Commission Guidance Regarding the Listing of Voluntary Carbon Credit Derivative Contracts, RIN 3038–AF40 (88 Fed. Reg. 89410)

CATF supports the CFTC's oversight of voluntary carbon markets but argues that current crediting protocols are insufficient to prevent market manipulation and over-crediting. The organization recommends adding 'durability' and 'vintage' as essential commodity characteristics and requiring project-level transparency rather than relying on general protocol disclosures. CATF further urges the Commission to strengthen criteria for additionality, quantification (specifically leakage avoidance and business-as-usual baselines), and the mitigation of reversal risks, particularly for nature-based projects. Finally, it emphasizes the need for independent third-party verification to avoid conflicts of interest between project developers and verifiers.

• CATF recommends that the CFTC add 'durability' and 'vintage' as additional commodity characteristics for VCC derivative contracts. Durability refers to the number of years carbon is stored, with a minimum industry standard of 20 years, while vintage refers to the year a credit was generated or issued.
• The document argues that transparency must be required at the individual project or activity level because existing crediting protocols are too flexible, which can lead to over-crediting and obscured credit quality.
• CATF supports defining additionality as projects that would not have been developed without the monetary incentive from carbon credits, and suggests that baseline assumptions be reassessed every 1 to 5 years.
• For nature-based projects, CATF warns that the risk of reversal from natural disturbances is often underestimated and that buffer pools must be sufficient to cover risks that are expected to increase due to climate change.
• The organization recommends that the CFTC require specific provisions for quantification, including leakage avoidance and a robust comparison to a business-as-usual baseline to ensure credits represent real removals.

APA

Clean Air Task Force (2024). Commission Guidance Regarding the Listing of Voluntary Carbon Credit Derivative Contracts, RIN 3038–AF40 (88 Fed. Reg. 89410). https://cdn.catf.us/wp-content/uploads/2024/02/28153613/cftc-voluntary-carbon-credits-comments.pdf

Chicago

Clean Air Task Force. Commission Guidance Regarding the Listing of Voluntary Carbon Credit Derivative Contracts, RIN 3038–AF40 (88 Fed. Reg. 89410). 2024. https://cdn.catf.us/wp-content/uploads/2024/02/28153613/cftc-voluntary-carbon-credits-comments.pdf.

Wikipedia

{{cite press release |author=Clean Air Task Force |title=Commission Guidance Regarding the Listing of Voluntary Carbon Credit Derivative Contracts, RIN 3038–AF40 (88 Fed. Reg. 89410) |date=16 February 2024 |url=https://cdn.catf.us/wp-content/uploads/2024/02/28153613/cftc-voluntary-carbon-credits-comments.pdf |access-date=23 October 2026 |via=Climate Insights Directory}}

BibTeX

@misc{cleanairtaskforce2024commission, author = {{Clean Air Task Force}}, title = {{Commission Guidance Regarding the Listing of Voluntary Carbon Credit Derivative Contracts, RIN 3038–AF40 (88 Fed. Reg. 89410)}}, publisher = {Clean Air Task Force}, year = {2024}, month = feb, url = {https://cdn.catf.us/wp-content/uploads/2024/02/28153613/cftc-voluntary-carbon-credits-comments.pdf}, urldate = {2026-10-23}, note = {Indexed by Climate Insights Directory} }