Public Comment on Voluntary Carbon Markets – Consultation Report

An overly proscriptive [sic] approach to the development of the voluntary carbon markets could have the effect of impeding the promise these markets offer to assist the larger community in reaching global emissions reduction targets.”[3] The CFTC did not heed all the CME Group’s warnings about proposing regulation of any kind for the “still evolving” voluntary carbon markets. [...] For example, consider the next iteration of the Assessment Framework, regarding permanence: “The ICVCM will consider longer monitoring and compensation periods (e.g., one hundred years) and shifting the monitoring and compensation oversight to the carbon-crediting program or the jurisdiction aligned with existing and emerging best practice among carbon crediting programs.”[8] The duration of perma. [...] At the very minimum, the bar for storage with significant climate benefits is several centuries.”[10] In the event of a ICVCM standard of a 100-year carbon storage permanence and crediting program buffer account failure, it is likely that developing country governments that host VCCs would have to assume the costs of monitoring and maintaining an adequately financed buffer account of high-quality. [...] The legal and economic consequences of adopting a science-based duration for the monitoring of offset reductions and compensation for emissions reversals are staggering, and not just for the crediting programs and the “shift” to governments of the monitoring and emissions reversals responsibilities and liabilities. [...] One analysis of CORSIA states: While CORSIA is the first international agreement to address emissions for a sector, it has also been heavily criticised for its shortcomings, including the lack of ambition of its goal of “carbon-neutral growth,” the coverage of CO2 emissions only, the limited [airline company] participation in the voluntary phase, the quality of the eligible carbon credits, and its.