As COP 27 draws to a close, and as we reach the seventh anniversary of the Paris Agreement, now is a fine time to assess the EU’s progress on climate, and address the urgent action still needed to pull us back from the brink. All eyes should be on the elephant in the room: agriculture.

Ben Snelson, Jurij Krajcic and Célia Nyssens report.

Upon unveiling its Green Deal in 2019, the EU boasted one of the most ambitious, comprehensive and robust environmental legislative programmes ever. With fresh commitments to act on the environmental crises, spanning everything from industrial pollutants to plastic waste and from biodiversity protection to agricultural production, hopes were high. Across certain policy areas, optimism remains, but in others, on the basis of scientific assessment, concern is growing – particularly agriculture.

The lay of the (farm)land

The UN estimates that around 30% of global greenhouse gas (GHG) emissions comes from the food system, the bulk of which is linked to agriculture. In the EU, the main culprits are intensive livestock and fertiliser use, as well as farming on drained peatlands.

Emissions from livestock and fertilisers are two of the sectors regulated under the EU’s Effort Sharing Regulation (ESR), while emissions from drained peatlands fall under the scope of both the LULUCF Regulation (which covers emissions and removals from land use and forestry) and the Carbon Removals Certification (CRC).

In 2021, the European Commission (EC) tabled revisions to the ESR and LULUCF, which proposed improvements on existing rules and targets. However, these fell direly short of action needed.

To make a fair contribution to global efforts to keep warming under 1.5°C, the EU should be cutting its emissions by 65% by 2030, yet the ESR only requires a 40% cut. On LULUCF, the EC proposed a 20% increase in the EU’s land carbon sink compared to today, though research shows that double this would be feasible. Rapid action to cease and reverse the decline of biodiversity in forests, grasslands and agricultural land could deliver major increases in carbon sequestration. 

But in both regulations, the agriculture sector is not bound by specific targets, and is free to mask inaction behind the efforts of other sectors for the rest of this decisive decade. This missed opportunity to drive much-needed climate action in agriculture is deeply regrettable, as business-as-usual benefits no one, including farmers who are bound to be suffering immensely from the effects of climate change.

Effort sharing or free-riding?

Between 2005 and 2018, Effort Sharing sectors (buildings, transport, small industries and waste) reduced emissions by 11%, while the agriculture sector only cut its own by 1%.

It speaks volumes of the EU’s environmental ambition that the biggest win in the ESR’s revision was that no new loopholes were introduced. Minor improvements were made to the EC’s proposal, but many existing loopholes remain, such as options for member states to compensate for missing targets by using credits from the land use sector if they exceed their target there. While higher targets will increase pressure on agriculture, these flexibilities are effectively get-out clauses. 

Contrary to the lax attitude from the law, tackling emissions from livestock and fertilisers couldn’t be more urgent. Over 70% of EU farmland is currently used to feed livestock, with this sector also receiving €30 billion in payments via the Common Agricultural Policy, which is to say 20% of the EU’s total annual budget. In the context of reduced exports from Ukraine and import-dependent countries facing growing food scarcity, the EU could both achieve its own climate and environmental objectives and support global food security by downsizing its livestock sector through a just transition.

A nutrient problem 

The Kremlin’s war in Ukraine has exposed another EU vulnerability: dependency on imported fertilisers. First, a drop in availability of cheap gas imports from Russia has left Europe’s fertiliser industry reeling, given the inordinate energy costs involved in their development. This has led to production being put on hold in Europe and a scramble to diversify trade relations to substitute the €1.8 billion worth of fertiliser imports from Russia, which nearly doubled between 2020 and 2021. 

Beyond the geopolitical quagmire, fertiliser use across Europe comes at an exorbitant cost to both our environment and future food security. Healthy soils are needed to supply our food. But blanket fertiliser application over decades has degraded them, resulting in erosion, acidification, growing vulnerability to diseases, and reduced productive capacity. The consequences for European waterways and coastal habitats have been dire, with many aquatic ecosystems already eutrophic ‘dead zones’. Two thirds of excess nitrogen and phosphorus in European waters originate from agricultural fertilisers.

The evidence is plain, and urgent action is needed to reduce synthetic inputs, improve the efficiency of fertiliser application that continues, and establish a robust framework for monitoring implementation. The EC has already laid the groundwork for this, with its proposed Integrated Nutrient Management Action Plan. It must now honour this commitment. 

Low-hanging fruit on agricultural land

While the LULUCF revision is welcome, it does not guarantee that current forest and land sink degradation will be reversed. The EC’s proposed 2030 target for increasing the EU’s total land sink was adopted, which is positive, but far off from NGO demands. Also, with various flexibilities secured by member states in negotiations, the real atmospheric achievements of this revision may, in reality, be nothing but hot air.

Included in the LULUCF sector, agricultural land (croplands and grasslands) are currently a net source of carbon emissions, driven largely by the draining of peatlands. Tackling this would be low-hanging fruit for member states, as drained peatlands cover only 3% of agricultural land. Replanting hedges and promoting agroforestry would also support biodiversity and carbon sequestration on farmland. Yet in these areas, most countries continue to demonstrate minimal ambition.

A programme for carbon removals 

In support of wider climate neutrality, and in an attempt to boost carbon removals, the EC is expected to propose a regulatory framework for the Carbon Removals Certification (CRC) on 30 November. Done right, this could provide real solutions and ensure long-term carbon removals. However, the draft proposal seen is anything but reassuring.

The proposal is immature and flimsy. 

It establishes a very basic framework for certification with many questions left unanswered, and numerous key decisions postponed to the future, such as reporting requirements and liability in case a carbon storage is re-released back into the atmosphere.

Land-based removals cannot “neutralise” fossil fuel emissions. 

Fossil greenhouse gas (GHG) emissions release carbon which has been stored for millions of years, whereas biogenic GHG have much shorter return times. These two carbon cycles are inherently separate and, to avoid misleading claims, should not be conflated. Absorbing carbon in the land sector can compensate for previous emissions of biogenic carbon, but never for GHG emissions from burning fossil fuels.

Offsetting is a dangerous strategy. 

Deep and rapid emission reductions in agriculture, industry and energy sectors should take explicit priority in the EU’s climate policy, with removals only acting on top of that effort. However, the draft aims to generate carbon credits for offsetting, essentially “concealing” emissions behind removals. Offsetting will likely deter emission reduction efforts and invite greenwashing, such as false “climate neutrality” claims. 

CRC not an integral part of the EU climate policy 

There are no clear links with the LULUCF target for regenerating EU land carbon sinks or with the Nature Restoration Law’s targets for supporting carbon-storing ecosystems. This is highly disappointing and a missed opportunity to build synergies between climate and biodiversity.

Sustainability objectives & forgotten social aspects

The EEB welcomes the fact that carbon removal activities must consider sustainability objectives, such as eco csystem integrity and biodiversity enhancement. Ecosystem integrity is critical for both ensuring long-term carbon storage in land and also increasing resilience to the existing and future impacts of climate change. However, social safeguards have been left out altogether leaving vulnerable farmers behind yet again.

Emission reductions ≠ Removals

The draft CRC stipulates that even emission reductions from the land sector can be certified as removals. But comparing reductions to removals is like comparing apples to pears. A legitimate removal is a physical removal of carbon from the atmosphere and a net removal of all associated emissions. If we want removals to play a role in our climate efforts, those two must be kept separate. 

In sum, while some positive developments continue to emerge on the EU’s climate and biodiversity policy agenda, there remains an overwhelming and worrying lack of coordination, alignment and ambition. Given its mammoth contribution to emissions, we must shine a light on agriculture and the potential of this sector to spearhead the EU’s response to the climate crisis.

During the most critical decade for climate action yet, the EU must live up to its lofty environmental rhetoric, focusing on the issue at hand and drawing on Europe’s collective abundant resources, knowledge and appetite for change to resolve these challenges together. The problem is evident, the solutions are clear, action is needed, and the time is now.

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