Newsletter

A comprehensive list of data-related regulations is given. Two are omitted, however: a) the Farm Sustainability Tool. The CAP Strategic Plan Regulation Article 15 Para 4g placed an obligation on all Member States to help all farmers with the sustainable management of nutrients, including, at the latest as from 2024, the use of a Farm Sustainability Tool for Nutrients, which is any digital application that provides at least:
(i) a balance of the main nutrients at field scale;
(ii) the legal requirements on nutrients;
(iii) soil data, based on available information and analyses;
(iv) data from the integrated administration and control system (IACS) relevant for nutrient management.
No Member State complied with this requirement, and no compliance action was taken by DGAGRI.

b)the High Value Datasets Implementing Regulation (2023/138) of the Open Data Directive (2019/1024). This clearly puts the IACS-GSAA-LPIS datasets in the list of high value spatial datasets which Member States have to provide:
a) free of charge,
b) under a permissive open licence (Creative Commons BY 4.0 or equivalent),
c) in machine-readable formats, and be accessible via both
d) Application Programming Interfaces (APIs), and
e) bulk download.
Five Member States are totally non-compliant, and only three are fully compliant (see Annex 1 of EURAF Policy Briefing #68). Compliance action is needed rapidly from DGCONNECT.

Other than those omissions, the conclusions are great. We urgently need to move to full open access to data collected with public money and work together with the farming unions to ensure that the "on-farm sustainability compass" proposed in the DGAGRI Vision for Agriculture and Food can work for all.

Dear Credible team, thank you for the opportunity to contribute to the Credible 2025 consultation. Our feedback reflects hands-on implementation across markets and aims to inform how digital infrastructure can accelerate traceable, cost-effective carbon farming aligned with the CRCF. The following feedback is based on our work designing digital infrastructure for credit-level traceability, automated sustainability reporting, and integration with emerging standards. In the attached letter, we provide reflections and recommendations in response to the following five expert reports:

1. Barriers and incentives for sharing input data needed in carbon farming and MRV systems in Europe; 2.Earth Observation (EO) for MRV of Carbon Farming; 3. Unlocking data for MRV: Data sharing for effective carbon farming; Ensuring carbon farming delivers sustainability benefits and 5. An effective policy mix for scaling up carbon farming We share our input based on practical implementation experience and with the aim of supporting the development of effective, transparent, and farmer-accessible carbon farming and MRV systems across Europe. Our experience building MRV infrastructure aligns closely with the data architecture envisioned under the EU Carbon Removal Certification Framework (CRCF). In this submission, we provide actionable suggestions to support CRCF-compatible implementation, especially as it relates to credit traceability, automated disclosures, and co-benefit accounting.

ICOS ERIC (www.icos-ri.eu) welcomes the recommendations of the CREDIBLE project related to “Barriers and incentives for sharing input-data needed in carbon farming and MRV systems in Europe” and to “Unlocking data for MRV: Data sharing for effective carbon farming”. As a Research Infrastructure established since 2015 and currently gathering 16 European member countries, ICOS ERIC is ready to fully contribute to the establishment and development of the European CRCF-MRV.

ICOS provides high-quality, standardized and near-real-time data on ecosystem fluxes (exchanges of greenhouse gases between the atmosphere and the land) that are FAIR and openly available on the ICOS Carbon Portal. In its search for a variety of data, Credible and the future MRV system can benefit from ICOS data freely. It is important to remember that ICOS also covers the monitoring of GHG concentrations in the atmosphere and in the surface ocean. These data are also available and Copernicus/ECMWF already makes use of climate-related data provided by ICOS.

The long-term observations delivers data sets that can help define baselines in the context of the CRCF-MRV. These baselines could also be regularly updated thanks to ICOS data. ICOS uses standardized protocols for its labeled (i.e. quality-controlled) stations, which ensures reproducibility over time and all over the ICOS network. These protocols have been updated and published in the International Agrophysics, isssue 04/2018 (http://www.international-agrophysics.org/Issue-4-2018,7048).

The ICOS protocols for measuring ecosystem/atmosphere carbon fluxes using the eddy covariance method are currently implemented in approximately 10 agricultural monitoring sites of the ICOS network. We recommend that this data be used in the definition of CRCF-MRV baselines. Currently, ICOS is also developing “station-duos” where the same agricultural plot is divided into two areas with different management practices, each area hosting a monitoring system able to track changes in GHG fluxes. This innovation is showing promising results.

The operations of ICOS ERIC are funded by its member countries for the benefit of researchers but the independent data is also available for upgraded products that can serve the needs of a large variety of stakeholders. Businesses are also encouraged to use ICOS data. On the longterm, the operation of ICOS could benefit, in the future, from resources made accessible by the European Union, e.g. through Copernicus/ECMWF.

Finally, in the analysis of existing “international research projects and other initiatives”, it is essential for Credible to note that ICOS is NOT a project with a limited lifetime, but an intergovernmental organization with legal personality that has been established precisely to ensure the sustainable monitoring of GHGs in Europe. ICOS, however, participates in a large portfolio of EU-funded projects, including the Integrated Research Infrastructure Services for Climate Change Risks project (IRISCC) that would deserve the attention of the Credible team. IRISCC is namely developing a Soil Carbon Service Design Lab that could support the efforts towards a reliable CRCF-MRV.

The principals in the recommendations are right. The main concern stays to keep cost to farmers low and make sure most of the proceeds reach the farmers improving the biology in their soils while reducing the administrative burden on farmers. Combination of high quality soil sampling and satellite data can resolve many of the issues as shown at the soil health now! conference of opengeohub. Also important to keep in mind that healthy soils increase biodiversity, clean water, improve nutrient density of food grown in it and are a great buffer/preventer of forest fires and desertification. And is directly linked to the amount of photosynthesis happening on that soil and how much it is covered which is the essence of the EARA policy proposal for simplifying agricultural subsidies and rewarding farmers for good land stewardship with highly reduced bureaucracy.