Forestry Direct Air Carbon Capture and proven long term storage (Forestry DAC): Some common questions

Why Direct Air Carbon Capture and Storage (DAC)?

Why forestry and not other DAC?

The future of the high integrity voluntary carbon market (VCM) is storage until at least the IPCC end goal of 2100. If that cannot be proven what is sold may be of little practical use for an emitter.

When we refer to DAC this implies not only carbon capture but also proven storage of that capture. In some ways carbon capture and storage (CCS) would be an equally good label, excepting when used in relation to mechanical CCS it implies capturing GHG emissions at their source and then storing them.

Mechanical direct air capture does what nature has long perfected. In general terms the process of photosynthesis involves trees inhaling CO2 during the night, breaking the bond between C and O2 and exhaling the O2 back into the atmosphere during the day, keeping the carbon as a building block.

Every effort helps. The planet needs both natural and mechanical DAC (and other CCS) to achieve IPCC goals, in addition of course to reducing GHG emissions in the first place. The key for nature-based DAC (photosynthesis) is proving there will be no reversals before 2100 because evidence shows earlier reversals are not neutral but increase GHG concentrations in the atmosphere, due in part to slowing rates of absorption as concentrations of GHG increase.

One advantage of forestry DAC is nature provides for free what it costs to achieve mechanical DAC (US$250-$600/tonne), or mechanical CCS (US$150 on average, but limited to static emitters). Of course, forestry is not free, because it involves land and management costs, as well as lost opportunity costs of selling lumber. But it is much cheaper than mechanical DAC and CCS.

Proven forestry DAC credits (tonne CO2 proven sequestered until at least 2100) are unlikely to be more than 1% of the size of the VCM in 2050, at least according to some credible estimates of the latter. In that context proven forestry DAC and storage is a useful part of a spread of CDR and storage methodologies that a GHG emitter can rely on to make GHG Statements.

Why PFS Certification Ltd?

PFS has published a standard (PFS Standard Part II version 1) “Best practice for proof forestry CO2 captured remains stored until 2100”, validated to ISO 14064-2 by SGS.

What the PFS Standard does, as a world first, is establish a credible science-based and silviculture focussed standard for ensuring forestry carbon dioxide removals (CDR) are not reversed in the critical period from now to 2100.

Standards are important because emitters want, and increasingly are obliged, to make GHG Statements about how they are countering the effect their processes have on the planet. Unless GHG statements can be defended emitters will increasingly be penalised for making them.

ISO14064 has always been important, which is why most published CDR and REDD Standards hopefully state they “follow” ISO, without being validated to it. It has become even more important after COP29. COP29, together with the UNFCCC’s Supervisory Body (SB), agreed on a process for establishing methodologies for transfers of carbon stocks between countries (ITMO). The SB has already published a draft addressing carbon reversals (SB014-A06), which is exactly what PFS “Best practice for proof forestry CO2 captured remains stored until 2100” seeks to do, and significantly the SB has adopted the principles of ISO 14064-2 (e.g., A6.4-STAN-AC-004) to which PFS Standard has already been validated.

PFS is the only verifier that offers to verify forestry DAC and proven storage in New Zealand against an ISO validated standard (ISO 14064-2) and have it then verified by a third party VVB, SGS.

Why proving GHG statements is important.

GHG emitters are prepared to contribute to CDR projects either to allow them to make GHG Statements about how they are attempting to remediate the effect of their past, present or future GHG emissions on the planet, or for an unrelated purpose (such as supporting biodiversity). PFS is supportive of biodiversity and encourages it after 2100, but it does not help the planet meet 2100 IPCC goals unless species selection allows the fastest possible sequestration before then. If not, efforts at achieving biodiversity before 2100 will likely retard, not assist, the need to rapidly slow and then halt rising global temperatures, because more suitable alternatives are available.

In addition to making GHG Statements about how they are attempting to remediate the effect of their emissions on the planet, GHG emitters are at the same time coming under pressure from supply chain partners, activist directors and shareholders, bankers, insurers, and the like to show they are taking emissions remediation seriously. Sometimes those pressures will require GHG statements be made. If so, they will be subject to the same constraints as GHG Statements that an emitter choses, or is required, to make, which are addressed below.

Emitters can often choose whether to make GHG statements, e.g., for marketing (“green” sells). These are public statements. Increasingly, and at the same time, emitters are being required to make GHG statements in their financial reporting documents, and in market statements and offerings. These may be public or semi-public. As already noted, private GHG statements may be required by supply chain partners, bankers, or the like. But whether public, semi-public, or private, GHG statements cannot be misleading.

The trend, already in some existing consumer protection and financial markets participation rules, is to penalise emitters who make express or implied GHG Statements about how their actions are helping the planet if that cannot be proved. This is and will be enforced by either statutory regulators or by private suit where breach of reporting, consumer protection and financial markets participation rules will be a necessary addition to any statement of claim. “Greenwashing” lawsuits are here and will increase. Emitters will find it increasingly difficult to treat awards against them as a management cost as non-monetary legislative penalties are tightened.

Further, “helping the planet” will be tested by what can be more effectively done at the same cost or with no harmful externalities, and by whether a touted practice leads to domestic or international leakage (meaning emissions that are reduced, removed or avoided at one site are increased at another).

Already cherished corporate strategies are being directly threatened. For example, in the Australian Federal Court an emitter is being challenged to prove “offsets” (and by implication “in-sets”), carbon avoidance projects and short-term reversable CDR projects help the planet. The result is likely to be that GHG emitters will only have a safe harbour for GHG Statements they wish to make if they can prove storage of carbon until at least 2100 and clearly state that, assuming they can prove all other necessary conditions exist, such as additionality.

This may well lead to emitters having to make honest and straightforward statements such as “we have been responsible for capturing and provably storing xx tonnes CO2 until at least 2100 (and we can prove this helps the planet achieve IPCC 2100 goals)”.

Making such a statement will require proof of storage and that will require a CA or validated compliance with SMB014-A06. PFS Standard Part II version 1 “Best practice for proof forestry CO2 captured remains stored until 2100”, validated to ISO 14064-2 by SGS, does that. So too will mechanical DAC and CCS, and some biochar, but forestry DAC does it much more efficiently and cheaply.

Other than the above processes, no other standards or methodologies available today adequately prove long-term storage, or if they can, after over crediting is discounted and appropriate reversal buffer accounts are established, at anywhere near the sequestration/cost ratio the PFS Standard can achieve.

What consumers and their lawyers are now realising is that while GHG statements can be controlled by climate change regulations, they are also controlled by regulations that either predate or are not directly related to climate change, such as consumer protection laws against misleading statements. Proof of compliance with one does not immunise the need to comply with the other.

Because the tonnes of CDR and proven storage which will be available to the VCM market is unlikely to ever be sufficient to meet the need for high quality credits that will comply with both climate change and other unrelated regulations, even taking into account projects which reduce GHG emissions, the price of proven long-term storage tonnes will increase.

Additionally, PFS Standard Part III Version 1 “Best practice for legal risk assessment for greenhouse gas statements (GHG Statements) implying long term storage of CO2 removals after tonnes CO2 sequestration forestry removals verified under Part II or otherwise complying with PFS-IB-018” allows GHG emitters to test GHG statements are compliant with relevant regulations before making them, as a defence to later lawsuits.