Carbon Removal & Carbon Farming: Feedback and Proposals Regarding Afforestation — Nature+ Coalition Response to the CRCF Consultation

The Nature+ Coalition brings together organisations and operators committed to promoting high-integrity nature-based solutions (NbS) in order to fight against climate change and biodiversity loss, through forest restoration, sustainable management, and conservation.

Our coalition welcomes the Commission's newest draft methodology for afforestation activities. We see considerable improvements over the latest version ("tree planting on unused and highly degraded land") that circulated in late 2024, which we deemed unsatisfactory on a number of key aspects which would have thwarted its impact, especially the need to preserve ecosystems (soil and water) and requirements regarding biodiversity.

We support the latest Commission's proposals, most notably:

• the need to guarantee the diversity of trees within afforestation activities (mixed-species with prevalence for native ones when still adequate, possibility to introduce non-native species if justified);
• mandatory monitoring of water and soil health through enhanced management practices;
• a clear listing of indicators and expected co-benefits on biodiversity that project operators are explicitly encouraged to report on.

We see two areas for improvement in order to make sure that the future credits generated are attractive considering current trends within carbon markets.

1. Some key methodological aspects should be aligned with major standards that currently serve as quality frameworks internationally

Duration

The draft methodology states the project activity is 30 years, while its MRV is 40 years. In order to ensure more clarity and consistency, the Nature+ Coalition recommends to align both the duration of activities and MRV with international methodologies covering afforestation to 40 years (such as Verra and ACR which have been approved by the ICVCM's Core Carbon Principles).

Baseline

Whereas the draft incorporates a standardised baseline equal to zero, we recommend the use of a dynamic baseline that would be project specific and take into account key geological characteristics of each area to be covered by project activities.

Auditing

While the draft currently plans audits every 5 years for all projects, we suggest introducing some flexibility with a possibility to adapt it to a shorter period when relevant (compliant with Verra's methodology for afforestation), while maintaining a maximum timeline of 5 years.

The Commission should also introduce a way to highlight projects that deliver the most co-benefits on biodiversity, soil and water, based on their assessment and the draft's promoted indicators (sections 5.1, 5.2, 5.3), at a time where many buyers have expressed their willingness to shift toward high integrity carbon credits.

2. Some methodological aspects are part of contractual relations and should be discussed by mutual agreement between contracting parties

This is particularly the case for the rules covering responsibilities linked to the risk of reversal. The methodology currently states that the operator is "fully liable" in the case of "evitable reversal", and that if the project ends before the expected period, the reversal would be considered "total".

Those aspects are contractual and should be discussed and agreed between contracting parties, not included in the methodology. Contracts may for instance introduce a force majeure provision so that a premature ending of a project does not lead to total reversal if duly justified, and contractors should be the ones discussing responsibility associated with the risk of reversal.

Contracting parties could also be encouraged to discuss the possibility to introduce pre-payments at the beginning of projects, in order to create an incentive for smallholder stakeholders/landowners — representing the vast majority of the EU's forest owners — which are more sensitive to administrative costs and may be reluctant to engage into structural actions due to limited financial capacity if they are to wait 5 years or more to be rewarded.

The future Buyers' Club could play a role in defining best practices in this regard, in relation with project developers.

Looking ahead: other forestry methodologies needed

Finally, the Nature+ Coalition would like to reemphasize the need to have other forestry methodologies quickly delivered — most notably forest restoration & conservation and sustainable / improved forest management — as the sole afforestation projects will only have limited impact on the EU's environmental commitments (climate targets, nature restoration law).

The coalition's members remain at the disposal of the Commission to specify some of the aforesaid recommendations if necessary, provide guidelines for future forestry methodologies and share their expertise.