Carbon Farming – for Whom? Analyzing Unintended Consequences of the European Union’s Carbon Removal Certification Framework Using Fuzzy Cognitive Mapping

In November 2019, the European Parliament formally declared a climate and environmental emergency. In this context, several pieces of legislation were published, laying the foundation for the Carbon Removal Certification Framework (CRCF). This framework sets out to certify net carbon removals, including through land-based “carbon farming”, and thereby stimulate financing through public and private sources. Yet the complexities of both the voluntary carbon market and land-based carbon sequestration raise the question – in whose interests is this framework designed, and how will the framework affect small and micro-sized farmers? This research used ‘fuzzy cognitive mapping’, a tool that analyses complex systems by turning qualitative information into a quantitative model, to study the EU’s envisioned regulation on carbon farming. This in turn allowed for the discovery of unintended consequences in the system. The results revealed seven concepts that the EU perceives to be instrumental in the frameworks success: access to knowledge, costs, demand for removals, GHG emissions, participation, revenue, and trust. Further analysis revealed a trade-off between administrative burden and accuracy of quantification, entailing consequences for both inter- and intragenerational justice. Unintentional side effects like a potential decrease in long term food security and a trade-off between quantity and quality of removals were also discovered. The research highlights potential systemic issues regarding the real-world implications of these findings and discusses how the EU may risk their long-term climate goals and the environmental integrity of the policy by underrepresenting small and micro-sized farmers, and placing economic benefits above climate benefits.