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How current carbon removals policy frameworks fail to benefit the climate

A recent report by Carbon Market Watch of 20 global, EU, national and sub-national climate policy frameworks shows that not one governs carbon removals in an environmentally sound way.

The IPCC has confirmed that carbon removals will be needed to deal with leftover emissions that cannot be cut and to reach negative emissions. Supported by the NEGEM project, an initiative funded by the EU Horizon 2020 programme, that evaluates the realistic potential of negative emission technologies and practices, our “Poor framing” report has analysed how three global frameworks, six EU policies and 11 national or subnational jurisdictions are contemplating the role of negative emission technologies and practices – those mechanisms that remove CO2 from the atmosphere and store it permanently, also commonly known as carbon dioxide removals (CDR). 

By setting criteria established in scientific evidence and previous analysis, and by citing the wisdom of academics and policy experts, we got to the heart of the environmental integrity of these plans. Unfortunately, we concluded that all of these analysed policy frameworks are inadequate and will require further development if they are to drive CDR in a direction that not only achieves the varying ambitions of climate goals, but that also has a lasting environmental benefit.

A worrying trend

According to the report, only a handful of countries (France, Germany, Sweden, Switzerland and the UK) recognise the role of removals as a supplement to, and not replacement for, emissions reduction. However, even then these countries only acknowledge this climate hierarchy in non-legally binding strategies instead of proper legislation. 

In addition, none of the policy frameworks set comprehensive, separate and legally binding targets for CDR, except for when a few referred to carbon sequestration in the land sink.

As a consequence of this legislative void, a worrying trend is emerging: carbon removals are being utilised to offset emissions and to alleviate pressure on the need for polluters to reduce their emissions. That is explicitly true for the global frameworks the Carbon Offsetting and Reduction Scheme for International Aviation, the Clean Development Mechanism of the Kyoto Protocol and Article 6 of the Paris Agreement, but loopholes that lessen emission reduction obligations through using land-based removals can be found in the EU’s Renewable Energy Directive and the flexibility mechanisms of its Effort Sharing Regulation. Fortunately, the EU Emissions Trading System does not include removals, although this possibility is being discussed

Moreover, many of the national and subnational jurisdictions reviewed include removals in offsetting mechanisms or to reduce compliance obligations in emissions reduction policies, as is currently the case in Australia, California, France, New Zealand, and Switzerland. The UK plans to do likewise with its national ETS. Finally, the EU’s proposed Carbon Removals Certification Framework (CRCF) purposely avoids defining the valid end uses of certified removals units, so that it can leave the door open for CRCF-certified units to be used for offsetting not only throughout national and EU-level climate policies, but also in voluntary carbon markets.

Leaky definitions and accounting

A sufficiently airtight definition of carbon removals is missing from all the frameworks we looked at. A common problem is the inclusion of potentially very short-term and/or highly vulnerable carbon sequestration methods (such as carbon sequestered in soil or vegetation) in the definition of carbon removal, without any or adequate differentiation between those more vulnerable carbon stores and any potentially more secure stores (e.g. storage in geological reservoirs). 

Last but not least, none of the frameworks contain robust, comprehensive accounting and Monitoring, Reporting and Verification methodologies, to prove that actual removals were generated by a given process. Typically, existing rules refer mainly to LULUCF or to specific aims, such as to certify removals, that are being used for offsetting purposes.

Policymakers should listen to the science

It is clear that how existing climate policy frameworks are currently framed does not guarantee that removals will play the role the science says they need to. That is to truly balance out only very last emissions that cannot be eliminated, leading eventually to negative emissions. Policymakers around the world must recognise this flaw and by acting now have the power to effectively limit global heating.

Carbon removals should be clearly defined as a process that removes CO2 directly from the atmosphere and stores it for at least a couple of centuries, with the emissions taken out of the air outweighing the emissions involved in the removal process. It is essential that removals are considered separately from emission reductions, and that they are given their own specific targets and governance frameworks, including clear monitoring, reporting and verification rules and accounting systems. 

All else is time wasted in the context of the climate crisis.


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