Ecosystem Value Association e.V.
EVA e.V.
Der Zweck des Vereins ist die Förderung von Ökosystemleistungen zur Wiederherstellung und Erhalt natürlicher Ressourcen und zum Erhalt und Ausbau der Leistungsfähigkeit und Klimaresilienz von Ökosystemen.
ID: 520882643615-86
Lobbying Activity
Response to Carbon Removal Certification
2 May 2022
EVA welcomes this initiative and is aligned with its goals to use carbon markets to scale land use climate protection activities within Europe. EVA’s mission is the valorization of ecosystem services through standards and certification. EVA is developing the German Forest Carbon Standard, based on a broad multi-stakeholder dialogue. First carbon removal certificates from German reforestation projects will be traded in the voluntary carbon market by the end of 2022. An “EU Framework for Carbon Removals” will have the potential to create significant ecological and economic benefits if certain principles and quality guidelines are applied.
*PRINCIPLES*
EUROPE'S DIVERSITY
Europe combines many different land-use systems, climatic zones, levels of economy, etc. This diversity is an unique strength and should be supported by all aspects of the EU Framework.
SPEED OF MARKET
Carbon markets develop at a pace where impactful innovation has surpassed any political debates and decisions. Therefore, the EU should not create its own carbon standard. It should rather define a quality framework to accredit existing voluntary carbon standards.
INNOVATION
The land-use sector has an enormous complexity when it comes to carbon accounting. On the other hand, the development of carbon markets has also shown that especially voluntary carbon standards were able to cope with this high complexity due to its diversification on niche markets, market-oriented development, innovative thinking and the application of edge-technologies.
*GUIDELINES*
We see the need to define quality guidelines for carbon standards in the EU to avoid reputational risks for carbon buyers, to provide sufficient security for investors and to create a level-playing field for different carbon standards within the EU. We ask the EU to develop guidelines for the accreditation of carbon standards that include:
SAFEGUARDS
Safeguards for carbon removal activities should be based on existing, long-term proven safeguard standards of the respective sectas. For forestry we suggest using the safeguard standards of FSC and PEFC.
ADDITIONALITY
All climate actions should have the goal to achieve the global 1,5°C target of the Paris Agreement. Thus, any definition of additionality should be linked to achieving this goal. We suggest, coherently to the Science Based Target initiative, that there shall be clearly defined science-based targets for every sector or project activity which serves as threshold for additionality.
ACCREDITATION
To ensure quality, speed and scalability of carbon projects, certification should be done by private testing bodies, which are accredited by national accreditation bodies, like DAkkS in Germany.
PERMANENCE
Since 2007, the voluntary carbon market has proven that its approach of a “permanence buffer” meets the interests of carbon buyers. This should be recognized as a best-practice approach under the EU Framework.
We encourage the EU to allow for a “ton/year accounting system” only after market-demand has been created for these types of credits, e.g. through the EU compliance market and/or EU-wide guidelines for Climate-Contribution-Claims, which would encourage the voluntary market to go beyond its current “compensation-thinking”.
MULTI-STAKEHOLDER-DIALOGUE
The EU Framework should only accredit standards that are developed in a multi-stakeholder-dialogue way, including representation from science, markets, land/forest owners and civil society. These dialogues ensure close to market development, high acceptance and market relevance of standards.
NO DOUBLE COUNTING
The current lack of clear guidance to avoid double counting is a major threat to the success of the voluntary carbon markets. We urge the EU to either establish an easy to use bureaucracy-free system for the issuance of Corresponding Adjustments as foreseen in Art. 6 of the Paris Agreement or to establish a European voluntary carbon market for which Corresponding Adjustments are not needed.
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