PAPER 01
Aug 2026
Published
No Common Ground, Part I: The Market Coordination Architecture to Align Carbon
Accounting Frameworks with Market-Based Instruments
The central hypothesis of the foundational and structural disconnects between carbon
accounting and environmental attribute markets caused by how their standards frameworks
coordinate information. Why the GHG Protocol was not designed as market architecture, why
multi-attribution is structurally incompatible with market clearance, and why the analogy
to product-level ingredient accounting fails on a base that is a property system for
transacting environmental performance.
PAPER 02
Forthcoming
Draft
No Common Ground, Part II: Constitution of the Asset and the System of Record
What it might take to constitute and legally recognize a verified environmental outcome
as property rather than to describe one. Exploring the relationship of environmental
market-based instruments and controlled electronic records under UCC Article 12; the
evidentiary record and certificate-of-title-to-an-EAC relationship read against the
warehouse receipt model under UCC Article 7; and what that might point to as market
coordination architecture.
PAPER 03
Forthcoming
Draft
No Common Ground, Part III: Systems Coordination — Governance, Recognition and
Sequencing
Who runs the layer of record, on what rulebook, and by what authority. Self-regulatory
precedent, the separation of functions the DTCC paperwork crisis forced, and a realistic
order of operations for recognition across standards, accounting bodies and hard law.
ADVISORY
2026
Note
RED III and the treatment of US-sourced gaseous fuels
The case for Commission interpretive guidance on chain of custody for gaseous fuels, so
that sustainability attributes and carbon-intensity scores carried as EACs or digital
product passports can be relied on for European compliance. Includes the coalition and
sequencing argument for the interpretive-guidance route over amendment.
ADVISORY
2026
Note
Procuring carbon-intensity data without buying a lawsuit
Contracting for CI and feedstock data across a grower-to-processor chain: who owns the
underlying data, what the verifier is actually attesting to, how fenceline processing
protects the producer, and where the representation and warranty package has to sit for
the resulting attribute to be sellable.