CDRmare Executive Board submitted comments on EU’s CRCF initiative
On March 23, 2023, the CDRmare Executive Board submitted comments on the “Certification of Carbon Removal Framework” initiative as part of an online consultation by the European Commission.
In November 2022, the European Commission published a proposal for a regulation on the certification of CO₂ removal activities (Carbon Removal Certification Framework, CRCF). The framework aims to develop the necessary measures and rules for monitoring, reporting and verifying the authenticity of carbon removal activities. The goal is to promote sustainable carbon removals and incentivize the use of innovative carbon capture, reuse, and storage solutions in agriculture, forestry, and industry.
As part of this initiative, comments of the joint statement by the CDRmare Executive Board can be viewed here: https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/13172-Certification-of-carbon-removals-EU-rules/F3389913_en.
In this statement, the authors point out that the certification methodology should urgently provide an opportunity to integrate marine Carbon Dioxide Removal and Storage measures. To this end, the methodology for these methods should be developed now in a transparent and inclusive process by the Commission together with its expert group and other relevant experts. This would allow (groups of) operators to identify – at an early stage – which criteria would need to be implemented and achieved for their particular method in order to incorporate it into the certification framework.
Only a holistic certification framework can identify and assess the potential, costs, and risks of carbon dioxide uptake by the ocean. Furthermore, it is important to establish links for marine measures to existing initiatives, directives and regulations of the European Union. For example, the restoration of marine ecosystems or the Marine Strategy Framework Directive (MSFD) to achieve the Good Environmental Status (GES).
The duration of CO2 sequestration is a critical component, as it cannot currently be predicted with certainty for many marine CDR methods, based in part on knowledge gaps, heterogeneity in actual implementation of a method, and unprecedented global changes. Therefore, the proposed regulation should develop rigorous procedures for monitoring and verifying carbon removal over long time periods.
Overall, the CDRmare Executive Board welcome the European Union’s goal of achieving climate neutrality by 2050 at the latest and the European Commission’s proposal to establish a certification framework for carbon removals that is consistent with sustainability goals and existing policy provisions. In particular, the QU.A.L.ITY (quantification, additionality, long-term storage and sustainability) concept of the certification framework is a good starting point.