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How to avoid threats to food production and biodiversity and support positive synergies

The document below is the second output from Credible’s Focus Group 1.3. It is a live document that will be improved thanks to everyone’s participation in this public consultation and the subsequent activities of the Focus Group. By sending your opinion on the matter, you can contribute to bringing valuable knowledge to the attention of the broader expert community and policymakers. This public consultation is monitored closely by the Expert Group on Carbon Removals that supports the Commission in its efforts to develop the Carbon Removals and Carbon Farming (CRCF) Regulation. We therefore invite all stakeholders and simple citizens to make your voice heard. It is the time to contribute to fair and transparent European policies, ones that can help the agricultural and forest sectors to stand out as an important solution to our current climate crisis.

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Your opinion matters

Received comments will be reviewed for compliance to our privacy policy and moderation standards. Once approved, they will be accessible through this webpage. With your consent, the sender's name, country of residency and professional affiliation will be displayed for each published feedback. You can either send a short comment (text) or a more formal view on the addressed issue (uploading a pdf file)

Feedback received so far

Gerry Lawson (Spain) | EURAF

07, 25

This is a rather negative conclusion: "A one-year long academic and technical debate about relationships between carbon sequestration, crop yield and biodiversity and an intensive review of the available literature led to the conclusion that there is no evidence of the sign and direction of these relationships."

I sympathise with the statement "there is no clear definition of the agricultural practices applied" (this should have been the job of TG1.1).

Comments on Recommendations: Holistic management plan needed before implementation of carbon farming projects – agreed. It is the job of regenerative or agroecological movements to provide clear studies on economic costs and benefits (for different types of farm and farmer).

Carbon farming project should consolidate the farm business – yes, which is why CAP payments have to be reinforced in a planned way through carbon payments.

Compensation should be higher in drier areas where production is lower – clearly, which is why it is a pity that the idea of a standardised baseline has been abandoned (for the time being) by the CRCF. Sadly, data on the current PMEF agri-environment climate indicators are simply not good enough for analysis at the Municipality level. Subsidies for biodiversity conservation should complement those for carbon – yes, clearly. The stress on measurable indicators at farm and parcel scale is crucial.

Additional point 1: I missed the special case of rented land (almost 50%) in the EU. The period of rents is ridiculously low in some countries.

Additional point 3: The structure of this document is confusing. Recommendations seem to be in the middle.

Pierre-Philippe CLAUDE (France) | Polyor

07, 25

I agree, SOC/M build up need not be viewed as costly. My take ( www.polyor.fr) is that SOC/M in ensured if the grain-N yield (kg-N_grain/ha) and N-fertilizer application rates (kg_Nf/ha) are coupled in such a way that soil borne crop residues will not be deprived of the N, P or K required for their proper humification into stable SOM. This scheme, referred to as AgroNum™ has no inherent cost and is applicable to low and high yield cropping systems, from organic agriculture to intensive conventional field crop production. More so, AgroNum™ target grain-N yields N-fertilizer use efficiencies are most often higher than the corresponding environmental means thus avoiding threat to food production security.

Anonymous

07, 25

Harnessing Nature-Based Soil Inputs to Support Biodiversity, Profitability, and Climate Goals To foster positive synergies between food production, biodiversity protection, and carbon sequestration, we recommend that the CRCF policy framework encourage the development and use of biodegradable, circular, and nature-aligned soil inputs that: Enhance soil structure and microbial biodiversity Support crop resilience to drought and pests without relying on synthetic residues Fit within low-cost, low-barrier strategies for regenerative transitions on dry or degraded land These tools are especially relevant in semi-arid regions or during transitional phases, where productivity may temporarily drop. Using degradable, microplastic-free nutrient carriers — especially those built from agricultural residues and fungi or biochar — can provide: Incremental soil carbon gains Water retention benefits Local biodiversity support (e.g. pollinators, in-soil organisms) We also encourage coordinated EU research on low-cost biodiversity indicators that reflect these ecosystem-level improvements, including soil fauna diversity, microbial activity, and surface biodiversity regeneration. Incorporating such tools into farm environment plans, subsidy design, and carbon-biodiversity bundled credit models can improve outcomes for both farmers and ecosystems — while maintaining long-term food production.