The second meeting of the EU Expert Group on Carbon Removals took place last week, on June 21-22, bringing together dozens of stakeholders to discuss methodologies to measure the climate impact of activities focused on soil carbon, forestry, and peatlands. The two-day meeting was centred around a series of presentations about existing nature-based carbon accounting method, several of which were from providers of nature-based carbon credits. This structure left little time for meaningful discussion, comparison of methodologies, or in-depth considerations.  

In particular, the following stood out: 

1 – Insufficient information was provided to allow meaningful analysis or comparison of methodologies. Before the expert group, a call for input collected different methodologies currently in use or under development for accounting of soil carbon, forestry, and peatlands, with some initial synthesis in advance of the meeting. However, the level of analysis was not sufficient to evaluate the merits and limitations of the considered methodologies. In particular, the analysis focused on methodologies currently in use, thus excluding potentially more recent innovations, and only assessed whether the methodologies included any general consideration of the Qu.A.L.itY criteria (laid out in the Commission’s proposal for a Carbon Removal Certification Framework) rather than comparing how each of those criteria were addressed. It must also be noted that that these criteria are currently being amended by the European Parliament and European Council, as per the ordinary legislative process. 

2 – The organisation of the meeting raises questions. While the composition of the agenda for this second meeting was a noted improvement on the previous iteration, some questions remain. The agenda of the expert group left little time for discussion, with questions typically relegated to the end of presentation panels that frequently ran over time. Moderators rarely made substantive effort to encourage panellists or participants to answer the questions posed, and many questions raised were not addressed. Furthermore, at the end of each of the three sessions, a rapporteur—a Type-A member designated by the Commission prior to the meeting—provided their personal reflection of the session they were responsible for. This summary was emphasised to be a strictly unofficial viewpoint. However, the appointment and role of the rapporteur remains unclear, including why the rapporteurs are not Commission representatives, or why they were allowed to provide personal views rather than simply summarise the presentations and discussion of the session. It is also unclear what influence and authority their summary will have.   

3 – Participants were told not to raise issues of the use of the methodologies despite continued discussion of these topics by panellists and rapporteurs. Participants were repeatedly instructed to remain focused on the methodological topics of “quantification, additionality, long-term storage, digital tools”, despite the fact that knowing the purpose of the framework (e.g., for project level vs. regional level measurement; annual flux accounting vs. long-term crediting; as a wholly stand-alone policy or situated as a piece of a larger set of standards) is fundamental to assessing which tools and methods are most appropriate. However, this same restriction was not placed on the panellists or rapporteurs, who themselves brought up topics such as offsetting, insetting, or national accounting. 

As it currently stands, the expert group meeting is not a constructive forum for evaluating or designing frameworks for developing carbon removal methodologies. Improvements that could lead to better collaboration—and a more efficient use of members’ time—include: 

1 – Design for dialogue, allowing more time for discussion between participants, and instructing moderators to ensure that questions raised are appropriately answered, not just left hanging. Workshops or breakout discussions in smaller groups could also better facilitate constructive conversations, rather than a commitment to plenary-only sessions. 

2 – Bring in more independent expertise, including from academia and civil society (e.g., NGOs and associations not representing profit motives). While it is important to include the users and providers of carbon removal methodologies, a more balanced perspective should include more actors who do not stand to directly pay or profit from the design of the methodology itself. The present-day use of a methodology in the unregulated voluntary carbon market should not be considered a credible credential, but rather methodologies should be evaluated by independent academic experts based on verified and reproducible research. Furthermore, issues such as acceptable levels of uncertainty, baselines, sustainability criteria, and liability timeframes are not merely technical issues, but concerns of social values—a conversation that must involve broader perspectives than the current composition of the expert group can offer. 

3 – Recognise that the ends define the means — if the CRCF and its supporting methodologies for quantification are to be fit-for-purpose that purpose must be clearly defined. Restricting participants from discussing the use cases of carbon removal certification methodologies hobbles the effective design of those methodologies. For example, the level of aggregation that the results will be used in (e.g., project-level or regional accounting) directly impacts the measurement tools and levels of uncertainty that will be acceptable, and the benefactor of the quantified removal materially determines the appropriate baselines that should be accounted for (e.g., physical, regulatory, and/ or financial). 

During the meeting, the Commission called on the need for quantification methods that are “highly accurate, highly standardised, low cost, and regionally specific”. Yet, even with the limitations of the format and content of the expert group, one trend that came through clearly was the lack of consensus on the appropriate methods, metrics, and baselines for quantifying carbon in above- and below-ground biomass; the acceptable level of uncertainty; or the appropriate use cases for any possible “carbon credits” arising from such quantification. This disagreement does not imply that any of the competing methods are acceptable, but rather that none of them currently are. The lack of a sufficiently robust and useable measurement framework must not be used as an excuse to allow sub-par quantification methodologies for the purpose of results-based incentives. Such a course of action could lead to activities being labelled and financed as ‘carbon removal’ without producing the desired outcome of reducing atmospheric levels of greenhouse gases. In the case of CDR and issuing quantified units to be exchanged, it is better to say “I don’t know” than to potentially be catastrophically wrong.  

It must be emphasised that the current lack of actionable consensus is not an excuse for inaction. We need healthy soils, forests and peatlands, but there are other types of incentives and measurement than project-level “per-tonne” carbon credits. The CRCF is a blunt instrument and rebuilding resilient, carbon-rich ecosystems is a complex problem that requires precise, adaptive, and activity-based approaches.  

Bellona recommends that the CRCF, the Expert Group supporting its development, also allow for activity-based incentives, which currently are not in the scope of the discussions.