As the international community looks to the period beyond the UN Copenhagen agreements on climate change, attention is focusing on the finance for implementing global emissions reductions on the ground. The requirement for significantly scaled-up investment into the solutions to climate change is a central issue, often characterized as investment flows into 'low carbon technologies'.

This paper draws on five years of insights from mainstream financiers leading the exponential growth in renewable energy investment, and key issues for policy-makers seeking to foster conditions for even greater investment are identified.

Lord Tu'ivakano, will deliver a keynote address on the development of the Tonga Energy Road Map (TERM), which plans for 50% of the country's energy to come from renewable energy sources by 2020. 

The Kingdom of Tonga is highly susceptible to both climate change as well as changes in global energy prices due to its high dependency on imported oil. The TERM has required both ground-breaking whole-of-sector institutional changes in Tonga as well as innovative coordination across a range of development partners, including the World Bank, ADB and the UN. Key players in the international community have closely watched the development and implementation of the TERM as it presents a complete change in the aid paradigm that is not just specific to Tonga, or the energy sector. 

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Summary

• Plans for an EU-wide Energy Union are taking shape, following the European Commission’s adoption in February 2015 of a ‘Framework Strategy for a Resilient Energy Union with a Forward-Looking Climate Change Policy’. The strategy underlines the EU’s ambition to attain ‘secure, sustainable, competitive, affordable energy for every European’.
• The initiative seeks to transform energy markets and energy/climate policy across the EU. Its goals include cross-border coordination and integration in energy security, supply, market operations, regulation, energy efficiency, low-carbon development, and research and innovation.
• There is an important foreign policy aspect to the Energy Union, given the imperative of managing security and supply risks in Europe’s neighbourhood and further afield. By addressing structural divisions between member states, the Energy Union could have a marked beneficial effect on the EU’s capacity to conduct a unified and effective foreign policy.
• Development of the Energy Union presents abundant challenges, however. Policy and legislative changes will need to be coordinated across 28 countries. Variations in EU member states’ attitudes to security and energy policy may lead to differences in, or clashes between, priorities. The wider context is also complicated. Interrelated challenges rooted in broader policy issues include the partial transition to low-carbon energy, and concerns over competitiveness relative to other major economies.
• The current EU approach to energy security and infrastructure focuses on natural gas. This ‘gas first’ approach risks crowding out other responses to the energy security challenge. It could result in the creation of ‘stranded assets’, if the future gas demand on which investments are predicated does not match projections. A narrow focus on new gas infrastructure could also impede development of other dimensions of the Energy Union.
• The markets for coal, oil, gas and renewables are changing significantly. The shale oil and gas ‘revolution’ in the United States has altered the economics of hydrocarbon fuels, and the plunge in oil prices since mid-2014 is causing energy businesses in the EU to reassess investment plans.
• The EU is rapidly expanding the use of renewable energy. Dramatically falling prices for renewables will challenge traditional energy utility business models. How the Energy Union enables market access for new business models will be key to determining future energy trajectories.

Summary

• Over the last 30 years the EU has played a central role in addressing the competitiveness, security and climate dimensions of energy policy among its member states. The UK has been critical in driving forward integration of the European energy market, and has been a strong advocate of liberalized energy markets and some climate change mitigation policies.
• If, at the June 2016 referendum, the UK does vote to leave the EU, energy and climate policy will be part of the overall package of issues to be negotiated, as it is unlikely that each sector will be treated separately. The model of relations for energy and climate may well be determined by political and public sentiment on higher-profile issues such as freedom of movement, rather than by what is best for the UK in these policy areas.
• The UK is increasingly reliant on imports, including from and through continental Europe, and its energy market is deeply integrated with that of its European neighbours. As a growing share of the UK’s electricity is exchanged with EU partners, it would be neither possible nor desirable to ‘unplug’ the UK from Europe’s energy networks. A degree of continued adherence to EU market, environmental and governance rules would be inevitable.
• This paper reviews the risks and trade-offs associated with five possible options for a post-exit relationship. Of these, the Norway or the Energy Community models would be the least disruptive, enabling continuity in energy market access, regulatory frameworks and investment; however, both would come at the cost of accepting the vast majority of legislation while relinquishing any say in its creation. The UK would thus have less, rather than more, sovereignty over energy policy.
• The Switzerland, the Canada and the WTO models offer the possibility of greater sovereignty in a number of areas, such as buildings and infrastructure standards as well as state aid. None the less, each would entail higher risks, with greater uncertainty over market access, investment and electricity prices. These models would reduce or even eliminate the UK’s contribution to the EU budget, but would also limit or cut off access to EU funding mechanisms.
• All five Brexit models would undermine the UK’s influence in international energy and climate diplomacy. The UK would no longer play any direct role in shaping the climate and energy policies of its EU neighbours, at a time when the EU’s proposed Energy Union initiatives offer the prospect of a more integrated and effective European energy sector. A decision to leave the EU would make it easier for a future UK government to change direction on climate policy, since only a change in domestic legislation would be required.
• ‘Brexit’ could affect the balance of energy policy among the remaining member states. In its absence, the centre of gravity for EU energy policy might shift away from market mechanisms and result in weaker collective action on greenhouse gas reduction targets.
• In the field of energy and climate change policy, remaining in the EU offers the best balance of policy options for Britain’s national interests: the UK would continue to benefit from the integrated energy market, while maintaining influence over its direction and minimizing uncertainty for crucial investment.

In May 2016, Chatham House published a research paper that assessed the options for the UK’s climate and energy policy in the event of a British vote to leave the EU. It determined that:

• The UK’s energy market is deeply integrated with that of its European neighbours and that it would be neither possible nor desirable to ‘unplug’ the UK from Europe’s energy networks. A degree of continued adherence to EU market regulations, energy efficiency standards of appliances, environmental and governance rules would be inevitable. 
• The EU’s collective negotiation on international climate issues has given the UK greater political weight than any member state has alone.
• The EU’s coordinated approach in engaging with major fossil fuel producers such as Russia and countries in the Middle East has helped support price stability and security of supply, including through infrastructure investment to make existing pipeline systems more efficient and improve storage and capacity.   

In light of the decision to leave, Chatham House is hosting a roundtable to reassess the options for a future UK-EU energy and climate change partnership. The meeting will bring together those experienced on UK and EU policy in both climate change and energy and explore the short and medium-term climate and energy policy considerations. 

Attendance at this event is by invitation only.

Chatham House’s recent paper, Woody Biomass for Power and Heat: Impacts on the Global Climate, highlights how the use of wood for electricity generation and heat in modern (non-traditional) technologies has grown rapidly in recent years, and has the potential to continue to do so. EU member states’ national targets for renewable energy generation agreed in 2009 have helped ensure that the EU is now the world’s largest producer and consumer of wood for energy. And although other member states use wood more extensively for heat, the UK is the EU’s largest user for electricity generation, mostly sourced from the US and Canada.

Wood for energy often has a positive image: a natural product of growing forests. The biomass energy industry, which has grown rapidly on the back of government subsidies, likes to contrast it with dirty coal or oil. They point to the government’s sustainability criteria, which notionally guarantee a reduction of at least 60 per cent in greenhouse gas emissions compared to the fossil fuels the biomass replaces.

The problem with this happy picture, however, is that in fact biomass, when burnt, emits more carbon per unit of energy than most fossil fuels. The exact amount varies with the type of biomass and the type and age of the power plant, but figures from the Drax power station, Europe’s largest consumer of wood pellets, show that in 2013 it emitted about 13 per cent more carbon dioxide per unit of energy generated from biomass than from coal.

How is this consistent with meeting the government’s requirement for a 60 per cent reduction in emissions? Only by completely ignoring the carbon emitted when the wood is burnt; the sustainability criteria measure only supply-chain emissions from harvesting, processing and transporting the wood. (Direct land-use change – for example, clearance of the forest for agriculture or urban development – also falls outside the criteria, but biomass for energy generally originates from existing forests.)

This treatment of combustion emissions as zero – and thus, the awarding to wood the same kind of financial and regulatory support as other renewables such as solar PV and wind – is justified on the basis that the carbon contained in woody biomass is part of the natural forest cycle. The carbon released during combustion was absorbed by forest growth in the past and will be reabsorbed by forest growth in the future; in contrast, fossil fuels originate outside this cycle and their combustion adds carbon to the atmosphere.

But this argument rests on a basic fallacy. Carbon is carbon, wherever it comes from, and if you burn wood for energy, you increase carbon dioxide concentrations in the atmosphere (by more than if you had used fossil fuels), and thereby contribute to climate change. The fact that the carbon emitted was absorbed by growing trees in the past is simply irrelevant. After all, when it’s harvested you don’t have to burn it; you could use it for construction or furniture or window frames or a host of other uses, fixing the carbon in wood products rather than emitting it to the atmosphere.

Climate impacts

It is true that continued forest growth will absorb carbon in the future, but the process is a long one, taking decades or even centuries if whole trees are harvested and burnt. Replacing large mature trees, with plentiful leaf cover absorbing large volumes of carbon dioxide, with small young ones mean that the rate of carbon uptake will be far lower for years. On top of that, the impact of harvesting itself releases soil carbon into the atmosphere, further accelerating climate change.

The impact on the climate of using sawmill or forest residues for energy rather than whole trees is undoubtedly lower, since these tend to be wastes from other industries which harvest trees for their own purposes, and do not imply any additional harvesting. Sawmill wastes which, if left to themselves, would rot and release their stored carbon into the atmosphere in a matter of months or years, are in many ways the ideal feedstock; it makes sense to use them for energy rather than leave them to decay. However, mill residues are already intensively used and there seems little room for expansion; a survey in the US in 2011 found that over 99 per cent of mill residues were already used, mainly for energy and wood products such as particleboard.

Forest residues are the parts of harvested trees that are left in the forest after log products have been removed, including stumps, tops and small branches, and pieces too short or defective to be used; these can amount to as much as 40–60 per cent of the total tree volume. Their impact on the climate if used for energy varies significantly. While the smallest pieces tend to rot and release their stored carbon into the atmosphere quite quickly, if left in the forest, they are generally not suitable for use for energy, as they contain too much dirt and ash to be burnt cleanly. Larger pieces are more suitable but take much longer to decay; burning them for energy instead of leaving them in the forest thereby increases carbon concentrations in the atmosphere for years or decades. And on top of that, a portion of the carbon and other substances contained in the residues is transferred to the soil as they decay; their removal from the forest for energy may reduce both soil carbon and the levels of the nutrients trees need to grow, again with negative impacts on the climate.

The biomass industry generally likes to claim that it uses mainly mill and forest residues, though on closer inspection the categories they report often contain whole trees, perhaps classified as ‘unmerchantable’ or similar. (This is not helped by the fact the categories used by Ofgem, for example, to whom UK biomass users have to report, are confusing and potentially overlapping.) Several independent studies, however, have concluded that the use of mill and forest residues is in reality substantially lower; pellet plants in the US – the UK’s main source of supply – in fact source about 75 per cent whole trees.

Setting aside these arguments about feedstock, however, can it be safely assumed that future forest growth allows us to treat biomass as carbon-neutral? If the trees would have grown anyway, even in the absence of the biomass energy industry, it cannot be assumed that their future absorption of carbon cancels out the carbon emitted when wood is burnt. If the rate of carbon absorption in forests remains the same whether or not some of the harvested wood is burnt, then clearly, the best outcome for the climate in the short and probably medium term is not to burn it, but to use it for wood products or leave it to decay slowly in the forest. This is not an academic argument: the current global rate of emissions of greenhouse gases is incompatible with the aims of the Paris Agreement and may risk triggering irreversible tipping points in the Earth’s climate system. We need to reduce carbon emissions now, not in several decades’ or centuries’ time.

The biomass industry likes to point to the expansion of US forests in recent decades to show that forests overall have been absorbing more carbon even while increasing volumes are burnt for energy – sometimes implying that this forest growth has been encouraged by the demand for energy. But in fact US forest expansion started in the 1950s, decades before European subsidies stimulated the expansion of the modern biomass industry. And there is little evidence of recent overall forest growth in the US southeast, the location of almost all the pellet plants supplying European demand. In any case, the point is not whether US (or European) forests are expanding, but whether they would have grown at a different rate if part of their wood had not been burnt for energy. If they would have grown at the same rate, or faster, in the absence of biomass energy use then it cannot be assumed that using wood for biomass is good for forests, or the climate.

Redirecting public money

There is no question that renewable energy policy and forest policy both have a critical role to play in the mitigation of climate change. But governments have limited resources to deploy in their support, which is why the Chatham House paper questions whether it is really a good use of public money to subsidise activities which release stored forest carbon into the atmosphere, thereby increasing carbon emissions and accelerating climate change.

I argue instead that support should be limited to those feedstocks which genuinely reduce carbon emissions over the short term – i.e. mill residues and post-consumer wood waste. This would not only have a positive direct impact on the climate but would also release more resources for genuine zero-carbon technologies, such as solar, wind or tidal – and perhaps also for programmes encouraging afforestation and the more extensive use of wood in buildings and products. Use it, don’t burn it.

To comment on this article, please contact Chatham House Feedback

As part of the international dialogue on Valuing Vital Resources, this seminar will convene policy-makers, scholars, technical practitioners, NGOs, multilateral agencies and the media to discuss recommendations for new policy approaches in India to reorient energy and water use in agriculture. The aim is to gain input to practical policy proposals and identify the work now needed to make them robust. 

Attendance is by invitation only. Please note this event is held in New Delhi, all times are local. 

This event is organized together with the CUTS Institute for Regulation & Competition (CIRC).

As the UK leaves the EU and the formal negotiations on the future relationship begins, this workshop will discuss any immediate changes and review the short and medium term impacts of Brexit on the energy sector. 

The workshop will look to cover:

• The implications for UK business and system operations of the UK leaving the Internal Energy Market.
• Current and future investment trends in the UK energy system.
• The trade of electricity and gas over inter-connectors.
• The need for the development of a new EU-UK operational framework mechanism.
• The UK's EU withdrawal agreement and the operation of the Single Electricity Market (SEM) across Ireland. 
• Options for the UK outside of the EU Emissions Trading System (ETS) and the impact on carbon prices.

This workshop is part of a programme funded by the UK Energy Research Centre on Brexit and the UK’s Net Zero Energy Policy being run by the University of Warwick and Chatham House.

Attendance at this event is by invitation only.

Brexit will significantly change the balance within the EU in relation to nuclear energy. Apart from France and Finland, both of whose nuclear development programmes are behind schedule, the UK is the only member state in northern or western Europe currently investing in new nuclear capacity. Brexit will therefore leave the supporters of nuclear energy within the EU27 and the European Commission in a weaker position.

The speaker will argue that at a time when the energy industry needs to accelerate its shift away from fossil fuels, and when the electricity generation industry must cut its carbon emissions faster than it has ever managed to do in the past, this change is unhelpful.

The workshop will also address the need for additional interconnector capacity and the future of carbon-trading outside the EU emission trading system and how this relates to potential nuclear energy capacity.

Attendance at this event is by invitation only. 

In recent years, clean energy access for refugees and internally displaced people has emerged as a potential method of improving humanitarian outcomes and enabling self-reliance. While recent research emphasizes the need for more quantitative data to inform energy access interventions, better qualitative understanding would also improve innovation in this area.

This ethnographic study is the first of its kind to analyse energy access and resilience strategies deployed in two refugee camps, Kakuma in Kenya and Goudoubo in Burkina Faso. The stories of residents in these camps demonstrate the importance of considering everyday experiences of displaced people in developing sustainable humanitarian energy interventions.

This paper highlights the need for new methodological approaches to expand the evidence base for humanitarian energy interventions and policies. Future research could usefully inform humanitarian energy projects by examining the technical knowledge and existing practices of refugees in the design of energy technologies, systems and business models. Uptake and sustained use of new systems may be more likely where interventions build on or work in harmony with these factors.

Climate change and energy transition are re-shaping the extractive sectors, and the opportunities and risks they present for governments, companies and civil society. As the central governance standard in the extractives sector, the EITI has a critical role in supporting transparency in producer countries.

This workshop will bring together experts from the energy and extractives sectors, governance and transparency, and climate risk and financial disclosure initiatives to discuss the role of governance and transparency through the transition. It will consider the appropriate role for the EITI and potential entry points for policy and practice, and the potential for coordination with related transparency and disclosure initiatives. 

Please note attendance is by invitation only.

Mass human displacement crises like those in Syria, Democratic Republic of Congo and Myanmar do not dissipate within a year or two. The average age of a refugee camp globally is 18 and counting.

Meanwhile, the pressures on resources and services in neighbouring countries absorbing an influx of vulnerable people can be harsh. Imagine the overstressed schools and hospitals where intake has doubled in areas of Jordan and Lebanon, and the damage to ecosystems and elephant habitats where camps have sprung up in Bangladesh. 

The fallout from such crises is prompting new ways of working in the international humanitarian system. These recognize that short-term, emergency responses can jeopardize national development goals if maintained indefinitely. In most refugee camps for instance, each family cooks with wood in regions already suffering from deforestation.

Reliance on polluting trucks to bring in fuel and water is high. At the same time, developing countries – which host 80 per cent of the record 70.8 million people currently displaced by conflict – desperately need to address health, water, energy and housing needs for their own populations. Aid and welfare interventions directed only at refugees can provoke frustrations amongst the local community, damaging social cohesion and fostering political instability. 

The Global Compact on Refugees, affirmed by the United Nations General Assembly one year ago, aims at fairer responsibility-sharing amongst countries and equitable resourcing to host communities and refugees. The Global Refugee Forum (GRF) taking place 17–18 December in Geneva is the starting point for donor pledges and commitments. 

An opportunity for refugee-hosting countries

Among the GRF’s 6 focus themes is ‘Energy and Infrastructure’ – a new priority for humanitarian aid and finance. This covers energy, environment, water and sanitation, health, shelter and connectivity – services that are tightly interconnected. In October, the UN Refugee Agency (UNHCR) also launched its first energy strategy, which ‘promotes the transition to clean, renewable energy at refugee camps and hosting sites’.

Given this impetus, alongside a growing international focus on speeding up Sustainable Development Goal (SDG) delivery, stabilizing migration and supporting climate resilience, more aid and soft credit for interlinked objectives will become available. Countries hosting refugees have an opportunity; how they approach it will determine the level of support they attract and how effectively it is deployed. 

Policy conditions are key to success

In a refugee situation, energy access is about much more than keeping warm or cooking food. It is also about connecting with loved ones across borders, safety at night, healthy births and making a living. Due to the lack of long-term funding, maintenance systems or government approvals, failed pilots to introduce for example, solar streetlighting or clean cookstoves, are the norm. 

To increase their durability and reach, projects need to harness local markets and support national development goals, especially those on access to modern energy for all (SDG 7), protecting ecosystems (SDG 15) and resilient human settlements (SDG 11). Several examples of these are emerging, each with valuable lessons to share. 

The policy environment, in particular, coordination between authorities, humanitarian agencies and private sector actors, can make or break a project. Beyond the basic conditions of adequate security and refugee acceptance, our research highlights three enabling factors:

First: government willingness to engage in long-term response and resilience coordination. Jordan is the most advanced in this with its three-year rolling Response Plan for the Syria Crisis whereby the government works with humanitarian agencies to integrate refugee welfare with national development needs.

Here, energy, water and housing needs are specified and have attracted funding. For example, in Irbid, Jordan where over 137,600 Syrian refugees live, the Norwegian Refugee Council, is expanding a programme under the Renewable Energy for Refugees (RE4R) initiative that applies energy efficiency and solar water heating to reduce bills and rents for refugee tenants while adding value for Jordanian homeowners.   

Second: strong, clear, energy and environment plans and legislation. Signals can be mixed. Jordan’s ‘wheeling’ regulation, allowed UNHCR to reduce its electricity bills through specially built solar plants at Azraq and Zaatari, yet the current freeze on renewable connections has stifled further projects.

In Rwanda,  the government banned the supply of woodfuel to refugee camps on the basis of concerns about deforestation. The announcement sharpens focus on cleaner cooking.

Yet with little guidance on enforcement and the timeframe for change, it is difficult for UNHCR and its partners to plan viable schemes. A reversion to stove and fuel handouts is likely, damaging the potential to create markets for alternative cooking practices in the camps. 

Third: local fuel prices. Where polluting fuels are subsidized or untaxed, additional subsidy is needed to make cleaner alternatives competitive. The higher prices of diesel in Uganda for example are an incentive for solar projects at Bidi Bidi, the world’s largest refugee settlement.

The Gaia Association-UNHCR clean energy programme in Ethiopia’s Western refugee camps has avoided burning some 10,000 tonnes of wood since 2006 through ethanol, but if  VAT (which is applied to neither charcoal nor kerosene) were waived, it could scale up commercially. 

Joining up the dots

Many humanitarian and government dots could be joined up in support of the SDGs. In Rwanda for example, clarity on electrification plans – which appear to cover refugee areas – could allow camp mini-grids to be designed for eventual grid integration. In Jordan, lessons learned from the home upgrading programme could be applied to meet city climate resilience ambitions. 

Donors at the GRF should support humanitarian operations that leave a positive legacy, increasing the robustness of country infrastructure and systems. Host-country governments should help define and encourage projects that benefit national and refugee populations. This will be critical to both development outcomes and limiting future human suffering. 

In the context of the feasibility of reducing greenhouse gas emissions to net zero, policymakers are beginning to pay more attention to options for removing carbon dioxide from the atmosphere. A wide range of potential carbon dioxide removal (CDR) options are currently being discussed and modelled though the most prominent among them are bioenergy with carbon capture and storage (BECCS) and afforestation and reforestation.

There are many reasons to question the reliance on BECCS assumed in the models including the carbon balances achievable, its substantial needs for land, water and other inputs and technically and economically viable carbon capture and storage technologies.

This meeting will examine the potentials and challenges of BECCS in the context of other CDR and emissions abatement options. It will discuss the requisite policy and regulatory frameworks to minimize sustainability and socio-political risks of CDR approaches while also avoiding overshooting climate goals.

Attendance at this event is by invitation only.

This project will be led by Practical Action and UNHCR and will deliver renewable energy investments through an innovative approach in humanitarian settings, working directly with refugees and host communities in Kigeme, Nyabiheke and Gihembe refugee camps in Rwanda and with urban refugees in Irbid in Jordan.

The project will provide access to affordable and sustainable sources of renewable energy, and improve the health, wellbeing and security of target populations.

As part of this programme, Chatham House will work on a series of research activities and outputs that look to disseminate and scale up the lessons-learnt and evidence-generated by the programme.

Access more of Chatham House's work on humanitarian energy through our Moving Energy Initiative microsite.

As the UK leaves the EU and the formal negotiations on the future relationship begins, this workshop will discuss any immediate changes and review the short and medium term impacts of Brexit on the energy sector. 

The workshop will look to cover:

• The implications for UK business and system operations of the UK leaving the Internal Energy Market.
• Current and future investment trends in the UK energy system.
• The trade of electricity and gas over inter-connectors.
• The need for the development of a new EU-UK operational framework mechanism.
• The UK's EU withdrawal agreement and the operation of the Single Electricity Market (SEM) across Ireland. 
• Options for the UK outside of the EU Emissions Trading System (ETS) and the impact on carbon prices.

This workshop is part of a programme funded by the UK Energy Research Centre on Brexit and the UK’s Net Zero Energy Policy being run by the University of Warwick and Chatham House.

Attendance at this event is by invitation only.

Summary

• Current climate efforts are not progressing quickly enough to prevent the world from overshooting the global emissions targets set in the Paris Agreement; accordingly, attention is turning increasingly to options for removing carbon dioxide from the atmosphere – ‘carbon dioxide removal’ (CDR).
•  Alongside afforestation and reforestation, the main option under discussion is bioenergy with carbon capture and storage (BECCS): processes through which the carbon emissions from burning biomass for energy are captured before release into the atmosphere and stored in underground reservoirs.
• This pre-eminent status is not, however, based on a comprehensive analysis of the feasibility and impacts of BECCS. In reality, BECCS has many drawbacks.
• Models generally assume that biomass for energy is inherently carbon-neutral (and thus that BECCS, by capturing and storing the emissions from combustion, is carbon-negative), but in reality this is not a valid assumption.
• On top of this, the deployment of BECCS at the scales assumed in most models would consume land on a scale comparable to half that currently taken up by global cropland, entailing massive land-use change, potentially endangering food security and biodiversity. There is also significant doubt about the likely energy output of BECCS solutions.
• BECCS may still have some role to play in strategies for CDR, depending mainly on the feedstock used; but it should be evaluated on the same basis as other CDR options, such as nature-based solutions or direct air carbon capture and storage (DACCS). Analysis should take full account of carbon balances over time, the requirements of each CDR option in terms of demand for land, water and other inputs, and the consequences of that demand.
• There is an urgent need for policymakers to engage with these debates. The danger at the moment is that policymakers are ‘sleepwalking towards BECCS’ simply because most models incorporate it – or, almost as bad, it may be that they are simply ignoring the need for any meaningful action on CDR as a whole.