Author: dchone

I work for Shell International Ltd. and I am the Chief Climate Change Adviser for Shell, working in the Shell scenarios team. I joined Shell in 1980 after graduating as a Chemical Engineer from the University of Adelaide in Australia. I have worked in refinery technology, oil trading and shipping areas for Shell. I am a board member of the International Emissions Trading Association (IETA), was Chairman of IETA from 2011-2013 and I am also a board member of C2ES in Washington.

Without Article 6 there may be no 1.5°C (or even 2°C)

May 30, 2023

The 58th session of the UNFCCC’s Subsidiary Body for Scientific and Technological Advice will take place in Bonn from June 5-15 and one of the features of the session is further progress in operationalising Article 6 of the Paris Agreement. My colleague, Malek Al-Chalabi, and I thought it would be useful to reflect yet again on the critical importance of this somewhat overlooked corner of the Paris Agreement.

Article 6 of the Paris Agreement is the section that formally promotes cooperative approaches between the Parties, but is widely recognised and is being negotiated as a carbon trading mechanism. The thinking behind Article 6 is profound, but the reality of a working mechanism is taking too long to appear in practice. Article 6 was the apparently the last piece of the Agreement to be completed in December 2015 and we all know that the completion of the so-called Paris ‘rule book’ was extended by two COPs (from Katowice in 2018 to Glasgow in 2021) because of Article 6. Now the fine detail of the mechanisms is trying to find a landing point.

One area that is really struggling, weighed down by constant challenge, is the incorporation of carbon dioxide removals (CDR) within Article 6.4, the project based mechanism under Article 6. A recent information note released by the UNFCCC seems to lean heavily towards land based removals (reforestation, ecosystem restoration, carbon farming etc.) but is particularly scathing on the prospect of engineered removals (direct air capture with geological storage or DACCS and bioenergy production and use with geological storage or BECCS), with statements such as;

  • Engineering-based removal activities are technologically and economically unproven, especially at scale, and pose unknown environmental and social risks. Currently these activities account for removals equivalent to 0.01 MtCO2 per year (P15:a) compared to 2,000 MtCO2 per year removed by land-based activities.
  • These activities do not contribute to sustainable development, are not suitable for implementation in the developing countries and do not contribute to reducing the global mitigation costs, and therefore do not serve any of the objectives of the Article 6.4 mechanism.

In any thorough analysis of net-zero emissions during this century, such as in the IPCC 6th Assessment Report, both land carbon management and engineered removals are critical for achieving the net-zero goal, so to simply dismiss engineered removals now because they have yet to scale can only be seen as short sighted. In the recently released Shell scenario Sky 2050, the role of both in 2050 is very clear, as shown below. In 2050 the use of fossil fuels is far from over, so balancing remaining emissions against sinks via various removal mechanisms is critical.

While land-based removals are larger in 2050 than engineered removals, the longer term mechanism for correcting overshoot and addressing atmospheric CO2 levels is engineered removals. By 2100 fossil fuel use is largely done with so the balancing of 2050 is not really required, but a robust business model will be needed to support ongoing negative emissions through engineered removals as a means of reducing atmospheric CO2 levels. This will also require a trading mechanism.

Further to the above, there is an almost certain dependency on the structure of Article 6 in the delivery of large scale removals. This is because the countries and sectors that find themselves in the situation of needing removals to balance ongoing emissions or to finance long term negative emissions may not have local access to them, perhaps for reasons of geography. This was highlighted in the Shell Scenario Singapore Sketch released last year. Without Article 6 Singapore cannot reach it’s goal of zero CO2 emissions, but with Article 6 in place net-zero emissions is achieved. Arguably the very essence and purpose of Article 6 is embraced within the word ‘net’ in net-zero. Eventually, removals become the only type of unit traded under Article 6 or created through the 6.4 mechanism.

The same clear message was also delivered in the IPCC AR6 Synthesis Report where CDR is shown to be vital if the world is to achieve 1.5°C, the more ambitious goal of the UN Paris Agreement. And similar to the case for Singapore described above, not all countries will have the same geographic and geological ability to harness or deploy CDR options or reduce emissions at the same rate, and the majority of countries cannot expect to reduce emissions to zero such that CDR is not needed.

In a previous blog post, we illustrated the importance of trade and how countries and sectors can work together in Article 6. This message can also be found in publication from a variety of organizations, including the International Chamber of Commerce, the International Emissions Trading Association (IETA), the International Energy Agency, and others.

There have been numerous examples that show how trade helps countries contribute to economic growth. This includes the trade of automobiles, medicines, clothing, electronics, and a variety of other goods. Not all countries will be automobile hubs, medicine hubs, clothing hubs, or electronic hubs. Trading allows countries to specialize in certain segments of the economy and trade with others that have other expertise in other goods – and it is a win-win for both countries. There have also been an equally abundant examples of how isolation or trade disputes can disrupt economic growth and progress.

Trading of carbon is a win-win – for economic growth and for decarbonization – and Article 6 has the potential to catalyse both elements. As such, in order to maximize the use of Article 6, IETA has identified the following elements for governments to consider (see the full IETA paper here):

  • Announce whether and how the country will authorize Article 6 credits and/or accept towards the achievement of its NDC.
  • Provide a clear strategy and stable guidelines on which sectors, activities and vintages will be eligible for Article 6 credits.
  • Articulate how the use of Article 6 will help achieve the goals of the Paris Agreement.
  • Elaborate what policy framework the host country will adopt and how it will interact with the receiving country.
  • Establish an effective interaction between compliance instruments and the voluntary carbon market (VCM).
  • Support the emergence of a widely accessible traded market for carbon credits.
  • Ensure a suitable digital registry or other infrastructure for GHG accounting and reporting is in place.
  • Address key risks in the activity cycle and identify mechanisms to reduce them.
  • Emphasize the areas where capacity building is required and the role of international organizations

But more recently, IETA and several other observers have called for the Article 6.4 Supervisory Body to take a more balanced approach to the assessment of removals. The IETA submission can be found here.

Carbon markets have the opportunity to contribute to decarbonization and economic growth. A recent example of this was highlighted at COP27, where the governments of Switzerland and Ghana agreed to the first government to government bilateral carbon trade. More signs of this are taking place, with Japan signing over 25 MOUs and other countries showing a keen interest, like the UAE, Sweden, and others. Further information on how carbon markets can assist decarbonization efforts can be found on a recent episode of the Energy Podcast (Season 5).

With the global stock take taking place in Dubai later this year, Bonn provides an opportunity for policy makers and governments to continue to encourage the use of Article 6 and embrace the role of removals, in all forms, within the 6.4 mechanism. Further government to government trade of carbon will be one of the cornerstones to limiting warming to 1.5°C.

Note: Shell Scenarios are not predictions or expectations of what will happen, or what will probably happen. They are not expressions of Shell’s strategy, and they are not Shell’s business plan; they are one of the many inputs used by Shell to stretch thinking whilst making decisions. Read more in the Definitions and Cautionary note. Scenarios are informed by data, constructed using models and contain insights from leading experts in the relevant fields. Ultimately, for all readers, scenarios are intended as an aid to making better decisions. They stretch minds, broaden horizons and explore assumptions.

How quickly can a synthetic aviation fuel industry emerge?

May 15, 2023

In late April, the European Parliament and EU Member States reached agreement on new mandates for sustainable aviation fuels through to 2050. Under the final agreement, the percentage of sustainable aviation fuel (SAF) that must be blended with kerosene will start at 2% by 2025, moving to 6% by 2030, 20% by 2035, 34% by 2040, and reaching 70% by 2050. A dedicated sub-target for synthetic fuels derived from green hydrogen will also come into force from 2030. Although the final wording and requirements for these mandates have yet to be released, the headline numbers are clear even if the detail isn’t – starting at 1.2%, the synthetic fuel requirement will be scaled up to 5% by 2035, reaching 35% by 2050.

SAF is going to require a huge effort and should rightly be the immediate focus of attention, largely because of the state of technology and the amount of effort that has gone into preparing the groundwork for a SAF industry. But while the overall SAF target is challenging, given the small quantities produced today, the synthetic fuel mandate looks daunting. In EU parlance, synthetic fuels are renewable liquid and gaseous transport fuels of non-biological origin, meaning liquid or gaseous fuels which are used in the transport sector other than biofuels or biogas, the energy content of which is derived from renewable sources other than biomass. In the aviation industry this presumably means two types of fuel;

  1. Hydrogen as a direct fuel derived from renewable energy sources.
  2. Synthetic kerosene (also known as an e-fuel), produced by combining hydrogen derived from renewable energy sources (via electrolysis of water) and carbon from the atmosphere (via direct air capture or DAC), with the energy required for the capture and final synthesis also coming from renewable sources such as wind and solar PV.

For 2030, hydrogen as a direct fuel is a non-starter given that the planes don’t yet exist and probably won’t do so until 2040 at the earliest, although we might see some small commuter versions before that. So for 2030 and probably 2035, this mandate is really only about e-fuels. The synthesis of such a fuel is discussed in detail in a paper by Kraan et al., An Energy Transition That Relies Only on Technology Leads to a Bet on Solar Fuels, Joule (2019), with the energy schematic they developed shown below. This is to produce one barrel of fuel (5.5 GJ solar fuel on the right of the schematic).

The illustration above presumes feasibility and the availability of a wide range of thechnologies at large scale. In reality, that isn’t the case today. Clearly solar PV and synthesis technologies exist at scale, but Direct Air Capture (DAC) is still to be demonstrated at scale (i.e. 1 million tonnes per annum or more) and hydrogen electrolysis is only just reaching the sort of scale required for synthetic fuel production. As such, the discussion below should be viewed in that context and not just be a question of quickly building the necessary facilities.

In 2023 we can expect EU aviation fuel consumption to be somewhere around 1 million barrels per day, which includes both internal EU demand and international aviation bunkers for flights departing from the EU, for passenger and freight movements. So a 1.2% synthetic fuel mandate means the production of at least 12,000 barrels per day of e-fuel within seven years, or over 4 million barrels (600 kt) produced in 2030.

Jet fuel is mainly carbon in terms of weight, so 600 kt is about 500 kt carbon and 100 kt of hydrogen. This amount of hydrogen (but in practice more is needed) will require multiple 200 MW electrolyser projects, each similar to the project recently announced by Shell in Rotterdam that will produce 60,000 kg per day of green hydrogen, currently Europe’s largest such project. The Shell project will begin operation in 2025 after two years of construction, along with offshore wind capacity built in the Hollandse Kust Noord area.

The 500 kt carbon equates to nearly 2 million tonnes of atmospheric carbon dioxide capture in 2030, which is a scale of capture that doesn’t currently exist in the world. However, Occidental and its subsidiary 1PointFive announced in late 2022 they plan to begin detailed engineering and early site construction for their first large-scale DAC facility with start-up expected in late 2024. Upon completion, the DAC plant will be the world’s largest of its kind and is expected to capture up to 500,000 metric tons of carbon dioxide per year.

However, the provisions of the EU Directive on these types of fuels allows for other sources of CO2 to be used, but in some cases for a limited time period. Up until 2041 it will be possible to use CO2 from sources such as industry where allowances have already been surrendered against such emissions. It is also permissible to use the captured CO2 from the production or the combustion of biofuels, bioliquids or biomass fuels. These provisions mean that an immediate relaince on DAC as a source of carbon for synthetic fuels isn’t required.

Producing sufficient hydrogen and capturing enough carbon dioxide is energy intensive and is just the start. These then must be combined to make the synthetic fuel, which takes even more energy and more hydrogen than the molecular weight of jet fuel points to. For example, a hydrogen based reaction is required to convert the carbon dioxide to carbon monoxide, which is required for the subsequent synthesis reaction. If the facilities designed to do this make use of Fischer-Tropsch technology, jet fuel won’t be the only product. Its yield might be as much as 67% (with the other 33% being lighter and heavier hydrocarbons, but this will require an optimised catalyst), which means that for the above jet fuel requirement the picture becomes more complex and bigger. The required production of synthetic fuels rises to 18,000 barrels per day, of which 12,000 is jet fuel.

The synthesis plants are not simple projects either, although the underlying technology is tried and tested in facilities such as the Shell gas-to-liquids synthesis plant in Qatar. That unit takes natural gas and breaks it down into hydrogen and carbon monoxide (synthesis gas) before recombining these into longer chain hydrocarbon molecules such as for jet fuel. That facility operates on a very large scale, producing some 150,000 barrels per day of product (of which some is suitable for jet fuel use). Building smaller versions is possible, although even the first Shell synthesis pilot plant, built 30 years ago in Malaysia and still operating today, produces 14,700 barrels of oil product per day. Even smaller scale gas-to-liquids is also possible, with Petrobras operating such a unit in a remote location as a pilot for the conversion of associated gas from oil production into useful liquids.

Given the rapid scale up of the synthetic fuel mandate (4x from 2030 to 2035), the sensible approach will be for the EU to build reasonably large from the start. A first facility might be the size of the Shell Malaysia unit (the illustration shows an 18,000 b/d unit but this is still small by global refining standards), but would also require about 3 GW of green hydrogen capacity and three million tonnes per annum of DAC. Apart from the synthesis unit which is arguably smaller than the desirable scale for modern refining, the hydrogen and DAC units are unprecedented in size. However, both hydrogen and DAC are scalable technologies, with the latter currently deployed on a modular basis, and as noted above DAC isn’t an immediate requirement.

Building an 18,000 b/d synthesis facility, 3 GW of hydrogen electrolyser capacity and 3 MT per annum of DAC combined with large scale renewable energy production (say 6 GW of offshore wind) is a formidable project, costing many billion euros and taking years in terms of planning, approvals, financing and construction. Such a project will also stretch the available technologies, given that DAC in particular doesn’t yet operate at scale anywhere. But the EU needs to start at least five such projects over the coming 2-5 years, not just to meet the synthetic fuel mandate of 2030, but also with an eye on the 2035 mandate and beyond.

Using scenarios to visualize possible EU emission pathways

April 17, 2023

The Shell Scenario Team released The Energy Security Scenarios about a month ago and I’ve been out talking with stakeholders about them in the meantime.

The two new scenarios (see Note below), Sky 2050 and Archipelagos, describe the tension that is playing out between the promises made by world leaders found themselves in at COP26 in November 2021 when there was a collective agreement to limit global warming to 1.5°C above pre-industrial levels and the energy security situation they were confronted with three months later when Russia invaded Ukraine.

In Archipelagos, the security mindset that is dominant today becomes entrenched worldwide. Global sentiment shifts away from managing emissions and towards energy security. Despite this shift, the drive for energy security still includes the greater use of low-carbon technologies but not emission management technologies such as carbon capture and storage. These dynamics translate into global emissions peaking in the 2020s and falling from the mid-2030s but net-zero emissions remains a long way off.

In Sky 2050, long-term climate security is the primary anchor, with specific targets to reach net zero by 2050 and ultimately bring the global average surface temperature rise to 1.5°C by 2100. The war in Ukraine translates into gradual progress in the early 2020s, but that progress gains momentum towards the 2030s. This happens as the need to deliver low-carbon energy infrastructure takes on an urgency of its own, driven largely by security and price concerns. While progress is initially difficult to see, emissions start to fall from 2025 and, by 2040, the goal of net-zero emissions is clearly in sight. The energy system rapidly transforms.

Underpinning both scenarios is a framework of archetype behaviours by countries in response to energy concerns. The EU falls largely into an archetype called Green Dream, where the focus is on shifting rapidly away from fossil fuels and even reducing energy demand. Government takes a strong role in crafting the direction of travel. By contrast, North America sits with other major resource holders in a group known as Innovation Wins, where long term incentive structures unlock a stream of innovation to allow the energy system to find a different way forward. Technologies such as carbon capture and storage flourish.

Both the EU and North America head towards net-zero emissions, but it is the Americans who get there first in Sky 2050. Perhaps more importantly, of the two it is the Innovation Wins countries which deliver a much bigger share of the global need for negative emissions after 2050, because they develop and embrace geological storage and technologies such as direct air capture (in Sky 2050). Negative emissions are the key to managing overall warming by 2100 and open up the possibility for climate restoration in the 22nd century.

By 2050 in the Sky 2050 scenario, for a similar population, North America has deployed twice the CCS capacity of the EU and has seven times as much direct air capture in operation. By 2100 the EU only has as much direct air capture as North America does in 2050, whereas North America is heading towards 1 Gt of capture capacity.

Within the EU, the pathway is more problematic in the Archipelagos scenario. Nuclear starts to decline quickly in the 2030s and 2040s and isn’t replaced and solar doesn’t multiply to the extent that it does in Sky 2050, although it still becomes very big within the energy mix. Fossil fuels decline, but the net-zero emissions goal for 2050 isn’t met, although emissions are more than 60% below 2019 levels by mid-century. However, the EU does modestly outpace North America in terms of energy efficiency in both scenarios.

In Sky 2050 both the Green Dream and Innovation Wins archetypes get to net-zero emissions around 2050, despite very different approaches to the energy transition. But in the Innovation Wins countries there is a broader range of energy possibilities and greater ability to manage atmospheric carbon dioxide simply because they fully embrace the opportunities available through carbon capture and geological storage.

Within the context of the global stories it is possible to do a deep dive into a particular region at a particular point on the scenario timeline and the team has provided a wealth of data in spreadsheet form for those who wish to embark on such a journey.

Note: Shell Scenarios are not predictions or expectations of what will happen, or what will probably happen. They are not expressions of Shell’s strategy, and they are not Shell’s business plan; they are one of the many inputs used by Shell to stretch thinking whilst making decisions. Read more in the Definitions and Cautionary note. Scenarios are informed by data, constructed using models and contain insights from leading experts in the relevant fields. Ultimately, for all readers, scenarios are intended as an aid to making better decisions. They stretch minds, broaden horizons and explore assumptions.

Reflecting on the IPCC Synthesis Report through new Shell scenarios

March 23, 2023

After a year of work, with a few hints along the way offered via this blog, the Shell scenarios team launched The Energy Security Scenarios this week. This is the team I am proud to be a member of and our new scenarios offer a very different perspective on the world in a time of challenging circumstances. With an almost identical release date, the IPCC 6th Assessment Synthesis Report also landed this week. The scenarios also offer a new lens through which to view the IPCC findings.

The Energy Security Scenarios are built on the foundation of a world in which a security mindset is becoming pervasive, be it national security based on military threats, energy security following a year of supply disruption and price volatility, economic security as we watch the banking system being challenged by some defaults or climate security as the global average surface temperature continues to rise and impacts are becoming more visible. How countries respond to energy price volatility and supply disruption is highly variable, but nevertheless a pattern has emerged that ties together disparate responses such as India buying Russian crude oil and the USA pumping billions of dollars into direct air capture. These behaviours form part of an archetype framework that underpins our new scenarios. This foundation also offers some colour to the energy story we tell, with our archetypes classified as Innovation Wins, Green Dream, Surfers and Great Wall of Change.

Two key drivers shape the stories that we explore, notably the call at COP26 in Glasgow to deliver net-zero emissions globally by 2050 and deep cuts in emissions by 2030 and the response to the Russian invasion of Ukraine which has stressed the global energy system over the past twelve months. As a result, two new scenarios emerge which embrace both drivers, but prioritise them differently as the world moves forwards. We look out not just to 2030 or 2050, but all the way to 2100 and even draw one surprising conclusion about what the 22nd century has to offer. These are stories that describe a world locked in an energy transition not only driven by cooperative change as called for by many, but instead trending towards a world of more intense competition as countries seek to shore up their energy system for the 21st century. The scenarios are Sky 2050 and Archipelagos. Both scenarios see the energy transition accelerating, but at different paces. In Sky 2050 climate security is the priority, whereas in Archipelagos there is more attention to ongoing energy security.

Highlighting the increasing pace of the transition is the recognition of an inflection point in this decade as fossil fuels begin to lose market share in primary energy, finally shifting away from the 80% role they have played for many decades. The pace in Sky 2050 is about twice that of Archipelagos, but both represent a trend break.

Meanwhile, the IPCC is very focussed on the diminishing carbon budget and the rapidly narrowing opportunities for limiting warming to 1.5°C. In the Synthesis Report they broadly conclude that action will be insufficient to contain warming below 1.5°C in the near term, which points to an overshoot outcome and therefore the need to recover the situation later in the century. This is similar to the pathway visible in Sky 2050, which does see global emissions start to fall in the 2020s and net-zero emissions reached in 2050, but nevertheless the surface temperature rises above 1.5°C in the mid-2030s. However, a burgeoning new direct air capture industry, borne out of initiatives such as the Inflation Reduction Act in the USA, appears in Sky 2050. It grows to such an extent than in combination with extensive change in land management practices, from forestry to farming, as much carbon dioxide is removed from the atmosphere between 2050 and 2100 as has been added from now to 2050. The result is that by 2100 surface temperature warming in Sky 2050 has returned to today’s levels, with the potential for climate restoration during the 22nd century.

The IPCC make the case that only a drastic reduction in near term emissions can avoid passing 1.5°C, with CO2 emissions needing to fall by 48% by 2030 relative to 2019 levels. These numbers will become higher with each passing day that emissions do not reduce. The table below comes from the Synthesis Report released on Monday and outlines what must happen in the seven years to 2030, then to 2035, 2040 and 2050.

Source: IPCC 6th Assessment Report – Synthesis

In The Energy Security Scenarios we do not see the scope for such large near term action reductions, with Sky 2050 achieving a reduction of around 12% by 2030. In Archipelagos emissions are higher in 2030 than in 2019. Although the Synthesis Report calls for immediate reductions, the IPCC note that of their modelled scenarios, only a small number of the most ambitious global modelled pathways limit global warming to 1.5°C by 2100 without exceeding this level temporarily. The IPCC state the following:

Global warming will continue to increase in the near term (2021-2040) mainly due to increased cumulative CO2 emissions in nearly all considered scenarios and modelled pathways. In the near term, global warming is more likely than not to reach 1.5°C even under the very low GHG emission scenario (SSP1-1.9) and likely or very likely to exceed 1.5°C under higher emissions scenarios. In the considered scenarios and modelled pathways, the best estimates of the time when the level of global warming of 1.5°C is reached lie in the near term.

In the case of overshoot, i.e. temporarily exceeding 1.5°C, they also note that the application of large scale carbon dioxide removal (CDR) technologies and practices is required to progressively reverse the overshoot situation. However, they also note that any overshoot brings with it the added risk of long term irreversible changes in the global ecosystem.

In short, the Synthesis Report paints a concerning picture of the world exceeding 1.5°C and taking on the associated climate risks. While the report makes every attempt to say that the possibility of not doing so still exists, there is little solid content to argue that this is achievable, a finding backed up by the analysis presented in The Energy Security Scenarios. The temperature outcomes for Sky 2050 and Archipelagos are presented below. The assessments were made by the MIT Joint Program using their climate model and also reported with the release of the Shell scenarios. You can also explore the scenario data here.

The Energy Security Scenarios complement the IPCC Synthesis Report well in that Sky 2050 sets out a very clear and unambiguous pathway to 2100, that both recognises the near term prospect of overshoot and the steps to take to more than redress the situation. By contrast, Archipelagos sets out a plausible pathway forward based on current tensions, but also shows that even under trying circumstances the world may find that 2.2°C is now the upper maximum for warming. While 2.2° is not considered safe territory by IPCC, the Archipelagos outcome is well positioned at the lower end of the range of outcomes that IPCC consider, which exceed 4°C in the worst case. Archipelagos is a story of global political headwinds buffeting the transition, but not to the extent that it slows in comparison with today. Quite the opposite – the pace increases as security concerns and competition drive the system away from fossil fuels.

You can find more on The Energy Security Scenarios here, which I would encourage readers to explore. But if you don’t have the time right now, this short video introduction may be of interest.

Finally, an EU foot in the removals door

March 6, 2023

As the EU continues to develop and progress legislation around its 2030 and net-zero emissions goals, one key proposal has surfaced that will be with us for decades to come.  It is the EU proposal to create a certification framework for removals – i.e. measuring and certifying the amount of CO2 that is removed from the atmosphere and permanently stored through some anthropogenic activity. Examples might include direct air capture with geological storage (DACCS) or reforesting an otherwise barren land area (nature base solution or NBS). The proposal includes the very clear reason why it is needed;

The European Climate Law provides for the EU to become climate neutral by 2050. This requires that GHG emissions are significantly reduced, and that the unavoidable emissions and removals should be balanced within the European Union at the latest by 2050, with the aim to achieve negative emissions thereafter. To achieve this objective, both natural ecosystems and industrial activities should contribute to removing several hundred million tonnes of CO2 per year from the atmosphere. Today and with current policies, the EU is not on track to deliver these quantities: carbon removals in natural ecosystems have been decreasing in recent years, and no significant industrial carbon removals are currently taking place in the Union.

Readers of my previous posts will know that this is something of a pet subject for me and so it is pleasing to see that the EU if finally recognising the importance of removals. The need for a tradable carbon dioxide removal unit is essential for net-zero emissions, in fact it is the essence of the phrase because of the use of the word ‘net’. However, while a first step is important, time is not on the side of the EU, so they will have to move much faster.

In a 2022 post I noted that the revised EU ETS allowance decline rate built into the Fit for 55 framework would take the system to zero new allowances in 2040, but that would almost certainly be ahead of the point in time at which there would be zero emissions in the covered sectors. As such, some form of new allowance would be needed, with the obvious candidate being a carbon removal unit brought in as an external credit. That would make the EU ETS a vibrant carbon removal trading platform, creating a market for carbon removals and establishing a clear price.

But it would seem that the EU is not yet prepared to take such a step. While the certification proposal is important, it lacks one key element, a business model to encourage businesses to use it. The EU appears to be pinning its hopes on voluntary activities, or companies looking to create or acquire certified removals to use for their net-zero commitments. This will happen to an extent, but mainly at the lower cost end of the spectrum such as soil carbon projects, land use change projects and similar. These do form an important part of the EU Fit for 55 framework, but so does the need for DACCS and bioenergy with CCS (BECCS).

The voluntary market and a certification process are no match for the $180 per tonne CO2 on offer in the USA for DACCS under the Inflation Reduction Act (IRA). In the EU there is the Innovation Fund to help drive technologies such as DACCS, but it isn’t operating on the same scale as the IRA. The Innovation Fund could provide EUR 40 billion of support over 2020-2030 for the commercial demonstration of innovative low-carbon technologies, whereas IRA is around USD 330 billion. And IRA has a specific and clearly defined incentive for carbon dioxide removal, which isn’t the case for the EU Innovation fund, although a DACCS would be considered within the framework. It’s therefore not difficult to guess where the DACCS projects will end up and which country will benefit from the investment. That being said, ETS revenues and other mechanisms could bridge this gap if directed more towards energy technology development and demonstration.

The EU could create demand for DACCS and BECCS on a large scale if it opened the EU ETS up to such units, recognising that they will be needed by 2040, but almost certainly prior to that as the ETS reaches reductions in excess of 80%, a point it will hit around 2035.  That is in 12 years. The EU Commission may well have such a move in their future plans, but history would argue that if they don’t start now, time will defeat them. Major changes in direction for the EU ETS take at least 5-10 years to be developed and bed in. For example, the Market Stability Reserve (MSR) started life in about 2011 with proposals for a set-aside of allowances to remove the post financial crisis surplus, then came backloading and finally the first implementation of the MSR and some tweaks a bit later. In 2023 it operates very well.

Given the need for a clear market price signal, i.e. the €100 per tonne CO2 price now available from the EU ETS, a clear set of implementation rules to support projects, and recognition that a functioning DACCS industry will take at least a decade to establish, if not more, the inclusion of removals within the EU ETS becomes rather urgent. Encouraging the use of Article 6 of the Paris Agreement to facilitate carbon dioxide removal technologies is another area that I have written about and is also relevant to the EU in this context. At the moment, the only signal on offer is an indication of a review of negative emissions and trading in a few years’ time.

Business schools and climate change

February 6, 2023

For quite a few years now I have found myself in front of a class of MBA students at a number of different institutions giving a talk on climate change and the energy transition. Each has their own take on how to tackle the subject. Some leave it up to me but at Harvard University the talk was entitled ‘The Future of Fossil Fuels in the Energy System’ and the session included a presentation from a well placed analyst in the finance sector. One common feature is the high level of interest in the class and the diverse and sometimes difficult range of questions that come my way. As such, the sessions are always enjoyable and something of a highlight of my job.

But another common feature is that my lecture was typically part of a module within the course that is optional and as such often populated by students who may have worked in the energy industry or have a close association with it. At least until recently, I didn’t get the impression that the bulk of the students saw energy and climate as pivotal to their future business success. But that appears to be changing.

In my experience, one of the leading business schools in promoting the climate issue as a much more important component of an MBA course is Tuck School of Business at Dartmouth College in Hanover, New Hampshire. I am particularly fortunate to have spoken there in person a few times, although more recently it has been a Zoom experience for the students.  Professor Anant K. Sundaram leads in this area for Tuck and he and Robert Hansen are to be commended for elevating the subject further, with the publication in January of The Handbook of Business and Climate Change.

The Handbook is a weighty document, some 560 pages long, and covers a swathe of subjects from decarbonising electricity and managing aviation to carbon pricing, green bonds and ESG investing – to name but a few of the many subjects. Sundaram and Hansen haven’t written the book in entirety themselves, but instead sought out numerous authors to write the various chapters. I was honoured when Professor Sundaram asked me to write one of the opening chapters, helping set the scene for the book.

After some thought, I decided to call the chapter ‘The End of Combustion?’, perhaps to challenge the orthodoxy that is emerging around the future role of fossil fuels throughout society. In the chapter I explore the transition pathways that have appeared in recent years and where they may be taking us and the extent to which fossil fuel use might end by 2050. Regular readers of this blog may notice a few extracts from my posts or should at least recognise some regular themes. Perhaps not surprisingly the chapter raises the issue of natural and engineered carbon sinks and the many challenges society faces in creating a vast industry that few seem to actually want yet many recognise we desperately need.

This may not be a book for everyone and as a university textbook it’s unlikely to appear on the New York Times Best Seller list, but as an aide for business school students it should prove invaluable. Accelerating the energy transition will require all of the skills that a good business school seeks to impart on its students and all of the talented people that graduate as well. ‘Energy and climate change’ is no longer an optional module for the interested, but an essential part of a business background. There isn’t a company in the world that doesn’t use energy in one form or another and there’s unlikely to be a company that isn’t impacted by the transition or climate change or both.

Thanks to Tuck and Dartmouth for leading the way. And in case you missed it above, here is the link to the handbook and here is a Chapter 1 teaser link along with the detailed contents.

A chat with ChatGPT about emissions mitigation

January 12, 2023

In a recent article from the World Economic Forum the authors made the point that artificial intelligence (AI) systems will be essential for the emissions mitigation task that society faces. In fact they go so far as to say that “without AI, we won’t meet ESG goals and address climate change”. In the article they refer to specific systems now coming into use, with different systems tasked with managing particular tasks within the overall mitigation journey. They conclude by noting;

Corporations that connect all their relevant data within a unified AI platform — not just ESG and financial data streams — will benefit the most. When corporations can see the entire picture and understand all the ESG metrics, only then will we produce goals that provide meaningful change and avoid the worst effects of climate change.

At the societal level, AI platforms are also starting to emerge and they are being designed to tackle a broad range of issues and questions by being introduced to huge amounts of data, such as you and I might come across if we sit all day and trawl through hundreds of internet sites and pages. The skill of the AI platform will be to integrate this data and use it to derive clear answers to questions and offer proposals for change so that progress can be made. Ideally the systems should develop insights that are not obvious to humans looking at the same data, perhaps because of the amount of data presented, which the AI system can easily handle.

Late last year one of the newest versions of such a system was made available for public testing. It is called ChatGPT and can be accessed here. To be fair this is a system that is designed more to engage in a conversation than to solve the world’s problems, but it does still draw on an immense data resource in compiling its responses. As such, I thought it would be interesting to engage with the system over the Christmas break and see what conclusions it might draw from a discussion on emissions mitigation. Note that the answers below are abbreviated, simply to limit the length of the blog post.

I started with posing a simple question;

Q: Atmospheric CO2 is now over 420 ppm. Why is this a problem?

A: Rising temperatures, changing climate, ocean acidification and therefore overall negative impacts on human health. Overall, it is important to reduce our greenhouse gas emissions and limit the concentration of CO2 in the atmosphere in order to mitigate the negative impacts of climate change and protect the health of people and ecosystems.

Q: So how might carbon dioxide emissions be reduced very quickly, say halved by 2030?

A: Increasing the use of renewable energy, improving energy efficiency, planting trees, electrifying transportation and making use of carbon capture and storage: Carbon capture and storage (CCS) is a technology that captures CO2 emissions from power plants and other industrial facilities and stores them underground. CCS has the potential to significantly reduce CO2 emissions from these sources, but it is not yet widely deployed.

So ChatGPT certainly understands the issue and is clear on the direction of travel. It also sees the importance of CCS without any prior reference to the technology by me (other than it may have read my blog posts as part of its learning), so that’s a good start. But getting it to be specific on how quickly these technologies could be scaled and how much difference they might make by 2030 turned out to be much more difficult.

Q: How quickly would these steps need to be scaled to cut emissions in half by 2030?

A: The rate at which these measures would need to be scaled up in order to cut carbon dioxide (CO2) emissions in half by 2030 would depend on the current level of emissions and the specific measures being implemented. For example, transitioning to electric vehicles (EVs) and public transportation could make a significant dent in transportation-related CO2 emissions, but it would require a rapid expansion of charging infrastructure and a significant shift in consumer behavior towards EVs. Improving energy efficiency in buildings and appliances and increasing the use of renewable energy sources could also make a significant impact on CO2 emissions, but again, it would require policy changes, infrastructure investments, and the deployment of new technologies. Planting trees and implementing carbon capture and storage (CCS) could also contribute to reducing CO2 emissions, but these measures alone are unlikely to be sufficient to achieve a 50% reduction by 2030. Overall, reducing CO2 emissions by 50% by 2030 would require a rapid and concerted effort across multiple sectors, including transportation, energy, and industry, and would likely involve significant policy and infrastructure changes, as well as the deployment of new technologies.

From this point the conversation became rather circular, with the system continually rephrasing the answer it had already given in different ways, depending on how I asked the question. More than once it said;

A: However, it is generally understood that the increased deployment of low-carbon technologies, such as EVs, solar PV, and advanced nuclear technologies, can make a significant contribution to reducing CO2 emissions.

A: However, if these technologies were widely deployed and powered by low-carbon energy sources, they could make a significant contribution to reducing CO2 emissions.

But the system was reluctant to offer a numerical assessment even when asked, although eventually it offered a number:

Q: By how much would global emissions fall if EV production, solar PV module production and nuclear power deployment all  quintupled by 2030.

A: It is difficult to estimate by exactly how much global carbon dioxide (CO2) emissions would fall if electric vehicle (EV) production, solar PV module production, and nuclear power deployment all quintupled by 2030, as it would depend on a number of factors, including the current level of emissions, the specific technologies being deployed, and the mix of energy sources used to power these technologies.

Q: Can you make a numerical estimate of the likely reduction in emissions?

A: It is difficult to make a numerical estimate of the likely reduction in carbon dioxide (CO2) emissions that would result from quintupling electric vehicle (EV) production, solar PV module production, and nuclear power deployment by 2030, as it would depend on a number of factors, including the current level of emissions, the specific technologies being deployed, and the mix of energy sources used to power these technologies.

Q: Can’t you make an estimate based on some simple assumptions?

A: It is possible to make a rough estimate of the likely reduction in carbon dioxide (CO2) emissions that could result from quintupling electric vehicle (EV) production, solar PV module production, and nuclear power deployment by 2030 based on some simple assumptions. However, it is important to note that such an estimate would be highly speculative and would not take into account a number of important factors that could affect the actual reduction in CO2 emissions. For example, if we assume that:

  • All EVs are powered by electricity from low-carbon sources and replace gasoline-powered vehicles
  • All solar PV modules are used to displace coal-fired power plants
  • All nuclear power is used to displace coal-fired power plants

. . . . and we further assume that these technologies are able to completely displace the higher-emitting technologies they are replacing, we can estimate the potential reduction in CO2 emissions that could result from these measures. Under these assumptions, if EV production, solar PV module production, and nuclear power deployment were all quintupled by 2030, it is possible that CO2 emissions could be reduced by a rough estimate of around 15-20%. However, it is important to note that this is a highly speculative estimate and the actual reduction in CO2 emissions could be higher or lower depending on a range of factors.

Q: Do you mean 15-20% of total global anthropogenic CO2 emissions?

A: Yes, the estimate of a 15-20% reduction in carbon dioxide (CO2) emissions that I provided is based on total global anthropogenic CO2 emissions, which are emissions that are produced by human activities, such as the burning of fossil fuels and deforestation.

There we have it; after some pushing the AI system was able to determine that quintupling (5x) the current deployment of solar PV, EVs and nuclear power generation would give us a 15-20% reduction in emissions by 2030, although this is still along way from the 45% goal of the Glasgow Climate pact. With that in mind I asked a follow-up question.

Q: So what extra steps would need to be taken to get a 45-50% reduction in global emissions?

A: Increasing the use of renewable energy, improving energy efficiency, planting trees, electrifying transportation and making use of carbon capture and storage: Carbon capture and storage (CCS) is a technology that captures CO2 emissions from power plants and other industrial facilities and stores them underground. CCS has the potential to significantly reduce CO2 emissions from these sources, but it is not yet widely deployed.

I was back in the same loop I had started with in that ChatGPT didn’t want to be specific on the measures. After  some additional pushing I hadn’t progressed out of the loop, but one extra important insight emerged.

A: Implementing carbon pricing: Establishing a price on carbon, through mechanisms such as a carbon tax or cap-and-trade system, can provide incentives for businesses and individuals to reduce their CO2 emissions.

At least as a set of basic insights and discussion points, ChatGPT seems to have a grip on the climate issue, but it is far from making clear recommendations on what needs to happen, when and at what scale. That still seems to be a job for the energy modelling community . . . . . at least for now!!

ChatGPT is an open system to try and use, which is what I have done. This post isn’t meant as a recommendation or a criticism of ChatGPT, but just a look at how AI is developing.

Happy New Year!

New business models required

December 6, 2022

With COP27 now behind us and no significant changes to Nationally Determined Contributions (NDC) on offer (e.g. from China), various commentators are now remarking that meeting the goal of 1.5°C may be in doubt. This means passing the 500 Gt carbon budget that the IPCC linked to the 1.5°C goal.

I have discussed this in many earlier posts, for example here and here. However, passing 1.5°C in the short term certainly isn’t the end of the story.

Many recent IPCC scenarios also show 1.5°C being breached, but deploying removals later in the century to draw carbon dioxide out of the atmosphere is then used in the scenario to reverse the balance and at least meet the 1.5°C goal by 2100. In the IPCC Special Report on 1.5°C released in 2018, all four model pathways required some form of future removal, ranging from very little in P1 to significant in P4, depending on the lifestyle and transition pathway the particular scenario embraced and the level of overshoot of 1.5°C. Both nature based and technological removals are required. In the 2018 report technological removals were shown as bioenergy processing with carbon capture and storage (BECCS), but today we could realistically envisage both BECCS and direct air capture with CCS (DACCS) playing a role. The latter has advanced considerably in just five years.

Source: IPCC SR15 Summary for Policy Makers

So as well as requiring CCS to get to net-zero emissions, society will almost certainly have to consider removals as a technology to deliver negative emissions globally, i.e. after the goal of net-zero emissions is achieved. Large scale removals might also offer the much longer-term prospect (i.e. in the 22nd century) of winding the atmospheric carbon dioxide levels back towards pre-industrial levels.

While global net-negative emissions on a scale that shifts the atmospheric concentration of carbon dioxide is technically possible, the contrast with the very limited scale of deployment of BECCS and DACCS today seemingly takes the task into the realms of science fiction. Yet a century ago the scale on which energy is generated now would also have seemed like science fiction, so the task should not be dismissed. Nevertheless, the longer term could require these technologies and changes in land use to scale to many billions of tonnes of carbon dioxide removal per year. The question this poses is not whether it is possible, but how can it be made to happen.

Carbon capture and storage has become a commercially available technology over the past twenty years, yet global deployment remains very limited. The technology itself isn’t the issue, it is the lack of sustainable business models for deployment. There is a carbon price in Europe, but for many years it languished at just a few Euros and other similar systems currently operating throughout the world typically maintain prices at levels well below what is required for CCS and therefore, not surprisingly, well below the levels required for a 1.5°C transition. Bespoke CCS deployment policies are almost non-existent outside the United States. In the USA a specific tax-credit mechanism exists at the Federal level and the California Low Carbon Fuel Standard will allow the use of credits based on DACCS. As a result the USA is the global leader in CCS deployment and the pipeline of projects looks impressive, largely based on the revised tax credit available through the Inflation reduction Act. There are also DACCS projects emerging and a BECCS ethanol facility has operated in Illinois for some time now.

CCS requires a very long term business model, based on some form of market pull. Today the support for CCS comes largely from direct government grants and support mechanisms for early stage technology, but there is always a limit to such incentives. However, with net-zero emissions now becoming a clear goal in most energy system policy frameworks, a more sustainable model is likely to emerge as businesses seek to mitigate their own emissions, either due to direct policy requirements or indirect consumer preference for zero carbon emission goods and services. A balance will be found between the cost of new technologies such as green hydrogen for industry and making use of CCS in industries that continue to use fossil fuels. Society will find ways to absorb these costs over time as net-zero emissions is reached and whether this results in large or small scale deployment of CCS remains to be seen, depending on the relative costs between competing pathways.

But the next stage of the CCS journey, possibly commencing as early as the 2040s for some, will be to deliver net-negative emissions via DACCS and BECCS, i.e. drawdown of carbon dioxide from the atmosphere. While this may seem like a long way off, the history of creating basic CCS business models points to the need for an early start. The journey probably commences at the UNFCCC level, where a framework for net-negative emissions would need to be established including a global goal, some form of burden sharing agreement between nations and a discussion on the role of nature versus the role of technological drawdown solutions. Unfortunately, with history as a guide, this could take some time. But perhaps the bigger challenge will be for national governments to cascade the need into the economy and find ways to spread the cost of net-negative emissions across society within goods and services and even through taxation. This may not be popular given the net cost of the task, yet with no immediate tangible benefit. Imposing deep emission reduction goals is still proving to be a difficult task in some economies today, let alone asking the population to pay for atmospheric drawdown of carbon dioxide. However, the very long term benefit can be measured in practical terms, such as avoiding metres of sea level rise.

With the prospect of a 1.5°C overshoot scenario looking likely, future biological and geological storage of atmospheric carbon dioxide becomes essential. This task may lead to the development of huge industries engaged in such activities, or very little activity at all, depending on the policy frameworks and business models that emerge.

Revisiting the climate budget maths

November 7, 2022

As COP27 gets underway this week, world leaders will be descending on Egypt with a further round of speeches, promises and pledges to keep 1.5°C alive as a goal to strive for. But as each day passes and global emissions continue at around the rate of 40 gigatonne per year (Gt/y), the simple maths behind the carbon budget gets more and more difficult.

In the IPCC 6th Assessment Report WGI summary the climate scientist authors developed Table SPM.2, shown below, which detailed the remaining carbon budget from 1st January 2020 for a given eventual global warming, relative to 1850-1900. In the case of 1.5°C this is 500 Gt. The permitted budget changes depending on the level of warming and the likelihood of the outcome. So a 2°C outcome with a 67% likelihood offers a budget of 1150 Gt, or over twice that for 1.5°C at 50% likelihood.

Source: IPCC 6th Assessment Report WGI Summary for Policy Makers

While a number measured in hundreds of billions of tonnes (or half a trillion in the case of 1.5°C with 50% likelihood) may seem very large, when set against current annual global emissions of over 40 Gt/y, it is around a dozen years. This means we are knocking on the door of 1.5°C right now. In fact, the 1.5°C carbon budget is being consumed by society at such a pace, that just during the time COP 27 is held, another 1 Gt of the 500 Gt will have been used.

Over time, the consumption of the carbon budget is measured in terms of cumulative emissions, or in a chart of annual emissions vs. time in years it is the area under the line. This then gives us a simple way of looking at the carbon budget and establishing what different trajectories might mean in terms of outcome.

The chart above starts at 2020 and goes through to 2070. In each of 2020, 2021 and 2022 the emissions are either known or almost known, so they are represented in grey as budget consumed. The total is about 120 Gt, with 2020 being the lowest due to the sharp COVID related downturn in March, April and May of that year. With the simplified assumption that emissions won’t be negative at some future time (but of course they may be and undoubtedly will need to be), the linear trajectory for 1.5°C now requires a step down in emissions in 2023 to 40 Gt, then a rapid reduction to 20 Gt in 2030 followed by net-zero emissions in 2047. By contrast, a direct linear reduction from current levels to net-zero emissions in 2050 means a 1.6°C outcome.

Three other combinations are also shown:

  • A plateau in emissions to 2030 then a quick linear descent to net-zero in 2050 results in 1.7°C of warming.
  • A further rise in emissions to 2030, then a fall to net-zero in 2060 gives 1.9°C of warming.
  • If a further rise is followed by net-zero emissions in 2070, then we might expect 2°C of warming.

Given the acceleration of the energy transition in recent years and the new pressures now being placed on fossil fuel use through both price and supply concerns, there are reasons to believe that the transition could accelerate further. It will certainly need to. In the last 15 years the share of coal, oil and natural gas in the primary energy mix has dropped by just 2 percentage points, a trend that would require 600 years to get to zero. By contrast, a 1.6°C outcome requires that rate of change to rise by a factor of 20 to nearly 3 percentage points per year. This is the challenge that leaders at COP 27 need to focus on.

And just like that, zero emissions looms

October 14, 2022

Some time ago I posted a discussion on the allowance decline within EU Emissions Trading System (EU ETS), with no new allowances available after 2058 based on the proposed linear rate of decline of 2.2% each year, but assuming that this would be brought forwards to 2050. Back in early 2020 the EU was in the first stage of laying out its ambition for the 2020s and I noted then;

Based on a continuation of the EU ETS under the current trajectory it won’t reach zero until the late 2050s. . . . Under a revised EU ETS, from January 1st 2050 (or perhaps 2051) there will be no further allocation of allowances, either by auction or freely given. Yet this may not be a time in which there are no emissions – thirty years is possibly insufficient time for the complete turnover of everything in the large emitters system.

A great deal of water has passed under the bridge since then and today as we look at the EU ETS, a radically different picture emerges. The EU has announced its Fit for 55 package and as part of that has also announced a significant change for the EU ETS. Notably, they have said;

In phase 4 of the EU ETS (2021-2030), the cap on emissions continues to decrease annually at an increased annual linear reduction factor of 2.2%. The Union-wide cap for 2021 from stationary installations is fixed at 1,571,583,007 allowances. The annual reduction corresponding to the linear reduction factor is 43,003,515 allowances. . . . . The Commission is proposing a new target to reduce emissions from the EU ETS sectors by 61% by 2030, compared to 2005 levels. This represents an increase of 18 percentage points compared to the -43% target under the existing legislation. To reach this target, the Commission proposes a one-off reduction of the overall emissions cap by 117 million allowances (‘re-basing’), and a steeper annual emissions reduction of 4.2% (instead of 2.2% per year under the current system).

The above is more easily viewed graphically and is shown below. As previously discussed, the original 2.2% line meant that the EU ETS finally reached zero new allowances in the late 2050s, but the changes proposed under Fit for 55 bring that forwards. Note that the rebasing proposal is a one-off reduction of 117 million allowances to bring the cap in line with a pathway that would have materialised if the 4.2% reduction factor would have been applied from 2021 onwards, but the chart below shows the new line as continuous from 2021.

The market doesn’t currently know what the plans are for post 2030 when annual allowance allocation will be around 800 million tonnes, but if the 4.2% linear reduction factor continues, then new allowance allocation will cease in 2041. That would bring the date for zero allocation forwards 17 years from the current 2.2% reduction factor line.

Zero emissions for the ETS sectors (power generation, industry, aviation and soon to include marine) in 2040 is incredibly ambitious and I could argue with some certainty that those same sectors won’t be emissions free in that time. There is no doubt that significant progress will have been made, but the idea that every plane will run on 100% sustainable aviation fuel or a new fuel, e.g. hydrogen, or that every cement plant will incorporate carbon capture and storage in just 18 years is unlikely. As such, the Commission will either have to alter the post 2030 trajectory or plan on a somewhat different outcome.

Altering the post 2030 trajectory such that the system reaches zero allowances in, say, 2050 may seem like the simple solution, but by the late 2020s when this could be under discussion, society may well be facing a situation where Europe both wants and needs to reach net-zero emissions prior to 2050. This would be linked with the global emissions pathway relative to the meagre carbon budget remaining for 1.5°C (now <400 Gt). In short, we will be heading for over-expenditure, which in turn means at least some regions reaching net-zero emissions even earlier than 2050. However, incorporating other sectors into the EU ETS, such as road transport, could also offer some flexibility with regards the decline rate of the cap.

The second approach is one that I have written a great deal about (e.g. here and here), but one that is still not part of the current EU ETS. It is to embrace net-zero and recognise that the ETS will need to become a platform for trading and surrendering carbon removal units against ongoing emissions. Removal units might come from within the EU in the form of units representing Direct Air Capture with geological storage (DACCS) or from outside under Article 6 of the Paris Agreement. The latter could include a much broader range of removals, such as the capture and storage of CO2 from ethanol manufacture in a country such as Brazil. Whatever is included will need to be the subject of extensive consultation, but without it the EU ETS will likely become an infeasible system (meaning that the only option for emitters is to default or shut down) as the zero allowances point is approached. The earlier that zero allowances is set, the more likely is the infeasibility.

Removals are near to becoming essential in Europe and it is important that the Commission accelerates its thinking on incorporating them within the EU ETS. Removals need to form part of the system within the 2020s, such that during the 2030s the mechanisms to create them can flourish and deliver.