Mr Ian Davis – Written evidence (NSD0007)



This submission is in addition to the evidence already submitted by The TFF Grassroots Group of which I am a member.


I submit this evidence as a note of caution relating to current approaches to climate mitigation around the world. I raise these in this submission as the issues are sufficiently serious that they question the deliverability of current policy.


Q2. What major scientific uncertainties persist in understanding the effects of nature-based solutions and affect their inclusion in carbon accounting, and how can these uncertainties be addressed?

Excellent work has been done by the Carbonplan organisation based in the USA, partly funded by Microsoft. They have published the conclusions of their detailed analysis of the robustness of current soil carbon based offset trading schemes.[1] They conclude that:


Improving soil health and ecosystems is unequivocally positive. But determining when certain agricultural practices actually increase carbon stocks, and how to measure and credit their gains, remains exceedingly complex. The efficacy of soil carbon interventions depends on local climate conditions, land management history, and soil characteristics. Soil carbon, meanwhile, varies substantially over time, space, and depth. On top of that, any changes in soil carbon occur slowly, which makes it difficult to reliably track changes once new practices are implemented.”


Our findings reveal that robust crediting of soil carbon is hard and that none of the existing protocols is doing enough to guarantee good outcomes. While this conclusion doesn’t mean that all projects are generating low-quality credits, the lack of rigorous standards makes it hard to ensure good climate outcomes in the voluntary market. Buyers that care about quality must screen candidate projects themselves, while developers of high-integrity projects must compete against those who might take advantage of lax standards. The additional due diligence required today could limit the role soil carbon can play in effective climate strategy and highlights the need for systematic market reforms.


Q5. How should implementation of nature-based solutions be integrated with other government policies for landscapes and seascapes, for example, agricultural, forestry, and land-use planning policies?

I am deeply concerned with many of the current policies being promoted by the UK Government to address and mitigate climate change. Many are underpinned by “offsetting” of various types and others are utterly dependent upon commercially engineered carbon capture and storage (CCS) or commercial capture for industrial carbon re-use (C-ICR). Whilst a number of projects are running around the world to investigate these options none are currently fully commercially viable and few have delivered any meaningful outputs.


Work by Sekera and Lichtenberger last year found that “commercial ICR (C-ICR) methods being incentivized by governments are net CO2 additive: CO2 emissions exceed removals. Further, the literature inadequately addresses the resource usage and biophysical impacts of these methods at climate-significant scale. We concluded that dedicated storage, not sale, of captured CO2 is the only assured way to achieve a reduction of atmospheric CO2.


They further concluded, regarding industrial carbon capture and long term storage, that “Governments should therefore approach atmospheric carbon reduction as a public service, like water treatment or waste disposal. They recommended, therefore, that the only viable payment mechanism for this is from public funds as a public good.


On biological CCS, a nature based solution, they note that:


Biological systems remove CO2 from the atmosphere and sequester it in soil and biomass. Such systems include forests (reforestation, afforestation, and averting deforestation); farming techniques (soil and biomass carbon sequestration through regenerative farming and other improved agricultural methods); grasslands and wetlands restoration. Our preliminary research suggests that biological methods are not only more effective at atmospheric CO2 reduction, they may also be more effective and efficient in resource usage not only in terms of energy but also in terms of land. In addition, they provide co-benefits such as soil-nutrient restoration, air and water filtration, fire management, and flood control.


These findings undermine large portions of current UK Government policy towards climate mitigation. They leave nature based solutions, especially those we can deliver within the UK itself, as the front runner candidate to mitigate our past climate emissions and those future emissions which we are unable to avoid. Even these will be inadequate unless we first cut our fossil fuel use as deeply as practicably possible and ensure the most climate efficient use of those non-fossil fuel energy sources we have available to us.


5 September 2021