A novel co-creation initiative involving a broad spectrum of stakeholders led to the development of a joint blueprint for carbon removals policies in the European Union. Sabine Frank reflects on the successes and challenges of the experiment.

The CO₂ol Down project, led by Carbon Market Watch in 2023-24, set out from the lack of a comprehensive governance framework for carbon dioxide removals in the EU. This is needed to allow the EU to reach its 2050 climate goal while delivering its fair share of the 1.5°C guardrail as enshrined in the Paris Agreement. 

The project revolved around a co-creation process involving a diverse set of stakeholders with seemingly polarised views.

Their mission? 

To create a policy blueprint that would help inform and inspire impending policy-making. The subject being relatively new on the political agenda made it especially suitable for a co-creation process: policymakers, by and large, don’t yet have established positions and need to rely on expert advice. 

Mission inspiration: accomplished. After much deliberation, CO₂ol Down put forward revisions to the EU Climate Law that would make it removals ready and developed a set of recommendations for EU instruments to handle permanent removals responsibly. 

The beauty of this co-creation process is that it not only got the wheel spinning, but can also save policymakers the need to reinvent the wheel. The CO₂ol Down vision is not only robust and anchored in science, it is also the result of a process with special legitimacy and credentials – that of having been ‘co-created’ by a broad range of stakeholders. 

Democratic designs

The co-creation which took place under the CO₂ol Down umbrella merits some special exploration. Over the course of three months, the CO2ol Down coalition gathered three times for full-day workshops. In addition, an editorial group with balanced participation from different stakeholder groups streamlined the results into tangible policy documents. The end results were shared with all participating stakeholders, and feedback on each proposal was accepted by a fixed deadline. 

Carbon Market Watch led the process with the support of co-creation experts from the Institute for Participatory Design. At the end of the process, proposals were published on Carbon Market Watch’s website. Those stakeholders who agreed to be mentioned were credited as co-creators. An endorsement process ensued and the coordinated advocacy work with the results was ready to begin.

A good process for good outcomes

The quality of the co-creation blueprint depends on the quality of the design process, so this merits a closer look.

An important premise of the co-creation process was that it should produce the kind of results a real policymaking process would produce. We asked participants to put themselves in the shoes of lawmakers and work on results which would be as close as possible in format to the regular outputs of the EU so as to be as ready for use as possible.

The focus of the first (online) workshop was to identify and discuss the key principles and concerns related to carbon removals that the EU Climate Law should address. In a sequence of plenary sessions and work in sub-groups, participants incorporated principles in the actual text of the Climate Law and drafted textual amendments.

The co-creation process was also designed to take a comprehensive view of what constitutes a governance framework for removals. The second (in-person) workshop was dedicated to considering the elements needed for a balanced and complete strategy for permanent carbon removals, building on a revised EU Climate Law. The task was imagined like the challenge of coming up with a healthy poké bowl containing ingredients from all food groups. Likewise, a serviceable strategy for permanent removals in the EU would have to combine key components in a ‘tasty’ way: financing solutions, target and governance, a portfolio approach to carbon removal methods, and sustainability criteria (including an environmental and social dimension). 

The work of the day was inspired by a variety of presentations on proposals from the EU and other jurisdictions around the world, sharing position papers and academic literature. 

While the first two workshops generated the content, the third – and final – workshop was dedicated to participants affirming their collective position on the proposals conceptualised together and streamlined by the editorial group.

A crucial moment came when participants were asked for their thoughts on whether or not they could accept the text they had helped to create. The response was overwhelmingly positive: more than 80% of participants were satisfied with the content and quality of the results and willing to bring the proposals to their organisations for official endorsement. 

Everyone’s a winner

Consultative and participatory processes are, of course, already part of the repertoire of many EU stakeholders. Co-creation, though, has a different quality in several respects.

First, it offers the widest possible participation from a great variety of interests and perspectives, based on a few basic conditions for participation. The majority of the most knowledgeable and engaged stakeholders from the still-small field of carbon removals took part in at least one of the three events of the co-creation process. In all, 48 organisations or individuals put their heads together. 

CMW, an NGO with a sound reputation as an independent watchdog, assembled representatives from four relevant industry associations, including some of their members, nine companies, key academics and representatives of the most principled NGOs, such as Greenpeace and Fern. All expressed their appreciation for the high quality of the process, offered follow-up conversations and expressed a constructive attitude. Two industry associations were represented in the editorial group. 

The prerequisite for participation was agreement with the basic tenet that removals, carbon sequestration in the land sector and emissions need to be handled separately to minimise their deterrent effect on emissions reductions and to ensure they help achieve the EU’s climate goals in a safe and sustainable manner. 

Furthermore, co-creation is not about finding ‘compromises’ between different stakeholders’ existing positions but acts as an incubator for innovative proposals emerging from their collective intelligence. Both policy proposals that resulted from the CO₂ol Down co-creation process were an evolution of the original positions of the stakeholders involved in the process. The proposals would not have come into being without this collective effort. More concretely, the amendments included in the proposal for a revision of the EU Climate Law suggest concrete new ideas for how the EU should treat natural sinks and set permanent removals targets. In the recommendations for EU instruments on permanent removals, the group conceptualised the establishment of proper funds dedicated to the development and delivery of carbon removals.

In addition, common positions are not determined by majority voting but result from systemic consensus-making, which involves repeated measuring of resistance to proposals on sliding scales and working on the proposals with the most resistance.

Finally, the process does not end with winners and losers but the sense that the participants grew in their thinking and understanding through their creative exchange and were strengthened in their resolve to contribute to good policy design through the experience of looking for solutions together.

Co-creation in the real world

For all that is special about co-creation, CO₂ol Down was only a testing ground for the concept in the ‘laboratory setting’ of a series of workshops. The project did not specifically seek to change the paradigmatic code of the wider stakeholder domain and lobbying system based on power competition. 

This relatively limited scope was reflected in how not all participants, despite their curiosity and interest in the process, had mandates from their organisation to support its outcomes. Ultimately, 30% of participants signed on to the results as co-creators or supporters on behalf of their organisations or as individuals. Considering the divergent starting positions, this was still a significant success.

Nevertheless, future exercises should draw lessons from the CO₂ol Down experience and incorporate mechanisms that ensure greater buy-in and endorsement from participants. This includes attempting to ensure beforehand that as many participants as possible have been empowered by their organisations to represent them officially and to endorse the resulting vision, or to support them in getting the buy-in from their organisations at the end.

The way forward

Carbon Market Watch hopes to take the CO₂ol Down project forward in three ways:

1. Sign here: Maximising the endorsement of the CO2ol Down results by organising dedicated meetings with participating organisations to deepen understanding of co-creation and encourage them to sign on the results by addressing the key concerns and providing solutions, such as the use of disclaimers.
2. Legal eagles: The European Commission plans to submit a proposal to include an EU 2040 target in the European Climate Law in the first quarter of 2025. As part of the EU’s ordinary legislative procedure, the proposal will then be passed to the European Parliament and the Council for respective amendments. CMW would coordinate the direct advocacy towards policymakers in the European Parliament and the Council on behalf of the CO2ol Down co-creators and supporters. We will target key Members of the European Parliament and their staff and representatives of member states.
3. Money matters:  The results of the first phase of the CO₂ol Down co-creation process include recommendations on how to provide finance for permanent removals. The recommendations elaborate on the key principles that should be followed when establishing an instrument dedicated to this purpose and provide basic ideas for concrete instruments as alternatives to the main sources of finance policymakers have focused on so far: the EU Emissions Trading System and the voluntary carbon market. These include the establishment of a public carbon removals development fund for early-stage initiatives and, separately, a blended delivery fund based on public and private funding for both procuring and generating demand for removals. During a second phase of the co-creation process, we would delve deeper into the operationalisation of such a fund and see, for example, if it can supplement other instruments.

By taking the co-creation experiment further, Carbon Market Watch will not only challenge the policymaking paradigm of others but also challenge its own identity. A ‘’watchdog’ will have to prove that it can also serve as a ‘herding dog’ and help counter polarisation in politically polarising times.