5th Carbon Removal Expert Group Meeting: New methodologies introduced, challenges ahead
Achieving the EU’s proposed 2040 climate targets will require significant deployment of carbon removals. One scenario in the European Commission’s impact assessment suggests that up to 330 metric tonnes (Mt) would need to come from the land use, land-use change, and forestry (LULUCF) sector and an additional 114 Mt split between bioenergy with carbon capture and storage (BioCCS) and direct air carbon capture and storage (DACCS)1. To support this, ongoing efforts aim to develop certification methodologies for these activities under the EU Carbon Removals and Carbon Farming Certification (CRCF) Regulation.
As part of this process, the European Commission held the fifth meeting of the Expert Group2 on 21-23 October 2024, presenting draft elements of the EU certification methodologies for input.
CATF’s key takeaways and analysis
For the CRCF methodologies to set a global standard they should at least match—and ideally exceed—the rigor of established voluntary carbon market standards.
While the quality of voluntary standards varies considerably, there are examples of robust requirements, many of which have been highlighted in academic studies and recent proceedings related to the Integrity Council for the Voluntary Carbon Market (IC-VCM) and Article 6 negotiations. Regrettably, there is not yet enough detail provided to evaluate quality and robustness for several of the methodologies provided.
Significant disparities persist in the progress and quality of the draft methodologies, highlighting differing levels of technical readiness.
Many methodologies still have substantial technical gaps to fill with limited agreement on best approaches. For example, experts raised concerns about trade-offs with how the proposals for carbon farming balance additionality requirements with a desire to reward, or at least not to penalise, early adopters of carbon farming activities.
There is also potential confusion arising from differences in proposed carbon farming activity periods (which range from five to 30 years) and monitoring periods (which range from 10 to 40 years inclusive of the activity periods) across the methodologies. Additionally, there was considerable discussion devoted to how minimum sustainability requirements would be operationalised in the many contexts in which the CRCF applies. Addressing inconsistencies in progress and quality across methodologies is essential to ensure that all certified units meet the high standards required for credible and reliable carbon removals under the CRCF.
Further discussion on use cases is needed to ensure the environmental integrity of the system.
The lack of ongoing clarity regarding the intended uses for distinct types of carbon removal and soil emission reduction units arising from the different activities makes it difficult to determine the most appropriate criteria for the methodologies, particularly in carbon farming, where decisions on monitoring periods, liability structures, and baseline setting are essential.
Many open questions and concerns remain on technical aspects of the methodologies.
Elements yet to be proposed should be addressed in additional workshops planned for later this year and into 2025. But the issues are complicated and there has been little scientific consensus around the remaining technical details to date, so a quick and robust resolution of these matters will be difficult to achieve.
- Permanent removals:
- Biochar monitoring and liability. The proposed biochar methodology does not require any monitoring once the biochar is applied to soil; instead, decay rate is accounted for solely based entirely on an empirical model. The CRCF states that methods categorised as ‘permanent’ must uphold requirements as stringent as those for removals using geological storage, and lack of monitoring falls short of the standard. Concerns were raised from field studies which call into doubt the conservativeness of the decay model used. There was also discussions relating to the unknown effects, biochar may have on soil characteristics.
- Determining Scope 2 emissions for DACCS and BioCCS. Concerns were raised that applying the same rules as for hydrogen production to carbon removals may hinder early projects deploying technology within the current energy supply mix. There was a recommendation to allow for operators to use annual temporal correlation in the near-term, and move to a stricter regime of hourly temporal correlation in the 2030’s.
- Accounting for net life cycle emissions for biomass resources. Biogenic emissions (those from biomass combustion or other processing of biomass resources) are considered zero under EU emissions accounting schemes. Determining appropriate accounting of such emissions in the lifecycle of BioCCS is complex. Biomass sourcing requirements to reduce emissions from indirect land use change are proposed to align with the revised renewable Energy Directive (RED III), but concerns were raised that these safeguards are not strong enough.
- Carbon farming:
- Standardised baselines for soil carbon and nitrous oxide quantification. Details on how standardised baselines will be determined for soil carbon storage remain under development, as do certification guidelines for reductions in on-farm nitrous oxide emissions, which were added into the CRCF later in the process.
- Incorporating albedo changes into forest certification methodologies. Current proposals do not account for non-greenhouse gas feedbacks to climate, such as changes to albedo with tree planting. This is despite evidence that in some locations in Europe decreased albedo with tree planting could offset more than half of the climate benefit from carbon removal.
- Risk assessments accounting for reversals. Decisions are still pending on mechanisms to account for model error in soil carbon quantification and risk assessment methods for a pooled risk buffer covering reversals in tree planting activities.
- Additional forestry activities. While forest restoration and forest management activities are to be covered under the CRCF, methodologies for these were not presented at the workshop.
Timeliness vs. quality
Timeliness is crucial, but never at the expense of quality. The technical challenges ahead are substantial, with many unresolved questions, especially in the carbon farming category, about how these methodologies will be operationalised to ensure a robust certification program. The upcoming workshops designed to focus on key elements of carbon farming protocols should help move these efforts along, but there are very complex challenges that remain, and limited time set by the European Commission to make critical advancements.
The path forward
Until mid-November 2024, members of the Expert Group can provide feedback on the draft elements of the certification methodologies. This feedback will be instrumental in further refining these methodologies to meet high standards of accuracy and effectiveness.
The CRCF will enter into force upon its publication in the Official Journal of the EU, which is expected in December 2024. The European Commission is tasked with presenting the first set of delegated acts within one year after the entry into force of the Regulation. The implementing acts on verification and registry rules are also expected in 2025.
The Commission is also mandated to assess by 2026 if and how to integrate permanent carbon removals in the EU Emissions Trading System (ETS), if integrated it is likely CRCF certified removals would be used. Jointly, CATF and CONCITO have collaborated on a report “The Balancing Act: Risks and Benefits of Integrating Permanent Carbon Removals in the EU ETS” that will examine the policy options for integrating permanent carbon removals into the EU ETS and provide recommendations on the design features and safeguards needed to avoid compromising the functioning and environmental integrity of the EU ETS, should removals be integrated. The report will be launched on 2 December 2024.
Find more information on the Expert Group on Carbon Removals.
1 Estimates from the S3 scenario in the impact assessment accompanying the Communication from the European Commission.
2 The Expert Group brings together over 70 members from diverse sectors—spanning national authorities, businesses, NGOs, and research institutions.
