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Policy & regulation

The rules that decide what gets built and who is liable

Nothing on this site deploys without policy. Capture, storage and conversion all cost more than venting, so every one of them exists because a rule or a subsidy made it exist. That makes the design of those rules at least as determining as the chemistry, and the evidence on how well they have worked so far is more sobering than the volume of policy discussion would suggest.

Carbon pricing has underperformed its reputation

Carbon pricing is the default instrument in most climate policy discussion, on the reasoning that internalising the externality will change behaviour. The ex-post evidence is thinner and weaker than that prominence implies.

A meta-review of quantitative ex-post evaluations of carbon pricing worldwide since 1990 found only 37 studies assessing actual effects on emissions, the vast majority focused on Europe. Aggregate reductions attributable to carbon pricing were generally between 0 and 2 percent per year, with considerable variation across sectors. Carbon taxes generally performed better than emissions trading schemes, and the EU ETS, the oldest such scheme, showed average annual reductions of 0 to 1.5 percent [1].

Set against the IPCC's stated requirement of emissions falling 45 percent below 2010 levels by 2030 for a 1.5 degree pathway, that is a limited impact [1]. The conclusion is not that pricing is useless but that pricing alone has not, historically, done the work assigned to it, and prices have generally been set too low to bring capture technologies into the money.

Which is why deployment has lagged the technology

CCS is broadly recognised as technically mature and has not been deployed at anything approaching the scale envisaged a decade ago, and the barriers that account for that gap are commercial and political rather than technical [2]. A technology that costs 50 to 100 dollars a tonne to operate does not deploy under a carbon price of 20.

Removal needs different instruments from abatement

Paying someone not to emit and paying someone to remove are different transactions, and the second does not fit the instruments built for the first.

CDR requires up-front capital, continuous funding to scale, and long-term operating funding, and instruments should differentiate by permanence of storage. No single instrument suffices: the assessment proposes a stepwise approach, with early differentiated R&D and pilot subsidies giving way to results-oriented financing and eventual inclusion in broader instruments, and concludes that CDR ultimately needs to become a regularly provided public service in the way that waste management did over the last century [3].

Transparency and early public deliberation are treated in the same assessment as prerequisites rather than niceties, both for political stability and to prevent rent-seeking at public expense [3].

Crediting integrity is where the accounting meets the money

The moment a removal earns a credit, the definition of a removal becomes a financial question. The minimum qualifications are unforgiving: physical removal from the atmosphere, storage intended to be permanent, comprehensive accounting of upstream and downstream emissions, and a net balance in which removals exceed emissions [4]. A crediting scheme that does not enforce all four will pay for things that are not removals.

Permanence is the hardest to write into a contract, because it outlasts the contract. Who owns a storage site after injection stops is a legal question with no settled international answer, and it bears directly on whether projects can be financed at all [5].

International law moves by list, not by principle

Marine routes illustrate how slowly the legal layer adapts. The London Protocol regulates marine geoengineering through a positive list, so an activity is prohibited until it is affirmatively added, and how that regime should adapt to the broader ocean-climate agenda is under active discussion in the treaty bodies themselves [6].

Open challenges

  • Price levels versus price existence. Most jurisdictions have a carbon price; few have one high enough to change investment decisions in heavy industry [1].
  • Instrument mismatch. Removal is not abatement, and reusing abatement instruments for it produces weak incentives and weak verification [3].
  • Post-closure liability. Unresolved ownership of storage sites after injection ends is a live barrier to financing [5].
  • Verification capacity. Rules are only as good as the measurement behind them, and durable public verification capacity is not yet in place at the scale crediting would require [4].

Evidence

6 verified sources
  1. [1]Green, J. F. (2021). Does carbon pricing reduce emissions? A review of ex-post analyses. Environmental Research Letters 16, 043004 doi.org/10.1088/1748-9326/abdae9
  2. [2]Bui, M.; Adjiman, C. S.; Bardow, A.; Anthony, E. J.; Boston, A.; Brown, S.; Fennell, P. S.; Fuss, S.; Galindo, A.; Hackett, L. A.; Hallett, J. P.; Herzog, H. J.; Jackson, G.; Kemper, J.; Krevor, S.; Maitland, G. C.; Matuszewski, M.; Metcalfe, I. S.; Petit, C.; Puxty, G.; Reimer, J.; Reiner, D. M.; Rubin, E. S.; Scott, S. A.; Shah, N.; Smit, B.; Trusler, J. P. M.; Webley, P.; Wilcox, J.; Mac Dowell, N. (2018). Carbon capture and storage (CCS): the way forward. Energy & Environmental Science 11, 1062-1176 doi.org/10.1039/c7ee02342a
  3. [3]Honegger, M.; Poralla, M.; Michaelowa, A.; Ahonen, H.-M. (2021). Who Is Paying for Carbon Dioxide Removal? Designing Policy Instruments for Mobilizing Negative Emissions Technologies. Frontiers in Climate 3, 672996 doi.org/10.3389/fclim.2021.672996
  4. [4]Tanzer, S. E.; Ramirez, A. (2019). When are negative emissions negative emissions?. Energy & Environmental Science 12, 1210-1218 doi.org/10.1039/c8ee03338b
  5. [5]Krevor, S.; de Coninck, H.; Gasda, S. E.; Ghaleigh, N. S.; de Gooyert, V.; Hajibeygi, H.; Juanes, R.; Neufeld, J.; Roberts, J. J.; Swennenhuis, F. (2023). Subsurface carbon dioxide and hydrogen storage for a sustainable energy future. Nature Reviews Earth & Environment 4, 102-118 doi.org/10.1038/s43017-022-00376-8
  6. [6]Vivian, C.; Del Savio, L. (2024). The London Convention and Protocol: Adapting to Address the Ocean-Climate Crisis. The International Journal of Marine and Coastal Law 39, 519-527 doi.org/10.1163/15718085-bja10178

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