Carbon Markets See Positive Signal In New US Climate Guidance, But No Game Change

Kelli Barrett

Earlier this week, the US Executive Office issued final guidance instructing all federal agencies to fully consider global warming and its impacts when making decisions and implementing activities. The guidance’s clear mention of land-based mitigation measures leads some practitioners to see market opportunity.

5 August 2016 | Every federal agency of the US government must soon begin quantifying the impact of its activities – both direct and indirect – on the climate under new guidance that the administration of President Barack Obama finalized this week after six years of consultations.  That means agencies that build roads must account not only for the emissions generated during construction, but for the emissions generated by cars and trucks that use it later. At the same time, agencies that work in land use must account not only for emissions generated, but for emissions reduced or sequestered – by, say, planting trees.

The guidance had been widely anticipated and could bring much-needed transparency to federal impact on the land-use sector, which in the US has been a net carbon sink but faces an uncertain future, according to a recent report Building Carbon in America’s Farms, Forests, and Grasslands: Foundations for a Policy Roadmap” by Ecosystem Marketplace’s publisher Forest Trends. The guidance is not, however, expected to have an immediate impact on carbon markets, because federal agencies are not yet permitted to reduce their emissions through carbon offsets.

What is the Guidance?

The Council on Environmental Quality (CEQ) formally released the guidance on August 2, calling it another big step in its climate change efforts. The CEQ published the final guidance in the Federal Resister on August 5.

“Information is the foundation of good management. The government should always be asking questions about the implications of carbon emissions and climate change,” says Lynn Scarlett, the Global Managing Director of Public Policy at The Nature Conservancy.

This guidance works in coordination with the National Environmental Policy Act (NEPA), a law established in 1970 that requires federal departments assess the potential impacts their activities, such as constructing a highway or managing public forestland, may have on the environment. Many of these actions can produce substantial greenhouse gas emissions, contributing to climate change. Or, alternatively, byproducts of a changing climate such as wildfires, rising seas and superstorms can affect federal initiatives. NEPA regulations often call for environmental review of projects and environmental impact statements for large projects that will have significant impact on nature.

With the new guidance, climate change will become part of NEPA’s environmental review in a more profound way. Debbie Reed, the Executive Director of the Coalition on Agricultural Greenhouse Gases says this is a positive change. Prior to this guidance, she says there weren’t any federal orders instructing agencies to account for their climate impacts that related to NEPA. The new guidance will not only direct all government agencies to consider climate change but quantify the impacts of their actions.

“Now federal agencies must fully and properly analyze the climate impacts of their proposed actions before deciding on how to proceed. They shouldn’t approve mines that will destroy the climate, or bridges that will get washed away,” Rhea Suh, President of the Natural Resources Defense Council said in a statement.

Scarlett sees a big opportunity in the guidance’s inclusion of bio-sequestration, the natural systems that store carbon. As the government is a major steward of land in the US, it has an opportunity to utilize the grasslands, forests and wetlands under its management to store carbon and build resiliency, she says. A NEPA review, for instance, that takes carbon storage into consideration might lead to developers relocating and redesigning a project in order to not disturb the carbon stocks.

“This guidance can affect the value of land that stores carbon,” Scarlett explains.

Market Signals

A revision to a 2009 Executive Order mandated federal agencies could offset energy and greenhouse gas emissions using renewable energy certificates (RECs) but it didn’t permit them to purchase carbon offsets. In 2015, the Obama administration issued another Executive Order that instructs the government to reduce emissions throughout its departments and supply chain. This new order essentially supersedes the 2009 order and its revisions. The 2015 guidance still allows for agencies to purchase RECs and, interestingly, it makes no mention of carbon offsets.

So the new policy does not specifically allow for carbon offsets to be utilized, it also does not exclude their use, Reed explains.

She believes the government’s stance on carbon offsets is likely to change and points to the accounting systems outlined in the new NEPA guidance combined with instructions to quantify greenhouse gas emissions as evidence.

“I think this new guidance is paving the way for federal agencies to be able to buy offsets as an opportunity to mitigate NEPA action,” she says.

Sheldon Zakreski, the Director of Carbon Compliance at The Climate Trust, doesn’t see the guidance as any kind of a huge game-changer for carbon markets. It’s more of a positive signal. Zakreski is pleased that the guidance recommends agencies consider climate mitigation measures when assessing projects. The inclusion of sustainable land management practices, forests, agricultural soils and greenhouse gas capture as carbon sequestration measures is particularly noteworthy to The Climate Trust. It relates directly to The Trust’s work designing and develops carbon offset projects in the forestry, biogas and grasslands spaces.

“We see this language as a positive signal toward forestry and agriculture offsets,” he says.

Scarlett agrees saying there isn’t a direct nexus between the guidance and market activity. That being said, the guidance’s consideration of nature based solutions to sequester carbon hints that carbon projects may play a part down the road, she says.

It’s also possible that the consideration of emissions could add another component to offset systems such as those compensating for biodiversity and wetland loss, Scarlett says. The carbon sequestration powers of habitat could factor in when offset developers are designating parcels to conserve.

Boosting Climate Comprehension

The guidance document recommends that agencies quantify a proposed project’s direct and indirect emissions, which are the emissions that come as a direct result from the project and those the project spurs.

When government agencies aren’t able to quantify climate impacts because of data constraints or the necessary tools aren’t available, the Obama administration expects them to perform a qualitative assessment. And agencies are expected to determine the carbon sequestration capabilities of a project, when applicable.

This guidance provides federal agencies a common approach for assessing their proposed actions, while recognizing each agency’s unique circumstances and authorities, the guidance reads.

Scarlett agrees adding that agencies have been striving to incorporate climate analysis on both the emissions and impact side but their efforts have been inconsistent and uncoordinated. She says the guidance strikes the right balance between delivering precision and certainty while still giving agencies the necessary wiggle room.

In a statement, the White House said the guidance will deliver a new level of detail and transparency, which will allow decision makers and the public to more fully understand the impacts of federal actions on the climate.

A better understanding, the administration says, will help all parties explore alternative methods that could help the US either adapt to climate change and build resiliency or mitigate global warming. It will also help implement proper mitigation measures that truly compensate for federal emission-producing endeavors.

Guiding Smart Climate Policy

“Climate change is the central environmental challenge of our time,” Suh said in an earlier statement. “These guidelines can pave the way for smart policies that better protect our children, our health and our communities from dangerous carbon pollution and climate catastrophe.”

The road to this guidance began in 2010. In that year, the Obama administration initiated efforts to modernize federal agency implementation of NEPA, involve the public and improve transparency and the efficiency of environmental reviews. These efforts resulted in draft guidance the same year and then again in 2014. A task force comprised of state, local and tribal leaders pushed for the finalization of the 2014 revised draft guidance to ensure that government projects keep emissions and climate in mind.

Kelli Barrett is a freelance writer and Editorial Assistant at Ecosystem Marketplace. She can be reached at [email protected]

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31 thoughts on “Carbon Markets See Positive Signal In New US Climate Guidance, But No Game Change

  1. Amazingly governments never ever consider the costs before doing things like this. Obama and the EPA will destroy millions of jobs in the process and will do this not through government and elected officials but through the back door and beurocrats. Americans better wake up they are on a slippery slope of unelected people running the country

    1. Oh? What’s your evidence for this “destroy millions of jobs” claim?

      The best experts in the world say the opposite: for the same $1 invested in renewable or fossil energy, three times as many renewable jobs of higher quality and better pay are created domestically, and those wages tend to stay home.

      The “slippery slope” is a logical fallacy.

      1. all the best experts in the world sure same lie told over and over again green jobs to replace the hundreds of thousands of jobs in coal plants the oil industry gas industry and this has happened where. Name one country state province anywhere??? I know it hasn’t worked in ontario canada or even germany england where??? you people make me sick all across europe and in Ontario they have people choosing to eat or heat there homes because of the skyrocketing costs your green energy is causing. The fossil fuel industry makes up 1/5 th of canada’s economy how the hell are you going to replace that

        1. You seem to be fact challenged.

          BC’s had a revenue neutral carbon tax for eight years now. Our economy in those eight years has been one of the top three in the country of any province — the only province to do that all eight years. We have the best credit rating of any province, and our jobs have been one of those ‘top three in the country of any province’ pretty consistently too compared to everyone else.

          You’re making crap up because you don’t want to pay the fossil dumping debt you owe for your fossil waste disposal , even if it means making jobs for three times as many people, reduced health problems from smog, and cheaper energy for everyone.

          Seems petty and selfish.

          Pay what you owe.

          1. we just saw canada’s entire economy nosedive thus the 30 billion i new debt Justin ran up mainly due to slumping oil prices fact. BCs economy has always been good because you have natural resources but your provinces government is still running a deficit. So good on ya so what have you looked at Ontariowe 350 billion in debt green projects costing tax payers an extra 39 billion in power costs even though they only supply 7% of the power occassionally. And don’t bring up hydro I agree with Hydro what I don’t agree with is doubling the cost of power and making it less reliable which again has happened in Ontariowe. And again where are those green JOBS in ontariowe (don’t include Hydro because they existed prior to this nonsense).
            And get a life blaming health problems on smog most canadian cities have no smog because of the filters and converters on car. And again where have energy costs gone down because of green energy name one country???talk about making shit up. And by the way do you eat travel use a car take a bus have a cell phone use plastic own winter gear anything if you do you owe too

          2. tl;dnr

            Ramble incoherently about your political fears and hates on your own time.

            Every tenant retailer in the world charges overhead for Market rent of scarce storefront, warehouse and office space as a part of the price of every sale.

            We know it takes thousands of human lifetimes for fossil CO2 a single person dumps by burning or clinkering or in process emissions to bleed out of the atmosphere and return to fossil form, making that fossil waste disposal scarce fruits of the land.

            We’ve known since 1776, the most elementary of economic principles from Wealth of Nations, that Market rents are the defense of a nation’s wealth from the Tragedy of the Commons, and that what is scarce must have attached to it a price so high as the Market will bear, set by the Law of Supply and Demand.


          3. Incoherent Rambling you are so right and I like the way your side brings Hate into the discussion no matter what the subject is and of coarse politics. I am really surprised you didn’t use the power word RACIST then I would be really shaking in my boots. And as always you always ignore facts and examples of your sides failures and keep repeating lies like green jobs cheaper energy and of coarse manufacturing manipulating raw data to match your theories.
            The earth needs CO2 in it’s atmosphere to support life on this planet. Earths atmosphere has less than 400 parts per million (.04%)of CO2 in its atmosphere right now. Most scientists agree the minimum we require for life to exist is anywhere from 175 to 200 parts per million. Your crowd somehow came to the conclusion that anything above this is not natural and that we are somehow way to high even though earth has had much higher levels of CO2 in the past (without mans help). And that it is only Man made CO2 that is the problem even though man is responsible for less than 4% of the total CO2 output yearly the other ocure “naturally”. And of coarse your theory that if we cut that 4% we can control nature weather global temperature is just again idiotic. Mostly because your theory requires us to believe the other 99.96% of gases that make up our atmosphere do nothing affect nothing.
            But the only response to these facts questions is to say the science is settled and your so called expert continue to run and hide from debating it.

          4. tl;dnr

            You’re just rehashing old failed fossil lies to try to stave off the day you pay your fossil debts.

            Deadbeats are all alike.

          5. You just proved my point so CO2 dosen’t make up .04% of the atmosphere ? And the fact man only emits less than 4% of total CO2 that is emitted yearly is also a fossil fuel lie??? And off coarse the name calling wow ! All the above are facts and all of those facts call into question your entire theory but your just ignoring them. Science is never settled every theory every scientific fact is tested and questioned that is what science is. I guess your just brainwashed

          6. “CO2 dosen’t make up .04% of the atmosphere ?”

            It does, Huey!

            If it’s so likely polar ice sheets will be able to withstand CO₂ so high, why isn’t there a single example of them doing so in Earth’s history?

            “The continent of Antarctica has been losing about 134 billion metric tons of ice per year since 2002, while the Greenland ice sheet has been losing an estimated 287 billion metric tons per year.”


          7. I WAS ASKING A QUESTION BECAUSE BART had a problem with me making up facts because i said it CO2 makes up only .04% of the atmosphere. So i was being sarcastic. And my point is it is a miniscule part of the entire makeup of the atmosphere but they blame it for everything even though it is needed for life to exist on our planet. I also explained that man is responsible for only 4% of the yearly output of CO2 so the plan to cut mans emmissions somehow will change and control weather is absurd. None of your predictions warming predictions have come true but you still believe ridiculous. So water vapor oxygen nitrogen have nothing to do with climate how about cloud cover volcanic eruptions solar flares the earth rotation nothing just CO2. One volcanic eruption on earth dose more to alter weather patterns than man ever has.

          8. “JURASSIC-CRETACIOUS PERIODS EARTH HAD MUCH HIGHER CO2 levels and there was glaciation.”

            Is that true!?

            How do you know, Huey?

            “The lighter blue shading for the Jurassic/Cretaceous icehouse reflects the fact that true polar ice caps have not been documented for this time interval.”


          9. Documented there where no humans to document anything in this time period because they did not exist but the scientists routinely support glaciation existed during both these periods. And there was 5 to 10 times more CO2 in the atmosphere during these periods and man was not around to cause it.

          10. No humans?

            But we’re not talking about humans.


            We’re talking about chickens and eggs.

            On timescales of a billion years or more, the Faint Young Sun Paradox comes into play on observations. When we take into account changes in the sun over half a billion years or more (hundreds of times greater than changes in the sun in a human lifetime), the correspondence between CO2 and temperature holds steady so far as we can estimate from geological proxy evidence.

            When we look at Milankovitch Cycle timescales, we find the intensity of the temperature and CO2 changes are too high by five to ten times to be explained by orbital differences.


            Only the power of CO2 in feedback loops with water vapor and albedo is strong enough to explain the height of the differences.


            That power is emphasized by the last 250 years, where CO2 from fossil sources alone has been responsible for the sharpest temperature rise in the history of the globe.


            It doesn’t look like much on human scale, but it’s enough to bring the planet to a state where in 70 years we will see over 3 degrees C global warming, sudden and dramatic sea level surges of up to twelve feet at a time every few decades for hundreds of years, extreme changes to patterns of drought, flood, weather and habitat, some 50% drop in the nutrient density of crops, 20% loss of soil fertility, and 40% increase in aquatic acidity.

            The question has to be asked, why do fossil waste dumpers think they have the right to do this without paying?

          11. So it is now 70 years from now in the 90’s predictions were made for 20 years and the worst ones never came true your models where all wrong. Now in the 2010’s your predictions are for 70 years from now when they are wrong you and your ilk won’t be around to answer for them. Talk about fear mongering, the Earths climate changes with or without man In for example Saskatchewan Canada was once like the Florida everglades they have found crocodile bones and fossils. And now its climate is reversed with a much colder climate did man cause that to. Changing 4% (manmade yearly emmissions of CO2)of 100%(total yearly yearly emmissions of CO2) of only .04%(CO2 in atmosphere) of the atmosphere is not going to do anything to change the climate.

          12. “Explained” is a pretty strong word for something that doesn’t make sense.That’s like arguing that just a little bit of arsenic can’d do any harm.

          13. Again ignore facts what I wrote above are the actual facts total CO2 in the atmosphere is only .04%, mans contribution is less than 4% of the CO2 that is released into the atmosphere on a yearly basis. So what exactly is your point so now we didn’t have those 2 periods where C02 was at 5 to 10 times higher than it is now and during those periods there was glaciation. and there ar plenty of papers that suggest other things have an effect on our climate so who’s side routinely ignores facts and questions because they call into question there “THEORY” And only report one side of any story and blame everything on CO2 . Hey in your world do you need CO2 for life to exist or is that a made up myth too???

          14. You have no point.

            You just have foot dragging to attempt to weasel out of paying the debt you owe.

          15. I don’t owe a debt you loon everyone would if your ridiculous theory is correct so get off your podium

          16. Everyone does owe a fossil debt, if they dump fossil waste, of course.

            But not everyone dumps fossil waste, and not everyone who dumps fossil waste dumps equally. Some dump more than others.

            On the other side of the ledger, everyone with lungs is owed the same equal share, the average of all that is owed.

            Put those two sides of the ledger together, and at the end of the day some people — about seven in ten — come out ahead (some of them way ahead) because they dump so little fossil waste, and others owe a lot (about three in ten owe something).

            If you’re one of the seven in ten, you should want people to pay what they owe. Which means you likely know very well that you’re one of the three in ten who dumps more than his share.

            Pay what you owe.


          17. Fossil waste is probably a new catch phrase from enviro crazies like you. Your one of those people who want everyone to feel guilty about being human and living and think we should go back to caves. Let me guess you live in a granola crunching neighborhood your a vegan and go around to demonstrations casting your dispersions on everyone who actually has a job. grow a small garden in boxes and think everyone should get back to the land. What a joke you hippies truly are s—–d you probably buy organic with your welfare money and pay twice as much fo the same product.
            And i guess we only have a share in the atmosphere here i thought it was free. I thought Air was actually free but I guess in your little idiotic world nothing is free you sir on a whack job of biblical proportions. So i bid you goodbye you can’t fix stupid so I am not even going to try anymore

          18. Thought I recognized the name.

            Good interview, very informative.

            One of the wonders for me of the mainstream economic arguments for carbon pricing is how easily they overlook how much more fundamental and simple a question this is than they recognize.

            It’s not that pricing carbon (specifically and only fossil carbon) is a good thing or has benefits or addresses issues as a specific case, but that pricing fossil disposal scarcity is exactly the one single issue underpinning all of economics since Adam Smith: how do we price scarcity to minimize misery, optimize utility and prevent perverse outcomes?

            The Market answer is privatization. It’s just that simple, in terms Elinor Ostrom set out so clearly:

            scarce + excludable + rivalrous = Privatize.

          19. Expansion is most certainly warranted.

            We have what is clearly an economic issue to do with a cloud or cluster of problems:
            1. climate science has reported for six decades that as CO2 levels go up, the average global temperature will warm, and many problems follow on directly from that one result;
            2. botany reports that as CO2 levels go up, while some benefits accrue to some plants in some situations, overall plants drop their nutrient density in key amino acids by about 1% per 1% rise in CO2 level, as well as lose some mineral density;
            3. agronomy reports that CO2 increase drives normally beneficial soil microbes to overconsume nitrates and emit their waste as NOx pollutants;
            4. oceanographers report aquatic acidification due CO2 level rise having a panoply of outcomes, mostly negative, on Earth’s living waters;
            5. Economies of scale tell us that renewables are far cheaper than consumables per kWh, but we can’t get renewables on the grid nearly as quickly as we ought to take full advantage due the sunk costs in consumables;
            6. developing markets are unable to access renewable technology due megaprojects funded by international development agencies as obstacles to these lower cost, more appropriate solutions;
            7. people remark on a profound sense of unfairness about the current situation, though not all agree on cause, etc.

            Now, the world could work on treating all these symptoms with lower-rung bandaids like Pigouvian taxes, command and control regulation, adaptation, regional strategies. That’s the sort of thinking that has met stiff opposition and little success for six decades.

            Or, we can attack the whole body of these problems at their root issue.

            Every tenant retailer in the world charges overhead for Market rent of scarce storefront, warehouse and office space as a part of the price of every sale, and holds that money in trust for the property owner until that rent comes due.

            We know it takes thousands of human lifetimes for fossil CO2 a single person dumps by burning or clinkering or in process emissions to bleed out of the atmosphere and return to fossil form, making that fossil waste disposal scarce fruits of the land.


            This scarcity is seen in the bottleneck of CO2 level rising in the atmosphere, and it is confirmed in the carbon isotope ratio of that CO2 that fossil carbon is 100% of the cause of this rise.


            We’ve known since 1776, the most elementary of economic principles from Wealth of Nations, that Market rents are the defence of a nation’s wealth from the Tragedy of the Commons, and that what is scarce must have attached to it a price so high as the Market will bear, set by the Law of Supply and Demand, to be paid to the property owner.

            This is the one common cause, and Market rent at retail is the one common solution we know will work.

            Is it enough by itself?

            Likely not. But until the price signal pervades the Market, perverse outcomes will result somewhere in the system.

            The scientists did their job six decades ago. This is an economic failure of the people who own the air — manifestly each of us with lungs — to collect rent for the trespass of fossil waste dumping on our property.

      1. another made up number invented by your side to somehow scare everyone into spending 50 trillion to prevent things that might occur. None of your predictions have ever come true your warming predictions wrong! greenland ice free Wrong! nothing your experts have predicted have ever come true but wait wait now those same experts are saying if our predictions come true it’s going to cost us trillions. You’ve gone from global warming to climate change and now blame every natural weather event on this evil CO2 in our atmosphere which only comprises less than .04% of that atmosphere but it controls everything. And whats even more idiotic than that you believe man is entirely responsible for all the warming and by cutting our emmissions which make up less than 4% of the Co2 that is released into the atmosphere on a yearly basis some how that will control the weather. What a joke. And making CO2 a villian is just stupid you do realize we need it in our atmosphere to have life on our planet or are you just that simplistic

        1. “another made up number”

          You think the economists at Citibank are “making up” how costly climate change is likely to be?

          Supply your own number, then, and the source of your information.

          Why haven’t you already done that?

          “If the Greenland Ice Sheet melted, scientists estimate that sea level would rise about 6 meters (20 feet). If the Antarctic Ice Sheet melted, sea level would rise by about 60 meters (200 feet).”

  2. Every tenant retailer in the world charges overhead for Market rent of scarce storefront, warehouse and office space as a part of the price of every sale.

    We know it takes thousands of human lifetimes for fossil CO2 a single person dumps by burning or clinkering or in process emissions to bleed out of the atmosphere and return to fossil form, making that fossil waste disposal scarce fruits of the land.

    We’ve known since 1776, the most elementary of economic principles from Wealth of Nations, that Market rents are the defense of a nation’s wealth from the Tragedy of the Commons, and that what is scarce must have attached to it a price so high as the Market will bear, set by the Law of Supply and Demand.

    When the same privatization was done for mobile bandwidth, it gave birth to the fantastically successful cell phone industry and led to the Smart Phone.

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