September 15, 2023
(press release)
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Verra welcomes and encourages the insight of the broader scientific and environmental community into our work on nature-based solutions, including the recent research papers by a team of natural resource and land-use academics led by Barbara Haya of the University of California, Berkeley. There is much we agree on with the authors of this research, and some important points of clarification we would like to make. Most importantly, we strongly feel that the current scrutiny of the voluntary carbon market is essential and necessary. It is part and parcel of a maturing and expanding market that has a critical role to play in ensuring a livable future for our children. As an environmental nonprofit, Verra’s mission is to ensure a habitable planet, doing everything we can to facilitate a voluntary carbon market that helps us get there. While many of the individuals involved in this research have been outspoken opponents of this approach for years, we appreciate that their concerns come from a profound desire for meaningful action, which we share. The Haya papers include several important retrospective findings about our REDD+ work to date. (“REDD” stands for “Reducing Emissions from Deforestation and Forest Degradation.” The “+” refers to the sustainable management of forests and the conservation and enhancement of forest carbon stocks.) However, it is important to note that the vast majority of findings and recommendations from this research align with extensive and systematic work to update the Verified Carbon Standard (VCS) Program that Verra has carried out over the last two years. A detailed response to specific observations within Haya et al.’s papers can be found below this statement. We are committed to transparency and have built an ecosystem of processes and relationships to develop consensus standards and methodologies that support climate action. Through a transparent process that engages a global network of experts and allows significant opportunity for public input, we have developed a new methodological approach for REDD+ projects, updated non-permanence risk tools, and strengthened provisions for safeguards, leakage, and baseline setting. Verra released much of this work as part of the August 29, 2023, VCS Program update, while other elements will be released over the coming weeks and months. Several other findings in the research either are not specific to the VCS Program (applying to any carbon standard) or include speculation that would benefit from additional information. The Haya et al. papers explore methodological provisions for baseline setting, leakage, permanence, carbon accounting, and safeguards. Below, Verra offers a detailed comparison of key points raised in the Haya et al. papers and those addressed in our forthcoming REDD methodology updates. Haya et al. Observation The report points out the various different approaches in the existing REDD methodologies for assessing, mitigating, and quantifying leakage that lead to inconsistencies. Verra Response Verra agrees there is a clear requirement to consistently assess market leakage, particularly when there is an impact on timber. As such, we have updated our approach by implementing standardized leakage accounting within the latest Avoiding Unplanned Deforestation (AUD) methodology to remove any inconsistencies between methodologies. Similar standardizations are planned for other activities. Find out more on the REDD methodology page. Haya et al. Observation Haya et al. argue that international leakage should be accounted for. Verra Response Verra’s decision to exclude international leakage from its methodology aligns with every standard in the market, including the Clean Development Mechanism (CDM). This is a general carbon market approach that exists because leakage should be mitigated and monitored. However, doing so in another country is not practical. For instance, a project in Zambia cannot enforce mitigation measures in Zimbabwe. Similarly, there are potential sovereignty issues when monitoring in another country. Verra recognizes the need to make progress on these matters globally. Each country should take responsibility for its domestic policies, and existing standards aim to support progress in countries where projects are actively implemented. In the meantime, Verra will be reviewing this policy. Haya et al. Observation The report levies a number of criticisms at historic baseline approaches. Verra Response For over two years, Verra has been updating its baseline methodologies. The forthcoming consolidated AUD methodology and module will be released in the next quarter. All relevant projects are required to update by 2025. Find out more on the REDD methodology page. Haya et al. Observation The report raises several key points regarding Verra’s permanence approaches. Verra Response Verra recently released an updated AFOLU non-permanence risk tool (PDF). Among other things, the new tool requires a minimum withholding amount, eliminates negative scores resulting from mitigation efforts, and incorporates climate impacts into risk assessments. Additionally, Verra has announced a new approach for long-term monitoring, ensuring a continuous evaluation of project areas both during the crediting period and beyond. Find out more about Verra’s long-term monitoring system and permanence updates (PDF). Haya et al. Observation The paper puts forth specific recommendations concerning greenhouse gas accounting in forest carbon projects (e.g., highlighting allometric equations and below-ground biomass). Verra Response Many of these suggestions are already incorporated into the new methodology. Verra will review the remaining recommendations and consider integrating any relevant updates. Haya et al. Observation The paper emphasizes the necessity for additional transparency and data accessibility. Verra Response Verra is in the process of launching new digital tools for project descriptions and methodologies. These tools will ensure all data is submitted correctly and is transparently available to stakeholders. Find out more in our recent announcement about the Verra Project Hub and in our update on project reviews. Verra has a responsibility to help nurture the ecosystem of sustainability markets by investing in and strengthening efforts that benefit the market as a whole. Providing adequate training and support of auditors – the validation/verification bodies (VVBs) – is a big piece of that. For example, in the latest Verified Carbon Standard (VCS) update released in late August, we introduced changes to strengthen the overall integrity of VVB performance. This includes updates to Verra’s responsibilities for oversight of the VVBs, as well as new sanction procedures in the case of poor performance and/or non-conformance by VVBs.
We are committed to remaining engaged with the academic and scientific communities as updates and changes go into effect.Verra's Response to Specific Observations within Barbara Haya et al.'s Report on the Integrity of Project-REDD+ Methodologies under the VCS Standard
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