Arcusa et al.

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Carbon accounting

CNCE Working Paper Series
CNCE 2022-001

CARBON REMOVAL ACCOUNTING METHODOLOGIES:
HOW TO RETHINK THE SYSTEM FOR NEGATIVE CARBON EMISSIONS
Stephanie Arcusa
Klaus Lackner
Robert Page
Vishrudh Sriramprasad
Emily Hagood

Working Paper 001

CENTER FOR NEGATIVE CARBON EMISSIONS
Arizona State University
Tempe, AZ 85287-3005
USA
November 2022

CNCE working papers are circulated for discussion and comment purposes. They have not gone
through the peer-review process.
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How to cite:
Arcusa S., Lackner K., Page R., Sriramprasad V., Hagood, E. (2022). Carbon removal accounting
methodologies: how to rethink the system for negative carbon emissions. CNCE Working Paper No. 0001
November 2022. Arizona State University KEEP Repository, https://hdl.handle.net/2286/R.2.N.170043.

Abstract
We analyze current approaches to carbon accounting for removed carbon sold on carbon
markets, focusing on carbon crediting under the framing of a remaining carbon budget, the issue
of durability, and approaches to accounting methodologies. We explore the topic of mixing
carbon with other problems in developing carbon accounting methodologies and highlight the
open policy questions. We conclude with a suggested framework for accounting for carbon
removal accounting that simplifies climate action and enables a world with negative carbon
emissions.

Contact:
Stephanie Arcusa
Center for Negative Carbon Emissions
Arizona State University
Tempe, AZ 85287-3005
sarcusa@asu.edu

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1 Carbon crediting in a finite budget
Increasing
carbon
dioxide
(CO2)
concentration in the atmosphere due to burning
fossil fuels and calcinating carbonates to
produce cement is causing climate change (IPCC,
2022a). Other greenhouse gases like methane
and nitrous oxide play a role, but their
characteristics differ in terms of their lifetime in
the atmosphere (Lackner, 2020; Pierrehumbert,
2014; Solomon et al., 2009). Once in the
atmosphere, 20-35% of the emitted CO2 will
remain there for hundreds of thousands of years
(Archer et al., 2009). Despite higher potency, this
longevity is not the case for other greenhouse
gases. Earth will likely recover from the massive
increase in CO2 concentration since the start of
the industrial revolution. Still, for humans and
most species, the climate changes will appear to
be a permanent state shift (Tierney et al., 2020).
The carbon problem is not a century-scale
problem but rather one that operates on a multimillennia scale more reminiscent of the
longevity of nuclear waste.
As a result of this multi-millennia
characteristic of CO2, CO2 emissions accumulate
in the atmosphere and tightly linked reservoirs
like the surface ocean. This accumulation occurs
because the Earth's processes cannot remove
the CO2 gas fast enough to match the rate caused
by humans (Solomon et al., 2009). The
accumulation of CO2 (and other greenhouse
gases) increases the global temperature. Simply
reducing emissions is not enough, as the
remaining emissions continue to contribute to
increasing the total atmospheric CO2
concentration. Instead, current emissions (and
some past emissions) must be eliminated or
canceled out, a situation that calls for zero
emissions. Additionally, any future emissions,
once emitted, must be removed. The elimination
and removal of emitted carbon is the basis of the
Intergovernmental Panel on Climate Change
(IPCC) concept of the remaining carbon budget

Carbon accounting

(IPCC, 2022a). This concept collides with carbon
credits based on trading emissions reductions
and carbon storage that is measured in decades
or centuries rather than tens of thousands of
years.
Meeting the Paris Agreement commitment to
1.5 °C means staying within a finite carbon
allowance that is quickly diminishing as
emissions continue (IPCC, 2022a). Therefore,
achieving the Paris Agreement commitment
using carbon markets and offsetting practices
means that carbon credits must represent a
complete and virtually permanent removal.
Credits for emission reduction used for offsetting
emissions continue to diminish the budget
because emissions are still produced. Moreover,
because the world has delayed climate action for
three decades (Stoddard et al., 2021), staying
within a 1.5 °C budget will require negative
emissions (IPCC, 2018; Morton et al., 2021).
Negative emissions are only possible through
carbon removal as CO2 concentrations are
irreversible on human timescales (Solomon et
al., 2009).
Alignment with the Paris Agreement
commitment means emission reduction credits
cannot continue to be used as offsets. Through
their use, the remaining carbon budget will
continue to shrink, bringing the world closer to
breaching the Paris commitments and going well
beyond. Furthermore, emission reductions
should not be certified as being the same as
emission removal; the mantra of a ton is a ton is
flawed. Reducing one emission cannot be used
to cancel out another emission. Both emissions
will have to be eliminated. In a zero-emission
world, nobody should have a right to emit freely
(Lackner and Jospe, 2017), and certainly not a
right that can be transferred to another emitter.
Removing an equivalent amount of carbon is the
only way to neutralize an emission. Carbon
removal is the price to pay for not eliminating
emissions. Put differently, with the 1.5 °C carbon
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budget in mind; carbon removal should be the
standard for carbon credits. If removal (or
negative emissions) is the standard, then
reduction (or decreasing positive emissions)
should not be given the same value by the
carbon market. The argument that removing a
ton is equivalent to avoiding a ton in a world of
voluntary action is not entirely correct.
There is nothing wrong with rewarding
action, just like it may be worthwhile to reward
emissions reduction during the transition to a
net zero economy. However, issuing carbon
credits is the wrong approach. For example,
capturing CO2 from the environment and using it
for synthetic fuels helps approach a net-zero
economy, even though the carbon ends up in the
atmosphere as CO2 again. However, this process
does not generate a carbon credit. Instead, it
avoids the need for one.

2 The issue of durable storage
Once one accepts that offsetting can only use
carbon removal, one must also understand the
distinction
between
certifying
carbon
sequestration and other forms of carbon offsets
for two reasons: durability (i.e., permanence)
and accounting.
Carbon removal includes capture and
sequestration. Durable sequestration is the
essential element that matters for climate
change mitigation. CO2 captured from the
environment and released (even 100 years later)
has little benefit for climate mitigation since CO2,
once re-emitted, will resume causing damage for
hundreds of thousands of years (Archer et al.,
2009;
Kirschbaum,
2006).
Temporarily
sequestered CO2 has a benefit for the
generations of humans and other species that
live during the sequestration period because it
minimizes the overshoot (i.e., the exceedance of
the limits set in the commitments of the Paris
Agreement) (Dornburg and Marland, 2008;

Carbon accounting

Girardin et al., 2021). This argument is valid if
one takes the optimistic view that global
atmospheric concentrations will peak and come
down within the span of temporary
sequestration, which implies active measures to
remove carbon from the environment. Unless
active carbon removal is maintained, releasing
carbon from temporary storage will create a
cycle of degradation of the climate and the
human environment. Temporary storage
without the obligation of re-sequestering losses
from storage represents a willful neglect of the
interest of future generations to lower the cost
of a habitable climate for our generation.
CO2 captured from the environment and
sequestered durably mitigates climate change
and allows the world to transition to net
negative emissions. This condition will be
necessary to uphold the Paris Agreement
commitments. However, this all depends on the
definition of durability. An arbitrary selection of
a timeframe, or applications of discounting,
ignores the well-being of future generations.
Intergenerational equity should be as much a
consideration for carbon accounting as calls for
sustainable development and safeguards on
gender equality, labor, the environment,
indigenous rights, biodiversity, human rights,
and land ownership. The Paris Agreement is
clear; parties must consider intergenerational
equity in tackling the climate crisis (United
Nations, 2015). Furthermore, a continuing cycle
of 50-100 years of carbon released from storage
will impede the world from reaching a stable netzero target and net negative emissions – it is an
issue
of
ongoing
maintenance
and
incompatibility with net-zero goals.
The definition of durability must be
commensurate with the damage we are trying to
prevent (Arcusa and Lackner, 2022). Preventing
damages from temperature requires storage on
timescales of multiple centuries to millennia to
match the absorption of CO2 into the biosphere
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and its transfer into the oceans (Archer and
Brovkin, 2008). However, climate change is not
only about temperature (IPCC, 2022b). The
scientific community has reported on the
significant damages that will be caused by ocean
acidification (Branch et al., 2013; Doney et al.,
2020; Guinotte and Fabry, 2008; HoeghGuldberg et al., 2017; Narita et al., 2012).
Preventing those will require storage over tens
to hundreds of thousands of years to match the
timescales of calcium carbonate reaction and the
silicate rock cycle (Archer et al., 1998; Archer and
Brovkin, 2008).
The urgency of the climate crisis is such that
nations must deploy carbon removal at scale
within the coming decades (Fuss et al., 2018;
IPCC, 2018). However, this goal comes with two
obstacles. Activities that could provide longterm sequestration are expensive and will take
time to deploy at the necessary scale. Activities
available today are relatively cheap and could
provide large-scale removal with the right
incentives, but they cannot offer long-term
sequestration in many instances. Therefore, all
forms of carbon removal must be considered
despite the shorter expected storage durations
from some.
How this impermanence is treated is one of
the core aspects of carbon accounting. One
suggestion has been to differentiate carbon
removal credits based on the variations in the
expected storage durations. However, suppose
removed carbon is to be used in a net-zero
economy. In that case, it needs a ton of removal
to be equivalent to a ton of emissions, and it
needs to be equal across all types of carbon
removal.
Various mechanisms have been proposed to
create equivalence across carbon removal of
different expected storage durations, for
example, by selecting a commitment period,
discounting short-term storage, renewing
expiring credits, or transferring responsibility

Carbon accounting

through time (Brander et al., 2021; Kim et al.,
2008; Marland et al., 2001; Wenger et al., 2022;
Whitmore and Aragones, 2022). Apart from the
perpetual renewal of expiring credits and
transferring responsibility, none of the other
mechanisms result in a true equivalence if the
timescales are not commensurate with the
climate damages. Commitment periods used in
standards vary between 10 and 100 years,
ending the responsibility of the buyer and the
storage operator after a set time, effectively
deciding that a partial cleanup of carbon waste is
acceptable. Discounting short-term storage on
timescales of tens of thousands of years very
quickly demonstrates the futility of temporary
storage to tackle the carbon problem. The
perpetual renewal of expiring credits was
unsuccessful in the Clean Development
Mechanism because buyers wanted to avoid
repurchasing (Neeff and Ascui, 2009). While
responsibility transfer is a promising mechanism,
it is only being used for geological storage (Dixon
et al., 2015). This short analysis demonstrates
the durability issue of carbon removal needs to
be solved adequately in carbon accounting.
Because certain sequestration activities cannot
provide durable storage yet must be used to
scale carbon removal quickly, and because the
integrity of the total sequestration effort
dictates the success of carbon removal as a
climate mitigation strategy, there must be a
bridge between temporary sequestration
activities and durable ones.
In addition to variable expected storage
durations, most carbon removal is susceptible to
premature
carbon
release.
Requiring
compensation for reversals, whether intentional
or accidental, is consistent with carbon removal
for climate mitigation. A commonly used
mechanism is to reserve a certain percentage of
issued credits in buffer pools to compensate for
reversals during a commitment period
(Gillenwater and Seres, 2011). Unfortunately,
this practice fails to ensure durable
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sequestration. The method protects the integrity
of the sequestration during the commitment
period, which, as discussed, falls short of the
durations necessary for climate mitigation.
Moreover, if inappropriately diversified, buffers
are examples of correlated risks; one forest fire
could destroy the reserve. This risk means buffer
pools need actuarial analyses to adequately set
aside sufficient credits of adequate types to
guarantee the integrity of sequestration even
during the commitment period (Badgley et al.,
2022a). The buffer pool must also be
continuously replenished as credits are used for
compensation.
Continuous
replenishment
causes an issue of sourcing: if the credits are only
set aside for the buffer as projects are
developed, the buffer pool can only be
replenished by a pyramid scheme. Such a system
would never transition to a net-zero stage, and
projects would need to continually be set up
under the threat of emissions being released
from storage elsewhere. How standards and
certification handle the durability issue will have
significant implications for the global climate
goals and the well-being of future generations.

3 Accounting methodologies
A rational and prudent accounting system
allows for a universal understanding that will
lead to acceptance. Certification must focus on
the accounting for sequestration, not capture, to
gain wide acceptance. The capture of CO2 is
comparatively easy, and although one may want
to check the source of the CO2 (atmospheric vs.
fossil), it will require much less involvement than
sequestration. Sequestration is the activity that
must be continuously maintained, monitored,
and verified to build trust.
CO2 is a colorless and odorless gas, and
carbon removal moves this gas into a reservoir
which is often unseen because it is underground
or underwater. As a result, verification is critical
to trust the system at the point of sequestration

Carbon accounting

and the point of claim. Verification at the point
of sequestration can cast aside doubt if it
compares a measurement made by a reservoir
manager against an independently measured
value produced by a third party. Verification at
the point of claim can cast aside doubt if it
compares a measurement made by a third party
against the number of credits awarded. It is
essential to create a fully verifiable system. It
means measurements are necessary, not
models, probabilities, declarations, or scenarios.
This approach will be challenging and costly for
certain sequestration activities, but the research
community can find measurement-based,
reproducible solutions in most instances.
Allowing methodologies that rely on
counterfactual scenarios and Life Cycle Analysis
to account for removed carbon as the norm does
not set up a verifiable system. Counterfactual
scenarios are representations of an alternative
world where something does not happen (e.g.,
there is no change in practice and business as
usual continues), and one is allowed to take
credit for deviating from this potential
alternative reality. Because the counterfactual
does not happen, it cannot be verified
(Lohmann, 2005), although one can show it to be
plausible using external information. While
methodology
development
can
take
conservative approaches, baselines are easily
manipulated (Badgley et al., 2022b; Liu and Cui,
2017). This baseline scenario is then compared
to a form of Life Cycle Analysis (LCA) that
estimates net removals within the boundaries of
an activity.
LCAs are very useful for understanding where
emissions come from in a process or comparing
the efficiency across different processes of the
same type of system. Despite their vast and
increasing application in carbon accounting
(Guinée et al., 2011), LCAs are not helpful for
carbon removal accounting purposes. Three
decades of research have amassed a large body
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of literature on the issues with LCA, some of
which are particularly pertinent to carbon
removal, and many remain unresolved.
The type of LCA will depend on the system
being assessed (Brander et al., 2021), which is
problematic when carbon removal accounting
spans activities as incomparable as forest growth
and direct air capture and injection in geologic
formations.
Furthermore,
they
require
knowledge of elements that are known only
approximately or rely on generic datasets (Plevin
et al., 2013). Drawing boundaries for LCAs is a
subjective yet essential part of the process (Reap
et al., 2008a). The subjectivity makes LCAs easy
to manipulate and inaccurate for accounting.
LCAs also rely on large amounts of data that are
frequently unknown or modeled, making the
attribution of emissions a challenge (Reap et al.,
2008b). LCAs must also make a value-judgment
decision on the question of durability (Brandão
et al., 2013), which has significant consequences,
as discussed in section 2. Moreover, because
LCAs for carbon accounting encapsulate other
greenhouse gases (e.g., methane, nitrous oxide),
it requires the reliance on Global Warming
Potential, another unverifiable and modeled
approach that makes a value-judgment on time
horizons (Balcombe et al., 2018). Even with calls
to switch from attributional to consequential
accounting (Brander et al., 2021) (that purports
to measure the change in emissions due to some
action), some of these problems persist. For
example, consequential accounting cannot
produce definitive quantitative estimates of
actual outcomes (Plevin et al., 2013), a clear
issue if carbon accounting is verifiable. The
complexity, expense, and time necessary to
perform an LCA make it a poor candidate as the
tool to account for carbon removal.
Accounting methodologies that rely on
counterfactuals and LCA often request that
estimates be made conservatively (Gustavsson
et al., 2000). Conservative estimates should

Carbon accounting

always be the right approach when accounting
for crediting purposes. Yet, what determines
conservativeness can be challenging to assess
when many factors are impossible to validate. By
relying on counterfactuals and LCA, the market
trades credits of removed carbon that it cannot
verify. This approach to carbon accounting does
not create a trustworthy industry.

4 Mixing carbon with other
problems
The climate change problem is a
development issue. However, it has become a
development issue because the world has failed
to act on the root cause of climate change. The
world has allowed energy generation to release
emissions, either by failing to develop other
energy sources or by failing to hold fossil fuel
sources accountable for environmental cleanup. The world may have been naïve about the
carbon problem three decades ago; it cannot
make that claim today. Focusing on carbon will
simplify climate action. Creating a more
equitable world by focusing on sustainable
development goals in carbon accounting
standards is admirable but misplaced. To accept
the conclusions of the IPCC reports is to accept
the severity of the climate impacts. A world that
does not seriously start managing carbon very
quickly will be a world where safeguards and a
focus on sustainable development goals will no
longer hold much weight. Carbon accounting
must tackle carbon to mitigate the climate crisis,
not co-benefits or sustainable development
goals. Those additional critical efforts must occur
in tandem, but not at the detriment of getting
right the carbon accounting that will support the
system the world needs to reach net zero.
Some customers may wish to pay a premium
for carbon credits if they come with certain cobenefits and enhance sustainable development.
Flagging out those differentiating features may
therefore be a worthy endeavor. Still, it does not
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substitute for a well-designed accounting system
that ensures carbon emissions have been
durably removed. Carbon accounting requires
credible, stringent rules to produce credits that
represent what they say they are. Credits
represent a guarantee that carbon has been
durably removed from the environment and that
the process by which this is accomplished
satisfies all applicable safety, environmental and
ethical standards as they would in any other
industry. Embellishing shoddy and cheap carbon
credits with attractive side benefits leaves the
purchaser open to a charge of greenwashing.
Bundling quality carbon credits with other
products that do not easily find purchasers is
unlikely to advance the rapid introduction of
carbon credits. Indeed, the current high cost of
trustworthy carbon credits would suggest that
selling such a bundle at a premium is hard.

5 Policy decisions
At the core, many carbon accounting issues
are policy questions that have yet to be
sufficiently debated in the public sphere. The
questions are:
• Is the accounting for and verification of carbon
removal a valuable part of achieving net-zero
emission goals?
• Is it acceptable to give credit to something that
was not proven with measurement?
• Is it acceptable to discount the wellbeing of
future generations?
• Is it acceptable to hold the carbon producer
only partially accountable?
• Is it acceptable to pay others to do something
that they should do anyhow?
• Do we want a definitive solution to climate
change, or let climate change remain an ongoing
crisis?
These are serious questions about
preferences that will have long-term
consequences. Methodologies of carbon
accounting will embed the decisions to these

Carbon accounting

questions. It must be clear to all who will benefit,
who will pay, and who will decide. The world
depends on carbon removal to succeed as a
climate mitigation solution, and success starts
with a solid framework that evolves from
addressing the root of the problem.

6 A framework for carbon removal
accounting
For the certification of carbon removal, there
are two critical issues. First, a certificate of
sequestration deals with carbon removed and
either stored permanently or in the case of
short-term storage, including the reservoir
manager's liability for any carbon lost from
storage (Arcusa and Lackner, 2022). This view, of
course, means that monitoring and verification
become critical. Permanent in this context
means "as long as the climate impact of carbon
would last" (Arcusa and Lackner, 2022). At a
minimum, this is a few thousand years. One
ought to accept that carbon in the ocean is also
a problem, then the time scale is measured in
tens of thousands of years. The required storage
times far exceed human ability to create
institutional safeguards against losses from
storage. Therefore, it becomes necessary to
have a scientific consensus that the probability
of loss from a storage system over such time
scales is small enough to eliminate most of the
risk of harm associated with the amount of
carbon stored.
That awareness creates several categories of
storage options. Short-term methods like
products and biomass would require an ongoing
chain of obligated remediation (i.e., storage of
carbon released from storage). Midterm
methods such as biochar are far too long for
institutional means of guaranteeing resequestration when needed but still too short to
prevent handing the climate problem to future
generations. And certain methods can be
scientifically verified as thousands of years, such
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as mineralization. To issue a certificate of
sequestration to a method, it must show a longterm obligation either through convincing
evidence of permanence or the reservoir
manager has a firm obligation to re-sequester
once the carbon escaped.
Second, the best way to deal with the carbon
problem is to demand a certificate of
sequestration the moment the carbon comes
out of the ground (Lackner et al., 2000; Allen et
al., 2009). Carbon should not percolate its way
through the supply chains, which makes it
virtually impossible to account for it, and
instead, people should be held accountable at
the point of extraction (Lackner and Wilson,
2008). If the carbon is cleared the moment it
comes out of the ground, LCA is unnecessary to
figure out who is responsible for what. All carbon
captured from the air, the surface ocean, and
anthropogenic point sources would qualify for
generating new certificates of sequestration. A
power plant could generate 90% of the
certifications it will need to purchase tomorrow's
fuel by capturing CO2 from the plant. The rest,
the fuel producer, will have to buy from other
people.
Instead of an LCA, direct measurements are
necessary. Each carbon reservoir would need
specific equipment and sampling plans. Still, all
accounting methodologies would need to meet

Carbon accounting

a set of requirements: methods must exist to
delineate the boundaries of the reservoir,
quantify the addition of carbon to the reservoir,
quantify the changing carbon content of the
reservoir at reasonable intervals in the future,
and quantify the error bars and uncertainties of
the associated measurements. The benefit of
measurements is that they can be verified by a
third party, providing proof that can stand up to
scrutiny. Auditors, paid by a public agency that
collects fees from auditees, could check their
measurements of the reservoir content against
the reservoir manager's claims providing
assurances for the reservoir manager's
insurance, investors, and clients.
There would be a transition in this model as
the carbon removal industry ramps up. However,
the liability to match all extracted carbon with
removal should begin as soon as possible, ideally
today. With such a policy change in place, fossil
fuel extractors would purchase certificates of
sequestration and futures that commit right now
to the removal of the extracted carbon at a
prescribed future date. If one can prove removal
capability, one should be allowed to sell futures
(in lieu of certificates) that come due in a
staggered phased-in timeframe. This would
make it possible for society to start demanding
carbon neutrality now and build carbon removal
capacity with a proven future market.

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