Summary of Interviews Conducted During the Inception Phase - vcmintegrity.org
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Contents I. Key Themes Emerging From Civil ABOUT VCMI The Voluntary Carbon Markets Integrity Initiative (VCMI) Society Organization Interviews is a multistakeholder platform to drive credible, net zero aligned Pg 5 participation in voluntary carbon markets (VCMs). VCMI’s goal is to ensure VCMs make a significant and meaningful contribution to climate action and limit global temperature from rising to 1.5˚C above pre-industrial levels, while also supporting II. Key Themes Emerging From the achievement of the UN Sustainable Development Corporate Interviews Goals (SDGs). Pg 11 Through consultation with stakeholders from civil society, the private sector, Indigenous Peoples, local communities, and governments, VCMI intends to develop and communicate III. ey Themes Emerging From K guidance on how carbon credits can be voluntarily used and claimed by businesses and others as part of credible, net Indigenous Peoples Interviews zero decarbonization strategies. It also engages countries to Pg 17 support development of strategies to access VCMs to drive ambitious climate mitigation. The UK Government is supporting VCMI, as announced by IV. Forest Solutions Dialogue: COP26 President-Designate Alok Sharma at the Climate and Environmental Integrity in VCMs Development Ministerial on 31 March 2021. To date, VCMI has been led by Meridian Institute, a US-based not-for-profit - Forest Country Perspectives organization, and supported by consultants (hereafter referred to as the VCMI Consortium). Pg 21 The VCMI Consortium’s role is to refine the scope, governance and processes that will underpin VCMI in its future phases. The Initiative is co-funded by the Children’s Investment Fund Foundation (CIFF) and the UK Department for Business, Energy and Industrial Strategy (BEIS). ABOUT THIS PAPER This Working Paper provides a preliminary The approach that was used to generate summary of the prominent themes that these preliminary results employs inductive emerged in over 50 interviews with nearly and inference-based methods rather than a 200 stakeholders. This summary focuses more rigorous qualitative data analysis (QDA) on three main categories of stakeholders methodology. This inference-based analysis including civil society organizations (CSOs) was conducted in over 50 semi-structured and CSO-led initiatives, companies from interviews. Semi-structured interviews a wide variety of sectors, and Indigenous were chosen to allow for a conversational Peoples. The Consortium Team is still approach to best capture the nuance of conducting interviews and will continue to views regarding voluntary carbon markets incorporate interview findings in the future, (VCMs) and to allow the interviewees to ask including a wider representation of the views questions of the interviewers regarding the of Indigenous Peoples and Local Communities purpose and intentions of VCMI. Interviews and CSOs from developing countries. were transcribed and coded by major themes using Atlas.ti software.i The major themes that Image: Dylan Gillis, Unsplash have emerged thus far are represented in the narrative below. 2 VCMI — Voluntary Carbon Markets Integrity Initiative i) https://atlasti.com/ Summary of the Interviews Conducted During the Inception Phase Working Paper 3
I. Key Themes Emerging From Civil Society Organization Interviews Image: Atul Loke for Panos Pictures/Food and Land Use Coalition 4 5
ROLE OF VCMS IN CONTRIBUTING GOVERNANCE OF DEMAND-SIDE CLAIMS TO THE PARIS AGREEMENT / ROLE OF VCMI INITIATIVE TEMPERATURE GOALS Across the board, CSOs described a strong In general, views expressed within CSO need for greater clarity and more clearly interviews on the role of voluntary carbon defined parameters for the voluntary carbon markets were mixed. Some CSO actors market, including clear guidance on claims to highlighted that voluntary markets could address the confusion that currently exists play a significant a role in closing the among VCM actors. Several respondents emissions reduction gap left by the Nationally underscored the importance of there being determined contributions (NDCs), channeling a credible authority to govern the market, as private finance to help countries increase integrity will be key for its functioning. their targets, and driving the development Image: Unsplash, Roberto Motoi It was suggested that VCMI could serve of new technologies. One CSO even stated as a platform in which the existing work of that the voluntary carbon market could bring various organizations and initiatives could us beyond the 1.5˚C goal in the mid-century be aggregated and amplified. Some CSO time period. Others were enthusiastic but representatives also pointed to the potential cautious, including several who expressed role that VCMI can play as a networking “A relative minority of CSO varying degrees of skepticism about the role platform, wherein representatives of representatives (as compared of voluntary carbon markets. countries/governments (from the global A subset of those who expressed doubts south in particular) can be in the same room to company representatives as around the role of the VCM suggested with companies that are both buyers and summarized below) acknowledged land as a scarce resource should be left it is much too small to be impactful in its sellers to gain insights into what types of to market forces. In order to guard against current manifestation. They cautioned that policy developments will help attract private there is a lack of consensus on what companies relying too much on offsets, some it could distract from the importance of sector finance. constitutes either a science-based or suggested there should be requirements mandatory requirements imposed by laws for companies to focus first on reducing and regulations, which was considered the even generally agreed upon net zero their own emissions before they can access RECOMMENDATIONS ON HOW TO BUILD primary means by which significant emission CONSENSUS ON SCALING VCMS decarbonization pathway for hard-to- the carbon market, regardless of intended reductions will be achieved, along with the uses of the carbon credits purchased and/ need to increase public finance to a much abate sectors.” or the claims companies make in association Recommendations from CSO representatives higher level than current levels. on how to grow VCMs included 1) “Jury- with those purchases. Several CSO rigging” voluntary carbon markets to representatives encouraged VCMI to look into Many CSOs expressed an interest in slowly link to the compliance markets via alternatives to offsets, with a focus on long- exploring how voluntary carbon markets OFFSETTING a “back door” to Article 6, i.e. through a term transformative solutions. can co-evolve with mandatory emission requirement for corresponding adjustments; Many CSO representatives emphasized reduction requirements to create the right A relative minority of CSO representatives 2) reintroducing the notion that offsetting that companies should rely very little, if at set of incentives to ensure VCMs make a (as compared to company representatives is allowed, while remaining cautious that all, on the use of offsets as an alternative to meaningful and significant contribution summarized below) acknowledged there is this could undermine efforts to have VCMs concerted efforts to abate their own value to meeting the climate goals of the a lack of consensus on what constitutes effectively help deliver on Paris Agreement chain emissions. Some spoke specifically Paris Agreement. either a science-based or even generally temperature goals; and 3) establishing a of physical limits to the type and scale of agreed-upon net zero decarbonization governance or guidance framework to ensure emission reduction and removal activities path way for hard-to-abate sectors. Some demand is high quality and is additional to that can be used as offsets while still being CSO representatives expressed concerns abatement practices in line with science- compatible with the Paris goals, arguing, for mirroring those voiced by some business based targets (SBTs), while acknowledging example, that land-based offsets are not a representatives-that there may not be this may reduce the demand pool. viable option due to the limited amount of sufficient incentives to encourage voluntary uninhabited land available for removals. In private investments in high integrity addition, due to the threat of land grabbing carbon credits from companies in hard-to- this causes, an ethical challenge was also abate sectors. raised regarding whether the allocation of 6 VCMI — Voluntary Carbon Markets Integrity Initiative Summary of the Interviews Conducted During the Inception Phase Working Paper 7
Despite being cautious about the role of ROLE OF VCMI offsets, one respondent argued that bringing Several recommendations were presented back the narrative that offsetting is possible regarding how VCMI could help with will be necessary for scaling the market. One coalition building to establish “collective CSO representative acknowledged that “the consciousness” around the need for high mitigation hierarchy is a principle, not the integrity VCMs and high integrity claims law”, and that while we should maintain a in particular. Recommendations included scheme that prioritizes abatement within a harmonizing global guidance with regional company’s value chain, we should also allow guidance, such as that being developed for some flexibility in its implementation. To by the Nordic Dialogue on Voluntary this point, a representative of a carbon credit Compensation, as well as country-level standard setting organization suggested guidance, such as that of the UK working offsetting could be used if a company tried group on VCMs led by Dame Clara Furst but failed to meet its targets, though this and Lord Stern of Brentford, Chair of the would require credible measures to evaluate Grantham Research Institute of Climate their efforts. They furthermore argued Change at the London School of Economics. there should be an incentive for companies The point was also raised that Taskforce on to go beyond their targets, to drive more Scaling Voluntary Markets (TSVCM), the investment, and that offsetting could play a Race to Zero, the Science Based Targets role there as well. In both cases, what types initiative (SBTi), and other key initiatives of claims are or are not appropriate were could point to VCMI as the appropriate venue noted as a key component of overcoming for generating “authoritative guidance” on this challenge. demand-side integrity. It was also noted, that in order for VCMI to be considered an TRANSITIONAL NATURE OF VCMS overarching authority on claims guidance, its status would likely need to be acknowledged Regardless of individual enthusiasm the role and supported at the UN level. VCMs can play to meet the Paris Agreement climate goals, the common view among CSOs was that this role must be transitional. For most CSOs, this meant facilitating the expansion of regulated compliance markets and using private sector innovation to drive new approaches, which will diminish VCMs in importance as compliance markets grow. Even among those who were agnostic regarding the scope of VCMs to meet Paris goals, several CSOs described a need for markets to be responsive and evolving, whether by extending the scope beyond CO2 to encompass “value for nature” and society, or ensuring that corporate strategies account for the changing forms of mitigation needed between now and mid-century. Image: Partnerships for Forests 8 Summary of the Interviews Conducted During the Inception Phase Working Paper 9
II. Key Themes Emerging From Corporate Interviews Image: The Climate Reality Project, Unsplash 10 11
Key Themes Emerging From Corporate Interviews ROLE OF VCMs The views of company representatives the middle. At the more skeptical end, there respondent who supported the latter view CARBON CREDIT STANDARDS interviewed regarding the role of VCMs were concerns raised about trade-offs with raised the concern regarding whether the There was a common feeling of ranged from implied acknowledgement that cost and difficulty for corporations that would prioritization of mitigation could result in low dissatisfaction from corporate actors on VCMs should play a constructive role in result from the regulation of claims. At the integrity reductions within value chains that carbon credit standards and standard setting helping meet the Paris Agreement climate other end, however, and more commonly, take place without third party certification agencies. The most common was a feeling goals to explicit acknowledgement that a mix of public and private regulation was taking precedence over arguably higher that they lacked consensus and coordination, VCMs can and must make a meaningful and broadly welcomed to introduce clarity for integrity offsetting. but concerns were also voiced about significant contribution to those goals. Many companies, with the hope this would lead Views on the availability of high-quality available quality and a lack of guidance for interviewees from business noted there is toward greater public credibility for claims offsets were more mixed. On the one hand, buyers. Beyond the less common view that great untapped potential to channel private related to the use of carbon credits as part there was the view that integrity of the third-party agencies lacked rigor, frustration finance into both climate change mitigation of a well-designed and well-executed climate market had improved massively since Kyoto, was raised that the processes those and broader development goals. Several mitigation strategy. and the high integrity use of offsets was a agencies follow are opaque and difficult to expressed the view that voluntary action by more significant concern than the availability penetrate for corporate sustainability teams, companies has catalytic potential to support OFFSETS AND MITIGATION HIERARCHY of high integrity carbon credits. On the other let alone non-specialists. Some suggested projects that governments are unlikely hand, some skepticism was voiced about that many firms do not have dedicated to finance. Appealing to the competitive Among corporate interviewees, views on supply-side integrity, with one interviewee sustainability research teams and therefore nature of CEOs and corporations, several the role of carbon offsets were mixed, but claiming 85% of offsets available through are unable to conduct necessary research to respondents pointed to the importance of on the whole positive. Many, cited the use the big four carbon credit standard setting determine the quality of the credits available. tracking competitor involvement in the VCM, of offsets as a crucial part of their climate agencies had “no carbon benefit associated This was exacerbated by the high cost in emphasizing that participation in VCMs mitigation strategy, regardless of their level with them at all”. terms of reputational risk in being seen as neither harms the “bottom line” nor creates of ambition. There was a common view that investing in poor quality credits. This was a an unreasonable reputational risk. skepticism towards offsets was misdirected, concern shared by many interviewees, some and that proper rigor regarding their integrity GREENWASHING Many interviewees from companies of whom felt that has been largely passed on could ensure they play a major role in acknowledged a need for a complementary There was widespread concern reported from to the buyers, rather than being owned by galvanizing the private sector. One finance relationship between VCMs and regulatory corporate interviewees over greenwashing, the credit issuing agencies. sector interviewee said offsets should be markets, with one stressing that VCMs regarding malpractice by competitors and a critical stepping stone for businesses in There was widespread support for cannot solve the climate crisis alone accusations that might be levied on their hard-to-abate sectors while they undergo standardization of carbon credit standards, and should primarily be used to support companies. In general, current or recent challenging transitions. This view was echoed with greater guidance available for buyers, governments and policy that move toward greenwashing was not seen as the result of ill by a representative from the Information more robust guardrails on quality, and better mandatory emissions reductions. intentions, but rather as ignorance and stem- Technology (IT) sector who explained that a access for corporates to communities of ming from a lack of clear guidance. Several large share of their emissions are difficult to practice and “safe spaces” for learning. respondents mentioned that the perceived REGULATION OF CLAIMS reduce, and therefore – in their view – the difficulties in selecting viable, high integrity only alternative to offsets was to do nothing. There was widespread support among the investments in carbon credits can lead to INDEPENDENT ADVICE WITH NO In the interim between now and when a corporate respondents for standardization of corporates purchasing low quality offsets, “SKIN IN THE GAME” net zero pathway is feasible, use of offsets claims, but with varying degrees of formality. despite good intentions. Others worried that would enable finance to flow towards climate There was a common frustration among The greatest enthusiasm came from financial the presence of greenwashing in any part of mitigation and sustainable development corporate interviewees at a lack of reliable actors, with more ambivalence in responses their sector would undermine consumer trust or other public goods that might not and independent advice on carbon credits from representatives of energy companies. in high integrity claims - regardless of their otherwise receive support. Other corporates and the carbon integrity of projects. They One interviewee differentiated between three validity - and underpinned the need for great- emphasized that, while there should be suggested this only compounds the anxieties levels of regulation: transparency between er clarity and standardization of claims. a role for offsets, they should never take felt by corporates at the expectation that company and consumer; industry-wide precedence over mitigation efforts within they should be experts in the extraordinarily standardization of practice and guidance; company value chains that are in line with the complex task of choosing between and formal regulation, favoring something in goals of the Paris Agreement. However, one standards, different types of credits, 12 VCMI — Voluntary Carbon Markets Integrity Initiative Summary of the Interviews Conducted During the Inception Phase Working Paper 13
and the many available types of ancillary from supply-side integrity and demand- originate as a matter of well-established in- engagement by corporations with consumers investments. On several occasions, a strong side integrity, which is data integrity. This ternational law as well as accepted account- and society in raising awareness and inciting wish was expressed for independent advice respondent made the point that, in many ing principles should not require a corre- demand for higher standards. The latter view which did not have “skin in the game” – respects, the data integrity of the reporting sponding adjustment, as that term is defined was shared by other interviewees, who see that is to say, it did not come from sources on abatement that occurs within corporate under Article 6 of the Paris Agreement. consumers as key drivers of change. who are not also sellers of carbon credits value chains is far less rigorous and reliable Some interviewees identified voluntary mar- Finally, some dissatisfaction was expressed themselves. Ideas on how this could be than the data that is used to establish kets as an opportunity for corporate invest- regarding a framing that the global goal of achieved varied. One suggestion was that the the integrity of many – although it was ments to address critical interconnected limiting global warming to 1.5°C could be coordination and governance of standards acknowledged not all – carbon credits. global issues like sustainable development reached via the sum of companies merely should take place at the UN level; another or biodiversity. In this view, the instruction for addressing their own internal emissions. was that of a platform for scientists and ROLE OF GOVERNMENTS IN “LEVELING businesses to focus on atmospheric integrity Some spoke of a need to be motivated by other experts to review and rank the integrity THE PLAYING FIELD” misses an opportunity to invest in a more shared global goals and collective effort, of projects. holistic public good. rather than individual efforts and specific While there were mixed feelings about the claims. These respondents indicated that extent to which formal regulation of the Others saw engagement beyond the supply “THE PERFECT IS THE ENEMY OF this idea resonated with certain government market was desirable in general, several chain as critical to their own mitigation THE GOOD” actors who describe global “shared corporate actors acknowledged the impor- efforts. For example, representatives from temperature goals”. An argument especially prevalent among tance of interaction between voluntary and the energy sector used the term “in step interviewees from the energy sector was that compliance markets. Among these views, with society” to describe their mitigation “the perfect” risked becoming “the enemy government regulation was seen as best pathways, suggesting their ability to of the good”. The suggestion was that a placed to rapidly raise the cost of carbon, meet targets rested on a broader societal preoccupation with quality of the credits and and pivotal to “leveling the playing field” in move towards a net zero ready world (i.e., the integrity of the claims is slowing down the terms of rules and regulations across a very tech innovations, appropriate regulatory flow of finance, diminishing the impact of the diverse corporate landscape. This would be landscape, and consumer demand). market, and prohibiting additional investment one way to ensure public accountability and One suggested this necessitates active outside of jurisdictions like the EU. One actor bridge otherwise incommensurable sectoral also said that the overly strict requirements differences. placed on companies (i.e., internal abatement) is squandering an enormous North-South INTERNAL ABATEMENT VS. finance opportunity. GLOBAL GOALS The view was often expressed that corporate TRUST AND DATA INTEGRITY commitments should not be treated as sep- Trust was frequently brought up in the arate from a larger global ecosystem. This is interviews with company representatives. a loosely defined point – encompassing both Whether public trust in corporate claims, corporate opportunities and obligations – corporate trust in the integrity of standards, which nevertheless reveals potential tensions or trust of NGOs in the potential of VCMs with the idea that corporate mitigation should and the good intentions of companies, trust focus on internal abatement. was widely described as being pivotal to A strongly held counterpoint to this holding the VCM together. view, shared by numerous corporate inter- One respondent noted there is a third viewees, was that purchases of carbon cred- Image: Anton Eprev, Unsplash critically important aspect of integrity in its by companies that are domiciled outside relation to voluntary carbon markets, aside of the host country where the carbon credits 14 VCMI — Voluntary Carbon Markets Integrity Initiative Summary of the Interviews Conducted During the Inception Phase Working Paper 15
Key Themes Emerging From Indigenous Peoples Interviewed ROLE OF VCMs Interviewees noted that voluntary carbon markets are a sensitive topic for many Indigenous Peoples and that there are different perspectives around this topic. While some Indigenous Peoples are interested in exploring what voluntary carbon markets could offer, other groups are not and are cautious around or critical of concepts such as “voluntary” and “markets”. In this sense, it is very important to identify and engage with Indigenous Peoples interested in the VCM, as the inception of these initiatives, participating in their design, and establishing links with existing initiatives are related. A commonly expressed view is that it is equally important to establish transparent processes that clearly lay out how and when Indigenous Peoples will be involved. RECOGNITION OF RIGHTS It was also highlighted that, while some national legislation has made progress in the recognition of Indigenous Peoples’ rights, in some cases the lack of implementation and enforcement against violations generate mistrust. It was suggested that new projects or initiatives should closely monitor the implementation of pilot projects to understand the rights of Indigenous Peoples and local communities in different national contexts. OTHER THEMES TO FURTHER EXPLORE Interviewees suggested focusing on the following themes: scope of the VCM (beyond forests), nature-based solutions, territorial governance, supply-side integrity, equity, geopolitical dimension, FPIC (Free, Prior and Informed Consent), Indigenous Peoples’ engagement with the government and businesses, social and environmental Image: Partnerships for Forests safeguards, human rights, land tenure rights, natural resource rights of IPLCs and Afro- descendants, and verification frameworks. 18 VCMI — Voluntary Carbon Markets Integrity Initiative 19
IV. Forest Solutions Dialogue: Environmental Integrity in VCMs - Forest Country Perspectives Image: © Stuart Clouth/Partnerships for Forests 20 21
Forest Solutions Dialogue: Environmental Integrity in VCMs - Forest Country Perspectives SUMMARY Each dialogue session opened with an (NCS) Alliance. VCMI was also initiated this 2. For country participants, meeting the NDC introductory presentation by UNDP and year to develop guidance on how voluntary targets or goals is a clear priority, but there This country dialogue focused on panel discussion with four senior technical carbon credits can be used by corporates was the perception that demand-side environmental integrity for forests in the experts on land use, forests, climate change, and other non-state actors as part of discussions and expectations (regarding voluntary carbon market (VCM) in the and carbon markets, followed by an open credible, net zero decarbonization strategies. quality of emission reductions and others) context of the Paris Agreement. The two dialogue with participants. tend not to consider NDCs when defining sessions of the Dialogue, held on 14 April At the time of hosting these sessions of the environmental integrity. This highlighted 2021 through Zoom, were hosted through the Forest Solutions Dialogue in April 2021, there the need for further dialogue between the Forest Solutions Dialogue and coordinated BACKGROUND were not yet opportunities for engagement private sector and supply countries. by the United Nations Development with a focus on the supply-side of forest Carbon markets are expected to play an Programme (UNDP) and partners of the emission reductions and removals in a carbon 3. Countries signalled their interest important role in the implementation of New York Declaration on Forests (NYDF) market context, specifically tropical forest and willingness to actively engage in the Paris Agreement to the UNFCCC. If Global Platform. “The Dialogue” is an countries. Recognizing that the high integrity discussions with potential buyers of designed and implemented in a way that initiative of Climate Advisers to provide a of forest emission reductions and removals REDD+ units. ensures high integrity, carbon markets can neutral space to share experiences, discuss has been a major focus of international mobilize significant private sector finance, 4. While countries recognize that VCM common challenges, and identify solutions negotiations on REDD+, this process was raise ambition by lowering climate change and the UNFCCC may have links, it was to accelerate action in the forest sector designed to be informed by and build upon mitigation costs, and contribute to the acknowledged that the principles and through the implementation of “cooperative that wealth of REDD+ experience. The intent achievement of the Paris Agreement goals. practices on how the VCM relates to NDCs approaches” under Article 6 of the was also to have these initial dialogues and Paris Agreement. will likely be defined outside the UNFCCC, The concept of high integrity in the related future discussions as part of this by the “court of public opinion”. carbon markets context often refers to process recognize the UNFCCC context, Two sessions were held to accommodate environmental integrity, understood as including the related issues of the NDCs, 5. There are unresolved technical matters different time zones: Session 1 included the supply of emission reductions and transparency and finance, and ensure this that warrant further discussion and country participants from Latin America, the removals being real, additional, quantifiable, is integrated as critical context for carbon clarification, such as corresponding Caribbean and Africa, and Session 2 was and verifiable, with issues of leakage market integrity discussions, without adjustments to the NDC and approaches for Asia-Pacific countries. French, Spanish, and permanence sufficiently addressed, prejudging the outcome of the Article 6 for nesting carbon projects within and Bahasa interpretation were provided. and units tracked through robust carbon negotiations. The following key messages jurisdictions. The sessions featured a discussion on accounting to avoid double counting. were considered the main “takeaways” challenges and opportunities related to the 6. There is overwhelming agreement that the However, there are broader aspects based on the expert presentations and environmental integrity of forest emission price of carbon does not reflect the true when considering high integrity voluntary contributions by country participants: reductions and removals in the context cost of forest protection, particularly in the carbon markets, including, for example, the of voluntary carbon markets. Participants long-term. Countries have mentioned the relationship between the VCM and Nationally included country-level focal points for KEY MESSAGES: lack of transparency on carbon market Determined Contributions (NDCs) under the various processes such as the United transactions and prices as a key challenge. Paris Agreement, as well as demand-side 1. After more than ten years progressing Nations Framework Convention on Climate considerations to ensure access and use through REDD+ readiness and 7. There is significant country interest in Change (UNFCCC), REDD+, and NYDF from of carbon markets are aligned with credible implementation, developing countries have tools to assess risks and opportunities countries that have submitted forest reference corporate climate change mitigation strategies. learned important lessons that can be built of engaging in carbon markets in the levels to the UNFCCC. The approach and outreach efforts facilitated the attendance of on to operationalize the high integrity of context of countries’ prior experiences, There are currently several other related several REDD+ country participants at the forest emission reductions and removals in existing systems, and climate policy and processes underway which also focus on Forest Solutions Dialogue for the first time, the context of VCM. finance priorities. the environmental integrity associated with expanding the reach and participation of the the VCM, including the development or Dialogue. Overall, the two sessions gathered application of sets of principles, such as the a combined total of 85 participants from Task Force on Scaling of Voluntary Carbon 32 countries. Markets and the Natural Climate Solutions 22 VCMI — Voluntary Carbon Markets Integrity Initiative Summary of the Interviews Conducted During the Inception Phase Working Paper 23
The Voluntary Carbon Markets Integrity Initiative (VCMI) is a multi- stakeholder platform to drive credible, net zero aligned participation in voluntary carbon markets (VCMs). Designed by Jory&Co vcmintegrity.org www.joryand.co
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