CMW’s response to the Article 6.4 Supervisory Body consultation on removal activities and broader methodological rules

Carbon Market Watch (CMW) argues for increased stringency in the Article 6.4 mechanism, specifically regarding the permanence of carbon removals and the accountability of project participants. CMW proposes a minimum 100-year monitoring period for removals, the removal of options to cease monitoring based on vague evidence, and the implementation of a reversal risk assessment tool grounded in peer-reviewed science. The response also suggests a fee-based system to fund long-term monitoring and the ability to permanently ban participants who violate human rights or repeatedly cause avoidable reversals.

• CMW proposes that monitoring for removal activities must be conducted for a minimum of 100 years after the last active crediting period to ensure the risk of reversals is negligible, noting that this timeframe is already required by the California Air Resources Board and the Climate Action Reserve.
• The document argues against allowing activity participants to request the conclusion of post-crediting monitoring (MRV) based on evidence of negligible risk, citing a 2023 UC Berkeley analysis showing that REDD+ projects often significantly underestimate natural disturbance risks.
• CMW recommends that the Supervisory Body's reversal risk assessment tool be updated at least every 5 years, based on peer-reviewed research, and include a minimum default risk rating by activity type that cannot be lowered by activity-level assessments.
• The response proposes a distinction between 'avoidable reversals' (under the participant's control) and 'unavoidable reversals' (such as natural disasters), suggesting that participants must fully replenish the buffer pool for avoidable reversals at their own expense.
• To address equity and long-term liability, CMW suggests implementing a share of proceeds or an issuance fee for MRV, linked to the activity's reversal risk rating, to fund monitoring systems and prevent host Parties (often developing countries) from bearing all costs.
• CMW advocates for the power to permanently ban activity participants and associated entities from the Article 6.4 mechanism if they violate the rights of Indigenous Peoples, cause land or human rights violations, or repeatedly cause avoidable reversals.
• The document suggests strengthening methodological rules by changing 'should' to 'shall' regarding the use of up-to-date scientific information and requiring the transparent disclosure of underlying data and assumptions in project design documents.

APA

Crook, J. (2024). CMW’s response to the Article 6.4 Supervisory Body consultation on removal activities and broader methodological rules. Carbon Market Watch. https://carbonmarketwatch.org/wp-content/uploads/2024/04/04-2024-CMW_Art6.4-SB-consultation-on-removals-and-meths.pdf

Chicago

Crook, Jonathan. CMW’s response to the Article 6.4 Supervisory Body consultation on removal activities and broader methodological rules. Carbon Market Watch, 2024. https://carbonmarketwatch.org/wp-content/uploads/2024/04/04-2024-CMW_Art6.4-SB-consultation-on-removals-and-meths.pdf.

Wikipedia

{{cite press release |last1=Crook |first1=Jonathan |title=CMW’s response to the Article 6.4 Supervisory Body consultation on removal activities and broader methodological rules |publisher=Carbon Market Watch |date=15 April 2024 |url=https://carbonmarketwatch.org/wp-content/uploads/2024/04/04-2024-CMW_Art6.4-SB-consultation-on-removals-and-meths.pdf |access-date=23 October 2026 |via=Climate Insights Directory}}

BibTeX

@misc{crook2024cmws, author = {Crook, Jonathan}, title = {{CMW’s response to the Article 6.4 Supervisory Body consultation on removal activities and broader methodological rules}}, publisher = {Carbon Market Watch}, year = {2024}, month = apr, url = {https://carbonmarketwatch.org/wp-content/uploads/2024/04/04-2024-CMW_Art6.4-SB-consultation-on-removals-and-meths.pdf}, urldate = {2026-10-23}, note = {Indexed by Climate Insights Directory} }