Latvian Peat Association
LPA
LPA unites Latvian peat producers, entrepreneurs and natural persons, which have given significant investment for the industry development.
ID: 206348832825-42
Lobbying Activity
Response to Report on the evaluation of the LULUCF Regulation
11 Jul 2024
Drafting and amending EU regulations is a large-scale work that requires a lot of resources from the parties involved. Therefore, before deciding on the revision of the regulation, the information on the basis of which the LULUCF regulation and other regulatory acts are developed should be critically evaluated. It is about the IPCC methodology. When evaluating the regulation, targeted consultation of experts is foreseen. Regarding the wetlands section, experts should be consulted who really have knowledge about GHG emissions from peat, and not simply wetland experts who probably focus their activities mainly on the biological diversity of wetlands. Regarding the current calculation of GHG emissions from the extraction of resources (according to IPCC methodology), especially peat, we point to several shortcomings. It is not wise to ask for zero net GHG emission in a place where there are natural emissions. For example, a natural bog has emissions, but a peat extraction site should aim for zero emissions. How can there be zero emissions in a place where it does not occur naturally and is not possible? We should talk about the difference between natural emissions and emissions from anthropogenic impact, we should strive to minimize this difference. The immediate oxidation method, according to which all extracted peat is oxidized in the year of extraction, does not correspond to reality. The entire cycle of peat circulation (extraction, use in greenhouses or for soil improvement, spreading on the field) is not taken into account. Also, it is not taken into account that horticultural peat is exported from extraction countries to countries where it is used. And there the peat continues its life cycle - it is used in greenhouses, ensuring CO2 absorption. This is not evaluated and calculated at all. After being used in a greenhouse, peat is not waste, but can be used to improve the soil and for greening of urban areas. In conclusion, we would like to emphasize that efforts first should be devoted to improving the GHG accounting methodology and then we can improve the legislation. The EC, as an influential player, could contribute to the IPCC's activities in this direction. This would allow for more productive progress towards the achievement of climate goals.
Read full responseResponse to Protecting biodiversity: nature restoration targets
19 Aug 2022
Please find attached an opinion of Latvian Peat Association. A Regulation should not be adopted, but a Directive can be discussed. The geographical differences of the Member States should be taken into account. The restoration of ecosystems is a sensitive issue that affects the interests of many involved parties, therefore there is no need to rush, but on the contrary, flexibility is needed. Restoration measures will need to be site-specific. The proposal of the Regulation in its current version suggests that the EU decides on the use of land instead of land owner (state, municipalities, private individuals). It shouldn't be so.
Read full responseResponse to Soil Health Law – protecting, sustainably managing and restoring EU soils
15 Mar 2022
Latvian Peat Association gives the feedback on planned Soil Health Law in scope of EC “Call for evidence”. There is no doubt that soils should be protected, but before a new law is drafted, existing laws must be implemented. The EU already has a number of regulations in place. Please see attached file.
Read full responseMeeting with Sofja Ribkina (Cabinet of Executive Vice-President Valdis Dombrovskis)
22 Dec 2021 · Upcoming Green Deal-related legislative acts, challenges and opportunities for peat sector
Response to Climate change mitigation and adaptation taxonomy
18 Dec 2020
Latvian Peat Association gives a feedback on Delegated Regulation (EU) …/... of XXX supplementing Regulation (EU) 2020/852.
In Annex I, Chapter 2.1. Restoration of wetlands, under headline “Do no significant harm (' DNSH ') ', p.60., line “(4) Transition to a circular economy / Peat extraction is minimized.” needs to be corrected. It is understandable that the impact of the planned activities on the circular economy should be assessed, however, in the case of wetland restoration, the connection with the circular economy is only if perennials (berries, other plants) are grown in the wetland. In the line “(4) Transition to a circular economy”, “N/A” may be entered as in, for example, 7.3. chapter and others. Or express this line as follows: “(4) Transition to a circular economy / Renewed wetlands are used for food production - berry plantations or other paludicultures.” The same applies to Annex II, Chapter 2.1. Restoration of wetlands, p. 44.
We draw your attention that the use of peat in horticulture is an example of a circular economy. Plants, when growing in peat substrates, attract oxygen, provide food, ornamental plants and tree seedlings. Afterwards peat and peat substrates are used to improve the soil by enriching the soil with organic matter and nothing ends up in the waste.
Assessing the DR annexes as a whole: there should be flexibility in the use of criteria, taking into account local conditions, such as water consumption. Not all MS have water scarcity. Similarly, there are different situations in MS for the use of agricultural and forest land.
Read full responseResponse to Climate Law
5 Feb 2020
We express some concerns regarding planned Climate Law. There are already many regulatory documents in the EU regarding climate issues. Member States (MS) just have prepared National Energy and Climate Plans (NECP). Other legislation pieces, including LULUCF Regulation are in force already. One more law will not improve climate, but certainly will create additional bureaucracy – MS will have to prepare more reports and inventories. Better is to try to implement already existing regulation (Climate Convention, EU requirements), MS already have difficulties with this.
If however, the Climate Law will be written, it should allow the MS themselves to choose how to reach climate-neutrality. MS should have a right to make choices how to compensate GHG emissions in scope of sector.
EU legislation should be based on correct (true) information which corresponds to real situation in the MS, EU and world. F.e., in the statistics about goods external sales, in accordance with the Combined Nomenclature (CN), peat is classified as an energy product and is mentioned next to coal products: “Section 27. Mineral fuel, mineral oils and their distilled products; bitumen substances: mineral waxes”, code 2703. There is no other place for peat and peat products (substratum) in CN. For peat and peat product exporting companies, this is the only place to account for this export. Therefore, the Latvian and EU statistics creates a completely incorrect conception about peat usage. Peat and peat substratum are exported only for use in agriculture and forestry. The peat extracted in Latvia is one third or 31% of the peat used in professional horticulture in the European Union. Unlike peat use for energy peat use for horticulture provides GHG sequestration. But still nobody took care to create appropriate CN. Therefore the risk that EC makes legislation using incorrect data and assumptions is very high.
In order to limit climate change, better to avoid flying to meetings of the EC, Climate Convention that result in no change (if the result is mitigation of climate change), because the public is not ready to pay for it. Creating of new law means endless meetings in Brussels and everywhere else.
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