Response to Article 6 Paragraph 4
9 November, 2022 | COP27, Sharm el-Sheikh, Egypt

The Women and Gender Constituency is highly concerned about the content and process of the Article 6.4 recommendation document prepared by the Supervisory Body (SB) and sent for consideration and adoption at COP27. 

The document produced did not respect the inclusive, consultative process with NGOs. It was finalized in a rush and late in the night to meet one of its mandates before the COP officially started, with only a few observers in the room. 

In terms of content, the definition of carbon removals (the various options under development for sucking carbon out of the atmosphere) is so broad that it includes almost everything, from marine geoengineering to monocropped tree plantations. As it stands now and with no defined methodology, it will most likely incentivize projects with huge risks and impacts for Indigenous Peoples, women and frontline communities. Offering credits for such a wide variety of problematic projects, some based on formative stage and unproven technologies, enables rich countries and corporations to avoid making rapid and deep decarbonization commitments, jeopardizing the goals of the Paris Agreement itself.

Furthermore, the language around removals does not guarantee a cumulative reduction in emissions, with critical loopholes that could allow credits to be earned despite emissions reversals. It also promotes ‘fungibility’ of carbon, treating all types of removals and carbon as the same and ignoring the issue of sequestration permanence, which is particularly problematic in the land sector.  

Market activities have a history of undermining human rights and the recommendation, by “acknowledging that the enforcement of environmental and social protection laws is a national prerogative of the Host Party”, further threatens the effective protection of human rights. 

Thus, we call for the rejection of the document as it currently exists, and for it to be sent back to the Supervisory Body for more work and consultations. This is an unacceptable approach to define the question of removals in markets, which is too important to be handled in such a rushed and opaque manner.