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The following comment was submitted to the Subsidiary Body on Scientific and Technological Advice (SBSTA) on March 15, 2023. 

The Institute for Agriculture and Trade Policy (IATP),1 a non-governmental organization accredited by the UNFCCC, appreciates the opportunity to submit this comment concerning three requests made by the Parties to the Paris Agreement (CMA) at the 27th Conference of the Parties (COP27) to the SBSTA in draft Decision CMA.4 “Guidance on the mechanism established by Article 6, paragraph 4 of the Paris Agreement.”2

Below we comment on three key requests of the CMA to the SBSTA:

  • Paragraph 8: “recommendations, for consideration and adoption by the Conference of the Parties serving as the meeting of the Parties to the Paris Agreement at its sixth session (November 2024), on further responsibilities of the Supervisory Body and of Parties that host Article 6, paragraph 4, activities in order for such host Parties to elaborate on and apply national arrangements for the mechanism under the approval and supervision of the Supervisory Body;”
  • Paragraph 9: “recommendations for consideration and adoption by the Conference of the Parties serving as the meeting of the Parties to the Paris Agreement at its fifth session (November–December 2023) on: (a) Consideration of whether Article 6, paragraph 4, activities could include emission avoidance and conservation enhancement activities;”  
  • Paragraphs 19-20: the Supervisory Body should develop recommendations on “Activities involving removals, including appropriate monitoring, reporting, accounting for removals and crediting periods, addressing reversals, avoidance of leakage, and avoidance of other negative environmental and social impacts in addition to in addition to the activities referred to in chapter V of the rules, modalities and procedures.” [pp. 9-14 of CMA.3] The SB has been well advised by other Observers on many of the issues to consider for these recommendations. We will refer in passing to this advice but focus on “accounting for removals and crediting periods,” the juncture at which the scientific and technological issues of removals are converted into the accounting logic of the financial markets on which Internationally Transferred Mitigation Outcomes (ITMOs) will be sold to non-Parties under the 6.4 mechanism.


In March, the International Energy Agency, as a contribution to the first UNFCCC Global Stocktake, reported, “Global energy-related CO2 emissions grew by 0.9% or 321 Mt in 2022, reaching a new high of over 36.8 Gt. . . . Emissions from oil grew even more than emissions from coal, rising by 2.5% or 268 Mt to 11.2 Gt. Around half of the increase came from aviation, as air travel continued to rebound from pandemic lows, nearing 80% of 2019 levels.”The increase in aviation emissions is relevant to this submission because of the prevalence of emissions avoidance projects from which are derived CORSIA credits used to make carbon neutral claims by airline companies.4 The absolute increase in CO₂ emissions in 2022 exacerbates the climate crisis that U.N. Secretary General Antonio Guterres characterized as a “code red for humanity,” when commenting on the findings of the Intergovernmental Panel on Climate Change (IPCC) report on the 6th Assessment physical science report in 2021.5

Furthermore, Parties and non-Parties are planning to increase fossils fuel exploration and production.6 The fossil fuel industry is a main beneficiary of billions of dollars of U.S. tax credits to build Carbon Capture and Storage (CCS),7 one of the main engineering-based removal technologies discussed in the Secretariat Information Note (henceforth “Information Note”) that is to inform SB deliberations.8 Since the advent of CCS 50 years ago, successive iterations of the technology have never managed to perform at a scale and for a cost promised by its promoters.9 Now the U.S. government and other Parties are subsidizing CCS development and facilities. A co-founder of the first private company dedicated to CCS research wrote recently, CCS “allow[s] for the continued production of oil and natural gas at a time when the world should be ending its dependence on fossil fuels. . . every dollar invested in renewable energy — instead of C.C.S. power — will eliminate far more carbon emissions.”10

It is widely acknowledged that the safest and most certain path to achieving the Paris Agreement Article 2.1a) goal of not exceeding a 1.5⁰C global average temperature increase over an Industrial Revolution baseline is to reduce CO₂ and other greenhouse gas emissions rapidly and sharply. The Center for International Environmental Law (CIEL) emphasized in its 2022 submission to the SB: “The IPCC has found that it is still possible to limit warming to 1.5 with limited or no overshoot, through steep and immediate reductions in the production and use of fossil fuels, rapid replacement of fossil fuels with renewables and energy demand reduction.”11 For economic and geopolitical reasons, Parties and non-Parties have rejected these difficult but feasible decisions and investment making pathways to 1.5˚C.12 Instead, they have sought to enable pathways that are dependent on technology-based and nature-based removals.

IATP advises the SBSTA and SB to follow CIEL’s advice from 2022: “The Supervisory Body must not do things quickly to just get them done. The urgency of the climate crisis does not justify expediency or eliminate the need for precaution in matters related to human rights and the environment.”13 Those matters include ensuring that the SB recommends to the CMA only those removals with a proven track record of reducing emissions on a pathway to realizing the 1.5˚C goal; that methodologies for monitoring, reporting, verifying and crediting removals contribute to reducing — not merely claiming to offset — emissions; and that removal definitions and methodologies include such safeguards as Free and Prior Informed Consent for use of natural resources in removal projects and a robust grievance mechanism in which evidence of removal project related land and human rights violations, as well as egregious misrepresentations of emissions reductions from removals, can be presented and adjudicated.

The argument for fast-tracking a SB recommendation that legitimizes “all of the above,” so-called “technology neutral” removals is very weak. In essence, the fast-track argument is that “climate science and climate economics denial have delayed climate action to the point where we must implement the solutions proffered by erstwhile deniers.” Proponents of a “technology neutral” recommendation ascribe to the technologies a higher degree of certainty about their technological success than the evidence warrants. The SB must not ignore the many knowledge gaps and uncertainties about engineering-based removal technologies characterized by the IPCC in its 1.5⁰C report. For example:

Evaluating the potential from BECCS [Bioenergy and Carbon on Capture and Storage] is problematic due to large uncertainties in future land projections due to differences in modelling approaches in current land-use models, and these differences are at least as great as the differences attributed to climate scenario variations. (Section 2.3) There is substantial uncertainty about the adverse effects of largescale CDR [Carbon Dioxide Removal] deployment on the environment and societal sustainable development goals. It is not fully understood how land-use and land-management choices for large-scale BECCS will affect various ecosystem services and sustainable development, and how they further translate into indirect impacts on climate, including GHG emissions other than CO2. (Section 2.3, Section 2.5.3)14 

Because of these uncertainties and knowledge gaps, the Information Note states, “Land-based activities currently provide most of the removals and are expected to be the main driver of removal in the near-term (i.e., to 2030) and possibly even until 2050.” (p. 43)

The Governments and the private sector in wealthy countries have and will invest in engineering-based removal technologies to be sited mostly in those countries regardless of whether a SB recommendation on removals sends a policy signal that all engineering-based removal technologies are equally feasible for achieving the Article 2.1a) goals. According to a recent article, “Global public investment in CDR research was around $4.1 billion between 2010 and 2022 and investment in new CDR technologies was $200 million between 2020 and 2022.”15 A SB recommendation to validate “technology neutral” removals will not serve to increase these investments. However, a prudent SB recommendation in support of proven technologies and practices to reduce emissions on the 1.5˚C pathway might deter wasteful spending on speculative removal technologies with very long and expensive research and development timelines at a moment where these resources must be channeled into emissions reductions.

Similarly, the Integrity Council for Voluntary Carbon Markets (ICVMC) project for the trading of “high integrity” Verified Carbon Units (VCUs) will launch whether or not the SB fast tracks a so-called “technology neutral” recommendation on removals from which credits would be derived for trading from Parties to non-Parties and in Voluntary Carbon Markets (VCMs). Neither the SBSTA nor the SB should be pressured to send a policy signal to VCMs validating removal technologies operating with such a high degree of uncertainty and non-performance at scale. VCMs are already characterized by a plethora of low to no environmental and social integrity land-based removal credits. IATP referenced 10 reports on environmental integrity problems and seven on social integrity controversies in emissions offset and avoidance projects in our February 28 letter to the SB.16 There are many more reports of low to no integrity credits than we could cite. Even if the ICVCM project succeeds in labeling emissions offset projects as “high integrity” credits, the current prevailing carbon trading strategy of buying and holding low-cost credits without retiring those credits17 could impede realization of the 1.5˚C goal and the goals of the 6.4 mechanism to finance developing country mitigation and adaptation.

In the next three sections of this letter, IATP proposes elements of a prudent recommendation that are grounded in what the SBBTA and SB know with a high degree of confidence, rather than advise CMA on a speculative basis for implementing the Article 6.4 mechanism.  

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