Comment Text:
I believe that the current document lacks the following requirements:
1. Future leakage insurance for carbon credit projects: For example, in projects like REDD+ (Reducing Emissions from Deforestation and Forest Degradation) and biodiversity initiatives, there is a risk of CO2 being released into the atmosphere due to events such as forest fires or the unintentional release of sequestered biochar. While initial risk assessments are conducted during project initiation, there is a lack of compensatory measures to address the rebound of CO2 in the event of unforeseen circumstances. If carbon credits that have been offset over several years suddenly become invalid due to project failure (e.g., fire damage), there is no emission credit collateral to cover the losses for all parties, including nature.
2. Standardization of cross-border carbon credit transactions: Currently, voluntary carbon markets (VCM) use fiat currencies as the basis for pricing. However, barter transactions can mix credits of different qualities, and the interchangeability of carbon credit quality and value can lead to difficulties in pricing control by a single country's policies. Transactions involving overseas carbon credit pledging and offsetting should be subject to a jurisdiction similar to the long-arm regulation of the United States dollar.
3. Standardization of registration, issuance, and certification transactions for carbon credits: Transaction amounts and contracts should be publicly disclosed globally. Currently, major VCM markets lack standardized disclosure rules for buying and selling grades, and there are no admission standards for becoming a registry.
