A recently published ‘Information Note’ — prepared by the Secretariat of the United Nations Framework Convention on Climate Change (UNFCCC) — is meant to inform the deliberations of the ‘Supervisory Body for the mechanism established by Article 6, paragraph 4, of the Paris Agreement,’ which is meeting this week.

That’s a mouthful, but it’s a big deal.

Article 6 was a key outcome of the Paris Agreement at COP26 where countries established the rules for a new carbon crediting mechanism — but figuring out exactly how to implement those rules is still a work in progress.

The Supervisory Body is tasked with making recommendations to decision-makers at the COP28 conference which kicks off in November of this year in Dubai. Among other things, they may take a position on which types of carbon removal projects should be eligible to generate carbon credits on the voluntary carbon market.

As is customary, the general public — organizations and individuals — was invited to provide feedback on the Note’s content. We had a lot to say about it, so we took them up on their offer and submitted a response.

Article 6.4 Removals Public Comment

We invite you to read it in full if that’s your kind of thing, but here we’ve laid out some of the most important points we felt were worth making:

We should not be pitting land-based solutions against engineering-based solutions — we need both

One of the most concerning aspects of this Note is how it generally approaches its analysis of land-based (aka, nature-based) and engineering-based (aka, technology-based) carbon removal activities.

It seems to treat the two types of projects as mutually exclusive, as though they’re in competition with one another. It even lists the ‘pros’ and ‘cons’ of each, as though we need to choose one over the other. We don’t.

First, the distinction between them is not so clear-cut. Many removal activities involve both natural processes and the use of technological innovations, increasingly blurring the line between these two types of projects. For instance, biochar is considered in many circles to be an engineering-based activity, but is listed in the Note as land-based. Meanwhile, ‘enhanced rock weathering’ (ERW)  and ‘bioenergy with carbon capture and storage’ (BECCS) projects are listed in the Note as engineering-based activities, even though the IPCC has previously described both as land-based.

Above all, there’s no reason we should restrict ourselves exclusively to one type of project or the other. We’ve often said that there is no single solution to climate change — rather, it will take a patchwork of diverse solutions to limit global warming in time. We strongly believe that both land-based and engineered solutions should, and will, be part of that patchwork.

Engineering-based projects do contribute to sustainable development

One of the ‘cons’ listed in the Note for engineering-based removals is that they “do not contribute to sustainable development.”

In our experience, this statement simply doesn’t hold up to reality. In fact, engineering-based solutions contribute in many ways to the UN’s own Sustainable Development Goals (SDGs). Here are a few examples:

• Many engineered removal projects create important employment opportunities, and therefore address SDG #1 (No Poverty) and SDG #8 (Decent Work and Economic Growth).
• The increased yields from land provided by certain engineered removal activities, such as ERW projects, contribute to SDG #2 (Zero Hunger).
• Tech-based projects that convert CO2 into materials — in particular building materials — directly address SDG #11 (Sustainable Cities and Communities) and SDG #12 (Responsible Consumption and Production).
• Above all, and perhaps most obviously, all carbon removal activities — be they land-based or engineered — contribute to SDG #13 (Climate Action).

Engineered removals are viable in developing countries

We also explicitly challenged the Note’s conclusion that engineering-based removal activities are “not suitable for implementation in the developing countries.”

As noted above, engineering-based removals contribute to many sustainable development goals. They’re also meaningful tools for attracting investment dollars, regardless of a country’s development classification. Indeed, many ecological factors — geology, climate, supply of natural resources, among others — are far more salient to the viability of engineering-based removal investments in any country.

Kenya, for instance, is an ideal location for ‘direct air capture with carbon storage’ (DACCS) projects, because the geology of the Rift Valley provides plentiful renewable geothermal energy and the right rock type to mineralize CO2 injected underground.

Another example: India has the world’s largest deposit of basalt outside of Siberia, which is the most common mineral used for enhanced rock weathering, a promising innovation that speeds up natural weathering in order to store more CO₂ in a shorter time.

Land based projects can have downsides

One of the Note’s unstated assumptions seems to be that all land based carbon removal projects are designed and implemented optimally, and can have no downsides.

We know this isn’t true.

For instance, there are many non-native eucalyptus monoculture projects with impressive carbon removal benefits — but they actively harm the broader ecosystem by spreading an invasive species, and deplete the ecosystem of nutrients and water. That’s why we at Catona Climate focus so much on broader ecosystem impacts and resource constraints when considering projects for our nature-based portfolio.

We must be clear-eyed and fair about the potential, and the risks, of both land-based and engineering-based solutions. Both are part of the path forward, and we must resist the urge to pit these solutions against each other.

Rather, we must understand and move forward with both land-based and engineered solutions playing a role in achieving a net-zero future. That means well-designed and executed land-based removals projects removing and storing carbon at scale in the immediate to near future, complemented with rational and thoughtful investment in early stage engineered-removals such that those approaches can mature and be deployed at scale in the future.

The bottom line

While we take issue with some of the Note’s content and the potential direction in which it may lead decision-makers, we do greatly appreciate the opportunity to officially provide our comments on it.

We trust that the Article 6.4 Supervisory Body will seriously consider our concerns and suggestions — and those of the many other interveners who’ve submitted responses. This is among the most important collective discussions we could be having — we need to keep talking these things through.

Most of all, as it considers what recommendations to bring to COP 28, we sincerely hope the Supervisory Body will adopt a “yes, and” mentality — as opposed to “either/or” — when evaluating the whole of potential carbon removal solutions.