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Kungl. Skogs- och Lantbruksakademien

KSLA

Kungl.

Lobbying Activity

Response to Taxonomy Delegated Acts – amendments to make reporting simpler and more cost-effective for companies

20 Mar 2025

Comments on Draft act Taxonomy Delegated Acts amendments to make reporting simpler and more cost-effective for companies The suggested changes in the Delegated Act, in form of reduced administrative burdens in line with the principle of proportionality, is supported by The Swedish Royal Academy of Agriculture and Forestry. These gives a more appropriate balance between environmental gains and company obligations. Our judgement is that this revision will not compromise the objective of the EU Taxonomy to facilitate the financing of new environmentally sustainable activities. We also support the suggested changes related to the accuracy of the key performance indicators where smaller companies are excluded. The agricultural and forest sector contain a high share of small and medium size enterprises. Their administrative burdens related to existing sustainability regulations are significant, and additional demands need to take into account the principle of proportionality. These suggested reduced reporting burdens are also judged to have a minor impact on the aggregated sustainable economic activities, which are targeted in the EU Taxonomy.
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Response to New EU Forest Monitoring and Strategic Planning Framework

4 May 2022

The Royal Academy of Agriculture and Forestry (KSLA) welcomes the opportunity to respond to the call for evidence for an impact assessment on a new EU Framework for Forest Monitoring and Strategic Plans. • Strategic forest planning is a national competence and therefore KSLA has doubts regarding the proposed strategic forest plans. • An impact assessment should clarify in which areas harmonized EU-level data are needed, what the data are needed for and where the potential information gaps lie. • EU should focus on capacity building in Member States (MS) on existing monitoring, before building new systems. • Remote sensing should be further developed as a tool for monitoring among MS but must be calibrated and supplemented with extensive ground observations. There is a great need for reliable and comparable data on EU forests. However, forest conditions vary widely within the EU and national data and monitoring varies between MS. EU Forest monitoring should be limited to data needed for monitoring progress of EU policies at EU level. Thus, the issue of providing data for forest management should be handled separately at MS level. KSLA supports the Council conclusions on the new EU Forest Strategy: “CALLS on the Commission, together with the MS and experts to analyse the currently existing discrepancies and possible gaps in forest data collection” and regarding strategic plans “ASKS FOR clarifications on the added value of such plans and RECALLS the need to acknowledge the cost-effectiveness and to avoid duplication and additional administrative burden, the already existing comprehensive national forest programmes or strategies, developed according to internationally agreed commitments, such as the United Nations Strategic Plan for Forests and the FOREST EUROPE Vienna Resolution, and their related MS competencies.” The forest data that are needed for monitoring forests on EU level need to be carefully assessed before any new, costly, monitoring program is developed. This is a key issue for the impact assessment. Before calling for general harmonization and to create a basis for comparable data, it is necessary to identify the areas where harmonization is needed, the purpose of such harmonization, which data are needed and with which resolution. In addition, the question of financing of data collection and monitoring and the respect of data privacy must be addressed. This should be done in a way that does not increase administration and costs in MS. Cooperation with UNECE, FAO and Forest Europe, which also collect forest data, is necessary. A likely starting point for the framework would be to make sure that all MS have sample plot based National Forest Inventory (NFI) that delivers harmonized data for a core set of key variables. A priority in the upcoming legislative framework should be to support MS in developing NFIs to achieve better quality data and facilitate knowledge-sharing and harmonization between MS. The use of natural resources, including forests, needs to rest on a solid basis of evidence and experience. As such, the proposal to increase insights in the state of EU forests is positive. Still, the proposed approach focusing on remote sensing will likely have a limited contribution, in relation to already existing initiatives. KSLA foresees a use mainly in relation to rapid processes, such as transnational forest fires and storms, for which there is a need for immediate mapping to counteract negative ecological, social, and economic effects. The development of satellite-based GIS systems is currently rapid. However, it is important to realize that these have their limitations and that they must always be calibrated with ground-based measurements. The benefits of satellite data products are high resolution in space and time, however at the cost of limited accuracy for most forest variables. It is therefore essential that the obtained accuracy is documented for any product based on satellite data.
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Response to Carbon Removal Certification

28 Apr 2022

KSLA shares the Commission's view on the value of integrating carbon sequestration into EU climate policy. We are positive about using innovative solutions to separate, recycle, store carbon dioxide and increase the amount of carbon dioxide in plants in agriculture and forestry through methods for increased growth. The Academy finds it positive that EU is developing a standardized certification system that regulates incorrectly claimed climate benefits. KSLA sees certification as a system with good development potential, even though knowledge is still lacking for a long-term useful certification system based on science. The proposal mainly points to agriculture's possibility of carbon storage, but KSLA agrees that forest and marine systems are also mentioned. KSLA believes, however, that it is important that the impact statement clarifies the differences between the different systems. KSLA agrees that agricultural cultivation systems, which result in increased carbon storage, can be a basis for certification. KSLA would like to emphasize, however, that even more knowledge is needed to achieve satisfactory production and good profitability for agriculture, when the mentioned cultivation systems are used, and that geographical differences are considered. KSLA is currently working on a development project focusing on reduced tillage for increased fertility, biodiversity, and carbon storage. It is important to consider the time perspective in certification systems for agriculture and forestry as the answers may seem completely different as measures that give results in the short term can be counterproductive in the long term. KSLA believes that it is important that the certification system is built up considering the work that users already do today and that this related to the rules that exist in each country. In addition to carbon dioxide, it is also mentioned that methane and nitrous oxide can be included in the certification system. However, KSLA emphasizes that the measurement of these gases is so complex that it complicates the usefulness of a certification system in the long run. It is important that the financial aspect for users is considered when developing a certification system. It needs to be easy to administer to avoid unnecessary costs. KSLA is doubtful that the EU itself should work with the practicalities of certification. An alternative is to apply the same solution used by the UN aviation agency ICAO for certification of compensation measures within the aviation's global climate compensation program CORSIA, i. e. that instead of building its own detailed certification system, it is possible for independent certification programs to, based on a number of basic requirements, to be approved for use under CORSIA - a "certification of certifications". It is important to note that it is the growth (photosynthesis) that creates the opportunities, and that the certification does not reward measures that reduce growth, which will result in a negative climate impact in the long run. It is important that the forest products (substitution) are included because the forest is special as the product (the tree) is also a warehouse. Increasing the stock too much reduces the possibilities for sustainable substitution. KSLA wants to emphasize that the role of the forest in the carbon balance is greater than the agricultural carbon sequestration in the soil. This means that the forest's function regarding the pursuit of net zero has a greater significance compared with agriculture. The certification should be linked to the products, i. e. that the farmer or forestry gets paid better for the product if they also manage to bind an increased amount of carbon. KSLA finds it positive that a committee is appointed to work further with possible ways to achieve a long-term stable certification system. KSLA is happy to contribute with science and proven experience in the upcoming work.
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Response to Restoring sustainable carbon cycles

7 Oct 2021

Agriculture Soil carbon stocks in arable mineral soils in Sweden have increased with the equivalent of 2,4 Mton CO2 per year over the last 30 years. Modern Swedish agriculture has turned from a carbon source, through drainage and cultivation of wetlands and intense soil cultivation, to a sink, by adapting soil conservation practices. This change has not occurred as the result of an intended carbon balancing strategy, but as a side effect from the production of food and feed. This shows that there is no fundamental conflict between agricultural productivity and climate change mitigation. Reduced tillage and more varied crop rotations, including cover crops and perennial forage crops, show promising results regarding increased soil carbon content, improved soil fertility and increased productivity. The use of mineral fertilizer results in increased CO2-assimilation and production as well as carbon inputs to soil. Closing yield gaps by increasing soil fertility and productivity is a land sparing strategy that also helps prevent climate change and biodiversity loss. Arable land is a major reservoir for organic carbon and it is crucial that the organic matter in soils is preserved or increased. Farmers may be rewarded for carbon storage. In a short-term perspective, verification of carbon changes at field or farm scale is expensive and almost impossible. Action based measures are cheaper and easier to verify. There is also a risk that a model based on net carbon sequestration will indirectly punish farmers who have been practising good carbon management over a longer period, and thus do not have the same carbon removal potential as farms on degraded soils. A system for promoting good carbon management needs to be based on third party certification of verified local mitigation actions, validated by long time trials and regional or national monitoring of soil carbon levels. Forestry The EU policy proposed aims at ”restoring” forests by applying “nature-based solutions”. Forests are dynamic across regions, but also through times scales of decades and centuries. For example, fires were much more common under unmanaged conditions. The terms restoration and nature-based solutions as used here are vague and not suitable bases for EU policy. Regarding forestry, the temporal and spatial delineation of the system considered is crucially important. For example, felling trees reduces the carbon stock in the clear-felled area in the shorter term. However, modern forest management in Norway, Sweden and Finland has demonstrated large increases in the carbon stock in forests and in removals by harvests as the growth rate in the managed forests has increased greatly. As from the early 1990´s, Swedish forest policy has aimed both at high production and increasing ambitions to enhance biodiversity. Thus, there have been documented increases in the percentage of old forests, the volume of dead wood, the volume of broadleaved trees, and in the area of forests set aside for non-wood production. Environmental conditions, such as soil fertility and climate, vary greatly across the union. Hence, one type of management will not be optimal across the union. For example, under the nutrient-poor conditions in northern Europe, forest management needs to create larger gaps (clear-fellings) to promote tree regeneration and growth than under conditions of higher nutrient supply in south and central Europe. Lastly, the EU needs to consider that a policy decreasing tree growth in the forests of northern Europe will have a substantial impact on the supply of wood products to EU consumers. This may result in needs to import wood products from outside the EU, greatly increase forest harvesting in other parts of the EU, or increased use of fossil raw materials. The two first options would result in no change in the overall effect on atmospheric CO2. The last option would clearly add fossil carbon to the atmosphere. The EU policy must encompass these perspectives.
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