C 184/84
EN
Official Journal of the European Union
25.5.2023
1.6.
The EESC calls on the Commission to ensure that the methodologies are based on scientific evidence and guided by the scientific community.
The EESC points out that the system for certification is far too complex and burdensome to promote a major uptake of these practices — these procedures look very time-consuming and technical and may demotivate operators in their activities, given that they are often small-scale businesses with narrow margins even in the best-case scenario. 1.7.
The EESC notes that a diverse range of measurements of carbon removals is required to conduct monitoring, reporting and verification (MRV), including the use of remote sensing and satellite imagery.
With regard to the required measurements, the EESC stresses that it is essential to keep the costs of carbon removal MRV as low as possible, to ensure broad accessibility of the certification framework. 1.8.
The EESC stresses that the potential risks and side effects for major players (farmers, forest industry, and construction and wood industries) associated with the proposal, including those of an environmental or socio-economic nature, need to be carefully assessed and addressed before integrating the certification framework into other policies, such as the common agricultural policy. 1.9.
In the EESC's view, the current Common Agricultural Policy (CAP) should not be used to finance carbon farming or carbon removals (1).
While there may be a small role for the CAP in carbon removals, this instrument is designed for the production of food, feed and biomass, which is the primary objective of the agriculture and forestry sector.
In this specific context, carbon removals are a by-product, which means that additional financing sources should be made available. 1.10.
The EESC feels that the high level of ambiguity from the Commission around financing will act as a strong disincentive for participation for potential partakers.
The EESC therefore emphasises that some level of certainty in relation to financing is necessary.
Given the opportunities of carbon removals in the future, the EESC recommends developing a roadmap towards a common financial instrument for these measures.
2.
General comments The need to scale up carbon removals to achieve net zero targets 2.1.
In accordance with the Paris Agreement, the European Union has committed to reaching net zero greenhouse gas emissions (GHGs) by 2050, and net negative emissions thereafter.
According to the latest report by the Intergovernmental Panel on Climate Change (IPCC), focusing solely on emission reductions will not suffice to reach this goal: ‘the deployment of carbon dioxide removals to counterbalance hard-to-abate residual emissions is unavoidable if net zero CO2 or GHG emissions are to be achieved’ (2). 2.2.
While carbon removals are no substitute for necessary drastic GHG emission reductions, they will need to complement emission reduction efforts to reach net zero and net negative emissions.
Consequently, carbon removals will need to be significantly upscaled globally to control atmospheric concentrations of GHGs and limit global warming.
To meet its climate goals, the EU anticipates that it will need to reduce its emissions by 85-95 % compared to 1990, with carbon removals needed to fill the gap.
Several hundred million tonnes (Mt) of CO2 will therefore need to be removed from the atmosphere every year.
2.3.
To this end, the EU has so far introduced several initiatives:
— the Climate Law, which sets the EU's objective of achieving climate neutrality by 2050; — the Land Use, Land Use Change and Forestry (LULUCF) Regulation, whose latest proposal for amendment foresees a net carbon removals target of 310 Mt CO2 equivalent in 2030, storing carbon in soils, forests and wood products; and — the Communication on Sustainable Carbon Cycles, which outlines the roadmap to carbon farming contributing to the proposed 2030 target for LULUCF, and industrial solutions removing at least 5 Mt in 2030.
The Communication also announced plans to develop the proposal for a regulatory framework for the certification of carbon removals.
(1) (2)
OJ C 323, 26.8.2022, p. 95.
IPCC WGIII SPM, 2022.