KSLA har besvarat EU:s publika konsultation om LULUCF-revidering

KSLA har svarat på EU:s konsultation om revidering av Land Use, Land Use Change and Forestry Regulation (LULUCF).

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KSLA har bifogat ett dokument med tillägg till svarsformuläret. Ett utdrag:


In the long run, active forestry with high harvest and efficient utilisation of biomass for replacement of carbon-intensive non-wood products and fuels provides significant climate mitigation, (Gustavsson et al. 2021). With the present EU focus on carbon sinks there is an obvious risk that the potential mitigation from forestry will be reduced overall and be less efficient where the potential is utilized. The discussion of forest use today is to a large extent focused on energy substitution (bioenergy). The primary goal for most forest owners, relying on income from their woodlands, is to produce sawn wood, which will be used in long-lived products (e.g. houses). There is also a rapid development of bio-based products that substitute for fossil carbon demanding products, such as the fibers used for textiles. Energy in the form of heating, electricity and liquid biofuels are positive by-products from these efforts to find bio-based alternatives.

In the long run, a high carbon sink cannot be maintained if the forests are unmanaged since growth decreases and the carbon losses increase with age. Research found already ten years ago that Europe’s forests showed the first signs of carbon saturation (Nabuurs et al 2013). The authors stated that: “countries should be less focused on the forest biomass sink strength and consider a mitigation strategy (adapted to national circumstances) to maximize the sum of all the possible components: carbon sequestration in forest biomass, soil and wood products, and the effects of energy and material substitution of woody biomass”. It is important to consider soil organic carbon when carbon sinks are discussed. In boreal forests ectomycorrhizal fungi acts as agent of N immobilization in N–poor forests. This speaks in favour of using rotational silviculture with planting after clear–felling or natural regeneration under a few seed trees in the N–poor systems (high C/N ratio). The introduction of clear–felling has been followed by very substantial increases in forest growth in Sweden (and Norway and Finland). (Högberg et al. 2021).


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