Both of the principles set out here must be fulfilled: 1. Demonstrate substantial avoidance or reduction of GHG emissions from production and related practices; and 2. Maintain existing sinks and increase sequestration (up to saturation point) in above- and below-ground carbon stocks.
Metric and threshold:
Opportunities for substantial mitigation and contributions to a net zero carbon economy An overarching goal of the Taxonomy is to enable the screening of economic activities to determine whether or when they do or do not deliver substantial mitigation, consistent with the underlying goal of a net zero carbon economy by 2050. In the context of agriculture, Net-Zero is a means to ensure that even where GHG emissions cannot be reduced to zero, they can be compensated for through increased removals (through carbon sequestration) on farmed land. The discussion about the scale at which net-zero should (and could) be met solely in agriculture remains open. It may not be possible to reach net-zero emissions on an individual farm holding in all cases. In other cases, it may be more feasible. At the aggregate level, it may be that some countries with concentrated production systems and small land areas, would struggle to reach net-zero emissions within the agriculture sector alone and within country. This raises the question as to the extent to which a given farm, or aggregation of farms, could reach net-zero and the extent to which these farms could appropriate negative emissions (sequestration) from other farms or other sectors. Furthermore, one opportunity for emissions reductions in the agriculture sector as a whole is to switch from higher emitting activities to lower emitting activities (for example, by reducing cattle numbers and increasing legume production as an alternative source of protein), with a corresponding consumption switch between agricultural commodities. These criteria and thresholds, which focus specifically on emissions within the perennial crop production activity, cannot address this type of mitigation action. The criteria and thresholds proposed therefore focus on ensuring that emissions are substantially reduced and removals substantially increased at the economic activity (NACE code) level. There is significant potential to reduce emissions, maintain carbon sinks, and increase sequestration through good practices in perennial cropland management. Each of these needs to be addressed in order to ensure that agriculture as a whole delivers substantial mitigation and contributes its part to a net zero carbon economy. Doing so will ensure each instance of perennial cropland management maximises its contribution – this rationale drove the principles set out above. Approach taken to setting thresholds for this economic activity There continues to be a relative paucity of information and data to set absolute thresholds (e.g. gCO2e/ ha or gCO2e/ unit of production) for agriculture that represent low carbon agriculture. Even if such information existed at the aggregate level, translating this to appropriate thresholds for implementation would remain challenging given the heterogeneity across farms and farming practice. However, setting relative GHG thresholds (i.e. % change in gCO2e) is possible, where these can be made relative to a counterfactual on the same farm or project. Whilst this provides some quantitative means of assessing mitigation performance, it is a relatively blunt mechanism as it does not take into account emissions reductions which might previously have been achieved and if the farm is already delivering significant mitigation. Therefore, it is harder for a farm that already performs relatively well to deliver an additional X% reduction in emissions than it is for a form that currently performs relatively poorly. Furthermore, to determine compliance with such a GHG threshold, GHG accounting at farm level is necessary. However, this is not yet mainstream, despite the existence of a range of tools and approaches. The proposals, therefore, allow for a different approach, namely the demonstration of the deployment of specific bundles of management practices, that are recognised as essential to delivering low carbon production in agriculture. This more qualitative approach is relatively simple to monitor, and there are existing mechanisms to do so, such as under the CAP. It also provides a more directly communicable approach to farmers and land managers who will implement such practices on the ground. As this approach is applicable for those who have already established such practices as well as those that will additional investment finance to do so, it also allows for the recognition of farms (and associated assets and equity) that are already high performers in terms of a low GHG footprint. As such, it avoids the problems associated with the relative GHG threshold as described above. Emission contributions from agriculture in the EU arise primarily from three sources: enteric fermentation (42.9%; 0.186 GtCO2e); management of agricultural soils (38%; 0.165 GtCO2e); and manure management (15.4%; 0.067 GtCO2e) (2014 figures). Mitigation potential therefore predominantly involves reductions in non-CO2 emissions as these form the majority of agriculture emissions in the EU, with CO2 from on-farm energy use being a minor component (covering only 0.13% of total EU28+ISL agriculture emissions in 2014). The largest share of the EU’s agricultural non-CO2 GHG emissions comes from the more potent nitrous oxide (N2O) and methane (CH4). Nitrous oxide accounts for 58% of non-CO2 emissions from agriculture (largely from fertiliser application and exposed soils, as well as grazing animals), with methane accounting for the remaining 42% (largely from livestock and rice cultivation). In some cases, GHG emission from energy (traction, heating, cooling, irrigation) can form a significant proportion of emissions arising from the farm. The proposed best practices therefore include a provision for when GHG emissions from energy are greater than 20% of farm emissions, these should be reduced by 20% through efficiency and energy source requirements. In respect of perennial cropland production, key sources of emissions are emissions associated with soil management and the application of fertilisers, and emissions embedded in post-harvest waste. Metrics and thresholds for this economic activity On management practices that deliver substantial mitigation Rationale for the selection of practices: Scientific literature identifies a wide range of possible mitigation practices available in the agricultural sector to address the different emissions and opportunities for sequestration in perennial cropland management. For the purpose of establishing criteria and thresholds which identify when the economic activity of perennial cropland delivers substantial mitigation, individual management practices were identified for which: 1) there is sufficient existing scientific knowledge and consensus on the mitigation effects and interactions with other environmental and food security objectives; and 2) the scale, certainty and consistency of mitigation effects is sufficiently demonstrated (for example, Smith et al. 2008 , Paustian et al. 2016 , Kay et al. 2019 ). These management practices have been demonstrated to improve soil health and soil productivity so as to secure agricultural yields and thus reduce the emission intensity of crop production – outcomes critical for the delivery of substantial mitigation - and/ or reduce the carbon intensity of agriculture, and also do not risk leakage effects. They also do not risk negative ancillary effects nor are in conflict with legislation in the EU. These practices deliver substantial mitigation with relatively high certainty across a range of biophysical and farming conditions. Scientific literature provides insights on mitigation potential on categories of individual practices and also indicates that it is the combination of practices which are applied over large areas that leads to substantial mitigation, i.e. an approach is required where all feasible mitigation practices which are environmentally sustainable should be pursued (Paustian et al. 2016). The literature, however, provides limited guidance on how to translate sectoral or activity-based mitigation potential into individual farm-level mitigation potential, i.e. what combination of practices should be applied together as a minimum at farm level in different conditions to deliver substantial mitigation. Therefore, TEG expert input was used to determine the minimum combination of practices which should be applied together for perennial cropland management to deliver substantial mitigation at farm level. The table below indicates the management practices selected as the bundle of essential practices that, deployed collectively, should deliver substantial mitigation at farm level. It is noted that given heterogeneity of farms, deployment of the same bundle of practices may result in different emissions impacts farm to farm, but overall it is expected that deployment of this bundle will deliver substantial mitigation in the majority of cases. The applicable area for management practices relates to where those practices could and should be deployed on a farm in order to meet their objectives. For example, buffer strips designed to prevent soil erosion and run-off are to be placed next to water courses and ditches, etc. Therefore, some practices may only be deployed on a small area of the farm where they add value. One best practice, the requirement to undertake a GHG assessment does not directly lead to reduced emissions or increased sequestration. The rationale for including this practice is to raise awareness of where the main emission sources are on a farm holding, what opportunities exist to reduce those emissions and thus where greatest mitigation impact could be achieved, including through opportunities for carbon sinks, and thereby improve the targeting of mitigation action. In this spirit, no verification or audit of the assessment is required to fulfil this best practice requirement. This is different from the quantitative baseline assessment and carbon audit, both of which are necessary when demonstrating compliance with the quantitative GHG thresholds. The assessment should be done using tools that cover all relevant emissions on the farm associated with crop, livestock production, as well as emissions associated with energy and fuel use. If it can be demonstrated that no carbon assessment tool is currently accessible to farmers in a given location (either because of language or lack of access to farm advisory support), this practice may be omitted in the first instance. The assessment, however, becomes mandatory within a five year period, On GHG emission reduction thresholds Substantial, in the context of substantial mitigation, falls on a spectrum of mitigation potential from net -negative (where removals exceed emissions), net-zero (where removals balance with emissions) to varying degrees of emission reductions. With no EU or global baseline target for emission reductions from the agriculture sector as a whole or perennial crop production specifically the degree to which emission reductions and removals should be required becomes a question of ambition and need. It is also noted that the Taxonomy has a global reach, and thus any level of ‘substantial’ should be consistent in the global context. A review by Wollenberg et al, 2016 suggests a total mitigation need from agriculture from between 0.9 – 1.4 GtCO2e (in 2030) to meet the 2 °C target, 1 GtCO2e (in 2030). This was selected as an approximate target. These figures relate primarily to non-CO2 emissions and are “an annualized”, not cumulative, goal. The target assumes an allowable emissions budget of 6.15–7.78 GtCO2e yr-1 for agriculture in 2030. The goal represents an 11–18% reduction relative to the scenarios’ respective 2030 business as usual baselines” . As these figures represent non-CO2 emissions, they implicitly do not recognise the role of potential carbon sequestration and its contribution to global mitigation goals. As such a GHG emissions reduction threshold of 20% over the 10 year period from 2020 to 2030 has been proposed as ‘significant contribution’ in the context of the Taxonomy. This is supported by work from Frank et al (2018) , and The IPCC’s fourth assessment report (Smith et al, 2007) . In terms of establishing a declining emissions trajectory for agriculture, the work by Wollenberg et al (2016) calculates emission reduction needs based on a trajectory of emissions from 2010 through to 2100. The emissions curve (level of emissions over time) increases and decreases at different points, relative to existing efforts, projected changes in external factors, etc. The average reduction figure needed over this whole timeframe is 28% emission reductions compared to the baseline. As we move towards 2040 and 2050 the level of emission reductions needed increases, and this implications for any threshold set beyond the 2030 timeframe. The reduction figure in 2050 would be larger (approximately a doubling). Although in the study the level of emission reductions needed is not linear between the years, for simplicity a linear reduction is drawn between the two pegs of 20% reduction by 2030 and 40% reduction by 2050 as a linear trajectory of emission reductions also simplifies implementation and communication. The study determined these reductions against a business as usual scenario for agriculture. However, establishing a BaU counterfactual level of emissions for each project or farm could limit implementation effectiveness, as the BaU emissions would need to be calculated assuming the mitigation action was not in place. For simplicity, the proposed approach is therefore to simplify the requirement to compare emissions at the start of period with those achieved in 10 years-time and assess this against the target reduction. The threshold metric for emissions reduction is gCO2e, and not an emissions intensity metric such as gCO2e/ unit of production, as this enables the Taxonomy to be applied by those reducing emissions intensity (e.g. through energy or resource efficiency) while also requiring them to reduce emissions overall – the overall goal. On setting Carbon stock thresholds Setting a universal (or global) absolute threshold (in terms of tC/ ha) for carbon stocks is not a viable option given the variability of carbon sequestration and stocking potential – which is very context specific. Those with low carbon stock potential will not be able to deliver substantial sequestration in line with a universal, absolute threshold. Even setting an absolute threshold linked to local conditions (based on maximum carbon stocking potential at that site) is not possible as at present is it is impractical to test and estimate the maximum sequestration potential (i.e. saturation point) of a specific area. Such calculations currently use default values based on soil type, and therefore are not truly context specific. Furthermore, even defining a specific % of carbon increase required is more challenging than setting the relative threshold for reducing emissions. Reducing emissions is always proportional to the level of emissions at a given point, therefore a 20% reduction over 10 years for example can be expected to deliver a ‘substantial’ contribution from an underperforming farm (resulting in high overall emission reductions). However, the premise is different when looking to increase sequestration on agricultural land as there is relatively little evidence and few studies that suggest what level of Carbon stock increase would be needed on agricultural land in a 1.5 or 2°C climate stabilisation target scenario, as this is relative to the level of emissions from that same land (if one is pursuing a net-zero approach) or the level of carbon sequestration needed to offset other sectors of the economy. It is however, recognised that C sequestration represents the largest mitigation potential available to the agriculture sector at global scale, while emission savings of non-CO2 emissions may be more important in the EU with a prevailing intensive production system. Smith et al (2007) estimate that 89% of the technical potential of emission reductions in the sector to 2030 and 2050 lies in soil carbon sequestration, i.e.in reducing net CO2 emissions from farming practices and management, including cropland management, grazing land management, restoration of cultivated organic soils and restoration of degraded lands. The proposal is therefore to require evidence of a positive direction of travel in terms of increasing carbon stocks, specifically, the progressive increase of carbon stocks over a 20-year period. A 20 year period for C stock saturation maintenance is proposed in line with the IPCC 20 year soil C saturation period. Where the (remaining) lifecycle of the crop production being financed is less than 20 years, assurance should be sought on the likely replanting of crops to promote the permanence of carbon sequestration trends. It is recognised that uprooting old crops and replacing with new, younger stage crops with a potential fallow/ restoration period between will lead to a reduction in carbon stocks and some emissions. With this in mind, the objective is to ensure overall maintenance of carbon stocks and/ or upward trends in sequestration are sought over multiple rotations. On no conversion of high carbon stock land A cut-off date of 2008 for no conversion of high carbon stock land is chosen to be consistent with the operation of the Renewable Energy Directive sustainability criteria relative to these land types. This provides a link with existing sustainability schemes through which compliance could be demonstrated for this criterion. On demonstrating compliance with these criteria and thresholds 3-year compliance checking is proposed to ensure progress is being made and mitigation is being delivered in practice, and also to reduce the burden necessary on operators. This compliance checking is required for management practice checking, C stock change and GHG reductions. To prepare the farm sustainability management plan a carbon calculator can be used, or the plan can also be prepared using other nutrient decision-support tools. Advisory support will likely be required in the process of preparing the plan and may also be required to ensure adequate implementation of the plan..
Key environmental aspects to be considered for investments in growing of perennial crops span across all other five objectives and are summarized as follows: • ability of farming systems to adapt to a changing climate; • impact on water quantity, water quality and water ecosystems; • impacts on air quality; • inefficiencies in the production system including nutrient management; • pollutant and nutrient run-off and leaching; • impacts on habitats and species, e.g. through conversion of areas, intensification of existing arable land, and invasive alien species. Note that areas of environmental risk are highly geographically variable. Guidance should be sought from the relevant competent national or regional authority to identify areas or issues of importance and relevance within the area or project concerned.
• Refer to the screening criteria for DNSH to climate change adaptation.
• Identify and manage risks related to water quality and/or water consumption at the appropriate level. Ensure that water use/conservation management plans, developed in consultation with relevant stakeholders, have been developed and implemented. • In the EU, fulfil the requirements of EU water legislation
Based on legislation:
General reference to EU legislation
• Activities should minimise raw material use per unit of output, including energy through increased resource use efficiency . • Activities should minimise the loss of nutrients (in particular nitrogen and phosphate) leaching out from the production system into the environment. • Activities should use residues and by-products the production or harvesting of crops to reduce demand for primary resources, in line with good agricultural practice;
Based on legislation:
• Activities ensure that nutrients (fertilisers) and plant protection products (e.g. pesticides and herbicides) are targeted in their application (in time and area treated) and are delivered at appropriate levels (with preference to sustainable biological, physical or other non-chemical methods if possible) and with appropriate equipment and techniques to reduce risk and impacts of pesticide use on human health and the environment (e.g. water and air pollution) and the loss of excess nutrients. • The use only of plant protection products with active substances that ensure high protection of human and animal health and the environment.
Based on legislation:
• Activities ensure the protection of soils, particularly over winter, to prevent erosion and run-off into water courses/bodies and to maintain soil organic matter. • Activities do not lead to the conversion, fragmentation or unsustainable intensification of high-nature-value land, wetlands, forests, or other areas of high-biodiversity value . This includes highly biodiverse grassland spanning more than one hectare that is: i) natural, namely grassland that would remain grassland in the absence of human intervention and that maintains the natural species composition and ecological characteristics and processes; or ii) non-natural, namely grassland that would cease to be grassland in the absence of human intervention and that is species-rich and not degraded and has been identified as being highly biodiverse by the relevant competent authority. • Activities should not : o result in a decrease in the diversity or abundance of species and habitats of conservation importance or concern; o contravene existing management plans or conservation objectives. • Where activities involve the production of novel non-native or invasive alien species, their cultivation should be subject to an initial risk assessment and on-going monitoring in order to ensure that sufficient safeguards are in place to prevent escape to the environment.
Based on legislation: