The additional data layer, which is updated annually, identifies a comprehensive pool of AHA-detected real and potential harvest sites in each U.S. hardwood producing county within a 12-month period. This may be used to demonstrate EUDR compliance using the “Declaration in excess” procedure outlined in EU guidance which allows operators handling bulk-traded or mixed commodities to submit a Due Diligence Statement (DDS) that includes a pool of multiple known, compliant plots of origin, even if a specific physical shipment only originates from a subset of those plots.  

Developing this additional data layer has been technically challenging because it requires identification of many lower intensity selection harvest sites that may not involve large scale opening of the canopy and which are not necessarily visible on publicly available satellite datasets. It is dependent on detecting and characterising annual changes in the Normalized Difference Vegetation Index (NDVI) and Normalized Burn Ratio (NBR) which may be calculated from publicly available Sentinel-2 satellite data. Those annual changes are corroborated using NASA GEDI LiDAR and ESA CCI biomass primary datasets. Additional checks are made by expert review of highlighted sites using high resolution satellite imagery delivered by the AHA Expert Eye tool. The Expert Eye input is also used to train AI to progressively increase confidence in harvest site detection.

These harvest site geolocations are identified only to allow users of the AHA system and their customers to meet specific technical requirements in EUDR for provision of geolocation data at the time products are first placed on the EU market. In practice, the AHA risk assessment is county-based, and the individual harvest-site geolocations are currently not an integral part of that risk assessment. In time, this more granular information on harvest locations may be used to improve the accuracy of the risk assessment at county level, but there is no intent to publish data on the level of deforestation risk or any cadastral or other information associated with individual harvest sites.

AHA harvest site geolocation data is subject to a strict Data Use Notice to avoid conflict with U.S. landowner and tribal rights and associated privacy and data protection issues.

AHEC and AHA have advanced a legal and technical case for provision of county geolocations instead of harvest site geolocations as a more technically appropriate and proportionate response in the context of U.S. hardwoods for which there is a demonstrably negligible risk of illegal harvest and deforestation. This case is based on the structure of the fragmented U.S. hardwood supply chain and the supporting risk-assessment evidence provided by AHA. The joint AHEC/AHA position paper, prepared with advice from external EU counsel, seeks a revision of European Commission (EC) guidance to recognize this approach.

Until such time as the EC formally accepts county polygons as compliant with Article 9 of EUDR, AHA advises that the GeoJSON file containing geolocations of identified real and potential harvest sites in the source counties is used for EUDR conformance purposes.

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