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Brazilian Tree Industry

IBÁ

The Brazilian Tree Industry (Ibá) is the association responsible for institutionally representing the planted tree production chain with its main stakeholders.

Lobbying Activity

Meeting with Sabine Weyand (Director-General Trade) and Suzano S.A. and

7 Mar 2024 · Deforestation

Meeting with Bernd Lange (Member of the European Parliament, Committee chair) and Suzano S.A.

5 Mar 2024 · Deforestation

Response to Carbon Removal Certification

6 Mar 2023

1. CONTEXT OF THE PROPOSAL Activities storing CO2 from an ETS installation in a storage site permitted under the CCS Directive are explicitly included in the EU ETS Directive and EU ETS allowances must be surrendered in the event of CO2 leakages. The proposed certification framework will ensure that the quantification of carbon removals for industrial activities such as bioenergy-based CCS (BECCS) and Direct Air Carbon Capture and Storage (DACCS) is in line with the rules set out in the Commission Implementing Regulation (EU) 2018/206613 on the monitoring and reporting of GHG emissions under the ETS and the detailed EU methodologies developed by the Commission for the quantification of GHG emission avoidance of BECCS and DACCS projects under the Innovation Fund Our comment: It is important to clarify to what extent and how the integration between biogenic removals and industrial operations would occur under the ETS, also bearing in mind its roles in the fulfillment of targets and NDCs. 2. LEGAL BASIS, SUBSIDIARITY AND PROPORTIONALITY A European framework would be more appropriate than national initiatives in addressing the difficulty to assess the quality of carbon removals. Such framework would create a level-playing field within the internal market for the certification of carbon removals, enhancing comparability and trust. A patchwork of national initiatives in this area would only exacerbate the problem rather than solving it. Our comment: We suggest the appliance of key parameters already adopted at the IPCC level, including the Good Practice Guidance on LULUCF accounting, taking advantage of previous high-level debates and policy standards regarding the issue. 15) Practices, such as forest monocultures, that produce harmful effects for biodiversity should not be eligible for certification Our comment: It seems that the current text is proposing the exclusion of monocultures from the certification eligibility. The debate regarding the role of monocultures and, especially, the way they are managed has also been developed by a long time in multiple fora. The most stringent forest certification schemes, such as FSC and PEFC, among other sustainable forest management (SFM) practices already represent a widely accepted set of management criteria that ensure the sustainability of monocultures. Excluding monocultures would be contradictory with the intent of the regulation to increase carbon removals activities at scale and in a way that sustainable development is fostered. The point is not about monocultures per se, but the way they are managed. There are several ways to make them sustainable and/or to assess their sustainability. 17) Certification methodologies should, as much as possible, incentivise the generation of co-benefits for biodiversity going beyond the minimum sustainability requirements. These additional co-benefits will give more economic value to the certified carbon removals and will result in higher revenues for the operators. In the light of these considerations, it is appropriate for the Commission to prioritise the development of tailored certification methodologies on carbon farming activities that provide significant co-benefits for biodiversity. Our comment: This is indeed a relevant opportunity. We believe forest certification schemes, such as FSC, PEFC, CCB(Verra) among other sustainable forest management (SFM) practices could be recognized as proper standards capable of covering the intent of the regulation. While the regulation need not be restricted to them and, most likely, will involve a more generic set of standards, such forest management schemes already represent a widely accepted set of management criteria that ensure the co-benefits for biodiversity.
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Meeting with Frans Timmermans (Executive Vice-President) and Confederação da Agricultura e Pecuária do Brasil and

23 Jan 2023 · the EU Deforestation Regulation

Meeting with Anthony Agotha (Cabinet of Executive Vice-President Frans Timmermans)

12 Sept 2022 · Deforestation regulation

Meeting with Gerassimos Thomas (Director-General Taxation and Customs Union)

13 Sept 2021 · Videoconference - Exchange of views on the Commission proposal for a CBAM