Carbon Reduction Projects and the Concept of Additionality

Author:Brian Joseph McFarland
Position:Recently finished a dual graduate degree in Business Administration and Global Environmental Policy from American University, is now Carbonfund.org's Carbon Projects Manager
Pages:15-18
 
CONTENT
SUSTAINABLE DEVELOPMENT LAW & POLICY15
INTRODUCTION
Carbon reduction projects follow a cycle that includes
conceptualization, due diligence, implementation,
documentation, audit or validation, and finally certi-
fication, with the eventual issuance of verified, serialized car-
bon reduction credits, also known as carbon offsets. To fulfill
this process, there are several technical elements that must be
addressed: monitoring or measurement, reporting, and verifica-
tion (“MRV”), permanence (i.e. ensuring the project’s duration),
leakage (i.e. addressing negative and identifying positive offsite
impacts), and additionality.
Additionality is a test that a carbon reduction project must
meet to ensure the project would not have been implemented
without the revenue of the carbon markets.1 This test of addi-
tionality must be satisfied if the project is being submitted to the
voluntary carbon markets—for which, voluntary buyers want to
be ensured their donations actually matter for a project—or to
the compliance markets since buyers need to be confident that
regulators will accept their carbon reduction purchase.
It is important to further note that all of the most prominent
carbon reduction certification standards—again, whether a com-
pliance market under the Kyoto Protocol or an internationally
recognized voluntary standard—require some type of addition-
ality test. This includes, but is not limited to, the following cer-
tification standards: the American Carbon Registry (“ACR”),2
Center for Resource Solutions (“CRS”),3 Green-e Climate
Protocol for Renewable Energy,4 Chicago Climate Exchange
(“CCX”),5 Clean Development Mechanism (“CDM”),6 Climate
Action Reserve (“CAR”),7 Climate, Community and Biodiver-
sity Standard (“CCBS”),8 Gold Standard,9 Regional Greenhouse
Gas Initiative (“RGGI”),10 and the Verified Carbon Standard
(“VCS”).11
Additionality is an important requirement because if non-
additional (i.e. “business-as-usual”) projects are eligible for car-
bon finance, then the net amount of greenhouse gas emissions
will continue to increase and the environmental integrity of car-
bon reduction projects will be called into question. For example,
if a project was already far exceeding its industry average return
on investment and was implemented over fifty years ago when
no carbon markets existed, why should this particular project
also be eligible for additional revenue from the carbon markets?
Similarly, if an activity was legally required, then why should
this activity of a regulated entity also be eligible for additional
revenue from the carbon markets? The challenge with addition-
ality, however, is that one must prove a counterfactual argument
(i.e. what would have otherwise happened in the absence of a
project) to ensure the project provides carbon reductions that
would not have otherwise occurred. This article explores the dif-
ferent concepts of additionality, while acknowledging its con-
troversial elements and proposing inclusion of some important
considerations to ensure net emissions reductions.
LEGAL OR REGULATORY ADDITIONALITY
Legal additionality, or what is sometimes referred to as
regulatory additionality or surplus, is perhaps the most objec-
tive type of additionality. If a law exists and a given activity
is regulated, then the project is most likely not eligible for car-
bon finance. Therefore, for a project to meet the legal addition-
ality standard, it must provide carbon reductions beyond those
required by law.12
To put this in context, the U.S. Environmental Protection
Agency (“EPA”) regulates large municipal solid waste (“MSW”)
landfills, and according to the Climate Action Reserve’s Landfill
Project Protocol Version 3.0, “[t]here are several EPA regula-
tions for MSW landfills that have a bearing on the eligibility of
methane collection and destruction projects as voluntary GHG
reduction projects.”13
Two challenges with legal additionality are that on one
hand, the concept might create perverse incentives, and on
the other hand, sometimes following the law is not common
practice. With the first idea in mind, the Montreal Protocol is
an international treaty designed to phase out the production of
ozone depleting substances (“ODS”).14 While the United States,
Canada, and European nations have phased out the production
of hydrofluorocarbons (“HFC”), which are ODSs and green-
house gases, the largest contributor of certified emission reduc-
tions (“CER”) under the Kyoto Protocol’s Clean Development
Mechanism are from HFC projects in China and India.15 Since
legal additionality would rule out the eligibility of HFC proj-
ects hosted in China and India if these countries were to pass
CARBON REDUCTION PROJECTS AND THE CONCEPT
OF ADDITIONALITY
by Brian Joseph McFarland*
* Brian McFarland, who recently finished a dual graduate degree in Business
Administration and Global Environmental Policy from American University, is
now Carbonfund.org’s Carbon Projects Manager. While finishing his Psychol-
ogy and International Development undergraduate degree from Clark Univer-
sity, Brian conducted environmental fieldwork in Mexico, Costa Rica, Kenya,
and Brazil. During graduate school, Brian also volunteered for the Smithson-
ian Institution, the United Nations Global Compact, and the U.S. Department
of State. In addition, Brian is currently a member of the Leonardo Academy’s
Emissions Inventories, Offsets and Reduction Credits Standard Committee,
a member of the Metropolitan Washington Council of Governments’ Air and
Climate Public Advisory Committee, and a Canadian Standards Association
(“CSA”) Standards Certified Greenhouse Gas (“GHG”) Inventory Quantifier.
The opinions expressed in this paper are those of the author and do not neces-
sarily represent the views of Carbonfund.org.
WINTER 2011 16
domestic laws eliminating the production of HFCs, they have
little incentive to begin regulating HFCs. If they did pass regu-
lations, China and India would experience a reduction of for-
eign investment towards the purchase of these carbon reduction
credits and would need to use their own public funds to phase
out HFCs. Due to the perception that manufacturers are actually
producing excess HFCs, the European Union Emission Trad-
ing Scheme will no longer accept these HFC reduction credits
beginning in 2013.16 Another example of this legal additional-
ity challenge is the tough predicament a government might face
when contemplating the passage of a strict feed-in tariff or an
aggressive renewable portfolio standard. Such a passage would
effectively legally require an increase in renewable energy pro-
duction, however, there would be fewer carbon reduction credits
from these renewable energy sources eligible for purchase from
international buyers.
On the second challenge of additionality, there are legal
reserve requirements on private property in Brazil. Depending
on the region (e.g. Amazon Region versus Cerrado Region), a
landowner is restricted from using twenty to eighty percent of
his or her land.17 However, it is a somewhat common practice—
particularly in the remote Amazon—to illegally clear forests
from the legal reserve.18 Now, if such practices are deemed to be
common, should legal additionality still apply and thus prevent
the reforestation of this fallow land using carbon finance?
Corruption also presents challenges for ensuring the legal
additionality of a project. There are currently carbon reduc-
tion projects either certified or under development in Ethiopia,
Nicaragua, the Philippines, Kenya, and Venezuela.19 Yet, Trans-
parency International’s Global Corruption Report 2009 rates
Ethiopia as the 126th most corrupt country out of 180 countries,
Nicaragua as the 134th, the Philippines as the 141st, Kenya as
the 147th, and Venezuela as the 158th.20 Where projects provide
much needed financing in developing countries with already
corrupt infrastructures, there may be a disincentive to upgrade
or improve legal frameworks that could reduce the number of
carbon reduction projects.
The evolving regional compliance carbon markets of the
U.S.—which are the Western Climate Initiative (“WCI”), the
Regional Greenhouse Gas Initiative (“RGGI”), and the Mid-
western Greenhouse Gas Reduction Accord (“Accord”)—have
Canadian Provinces and Mexican States as either participants
or observers.21 As these regional programs transform, it will be
interesting to see how state or national laws, and thus legal addi-
tionality, will be applied.
COMMON PRACTICE OR TECHNOLOGICAL
ADDITIONALITY
Common practice additionality, which could incorporate
either the technological or market penetration of a given project
type based on its geography, is another objective additionality
test. The aspect of geography is important because what is prev-
alent in one location—for example, wind turbines in Texas or
solar photovoltaic systems in California—might not be so preva-
lent in other locations (i.e. such as New Hampshire or Alaska).
According to the American Carbon Registry’s standard, com-
mon practice is determined by whether there is “widespread
deployment of the project . . . within the relevant geographic
area.”22 Similarly, the Verified Carbon Standard defines it as one
which is “not common practice in the sector/region, compared
with projects that have received no carbon finance.” 23
Yet, how does one define common practice and what spe-
cifically would be the particular geographic focus (i.e. a coun-
try, state, local electric grid)? Perhaps one of most controversial
examples surrounding common practice was the Chicago Cli-
mate Exchange’s acceptance of soil conservation carbon reduc-
tion projects (i.e. also known as no-till), which were previously
enrolled in the U.S. Department of Agriculture’s Conservation
Reserve Program.24 Under this program, farmers were rewarded
by the purchase of their carbon reduction credits for activities
that they were already undertaking without revenue from the
carbon markets.25 If a regulated industry is allowed to emit
greenhouse gas emissions because they are supporting non-addi-
tional carbon offset projects, then the environmental integrity of
the system should be called into question because the net green-
house gas emissions will continue to increase. Climate Action
Reserve (“Reserve”) aptly points out that there are many dif-
ficulties in actually defining the common practice of a region. 26
According to Derek Six, the Portfolio Manager for Environ-
mental Credit Corporation, the best assessment of additionality
would be the use of a market penetration approach.27 Such an
approach, which is similar to common practice, would incor-
porate knowledge and technology barriers to implementation,
along with financial aspects of additionality.28 For example,
agricultural methane destruction or agricultural methane gas-to-
energy projects are only installed on about 0.5% of U.S. farms.29
Thus under a market penetration approach, all agricultural meth-
ane destruction and agricultural methane gas-to-energy proj-
ects would be eligible for carbon finance whether or not there
were projects clustered in a specific region (e.g. California) or
whether a particular project had a slightly higher financial return
(i.e. financial additionality).
FINANCIAL ADDITIONALITY
Many carbon market participants are averse to the concept
of financial additionality, which is much more subjective than
legal additionality or common practice. Likewise, financial
additionality is difficult to determine due to matters of confiden-
tiality, proprietary internal business decisions, and the potential
use of arbitrary metrics. The Clean Development Mechanism,
which refers to financial additionality as the investment analy-
sis, considers whether the project would have been financially
attractive without the revenue from carbon reduction credits.30
The Verified Carbon Standard considers financial addition-
ality, which it defines as an investment barrier and a subset of
implementation barriers.31 The American Carbon Registry also
considers financial additionality a subset of implementation bar-
riers and asks whether funding from carbon reduction credits
will incentivize the project’s implementation.32
SUSTAINABLE DEVELOPMENT LAW & POLICY17
Confidential and proprietary internal business matters that
make financial additionality a subjective and difficult assess-
ment include, but are not limited to:
      
funded and why?)
       
capitalists)
  -
ments/projects are possible?)
    
(“ROA”), return on equity (“ROE”), and/or payback
period (i.e. which metric does a firm use and what is the
requirement?)
While the Clean Development Mechanism has an extensive
discussion on appropriate metrics for financial additionality
(i.e. discount rates and benchmarks), arbitrary metrics such as
the following could be used as justification for allowing or not
allowing a project to count as eligible for carbon finance:
   
employees)
      
electric grid)
 
 
This said, how do you compare a small, specialized renewable
energy company to a large, diversified provider? Similarly, do
start-ups differ from “well-established” companies enough
to present a challenge when comparing financial additionality
thresholds? Also, how does the ownership structure (i.e. non-
profit, limited liability corporation, type C corporation, public-
owned entity, joint-ownership) impact financial decisions and
thus, financial additionality?
Applying financial additionality across a broad spectrum
of project types is another significant challenge, posing many
serious questions. Likewise, why should carbon markets reward
projects that demonstrate the poorest financials? If two different
projects existed and with one thousand dollars, one could reduce
one thousand metric tons of carbon dioxide and the other could
reduce one hundred metric tons, why should the one hundred
metric tons project be considered more financially additional?
On the other hand, why reward projects that already have “supe-
rior” returns and that existed before the formation of carbon
markets (i.e. a question which relates to voluntary buyers want-
ing their donations to matter)?
Financial additionality should be phased out of future certi-
fication standards and new revisions of current certification stan-
dards, a position supported by Green-e Climate.33
PROJECT-BY-PROJECT ADDITIONALITY
Under the project-by-project test for additionality, each proj-
ect individually undergoes a series of additionality tests accord-
ing to the given standard. Two main standards, which apply a
project-by-project additionality test, are the Clean Develop-
ment Mechanism and the Verified Carbon Standard. The Clean
Development Mechanism is the carbon reduction standard for
Certified Emission Reductions (“CER”) for the Kyoto Proto-
col’s international compliance market.34 In contrast, the Verified
Carbon Standard is the leading voluntary carbon markets stan-
dard, in terms of market share, and has adopted methodologies
from the CDM.35
Essentially, project proponents—whether referring to inves-
tors, project developers, landowners or buyers—need to assess
whether each and every individual project meets the additional-
ity tests. Such a process can be expensive, time-consuming (i.e.
reduces scalability and time-to-market), and difficult for both the
general public and local communities to grasp. Furthermore, it is
difficult for auditors to determine an individual project’s subjec-
tive assertions, especially with regard to financial additionality.
PERFORMANCE OR SECTORAL ADDITIONALITY
Many current and evolving certification standards—includ-
ing the Regional Greenhouse Gas Initiative, the Western Cli-
mate Initiative, and the Climate Action Reserve—are adopting
performance or sectoral approaches to additionality. Essentially,
such performance or sectoral approaches use a uniform addition-
ality test or benchmark, which could be based on an industry or
geographic region. It is important to note, the same additionality
criteria—such as legal, common practice/technology, and finan-
cial—can be applied to a performance or sectoral approach, the
main difference is that such criteria are not uniquely applied to
each single project. Under the Regional Greenhouse Gas Initia-
tive (“RGGI”) offset projects may not be government ordered
projects, may not receive incentives from RGGI auction pro-
ceeds, and must meet certain requirements to qualify.36
Recent discussions of the WCI indicate that it will attempt
to set a standardized baseline for offset protocols that reflect
the strictest regulatory and legal requirements.37 The Climate
Action Reserve uses standardized performance based tests for
additionality because they are administratively easier to imple-
ment and less subjective.38
For the level of scalability required to address global cli-
mate change, there needs to be a near-full transition to sectoral
or performance benchmarks for additionality. To this end, one
of the decisions made at the sixteenth session of the Conference
of the Parties of the United Nations Framework Convention on
Climate Change in Cancun, Mexico, was for the Clean Devel-
opment Mechanism to work towards standardized baselines and
additionality tests.39 Similarly, the Verified Carbon Standard
has convened a steering committee, which is developing “VCS
requirements and guidance on performance benchmark and
technology test approaches to baselines/additionality.”40
CONCLUSION
Carbon reduction credits, also known as carbon offsets, are
an effective cost-containment mechanism and have the potential
to produce greenhouse gas reductions alongside a host of co-
benefits (e.g. local jobs, technology transfer, reforesting critical
wildlife habitat). However, the general public, regulators, and
environmentalists do not want to hear, “well we were already
doing the project and we are doing nothing different, but now
WINTER 2011 18
we are getting revenue from the carbon markets.” To ensure
overall reductions in greenhouse gas emissions, additionality is
a useful technical tool to ensure the integrity of carbon reduction
projects, but certification standards should be less concerned
about financial additionality and more focused on transitioning
to sectoral or performance approaches.
Endnotes: Carbon Reduction Projects and the Concept of Additionality
1
See WORLD BUS. COUNCIL FOR SUSTAINABLE DEV., CDM PROJECT DEVELOPERS
WORKSHOP 6 (2005), http://www.wbcsd.org/DocRoot/oMH7wF8hI2xp8Upd-
jTQY/additionality.pdf.
2
See Standards and Methodologies, AM. CARBON REGISTRY (last visited Jan.
25, 2011) http://www.americancarbonregistry.org/carbon-accounting.
3
See CTR. FOR RES. SOLUTIONS, http://www.resource-solutions.org (last visited
Feb. 27, 2011).
4
See Climate Standards and Governing Documents, GREEN-E, http://www.
green-e.org/getcert_ghg_standard.shtml (last visited Jan. 25, 2011). CRS also
operates the Green-e Energy program to certify Renewable Energy Certificates
(“RECs”), which are in a different environmental asset class than carbon reduc-
tion credits. There are different mechanisms—such as technology type and
project start date—to determine eligibility of REC projects.
5
CCX Offsets Program, THE CHICAGO CLIMATE EXCHANGE, http://theccx.com/
content.jsf?id=23 (last visited Jan. 25, 2011).
6
CDM Methodologies, UNITED NATIONS FRAMEWORK CONVENTION ON CLIMATE
CHANGE, http://cdm.unfccc.int/methodologies/index.html (last visited Jan. 25, 2011).
7 Protocols, CLIMATE ACTION RESERVE, http://www.climateactionreserve.org/
how/protocols/ (last visited Jan. 25, 2011).
8 The CCB Standards, CLIMATE, COMMUNITY & BIODIVERSITY ALLIANCE, http://
climate-standards.org/standards/index.html (last visited Jan. 25, 2011).
9 Gold Standard Version 2.1, GOLD STANDARD, http://www.cdmgoldstandard.
org/Current-GS-Rules.102.0.html (last visited Jan. 30, 2011).
10 Offset Requirements, REGIONAL GREENHOUSE GAS INITIATIVE, http://rggi.org/
market/offsets/offset_requirements (last visited Jan. 25, 2011).
11 Methodologies, VERIFIED CARBON STANDARD, http://www.v-c-s.org/
methodologies.html (last visited Jan. 25, 2011).
12 For example, the American Carbon Registry’s standard asks the following
question: “Regulatory Surplus: Is there an existing law, regulation, statute, legal
ruling, or other regulatory framework in effect now or as of the project start
date that mandates the project or effectively requires the GHG emissions reduc-
tions? Yes = Fail; No = Pass.” AM. CARBON REGISTRY, AM. CARBON REGISTRY
2.1, at 23 (2010), http://www.americancarbonregistry.org/carbon-accounting/
ACR%20Standard%20v2.1%20Oct%202010.pdf. Similarly, the Verified Car-
bon Standard states: “Test 1–The Project Test: Step 1: Regulatory Surplus: The
project shall not be mandated by any enforced law, statute or other regulatory
framework.” VCS ASSOCIATION, VOLUNTARY CARBON STANDARD 2007.1, at 16
(2008), http://www.v-c-s.org/docs/Voluntary%20Carbon%20Standard%20
2007_1.pdf. The full name of the VCS changed from Voluntary Carbon Stan-
dard to Verified Carbon Standard in 2011; therefore reports cited include the
former designation while websites include the latter.
13
CLIMATE ACTION RESERVE, LANDFILL PROJECT PROTOCOL VERSION 3.0, at 9
(2009), http://www.climateactionreserve.org/wp-content/uploads/2011/01/
Landfill_Project_Protocol_V3.0_010411_Package1.pdf. “These regulations include:
 
40 CFR 60 subpart WWW – Targets landfills that commenced construction
or made modifications after May 1991
           
subpart Cc. – Targets existing landfills that commenced construction
before May 30, 1991, but accepted waste after November 8, 1987
    
codified in 40 CFR 63 subpart AAAA – Regulates new and existing landfills.”
14 Montreal Protocol on Substances that Deplete the Ozone Layer, Sept. 16,
1987, 1522 U.N.T.S. 3, 1 as amended at London 1990, Copenhagen 1992,
Vienna 1995, Montreal 1997, Beijing 1999 (2000), http://www.unep.org/ozone/
pdfs/montreal-protocol2000.pdf.
15
See India’s Growing Carbon Offset Market, REUTERS, June 22, 2010, http://
in.reuters.com/article/2010/06/22/idINIndia-49524120100622?feedType=RSSf
eedName=topNewsutmsource=feedburnerutmmedium=feedutmcampaign=Fee
d3Areuters2FINtopNews28News2FIN2FTopNews29; see also Issuance Certi-
fied Emission Reductions (CERs), UNITED NATIONS FRAMEWORK CONVENTION ON
CLIMATE CHANGE, http://cdm.unfccc.int/Issuance/cers_iss.html (last visited Feb.
27, 2011) (listing all credits issued under CDM).
16
Press Release, Europa, Emissions Trading: Commission Welcomes Vote to
Ban Certain Industrial Gas Credits (Jan. 21, 2011), http://europa.eu/rapid/press-
ReleasesAction.do?reference=IP/11/56.
17
Lee Alston & Bernardo Mueller, Legal Reserve Requirements in Brazilian
Forests: Path Dependent Evolution of De Facto Legis., 8 REVISTA ECONOMIA 25,
26 (Dec. 2007), http://www.anpec.org.br/revista/vol8/vol8n4p25_53.pdf.
18
See generally Rhett Butler, Deforestation in the Amazon, MONGABAY, http://
www.mongabay.com/brazil.html (last visited Jan. 25, 2011).
19
See, e.g., The Kasigau Corridor REDD Project – Phase I Rukinga Sanc-
tuary, VERIFIED CARBON STANDARD, https://vcsprojectdatabase1.apx.com/
mymodule/ProjectDoc/EditProjectDoc.asp?id1=562 (last visited Feb. 25, 2011)
(providing details of a project in Kenya); Gold Standard CDM/JI Projects,
THE GOLD STANDARD, https://gs1.apx.com/myModule/rpt/myrpt.asp?r=113 (last
visited Feb. 25, 2011) (listing projects in Venezuela, Philippines, Nicaragua,
Kenya, and Ethiopia); CCB Projects, THE CLIMATE, COMMUNITY & BIODIVERSITY
ALLIANCE, http://www.climate-standards.org/projects/index.html (last visited
Feb. 25, 2011) (listing projects in Kenya, Nicaragua, Philippines, and Ethiopia).
20
TRANSPARENCY INTL, GLOBAL CORRUPTION REPORT 176, 184, 227, 243, 290
(2009), http://www.transparency.org/content/download/46187/739801.
21
See Map of WCI Partners and Observers, W. CLIMATE INITIATIVE (2010),
http://www.westernclimateinitiative.org/wci-partners-and-observers-map.
22
AM. CARBON REGISTRY, supra note 12, at 23.
23
VCS ASSOCIATION, supra note 12, at 16.
24
See Chicago Climate Exchange, THE CLIMATE INST., http://climate.org/cli-
matelab/Chicago_Climate_Exchange (last visited Jan. 25, 2011).
25 Jeff Goodell, Capital Pollution Solution?, N.Y. TIMES, July 30, 2006,
http://www.nytimes.com/2006/07/30/magazine/30carbon.
html?pagewanted=3&_r=1.
26
See CLIMATE ACTION RESERVE, CLIMATE ACTION RESERVE PROGRAM MAN-
UAL 9 (Mar. 16, 2010), http://www.climateactionreserve.org/wp-content/
uploads/2009/04/Climate_Action_Reserve_Program_Manual_031610.pdf.
27
Interview with Derek Six, Portfolio Manager, Environmental Credit Corp
(Dec. 8, 2010).
28
Id.
29
Id.
30
See CDM-EXECUTIVE BOARD, UNITED NATIONS FRAMEWORK CONVENTION ON
CLIMATE CHANGE, TOOL FOR THE DEMONSTRATION AND ASSESSMENT OF ADDITIONAL-
ITY 5 (2008), http://cdm.unfccc.int/methodologies/PAmethodologies/tools/am-
tool-01-v5.2.pdf.
31
VCS ASSOCIATION, supra note 12, at 16.
32
AM. CARBON REGISTRY, supra, note 12, at 23.
33
See CTR. FOR RESOURCE SOLUTIONS, GREEN-E CLIMATE PROTOCOL FOR RENEW-
ABLE ENERGY 6 (2010), http://www.green-e.org/docs/climate/Green-eClimate-
ProtocolforRenewableEnergy.pdf.
34
Clean Development Mechanism, UNITED NATIONS FRAMEWORK CONVENTION
ON CLIMATE CHANGE, http://unfccc.int/kyoto_protocol/mechanisms/clean_devel-
opment_mechanism/items/2718.php (last visited Jan. 25, 2011).
35 To access the individual Project Design Documents (“PDDs”) and see
specifically how project-by-project additionality is applied, see Project
Cycle Search, CLEAN DEVELOPMENT MECHANISM, http://cdm.unfccc.int/
Projects/projsearch.html (last visited Feb. 25, 2011); Public Reports Access,
VERIFIED CARBON STANDARD, http://www.vcsprojectdatabase.org/resources/
AccessReports.asp (last visited Feb. 25, 2011).
36 Offset Requirements, REGIONAL GREENHOUSE GAS INITIATIVE, http://rggi.org/
market/offsets/offset_requirements (last visited Jan. 15, 2011).
37 See W. CLIMATE INITIATIVE, OFFSETS SYSTEM ESSENTIAL ELEMENTS FINAL REC-
OMMENDATIONS PAPER 4 (2010), http://www.westernclimateinitiative.org/compo-
nent/remository/func-startdown/277/.
38 CLIMATE ACTION RESERVE, supra note 26, at 7.
39
See generally Report of the 58th Meeting of the CDM Executive Board Released,
IISD LINKAGES (Nov. 26, 2010), http://www.iisd.ca/recent/recentmeetings.aspx?id=5.
40
New Requirements and Rules Being Developed by the VCSA, VERIFIED CAR-
BON STANDARD, http://v-c-s.org/methodologies.html (last visited Jan. 15, 2011).