Carbon Market Watch reply to the TSVCM’s second public consultation

Carbon Market Watch critiques the TSVCM's objective of scaling the voluntary carbon market (VCM), arguing that growth should not be the primary goal and that financial speculation through secondary markets and futures contracts does not benefit the climate. The organization emphasizes the need for a truly independent governance body, free from industry associations and conflicts of interest, and calls for more rigorous Core Carbon Principles (CCPs). Key recommendations include excluding ex-ante and retroactive crediting, requiring a minimum permanence timeframe of at least 100 years, and ensuring that credits used for offsetting include corresponding adjustments to national reporting to avoid double claiming.

• The TSVCM's objective of scaling the voluntary carbon market (VCM) is questioned, as the market should serve as a tool to channel finance to mitigation projects lacking commercial appeal rather than growing for its own sake.
• Financial products such as carbon index funds and financially-settled Futures contracts are criticized for potentially creating price volatility and failing to channel money to project developers, thereby providing no clear benefit to the climate.
• The proposed governance body must be strictly independent to be credible; Carbon Market Watch argues that industry associations like IETA and ICROA should be excluded and that funding should not be linked to market activity via user fees to avoid incentives to over-recognize compliant credits.
• The TSVCM's approach to quality assessment via 'methodology types' is deemed insufficient due to heterogeneity between projects; the organization recommends regular spot checks of individual projects and the removal of self-assessment by standards.
• To ensure environmental integrity, the document supports the exclusion of both ex-ante and retroactive crediting, the latter of which can lead to the issuance of non-additional credits.
• The organization advocates for a minimum permanence timeframe of at least 100 years, arguing that shorter periods (such as 10, 30, or 40 years) do not provide a material impact relative to Paris Agreement temperature goals.
• The document asserts that for credits used to neutralize actual emissions, the application of a corresponding adjustment to national reporting is critical to prevent double claiming.

APA

Carbon Market Watch (2021). Carbon Market Watch reply to the TSVCM’s second public consultation. https://carbonmarketwatch.org/wp-content/uploads/2021/06/Carbon-Market-Watch-response-to-2nd-TSVCM-consultation-1.pdf

Chicago

Carbon Market Watch. Carbon Market Watch reply to the TSVCM’s second public consultation. 2021. https://carbonmarketwatch.org/wp-content/uploads/2021/06/Carbon-Market-Watch-response-to-2nd-TSVCM-consultation-1.pdf.

Wikipedia

{{cite press release |author=Carbon Market Watch |title=Carbon Market Watch reply to the TSVCM’s second public consultation |date=June 2021 |url=https://carbonmarketwatch.org/wp-content/uploads/2021/06/Carbon-Market-Watch-response-to-2nd-TSVCM-consultation-1.pdf |access-date=23 October 2026 |via=Climate Insights Directory}}

BibTeX

@misc{carbonmarketwatch2021carbon, author = {{Carbon Market Watch}}, title = {{Carbon Market Watch reply to the TSVCM’s second public consultation}}, publisher = {Carbon Market Watch}, year = {2021}, month = jun, url = {https://carbonmarketwatch.org/wp-content/uploads/2021/06/Carbon-Market-Watch-response-to-2nd-TSVCM-consultation-1.pdf}, urldate = {2026-10-23}, note = {Indexed by Climate Insights Directory} }