What if carbon removal policy went beyond climate policy?
There is clear scientific consensus that the world needs to remove gigatons of carbon dioxide from the atmosphere to avoid the worst impacts of climate change and meet the goals of the Paris Agreement. There is also growing awareness that policy support is needed to scale the carbon removal (CDR) industry and countries around the world are starting to invest in CDR.
But our current policy playbook is not enough.
First, CDR policy today relies on innovation support mechanisms that worked for solar and batteries, despite the fact that carbon removal is not a physical product with a pre-existing market. The policy tools that worked for other cleantech are a necessary but insufficient driver for carbon removal scale-up. Second, federal investment in early-stage (so-called “unproven”) technology is exactly the kind of spending that is being eliminated by the current US administration. Innovation and R&D budgets will also be cut by other governments in times of geopolitical uncertainty and war. Third, the end game for innovation policy is a compliance market, but compliance markets and carbon pricing mechanisms are unlikely to achieve the scale we need, even in the most optimistic scenarios.
We need more.
Carbon removal needs to be integrated into industries that operate at large scale across the globe, like mining and waste management. Only through these integrations can we get closer to the massive quantities of carbon removal needed in a world that continues to fail to decarbonize.
A simple model for CDR policy
An enabling policy environment for carbon removal must have three things:
First, we need a reason to do the carbon removal activity. Importantly, the reason might not be carbon removal or climate. Carbon removal might be just a co-benefit of another activity crucial to a certain industry, like generating hydrogen as an alternative to conventional fuels.
Second, we need a way to pay for the carbon removal activity. As above, we might fund or partially fund the activity through a non-climate revenue stream, like agriculture subsidies or the sale of co-products.
Third, we need to measure any carbon removal that occurs. Municipal, state, and federal governments can report this carbon removal number in their inventories, use it to track progress against their climate goals, and ultimately roll this value into Nationally Determined Contributions and tracking for the Paris Agreement. (Note: Throughout this piece, I’ll use “measure” and “quantify” interchangeably. In all instances I mean “measure, model, and monitor carbon fluxes that demonstrate removal from the atmosphere.”)
In theory, compliance carbon markets do all of these things together. Compliance markets give us a reason to do the activity (meet a sectoral emissions cap), a way to fund the activity (buying and selling allowances in the market), and a framework for measurement (the process for reporting emissions and generating allowances). It is a complete, self-consistent enabling environment, if done well.
Promising efforts are underway to incorporate CDR into regulated carbon markets. The problem is that, again, compliance markets alone might not generate sufficient demand for carbon removal to reach scale. So we need to get creative.
What if we used different policy mechanisms to achieve each of the three enabling factors?
At first glance, it might not seem like we’re doing “carbon removal policy” at all. And that’s kind of the point. By developing a deep understanding of both the technical details of carbon removal processes and the regulatory regimes governing large-scale industries, we can be opportunistic and tactical in building the next wave of carbon removal policy, as a complement to direct climate and carbon management advocacy efforts.
Case study: Enhanced weathering
Consider enhanced weathering, a form of carbon removal that involves spreading crushed rocks on farmlands using equipment farmers already have. How many policies could enhanced weathering link onto? Certainly policies that directly consider climate impacts: corporate disclosure laws, climate tech R&D funding, and the integration of removals into compliance markets. But we can also consider efforts that target things farmers care about: soil pH management, improved nutrient use efficiency, and improved crop yields. We should turn our attention to policies that aim to maximize those benefits.
For example, soil acidification due to fertilizer use is a challenge in many places, and governments around the world have implemented subsidies to help farmers cover the cost of soil pH management. What if these policies were expanded to include materials that combat soil acidification and efficiently remove carbon?
One of the challenges with this approach is that the motivating (and/or funding) policy alone does not enable good carbon removal quantification. Again, we have to get creative. For example, we could use public water quality infrastructure, like the USGS stream monitoring system, to help us track carbon from farm fields to the ocean.
For this approach to have legs, key scientific uncertainties need to be resolved around our understanding of carbon removal via enhanced weathering and our ability to cost effectively measure and model this process. But we can start designing field trials, collecting baseline data, and educating stakeholders to set us up for a future where we use policy to promote carbon removal and healthy soils at climate-relevant scale.
Set it but don’t forget it
I’ve often heard folks say you don’t need measurement (or what in carbon market lingo is called MRV) at all for policy ideas like this one. The goal of the policy is to generate some other benefit, so why bother with carbon accounting?
I’m going to have to disagree.
Perhaps methods and models will look different across contexts, but it remains essential that we count the carbon correctly, no matter where carbon removal is happening. For each policy, we need fit-for-purpose standards that are administratively feasible, logically consistent with existing regulations, and scientifically sound. We need to be able to count the “down arrows” (carbon out of the atmosphere) accurately so we can reward cities, states, and countries that make progress towards our shared climate goals under the Paris Agreement.
If governments can’t quantify and get recognition for carbon removal, they will be less likely to bother with these kinds of policies—even if they are cheap and generate other benefits—and the public will be less likely to trust CDR as a climate solution.
Early steps for an integrated future
It is necessary and possible for us to create enabling environments for carbon removal across all sectors of our economy. As the field has said from the beginning, there’s no silver bullet approach for carbon removal. If we continue to expand our understanding of what “CDR policy” can mean, we can, through creative policymaking and collaboration, get carbon removal to climate-relevant scale.
