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Fern

Fern is a non-governmental organisation monitoring the EU's impact on forests and forest peoples' rights.

Lobbying Activity

Meeting with Kerstin Jorna (Director-General Internal Market, Industry, Entrepreneurship and SMEs) and Transport and Environment (European Federation for Transport and Environment) and

19 Nov 2025 · Exchange of views on raw materials, on the side of the EU Raw Materials Week 2025

Meeting with Kira Marie Peter-Hansen (Member of the European Parliament) and Transport and Environment (European Federation for Transport and Environment) and

17 Nov 2025 · Sustainability omnibus - update for civil society

Meeting with Karin Karlsbro (Member of the European Parliament)

11 Nov 2025 · Liberia-EU Voluntary Partnership Agreement (VPA)

Meeting with Catarina Vieira (Member of the European Parliament)

6 Nov 2025 · FLEGT and Forest partnership Liberia

Meeting with Martin Günther (Member of the European Parliament) and Carbon Market Watch

4 Nov 2025 · Carbon Removals Certification Regulation methodology

Meeting with Karin Karlsbro (Member of the European Parliament)

4 Nov 2025 · Ghana FLEGT Licencing

Meeting with Kira Marie Peter-Hansen (Member of the European Parliament, Shadow rapporteur) and Transport and Environment (European Federation for Transport and Environment) and

3 Nov 2025 · Sustainability omnibus - update for civil society

Meeting with Per Clausen (Member of the European Parliament, Shadow rapporteur)

15 Oct 2025 · Action against environmental omnibuss

Meeting with Per Clausen (Member of the European Parliament)

15 Oct 2025 · Forest protection texts under multiple attacks, Omnibus

Meeting with Humberto Delgado Rosa (Director Environment) and Pro Silva

15 Oct 2025 · Relevance of EU policy to support the targets of preventing deforestation/illegal logging and to ensure maintenance of biodiversity in forests. Deforestation Regulation (EUDR) Nature Restoration Law (NRL) Forest Monitoring Law (FML) proposal

Meeting with Sirpa Pietikäinen (Member of the European Parliament) and Global Witness

8 Oct 2025 · Deforestation Regulation

Meeting with Delara Burkhardt (Member of the European Parliament) and WWF European Policy Programme and

6 Oct 2025 · deforestation

Meeting with Kira Marie Peter-Hansen (Member of the European Parliament, Shadow rapporteur) and Transport and Environment (European Federation for Transport and Environment) and

2 Oct 2025 · Sustainability omnibus - update for civil society

Response to Carbon removals, carbon farming and carbon storage - certification methodologies for permanent carbon removals

22 Sept 2025

We thank the European Commissions DG CLIMA for this additional opportunity to express our concerns about the draft Delegated Act for certifying permanent carbon removals, in particular the methodologies for BioCCS and Biochar. As stated many times within the Expert Group and in subsequent meetings in the past year, the draft methodologies for BioCCS and Biochar do not guarantee that genuine carbon removals from the atmosphere would be achieved, let alone permanently. Built on unscientific bioenergy rules, these methodologies would likely cause even more CO2 emissions and waste scarce public and private capital. Since the carbon credits generated by the use of these methodologies are expected to be used in voluntary offsetting markets and, subsequently, compliance net zero markets such as the EU ETS, the additional emissions caused by the certified activities would worsen, rather than mitigate, the climate crisis. And since the cost of purchasing these carbon offsetting credits will be passed by polluting companies onto consumers, EU citizens will end up paying for a certification and offsetting scheme that creates even more climate damage in the name of climate action. That DG CLIMAs leadership chose to largely ignore these concerns raises questions as to how credible it wants the CRCF to be, and beyond it the EUs Climate Action itself. It is understandable to create a favourable environment for private investors to invest in CDR technology deployment, but not that this deployment would come at the expense of the climate itself. We have already shared our recommendations for limiting the damages caused by the draft methodologies in an analysis that we enclose, and can be consulted here https://www.fern.org/fileadmin/uploads/fern/Documents/2025/Greenwashing_Carbon_Removal.pdf Our main recommendations have not changed as the few improvements brought to the methodologies since then (restriction of eligible feedstocks for biochar, better transparency of biomass use) do not address them. However, a better consistency with RED III Article 3 (3c) (exclusion of saw logs, veneer logs, industrial grade roundwood and roots and stumps from eligible feedstocks for BioCCS and Biochar) could still be achieved, as this article is part of the REDs sustainability framework but not of the REDs sustainability criteria. Overall we would recommend that the European Commission goes back to drafting these methodologies with the aim to exclude from certification any activity that does not lead to genuine carbon removals from the atmosphere in climate relevant timescales (up to five years maximum).
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Environmental NGO Fern Opposes Carbon Credits in EU 2040 Target

15 Sept 2025
Topic — Amendment to European Climate Law establishing EU's 2040 greenhouse gas reduction target.
Message — Fern urges a domestic 90-95% emissions reduction by 2040 without international carbon credits. They call for reduced forest logging and an end to burning wood for energy.123
Why — This would prevent weakening of climate targets and protect forest carbon sinks from degradation.45
Impact — Fossil fuel industries and biomass energy producers lose flexibility to offset emissions cheaply.6
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Fern advocates for inclusive forest partnerships in EU climate strategy

11 Sept 2025
Topic — This consultation shapes the EU’s global climate and energy strategy for the 2025-2029 mandate.
Message — Fern calls for systemic change through inclusive partnerships involving local communities and Indigenous Peoples. They suggest supporting public traceability systems and binding resource reduction targets to move beyond extractivism.123
Why — These proposals would grant NGOs a permanent and influential role in shaping international forest governance.4
Impact — Extractive industries would face significant challenges from mandatory limits on EU resource consumption.5
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Fern warns against taxpayer-funded CO2 transport infrastructure

5 Sept 2025
Topic — This consultation addresses the development of competitive markets and transportation infrastructure for CO2.
Message — Fern opposes building large-scale CO2 infrastructure at taxpayer expense. They argue current carbon removal technologies are unproven and threaten biodiversity.12
Why — This approach prevents the depletion of land carbon sinks.34
Impact — The fossil fuel industry loses its primary justification for continued operation.5
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Meeting with Eric Sargiacomo (Member of the European Parliament, Rapporteur)

4 Sept 2025 · Forêts

Meeting with Pär Holmgren (Member of the European Parliament)

3 Sept 2025 · CAP and EU forest policy

Meeting with Pär Holmgren (Member of the European Parliament, Shadow rapporteur)

27 Aug 2025 · Forest Monitoring Law

Meeting with Matthieu Moulonguet (Cabinet of Commissioner Wopke Hoekstra), Miguel Jose Garcia Jones (Cabinet of Commissioner Wopke Hoekstra) and

27 Aug 2025 · Carbon Farming and Carbon Removal Certification

Meeting with Taru Haapaniemi (Cabinet of Commissioner Christophe Hansen) and WWF European Policy Programme and

17 Jul 2025 · EUDR and its implementation

Fern Urges End to Bioenergy Carbon Price Exemptions

8 Jul 2025
Topic — Review of the EU emissions trading system and market stability reserve.
Message — Fern calls to end the zero-rating of bioenergy emissions. They argue all energy sector CO2 should be counted as precisely as possible.12
Why — This would prevent subsidized forest destruction and help the group achieve biodiversity goals.34
Impact — Bioenergy companies would lose billions in subsidies and struggle to remain profitable.56
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Response to Verification of carbon removals, carbon farming and carbon storage in products

1 Jul 2025

Dear Madam, dear Sir, thank you for this opportunity to contribute to the elaboration of this very important file: as per the CRCF architecture, inspired from the Renewable Energy Directive, certification schemes for carbon removals will have to ensure the compliance with CRCF methodologies of the carbon credits generated by certified activities. The RED has been relying on private certification schemes for a long time and, in that context, the schemes have been exposed multiple times by media and NGOs for their lack of reliability, opacity, conflicts of interest and not enabling proper traceability from the logging site to the use site. Even as we write, EU Member States have started police investigations (under the pressure of their own biofuel producers) into very large imports of fraudulent Used Cooking Oil in the EU that had been certified by the ISCC... despite being virgin palm oil. https://www.transportenvironment.org/articles/uco Similarly, for woody biomass fuels, multiple scandals have plagued the credibility of the Sustainable Biomass Partnership (SBP), notably used by Drax in the UK which was found to have sourced its pellets from primary old growth forests in British Columbia (Canada)... And these pellets were all SBP-certified. https://www.biofuelwatch.org.uk/wp-content/uploads/Drax-in-BC-report.pdf At Fern, we commissioned an expert report into the structural flaws of RED certification schemes, "Mass Imbalance", published last September 2024. https://www.fern.org/publications-insight/mass-imbalance/ This report explained why the RED certification schemes were so weak and likely to generate media scandals. As a matter of fact, they: - were riddled with conflicts of interest, with auditors being directly paid by the companies they audit; - were poorly supervised, when at all; - did not report information that would enable the European Commission and/or Member States to enforce compliance on operators. Many of these problems are structural and derive from the unfortunate political compromises in the regulations which set up these rules. With such a background, we were pleased to read in the draft rules for CRCF certification schemes proposed in this consultation that schemes should have a governance ensuring their independence, impartiality and have "rules and procedures to avoid conflicts of interest". Nevertheless, no definition of "independence" or "conflicts of interests" are proposed. We would suggest that a minimum definition of independence for these schemes should be that they are financially independent from the companies they audit, and that, similarly, conflicts of interest should be defined so as to exclude from these schemes' decision-making roles the financial interests linked to the companies producing the biomass fuels and the companies using them in CDR activities, be it for BioCCS, biochar or others. Both sectors should pay into a public fund, whose managers would in turn blindly and randomly assign auditors to companies, with audits not announced in advance and the auditing costs paid by the fund. This would both deliver better information and a level playing field. Similarly, while we welcome the insistence on transparency, we see that only publishing the information listed in Annex IV, as proposed, would not enable meaningful public and market scrutiny: for this to happen, schemes should also make publicly and freely available the information listed in Annex III, on the content of audit reports, as this information is not business sensitive. It would simply be necessary to edit out the information pertaining to physical persons (for instance on the composition of the auditing team). We look forward to new rules for these schemes that learn from the mistakes done for the RED, and set up a reliable quality standard for carbon removals certification.
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Response to Land use, land use change and forestry - flexibility mechanism related to impacts from natural disturbances

13 Jun 2025

We welcome the opportunity to provide feedback on the proposed Delegated Act under the LULUCF Regulation concerning the mechanism for determining the impacts of natural disturbances. Please find below the following recommendations to strengthen the integrity, comparability, and environmental ambition of the regulation: 1. Ensure a harmonization of areas affected by climate change Allowing Member States (MS) to define and apply their own indices for assessing the impacts of natural disturbances introduces significant risks of inconsistency, reduced transparency, and potential manipulation. Such flexibility undermines the comparability of data across the EU and weakens the robustness of the Union-wide accounting framework. We strongly recommend deleting Article 2(3) and 2(4) to ensure that all MS apply harmonized, scientifically validated methodologies. 2. Raise the threshold for Exceptionally High Proportion of Organic Soils The current threshold of the 90th percentile for defining an exceptionally high proportion of organic soils is too permissive. To preserve the environmental integrity of the mechanism and ensure that only truly extraordinary circumstances qualify for flexibility, we propose raising the threshold to the 99th percentile of the frequency distribution. This change would align the regulation with the principle of using flexibility mechanisms only in rare and extreme cases. 3. Maintain and Promote Geographically Explicit Identification of Affected Areas We support the requirement for geographically explicit identification of areas affected by natural disturbances. This spatial precision is essential for transparency, verification, and effective monitoring of land use impacts. It also facilitates targeted restoration and adaptation measures, contributing to the EUs broader climate and biodiversity goals. 4. Ensure Comparison with Areas of Similar Climate and Soil Type To avoid biased or misleading assessments, it is critical that areas affected by disturbances are compared with reference areas within the same MS that share similar climatic and soil characteristics. This approach ensures that deviations attributed to natural disturbances are not confounded by underlying ecological or geographical differences. We urge the Commission to reinforce this requirement in the final text of the Delegated Act. These recommendations aim to uphold the environmental ambition of the LULUCF Regulation while ensuring fairness, scientific rigor, and consistency across Member States. We appreciate the Commissions efforts to refine the regulatory framework and encourage continued stakeholder engagement in its implementation.
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Meeting with Kathleen Van Brempt (Member of the European Parliament)

28 May 2025 · Women human rights defenders

Meeting with Luis Planas Herrera (Cabinet of Commissioner Jessika Roswall) and WWF European Policy Programme and

27 May 2025 · EUDR

Meeting with Taru Haapaniemi (Cabinet of Commissioner Christophe Hansen) and Pro Silva

22 May 2025 · LIFE funding, opportunities and barriers of closer-to-nature forest management

Meeting with Karin Karlsbro (Member of the European Parliament)

15 May 2025 · VPA FLEGT

Meeting with Saskia Bricmont (Member of the European Parliament)

15 May 2025 · Respect des droits humains dans les accords de libre échange

Meeting with Lynn Boylan (Member of the European Parliament)

15 May 2025 · Implementation of the EU Deforestation Regulation

Meeting with Luis Planas Herrera (Cabinet of Commissioner Jessika Roswall)

14 May 2025 · The Regulation on Deforestation-free Products (EUDR)

Meeting with Christophe Hansen (Commissioner) and

30 Apr 2025 · Sustainable Protein Diversification for the Vision

Meeting with Eric Sargiacomo (Member of the European Parliament, Rapporteur)

11 Mar 2025 · Forêts

Meeting with Karin Karlsbro (Member of the European Parliament) and Human Rights Watch and Earthsight

4 Mar 2025 · Avskogningsförordningen

Meeting with Alisa Tiganj (Cabinet of Commissioner Christophe Hansen) and Bureau Européen des Unions de Consommateurs and

25 Feb 2025 · Vision for Agriculture & Food Exchange of views on the Vision on agriculture and food, in particular aspects related to the “food” aspects.

Meeting with Martin Häusling (Member of the European Parliament)

18 Feb 2025 · Meeting on EU action on diets & nutrition

Meeting with Stine Bosse (Member of the European Parliament)

17 Feb 2025 · European forestry policy

Fern urges more detailed forest restoration reporting standards

7 Feb 2025
Topic — This consultation concerns the uniform format for national nature restoration plans.
Message — The organization calls for a dedicated section for forest restoration strategies and Annex VII measures. They want member states to clearly link farming subsidies to specific restoration targets. The format must guarantee early and inclusive public participation during plan development.123
Why — Stricter reporting formats ensure that forest restoration is scientifically grounded and legally compliant.4
Impact — Member states face more complex reporting tasks to link funding to specific outcomes.5
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Meeting with César Luena (Member of the European Parliament)

4 Feb 2025 · Healthy and sustainable food

Meeting with Peter Liese (Member of the European Parliament) and Eurogroup for Animals and

29 Jan 2025 · Austausch

Meeting with Lynn Boylan (Member of the European Parliament)

28 Jan 2025 · EU Voluntary Partnership Agreements

Meeting with Martine Kemp (Member of the European Parliament)

28 Jan 2025 · Delegation West-Central Africa on EU Partnerships on forests

Meeting with Karin Karlsbro (Member of the European Parliament, Rapporteur)

28 Jan 2025 · Forest governance and logging

Meeting with Ricard Ramon I Sumoy (Acting Head of Unit Agriculture and Rural Development) and Bureau Européen des Unions de Consommateurs and

28 Jan 2025 · Exchange of views on issue considered relevant by the organisations on the Vision of agriculture and food, under preparation; in particular the food aspects.

Meeting with Sigrid Friis (Member of the European Parliament)

8 Jan 2025 · Forest Monitoring Law

Meeting with Ville Niinistö (Member of the European Parliament)

16 Dec 2024 · Upcoming 2040 climate legislation

Meeting with Erik Marquardt (Member of the European Parliament)

12 Dec 2024 · Exchange on deforestation/ development cooperation

Meeting with Catarina Vieira (Member of the European Parliament)

12 Dec 2024 · EU-Cameroon

Meeting with Lynn Boylan (Member of the European Parliament)

4 Dec 2024 · EU Deforestation Regulation; Biomass in the Renewable Energy Directive; Carbon Removal Certifications

Meeting with Per Clausen (Member of the European Parliament, Shadow rapporteur) and Stichting BirdLife Europe

3 Dec 2024 · Meeting on the ongoing negotiations on the Forest Monitoring file

Meeting with Eric Sargiacomo (Member of the European Parliament, Rapporteur)

20 Nov 2024 · Gouvernance des forêts

Meeting with Pascal Arimont (Member of the European Parliament)

5 Nov 2024 · Forest Monitoring Law

Meeting with Cristina Guarda (Member of the European Parliament)

22 Oct 2024 · Forests

Meeting with Marie Toussaint (Member of the European Parliament) and WWF European Policy Programme and

15 Oct 2024 · deforestation

Meeting with Maria Ohisalo (Member of the European Parliament) and Suomen luonnonsuojeluliitto - The Finnish Association for Nature Conservation

15 Oct 2024 · Conservation

Meeting with Peter Van Kemseke (Cabinet of President Ursula von der Leyen)

9 Oct 2024 · EUDR (NGOs)

Meeting with César Luena (Member of the European Parliament)

4 Oct 2024 · Forest

Meeting with Michal Wiezik (Member of the European Parliament)

26 Sept 2024 · EUDR compliance in Côte d'Ivoire cocoa sector

Meeting with Grégory Allione (Member of the European Parliament)

25 Sept 2024 · Réunion FERN

Meeting with Martin Häusling (Member of the European Parliament)

24 Sept 2024 · Exchange on the forest files

Meeting with Delara Burkhardt (Member of the European Parliament) and WWF European Policy Programme and

18 Sept 2024 · EUDR

Meeting with Marie Toussaint (Member of the European Parliament)

5 Sept 2024 · deforestation

Meeting with Peter Liese (Member of the European Parliament)

28 Aug 2024 · Waldpolitik

Fern warns forest decline puts EU climate targets at risk

11 Jul 2024
Topic — Evaluation of EU regulations governing carbon removals from land and forestry sectors.
Message — Fern urges ending wood burning incentives and prioritizing natural forest restoration. They demand stricter enforcement against Member States failing to protect carbon sinks.123
Why — Strengthening these rules helps the NGO meet its objective of forest preservation.4
Impact — The bioenergy and paper industries would lose lucrative incentives for wood-based products.56
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Meeting with Peter Van Kemseke (Cabinet of President Ursula von der Leyen)

23 May 2024 · Forest policy

Meeting with Helena Braun (Cabinet of Vice-President Maroš Šefčovič)

23 May 2024 · Presentation on Focus Group findings on rural attitudes to European forests

Meeting with Taru Haapaniemi (Cabinet of Commissioner Janusz Wojciechowski)

14 May 2024 · Focus Group findings - European forests key to wellbeing and stability

Meeting with Eglantine Cujo (Cabinet of Commissioner Virginijus Sinkevičius), Elena Montani (Cabinet of Commissioner Virginijus Sinkevičius)

13 May 2024 · Meeting with FERN on the results of the focus group on rural attitudes to forests and the EU

Meeting with Marie Toussaint (Member of the European Parliament)

2 Apr 2024 · deforestation regulation and attacks on the implementation of the text

Meeting with Barry Andrews (Member of the European Parliament)

20 Mar 2024 · EU-Mercosur / EU Deforestation Regulation

Meeting with Maroš Šefčovič (Executive Vice-President) and European farmers and

14 Mar 2024 · High level dialogue on forest-based bioeconomy

Response to New EU Forest Monitoring and Strategic Planning Framework

6 Feb 2024

To whom it may concern, We welcome the proposal of regulation on a monitoring framework for resilient European forests (forest monitoring law, FML). We see it as a building block in ensuring implementation of EU climate and biodiversity objectives as well as contributing to socio-economic resilience and ecosystem resilience in forests in times of fragility. Relying only on unharmonized and uneven quality data jeopardises our ability to make progress and limits the EUs potential to protect its forests. The main shortcomings of the proposal are the lack of some relevant indicators and the failure to make strategic plans mandatory.. Improvements needed to indicators Include forest carbon stock in the list of indicators as this is one that the Nature Restoration Law (NRL) Article 10 will need to monitor. Indicator related to forest habitats within and outside of Natura 2000 should be included in Article 5 requirements as their definition and methodology requires no further development. Shortening the timeline to report on the location of European old growth forest and complementing it with indicators that are not dependent on the current narrow definition of old growth forests Complimenting the indicator on connectivity with a forest integrity index that combines the ecological state of the forest with connectivity. Including indicators on the state and trends of species in a forest. Adding indicators on forest soil and hydrology to follow the trends in these fronts. Monitoring wood flows and economic metrics. Improvements needed to Strategic Plans The strategic plans are currently foreseen to be voluntary. We believe they should be mandatory. Furthermore, to add weight on the strategic plans, we suggest making national strategic plans a precondition for accessing EU funds or a condition for national programs requiring state aid approval. Strategic plans must be developed inclusively, consulting all the stakeholders. They need to include specific measures to address unwanted trends in a scientifically sound manner. Included stakeholders The oversight of both, the data collection and developing strategic plans, should not lay in the hands of member states alone. The independent expertise of national agencies, research institutes, NGOs, competent authorities and international institutions should be at the centre of co-decision, implementation and review processes. Our more detailed observations and suggestions can be found at: https://www.fern.org/fileadmin/uploads/fern/Documents/2024/How_could_European_forests_best_benefit_from_the_EU_Forest_Monitoring_Law.pdf
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Meeting with Heidi Hautala (Member of the European Parliament, Shadow rapporteur) and Deutsche Gesellschaft für Internationale Zusammenarbeit (GIZ) GmbH and FERRERO International

1 Feb 2024 · EU Cocoa Talks panel discussion

Fern urges coal heater ban and tougher wood stove standards

13 Dec 2023
Topic — EU review of environmental performance rules for solid fuel space heaters.
Message — Fern calls for a ban on coal heaters and mandatory pollution-cutting technologies like catalytic converters. They demand stricter emission limits for wood stoves and testing methods that reflect real-world usage. They also advocate for automated air regulation and measures to prevent indoor air pollution.123
Why — Stricter rules would help protect forests and reduce climate-damaging biomass burning.4
Impact — Manufacturers of cheap heaters would lose sales due to bans and higher costs.56
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Fern urges stricter emission standards for solid fuel boilers

13 Dec 2023
Topic — The consultation reviews energy labelling and ecodesign rules for solid fuel boilers.
Message — Fern calls for banning coal heaters and requiring automated air regulation. They also demand stricter limits on pollutants like particulate matter and black carbon.123
Why — This proposal aligns with Fern's goal to protect forests from excessive harvesting.45
Impact — Boiler manufacturers and low-income households may face significantly higher equipment costs.67
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Meeting with Mick Wallace (Member of the European Parliament, Shadow rapporteur)

17 Nov 2023 · Carbon offsetting

Meeting with Pascal Canfin (Member of the European Parliament) and European Environmental Bureau and

16 Nov 2023 · Green Deal

Meeting with Ville Niinistö (Member of the European Parliament, Shadow rapporteur) and Climate Action Network Europe and Carbon Market Watch

6 Nov 2023 · Carbon removals

Meeting with Nils Torvalds (Member of the European Parliament, Shadow rapporteur) and Cosmetics Europe

7 Sept 2023 · PPWR

Meeting with Jessica Polfjärd (Member of the European Parliament)

7 Sept 2023 · PPWR

Meeting with César Luena (Member of the European Parliament) and DS Smith

7 Sept 2023 · PPWR

Meeting with Delara Burkhardt (Member of the European Parliament, Shadow rapporteur)

6 Sept 2023 · Packaging Waste

Fern Urges EU to Exclude BECCS From Carbon Strategy

31 Aug 2023
Topic — The EU is consulting on strategies for deploying carbon capture, transport, and storage infrastructure.
Message — Fern argues that BECCS should be excluded because it remains unproven at scale and creates significant carbon debt. They recommend reserving scarce storage sites specifically for hard-to-abate industrial sectors.12
Why — This approach would protect forest biodiversity and prevent land-use competition from industrial biomass production.34
Impact — The bioenergy and fossil fuel industries lose subsidies and the social license for combustion-based energy.5
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Response to Review report on the Governance Regulation of the Energy Union and Climate Action

10 Jul 2023

The Governance Regulation is an essential item in the EU's climate policy toolbox, but has suffered from serious implementation issues when it came to complying with forest biomass reporting obligations so far. While the EU's renewable energy and carbon market legislation provide very significant market incentives for using wood for energy, which re-emits all the carbon contained in the wood as CO2 in the atmosphere, the Commission so far does not seem to have taken seriously its duty to remind Member States of their solid biomass reporting obligations under the Governance Regulation. Research we commissioned on how Member States were reporting their use of forest biomass in their NECPs (see https://www.fern.org/fileadmin/uploads/fern/Documents/2021/Fern_-_Biomass_in_NECPs_-_Final_report.pdf ) shows that: - there are significant deficiencies in the information Member States provided on biomass supply and feedstocks and, especially, on the sourcing of forest biomass and its LULUCF impact: fewer than half of the NECPs provided sufficient information. Better distinction between solid biomass and other bioenergies in the NECPs, in particular, would improve transparency and their usefulness. - In terms of planned measures for biomass, consideration and information on whether biomass availability and its uses and sustainability measures were taken into account was assessed to be generally poorly addressed. Whilst 18 of 24 MS had planned measures for biomass, only 8 or 9 clearly took into account biomass availability and sustainability. - The impact of planned measures was modelled in the NECPs but it is usually not possible to separate out the impacts of specific technologies or policies to assess the specific impact from biomass or biomass-related measures. Separating these dimensions would be particularly useful to identify potential positive or negative impacts of biomass, e.g. potential negative impacts on air quality. For the proper impact of forest biomass use on national carbon sinks, biodiversity, air quality... to be understood, it is essential that the reporting is seriously improved, and adequate resources given to national administrations to perform this task.
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Meeting with Kathleen Van Brempt (Member of the European Parliament)

29 Jun 2023 · Trade relations with Mercosur, deforestation and climate issues in international trade

Meeting with Ville Niinistö (Member of the European Parliament, Shadow rapporteur)

28 Jun 2023 · Carbon removals

Meeting with Jorge Pinto Antunes (Cabinet of Commissioner Janusz Wojciechowski)

19 Jun 2023 · Low carbon, high risk - Lessons for the EU from Label Bas-Carbone forestry projects in France

Meeting with Delara Burkhardt (Member of the European Parliament, Shadow rapporteur)

8 Jun 2023 · Packaging

Meeting with Michal Wiezik (Member of the European Parliament)

7 Jun 2023 · Paper packaging induced deforestation: Case of Indonesia

Meeting with Tiemo Wölken (Member of the European Parliament, Shadow rapporteur) and Carbon Market Watch and Ecologic Institute

30 May 2023 · Event on "The CRCF and the EU climate targets: Opportunities and shortcomings"

Meeting with Marie Toussaint (Member of the European Parliament) and Greenpeace European Unit and

27 Apr 2023 · follow up on deforestation file

Meeting with Helena Braun (Cabinet of Executive Vice-President Frans Timmermans)

25 Apr 2023 · European Green Deal and forest related initiatives

Fern demands ban on carbon offsets in EU certification

22 Mar 2023
Topic — A proposed regulatory framework to monitor and certify the authenticity of carbon removal activities.
Message — Fern demands a ban on carbon offsets and a shift toward activity-based certification. They want strict environmental criteria and the exclusion of emission reductions from the framework.12
Why — This would secure direct funding for restorative farming practices rather than administrative carbon monitoring.3
Impact — Carbon market intermediaries and industrial lobbies lose their financial and regulatory grip on certification.45
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Meeting with Karen Melchior (Member of the European Parliament, Shadow rapporteur for opinion)

20 Mar 2023 · Discussion and policy paper handover: logistics of paper production and impact on global forests. Need to keep production in Europe and set sustainabile level of recollection and recycling in order to make sustainable paper production in Europe.

Meeting with Pär Holmgren (Member of the European Parliament, Shadow rapporteur for opinion)

15 Mar 2023 · Carbon Removal Certification

Meeting with Heidi Hautala (Member of the European Parliament, Shadow rapporteur)

9 Mar 2023 · EU Deforestation Regulation

Meeting with Anja Hazekamp (Member of the European Parliament)

8 Mar 2023 · Mercosur

Meeting with Kathleen Van Brempt (Member of the European Parliament)

7 Mar 2023 · Deforestation and update on the ongoing negotiations on the EU Mercosur Agreement

Meeting with Suvi Leinonen (Cabinet of Commissioner Jutta Urpilainen)

7 Mar 2023 · EU regulation on deforestation-free products

Meeting with Helena Braun (Cabinet of Executive Vice-President Frans Timmermans) and Skydda Skogen

2 Mar 2023 · Stakeholder’s views on nature restoration law proposal and expectations to the upcoming forest monitoring proposal

Meeting with Elena Montani (Cabinet of Commissioner Virginijus Sinkevičius) and Skydda Skogen

2 Mar 2023 · Stakeholder’s views on nature restoration law proposal and expectations to the upcoming forest monitoring proposal

Meeting with Emma Wiesner (Member of the European Parliament) and Swedish Society for Nature Conservation

1 Mar 2023 · Paneldiskussion skogspolitik

Meeting with Ville Niinistö (Member of the European Parliament, Shadow rapporteur)

13 Feb 2023 · RED staff level

Meeting with Tiemo Wölken (Member of the European Parliament, Shadow rapporteur for opinion) and Partnership for Policy Integrity

26 Jan 2023 · Biomass Sustainability Criteria (Staff Level)

Meeting with Heidi Hautala (Member of the European Parliament, Rapporteur)

24 Jan 2023 · Sustainable cocoa supply chains

Meeting with Marina Mesure (Member of the European Parliament)

29 Nov 2022 · Forêts

Meeting with Marie Toussaint (Member of the European Parliament, Shadow rapporteur) and Greenpeace European Unit and

23 Nov 2022 · deforestation

Meeting with Arunas Ribokas (Cabinet of Commissioner Virginijus Sinkevičius) and WWF European Policy Programme and

10 Nov 2022 · the EU forest policy, including on biomass

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

3 Nov 2022 · Deforestation Regulation

Meeting with Tiemo Wölken (Member of the European Parliament, Shadow rapporteur for opinion) and Partnership for Policy Integrity

26 Oct 2022 · RED

Meeting with Marie Toussaint (Member of the European Parliament, Shadow rapporteur) and Greenpeace European Unit and

26 Oct 2022 · deforestation

Meeting with Martin Hojsík (Member of the European Parliament)

12 Sept 2022 · Renewable energy directive

Meeting with Sara Cerdas (Member of the European Parliament) and ClientEarth AISBL and

6 Sept 2022 · Desflorestação

Meeting with Marie Toussaint (Member of the European Parliament, Shadow rapporteur) and Greenpeace European Unit and

2 Sept 2022 · deforestation

Meeting with Tiemo Wölken (Member of the European Parliament, Shadow rapporteur for opinion)

30 Aug 2022 · Erneuerbaren Energien-Richtlinie (RED)

Meeting with Michal Wiezik (Member of the European Parliament) and ClientEarth AISBL and Global Witness

5 Jul 2022 · Imported Deforestation Regulation

Meeting with Helena Braun (Cabinet of Executive Vice-President Frans Timmermans), Lukas Visek (Cabinet of Executive Vice-President Frans Timmermans), Stefanie Hiesinger (Cabinet of Executive Vice-President Frans Timmermans)

23 Jun 2022 · Carbon removal certification

Meeting with Helena Braun (Cabinet of Executive Vice-President Frans Timmermans), Lukas Visek (Cabinet of Executive Vice-President Frans Timmermans), Stefanie Hiesinger (Cabinet of Executive Vice-President Frans Timmermans)

23 Jun 2022 · Discussion on the Commission’s work on stimulating sustainable carbon cycles

Meeting with Jorge Pinto Antunes (Cabinet of Commissioner Janusz Wojciechowski)

22 Jun 2022 · To discuss the piece of work the EU is embarking on to stimulate sustainable carbon cycles

Meeting with Ville Niinistö (Member of the European Parliament, Rapporteur) and European Environmental Bureau and

2 Jun 2022 · LULUCF (staff level)

Meeting with Delara Burkhardt (Member of the European Parliament, Shadow rapporteur) and Earthsight

11 May 2022 · deforestation

Fern calls for unified EU forest monitoring and planning

6 May 2022
Topic — The EU initiative develops an observation framework for forest condition and management information.
Message — Fern requests harmonised national inventories to ensure objective assessments of biodiversity and carbon. They demand clear indicators and thresholds to define sustainable management and increase transparency. Strategic plans are needed to address climate and biodiversity risks over the next decade.123
Why — Transparent data would stop NGOs from needing to manually reconstruct inaccessible databases.4
Impact — Managers using clearcutting would lose the ability to label destructive practices as sustainable.5
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Meeting with Ville Niinistö (Member of the European Parliament, Rapporteur) and Climate Action Network Europe

22 Apr 2022 · LULUCF (staff level)

Meeting with Marie Toussaint (Member of the European Parliament, Shadow rapporteur) and WWF European Policy Programme and

4 Apr 2022 · deforestation

Meeting with Marie Toussaint (Member of the European Parliament, Shadow rapporteur) and WWF European Policy Programme and

18 Mar 2022 · deforestation

Meeting with Marie Toussaint (Member of the European Parliament, Shadow rapporteur) and WWF European Policy Programme and

15 Mar 2022 · deforestation

Meeting with Marie Toussaint (Member of the European Parliament, Shadow rapporteur) and WWF European Policy Programme and

23 Feb 2022 · deforestation

Meeting with Marie Toussaint (Member of the European Parliament, Shadow rapporteur)

11 Feb 2022 · deforestation

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

8 Feb 2022 · Deforestation file

Response to Act amending Implementing Regulation (EU) 2018/2066 on the monitoring and reporting of greenhouse gas emissions

11 Jan 2022

We are grateful for the opportunity to comment on the Commission’s Implementing Regulation amending Article 38 of the MMR Regulation on the zero-rating of biomass emissions. While current EU policy indeed considers biomass emissions to be zero, this policy could not be more at odds with the climate crisis context in which we are. Woody biomass emissions’ zero-rating is an indirect but very effective incentive for energy companies, making it more and more competitive against other combustion-based energy sources as carbon prices rise. This is a terrible policy for forests and the climate, and it must be ended as soon as possible. At the point of combustion, woody biomass has the highest GHG emissions by unit of energy produced of all fuels: how can it be a beneficial substitute for fossil fuels? Enabling EU Member States to incentivize its use accelerates the destruction of forests in Europe and all over the world, undermining their role as carbon stocks and sinks, their resilience, and wiping out the biodiversity they harbour. This is a fact many scientists, NGOs and the media have been abundantly criticizing and reporting since the bioenergy industry started its tremendous growth, driven by EU policy incentives. On the other hand, the supposed climate benefits of woody biomass are very uncertain, relying on false or shaky assumptions and modelling (payback times for instance are not even mentioned in relevant EU legislation, despite being central to the relevant work of the EU's Joint Research Centre (1) and in published, peer-reviewed science on the matter). Incentivising woody biomass also distorts the wood market, to the detriment of other wood-using sectors whose products store carbon rather than releasing it into the atmosphere. From that perspective, we would like to support the Commission’s suggestion that, given the “need for alignment of bioenergy policies with other environmental objectives”, Member States “should therefore take into consideration the available sustainable supply of biomass for energy and non-energy uses and the maintenance of the national forest carbon sinks and ecosystems as well as the principles of the circular economy and the biomass cascading use, and the waste hierarchy established in Directive 2008/98/EC of the European Parliament and of the Council on waste” when looking at biomass emissions regulations. We also support the Commission’s suggestion that Member States “use market-based instruments and tools such as taxation at their disposal in order to ensure that the use of unsustainable biomass in the ETS sectors are discouraged to avoid negative environmental impacts.” But we do not agree with the Commission’s suggestion that current delays in the transposition of REDII by Member States, and the delays in the adoption of certain implementing and delegated acts on REDII should mean that a one-year exemption should be granted to allow the bioenergy industry to keep applying the current policy of rating as zero all biomass emissions. In fact, the opposite should happen, given that the non-adoption of the delegated act specifying the implementation of REDII’s sustainability criteria for forest biomass has been largely caused by the obstruction of the bioenergy industry and its allies among certain governments. Such a decision would unfairly reward these stakeholders’ irresponsible defense of the status quo. We would encourage the Commission to send the right signal to investors already today: close the “zero rating” loophole for woody biomass emissions, and, given the absolute need for the EU to reduce its carbon emissions in the short and medium term, treat the carbon content of woody biomass in the same way as fossil carbon. There are many cleaner alternatives to fossil fuels than woody biomass. Kind regards (1) https://publications.jrc.ec.europa.eu/repository/bitstream/JRC122719/jrc-forest-bioenergy-study-2021-final_online.pdf
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Meeting with Ville Niinistö (Member of the European Parliament, Rapporteur)

6 Dec 2021 · LULUCF

Meeting with Jorge Pinto Antunes (Cabinet of Commissioner Janusz Wojciechowski) and WWF European Policy Programme and

9 Nov 2021 · Forestry

Meeting with Ville Niinistö (Member of the European Parliament, Rapporteur)

4 Nov 2021 · LULUCF (staff level)

Meeting with Eglantine Cujo (Cabinet of Commissioner Virginijus Sinkevičius)

29 Oct 2021 · Meeting with representatives of indigenous people from Brazil to discuss upcoming COM legislative proposal on deforestation

Meeting with Anthony Agotha (Cabinet of Executive Vice-President Frans Timmermans), Helena Braun (Cabinet of Executive Vice-President Frans Timmermans) and

7 Oct 2021 · EU action on tackling global deforestation

Meeting with Ville Niinistö (Member of the European Parliament, Rapporteur)

30 Sept 2021 · LULUCF

Meeting with Diederik Samsom (Cabinet of Executive Vice-President Frans Timmermans), Helena Braun (Cabinet of Executive Vice-President Frans Timmermans) and Naturschutzbund Deutschland e.V.

20 Jul 2021 · Bioenergy

Meeting with Jorge Pinto Antunes (Cabinet of Commissioner Janusz Wojciechowski)

2 Jul 2021 · Renewable Energy Directive and Forestry

Meeting with Stefanie Hiesinger (Cabinet of Executive Vice-President Frans Timmermans)

21 Jun 2021 · Discussion on the NGO’s detailed position on the LULUCF file as well as exchange of views on interactions with the EU Climate Law

Meeting with Kurt Vandenberghe (Cabinet of President Ursula von der Leyen) and Världsnaturfonden WWF (WWF Sweden)

16 Jun 2021 · Discuss RED forest biomass sustainability criteria

Meeting with Filip Alexandru Negreanu Arboreanu (Cabinet of Commissioner Adina Vălean)

8 Jun 2021 · Renewable Energy Directive and REDII forest biomass criteria

Meeting with Andrea Beltramello (Cabinet of Executive Vice-President Valdis Dombrovskis), Caroline Boeshertz (Cabinet of Executive Vice-President Valdis Dombrovskis) and

7 Jun 2021 · Renewable Energy Directive (RED II) review

Meeting with Camilla Bursi (Cabinet of Commissioner Virginijus Sinkevičius)

7 Jun 2021 · Revisions on RED II and bioenergy sustainability criteria

Meeting with Isabelle Perignon (Cabinet of Commissioner Didier Reynders)

31 May 2021 · presentation by FERN on their views regarding Renewable Energy Directive (RED) II forest biomass criteria

Meeting with Laure Chapuis (Cabinet of Commissioner Kadri Simson)

26 May 2021 · Biomass external costs / revision Energy Taxation Directive.

Meeting with Jorge Pinto Antunes (Cabinet of Commissioner Janusz Wojciechowski) and WWF European Policy Programme and

19 May 2021 · Forests, climate and biodiversity

Meeting with Virginijus Sinkevičius (Commissioner) and

12 May 2021 · To discuss the Renewable Energy Directive (RED II), in particular from the bioenergy angle, and the upcoming Forest Strategy.

Meeting with Eglantine Cujo (Cabinet of Commissioner Virginijus Sinkevičius) and WWF European Policy Programme and

7 May 2021 · Discussion about Commission's legislative proposal on deforestation and forest degradation

Meeting with Andrea Beltramello (Cabinet of Executive Vice-President Valdis Dombrovskis), Caroline Boeshertz (Cabinet of Executive Vice-President Valdis Dombrovskis) and

7 May 2021 · Deforestation

Meeting with Diana Montero Melis (Cabinet of Commissioner Jutta Urpilainen) and WWF European Policy Programme and

30 Apr 2021 · upcoming regulation on deforestation

Meeting with Jorge Pinto Antunes (Cabinet of Commissioner Janusz Wojciechowski) and WWF European Policy Programme and

29 Apr 2021 · Deforestation and forest degradation.

Environmental NGO Fern Calls EU Forest Biomass Guidelines Insufficient

28 Apr 2021
Topic — EU operational guidance on sustainability criteria for forest biomass under renewable energy rules.
Message — Fern urges the EU to exclude primary forest biomass from energy use and strengthen verification requirements. They argue current guidelines allow destructive harvesting practices that are technically legal but harm climate and biodiversity.12
Why — This would advance their mission to protect forests from harmful EU bioenergy policies.34
Impact — The bioenergy industry loses access to primary forest biomass and faces stricter verification costs.5
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Meeting with Frans Timmermans (Executive Vice-President) and Transport and Environment (European Federation for Transport and Environment) and

19 Apr 2021 · Foreseen review of the renewable energy directive and use of forest biomass for energy production

Meeting with Ditte Juul-Joergensen (Director-General Energy) and Transport and Environment (European Federation for Transport and Environment) and

14 Apr 2021 · Videoconference discussion on the use of biomass for energy, especially forest biomass, and on transport biofuels.

Meeting with Riccardo Maggi (Cabinet of Executive Vice-President Frans Timmermans) and WWF European Policy Programme and

13 Apr 2021 · Preparation for the meeting with EVP Timmermans

Meeting with Stefanie Hiesinger (Cabinet of Executive Vice-President Frans Timmermans)

2 Mar 2021 · Discussion on Fern’s position on the future of the LULUCF regulation

Meeting with Helena Braun (Cabinet of Executive Vice-President Frans Timmermans)

19 Feb 2021 · EU 2030 Biodiversity Strategy and forest related initiatives, including the EU Forest Strategy

Meeting with Agne Razmislaviciute-Palioniene (Cabinet of Commissioner Virginijus Sinkevičius)

2 Feb 2021 · How bioenergy impacts forests

Meeting with Laure Chapuis (Cabinet of Commissioner Kadri Simson)

1 Feb 2021 · Revision RED 2, biodiversity, bioenergie

Meeting with Andrea Beltramello (Cabinet of Executive Vice-President Valdis Dombrovskis), Cristina Rueda Catry (Cabinet of Executive Vice-President Valdis Dombrovskis)

15 Jan 2021 · Sustainable cocoa initiative; deforestation and forest degradation

Meeting with Diana Montero Melis (Cabinet of Commissioner Jutta Urpilainen)

15 Jan 2021 · sustainable cocoa initiative; deforestation and forest degradation (meeting organized by CAB EVP Dombrovskis)

Response to Climate change mitigation and adaptation taxonomy

18 Dec 2020

BIOENERGY Our input for the public consultation applies to the following sections of the draft Delegated Act: 4.8. Electricity generation from bioenergy 4.13. Manufacture of biogas and biofuels for use in transport 4.20. Cogeneration of heat/cool and power from bioenergy 4.24. Production of heat/cool from bioenergy We are extremely concerned that the draft DA has chosen to accept that all forest biomass - wood sourced directly from forests - may be burned as feedstocks and that almost any activity that is aligned with the flawed Renewable Energy Directive is counted as sustainable, including the use of dedicated cropland. This is completely unscientific and we urge the Commission to improve this. The draft currently contradicts all recent authoritative scientific research and the Commission’s own impact assessment on bioenergy, which stated that the idea that forest biomass can mitigate climate change is extremely problematic and acknowledged that demand for forest biomass is hindering EU forests’ ability to act as a carbon sink. Separately, 100 civil society groups have called for an end to subsidies and other incentives for burning all forest biomass. When comparing the draft DA with the TEG recommendations on bioenergy, we conclude the following: Although the TEG likely intended to strengthen biomass criteria, the wording the expert group came up with didn't achieve that aim. In practical terms, its effect would have been absolutely no different than the effect of the text in the draft DA. Our analysis is that there's no practical/legal difference between the TEG recommendations about energy from wood on the one hand and the recommendations in the Draft DA on the other hand. They basically mean exactly the same thing, even if members of the TEG had intended something else. It is crucial for the draft DA to be improved on this topic, but not on the basis of the TEG recommendations as that would be just a matter of textual adjustment without making any difference in practice (not for people, nor for the environment). The Commission should either reverse its decision to classify the burning of logged forest biomass for energy as renewable and/or adopt criteria that exclude harmful feedstocks (roundwood, stumps, purpose-grown crops), and only allow the most optimal uses in terms of conversion efficiency and in those sectors with fewer alternatives for decarbonisation (i.e. restricting role solid biomass in heat and power). Forestry The draft taxonomy uses the FAO definition for forests, which does not make a distinction between natural forests and (monoculture) tree plantations. The latter have a strong, negative impact on biodiversity and have a potential high opportunity cost, as land used for monoculture tree plantations could also be used for the regeneration of natural ecosystems, which capture and store more carbon than the plantations that are harvested in cycles. The draft DA would allow activities such as short-term rotation below 20 years, which is not compatible with climate goals. Short-term rotation usually employs the wrong type of trees without considering existing forest / tree structures / sustainable biomass use. The DA does not provide sufficient safeguards to prevent this. It should also specify that carbon storage must include carbon below and above ground. The former is usually neglected. Finally, afforestation or reforestation of forests is insufficient to replace forests lost to deforestation or which are highly degraded. The Commission, and the taxonomy, should focus on protecting existing natural forests, restoring and enriching biodiversity as well as the carbon storage potential to generate forests that are resilient.
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Meeting with Jorge Pinto Antunes (Cabinet of Commissioner Janusz Wojciechowski)

8 Dec 2020 · To discuss a newly published paper ‘State aid for solid biomass: The case for improved scrutiny’.

Response to EU Forest Strategy

4 Dec 2020

“European forests are under pressure.” Two major reports released this year reinforce this statement. The European Environmental Agency’s (EEA) 5-year report on the state of the European environment and the ecosystem assessment from the Joint Research Centre (JRC) to support evaluation of the Biodiversity Targets. Both show that the trend towards land being degraded by agriculture and forestry practices is worsening. Just under 85 per cent of forests under the Habitats Directive are in poor health and pressures on forests are increasing, including climate change and logging. Over two thirds of European forests are exposed to three or more drivers of degradation. The EU forest area increased between 1990 and 2015 due to active afforestation and natural processes. But as the above reports show, more forest area does not necessarily mean healthier and more biodiverse forests. After millennia of forest use, currently only between two and four per cent of EU forests are primary and old-growth. And EU policy does not plan to reverse this picture. National Energy and Climate plans reveal that Member States plan to increase forest biomass for energy, and that around a third of the 2005 EU carbon sink could be lost by 2030 - primarily from forest management. A recent report by Greenpeace found that burning wood is the biggest driver of increased harvests, indicating harvests for energy have increased with 47 per cent between 2000-2018. Europeans overwhelmingly want action to mitigate climate change and protect nature. The EU Forest Strategy should therefore include measures to avoid or correct unsustainable practices and protect and restore forests, in strong cooperation with foresters, farmers and local communities. In line with the Biodiversity Strategy, the EU’s last remaining primary and old-growth forests must be strictly protected. The following elements should underpin the next EU Forest Strategy: - Endorse climate and biodiversity objectives: The strategy should recognise the above-mentioned trends and endorse the central objectives of reaching binding restoration targets, increasing carbon sequestration in forests, strict protection of old-growth forests, and development of guidelines for biodiversity-friendly management. - Support a precautionary approach to the ‘bioeconomy’: The strategy should recognise that a bioeconomy can be both a carbon sink and a source of carbon, and that a regulatory framework needs to be carefully balanced. In light of the need to enhance carbon removal from forests. the Forest Strategy should condemn an increasing use of harvested wood for energy purposes, notably heating and power – in light of a need for a more optimal resource use in a circular economy. - Harmonise forest data to better assess impacts of management: National Forest Inventories (NFIs) in Europe do not all monitor the same data, making it difficult to compare information across countries. Particularly useful metrics would allow for a clearer picture on changes in forest area, intensity of forest management and forest condition across Europe, reported annually . - Identify how to improve forest management across the EU: Current forest trends reveal that Sustainable Forest Management has not achieved its purported goals. Defining what we mean by healthy forests will be key to restoring them. Some suggestions can be found in this case study. - Prioritise protecting and restoring forests over planting trees: The growth of forest cover has not helped our weakening forests. The proposal to plant three billion trees could prove detrimental if ecological and social objectives aren’t clear (see our ‘tree planting Frequently Asked Questions’). - Align social and environmental objectives: Restoration is a huge financial and social opportunity to address unsustainable management of forests. Support should be directed to foresters for biodiversity-friendly activities respecting principles for rights-based restoration.
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Response to Protecting biodiversity: nature restoration targets

2 Dec 2020

“European forests are under pressure.” Two major reports released this year reinforce this statement: the European Environmental Agency’s (EEA) 5-year report on the state of the European environment, and the ecosystem assessment from the Joint Research Center (JRC) to support evaluation of the Biodiversity Targets. Both show that the trend of land being degraded by agriculture and forestry practices is worsening. Just under 85 per cent of forests under the Habitats Directive are in poor health and pressures on forests are increasing, including climate change and logging. Over two thirds of European forests are exposed to three or more drivers of degradation. Strong definitions of what effective solutions should look like will be key to the success of EU restoration targets. Using the following principles, efforts to protect and restore forests can respect and even enhance human rights while increasing both biodiversity and forests’ ability to fight and survive the climate crisis. These principles alone are not sufficient to define objectives for forest restoration but should provide guiderails for the law. Human rights: - Safeguard local and Indigenous Peoples’ rights - Promote social justice and gender equality - Enable inclusive, deliberative governance - Ensure local communities receive equitable access to and benefits from forests with specific attention paid to including women Biodiversity: - Protect and enhance ecosystems - Promote environmental co-benefits - Avoid conversion of highly biodiverse and resilient landscapes Climate: - Restore resilient ecosystems - Do not increase plantations - Protect remaining mature forest - Undertake action in addition to reducing fossil fuel emissions If the above principles are followed laws can deliver rights-based restoration, rights-based conservation, and community-led forest management. As the vast majority of EU forests are managed, serious effort must be dedicated to decreasing unsustainable management practices across the EU. To protect and enhance biodiversity, priority should be given to preserving the few remaining old-growth forests, but the bulk of the effort lies in restoring the health of overharvested forests. The EU and Member States must set national targets to protect and restore forests across the EU. The targets should be placed within a robust governance framework that allows local people and civil society to influence the design and implementation of national restoration plans. In relation to forests, targets should: - Contribute to climate action: In addition to area-based targets, the restoration targets should include a carbon dioxide (CO2) removals contribution. - Improve the health of forests from today: Targets should be set against a 2020 baseline, meaning that restoration activities carried out as of 2020 should count towards these targets to avoid disincentivizing prompt action. - Cover all forests: Targets should take into account all EU forests and require activities that are additional to those in existing EU legislation to protect habitats. - Define objectives for healthy forests: This can be based on existing definitions - such as those under the Habitats directive - and metrics such as those elaborated under the mapping and assessment of ecosystem services (MAES), or be achieved through reducing identified drivers of forest degradation such as logging and urban development. - Promote biodiversity-friendly activities: This includes close-to-nature management, natural regeneration of forests and reforestation to transition forests towards a greater variety of species adapted to the local geography. - Improve forest data to better assess biodiversity impacts: Developing a common set of national data can facilitate action on climate and biodiversity. Particularly useful metrics would allow for a clearer picture on changes in forest area, intensity of of forest management and forest condition across Europe, reported annually.
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Response to Land use, land use change and forestry – review of EU rules

26 Nov 2020

Fern agrees that the focus should be improving accounting and data gaps, as well as increasing carbon sequestration from land. However, the suggestion that this should be done through land-use trading with other sectors is seriously flawed and may further aggravate disincentives to proper forest management. Unfortunately, many of the review’s proposed options focus on increasing flexibility between land and other sectors including those under the Emissions Trading System (ETS), the Effort Sharing Regulation (ESR) or specific sources of greenhouse gases (GHGs) such as non-carbon dioxide (CO2) emissions from the agricultural sector. All of these options would mean other sectors could be less ambitious. This goes against the objective outlined in the Inception Impact Assessment for the ETS which is to increase the levels of reductions in light of the proposed update to the 2030 climate target. Such options also backtrack on proposals to decrease offsets allowed under the ETS (which already excluded LULUCF credits) and to increase ambition. We are also concerned by the idea that wood products could get carbon removal credits. It is important to both incentivise carbon removals and reduce emissions. Offsetting can be a perverse incentive that decreases willingness to reduce emissions. As outlined by the United Nations Environment Programme, we need a five-fold increase of current climate ambition, and offsetting will prevent us from achieving this. If LULUCF focuses on land-use trading it will not improve land management or increase ambition. This is because the regulation considers Member State compliance, not the actions of foresters or farmers. There is already significant money for land use change under the Common Agricultural Policy (CAP), which has not improved practices, in part due to the lack of a binding framework to improve the health of EU forests and land. A recent assessment of the completeness and accuracy of LULUCF highlighted that countries are more likely to increase ambition in the land-use sector if there is a closer connection between improved land practices, other land-use policy targets such as Restoration targets under the Biodiversity Strategy, and GHG inventories. LULUCF cannot achieve all of this alone. This is why the regulation review should focus on elements which it is fit to address: accounting rules and how the land-use sectors contribute to meeting climate targets. Issues with forestry accounting, outlined in the NGO submission on the LULUCF Delegated Act, point to ways in which harvesting goes unaccounted. It is particularly important to address emissions from biomass use in the energy sector and harvested wood products. Deficiencies in the regulation should be analysed as part of the impact assessment. For example, sub-targets for land-use categories could increase sequestration or emissions reductions. The following principles should underscore the review: On Accounting - Strive for Transparency, Accuracy, Completeness, Consistency and Comparability (TACCC principles) of data: Improve the quality and harmonisation of data coming from Member States - No offsetting: Avoid allowing land removals from reducing the contribution of other sectors towards achieving climate targets - No credit for free: Avoid artificially increasing forests’ climate contribution, through rule changes that do not lead to real action on the ground. On target setting for land-use categories - Keep land-use targets separate: Ensure the separation of objectives to increase removals and reduce emissions between land-use categories. For example, any new targets to decrease emissions for agriculture should be separate from targets to increase carbon sequestration from forests. - Set targets to increase the land carbon sink: regardless of the policy option chosen, the direction is clear – EU land could remove 450 megatons CO2 annually by 2050, significantly more than what is expected under the current legislation.
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Meeting with Anthony Agotha (Cabinet of Executive Vice-President Frans Timmermans)

26 Nov 2020 · Discussion on Deforestation

Meeting with Helena Braun (Cabinet of Executive Vice-President Frans Timmermans)

24 Nov 2020 · Implementation of the European Green Deal

Meeting with Diederik Samsom (Cabinet of Executive Vice-President Frans Timmermans), Helena Braun (Cabinet of Executive Vice-President Frans Timmermans), Riccardo Maggi (Cabinet of Executive Vice-President Frans Timmermans), Stefanie Hiesinger (Cabinet of Executive Vice-President Frans Timmermans)

25 Sept 2020 · biodiversity

Meeting with Diana Montero Melis (Cabinet of Commissioner Jutta Urpilainen), Renaud Savignat (Cabinet of Commissioner Jutta Urpilainen) and

23 Sept 2020 · Making the European Green Deal work for International Partnerships

Fern urges EU to exclude forest biomass from renewable targets

21 Sept 2020
Topic — The European Commission is revising the Renewable Energy Directive to meet 2030 climate goals.
Message — Fern recommends excluding forest biomass as a form of renewable energy. They urge the Commission to discontinue financial incentives and introduce a quantitative cap on biomass use.123
Why — Removing support would protect terrestrial carbon sinks and ensure biomass use achieves positive climate effects.45
Impact — The bioenergy industry would lose billions in annual operating aid and preferential regulatory treatment.67
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Response to Commission Delegated Regulation amending Annex IV to the LULUCF Regulation

14 Sept 2020

Submission on behalf of several NGOs (signatures in attached pdf). The Member States’ reference levels show a clear trend: Over the next five years less carbon will be stored in European forests. This is the second way the LULUCF regulation has permitted carbon loss in forests. First, it negotiated how much carbon dioxide (CO2) was considered stored in forests from 2000-2009. This starting point, or baseline, allowed for around 40 million tons of CO2 worth of increased harvesting compared to actual emissions. Now the reference levels presented in the delegated act will allow Member States and the UK to further reduce the CO2 stored in their forest by another 40 million tons over the first half of this decade. Taken together these amount to an 18.7 per cent drop in the carbon sink from early 2000s levels. This jeopardizes the integrity of the EU’s 2030 climate target for and is not in line with goals to maintain or enhance the carbon stored in forests. The LULUCF sink reduction comes at the same time as many EU voices – citizens, Member States and Members of the European Parliament (MEPs) are calling for a significant increase of the EU’s greenhouse gas cutting target, which the Commission President has committed to. In addition to the allowed decreased in harvesting there are other flaws that impact the construction of the reference level that Fern and FANC – members of the LULUCF Expert Group - outlined: - Countries are allowed to increase harvesting of old trees with minimal justification: Older forests are vital not just as carbon stocks and ongoing carbon sinks, but also for their biodiversity and social value. Cutting old trees is not in line with climate objectives or the EU Biodiversity Strategy, which outlines the need to protect ‘remaining primary and old-growth forests’. - Little of the estimated reduction in the carbon sink will be accounted for, even if it is used as bioenergy: The LULUCF Regulation aimed to ensure emissions from increased biomass energy use would be accounted for. This is a founding idea behind the sustainability criteria in the Renewable Energy Directive, but it does not seem to be accounted for in the Member State National Forest Accounting Plans (NFAPs). The ‘constant ratio’ principle (maintaining the percentage of wood used for energy and wood used for materials) in the LULUCF Regulation is of little solace given that many countries increase their amount of wood harvested and admit that the 2000-2009 baseline ratio is based on patchy data. This ratio has been little scrutinised by the EU Expert Group. - Countries can define forest management intensity, a key parameter for establishing reference levels, in differing ways: The Commission has identified seven differing interpretations, which for some forested countries, like Finland and Estonia, have allowed for significant drops in carbon storage over the next five years. As the reference levels in the Delegated Act and recent analysis confirm, LULUCF is not a sufficient instrument to ensure countries enhance the contribution of the land sector to reach 1.5°C. It will at best maintain current logging practices over this upcoming decade without regard for their intensity, which is currently having serious impacts on forest health. Countries are more likely to increase their ambition level in the land-use sector if there is a closer connection between improved management practices, co-benefits of other policy targets (e.g. area of organic farming, hectares of restored ecosystems) and greenhouse gas inventories. There is a clear need for a carbon removals target to increase ambition in the land sector. Such a carbon removals target should be the central debate when reviewing climate and land-use policy to increase Europe’s ambition. We need to take older forests out of the line of fire, carve a pathway for biodiversity-friendly management practices and support foresters to enhance the biodiversity and carbon stored in their forests.
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Meeting with Anthony Agotha (Cabinet of Executive Vice-President Frans Timmermans), Damyana Stoynova (Cabinet of Executive Vice-President Frans Timmermans), Helena Braun (Cabinet of Executive Vice-President Frans Timmermans) and

9 Sept 2020 · The Green Deal implemetation with view to external relations

Meeting with Helena Braun (Cabinet of Executive Vice-President Frans Timmermans), Lukas Visek (Cabinet of Executive Vice-President Frans Timmermans)

14 Jul 2020 · Sustainable forestry

Meeting with Helena Braun (Cabinet of Executive Vice-President Frans Timmermans)

14 Jul 2020 · European Green Deal, biodiversity, climate and forest policies

Response to Revision of the EU Emission Trading System Monitoring and Reporting Regulation (MRR)

13 Jul 2020

The current EU ETS and rules on monitoring and reporting do not take into account emissions from biomass burning (counted as zero). We argue that this is a concern and incoherent with the broader rationale of support to renewable energy under the Guidelines for State aid for environmental protection and energy. The main rationale of State aid for renewable energy production is to increase the level of environmental protection by the compensation for the benefits of renewable energy for as long as the external costs of energy are not effectively priced in. Yet current State aid rules do not allow for an assessment of the compatibility of aid for bioenergy with EU law that gives full consideration to the external costs of bioenergy itself. While State aid has since the early 2000s triggered a significant increase in the use of forest biomass for energy and reduced emissions from avoided fossil fuel use, its net-effect in terms of greenhouse gas savings is uncertain / unproven. The current State aid regime does not foresee in a full assessment of the net-greenhouse gas effect of bioenergy, as it ignores the most significant emission factors, i.e. those from biomass combustion and forest harvests. These negative costs are also not factored in through other policies, while the EU ETS and the LULUCF frameworks allow for emissions from biomass combustion and harvests to go unaccounted. This is not a trivial issue, as biomass combustion increases primary energy consumption and leads to more CO2 emissions at smokestack compared to coal. Ignoring the full GHG impact of biomass burning in State aid assessments / carbon accounting framework may lead to a skewed image of its cost-effectiveness as an option for renewable energy. Unlike other forms of renewable energy, bioenergy relies on the combustion of carbon and the use of a limited natural resource and is associated with relatively high external costs compared to other renewables. Currently, these costs thus come at the expense of the society at large. This reveals an important discrepancy between the specific way in which support for biomass is treated by the current rules and the rationale and objectives of the current State aid regime for renewable energy. Not factoring in external costs of forest biomass may result in an inherently preferential treatment of solid biomass and hinder the development of other – more innovative and cleaner – technologies, which can undermine the principle of technology-neutrality embedded in the EEAG. This is further reinforced by the design of the current rules, which allow for continuous operating support to the use of solid biomass for energy as a (close-to) mature technology. This can lead to the lock-in of State aid, of a specific renewable energy technology and of (limited) biomass materials for energetic use. We acknowledge the complexity of accounting for biomass emissions under the EU carbon accounting framework. Considering the urgency of climate action and the need for increased climate ambition towards 2030 and 2050, we urge the Commission to address this issue in future policy design and ensure that CO2 emissions from biomass burning are accounted for in full.
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Meeting with Diana Montero Melis (Cabinet of Commissioner Jutta Urpilainen), Renaud Savignat (Cabinet of Commissioner Jutta Urpilainen) and

10 Jun 2020 · European Green Deal, COVID-19 and development cooperation

Forest NGO Fern Urges Limits on Biomass Energy Funding

3 Jun 2020
Topic — The consultation concerns the establishment of a new Union renewable energy financing mechanism.
Message — Fern calls for a precautionary approach to funding solid biomass to protect forests. They recommend excluding large-scale biomass plants and ensuring aid only targets market failures.12
Why — This approach would protect carbon sinks and stimulate investment in truly clean energy.3
Impact — Mature bioenergy firms and large power plants would lose access to significant public subsidies.4
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Meeting with Diana Montero Melis (Cabinet of Commissioner Jutta Urpilainen)

2 Jun 2020 · Forest strategy and communication

Response to Climate Law

30 Apr 2020

The Climate Law is a good step forward and could be a great opportunity and tool for climate governance. It will enshrine the long-term climate target into law and should define how the ambitious policies that make up the European Green Deal will be governed. The law should ensure that the speed and ambition of climate action is not weakened. Separate emission reductions from emissions removals: Targets and accounting for negative emissions should be explicitly set and managed separately from existing and future targets for emissions reduction. Failure to make such a separation has already hampered climate policy (see Land Use Land Use Change and Forestry (LULUCF) flexibilities), and could further delay ambition if emitting sectors exaggerate the expected future contribution of negative emissions technologies. If the Commission wants to fulfil its promise of making the EU’s economy sustainable it should reach climate neutrality by 2040 and increase the 2030 climate target to reducing emissions by at least 65%. The target of increasing the EU’s Nationally Determined Contribution (NDC) by 2030 should not be met by a combining fossil fuel reductions and removals from land use (offsetting) – it must be fully achieved by emissions reductions. This means the EU should have a separate target for removing emissions already in the atmosphere in order to preserve climate ambition and environmental integrity. Avoid putting false hope in large-scale geo-engineering: Countries are not decarbonising their economies fast enough to meet the Paris Agreement goals. Often this is because countries claim future technical solutions will arrive, but there is no substitute for keeping fossil fuels in the ground. Despite numerous trials, geo-engineering projects have failed. They have been shown to be unworkable at scale, and have been found to significantly delay or deter planned emissions reductions. Bioenergy with Carbon Capture and Storage has been found to be particularly problematic. Prioritise natural sinks: Our plants and oceans are the largest absorbers of carbon dioxide (CO2) in Europe and across the globe. Since 2000, each year the LULUCF sink has removed around net 300 megatons (Mt) CO2e on average. According to the European Environmental Agency (EEA), this has been reducing over the past 8 years due to growing demand for wood for material uses and energy production. Proper protection and restoration of forests could triple the amount of CO2 removed by forests each year. Mainstream action on climate and biodiversity: All paths and measures to achieve climate targets should respect and enhance biodiversity. They should build on the conclusions of Intergovernmental Science-Policy Platform on Biodiversity and Ecosystem Services (IPBES), which are as relevant and pressing as those of the Intergovernmental Panel on Climate Change (IPCC). (Hyperlinks in attached document)
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Response to 2030 Climate Target Plan

15 Apr 2020

Fern welcomes the assessment of climate and energy policies to accommodate the increase in climate ambition. It is crucial that this assessment moves beyond the existing framework to reflect the broader ambition of the European Green Deal to cut pollution, restore biodiversity and create a healthy and just society for European citizens. This is particularly important to assess the impact of climate and energy policies on forests, which have both carbon dioxide (CO2) and biodiversity impacts. Increased harvesting has had dire consequences for forest health within and outside of the EU and has devastated biodiversity. Increased demand for timber has led to trees being harvested at an ever younger age and from more biodiverse areas . This means that even forests in protected areas are becoming degraded . Although tree cover is increasing, EU forests’ capacity to remove CO2 has been significantly declining since 2015 and this trend is set to continue. Simultaneously, CO2 emissions from biomass have increased 160% since 1990 . The roadmap assessment should pay particular attention to adjusting the following elements: What the initiative will assess: - ‘the synergies and trade-offs with social and other environmental concerns such as biodiversity, the use of resources, pollution or food security’: The assessment should look at policy synergies and conflicts with other areas of EU legislation, especially regarding the impacts of bioenergy and the opportunities offered by ‘increasing the role of natural sinks’. Specific attention should be given to compatibility with the Birds and Habitats Directives. - ‘The co-benefits and synergies of adaptation and mitigation approaches in protecting and enhancing viable long-term ecosystem carbon stocks and sinks that contribute to and support climate resilience and contribute to other environmental goals’; Approaches must work together to protect well-adapted, biodiverse ecosystems which are already storing and will continue to store the most carbon and exhibit greatest resilience. - ‘How the EU can increase the absorptions of CO2 emissions over time, including in its natural sinks and the role of biomass-based products and nature based solutions;’: Bieoenergy is not ‘carbon neutral’ and real greenhouse gas emissions should be assessed with current bioenergy trends in mind. The Renewable Energy Directive (RED) must come under review. It is also important that targets under Land Use, Land Use Change and Forestry (LULUCF) remain separate to those associated with fossil fuels, to ensure that activities in either one of these areas do not lead to a lack of measures in the other. - ‘What type of specific flanking measures related to climate and energy policies are needed to safeguard international competitiveness, remove barriers, including for the roll-out of clean energy and transport technologies, guarantee energy and food security,... and improve climate and environmental resilience;’ The link between environmental degradation and biodiversity loss and the real economy is absent. The criteria should explicitly mention ‘how to reverse biodiversity loss’ as key to climate adaptation and mitigation. Likely impacts: It is important that the assessment recognises the need to address the environmental impact of land-use hence the importance of the roadmap to 1) assess the CO2 and environmental impact of bioenergy and 2) expand beyond climate and energy legislation to sustainably achieve the EU’s carbon neutrality goal through actions that enhance the biodiversity and resilience of forests. We appreciate the opportunity to provide our views. Given the wide-ranging impacts of climate change, it is important to expand the diversity of stakeholders who are consulted, in order to ensure balanced solutions resulting from the inclusion of a range of expertise.
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Meeting with Diana Montero Melis (Cabinet of Commissioner Jutta Urpilainen) and WWF European Policy Programme and

26 Mar 2020 · international dimension of the European Green Deal

Fern urges EU to enact mandatory due diligence against deforestation

3 Mar 2020
Topic — This consultation addresses minimizing deforestation risks linked to products on the EU market.
Message — Fern calls for mandatory due diligence laws requiring companies to avoid deforestation and human rights abuses. They advocate for legally recognized land rights and enforceable sanctions for non-compliant firms.12
Why — Enforceable regulations would help Fern realize its goal of protecting global forest ecosystems.3
Impact — Agribusiness and biomass industries would face significant restrictions on their current production methods.45
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Meeting with Helena Braun (Cabinet of Executive Vice-President Frans Timmermans)

12 Feb 2020 · biodiversity and forests

Response to Climate Law

6 Feb 2020

Fern supports the European Commission’s initiative for a Climate Law enshrining a legally binding climate neutrality commitment for Europe, with decarbonisation plan and specific time commitments, into law. Doing so will confirm the commitment of the EU and its member states to the Paris Agreement targets. Fern stresses the need for the Climate Law to include: - A binding climate neutrality date of 2040, and an enhanced 2030 target of 65% GHG emissions reduction: this must be achieved without reliance on offsetting our emissions into the future - A five year review mechanism for EU climate and energy targets building on the common framework of the Governance Regulation. - An EU-wide 'natural carbon sinks' policy that aligns climate objectives with protecting and restoring natural sinks and provides the right signals for restoring, conserving, enhancing and managing natural carbon sinks: A commitment to triple the natural carbon sink in the EU by 2050. Since 2000, the net reported annual LULUCF sink has been around 300 Mt CO2e on average, with an unfavourable declining trend over the past 8 years owing to growing demand for wood for material uses and energy production, according to the EEA. A recent study shows with proper protection and restoration of forests we could triple the amount of carbon they store each year. Restoration and protection of natural carbon sinks by restoring at least 15% of Member States territories by 2030, through legally binding targets and appropriate funding. By 2021, the European Commission needs to propose a legal instrument including a binding target for the Member States to restore 15 % of their territories and of their sea areas. - Climate policy coherence (mainstreaming of climate policy), with particular attention to: - Mainstreaming action on climate and biodiversity through accounting of new ecosystem restoration initiatives: Ecosystem restoration targets must be counted towards achieving climate neutrality. Large amounts of carbon are stored in highly biodiverse areas; any targets to protect and restore forests should be quantified in CO2 terms and contribute to enhancing the EU’s carbon sink. - The proposed “Do no harm” policy of the European Commission should require a revision of legislation inconsistent with the EU long-term climate objective, with particular emphasis on the Renewable Energy Directive and Emissions Trading System (ETS). To incentivize the shift from increasing biomass use to increased protection and improved forestry practices, Fern recommends the following: Correct the myth of carbon neutral biomass: Removing the zero-rating of biomass under the ETS, and accounting for emissions where they are burned. Phase-out a lock-in of fossil-fuel infrastructure: Wood use is limited and the growing use for energy in power plants is inefficient and should be capped and phased-out over time. The phase-out pathway for forest biomass in the public energy sector should peak by 2025 with full phase-out by 2040 at the latest. - Creation of an independent scientific advisory and monitoring body to scrutinise the EU’s targets, and its plans and policies to tackle the climate emergency. - An obligation for meaningful public participation and engagement of citizens in further policy design with the aim to be a basis for a deep and just transition. - Alignment of public and private financing for ecosystem restoration consistent with a 1.5°C pathway: Phase out of bioenergy subsidies: EU Member States spent €6.5 billion subsidizing bioenergy in 2017, not including indirect subsidies like carbon tax exemptions. Money should go to restoration, protection and enforcement of current nature legislation including the Birds and Habitats Directives so that once restored, healthy and functioning ecosystems remain carbon sinks or stores supportive of biodiversity that are able to make a significant contribution to climate change mitigation.
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Response to EU 2030 Biodiversity Strategy

20 Jan 2020

*Links provided in attached file Action needed in Europe Ahead of the negotiations on a post-2020 global biodiversity framework, the EU 2030 Biodiversity Strategy should position Europe to address the climate and biodiversity crises jointly by identifying targets and legislation to protect and restore forests and other ecosystems inside and outside of Europe. Before developing new legislation, the Biodiversity Strategy should reemphasize the commitment to achieve current targets through proper enforcement and implementation of the EU Birds and Habitats Directives and other environment-related EU legislation. The EU budget should allocate a level of financial support necessary to achieve full implementation. In addition, new binding targets to restore terrestrial nature are necessary to meet both environment and climate commitments, since terrestrial ecosystems can sequester and store increased amounts of carbon dioxide as well as provide a haven for biodiversity to return to. This should come in the form of legally binding legislation. For these binding targets to directly contribute to the overarching goal of climate neutrality by 2050, there should be a link between these new initiatives and existing frameworks, such as the laws for monitoring and verifying greenhouse gases under the climate and energy framework. In priority these initiatives should put forward new requirements that enshrine an improvement of the ecological health of ecosystems. In addition, future initiatives should include: - Quantification of biodiversity actions in amounts of carbon dioxide, in addition to new metrics that take into account the resilience of ecosystems. The most recent figures show that protecting and restoring ecosystems in Europe could remove 1.2 billion tonnes of CO2 per year by 2050. The vast majority of action comes from restoring forests. - Existing reporting frameworks such as the Governance Regulation and the Climate Monitoring Mechanism could be used to report these gains. Acting on Europe’s impact on biodiversity internationally The EU is a large driver of biodiversity loss, primarily due to deforestation, through its consumption of agricultural commodities and its financing of infrastructure projects. The EU is one of the major importers of forest risk commodities: i.e. palm oil (25% of global imports), soy (15%), rubber (25%), beef (41%), maize (30%), cocoa (80%), and coffee (60%). According to a Commission study, an area of forest the size of Portugal was lost globally between 1990 and 2008 because of EU consumption of commodities grown on deforested land. A number of studies made public by forest peoples and forest defenders has exposed the serious social and human rights impacts of deforestation driven by EU trade and imports from tropical forest countries. It is therefore impossible for the world to meet any global biodiversity targets involving forests unless EU demand of forest-risk commodities is addressed. It is therefore critical that the EU delivers on its commitment in the European Green Deal to introduce regulation to curb the EU’s devastating impact as a matter of urgency. Fern’s position on what this regulation should look like is outlined in this joint NGO brief available here. This should be a firm commitment in the EU Biodiversity strategy, which would also encourage other markets with high consumption of products causing deforestation, such as China, to take action. This would mean that the 2030 biodiversity agenda would be the major turning point in the fight against global deforestation and terrestrial biodiversity loss.
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Meeting with Frans Timmermans (First Vice-President)

6 Nov 2019 · Discussion on sustainable development, environmental protection and the rights of the indigenous people

Meeting with Helena Braun (Cabinet of First Vice-President Frans Timmermans)

16 Oct 2019 · discussion on EU Action on fighting deforestation

Meeting with Helena Braun (Cabinet of First Vice-President Frans Timmermans) and WWF European Policy Programme

30 Jul 2019 · discussion on UN General Assembly & EU action on forest protection

Meeting with Miguel Arias Cañete (Commissioner) and WWF European Policy Programme and

4 Jun 2019 · Debate on the strategic agenda and its relevance for climate and energy, NECP recommendations

Meeting with Peter Wehrheim (Cabinet of Commissioner Phil Hogan)

30 Apr 2019 · Deforestation & forest degradation & Rural Task Force for Africa

Response to Prolongation of State aid rules reformed under the State aid modernisation package that expire by the end of 2020

4 Mar 2019

Please refer to the attached Word document for Fern's full feedback. --- This briefing provides feedback to the Commission’s Roadmap on the prolongation of the state aid rules reformed under the state aid modernisation (SAM) package expiring at the end of 2020. As the Roadmap indicates, before deciding on the design of the State aid rules post-2020, the Commission is launching a fitness check of the SAM package, in order to ‘verify the extent to which the objectives of the SAM have been reached, whether there is scope for further updating the rules in view of the EU priorities under the new Multiannual financial framework, new EU legislation or developments on the internal and global market’. The SAM package includes two sets of rules relevant for aid granted to renewable energy and bioenergy in particular: the General Block Exemption Regulation and the State Aid Guidelines on environmental protection and energy. Since the introduction of the Renewable Energy Directive, demand for (forest) biomass for energy purposes has increased and concerns have been raised that subsidies lead to distortion of the market, notably the raw material market. Also, scientists have repeatedly warned that the creation of bioenergy from forest biomass leads to significant greenhouse gas emissions and is an inefficient use of limited resources. In light of these concerns, we welcome an evaluation of the current state aid rules by the Commission. However, we are concerned a broad ‘fitness check’ will not provide a sufficiently thorough evaluation of the rules relating to bioenergy, which is so urgently needed. It remains the principle task of state aid rules to mitigate risks of distortion of the internal market and to ensure that potential market distortion is justified by the (assumed) benefits of those activities receiving aid. We recommend the Commission to specifically consider : 1. Climate-and energy framework 2021-2030 Whether there is any relevance to revise the current rules following the recast of the Renewable Energy Directive (REDII) as well as the adoption of the Governance Regulation, specifically taking into account the new sustainability policy for the use of forest biomass, and rules on LULUCF in particular. 2. Market developments The extent to which state aid for the use of forest biomass for energy has led to distortion of the raw material markets in the years 2010-2019, in the EU as well as beyond; Whether the REDII is expected to lead to any (further) developments on raw material markets, taking into account sustainable supply of biomass at Member State level. 3. Large-scale installations The extent to which large biomass installations can drive excessive distortion on raw material markets, as well as the wood fuels markets; in combination with an assessment of studies done on potential negative climate and environmental impacts, including health impacts, and the relative impacts of burning roundwood, stumps, and forestry residues, by large biomass installations (cost-benefit analysis for the purpose of a proportionality test). 4. New EU objectives Whether newly established EU objectives and commitments provide a reason to update state aid rules on bioenergy. Those include commitments under the Paris Agreement and the Sustainable Development Goals as well as EU objectives to promote a circular economy and a bioeconomy under the Multi-Annual Financial Framework. 5. GBER – Guidelines on State aid on environmental protection and energy Whether, considering the evaluation and possible market distortion, there is a reason to reduce the scope of the General Block Exemption Regulation, to allow the Commission to assess whether certain aid for bioenergy is compatible with the internal market in a wider range of cases.
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Fern urges mandatory regulation of EU forest risk imports

15 Jan 2019
Topic — EU initiative to present an integrated approach to combat global deforestation.
Message — Fern calls for mandatory regulations on imports to replace ineffective voluntary schemes. They recommend laws that hold companies and banks accountable for forest destruction and human rights abuses.12
Why — Legal mandates would fulfill Fern’s mission of holding large companies strictly accountable.34
Impact — Financial institutions and importers would face significantly higher compliance costs and liability.56
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Meeting with Xavier Coget (Cabinet of Vice-President Jyrki Katainen)

14 Dec 2018 · Deforestation

Response to Evaluation of the impact of the CAP on habitats, landscapes and biodiversity

6 Dec 2018

The following constitutes Fern’s recommendations for what should be covered in the European Commission’s Evaluation of the impacts of the CAP on habitats, landscape and biodiversity. We recommend that the Evaluation should: 1) Evaluate the impact of CAP funding on the effective implementation of the EU Biodiversity Strategy. Specifically, we suggest the evaluation should look at the impact of CAP funding on biodiversity loss through • Direct and indirect land use change • Pesticide use • Fertiliser use • Intensification of agricultural and forestry management 2) Evaluate the impact of Rural Development funding on • the increase of bioenergy (forest biomass) production and use in EU Member States • the impact of this increase on forest management practices • the impact of this increase on forest biodiversity • the planting / maintenance of monoculture plantations. There is concern that EU money is still being spent on maintaining monoculture forest plantations. See investigation by Portuguese newspaper on level of EU subsidies going to eucalyptus plantations that fuelled fire tragedy in 2017: https://www.dn.pt/edicao-do-dia/29-jul-2018/interior/-eucaliptos-tem-cinco-vezes-mais-apoio-do-que-floresta-nativa-9650078.html (article in English: http://www.geoengineeringmonitor.org/2018/11/fire-and-plantations-in-portugal/) • the decrease of the carbon sink of EU forests 3) Evaluate to what extent Rural Development funding has been used to • Implement Natura 2000. It has been estimated that approximately 375,000 km² of forests are included in the Natura 2000 Network. This represents around 50% of the total area in Natura 2000. Funding is required for management of this network and the EFARD is main source of funding. • Implement the European Commission Strategy to promote a Green Infrastructure across Europe, including improving the connectivity of forest habitats by e.g. enlarging the area of forest habitat types through reforestation or improving the ecological quality of existing forest habitats. • Increase the overall biodiversity levels in EU’s forests and enhancement of carbon sinks. 4) Evaluate the impact of CAP provisions, such as • direct payments, onLand use change leading to deforestation in Latin America, due to feed import dependency (notably soya) for EU animals Read our report: https://fern.org/CAPreform 5) Ensure that Environmental NGOS are properly consulted throughout the evaluation process and that there is a system in place to make sure that their contributions are reflected in the evaluation report.
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Meeting with Miguel Arias Cañete (Commissioner) and WWF European Policy Programme and

27 Sept 2018 · Long-Term Strategy, Preparations for COP24 and October ENV Council

Meeting with Jyrki Katainen (Vice-President)

23 Jul 2018 · Deforestation

Meeting with Mauro Raffaele Petriccione (Director-General Climate Action)

26 Jun 2018 · forest protection/restoration and the mid-century decarbonisation strategy

Response to Update of the 2012 Bioeconomy Strategy

20 Mar 2018

Land and biomass are limited resources and their utilization in the EU should be guided by the objectives of mitigating climate change, protecting biodiversity and supporting sustainable development as laid out in the Paris Climate Agreement, Convention on Biological Diversity and the Sustainable Development Goals. Current trends of increasing global population, climate related changes in ecosystem health, biodiversity loss, degradation of land and deforestation, reduction of fertile land and increased biomass demands all present challenges for ecosystems and the development of bioeconomy. Currently EU forests sequester more CO2 than they release and thus help to mitigate against the impacts of climate change. However, the EU forest sink is expected to decrease, also due to increased biomass harvests. Understanding of trade-offs of policy actions is critical when it comes to the use of wood for energy, which has been shown not to be carbon neutral. EU policy must be revised to make sure wood use for energy supports Paris Agreement goals. The way we manage forests, the amount of wood we extract and the use of wood are all critical in determining the impact EU forests will have on the climate and on biodiversity. Despite a considerable increase in forest cover in Europe since 1750, research shows that the increase in management intensity and changes in species composition have led to negative climate impacts. The conclusion is that climate action through forests risks failure, unless it is recognized that not all forestry measures contribute to climate change mitigation. Modelling studies show that more natural management methods and lower harvesting levels could support multiple ecosystem services but also be economically viable. The EU Bioeconomy Strategy must recognize that something ‘bio’ is not necessarily good for the environment. Bioeconomy should thus be carefully governed and regulated to make sure it doesn't prove counterproductive for environmental objectives. Substitution of non-renewable resources with biological resources should not be the main aim of the Bioeconomy Strategy, but that of ensuring utilization of resources within planetary boundaries and making more from less. Precautionary approach should apply to all investments. EU Bioeconomy strategy should prioritize research, investment and awareness raising of synergies between efficient and moderate resource use, the enhancement of carbon sequestration by forests and other ecosystems and biodiversity protection. It should also call for stronger policy coherence to support the Unions climate and biodiversity objectives. The EU Bioeconomy strategy must be revised to • disincentivize utilization of virgin resources and support more moderate and less resource intensive consumption patterns • be in full coherence with and implement the Circular Economy package, including waste legislation • call for priority of long lifetime material uses of biomass vs. energy use • assess the impacts of bioeconomy, including carbon balance (potentially on regional, sectoral level) in a time frame relevant to stay in Paris Agreement temperature limits • call for additional safeguards on EU and Member state level to ensure bioeconomy does not create environmental harm • stronger enforcement of the EU Nature Laws and Biodiversity Strategy and ensure their objectives are supported by other EU policy areas • ensure investments do not drive increased harvesting of forests nor pose other risks to the environment • support sufficient funding to reach the Union’s biodiversity targets • support more EU investments to protection and restoration of natural ecosystems also outside of the EU Sources: EASAC 2017: https://www.easac.eu/fileadmin/PDF_s/reports_statements/Forests/EASAC_Forests_web_complete.pdf Naudts 2016: http://science.sciencemag.org/content/351/6273/597 Heinonen 2017: https://www.sciencedirect.com/science/article/pii/S1389934116303823
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Meeting with Christiane Canenbley (Cabinet of Commissioner Phil Hogan)

9 Jun 2017 · CAP, soy and deforestation

Meeting with Telmo Baltazar (Cabinet of President Jean-Claude Juncker) and Transport and Environment (European Federation for Transport and Environment) and Stichting BirdLife Europe

29 Sept 2016 · Energy Union

Meeting with Grzegorz Radziejewski (Cabinet of Vice-President Jyrki Katainen) and Stichting BirdLife Europe

23 Sept 2016 · bioenergy sustainability

Meeting with Telmo Baltazar (Cabinet of President Jean-Claude Juncker) and European Environmental Bureau and

12 Jul 2016 · Climate Action and Energy

Meeting with Aurore Maillet (Cabinet of Vice-President Karmenu Vella) and OXFAM INTERNATIONAL EU ADVOCACY OFFICE and Forest Peoples Programme

27 Apr 2016 · deforestation, palm oil, indigenous peoples rights

Meeting with Cecile Billaux (Cabinet of Vice-President Cecilia Malmström)

15 Apr 2016 · workshop on civil society engagement in FLEGT VPAs (timber) and FTAs,

Meeting with Dagmara Koska (Cabinet of Vice-President Maroš Šefčovič)

2 Feb 2016 · Bioenergy

Meeting with Daniel Calleja Crespo (Director-General Environment)

17 Dec 2015 · Forest Policy priorities

Meeting with Yvon Slingenberg (Cabinet of Vice-President Miguel Arias Cañete)

16 Jul 2015 · LULUCF 2030 climate target

Meeting with Aurore Maillet (Cabinet of Vice-President Karmenu Vella) and WWF European Policy Programme and Greenpeace European Unit

19 Jan 2015 · Deforestation