• Paul Zakkour

COP27: Paving the way for the “removals COP”

Eve Tamme and I got together again to reflect on our time at COP27 in Sharm El-Sheikh, and to have a think about where the world of carbon removals may go over the year ahead.


Here's what we had to say on the matter...

Photos by Matthew TenBruggencate

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Let’s explore how carbon removal featured at COP27, the relevant developments in climate change negotiations, and what to watch out for through 2023 and up to COP28.


The Egyptian Presidency called COP27 the “African COP” and the “implementation COP”. The meeting in Sharm El-Sheikh could, however, also have adopted the strapline of the “removals COP”, given the levels of activity on the subject across the two-week conference.


The dedicated carbon removal community presence was probably the highest ever seen at a COP; more than 70 side events relating to carbon removal were listed on a virtual platform established by the UN Climate Change High-Level Champions Team, Carbon Gap, Open Air Collective, Rethinking Removals, Carbon Business Council and DAC Coalition.


Events on the side were complemented by new initiatives, for example, the CDR Launchpad, which includes a commitment to build at least one 1000+ tonne a year CDR project by 2025 by each member country — currently listing Canada, the European Commission, Japan, Norway, the United Kingdom, and the United States.


COP outcome

COP27 will go into history as the “Loss & Damage COP”, finalising a decades-long conversation and establishing a dedicated fund to assist especially vulnerable developing countries in responding to loss and damage from climate change. While not entirely obvious on first reading, the threat of loss and damage assistance can provide a valuable spur for large emitters to deepen their mitigation ambition.


COP27 offered some surprises for carbon removal. For example, a draft version of a Cover Decision called for “developed countries to attain net-negative carbon emissions by 2030”. Such calls for developed countries to achieve net zero earlier to provide more time to developing countries have become louder in recent years. The final text, as expected, did not include such a 2030 target but left anyone working “to keep 1.5C alive” disappointed — it took all efforts to keep what had been agreed a year before in Glasgow.


Although an inherent part of climate change mitigation, carbon removal is, in practice, still something of a separate topic operating within a bubble. Further work is needed before the subject becomes entirely mainstreamed into the broader mitigation discussions. Perhaps such separation is a good thing though, considering the particularly unique features of carbon removal. The complicating aspects, such as leakage, monitoring and reversals risk, have led to complex discussions in fora such as the Article 6.4 Supervisory Body.


Demystifying carbon removal should be high on the agenda in 2023, including under:

  1. The technical dialogues ongoing under the Global Stocktake.

  2. The work programme on urgently scaling up mitigation action that will take place alongside the global stocktake. This may provide an opportunity to open up a dialogue on the role of carbon removal in pre-2030 mitigation. Parties and observers have until the 1st of February 2023 to submit views on suggested topics for the dialogue.

  3. The work of the Article 6.4 Supervisory Body (SB), where a request has been made for more input, by 15 March 2023, regarding activities involving removal in the UNFCCC’s project-based crediting mechanism. This also creates another space for a structured conversation dedicated to the unique features of removal.



Removals under Article 6

As an “implementation COP” would have it, the negotiations on Article 6 were increasingly technical. Lengthy discussions spanned accounting, reporting, and authorisation of units (and whether that could be revoked) under Article 6.2. The latter, together with other contentious issues like whether emission avoidance could be credited, were deferred to COP28.


Under Article 6.4, the question of non-authorised emission reductions (ERs) was one of the major causes of disagreement. In the final text, the chapter on the registry distinguishes between “authorised ERs” used towards the achievement of Nationally Determined Contributions (NDCs) or other international mitigation purposes, and “mitigation contribution ERs” used to reduce the emission levels in the Host country.


Among other documents, the Article 6.4 SB had prepared (3 pages of) recommendations on carbon removal for approval at CMA. These arose from SB discussions that went on into the night right before the start of the COP, and drew on hundreds of pages of materials submitted by stakeholders. Thanks to all those who responded to our previous clarion call!


During the negotiations, countries highlighted a range of shortcomings: the language on human rights and indigenous people's rights was lacking; civil society had not been thoroughly consulted during the preparation of the recommendations. And there were strong warnings not to adopt removal recommendations whilst the recommendations on methodologies are not yet ready. Many cross-cutting issues between the two need to move forward in lockstep. Such feedback was not surprising given the immense time pressure Article 6.4 SB had to work under to deliver recommendations on such a complex topic.


Our discussions in the corridors around the middle of week 2 of COP suggested that views were coalescing around the need for a structured process that took in more views and concerns from Parties and Observers, as well as ideas by which to address these concerns. So while various versions of the draft decision text appeared during the CMA negotiations, the final agreement reflects the consensus that was emerging in the room. The decision provides useful and practical guidance that gives Article 6.4 SB the mandate to "elaborate and further develop" their work on removal over the next year, building on stakeholder input due in March 2023.


The main focus for the Article 6.4 SB through 2023 covers the following:

  • Appropriate monitoring and reporting. Open questions remain as to the extent to which this should be different to other types of ER activities eligible for crediting under the mechanism.

  • Accounting for removals and crediting periods. How credited removals, and in particular the timeframes for crediting and addressing reversals, can effectively dovetail with the accounting around NDCs?

  • Addressing reversals. Who will be liable, and over what timeframe, for any intentional or unintentional depletion of enhanced carbon sinks and reservoirs arising from activities under the mechanism?

  • Avoidance of leakage. Whether enhancing carbon sinks and reservoirs in one place could cause the depletion of carbon stocks (i.e. emissions) elsewhere, and how could this be measured and accounted for?

  • Avoidance of other negative environmental and social impacts. Taking into account the need to first enhance and then subsequently maintain terrestrial carbon sinks and reservoirs in ways that may significantly alter the management methods applied to these resources.



A look towards COP28

When it comes to removals, the COP27 outcome was constructive. There is now time and space to develop robust recommendations for the whole suite of carbon removal methods. This is the time Article 6.4 SB lacked in 2022 due to its late start.


Article 6.4 SB will prepare a dual set of recommendations on removals and methodologies that will be up for consideration by Parties at COP28. Their agenda for 2023 foresees five meetings, each lasting four days, starting in March. There will be plenty of opportunities for removals stakeholders to engage, be it via submissions and/or by attending the meetings as observers or just following the live stream.


The COP28 will be the “Global Stocktake COP”. This process, running from 2021 to 2023 and every 5 years thereafter, takes stock of the implementation of the Paris Agreement and has already paid attention to removals. There’s an expectation for another round of updated NDCs, and as the focus of NDCs and the stocktake itself is moving beyond 2030, the focus on removals is bound to increase.


The United Arab Emirates, as the incoming COP28 Presidency, is bound to have a deep interest in carbon capture and storage (CCS) and is likely to offer these technologies a stronger platform. Since geological CO2 storage is also a key ingredient of several removal methods, broad support for both CCS and carbon removal can be expected throughout the year up to the next COP.


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