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COP28: Removing ambition from Article 6 carbon markets

Carbon removals are again on the negotiating table at COP28 in Dubai. And, again, the text is inadequate.

Carbon Market Watch’s delegation at COP28 has been getting distinct déjà vu vibes in Dubai, and not just because the hot desert atmosphere reminds them of last year’s COP in Sharm el-Sheikh.

The team spent some time looking into the draft text on carbon removals that the Article 6.4 Supervisory Body has submitted for adoption into the Paris Agreement rulebook. Just like last year, we feel the draft is more likely to remove ambition from climate action than carbon dioxide from the atmosphere, even if it is longer and more detailed than last year’s and improves on several elements of the original. 

In its current state, the text is far from ready for negotiators to adopt it. Yet it still asks of negotiators, and the planet, to take a leap of faith and put the future of this crucial ruleset in the hands of a small group of experts, the Supervisory Group, that are operating away from the spotlights of the COP (though we do very much appreciate the level of transparency of the Supervisory Body so far).

Definitive problems

The list of problematic elements is barely shorter than last year. The definition of carbon removals keeps the door too wide open for risky practices, such as counting products as safe storage mediums for CO2. The reversal risk assessment tool is simply non-existent at this stage, despite the fact that the draft rules rely heavily on its application. There are currently also no buffer pool arrangements. 

The post-crediting monitoring period is a welcome addition that goes further than common practice in carbon markets so far, but it remains open-ended, with the possibility of it being a very short period depending on what future rules will be adopted. The lack of a clear definition of “avoidable” and “unavoidable” reversals – i.e. those due to natural factors outside a project’s control and those due to intentional activities – leaves another key element of text in limbo with little guidance about how effective that distinction will actually be. 

Similarly, the absence of any explicit reference to human rights and the heavy reliance on safeguards that are yet to be defined (such as grievance mechanism) leave important questions about the local impact of these activities unanswered. 

We appreciate that the Supervisory Board cannot adopt rules to cover all possible eventualities on the first (or, in this case, second) try. But having monitored the discussions for over two years now, we think that negotiators will not send the right signal, both to the Supervisory Board and the market, if they were to adopt this text.

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This is an adapted version of an article that appeared in CAN Internationals ECO newsletter

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