Response to the call for input on the annotated agenda and related annexes of the 5th meeting of the Article 6.4 Supervisory Body
The Zero Emissions Platform (ZEP) welcomes the opportunity to provide input to the Supervisory Body
Call for inputs on issues included in the annotated agenda and related annexes of the fifth meeting of the Article 6.4 Supervisory Body, namely document A6.4-SB005-AA-A09 ‘Information note: Removal activities under the Article 6.4 mechanism’ (hereinafter, ‘information note’).
ZEP is pleased to contribute to the work of the Supervisory Body and remains available to expand on
any element of this response.
The role of carbon dioxide removals in climate change mitigation
Tackling climate change will require a plethora of approaches. While removals must never be used as
a substitute for emissions reductions, the development and deployment of carbon removals is an
essential part of that portfolio and is necessary to counterbalance both residual and historical CO2
emissions. As highlighted by the United Nations Intergovernmental Panel on Climate Change (IPCC), carbon removals are a crucial element on the road to net-zero (reducing net emission levels), to enable
net-zero (balancing residual emissions), and to achieve and sustain net-negative emissions.
Reaching net-zero by 2050 and net-negative thereafter requires the deployment of large volumes of
carbon dioxide removals, to be achieved through the various methods available – both land-based
and engineered. As noted by the IPCC, around 30-1,090 Gt of engineered carbon removals are needed
between 2020 and 2100 alongside emission reductions to keep the global average temperature increase within 1.5°C.
Main views and recommendations
In its current writing, the information note does not provide a balanced overview of the pros and cons
of land-based and engineered activities (table 3, pp. 18-19), appearing biased against the latter. Other elements in the information note further contribute to a biased stance on engineered carbon activities, which can accomplish permanent storage, such as the inclusion of tonne-year accounting and the emphasis on a 100-year time horizon.
The deployment of the different types of carbon removal methods needs to take due consideration
their respective characteristics and potential trade-offs – for example, in terms of the storage timescale, reversal risks, financial cost, energy intensity, and land-use. Monitoring, reporting, verification, and governance mechanisms should be developed taking those characteristics into account. A good overview and comparison of the advantages and disadvantages of implementing the different removal methods is provided by the IPCC (pp. 115-116).
As noted above, the science is clear about the contribution of engineered removals. Unlike postulated
by the information note, this is in line with both Sustainable Development Goal (SDG) 13 (Climate
Action) and the objectives of the Paris Agreement Article 6.4 mechanism. In the particular case of
BECCS, the information note acknowledges that the activity can provide energy (e.g., for district
heating or industrial processes) and remove carbon from the atmosphere, thus arguably fulfilling
multiple SDGs when done with the appropriate safeguards.
Considering the important role that engineered carbon removals play in climate mitigation, it is essential that they are not excluded from the very mechanisms that can support their development at scale. This will provide the needed predictability for prospective carbon removal developers and corporate buyers, create early demand, and thus support the need to scale up removals in parallel to emissions reductions.