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Forest reference levels under Regulation (EU) 2018/841 for the period 2021-2025


Regulation (EU) 2018/841 (‘LULUCF regulation’) sets the accounting rules for the Land Use, Land-Use Change and Forestry (LULUCF) sector in the EU for 2021–2030, i.e. how the emissions and removals of greenhouse gases from LULUCF will be counted towards the climate targets. The LULUCF regulation is part of the EU’s commitment to reduce overall emissions by at least 40% by 2030 under the Climate and Energy framework. Every Member State must balance its accounted greenhouse gas emissions on the LULUCF sector by an equal amount of accounted greenhouse gas removals. Possible surplus removals, under certain conditions and up to an overall total of 280 Mt CO2e, may be used to compensate emissions from the sectors covered by the Effort Sharing Regulation. The technically most complex part of the LULUCF regulation is the set of accounting rules for managed forest land, which are based on a projected Forest Reference Level (FRL), estimated nationally by each EU Member State. The FRL is a benchmark level against which future net emissions from forests are accounted for. In its essence, the FRL is a projection of the net emissions from managed forest land in 2021—2030 (divided into two compliance periods, 2021—2025 and 2026—2030), assuming that the forest management practices had continued similar to the practices in the reference period 2000—2009. This way, the FRL provides a means to account for the impact of policy changes on the emissions and removals from forests, while factoring out the impact of age-related dynamics in the forests. The FRLs for the 2021—2025 period are reported as a part of National Forestry Accounting Plans (NFAPs). After a thorough assessment by the European Commission and a dedicated Expert Group in 2019 and 2020, these FRLs are due to be laid down in a delegated act adopted by the Commission by the end of October 2020. This report outlines the main technical findings of the assessment of the Member States’ proposed FRLs, and complements the forthcoming Commission Staff Working Document (2020) accompanying the delegated act. The assessment found that the Member States had generally followed the principles and criteria laid out in the LULUCF regulation. The NFAPs provide a wealth of information on the forests and forest management practices in the Member States – some of which has not been available for the international community before – and in general include the elements required by the LULUCF regulation. All Member States projected the development of the forest net emissions for 2021—2025 as a continuation of the historical management practices, therefore excluding assumptions on policy development. While the submissions by the Member States were in general detailed and carefully prepared, the assessment identified in several cases minor issues that will need to be amended before the compliance check. The most common issues are related to methodological inconsistencies between carbon pools, greenhouse gases or forest area included in the FRL and those reported in the national greenhouse gas inventories. Some of these mismatches have already been amended by the Member States through Addenda or Corrigenda to the NFAPs. The remaining inconsistencies will be addressed through technical corrections to the FRLs at the end of the compliance period and therefore do not impair the reliability of the FRL as an accounting baseline. For five Member States, the assessment resulted in a recalculation of the Member State-proposed FRL by the Commission. In numerical terms, the sum of the Member States’ FRLs (incl. the United Kingdom) in the delegated act is a projected sink of -337 Mt CO2 y-1 for the period 2021–2025. This projection is about 18% lower than the sink of -413 Mt CO2 y-1 reported by the EU 2019 greenhouse gas inventory on managed forest land for the period 2000—2009 (EEA 2019). The FRL projection is associated with a projected increase of harvest by about 19% over the same period, due to age-related effects. It is noteworthy that the FRLs project sustainable forest management practices as documented in the period 2000–2009, taking into account dynamic age-related forest characteristics, and do not represent an expected sink or expected harvest levels. Instead, the FRLs laid out in the delegated act provide a robust and trustworthy counterfactual for accounting the impact of mitigation actions on emissions and removals from managed forest land in the first compliance period 2021—2025.