This is a response made on behalf of the Grantham Research Institute on Climate Change and the Environment to the United Nations Framework Convention on Climate Change (UNFCCC) Information note ‘Guidance and questions for further work on removals’ published in June 2023. The information note is available at:   

Summary messages

  • The authors see a lack of confidence in the integrity of carbon trading mechanisms as an overarching threat to the success of all activities, including removals, under Article 6.4.
  • Addressing this threat requires a careful, conservative, and demonstrably rigorous approach to crediting mitigation from removals. In general, crediting practices in both voluntary and compliance markets have not yet achieved scientific or public credibility.
  • Policymakers must now focus on identifying and crediting only those removal activities that have a known and demonstrable mitigation impact.
  • The integrity/confidence issue appears most severe for removals based on interventions in ecosystems (i.e. ‘nature-based solutions’, or NbS). However, these ‘open-loop’ interventions can be scaled up rapidly and should be a key element of short-term mitigation strategies. Recognising high-quality NbS removals should therefore be a priority for crediting mechanisms.
  • Action is needed to ensure that companies with legitimate residual emissions (e.g. those in agriculture, heavy industry) are purchasing removals, as opposed to the tech and financial services companies who dominate removals purchases presently.
  • It is important to properly account for the time value of removals, the need for current-generation statistical techniques to assess additionality, and the need to address leakage from interventions.
  • Temporary removals should be permitted under Article 6.4, if and only if appropriate accounting frameworks can be put in place.
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