CRCF: Our Feedback to the EU proposal

In November 2022, the European Commission published a proposal for a Carbon Removal Certification Framework (CRCF). The initiative is supposed to develop EU rules to monitor, report and verify the authenticity of CDR methods. CDRterra researcher submitted their feedback to the proposal on march 23, 2023. Above all, they stress the importance of distinguishing between emissions reductions and CO₂ removals to avoid limited mitigation targets. The main points at a glance:

CDR is only a complementary measure in addition to emission reduction

CDRterra researcher highlight that carbon removals should not be used as a substitute for reducing emissions at a source, but as a complementary measure to help achieve net-zero and later net-negative CO₂ and other greenhouse gas emissions. Therefore, the proposed framework needs to be embedded in a policy landscape that ensures that the role of carbon removal is clearly defined as a means to compensate for hard-to-abate residual emissions, in addition to deep reductions in emissions.

No negative effects on other ecosystem services

The “Do No Significant Harm” approach is welcomed in the context of carbon removals because it helps to ensure that efforts to combat climate change do not cause unintended harm to other important environmental values such as biodiversity. However, the operationalization from such a broad principle into concrete guidance and safeguards is essential and it is not clear from the current proposal how this will be achieved. Experience in carbon markets shows that the operationalization is challenging and requires transparent processes including built-in opportunities for complaints by stakeholders.

In order to avoid negative side-effects on other ecosystem services and sustainability goals in general, it is important to develop a standard no-harm check-list, based on indicators that can easily be monitored.

Transparency and accountability of carbon removals

It is important to ensure that carbon removals are transparent and accountable, and that the methods used to measure and verify carbon removals are accurate and reliable.

Clear definition and baseline of additionality

To ensure that carbon removals are truly additional and not business as usual, the framework should establish strict criteria for the demonstration of additionality, such as the use of counterfactual analysis.

Permanence of carbon removals

The framework should guarantee that carbon removed from the atmosphere is stored permanently, rather than temporarily sequestered and released without accountability. Therefore, the framework should establish rigorous procedures for monitoring and verifying carbon removals over time and for ensuring that carbon removals are not lost due to leakage or other factors (especially in the biosphere) and that adequate action is automatically triggered in case of re-releases. The framework should clearly set procedures and resolve liability issues if permanence is not fulfilled.

See the full feedback of CDRterra to the CRCF on the website of the European Commission