Writing
Everything from short-form thoughts of the day, to long-form deliberations over market-aligned climate systems, law and policy, to infrastructure design development, to shorter advisory notes on live regulatory questions, and the occasional podcast with trusted experts and leaders in the space.
E-ledgers is close to right as a data ontology and out of its league as an accounting standard. Without property rights in the attribute, there is nothing for it to account for.
Carbon accounting is a system of data without property; the verified carbon market is a system of property without data. The paper sets out why the GHG Protocol was never built as market architecture, why multi-attribution is structurally incompatible with clearance, the five conditions an intangible must meet to clear, and what it would take to constitute verified environmental performance as an object that can be owned, financed and settled.
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.
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.
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.
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.