Carbon Market Watch (CMW) welcomes the opportunity to comment on activities involving removals. We encourage both SBSTA and the 6.4 Supervisory Body to continue inviting stakeholders to submit views. CMW is also keen to participate in the “structured consultation process” on removals and other subjects that will take place this year (para 22, 6.4 decision at COP27).

The intersection of removals and carbon crediting is a highly important and complex topic that requires proper consideration to get the details right. We strongly urge the 6.4SB to take its time in developing its recommendations, taking account of stakeholder inputs via “the structured consultation process”. The recommendations on methodological requirements should be adopted together with those on removals since these issues overlap. Doing this correctly may mean it will not be possible to finalise both sets of recommendations by COP28 – if they must be delayed again for the sake of quality, this is better than taking shortcuts to satisfy a mandate. These recommendations will have direct consequences for what is permitted under the 6.4 mechanism for years to come, as well as knock-on effects on the voluntary carbon market, compliance markets, and future legislation such as the European Commission’s proposed Carbon Removal Certification Framework.

Apart from the procedural aspects, the issue of impermanence is closely tied to any discussion of removals. In general, emission reductions and removals should not be considered equivalent, as addressing the climate breakdown means focusing first on emission reductions and second on upscaling removals. Emission reductions and removals should therefore be developed as complements rather than substitutes. However, since offsetting is likely to occur under Article 6.4, at the very least temporary storage and permanent emissions should not be equated. Simply put, the SB must not allow crediting of temporary carbon storage if this is used for offsetting purposes