Abstract

In Grassi et al. (2018) it is argued that wrong premises result in misleading conclusions in Kallio et al. (2018) about the Forest Reference Level (FRL) approach included in the EU LULUCF Regulations. Discussing the arguments presented by Grassi et al., we find that they fail on all major points, and, in addition, reveal a surprising lack of understanding about how FRLs will function in the global market-driven forest sector economy. The results shown in Kallio et al. (2018) are still valid, suggesting that due to the globally growing demand for forest products and available forest resources outside the EEA (i.e. in RoW), the trade leakages of harvests, forest industry productions, and consequently also employment, from EEA to RoW could be considerable. Therefore, climate mitigation benefits of the FRL policy unilaterally implemented by the EU in the form of increased forest sinks within the EEA, would be much reduced.

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