By Gabriel Labbate, Teo Hoong Chen, and Pedro Martins Barata

The Article 6.4 Methodological Expert Panel has published a draft tool, A6.4-MEP014-A07, “Reversal Risk Assessment,” open for comment until 24 July. The draft document proposes that contributions to buffer pools be made by estimating the sum of natural and human-induced risks. Based on its draft preliminary numbers, several countries and sub-regions could see combined risk ratings that make clean cooking credits commercially unworkable. The MEP has signalled that these same natural-risk defaults are intended to extend to other nature-based categories. Expect the debate over these numbers to be intense.

But this is not all. Following on the previously published Reversal Standard (A6.4-STAN-METH-007, v.01.0), the draft tool extends permanence requirements, together with their associated buffer deduction, to clean cooking. It does so by requiring a 100-year reversal-risk assessment and a buffer-pool contribution, which is immediately cancelled rather than held in escrow. This functions as a one-time permanence discount, even though no ongoing monitoring or remediation is required.

This marks a genuine departure. For two decades, under the CDM and every voluntary standard that followed it, clean cooking credits have been issued as flow-based emission reductions, without buffer pools, reversal ratings, or long-term monitoring liabilities. Article 6.4 would toss that precedent aside.

This is not a minor decision, and therefore, before getting dragged into discussing risk ratings, it is worth pausing on a first-order question: should clean cooking be subject to permanence requirements in the first place?

We believe it should not.

Permanence risk management (reversal buffers, long-term liability, post-crediting monitoring) was designed for one specific problem: crediting activities where the claim depends on a carbon stock continuing to exist over time (e.g. forest-based removals, a geological storage site). If the stock disappears, the credited benefit disappears with it. That is a genuine risk requiring insurance-like instruments.

Clean cookstoves don’t have this structure. A cookstove credit claims that emissions were reduced relative to a baseline during a specific period (less fuel burned, less non-renewable biomass harvested, fewer emissions released, than would have occurred otherwise). Once that period’s emissions reduction has occurred and been verified, it is a completed fact. If a household stops using the stove next year, that simply means no further credits are generated going forward. It does not erase the abatement that already happened.

This is the core distinction between stock-based claims (continued existence of a reservoir) and flow-based claims (emissions performance over a bounded period). Clean cookstoves, along with renewable energy, fuel switching, and energy efficiency, fall into the flow-based category. Applying the stock-based permanence toolbox to these activities imposes costs and complexities without any corresponding integrity benefit.

The standards approved under Article 6.4 do not provide a conceptual explanation for why clean cooking should be treated as though it generates a stock-based claim. Below we explore some potential reasons and corresponding counterarguments.

First, it might be argued that in the case of clean cooking, the ability to observe and attribute carbon loss with some precision justifies permanence requirements. This traceability may be taken to imply an accounting obligation: if carbon loss can be directly observed and attributed, there is a basis on which to hold specific actors accountable for that loss. Yet fossil reserves are traceable in much the same way: extraction and combustion are observable, attributable events, and this has not led anyone to propose that renewable energy projects should undergo risk ratings and set aside credits for a buffer.

A variation on this argument states that a stove’s emissions reduction is inseparable from the fuel it displaces, and that this is evidence that the underlying claim is really a stock-based one. There are two problems with this line of thinking. One is that if inseparability were the relevant test, it would apply with equal force to the identifiable, and still extractable, fossil fuel that a renewable-energy project displaces. The other is that clean cookstoves are not issuing credits for preserving forest stocks through lower use of non-renewable biomass; the credit is issued on the basis of energy efficiency and fuel switching. A renewable-energy project works the same way: it does not claim credits for preserving a fossil fuel reservoir, but for displacing CO2 emissions.

Finally, another concern is that the potential vulnerability of forest carbon stocks reveals intrinsic weaknesses in the clean cooking category. But this does not quite follow either: the vulnerability of one particular reservoir and the claim type of the credit are unrelated things. Fossil fuel reservoirs, for their part, are similarly exposed to future use. Nothing in their physical nature guarantees that extraction will not resume in the future.

As the comment period runs to 24 July, we would encourage the market to ask whether stock-based logic warrants wholesale application to every credit category with links to forest carbon. Before any reversal-risk figure is estimated, the more fundamental question for any credit category should be whether it embodies a flow claim or a stock claim. Misclassify that, and no degree of technical refinement to the buffer calculation will put matters right.

Permanence requirements attached to a flow-based category do not, in our view, add integrity. They add cost and delay, at precisely the moment when the transition to a low-carbon economy can least afford to be slowed.

Written by Gabriel Labbate, United Nations Environment Programme; Teo Hoong Chen, Centre for Nature-based Climate Solutions, National University of Singapore; and Pedro Martins Barata, Environmental Defense Fund.

Any opinions expressed in this commentary reflect the views of the authors and not of Carbon Pulse.

Carbon Pulse allows subscriber companies to submit one piece of ‘Contributed Content’ (op-eds, advertorials, tenders/RFPs, etc) per year. This post appears in front of our paywall, so it’s readable by anyone.  It also appears in our CP Daily newsletter once. Beyond that, or for non-subscribers, we allow companies to purchase ‘Sponsored Posts’. These posts also appear in front of our paywall, while we feature them in our daily newsletter for three consecutive days (instead of one).

You can read more about our Contributed Content/Sponsored Post offering here: https://carbon-pulse.com/advertising-brochure/