Response to European Commission consultation on LULUCF Regulation

Response to European  Commission consultation about EU rules on LULUCF – evaluation

Preventing the worst impacts of the climate crisis requires rapid phasing out CO2 emissions as well as strengthening the ability of natural ecosystems to sequester and store carbon. We are deeply concerned that, despite the 2030 LULUCF target, forests and other ecosystems in the EU are sequestering progressively less carbon. The impact of reduced carbon sequestration is equivalent to that of greater fossil carbon emissions. The main reason for this is the reduction in forest carbon sinks, to a large part due to the intensification of logging which correlates with the growing demand for wood bioenergy.

In Germany for example, carbon sequestration by forests has been decreasing since 2013 and, as a result, the LULUCF sector as a whole has become a net source of CO2e emissions, despite the fact that Germany’s LULUCF target is part of its domestic climate law. The reason is a combination between over-exploitation of forests, increasingly for wood bioenergy, and the escalating climate crisis. Over 600,000 hectares, mostly of spruce monocultures, have died off. Instead of allowing the forests to regenerate, those areas are routinely cleared of all wood, with low-quality wood in high demand for energy – even though this depletes forests soils and exposes saplings to greater heat and drought. Logging rates have been increasing since 2016, putting already damaged forests under more pressure rather than allowing them to recover. Close-to-nature forestry, which would make forests more resilient, is widely rejected in fabour of short-term maximisation of wood recovery. Half of all wood in Germany is burned for energy, including one-third of every tree that is cut down.

Germany is one of seven EU member states where the LULUCF sector is now a net source of CO2 emissions. In another 11 member states, the LULUCF carbon sink is now smaller than it was in 1990, i.e. when the Kyoto Protocol was signed.

We believe that the Commission must effectively challenge Member States that are not taking credible action to meet LULUCF targets, including those that fail to align their implementation of the 2023 Renewable Energy Directive with their LULUCF target. Under that directive, energy from domestic forest biomass must be consistent with LULUCF targets, something that is clearly not the case in the large majority of EU member states with declining LULUCF carbon sinks or where the LULUCF sector is already a net source of CO2e emissions, such as in Germany. Direct and indirect subsidies to buring forest wood must not continue when LULUCF targets being ignored and forecast to be missed by a large margin.

Furthermore, the LULUCF Regulations need to be implemented in alignment with the Nature Restoration Law, given that carbon sequestration depends directly on protecting and restoring ecosystems, including healthy forest ecosystems.