Download the request from 10 member states

13 May 2016
Mr. Miguel Arias Cañete
Commissioner
Climate Action and Energy
Mr. Phil Hogan
Commissioner
Agriculture and Rural Development
Commissioners, Dear Colleagues,
We wish to congratulate you, and all of us, for a very successful event - the signing of the historic
Paris Agreement - which took place in New York on 22 April 2016. With this important step, the EU
and its Member States confirmed their commitment to the Paris Agreement and the fight against
climate change. Now we need to move swiftly on implementation. In this respect, we are looking
forward to Commission’s proposals on the EU’s Effort Sharing Decision and on Land-Use, Land-Use
Change and Forestry (LULUCF).
We as ministers coming from very different parts of Europe, with very diverse national
characteristics and natural circumstances, highlight the importance of the LULUCF sector,
especially forests, in the EU’s 2030 climate framework. Our countries are the most forested
Member States of the EU, with an average forest cover of more than 50 %, one and a half times
higher than the EU average. Despite our small number, we represent more than 45 % of the EU’s
forest area, and our wellbeing is dependent on sustainable management of our forests.
Sustainable forest management and agriculture have multiple objectives, including food security
and they provide a number of co-benefits and opportunities for synergies, e.g.
 Promoting a sustainable economy; this sector will have an increasing role in the transition
process from fossil fuel based economies to sustainable bio-based economies;
 Promoting a resilient economy, supporting the aim to halt the loss of biodiversity and
improving the state of Europe’s species, habitats, ecosystems and services, including by
adapting to climate change;
 Sustainable Agriculture, supporting headline targets of the common agricultural policy, in
particular retaining a degree of self-sufficiency in the long term;
 Sustainable Forestry, aiming at maintaining vital and diverse forest ecosystems, which
produce an annual yield of timber, fibre or energy from forests;
 Safe and Sustainable Energy policy, promoting a sustainable supply of bioenergy,
supporting the long term climate and energy targets of the Union and contributing to the
goals of the Energy Union, e.g. decreasing dependence on energy imports.
Our countries practice sustainable agriculture and sustainable forest management. In
agriculture the potential for cost-efficient mitigation is limited. Forests provide bioenergy and
long-lasting renewable forest products. The EU’s climate and energy policies should be
coherent with and supportive of these practices.
There are significant national differences between the Member States in terms of forest
coverage, land use, forest management, natural conditions, GHG profiles and mitigation
potential. These diverse national circumstances need to be fully considered whilst ensuring
that forest policy remains the responsibility of Member States, and matters under EU and MS
shared competence are subject to subsidiarity.
The Paris Agreement requires the international community to achieve rapid emissions
reductions and to achieve a balance in emissions and removals in the second half of this
century. It is clear that LULUCF will contribute significantly to this low-emissions pathway.
The current treatment of LULUCF under the Kyoto Protocol and in the EU is a first step towards
full integration of the sector, but there is room for improvement. For proper implementation
of the NDC and the Paris Agreement, future EU policies concerning the LULUCF sector need to
be clear for Member States. The EU needs to move forward swiftly with its own climate
policies with one of the important questions being, how to include LULUCF into its climate
framework. In this respect, we need to ensure the overall ambition and environmental
integrity whilst providing opportunity for sustainable agriculture and forestry.
We wish to share with you our comments on how to include the LULUCF sector into the EU’s
2030 climate framework:
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The contribution from LULUCF must be considered in a holistic manner, acknowledging
that this sector, especially forests, has the potential to contribute positively to climate
change mitigation in manifold ways, e.g. via reducing emissions and increasing removals
and substituting fossil fuels and materials with higher life-cycle emissions;
The contribution also needs to be sustainable; thus long-term stability of mitigation actions
should be promoted, while avoiding incentivizing short-term actions only;
Mitigation actions should also be linked to increasing the adaptation potential and
promoting resilience of ecosystems with a view to safeguarding future ecosystem services;
The LULUCF sector has some special characteristics and we are willing to discuss how
flexibility between the LULUCF and non-ETS sectors can be established, while ensuring the
overall environmental integrity.
We should move to a land-based accounting system, with at least forest land, cropland and
grassland to become compulsory. In this respect, we should make use of IPCC 2006
Guidelines and UNFCCC reporting practices as much as possible and build on
internationally agreed approaches. It is important to ensure that EU’s own system makes
full use of the reporting and review system under the UNFCCC in order to increase
efficiency and avoid the current duplication;
The sustainable management of forests offers the greatest mitigation potential. We prefer
a reference level approach, as already applied for the period 2013-2020. The reference
levels should be nationally determined and represent recent policies, and a technical
assessment process should be used to increase transparency;
As national circumstances are quite different within the EU MS, it is of utmost importance
to keep a balanced approach to different land categories and different mitigation
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measures, aimed not only at increasing the forest area (e.g. due to afforestation). The
potential for afforestation varies significantly within the EU, and is rather limited
particularly in forest rich countries. Putting emphasis on afforestation only would penalize
forest rich countries and introduce an early action malus. At the same time, some land use
change from forest land to other land uses will continue, especially in forest rich countries.
It would be unfortunate if those countries enhancing removals by sinks and providing
significant climate benefit through sustainable forest management would be penalized by
inappropriate accounting rules.
We recognize the important role of long-lasting forest products through the inclusion of
Harvested Wood Products into accounting.
On agriculture, we highlight the well-justified need to maintain and keep up sustainable
agriculture production throughout the Union, whilst recalling the limited emissions
limitation potential, and while at the same time seeking to stimulate emission reductions in
agriculture.
The inclusion of LULUCF sector into EU’s 2030 climate framework should ensure a balanced
and sustainable use of forest and agriculture lands, cost-effectivity in implementation and
investments, ambitious mitigation measures while responding to increasing demand of
food and fibre.
We look forward to working with you and all Member States to find a balanced and fair outcome
that represents the interests of all Member States.
Mr. Andrä Rupprechter
Minister of Agriculture, Forestry, Environment and
Water Management, Austria
Mr. Davor Romić
Minister of Agriculture, Croatia
Mr. Slaven Dobrović
Minister of Environmental and Nature Protection,
Croatia
Mr. Richard Brabec
Minister of the Environment, the Czech Republic
Mr. Marko Pomerants
Minister of the Environment, Estonia
Mr. Kimmo Tiilikainen
Minister of Agriculture and the Environment,
Finland
Mr. Jānis Dūklavs
Minister of Agriculture, Latvia
Mr. Kęstutis Trečiokas
Minister of the Environment, Lithuania
Mrs. Cristiana Pasca Palmer
Minister of Environment, Waters and Forests,
Romania
Ms. Irena Majcen
Minister of the Environment and Spatial Planning,
Slovenia
Mr. Dejan Židan
Minister of Agriculture, Forestry and Food, Slovenia
Mr. Sven-Erik Bucht
Minister for Rural Affairs, Sweden
Ms. Åsa Romson
Minister for Climate and the Environment, Sweden