Captain Drawdown’s daily logbook on every CDR story, paper, and expert voice — so you don’t have to read them all.
In March 2025, Robert Hoglund published a line-by-line critique of the draft SBTi Net Zero Standard 2.0 arguing that interim carbon removal targets must cover a company’s total CDR need, not just its Scope 1 emissions. It is the kind of comment - technical, specific, aimed at one clause in one draft - that ends up rewriting the clause. That is what Hoglund does now.
He runs Marginal Carbon, a one-person policy shop that has become one of the more quietly consequential voices in carbon removal. Over the past two years he has published on the Swiss Climate Act’s corporate CDR milestone rule (January 2025), the SBTi 2.0 draft, the shipping and aviation carve-outs that exclude removals from compliance markets (September 2025), and a semantic attack on the phrase “residual emissions” itself. Taken together it is a policy toolkit. Read in sequence it is an argument.
The argument goes like this. Most net-zero standards treat CDR as a scarce last resort, usable only against “unavoidable” or “residual” emissions in a narrow band of hard-to-abate sectors. Hoglund thinks that framing is the reason demand for removals is anemic. In his words, “If you restrict removal use for ‘unavoidable’ emissions, you end up using it for nothing. We need to treat CDR as any other mitigation solution, and let markets allocate its use.” He is not saying permanence and quality do not matter. He polices those hard, including a Medium piece telling enhanced rock weathering buyers to demand better measurement, reporting, and verification. He is saying the rationing frame and the quality frame are being conflated, and the conflation is killing the market.
The work is regulatory, and it is specific. On Switzerland, Hoglund is documenting the first jurisdiction to write corporate CDR milestone targets into binding climate law. Other governments will copy or reject that template, and how it gets interpreted in year one matters. On the EU side, he has mapped exactly which shipping and aviation rules currently make CDR ineligible for compliance - the specific clauses inside CORSIA and the EU ETS carve-outs that a future amendment would have to touch. On SBTi 2.0, his fix is a single sentence about how interim targets are scoped. On the framing layer, he wants regulators to retire “residual emissions” as a concept, because the word “residual” is doing more work than any definition can support.
His lens is that regulators keep having one fight - permanence - when they should be having three. As Hoglund puts it, “Arguments over CDR permanence miss the point when net zero, legacy emissions, and interim responsibility are conflated.” Three jobs, three sets of rules. Net-zero balancing is one problem. Drawing down legacy CO2 is another. What a company owes for its emissions this decade, before it hits net zero, is a third. Standards drafters have not made that distinction cleanly, and until they do, every eligibility argument is really three arguments in a trench coat.
The bet Hoglund is making is that scarcity thinking loses. “Plan for scarcity, build for abundance,” he has written, arguing against caps and rationing in CDR policy. That bet is being tested right now inside SBTi 2.0 and inside the EU’s removals integration work. He is sober about the timeline. “We had a fast start, but it will be slow before it speeds up again,” he wrote in his mid-decade assessment, framing the slowdown as a policy design problem rather than a technology one.
Why his voice matters here: Hoglund is one of the few commentators trusted by both corporate buyers and standard-setters, and he is arguing for looser, market-based CDR rules at exactly the moment the drafting processes are trending tighter and more sector-restricted. That is an unusual position to hold credibly. It works because he pairs the “let markets allocate” argument with a hard line on method quality - the ERW post is the tell.
For anyone building a removal company, the leading indicator is narrow and specific. Watch whether the final SBTi Net Zero Standard 2.0 adopts Hoglund’s fix on interim CDR target scope. If it does, the addressable market for removals in 2028 is meaningfully bigger than today’s guidance implies. If it does not, the residual-only camp has held, and the wedge Hoglund has spent the past two years sharpening will need another draft cycle to cut.
Citations
- Substack (marginalcarbon) — “If you restrict removal use for ‘unavoidable’ emissions, you end up using it for nothing. We need to treat CDR as any other mitigation solution, and let markets allocate its use.” — Substack post
- Medium — enhanced rock weathering buyers to demand better measurement, reporting, and verification
- Substack (marginalcarbon) — documenting the first jurisdiction to write corporate CDR milestone targets into binding climate law — Substack post
- Substack (marginalcarbon) — mapped exactly which shipping and aviation rules currently make CDR ineligible for compliance — Substack post
- Substack (marginalcarbon) — retire “residual emissions” as a concept — Substack post
- Substack (marginalcarbon) — “Arguments over CDR permanence miss the point when net zero, legacy emissions, and interim responsibility are conflated.” — Substack post
- Medium — “Plan for scarcity, build for abundance,”
- Substack (marginalcarbon) — “We had a fast start, but it will be slow before it speeds up again,” — Substack post
Correction (2026-09-18): this log originally dated Hoglund’s SBTi critique to “last week” and his policy series to “the last month.” The pieces span January 2025 to late 2025. Dates corrected; the portrait stands.