy (FFLAP) as a

main background and actually the first national forest programme element and

result at the same time.

Based on a complex content of the FFLAP, comprising much wider

(multifunctional) aspects than only those related to forest and forest lands’

administration (to which the title corresponds), it could be stated that the FFLAP

is a Forest Sector (not only the forest and forest land) Development Policy.

NFP Content issues

The FFLAP as a main national forest programme / forest sector reform element

and its first result at the same time, defines generally, in its introductory part,

also other national forest programme elements1 which are planned to be

developed. Taken the implementation part of FFLAP into consideration – that

part defines e.g. the content of National Forest Strategy (NFS)2 more in detail –

the Consultant noted that there is actually no difference between the NFS and

the Forest Sector Development Programme (FSDP) documents. From that

1These general national forest programme elements or components are:

a) Forestry and hunting laws, b) Forestry Sector Development Programme (including strategy and budgets), c) Participative monitoring of the programme

1 implementation,

d) The reform of Governmental institutions and services in forestry sector (based on corresponding specific programme),

e) Building human capacities at all levels, f) Support to establishment of sustainable private sector in forestry.

2 Citation from FFLAP: »The Policy will be implemented through the National Forest Strategy,

which defines short-term, mid-term and long-term objectives and programmes for areas of work, and regions, addresses critical issues by their priorities, defines multiyear budgetary programme and lays foundation for detailed annual work plans and budgets. The Strategy will define more in detail the organizational and institutional roles and responsibilities in order to adjust on new Policy vision, and the changes will be reflected in the new legal and operational frameworks.«

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aspect, only one document is expected to be developed. However, a question is,

as also discussed with the MAFWM and FODEMO, if this is appropriate in

current Montenegrin situation? Or to develop the NFS first, independently from

its concrete programmes / plans (in numbers)?

Taking the situation with already adopted policy, as well as indispensable

connections between strategies and programmes/plans, the Consultant also

recommends only one such (jont) document to be developed, in its integrated

form (strategy and programme/plan together). It could be entitled as Forest

Sector Development Strategy and Programme (FSDSP).

However, the Consultant would also like to stress the fact that for preparation of

such a joint document, if containing3 both the Forest Master Development Plan

(FMDP) and other forest sector plans, usually the National Forest Inventory

(NFI), which has not started yet in Montenegro, is indispensable. This means

that preparation of such document could follow only after the NFI is conducted,

i.e. early after next two years. Until then, certain background analyses and

studies, including NFI and other data collection, could be produced. In order not

to wait with development of the joint document for such a long time, option with

separated NFS (to be developed first, without available NFI data) and FSDP

documents (to be developed after the NFI is completed) would be a better

solution. In case, FMDP will not be part of FSDP, i.e. the master plan is planned

to be developed separately and later on, also such FSDP could be prepared

earlier (integrated with NFS).

That is why some further considerations4 regarding having one or two such

strategic-planning documents, as well as on its contents, would be needed in

order to create final definition of the document(s) and put it in the new (draft)

Forest law.

Related to the above and the normal forestry planning and implementation

hierarchy (i.e. policy, legislation, strategies and programmes / planes),

development of the forest legislation should be planned as immediate next step,

before development of the Strategy as previously anticipated.

NFP Process issues

The FFLAP defines also a key principle for carrying out and monitoring the

national forest programme / reform process, i.e. cooperation of stakeholders

based on their participation, joint decision making and sharing the

responsibilities. It defines also corresponding cooperation/partnership bodies for

that purposes: National Forest Council (NFC) and Municipality Forest

Councils.

3 This issue has been discussed more in detail within the new Forest law recommendations in

Annex to local version of that Report.

4 More detailed discussion and recommendations regarding the forestry strategic planning

hierarchy are given in Annex to local version of that Report.

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MAFWM, supported by FODEMO’s technical assistance, has already prepared a

draft concept5 on carrying out the next steps of the national forest programme /

forest sector reform, particularly in formulating the NFS and new Forests Law.

Establishing of a National Forest Programme Coordination Committee

(NFPCC), a National Forest Programme Secretariat (NFPS) and NFS working

groups was proposed. In parallel, also establishment of NFC was mentioned, but

with no clear distinction (most likely overlapping) with the NFPCC. Based on it,

FODEMO has currently developed a comprehensive proposal of further currying

out the entire national forest programme / forestry reform process under its

project objectives. The proposal has already been approved by the Minister.

However, the Consultant’s opinion based on his practical experiences is that the

proposed mechanism of a high-level advising and coordinating must be

simplified. Only one advisory body, i.e. NFC or NFPCC should be established as

soon as possible for political guiding of the reform process. Technical

commissions such as Forest law commission, and appurtenant working groups

of experts, should be established for development of individual national forest

programme / reform components when necessary. The technical role of NFPCC

should rather be taken over by NFP Secretariat. Otherwise, nepotism of

functions will be a reality.

Based on these, also the proposed MAFWM / FODEMO national forest

programme / reform development concept and work plan could quickly be

adapted and agreed.

Promotion of private forest owners’ associations

Current situation regarding private forest owners’ associations

(PFOAs)

Montenegro already made significant and fast progress, supported by SNV, in

associating the private forest owners. Currently, eight municipal PFOAs were

established, covering already about 70% of private forests, and additional five of

them are planned to be in order to cover the whole private forest lands. Current

conditions were mature and the need very much actual already during the

mission to establish also national private forest owners’ association

(NPFOA).

NPFOA Promotion workshops

In order to promote and assist that process, SNV organized a workshop where

the Consultant presented general associating purposes, European and

particularly Slovenian experiences in this regard. He also co-facilitated follow-up

5 Proposed process for next steps in Formulating a National Forest Strategy with SEA and new

Law on Forests, MAFWM and FODEMO, 22 February 2008.

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discussions (at this and a next meeting) with representatives of municipal

associations on their joint problems, interests, visions and needs which they

would like to realize through anticipated national or, if this is not possible,

regional association. He also suggested technical framework for their possible

work programme (taken from his presentation), based on activities and

experiences of Pan-European confederation of forest owners and the Slovenian

association. This framework served later as framework for their Statute

preparation.

Decision for establishing NPFOA

Based on this promotion and facilitation activities, the decision for establishment

of national association has been taken at the second meeting, before end of the

mission. This decision was planned to be formalized by its first Assembly

meeting and should lead to registration of the national association very soon6.

Programme of support to PFOAs

At the workshops, particularly the second one, capacity building needs of

PFOAs have been assessed. Taking the expressed needs of municipal PFOAs

representatives into account, the Consultant recommends the following kinds of

SNV support to be provided to them: (a) further organizational support to

establish remaining municipal PFOAs (five of them) as well as to establish and

register NPFOA, (b) administrational and, if possible, financial support to

NPFOA functioning, (c) advocacy support to NPFOA, (d) support to

development of appropriate communication (with MAFWM and FA) and (c)

education and training of PFO/PFOAs representatives on various forestry issues

(e.g. forest management planning, public forestry financing (subsidies), forest

management and marketing, safety execution of forest operations).

Based on the above also concrete draft programme of technical and other

SNV support to PFOAs, particularly the NPFOA, was prepared by the

Consultant and included into SNV Forestry Work plan for the period until

February 2009.


General approach of FL development

The Consultant created his opinion and recommendations for development of

new Forest Law (FL) on the basis of his general overview of the current legal

framework, the new forest policy statements and on his more detailed analysis

of a proposed FL changes (prepared by former LC and most recently, by a

FODEMO consultant).

6 By the time of delivering of this final report, all this has already been done.

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The Consultant came to his general conclusion that completely new FL is

needed, i.e. that current FL is not appropriate base for development the new,

modern legal framework. The new FL should be developed, based on

corresponding FFLAP statements (which need legal implementation) and

appropriate, existent legal solutions, using contemporary FL development

standards.

The process of new FL development

The process of development of new FL, as well as facilitation of it, was agreed

between the Consultant (on behalf of SNV), the MAFWM / Assistant Minister

and its Legal Commission (LC), and FODEMO taking into account a previously

prepared and (for that purpose) adapted FODEMO draft methodology.

As concerned the LC nominated by the Minister (nine members), the Consultant

recommends to extend it by at least one representative of NPFOA. For

development of the draft FL also certain working groups, i.e. sub-commissions

should be formed as soon as possible.

The Consultant has prepared a corresponding work plan for the FL

development, taking into consideration that the first draft FL should be prepared

(e.g. if the LC would have enough capacity), after public consultations, in early

November. Within the work plan, also certain analyses and studies will be

prepared (from international, regional and local consultants) and supported both,

by FODEMO and SNV. The Consultant integrated that work plan in an internal

SNV Forestry work plan for the period until February 2009.

Upon request of Assistant Minister, the Consultant as future SNV Senior

Forestry Advisor took over a commitment for preparation of a pre-draft FL, which

will serve as platform for further work and discussions within LC and with

stakeholders. After it is elaborated the Consultant / SNV will mainly retain

advisory and facilitation role.

Consultants’ analytical work done

The Consultant submitted the first part of his detailed analysis of the new FL

material with recommendations to the Assistant Minister already during the

mission (in local language).

The Consultant participated in the first (formally the second) substantial meeting

of the LC where a number of these recommendations were discussed in detail.

Consequently, the approach for preparation of completely new FL, in which all

appropriate solutions from the current FL, as well as experiences from others

West Balkan countries (particularly Serbia and Slovenia), would be used, was

agreed.

Upon request of the Assistant Minister and his LC, the Consultant completed the

detailed draft law material analysis with recommendations, which demanded his

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additional (voluntary) time after the mission (given in Appendix 4, in local

language).


General aspects

Based on review of the forestry planning levels and types of plans, defined by

the FFLAP, and under consideration of common forestry planning hierarchy, as

well as of appurtenant contents and terminology of forestry plans (both, common

and specific one for Montenegro), the Consultant provided an initial input to

definition of the new concept of Montenegrin forestry strategic planning,

forest development and forest management planning which is not clear from

the FFLAP.

The general forestry planning concept, including its terminology, was discussed

with FODEMO and particularly with the LC (at its above mentioned second

meeting). More into detail, it was presented by the Consultant within his

recommendations to the new Forest law (available in Appendix to the local

Report version) and its corresponding chapter, respectively.

The general concept needs further consideration and final agreement as soon

as possible (within the LC’s sub-group for forestry planning) in order to be able

to define it clearly in the new FL and later, in secondary legislation.

Proposal of forest planning concept (summary)

The concept which anticipates four planning levels in case of forests, e.g.

national, municipal (as a kind of narrower regional), forest management unit

(FMU) and operational (forest compartment or holdings) should be based on

forest development plans (“planovi razvoja šuma”) for national and municipal

level and on forest management plans (“planovi gazdovanja šumama”) for

FMUs. These planes are neutral in respect of the forest property or the fact by

whom the forests are administered, and must not be exchanged with the forest

administration plans.

The biggest forest owners for example, such as State, Municipalities or Church

could have their own forest administration planes (“planovi upravljanja šuma”)

which include their forests from different regions or municipalities and FMUs.

Such planes are normally not legally binding, could be annual or, rarely, mid-

term ones, and comprise - beside the forest management (or utilisation with

protection, conservation and development) - also other forest administration

aspects, e.g. allocation or renting of forest and forest land (for their use) and

disposal of forests, and particularly the forest enterprises’ or business

administration aspects. From the other side, such forest (business)

administration plans for smaller holdings are not, or should not really be, much

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different from the forest management plans, particularly if the lasts include also

corresponding economic segment.

Proposal of forest sector programming concept (summary)

One of another type of forestry plans, typical for national level, is FSDP based

on corresponding development strategy (in the same or separated document)

which usually, but not necessarily, comprises the FMDP7 as well as

corresponding other plans of the sector’s responsibility, e.g. Plan of state

forestry reorganisation, Plan of forest and forestry public support, Plan of

development of forestry enterprises, Plan of development of forestry industries,

etc.. As mentioned under the national forest programme topic, this should be

finally agreed and defined by the new Forest law.

SNV (G2G) Project proposal on municipal level forest management

planning

The Consultant reviewed also a draft proposal of so called G2G project on

“Integral forest management in Montenegro” which particularly strives to

develop the municipality level planning. Particularly that level planning concept,

as a new one, needs to be developed, e.g. based on so called forest

development or forest functions’ planning approaches. The Consultant

considered the G2G proposal as very appropriate and proposed a bit more

specific title only, i.e. integral forest management planning in order to

concentrate on development of planning instead of management systems.

FODEMO Proposal of forest management unit planning startegy

During the mission, the Consultant briefly got information also on development

of the forest management planning methodology for forest management

unit level and appurtenant strategy for Montenegro, under development by

FODEMO, i.e. its sub-contractor (from Baden-Württemberg, Germany). The draft

report on that strategy was delivered to MAFWM right about the end of the

Consultants’ field mission and was not available yet. However, the Consultant

has a brief opportunity to speak with the sub-contractors’ Consultant and

exchange some views with him regarding the overall forestry planning strategy.

This FMU level strategy is certainly a segment of anticipated general forestry

planning strategy and will significantly contribute to its development.

FODEMO Proposal for NFI Project coordinator employment (Terms

of reference)

The consultant provided his general opinion also to the draft concept (Terms of

reference) of the NFI project coordinator (prepared by FODEMO) which was

prepared for launching. His recommendations went particularly into

organisational direction, e.g. necessary role the Forest Administration (FA)

7 This plan could be an independent (master) plan.

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should get in coordination of that activity, taken into account that the FA, as a

state/public forest service institution, should/would formally be responsible for

carrying out of that activity.

Other relevant forestry issues

The Consultant considered also some of other relevant documents and issues

put forward by the MAFWM/FA, FODEMO or SNV, for example:

a) Programme of usage of funds for 2008, by Forest Administration (April

2008)

Comment: Concise document showing a complete input – output flow of

financing of the Forest Administration activities and investments to forests (forest

reproduction) for 2008, including private forest support. The main segment is

budget plan of financing forest and forestry measures. The document is a

preceding document to the long-term Forest Development Programme as a key

element of national forest programme. It shows quite a capacity of

Administration for such planning.

b) Legal and Institutional Framework (of forest sector in Montenegro), by

FODEMO/Stritih (June 2008)

Comment: The report is a complex overview of legal, institutional / organizational

and forest management standards’ aspects with corresponding

recommendations. Majority of the recommendations has already been included

into adopted Forest and Forest Land Administration Policy. It recommends also

corresponding changed priorities (e.g. to development of forest legislation first)

in further forestry reform planning and development.

c) Legal and Institutional Framework for Concession Management, by

FODEMO /McRae (June 2008)

Comment: Comprehensive contribution to arrangement of the forest concession

relations, although based on Canadian experiences, and useful background for

drafting corresponding segment of the Forest Law and/or corresponding

regulation. Detailed consideration of all recommendations would be needed.

Combining the experiences and recommendations with Montenegrin specifics

and reality should give and optimum result.

d) Project on development and revitalization of timber industry and

forestry in Montenegro, by Nikčević et al. (2003).

Comment: The document served as background for consideration (between

FODEMO and SNV) on possible future support to repeat such a study, now in

the context and needs of new Forestry Strategy. As the support to development

of timber industry and its value chain will certainly be a part of new Forestry

Strategy, and taking into account that the above project gives not very much

strategic recommendations for the Strategy, the Consultant recommended to

leave the decision for the study to corresponding Forest Strategy experts.

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e) Non-Timber Forest Products (NTFP) Survey, Draft report by ISSA

(June 2008)

Comment: Interested survey, based on quite a comprehensive questionnaire

targeted on private forest owners (with focus on their forest management and

forest products, particularly NTFP). It would be good if such surveys, as

framework for private forestry sub-sector analysis could at the same time

incorporate also other relevant aspects (e.g. policy/regulatory, organizational,

education, extension, informational and financial/incentives).

7-Months draft Work plan for SNV Forestry sector

General background

As a main internal task, the Consultant prepared a comprehensive draft Work

plan of activities for SNV Forestry team, for the period from 1 August 2008 to

28 February 2009 with all key programme areas, assignments and activities.

The draft was prepared under consideration of the Montenegrin national forest

programme / reform process and its priorities (some of them have also been

adapted during the mission) and needs, taking into account current SNV

strategy and activities, capacities and visions, as well as experiences from

neighbouring countries.

The draft WP offers a wide (much wider than current one) and ambitious,

interdisciplinary platform for engagement of current SNV advisors, national,

international, regional national consultants as well as LCB(s) and other experts.

Planned assignments and activities

Draft WP assignments and activities are planned for NPFOA, MAFWM and FA.

Planned assignments / activities with NPFOA are:

a) Organisational and functional support (promotion of new PFOAs and

NPFOA functioning),

b) Advocacy,

c) Communication with MAFWM and DF,

d) Education and training of PFO/PFOAs representatives.

Current SNV activities were performed on organisational issues (part of a) only.

Activities under (d) will be performed in collaboration with FODEMO (as it has

also similar objectives) as predominant SNV activity.

Planned assignments / activities with MAFWM are:

a) National forest programme content and process issues (clarification only),

b) New Forest law development (facilitation),

c) Hunting law development (general recommendations only),

d) Communication.

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These activities are completely new except for communication issues (d). Activity (a) is

predominant FODEMO’s objective whereas activities (b) and (c) predominantly SNV’s

with FODEMO’s support.

Planned assignments / activities with FA:

a) Private forest sub-sector analysis,

b) Mushroom and other non-timber forest products (NTFP) value chains’

development,

c) Promotion of forest-related small and medium enterprises (SMEs)’

development,

d) Private forest planning (including G2G proposal) and private forest

management development (later on),

e) Private forestry information system development (later on) and

f) Forestry education, training and extension of foresters (for private

forests).

The activities on (a) and (b) and partly (c) are already ongoing, all others (c, part

d, e and f) are planned as new. Activities under (d), (e) and (f) will be performed

in collaboration with FODEMO (as it has also similar objectives). SNV’s support

will concentrate on private forests and PFO.

The above assignments / activities were planned for implementation within the

first, next 7-months period but have practically all of them also longer-term

character.

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Summary recommendations


Taking the Montenegrin situation with already adopted FFLAP, as well as

indispensable connections between NFS and FSDP, only one - joint document is

recommended to be developed (with strategies and planes). Such a document

could be entitled as FSDSP. If the joint document is containing also the forest

development (master) plan, the new NFI data are indispensable for its

preparation.

Development of the new FL should be planned as immediate next step, before

development of the NFS / FSDP.

The proposed mechanism of a high-level advising and coordinating in forestry

must be simplified. Only one advisory body, i.e. NFC or NFPCC should be

established as soon as possible. Technical commissions and appurtenant

working groups of experts should be established for development of individual

national forest programme / reform components, when necessary.

Promotion of private forest owners’ associations

The following kinds of SNV support, based on previous assessment of

PFO/PFOAs needs are recommended: (a) further organizational support to

establishment the remaining municipal PFOAs (five of them) as well as to

establishment of NPFOA, (b) support to NPFOA functioning, (c) advocacy

support to NPFOA, (d) support to development of better communication (with

MAFWM and FA) and (c) education and training of PFO/PFOAs representatives.


A completely new FL should be developed, based on corresponding FFLAP

statements (which need legal implementation) and appropriate, existent legal

solutions, using contemporary FL development standards.

The FL Commission should be extend at least with a representative of (N)PFOA.

For development of the draft FL also certain working groups, i.e. sub-

commissions should be formed as soon as possible.

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The LC members should analyse Consultants’ recommendations on new FL

development carefully and provide their detailed responses (before September)

in order to enable efficient pre-draft law preparation.

Concept of Montenegrin forestry planning

The forest planning concept, which anticipates four planning levels, e.g. national,

municipal, FMU and operational level, should be based on forest development

plans (for national and municipal level) and on forest management plans.

The planes should not be exchanged with (annual) forest administration planes

which might be elaborated by (biggest) forest owners and include their forests

from different municipalities and FMUs.

The FA should get its necessary role in coordination of NFI execution, taken into

account that the FA should / would formally be responsible for carrying out of

that activity.

The forestry planning concept / strategy needs further consideration and final

agreement as soon as possible (within LC’s sub-group for forestry planning) in

order to be able to define it clearly in the new FL and later, in secondary

legislation.

snv montenegro forestry programme preparatory mission report, 2008

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