In brief: The cost of removing already-emitted CO₂ from the atmosphere does not arise from any law — it arises from physics: it is real, quantifiable per installation, and unavoidable, because only removal brings warming back below 1.5 °C. The legislator cannot decide whether this cost exists; it can decide only who bears it: the emitters (then it belongs on their balance sheets) or the taxpayers (then it must be shown in public budgets). The one outcome existing law does not permit is the present one — that it appears nowhere. Paying for ETS allowances does not discharge the emitters' duty to provision and disclose the true removal cost.
The evidence: today it is recorded nowhere
Over 2025–2026, twelve written statements from German authorities in six Länder and at federal level confirmed — each with a file number — that these removal costs are examined in no permitting procedure, no environmental impact assessment, no budget and no balance sheet. Every authority points to the ETS as the exhaustive instrument; yet the ETS prices the right to emit and neither funds nor mandates removal. On 3 August 2026 the federal financial supervisor (BaFin) completed the chain: balance-sheet enforcement has never examined the question, no supervisory position exists, and it knows of no company that has recognised such a provision — while noting that the applicable accounting standards (incl. the IFRS IC agenda decision on climate-related commitments, IAS 37) are the framework to assess it. Originals, per installation, are linked in the public register (26 gas-fired power plants ≈ 30.6 Mt CO₂/yr ≈ €305 bn over 20 years at €500/t).
The full case: our evidence dossier
The complete argument — the six-step chain, the authorities' quotations with file numbers, the economics and sources — is set out in the dossier that accompanies our submission. Section 7 assesses the Commission's proposal of 17 July 2026 (COM(2026) 616): a central purchase of 250 million removal units financed by a cap increase (new Art. 9c).
Open / download the dossier (PDF, 10 pages)
Request for comment
The submission has been filed; the legislative debate in Parliament and Council is only beginning. We would genuinely value your critique — including where you think we overstate. In particular, on the six-step chain in the dossier (section 2):
- Steps 1–2: Is it correct that returning below 1.5 °C requires active removal of already-emitted CO₂ (net-zero only halts the increase), and that this is scientifically required rather than optional, given tipping risk between 1.5 and 2 °C?
- Step 3: Is €388–500/t a defensible conservative figure for permanent removal at scale — or how would you frame the floor?
- Step 6: Is it sound that overshoot duration and tipping feedbacks raise both the quantity to be removed and the cost attributable to each major emitter (allocated by share of the exceeded budget), so today's cost is a floor, not a ceiling?
- Attribution: is per-installation attribution (ETS MRV) for direct emissions, plus fair-share allocation of the systemic overshoot, methodologically sound as presented?
- Anything we should temper, correct or strengthen before submission.
Replies, corrections and objections are welcome at jan@kechel.de; with your permission we would cite substantive comments.
Documents
- Evidence dossier (PDF, 10 pages) — embedded above.
- Portal feedback text as submitted (TXT) — the text filed on 23 August 2026 (3,993 of the 4,000 characters permitted), with the evidence dossier attached.
- Official published feedback (European Commission, F33566027) — the submission as it appears on the Commission's record (COM(2026) 616 thread); earlier copy F33564904 (COM(2026) 619 thread).
- Public register — 26 plants, cost per installation, sources and authorities' answers per plant.
- Germany's climate responsibility — the numbers.
Submission record
The submission is on the public record of the European Commission:
- Feedback references: F33566027 (COM(2026) 616 thread, 25 August 2026) and F33564904 (COM(2026) 619 thread, 23 August 2026) · user type: EU citizen (Germany)
- Initiative: EU emissions trading system for maritime, aviation and stationary installations, and market stability reserve – review (14549); feedback period 20 August – 18 October 2026, extended until the adopted acts are available in all EU languages
- Subject: the carbon-removal provisions of the ETS Directive revision COM(2026) 616 (new Art. 9c). Filed in the COM(2026) 616 feedback thread on 25 August 2026 (the thread opened once the 141-page act was available); an earlier copy of 23 August (reference F33564904) also stands in the thread of the accompanying regulation COM(2026) 619.
- Permanent link (main thread): ec.europa.eu — Feedback F33566027 (with the 11-page evidence dossier attached)
All feedback received is summarised by the Commission and presented to the European Parliament and Council for the legislative debate. The submission has been checked against the final adopted text of COM(2026) 616 (Art. 9c(1) — 250 million allowances auctioned 2031–2040; Art. 9c(2) — 10 million contingency; recital 32; Art. 9c(8) — operator integration deferred to a 2034 report). This entry adds a European file number to the chain of twelve written statements from German authorities documented in the register.