Carbon Market Watch (CMW) welcomes the opportunity given by SBSTA to comment on “whether Article 6, paragraph 4, activities could include emission avoidance […]” (para 9a, 6.4 decision at COP27).

We would reiterate points from our previous submission, namely, that emission avoidance should not become eligible as a way to generate A6.4ERs or ITMOs. Carbon Market Watch would align with the numerous Parties at SBSTA 56 and SBSTA 57 who opposed integrating emission avoidance under Article 6, including by expressing significant concerns about the potential negative impacts of its inclusion. At COP28, Parties should definitively decide that emission avoidance is not eligible under Article 6.

These concerns are well founded since “emission avoidance” is an inconsistently defined term, especially in a carbon crediting context, and could be interpreted in a variety of ways with potentially devastating outcomes. In some cases it is quite unclear how to distinguish emission avoidance from emission reduction. Would all reductions against an increasing baseline qualify as avoidance? In such cases, emissions are not actually decreasing, they are just increasing by less than the baseline. Overall however, emissions would still increase, which is justified by the argument that “it could be worse”.