Policy

Public Consultation: Voluntary Carbon Market Integrity Initiative’s Claims Code of Practice

by
Ben Rattenbury
August 16, 2022
Sylvera’s response to the Voluntary Carbon Market Integrity Initiative’s Claims Code of Practice public consultation
Sylvera’s response to the Voluntary Carbon Market Integrity Initiative’s Claims Code of Practice public consultation

Does your organization have a climate target? 

We are in the process of setting an SBTi net zero target.

What does your organization do with carbon credits? (e.g., purchase for your own use, develop projects, sell/broker, MRV, consult, regulate, other)

We rate carbon crediting projects. We also use credits for our own BVCM.

General (7 Questions)

To what extent do you agree with the statements below? (Please score from 1 to 5 stars,  with 5 being totally agree and 1 being totally disagree).

1. The Claims Code is readily understandable.

Score: 5

2. The Claims Code provides sufficient information to use and apply.

Score: 5

3. The Claims Code provides aspirational goals and incentives for companies that are on the journey to becoming climate leaders.

Score: 3

4. Use of the Claims Code would provide confidence to consumers, investors, and broader stakeholders that a company making the claim is a responsible climate actor.

Score: 4

5. The Claims Code would influence my/my organisation’s decision-making with regards to purchasing decisions, climate strategy and action.

Score: 3

6. The Claims Code should be incorporated into relevant regulation e.g. corporate disclosures, advertising, consumer protection, etc.

Score: 5

7. The Claims Code should be tailored for a) SMEs, b) hard to abate sectors, c) companies in least developed countries. If you agree, what are the most important considerations in tailoring for each audience.

Score: 4

Step 1: Prerequisites (7 Questions)

To what extent do you agree with the statements below?(Please score from 1 to 5 stars, with 5 being totally agree and 1 being totally disagree).

1. The prerequisites are clear, comprehensive, and represent a reasonable expectation of good corporate climate practice.

Score: 5

6. There should be a step before meeting the Claims Code prerequisites (an “on ramp”) to encourage companies who do not yet meet the prerequisites to begin the VCMI journey.

Score: 4

7. Further guidance is required to substantiate that a company’s policy engagement is aligned with its Net Zero commitment.

Score: 5

Prerequisites Section General Comments. Please provide any additional comments on the questions above.

‘Compliance with all the prerequisites must be confirmed by a credible, independent third party.’ There should be more details about this process and the definition of a ‘credible, independent third party’, with examples.

In general, a science-based approach is encouraged and the SBTi has outlined ambitious and effective pathways for a number of sectors. However, some sectors still do not have appropriate pathways available to them, including some high emitting but hard-to-abate sectors which should be a priority for encouraging emissions reductions. Similarly, start-ups and fast growing SMEs do not have appropriate pathways available that adequately consider the effect of growth from the base year. 

Step 2: Claims (10 Questions)

To what extent do you agree with the statements below?(Please score from 1 to 5 stars, with 5 being totally agree and 1 being totally disagree).

1. The schedule of claims respects the accepted mitigation hierarchy.

Score: 5

2. Thresholds for use of carbon credits in VCMI Gold, Silver and Bronze are appropriate.

Score: 4

4. Further criteria are needed to ensure companies increase the share of unabated emissions that they cover with carbon credits in VCMI Silver and Bronze claims.

Score: 5 

5. Further criteria are needed to ensure companies make significant improvements on Scope 3 interim reduction targets through time in the VCMI Bronze claim.

Score: 3

6. Additional factors should be taken into account when assessing whether a company is “on track” to meet its interim targets.

7. The claims schedule is not sufficiently accessible for (i) SMEs and (ii) different sectors and should be tailored.

Score: 5

8. Carbon credits underpinning VCMI contribution claims should not need to be associated with corresponding adjustments.

Score: 3

Claims Section Comments

Please provide any additional comments on the questions above.

The trajectory of required compensation with carbon credits should be outlined. Organisations should disclose not only their strategy to reduce emissions in line with their SBT, but also include projected numbers and costs of credits in their forecasting. 

Organisations should not be awarded VCMI Bronze without disclosing a strategy to reduce scope 3 emissions to reach their net zero trajectory by 2030. 

We agree that it is too early to make a definitive decision on the use of corresponding adjustments. However, present uncertainty on the use of corresponding adjustments for voluntary credits is resulting in significant uncertainty in the market and in issuing countries. Although it is right for VCMI to consider the issue carefully, it should also prioritise clarity in the rules, at least in the short term e.g. for claims in 2022 and 2023. 

Step 3: Credits (2 Questions)

To what extent do you agree with the statements below?(Please score from 1 to 5 stars, with 5 being totally agree and 1 being totally disagree).

1. The criteria for high quality carbon credits are clear and comprehensive.

Score: 3

2. There are gaps and/or alternative information sources and tools to draw on which should be included in the criteria.

Score: 5

Credits Section Comments

Please provide any additional comments on the questions above.

The outcomes of the IC-VCM are still not certain and will have some shortcomings: the CCP accreditation will likely reflect a quality floor and assess credits at a methodology-level rather than consider the risks of individual projects. Likewise CORSIA has been criticised for these challenges.

Credit buyers should be encouraged to do their own due diligence against more rigorous guidelines, for example on additionality and permanence. The VCMI should highlight third party organisations that are able to support credit buyers with this. Crucially, credit buyers should disclose this due diligence alongside their other disclosures. 

Step 4: Transparency and Reporting (4 Questions)

Transparency and Reporting Comments

Reporting and disclosures requirements should also specify how information should be disclosed, for example that information should be disclosed in a coherent order and format, rather than scattered throughout different reports.

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