The EU’s new LULUCF Regulation: is it fit for (climate) purpose?
By Hanna Aho, Fern’s forest and climate campaigner
For the last three years, Fern has been involved in the debate about the LULUCF Regulation. This prohibitively complex acronym spells out the contribution the EU’s land and forests will make to fighting climate change.
This work came to a conclusion on 17 April 2018 when the EU Parliament adopted the new Regulation. So, what is Fern’s verdict?
At the beginning of our campaign, Fern said the Regulation needed to do four things:
1. Be dedicated only to land use as this would stop it from reducing the EU’s overall ambition (so EU climate action would be part of three separate pillars – the LULUCF Regulation, the EU Emissions Trading System and the Effort Sharing Decision.
2. Improve rules about how to account for carbon fluctuations to make them more honest and transparent about what is going on in forests
3. Fully account for emissions from biomass energy use
4. Set a target to increase the amount of carbon dioxide (CO2) that forests take up (sinks) while maintaining the amount they store (stocks).
Sadly, these objectives have only been partly achieved and the Regulation contains some major deficiencies.
Fern’s verdict on the LULUCF regulation
Firstly, the LULUCF sector continues to be closely linked to the effort sharing sector. This means action on LULUCF can (to a limited extent) be used to offset lack of action to reduce emissions from transport, agricultural and building.
The news is a little better with regards to the second aim - the integrity and transparency of accounting rules have certainly improved. New provisions make accounting for emissions from managed wetlands mandatory and a safeguard should ensure forests and land maintain the amount of CO2 they sequester across the EU until 2030.
The Regulation has, however, failed to provide full transparency on how Member States should set forest management reference levels (the way each country will track changes in its emissions). Measures are taken to ensure the baselines are realistic, but devil is in the details and a strong review process will be necessary to make sure Member States do not cheat and set baselines according to the common target.
Thirdly the accounting for emissions from biomass energy use has improved, but only a part of the emissions will be accounted for. The Regulation will hardly be able to counter the failures of other EU policies, notably the Renewable Energy Directive, that incentivise burning of wood. Member States relying on biomass energy use should remember the negative impacts this has on the forest carbon sink and ensure national energy plans do not threaten the positive role of forests. The LULUCF Regulation is not strong enough to make sure the wood that is used for energy is climate-friendly, so the Renewable Energy Directive must propose other ways to ensure bioenergy reduces CO2 emissions.
Finally, the EU missed the opportunity to set strong enough targets and measures to limit global warming to 1.5˚C.
Nonetheless, the LULUCF regulation is a clear improvement over its predecessor as its aim is to maintain land-use sinks, and it does provide incentives to avoid deforestation.
Scientists and environmental NGOs’ involvement was crucial in securing these improvements and avoiding backsliding. They must remain involved in the national and EU-level conversations about forest management reference levels that will take place later this year. Only then can the Regulation’s robustness and likely climate impacts be fully assessed.
Forested countries fought hard to weaken the EU’s climate ambition
During the negotiations it was disappointing that several forested countries continuously pushed to undermine climate efforts. Estonia, Finland, Sweden and France were the main culprits. They must now rethink their forest policies in light of what is needed to meet the Paris Agreement goals, achieve the aims of the LULUCF Regulation, and stop forests from being destroyed to meet the demand of the growing bioeconomy.
The discussion over increasing sinks and protecting stocks – though seeming technical – is too important to ignore and is not going away. It is now one of the hottest topics in the EU’s 2050 decarbonisation strategy (FW234),
It is also firmly on the international agenda. The leaked version of the Intergovernmental Panel on Climate Change (IPCC) 1.5˚C report emphasises the need for negative emissions (where more CO2 is absorbed than released) and, the only realistic and cost-effective way of achieving that is to protect and restore forests.
Although the LULUCF Regulation is now finalised, the EU has other opportunities to improve its policies, notably during producing its 2050 decarbonisation strategy the Talanoa Dialogue and the Trilogue negotiations on the Governance Regulation (FW 232).