Recommendations for Governing Carbon Removal in Long-term Climate Planning

Over the last several years, a growing number of countries have expressed plans to use, or intentions to explore the use of technological carbon dioxide removal methods to reach their long-term climate change mitigation targets. This includes carbon removal approaches like direct air capture and carbon mineralization that are not providing large-scale removal today.

These commitments are of critical importance, as around 80% of global emissions are covered by a national net-zero emissions target, and carbon removal is needed to reach net zero. Indeed, these technologies can counterbalance emissions that are too difficult to abate in the near-term, while in the longer-term help achieve net-negative emissions and reduce the cumulative carbon dioxide in the atmosphere that are causing climate change.

For many countries, these net-zero targets are included in long-term, low emission development strategies (known as long-term strategies) that countries submit under the Paris Agreement to outline plans for achieving their mid-century climate and development goals. As of May 2023, 62 countries had submitted these strategies. Twenty-six, or nearly half, contain mention of some interest in technological carbon removal.

However, despite this growing interest, there is little guidance or even discussion at the international level around the role that technological carbon removal methods can and should play in meeting long-term climate targets. While the Intergovernmental Panel on Climate Change (IPCC), the world’s foremost body on climate science, has made it clear that carbon removal — including technological carbon removal approaches — will be needed alongside deep emissions cuts to meet global climate goals, more guidance is needed to ensure that carbon removal does not come at the expense of emissions reduction, is equitable and is able to be measured accurately and tracked credibly.

These governance gaps are also particularly relevant to the upcoming UN Conference on Climate Change (COP28), which will be held in Dubai in late 2023. Carbon removal — along with carbon capture at emissions sources — is expected to be an area of focus given the host’s position as a small, oil producing country. Critical questions around carbon removal’s role in relation to emissions reduction and fossil fuel use are likely to be brought to the fore since the promise of carbon removal has been used by some to justify continued fossil fuel production. Furthermore, countries are expected to submit updated nationally determined contributions under the Paris Agreement by 2025, which may include increasing levels of interest in technological carbon removal.

To help understand these and other emerging challenges and concerns, WRI has released a new working paper on international governance of technological carbon removal, which explores these issue areas and provides preliminary recommendations.

In our research, we identify three major governance gaps related to managing mitigation deterrence, promoting equity, and improving measurement, reporting and verification, and explore what existing international bodies and processes can do to help address them.

Managing Mitigation Deterrence

Mitigation deterrence is the concern that focusing attention and investment on carbon removal can reduce attention on the urgent need for emissions reduction by providing a false sense of security that future technology will provide large-scale removals. As global investment in carbon removal begins to increase, its relevance to long-term climate planning is becoming more important. The concern is that excessive reliance on carbon removal could come at the expense of emissions reductions, threatening the broader goal of reaching net zero if the anticipated carbon removal does not materialize. Since some degree of carbon removal is necessary to achieve climate goals, as recognized by the IPCC, but excessive focus on carbon removal, or deployment of carbon removal for the wrong purposes, would undermine these goals, this raises the additional questions of what emissions are appropriate to be counterbalanced by carbon removal and what counts as “excessive.”

Several international bodies and processes have it within their scope to help address these questions. Chief among them is the UN Framework Convention on Climate Change (UNFCCC) — the parent treaty to the 2015 Paris Agreement, under which countries must submit nationally determined contributions outlining their climate commitments and are invited to submit long-term strategies. There is an opportunity for countries to provide more transparency around their carbon removal planning, which could be encouraged by the UNFCCC through official guidance.

Meanwhile, the IPCC, whose findings are used as a basis for negotiations, also plays a role. The IPCC’s 2018 Special Report on Global Warming of 1.5C clarified the need for carbon removal in meeting global climate goals and played a major role in setting the industry in motion. How the IPCC talks about the role of carbon removal within climate mitigation is critical to inform how the industry and all its stakeholders plan for the coming decades.

We offer more specific recommendations in this area:

Ensuring Equity in Who Pays and Who Benefits

There are many ways that equity intersects with carbon removal. One area is around the responsibility for developing and deploying carbon removal, which should be distributed equitably, with consideration of who benefits from and who pays for it. There is a distinct role for countries who did the most to cause the climate crisis to take the lead in investing in developing these technologies to lower costs and de-risk them for wider use. Carbon removal projects, if done well, can also provide jobs and spur economic growth, meaning that countries that are not mainly responsible for climate change may nevertheless have incentives to want to host carbon removal projects.

There are many means by which to increase equitable access to these technologies and approaches to ensure that countries that did the least to cause the climate crisis do not end up hosting projects that do not benefit them.

The UNFCCC, for instance, can play a role through its Climate Technology Center and Network, which is a mechanism for technology transfer and capacity building. The network can facilitate collaborative research and development, and as part of that mandate, identify capacity, governance and market gaps in different regional and local contexts. More broadly, the UNFCCC can help create opportunities for greater international dialogue among countries to improve coordination and knowledge sharing.   

Civil society and research organizations focused on carbon removal can also play a role in ensuring equity in who pays for and who benefits from carbon removal. For instance, researchers can explore the benefits and tradeoffs of unique carbon removal ownership structures that can help facilitate equitable outcomes for local communities, such as through public or community ownership of projects.

 Our preliminary recommendations for promoting equity include:

Improving Measurement, Reporting and Verification

Measurement, reporting and verification (MRV) processes underpin the quantification of carbon removal benefits for projects and inventories, and they provide the transparency that is critical for building trust in the sector. Carbon removal is a relatively new industry that includes a range of diverse approaches at different levels of development, so the MRV landscape today for carbon dioxide removal is fragmented and inconsistent. In the voluntary market, where both emissions reduction and removal credits are sold, bodies like the Integrity Council for the Voluntary Carbon Market and Voluntary Carbon Markets Integrity Initiative are working to provide guidance around what counts as high-quality credits and how companies can use credits to meet their targets, respectively.

Article 6 of the Paris Agreement, which enables exchange of carbon credits (including carbon removal credits) between countries, is designed to help increase cooperation among countries to meet climate goals more efficiently. The accounting rules under Article 6 are currently being discussed and will be a critical precedent for the carbon removal industry as a whole in terms of setting guidelines to ensure high-quality and credible accounting.

Outside of the Article 6 process, the IPCC can play a role as well. The IPCC’s Task Force on National Greenhouse Gas Inventories, for instance, can work on providing guidance for carbon removal activities, as is suitable based on their stage of development, to enable them to count toward national inventories.

Our preliminary recommendations include:

What Comes Next?

Ultimately, these challenges and the recommendations are intended to spur further discussion about the ways in which international bodies, civil society groups, academics and others can work toward developing a robust governance regime around technological carbon dioxide removal.

This is particularly important because the carbon removal industry is still in the early stages of development and growth and is expected to be an area of focus at the upcoming COP28. The concerns raised in this context mean greater focus is urgently needed to set up the right governance frameworks to avoid mitigation deterrence, promote equity, and build robust MRV systems that support responsible deployment of these nascent — and critical — technologies to ensure carbon dioxide removal can be deployed sustainably and responsibly to advance global climate goals.

For more, read the WRI working paper, International Governance of Technological Carbon Removal: Surfacing Questions, Exploring Solutions.