Carbon farming and other forms of nature-based temporary carbon sequestration will not store CO2 long enough to tackle the climate crisis nor will they help farmers. We need better tools, argues Sabine Frank.

While EU member states work out their long-term strategies for carbon removals and ponder whether they should introduce their own market mechanisms, they should prioritise high-quality policymaking at the EU level.

Scientific evidence goes against the idea of a market-based certification system for enhancing natural carbon sinks. Yet many lovers of market-based approaches just can’t resist the idea of introducing additional money-spinning opportunities in times of tight public purse strings. 

The EU’s proposed Carbon Removal Certification Framework is heading us towards a problematic market logic in which temporary carbon storage and even emissions reduction from soil can be certified and traded. 

While this is a bad start to creating the governance framework for carbon removals, all isn’t lost yet. The legislative process for setting the EU’s 2040 climate target is an important opportunity to get carbon removals right. 

Once and if the EU sets a governance framework that differentiates between temporary biogenic carbon sequestration and permanent removals, one particular question remains: where should the money for ‘ecological services’ and non-permanent removals as one of their benefits come from? 

Old and new policy instruments need to provide the answers.

Not the natural choice

This raises the question of why temporary carbon sequestration should be excluded from market-based mechanisms.

As CMW research clearly shows, for temporary carbon sequestration to contribute to meeting the warming limits of the Paris Agreement, carbon must remain out of the atmosphere for at least as long as it takes to stabilise global temperatures.

As current climate policies are not yet sufficient globally to limit warming to below 2°C, we must assume that carbon will need to be stored for at least a century to help reduce peak planetary temperatures. Should humanity be even less successful in reducing its emissions, the timeframe would become even longer. The precautionary principle, therefore, demands storage for more than 100 years.

All processes that sequester the CO2 directly from the atmosphere and store it for less than a century can thus, at best, only delay emissions. Because of their inherent vulnerability to natural and human disturbances, processes that enhance carbon sequestration in land and biomass, such as carbon farming, are part of the temporary sequestration category. While crucial to foster ecosystem resilience and halt the ecological crisis, these processes cannot counterbalance residual hard-to-abate emissions to reach climate neutrality. 

Betting the farm

On the basis of these facts, certification of temporary sequestration through variants of ‘carbon farming’ or ‘product storage’ is highly questionable. After all, for what honest purpose could a demand for such certificates arise? Offsetting is clearly not a bona fide purpose.

There is also a danger that carbon farming certificates could be used for offsetting in the agricultural and food sectors, thereby preventing genuine decarbonisation in these areas. 

Reliable quantification is another insurmountable challenge facing carbon farming. Current monitoring, reporting and verification (MRV) techniques, such as remote sensing, lack accuracy and precision, especially when differences in ecosystems, climatic conditions, soil types, agricultural characteristics and land management practices are taken into account. Furthermore, the causality between land management measures and carbon fluxes is difficult to determine. Similarly, establishing baselines is time-consuming, requires potentially unavailable historical data and risks being manipulated or overestimated by participants. The EU Scientific Advisory Board (ESABCC) has warned of all these dangers.

These MRV requirements would be a considerable burden for farmers, foresters, and landowners. They would only represent an economic opportunity for large companies. In addition, farmers, foresters, and landowners – and their successors over generations – would be liable for any reversals if certified removals were to become emissions again, for example, due to forest fires.

For all these reasons, there is only one thing left to do: abandon the ‘carbon tunnel vision’ and protect nature in all its complexity and wonder and not just as a glorified carbon bank. 

The conservation of nature, the restoration of soils, forests and peatlands and the protection of biodiversity are activities that must be supported in their own right. They should not be seen as ‘co-benefits’ to carbon sequestration. Rather, carbon sequestration should be seen as a ‘co-benefit’ of nature conservation and restoration. Conservation and restoration measures must therefore not be monetised and promoted through carbon credits. They must be rewarded through activity-based funding.

Certifiably wrong

One major flaw with the proposed Carbon Removal Certification Framework is that it does not exclude the use of certificates for offsetting and in emissions trading. Furthermore, the CRCF does not rule out the double counting of withdrawals by companies and state governments at the same time.

Another serious point of criticism is that the sustainability criteria for the required biomass are not strict enough with regard to CO2 removal by biochar and with regard to BECCS (bioenergy, carbon capture and storage).

Unfortunately, European Commission President Ursula von der Leyen recently touted so-called ‘nature credits’ as a solution again. “You can get rich by taking fossil fuels out of the ground, but you certainly won’t get rich by putting carbon back into the ground. You can make good money by cutting down a forest, but not by planting a new forest and letting it grow old,” she said at a recent event. “We need new financial instruments to compensate farmers for the additional sustainability costs and to reward them for protecting soil, land, water and air. It’s time to reward those who serve our planet with nature credits.”

Yes, farmers should be rewarded for being sustainable stewards of the land, but this cannot be achieved through carbon markets.

The 2040 battlefield

A crucial battle arena will be the EU’s 2040 climate targets.

In a co-creative process with many stakeholders, CO2ol Down, led by CMW, has developed a vision for an EU carbon removals framework. It has put forward proposals for a revision of the EU climate law as well as recommendations for instruments to permanently reduce emissions.

The proposals for the revision of the EU Climate Law concern the role of carbon removals in the EU’s climate targets which excludes the use of natural sinks to offset any emissions, even residual emissions to reach net zero.

Opening the public purse

Now, of course, the question remains: if incentives for non-permanent removals are not to be created by trading carbon removal certificates, how else are they to be created?

The main existing EU funding instruments that can be harnessed for this purpose is the Common Agricultural Policy (CAP), which remains key to achieving the land use change and forestry (LULUCF) targets, and the Cohesion Fund. 

An important new financing instruments could be a special fund for restoring nature. 

The fundamental flaw with the CAP lies in its structure: according to the WWF, 60% of CAP funds (€32.1 billion annually) are spent by EU countries on measures that promote unsustainable agriculture on a large scale. The main problem here is area-based payments, which mean that 80% (2019) goes to the largest farms. We urgently need a shift away from this and a reorientation towards direct payments that reward sustainable land management, improve soil health and water quality and promote animal welfare.

A reform of the CAP would also have to eliminate contradictory subsidies and obstacles to the use of targeted subsidies. For example, peatland protection is among the targets for the eco schemes and the agricultural and climate policy measures and instruments of the first and second pillars of the CAP, but direct payments for drained peatlands would remain, and rewetted peatlands used for paludiculture (use of peatlands and wetlands) are not consistently eligible for direct payments.

For the public good

We need a comprehensive CAP reform combined with significant changes to the next EU budget. An important concept in this context is that of European public goods. These are defined as “goods that cannot be adequately provided without public intervention”. 

Based on a European public goods approach, direct transfers to farmers – the largest component of the CAP – which serve redistributive purposes should no longer be financed by the EU but ultimately by the member states (the next EU budget could start with the introduction of 50% national co-financing), as suggested by Bruegel. The released CAP resources should then be used to make direct payments linked to environmental protection and the reduction of agricultural emissions.

Following on from the concept of European public goods, a fund could also be introduced to implement the objectives of the Nature Restoration Act.  A dedicated EU fund for nature restoration (in the order of €15-25 billion per year) is the demand of an alliance of green non-governmental organisations. A similar demand is contained in the recent report on the strategic dialogue on the future of agriculture in Europe convened by the European Commission.

In a nutshell

Conserving Europe’s nature and protecting its biodiversity requires a reform of agricultural policy and a reorganisation of subsidies. This requires a bold reinvention of the EU budget.

Such daring reform is fraught with enormous political difficulties but taking the path of least resistance is not an option. Global heating will not wait for a more conducive political climate. Politicians must act now.

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