To reach full carbon neutrality in the EU, we need sustainable carbon cycles and a reliable way to certify carbon removals. However, the number one priority must always be to reduce fossil emissions. That entails investing in active forest management and providing more wood-based products to replace fossil resources.
In December 2021, the European Commission adopted a communication on Sustainable Carbon Cycles. It sets out an action plan on how to develop sustainable solutions to increase carbon removals. The communication includes several initiatives, among them to promote carbon farming practices, increase the share of biobased materials and carbon in construction and industry, and an ambition to incentivize carbon removals through Bio-Energy Carbon Capture and Storage (BECCS).
The European Commission believes that to scale up carbon removals, we need to improve the monitoring, reporting and verification of carbon removals. It will, therefore, by the end of 2022 put forward a regulatory framework for the certification of carbon removals.
The Swedish Forest Industries (SFIF) welcomes the initiative for Restoring sustainable carbon cycles and the upcoming legislation for certifying carbon removals.
The Swedish Forest Industries makes the following contribution to the initiative:
- Safeguard that reduction of fossil emissions is priority number one. Impacts of incentives on the availability of renewable raw materials and the development of the bioeconomy must be carefully assessed, including consequences of storing more carbon in forests on fossil dependency.
- Encourage active forest management, balancing all sustainability aspects, increased forest growth and more wood-based products. This way, incentives will be directed both to enhancing forest carbon stock and to the number one priority – reducing fossil emissions.
- Recognize that biodiversity conservation measures and climate mitigation efforts are not necessarily the same, and they both need to be addressed in a strategic and efficient manner in their own right. Setting aside forests for biodiversity conservation is a crucial component of overall forest management but does not provide the best climate change mitigation from forests.
- Prioritise and incentivise BECCS by developing the necessary political and financial framework. Besides certification and accounting, EU financial means for research, innovation, commercialisation and deployment will be needed.
- EU carbon removals certification should:
- Ensure transparency, permanence and that removals are not double counted
- Consider that additionality in forest management is an arbitrary concept, as carbon removals cannot easily be separated from removals resulting from other management goals. It is relevant to measure the full carbon removal from forest management, as reported in LULUCF.
- Consider the difference in nature of the permanent carbon removals from technological solutions, compared to those from carbon farming, which are more uncertain, shorter-time and where the risk of negative externalities and carbon leakage is bigger.
- Be explicit about different types of captured CO2, differentiating fossil and sustainable non-fossil sources of carbon.
- Learn from experience, opportunities, and pitfalls of previous and current schemes for carbon removals.