Carbon dioxide removal: trade-offs, governance gaps and irretrievable risk

3 March 2021

Carbon dioxide removal: trade-offs, governance gaps and irretrievable risk

In the upcoming Trilogue negotiations on the European Climate Law, there is a crucial choice to be made about the balance between emission reductions in the EU Emissions Trading System (EU ETS) and Effort Sharing Regulation sectors, and carbon removals in the Land Use, Land Use Change, and Forestry (LULUCF) sector. Near-term emission reductions with only minimum reliance on carbon dioxide removal (CDR) are hugely important to avoid both intolerable risks of overshooting 1.5°C rise, and of aggravating the social risks of large-scale CDR.

The issue of CDR, also called negative emissions, is critical to the Climate Law and the ongoing LULUCF regulation’s revision. The 2018 Special Report on Global Warming of 1.5°C indicates that achieving the Paris climate target would require the advancement of CDRs. Of the four roadmaps to 1.5, the least risky relies solely on land-use activities, but other pathways include Bioenergy with Carbon Capture and Storage (BECCS). We have serious concerns about the large-scale promotion of CDR, particularly BECCS, though all activities can have negative impacts on a large scale.

Importantly, the Special Report notes that land-based CDRs may result in major, competing demands for land between climate change mitigation and food security (FW 262). There is a high risk that emissions reductions may not be permanent, due to increasing natural disturbances such as forest fires and unforeseeable future land-use decisions.

The recent Carnegie Climate Governance Initiative (C2G) report, “Governing large-scale carbon dioxide removal: are we ready?” highlights that governance issues surround the implementation of CDR. Data gaps and permanence of carbon sequestration remain perennial issues for all CDR activities, including land-use: the risk in attempting to trade land-use credits, as suggested by the European Commission, remains as high as ever.

To protect the integrity of EU climate targets, instead of generating credits for trading, the EU should pursue separate targets for emission reductions and for carbon removals from forests.

The scientific evidence outlined in the C2G report also supports Fern’s position that Member States should step up ambition to achieve the 2050 climate target through actual emissions reductions, with only minimal reliance on carbon removals. Where undertaken, carbon removals should focus on ecosystems-based restoration, which have multiple positive impacts for people and ecosystems. Expensive and uncertain large-scale carbon removal plans risk distracting us from reducing emissions and tackling the biodiversity crisis.

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