Standards-based, and solution agnostic.

Standards-based, and solution agnostic.

Successful, impactful CDR procurement must be rooted in a set of clear principles and standards that guide CDR investment and ensure accurate measurement and accounting. The task of establishing the latter will be the purview of the Irish Government, but will be informed by an analysis of established and emerging global best practices that are already being advanced by private and public sector actors.

Points

Ensure 1. additionality, 2. minimum CO2 storage durability/permanence, and 3. verifiability of removals and storage in accordance with established best practices approved by the implementing government authority.

I would reconsider additionality as an acceptance criteria. For me it’s an unnecessary barrier to entry at a time we’re trying to scale CDR. It can be an expensive and time consuming verification requirement too. There is also no single standard or definition of additionality, mostly because the baseline is not observable/verifiable. Standards based should be more about solution agnostic, fact-based evidence, ex-post verification and durable sequestration.

Agree that quality should be primary concern - additionality, permanence, scalability etc Adding geographic barriers essentially makes the approach not technology agnostic.

Use durability instead of permanence as it’s less absolute and recognises the temporal variability of a diverse range of CDR solutions the proposal is looking to support. Next step is how to define durability…think about normalising the time horizon to a fixed amount of time e.g. C-Capsule we standardise to 100 years. 5 years is too short relative to the problem and 1,000 years is too long to assess individual risk factors.

On top of a fixed time horizon you may want to explore a threshold on likelihood of achieving that durability of sequestration e.g. 95%- although that may hinder acceptance of NBS and soil sequestration projects.

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