巴西碳信用出口拟设限，中资碳资产开发需关注政策风向

Marcelo Medeiros Ana Paula Paiva/Valor Two pioneering executives in Amazon and Atlantic Forest restoration—economist Arminio Fraga, an adviser to and investor in re.green, and Marcelo Medeiros, the company’s board chair and co-founder—believe Brazil can become the leading force in removing CO₂ from the atmosphere. Both Fraga and Medeiros are concerned, however, about proposed regulations governing carbon-credit exports that the Ministry of Environment submitted for public consultation. In this interview, they explain their objections to export limits and argue that Brazil needs not a quota negotiated between the government and the private sector, but a national policy debate about the role the country wants to play in addressing the climate crisis. Below are the main excerpts from their interview with Valor. Valor: You say Brazil could become the world leader in removing CO₂ from the atmosphere. Could you explain? Marcelo Medeiros: Humanity faces the serious problem of global warming. The world currently releases about 50 billion tonnes of CO₂ into the atmosphere each year. Cutting greenhouse-gas emissions is indispensable, but the global climate equation will not balance unless 7 billion to 9 billion tonnes of CO₂ are removed from the atmosphere annually by 2050. This is where Brazil has both the opportunity and the obligation to play a decisive role. Valor: How can it be removed? Medeiros: The main removal technologies capable of contributing quickly and at scale—such as forest restoration; biochar, a type of charcoal produced by heating organic waste including wood scraps, straw, or sugarcane bagasse; enhanced rock weathering, a technique that grinds certain rocks into fine powder and spreads it on farmland; and bioenergy with carbon capture—depend on two inputs: land and climate. More than any other country, Brazil has land suitable for all these approaches, along with abundant sunshine and water. Arminio Fraga Ana Paula Paiva/Valor Arminio Fraga: In forest restoration, carbon is captured as plants grow. The carbon is stored in them. Organic chemistry—the chemistry of living organisms—is carbon chemistry. The concept here is exactly the classic principle of international trade: ideally, a system would let whoever can remove it at the lowest cost do so. It is comparative advantage, in other words. Brazil is in a privileged position in this case. Valor: Does that include exporting carbon credits under the Paris Agreement rules the government is developing? Medeiros: Consider Singapore, for example, which lacks the space for restoration. It will have to reduce its emissions by purchasing carbon credits from someone else. Some countries are clearly buyers of credits, while others are clearly potential exporters. Brazil belongs to the latter category. Fraga: It is as though we were taking on a task that another country cannot perform. Yet that is precisely the advantage the regulations submitted for public consultation propose to ration. Valor: A few days ago, the government, through the Ministry of Environment, closed its public consultation on regulations for carbon-credit exports—or internationally transferred mitigation outcomes, known as ITMOs. Several points drew criticism, including from you. Could you explain? Medeiros: We believe the regulations submitted for public consultation propose rationing the very advantage Brazil possesses. They set an export cap of 50 million tonnes of CO₂ for the period from 2031 through 2035, equivalent to 10 million tonnes annually. That represents just over 0.1% of global demand. Export restrictions received the most comments during the consultation, signaling a dangerous bargaining process over the degree of restriction to be adopted. What we need is not a quota negotiated between the government and private-sector participants. We need a national policy debate: What role does Brazil want to play in solving the climate crisis? Valor: What would constitute double counting in the Singapore example? Medeiros: Double counting would occur if Brazil used a CO₂ removal to lower its climate target—its nationally determined contribution, or NDC, in diplomatic terminology—and Singapore used the same credit toward its own target. The idea of restricting exports arises from a legitimate concern. When a Brazilian project exports a removal credit to the European Union or the international aviation offset market, the so-called corresponding adjustment means that tonne is counted in the buyer’s balance, not ours. Under this interpretation, exporting removals means exporting climate effort and making it harder to meet our own NDC—the target each country assumes under the Paris Agreement. The reasoning appears logical, but it rests on a false premise. Valor: How so? Fraga: The premise is that there is a fixed stock of removals to be divided between domestic and foreign markets. There is not. Most removal projects are capital-intensive and cannot move forward without long-term carbon-credit purchase agreements that make them bankable. We have the climate, the land, the science and the capacity to develop technology, but the market ultimately determines whether the sector develops. Without an export market, other countries will dominate the removal of CO₂ from the atmosphere. In that sense, the cap the government is proposing—this rule—is, in my view, an illusion. Valor: Under the proposal submitted for public consultation by the Ministry of Environment, the goal is to reduce emissions by 100 million tonnes of CO₂ from 2031 through 2035, while up to 50 million tonnes of CO₂ could be transferred through ITMOs. One government argument is that carbon-credit exports must be limited so the country can meet its NDC, its climate target. Medeiros: Making exports conditional on meeting the NDC creates a false dilemma and distorts priorities. Brazil’s target will not be decided in the carbon-credit market. Land use will decide it, as it is our largest gross source of emissions. Fraga: Brazil is meeting its target. The essential task is to end illegal deforestation. Deforestation has declined, but it remains high and has considerable room to fall further. The idea that we must restrict carbon-credit exports to meet the target is an illusion. Medeiros: Limiting exports of removal credits does not prevent deforestation. A restoration sector operating at scale does: it gives forests economic value, establishes firefighting brigades, brings legally mandated forest reserves into compliance and turns communities into allies against deforestation. Meeting the NDC gives the country authority in the climate debate; exporting removals brings jobs, technology and foreign-currency earnings. These objectives complement each other. Treating them as competing goals destroys the value of both. Fraga: One relevant detail is that this work is being financed with private money. Why can someone start an orange-growing business and export the oranges, or an iron-ore business and export the ore, or an aircraft business and export the aircraft, without these restrictions, while we—operating a business that provides a substantial public benefit—must be subject to them? It makes no sense. International trade in carbon credits is still in its infancy, but it could become very large. Pollution—greenhouse-gas emissions—affects society as a whole. Anyone helping reduce pollution is therefore providing, in a sense, a public good. Medeiros: A useful comparison is eucalyptus. Consider an area degraded by pasture. If a company buys it to plant eucalyptus, it can grow and harvest the trees and export the resulting product, whether timber or pulp. If a restoration company buys the same land and restores a tropical forest perfectly—with biodiversity, improvements in water quality and availability, and all the other benefits—our product cannot be exported. However, the Brazilian Development Bank (BNDES) has supported the restoration sector at a level comparable to the assistance it previously provided to sectors that later took off, such as pulp and paper and renewable energy. Valor: In summary, what do you want? Medeiros: It can be expressed in one sentence: remove the caps from the implementing resolution and elevate the decision about the scale of this sector to the level of national strategy. Move beyond regulatory bargaining and think big. Between meeting an ambitious NDC and becoming the world leader in removing CO₂ from the atmosphere, we choose both. Translation: Todd Harkin