Don't subvert the Regulation and its objectives
In its current report on the draft LULUCF Regulation, the Committee for Environment of the European Parliament is shifting the focus of the legislation from its primary climate mitigation objective towards a biodiversity protection one.
This will put at risk the chances for the bioeconomy to develop in Europe and to contribute to a more sustainable economy.
As an example, active management practices have enabled the forests to increase substantially the amount of carbon stored in Europe and the volume is still increasing. A too strong focus on forest conservation might reverse this trend and reduce the stored carbon in the forests and even release large parts of the currently stored carbon. In addition, products from forests are used in a range of applications. where they replace products with substantially higher GHG footprints and this should be further encouraged.
We, the biomass-derived chemical industry, therefore ask the European Parliament and its members to re-establish the long-term climate benefit as the prime objective of the Regulation and, therefore, to:
- Limit the removal objective of the regulation to feasible values without disincentivizing the harvesting and marketing of biomass.
- Recognise that, thanks to research and innovation, new bio-based products can offer a prolonged storage benefit the same way harvested wood products already do, and therefore allow for extending the list of such products as provided for in the Article 9 proposal by the Commission.
- Avoid using the LULUCF Regulation to achieve biodiversity conservation objectives which shall be more suitably pursued through dedicated biodiversity policies.