CAN Europe made a submission on the European Commission’s Consultation on how to treat land-based emissions in the 2030 target.
As LULUCFs a net sink and was not included in the 2020 package, the EU’s 2030 target would be significantly reduced if LULUCF credits were fungible with other sectors. Inclusion of LULUCF would lead to lower reduction commitment in the other sectors.
Furthermore the current accounting rules for forest management allow emissions to be ignored. LULUCF sector should be covered by a separate reduction target with comprehensive accounting of all GHG emissions and removals from land use and forestry activities, including full accounting for emissions from bioenergy. It should be ensured that accounting rules are clear, honest and transparent, allowing real emission reductions, avoiding “hidden emissions“. Environmental integrity needs to be defined beyond integrity of emission savings.