How Carbon Dioxide Removal Can Be Scaled Responsibly

Carbon dioxide removal (CDR) has grown from a little-known concept to a fast-growing field in the last several years. Beyond the climate benefits from removing carbon dioxide (CO2) from the atmosphere, many CDR approaches may also benefit people and the environment, like creating jobs to boosting soil health or reducing local ocean acidification. However, CDR projects can also come with unintended consequences or negative impacts, so robust governance frameworks must be in place to minimize any damages.

Comprehensive and fit-for-purpose governance frameworks are needed, for example, so that oil and gas industries don’t rely on CDR to justify their continued fossil fuel production. These frameworks can also help protect communities that already face increased pollution and harm from the fossil fuel industry from additional risks tied to land, water and energy use that may come from these new CDR facilities.

As the carbon removal industry ramps up, there is a growing emphasis on “responsible” carbon removal to ensure communities don’t experience harm and have access to local benefits. But what does this mean concretely? In the context of ensuring robust governance, what can be done to improve policy and regulation to deliver responsible outcomes?

Here, we answer some of these questions.

What Does Responsible Carbon Removal Entail?

Responsible carbon removal emphasizes the importance of sustainably and safely deploying a range of CDR approaches that use chemicals, rocks, biomass, soils, the ocean and more to complement efforts to drastically reduce greenhouse gas emissions without exacerbating any historical harms to communities or the environment.

At a project level, this includes thoroughly assessing the social, economic and environmental impacts of CDR projects and minimizing negative effects while equitably distributing benefits. At a policy level, it entails the creation of policies and regulations that ensure that CDR contributes to real climate benefits, while protecting communities and ecosystems.

Achieving responsible carbon removal therefore requires robust governance to minimize these trade-offs. In addition to its global climate benefit, it must deliver local tangible benefits like improvements to air quality or revenue to invest into communities and ecosystems rather than exacerbate inequities or environmental harms of other industries. It must also entail inclusive decision-making and complement — not substitute — ambitious emissions reductions.

Without public trust and community support, CDR projects may struggle to gain any social license and scale, limiting their ability to contribute to climate goals. For instance, other clean energy projects that did not adequately engage communities have faced delays or cancellations. Ensuring responsible implementation by industry and governments is therefore key to building that trust.

Key Questions to Inform Responsible CDR Policy

Below we answer three key questions about the role of policymaking to ensure the responsible deployment of CDR.

How Can Policies Ensure that CDR Maximizes its Benefit to the Climate?

Scientific consensus is clear: Removing carbon dioxide from the atmosphere will be necessary to complement efforts that drastically reduce greenhouse gas emissions by mid-century to prevent further unprecedented warming across the Earth. There are however various concerns (including from academics and NGOs), ranging from the risk of delaying emissions reductions, to the need for more accurate measurements of projects’ net climate benefits. Some policy measures and safeguards can help address these risks:

Setting Separate Targets

Without adequate policy measures in place, scaling CDR in the next decades could risk shifting focus and resources away from the urgent need to reduce emissions today and transition away from fossil fuels. This risk is known as mitigation deterrence.

Separate long-term climate targets for emissions reduction and CDR can help address this risk, with some U.S. states, like California and Washington, providing early examples. This might be more easily achieved in states or countries with net-zero policies and greenhouse-gas reduction mandates, through which the role of CDR can be responsibly defined.

Under this approach, CDR is planned and accounted for separately based on a quantitative assessment of expected residual emissions. This clarifies how much CDR is planned to reach net-zero, ensuring transparency and preventing CDR from being misused to offset emissions that could instead be reduced.

Policymakers must refrain from planning for CDR to sustain fossil fuel use, which would undermine emissions reduction efforts and risk derailing climate targets. Emitting CO2 now and removing it later does not prevent its consequences: CO2 emissions cause irreversible climate damage, which CDR cannot undo.

Scaling CDR will also be constrained by sustainability limits on land, water and energy availability as well as societal impacts.

Lastly, CDR technologies are still largely in development. There is uncertainty as to the extent to which they will scale in the coming decades. Relying on the promise of a massive scale up to address residual emissions is therefore risky, highlighting the need to rapidly reduce emissions to the maximum extent possible.

Ensure Projects Maximize Net-Negativity

CDR projects must be net-negative. If a project’s emissions exceed removals, it is not net-negative and does not result in net carbon removal.

Policymakers can encourage net-negativity in several ways:

• Prioritize renewable energy use: Energy intensive CDR approaches like DAC must prioritize renewable energy to avoid fossil fuel emissions. However, the U.S. grid is not yet fully decarbonized and diverting limited renewable energy to power CDR at the expense of providing clean energy to buildings or transportation, could slow broader climate progress. Policymakers should prioritize funding projects that co-locate with renewable energy sources and incentivize the development of dedicated renewable energy infrastructure for CDR operations.
   
• Prohibit enhanced oil recovery (EOR): Policies must prevent CDR from prolonging fossil fuel dependence through EOR, which uses captured CO2 to extract more oil. While some argue EOR could be net-negative under some conditions, the climate math remains uncertain and the continued fossil fuel extraction negates the climate benefit of removals. More importantly, using DAC-derived CO2 for EOR also risks damaging public trust in CDR and therefore must be avoided. Some states, like California, have already prohibited this practice for carbon capture and sequestration and CDR projects, setting a precedent for stronger safeguards.

Establish High-Quality and Harmonized Measurement, Reporting and Verification Practices

Robust and harmonized measurement, reporting and verification (MRV) standards is the cornerstone of responsible CDR. MRV must prove that a project provides net-negative emissions, and permanently sequesters CO2, which is typically verified via third party verification.

Despite a number of efforts to advance best practices, the current MRV ecosystem for CDR is uncoordinated and unregulated. Without common standards it is unclear what constitutes high-quality MRV, risking a race to the bottom when it comes to quality.

Establishing a federal MRV function or an independent and authoritative standards body within government, that is free from vested interests is essential to ensuring a high-quality, transparent MRV ecosystem for CDR. This would provide accountability and verify that CDR projects deliver on their promised removals.

To avoid a proliferation of efforts, such a body should harmonize with existing efforts rather than duplicate them. In the long-term, a standardized MRV framework is critical for carbon removals to be recognized in national reporting and contribute toward countries’ nationally determined contributions, as well as to avoid perverse incentives that may result in double counting.

How Can CDR Policies be Designed to Avoid Reinforcing Existing Inequities?

As policymakers develop frameworks for carbon removal, embedding equity and environmental justice principles is critical to ensure that benefits are maximized, risks are minimized and both are distributed fairly.

Low-income Black, Latino and Indigenous communities in both rural and urban areas, already bear disproportionate pollution burdens and poor health outcomes compared to higher-income, majority-white communities. Policymakers must prioritize designing safeguards to prevent exacerbating existing inequities and burdens, ensuring that historic harms are neither repeated nor worsened, while maximizing the potential improvements and benefits for host communities.

Require Meaningful Community Engagement

A recent survey found that 73% of voters support being consulted on new carbon removal projects, highlighting strong public demand for early and meaningful engagement. Strong policy frameworks must establish clear requirements for engagement that goes beyond informing potential host communities, especially on project siting and community benefits. Communities should have the opportunity to actively shape decision-making processes and should be compensated appropriately for their input and time. Policies should require developers to communicate transparently about the benefits and potential risks of a project and acknowledge that genuine community engagement includes the possibility of project rejection. Policies should provide clear, enforceable mechanisms to respect and act upon a community’s decision to decline a project, ensuring future efforts in that location are appropriately reconsidered or redirected.

Strengthening Community Benefits as a Standard Practice

Community benefits plans can provide a structured framework for integrating community voices, outlining expected benefits, and ensuring that local priorities shape project implementation.  While they do not carry the legal weight of a community benefits agreement, the plans are a critical tool for building trust, addressing community concerns and fostering long-term partnerships.

Community benefits plans have already been used in a handful of projects across sectors, however, they are not yet the norm. These plans should become standard industry best practice, with developers proactively adopting them rather than waiting for mandates. By voluntarily implementing community benefits plans, companies can demonstrate a commitment to equitable development, making projects more viable and reducing opposition.

While community benefits plans set the foundation for engagement, legally binding community benefit agreements codify commitments to tangible, enforceable benefits for communities. They can guarantee specific local benefits, such as revenue-sharing arrangements, infrastructure investments, or workforce development programs and provide accountability mechanisms that ensure developers deliver.

Policymakers can encourage or require community benefit agreements by embedding them into state-level policies or permitting requirements. This can provide a stable framework for equitable project development and ensure that communities hosting CDR projects receive durable economic and social benefits.

For communities to fully benefit from CDR projects, they must have the legal expertise, technical knowledge and negotiation skills to advocate for their interests when engaging with developers. Many historically marginalized communities lack the resources to navigate complex agreements, assess project risks or negotiate strong community benefits, often resulting in vague or insufficient commitments that fail to deliver long-term value.

To address this, policymakers and industry leaders should invest in capacity-building initiatives, such as legal support funds, community-led training programs and technical advisory services. Empowering community organizations as intermediaries and establishing publicly funded legal aid or negotiation support teams would help level the playing field, ensuring that communities can secure enforceable agreements that maximize both economic and environmental benefits.

Advance Innovative Benefit Models

Achieving equitable CDR deployment may also require initiatives that go beyond traditional benefit-sharing models. One promising pathway is creating opportunities for local communities to hold equity stakes in CDR projects, creating more enduring economic benefits while also fostering deeper trust and alignment between developers and host communities. CDR projects can generate revenue through carbon credit sales, corporate sustainability investments, government incentives and CO2 utilization in commercial products, making these benefit-sharing models potential opportunities for co-benefits.

For example:

• Community profit-sharing agreements: A percentage of the project’s revenue could be allocated directly to local community funds, supporting infrastructure, education or healthcare projects.
   
• Co-ownership models: Communities or local organizations own a portion of the project, granting them both financial benefits and decision-making power.

Examples from renewable energy sectors can provide examples for CDR. For instance, the Saulteaux First Nation in Canada partnered with a renewable energy company to co-own and operate a wind power project. The community holds a majority ownership stake, which has provided sustained and long-term financial returns, ensured local decision-making power and fostered community trust in the project’s development.

Establishing federal-level guidance and best practices for these models will help ensure consistency across projects while allowing for local customization. Transparent monitoring protocols, accessible reporting channels and clear enforcement mechanisms will be critical to ensuring these profit-sharing and ownership structures deliver on their promises.

Robust policy frameworks that center community decision-making and ensure equitable distribution of benefits are needed to ensure that CDR deployment supports environmental justice goals.

How Can CDR Policies Protect Lands, Ecosystems and Natural Resources?

Building public trust in CDR will require careful evaluation of potential resource use, and community and environmental harms and action to prevent them.

Like any other industry, CDR uses resources like water and minerals. In addition, CDR facilities such as DAC plants require infrastructure such as CO2 pipelines, which occupy land. Responsible CDR projects should not only minimize any negative impacts of resource use, but should also be sited in locations that do not exacerbate resource concerns such as water shortages. To protect communities and ecosystems, projects should carry out environmental and social impact assessments and include legal mechanisms to ensure ongoing responsibility for mitigating any environmental harms that occur, while considering their entire value chain.

Conduct Environmental Impact Assessment and Mitigate Impacts

Conducting both robust MRV and environmental impact assessments can identify resource needs, environmental impacts, human health impacts including cumulative pollution burdens, and help project developers plan to mitigate any negative impacts.

In the U.S., National Environmental Policy Act requires that for projects using federal funding or require a federal permit that federal agencies carry out environment impact assessments and provide environmental statements for any construction, permitting or planning action with significant environmental impact. Projects can choose to complete assessments even without federal involvement, a practice that CDR projects should pursue to plan for unintended impacts that could impede a project’s viability. Since environment impact assessments can be expensive for companies, state and local governments could establish grant or loan programs to support the process.

Implement Rigorous Environmental and Safety Standards

CDR projects must adhere to existing environmental and safety regulations, and policymakers should work with the emerging CDR industry to update and strengthen regulations and standards over time.

This includes having robust plans in place to mitigate adverse impacts such as excessive water use, chemical spills and carbon leakage while also implementing emergency response systems to protect nearby communities from unforeseen hazards. These measures will not only enhance environmental safeguards but could also foster public trust and confidence in the responsible deployment of CDR technologies. CDR projects should also plan for long-term responsibility for remediation of any adverse environmental impacts.

U.S. lawmakers have also begun developing policies to support the responsible deployment of some CDR technologies. Aspects of approaches like DAC are already largely covered by federal policies, such as the EPA’s regulation on sequestering CO2 in deep underground geologic formations. Many CDR approaches are however quite novel, meaning that the regulations that apply to these projects were written before they existed. This means that significant regulatory gaps remain, and comprehensive safety standards must be updated in response to development of these new approaches, including DAC, to ensure regulation is fit-for-purpose. 

Creating Safe Frameworks to Scale CDR

As the field continues to evolve, policy frameworks must prioritize equity, environmental integrity and community empowerment to prevent CDR from replicating past harms.

A commitment to strong safeguards, inclusive decision-making and durable accountability measures will be essential to ensuring that carbon removal meaningfully contributes to long-term climate goals. If not implemented with high standards and adequate safeguards, CDR risks being scaled in ways that neglect public safety and environmental sustainability, diminishing its purpose as a climate solution and further endangering our ability to meet national and global climate goals.