The European Commission should relax the criteria for including forestry and bioenergy activities in the EU taxonomy, says a draft of the delegated act establishing the criteria for the climate taxonomy, obtained on 16 April by EUROPE (see EUROPE 12700/5).
Compared to the first draft of the delegated act published in November 2020 and submitted for public consultation (see EUROPE 12606/15), “changes were introduced to reduce complexity and burdens notably for smaller forest holdings”, the document states.
Forestry
For forestry, the main criterion for a forestry operation to be defined as sustainable under the taxonomy is that the activity takes place in an area subject to a forest management plan or equivalent instrument, in accordance with national legislation.
This criterion is considered too low by many NGOs, including ECOS, which is concerned that almost all logging can thus be taxonomy-compliant when current logging has “massively degraded biodiversity and is rapidly reducing Europe’s carbon sinks”.
A significant change from last November’s text is that farms of less than 25 hectares will not be required to carry out a climate benefits analysis of their activity to claim that it makes a substantial contribution to climate change mitigation.
For the NGO WWF, this would be a real loophole in the taxonomy, given that about two thirds of EU forest owners have holdings of less than 3 hectares.
The NGO also criticises the requirement to demonstrate climate benefits over a period of 30 years after the start of forestry activity, whereas the draft delegated act published in November mentioned a period of 20 years.
“If any climate benefit can do the trick, even a 1% improvement over 30 years, then this is not a substantial contribution [to climate change mitigation],” WWF laments in a joint letter with other civil society organisations (see EUROPE 12696/7).
Bioenergy
Bioenergy, on the other hand, “is no longer labelled as transitional and the criteria for bioenergy were aligned more closely with applicable EU legislation”, the Commission document states.
According to the draft text, agricultural and forestry biomass activities will, among other things, have to comply with the criteria set out in the EU Renewable Energy Directive (2018/2001) (RED II) in order to qualify as activities contributing substantially to climate change mitigation.
Agriculture
The paper further stresses that agricultural activities will not be covered by the taxonomy, “pending progress in the ongoing negotiations on the Common Agricultural Policy (CAP)”.
Finally, it should be noted that this document is a draft. The Commission will present the final delegated act on Wednesday (21 April).
See the new provisional version of the delegated act and its annexes: https://bit.ly/3x4zIRR; https://bit.ly/32noWrK; https://bit.ly/32msg6w (Original version in French by Damien Genicot)