ECO is getting some “déjà-vu” vibes arriving in Dubai. Not just because the desert atmosphere reminds us of last year’s COP.
ECO spent some time analyzing the draft text on carbon removals that the article 6.4 Supervisory Body has submitted to the CMA for adoption. Just like last year, ECO feels the draft is more likely to remove ambition than carbon dioxide. It is definitely not ready for negotiators to adopt the text.
The proposal is longer and more detailed than last year and several elements have been improved. But it still very much requires taking a leap of faith on putting the future of this crucial ruleset in the hands of a small group of experts operating away from the spotlight of the COP.
The list of problematic elements in the draft submitted is barely shorter than in 2022. The definition of removals keeps the door wide open for risky practices, such as counting products as safe storage for CO2. The reversal risk assessment tool is simply non-existent at this stage, despite the fact that the draft rules rely heavily on its application. So are the buffer pool arrangements.
The postcrediting monitoring period is a welcome addition that goes further than common practice in carbon markets so far, but it remains open-ended with the possibility of it being a very short period depending on what future rules will be adopted. The lack of a clear definition for “avoidable” and “unavoidable” reversals leaves another key element of text in limbo, with little guidance about how effective that distinction will actually be. Similarly, the absence of any explicit reference to human rights and heavy reliance on safeguards that are yet to be defined (e.g. grievance mechanism) leaves important questions about local impacts of “removals” unanswered.
ECO understands that the Supervisory Body cannot adopt rules to cover all possible eventualities on the first (or, in this case, second) try. But having monitored the discussion for over two years now, ECO does not think that negotiators will set the right direction — neither to the Supervisory Body nor to the market – by adopting this text.