The Commission published its proposal on the inclusion of greenhouse gas emissions and removals from land use, land use change and forestry into the 2030 Climate and Energy framework (LULUCF) on 20 July 2016. The proposals serves as the new accounting framework for land use and forestry, as the global Kyoto Protocol comes to an end. According to the proposal, carbon emissions and removals by forests should be compared to a projected Forest Reference Level based on past forest harvest intensity and projected biomass availability. CEPF is strongly concerned over the new proposed model of LULUCF accounting, and encourages policy makers to make sure that the proposed model takes into account the biological carbon stock and sink which can be maintained while harvesting can be sustainably increased.
“If the harvesting does not exceed forest growth, there should not be any additional debits as the forest sink still removes CO2 from the atmosphere, while providing a renewable raw material to replace fossils. The LULUCF accounting needs to be revised to better reflect the real biological carbon removals and emissions”, states Bernhard Budil the Secretary General of Austrian Private Forest Owners and Farmers Association (Land&Forst Betriebe Österreich). The Commission proposal compares emissions from harvesting to past intensity and puts the emphasis on the forest sink, making it incompatible with the best long-term climate change mitigation strategy in the forest sector. MEP Lins report improves the Commission proposal, but fails to fully tackle this issue. Emphasis should be placed on active forestry and the replacement of fossils, rather than on a short-term increase of the carbon stock in standing forests.
CEPF identifies several positive suggestions in MEP Lins’ draft report, such as the peer review process regarding the Forest Reference Levels. This would take the decision of the Forest Reference Level more close to Member States. Furthermore, the draft acknowledges the long-term climate benefits of the LULUCF sector to contribute significantly to the achievement of Union and international long-term climate goals. Moreover, the draft report does not only talk about the LULUCF sector’s ability to contribute to climate change mitigation by reducing emissions, maintaining and enhancing sinks and carbon stock, but also by its ability to provide bio-materials that can substitute fossil- or carbon intensive materials. In addition, the draft report highlights sustainable resource management as an effective tool to increase carbon sequestration. CEPF emphasises that the long-term stability and adaptability of carbon pools are essential, as stated in the proposal. However, it is of utmost importance to look at beyond 2030 as increased use of natural resources facilitate the transition from a fossil-based era to the bioeconomy. Therefore, CEPF very much welcomes the inclusion on long-term strategies that are needed to make sustainable investments possible in the long run. Furthermore, the draft report encourages Member States to invest in preventive actions, such as sustainable forest management, to reduce risks associated with natural disturbances. “The amendment is of utmost importance, especially for CEPF members in Southern Europe where negative impacts of the climate change already occurs in terms of increased forest fires”, says Emma Berglund, CEPF Secretary General.
On flexibility, MEP Lins’ draft report follows the Commission suggestion that Member States should be able to use at least 280 million tonnes of CO2 equivalent to offset emissions from Effort Sharing Regulation. In addition, Lins adds that Member States should be allowed to use credits generated by the accounting category of Managed Forest Land when new Forest Reference Levels have been updated.
Ms Berglund explains “following these strict rules for setting up Forest Reference Levels, the report increases the amount of credits that could be used from the Managed Forest Land accounting category. In the Commission proposal the use of these credits were capped to 3,5 % of Member States emissions during the base year set in Annex III of the proposal. The new amendment by MEP Lins would raise the amount of credits to 7 %”.
However, Ms Berglund reminds that “the most important thing for CEPF is the Forest Refence Level that should not be tied to past harvest intensities, but allow for the highest possible sustainable harvest levels. This would allow for the best climate benefit from the forest sector in the long term. As soon as these rules are being agreed, it is possible to predict impacts of flexibility and the capping of credits from the Managed Forest Land accounting category”.
The draft opinion of COM AGRI rapporteur MEP Elisabeth Köstinger, EPP/Austria, goes in the right direction and supports a more realistic view on the role of forests in climate change mitigation. In contrary, the draft opinion of COM ITRE rapporteur MEP Marisa Matias, GUE-NGL/Portugal, goes in a dangerous direction where long-term climate change mitigation is put at risk.
CEPF position on LULUCF can be seen below.
Should you have any questions on CEPF position, please do not hesitate to contact:
Meri Siljama, CEPF Policy Advisor, firstname.lastname@example.org.