The Greenhouse Gas Protocol recently released its long-awaited Land Sector and Removals Standard (LSRS). However, are guidelines suitably clear to steer companies towards climate accountability, or are loopholes opened that allow for creative carbon accounting?

The Land Sector and Removals Standard is designed as a framework to allow companies to account their activities that generate land-based carbon emissions and for companies that want to account and receive recognition for removals activities. This standard was long-awaited by companies and other voluntary initiatives, as it should pave the way for robust calculation, reporting, and target setting of land-based emissions and removals. 

The publication arrives at a time when many voluntary frameworks are in a phase of revision and development – notably standards by the International Organisation of Standards (ISO), the Science-Based Targets initiative (SBTi), and the Greenhouse Gas Protocol (GHG-P) – and will likely be influenced by LSRS provisions or even complemented by the LSRS. 

However, CMW has sketched the scenario of companies adhering to both the LSRS and the SBTi’s FLAG Guidance, and found worrying evidence that compliance with the FLAG Guidance is taking precedence over the LSRS (more about that below).

A high bar, but only for the willing  

The LSRS dictates suitable requirements for carbon removal safeguards ranging from accounting, reporting, traceability, data quality, allocation for scope 3 emissions, and permanence. It doesn’t fall short of defining removals as either land-based or geological, and mandates that companies account for all life-cycle emissions of removals across all scopes. 

Commendably, product carbon storage is excluded from the definition of removals and may be reported under a separate accounting ledger. This is a big leap forward for integrity, since product carbon storage is heavily dependent on what happens to products after they have been transferred to the end user. 

However, it is not all good news. Applying the LSRS offers companies the option to report their use of removals on a voluntary basis. We identified this as the Achilles heel of the document; introducing such flexibility – in what is already a voluntary framework – sends the wrong signal about the importance of accurate reporting on carbon removals. 

Additionally, while the principle of permanence is defined in line with climate science, no definition of ‘continued storage’ is given. Without a timeframe, this could mean anything from lasting two months or over 1000 years (as suggested by scientific research). 

Moreover, by using the term ‘non-atmospheric pools’, the document conflates land-based, temporary storage with geological pools, which has much longer storage capacity. The duo of faux pas is only slightly mitigated by inclusion of a safeguard that mandates for companies to report reversals to removals when they lose the ability to monitor accurately.    

Complementing but not contesting the SBTi’s FLAG Guidance

Previous analysis conducted by NewClimate Institute in collaboration with Carbon Market Watch indicates that the climate targets adopted by major food companies that adhere to the provisions set out in the SBTi’s FLAG Guidance are too vague to meaningfully drive demonstrable emission reductions in the land sector. 

The FLAG Guidance advises that companies must count their carbon removals and emissions separately, but that approach is undermined by allowing targets to be netted out without requiring specificity on what was a removal, and what was an emissions reduction. 

The LSRS suggests the right approach in its target setting chapter which instructs that separate targets be used for emissions reductions and carbon removals. But before getting your hopes up that the LSRS can finally contribute to a stakeholder and consumer friendly target setting system, you must read the part where the LSRS is granting precedence to the SBTi’s FLAG Guidance thus overriding the stricter, separate target-setting rules. 

The importance of clear guidelines is there for all to see. Loopholes must be closed before companies can selectively use the LSRS for carbon accounting, and switch to the FLAG Guidance for muddied down target setting.

The SBTi can and should close this loophole by updating its FLAG Guidance to align with the LSRS.