Last week, Bellona submitted a response to the European Commission’s public consultation process on its so-called ‘Restoring Sustainable Carbon Cycles’ roadmap. The stated aim of this initiative is to publish a communication towards the end of the year which should provide more insight into the Commission’s plans when it comes to the use and storage of carbon in its many different forms.

Bellona called on the Commission to provide clarity and distinguish between the different types of activities based on their real-life impact on the atmosphere. Chiefly, to illustrate the direct effect on the atmosphere, the emphasis should be on where the carbon originates and where it ends up. A key point to remember is that carbon removal can only occur when CO2 is extracted from the atmosphere and stored permanently, since the overall purpose of CDR is to actively reduce the amount of CO2 present in the atmosphere. On the other hand, emissions reductions seek to reduce the amount of CO2 that enters the atmosphere.

As such, Bellona suggests a simple initial assessment to qualify the contribution a particular activity may have on climate mitigation, based on the source and fate of carbon.

On the source of the carbon, the binary distinction must determine whether the carbon is of atmospheric origin or fossil/geologic origin. So-called ‘waste carbon’ flows must also be characterised by their origin, be that atmospheric or geological.

On the fate of carbon, a binary distinction must be made between an emission of carbon to the atmosphere or permanent storage.

When CO2 is used in a product (CCU), the outcome may be characterised as a permanent carbon store only in cases where the CO2 is demonstrably stored in a manner intend to be permanent. In all other cases CO2 use (CCU) will ultimately result in the CO2 being emitted and thus its fate must be assessed as an emission of carbon to the atmosphere.

The avoidance of an emission (i.e. a ‘non-emission’) can never count as ‘negative emissions’ since ‘negative emissions’ is always an active effort to remove and store carbon from the atmosphere (as illustrated above).

Bellona’s full response can be found here