Carbon Market Watch response to the EU consultation on addressing greenhouse gas emissions from agriculture and LULUCF in the context of the 2030 EU climate and energy framework
1. In your view, which of the multiple objectives of agriculture, forestry and other land use will gain most in relative importance by 2030?
It will be critical to ensure the long-term stability of carbon pools for carbon storage, biodiversity protection and ecosystem preservation in the future. Currently the emissions from land use represent a quarter of all human emissions and it is hence vital that the land use sector also contributes to tackling climate change.
The use of biomass is limited due to finite land availability and therefore the use of biomass should follow the cascading hierarchy and only as a last resort be used for lower-quality applications where other viable alternatives exist, which is the case with power generation.
Finally, it should be recognised that food security and sustainable farming should go hand in hand. Actions that support this include no-till farming, silvopastoral practises and demand-side measures to limit excess consumption.
2. How can the contribution of agriculture, forestry and other land use to the production of renewable energy and raw materials be optimised, while fully exploiting the mitigation potential in these sectors?
Land is a limited resource and its resources must be used sustainably. Current EU policies unfortunately do not promote a sustainable bio-economy founded on resource efficiency, since policies promote the use of lower-value applications (bio-energy) instead of higher value applications such as biomaterials and biochemicals. There is a need for regulation to ensure an optimised use of biomass which should include binding sustainability criteria for solid biomass and a cap on the use of biomass for energy, to ensure that biomass is primarily used for higher-value applications and to avoid serious negative consequences for carbon emissions, biodiversity and land conflicts.
Agriculture is a large source of emissions in the EU which must be reduced in line with the 30% non-ETS target for the year 2030 compared to 2005 levels. Since the accounting rules for agriculture are consistent with the other sectors covered by the Effort Sharing Decision (ESD), whereas LULUCF rules are not, agriculture should remain part of the ESD.
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