Brussels, 03 of December 2021
To: Mr Frans Timmermans, European Commissioner for Climate, and Commission Executive Vice-President for the European Green Deal
Cc: Mr Janusz Wojciechowski, European Commissioner for agriculture and rural development
Dear Executive Vice-President Timmermans,
We wish to share with you our concerns on the leak communication on “Restoring Sustainable Carbon Cycles” and the related Staff Working Documents #1 and #2, and to hereby request a meeting with you or a member of the cabinet in the coming weeks, prior to the release of the communication. We would be pleased to hear your replies to our concerns and observations below.
We have long since been working to combat the negative environmental impact of certain farming methods, underlining the importance that small-scale farmers must play in on the reduction of greenhouse gas emissions and climate mitigation. We were initially very supportive of the carbon farming initiative in this respect. However, the communications we have read announce a future that would cause yet more climate damage, and it is our role to ask you to take action immediately to avoid this. We are also deeply concerned that nothing from our reply to your consultation on the roadmap to the initiative was taken into account.
The role of farmers is to provide sustainable and healthy food
We wish to recall that the role and work of farmers is to produce food. It is not to sell carbon credits. We are not only “land managers”, we are farmers. ECVC is a European-wide coalition of small- and medium-scale farmers’ organisations and unions. We have 31 member organisations from 21 countries. We work towards food sovereignty and supporting a transition to agroecology. We wish to promote the installation of millions of farmers in EU countryside, to provide jobs for people and healthy, sustainable, appropriate food to citizens, no matter how big their wallet . Our practices sequestrate carbon, have generally the lowest GHG emissions, and cultivate a flourishing biodiversity.
According to our analysis, the initiative will likely contradict the objectives laid out in the Contingency plan for the continuity of food supply in the EU. In order to ensure food production in Europe, farmers need to be remunerated for their work of producing food and not for managing carbon. We do not want to be paid via carbon credits. Instead, we demand fair prices for the agricultural products we sell.
Carbon credits are not the solution to European agricultural impact on climate
ECVC wishes to call on DG CLIMA and DG AGRI to not adopt any form of carbon crediting. There is rising evidence  that carbon credits, carbon market and compensation principles have perverse effects. We are concerned that carbon credits linked with agriculture will lead to huge speculation and concentration of agricultural land. This would have consequences on job losses, rural desertification, biodiversity damages, and threats on food security and food sovereignty. The detrimental effects of these mechanisms are highlighted at the core of the UNFCCC 26 negotiations. We wish to ask why no precautions are taken against these carbon credit mechanisms as well as the reasons why there seems to be no limitation on who can buy carbon credits. There is an important gap between the means announced in the communication and the reality of the effects of such means, many of which we are already experiencing.
ECVC is alarmed by the mix between public and private funding
In the communication, the recourse to carbon credits is explained by the announced incapacity of the CAP to cope with the cost of carbon farming practices. With its €54bn per year budget, isn’t it the very purpose of the CAP to ensure that European agriculture remains sustainable and coherent with the Green Deal’s objectives? We must remember that within the current modalities of the CAP, it is almost impossible for farmers to ensure a safe transition towards healthier practices, or to make a living out of sustainable practices. From our view, the carbon farming initiative does not provide any solution to this and we would like to understand why. ECVC encourages the Commission to give priority to market regulation including a drastic decrease of importations and exportations and to stop free trades agreements.
We would also like the Commission to clarify the relation between public funding (the CAP is described to be ideal to ensure the “uptake” of carbon farming) and private funding (describes as the only way to support the initiatives in the long term). Public funding supports public interest, while private funding is meant to generate private profit. It would be unacceptable for farmers receiving CAP subsidies to be forced into carbon credits in order to maintain their revenue. What concrete safeguards is the Commission planning to install to prevent this from happening?
Additionally from ECVC’s analysis, within the documents, monitoring, reporting and verifying (MRV) mechanisms seem to be the main source of expenditure, together with the approach of costly new technology. We ask for more clarity on what it entails and implore the EU to prevent these mechanisms falling into the hands of private interests.
An incomprehensible lack of systemic approach
Despite supporting the Green Deal objectives, ECVC believes that the approach of the carbon farming initiative as it is will not solve climate issues. Instead of fragmented, insufficient solutions, the European Union needs a systemic approach.
ECVC recognises the positive environmental impacts of the five types of practices mentioned as examples of carbon farming. However, it recalls that these practices would not have any impact if not addressed in a systemic way. The communication does not make any mention of small- or medium-scale farming, it makes very poor mentions of agroecology or even organic farming approaches. We underline that a 2021 FAO report stated that small farms produce one-third of the world’s food. Family farms, of any size, produce 80%. Research has proven that it is viable for Europe to undertake the transition to agroecology. The fragmented approach exposed by this leaked communication sets aside the majority of European farmers and is detrimental to the legitimacy of the entire proposal.
Instead, ECVC encourages the Commission to invest in maintaining and settling numerous farmers throughout Europe in order to ensure a fair transition towards agroecology, climate friendly agriculture and healthy food production for all EU citizens. We have strong hope that the European Commission’s Farm to Fork Strategy is a first step towards sustainable, agroecological and holistic practices, but believe this is dependent on also implementing better market regulations and fair agricultural prices.
In the name of ECVC’s Coordinating Committee, we wish to thank you sincerely for having taken the time to read our observation. We look forward to exchanging with you on these issues and kindly ask you to review the Sustainable Carbon Cycle Communication in light of the above. The future of European farmers and agriculture, the future of European food as well as of the world climate depend on it.
Mrs Morgan Ody, Mr Andoni Garcia, Mr Attila Szocs, ECVC Coordinating Committee members
 The present letter will focus on the Carbon Farming mechanisms of the leak documents. It does not address the concerns we have on the industrial carbon capture and storage and on the certification of carbon removals which are also mentioned in the Communication.
 Among other sources: https://www.foei.org/wp-content/uploads/2021/02/Friends-of-the-earth-international-carbon-unicorns-english.pdf ; https://www.iatp.org/documents/why-carbon-markets-wont-work-agriculture
 The communication sets that they may be “companies and individuals outside the bio-economy who want to financially contribute to more climate action on the land and to neutralise their own emissions.” ( Section 2.1 of the leak communication “sustainable carbon cycles”)
 Notably in SWD 2
 Detailed in section 2.1 of the leak communication “Sustainable Carbon cycles”, under the sub-section “Carbon farming practices”
 Except once to say that they will need support to bear the administrative burden. Cf. Section 3.2 of SWD 2
 FAO, 2014. The State of Food and Agriculture 2014: Innovation in Family Farming Food and Agriculture Organization of the United Nations; and Lowder et al., 2021, Which farms feed the world and has farmland become more concentrated? World Development, Volume 142.
 In particular the TYFA scenario (Ten years for Agroecology), see Xavier Poux and Pierre-Marie Aubert, Demain une Europe agroécologique, Actes Sud; but also the scientific article written by Gilles Billen and published in One Earth https://www.cnrs.fr/fr/une-agriculture-biologique-pour-nourrir-leurope-en-2050
 According to Eurostat 2020, 77% of European farms are smaller than 10 hectares.