CORSIA, Carbon Removal, and the Geopolitics of European Green Power
A conversation with Lev Gantly, partner at Philip Lee LLP
This is a summary of episode #392 of the Reversing Climate Change podcast. You can listen to the episode on Apple Podcasts, Spotify, YouTube, or wherever you enjoy your shows. You can also listen to the full episode right below this paragraph.
Quick Takeaways
Europe’s flagship climate policies—the ETS, CBAM, and its carbon removal frameworks—are facing unprecedented political pressure from right-wing populism, US withdrawal from climate commitments, and basic guns and butter opportunity cost dynamics.
CORSIA, the international aviation offset scheme from ICAO, faces a critical decision point in June 2026, when the EU must decide whether to maintain the scheme or revert to imposing its own emissions trading system on international flights.
Carbon dioxide removal sits outside NDC (Nationally Determined Contribution) targets globally, which is actually a strategic advantage for CORSIA if the right regulatory carve-out is created.
The durability of any climate policy ultimately depends on creating sticky demand: either mandatory compliance-based purchasing or government procurement, not just subsidies and tax credits.
European Climate Policy Under Siege
When Lev Gantly and I began our conversation, I wanted to understand how much of my own worry about geopolitics eroding climate action was grounded in reality or paranoia. The answer turned out to be more sobering than reassuring.
Lev’s assessment is clear: the political environment has shifted radically in just the last two months. The US withdrawal from climate commitments hasn’t just weakened American climate action—it’s emboldened political figures across Europe to openly challenge the EU’s “flagship pillars” of climate policy. Friedrich Merz in Germany recently suggested the emissions trading system might no longer be “fit for purpose” given the competitiveness pressures Europe now faces. Giorgia Meloni’s government in Italy is moving to circumvent aviation allowances. Hungary has been vocal. The messaging is consistent: climate spending is a luxury Europe can no longer afford.
This isn’t the bluster of marginal figures. These are serious politicians in major economies, and they’re operating from a coherent political logic. Europe is facing low growth projections, must dramatically increase military spending to defend against Russia and shore up NATO without trusting the US, and is watching right-wing populist parties surge in election after election. In this context, asking voters to accept higher energy costs or restrictions in service of a global climate goal starts to look electorally suicidal—especially when the world’s largest emitter just withdrew and is calling the whole thing a scam.
The EU’s response so far has been to propose modest flexibilities: reducing the linear reduction factor from 4.3% to 3.4% (pushing the complete phase-out of free allowances from 2039 to the early 2040s), and extending out the dates when airlines must purchase allowances at full cost. These aren’t dramatic changes, but they signal that the Commission is paying attention to the pressure and beginning to accommodate it.
What makes this moment particularly precarious is timing. Two critical public consultations on climate policy were released in early 2026 and run through May. One concerns integrating carbon removal projects under the EU Carbon Removal Certification Framework into the broader climate architecture. The second addresses how Europe will integrate up to 5% of its 2040 climate target through international credits under the Paris Agreement. And right now, Ireland—Lev’s home and where his firm is headquartered—holds the rotating presidency of the EU Council for the second half of 2026, which is precisely when the most consequential revisions to the ETS will be on the table. This is the hinge moment for European climate policy.
CORSIA: A Scheme in the Eye of a Geopolitical Storm
To understand what’s at stake, you need to understand CORSIA—the Carbon Offsetting and Reduction Scheme for International Aviation. It’s a UN-backed program that most people outside climate policy have never heard of, which makes it simultaneously less politically salient and less protected than the ETS itself.
CORSIA’s history is a lesson in how geopolitical power works. In 2005, the EU created the emissions trading system. In 2008, it expanded the ETS to include aviation—first for flights within the European Economic Area, then immediately expanded to all international aviation touching EU airspace. This meant airlines flying to and from Europe would have to purchase and retire EU emissions allowances, potentially expensive if they operated nowhere else in the system.
The US fought this tooth and nail. The UK (then still in the EU) was taken to court; airlines sued; the European Court of Justice backed the EU, but the backlash was severe. China canceled billions in Airbus orders. The Obama administration passed the ETS Prohibition Act, forbidding US carriers from complying. Rather than escalate further, the EU agreed to step back and let the UN’s International Civil Aviation Organization (ICAO) design a multilateral scheme instead. In 2016, ICAO’s General Assembly adopted CORSIA.
Here’s how CORSIA works: it entered a pilot phase from 2019 to 2022. We’re currently in CP1 (Phase 1), which covers 2023-2026 emissions. CP2 (Phase 2) begins in 2027 and is mandatory for all ICAO contracting states. About 120 countries have voluntarily opted into CP1. Eligible emissions units are due to be retired by January 2028—about eighteen months away.
But here’s the critical decision point: the EU has a rule called “stop the clock” that suspends application of its own ETS to international aviation as long as CORSIA is working. The EU is required by its own 2023 regulations to assess CORSIA’s effectiveness this June—2026—and decide whether to lift “stop the clock” and apply the ETS to international aviation, maintain CORSIA, or pursue a hybrid approach.
The June assessment hinges on two questions: Has participation reached at least 70% of ICAO contracting states? Does CORSIA align with Paris Agreement climate goals?
This timing is toxic. The assessment comes less than twelve months after the US withdrew from climate commitments and abandoned the International Maritime Organization’s deal to regulate emissions from international shipping. It comes when right-wing parties are surging. It comes when European governments are already under pressure to water down climate policy. Meanwhile, NGOs and aviation groups are lobbying hard against CORSIA, citing low credit quality, insufficient participation, uncertain penalties, and slowness in implementation.
Lev’s view is that this is an arbitrary moment to judge a scheme still in its voluntary phase. CORSIA depends heavily on Article 6 of the Paris Agreement, which was only finalized eighteen months ago. Host countries are just now developing the frameworks to implement Article 6. Supply is only now coming online. It would be madness, in his view, to kill CORSIA based on a snapshot of a system barely given a chance to mature. He also notes an equity dimension: asking airlines serving all of humanity to pay European carbon prices to serve a few wealthy travelers seems contrary to the principle of “common but differentiated responsibility” enshrined in the UNFCCC.
But CORSIA has another problem: if the EU kills it and reverts to the ETS, that’s a geopolitical grenade. It would unilaterally apply EU law to international airspace, exactly what triggered the backlash fifteen years ago. The world has changed, but the politics haven’t become simpler.
Why Carbon Removal Needs CORSIA—And Why It Doesn’t Get It Today
Carbon removal has an unusual position in the international climate architecture: it sits almost entirely outside NDC targets.
This is worth understanding deeply. Under the Paris Agreement, countries submit NDCs—Nationally Determined Contributions—that outline how they’ll meet their climate targets. These targets typically include emissions reductions in specific sectors: energy, transport, waste, agriculture, industrial processes. But carbon removal activities like biochar, enhanced weathering, and direct air capture aren’t in most countries’ NDC targets. Why? Because they’re expensive, countries haven’t planned to do them at scale, and they’re not like standard sectoral emissions reductions that governments can require industry to achieve.
This quirk is actually strategically powerful for carbon removal under Article 6 and CORSIA. Here’s why: Article 6 requires host countries to make “corresponding adjustments”—basically, when a country exports carbon credits from a project, it has to add the tons back into its national inventory so nobody double-counts between two countries’ accounting ledgers. The rule exists to prevent a country from exporting millions of tons from a coal plant closure and then also counting those same tons toward its own NDC target.
But carbon removal doesn’t fit this logic. If a country exports biochar credits from Kenya and those activities don’t appear in Kenya’s NDC, why should Kenya have to apply corresponding adjustments? There’s no double-counting risk because Kenya isn’t counting those tons in its own climate target. And an airline buying those credits is making a claim to offset its emissions, not creating an overlap with two national inventories.
Yet CORSIA and Article 6 as currently written don’t make this distinction. They require corresponding adjustments even for carbon removal activities that sit outside NDC targets. This creates an unnecessary friction: host countries worry that any export of carbon removal credits—even from outside their NDC—could somehow jeopardize their ability to meet their targets. So they’re reluctant to authorize exports.
The solution, which Lev and others have been pushing, is to create a regulatory carve-out for “novel CDR” activities that sit provably outside NDC targets. Under this rule, if biochar or enhanced weathering is confirmed to be outside a country’s NDC, it wouldn’t require authorization. Supply would unlock. Countries could issue credits freely because they’d face zero risk of double-claiming.
Think about the demand numbers: CP1 (2023-2026) requires somewhere between 120 and 220 million tons of offsets. CP2 (2027-2035) could require hundreds of millions of tons. If you could unlock carbon removal supply at $100-150 per ton via biochar and other CDR pathways in the Global South, you’d have a massive incentive to scale these activities over the next decade. And because CDR is expensive and permanent, it’s actually a good tool for CORSIA’s integrity.
The problem is that ICAO’s technical advisory board—the folks who set the rules for what counts as an eligible credit—takes direction from ICAO’s contracting states. And the folks who show up at ICAO’s General Assembly are aviation ministers and transport ministers, not climate ministers. So the people who understand Article 6’s architecture and CDR’s potential don’t get a seat at the table. The rule change hasn’t happened.
Lev notes that several CDR-focused standards have recently been approved for CORSIA or are in the window to apply for CP2 approval. But unlocking the supply problem requires political direction from ICAO member states, and that direction needs to come from climate ministers talking to their transport and aviation counterparts. It’s a coordination failure in plain sight.
Where Durable Carbon Removal Policy Actually Exists
The conversation then shifted to a harder question: forget the policy architecture. Where is carbon removal actually getting meaningful, durable policy support today?
Not in the Global South, Lev says bluntly. This is the discouraging part. Host countries are more ready than ever—they’ve just finalized Article 6 implementation frameworks, written sophisticated carbon market laws, and are actively seeking carbon finance. But demand-side commitment from the Global North just isn’t materializing at scale.
In North America, the approach has been carrots: tax credits and grants. These enable innovation and small pilots, which is valuable. But they’re not sticky. A tax credit that depends on Congress or the IRA can be reversed with a political shift. They don’t create mandatory demand.
Europe is where you see something more durable emerging.
Spain and Germany have both announced budget commitments to carbon removal. Ireland has been in active conversation with government departments about creating a regulatory framework for carbon farming, with a focus on biochar. There’s genuine interest in how biochar could help Ireland meet its effort-sharing regulation targets (the portions of the EU climate goal that don’t fall under the ETS).
And then there’s the EU CDR Buyers Club, a nascent initiative that remains somewhat opaque about who the members are and what it will look like, but represents an attempt to aggregate buyer demand.
The most interesting opportunity Lev describes is Ireland’s situation. Ireland is behind on its effort-sharing targets and could face fines between 4 and 20 billion euros if it doesn’t hit its goals. The effort-sharing regulation covers waste, agriculture, transport, and land-use changes—sectors where biochar deployment could help. If Ireland legislates that biochar counts toward meeting those targets, the government could procure biochar and spread it on farmland, and it would reduce Ireland’s compliance costs. That’s a genuine, durable incentive: if you have to choose between paying a billion-euro fine and paying for carbon removal, you pay for carbon removal.
The catch is political palatability. Farmers are under margin pressure. You can’t mandate carbon removal on farms without making it affordable or profitable for farmers. So the policy has to look like a subsidy or benefit to farming, not a climate mandate. That requires careful design. But it’s the kind of policy that could survive a change in government because it’s solving a real problem (meeting climate targets and avoiding fines), not just a symbolic one.
The Durability Test: Who Actually Buys This?
This brought us to the question that Lev says defines his approach to every new client conversation: Who’s going to buy this?
Not eventually. Not theoretically. Not if the subsidies last forever. But actually buy, sustainably, over twenty or thirty years?
The venture capital and startup world around carbon removal often sketches an answer that looks like: tech gets cheaper, voluntary corporate demand grows, governments eventually require it. But that’s a story that works if policy doesn’t shift and if corporate commitments don’t evaporate during a recession. Lev’s experience suggests those are big ifs.
Sticky demand comes from one of two sources: either mandatory compliance-based demand (you have to buy to meet a regulatory target, or you face fines) or government procurement (the government has to buy to meet a target, and it’s cheaper than alternatives).
The tax-credit approach is useful for building supply and testing technologies. But it’s the opposite of sticky. Every change in administration is a threat. Every budget cycle is a battle.
The Ireland effort-sharing approach, if executed, would be sticky. Fines are real. Meeting them with biochar is cheaper than paying them. A government department that deploys biochar has a budget line to defend, not a discretionary program. A politician explaining why they cut biochar spending can be asked: “So you want to pay a billion-euro fine instead?”
This is also why integrating carbon removal into the ETS would be powerful. If engineered CDR like direct air capture could retire ETS allowances, then demand for those removals becomes a function of the ETS carbon price. As the ETS price rises (which is the whole point of the system), demand for CDR rises too. You’ve created a durable, price-responsive demand curve.
The challenge is political: introducing CDR into the ETS requires acknowledging that the ETS alone won’t get Europe to its 2040 target, and that’s politically awkward when right-wing parties are already claiming the ETS is too much. But it might be the path to the most durable demand.
The Parallel Universe Problem
Toward the end of our conversation, Lev raised a question that haunted the entire exchange: Are we living in a parallel universe?
Scientists say we need removals at the scale of the fossil fuel industry’s emissions. We need massive deployments of carbon removal to deal with overshoot. The data is clear. But voters are worried about grocery bills and heating costs. Governments are cutting military slack and scrambling to defend themselves. Right-wing parties are surging. And the world leader is withdrawing from climate commitment entirely.
How do you bridge that gap?
Lev didn’t have an easy answer, and neither did I. But the conversation suggested something: maybe the answer isn’t to convince voters that climate is more important than the kitchen table. Maybe it’s to show that climate solutions—biochar for soil health, carbon removal for meeting compliance costs—can solve kitchen-table problems first, and climate second. Policies that make farming more profitable (biochar), reduce the risk of billion-euro fines (carbon removal), or lower energy costs (renewable energy procurement) survive political shifts because they have local constituencies that benefit.
The policies that survive are the ones people want because they solve real, local problems. The policies that evaporate are the ones that ask people to sacrifice for a distant future they’re skeptical about, especially when the world leader says the whole thing is a scam.
The narrow window for creating those policy foundations is closing. Lev thinks Europe will probably maintain some version of CORSIA in June. He hopes he’s right. But the margin is narrower than it was a year ago, and narrowing still.
Full Transcript
Ross Kenyon: Lev, since we started talking, the world has changed quite a bit. So where should we even start with climate policy? What should we even talk about today?
Lev Gantly: Yeah, I mean, a lot has changed. We obviously have quite a number of conflicts, and I think one of the things that I’m most disappointed by, although perhaps not surprised, is how quickly the various tensions—not least in part imposed by the current US administration—have spilled over into Europe. And how all of a sudden we have “brave” politicians in certain member states taking what I would consider, and I think others would consider, fairly aggressive measures in the name of competitiveness and geopolitical climate to take “almighty cracks at” the flagship pillars of EU climate policy. That’s one of the knock-on consequences I’m sensing in my bones in the climate world over the past couple of months.
But it does feel limiting to talk about climate generally in light of what’s going on. I’m not an alarmist, but I do feel a civic duty to keep up with what’s going on. It is obviously concerning.
How do you feel, Ross? What should we talk about? I mean, there’s some good news we can get into.
Ross Kenyon: Yeah, I think we should try to take an accurate pulse on world climate politics. I think the canonical view right now is that even though the US has pulled out of Paris and the UNFCCC, and the IMO deal didn’t happen because of the US, various things we were all hoping for are being carried on in places like Japan, Germany, the EU broadly, and the UK.
While I think that’s true, I also think the world is distracted by geopolitics and war. And there’s right-wing populism that’s electorally ascendant. The Japanese parliament has shifted far to the right. I’m watching Germany with the AfD gaining ground. And when Europe is projecting low growth rates and spending a lot on climate or things that feel altruistically like supporting Ukraine, that’s a recipe for right-wing populism.
I would not bet on CBAM remaining strong in Europe. I’m not holding my breath on the ETS. And I hate that I’m saying this because it’s all terrible news for us. But I also think we have to understand the probabilities we’re facing. How much of this is me being paranoid? And how much of this are you very concerned with?
Lev Gantly: I think you’re right to be worried. Some nights I go to bed worried about those things. Other nights I think about the other side, and I think there’s some sense left in the universe. I try to keep myself on that side of the equilibrium as much as I can.
But let me zoom in on some of the things you mentioned. Friedrich Mertz, just a few weeks ago at a green industry conference in Europe, was one of the big voices taking a go at the emissions trading system. He was effectively saying something like: if this is no longer fit for purpose within the current competitiveness landscape we’re in, we might need to re-engineer this policy or look at something else completely.
He paired back on that a couple of days later when challenged. But there have been other moves. Georgia Meloni has a new energy policy coming out in Italy, effectively trying to circumvent emissions allowances that power producers would have to buy and retire. There’s a question about whether that unilateral move would be challengable under EU law.
There’s been noise about how to appease these utterances against the ETS. The obvious candidates are lowering the linear reduction factor and extending the dates for the phase-out of free allowances. The linear reduction factor is currently 4.3% and goes up to 4.4% in 2028, which leads to zero allowances in 2039. The suggestion from people like Peter Lisa is to reduce it from 4.3% to 3.4%, which would mean zero allowances in the early 2040s instead of 2039.
There are two big public consultations out right now that run through May. One is about integrating carbon removal certification framework projects with the climate architecture. The second is about how to integrate up to 5% of the 2040 target through international credits under the Paris Agreement. These consultations are really important for anyone who cares about keeping Europe’s climate goals on track.
Interestingly, little old Ireland holds the presidency of the European Council in the second half of this year—exactly when the greatest revisions to the ETS will be on the table. We may end up submitting documents to ministers laying out the landscape of different directions things might go around the ETS and carbon removal integration, not just in Ireland but across Europe.
Ross Kenyon: Did you put in a letter on behalf of Philip Lee or yourself?
Lev Gantly: We have to be careful from a lobbying perspective because we’re a regulated law firm registered with EU authorities as an entity that could engage in lobbying activities. We have to make disclosures. We haven’t planned on submitting directly. But the International Admissions Trading Association, of which we’re a member, is submitting responses, and we’re feeding into what they’re saying.
Ross Kenyon: Tell me about CORSIA. Is it something that’s good for carbon removal if it survives intact? And is it likely to survive intact?
Lev Gantly: I’m happy to explain CORSIA. Let me answer the question of CORSIA and what’s happening first, then we can get into its relevance for carbon removal.
Why do we have this scheme for emissions in international aviation? Back when the EU was bold, in that galaxy far, far away, the EU set up the ETS in 2005. In 2008, it updated it to include a requirement on airlines to retire emissions allowances for intra-EEA flights. They then announced they were immediately extending it to international aviation—flights coming in and out of the European Union.
The UK government was brought to court, basically for implementing the CORSIA regulation into UK law. There was a court case taken by airlines and related groups suing the UK government for applying EU law extraterritorially. The European Court of Justice ruled the EU was right, but there was a pretty negative reaction. Chinese carriers canceled over $10 billion in Airbus orders in retaliation. The Obama administration passed the ETS Prohibition Act, forbidding US carriers from complying.
At that point, the Europeans said, “Okay, we’ve won the case, but we’ll play good global citizens and let ICAO come up with a multilateral scheme that creates a level playing field for airlines operating in international airspace.”
In 2016, ICAO’s General Assembly introduced CORSIA. We had a lame-duck pilot phase from 2019 to 2022. We’re currently in CP1 (CORSIA Phase 1), which covers 2023, 2024, 2025, and 2026 emissions. We’re still in CP1, which is voluntary. But about 120 contracting states of the Chicago Convention have opted in to voluntary participation.
This year, 2026, is the last year that needs to be monitored for CP1. The retirement of eligible emissions units is January 2028—about eighteen months away. Next year, 2027, is the start of CP2, which is mandatory. All contracting states have to comply.
What’s really interesting mechanically is that you have this UN scheme called CORSIA running in the background, and the EU has a rule that stops the clock—the application of the ETS to international aviation stops while CORSIA is operating. But the EU already pushed back the assessment of CORSIA’s effectiveness twice. The point in time at which the EU must definitively and conclusively review CORSIA’s effectiveness is this June.
The Commission has to produce a report explaining how effective it thinks CORSIA is by looking at two particular points: whether participation is at least 70% of contracting states or covers at least 70% of overall volume of international flights, and whether CORSIA has been strengthened to be in line with Paris Agreement goals.
Depending on how this report turns out, the Commission’s proposal will be accompanied by an amending regulation that will do one of two things: it’ll either stop the clock and apply the ETS to international aviation, or it’ll say CORSIA is working quite well and we need to give it time to breathe, or adopt some hybrid approach.
All of this is coming this June, after we’ve had US withdrawal from climate commitments and the IMO deal. We’re seeing the spillover effects we talked about in relation to the overall sentiment on the ETS in Europe. But CORSIA is something that US airlines pushed for. It really happened because of US airlines. So it would be really interesting to see what Europe does now, because historically they didn’t want it.
There are certainly plenty of lobby groups, NGOs saying CORSIA doesn’t work: credits are low quality, not enough of them, low integrity, not enough states participating, not enough states have transposed CORSIA into domestic laws, penalties are uncertain.
My own view is that it would be crazy at this point for the EU to abandon CORSIA because it’s still effectively in the middle of a voluntary phase. It relies on Article 6 of the Paris Agreement, which was only concluded a year and a half ago in Baku. It’s just now, in the last twelve months, that host countries are getting to grips with how Article 6 is supposed to work. Supply of credits is only now coming online. It’s just a terrible time for the EU to make a decision around this.
I also think telling airlines that they have to pay European carbon prices is not particularly equitable. It ignores the principle of common differentiated responsibility enshrined in the UNFCCC.
Ross Kenyon: I hope so. Although I am spooked by seeing things like the National Rally predicted to maybe win a major French election. I’m concerned because I don’t want to avoid standing up for climate, but there are ways of doing it that antagonize a stressed Europe that has to commit much more GDP to defending itself and no longer trusts the US with NATO. They also have to spend on climate, and growth rates are pretty small.
Climate politics are a bit of a loser electorally unless they’re framed in the right ways. CORSIA might catch the national pension as something to rail against, rather than the ETS, which is more well-known.
Lev Gantly: One quick point on competency: European airlines like Air Lingus, Air France, KLM will react. This year, 2026, is the first year there are no free allowances for the aviation sector. Previously, there was free allocation until last year, when they phased out 50%. So there’s auctioning for 50% for airlines. By April 2027, European airlines will have to have purchased and retired emissions allowances for their full exposure for the first time. That’s going to be expensive and weigh heavily on their balance sheet.
If you then turn around and say they have to pay the same price for international emissions, the reaction will be predictable from CEOs and CFOs.
Ross Kenyon: I’m not worried about them. I’m worried about consumers.
Lev Gantly: But that’s it—it’s a pass-through. All of a sudden, you’re not going to be able to visit cousins in Austria if you’re living in France. It’s going to be a lot more expensive over the next five or six years.
Ross Kenyon: Let me ask about CDR’s potential to interact with CORSIA.
Lev Gantly: The challenge with unlocking supply of credits into CORSIA is linked with challenges in implementing Article 6 at the host country level. In order to determine if you as a country can authorize the export of carbon for use under CORSIA, you have to determine that your NDC—your Nationally Determined Contribution submitted to the UN—is sufficiently ambitious. You have to have headroom to export tons from a mitigation activity and a project class for which you’ve made expressly clear you’re seeking external finance.
What’s interesting about CDR is that CDR sits outside NDC targets. As far as I’m aware, I haven’t seen any NDC with references to CDR within the NDC targets. There are long-term goals under the Paris Agreement that stretch 10, 15, 20 years, and there are some references to carbon capture and sequestration, but those aren’t the same as NDC targets.
For all intents and purposes, biochar and enhanced weathering, direct air capture—they are not currently within Global South country targets. Because they’re outside those targets, it should be a no-brainer that countries could authorize and export those tons freely because they don’t jeopardize the achievement of an NDC target.
The problem with CORSIA at the moment is that it married Article 6 too much—maybe 70 or 80%, not 100%. The Article 6 rules basically say you as the host country, once you’ve authorized the mitigation activity, have to correspondingly adjust your emissions balance or your national inventory accounting. You arithmetically add the tons to your emissions balance, irrespective of whether the authorized activities are inside or outside your NDC.
The reason that rule exists is to prevent double counting between two national greenhouse gas inventories. But CORSIA—which operates over international airspace—is not a national greenhouse gas inventory. CORSIA is solving for a different problem: preventing double claiming between an airline and a country, which is not the same as counting between two national inventories.
If an airline is buying biochar credits from Kenya, and biochar sits outside Kenya’s NDC, why should Kenya have to authorize this and apply corresponding adjustments? It’s not in the NDC target, so there’s no double-counting risk between two greenhouse gas inventories. There’s just a claim by an airline for emissions in international airspace.
This has come up increasingly in conversations because there’s fear that pressure at host country level around jeopardizing NDCs through over-export could constrain supply going into CORSIA. Think about the demand numbers: for CP1, overall demand is somewhere between 120 and 220 million tons. CP2 runs from 2027 through 2035 and could demand hundreds of millions of tons.
Could we scale carbon removal in the Global South if we created a demand pool through CORSIA? If there was a rule change from ICAO saying that for a narrow category of activity types that sit outside NDC targets—what we call “novel CDR”—we don’t need authorizations because there’s no fear of double claiming?
You could unlock significant demand and help these activities scale over the next decade. We’ve been trying to push that narrative with relevant people in the right rooms, and what we’ve been told is that it’s a great point that needs to be pushed at ICAO’s General Assembly by member states.
The problem is that you have aviation ministers and transport ministers showing up to ICAO, not climate ministers. So these ministries need to start talking to each other if we want to unlock the supply.
Even if we cut the cord and say, “Don’t need authorizations for novel CDR pathways,” you’re still going to get into a pricing debate. Right now, we’re talking maybe $100 to $150 for biochar in Kenya versus $200-300 for a clean cooking ton. But think about it this way: if Article 6 works, the availability of low-hanging fruit mitigation should disappear because NDCs are supposed to ratchet up in ambition. You keep all the low-hanging fruit for yourself and export higher-hanging, more ambitious fruit that you can’t afford to pay for yourself.
If the whole thing starts to work as intended, we could create quite a lot of interesting demand. Isometric was recently approved for CORSIA, and I think some of the other CDR-focused standards have just recently or are about to submit applications for approval. I know there’s a window for application for some CDR standards right now that might be closing this week.
Ross Kenyon: It’s very useful to understand how all these terms interact and the potential overlaps and gaps. Thanks for clarifying that. Are there places where you are seeing good, durable policy support for carbon removal right now?
Lev Gantly: Not in the Global South, I would say. I’m just not seeing it. It doesn’t mean it’s not happening. One interesting thing happening is that we’re starting to see interesting things even in places like Ireland.
But one positive thing—and it’s unfortunate because Article 6 negotiations concluded eighteen months ago—is that a lot of host countries are really ramping up their readiness for policy support, not just for CDR but for other types of mitigation activities and renewable energy and clean cooking. They’re putting in place pretty sophisticated climate laws and carbon market frameworks across Sub-Saharan Africa and central Asia. We work with local lawyers to understand these laws as we advise our clients. We’re pleasantly surprised by the detail and work that goes into creating those frameworks. It’s unfortunate we don’t see specific references to CDR activities yet, but I suspect it’s a matter of time.
In terms of the CDR landscape in Europe, things seem to be happening. Reports are coming out of Spain. Germany has announced a budget to commit to CDR activities. In Ireland, we’ve had good conversations with several government departments around potentially creating a framework here for carbon farming, with a real focus on biochar. There’s the EU CDR Buyers Club that’s in formation.
Ross Kenyon: What’s your take on what makes a good CDR policy right now?
Lev Gantly: I’m looking for policies that are likely to survive changes in polity, depending on which political party is in office. Different countries that previously supported carbon removal—I’m wondering if that’s changing. Canada has historically been supportive, and Mark Carney seems personally supportive. But Canada is facing very high cost of living, spending much more on military, and trying to cut trade deals. Their economy is going through structural changes. To what degree will climate policy remain a priority in Canadian politics?
Ross Kenyon: My high-level take on carbon removal policy in places like Canada and the US over the last couple of years is that there have been quite a few carrots in terms of tax incentives and grants. That’s all great because it allows people to innovate and test small-scale pilot projects. But in terms of durability and stickiness, that requires people to buy.
My question is always when I get new clients doing interesting things: this is brilliant, you’re great, I love it, but who’s going to buy this? Who’s going to buy the tons? This is really expensive. I want you to succeed, but who’s buying this year? Who’s buying in five years? Who’s buying twenty years from now?
This is about creating mandatory compliance-based demand on either polluters or government departments. One of the things we’re thinking about for Ireland, for example, is the effort sharing regulation and the new LULUCF regulation. Ireland’s not the only member state; Spain, France, Germany and many others are behind. They’ll have to pay billions in fines if they don’t hit their targets—in Ireland, the range is four to twenty billion euros.
There are questions about whether those fines just move from one pocket to another. But how do we actually help Ireland meet its climate targets? The effort sharing regulation covers waste, agriculture, transport—things not in the ETS. There are a lot of farms in Ireland with grazing, dairy, beef production.
If we wrote a policy that required farmers to buy biochar and spread it across their land, that enhances soil fertility and sequestration, the government could pay for that. That would act as a subsidy to farmers. It needs to be thought through more carefully in government, and we might end up supporting government in mapping this out.
But we have to use levers that don’t agitate folks that are already struggling. Farmer margins are tight. We’re asking people to decarbonize, but people are just trying to make ends meet. It has to be palatable. Who’s going to buy? Is Ireland going to legislate for corporates that are polluting to buy these tons? Or will the Irish department of agriculture or climate change buy these tons and count them in Ireland’s national ledger, which sits within the EU target? Otherwise, we’re going to have to pay fines. Either do good stuff and help farmers decarbonize, or pay fines.
The integration into the ETS is the other piece. We talked earlier about reducing the linear reduction factor and pushing out the date for availability of free allocation. There’s obviously talk of introducing DACs and BECs into the ETS because there’s obsession with permanence. How about buying biochar?
Ross Kenyon: ETS delay might be a really smart example of surviving the political moment. It’s no longer an urgent political issue because the biting point is farther away. The next election cycle deals with it. That might give breathing room, even though it’s painful, like losing years and the curve gets steeper. I like the suggestion for farm inputs.
I was also trying to think: did you follow the attempts to limit liability for glyphosate with regard to Bayer and Trump? Are you too busy being a lawyer?
Lev Gantly: I do know a lot of my nighttime is consumed by following what’s happening in the US, but there’s a cap on that, Ross.
Ross Kenyon: Well, there’s a lot of tension between MAGA and MAHA parts of the Republican party right now—”Make America Healthy Again,” the Robert F. Kennedy crew. They’re obviously no great fan of pesticides and would like things to be more regenerative and less toxic. There’s room for biochar in there for sure. That’s a really cool crossover point that could be bipartisan.
Bayer’s trying to limit their liability for the never-ending glyphosate lawsuits. The glyphosate side is winning, and the MAHA side feels betrayed. It was a smart pick to make Kennedy health secretary for the election, but as it goes on, you realize that commitment wasn’t equally shared.
I’m wondering if the politics are different in Ireland such that a more regenerative farming model might not face the same uphill battle. Everyone in America likes Kerrygold butter. I’d love to see Kerrygold that said “made with biochar” on the box.
But agribusiness is very powerful. Synthetic fertilizers have diminishing returns and can’t be applied forever without soil harm. Consumers want to switch. But this all cuts against cost of living too. People care less about a little biochar logo when feeding your family is hard and a hundred dollars of groceries used to be four bags several years ago.
Maybe none of this matters as long as bread and butter issues at the kitchen table are top of mind.
Lev Gantly: They are. Thanks for that, Ross. When you say bread and butter issues being top of mind, are we living in a parallel universe?
You and I—I know you do, I know I do—spend most of our time thinking about what scientists say. Scientists say we need removals, we need a lot of removals, removals at the scale of the fossil fuel industry’s emissions. That’s the scale we need to get to.
How do we bridge the gap between where most folks feel what’s important and what stresses us out in the climate and CDR community? It’s a pretty colossal gap.
I’m an optimist, though. I believe that we need enough like-minded, right-minded politicians. If you had your pick, and I don’t know what you think of Governor Newsom in terms of 2028, but let’s say he did come in—he’s responsible for some fairly interesting policies in California, a backer of cap-and-trade there. What would you like to see on a global stage, domestically, and at the federal level? The US is such a big tone-setter for what happens to the rest of the world.
Ross Kenyon: I think the format of this question is fascinating because I haven’t even thought that far ahead. The news cycle has been so much quicker. People are thinking toward the midterms later this year.
I keep seeing people talking about a Newsom candidacy, but he’s also highly polarizing. Much of the country hates his guts. People blame him for San Francisco. He said supportive things about trans athletes that a lot of the country finds important, and he’s taken courageous stands.
We’ve seen people do well, like the Hochul win in New York. Democrats talk left in primaries but govern from the center and run from the center in generals because most of the country doesn’t like socialism rhetoric.
Even if Newsom made it, I’m curious how much he could do. Political capital brought into the White House—are you able to quickly rejoin Paris and the UNFCCC and restart these things? Or are there legal or Supreme Court decisions that make it really hard to dive back in?
It’s also possible this causes a backlash in the opposite direction. Even if Democrats took the presidency and had a good midterm showing, they might control the house and maybe the Senate, but it’s probably even. And Presidents with a house majority usually get hit pretty hard in midterms.
I don’t think far ahead. Even if you had a committed president, can they easily rejoin climate multilateralism?
Lev Gantly: I’ll caveat this by saying I’m not a US lawyer or constitutional lawyer, so these are technical points. I think there are qualified professors from Stanford and other places that have written about this. There’s some suggestion that because he executive ordered his way out of the UNFCCC, it doesn’t need congressional approval to come back in. The next president can just executive order back in. Apparently the same applies with Paris.
But what does it mean to be party to the Paris Agreement? Why does it matter if the US is party to the UNFCCC or Paris Agreement? I think the most important thing is that the US is the first or second largest polluter globally in terms of emissions. The Paris Agreement brings together over 190 countries and all their ledgers. Everybody starts bean-counting to figure out global emissions and global targets and how much we need to enhance targets every five years to hit the Paris temperature goals.
But right now there’s a big gaping goal in the Paris Agreement target of 1.5 degrees. How could you try to meet that target when the biggest emitter is no longer counting the beans?
Knowing the US plan from a carbon markets and CDR perspective would be slightly more granular, but just on a macro level, it’s really important to have everyone’s counts. We can’t work out where we are without the counts.
Ross Kenyon: Can I jump in on this one point specifically? This spooks me very badly. The US not being part of the game theory: we’re probably not going to achieve climate targets without US participation. Voters are going to be smart enough to be like, if the US isn’t doing this and they’re the world leader and biggest polluter, we’re probably not going to hit our targets. Why are we spending tax dollars on something that won’t ultimately stop this?
When the world was broadly committed, holdout countries could be wagged at. But momentum switches without the US. The politics become: why are we still doing this if the US isn’t? That part really scares me. And I feel like people don’t talk about how much US leadership matters because it’s easy to hate on the US for being a world leader. But having the world leader say this is not a thing, it’s a scam, and we’re not doing it anymore—that’s extremely disruptive everywhere.
Lev Gantly: Yeah, Ross. What breaks my heart is all the work we’re doing in Global South jurisdictions on all manner of projects—the purpose of which is to serve basic human needs: clean cooking, access to clean water.
A lot of these countries are just getting to grips with the Paris rule book for carbon markets, which closed eighteen months ago. It’s really only in the last eighteen months that countries have started writing elegant regulation frameworks saying, “We’re here, we’re ready for carbon finance, we’re ready for UNFCCC. Come sort out our clean cooking problem because 1.2 billion people still cook on open fires.”
These activities are expensive to implement at scale. Finance is needed. A lot form conditional parts of NDCs. So they’re exportable from a carbon finance perspective.
What I find quite upsetting is that we’re at a point where host countries are ready to engage with global carbon markets through Article 6 or through CBAM. But where’s the buying power? Where’s the buying?
Likewise with CORSIA, you’ve got China, Japan oddly building up ends through Joint Implementation mechanisms, bilateral deals. We were hoping for big buying countries to come in and buy these tons and have them transfer, helping buying countries meet their targets.
With the US dropping, not participating in Article 6, not being in Paris, it sends the message you talked about, and the influence of that on other Global North players. Maybe they don’t bother helping Global South folks. Maybe they can’t be bothered doing their own thing.
Or maybe it’ll have the counter effect. Maybe they’ll say, the US is out, maybe we won’t spend $100, $200, $300 per ton on marginal cost of abatement in a particular sector. Maybe it’s actually better for us to buy from the Global South at 5%.
But 5% in Europe isn’t a lot. Right? Maybe they’ll change it again. I don’t know. But the US tends to set the tone for overall sentiment on climate. And I do dream about 2028, Ross. I’m not in the US, but I’m keeping an eye on sentiment around the midterms. I do try and look forward to figure out what happens after he’s gone—assuming he’s gone.
Ross Kenyon: Lev, thank you for joining me for the impossible task of one, explaining CORSIA and its history. Super hard. Speculating on possible roads for carbon removal to enter CORSIA. And then also just grimly looking into the state of world politics as pertains to climate and so much else. Thank you for going on this wild, multifaceted ride with me.
Lev Gantly: It’s been fun. Thanks for having me.
