7 July 2023

To:

The Supervisory Body Members, Article 6.4 of the Paris Agreement

Parties to the UNFCCC –

This open letter from civil society groups from across the world reiterates our demands regarding the processes surrounding Article 6.4 of the Paris Agreement and the wider issue of carbon markets and offsets. Namely:

• Carbon markets, offsets schemes, and carbon removals cannot offer solutions to the climate crisis and instead further prop up a system that has enabled Big Polluters and rich countries to profit off of the crisis. They should therefore not be enabled under any provision of the Paris Agreement.
• Land-based removals do not result in emission reductions and further lead to unacceptable negative environmental and social impacts, and foster unsustainable development, which are contrary to the objectives of the Paris Agreement and to adequate climate action – they should therefore be rejected.
• Geoengineering removals are unproven, risky, and costly technologies that put the profits of Big Polluters above the protection of our communities and environment, and further distract and derail from the urgent, deep, real emission reductions needed – they should therefore be rejected.
• Emissions avoidance should not be considered as it does not compensate for ongoing emissions, but instead poses a significant risk for inflating baselines.
• Carbon markets cannot be enabled to be propped as climate finance in lieu of the commitments urgently needed from rich countries, including toward the loss and damage fund and in other UNFCCC work streams.
• The process surrounding Article 6.4 is proving increasingly biased in favour of the industry and needs to be reassessed if it is to remain credible, including concerning the timeline of consultations and who is given a say in it.

OUR DEMANDS

Carbon Markets and Removals

We reiterate our opposition, as climate justice, human rights, Indigenous and gender justice groups and movements, to global carbon markets, offsets schemes, and carbon removals.  

The science is as clear as the increasing frequency and violence of climate impacts across the world: we cannot waste any more time for adequate climate action. Whilst impacts wreak havoc over our communities and ecosystems, Big Polluters carry on emitting under the cover of deceiving net zero claims. These schemes open the door to dangerous distractions in the form of land-based and technological removal offsets to be traded on carbon markets for Big Polluters to profit from. This should not be the result of an international agreement that was intended to avert climate catastrophe.

We refuse to buy into the greenwashing ploy to prop up these false solutions as climate action given that they not only do not address absolute emissions reductions but also perpetuate global North-South inequalities and inequities relating to carbon emissions.

Crucially we express our deep concern over the unacceptable environmental and social risks and costs that these so-called ‘solutions’ put on our communities. Removals and offsets cannot be considered as solutions so long as they continue to result in Indigenous rights violations, additional Human rights violations, land grabbing, and disproportionate impacts especially on communities in the global South and small peasant farmers communities.

We also reiterate that carbon markets are not climate finance. The climate debt of developed countries should be discharged through provision of public financial resources as part of the obligation of developed countries under the UNFCCC and the Paris Agreement and in line with the principle of Common But Differentiated Responsibilities (CBDR), not via carbon markets and offsets.

Issues with Removals

Land-based removals, or so-called ‘nature based solutions’, cannot compensate for the permanent emissions from the fossil fuels and other high emitting industries. An increasing number of investigations have demonstrated that these offsets are, in the majority of cases, worthless, and do not result in actual, real emission reductions. Further, such projects including REDD/+ schemes, tree plantations, and soil carbon farming, have been linked to extremely concerning Human rights and Indigenous rights abuses. We cannot allow for the appropriation of land from Indigenous Peoples, small peasant farmers, and communities first and foremost in the global South, or for the erasure of ancestral practices that have maintained and protected ecosystems for centuries. Safeguards are needed but cannot be enough. Any land based removal activities will risk perpetuating the systemic causes of violations of Indigenous customary land rights and territories. 

Technological removals, or geoengineering, provide the illusion that polluters can keep on emitting based on the promise of future technologies that would allow for the removal of carbon from the atmosphere. Geoengineering approaches, such as Direct Air Carbon Capture and Storage (DACCS) or ocean fertilization and alkalinization or enhanced weathering, are risky, speculative, technologically unproven and/or unable to be proven at scale, and pose new impacts and considerable and unacceptable environmental and social risks, including serious threats to Indigenous rights and Human rights in general, and negative transboundary impacts. Their development at scale would drive disproportionate economic cost as well as put an irreversible strain on scarce resources such as land and water that we desperately need to uphold living systems. Science says we need to urgently phase out fossil fuels. The IPCC states that the best way to curtail climate change is “deep, rapid and sustained reductions in greenhouse gas emissions” this decade and that Carbon Dioxide Removal (CDR) technologies are “uncertain and entail(s) clear risks”. The IPCC has been critically questioned for its over-use of CDR technologies in its mitigation scenarios. An equity assessment of global mitigation pathways in the IPCC 6th Assessment Report finds that the continued fossil fuel use in developed countries, even until 2050, is compensated for by higher sequestration (through land-based and Carbon Capture and Storage technologies in developing regions).

Crucially, the amount of land required for both types of removals (land-based or some geoengineering technologies such as Bioenergy with Carbon Capture and Storage, BECCS) will result in competition with cropland and associated negative impacts on food sovereignty, biodiversity loss, Human rights abuses, and increased food prices. Techniques like Ocean Alkalinity Enhancement and Enhanced Weathering would demand an additional expansion of the mining industry, creating more ‘sacrifice zones’, more habitat destruction, and adverse impacts on water quality. Not only would they impact communities and land, they could be detrimental for marine ecosystems and life. All of these techniques require an increase in energy use across their value and supply chains. In the case of DACCS, immense energy is needed that would drive the continued use of fossil fuels causing more and more delay.

As civil society groups and communities impacted by climate change we reiterate our demands for real, deep, and urgent emission reductions in line with principles of fair shares; as well as our opposition to the dangerous distractions that carbon markets, offsets, and net zero schemes represent.

Article 6.4 and Article 6.2

• There should not be carbon markets, especially those that enable offsets, under the Paris Agreement. To include removals in such mechanisms is profoundly dangerous, due to continuing concerns about lack of permanence, additionality, the negative impacts and pose high risk on people and the environment, and reliance on speculative technology that is unproven or/and unable to be proven at scale, among others.
• Geoengineering-based removals need to be excluded. The moratorium under the Convention on Biological Diversity (CBD) must be respected as well as the precautionary decisions of the London Protocol / London Convention (LC/LP) given the risks they pose to communities and the environment. All BECCS, DAC, CCS, CCUS, or any other marine or land-based geoengineering proposals must be excluded from Article 6.4 as well as any other articles of the Paris Agreement.
• Removal activities risk fostering unsustainable development in developing countries, resulting in land grabs and competition with cropland which will increase food prices. This goes against the objective of Article 6 and is a form of climate injustice.
• Removals into land and soils cannot compensate for permanent emissions from fossil fuels. This cannot be resolved by carbon accounting practices. Emissions avoidance should not be considered as it does not compensate for ongoing emissions, but instead poses a significant risk for inflating baselines.
• Carbon markets are not climate finance, and cannot provide an escape hatch in lieu of the needed financial commitments with rich countries taking the lead – including toward the loss and damage fund as well as with financial agreements in other UNFCCC work streams. 
• Not only must there be an independent and effective grievance redress mechanism in line with respecting the right to remedy – all techniques and projects being considered must first undergo independent and rigorous preliminary Human rights and biodiversity impact evaluations that take into consideration the full life-cycle impacts, pursued with meaningful, inclusive and participatory consultations with all right-holders and communities potentially affected.

Process Flaws

We express our concerns regarding the process surrounding Article 6.4 and the engagement with stakeholders and rights holders. 

Firstly, as the objectives of Article 6 aim to allow for higher mitigation ambition and to promote sustainable development, it seems an obvious conflict of interest to allow for the input of industries that have been fueling climate change as well as distracting and delaying adequate action for decades. In line with the Kick Big Polluters Out demands, we reiterate that Big Polluters should not be granted access to policy making. The consultation process held by the Supervisory Body for Article 6.4 provides a strategic opportunity for pro-markets stakeholders to strengthen their tactics and therefore renders the process deeply flawed. Rights holders, on the other hand, must be given adequate avenues to actively provide input and influence the process and provisions of Article 6.4.

We also express our disappointment in the way the additional June 19th  consultation process was carried out. The short turnaround time offered for rights holders and civil society to provide additional and more specific feedback – while in the heart of the SB58 negotiations – is on the verge of improper consultation that privileged time to the Carbon Dioxide Removal (CDR) industry. 

We are concerned that the unbalance of this process could lead to a disproportionate influence of the CDR industry on the process going forward, which would put into question the credibility of the Supervisory Body and the whole process. We therefore call on the Supervisory Body to maintain its impartiality in the process and to not allow for the influence of an industry that has so much interest in the question to weaken provisions regarding such risky and dangerous processes as carbon dioxide removals.

Sincerely,

Organizational Signatories

350.org

AbibiNsroma Foundation

Accelerate Neighborhood Climate Action

ActionAid International

Asian Peoples Movement on Debt and Development

Association des Agriculteurs Sans Frontières AASF DRC 

Association Jeunes Agriculteurs (AJA)

Association pour la protection de l’environnement et le développement durable de Bizerte APEDDUB 

Biofuelwatch

Break.The.Ice

Businesses for a Livable Climate

Call to Action Colorado

Catholic Network US

CCFD – Terre Solidaire

Center for International Environmental Law (CIEL)

Centre for Rights and Democracy (CRD) South Sudan

Centre for Citizens Conserving Environment & Management (CECIC) Uganda

Centre for Feminist Foreign Policy (CFFP)

Centro Ecológico

Climate Justice Alliance

Climate Action Network Australia

Collectif Sénégalais des Africaines pour la Promotion de l’Éducation Relative à l’Environnement (COSAPERE)

Community for Sustainable Energy

Congo Basin Conservation Society CBCS network DRC

Consejo Shipibo Konibo Xetebo Peruvian Amazonia

Corporate Accountability

Corporate Europe Observatory

Earth Ethics, Inc. 

EcoEquity 

EcoNexus

Elders Climate Action

Emonyo Yefwe International 

Ensemble pour la Justice climatique et la Protection des Défenseurs de l’environnement 

Environmental Defence Canada

Equidad de Género: Ciudadanía, Trabajo y Familia

ETC group

Friends of the Earth Canada

Friends of the Earth England, Wales and Northern Ireland

Friends of the Earth Georgia

Friends of the Earth Germany (BUND e.V)

Friends of the Earth International

Friends of the Earth Japan

Friends of the Earth Spain

Friends of the Earth U.S.

Front Commun pour la Protection de l’Environnement et des Espaces Protégés (FCPEEP RDC)

GenderCC SA

Global Forest Coalition

Grassroots Global Justice Alliance

Greater New Orleans Housing Alliance

Green Revolution Initiative GRI ltd DRC

groundWork/ Friends of the Earth South Africa

Grupo para o Desenvolvimento da Mulher e Rapariga (GDMR)

Honor the Earth

I-70 Citizens Advisory Group

Iakwatonhontsanónstats of Kahnawake 

Indigenous Environmental Network

Indivisible Ambassadors

Innovation pour le Développement et la Protection de l’Environnement (IDPE)

Institute for Agriculture and Trade Policy

Institute for Globalization Studies

Institute for Policy Studies Climate Policy Program

Institute of Socioeconomic Studies (Inesc)

International Network of Liberal Women

Jeunes Volontaires pour l’Environnement Côte d’ivoire (JVE Côte d’Ivoire)

Just Transition Alliance

Khumbilo Agroecology Media Services

Larimer Alliance for Health, Safety and Environment 

Les Amis de la Terre-Togo

LIFE Education Sustainability Equality e.V.

Littleton Business Alliance

Mayfair Park Neighborhood Association Board

Mental Health & Inclusion Ministries

MenEngage Global Alliance

Milieudefensie

Montbello Neighborhood Improvement Association

Movement For Education And Advocacy Network Salone 

National Birth Equity Collaborative

National Campaign for Sustainable Development Nepal

National Family Farm Coalition

Natural Justice

NGO Forum on ADB

NOAH Friends of the Earth Denmark

Ntaamba Hiinta Development Trust

Peace Track Initiative 

Plateforme Ivoirienne sur le Climat (PIC)

RapidShift Network

Reacción Climática – Bolivia 

ReCommon 

Réseau Peace World International 

Rise Up Movement DRCongo 

Save EPA

Sahabat Alam Malaysia – Friends of the Earth Malaysia

Santa Cruz Climate Action Network

Sciences Citoyennes

Secours catholique- Caritas France

Small Business Alliance

Société Civile environnementale et Agro Rurale du Congo SOCEARUCO RDC

Southwest Organization for Sustainability

Spirit of the Sun, Inc.

Stay Grounded Network

System Change Not Climate Change

TEAL Climate

The Green House Connection Center

The Mind’s Eye

The People’s Justice Council

The RedTailed Hawk Collective 

Third World Network

Union Nationale des Marginalisés pour un Développement Durable UNAMDD DRC

Unite North Metro Denver

Vision Plus pour le Développement Durable (VIPDD/RDC)

Wall of Women

War on Want

Wen (Women’s Environmental Network)

Western Slope Businesses for a Livable Climate

WhatNext?

Women Changing The World

Women Engage for a Common Future (WECF) International

Women in Law and Development in Africa (WILDAF-A0)

Women’s Earth and Climate Action Network

Women’s Environment and Development Organization (WEDO)

Womxn from the Mountain

Working for Racial Equity

Zambia Alliance for Agroecology and Biodiversity 

Zambian Governance Foundation

Zero Hour