Category: Keeling’s Descent

KD #2: A few thoughts on MRV and additionality

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It’s an age-old question, and it’s perhaps more philosophical than anything: If a tree falls in the forest and no one is around to hear it, does it make a sound?

I’ve always argued that it does not. By definition, sound waves need eardrums to hit for them to constitute sounds, as opposed to merely vibrations moving through the air. (Of course, I’m assuming no squirrels, rabbits, chipmunks, or other forest-dwelling, eardrum-possessing creatures are present, either.)

But a newer question, more relevant to our physical world, might be: If a tree grows in the forest and no one is around to measure it, does it capture any carbon?

The answer might not be as straightforward as you think.

Let’s set the stage

Additionality and MRV (monitoring, reporting, and verification) are distinct concepts, but in many ways, they walk hand-in-hand.

According to the World Resources Institute (WRI), a “CDR activity is additional when it can prove that it would not have otherwise happened” without the influence of an organized project and the credit revenues that funded it.

Also according to WRI, MRV is “a process for tracking the outcomes of climate mitigation activities. It includes measurement, reporting, and verification to quantify and transparently share information on the outcomes of a variety of climate actions, as well as ongoing monitoring to ensure that outcomes are maintained over time.” Required to verify the delta between a system’s emissions (or negative emissions) with and without the desired intervention, performing robust MRV is the only way for a developer (or country, or whoever wishes to understand their emissions) to have high confidence – and any evidence – that their intervention has removed as much CO₂ from the atmosphere as they said it would.

Without this robust MRV, developers don’t know how much CO₂ they’ve removed. Without knowing how much CO₂ they’ve removed, they can’t issue carbon credits. Without carbon credits, corporate buyers can’t apply removals to their respective carbon budgets while developers lose the backbones of their capital stacks. Without capital, projects fall apart.

MRV and additionality today are so central to the carbon removal ecosystem that sometimes it feels like we talk about the carbon removal credits more than the carbon removal itself.

Despite what The Guardian says (or, conversely, what it… also says?), carbon credits aren’t going anywhere. I want to be clear on that. However, I do think it’s worth asking: Do we over-index on credits?

How did we actually get here?

Credits and offsets for carbon dioxide, or pollutants in general, are not new. Their history goes back decades:

• • The U.S. Clean Air Act Amendments of 1977 introduced sulfur dioxide and nitrous oxide offset requirements for new and modified industrial facilities.
  • The U.S. Environmental Protection Agency (EPA) ran a lead credit trading program from 1982 to 1988 before completing the phaseout of leaded gasoline in 1996.
  • The Montreal Protocol set a precedent for international emissions cap-and-trade systems in 1987, specifically for chlorofluorocarbons and other ozone-depleting substances.
  • Title IV of the U.S. Clean Air Act Amendments of 1990 set a cap on sulfur dioxide emissions and the EPA issued a finite number of tradable allowances.
  • Using the Montreal Protocol as a model, the Kyoto Protocol of 1997 set mandatory emissions limitation and reduction commitments for 37 industrialized countries and the E.U. and allowed for carbon credit trading through flexible mechanisms.
  • To implement the Kyoto Protocol, the E.U. created an emissions trading system (ETS) in 2003; while prices remained as low as €5 in 2017, prices have since spiked, even briefly surpassing €100 in 2023.
  • The Paris Agreement of 2015, and specifically Article 6, opened the door for countries to support carbon reduction and removal projects in other countries and apply those reductions and removals toward their Nationally Determined Contributions (NDCs).

 

 

 

 

 

 

 

 

It can feel like they haven’t, but the agreements from Montreal, Kyoto, and Paris have definitely spurred environmental progress (as skeptical as many of us tend to be about international environmental agreements).

However, that the storied history of carbon credits may as well be the storied history of carbon credit scandals is news to nobody reading this blog. The fact that there is now an accepted premium on carbon removal credits, as opposed to more conventional offsets for “avoided deforestation,” lends credibility to the still early-stage global carbon removal ecosystem. And even to those not familiar with CDR, this premium shouldn’t come as a shock; while human activity has raised atmospheric CO₂ levels by over 50 percent, other gases in the atmosphere still outnumber CO₂ by roughly 2,300-to-1. We really are looking for needles in haystacks.

Is the voluntary carbon market the right way to look through those haystacks?

For as much talk as there is about the voluntary carbon market (VCM) and its role in scaling carbon removal, as a whole we are missing a few key points. Marc Roston, senior research scholar at Stanford’s Precourt Institute for Energy, recently went on The Carbon Curve to discuss his paper from April, titled “The Market That Won’t Trade: Fixing Structural Failures in the Spot Market for Carbon Removals.” He offers three core reasons why the VCM fails to function like a typical market:

1. 1. Alienability, or Original Sin: The VCM inherited from compliance markets the idea that buyers could purchase certificates and retire them. Under a compliance scheme in which certificates are just permission slips to emit, there’s no point in keeping those certificates; they can go back to the regulator. But under a voluntary CDR scheme, credits are supposed to represent ongoing ownership. Retiring those credits absolves the buyer (and more importantly, the developer) from maintaining the project.
   2. Custody, or the “Hotel California” problem: In commodities markets (or any other market), transferability is key. Much of the value of an asset comes from the ability to move it or sell it to someone else. With CDR, you can store the CO₂, but it can never leave its “storage facility.” So, when buying carbon removal, buyers run the risk of not understanding what they own or where their assets are, and they certainly can’t move their assets.
   3. Fungibility: Other commodities are fungible, but CO₂ captured via some engineered method does not have the same storage timeline or reversal risk as CO₂ captured via some nature-based method. And because ton-year accounting is a “philosophical exercise” more than anything, Marc offers us this: “If you emit a ton of CO₂ in the atmosphere, you have an obligation to remove a ton of CO₂. That has nothing to do with discounting, nothing to do with the social cost of carbon. It has everything to do with the confidence with which you defease the liability.”

I agree that we need to fix these three failures of the VCM as it exists today if it is ever going to mature and function as a legitimate market. But I think it’s worth considering whether it’s possible to achieve some level of negative emissions without going through these growing pains.

MRV isn’t exactly free

Within power generation, overall costs tend to balloon when maintenance costs increase. This can happen with newer technologies, like floating offshore wind turbines, and this can happen with older technologies, like aging nuclear plants. In the former case, massive vessels must tow turbines the size of the Eiffel Tower back to port for lengthy maintenance procedures. In the latter case, evolving regulations can force expensive upgrades. Either way, customers bear the costs.

Carbon removal is no different.

Ongoing operational costs can (and often do) unexpectedly increase, and MRV is a major line item among those costs. For some of the open-system methods, like enhanced rock weathering and ocean alkalinity enhancement, we may someday have a scalable solution to measure CO₂-capture at a relatively low cost. Or perhaps we’ll accept some sort of uncertainty range and simply sell the number of credits corresponding with the lower bound of that range to prevent over-crediting. Given that MRV can account for more than half of ERW and OAE project costs, one of these things will simply have to happen if we want to scale these solutions.

I’m a fan of open-system CDR methods not because of their carbon removal attributes, but because of their potentially monetizable side benefits. Let’s say, for example, that we can eliminate enough OPEX and overhead costs in an ERW project for the agricultural benefits to make the project economically viable in its own right. All of a sudden, carbon credits are unnecessary, and the project is by definition not additional. Under our conventional thinking around CDR, this would not be a good thing, because it would no longer be true carbon removal at all. It would simply be the status quo.

But who cares that nobody can take credit for the project? Negative emissions are negative emissions, and that’s really all we should be going for. Just as developers of new technologies should celebrate when their innovations become boring, we should celebrate when carbon removal becomes non-additional… and is therefore not “carbon removal” at all.

A basic thought experiment

This might be an unpopular question, but I’ll ask it anyway. When entities that verify removals, certify credits, or facilitate transactions make up such a large portion of the carbon removal ecosystem, are we even aiming for the right goal? Or better yet: Are we even playing the right game?

An economy-wide crash, or at the very least a dip, is at this point more a question of “when” than “if.” The AI bubble buoying the tech companies (who buy virtually 100 percent of carbon removal credits) will eventually pop, profits will fall, and expenses will have to fall with them. I’d like to say this is just the devil on my shoulder speaking, but it’s not. And when this crash (or dip) happens, will CDR buyers continue to buy? Will they still pay a premium for the permanence and the MRV? I’m no clairvoyant, but I’m pretty confident in my guess.

As crazy as it may seem, the carbon removal ecosystem may do itself a favor by radically rethinking additionality and the associated MRV. This piece is, of course, not comprehensive. It doesn’t detail things like certification, permanence, durability, or leakage, and it doesn’t propose a solution for how we could actually reduce CAPEX to the point at which “side benefits” provide reason enough to invest in a project with negative emissions. I merely hope to propose a basic thought experiment.

So, once more: If a tree grows in the forest and no one is there to measure it, does it capture any carbon?

I’d say it does.

But we’d better coordinate an international protocol to make sure.

Latest CO₂ reading: 425.82 ppm

Ryan Davidson is a business development and policy specialist in the U.S. marine energy sector, and in his free time he writes Renaissance Carbon, a weekly Substack about the tech, politics, and culture of all things carbon. The opinions expressed in Keeling’s Descent are his own and do not necessarily reflect the opinions of any employer.

Contact: ryandavidson911@gmail.com

KD #1: We can only scale carbon removal to relevant levels if we emphasize its economic benefits over its climate benefits.

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I used to think carbon removal was a distraction from “real” climate action.

Like too many people working in decarbonization, I thought it was a red herring in the hunt for a sustainable future, a moral hazard enabling us (not just oil companies, but everyone) to continue emitting CO₂ and other greenhouse gases.

I’ll come straight out and tell you that I no longer believe those things.

My name is Ryan Davidson, and for my full-time job, I’ve worked for a wave energy technology developer on business development, policy advocacy, and communications, among other things, since 2021. After a few years working on emission reductions, though, I realized reductions alone wouldn’t be enough to slow climate change to a halt. I understand I’m preaching to the choir here, but in spring 2024 it hit me just how vital removals will be, too.

I started learning about carbon removal in my free time in mid-2024, mulling over what my personal philosophy on the topic might be. I completed the AirMiners Boot Up program last fall (shoutout to AirMiners co-founder, and fellow IRCR contributor, Jason Grillo). During and after that time I met folks working in all corners of the CDR ecosystem who were kind enough to offer me their time and wisdom.

Semi-confident in my understanding of the vast world of CDR, last November, I started committing my thoughts to writing  in Renaissance Carbon, a weekly Substack on the tech, politics, and culture of all things carbon removal. One of my main points – perhaps the main point – has been that we can only scale carbon removal to relevant levels if we emphasize its economic benefits over its climate benefits. While this has been (and will continue to be) especially true during the second Trump administration, I believe the point stands regardless of who occupies the White House.

One of my first Renaissance Carbon posts included a “10 Commandments of CDR.” We live in a different world now than in late 2024, but I believe the Commandments still generally hold:

1. 1. Thou shalt not focus too much on DAC.
   2. Thou shalt not cast stones at DAC, either.
   3. Thou shalt emphasize CDR methods with viable revenue streams beyond CDR.
   4. Thou shalt not rely upon the voluntary carbon market to build a gigaton-scale CDR industry.
   5. Thou shalt not forget about lifecycle emissions.
   6. Thou shalt not compare CDR to waste management.
   7. Thou shalt not mistake CCUS for CDR.
   8. Honor thy market-pull mechanisms.
   9. Honor thy subnational policy mechanisms.
   10. Thou shalt not covet funding for emissions reductions.

My CDR beliefs have evolved over the past nine months, but I wouldn’t change much about this list. If I were to change anything, I’d reword Number 4 and add an 11^th one somewhere: CDR is not an industry at all. I’m highly confident in this statement for several reasons:

1. 1. Lots of CDR methods are only similar to each other in that they each happen to remove CO₂from the atmosphere.
   2. If we consider carbon removal an industry, the failure or scandal of one company could poison the well for other companies that are in no way similar.
   3. Just as carbon emissions are a negative externality, carbon removals are a positive externality. “Carbon emissions” isn’t an industry, so carbon removal isn’t either.
   4. Bunching together a variety of seemingly different climate technologies and processes and calling the aggregate an “industry” shines a spotlight on one of the biggest things we don’t want to put in the spotlight: the fact that we’d support projects primarily for their climate benefits to begin with. Whether you like it or not, the economic argument must take precedent.

Individual CDR methods like direct air capture and biochar may be industries, and even MRV may be its own industry, but bundling the entire CDR ecosystem together and acting like it’s a cohesive industry will do us more harm than good. Throughout 2025, I’ve added additional pillars to my CDR philosophy. Here are a few of them:

• • CDR is not about “degrowth.” The Abundance discussion, spurred by the New York Times bestseller from Ezra Klein and Derek Thompson, is a bit too simple, unstructured, and, in my opinion, optimistic. But what Klein and Thompson get right is that we won’t scale low- and negative-emissions infrastructure with the same stringent regulations in place that strangle infrastructure development today.
  • CDR can help bolster national security if we want it to . As one example, manufacturing negative-emission materials may allow us to build a domestic circular economy and reduce our reliance upon imports. As another example, bioenergy with carbon capture and storage (BECCS) can remove CO₂ from the atmosphere and provide baseload power to the grid, all the while supporting local feedstock providers and decoupling the domestic economy from global supply chains.
  • There are no silver bullets in addressing climate change. Within the world of carbon removal, perhaps the biggest violation here comes from unrelenting proponents of ocean iron fertilization. When we give any solution the silver bullet treatment, we implicitly decide that its benefits outweigh its risks. Sometimes, I fear we lose the forest for the trees. Or in the case of OIF, I guess we lose the algae bloom for the plankton.

One of the most rewarding parts of writing Renaissance Carbon is learning lessons like these. I’ll continue writing Renaissance Carbon, which I’ve recently expanded to cover a broader range of carbon-related topics than just carbon removal. This publication with the Institute for Responsible Carbon Removal, however, will focus exclusively on CDR.

I thought for a while about what to call this publication. I decided on “Keeling’s Descent” because that’s exactly the long-term goal of the CDR ecosystem: to not only flatten the Keeling Curve, but to force it downward. Before the Industrial Revolution, atmospheric CO₂ levels sat at around 280 parts per million (ppm). Now they’re at 424 ppm, representing a human-caused increase of 51 percent. Don’t get me wrong; we’re much more than 51 percent better off now than we were before the Industrial Revolution. But at some point, our increased well-being will plateau while emissions and their associated negative impacts continue to expand. Given the quantum leaps we’ve seen in clean energy technologies over the past couple of decades, I’m inclined to believe that point is now.

Achieving net-zero emissions globally by 2050 would imply that the curve will flatten out within the next 25 years. I hate to say it, but this feels like a pipedream. The curve won’t trend downward for a very long time; I’d give it at least three decades, and even that might be aggressively optimistic. I am optimistic that it will someday happen, though.

On this note, I’ll offer a disclaimer. I’m not going to use this platform to paint a rosy picture of the future or push crackpot proposals that will magically help us remove 10 billion tons of CO₂ from the atmosphere each year. I consider myself a climate optimist, but optimism without realism is nothing short of insanity. I may discuss uncomfortable topics, and we will face all too many inconvenient truths in the years to come. One example: Oil and gas companies will play a huge role in scaling CDR. Do they see it as a hall pass to continue producing fossil fuels? Maybe. Do they see it as a way to stay relevant? Absolutely. But does that even matter?

Finally, at the end of each Keeling’s Descent post, I’ll drop the latest CO₂ reading from the Scripps Institution of Oceanography. In the summer months, this number will fall because the growth of land-based vegetation in the Northern Hemisphere outweighs human-caused CO₂ emissions. In the fall, winter, and spring months, this number will rise as biologic sinks (and humanity, of course) release their CO₂ back into the atmosphere.

Nobody knows when (or even if) the Keeling Curve will reach an apex.

But when (or if) it does, let’s be ready to pull the curve downward while building our economy upward.

Latest CO₂ reading: 423.84 ppm

Ryan Davidson is a business development and policy specialist in the U.S. marine energy sector, and in his free time he writes Renaissance Carbon, a weekly Substack about the tech, politics, and culture of all things carbon. The opinions expressed in Keeling’s Descent are his own and do not necessarily reflect the opinions of any employer.

Contact: ryandavidson911@gmail.com