The Institute for Agriculture and Trade Policy, Land Stewardship Project, Missouri Rural Crisis Center, Iowa Citizens for Community Improvement, Food and Water Watch and the National Family Farm Coalition welcome the opportunity to respond to the USDA’s request for information for a proposed Greenhouse Gas Technical Assistance Provider and Third-Party Verifier Program.

When the Growing Climate Solutions Act was debated in Congress, our organizations opposed its passage and signed onto a letter with over 220 groups in opposition.¹ We believe voluntary carbon markets are fundamentally inconsistent with the latest climate science. For example, the Intergovernmental Panel on Climate Change (IPCC) concluded in its Sixth Assessment report that fossil fuel emissions are not offset by land-based emissions sequestration on a one-to-one ratio.² Indeed, peer-reviewed climate science modelers report an accelerating asymmetry between fossil fuel emissions and sequestration efficacy.³ Additionally, carbon-related offsets, such as temporary sequestration, are not consistent with non-CO2 emissions (methane and nitrous oxide) with different timescales and intensity. As a result of these climate science findings, USDA must disapprove of any protocol or technical assistance provider that states or implies in its contractual or marketing language that soil carbon sequestration projects “offset” or “manage” fossil fuel derived greenhouse gas emissions.

Unregulated voluntary markets also pose legal and economic risks to farmers that we discuss in this comment. Additionally, voluntary carbon markets have experienced widespread fraud for more than a decade, with no signs of abatement. A protocol or third-party certifier should not be eligible for listing while it is in litigation with either carbon credit buyers, intermediaries or primary producers of the carbon credits.

As USDA develops its proposed program, we urge the Department to hold protocols and certifiers to a high, rigorous standard that prevents proliferation of the many weaknesses present in voluntary carbon markets. As a governmental institution, the USDA has a responsibility to ensure farmers’ rights and interests are protected and that these markets are not deceptive or misleading in claiming to benefit the climate. Listing protocols or third-party certifiers within the USDA program effectively signals an endorsement. The USDA should set a high bar to protect its credibility with farmers and the public, including the possibility that no protocols or verifiers currently meet a high standard for listing.

Setting a high bar is critical because of warning signs about the financial viability of voluntary markets. The Ecosystem Marketplace reported last month that the transaction value of the voluntary market for carbon offsets dropped 61% from 2022 to the end of 2023.⁴ They attributed the market plunge to recent scientific research and investigations indicating that many offset projects fail to reduce emissions and some are linked to human rights violations around the world. The sharp drop in the market reminds many of the full-scale collapse of the voluntary carbon credit market tied to the Chicago Climate Exchange in 2010.⁵

The corporate retreat from voluntary carbon markets is tied to the rising need to reduce (not offset) emissions to avert the climate crisis. There is now substantial evidence that carbon offset projects provide little climate benefit⁶ and that offsets are incompatible with meeting the goals of the Paris Climate Agreement.⁷ The recommendations from the UN High Level Expert Group on corporate net zero commitments concluded that carbon credits should not be counted to meet interim reduction targets.⁸ The “technology-neutral” IPCC in its last Synthesis Report (2023) did not support or even mention offsetting as a viable option.⁹

To continue reading the comment, please download a PDF.