Bellona welcomes the opportunity to provide input on removal activities under the Article 6.4 mechanism. We look forward to further opportunities for external stakeholders to engage with the work of the SBSTA and the Supervisory Board. Bellona also welcomes the decision at COP27 to postpone the adoption of the recommendations on removal activities. As was raised during the call for input in 2022, the timeline of the process was excessively rapid, especially given the complexity of the topic. We again stress the need to develop robust recommendations, rather than swift recommendations. In the EU context, these discussions are expected to take several years to come to fruition and it is advisable that the Supervisory Board follow a similar timeline.
In answering the questions raised in Information note A6.4-SB004-A02, “Guidance and questions for further work on removals”, we find it particularly urgent to respond to Information note A6.4-SB004-AA-A04 on “Removal activities under the Article 6.4 mechanism”. The note considers the many challenges of operationalising the verification and quantification of carbon dioxide removal as a type of climate mitigation. However, it also contains many fundamental errors and logical inconsistencies that result in incorrect and inappropriate conclusions on several of these matters. Below we highlight a few of the more consequential issues, along with recommendations, though in the interest of brevity many issues were excluded.
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