SNV Montenegro Forestry Programme Preparatory Mission Report, 2008


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The mission resulted in analysis, proposals and recommendations to:
1) development of Montenegrin national forest program / sector reform;
2) promotion and establishing of national private forest owners’ association;
3) new Forest Law development (including valid law analysis with recommendations for its change, concept, contents-structure and issues of new law);
4) concept of Montenegrin forestry planning and programming;
5) draft Work plan for SNV's technical assistance to Montenegrin forestry sector.

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SNV Montenegro Forestry Programme Preparatory Mission Report, 2008

  1. 1. SNV Montenegro Forestry Programme Preparatory Mission Report 23 Jun to 11 July, 2008 Franc Ferlin, Forestry consultant Ljubljana, August 30, 2008
  2. 2. LIST OF CONTENTSIntroductionResults, 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-agreementsSummary recommendations Contribution to development of Montenegrin national forest programme / forest sector reform Support to new Forest Law development Concept of Montenegrin forestry planning and programming 2
  3. 3. LIST OF ABBREVIATIONSFA Forest AdministrationFFLAP Forest and Forest Land Administration PolicyFL Forest LawFMDP Forest Master Development PlanFMU Forest Management UnitFODEMO Forest Sector Development in MontenegroFSDP Forest Sector Development ProgrammeFSDSP Forest Sector Development Strategy and ProgrammeLCB Local Capacity BuilderMAFWM Ministry of Agriculture, Forestry and Water ManagementNFP national forest programmeNFC National Forest CouncilNFPCC National Forest Programme Coordination CommitteeNFPS National Forest Programme SecretariatNFS National Forestry StrategyNFI National Forest InventoryNTFP Non Timber Forest ProductsNPFOA National Private Forest Owners’ AssociationPFOAs Private Forest Owners’ AssociationsSFM Sustainable Forest ManagementToR Terms of Reference 3
  4. 4. IntroductionThis mission was arranged between SNV Montenegro and the Consultant -future SNV Senior Forestry Advisor and Content Leader - to assist thePodgorica portfolio team in the positioning choice forestry, i.e. to its legal andstrategic framework, forest organization, governance and management, forestproducts harvesting, marketing and use including related value chains andbusiness, all of them particularly related to private forest sector. The core of theassignment was geared around the preparation and implementation of clientwork with the Ministry of Agriculture, Forestry and Water Management(MAFWM) and its Forestry Sector, the Forest Administration (FA) with itsmunicipal units, the Private Forest Owners’ Associations (PFOAs) with theirfuture national association, and a Local Capacity Builder (LCB).From substantial aspects, the assignment was mainly devoted to briefassessment of main current outcomes, concepts and proposals of theMontenegrin national forest programme, i.e. forest sector reform, to sharing ofexperiences and advising on most appropriate next steps’ in mutual planningand development of the reform elements, as well as to own implementation ofcertain promotion, e.g. forest owners’ associating, activities in practice.During the mission, the tasks and anticipated outputs of the Consultant havealso dynamically being adapted (with respect to its primary definition) to actualMontenegrin national forest programme / reform developments and needs, inagreement with SNV Portfolio Coordinator, taking particularly the objectives,outcomes and planned activities of the Forest Sector Development inMontenegro (FODEMO) project into account. Consequently, the assignmentconsisted 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 4
  5. 5. 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). 5
  6. 6. Results, conclusions and recommendations Contribution to development of Montenegrin national forest programme / forest sector reform Forest and Forest Land Administration Policy statusIn order to contribute to the concept, process as well as to further developmentof Montenegrin national forest programme / forest sector reform, the Consultantanalysed the Forest and Forest Land Administration Policy (FFLAP) as amain background and actually the first national forest programme element andresult 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 FFLAPis a Forest Sector (not only the forest and forest land) Development Policy. NFP Content issuesThe FFLAP as a main national forest programme / forest sector reform elementand its first result at the same time, defines generally, in its introductory part,also other national forest programme elements1 which are planned to bedeveloped. Taken the implementation part of FFLAP into consideration – thatpart 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 andthe Forest Sector Development Programme (FSDP) documents. From that1 These general national forest programme elements or components are: a) Forestry and hunting laws, b) Forestry Sector Development Programme (including strategy and budgets), 1 c) Participative monitoring of the programme 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 programmeand lays foundation for detailed annual work plans and budgets. The Strategy will define more indetail the organizational and institutional roles and responsibilities in order to adjust on new Policyvision, and the changes will be reflected in the new legal and operational frameworks.« 6
  7. 7. 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 incurrent Montenegrin situation? Or to develop the NFS first, independently fromits concrete programmes / plans (in numbers)?Taking the situation with already adopted policy, as well as indispensableconnections between strategies and programmes/plans, the Consultant alsorecommends only one such (jont) document to be developed, in its integratedform (strategy and programme/plan together). It could be entitled as ForestSector Development Strategy and Programme (FSDSP).However, the Consultant would also like to stress the fact that for preparation ofsuch 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 meansthat preparation of such document could follow only after the NFI is conducted,i.e. early after next two years. Until then, certain background analyses andstudies, including NFI and other data collection, could be produced. In order notto wait with development of the joint document for such a long time, option withseparated NFS (to be developed first, without available NFI data) and FSDPdocuments (to be developed after the NFI is completed) would be a bettersolution. In case, FMDP will not be part of FSDP, i.e. the master plan is plannedto be developed separately and later on, also such FSDP could be preparedearlier (integrated with NFS).That is why some further considerations4 regarding having one or two suchstrategic-planning documents, as well as on its contents, would be needed inorder 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 implementationhierarchy (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 issuesThe FFLAP defines also a key principle for carrying out and monitoring thenational forest programme / reform process, i.e. cooperation of stakeholdersbased on their participation, joint decision making and sharing theresponsibilities. It defines also corresponding cooperation/partnership bodies forthat purposes: National Forest Council (NFC) and Municipality ForestCouncils.3 This issue has been discussed more in detail within the new Forest law recommendations inAnnex to local version of that Report.4 More detailed discussion and recommendations regarding the forestry strategic planninghierarchy are given in Annex to local version of that Report. 7
  8. 8. MAFWM, supported by FODEMO’s technical assistance, has already prepared adraft 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 workinggroups was proposed. In parallel, also establishment of NFC was mentioned, butwith no clear distinction (most likely overlapping) with the NFPCC. Based on it,FODEMO has currently developed a comprehensive proposal of further curryingout the entire national forest programme / forestry reform process under itsproject objectives. The proposal has already been approved by the Minister.However, the Consultant’s opinion based on his practical experiences is that theproposed mechanism of a high-level advising and coordinating must besimplified. Only one advisory body, i.e. NFC or NFPCC should be established assoon as possible for political guiding of the reform process. Technicalcommissions such as Forest law commission, and appurtenant working groupsof experts, should be established for development of individual national forestprogramme / reform components when necessary. The technical role of NFPCCshould rather be taken over by NFP Secretariat. Otherwise, nepotism offunctions will be a reality.Based on these, also the proposed MAFWM / FODEMO national forestprogramme / reform development concept and work plan could quickly beadapted 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, inassociating the private forest owners. Currently, eight municipal PFOAs wereestablished, covering already about 70% of private forests, and additional five ofthem are planned to be in order to cover the whole private forest lands. Currentconditions were mature and the need very much actual already during themission to establish also national private forest owners’ association(NPFOA). NPFOA Promotion workshopsIn order to promote and assist that process, SNV organized a workshop wherethe Consultant presented general associating purposes, European andparticularly Slovenian experiences in this regard. He also co-facilitated follow-up5 Proposed process for next steps in Formulating a National Forest Strategy with SEA and newLaw on Forests, MAFWM and FODEMO, 22 February 2008. 8
  9. 9. discussions (at this and a next meeting) with representatives of municipalassociations on their joint problems, interests, visions and needs which theywould like to realize through anticipated national or, if this is not possible,regional association. He also suggested technical framework for their possiblework programme (taken from his presentation), based on activities andexperiences of Pan-European confederation of forest owners and the Slovenianassociation. This framework served later as framework for their Statutepreparation. Decision for establishing NPFOABased on this promotion and facilitation activities, the decision for establishmentof national association has been taken at the second meeting, before end of themission. This decision was planned to be formalized by its first Assemblymeeting and should lead to registration of the national association very soon6. Programme of support to PFOAsAt the workshops, particularly the second one, capacity building needs ofPFOAs have been assessed. Taking the expressed needs of municipal PFOAsrepresentatives into account, the Consultant recommends the following kinds ofSNV support to be provided to them: (a) further organizational support toestablish remaining municipal PFOAs (five of them) as well as to establish andregister NPFOA, (b) administrational and, if possible, financial support toNPFOA functioning, (c) advocacy support to NPFOA, (d) support todevelopment 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), forestmanagement and marketing, safety execution of forest operations).Based on the above also concrete draft programme of technical and otherSNV support to PFOAs, particularly the NPFOA, was prepared by theConsultant and included into SNV Forestry Work plan for the period untilFebruary 2009. Support to new Forest Law development General approach of FL developmentThe Consultant created his opinion and recommendations for development ofnew Forest Law (FL) on the basis of his general overview of the current legalframework, the new forest policy statements and on his more detailed analysisof a proposed FL changes (prepared by former LC and most recently, by aFODEMO consultant).6 By the time of delivering of this final report, all this has already been done. 9
  10. 10. The Consultant came to his general conclusion that completely new FL isneeded, i.e. that current FL is not appropriate base for development the new,modern legal framework. The new FL should be developed, based oncorresponding FFLAP statements (which need legal implementation) andappropriate, existent legal solutions, using contemporary FL developmentstandards. The process of new FL developmentThe process of development of new FL, as well as facilitation of it, was agreedbetween the Consultant (on behalf of SNV), the MAFWM / Assistant Ministerand its Legal Commission (LC), and FODEMO taking into account a previouslyprepared and (for that purpose) adapted FODEMO draft methodology.As concerned the LC nominated by the Minister (nine members), the Consultantrecommends to extend it by at least one representative of NPFOA. Fordevelopment of the draft FL also certain working groups, i.e. sub-commissionsshould be formed as soon as possible.The Consultant has prepared a corresponding work plan for the FLdevelopment, taking into consideration that the first draft FL should be prepared(e.g. if the LC would have enough capacity), after public consultations, in earlyNovember. Within the work plan, also certain analyses and studies will beprepared (from international, regional and local consultants) and supported both,by FODEMO and SNV. The Consultant integrated that work plan in an internalSNV Forestry work plan for the period until February 2009.Upon request of Assistant Minister, the Consultant as future SNV SeniorForestry Advisor took over a commitment for preparation of a pre-draft FL, whichwill serve as platform for further work and discussions within LC and withstakeholders. After it is elaborated the Consultant / SNV will mainly retainadvisory and facilitation role. Consultants’ analytical work doneThe Consultant submitted the first part of his detailed analysis of the new FLmaterial with recommendations to the Assistant Minister already during themission (in local language).The Consultant participated in the first (formally the second) substantial meetingof the LC where a number of these recommendations were discussed in detail.Consequently, the approach for preparation of completely new FL, in which allappropriate solutions from the current FL, as well as experiences from othersWest Balkan countries (particularly Serbia and Slovenia), would be used, wasagreed.Upon request of the Assistant Minister and his LC, the Consultant completed thedetailed draft law material analysis with recommendations, which demanded his 10
  11. 11. additional (voluntary) time after the mission (given in Appendix 4, in locallanguage). Concept of Montenegrin forestry planning and programming General aspectsBased on review of the forestry planning levels and types of plans, defined bythe FFLAP, and under consideration of common forestry planning hierarchy, aswell as of appurtenant contents and terminology of forestry plans (both, commonand specific one for Montenegro), the Consultant provided an initial input todefinition of the new concept of Montenegrin forestry strategic planning,forest development and forest management planning which is not clear fromthe FFLAP.The general forestry planning concept, including its terminology, was discussedwith FODEMO and particularly with the LC (at its above mentioned secondmeeting). More into detail, it was presented by the Consultant within hisrecommendations to the new Forest law (available in Appendix to the localReport version) and its corresponding chapter, respectively.The general concept needs further consideration and final agreement as soonas possible (within the LC’s sub-group for forestry planning) in order to be ableto 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 onforest development plans (“planovi razvoja šuma”) for national and municipallevel and on forest management plans (“planovi gazdovanja šumama”) forFMUs. These planes are neutral in respect of the forest property or the fact bywhom the forests are administered, and must not be exchanged with the forestadministration plans.The biggest forest owners for example, such as State, Municipalities or Churchcould 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 withprotection, conservation and development) - also other forest administrationaspects, e.g. allocation or renting of forest and forest land (for their use) anddisposal of forests, and particularly the forest enterprises’ or businessadministration aspects. From the other side, such forest (business)administration plans for smaller holdings are not, or should not really be, much 11
  12. 12. different from the forest management plans, particularly if the lasts include alsocorresponding economic segment. Proposal of forest sector programming concept (summary)One of another type of forestry plans, typical for national level, is FSDP basedon corresponding development strategy (in the same or separated document)which usually, but not necessarily, comprises the FMDP7 as well ascorresponding other plans of the sector’s responsibility, e.g. Plan of stateforestry reorganisation, Plan of forest and forestry public support, Plan ofdevelopment of forestry enterprises, Plan of development of forestry industries,etc.. As mentioned under the national forest programme topic, this should befinally agreed and defined by the new Forest law. SNV (G2G) Project proposal on municipal level forest management planningThe Consultant reviewed also a draft proposal of so called G2G project on“Integral forest management in Montenegro” which particularly strives todevelop the municipality level planning. Particularly that level planning concept,as a new one, needs to be developed, e.g. based on so called forestdevelopment or forest functions’ planning approaches. The Consultantconsidered the G2G proposal as very appropriate and proposed a bit morespecific title only, i.e. integral forest management planning in order toconcentrate on development of planning instead of management systems. FODEMO Proposal of forest management unit planning startegyDuring the mission, the Consultant briefly got information also on developmentof the forest management planning methodology for forest managementunit level and appurtenant strategy for Montenegro, under development byFODEMO, i.e. its sub-contractor (from Baden-Württemberg, Germany). The draftreport on that strategy was delivered to MAFWM right about the end of theConsultants’ field mission and was not available yet. However, the Consultanthas a brief opportunity to speak with the sub-contractors’ Consultant andexchange some views with him regarding the overall forestry planning strategy.This FMU level strategy is certainly a segment of anticipated general forestryplanning 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 ofreference) of the NFI project coordinator (prepared by FODEMO) which wasprepared for launching. His recommendations went particularly intoorganisational direction, e.g. necessary role the Forest Administration (FA)7 This plan could be an independent (master) plan. 12
  13. 13. should get in coordination of that activity, taken into account that the FA, as astate/public forest service institution, should/would formally be responsible forcarrying out of that activity. Other relevant forestry issuesThe Consultant considered also some of other relevant documents and issuesput 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. 13
  14. 14. 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 backgroundAs a main internal task, the Consultant prepared a comprehensive draft Workplan of activities for SNV Forestry team, for the period from 1 August 2008 to28 February 2009 with all key programme areas, assignments and activities.The draft was prepared under consideration of the Montenegrin national forestprogramme / reform process and its priorities (some of them have also beenadapted during the mission) and needs, taking into account current SNVstrategy and activities, capacities and visions, as well as experiences fromneighbouring 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 activitiesDraft 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 hasalso 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. 14
  15. 15. These activities are completely new except for communication issues (d). Activity (a) ispredominant FODEMO’s objective whereas activities (b) and (c) predominantly SNV’swith 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, partd, e and f) are planned as new. Activities under (d), (e) and (f) will be performedin collaboration with FODEMO (as it has also similar objectives). SNV’s supportwill concentrate on private forests and PFO.The above assignments / activities were planned for implementation within thefirst, next 7-months period but have practically all of them also longer-termcharacter. 15
  16. 16. Summary recommendations Contribution to development of Montenegrin national forest programme / forest sector reformTaking the Montenegrin situation with already adopted FFLAP, as well asindispensable connections between NFS and FSDP, only one - joint document isrecommended to be developed (with strategies and planes). Such a documentcould be entitled as FSDSP. If the joint document is containing also the forestdevelopment (master) plan, the new NFI data are indispensable for itspreparation.Development of the new FL should be planned as immediate next step, beforedevelopment of the NFS / FSDP.The proposed mechanism of a high-level advising and coordinating in forestrymust be simplified. Only one advisory body, i.e. NFC or NFPCC should beestablished as soon as possible. Technical commissions and appurtenantworking groups of experts should be established for development of individualnational forest programme / reform components, when necessary. Promotion of private forest owners’ associationsThe following kinds of SNV support, based on previous assessment ofPFO/PFOAs needs are recommended: (a) further organizational support toestablishment the remaining municipal PFOAs (five of them) as well as toestablishment of NPFOA, (b) support to NPFOA functioning, (c) advocacysupport to NPFOA, (d) support to development of better communication (withMAFWM and FA) and (c) education and training of PFO/PFOAs representatives. Support to new Forest Law developmentA completely new FL should be developed, based on corresponding FFLAPstatements (which need legal implementation) and appropriate, existent legalsolutions, 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. 16
  17. 17. The LC members should analyse Consultants’ recommendations on new FLdevelopment carefully and provide their detailed responses (before September)in order to enable efficient pre-draft law preparation. Concept of Montenegrin forestry planningThe forest planning concept, which anticipates four planning levels, e.g. national,municipal, FMU and operational level, should be based on forest developmentplans (for national and municipal level) and on forest management plans.The planes should not be exchanged with (annual) forest administration planeswhich might be elaborated by (biggest) forest owners and include their forestsfrom different municipalities and FMUs.The FA should get its necessary role in coordination of NFI execution, taken intoaccount that the FA should / would formally be responsible for carrying out ofthat activity.The forestry planning concept / strategy needs further consideration and finalagreement as soon as possible (within LC’s sub-group for forestry planning) inorder to be able to define it clearly in the new FL and later, in secondarylegislation. 17