Climate scientists have made it clear that carbon dioxide removal (CDR) will be needed — alongside deep emissions reductions — to meet our national and global climate goals. In response to this consensus, originally put forward more than 5 years ago by the most authoritative body on climate change, the Intergovernmental Panel on Climate Change (IPCC), and re-confirmed many times since, the United States government has invested billions of taxpayer dollars in developing and deploying new types of carbon dioxide removal. This “novel CDR” includes technologies and approaches such as direct air capture and carbon mineralization.
While these new CDR approaches and technologies are being developed, researchers, scientists and project developers are devising ways to measure and assess how effective they are at removing carbon dioxide from the atmosphere. This is the first step in a process known as measurement, reporting and verification, or MRV. MRV can be applied to many different types of climate action to track impact. For example, MRV can be used to conduct a corporate greenhouse gas (GHG) inventory, track the GHG impact of a mitigation policy or quantify the emissions associated with a product.
| Type of MRV | Objective of MRV |
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| National | Quantify GHG emissions and removals for a national GHG inventory; based on guidance from IPCC |
| Policy | Quantify the GHG impact of certain policies |
| Organization | Quantify entity or organizational level emissions for reporting under emissions trading schemes or to report for corporate/ organizational GHG inventories |
| Project | Quantify GHG reductions or carbon removed associated with a specific project. |
For carbon removal, MRV is needed in the near-term to provide transparency and accountability around removal claims. In the long-term, MRV will be crucial to incorporate novel CDR into national inventories so that it can count towards countries’ climate goals, known as nationally determined contributions (NDCs).
As U.S. policy supporting CDR increases in scale and scope in coming years, consistent and credible MRV standards and protocols will be needed to hold project developers accountable to their claims and to codify expectations in terms of quality for CDR supported by policy. MRV standards will be important to direct taxpayers’ dollars to the most effective CDR projects to maximize the climate benefit of these investments.
What Is MRV for Carbon Removal?
Beyond quantifying and measuring the removal, MRV for CDR also includes reporting this information, and verifying its accuracy. MRV can take different forms depending on what it’s being used for; it should be fit-for-purpose for different applications. In other words, the way it is designed should reflect the type of activity it addresses and the intended outcomes of a project or policy.
Source: Based on IGES 2013.
For CDR approaches, the “M” in MRV stands for measurement of carbon removed. Measurement of the amount of net carbon removed from the application of a CDR approach involves lifecycle carbon accounting that measures emissions from all stages of that technology’s production, use and disposal, as well as the gross removal to determine the net-negativity of the whole process.
The “M” is also understood to stand for monitoring, which is often used interchangeably or in combination with ‘measurement.’ What was initially measured needs to be monitored over time to ensure that sequestered carbon is not released back into the atmosphere.
Reporting is the administrative aspect of the MRV process. The data compiled in the measurement stage is shared with third parties, regulators, other relevant authorities and/or the public. What, how and when data is reported is purpose- and project-specific. Reporting data is integral to the MRV process, as it makes this data available for assessment and can help create accountability for project developers.
The measured and reported data is then verified to ensure its accuracy and reliability. Verification is crucial to detect errors in the reporting or measurement, including potentially fraudulent reporting. For carbon removal, verification is commonly carried out by accredited third parties. These can include certified validation and verification bodies which are accredited by a standards body such as the International Standards Organization.
Why Is MRV Important for CDR?
Novel CDR will ultimately be needed to help achieve national and global climate goals. However, today, most novel CDR approaches and technologies are in early development or demonstration. As such, high-quality project-level and technology-level MRV is needed to assess efficacy and enable credibility and transparency around claims that certain amounts of carbon have been removed by certain projects or technologies.
What Are MRV Standards and Protocols?
MRV Standards: Standards provide the overarching set of rules, guidelines and procedures to determine a minimum level of quality and rigor. A quantification standard for carbon removal details how project developers measure and monitor carbon removal and other potential controls. It may include a set of protocols, each applying to a more specific type of project. For projects to be certified under the standard, project developers must follow the rules and requirements of the corresponding protocol, and the overarching standard.
MRV Protocols: Protocols refer to a set of rules tied to how a project carries out the measurement, monitoring, reporting and verification for a specific CDR approach or project type. They detail what physical processes are to be measured and how, as well as how the carbon accounting for a specific method is to be carried out. Project developers generally develop protocols for their project type and submit these for approval by a standard-setting organization. The term “methodology” is often used interchangeably with protocol.
Consistency across MRV standards and protocols is critical to providing this credibility. Without consistency, removal from the same type of project can be measured in different ways, creating confusion for buyers of carbon removal credits and undermining trust. Inconsistency also makes it hard to accurately account for the climate benefits of different CDR projects.
Virtually all carbon removal credits being bought and sold today are on the voluntary carbon market through voluntary purchases by buyers and sellers, often to meet corporate climate commitments. However, overall, the voluntary carbon market includes mostly emissions reduction and avoidance credits; carbon removal credits are only a small portion of the total today. Reduction and avoidance credits generally face more challenges associated with establishing additionality and avoiding leakage than projects using novel CDR approaches.
In the past few years, there has already been a proliferation of standards and protocols for carbon removal credits. Several organizations have launched efforts to create quality standards across carbon credits, but more oversight will likely be needed to create consistency and build trust.
As government policy for CDR increases in scale and scope, there is a risk that this lack of consistency around MRV for CDR spills over into policy as well. For example, if different policies supporting CDR point to different rules for MRV, that would cause similar confusion for CDR suppliers, who would need to meet multiple standards.
The European Union’s Carbon Removal Certification Framework aims to bring this type of oversight to credits traded in Europe, but the United States currently lacks such a mechanism. The European Union’s framework could provide some lessons learned on what role governments can play in creating a credible and consistent MRV ecosystem for carbon removal.
What Is the Role of MRV in Federal Policy Supporting CDR?
Carbon removal approaches have received growing policy support in the United States over the last several years. The U.S. government has provided historic levels of funding for research, development and demonstration of novel carbon removal approaches through the 2021 Bipartisan Infrastructure Law, the 2022 Inflation Reduction Act, and ongoing annual budget appropriations. Policies and programs launched or enhanced in recent years include the 45Q tax credit, the CDR Purchase Pilot Prize, the Regional Direct Air Capture Hubs program and the Carbon Negative Shot Pilots.
All of these policies include MRV components, as they generally involve the quantification of tons removed. However, the MRV provisions across these policies are not consistent or harmonized. This is in line with the overall lack of standardized MRV rules for CDR quantification across the CDR industry, which is somewhat to be expected in a nascent industry but is also a result of the U.S. prioritizing investment in technology development before developing and adopting rules for quantification and reporting, as the EU has done.
As policy support for CDR grows, there’s a need for more consistency across MRV standards and consensus around the rules for how different CDR approaches quantify how much carbon is removed. Along these lines, there is an important opportunity for a federal MRV function to create oversight and set quality standards for federally supported CDR, with the goal of avoiding a replication of proliferation and inconsistencies among standards that are already occurring within the voluntary carbon market.
The operation of such a function could take different forms that would imply different levels of effort from the federal government. While government agencies would not have the internal capacity to track and verify removal claims from every CDR project, the federal government can play a critical role in creating a high accountability ecosystem where project developers and third-party verifiers are required to adhere to best practices for measuring carbon removal and environmental and social impact, monitor sequestered carbon to ensure permanence, and report methods and impacts transparently.
What Would a Federal MRV Function Ideally Do to Build a Robust MRV Ecosystem?
In a new WRI working paper examining the topic of MRV for CDR in federal policy, we propose seven criteria for consideration within a federal MRV function.
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Build on existing efforts
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Build on existing expertise and efforts in the private sector, academia and within the government to avoid duplication of efforts. A first step could involve a landscape assessment and stakeholder mapping of existing efforts by CDR approach (within and outside of the federal government) with identification of gaps, inconsistencies and pain points. |
| Designate roles | The government should determine roles and responsibilities within a federal MRV function, including delegating crucial functions that are outside of their capacities. For instance, federal government agencies could set standards while delegating the development of methodologies and protocols as well as ongoing verification to other approved organizations. |
| Manage incentives | It will be necessary to determine an appropriate compensation framework for those designing and verifying MRV methodologies and protocols management to avoid over-crediting and fraud. |
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Set standards with the best available science
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The federal government can create oversight by setting standards for CDR MRV with the best available science. At minimum, standards should address thorough and transparent lifecycle carbon and greenhouse gas accounting, ongoing monitoring and assessment of community and environmental impacts, which could also help raise quality standards for the voluntary carbon market and increase buyer confidence in these markets. |
| Centralize data and transparency | Publicly and transparently reporting the outcomes of CDR projects is key to building trust in CDR and holding companies accountable for backing their claims. In the near term, this entails providing public information on projects including reported levels of carbon removed and ongoing monitoring. In the longer term, once inventory guidance is developed to incorporate CDR into the national inventory, this centralized data function can help serve that purpose as well. |
| Set an appropriate threshold for uncertainty | Policies designed to support carbon removal on a per-ton basis will need to set guidelines for acceptable levels of uncertainty related to the number of tons removed, and ways to address the uncertainty that remains within that threshold. In the context of a ton-based policy support, uncertainty tolerance will differ depending on the CDR approach and how the removal is being used. |
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Address non-carbon impacts
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Carbon removal projects must not only remove carbon but also minimize negative impacts on the environment and people to be sustainable and scalable. As such, MRV frameworks should address non-carbon impacts, including impacts on air and water quality. |
The sixth consideration — setting an appropriate threshold for uncertainty — is particularly important since novel CDR approaches vary in terms of how easily the carbon removed can be measured and the level of reversal risk that the sequestered carbon could be re-released. For approaches where there is greater uncertainty around measurement or greater risk of reversal, MRV will require more effort and cost. Different uses of CDR credits may require different levels of confidence around accuracy of MRV. As such, thresholds for uncertainty will likely depend on the type of CDR approach and how the tons of removal are used (e.g., for compensatory claims or not). Such thresholds would also help companies decide how to allocate resources for MRV, particularly when it could be very expensive to lower uncertainty past a certain level. Any remaining quantification uncertainty — at least for approaches where the level of uncertainty can be quantified with some level of confidence — can be addressed through uncertainty management mechanisms such as uncertainty discounts, insurance or buffer pools.
Looking Ahead, the Time is Right for a Federal MRV Function
The carbon removal industry has grown tremendously in the past several years and with this rapid growth has come simultaneous efforts to develop the rules governing this scale up. As the U.S. government plays an increasing role in supporting a range of different novel CDR approaches, it is an opportune time to provide oversight and quality standards for the CDR supported by federal policy. Such an intervention would also bring some order to CDR credits sold elsewhere, adding credibility to the industry as a whole.