Specific Details
Carbon Farming Framework for Ireland
Intended results
To emphasise that farmers are committed to playing their part in reducing greenhouse gas emissions. Already, they have made significant investments to improve efficiency and reduce emissions. In dealing with the climate change challenge, it is imperative that Irish farmers' current sustainability credentials and the existing carbon reservoirs on farms in the soils and hedgerows are fully acknowledged.
To seek additional payment to carry out the measures set out in the Climate Action Plan 2023 (CAP23) to deliver the emissions reduction target. Even if a measure is supported under the Climate Action Plan (CAP) or the Forest Programme farmers should be eligible to generate an additional payment for the carbon removed or the emissions reduced as a result of the measure being implemented.
To insist that this payment will be paramount to incentivise widespread adoption and the long-term sustained change that is required at farm level to meet sectoral targets. Based on the latest Teagasc MACC report widespread and near full adoption of measures set out in the Climate Action Plan (CAP) 23 is required to deliver the legally binding emission reduction targets.
To highlight that a primary motivation for farmers to adopt carbon farming practices, particularly at the scale required, will be that it improves overall economic profitability and intergenerational resilience of their farm business. These co-benefits will be strong motivators for adoption and should be central to the design of Ireland's carbon farming framework.
Carbon Farming Definition -
To welcome the widening of the scope of the definition of carbon farming as proposed in the guidance document to go beyond carbon removals. Under the proposed framework there will be a three-pronged approach to reward measures undertaken by farmers to (i) remove carbon, (ii) reduce/avoid emissions and (iii) deliver co-benefits of biodiversity and ecosystems.
- The expansion of definition to include emissions reduction and nature-based solutions is very important considering that carbon removals such as afforestation or rewetting peatlands are accounted for under Land Use and Land Use Change and Forestry (LULUCF) not under Agriculture.
- Bearing in mind that approximately 65% of agriculture's emissions are biogenic methane it was vital that the framework created a mechanism that can value and pay farmers for reducing on farm emissions and support the widespread adoption of the proposed measures set out in the Climate Action Plan 2023.
Credibility of Carbon Framework -
To propose that Ireland should take advantage of the lessons learnt from voluntary carbon markets (VCMs), particularly around allegations of “greenwashing” that some programmes have been plagued with in recent years as they did not deliver the predicted carbon reductions.
To ensure that the development of government led regulatory framework to certify carbon removals or emission reductions is based on robust measurement, using Irish science where possible, to safeguard the credibility and integrity of the carbon credits generated on Irish farms. There must be full transparency on the guidelines, methodologies used as well as carbon transactions to create trust.
If there is trust in the framework this could lead to greater market activity and potentially unleash significant finance to enable farmers to invest in low-carbon technologies and nature-based climate solutions.
Additionality Viewed Negatively by Farmers -
To demonstrate that the proposed additionality requirement that farmers would only be eligible for a carbon payment for new actions or measures implemented to remove carbon is viewed negatively by farmers, as it (i) does not value the existing carbon reservoir in soils and or hedgerows on farms and (ii) penalises earlier adopters of practices that have improved carbon removals and prevents them from earning as much money as farmers who adopt practices later.
To propose that the additionality requirement as well as the definition of additionality be reviewed so that it does not create an unfair penalty for farmers who had been innovative and forward-thinking enough to adopt beneficial practices years before the framework is introduced. Farmers should be paid for their beneficial practices, regardless of when they started.
To highlight how studies have shown that the additionality requirement can establish a perverse incentive against maintaining beneficial practices over the long term and/or encourage farmers to switch practices in order to qualify or enhance their eligibility for payments in the future. This needs to be fully considered as part of the development of the framework.
Terms and Conditions of Carbon Payment -
To ensure that the carbon farming framework provides farmers with an additional payment for the carbon removed or the emissions reduced to encourage farmers to act for the climate. A farmer must not be restricted from receiving a carbon payment if in receipt of a Climate Action Plan (CAP) payment for undertaking a measure that is included within the framework.
To highlight that, as set out in Ireland's Common Agricultural Policy (CAP) Strategic Plan 2023-2027, payments are made based on (i) additional costs incurred and (ii) income foregone as set out in the EU Regulations under Article 31 (7) (b) of the Common Agricultural Plan (CAP) Strategic Plan Regulation. It is not a payment for the carbon sequestered or the ecosystem service provided.
Therefore, farmers should be eligible for a carbon payment even if the measure is supported under the Climate Action Plan (CAP), particularly considering the carbon sequestered goes beyond the lifespan of the current Climate Action Plan (CAP) programme.
Predictable Carbon Payments -
That the carbon price to be paid must be predictable and fully transparent for each measure eligible under the framework. The uncertainty with regards payments has been a criticism of farmers who have participated in VCMs globally.
To highlight that, according to studies the most consistent complaint raised by farmers participating in carbon markets is that the payment is simply too low to drive substantial practice changes on their farms. The cost of changing practices, should be fully compensated, or else farmers will be hesitant to take a ‘leap of faith' into the VCM.
To propose that a clear price signal would allow farmers to plan and invest in low-carbon technologies and nature-based climate solutions. Establishing a carbon price corridor (carbon floor and ceiling price) that could be reviewed regularly could provide the necessary certainty and reduce the risk for farmers as there would be transparency on the payment to be received.
To ensure that, as carbon sequestration is a long-term process, farmers need long-term support for at least 20 years.
Farmers Must be Main Beneficiary -
To insist that the carbon farming framework must be designed and structured to benefit farmers rather than agri-businesses, large corporations and/or offset buyers. There must be transparency in relation to the pricing structures and traceability to ensure that farmers are being fairly paid to undertake the measures versus the carbon price paid for the credit generated.
- The framework must support the development of a fair price for farmers that reflects the real costs for farmers, as well as for the benefits for society. It is important to prevent the reward for carbon farming from entering an international race to the bottom, just as we do with food prices.
Suitable for All Farm Types -
To propose that the carbon farming framework must be structured so that it can be easily applied to all farm types and enterprises. The cost of measuring and verifying carbon credits, including third party verification, must not be a barrier to smaller family farms participating. The level of detail required to participate in the programme must not disadvantage small and mid-sized farms and contribute to further consolidation of agricultural land.
Standardisation of Measure, Verify and Report (MVR) of Different Measures -
To insist that Teagasc should be the lead organisation to support the development of science-based methodologies to measure, verify and report (MRV) the carbon reductions. This would complement the work that is ongoing as part of the development of the MACC, Signpost Farms and the NationalAgricultural Soil Carbon Observatory (NASCO). It would also ensure that the credits are only issued for genuine reductions in greenhouse gases.
Support Widespread Adoption -
To highlight that, in order to support widespread adoption farmers must trust the systems and methods used to measure the carbon payment. The incentive for adoption must reflect the effort and cost of implementing the measure as well the costs involved in measuring, verifying and reporting, which could hinder the wider adoption of the framework by farmers.
Simple and Streamlined Participation Process -
To ensure that the framework should not be excessively convoluted and burdensome, and should enable farmers once baseline has been created to input data without the need of professional assistance. It should have simple methodologies and flexibility including easy to follow rules and administrative processes and it should not impose legal constraints that may affect the viability of the farm and the earning potential of future farmers.
Governance -
To propose that formal adoption of voluntary frameworks into national rules would help delineate responsibilities and reduce the opportunities for inaccuracies and fraud. The framework should aim to connect companies looking to offset their carbon footprint directly with farmers. This would give buyers the comfort of knowing that their money actually ends up with the farmers they want to support.
It should provide a clear and motivating framework that is aligned with other policy objectives and requirements (CAP23, Water Framework Directive (WFD), National Biodiversity Action Plan, proposed EU Nature Restoration law, proposed EU Soil Monitoring law etc.). This would avoid contradictory policy and administrative tangle for farmers at farm level.
Farmers must not Lose Control of their Data -
To highlight that, to qualify for carbon credits, farmers will be required to share enormous amounts of data about what is happening on their farm. Farmers are concerned about who will control the data and as this could provide agri-businesses and companies with unprecedented access to their data. Often these are the same companies on which farmers depend for purchasing farm inputs, hence creating a conflict-of-interest situation. All data must remain in the ownership of participating farmers.
Educational and Training Barriers -
To insist that it will be vital that information and training is provided to interested farmers. Educational barriers, such as insufficient knowledge or training, have been widely cited as a barrier to adoption. These barriers include unfamiliarity with and lack of information about practices, their requirements under the framework and concerns about the costs of implementing new activities, despite financial incentives.
This will help to support adoption and will alleviate concerns and/or potential distrust of Voluntary Carbon Markets (VCMs).
To acknowledge that the Voluntary Carbon Markets (VCM) have the potential to offer farmers new opportunities to diversify and generate additional income to improve the long-term resilience of their farm. However, for such incentives to be effective in inducing farmers to implement on-farm activities, they need to be functional for farmers who are implementing them.
To highlight that there are a number of barriers that need to be considered as part of the development of Ireland carbon farming framework which include;
(i) farmers unfamiliarity with and lack of information about practices
(ii) concerns about the costs of implementing new activities versus the carbon payment as well as the predictability of that payment
(iii) the additionality requirement to qualify for payment
(iv) additional paperwork and administrative requirements
v) a lack of predictability and the 'black box' of credit calculations.
To emphasise that it is imperative that changes are made to ensure farmers who are already sequestering carbon both above and below ground are rewarded for these actions. A system that only pays based on additionality will not be credible in the eyes of farmers and fails to reward the sequestration already taking place n many farms via hedgerows and regenerative practices that promote increased coil carbon storage.