Fern

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.

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.

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.

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.