Comment Details
| Comment Author: | Mary Grady |
| Organization: | American Carbon Registry |
| Comment Date: | Friday, 21 August 2009 |
| Uploaded Comment File: | Download File |
| Comments: |
Comments specific to Section 3: Definition of an offset: 3. Definition of an Offset ACR defines an offset, or Verified Emissions Reduction (VER) as the reduction or removal from the atmosphere equivalent to one metric ton of carbon dioxide. ACR’s carbon currency is an Emissions Reduction Ton (“ERT”). One ERT represents the reduction or removal of one metric ton of carbon dioxide from the atmosphere. We consider our currency to be fungible with other high quality offset programs (VCS, CAR) – “a ton is a ton is a ton.” Ownership Issues American Carbon Registry requires documentation of ownership and believes this is critical to ensuring that tons are real and not double counted / over sold into the marketplace. Use of approved protocols American Carbon Registry has taken the approach of building on the good work that has been done in other programs and allowing the use of protocols / methodologies and tools from other reviewed and approved programs to the extent that they meet ACR Standards. All approved methods and tools have been subject to a rigorous scientific peer review process. We would recommend that WCI also take the approach of accepting established high quality protocols from existing programs. |
| Comments: |
What has been your experience with the offset system examples cited in this paper? What have been the advantages and disadvantages to their approaches? : Winrock International’s non-profit American Carbon Registry (ACR) applauds the Western Climate Initiative (WCI) for its work in the development of an offsets program and welcomes the opportunity to provide comment to the WCI Design Recommendations. We believe the WCI offsets program can be stronger and more flexible by building on the experiences of existing programs, such as the eleven programs reviewed. You did not include ACR in your review, but we believe Winrock’s two decades of expertise in carbon science, methodologies and protocols and ACR’s experience with the issuance of more than 30 million tons of offsets since 2005 can provide helpful insights. We offer the following comments on the issues outlined in your White Paper and look forward to future collaboration with WCI. |
| Comments: |
Are the appropriate criteria listed? : The following two criteria were not covered in the White Paper, but are criteria that ACR considers relevant and important. They are somewhat related, but separate criteria. Direct emissions: An emission reduction or removal is a “direct emission” if the Project Proponent owns or has control over the source of the emissions (e.g., equipment) or the emissions sink (e.g., project lands). ACR requires a Project Proponent to own or have control over the GHG sources or sinks from which the emissions reduction or removal originate and therefore does not register indirect emissions. ACR’s exception to this rule is indirect emissions reductions from renewable energy and energy efficiency projects from developing countries, which are eligible for registration. Renewable Energy: ACR does not accept registration of U.S. renewable energy projects which are generating Renewable Energy Credits (RECs) for the voluntary or Renewable Portfolio Standard (RPS) markets for a number of reasons: 1) Selling RECs and offsets is double counting of the environmental benefit of the project; 2) RECs are not equivalent to offsets as they are not generated / governed by the same criteria including ownership and additionality; 3) RECs convey ownership of indirect emissions attributes. |
| Comments: |
Comments specific to Section 4: Real: 4. Real ACR considers an offset to be real if it yields after-the-fact, quantifiable and verifiable GHG emissions reductions or removals. ACR requires that the GHG reduction or removal exist prior to offset issuance and will not forward issue nor forward register a projected stream of future offsets. Leakage Leakage refers to a decrease in sequestration or an increase in emissions outside the project boundaries as a result of project implementation. Leakage may be due to the shifting of the activities present in the baseline, or due to market effects whereby emission reductions are countered by emissions created by shifts in supply and demand of the products and services affected by the project. ACR requires Project Proponents to assess, account for, and mitigate leakage, and provide documentation to support leakage mitigation assertions. Project Proponents must deduct all leakage that reduces the GHG emissions reduction and/or removal benefit of the project. ACR assesses leakage on a case-by-case basis. Quantification, uncertainty and accuracy ACR requires use of scientific best practices as incorporated in ACR approved methods and tools. Best practice entails that a Project Proponent be conservative, transparent and thorough and include a systematic explanation of establishment of the baseline and baseline update, additionality determination, GHG modeling and measurement, monitoring emissions reductions or removals, determining reversal risk and estimating leakage. |
| Comments: |
Comments specific to Section 5: Additional: 5. Additional ACR defines additionality as a test to ensure that a project-based offset is “in addition to” reductions and/or removals that would have occurred without carbon market incentives. ACR requires every project to pass either an approved performance standard and a regulatory additionality test or a three-pronged hybrid test of additionality in which the project must: 1) exceed regulatory / legal requirements; 2) go beyond common practice; and 3) overcome one of three implementation barriers: institutional, financial or technical. ACR has made the determination to be flexible in its approach to additionality in order to promote innovation for development of new methodologies and project types. We would recommend that WCI also adopt an approach which allows for flexibility and innovation. Baseline ACR considers the baseline to be a counterfactual scenario that forecasts the likely stream of GHG emissions reductions or removals to occur if the project proponent does not implement the project, i.e., the "business as usual" case. Baseline calculations must be consistent with the WRI / WBCSD GHG Protocol and ISO 14064-2, and use ACR-approved best practices. Project start date / eligibility ACR defines project start date for non-forest / land-use-change projects as the date by which the project began to reduce GHG emissions against the project’s baseline and the start date for forest and land-use-change projects as the date by which the Project Proponent began the project activity on project lands. In determining appropriate start dates for project eligibility, ACR decided to tie start date and eligibility to recognized milestones rather than to its own existence (The ACR was founded as the GHG Registry and began operation in 1997). ACR has determined a project start date for non-forest / land use change of 01 January 2000 or later as eligible for ACR registration. This date is based on the start date for CDM. ACR has determined a project start date for forest and land-use-change projects of 01 November 1997 or later as eligible for ACR registration. This date is based on the October 1997 publication of the “Guide to Monitoring Carbon Storage in Forestry and Agroforestry Projects.” Forest and land-use-change projects with an earlier start date will be evaluated on a case-by-case basis and accepted or rejected based on the conformity of the methodology to best practices for monitoring carbon storage in forestry and agroforestry projects and conformity with ACR Standards. For WCI, ACR would recommend considering a relevant regional, national or international milestone for a project start date in order to give appropriate credit to those true early actors who began reducing emissions in anticipation of regulation and have provided an emission reduction benefit to the environment. ACR would recommend crediting “early action” emissions reductions beginning from the project start year for eligible projects which would be tradable for allowances once compliance begins. Crediting period ACR requires a crediting period of ten (10) years or less for non-forest projects, with opportunities for renewal and thirty-five (35) years or less for afforestation / reforestation (AR) projects, with opportunities for renewal. ACR requires improved forest management (IFM) and reduced emissions from deforestation and degradation (REDD) projects to have a crediting period of ten (10) years or less, with opportunities for renewal. To renew the crediting period, Project Proponents must secure the services of an independent, approved verifier to validate the PD as using Best Practice methodologies, tools, factors, and monitoring processes at that time. |
| Comments: |
Comments specific to Section 6: Permanent: 6. Permanent Permanence is a reference to the longevity of the atmospheric benefit created by geologic and terrestrial (e.g., carbon that is stored in biomass and soil) sequestration. ACR requires that Project Proponents address the risk of reversal by use of one of the following: an approved insurance product to guarantee offsets; a carbon buffer pool; access to a secure source of replacement offsets; or other approved risk management technique. ACR requires terrestrial sequestration Project Proponents to use the approved “Tool for AFOLU Non-Permanence Risk Analysis and Buffer Determination” in order to address reversal risk and to determine the size of the buffer. ACR requires geologic sequestration Project Proponents to use approved methodologies that assure permanence including ongoing QA/QC and long-term monitoring. |
| Comments: |
Comments specific to Section 7: Verifiable: 7. Verifiable Verifiable reductions are those that can be independently validated as accurate through verification. Verification is the independent assessment by a qualified and impartial third party of GHG emissions reduction / removal. The outcome is a verification report and a statement signed by the lead verifier that provides an opinion on the relevance, completeness, accuracy, reliability, and transparency of the GHG quantification data and methods. ACR requires third party verification by an approved verifier prior to offset issuance. Verifiers must use transparent and replicable verification methods against the relevant ACR standard. ACR reserves the right to reject the verification report from an approved verifier. |
| Comments: |
Comments specific to Section 8: Other considerations: 8.0 Co-benefits Projects have the potential to generate both positive and negative community and environmental impacts. While ACR does not require projects to have co-benefits, projects that do have co-benefits can be certified to an additional standard, such as Climate, Community and Biodiversity (CCB) Standard, and branded as such on ACR. ACR does not require compliance with CCB Standard or completion of the CCB certification process, but does recommend that Project Proponents choose among the CCB’s published list of preferred tools and methodologies to identify, assess, and report on community and environmental impacts. Additionally, prior to registration and on an ongoing basis, ACR requires written disclosure of any prior negative environmental or community impacts or claims of negative environmental and community impacts. All projects must document a mitigation plan for any foreseen negative community or environmental impacts. |
| Comments: |
Please provide any additional/general feedback. : About Winrock International and the American Carbon Registry Winrock International Institute for Agricultural Development (“Winrock”), a non-profit organization dedicated to sustaining natural resources and improving the environment, has over two decades of expertise in carbon science, methodologies and protocols. Winrock’s American Carbon Registry is a recognized voluntary offset program with strong standards for environmental integrity and over a decade of time-tested operational experience in high quality carbon offset issuance, serialization and transparent on-line transaction reporting. The American Carbon Registry (ACR) was founded in 1997 as the GHG Registry by the Environmental Defense Fund (EDF) and Environmental Resources Trust (ERT). As the first private voluntary GHG registry in the U.S., ACR has set the bar for transparency and integrity that is the market standard today. ACR has issued over 30 million project based carbon offsets, and in 2008 was the most widely used voluntary carbon market registry in the world. The American Carbon Registry and ERT joined Winrock in 2007, expanding Winrock's team of experts in climate change, forestry, clean energy, agriculture, biofuels and carbon markets. Winrock is a leader in developing scientific-based standards and protocols for key climate change initiatives. Winrock experts who are responsible for the development of American Carbon Registry standards and protocols have authored and co-authored carbon protocols and methodology manuals and guidelines for a wide range of organizations including but not limited to U.S. Environmental Protection Agency (EPA), U.S. Department of Agriculture (USDA), USDA Forest Service (USFS), U.S. Agency for International Development (USAID), World Bank, International Tropical Timber Organization (ITTO), United Nations, The Nature Conservancy (TNC), Electric Power Research Institute (EPRI), Climate, Community and Biodiversity Alliance (CCBA), Voluntary Carbon Standard (VCS) and California Climate Action Reserve (CAR). Winrock has partnered nationally and internationally with leading environmental NGOs, who trust our commitment to science-based methodologies and policies that ensure precision and rigor in the measurement of carbon sequestration and environmental benefits. Current and previous NGO partners include (TNC), Wildlife Conservation Society (WCS), Conservation International (CI), World Wildlife Fund (WWF), American Land Conservancy and Environmental Defense Fund (EDF). Winrock’s ACR provides an electronic registry system designed to serialize and transparently track offset credits from projects around the globe (www.americancarbonregistry.org). ACR has registered tons from project types including landfill methane, livestock methane / biodigesters, industrial gas substitution, enhanced oil recovery, fuel switching, transport efficiency and developing country renewable energy. ACR also publishes standards, methodologies, protocols and tools for greenhouse gas (GHG) accounting, which are all based on International Standards Organization (ISO) 14064. ACR only registers project-based carbon offset tons that are real, additional, permanent and verifiable and comply with American Carbon Registry Standards including meeting our published American Carbon Registry Technical Standard, which outlines requirements for registration of project-based carbon offsets. ACR allows project developers to use methodologies and tools for GHG measurement from other approved programs to the extent that they comply with the Registry’s published standards. ACR has published project specific protocols for various project types as well as a Forest Carbon Project Standard which includes requirements for afforestation, reforestation, improved forest management and reduced emissions from deforestation and degredation (REDD) projects. Other standards are in process of development and publication including landfill methane, livestock waste management and reduced nitrogen from fertilizer use. All new methodologies must be validated through a scientific peer review process. All projects must be third party verified by an approved ACR verifier before issuance of tons. |