This post has been co-authored by Paul Zakkour, Director at Carbon Counts.
The spotlight on carbon removal is getting brighter. UN standard-setters have begun a crucial process to lay the groundwork for removals under the Paris Agreement. This has gone largely unnoticed by the carbon removal community, which has been mainly focusing on the voluntary carbon market. Why is this development so important? What has taken place so far? And how to get engaged? Learn more by reading on.
Carbon markets under the Paris Agreement
Article 6 is the markets clause of the Paris Agreement. It sets the basis for countries to cooperate to meet their climate targets by allowing emission reductions and removals in one country to be traded and counted towards the target of another.
Architects of Article 6 envisaged two ways for this cooperation to happen: one through decentralised forms of cooperation such as linkages between various national trading systems (Article 6.2), and another through a centralised UN-run pathway for countries lacking the capacity to implement trading approaches domestically (Article 6.4).
A 24-person Supervisory Body of national representatives was nominated to run Article 6.4 and tasked by the Glasgow COP26 to review various methodological issues, including those specific to carbon removals, and make recommendations to the COP27 in Sharm El Sheikh.
Why should the carbon removal community pay attention?
The Supervisory Body will prepare the foundation for how the UN’s carbon crediting mechanism will apply to removals. They have only begun this work and are seeking stakeholder input. How removals are included in this mechanism can have a wide-ranging impact, similar to how the Clean Development Mechanism (CDM) helped shape the voluntary market we know today.
Experiences with removals under the CDM were limited, whereas the voluntary carbon market has recently been more progressive in these respects. As such, the matter offers an interesting test bed to see how far voluntary standards could be accepted by policymakers at the UN level.
The carbon markets are in a state of convergence, with the voluntary markets attempting to align themselves more closely with the compliance markets and the latter trying to take advantage of the infrastructure of the former. Those voluntary market standards that are aligned with the future Article 6.4 rules could get their methodologies approved and tap into the additional demand from governments.
Lack of stakeholder input to date
The second Supervisory Body meeting in September had carbon removal firmly on its agenda, and a call for input was published shortly before. The feedback was surprisingly sparse; only two submissions commented on carbon removal.
Why such limited input on removals? One of the reasons might be that many stakeholders are relatively new, focus solely on the voluntary market, and lack the understanding and expertise to feed into the UN process.
Those that don’t have an accredited observer status under the UNFCCC won’t be invited to participate in the Supervisory Body meetings (read how to obtain observer status). In the case of for-profit entities, many don’t know whom to work with to provide input.
Another reason is the complexity and lack of best practices in resolving the issues at hand. The EU is also presently grappling with these matters.
Gaps and confusion in removals discussion
The second Supervisory Body meeting demonstrated the need for the SB members and the UNFCCC Secretariat to draw upon a wider range of experts, including those in the voluntary market, as well as similar expertise that the UN brought together under the auspices of the CDM (e.g. working groups on forestry; Carbon Capture and Storage).
An informal sub-group of 10 members of the Supervisory Body (listed here) is spearheading the work on removals. They provided input for the two draft documents shared for public input before the meeting.
The interventions during the meeting included confusion over the content of the documents. Questions were raised over why tonne-year crediting has been built into the drafts when Supervisory Body members have not requested it. There are good reasons why this concept has not been featured in UN carbon crediting mechanisms to date (here is an example of a more recent criticism). Another frequent comment was the lack of inclusion of good practices built on decades of work in carbon markets, such as jurisdictional crediting for natural carbon stocks. Conversely, the recommendations drew heavily from prior experience in other areas, such as geological carbon storage.
The participants agreed that the documents went into too much detail, while at the same time lacked clarity around the options to deal with the complex methodological issues at hand (esp. boundaries, leakage, non-permanence, liability and accounting).
A third document was drafted during the meeting. There was no agreement on whether the work should be about carbon or greenhouse gas removal, despite looking at three different definitions.
One member asked for clarification on whether reversals from carbon storage should be tackled under removal work, or under emission reductions, given that geological storage technology features in both.
Throughout the meeting, several Supervisory Body members repeatedly requested further input from stakeholders on carbon removal. All in all, three separate working documents were discussed, but there remained quite a bit of confusion around the basics. No final decisions were taken, and the informal carbon removal working group will return to the drawing board to prepare for the upcoming meeting.
The goal now will be to prepare a broader set of recommendations that apply to the full spectrum of carbon removal methods. It is essential to get it right, given that, as one member put it, “what we adopt here will be the foundation of every single future decision we adopt on removals”.
There are many ways to advocate for a robust carbon removal framework and methodologies in the UN’s carbon crediting mechanism, such as following and taking part in the Supervisory Body meetings, responding to official calls for input, and conducting capacity building with those involved.
A new call for input with a deadline of 11 October was just launched and will feed into the third meeting of the Supervisory Body that will take place 2-5 November in Sharm El-Sheikh. Accredited observers to the UNFCCC can register to attend the meeting until October 13th.
It’s time to read up, get engaged, establish expertise and/or collaborate with those who have it, and help shape the global rules for carbon removal.
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