Carbon Business Council Open Letter May 2023

May 24, 2023
Supervisory Body
United Nations Framework Convention on Climate Change (UNFCCC)
RE: Input to SB005 Annotated Agenda and Related Annexes

Dear Supervisory Body:

Thank you for your continuing efforts to ensure that the UNFCCC considers carbon dioxide removal (CDR) as an essential component for a just energy transition and to limit warming to 1.5 °C. The 100+ organizations below appreciate your invitation to respond to the call for input that you issued. Specifically, we would like to share some thoughts here in response to the Information Note entitled “Removal activities under the Article 6.4 mechanism” (A6.4-SB005-AA-A09 version 0.40).

We are pleased to see the Supervisory Body Information Note concur with the IPCC that the science is clear that CDR – alongside a strong global prioritization on emissions reduction of CO2 and other greenhouse gases – is “unavoidable,” and in fact will be required at gigatonne (Gt) scale by mid-century for us to reach net zero and have a chance to limit warming to 1.5 or even 2°C (IPCC AR6 Synthesis Report p 50). It is important to further highlight that CDR encompasses a range of pathways, from land-based soil and forest carbon sinks; biomass-based carbon removal and storage (BiCRS); to marine carbon dioxide removal (mCDR); to mineralization-based approaches; to direct air capture (DAC) – as well as emergent and potentially as yet undiscovered methods.

CDR is a new commercial sector, and the range of potential pathways are at varying stages of discovery, development, and deployment. The sector is advancing quickly, and there are a number of approaches ready for eligibility under Article 6.4 now, with more expected to reach that stage of maturity in coming years. (We have significant concern with the assertion on p. 18 of the Information Note that CDR does not “contribute to sustainable development,” and we would be pleased to connect you with carbon removal leaders advancing projects in Kenya, Kiribati, India, Brazil, and other locations around the world where CDR is contributing directly to local and regional economic development.)

In a recently published Issue Brief by the Carbon Business Council, this resource follows the IPCC’s lead to define CDR as” anthropogenic activities removing carbon dioxide (CO2) from the atmosphere and durably storing it in geological, terrestrial, or ocean reservoirs, or in products” (IPCC AR6 WGIII Report p1,796). The Brief goes on to outline five key criteria for high-quality CDR: additionality, durability, net-negativity, verification, and equity and community engagement. We strongly urge the Supervisory Body to adopt this IPCC definition of CDR, and a similarly method-neutral, criteria-based approach to determine CDR project’ eligibility under the Article 6.4 mechanism.

The Information Note lists four CDR approaches under the label of “engineering based activities” – a label we do not recommend given that virtually every CDR approach is a hybrid of nature and engineering. We would suggest, instead of labeling and enumerating individual CDR pathways and approaches, that the Supervisory Body define the criteria that a given CDR project must demonstrate to be eligible under the Article 6.4 mechanism – and let science, innovation, and the market compete to deliver the solutions offering the greatest climate impact and other co-benefits.

We would be pleased to discuss this further with the Supervisory Body, and very much appreciate your continuing work to achieve a safe and equitable climate future, as well as the opportunity to submit this input for your consideration.


Aditya Agrawal, Chief Innovation Officer, Global Carbon Removal Partnership
Alex Bell, Chief Growth Officer, Removr
Alexander Milde, Engineer, Scaled Carbon
Amy Chambers, Director Marketing Communications & Sustainability, Carbon Streaming Corporation
Andre Sobolewski, CEO, Blue Skies Minerals Inc
Andrew Denu, Commercial Lead, Andes
Andy Lam, Senior Manager, Climate Programs, MaRS Discovery District
Angela Hepworth, SVP Commercial, BECCS Drax Group
Anna Lehner, Standards & Methodologies, Carbonfuture
Anna Lerner, CEO, Climate Collective
Antti Vihavainen, CEO,
Apoorv Sinha, CEO, Carbon Upcycling
Aranzazu Carmona Orbezo, Founder / CTO, Parallel Carbon
Ben Rubin, Executive Director, Carbon Business Council
Ben Swainbank, Founder, Oceanid MRV
Ben Tarbell, CEO, Ebb Carbon
Benedikt Zimmermann, Vice-chairman, German Biochar Association
Bradley Rochlin, Director of Strategic Partnerships, Running Tide
Brandon Vlaar, CEO, Mangrove
Brian Krohnke, President, Tiny Carbon LLC
Brian Reynolds, Director, Carbon char store
Bryan Eagle, CEO, Glanris
Calli Obern, Director of Policy, Capture6
Casey Handmer, Founder and CEO, Terraform Industries, Inc.
Chris Neidl, Co-Founder, OpenAir Collective
Chris Sherwood, Secretary General, Negative Emissions Platform
Christiaan Gevers Deynoot, Senior Manager, Carbon Removals Platform South Pole
Claire Nelson, Co-founder and CTO, Cella
Corey Pattison, Co-Founder and CEO, Cella
Crystal Kuyumcu, CEO, Exhale Aerosystems
Daniel J. Soeder, Owner and Principal, Soeder Geoscience LLC
Delia Meth-Cohn, Co-founder, Rethinking Removals
Diana Maranga, Business Development & Policy Lead, Octavia Carbon
Dr. Matthew Eisaman, Chief Scientist, Ebb Carbon
Elodie Vignon, Senior Climate Policy Manager, neustark
Felix Harteneck, CEO, InPlanet GmbH
Florian Hildebrand, CEO, Greenlyte Carbon Technologies GmbH
Frederic Clerc, Director, Carbon to Value Initiative
Giana Amador, Executive Director, Carbon Removal Alliance
Grant Faber, Founder and President, Carbon-Based Consulting LLC
Hanna Ojanen, Public Policy Lead, Carbo Culture
Hayley Moller, Founding Team + Chief Marketing Officer, Thallo
Helen Bray, Vice President Policy,
Isabella Corpora Associate Director Carbon Business Council
Jack Sullivan, Chairman & Founder, RedCarbon
James Rogers, Officer, Direct Air Capture Coalition
Jason Grillo, Director, AirMiners
Jason Hochman, Co-Founder and Senior Director, Direct Air Capture Coalition
Jesse Hebert, Co-Founder & COO, OCHIUS
Jim Mann, CEO, UNDO
Jodi Formosi, CEO/FOUNDER, Bella Biochar Corporation
Johan Börje, BECCS Development, Stockholm Exergi AB
John Hoopes, Co-Founder, Toucan Protocol
John Lin, CEO and Co-Founder, Tau Carbon Inc.
Jordon Sansom, CEO, Minera Systems
Josh Dorfman, CEO, Plantd, Inc.
Julio Friedmann, Chief Scientist, Carbon Direct
Kel Coulson, Policy and Engagement Lead, Carbon Engineering
Kelly Erhart, President, Project Vesta, PBC
Linus Hiscox, Senior Carbon Rating Scientist, BeZero Carbon
Lucy Hargreaves, VP, Corporate Affairs + Climate, Policy Patch
Marcel Rensmann, Head of Technical Sales, PYREG GmbH
Marcius Extavour, Chief Climate Solutions Officer, TIME CO2
Matt Bright, Director of External Affairs, CarbonCapture Inc.
Matthias Krey, Managing Director, Perspectives Climate Group
Maurice Bryson, Founder and director, Silicate
Megan Mayzelle, Executive Founder, Written Progress
Melody Ma, Global Head of Policy & Regulatory Affairs, ACX
Michael Avery, President, 1PointFive
Michael Baute, Entrepreneur in Residence & Director, Carbon Removal AES
Michael Kelland, CEO, Planetary Technologies
Mike Carpenter, CEO, Inherit Carbon Solutions
Mike Green, Partner, Carbon Capital Advisors
Mira Nagarajan, Market Development and Policy Lead, Origen Carbon Solutions
Natalia Dorfman, CEO and Co-Founder, Kita
Nicholas Gogerty, Managing director, Carbon Finance Lab
Nicholas Rockwell, VP of Revenue, Alcove
Niklas Kluger, COO and Co-Founder, InPlanet
Oliver Katz, Founder and CEO, Unbound Summits
Olivier Dufresne, CEO, Exterra Carbon Solutions
Ongeleigh Underwood, Director, Circular Carbon Network
Pascal Michel, Founder & CEO, Everest Carbon Inc.
Patricia Estridge, CEO, Seaweed Generation Ltd
Patrick Dwyer, Partner, Carbonseek Partnerships
Paul Gambill, CEO, Nori
Paul Stevers, CEO, Integrated ClimateTech, Inc. (iClimateTech)
Peter Chargin, Vice President, Government and
Community Relations, Planetary Technologies
Qinhong Cai, CEO, Gaia Refinery
Ryan Anderson, CEO, Parallel Carbon
Ryan Jeffery, Senior Managing Director, Sustainability gener8tor
Savita Bowman, Program Manager, Carbon Management, ClearPath
Sean Lowrie Head of External Affairs Arca
Sebastian Manhart, Senior Policy Advisor, Carbonfuture
Shantanu Agarwal, Director, Swaniti Initiative
Silko Barth, CTO, Blue Skies Minerals
Simon Manley, Head of Carbon, UNDO Carbon Ltd
Simon Nicholson, Co-Director, Institute for Carbon Removal Law and Policy
Stephanie Bischof, Managing Director, Airfix
Steve Oldham, CEO, Captura
Susanne Veser, Dr.-Ing., Fachverband Pflanzenkohle e.V.
Svenja Telle, Director of Origination, Base Carbon
Toby Bryce, Policy Advisor, Carbon Business Council
Tony Pan, CEO, Modern Hydrogen
Torsten Becker, CEO, carbonauten GmbH
Travis Caddy, Product Manager, Evident
Trip Allen, CEO, Levitree
Vida Gabriel, Co-Founder, TerraFixing