CDR Policy Progress Tracker methodology

Purpose and framing of the Tracker framework

The purpose of developing this framework is twofold:

• To allow the high-level assessment of countries’ current CDR policy environment and progress towards a comprehensive CDR policy.
• To allow a comparison of how countries are doing, as well as highlight best practices that other countries could learn from.

This initiative creates a framework to assess countries’ CDR policies systematically. It also allows the comparison of countries’ respective CDR policies. The framework will therefore not provide an exhaustive checklist of all policies that need to be in place, nor represent Carbon Gap’s complete advocacy position on required policies. Rather, it will highlight all the basic elements that should be considered in an appropriate national CDR policy framework in the near to medium term.

It therefore needs to be sufficiently broad to account for national differences, while being comprehensive enough not to miss any key element. In terms of national priorities, the assessment will seek to understand which CDR methods a country sees as relevant, and review policies with this in mind. It is not expected that a country should have policies relevant to all CDR methods, and in this sense the assessment should not be biased towards larger countries with greater resources to enable a broader portfolio.

The framework will be dynamic and evolve as time passes and new best practices emerge.

Indicators and scoring system

The assessment framework reflects Carbon Gap’s view of key policy dimensions for CDR (“indicators”). The indicators are defined broadly, to encompass different national priorities and policy formulations. Across each indicator, the framework defines progress thresholds, which reward detail, ambition and maturity of policies – for example recognising countries that have implemented binding instruments or developed tailored mechanisms over indicative and generic ones.

The framework’s scoring system is based on:

1. Policy progress – whether the country is fully “on track”, showing some progress, or none at all. For each element, a definition is provided to support assessment in the annex.
2. Policy importance – some indicators are priority indicators (indicated in bold below), and receive additional points if they are met, or deductions if they are not met.

When assessing countries’ policy progress, we will consider both country-level policies and any prevailing policies at the supranational-level (e.g. EU level), as well as the contribution of any sub-national instruments.

Structure of the framework:

The framework follows the structure created in Carbon Gap’s “Envisioning a carbon removal strategy for Europe”: three enabling conditions and four pillars. It also adds another enabling condition, namely for countries to develop a national CDR strategy.

Each of the seven elements of the framework is divided into sub-indicators, which represent more granular policy interventions.

Indicators

The eight indicators and 24 sub-indicators are the following, where items in bold are seen as priorities and weighted more heavily in the scoring system:

• Enabling condition 0: Develop a national CDR Strategy
• Enabling condition 1: Set targets
  1. Net neutrality
  2. Intermediate targets
  3. Separate reductions and removals targets
  4. Durable and non-durable CDR targets
  5. Net negative target
• Enabling condition 2: Clarify rules
  5. Safeguards against climate, environment, and social harms: like-for-like principle, other mitigation deterrence rules, biomass sustainability
  6. Certification mechanism in place, including MRV rules
  7. Rules for business-, product-, and value-chain-related climate claims (and rules in national VCMs if relevant)
  8. Defined role of CDR in national/EU GHG inventories and NDCs
  9. Defined role of Article 6 of the Paris Agreement
• Enabling condition 3: Physical infrastructure
  10. Legal framework, covering liability, environmental safety and remediation across CO₂ transport and storage, as well legality of CO₂ transport and of CO₂ storage as per EU CCS Directive and London Protocol+ bilateral agreements.
  11. Quantification of physical storage capacities (geological, mineral, in long-lived products)
  12. Ensuring a safe and efficient permitting process (clear approval timelines, data sharing and transparency, clear responsibilities and liabilities)
  13. Other de-risking measures of CO₂ transport and storage activities (clarifications on ownership of infrastructure, cross-border cooperation, state support)
• Pillar 1: Support RD&I
  14. Identification of potential to deploy within the country’s territory for relevant CDR methods (in terms of physical and economic resources along the whole value chain, including biomass availability, renewable energy and infrastructure availability)
  15. Long-term plan/roadmap for RD&I funding for CDR, including identifying relevant research gaps
  16. Dedicated funding earmarked for relevant CDR methods
• Pillar 2: Introduce dedicated deployment incentives
  17. Deployment incentives in place for relevant more durable CDR methods (ex. subsidies, grants, low-interest loans, tax incentives, CCfDs, etc)
  18. Deployment incentives in place for relevant less durable CDR methods (ex. subsidies, grants, low-interest loans, tax incentives, CCfDs, etc)
• Pillar 3: Secure an enduring policy framework

19. Integration of CDR into national long-term compliance policy (ETS, RTS, CDR obligations)
20. CDR mainstreaming in existing legislation (ex. in public procurement rules, regulatory standards for the built environment, etc))
21. Carbon pricing measures for sectors not covered by an ETS

• Pillar 4: Ensure just governance and deployment
  22. Mechanisms to enable public participation in CDR decision-making
  23. Mechanisms to enable benefit sharing or prevent/address unfair distribution of burdens (which may be present, future, or historical)
  24. Public support for research into social and ethical dimensions of CDR

Assessment of progress based on the framework

Progress against each action are assessed using the following scale:

• On track
• Clear signs of progress
• Early signs of progress
• No signs of progress/wrong direction

Carbon Gap conducted desk research to track progress against each action. The data was collected and inputted into a template document to ensure consistency and comparability. Existing collaborators in various European countries of the Policy Tracker were also engaged to ensure the information was as comprehensive as possible.

Progress against each action was then consolidated into an assessment of the progress within the seven indicators (for ex. Progress on setting targets is on track, but on physical infrastructure, there are only early signs of progress).

The assessment was done using the weighting system shown in the annex. Should the score for one indicator fall between two categories – namely a score ending with 0.5 -, the authors reserve the right to round the final score up or down, based on reasonable justification.