COMMUNICATION FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT, THE COUNCIL, THE EUROPEAN ECONOMIC AND SOCIAL COMMITTEE AND THE COMMITTEE OF THE REGIONS Accounting for land use, land use change and forestry (LULUCF) in the Union's climate change commitments
Date: 2012-03-12
Institutions: European Commission
Subjects: accounting system, agri-foodstuffs, climate change, disclosure of information, economic accounts for agriculture, environmental standard, farming sector, greenhouse gas, management of resources, reduction of gas emissions, renewable energy, silviculture, sustainable development

EUROPEAN COMMISSION 

Brussels, 12.3.2012  
COM(2012) 94 final 

COMMUNICATION FROM THE COMMISSION TO THE EUROPEAN 
PARLIAMENT, THE COUNCIL, THE EUROPEAN ECONOMIC AND SOCIAL 
COMMITTEE AND THE COMMITTEE OF THE REGIONS 

Accounting for land use, land use change and forestry (LULUCF) in the Union's climate 
change commitments 

 
 
 
 
  
 
1. 

THE NEED TO ACT ON CLIMATE CHANGE NOW  

At  the  end  of  2010,  in  the  context  of  United  Nations  Framework  Convention  on  Climate 
Change (UNFCCC), it was recognized that global warming must not exceed the temperatures 
experienced before the industrial revolution by more than 2˚ C1. This is vital if the negative 
consequences of human interference with the climate system are to be limited. This long-term 
goal  requires  global  greenhouse  gas  emissions  to  be  reduced  by  at  least  50%  below  1990 
levels by 20502.  

Developed  countries  as  a  group  should  reduce  their  emissions  by  80  to  95%  by  2050 
compared  to  1990  levels3.  In  the  medium  term,  the  EU  has  committed  to  reduce  its 
greenhouse gas emissions by 20% below 1990 levels by 2020, and by 30% if conditions are 
right. This commitment forms part of one of the EU's five headline targets in the Europe 2020 
Strategy.4 Additionally, both the European Council and the European Parliament have agreed 
that all sectors of the economy should contribute to reducing emissions5.  

Land use, land use change and forestry (LULUCF) has a positive and significant impact on 
the EU's greenhouse gas emissions. The sector removes the equivalent of 9% of greenhouse 
gases  emitted  in  other  parts  of  the  economy6.  Although  emissions  and  removals  from 
LULUCF are reported under the UNFCCC and partially accounted under the Kyoto Protocol, 
the  sector  was  left  out  of  the  EU's  climate  commitments  under  the  Climate  and  Energy 
Package7  due  to  the  recognition  of  serious  deficiencies  in  international  accounting  rules  of 
emissions from this sector. 

Also, the expectation at the moment of setting the EU emission reduction target was that the 
climate summit in Copenhagen in 2009 would deliver an international agreement on climate 
change, including revised accounting rules for LULUCF, which could then be adopted by the 
EU. This did not happen, and despite the progress achieved through the Copenhagen Accord 
and  the  Cancun  Agreements  an  international  agreement  on  revised  accounting  rules  for 
LULUCF as of a second commitment period under the Kyoto Protocol was only achieved at 
the 17th Conference of the Parties to the UNFCCC meeting in Durban in December 2011. 

This Communication outlines how the LULUCF sector increasingly could be integrated in the 
EU's  climate  policy  using  a  step-wise  approach.  As  a  first  step,  it  is  proposed  to  establish 
robust  common  accounting,  monitoring  and  reporting  rules.  In  view  of  the  sector's  specific 
emission profile, the Commission proposes a dedicated legal framework, rather than including 

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Decision 1/CP.16 of the Conference of Parties to the UNFCCC (the "Cancún Agreements"). 
Based on the Fourth Assessment Report of the Intergovernmental Panel on Climate Change (IPCC). 
Conclusions  of  the  European  Council  of  29/30.10  2009  and  European  Parliament  Resolution  of  4.2 
2009 (2008/2105(INI)). 
COM(2010) 2020 final. 
Directive 2003/87/EC and Decision 406/2009/EC. 
National total excluding the LULUCF sector. 
Unlike  non-CO2  greenhouse  gases  from  agricultural  activities  e.g.  methane  and  nitrous  oxide  from 
ruminants and fertilisers. 

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it in the EU Emissions Trading Scheme8 or as part of the rules created by the Effort Sharing 
Decision9.  

Setting solid accounting rules for emissions and removals in the EU that take into account the 
specific  profile  of  the  LULUCF  sector  would  bring  multiple  benefits.  Most  importantly,  it 
would complete the accounting of anthropogenic greenhouse gas emissions from all economic 
activities within the EU10 by capturing important fluxes currently ignored. As part of that, it 
would increase the visibility of mitigation efforts in agriculture, forestry and related industries 
(e.g.  pulp  and  paper,  wood  processing)  and  provide  a  basis  for  designing  adequate  policy 
incentives,  for  example  in  the  Common  Agriculture  Policy  (CAP)  and  in  view  of  the 
Roadmap to a Resource Efficient Europe11. Laying down common EU accounting rules would 
also level the playing field between different Member States. Most notably, it would capture 
the  changes  in  carbon  stocks  due  to  the  use  of  domestically  produced  biomass,  thus 
completing  the  accounting  of  bioenergy  at  the  level  of  the  economy,  as  stipulated  by  the 
Intergovernmental Panel on Climate Change (IPCC)12 as a condition for assuming bioenergy 
as carbon neutral in the energy sector. This would strengthen the environmental integrity of 
the EU's climate policy. Lastly, it would be an important and necessary move towards a cost 
effective pursuit of more ambitious climate targets. 

The second step would be to formally include LULUCF in the EU's greenhouse gas reduction 
target.  It  is  proposed  to  take  this  step  when  the  Member  States  have  implemented  the 
accounting framework and it has proven to be robust.  

As the LULUCF sector's positive impact on the EU's emissions decreases over time, there is 
an  urgent  need  for  coherent  action.  Therefore,  the  Commission  proposes  as  part  of  the  first 
step that the Member States prepare LULUCF action plans setting out a long-term strategy for 
the sector across different policies. 

2. 

THE ROLE OF LAND USE AND FORESTRY IN CLIMATE CHANGE 

In the LULUCF sector carbon is removed  from the atmosphere and stored in  growing trees 
and other plants, soils and wood products. Carbon is emitted as a result of deforestation and 
forest degradation (due to e.g. infrastructure development, agricultural expansion, conversion 
to pastureland and fires) or of agricultural practices (e.g. ploughing). 

Different  LULUCF  elements  have  different  characteristics  in  terms  of  carbon  stocks  and 
potential emissions and removals. The soil carbon content (0-30 cm) of forestry is relatively 
high compared to agricultural soils. In the EU, it is estimated at around 90 tC/ha, whereas the 
soil  carbon  content  from  cropland  and  grassland  is  around  65  and  90  tC/ha  respectively 
(Figure  1).  Still,  there  are  significant  variations  both  across  and  within  Member  States.  In 
European organic soils/peat lands the carbon soil content can be up to 1000 tC/ha. Different 
land uses and management activities in agriculture and forestry and uses of harvested wood 
products can affect carbon stocks, and emissions to and removals from the atmosphere. 

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Directive 2009/29/EC. 
Decision No 406/2009/EC. 
Except for international aviation and maritime transport. 
COM(2011)571 final. 
IPCC 2006 Guidelines. 

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Figure 1. Average carbon stocks (t C/ha) in different land use in the EU  

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living biomass

dead organic matter

soil

Forest

Cropland

Grassland

Note: For peat land, estimates can be as high as 1000 tC/ha with variations depending on type of peat. 

Source: Elaborations done by the Joint Research Centre of the European Commission, based on various sources13 .  

The global biomass and soil carbon stock is immense (compared to the annual greenhouse gas 
emissions).  But,  globally  LULUCF  accounts  for  about  15  %  of  greenhouse  gas  emissions14 
due  to  substantial  deforestation.  This  is  more  than  the  emissions  from  the  entire  global 
transport sector and second only to the energy sector. 

Therefore  it  is  crucial  to  preserve  and  enhance  the  carbon  stock  and  reduce  LULUCF 
emissions  from  it.  The  EU's  objective  is  to  halt  global  deforestation  by  203015.  Reducing 
Emissions  from  Deforestation  and  Forest  Degradation  (REDD)  in  developing  countries  is  a 
mechanism developed in the UN to counter this trend.  

In  industrialised  countries  the  LULUCF  sector  represents  in  most  cases  a  net  sink  (i.e. 
removals  are  higher  than  emissions).  However,  the  capacity  of  this  sink  is  decreasing  for 
reasons such as increased demand for biomass, ageing forests in certain countries and a trend 

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to 

The  sources  used  include:  Forest  Europe,  UNECE  and  FAO  (2011):  State  of  Europe’s  Forests  2011; 
Status  and  Trends  in  Sustainable  Forest  Management  in  Europe;  FAO,  Global  Forest  Resources 
Inventory 
Assessment  FRA  2010,  http://www.fao.org/forestry/fra/fra2010/en/;  GHG  National 
Submissions 
UNFCCC 
(2011) http://unfccc.int/national_reports/annex_i_ghg_inventories/national_inventories_submissions/ite
ms/5888.php;  IPCC  Guidelines  for National  Greenhouse  Gas  Inventories  (2006),  Volume  4, 
Agriculture, Forestry and Other Land Use; Pan et al. (2011) A large and persistent carbon sink in the 
world’s  forests.  Science  DOI:  10.1126/science.1201609;  Hiederer  et  al.  (2011)  Evaluation  of  BioSoil 
Demonstration 
Project; 
http://publications.jrc.ec.europa.eu/repository/bitstream/111111111/15905/1/lbna24729enc.pdf; 
FAO/IIASA/ISRIC/ISS-CAS/JRC, 2009. Harmonized World Soil Database (version 1.1). FAO, Rome, 
Italy and IIASA, Laxenburg, Austria; Schulze et al. (2009) Integrated assessment of the European and 
North  Atlantic  Carbon  Balance  (results  of  CarboEurope-IP),  DOI  10.2777/31254;  Smith  et  al.  (2005) 
Projected  changes  in  mineral  soil  carbon  of  European  croplands  and  grasslands,  1990–2080.  Global 
Change Biology DOI: 10.1111/j.1365-2486.2005.001075.x. 
Intergovernmental Panel on Climate Change Report IV (2008). 
Conclusions of the European Council of 4.12.2008. 

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towards intensification of forest use. In the EU, greenhouse gas emissions come mainly from 
energy production, transport and buildings (see Figure 2).  

Figure 2. Emissions and removals per sector in the EU-27 as share of the total excluding LULUCF (2009) 

Energy production

Transport

Households&services

Manufacturing&construction

Agriculture

Industrial Processes

Waste

Solvent & other product use

LULUCF

-20.0%

-10.0%

0.0%

10.0%

20.0%

30.0%

40.0%

Note:  (1)  Negative  numbers  denote  net  removals  and  positive  numbers  net  emissions.  (2)  Emissions  from  "Agriculture" 
include  methane  (e.g.  from  livestock  production)  and  nitrous  oxide  (e.g.  from  fertilizer  use).  CO2  emissions  and  removals 
associated with agricultural land use are included in the LULUCF sector.  

Source: EEA (2011) 

The sink in the LULUCF sector is projected to decrease in the EU by 2020 under a business-
as-usual scenario16. For the LULUCF sector as a whole, a decline of about 10% is expected in 
2020  compared  to  the  period  2005-2009,  equivalent  to  emitting  33  MtCO2  more  per  year. 
This is roughly equivalent to all greenhouse gas emissions in Latvia and Lithuania combined, 
or twice those of Estonia in 2009.  

A  closer  look  at  this  projection  shows  that  there  are  big  differences  between  individual 
activities  within  the  sector.  The  decrease  is  expected  to  be  very  pronounced  in  forest 
management, for which net removals are expected to fall by about 60 MtCO2, i.e. roughly the 
equivalent to the total greenhouse gas emissions of Bulgaria, Denmark, Ireland or Sweden in 
2009.  This  is  partly  compensated  by  the  plantation  of  forests  (afforestation).  Emissions  and 
removals  from  agricultural  activities  such  as  cropland  management  and  grazing  land 
management are expected to remain fairly stable or to improve. But pressure on land use, such 
as the conversion of permanent grassland into cropland due to increased need of biomass (e.g. 
for biogas production based on maize) and continued cultivation of organic soils may reduce 
soil carbon content and contribute to emissions.  

16 

In this context "Business as Usual" assumes that Member States will reach their 20% reduction targets, 
including the targets for renewable energy.  

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According to projections, as shown in the Roadmap for moving to a competitive low-carbon 
economy  in  205017,  this  negative  trend  is  expected  to  continue  in  the  long  run.  But  the  real 
results for the sector will depend greatly on incentives given under various policies.  

Figure 3. Projected emissions and removals in LULUCF as a whole and in pre-1990 forests (2000-2020)  

2005

2010

2015

2020

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2000

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-100000

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Notation key: ●–●–● LULUCF (sum of all activities), ▲–▲–▲ Deforestation, +–+–+ Cropland management, ––– Grazing 
land management, ♦–♦–♦ Afforestation, and ■–■–■ Forest management. Unconnected points show reported / historical data.  

Note: A negative number indicates that removals are greater than emissions for that activity. 

Source: Böttcher et al. (2011) and JRC (2011b) 

3. 

AGRICULTURE,  FORESTRY  AND  THE  EFFICIENT  USE  OF  LAND  RESOURCES  ARE  KEY 
TO MEETING THE CLIMATE CHALLENGE  

Agriculture,  forestry  and  related  industries  can  contribute  to  reducing  emissions  in  the 
LULUCF sector in several ways.  

Agricultural measures should focus on reducing the conversion of grassland to cropland and 
carbon  losses  from  cultivated  organic  soils.  They  could  include  improving  agronomic 
practices  such  as  using  different  crop  species  (e.g.  more  leguminous  crops),  extending  crop 
rotations  and  avoiding  or  reducing  unplanted  fallow  (e.g.  through  green  cover  or  ecological 
set-aside).  Agro-forestry  practices  that  increase  soil  carbon  stocks  by  keeping  livestock  or 
growing  food  crops  on  land  where  also  trees  are  grown  for  timber,  energy  or  other  wood 
products  would  also  help  cut  emissions.  Returning  or  leaving  adequate  amounts  of  organic 
material (e.g. farmyard manure, straw, crop residues) on the land can improve the productivity 
of  croplands  and  grasslands,  while  rewetting,  setting  aside  or  not  draining  organic  soils, 
including  peat  land,  and  restoring  degraded  soils  can  have  significant  mitigation  and 
biodiversity benefits. Including cropland and grazing land management into accounting would 

17 

COM(2011) 112. 

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be a necessary step towards the full recognition of the contribution of these activities to meet 
the climate challenge.  

Forestry  also  has  much  potential  to  boost  mitigation.  This  includes  practices  such  as 
converting  non-forest  land  to  forest  (i.e.  afforestation)18,  avoiding  the  conversion  of  forest 
land  to  other  types  of  land  (i.e.  deforestation),  storing  carbon  in  existing  forests  through 
longer  rotation  periods  of  trees,  avoiding  clear-felling  (e.g.  forest  management  decisions  on 
thinning or selective logging) and conversion to undisturbed forests, and more widespread use 
of prevention measures to limit the impacts of disturbances such as fires, pests and storms. It 
is  of  equal  importance  to  enhance  production  in  forests  for  example  by  adjusting  rotations 
closer  to  the  productive  maximum,  producing  more  from  low-production  forests,  increasing 
the  harvest  of  timber  off-cuts  and  branch-wood  (provided  biodiversity,  soil  fertility  and 
organic matter can be maintained). Changing species composition and growth rates can also 
make a difference.  

In addition to the opportunities directly linked to forestry and agriculture, there are potential 
mitigation  benefits  in  related  industries  (e.g.  pulp  and  paper,  wood  processing)  and 
renewable energy sectors if agricultural land and forests are managed for the production of 
timber and energy. Whilst carbon is stored in trees and in other plants and soils, it can also be 
stored  for  several  decades  in  products,  e.g.  construction  wood.  Industry  and  consumer 
oriented  policies  can  make  a  significant  contribution  to  increasing  the  long  term  use  and 
recycling of wood and/or production of pulp, paper and wood products as substitutes for more 
emission-intensive  equivalents  (e.g.  concrete,  steel,  fossil-based  plastic).  The  bio-based 
industry  can  make  use  of  crops  grown  for  material  substitution  (e.g.  hemp  and  grass  for 
insulation  instead  of  glass  fibre,  straw  for  furniture  production,  car  door  panels  made  from 
flax or sisal plants, bio-plastics) or energy (e.g. using biomass instead of fossil fuels). Studies 
show  that  for  each  tonne  of  carbon  in  wood  products  substituted  for  non-wood  products  an 
average  greenhouse  gas  emission  reduction  of  approximately  two  tonnes  carbon  can  be 
expected19. 

Expanding  mandatory  accounting  to  include  forest  management,  cropland  management  and 
grassland management would improve the visibility of action taken by farmers, foresters and 
forest-based industries and provide the basis for designing policy incentives to increase their 
mitigation action. If such efforts are being accounted for, their overall greenhouse gas impact 
is  more  correctly  reflected  and  the  cost-efficiency  of  reaching  emission  reduction  targets 
would be improved. 

Considering  that  agricultural  land  use,  forestry  and  related  industries  are  very  different  in 
terms  of  mitigation  potential  within  the  EU-27,  a  single  policy  will  not  fit  all.  A  tailored 
approach is needed to tackle the range of different forms of land use and forestry practices. 
For instance, in Sweden and Finland, net removals in LULUCF are more than half the total 
emissions in other sectors and in Latvia net removals are almost double (Figure 4), while in 
other Member States such as Malta the significance of the sector is marginal. This highlights 
the importance of considering national circumstances when developing policy for the sector to 
meet climate change commitments. 

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19 

There  is  also  a  trade-off:  conversion  should  not  induce  "carbon  leakage",  i.e.  replacement  of 
domestically produced food by imported food that has a more negative carbon footprint. 
See e.g. Sathre R. and O'Connor J. (2010), A synthesis of research on wood products and greenhouse 
gas impacts, 2nd edition, Vancouver, B. C. FP Innovations, 117p. (Technical Report No. TR-19R).  

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Figure 4. Relative importance of LULUCF in Member States: emissions and removals of the sector relative to total 
greenhouse gas emissions in other sectors (2009).  

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Note: A negative number indicates that removals are greater than emissions in LULUCF for that Member State. Due to inter-
annual variations in emissions and removals the share varies between years. 

Source: Based on EEA (2011) 

The  fundamental  pre-condition  for  protecting  and  enhancing  carbon  stocks  and  the  rate  of 
removals is to provide a level playing field between different types of measures (e.g. grazing 
land  management  or  bio-energy  production),  sectors  (e.g.  forestry  or  forest-based  industry) 
and Member States by ensuring that emissions and removals from different land management 
practices and uses of resources are accurately reflected in accounting. This will also improve 
the environmental integrity of the EU's climate change commitments. 

4. 

CURRENT POLICIES ARE NOT ENOUGH  

4.1. 

Setting robust and harmonized accounting rules 

Although  LULUCF  does  not  yet  count  towards  the  Union's  emission  reduction  target  for 
2020, it counts towards the Union's commitment under the Kyoto Protocol to the UNFCCC 
for the period from 2008 to 201220. However, the existing accounting rules, which are a mix 
of  voluntary  and  mandatory  practices,  have  significant  drawbacks.  During  the  international 
negotiations held in recent years, there was a consensus that improvements were needed.  

Under  the  existing  accounting  rules,  accounting  is  voluntary  for  most  LULUCF  activities, 
notably for forest management (which represents about 70% of the sector) and cropland and 
grazing  land  management  (17%).  It  is  only  mandatory  for  some  land  use  change  activities 
(afforestation, reforestation and deforestation). As a result, accounting in the Member States is 
currently  highly  variable  (Figure  5).  Less  than two  thirds  of  the  Member  States  account  for 

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Council Decision 2002/358/EC.  

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forest  management,  only  three  for  cropland  and/or  grazing  land  management  and  one  for 
revegetation.  

Another drawback is the lack of incentives provided for climate change mitigation in forestry. 
Current  rules  for  forest  management  essentially  guarantee  countries  an  amount  of  credit, 
regardless  of  the  action  taken.  Incentives  to  improve  practice  are  limited  by  a  cap  on 
emissions and removals, beyond which point action no longer counts. This creates distortions 
between  different  sectors  and  land  uses  and  improvements  are  necessary  to  create  a  level 
playing  field  within  the  forestry,  agricultural  and  energy  sectors  in  the  Member  States,  to 
provide a fair distribution of effort and to ensure a consistent treatment of agriculture, forestry 
and related industries within the Union's internal market.  

Figure 5. Share of Member States that have chosen to voluntary account for the various practices 

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Forest management

Cropland
management

Grazing land
management

Revegetation

4.2. 

Improving monitoring and reporting 

Robust  and  harmonised  estimation  of  emissions  and  removals  in  agriculture  and  forestry 
requires investment in monitoring and reporting capacity. Member States are obliged to report 
annually  to  the  UNFCCC  and  there  are  additional  reporting  requirements  under  the  Kyoto 
Protocol.  Monitoring  and  reporting  have  started  to  improve  in  recent  years  and  will  most 
likely continue to do so. Definitions, modalities, and rules relating to LULUCF for the second 
commitment  period  of  the  Kyoto  Protocol  were  revised  and  improved  during  the  17th 
Conference  of  the  Parties  of  the  UNFCCC  meeting  in  Durban  in  December  201121.  In 
particular  accounting  for  forest  management  activities,  including  harvested  wood  products, 
will  be  mandatory  and  definitions  for  "natural  disturbances"  and  "wetland  drainage  and 
rewetting" have been established.  

Nonetheless,  there  are  still  significant  gaps  and  more  must  be  done  to  improve  the  level  of 
accuracy  and  completeness  of  the  reported  data,  especially  data  on  agricultural  soils.  The 

21 

Decision -/CMP.7 of the Conference of the Parties serving as the meeting of the Parties to the Kyoto 
Protocol.  

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current level of uncertainty is relatively high (about 35%, meaning that 1 tonne of CO2 could 
be either 1.35 or 0.65 tonnes). Improvements will not only support accounting, it would also 
provide a robust, clear and visible indicator of progress in agriculture and forestry22.  

4.3. 

Fostering synergies with wider policy objectives 

Incentives exist to promote the use of bio-energy23 but currently there is no coherent approach 
to climate change mitigation in the LULUCF sector via measures in agriculture, forestry and 
related industries.  

Indeed,  climate  change  mitigation  could  play  an  increasingly  important  role  in  the  CAP. 
Under  the  CAP  reform,  the  so-called  "Health  Check"24  of  2008,  climate  change  mitigation 
and  adaptation  were  flagged  as  "new  challenges".  To  prepare  the  CAP  for  2014-2020,  the 
Commission  has  outlined  how  the  environmental  and  climate  performance  of  agricultural 
policies  could  be  improved  through  mandatory  "greening  components"25  addressing  climate 
change and environmental goals26. In addition, in the post-2013 EU rural development policy, 
climate  change  mitigation  and  adaptation  could  be  tackled  by  offering  better  incentives  for 
carbon  sequestration  in  agriculture  and  forestry.  Some  of  them  would  at  the  same  time 
enhance and protect carbon stocks and generate co-benefits for biodiversity and for adaptation 
by  increasing  water  holding  capacity  and  reduced  erosion.  Mandatory  accounting  of 
associated carbon fluxes would make the positive contribution of these measures more visible 
and ensure their full contribution towards meeting the climate change challenge. 

Accounting for LULUCF would also clarify the benefits of sustainable bio-energy by better 
reflecting related emissions, in particular resulting from the combustion of biomass, which is 
unaccounted  for  at  the  moment.  This  would  strengthen  the  incentives  provided  by 
sustainability criteria in the context of renewable energy targets. 

4.4. 

Accommodating the special features of the sector 

LULUCF is, however, not like other sectors. Removals and emissions of greenhouse gases in 
this  sector  are  the  result  of  relatively  slow  natural  processes.  It  can  take  decades  before 
measures  such  as  afforestation  have  a  significant  effect.  Therefore,  action  to  increase 
removals and reduce emissions in forestry and agriculture should be considered over the long-
term.  

Moreover, emissions and removals are reversible. Reversals can be caused by extreme events 
such as fires, storms, droughts, pests having an impact on forest and land cover or they can be 
a  result  of  management  decisions  (e.g.  to  harvest  or  plant  trees).  In  addition,  annual 
fluctuations of emissions and removals in forests are high and can amount to as much as 35% 

22 

23 
24 

25 
26 

Only emissions of methane and nitrous-oxides are currently accounted in agricultural activities, while 
CO2  emissions  and  removals  associated  with  agricultural  land  use  are  not  (soil  carbon  emissions  and 
removals).  The  obligatory  accounting  of  these  measures  through  legal  proposals  would  complete  the 
assessment of emissions and removals associated with agricultural activities. 
Directive 2009/28/EC.  
Council  Regulation  (EC)  No  72/2009,  Council  Regulation  (EC)  No  73/2009  and  Council  Regulation 
(EC) No 74/2009 related to the CAP "Health Check".  
Payment for agricultural practices beneficial for the climate and the environment. 
COM(2010) 672. 

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of the total annual emissions in some Member States as a result of natural disturbances and 
harvesting. This would make it difficult for Member States to comply with annual targets. 

5. 

WAY FORWARD: A GRADUAL APPROACH  

To  prepare  for  taking  advantage  of  the  mitigation  potential  of  LULUCF  through  its  formal 
inclusion  in  the  EU's  climate  commitments,  the  inadequacies  in  the  current  accounting 
framework,  special  features  of  LULUCF,  and  circumstances  of  Member  States  must  be 
addressed appropriately. A gradual approach is therefore needed. 

Firstly, frameworks for robust accounting and monitoring need to be in place. Together with 
this  Communication,  the  Commission  is  putting  forward  a  legal  proposal  for  robust 
accounting  rules.  It  involves  inclusive  accounting  of  emissions  and  removals  from  both 
forestry  and  agricultural  activities  and  gives  equal  weight  to  mitigation  action,  whether  in 
forestry, agriculture, in related industries or the renewable energy sector.  

Monitoring  and  reporting  on  the  LULUCF  carbon  balance  needs  to  be  further  improved  to 
underpin the accounting framework and the EU indicators tracking progress in agriculture and 
forestry. The Commission proposes to improve monitoring and reporting through a revision of 
the  Monitoring  Mechanism  Decision27  and  the  further  development  of  existing  land  use 
monitoring systems like the Land use/cover area frame survey (LUCAS). 

High variability of emissions and removals in forests and the lower frequency of gathering the 
fundamental data needed for the inventories mean that it is inappropriate to require the sector 
to comply annually with the emissions reduction targets that apply for other sectors. The long 
lead  times  needed  for  mitigation  measures  to  take  effect  also  set  LULUCF  apart  from  most 
other sectors. The Commission therefore proposes to establish a separate framework designed 
to address the special circumstances of LULUCF.  

Secondly, once a harmonised and robust accounting framework is established within the EU, 
consideration could be given to formally include the sector in the EU's climate commitment.  

However, this must not mean that mitigation action in the LULUCF sector should be put on 
hold. In view of the trends in the sector and to kick-start the necessary mitigation efforts, the 
Commission  proposal  requires  Member  States  to  prepare  LULUCF  action  plans.  This  will 
provide  a  strategic  perspective  for  LULUCF  as  well  as  an  intermediate  step  towards  full 
inclusion of the sector and its integration into the EU's climate policies. 

In  conclusion,  there  are  good  reasons  to  gradually  integrate  LULUCF  in  the  EU's  climate 
change policy. The Commission's legislative proposal for a step-wise approach would: 

–  draw  up  robust  rules  for  accounting  for  emissions  and  removals  in  land  use,  land  use 

change and forestry and, through a separate act, improve monitoring and reporting; 

27 

Commission proposal for a Regulation of the European Parliament and of the Council on a mechanism 
for monitoring and reporting greenhouse gas emissions and for reporting other information at national 
and Union level relevant to climate change, (COM)2011 789 final - 2011/0372 (COD). 

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–  improve the visibility of, and provide the basis for designing policy incentives for a range 
of  mitigation  measures  in  agriculture,  forestry  and  the  production  and  sustainable  use  of 
harvested wood products;  

–  strengthen  the  environmental  integrity  of  the  commitments  made  by  ensuring  that 

emissions and removals are correctly reflected; 

–  foster  synergies  with  existing  policies  on  renewable  energy  and  the  wood  industry  by 

promoting sustainable and climate-friendly production in the EU; 

–  generate  significant  co-benefits  for  biodiversity,  soil  protection  and  climate  change 

adaptation (e.g. Natura 2000) by enhancing and preserving carbon stocks; 

–  improve  economic  efficiency  in  the  pursuit  of  more  ambitious  targets  by  allowing  all 

sectors to contribute. 

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