CMW inputs on removal activities in Article 6.4, in response to the invitation for observer comments

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Carbon Market Watch (CMW) urges the Article 6.4 Supervisory Body to avoid shortcuts in developing recommendations for removal activities, emphasizing that temporary carbon storage should not be equated with permanent emission reductions. CMW argues that current forestry and land-use credits lack permanence, and that buffer pools are insufficient to manage reversal risks. The organization specifically opposes the inclusion of tonne-year accounting, claiming it creates a false equivalence between temporary storage and permanent removals, and criticizes the proposed definition of removals for including 'products' and 'processes' rather than focusing solely on outcomes.

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  • Emission reductions and removals should be treated as complements rather than substitutes, and temporary carbon storage must not be credited if used for offsetting purposes.
  • Forestry and land-use projects, which account for 41% of the 1.7 billion credits issued by the four largest voluntary carbon market standards, cannot guarantee permanence for 100 years or the required 2-3 centuries due to reversal risks like fire, drought, and disease.
  • Buffer pools are an inadequate solution to impermanence because they may be undercapitalised and rely on monitoring that typically ends with the project's crediting period, leaving later reversals undetected.
  • Tonne-year accounting should be excluded from the 6.4 mechanism because it is inaccurate, contradicts IPCC and Paris Agreement temperature goals, and creates a false equivalence between temporary storage and permanent removals.
  • The proposed definition of removals is flawed because it includes 'products', which risks crediting wood products or synthetic fuels that lack long-term permanence, and 'processes', which could incorrectly allow CCS on fossil fuel point sources to qualify as atmospheric removals.

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APA
Carbon Market Watch (2023). CMW inputs on removal activities in Article 6.4, in response to the invitation for observer comments. https://carbonmarketwatch.org/wp-content/uploads/2023/03/CMW-input-on-removals-to-SBSTA_March-2023.pdf
Chicago
Carbon Market Watch. CMW inputs on removal activities in Article 6.4, in response to the invitation for observer comments. 2023. https://carbonmarketwatch.org/wp-content/uploads/2023/03/CMW-input-on-removals-to-SBSTA_March-2023.pdf.
Wikipedia
{{cite press release |author=Carbon Market Watch |title=CMW inputs on removal activities in Article 6.4, in response to the invitation for observer comments |date=14 March 2023 |url=https://carbonmarketwatch.org/wp-content/uploads/2023/03/CMW-input-on-removals-to-SBSTA_March-2023.pdf |access-date=23 October 2026 |via=Climate Insights Directory}}
BibTeX
@misc{carbonmarketwatch2023cmw, author = {{Carbon Market Watch}}, title = {{CMW inputs on removal activities in Article 6.4, in response to the invitation for observer comments}}, publisher = {Carbon Market Watch}, year = {2023}, month = mar, url = {https://carbonmarketwatch.org/wp-content/uploads/2023/03/CMW-input-on-removals-to-SBSTA_March-2023.pdf}, urldate = {2026-10-23}, note = {Indexed by Climate Insights Directory} }

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