Open consultation on Integrating Greenhouse Gas Removals in the UK Emissions Trading Scheme

Carbon Market Watch strongly opposes integrating greenhouse gas removals (GGRs) into the UK ETS, asserting that emissions and removals are not equivalent and that such a move would cause mitigation deterrence. The organization argues that GGRs are a weaker form of mitigation and that their inclusion could lead to an overreliance on cheap, unsustainable options. If integration were to occur, they insist on maintaining the gross cap, issuing allowances ex-post, and implementing a strict permanence framework. They specifically oppose the inclusion of woodland units due to their lack of permanence and the 'carbon debt' they create. Instead, they recommend 'indirect inclusion' where ETS revenues fund GGR projects, or the creation of a separate Removals Trading Scheme.

• Carbon Market Watch opposes the integration of GGRs into the UK ETS because emissions and removals are not equivalent, and equating them leads to mitigation deterrence and the false assumption that they have the same climate impact.
• The organization recommends 'indirect inclusion' as an alternative to direct integration, where the UK ETS uses its revenues to financially support GGR projects, or the establishment of a separate Removals Trading Scheme.
• If GGRs are integrated, the UK ETS must maintain its gross cap to ensure continued pressure on emissions and prevent a regression of previous reductions.
• GGR allowances should only be issued ex-post, after the removal has been verified, to avoid an oversupply of allowances backed by removals that may not occur.
• The document argues against including woodland units in the UK ETS, stating they are not permanent removals due to vulnerability to climate-driven disturbances and the creation of a 'carbon debt'.
• Carbon Market Watch criticizes the use of buffer pools and equivalence ratios for managing impermanence risk, arguing that they are not robust and often rely on myopic economic discount factors rather than physical risk.
• To be considered permanent, carbon storage should be guaranteed for at least two to three centuries, reflecting the time needed to contain climate breakdown.

APA

Carbon Market Watch (2024). Open consultation on Integrating Greenhouse Gas Removals in the UK Emissions Trading Scheme. https://carbonmarketwatch.org/wp-content/uploads/2024/08/CMW-response-to-public-consultation-on-GGRs-integration-in-the-UK-ETS-1.pdf

Chicago

Carbon Market Watch. Open consultation on Integrating Greenhouse Gas Removals in the UK Emissions Trading Scheme. 2024. https://carbonmarketwatch.org/wp-content/uploads/2024/08/CMW-response-to-public-consultation-on-GGRs-integration-in-the-UK-ETS-1.pdf.

Wikipedia

{{cite press release |author=Carbon Market Watch |title=Open consultation on Integrating Greenhouse Gas Removals in the UK Emissions Trading Scheme |date=8 September 2024 |url=https://carbonmarketwatch.org/wp-content/uploads/2024/08/CMW-response-to-public-consultation-on-GGRs-integration-in-the-UK-ETS-1.pdf |access-date=23 October 2026 |via=Climate Insights Directory}}

BibTeX

@misc{carbonmarketwatch2024open, author = {{Carbon Market Watch}}, title = {{Open consultation on Integrating Greenhouse Gas Removals in the UK Emissions Trading Scheme}}, publisher = {Carbon Market Watch}, year = {2024}, month = sep, url = {https://carbonmarketwatch.org/wp-content/uploads/2024/08/CMW-response-to-public-consultation-on-GGRs-integration-in-the-UK-ETS-1.pdf}, urldate = {2026-10-23}, note = {Indexed by Climate Insights Directory} }