On the eve of COP27 opening, while many were fast asleep, the Article 6.4 Supervisory Body adopted dodgy recommendations on guidance for activities related to removals. Just a reminder: Adopting a rushed decision in the middle of the night is decidedly not a good practice and not surprisingly has led to a bad outcome. Throughout the meeting, observers were relegated to a separate room and the intended interaction didn’t happen due to “insufficient time.”
ECO is worried about some elements of the text, and thinks that these should be removed before they sink ambition.
First, the proposed definition of removals is not appropriate. No credits should be issued to “processes to remove GHGs”. The credits should only go to outcomes, because these credits represent “mitigation outcomes”, not “some process that might deliver mitigation outcomes if things go well”. And keep in mind that removals are not reductions.
Second, the list of possible sinks to store the removed GHGs is too wide. Including “oceans” as a possible sink with no further limitations opens the door to dangerous and far-reaching options such as ocean fertilization. While some niche practices that restore damaged ocean ecosystems (seagrass, salt marshes, mangroves) could play a useful role in removing GHGs through anthropogenic actions, the proposed language is too broad and goes much beyond those activities. Oceans are the largest natural sink on the books, but due to rising temperatures and the resulting human-induced changes in ocean chemistry, the ability of oceans to absorb CO2 is rapidly reduced. We don’t need any more large-scale experiments,
In addition, the suggestion that “products” could be considered durable sinks is not credible. Just ask IKEA, which incidentally plans to count carbon stored in its short-lived furniture as a durable removal!
Finally, activities should minimize risk of loss by ensuring ecosystem integrity and supporting human rights. Negative social and environmental impacts must be prevented. Human rights including the rights of Indigenous Peoples have long been undermined by carbon market activities. You’ll recall that at COP 26, the Supervisory Body was mandated to establish requirements and processes related to respecting, promoting and considering their respective obligations on human rights including the rights on Indigenous Peoples and robust social and environmental safeguards, and ensuring they don’t repeat mistakes of the past. But rather than building on those positive outcomes, the Supervisory Body is taking a huge leap backwards. The current caveat that places the enforcement of this under the “free-for-all” provision of “national prerogative” is not acceptable.
Yes, we are in a climate emergency and ECO knows we need to get things done. But adopting recommendations for the sake of “getting the work done” isn’t the right way. Once again, having no rules is better than adopting bad rules.