Response to Verra’s public consultation on labelling of VCUs

1 August 2022

Negative Emissions Platform has responded to the consultation by Verra concerning a “labeling” of Verified Carbon Units (VCUs/carbon credits). In its proposal, Verra is following much of the work and recommendations of the Taskforce Scaling Voluntary Carbon Markets (TSVCM) as regards the pending Core Carbon Principles that are likely issued very soon by the newly established Integrity Council. We encourage Verra to clearly differentiate carbon removals and reduction credits by establishing a new credit unit for carbon removal projects. We also encourage Verra to focus on capture method and storage timeframes to categorize removals. Thereby, we hope to strengthen the evaluation of high durability projects like PyCCS, BECCS and DACCS and want to evade an arbitrary classification of projects into nature-based and tech solutions.

Response to the consultation on Carbon Removal Certification Mechanism

3 May 2022

Negative Emissions Platform supports the Commission’s initiative to design a Carbon Removal Certification Mechanism (CRC-M). We encourages the Commission to provide a framework that is robust, credible, implementable and establishes comprehensive and robust rules for each type of carbon removal, on top of a common EU minimum standard. A timely development of methodologies to enable policy support is critical. We call on the Commission to implement methodologies as soon as possible, i.e. when robust assessments are achieved. Difficulties in the assessment of certain CDR methods should not undermine progress towards implementation of approaches which are ready to be incentivized to scale in the short-term.

Statement on the Communication Restoring Sustainable Carbon Cycles

7 January 2022

We welcome the publication by the Commission of a Communication on Sustainable Carbon Cycles setting out the vision to reduce the reliance on fossil carbon across the economy. We agree with the Commission that the “development and deployment at scale of carbon removal solutions is indispensable to climate neutrality and requires significant targeted support in the next decade”. We call on the Commission to ensure that technological solutions, alongside ecosystem-based methods, receive adequate levels of regulatory and financial incentives to realise their full potential.

Response to the Roadmap on Restoring Sustainable Carbon Cycles

6 October 2021

The Roadmap focuses in the first place on nature-based removals from land-use sector and indicates the timeframe of 2035 to achieve carbon neutrality in this sector. We believe that due to inherent reversibility and difficulty of monitoring of carbon farming practices this is a high-risk approach and there should be a greater focus in the upcoming Communication on technological removals as an at least equally important way of neutralising residual emissions. Only technological removals can remove and store carbon in climate-relevant timeframes (>100years).  An enabling framework for technological removals should be put in place by 2025 at the latest to enable deployment at scale of DACS, BioCCS, Waste-to energy CCS projects, large scale production and application of biochar and an increase in enhanced weathering demonstration pilots, as well as generation of increasing volumes of air-captured CO2 to gradually replace fossil carbon in a range of products and materials. Download our full response to learn more.

Carbon Removal Certification Mechanism - our response

15 September 2021

Negative Emissions Platform has responded to the survey launched by the EC-funded consortium tasked with assessing options for certification of removals. We encourage classification of removal methods based on nature and durability of storage and call for exclusion of fossil based carbon capture and short/medium-term CCU from the mechanism. We believe that the number of removal certificates issued should be adjusted according to the likely permanence of the solution and that the certificates should be equipped with additional descriptions to demonstrate certain co-benefits (i.e catalysing innovation) and adherence to sustainability criteria in line with relevant EU regulations (LULUCF, REDII). Download our full response to learn more.

Reaction to the draft of the EU ETS Directive

8 July 2021

Following the publication of draft EU ETS directive we reached out to the European Commission to address the plan to include the GHG emissions pertaining to the EU ETS under the regulatory framework for the certification of carbon removals. We clarify that the scientifically accepted definition of carbon removal includes only atmospheric and biogenic sources of CO2/carbon. Conflation of carbon removals and emission reductions/avoidance will hinder creation of a level-playing field for large-scale deployment of negative emission technologies versus fossil-based CCU methods with permanent storage.

Response to the Trans-European Networks for Energy (TEN-E) proposal

8 March 2021  

The Trans-European Networks for Energy (TEN-E) proposal in its current form is not fit to support the achievement of the climate neutrality objective. We shared our feedback on the revised version of the TEN-E Regulation with reference to the exclusion of CO2 storage and CO2 transport modalities other than pipelines from its scope. Despite ongoing efforts by a number of stakeholder groups the proposal from the European Commission does not include these two key elements. As the representatives of an emerging carbon dioxide removal industry we have joined the calls of NGOs and industry and urged the Commission, the European Parliament and Member States representatives to introduce relevant amendments during the upcoming negotiations of the dossier.

Input into the consultation on the renewable energy directive

9 February 2021

Negative Emissions Platform responded to the relevant sections of the consultation on Renewable Energy Directive review. We welcome a clear distinction between renewable and recycled fuels and an open discussion about atmospheric vs. fossil CO2. We believe that all types of renewable energy need to be supported, not only renewable electricity. Revised RED II needs to contribute to sector coupling and sector integration and renewable fuels of non biological origin (RFNBO) can play an important part in this. Overall, the target for renewable energy should be more than 14 percent. Fuels produced from hydrogen, generated by renewable electricity, and CO2 taken directly from the atmosphere or from processes using sustainable biomass (to achieve a closed CO2 cycle) will play an important part. The aviation and maritime sector will also benefit from this approach, because value chains and technologies are largely overlapping. The EU is already planning sustainable aviation fuel (SAF) shares from 5% in 2030 and a ramp-up to 20% in 2035, 63% in 2050. According to Dena from 2030 onwards, point sources will not provide enough CO2 to cover the demand to produce renewable fuels - a substantial amount of CO2 needs to come from the atmosphere through direct air capture already in 2030. Therefore, certification of fuels must be supported by a full LCA methodology that accurately measures total GHG reductions, ultimately measuring the net flow of CO2 into the atmosphere from the entire system. The use of CO2 point sources should be limited to industrial emissions in the EU ETS, such as cement industries, and should be limited in volumes and in timeframes, so as not to delay application of CCS technologies that exist today to decarbonise these sectors.

Regulation on the inclusion of greenhouse gas emissions and removals from land use, land use change and forestry (LULUCF)

5 February 2021

Negative Emissions Platform responded to the public consultation on LULUCF. It is forecasted that the EU removals will need to almost double from their current levels to up to 500 Mt CO2eq./yr by 2050 to be in line with the goal of a climate-neutral EU. However, the European forests, by far the largest carbon sink in the LULUCF sector, are projected to store increasingly less CO2 in the next decade due to ageing and events such as droughts, forest fires and pest outbreaks which are caused or exacerbated by climate change. In addition, the Communication on increasing the EU’s 2030 climate ambition indicates that non-CO2 emissions from the agricultural sector will constitute the largest share of the residual emissions in 2050, as they are difficult to completely eliminate with existing technology and practices.  This assessment calls for a rapid initiative to introduce a separate policy framework encompassing the nature-based, technological and hybrid removals that will be deployed EU-wide to tackle agricultural and all land use-related emissions. This framework should take into account the synergies between the LULUCF sector and other land-related sectors in particular the carbon farming initiative announced in the Farm to Fork Strategy, as well as the certification of carbon removals announced in the Circular Economy Action Plan.  We call for closing off the LULUCF loophole in the ESR Regulation, and for keeping the promotion of natural and technological sinks separate from emission reduction efforts. We support the option of a new policy strand covering emissions from the land sector (agriculture, forestry and other land use) and call for a separate EU-wide target to be delivered by a combination of land-based and technological removals.

Input into the consultation on the translation of increased EU 2030 targets to upgraded EU ETS

5 February 2021

Negative Emissions Platform responded to the public consultation on how to translate the increased EU 2030 emissions reduction ambition into an upgraded EU ETS. We call for an increased target going beyond of what the potential for cost-efficient reductions would indicate in order to stimulate innovation of current EU ETS sectors. A number of measures should be applied to strengthen the system such as an increase of the linear reduction factor an its one-off reduction, combined with cancellation of allowances held in the Market Stability Reserve and an increase of its feeding rate. In our view the inclusion of new sectors (except maritime) such as building or transport would have negative consequences for the stability of the EU ETS while displacing more effective decarbonisation incentives in the concerned sectors. Finally, we call for an increase of the size and the maximum funding rate of the Innovation Fund - one of key tools to reinforce EU clean energy technology leadership.

Input into the public consultation on the carbon offsetting and reduction scheme for international aviation (CORSIA)

14 January 2021

Negative Emission Platform responded to the public consultation on the update of rules for aviation considering ways to implement CORSIA - Carbon Offsetting and Reduction Scheme for International Aviation- through the EU ETS Directive. In our view, the Commission should analyse the impact of a 'combined' option whereby the EU ETS price would continue to apply to all intra-EU/EFTA flights and would be added for emissions from flights departing from or arriving in the EU/EFTA up to an operatorsʼ 2020 levels for those flights, with CORSIA covering the emissions above the 2020 levels for flights departing from or arriving in the EU/EFTA. We also advocate for a phase-out of free allocation for aviation sector. The revenues generated by eliminating around 32.3 million tonnes of free allowances per year could be used to finance contracts for difference (CfD) supporting the use of sustainable alternative fuels (SAF) or direct support to negative emissions technologies such as DACCS and BECCS.

Letter to the EU Commission’s Vice-President on sustainable finance taxonomy

23 December 2020

In a follow-up to our input to the public consultation on Sustainable Finance taxonomy we would like to bring our main concerns and recommendations directly to the attention of the Commission’s Vice-President for the Green Deal and relevant Commissioners.  In our view, the Commission should urgently address the issue of exclusion of Direct Air Capture technology from the draft Delegated Regulation establishing technical screening criteria of the EU sustainable finance taxonomy. We urge the Commission to reinstate the section covering Direct Air Capture in line with the recommendation of the final report by the EU Technical Expert Group (TEG) on Sustainable Finance from March 2020. We are also calling for recognition of development of  BECCS and biochar as sustainable activities. 

Incentivising the uptake of e-fuels based on renewable hydrogen and air-captured CO2

26 October 2020

In order to address the environmental footprint of aviation in line with the European Green Deal objectives and EU’s climate ambition, the European Commission is developing policy options to promote the production and uptake of sustainable aviation fuels. Negative Emissions Platform has responded to the public consultation and provided additional input focusing on the ways to incentivise the uptake of e-fuels based on renewable hydrogen and air-captured CO2 in the context of the ReFuelEU Aviation policy initiative.

Comments on Verra’s public consultation on the proposal for scaling voluntary carbon markets and avoiding double counting of carbon credits post-2020  

17 October 2020

We have provide comments to the public consultation by Verra on the Proposal for Scaling Voluntary Carbon Markets and Avoiding Double Counting Post-2020 concerning the application of ‘corresponding adjustment’ (CA) by the offset project host country in line with (pending) Article 6 of the Paris Agreement. In the absence of separate targets for carbon removals in national jurisdictions, voluntary carbon markets will remain a key driver for climate action in this area. Therefore, we propose a transitional period when both the corporate actor could claim the credit towards their voluntary commitement, and the host country could count it towards their NDC target. At a target date, after administrative capabilities and certification methods have been built up, the countries should be required to provide CAs and phase-out double-claiming of credits, so as not to hinder the long-term climate mitigation ambition of voluntary markets.

Input into the EU Commission’s consultation on the renewable energy directive, REDII

21 September 2020

We have responded to the Commission’s consultation on the review of Renewable Energy Directive (REDII). We welcome the initiative to streamline the provisions of REDII with recent initiatives to increase the 2030 target, promote hydrogen and sector integration. We call for an increase of a sub-target in transport sector and introduction of a quota for e-fuels together with an obligation on producers to source an increasing share of CO2 from the atmosphere to reduce carbon intensity. We call for a development of a robust terminology for all renewable and low-carbon fuels differentiating between various origins of CO2, and introduction of clear labels/ certification schemes to help consumers make informed choices.

Response to the European Parliament’s environment committee report on the EU climate law

10 September 2020

Ahead of the vote on the report on Climate Law in the Environment Committee we have shared our input with the Committee members.

We welcome the Rapporteur’s amendments on the EU carbon budget, sectoral roadmaps and negative emissions objective post-2050. We also fully support the inclusion of a concept of a separate target for removals by some Members of the Committee, which we believe requires further scoping in the final text. We bring the MEPs attention to our considerations concerning the Commission's scenarios, targets setting and structure, and the choice of legislative procedure. 

Response to the public consultation on the EU 2030 target plan 

24 June 2020

Negative Emissions Platform has submitted an additional response to the public consultation concerning the 2030 Target Plan by the European Commission. We support the highest proposed target of 55%, while fully welcoming the European Parliament’s proposal to increase the ambition to up to 65%. We highlight the need to disaggregate the 2030 target into separate target for emissions reduction and carbon removals, both nature based and technological. This would enable a clear assessment of the practicality of each element including technological, financial and regulatory gaps to be addressed. We welcome the idea to establish and EU-wide methodology to certify removals, and call for consideration of a carbon take-back obligation scheme as a framework to scale up the market for removal credits.