Familienbetriebe Land und Forst
Die Familienbetriebe Land und Forst vertreten die Interessen von rund 2.000 Betrieben, hinter denen 50.000 Familienmitglieder, Mitarbeiter und Eigentümer stehen.
ID: 784308041110-90
Lobbying Activity
Response to Land use, land use change and forestry – review of EU rules
8 Nov 2021
The Ger. Landowners’ Org.(FABLF)WELCOMES the EC’s efforts to combat clim. change and to pave the way for a transformation towards a greener economy.Nevertheless,WE FEEL OBLIGED TO POINT OUT some structural weaknesses that jeopardise the proposed goals in the EU Green Deal and in the amendment to the LULUCF Reg.2018/841 (draft) as presented on 14.7.21.(1)The draft aims at future CO2 storages within the LULUCF sector.According to the reading of this draft,the only way forward would be to focus on restricting forest management.Unfortunately,the EU BioDivStrat 2030 also takes this - misguided - approach.However,there is scientific evidence that SUSTAIN. MANAGED FORESTS that produce wood as a renewable resource HAVE HIGHER CO2 STORAGE CAPACITIES compared to unmanaged forests,which also extends to long-lived wood products (Opin. attached).In this context, the draft also fails to take into account that the negative impact of clim. change on forests already requires strong efforts of forest owners to maintain their forests and to increase their clim. resilience.Further restrictions will undermine financial capacities to preserve forests.(2)The draft sets the target to store 310 mio. tons of CO2 equi. in the LULUCF-sector by 2030.However,the distribution of this storage on agricultural and forestry is not defined in the draft.It is a necessity of political transparency to be clear about the significance of THE POLITICAL GOALS TO THOSE AFFECTED,and therefore it needs to be made clear how this distribution is planned.(3)The draft aims to merge the agriculture and LULUCF sectors into a new AFOLU-sector by 2035.The AFOLU-sector will aim for clim. neutrality by 2035 and is deemed to be developed into a new CO2 sink to compensate other sectors by 2036.This means that limits of CO2 reduction in other sectors such as industry and energy need to be compensated by farmers and forest owners.It is unfair and unwise to shift the limitations of other sectors in reducing their CO2 emissions onto agriculture and forestry,further complicating the difficult conditions of food and wood production.Nevertheless,if the EU uses agricultural land and forests to compensate the emissions of other sectors,FARMERS&FOREST OWNERS NEED TO BE FINANCIALLY COMPENSATED for their contribution to achieving clim. neutrality.Yet,the draft does not propose any mechanism of compensation at this point.(4)Decreasing forest management in order to increase the storage leads to increasing wood imports from countries outside the EU.The EC itself promotes the use of wood in its Bioec.Strat.&Bauhaus Init.However,decreasing EU forest management in order to increase CO2 storage clearly contradicts these initiatives and the use of wood as a sustainable resource.The draft does not provide a CONVINCING MECHANISM TO AVOID CO2 LEAKAGES from wood imports from outside EU.(5)While forest owners make use of the opportunity to participate in public consultations,and while the EC has occasionally been open to direct communication with forest associations,we feel that our expertise, our suggestions and our interests have not been taken into account in the draft so far.The goals of the draft cannot be reached without the buy-in and without the expertise of our members.Their involvement is key to its success.WE THEREFORE URGE THE EC to revise the draft,(1)in particular to take into account the benefits of managed forests and the efforts and investments needed to maintain the capacity of forest as sinks in the future,(2)to specify the contribution of agricultural areas as CO2 sinks,(3)to further specify the concept of a cross-sectoral CO2 emission and storage compensation and to establish a mechanism to financially reward farmers&forest owners for their contribution to clim. neutrality(4)to define an effective mechanism to prevent carbon leakage through wood imports,and(5)finally, to take into account the expertise and the interests of European forestry associations when further developing the draft.
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