Cascade Climate is a philanthropy-backed climate not-for-profit organization focused on addressing aspects of the climate challenge that are underrepresented and underresourced in the current global climate strategy.
Cascade Climate welcomes the opportunity to provide feedback on the European Commission's consultation on the revision of the EU ETS. As a philanthropy-backed climate non-profit focused on Enhanced Rock Weathering (ERW) and other underrepresented climate solutions, we believe this revision is critical to clarify the potential role of durable carbon dioxide removal (CDR) within the EU ETS while maintaining strong alignment with the EU's climate goals. To complement our response, we are submitting a paper outlining Cascades views on the necessary safeguards to ensure environmental integrity and preserve the system's primary function of driving emissions reductions. Too summarize, we recommend the the following safeguards if the EU decided to integrate carbon removals into the ETS: ensure CDR integration does not undermine emissions abatement by maintaining the gross emissions reduction trajectory; limit integration to durable removal methods with long-term storage (geological, mineralization, dissolved bicarbonates); require robust measurement, reporting, and verification (MRV); and address price differentials through design features like minimum CDR quotas or price support mechanisms to secure steady demand. We believe it is essential that the EU recognize the need for complementary near-term policies to build stable demand for CDR units, as ETS integration could take years to design and implement. Critical options include procurement policies such as direct government purchasing or buyer's clubs to create predictable demand, and activity-based payments for removal activities in agricultural contexts that recognize both climate and agronomic benefits. The climate challenge requires gigaton-scale carbon removal alongside deep emissions reductions, so the EU should support CDR demand through multiple policy levers. For more details on our views and recommendations, please refer to the full paper attached.