Fern

We welcome recognition in the Climate Target Plan Communication of the need to increase efforts to mitigate climate change, increase renewable energy consumption and enhance the EU’s terrestrial carbon sinks by 2030, while protecting forests and safeguard the environment.

To promote raw materials resilience and safeguard a just transition, the CRMA must include measures to reduce raw material demand, ensure that strategic projects operate transparently and guarantee complete participation of local civil society, communities and indigenous peoples, prioritise circularity, and mandate compliance with existing due diligence standards and international human rights and environmental…

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.

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.

CERTIFYING EU ACTIVITIES TO INCREASE CARBON REMOVALS FROM LAND M A R C H 2 0 2 3 - N G O P O L I C Y PA P E R F or agricultural and forested land, the KEY RECOMMENDATIONS aims of the European Commission’s proposed voluntary EU Carbon Removal • Ban carbon offsetting and only allow the Certification Framework (CRCF) include: certification of land-use activities (activity- − Increasing carbon removals by establishing…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Carbon must have its price, said many times the European Commissions President Ursula Von der Leyen. The gradual broadening of the EU ETS1 and the upcoming ETS2 are meant to implement this vision. Globally, about 30% of the excess CO2 added to the atmosphere by humans since 1850 has come from land use change, i.e. deforestation, forest degradation, agriculture etc. Using biogenic carbon is not climate neutral.

We appreciate the opportunity to provide feedback on this most strategic topic. We mostly comment on the bioenergy framework. We enclose our full feedback in the enclosed document, but our main observations are the following: The justification for renewable energy targets and subsidies has been the reduction of carbon dioxide emissions.

“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.

These are Ferns observations on the proposed EU Climate Law Amendment: - As the ESABCC observed, a 90-95% domestic reduction by 2040 is feasible and aligned with Europes strategic interests. The European Commission failed to align its initial proposal on this scientific recommendation, and Member States are now weakening it further.

It is surprising, and even scandalous, that this consultation on CCUS is happening. The fossil fuels industry has been pushing the concept in policy for at least three decades, arguing this would be a way to produce low carbon fossil fuels and that CCS technologies would be needed to reach climate goals.

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.

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.

The poor state of European forests means better monitoring is necessary: Many stand-alone studies suggest a grim picture of the state of Europe’s forests. The overwhelming majority of forests in Europe have medium to low ecosystem integrity, despite having high forest cover, because the landscape has become so fragmented. In protected areas, forestry is the highest threat to protected habitats and species.

On behalf of Fern, we welcome the revision of the Ecodesign Regulation for solid fuel space heaters (EC 2015/1185). The energy prices crisis which followed the Russian invasion of Ukraine has driven up both the prices of fossil fuels and wood solid fuels.

Fern welcomes the opportunity to contribute to the call for evidence on the update of the Governance Regulation. Our feedback will be limited to the issue of the reporting of woody biomass production and uses by Member States. The 2018 Regulation, Annex IX (m) and (n) required detailed reporting by EU Member States on their supply of primary woody biomass used for energy production and final energy consumption.

Fern welcomes the review of the Directive on unfair trading practices in the agricultural and food supply chain as an opportunity to strengthen protections for small farmers. We have extensive experience monitoring the cocoa sector, which consist mostly of production by small farmers; these small farmers systematically and constantly experience abusive trading practices from their buyers.

Land Use, Land Use Change and Forestry reporting shows EU climate targets are in danger of not being met 2030 LULUCF target not on track: risk to overall EU climate target As the first reporting period for the Land Use, Land Use Change and Forestry (LULUCF) Regulation ends in 2025, this is a good moment to consider progress towards the target of removing 310 megatons (Mt) of carbon by 2030.

The EU and UN cannot meet their climate goals unless they step up action to protect the world’s forests. The first way to do this is by strengthening forest and land governance. As numerous studies have proven, forests are protected best when land and tree tenure rights of local communities are legally recognized.

Fern welcomes the initiative of a Roadmap but we are concerned about the suggested reliance on existing policies and tools to step up EU action, as the Roadmap does not expressly recommend filling gaps in the existing framework with new and targeted policy actions / new regulatory measures to contribute to halting, preventing and reversing deforestation.

On behalf of Fern, we welcome the revision of the Ecodesign Regulation for solid fuel boilers (EC 2015/1189). The energy prices crisis which followed the Russian invasion of Ukraine has driven up both the prices of fossil fuels and wood solid fuels.

Fern is a non-governmental organisation which aims to achieve greater environmental and social justice, focusing on forests and forest peoples’ rights in the policies and practices of the European Union. Fern believes that the EU Forest Law Enforcement Governance and Trade (FLEGT) Action Plan through its Voluntary Partnership Agreements (VPAs) has prompted forest-related legal and policy reforms in all partner…