Comments on Proposed Regulation – Offset Credits, Compliance Offset Verification and Offset Protocols

The document argues that the expansive use of offset credits under AB 32 risks undermining the cap-and-trade system by allowing companies to avoid actual emissions reductions. The authors propose reducing the percentage of total emissions that can be met through offsets to no more than 2.5% per compliance period and implementing stricter protocol requirements to prevent 'business-as-usual' activities from being credited. They also recommend enhanced verification oversight, including performance reviews of verification bodies and measures to prevent double counting of credits across different programs.

• The document recommends that offset protocols only be adopted or remain valid if there is high confidence that credits will not exceed actual reductions, if projects are unlikely to be pursued without the credits, and if 'business-as-usual' reductions are counter-balanced by conservative calculation methods.
• The authors suggest strengthening verification oversight by requiring CARB to formally coordinate with other carbon crediting regimes to prevent double counting and by instituting regular performance reviews of verification bodies.

APA

Union of Concerned Scientists (2011). Comments on Proposed Regulation – Offset Credits, Compliance Offset Verification and Offset Protocols. https://www.ucs.org/sites/default/files/attach/2018/02/AB-32-Compliance-Offsets-comments-group-sign%255B1%255D.pdf

Chicago

Union of Concerned Scientists. Comments on Proposed Regulation – Offset Credits, Compliance Offset Verification and Offset Protocols. 2011. https://www.ucs.org/sites/default/files/attach/2018/02/AB-32-Compliance-Offsets-comments-group-sign%255B1%255D.pdf.

Wikipedia

{{cite press release |author=Union of Concerned Scientists |title=Comments on Proposed Regulation – Offset Credits, Compliance Offset Verification and Offset Protocols |date=11 November 2011 |url=https://www.ucs.org/sites/default/files/attach/2018/02/AB-32-Compliance-Offsets-comments-group-sign%255B1%255D.pdf |access-date=23 October 2026 |via=Climate Insights Directory}}

BibTeX

@misc{unionofconcernedscientists2011comments, author = {{Union of Concerned Scientists}}, title = {{Comments on Proposed Regulation – Offset Credits, Compliance Offset Verification and Offset Protocols}}, publisher = {Union of Concerned Scientists}, year = {2011}, month = nov, url = {https://www.ucs.org/sites/default/files/attach/2018/02/AB-32-Compliance-Offsets-comments-group-sign%255B1%255D.pdf}, urldate = {2026-10-23}, note = {Indexed by Climate Insights Directory} }