Executive summary

The European Commission is expected to publish legislation on how to include the land use, land use change and forestry (LULUCF) sector into the EU’s 2030 climate framework in the summer of 2016. Three options presented by the Commission on how to do this suggest various levels of integration with other sectors, from keeping LULUCF in a separate pillar, combining the sector with methane (CH4) and nitrous oxide (N20) agriculture emissions, or adding the sector into the Effort Sharing Decision (ESD).

Regardless of what option is chosen, there is a potential risk that the LULUCF sector will be used to reduce the climate efforts of other sectors such as transport or manufacturing. This is because the LULUCF sector is an overall sink, which means that more carbon is removed from the atmosphere than released. Counting the carbon removals from the LULUCF sector towards the same target as other sectors will therefore reduce the effort needed to reach the EU’s climate goal and slow decarbonization of the European economy.

There are several characteristics of the LULUCF sector that make it unfit for inclusion in the EU’s existing climate instruments:

1. Data uncertainty: Forest inventories are done every 5-10 years and possible technical corrections can lead to significant recalculations. Since the EU’s existing climate instruments have an annual compliance cycle, merging the LULUCF sector with the other sectors would disturb national accounting and create a large degree of uncertainty.

2. Incomplete accounting: Forest accounting techniques are highly approximate as they attempt to separate manmade from natural impacts on the land. Methods allow for over-crediting, which represent reductions without real mitigation actions.

3. Non-permanence: While the fossil fuel carbon stock is permanent unless tampered with, forests and soils naturally release carbon on relatively short timescales, through ageing or fires. This makes carbon absorption activities by plants and soils non-permanent and thus unfit to replace the reduction of fossil fuels.

4. Removing carbon from the atmosphere: In light of the Paris agreement and the new goal to limit global warming to below 1.5°C, it has become crucial that carbon removals are promoted in addition to emission reductions, rather than replacing them. If other sectors are allowed to use LULUCF credits to meet their targets, the ambition level of the EU’s 2030 climate ambition could be reduced by a massive 5%.

This policy briefing explains the problems of using the emission removals from the LULUCF sector to meet climate targets in other sectors and recommends how the LULUCF sector can be best integrated into the EU’s climate framework.

Key recommendations: LULUCF should be addressed in a separate pillar so that efforts in the land use sector are done in addition to the efforts to phase out fossil fuels. The LULUCF sector should not be used to generate land use offsets that would undermine the mitigation efforts of other sectors. Mitigation activities for the land use sector should prioritise preserving biodiversity and supporting the sustainable use of land as a resource above pure mitigation, which alone can have adverse effects. Only biomass that adheres to sustainability criteria can be considered carbon neutral in the EU’s climate legislation. The greenhouse gas emissions from burning biomass that do not meet these criteria must be accounted for in the ETS or the ESD.

Read full policy brief here