As Verra’s revolutionary REDD methodology is set to become fully operational with the release of the first batch of jurisdictional baseline data, long-standing critics of the voluntary carbon market (VCM) are once again amplifying their objections.
At Verra, we welcome constructive criticism and encourage different perspectives, which is essential for the VCM’s ongoing improvement.
But criticism must be grounded in scientific evidence and real-world facts, rather than relying on philosophical rhetoric.
Last week, it was reported (external) that four out of 26 members of the Integrity Council for the Voluntary Carbon Market (ICVCM) Expert Panel disagreed with the panel’s overwhelming majority decision to approve Verra’s REDD methodology as meeting the criteria of the high-integrity Core Carbon Principles (CCPs) Assessment Framework.
These four members also shared their reasoning publicly, which the ICVCM has responded to (external), confirming the correct process was followed in approving the Verra methodologies.
However, the criticisms are at times flawed and inaccurate, which has prompted us to provide this response.
There is no higher standard for approval than the ICVCM, and we would like to emphasize the overwhelming majority’s view that our methodology satisfies the most rigorous benchmarks in the industry.
We have long acknowledged that no market, including the VCM, can be perfect. As such, we are prepared to monitor the implementation of our new REDD methodology to support the highest level of integrity possible.
In the spirit of transparency and our commitment to continuous improvement, here are our responses to the four members’ criticisms of our REDD methodology.
While baseline uncertainty is an inherent challenge in any predictive model, Verra uses a rigorous science-driven approach to ensure baseline deforestation levels align with the best available data and internationally accepted practices.
The criticisms assume perfect foresight is possible, which it is not.
Baselines are recalibrated every 4–6 years to integrate updated data, reducing the risk of long-term overestimation or underestimation. As the critics also state: “We note that this effect may be mitigated over time because the baseline is updated every five to six years.”
Verra employs a jurisdictional-level baseline approach in its new REDD methodology, mitigating the over-crediting risks posed by project-level anomalies.
The assertion of “selection bias” assumes project developers possess significantly better deforestation risk data than Verra’s jurisdictional assessments, which is unlikely given Verra’s rigorous data modeling.
Jurisdictional approaches inherently account for large-scale trends, reducing the potential for project-level manipulation.
Selection bias is mitigated under the REDD methodology, where potential over-crediting in one area cancels out under-crediting elsewhere.
Regular reviews and updates ensure baselines remain consistent with observed trends and new data. In addition, Verra and ICVCM will be assuring there is close oversight of these risks to prevent any systematic bias.
This assertion of declining trends also assumes that deforestation may decline on its own or that reductions in deforestation may continue over time without further incentives. Both of these are incorrect and unsubstantiated claims. Even in places with large reductions in deforestation, such as Brazil, large swings in deforestation rates based on political factors have been observed. The reality is that the vast majority of places where deforestation is decreasing are places where REDD programs, and related incentives and efforts (such as payment for performance and the implementation of regulation, with the intent of generating carbon credits) are already underway. Where these are undermined, deforestation rates often rise again. Rather than suggesting that these reflect inflated baselines, then, instead it demonstrates both the power and need for this form of climate finance.
Leakage monitoring at a jurisdictional level is robust, capturing activity-shifting deforestation leakage through direct observation in surrounding areas.
International leakage cannot be practically addressed at the project level and is outside the mandate of voluntary markets, where projects operate within national boundaries.
Enhanced scrutiny of leakage monitoring in auditing processes also ensures accurate reporting.
In addition, Verra will be adding new modules for market leakage accounting, when new activities that are more likely to drive market leakage are added (i.e., planned deforestation activities that may displace larger-scale commercial plantations).
By their nature, additionality assessments inherently require counterfactual analysis, which involves a degree of uncertainty but is the best available method for establishing causality.
The methodologies already require robust evidence linking reductions to project activities.
Our new methodology introduces stricter provisions for project implementation plans and carbon credit revenue dependency to address specific additionality concerns.
Updates in future versions of the Verified Carbon Standard (VCS) Program will further refine timelines for documentation and validation to ensure stricter adherence.
While the criticism here is not directed at the Verra methodology specifically, we feel it’s worth pointing out that pooled buffer reserves are an industry-standard approach and are proportional to assessed risks.
The criticism assumes reversals at a scale that has not been substantiated by existing trends.
From Verra’s perspective, we believe that enhanced monitoring and reassessment protocols ensure reserves are sufficient to address reversals. Buffer contributions are also reassessed periodically to reflect updated risk profiles.
Related Resources
Earlier this year, Verra responded in detail about similar claims. Find our full statement at the link below.
