The CDR Policy Scoop

In this episode of The CDR Policy Scoop, Eve Tamme and Sebastian Manhart dig into the cost assumptions behind the European Commission's EU Emissions Trading System review proposal, a month after the impact assessment first set out what BioCCS, DACCS, and biochar carbon removal are actually expected to cost between now and 2040. Sebastian has spent the past weeks tracing where those numbers come from, and brings in Hansjorg Lerchenmuller, Chairman of Biochar Europe, and Eadbhard Pernot, Executive Director of Carbon Management Europe, to stress test the modelling against real project economics.

The picture that emerges is one of a forecast built on remarkably thin foundations. All the Commission's numbers trace back to just four sources, and because the medium scenario is simply an average of a low and a high estimate, a single shaky assumption can drag the whole range off course. For BioCCS, that means a low cost calibrated against an unverifiable 2022 conference remark and a transport and storage figure of just 38 euros a ton that barely holds up against real infrastructure costs. DACCS fares little better, with the entire range resting on a single McKinsey report whose underlying assumptions were never published.

Biochar gets the most detailed correction. Hansjorg lays out where the European industry actually stands, more than 235 plants and a real scalable price closer to 175 to 200 euros a ton, well above what the Commission's own modelling implies.

The conversation closes on a shared plea: better data, more transparency about assumptions, and more developers willing to submit real transaction numbers before the next round of forecasts gets built.

Links:
Eve Tamme: LinkedIn and Website
Sebastian Manhart: LinkedIn and Website
Hansjorg Lerchenmuller: LinkedIn
Eadbhard Pernot: LinkedIn and Carbon Management Europe
Sebastian Manharts’ Why the BioCCS costs in the ETS proposal simply don't add up
McKinsey’s Carbon removals: How to scale a new gigaton industry
European Biochar Market Report, 5th edition
CDR.fyi
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In this episode of The CDR Policy Scoop, Eve Tamme and Sebastian Manhart sit down with Lisa DeMarco to unpack the legal machinery behind Article 6 of the Paris Agreement. A letter of authorization is an enforceable contract by which a host government permits a project to export a piece of its own climate progress. Lisa explains that it only counts as genuine under Article 6 if it conforms exactly to the minimum requirements set out in Article 6.2 or 6.4. She warns that letters of approval, acknowledgement, or no objection are routinely confused in the market, and points listeners to the model LOA forms she helped develop with the World Bank.

The conversation turns to the KOKO cookstove project in Kenya, where two government entities each argued they lacked the authority to issue the LOA, leaving no party accountable when the project collapsed. Lisa breaks down the three part diligence host governments should complete before signing an LOA: confirming which branch of the state actually holds authority, checking the export will not take the country off track from its NDC, and reviewing domestic constitutional questions around trading natural resources.

Lisa and the hosts also dig into revocation, distinguishing between a government's right to revoke a bad actor's authorization and the far more consequential question of retroactively cancelling units that have already changed hands, something she compares to printing a dollar bill and tearing it up. On corresponding adjustments, she lays out exactly when they are legally required by law and when not. However, even when projects don’t require corresponding adjustment, arranging a letter of acknowledgement from the government is crucial.

They close by sizing up the market: roughly thirty five Article 6 projects have been authorized since the start of 2025, worth about one hundred million credits combined, against a European Union that alone could need hundreds of millions of credits by 2040.

LINKS
Eve Tamme: LinkedIn and Website
Sebastian Manhart: LinkedIn and Website
Lisa DeMarco: LinkedIn and Resilient LLP
World Bank: Letter of Authorization and Acknowledgement (incl templates)
IETA Article 6 Project Directory
Paris Agreement Article 6 Implementation Partnership

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In this episode of The CDR Policy Scoop, Sebastian Manhart and Eve Tamme are joined by Mel Murphy, an independent geochemistry consultant, and Dirk Paessler, founder and CEO of Carbon Drawdown Initiative and Vice President of the Negative Emissions Platform, for a very special episode on how anyone actually knows enhanced rock weathering is working.

Mel explains the two dominant measurement approaches, solid phase and aqueous pore water, and why they often tell different stories about the same field. Dirk brings the view from Carbon Drawdown Initiative's own experiments: a field trial with no measurable signal, buried buckets that still show nothing after 1400 days, and a greenhouse programme now running hundreds of soil and rock combinations. The pattern that keeps surfacing is that results depend on the specific rock, soil, and method used.

That uncertainty has not stopped the market. Over 20,000 credits have been certified across Brazil, the US, and India, even as Vera has declined to build a methodology, citing immature science. Mel unpacks Carbon Plan's critique of credits from the US company Lithos, where an implied dissolution rate came out roughly ten times higher than a new peer reviewed estimate, and how registries like Isometric are adjusting requirements accordingly.

The conversation closes on cost. Measurement now eats up 56 percent of enhanced rock weathering's budget, the highest share of any removal method. Dirk and Mel discuss whether machine learning trained on greenhouse data and satellite based field mapping can bring that down, and why neither will commit to a timeline for readiness under something like the EU ETS.

Show notes:

Eve Tamme: LinkedIn and Website
Sebastian Manhart: LinkedIn and Website
Mel Murphy: LinkedIn
Dirk Paessler: LinkedIn and Carbon Drawdown Initiative
Questions about Lithos’ first ERW credit issuance
An Ecosystem of Carbon Dioxide Removal Reviews – Part 3: Enhanced Weathering
MRV Proxies for EW? A Guided Tour Through Our Data From Our Two-Year Greenhouse Experiment
Portfolio Spotlight: AEROC — Giving Enhanced Rock Weathering Its Eyes
Where does the CO₂-removal potential of enhanced weathering actually go?
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In this episode of The CDR Policy Scoop, Eve Tamme and Sebastian Manhart sit down with Dr. Injy Johnstone, Senior Research Fellow at the Max Planck Net Zero Lab, to unpack her new report, What Are Residual Emissions, which tries to bring clarity to one of climate policy's most used and least defined terms.

Johnstone explains why, more than a decade after the term entered use, there is still no shared definition. The IPCC modeling community that coined it works from different inputs than a corporate net zero team, and the timeline question, today's technology versus a 2050 horizon, changes the answer. She also draws a distinction the sector often blurs: hard to abate describes a technological limit, while residual emissions is a broader, more normative category shaped by choices about demand reduction and regulation.

The conversation turns practical as Johnstone breaks residual emissions into near, medium and long term buckets that corporates and governments can plan against. Sebastian presses on the middle bucket, where overly optimistic assumptions about future technology can quietly reduce carbon removal investment today. Johnstone and Eve also test the new SBTi and ISO standards released since the report's publication.

They close on equity: who decides an industry keeps its social license to keep emitting, and who absorbs the trade offs within a finite carbon budget. Johnstone argues these normative choices are already being made, whether admitted or not, and surfacing them is the first step toward distributing that cost fairly.

Links:
Eve Tamme: LinkedIn and Website
Sebastian Manhart: LinkedIn and Website
Injy Johnstone: LinkedIn
"What Are Residual Emissions” Report
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In this episode of The CDR Policy Scoop, Eve Tamme and Sebastian Manhart follow up on their interview with Mette Quinn to hash out their own read of Brussels' proposal to fold carbon removals into the EU ETS, and they don't agree on much. Is this really a "compliance market," or a purchasing programme that happens to sit on the ETS cap? Eve and Sebastian take opposing sides, and the answer matters more than semantics: it shapes how the whole mechanism should be judged.

The cost assumptions get the roughest treatment. Sebastian has spent the past week stress-testing the BioCCS and DAC numbers behind the impact assessment, and he's not convinced. The transport and storage figures look wildly optimistic against what he's hearing from Europe's biggest BioCCS developers off the record. Biochar comes off worse still: favourably discussed in the impact assessment, then dropped entirely from the actual proposal, with nature-based solutions getting an explicit review clause that biochar never received.

Timing is the other flashpoint. A 250 million ton removals commitment sounds decisive, until you line it up against a 48 million ton auctioning target for 2039 and realise the years don't match. Add in unresolved questions about who eats the risk on non-delivered offtakes or a shifting carbon price, and the "who pays" question stops being hypothetical.

They close on supply: will a demand signal alone be enough to pull removals out of the Global South, or will an undersupplied market let developers simply triage toward whoever pays most? Robert Höglund's observation that this may be the first major EU proposal to treat permanent removals as functionally equivalent to reductions gets a nod too, a precedent Eve and Sebastian both think could ripple well beyond the ETS.

Show notes:

Eve Tamme: LinkedIn and Website
Sebastian Manhart: LinkedIn and Website
Removals Enters the EU ETS — with Mette Quinn
EU ETS revision proposal
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