LULUCF Forest Reference Levels for 2021-2025 set by the European Commission

On 28 October 2020, the Commission adopted forest reference levels (FRLs) for each Member State to apply between 2021 and 2025. FRLs are benchmarks to calculate the sum of greenhouse gas removals and emissions from existing forests in each Member State. In the EU climate policy, forests are part of the sector called Land Use, Land-Use Change and Forestry (LULUCF). The CO2 removal units generated by forests and forest management practices is the backbone of the EU land use sink.

EUSTAFOR considers the publication of Forest Reference Levels (FRLs) to be applied by the Member States in the period 2021- 2025 as an important step in setting conditions for the entire LULUCF sector as regards its role in meeting the 2030 climate change mitigation targets of the EU. The FRLs published by the Commission reflect a compromise achieved with the Member States resulting from a long consultation process. In a number of cases, the FRLs published by the Commission are different from those submitted by the Member States. This particularly applies to Member States in Central and South Eastern Europe in which, over the last few years, primary and secondary biotic and non-biotic factors, induced by climate change, have caused significant damage to forests.

Acording to EUSTAFOR’s internal statistics, a case in point is the recent severe damage of 1,2 million hectares of European state forests throughout Europe resulting from extreme weather and climate events, followed by pests and diseases. Therefore, the question remains, whether the calculation approach for Forest Reference Levels adopted by the Union in 2018 consists of sufficient provisions to make sure that such recent developments, more recent that those embraced by the reference period 2000-2009, will be taken into account.

EUSTAFOR has consistently argued that forests are tackling climate change in two fundamental ways: through climate mitigation and through climate adaptation. Climate mitigation occurs when forests help to reduce the level of climate change, whereas climate adaptation means our forests must adapt to the negative impact of climate change so they can fulfill their mitigation role. EUSTAFOR’s position is that all adaptation measures and related harvesting that aim to counteract and cope with ongoing forest dieback, as well as to enhance the resilience and vitality of future forest stands, require due consideration within the LULUCF policy and FRL calculations.

The role and potential of sustainable forest management (SFM) to tackle climate change are concretely presented in European forests: Tackling climate change, EUSTAFOR’s newest compilation of good practices in different aspects of climate mitigation and adaptation. The compilation of practical cases from field management complements EUSTAFOR’s previous contributions to this debate.

EUSTAFOR emphasizes three equally important ways – the so-called three Ss – in which forests help reduce the impact of climate change:

  • Sink – Carbon sequestration;
  • Storage – Carbon storage in living trees and long-term carbon storage in forest products; and
  • Substitution – A sustainable alternative for fossil fuels and fossil-based high energy consuming materials.

Consequently, we believe that Harvested Wood Products (HWP) and forest bioenergy deserve due attention when calculating FRLs. Renewable energy plays a key role in combating climate change in a cost-effective manner while enhancing energy security and reducing pollution. Out of the approximately 70% of the annual forest growth that is harvested, around 20-25 % belongs to the fuelwood quality assortment. This number can be even higher in situations which require sanitary cuttings to be undertaken in forests damaged by climate change­-induced calamities. Fuelwood is derived from forest management along with all other wood qualities. It should not be wasted as this would go against the responsible and efficient use of renewable resources. All of these elements must be taken into account in the assessment of the implementation of the newly published FRLs and in programming new levels for the period 2026-2030.


Published 29/10/2020, Brussels

Mr. Piotr Borkowski

Executive Director

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