Monitoring, reporting and verifying carbon removal

Over two days, more than 100 attendees from across industry, policy and the scientific community discussed and debated the most pressing problems in MRV.​

All CDR pathways share one fundamental challenge: how to best apply MRV practices to increase high-quality supply, generate greater demand and scale the carbon removal industry.

This paper distills hours of discussions centered around answering that question. Participants shared their views on best practices in MRV and the conditions needed to ensure carbon removal credits are properly verified.

Nine key principles emerged from the discourse between the industry’s leading buyers, suppliers and scientists. This paper sets out those principles of rigorous MRV. Isometric remains committed to supporting the implementation of these principles in order to help achieve our mission—to scale carbon removal responsibly and fast. We encourage readers to do the same.

A lack of agreed definitions for CDR terms and concepts creates confusion across the ecosystem.

For buyers, the lack of standardization creates risk and uncertainty, which suppresses demand. Buyers are forced to navigate complex concepts without knowing how their work will be understood by the public. Procurement cycles and contracts are inefficient as basic terms get redefined for each CDR purchase. Comparing different projects and making purchasing decisions is difficult as pathways and technologies do not have universal definitions.

Beyond hindering demand, a lack of standardization is also a drag on scientific development. Terms like system boundaries, additionality, durability, uncertainty levels and more are debated ad nauseum and regularly (re)defined in new research papers.

Although perfect standardization and taxonomy is unlikely, the CDR industry should create and agree on a clearly defined set of terms. This will significantly accelerate the science of CDR and faster commercialization, reducing the inefficiencies created by disparate terminology.

Governments should create national definitions of quality for CDR.

Defining what constitutes sufficiently high quality in a carbon removal credit (“credit”) will go a long way to pulling the market forward. This is a well-established role for regulators around the world in other important sectors of the economy. 

Today, in the absence of regulation, definitions of quality need to be agreed in every contract and agreement for the sale of CDR. The creation of government-backed standards will help streamline transactions, creating efficiency in the market and allowing buyers to have trust and confidence in their purchases.  

Crucially, legislated quality standards for credits can raise the bar for rigorous MRV across the whole market so that buyers of credits can be confident that what they are buying represents genuine climate impact. 

A range of approaches to regulating CDR are now underway. Some governments are directly writing methodologies for what constitutes high quality CDR. Other jurisdictions are creating national procurement programs for CDR—which will create implicit quality standards. Whichever approach governments do take, consistency between national standards will be critical to achieving scale.

Such standards must cover 7 key topics.

Government-backed standards must be both robust and sufficiently high-level to be future proofed as science and technology evolves. There is an important role for independent registries to play in implementing such standards through more detailed protocols that suppliers then follow in their carbon removal processes (and which can be updated regularly as the state-of-the-art in technology and science evolves).

Today buyers of carbon removal in the voluntary carbon market have to do their own due diligence on how to use a credit, even when they are working with high quality MRV partners. 

The lack of guidelines for use cases, when combined with a lack of minimum quality standards, allow poor MRV to exist and holds back demand. Buyers should not have to take the risk of acting without clarity of how they can use a carbon credit—and many companies do not. This approach will not scale.

Many potential buyers expect they will soon be required to make carbon credit purchases. Potential buyers that expect to face such compliance requirements are seeking to learn about carbon markets and action around credit quality and use cases is crucial to bringing forward this type of latent demand.

Governments or industry should take three key steps to address this ambiguity:

The ultimate goal of MRV in carbon removal is to ensure that every credit is equal to one tonne of carbon dioxide removed from the atmosphere.

MRV protocols must be rigorous enough to prove that this goal has been met.

Those same protocols must also be flexible enough to incorporate key scientific advancements and new evidence that emerges from the deployment of projects. This is especially true in CDR where most suppliers are doing cutting edge science that will continue to advance the field.

Striking the right balance between scientific rigor and flexibility should be informed by three parameters:

There are many early stage CDR suppliers that are preparing for their first deployments but haven’t yet had time or budget to think about MRV in a meaningful way.

Selecting a registry is a critical decision for them with long-lasting implications.

Many suppliers at this stage need more information and support to make a well informed choice. Registries have an important role to play in ensuring that their protocols and processes are transparent and easily accessible so that suppliers can properly consider MRV requirements to which they are signing up.

The science of CDR is being done in a far larger set of organizations than ever before: universities, government, not for profit organizations and the private sector. When collaboration between these different institutions works well, it is incredibly effective at advancing CDR science.

Existing government programs and structures that support this type of institutional collaboration should be continued. To continue to be effective, the results of research and data must be proactively shared amongst all ecosystem participants—as much as possible—so that the field collectively continues to improve. 
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This means:

Effective collaboration in the form of data sharing will enable greater clarity of operational expectations for suppliers, build social license to operate (if data is shared properly with the public) and advance MRV by creating greater clarity on key decisions such as when reliance can be placed more heavily on modeling outcomes versus direct measurements.

All CDR MRV aims to ensure that a credit equals a tonne of carbon removed from the atmosphere. In each pathway this requires finding the right balance between feasibility and scientific rigor. This is especially true in open systems where direct measurement must be balanced with the use of well-established models.

All CDR pathways have specific challenges and unique MRV principles that define high quality in their pathway. Important aspects that registries must consider in a protocol for each pathway include:

Biomass Carbon Removal & Storage (BiCRS)

• Rigorous accounting of waste biomass feedstock to avoid direct or indirect market leakage
• Robust rules for conservatively baselining storage counterfactuals (i.e., the quantification of carbon dioxide storage that would have taken place without the project)

Direct Air Capture (DAC)

• Carbon storage must be aligned with regulations for geological storage
• Handling of all embodied emissions, either through allocation at the start of a project or distribution over a project’s operational lifespan
• Accurate accounting for energy emissions, especially grid-based emissions

Enhanced Weathering (EW)

• Prescriptive, empirical in-field measurements to account for field heterogeneity, time accounting and downstream riverine losses

Ocean Alkalinity Enhancement (OAE)

• Direct measurements of initial outflows related to a project
• Well established risk mitigation framework (for reversal risks) and environmental monitoring parameters

Biogenic Carbon Capture and Sequestration (BCCS)

• Detailed, robust requirements for sustainably sourcing biomass to avoid deforestation or land use changes that would create further emissions

Biochar

• An approach to decay rate that accounts for the chemical makeup of the biochar and environmental factors

• A conservative approach to crediting, with only the durable portion of the organic carbon content in the biochar being eligible for the generation of credits

• Project-specific measurements and assessments of durability, sustainable biomass sourcing criteria and environmental safeguarding information

Electrolytic Seawater Mineralization (ESM)

• Direct measurement of the inputs and outputs of the ESM system

• Direct measurements throughout the ESM system to validate each step of the process

• Reconciliation calculations to establish confidence in these measurements 

Subsurface Biomass

• Characterizing the minimum detection limit of testing to conservatively estimate carbon storage

• Rigorous requirements for ensuring storage sites are protected and undisturbed

• Sustainably sourcing biomass

Scientifically rigorous, transparent MRV is critical to countering a broad public perception that carbon credits are used for greenwashing.

As MRV becomes more rigorous and transparent, public perception should change but the industry must proactively tackle this challenge. One clear way to do that is by the creation of evaluation frameworks for co-benefits.
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Today most co-benefits are not accounted for in crediting a project or evaluating a purchase of carbon removal, but they can be critical to ensuring a project’s social license to operate and ultimately scale. As such, they need to be uniformly considered to ensure communities understand and benefit from the carbon removal happening in their backyards. Suppliers need guidelines from governments or industry for how to engage with communities and a defined role for co-benefits in crediting.
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Guidelines for accounting for community benefits will go a long way to addressing concerns, helping the public understand the advantages of CDR and how it can be deployed safely and effectively for the benefit of all. 

MRV is critical to ensuring CDR has positive climate impact. It also introduces cost and complexity for suppliers and buyers.

If the way MRV is conducted does not improve over time, it will act as a drag on the market and prevent scaling of the CDR industry. That is why registries must develop technological solutions that can speed up the MRV process, and ultimately make credit issuance a process that takes weeks, not years.
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There are three key things that must happen to speed up MRV and enable it to scale with the wider CDR industry. 
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First, registries must improve their technology to make MRV more digital. Today verification is slow and manual. In traditional registry processes, projects only get verified and issue credits once a year—and sometimes even less. Up to five years is not uncommon for nature based solutions (NBS). If MRV cycles remain this slow in CDR, the industry will never reach gigatonne scale. Far too much revenue would be locked away from suppliers for long time spans—preventing reinvestment into, and improvement of, their operations.
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Second, supply chain and sensor data must be standardized so data ingestion, validation and analysis can be automated. This would improve accuracy, accessibility, and ultimately the speed and quality of verification. Additionally, making protocols more prescriptive and digitally accessible will help verification and validation bodies (VVBs) move faster, more easily and with fewer mistakes. 
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Finally, the entire CDR ecosystem needs to focus on capacity building. MRV—and the whole industry—requires more climate scientists, engineers, and VVBs, at all stages of career progression. Registries can include more specificity in protocols to lower the necessary level of expertise for VVBs, but ultimately there must be incentives and training opportunities. As suppliers scale up, the need for VVBs is only going to increase.