We very much welcome the recognition of the purpose of Greenhouse Gas Removals (GGRs) to balance residual emissions from hard to abate sectors whilst not substituting for ambitious mitigation. We are encouraged by the recognition in this strategy that both nature and technology have a role to play. Managing our natural resources, such as blue carbon habitats (saltmarsh and seagrass) can provide numerous co-benefits for biodiversity and climate adaptation as well as carbon sequestration. However, we would like to see greater exploration in the science to determine the role some of these natural resources such as soils and blue carbon could play for our coastal society and are encouraged that further work to close these evidence gaps are on the UK Government’s agenda. 

The recognition of the critical need for a robust approach to monitoring, reporting and verification (MRV) of GGRs to both channel finance and demonstrate positive climate action is also welcomed. In this decisive decade, choices will be made that channel our trajectory for years to come and as such, it is critical that counterproductive decisions are avoided. To do this, holistic systematic approaches to the problem will be required and it is therefore encouraging to see the UK Government recognise that there are key constraints to scaling technologies such as CCS, such as the transport and storage infrastructure. It is also key for some of the GGR technologies included within this report to understand the carbon intensity of the supply chain and the possible wider detrimental impacts that could result, such as localised air quality issues from the deployment of BECCS. Therefore, we encourage the government’s commitment to develop regulation and abatement on emissions other than CO2 but would also suggest any such changes or developments address wider environmental and social impacts and don’t solely focus on emissions. 

Not having an established market or current customer demand for GGR technologies is a fundamental barrier to GGR deployment. So, it is interesting to see the proposal to utilise the existing UK Emission Trading Scheme as a possible market solution for stimulating investment by GGRS. Again, for credibility and transparency, the MRV approach and its governance will need to be faultless in its execution. Pace will be needed in determining any eligibility criteria to ensure that those projects in the pipeline don’t miss the opportunity for participation. This approach moves us to a single integrated compliance market for carbon, with negative emissions supporting liquidity as the ETS allowance cap falls over time, ideally regulations and governance will follow suit and be consolidated to improve emission management efficiency and direct focus and energy of those responsible to where it most needed – driving emissions down. 

At Xodus, we believe there are lessons to be learned from the approach to the MRV system in place and encourage the UK Government to address any existing opportunities for improvement at the same time.