Farm groups are calling for stringent requirements for third-party verifiers of carbon farming projects, including knowledge of crops grown in the U.S. and specific soil types, as USDA seeks to implement the Growing Climate Solutions Act.
Over 150 organizations recently provided feedback to the USDA on how to establish industry-wide requirements for Greenhouse Gas Technical Assistance Providers and Third-Party Verifiers. While there were varying opinions, almost all advocated for a voluntary, market-driven carbon market.
Opinions were divided between those applying for credit and those verifying them. Verifiers said the current standards for accreditation are working well, while some agricultural groups argued for more requirements tailored to U.S. crops, including one group calling for verifiers to be U.S. citizens.
An October general assessment of carbon credits in agriculture issued by USDA cited market confusion, administrative obstacles, high costs and complicated project requirements for producers who wish to benefit from their use of climate-smart practices.
To implement the GCSA, which passed Congress and was signed into law by President Biden at he end of 2022, USDA is working to identify the qualifications, expertise, and certifications required for third-party verifiers — independent entities that verify whether projects followed the requirements in carbon offset protocols — and technical assistance providers (TAPs), who assist landowners in implementing practices. Comments touched on commonly used protocols or criteria for how carbon credits are created and measured, the timeline of participating in the market, and identifying definitions and metrics for evaluation.
The National Cotton Council submitted a detailed list of qualifications to ensure those working on projects have filed verification competence They suggested that TAPs be able to interpret and apply international climate change methodologies for national GHG inventories, pass a standardized test covering key quantitative skills and have experience applying at least three different carbon offset protocols.
Third-party verifiers should be familiar with field measurement techniques, have a proven track record in verifying carbon offset projects, engage in continuous professional development, and have completed at least five verifications in the past three years,
American Farmland Trust said industry-specific qualifications could be potential requirements for TAP, such as the Certified Crop Adviser (CCA) certification.
The American Soybean Association agreed, saying TAP providers should use existing protocols and USDA should model the process after Natural Resources Conservation Service (NRCS) TSP certification "to give growers the confidence and local presence needed to participate in the program.”
Three agricultural scientific societies — American Society of Agronomy (ASA), Crop Science Society of America (CSSA), and Soil Science Society of America (SSSA) — emphasized the importance of having auditors who understand the practical implications of carbon credit projects on farming and forestry operations. They stressed that “carbon credit recommendations should not hinder agricultural productivity or sustainability goals.”
Minimal qualifications standards are important to groups, but many want to ensure that certification and education requirements are not so difficult to meet that they discourage participation in the program.
The Agricultural Retailers Association suggested USDA require verifiers to register on a USDA list of known third-party verifiers and recommended that, at a minimum, they be U.S. citizens or permanent residents. “In some instances ... verifiers have little to no experience with regional soil types and/or cropping systems,” ARA said.
Although many verification bodies are based in the United States, depending on the verifier’s contractors, auditors often travel globally to complete third-party audits, causing concern within the American agriculture community. Some carbon projects use remote sensing technologies, eliminating the need for in-person verification.
Carbon markets are global and encompass various project types such as forest carbon, livestock waste management, wetland restoration, and soil enrichment. Verra contracts with 35 Validation & Verification Bodies (VVBs), of which only five are based in the United States. U.S. Climate Action Reserve uses VVBs from the National Accreditation Board list, with 12 of 19 accredited organizations based in the U.S. The SCS Greenhouse Gas Program currently employs three VCSA-approved Agriculture, Forestry, and Other Land Use (AFOLU) experts.
Despite widespread use of these verifiers, the federal government has yet to adopt any qualifications — which is specified in the GCSA.
California has a Cap-and-Trade Program that mandates regulatory verification for all GHG reduction programs. This requires VVBs to be certified by the Air Resources Board, attend agency training and demonstrate competency through examinations.
ARA, however, is asking for additional steps beyond accreditation for placement on a federal USDA list of third-party verifiers.
For landowners engaged in the carbon markets through the production of credits, popular carbon programs — which help enroll participants — like Indigo Ag use Climate Action Reserve and Verra as third-party verifiers. Truterra uses SCS Global Services, and Nutrien is contracting with the Ecosystem Services Market Consortium for verification.
In response to ARA’s comment on nationality requirements for verification programs, SCS Global, a prominent third-party verifier, said, “Our approach has long been to favor auditors with regional experience and expertise, which is part of the basis for our qualification for competence.”
SCS Global said all their verifiers are accredited and maintained that the International Organization for Standardization (ISO) 14065 standard is a well-established benchmark for competence, training, and calibration. However, “not all auditors or VVBs are accredited under ISO 14065, which is the most rigorous accreditation today,” said Linda Brown, the Senior VP at SCS Global.
All four carbon registries have forms of accreditation, but they often vary. Most align with two standard: the American National Standards Institute (ANSI) National Accreditation Board and ISO 14065 requirements by the International Accreditation Forum or the UN Clean Development Mechanism (CDM).
Registries and carbon programs can set their own accreditation requirements for VVBs or additional requirements to ensure an effective and accurate auditing process – as ARA suggests. However, current qualifications satisfy current third-party verifiers like SCS Global and Verra, who requested no changes from the USDA.
Verra, another large verifier, provided brief comments on additional third-party qualifications, maintaining that current requirements are adequate. Entities like the International Emissions Trading Association and data collection companies such as Puro.earth also suggested no changes to current accreditations.
Groups are seeking further dialogue beyond the comments already submitted. The National Council of Farmer Cooperatives supports forming an advisory council to help further develop the program and to coordinate with the USDA on various technical issues.
The Land Trust Alliance states that landowners and farmers who participate in carbon programs find it challenging to select a reputable developer because it is difficult to make ‘apples to apples’ comparisons of the commercial terms and other contractual services developers offer.
The USDA hopes to provide information to assist farmers, ranchers, and private forest landowners in better accessing these providers.
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