Comment Text:
aDryada welcomes the CFTC's wish to strengthen the integrity and transparency of markets for derivatives of voluntary carbon credits. As a developer of large-scale reforestation projects all over the world, with a strong focus on biodiversity and well-being of local communities, we are convinced that carbon credits must be of "quality" to fully play their role against global warming. At aDryada, "quality" means that the projects generating these credits are based on three inseparable pillars: climate, biodiversity, and local populations.
Our comments are the following ones :
Questions 1/2 - Quality/reversability
On its document, the CFTC particularly insists on the need for a buffer zone to prevent reversibility.
Comment:
Although the presence of a buffer is essential to limit risks, it is not enough. The two main factors for the non-permanence of projects are in fact the absence of biodiversity (a field of trees is created or preserved, not a forest. This means any single fire or illness destroys the whole area) and the lack of support for the project from neighboring populations (social risk).
Comment
- aDryada suggests the CFTC indicates carbon credits must be generated by projects that : 1/ apply the highest international standard regarding their social impact (we suggest the IFC PS) and demonstrate a net positive impact of biodiversity (not only a "do not harm" effect)
Questions 13/14 - Double-counting
On its document, the CFTC states that "a DCM should consider whether the crediting program for the underlying VCCs can demonstrate that it has effective measures in place that provide reasonable assurance that credited emission reductions or removals are not double
counted. That is, that the VCCs representing the credited emission reductions or removals are issued to only one registry and cannot be used after retirement or cancelation"
Comment :
- The market for voluntary carbon credits is now polluted by confusion around the definition of “double counting” : are we talking about double insuance, double use, or double claim ? If double issuance and double use of the same unit are clearly condemnable because they are contrary to the achievement of climate objectives, is the fact that a country and a company both make a claim about the same credit also condemnable given their carbon accounts are clearly distinct?
- There are several types of registers, and countries wishing to carry out international carbon credit transactions (article 6) are currently creating their own.
- Considering this confusion, aDryada suggests CFTC indicates "(...) are issues to only one volontary carbon registry" (eq. Verra or Gold Standard for instance)
