392: What Will Happen to CORSIA & Carbon Dioxide Removal?—w/ Lev Gantly, partner at Philip Lee LLP

Thanks so much for tuning in to reverse in climate change. I'm the host Ross Kenyon. I have two sponsors right now. Rainbow, infillably LLP. If you give me a couple of minutes, I'll tell you about why they are very relevant to your interests. So listen up. If you follow me on Substack or LinkedIn, you've probably seen me write for Rainbow recently. They have a very idiosyncratic approach to how science is commercialized and how engineering works within carbon removal. And I really like working with them. I've learned a lot from the people there, the very smart, thoughtful people. And they're aiming to be the most developer-centric registry out there. What's cool about Rainbow is how seriously they take field engineering experience. They aren't there just to write a bunch of detached rules about how things should work in the abstract and then let project developers figure it out. No, they are very serious about field engineering, about how operations actually work in the real world. 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Well, one, Ryan Covington and I did a very fun show about how basically no one except for an elite few really know what bankability and project finance even mean. He lays it out very clearly. If you'd like to go listen to that show, it's awesome. It's linked in the show notes. And also we ended up talking about Ernest Hemingway from now to so keep Philip the tradition of reversing climate change. One also really cool thing is that they just won environmental finances. The DCM law firm of the year, they put it three years in a row 2023, 2024 and 2025. It's the only award for legal teams operating in the VCM and they have offices in the US, Europe, and the UK. You should check out Philip Lee LLP. Thank you for the bottom of my heart for listening to this and thank you to our sponsors. You really make this so that it's something that in a busy life with lots of competing priorities, I'm able to keep coming back and making more reversing climate change. Thanks so much for what you do. And now here is the show. Hey, welcome to the reversing climate change podcast. I'm the host of the show Ross Kenyon. I'm a long time carbon removal and climate tech entrepreneur. Today I have with me, Lev Gantley, who is an attorney at Philip Lee LLP, one of the shows sponsors. If you are looking for counsel within carbon markets, carbon removal, climate tech, let me know the above. You should consider Philip Lee LLP. Lev's expertise here in Corsia, its history article six, all of the various ins and outs of international climate policy, as well as what's happening at the national level. I want to ask Lev about what is happening in the world of climate policy, what kind of trajectory that we're on last week's show. I made the case for why I am not feeling especially optimistic about the overall direction of policy with regard to climate and carbon removal. And you'll hear some of those same themes echo today. But Lev also has a lot of experience in thinking through the nuts and bolts of law with regard to international climate policy. I'll leave it to Lev to go further than that. Thanks so much for listening and hope you enjoy the show. Lessons we started talking, the world has changed quite a bit. So where should we even start with climate policy? Which we even talk about today? Yeah, I mean, a lot has changed. We obviously have quite a number of conflicts and I think one of the probably one of the things that I'm most disappointed to buy, although perhaps not surprised is how quickly the various tensions, not at least in part imposed by the current US administration, have spilled over, into Europe, for example, and how all of a sudden we have brave, quote unquote, politicians in certain member states, taking what I consider, I think all of it as a consider, and fairly aggressive measures in the name of competitiveness in the current geopolitical climate to have all mighty cracks at flagship pillars of the EU's climate policy. That's one of the knock on consequences that I sort of sad thing in my bones in the climate world over the past few months, maybe maybe two months, but it does feel limiting to talk about climate generally in light of what's going on. And I'm not alarmist or extremists in my views. I just try to read news, feel a city to keep up to date with what's going on, but it is obviously. I don't know how to infuse your thoughts. What should we talk about? I mean, there's some good news that we can get into. Yeah, I think we should try to take an accurate pulse of world climate politics. I think the canonical view right now as I understand it, and I hear this most commonly from people who want it to be true. And I desperately hope that they are correct about it, that even though the US has pulled out of Paris, the UNF triple C, the IMO deal didn't happen because of the US. Various things that we were all hoping for that would solidify carbon removal demand or no longer arriving or arriving in the same kinds of ways are being carried on in places like Japan, Germany, the EU broadly, the UK. And while I think that's true, I think one the world is distracted by geopolitics in war. And there's a lot of different things happening with regard to like Hungary and Ukraine and the aid package to Ukraine. And there's also right wing populists who are electorally ascendant. There's also the Japanese Prime Minister and the changes that the composition of their parliament has shifted pretty far right to the extent that I wonder how durable CDR politics will be in Japan. I'm also watching things like what's happening in Germany and with AFD gaining ground. And you just know that when Europe is projecting low targeted growth rates and you're spending a lot of money on climate or things that deal altruistically like supporting Ukraine, that's a recipe I think for right wing populism to grow. And I think right now I would not bet on CBM remaining very strong in Europe. I'm not necessarily holding my breath on the ETS with regard to carbon removal. And I hate that I'm saying all of these things because they're all terrible news for us. But I also don't think that we can look away in the same way that if you have cancer or something like that, you should probably understand what the true probabilities that you're facing are. And I hate playing this role. And it's not fun for me. So how much of it is me being paranoid and how much of this do you think is something that you're very concerned with? I think you're right to be worried. And I do some life cycle to be able to be worried about both things. Other than life cycle to that, I think about, you know, the other side. And I think there is some sense that in the universe and I tend to keep myself on that side of the, of the, of the, of the atmosphere as much as I can because otherwise the job's far enough as it is. Right. So, so, but I mean, just just sort of focus on making zoom in on some of the things that you, that you mentioned. And I mean, you mentioned Germany ends in the right wing pocket as part of there. I mean, I wouldn't even go that far. I would say, you know, Friedrich Merz, only a few weeks ago. I think green. industry conference, I think it was called something on those mines. In Europe, it was one of the big voices to have had to go at the emissions trading system, you know, effectively, and I'm paraphrasing it now, I don't have to quote, but it effectively saying something along the lines of, and if this is no longer shit for purpose, then the current cost and penalty list amounts, Kate, that we're in, we're in writing to the re-engineer of this policy or could something else completely. And yeah, he, he, he paired back on that a couple of days later because he was challenged on us. And, but there have been, you know, George and Meloni, and you had energy policy coming out and Italy as well, effectively trying to circumvent the emissions allowances that power producers in that they would have to buy and retire, question mark around whether or not that kind of unilateral move by ethnic would be fashionable and under under under you law, they actually go ahead with this. The, I think there's been noises around how do we, how do we appease some of these utterances that are coming out against the ETS and, and the sort of obvious candidates for how to do that are things like lowering the, what they call the near reductions factor and it's not extending out the dates by which there will be a phase out, but then he pays out of, of free launches. And, and they're not, and what's been suggested to be fair is in drastic either. So, so for example, and the linear reduction factor, and at the moment, I think it's 4.3 percent and it goes up to 4.4 percent, I'd be in 2028, which leads us to zero allowances in circulation in 2039. So that's just to be clear, that's the rate at which the overall volume of allowances that are issued and unilateral basis reduces. So the suggestion by, and the guy called Peter Lee's is one of the sort of big thinkers in the bureaucracy around how all this should work, the suggestion for greatness to reduce that down from 4.3 percent to 3.4 percent, which would mean it would get to zero Iber E, some time in year and 40's, it's that have been 20.2 or 20.3, instead of 20.3 United States, it's not a drastic difference. And so that's some sense coming through there, like the other, the other big point around this Ross is how they will deal with this wonderful work, and the people like to call flexibilities, right? Flexibilities. Flexibilities within the pillars of E, climate policy, you have flexibility. So there's three big things that probably know that hold up Europe's climate targets, the image of trading system, the apprituring regulation, and other than see a regulation in each of those as up, that's the reason. And there are questions around, and there's actually about interestingly some CDR perspective there are, and actually from an international market perspective, there are two big consultations out at the moment they were released I think two or three weeks ago, and the consultation period runs to the, I think it's end of May, on May, something like that. So first, it's got to do with the integration of a Brexit project occurring under the current little certification framework, the CRCF, and how that should happen. I'm off the back, second. And the sector will is around, how should the integration, you might have seen that actually last week they finalize effectively, it hasn't been, because they're publishing the European journal yet, but it will be back to the last four-year-old step. But the amendment to the European climate law is definitively finally approved, and that climate law sets the European target for 2020, which is 90% of the production is against and by 2040 against 1990 levels of the issues. And within that they make a specific reference to integration of up to 5%, or the achievement of up to 5% of that targets through the views of international class on the power of the screen. Now, mechanically, and from a quality perspective, et cetera, how exactly that will work remains seen. But the second consultation that I mentioned is around the questions about how that will work and what the different options are. So the two public consultations are really worth reading, and really worth responding to and for other things that care about keeping your climate goals on track, and they're reading importance. And I'll pause there, but I can get into some detail around those things. Well, I'd be curious to know, did you put a letter in on behalf of Philip Lee LLP or yourself for clients, or do you actually weigh in on those matters? Do you try to put out a perspective? We need to be careful from a lobbying perspective, because we are a regulated morpher, so we are registers with the appropriate authorities as an entity that could engage in certain modern activities that we definitely make disclosures around exactly what we're doing. So I haven't planned on doing that, and IEDA, the International Relations Training Association, that we remember of our submitting responses, and we are feeding into what they're saying, that's for sure. The really interesting thing, Ross, is the live-loaded Arons, where I'm based and where the firm's headquarters is, holds the presidency and of the council of New Guinea in the second of our fiscal year, writes exactly the point in time where, you know, arguably the greatest set revisions to the ETS will be on the table. So one of the things that we may end up doing, and I suspect, the world is, and TEC is submitting some sort of document to our ministers here, just to lay out the lay of the line to enter conventions in which things let go. Around the ETS, around the increased gracious CER, actually not just in our, but then it is in Europe or general. And interestingly, the big question would be around that. One of the biggest questions I would be around this update to the TEC is as it applies to the carbon offsetting with oxygen pressure, actually, the radiation, just cause CER. That is, that is, if they do what some NGOs are not being going to do, it would be big relays, at the end of the 8, into the overall trained geopolitical dynamic the very hard we've been through. Oh, yeah, fishers that I'm sorry. No, no, I mean, I'm a closed like I'm getting stuff, people I can. Yeah, I mean, there's so many different parts of the political framework here to dive into. And of course, he is obviously a big one that people look forward to. It has less for carbon removal people, I think, just because the types of credits that qualify for of course, he, I think are so much cheaper than carbon removal. There's probably changes here. I'm not really aware of that you can fill the audience in myself in on, but is of course he is something that is good for carbon removal if it survives intact? And is it likely to survive intact? Will it also face political pressure as the biting time comes to bear? Well, I'll click the rest of the episode and I think so. 40 minute lecture. No, I'm happy to give it up. I'm happy to give it up. I want to keep it, keep it assisted by 10. I think that just answered the question of course, see it and what's happening. The first and then we can get into relevance. Of it all for carbon removal and I guess the audience of your, of your show. It's what's just about to track a little bit. Why do we have of course see up? Why do we have this scheme for emissions of the national aerospace? But we have it because back in the days when the EU was bold in that gun it's see far, far away. We no longer do it. The EU set up the emissions trading system back in 2005 in 2008 I think it updated this to include a requirement on carriers so on airlines to retire and emissions analysis. Right. And initially that was sort of included for intra EEA so you're thinking economic area flights. They then announced that they were going to actually, in idiotically at the same time, extended to the international aviation. So flights coming in and out the European Union would be liable to buy in the tire emissions of analysis. To effectively allow them to, well, emissions amounts to what they are. The carbon credits that bear their licenses to pull you rather than project-based credits for the Reduction to the Redubber, so that they would be required to buy these licenses to Pula for their international Rats. As soon as that happened, back then, the UK was, again, in that galaxy far far away, it was part of the EU. And the UK was brought to courts. I believe it was by the UK Government has brought to court for basically implementing the Courcior Regulation into domestic and UK law, and it was a court case taken by I believe. Airlines for America or the prior iteration of airlines for America and related groups suing the UK Government for effectively applying EU law extraterritorial rights. So for applying European law to things that occur effectively in international aerospace over which no one really has jurisdiction. The UK court needs to high court appeal to the European Court justice. And I believe a couple of years later, two to three years later, and the European Court Justice Roots say, "Well, actually, no, we disagree and we think that this is a violent application in European law for all its reasons." But there was a pretty negative reaction. So I think the Chinese carrier has cancelled several, I think, over 10 billion dollars worth of orders from Airbus and retaliation and the Obama administration. I think this was in 2010-2011. The Obama administration passed the, um, what was it called, the ETS Prohibition Act. Right, so basically prohibiting US carriers from complying this. Which point the European said, "Okay, okay, we've won the chase, but we'll play good global citizens here." And we'll let IK owned the introduction of civil aviation organization come up with this multilateral esteem that creates a level of paying fields for all the airlines that are on the world that operate on the roads and across international aerospace. So then in 2016, you have a general assembly, um, um, the NK General Assembly, which introduced Corsia and then you've had a pretty named duck pilot pace, which ran from 2019 to 2021, so right through COVID. And we are, we're currently going through what we call CP1. So of course, CX phase 1, which covers, sorry, the pilot phase, I think of from 2019 to 2022. And so CP1 covers 2023, 2024, 25, and emissions and 2036, so we're still in CP1. And it's a voluntary phase. It's still a voluntary phase. But it's only voluntary to the extent that, um, contracting states, IK, zoom out for seconds, IK is a creature of the Chicago Convention, Chicago Commission deals with all the other things that do with international aviation, from safety to ability to land and dock and certainly airport, etc, to environmental to matters like Corsia. So and then most nations around the world are part of the Chicago Commission, otherwise the wind being able to operate aircraft. Um, so where we are with this now is, um, we've got about 120 most contracting states, the Chicago Convention that I've opted in to voluntary participation in this, um, Corsia phase 1. And the last year, it used to be monitored just this year, basically six. And the date for retirement, of course, the eligible emissions units is, uh, January, 12 to 28. So about 18 months from now, next year, 20,000 is actually start of this, of CP2, Corsia phase 2, which is mandatory. So all contracthood states have to comply with Corsia pathways. And what's really interesting about all of this, just the mechanical, so you have this like UN scheme called Corsia. Me and the me, like in the background, you have this EU law that's sought to apply the ETS to international aviation. But in effectively, there's a small room change in the regulation that stopped the clock, right, on the application of the European ETS. And then they deferred, but it pushed back the assessment of how Corsia is going twice already, right? So they revisited that, they, they, they extended the stock the clock two times. And so the point in time, at which the effectiveness of Corsia, as far as the EU is concerned, must be definitively, conclusively reviewed by the EU is this June. So the commission, under the 2020s re-update the recommendation, I think the commission has to produce a report to the council and the parliament. Effectively explaining how effective it, it, it, it, it thinks the Corsia is by looking at two and particular points. I think, I think the points are, if I remember correctly, that participation is at least, why not less than 70% of contracting states and, or Corsia at least, are not less than 70% of overall running the list of flights, it's something like that. And the second one is that the Corsia has been strengthened to be in line with powers of the EU goals. And then it says, depending on how this report turns out, the commission proposal will be accompanied by a piece of, I mean, I guess, amending recognition, which will, it do one of two things. It will either say, right, we're stopping the stock the clock, we've had enough of this, it's not working. By, but with 10 years now, well, we wanted to apply the ETS, you told us no, the Corsia, go, been waiting, ain't working. Yeah. Or they say actually this is working quite well, it's, you know, creating a plain field that's a common cost for emissions, international aerospace, that all the airlines wrong the world described to be all paying the same amount, they don't have to deal with the confusing patchwork of approaches depending on where they fly to the uniform price, the rules that apply to the credits are all the same because the, I, Kale sets those rules, and we quite like it, we need to, we think we need to get this time to breathe. And, or they'll adopt some sort of a hybrid approach I can get into. But all of this is very interesting because again, this is coming, this assessment, this June, you know, after such a long time and kicking the chance down the road and ratios to stop the clock, is obviously coming at a point in time where, you know, less than 12 months ago, the US put a put a put an embargo effectively on the IMO and discussions. And we're seeing what current administrations do, kind of policy generally. And we see what the spill over effects that we talked about in relation to the overall sentiment in relation to ETS in Europe. But the Corsia is something that, then, the US airlines pushed for it, right? They, they pushed for that. They would have really kind of happened because of US airlines. So, it will be really interesting to see what, what Europe does now, because this historically they didn't really want it, they wanted to apply. And, and there's certainly a kind of deep lobby groups out there in NGOs and, and what got, say, no, no, this doesn't work, credits are low quality. There's not enough of them, both, the integrity, not enough states that participating, not enough states of transposed, Corsia, their domestic laws, penalties are on circle, right? All these things are out there. So, I mean, might, just to close it out, we can go to the CDR aspects of this and let me ask any questions. I mean, might, might own view on this for what it's worth is that I think it would be crazy at this point for the EU to, I just think it's, it's, it's, it is an arbitrary point in time to look at Corsia because it's still, effect could be in the middle of what is a voluntary phase. And it relies, Corsia relies on Article 6 of the Paris Agreement to a large degree. An Article 6 of the Paris Agreement was only concluded a year and a half ago or so in Bakun. And it's just now in the last 12 months where you got host countries that host these projects are getting to grips with how Article 6 is supposed to work. So we're just now starting to see supply of planets come online. And so it's just a terrible time for the EU to make a decision around this. And also I think I'm telling the best of the airlines, you know, that, that, that ferry people around the world that didn't and couldn't necessarily afford to travel them to the repren of the decent thing that they have to pay the price that we pay year in Europe. Does the strike means particularly equitable rise in the kind of ignore, in the kind of of ignores which the EU tends to do anyway actually to the EU's fall to some degree this principle of common depreciating responsibility that we have ensured and we would have triple C and, and all the treaties that follow this, right? So I'll pause there but I, and I'll ask questions that we can get into the CDR and why this is running. But I'm actually very interesting for CDR down in the line. If it's And I think on balance sense it's going to prevail here. And I think that some version of it would maintain in Europe. Hmm. Okay. I hope so. It would be good if we didn't, although I am also spooked by saying things like the national rally is predicted to maybe when I'm like a major French election, like that's sort of like being set up and predicted right now. And I don't know, it's a tough spot because I don't want to avoid standing up for the climate, but also there are ways of doing it that potentially antagonize the stressed Europe that is having to commit much more of its GDP every year to defending itself and no longer thinking that the US is trustworthy with regard to NATO. And they also have to spend on climate stuff on top of that. And like I mentioned earlier, the growth rates are pretty small for Europe this year. And they're probably much smaller now given what's happening with oil prices. So that being the case, I feel like climate politics are a little bit of a loser, electorally, unless they're framed in the right kinds of ways. To what degree, of course, it catches the national attention and something to rail against rather than the ETS, which I imagine in Europe is probably more well known on like a household basis than Corsia, which is like a more specialized obscure kind of thing, I think. Feel free to comment on that if you'd like, but assume you don't survive, tell me about the CTR's potential. I would rather that would pick point like the end. Yeah, you have the confidence in the response to that. Like the other thing that the European needs to be mindful of is the reaction of their own arrogance, like, they're in the Serf Franz, KLM, etc. And so the reason why this is really interesting as well is because this is the first year, 2020, 2006 is the first year. So up until the middle of last year, I believe, there was a significant portions of the, I think, which all, I think they started to face them out last year. So I'm talking about free allowances for the aviation sector, right? So they had free allowances for the aviation sector, only ETS, up until the last year, right? When they faced out, I think 50%, so then there's auction for 50% for airlines. This year is the first year and there's no free allowances. No free allowances. So European airlines, by April, 2027, will have to have purchased and retired and emissions allowances for the full exposure for the first time. That is going to be expensive. So it's done as, you know, got to wake heavily on their bottom shoes, I suspect. Let's just say, if you're supposed to turn around and say, "Oh, yeah, guys, in addition to backs, you're going to have to pay the same price for international emissions." You know, you cannot anticipate what kind of reaction that is going to be from the CEOs, the CFOs, from European, from European bank carriers. I'm not even worried that much about them. I'm worried about the Gilles de Jean, you know? Well, but this is the plong pack. It's exactly, but two things are completely related because the only thing that's going to happen is that they've gone to pass through to the consumer, right? And all of the sudden, you're not going to be able to go and visit your cousins and the Austria-Gurus friends or wherever they might be. It's going to be a lot stentier. You can see all the next T3s, 4, 5, 6 years. Right, CDR. CDR and Corsia. I mean, I think I keep this simple. We, the challenge with unlocking supply of credits into Corsia is linked with the challenges in implementing Article 6 and the power of the Green and app-host country level. So in order to determine if you as a country can authorize the export of carbon for use by someone else, including an airline under Corsia, you have to have determined a few things. Those things include your ADC, your last-year-determined conjugation that you submitted to the U.S. efficiently ambitious, but they can have headroom, that, within how you design that NC, to export tons, a particular re-vehigation activity from a project class that fits within a particular sector, right? For which you have, for example, mid-specity clear, you're going to seat external finance for the mighty Concordial Finance, that is how you go to meet your NC, right? You have to have headroom to export the tons. If you export the tons, you can't count them towards the agency, right? And what's interesting about CDR is that CDR sits as far as I'm aware, tell me if I'm well, then I haven't seen any NC and have been read reports about this, I'm not aware of any NC that has any reference, within the NDC targets, the country is going to include any element of CDR within the current NCC cycle. Now, they have this separate thing in addition to NC's called Bang-London goals, some of the powers of remittance stretch is 10, 15, 20 years. I think there's some references to carbon characteristics that are just those, but those are not the same as NDC target, this is supposed to help guide the design of future NC targets. So for all the Tedson purposes, things like biochar, hair stock weathering, DAX and DAX, they are not currently within global sales, country targets, right? And so therefore, because they're currently outside those targets, it should be a no-brainer and that countries could authorize and export those tons freely because they do not, and canals, jeopardize the achievement of an NDC target because they don't throw a part of that ton. The problem, the problem, of course, is that it kind of married, it married Article 6 too much, you should have married 70% of the way, already percent of the way, right? The Article 6 rules, the way they're written, they basically say, you have to, you as the host country, once you've authorised the mitigation at today, you have to correspondably adjust your emissions balance and your national inventory accountant apply, rhythmically add the tons to your emissions balance, their respective of weather and authorised activities inside or outside of the NDC. And the reason that rule book does that, it's because it's supposed to ensure fair principle than balanced application of corresponding adjustments between two countries, it's supposed to prevent double counting as between two national greenhouse gas industries, right? Corsea, the land of international airspace, is not of actual greenhouse gas in Richard, and Corsea solving for a different problem, and that problem is double playing, playing between the airline, playing between the country, it's not the same as counting between two national greenhouse gas industries. And so the point, therefore, goes like this, if an airline is buying the biochar ques from K, for example, they're using that for Corsea, and biochar sits outside of K, saying C, why should K, you have to also analysis, right? An exporters and apply power spot adjustments, because it's not in the end in C target, right? And it's not double counting between two greenhouse gas industries, because one of them is just to claim by an airline for emissions in slash airspace, right? So this has come up in conversations increasing and increasing frequently, because there is a fear that because of this pressure at host country level, around jeopardization of NDCs to overselling and over export tons, how do we make sure that there's enough supply, going into Corsea? Think about this, Rothschild, for phase two, I think for the current, for phase one, Cp, on three or four, 25 and 26, the overall demand is somewhere between 120 to 220 billion tons, something like that. And CP2, which runs for 20, 20, 23, 25, there's hundreds of millions of tons, it can add, right? Could be scale, and for as long as CDR remains outside of NDC targets, which I suspected will for a long time in the future, because those activities are expensive, you know, they really carbon price is about us to come and do them. They're not things that countries have really planned to do, they're not the sailors reducing emissions in your way sector, for example, but you will probably stay outside of NDC targets. Could we scale CDR and the global south, if we created a demand pool through Corsea, if there was a root change for my tail that says, actually, for a narrow category of activity times that sit outside of NDC targets, that's called the null CDR. We don't need to see authorizations because there is no fear of double-claiming. No fear of double-campus because the countries are counting it as they're outside the terrace. You could unlock what is significant to that in a half-life and it's actively staying over the next 10-year period. It's something we have been trying to push that narrative with the folks we're speaking to and what we've been told, including by relevant people in the right rooms, that it's a great point and the point needs to be pushed at the IK Regional Ascenders by my major states, the only way because the TAR, the technical advisory board, made the people that assess and make all these rules around what's called and what doesn't, what you have to do, what you offer, what not, they take direction from contracting states, that's the Chicago Convention and those directions are given in the general ascenders. Part of the problem, though, of course, is that you have along the aviation ministers and traffic ministers showing up the IK Agenda Assembly, not the climate ministries, like right? So these ministries need to start talking to each other. So you want to unlock the supply. I know, I mean, if we could just click the court here and say, "Don't need authorizations," art 6 doesn't matter for novel CDR pathways. Right? Now, you're still going to get into a price in debate, right? You're still talking at the moment of $100 million made from biochar in Kenya versus 2013 for a king-cooking tone. But think of it this way, right? If art in 6 works, the availability of lower-hagant fruit mitigation should disappear because NDC is supposed to ratchet up an ambition. You keep all the low-hagant fruit for yourself in export higher-hagging, more ambitious fruit that you can't afford to pay for yourself. Next answer? So if the whole thing starts to work as it was intended, we could create a lot of demand. It could get very interesting. I see isometric. I've been approved for Corsia, and I think some of the other CDR-focused standards have just recently been the last week or two or are about to make it this week. There's a window for application for C-truity-approved program for C-Face 2 that is open right now, maybe it's closing this week. But I know there's a two of the CDR-focused standards that are submitting occupations. Sorry, I'll post there. I realize I talk quite a bit. That's okay. Now it's very useful information to understand. I think a lot of people know these terms, but how they interact and the potential overlaps and potential gaps they might fit into are obscure. So thanks for clarifying that. Are there places where you are seeing good, durable policy support for carbon removal right now? I mean, not in the global south. I would say not in the global south. I'm just not seeing it. It doesn't need that. It's not happening. I mean, what interesting thing Ross that is happening, and I'll come back to carbon removal in just a second because we are starting to see interesting things, even faces like R and R, or start on carbon removal. Would like what are the positive things that say it's kind of unfortunate because at a point in time where we passed the R6 negotiations, conclude 18 months ago, a lot of host countries are really ramping up as they are readiness. So policy support, just not for CDR, but for other types of mitigation activities and new energy, you could copy and whatnot. You could put it, they're putting in face and pretty sophisticated, you know, climate laws and carbon market frameworks all across the board, sub to higher and Africa, central Asia. You know, we work with local lawyers to understand what these laws are as we, as we advise our clients and we are always present and surprised to see some detail and the work that goes into creating those frameworks. It is unfortunate that the moment we don't see specific references to CDR activities, but I suspect it's a matter of time probably before we do. In terms of CDR, I'm not scared. Europe thinks it's seen to be happening. The reports to me out of Spain and the durability, obviously, is a budget of the odds to commit to CDR activities. In Ireland, we've had good conversations with several government departments that are around potentially creating framework here for carbon farming. And there's a refocus on biochar here then as well. There's the, you might have heard about the EU CDR Buyers Club that is informed. Remains to be seen with that looks like the members of this club are whether it's private culprits or member states or government departments or a combination. But you know, what's your take on what makes a good CDR policy? Right now, I'm looking for policies that are likely to survive changes in polity. And depending on which political party is in office and different countries that previously supported carbon removal, I'm wondering if that's changing. Like, there's two parts of it. One are places like, okay, Canada has historically been supportive of carbon removal and Mark Carney seemingly is personally supportive of growing carbon removal. But Canada is also facing very high cost of living and spending much more on their military and is trying to cut trade deals around the world and their economy is going through structural changes. And to what degree is climate policy going to remain a priority in Canadian politics, especially noting that the Liberal Party only won the Prime Minister because of Trump's 51st-state talk. And without that, a pro-lever would have won and the conservatives would have been in power. It's like Canadian carbon removal commitments do not seem super durable to me for that reason right now. But there's also things just like, even if you wanted to do it, the politics may not be supportive of it, given changes in military spending, cost of living, much more pressing. There's a pothole on my street kind of issues that politicians need to worry about and worrying about things 20 or 30 years in the future for temperate climates like Europe might be a harder sell on a population that is concerned about their grocery bills going up, where they're heating costs going up. So I'm just trying to find places where carbon removal has policy that is life enhancing, cost reducing. We're just like something else that has a durable political coalition around it that is not an easy target. I feel like things like the ETS are kind of easy targets to poke out and be like, "Yeah, why are we doing this if the US isn't doing this? Why are we bothering to do it? We have low growth rates and a population that's going to throw us out of power if we don't sort of be realistic about what it costs to live in Europe right now. What is going to survive dynamics like those?" Super interesting. I mean, my high level, not very sophisticated, take on carbon removal policy in places like Canada and the US over the last couple of years, just that I have quite a few carrots, and I've got a lot of things to do with carbon removal. I've got a lot of things to do with carbon removal policy. In terms of how do we ensure a concerted, stickyness of policy, stickyness of policy of hangs around people that requires people to bond. My question is always, I get in clients doing interesting things several times, you know, open for months, and I always ask them, I don't say this is bringing it quite a great lot of health. I'm not here to get business applause, interesting lawyer, but who's going to buy this? This is great, but who's going to buy it? Who's going to buy the tons? This is really expensive, right? You guys doesn't see, but who's bond? Who's buying this year? Who's buying five? Who's buying 20 years? Where are you doing this? And so this is all about how do we create demands, mandatory compliance based demands, either on polluters or by or government departments. So, you know, one of the things that we're thinking about for our own, for example, is the effort sharing information and see our contribution. And the order is that the only member state, like a lot of the member states are compiled, and they'll have to pay for this. They don't hit their targets, they'll have to pay billions of euros in funds. In Ireland, the rate is so much towards 20 billion euros. There's some questions around it. There's also one pocket in it. You can back around it in a different way. Question marks the levels of those shrines. But that's what he talked about. So how do we actually help Ireland meet its clientele targets? The sharing recognition, which covers things like waste, agriculture, transport, things that are not of the ETS, right? And then the landing signs changing forestry sector. A lot of farms in Ireland, lies. A lot of grazing going on and while not dairy production, beets etc. If we want a policy that requires, for example, farmers to implement biochar, well, not necessarily, but bio-bying child has been produced and it's spread across the land. It has the soil, fertility and sequestration in the lands. You know, could the government, for example, pay for us, rice? And that would allow effectively others to subsidy to farmers. It needs to be solved through in a bit more detail in government. We might adopt supporting government to map the South, but using levers that don't agitate folks that are struggling already, like the margins of these people make are already quite tight. And that's the case with the Giozion as well, right? You know, that's why there's always rows in the verge of that combustibility, we're asking people to be carbonized if people are just trying to make ends meet. So we have to make it palatable, right? So, so who's going to buy? Because Ireland goes to legislate for corporates that are pillaging or that have got their headquarters in Ireland for the rest of Europe to buy these tons or incentivize them to participate voluntarily or is the Irish to, you know, department for agriculture department for climate change going to buy these tons and count them in Ireland's national measure. You know, that sits with the the targets, right? Because otherwise we're going to have to pay fine. We need to do some good stuff. Farmers deferred or help farmers, you know, room of missions who buy which are other means we generally in agriculture and, or we pay fines. Right? So we have to be smart about how we do this. And you know, the integration into the ETS, that's the other piece like, right? Who we talked earlier about like reducing the, you know, easy topic about reducing the linear reduction factor, keep free put, what was said, pushing out the date for the period of your free allocation roses. And there's obviously talk of introducing backs and backs into the ETS. Because they're, because they're obsessed with, you know, the Indian years. Tra, yeah, might for Mike have a fine chart. I like, I mean, ETS delay might be a really smart example of this just first surviving the political moment where, okay, it's no longer an urgent political issue because the biting point is farther away. The next election cycle can deal with us instead. That might give some breathing room, even though it's painful like losing years to this, the curve just gets steeper and steeper and it doesn't feel great. I like this suggestion for farm inputs. And I was trying to think two of the politics are different in Ireland around this where, like for instance, did you follow the attempts to limit liability for glyphosate with regard to Bayer and interaction with the Trump administration? Did you see any of this? Are you too busy being a lawyer? I do, a lot of my night time is consumed by what by following what's happening in the U.S. But there's a couple in that roster. Yeah. But do educate me. Well, there is just an attempt where, well, okay, I guess the best way to put it is that there's a lot of tension between the MAGA and LAHA parts of the Republican Party right now so that make America healthy again, Robert F. Kennedy, crew, obviously no great fan of pesticides, would like things that would be more regenerative, less toxic in this room for biochar in there, for sure. I think that's a really cool crossover point that could be bipartisan in a way that everyone could pretty much like Bayer trying to limit their liability for the never ending onslaught of glyphosate lawsuits that they face where they have billions in payouts over and over. It's like, please cap our liability so we stop having to pay out forever for these cancer cases. The glyphosate side of that is winning and the MAHA side is sort of just like, okay, well, guess, guess, this is like a betrayal for them where for the election process it was like probably a really smart pick to make them the health and human services head. But as it goes on, you realize that commitment was probably not equally shared across the administration. And so I'm wondering if the politics are different. Okay, everyone in America likes carry gold butter. I would love to have carry gold that had a sweet made with biochar tag on the box. That would be wonderful. The ag inputs industry is also just super powerful. There's not that many of these large agribusinesses and they have a lot of power in Washington. And I wonder if the politics are different in Ireland such that a more regenerative farming model might not face the same amount of uphill battle. What I think said one small caveat is that agribusiness is trying to figure out how to incorporate some of these changes as they're noticing in some cases that synthetic fertilizers have diminishing returns and cannot be applied forever without causing other harm to soil. And that consumers in some cases do want to switch. But also all this cuts against cost of living stuff too. Like people just care a lot less about the sweet little biochar logo on the carry gold box when feeding your family is hard and $100 of groceries is a single bag when it used to be four bags several years ago. So maybe know this matters as long as the bread and butter issues at the kitchen table are top of mind for so many. They are and clients rust for that and they are. I tap help but think and go back to this point. You know when you say things like bread and butter issues being top of my ears and the kitchen table has got food on it being obviously called firearm for pretty much everyone. Are we living in a power of the universe? Like that's the question. I know I do think that you spend most of your time thinking about the scientists says, I have to say we need to have a lot of removals. We need to have removals to chew off the thought of the human industry effectively like writing terms of the size of your scale that we get to. Yeah. And that's to bring us down from when we all have shit. Right. So I'm essentially not the arch old to all the shape. There's what we're dealing with I think. I mean, this is to come back down. How do we, how do we bridge this gap between where most folks feel what most folks write me feel is important to what people, you know, in the CDR community in the climate team, what stresses us out. What keeps us awake at night. How do we, how do we bridge that gap? It's a pretty close gap, isn't it? I like that. I struggle with that. I would do an eye on there can't be enough, you know, like mine did right minded, maybe that left side of politicians, you know, let me ask you this question. If you, if you had your pick, and I don't know what you think of Mr. Newsom in terms of 20, 20, 20, 20, 28, but let's say he did commit his office is responsible for, for some fairly interesting policies in California, but you know, he's a backer, all the cap and tray there. What would you in a world just just just just just fantasize for a second, like, you know, where up really comes it? What kind of policies, what do you like to see us do on global stage? And the good end, you know, but also domestic, you know, that credible level. Right? That's interesting because like, like the, like the Ross, the US is such a big tone set for what happens, right? To the rest of the world, you know, which is what we see. The spillover that we mentioned starts into into into EU politics, like that, like I find myself thinking about that quite regularly. And I can't personally, I'll let you talk with the second, I can't put my finger on. It's a use and we're someone else. Why come saying, what is a bup-a in terms of 20, 20, 20, 20, 20, 30? I think the format of this question is fascinating because I haven't even thought that far ahead. The news cycle has been so much quicker and more immediately oriented. As far as people are thinking ahead, I think it's more towards the midterms later this year. And yeah, I mean, I keep saying people talking about a new, some presidential candidacy, but he's also a highly polarizing figure. Now, much of the country hates him. Like, hates his guts. A lot. People blame him for the state of cities like San Francisco and things like that. He said things about trans athletes that were supportive, that like a lot of the country finds out to be like a super important issue to them. And he's taken some stands that are pretty courageous in that way. We've also seen people do pretty well that are, like for instance, the mom Donnie win in New York is something that people look to. Like Democrats at the national level, during the primaries they talk left, but they govern from the center. And then the general election, they also run from the center, relative to the primary because most of the country doesn't like friendliness with socialism. That sort of imagery in rhetoric turns a lot of the country off. And so even when you do have people who make it that far, there's not that many of them, like Bernie Sanders is in the Senate. But it's Vermont, so that kind of makes sense. The other members of the squad are in the house, and the house oftentimes has more radical politics of right and left. That's just like part of how how that process works. It's like even if governor, governor Newsom was able to make it to the White House. I'm also curious how much he would be able to do. Over the political capital that you bring into the White House, are you able to quickly rejoin Paris and the UNF, Triple C and restart some of these things? Or are there things in place, legally that have already been decided at the Supreme Court level, or legislatively that makes this really hard to just dive back into? And it's also possible this causes a revolt in the opposite directions as well. Like even if the Democrats took the presidency, and we're still running off of a good midterm showing, and maybe they control the House, maybe they do or don't control the Senate, but it's probably pretty even still. And if that were to happen, very famously, presidents come into office with a majority in the House, midterms usually slap them back, pretty good too. So it's possible that Newsom would overextend and then lose control of Congress, and that would stime you think. In the same way that we're like, we're all expecting that to happen with Trump, unless his voter ID stuff passes, in which case one expects like the Democrats not to sweep the midterms. This is my own super long explanation. So I don't even think that far ahead. Even if you did have a committed US president enter, the presidency, are they able to easily rejoin climate multilateralism, UN climate politics? Can they rejoin these agreements? Or how would that even work? I mean, I was caveats by saying I'm not a US lawyer, or a US constitutional lawyer. So these are really sort of technical. I mean, they're mine. I just talk, man. You're a lot, it's a podcast. I know, I know that. And look, I think there's some pretty qualified professors from staff or other places that have written articles about this already, I believe. Oh, yeah. And I think there are some news to suggest that because he's so executive orders that's his way out to the UNFCC, that it doesn't need a other congressional approval to come back in. The next president's to use this executive order. Interesting. And, oh, same, I'm parrically with Paris. I'm pretty. But it's, you know, what is being party to the Paris agreements? Like, what is that about? Right? And I think the most important thing about it is, like, why does it matter? Why does it matter if the US is party to the UNFCC and party Paris agreements? Right. I think, but the Paris agreement it matters because the US is second, first or second largest plurator and globally in terms of the missions. And what does the Paris agreement do? Well, in theory, you know, brings together the emissions of, you know, over 190 countries and all of their measures. Then you start being out and figure out what a work will be wishes and what are our global targets and how much do we need to, and how does those targets fly every try years to hit the Paris-Telverture goals? Right now, there's a big gaping hole, right? And the Paris agreement target, what point-fired Greece? How could you try to beat that target when the biggest emitter is? It is no longer counting the beans, right? So, you know, I think that's the first problem. You know, knowing what the planet is for the US and the US is actually playing ball. From a carbon markets and from a CDR perspective, about to slide more of greater conversation, low-pocket to carry to. Yeah. All the interest to see, but just like on a macro level. And it's really important to have everyone's accounts. He had to work out where we are without having any accounts. Right. I've just, you know, guys have been on this one point specifically in all of pressure. This one point is the thing that I am always thinking about when people are saying, like, look to the rest of the world, their climate politics are still going. And I'm concerned by that for part of that might just be inertia. And it's going to continue on for a while, then we'll see what happens. And maybe it rolls back. But the US not being a part of this, the game theory of it, spooks me very badly because we're probably not going to achieve climate targets without US participation. And the politics of countries that are still participating in climate politics, voters are going to be smart enough to be like, if the US isn't doing this, and they are the world leader in one of the biggest polluters, we're probably not going to hit our targets. So why are we spending a bunch of our tax dollars on something that is not going to ultimately stop this thing if we don't have full buy-in? It like inverted the politics. So like when the world was broadly committed to climate politics, countries that were holdouts could, you know, everyone could wag their fingers out there and say like, we're already all doing this. Like you should join us. And the momentum is on that side. But the momentum switches without the US in it where it's like the voters are saying, why are we still doing this if the US, we're not going to hit the target. So why are we spending the money on it? And that part really scared it. And what you just said, I feel like people don't like technology, or don't talk about how much US leadership matters because it's easy to hate on the US for, you know, being a world leader and has like that team America kind of effect to it. I get it. But also like if you don't have that, and like the world leader, almost indispeedably, who knows how long that will continue on for at the pace that we're going. But like having the world leader be like, this is not a thing, it's a scam, and we're not doing it anymore. That is extremely disruptive everywhere. And even if inertia hasn't caught up yet, it's still very disruptive. Yeah. Yeah. I'm not breaking my-- I'm not breaking my-- Yeah, I'm sorry. I took you away from your core point though. You want to keep going, so I'm sorry about that. No, no, just fly. Let's go down to this and root for a minute. Okay, go ahead, yeah. I am. What just a dove tail into what we said. What breaks my heart just a little bit is all the work that we're doing here. And global software restrictions on all the matter of projects, the purpose of which is to basically service basic human needs, like quite too cooking and access to key wire. I mean, a lot of these countries as I mentioned, like the palace room book for carbon markets and carbon projects, it's a bay that closed 18 months ago. And it's really only in the last 18 months, the countries of Starietra right now are leading interesting, elegant pieces of regulation, framework to say to the world, "Hey, we're here. We're ready for carbon finance. We're ready for UNF trickle C. Come sort out our clean cooking pral for us, because, you know, they're still-- I don't know what the exact number is. I think the IEA says something like 1.2 billion people still cook on open fires, right? In 2026, maybe more. I think that's the-- doesn't need to serve them. And these activities are-- you know, they're still quite expensive to implement at the scale that's needed, five ads is needed for us, which is why a lot of them, for part, are the conditional parts of NNC, and so there, for they are, at least to some degree, exportable through the carbon finance perspective. So, well, I find quite upsetting is that we're just at this point in time where these host countries are ready to engage with global carbon markets. You know, through our analysis, also through CBAA, that's found in the compensation, but there are the six product-backed-to-the-tey types that you may either have found like a framework, as I mentioned. Some say they're not America as well, you know? Whereas the buying power, where's the buying-- who's going to pay for this? Like rice? But this course, you're sure, then there's, you know, you've got no reason to do things hard with style pairing, Switzerland and time, country, Singapore, climate, country. Japan have got, you know, bought ends built up through the Zeyra and joint-of-mutation actors. They kind of did buy that on the Greens. We were hoping-- we were hoping for big, big buying companies to commit and buy these tones, like, and have them transferred to help buying countries in their parts. But with the US drop, you know, not participating in politics, just not being in Paris. It just said, so with that message that we talked about and the influence of that on other global North players, they bother helping folks in the global South. They can be bothered doing their own thing, global Morrison, and they'll have the count-- maybe I'd run here, or else-- maybe they'll have the counter effect. Maybe they'll say, yeah, US is out. Maybe we won't-- maybe we don't want to spend 100 euros, 200 euros, 300 euros per ton based on the marginal cost of the payment in a particular sector. Maybe it's actually better for us to buy from the global South. And Miley said in Europe as a whole, is a lot. Five percent is not a lot. Right? Maybe they'll wrap it up. Maybe they'll change it again. I don't know. And but look, the point here is that the US just said to, you know, tend to set not all the control, but certainly, it would agree up the tone for overall sentelings. I do dream. I do think 2020 across the United States. I'm also keeping that I own sentelings around the literature, the poorest, but I didn't try to look forward to figure out what happens as Dr. Heskahn. He was the ancient and not the saddest God. Assuming, assuming he's gone. Left, thank you for joining me for the impossible task of one explaining Corsia and its history. Super hard. Speculating on the possible roads for carbon removal to enter Corsia. And then also just grimly looking into the state of world politics as pertains to climate and so much else. Thank you for going on this wild, multi-basited ride with me. It's been fun. Thanks Ross. Thanks for having me. [Music]