European Commission
Carbon removals and carbon farming – methodologies for certifying carbon farming
The Central Union of Swedish-speaking Farmers and Forest Owners in Finland, thanks for the opportunity to give feedback on the carbon farming methodologies. SLC wishes to emphasize that forest owners have potential to contribute to an increased carbon sink. Forest owners are interested in enhancing the growth of their forests and provided that the system is built on incentives that are economically viable, producing carbon credits. If the framework becomes too bureaucratic and administratively burdensome, there is a risk that forest owners will not benefit from it in practice and refrain from participating. For this reason, SLC highlights the importance of an easy to manage framework and need of support to ensure that the system becomes smooth, manageable and attractive for landowners.
In this statement, SLC focuses on afforestation and on ensuring that the framework is adapted to practical forestry so that forest owners willing to participate in the activity can do so. The primary objective must be to create an increased carbon sink. Unnecessary detailed regulations should be avoided. Activities that increase the carbon sink during the activity period should be eligible and encouraged. SLC calls on flexible criteria where actions can be allowed also as exceptions to the presented criteria when scientifically proven to increase the carbon sink. SLC is concerned that the eligibility requirements as presented exclude areas suitable for afforestation and limit the climate potential of the framework. On areas with existing vegetation but where the stand is clearly underproductive, afforestation could increase the carbon sink. These kinds of land should be eligible for afforestation. If these areas cannot be accommodated under the afforestation criteria, they should at least be considered under future schemes. The framework should encourage the conversion of low-productivity land into well-managed forests with higher carbon sequestration capacity.
Regarding fertilization, SLC considers it essential that fertilization is not unnecessarily restricted. It is positive that fertilization may be applied in both young and older stands where there is evidence of nutrient imbalance. Nutrient deficiencies, including boron deficiency, can occur at later stages of stand development and, if not corrected, may significantly reduce growth and thus carbon sequestration. It is therefore crucial that both organic and non-organic fertilizers can be used where necessary to secure tree growth and the overall climate benefit of the stand.
SLC questions the strict limitation on soil preparation for afforestation since tillage deeper than 15 cm and on grassland is often needed to establish a stand. Allowance of soil preparation should therefore be the default assumption. Nevertheless, the exception to the restrictions presented when justified is welcome as it recognizes that tillage may be necessary for successful afforestation.
The difference in length between the monitoring period and the activity period raises concerns. It´s understandable that the credits sold need to be secured for a certain time. Nevertheless, the current wording of a longer monitoring period than the activity period risks discouraging forest owners from participating. SLC considers that greater flexibility in the length of the activity period could be explored, provided that the integrity of the credits is safeguarded.
Finally, SLC stresses that the success of the carbon certification framework depends on its practical feasibility. Proportionate monitoring requirements and legal certainty are essential. The system must be designed so that it attracts forest owners and delivers measurable climate benefits without imposing disproportionate administrative burdens. By focusing on increased carbon sequestration, economic viability and flexibility, the EU can create a framework that mobilizes forest owners across Member States and contributes effectively to the Union’s climate objectives.
THE CENTRAL UNION OF SWEDISH-SPEAKING FARMERS AND FOREST OWNERS IN FINLAND
Mats Holmgård
Forestry Expert
