Resources

• Integrity Council for the Voluntary Carbon Market (ICVCM)
• ICVCM’s Core Carbon Principles (CCPs) and Assessment Framework
• ICVCM’s work with indigenous peoples and local communities
• Science Based Targets Initiative (SBTi)
• World Bank E-course: Communicating Carbon Pricing
• Asian Development Bank E-learning (free): Energy Economics, Environment, and Policy
• HBR "What Every Leader Needs to Know About Carbon Credits" by Varsha Ramesh Walsh & Mike Toffel

Host and Guest

Climate Rising Host: Professor Mike Toffel, Faculty Chair, Business & Environment Initiative (LinkedIn)

Guest: Amy Merrill, CEO, Integrity Council for the Voluntary Carbon Market (LinkedIn)

Transcript

Editor's Note: The following was prepared by a machine algorithm, and may not perfectly reflect the audio file of the interview.

Mike Toffel:

Amy, thank you so much for joining us here on Climate Rising.

Amy Merrill:

It's a real pleasure to be invited. Thanks for the invite.

Mike Toffel:

So why don't we begin with just a brief introduction. So how did you end up becoming the CEO of your organization? What were the key milestones of your career that led you here?

Amy Merrill:

Well, thanks for the chance to say who I am. I studied law at university and then specialized in environmental law at the College of Europe and then went into private practice as a lawyer working at two major law firms on carbon markets and climate finance structures and then moved to the UN as a climate change lawyer. And then about 10 years ago, I got pulled into working on what became the Paris Agreement, and the negotiations that covered mitigation and forests and markets. And after getting Article 6 adopted in the Paris Agreement, I worked until the end of 2021 as the lead UN support to those negotiations to get the rulebook delivered. And that happened in 2021 at COP26. And then after that, I went back to private practice to develop community-focused projects with a nature angle and ended up at C2ES a short while after as head of carbon and then joined the ICVCM and became the CEO about eight months ago.

Mike Toffel:

Got it. And so just to decipher some of that for the non-experts, the Article 6 piece of the Paris Agreement is the portion about carbon credits. And C2ES, do you want to say a word about that, that's your most recent organization?

Amy Merrill:

That's right. Yeah, that's the Center for Climate and Energy Solutions and that's obviously a think-do tank working in the US focused on all those issues around climate action and community action.

Mike Toffel:

So legal background, Europe history, UK history, but also US. Then here you are at the center of an organization that's really trying to work hard to upgrade, as I understand it, upgrade the standards that folks need to adhere to in the carbon credits market. And so, let's talk a little bit about the creation of the organization, the Integrity Council for the Voluntary Carbon Markets, your organization. What caused it to be founded? What was the problems it was going after? And then how has it evolved since that founding moment?

Amy Merrill:

So, the integrity council was established in 2021 to respond to the recognition led by an international initiative looking at how to get carbon finance scaled, recognizing that to scale the carbon markets we needed to make them more comparable, make them higher integrity and make them more consistent so that they were easier to invest in.

So, the problem we were trying to solve was a fragmented market that was quite boutique in nature and just wasn't in a condition to be investable at scale. And so, the ICVCM, the integrity council was set up to provide a global threshold for high integrity and bring comparability and consistency to the market so that it was easier for buyers to identify where to bring their investments.

Mike Toffel:

Great. Now, one of the major elements of this has been what you're calling the core carbon principles that your organization developed, which is, I think, 10 points, including things like transparency and clarity on the no double counting and clarity on the way that people are measuring carbon credits. At first blush, to me, those seem like so foundational, like how can those be raising the bar? But then as I read a little more into it, I was convinced that in fact these foundational elements are not actually widespread and getting folks to adhere to these, as you call them, core carbon principles is not so obvious. So, can you tell us a little bit about the foundation of those principles and how you're trying to get folks to adhere to them?

Amy Merrill:

Yeah, I think you're right. Everybody understands simple things differently, right? And the core carbon principles are backed up by an incredibly detailed assessment framework that shows just how they do deliver high integrity, consistent, comparable markets. And there are 10 of them and they are those recognizable terms if you're a carbon market operator. And there are four of those that look at the way that programs operate carbon crediting programs and look at their governance systems, the way they manage risk in registries, how transparent they are and how they use third party verification. And so that provides us a sort of governance underpinning for integrity. And then we have four carbon principles that really look at how you measure what's being achieved in any given core carbon project. You talked about additionality and permanence.

Those are ways you measure whether something would happen and then impermanence, how you manage risk of something, some action being reversed. And we also have rules around avoiding double counting and making sure you're not issuing two credits for one ton of action and how you really use conservative measurements to measure the project's delivery of carbon credits and avoid over-crediting, which has been a problem in the past.

And then we have two core carbon principles that really are the space where the market was least coordinated, least transparent and achieving the least around sustainable development benefits and safeguards and the contribution to net zero. And here the core carbon principle, rule-based there, really drives the market to deal much more holistically and effectively with things like human rights, free prior informed consent, other environmental pollutants and managing the transition globally to net zero.

Mike Toffel:

Yes, that's an interesting amalgam of measurement and governance and other issues. When you mention programs, these are the VERA and Gold Standard, those types of organizations that some call standards and others call registries because they operate in many different dimensions in this arena. So that's programs. If I understand it correctly, your organization is assessing both at the program level, so like the way that gold standard does its work, but then also at the methodology level, which is all of these programs, one of the reasons they're called standards is because they have a variety of what they call methodologies, which is if you're a cookstove project developer or you're trying to cap methane at landfills or you're trying to grow trees or prevent the deforestation, all of those in order to earn credits have to pass through the check boxes of a methodology that one of these programs has put forth, and you're evaluating not just the programs, these organizations as a whole, but also each of these methodologies.

Amy Merrill:

That's right. It's what we call our double tick approach. And we have multi-stakeholder working groups and experts that get together and look at all the similar types of methodology and assess whether they meet the rule book that we published last year after a wide stakeholder consultation process. And one of the things that is really important to understand is that obviously across the carbon market space, there are lots of different learnings in different places around what has improved over time and what's still not being done as well as it can, and what kind of real-world conditions particular implementations project face. And so, when we bring together the multi-stakeholder process for assessing all these methodologies, we're really hearing from everyone and our experts around, you know, what does this methodology work? Is it high integrity? Have all the risks been considered? And what do we need to do to make it work better? And where we can approve it, we will do so sometimes with conditions and where it needs to be evolved before it can receive our approval, we will reject it and then the programs will normally take it away to work further on it. And the combination of that review of programs and that stakeholder approach to assessing methodologies allows for labeling of specific carbon credits as having the CCP label and that's what buyers can use to identify where high integrity purchases can be made.

Mike Toffel:

So, this labeling system is awarded to those carbon credits that adhere to a methodology that has passed your organization's scrutiny. Is that right? So, it's not on a credit-by-credit basis. It's on a methodology-by-methodology basis.

Amy Merrill:

That's right. So, we provide an oversight of programs and their methodologies. And if the program passes and the methodology passes, the program will label its credits with our logo. And that will help buyers see those are the credits that have passed our framework, and they may be more incentivized to purchase those.

Mike Toffel:

And so, let's talk a little bit about the experience of assessing these programs and of methodologies. Where are the areas that have been sticky where a program has not, for example, not been approved at first blush? Like what was it that they were falling down on or not adhering to your standard? And maybe they then resubmitted for a second shot after they upgraded in some manner. Let's start at the program level and then I want to dig into the methodology level as well.

Amy Merrill:

Sure, one of the areas we found in program assessment was generally that the level of transparency of the process needed improvement. One of the things that enables the market to be confident in carbon crediting programs is their ability to scrutinize data and information about how programs make decisions and what projects are doing with their own individual calculations. And so, one of the areas we really found we were able to invite programs to make big improvements was in the way they are publishing information about specific projects and processes.

The other really big stretch assignment we really saw in the market when ICVCM issued its rule book in July 2023 was around sustainable development benefits and safeguards. The rules we brought to the market were really, really detailed and a lot of the programs that subsequently applied had gone through an upgrading process of, for example, grievances processes, complaints processes, stakeholder consultation processes, measurement of free prior informed consent processes. And we really saw the market treat those issues far more seriously as a response to our assessment rules and our assessment process.

Mike Toffel:

I see. And how about on the methodology side? I see on your website that there's methodologies that you've approved. There's a number that you've rejected. There's some that you sort of conditionally approved if they make the upgrades and they've gone ahead and make some of those upgrades. What are the major issues that you're finding as the sticking points? There's a number of rejected ones. I was actually interested to see how many were rejected.

Amy Merrill:

Yes, that's right. A lot of methodologies, the key issues are how additionality is demonstrated. Additionality is about whether or not a project would have happened anyway or not, or whether the carbon component was decisive in making that mitigation occur. A lot of the methodologies have been rejected and are rejected because the way that is evidenced is not robust enough. And it doesn't mean they're not additional, but it just means that the collation of the evidence to support that interpretation needs reworking. So that's been a real core area where we've seen a place where the market can improve. We also have usually close discussions around reversal risk when that type of project is at risk of losing the benefit due to some unanticipated event.

And a real area of focus for the assessments today is also about how we are ensuring that calculations are conservative and not accidentally over crediting or at risk of over crediting. And so really the area where we've seen the most rejections, the most need for changes is around those core emission impacts, core carbon principles. I think that, you know, one of the things we're also seeing is new methodologies being developed are just already hitting a much higher bar and designing themselves to make sure that they are going to meet the CCPs. And that shows that not just through the assessment process, but also through the market collectively, we are moving everyone towards high integrity. So, we've seen a lot of changes in the last two years.

Mike Toffel:

Yeah, is it your sense that some of the methodologies or many of the methodologies that have not passed yet that are listed as rejected, that they will strengthen their standards and come back to you for your seal of approval? Or do you think that they had one shot, and they tried it and they're going to move on and go on, live without the label?

Amy Merrill:

The assessment process in the ICVCM is across a sector. And so, when we reject a set of methodologies from different programs, it's really often a statement around the need for the sector as a whole to evolve. And renewable energy was a really good example. Those methodologies were in wide use and had been in use for many years. There's a real understanding that renewable energy has a big part to play in a carbon market and that carbon markets can incentivize deployment of renewable energy very effectively. And at the same time, those methodologies need to evolve. And that's the reason for the rejection. And so, we really expect those methodologies to come back in revised in the next year or so, if not before.

Mike Toffel:

And is the need for them to be updated because the cost of, for example, solar and wind have come down? And so the question of additionality in some areas, like, well, it's profitable to do it. that actually ought not merit the label of a carbon credit because it doesn't pass the additionality. Whereas in other areas, it still requires that additional finance for it to be viewed as profitable. Is that the wedge that is leading to that particular industry being flagged right now by your organization?

Amy Merrill:

In some cases, yes. And in some cases, it's really just that the methodology at a technical level provides a choice that needs more explanation or more underpinning. So sometimes broad issues around that, and sometimes just the technical presentation of the methodology itself.

Mike Toffel:

I see. And how ubiquitous is the label now? I think the label has been awarded or eligible to very few methods so far. Is that right?

Amy Merrill:

At the moment, we have assessed 38% of the market and only about 3 % of the market has passed. we do expect to see the figures change and more of the market to be labelled. It's also fair to say that about 20% of the market was excluded by those programs because they wanted to move on from those methodologies that that volume was issued under and have submitted newer versions of those methodologies to us for approval. And that was particularly the case in relation to what we call RED projects, which are reducing emissions and avoiding deforestation.

Mike Toffel:

Right, that's an area that's been somewhat controversial in the past and tracks media scrutiny. And so, there's been a big effort as far as I understand, and I guess you're confirming that, to upgrade those methodologies to sort of address some of the concerns that were raised.

Amy Merrill:

That's right, there's a newer generation of methodologies and some of those we finished the assessment on, and they were awarded the CCP approval.

Mike Toffel:

What's been the big difference between the old methods and the new methods in the RED or RED+ area just at a high level?

Amy Merrill:

Generally, the issue there is around quantification and making sure that the estimation of emissions reductions avoidance that would be achieved is conservative. It's generally a conservativeness related issue.

Mike Toffel:

I see, got it. So, these 3% of the methods that you've, 3 % of the market that have a methodology that passes muster in order to earn your label, are you tracking the extent to which credits with the label are flying off the shelves or are able to achieve a higher price to differentiate them from others?

Amy Merrill:

We know that the retirements of credits with the CCP label are going up as compared to retirements of other non-labelled credits. I think it's too early right now to say how we're seeing how the market will evolve once there are bigger numbers of credits in the market. And yet we are seeing and we are being told that there's a lot more interest in buying CCP-labelled credits.

Obviously the ICVCM is not set up to look at the sort of market pricing. One of the things we want to do is create this global threshold for integrity so that the market as a whole can scale and move towards a consistent and comparable market. So, over the year that comes, I think we'll expect to see more active trading of CCP labeled credits, new methodologies aligning more easily to the CCP's and everybody moving towards using the CCP's as the benchmark across the world, including governments and creating interconnected markets through the CCP's. So, it's a broader vision than just the trading.

Mike Toffel:

Yeah, it would seem like part of success would be not just on the retirement side, which is when folks sort of use the carbon credits to offset their emissions, but in the entry. So, at the project developer level, when they're saying, we're going to develop a project, I imagine you're going to want folks to sort of lean in and use the methodologies that you've approved. So, to the extent that we see that shift on the supply side, not just on the demand side. That's sort of what's critical to scaling up the high integrity credits. I think that's key to your mission. Is that my understanding that correctly?

Amy Merrill:

That's right. And I think we are already seeing that. And in fact, we started to see that in July 2023, when the framework was issued, methodologies in development being redesigned to explicitly address particular provisions of the framework. And that's really the goal, right? That all the innovation and difference that comes from really great project development and methodological development is all still underpinned by a really stakeholder-led and independent assessment of what good enough looks like. And I think that, you know, the more we see projects choosing methodologies that are CCP labeled, the more methodology development that is aligned to that, the easier it becomes for the market to scale as a whole and deliver, you know, the climate finance that the whole market is designed to deliver, you know, able to deliver on its purpose.

Mike Toffel:

Yeah, you've mentioned multi-stakeholder and stakeholder engagement a few times. I know that's part of the core to your organization's mission. So, let's dive into that just for a few minutes, if we could. So first, I thought I would ask about the other organizations in this space. So, there's other integrity initiatives. There are other private sector organizations that are curating, offering a curated set of carbon credits. There are rating agencies. There are companies providing insurance against reversals, all these different stakeholders, are they or a subset of them involved in your multi-stakeholder groups in terms of setting the bar and helping to assess the extent to which these programs and the methodologies are adhering to this bar? Or are you trying to keep more of an arm's length relationship to them?

Amy Merrill:

We work with all the stakeholders in the market and particularly the work we do in stakeholder engagement around continuous improvement. In the assessment process, we obviously manage interests, and we bring stakeholders to the table who are experts in methodology. In our work on continuous improvement, that's a work area around leading the market forward and bringing everyone together to agree what the next level of ambition in integrity and scale looks like. And there we have, you know, every voice around the table and that really brings a really holistic perspective on the process. We have methodological experts, we have representatives from our Indigenous Peoples and Local Communities Engagement Forum, we have activists, we have business, have sellers and buyers, we have academics and environmental NGOs. And together they all discuss those core issues and, you know, debate and engage with each other to understand what the next version of good looks like.

And so, one of the really interesting things about the ICVCM is the way it brings the market around a center point of discussion and enables everyone to share their view and engage in ensuring that carbon markets are high integrity and really help scale action and are really robust within the framework of all the other things that happen. And in our ecosystem, you're right, there are many actors, there are actors like Greenhouse Gas Protocol who teach companies how to report their emissions and calculate their emissions. There are disclosure organizations like CDP. There's target setting organizations like SBTI and our sister organization VCMI. I think you spoke to Mark who helped companies make the appropriate kind of claim and be transparent about how they use carbon credit. And then, in the wider ecosystem, of course, there are ratings agencies who do project specific risk ratings for investors and help manage and lower risk for specific investments, you know, many initiatives and alliances around particular sectors.

So, for example, nature-based alliances. So, it's a really vibrant ecosystem and everybody is trying to help get this market to an investable scale and a scale where it can operate and, be trustworthy and a market that we can believe in and be investable for large scale investments to help make that climate finance flow. So yes, the number of acronyms is quite exceptional in this space.

Mike Toffel:

So anytime folks talk about multi-stakeholder engagement, my head goes to two things. One is that's a great way to hear information you wouldn't have access to otherwise. And when conflicts arise, to help flesh them out by hearing different perspectives on the same issue and perhaps even forge some common ground so that there's more acceptance of the results.

But then there's another piece, the risk. Sometimes there is perception of conflict of interest in that if you hear this with regulatory rulemaking, depending on whether you trust the rule makers to incorporate information they're hearing from the regulated without being overly swayed by them. That's on the regulatory space. And you're in a quasi-regulatory role, a private regulatory role in the sense of rulemaking. And I imagine you have the very programs whose methodologies you're assessing are part of your stakeholders, no doubt.

How do you manage the perception of conflict of interest to ensure that you're availing yourself of the information that you need, but at the same time, protecting yourself against charges that foxes are in the hen house.

Amy Merrill:

So, we have really robust conflict of interest policies and when we're doing multi-stakeholder work on assessment, everybody has to sign conflicts of interest and confidentiality declarations. Obviously, people who are deeply conflicted can't participate. We take a really big tent approach so that one of the things you get is you get everyone's perspectives.

And we will, for example, we will have carbon crediting programs in that meeting to clarify their methodology so that people understand it, but they won't have an opinion. They won't be allowed to have an opinion on whether it should be approved or not. Right. And so, we have very robust and public procedures around how to manage those groups so that we hear those voices and that assessment, but they don't take decisions. The assessment they do is well balanced and well understood and views are recorded where they're different. And I think that that really helps because one of the things you get in that environment is the back and forth that pull out the really technical issues that some people will know, and others won’t, and some will be able to respond to. And so that some of those discussions are very, very technical and it really helps to hear different perspectives on how that is measured in practice or how you can put a safeguard in as a written condition in any kind of methodology. That process then is filtered through, right? So those assessments are then considered in the light of other things as well. Other academic information, other expert reviews, stakeholder input, all of those things. And there's a filtration process to make sure that by the time that gets to the governing board who take decisions, all of that has been balanced out.

We have really strict conflict of interest policies around the whole of the ICVCM and we use them very carefully to make sure that every decision is taken only by non-conflicted people. We have a very, very large governing board all under very detailed conflicts and disclosure rules and that helps us manage all the challenges that come with having a relatively small, technically competent community and a lot of opinions within it. And so, it's a really interesting discussion in any stakeholder group. Obviously, when we're working on thought leadership and continuous improvement, no decisions are being taken there. And the issues of conflicts of interest are generally much lower and the groups are really large, and people can join if they apply or can be invited. So, where we're doing the sort of thinking ahead work, those generally we're not in such a situation of having to manage conflicts of interest in quite the same way. But again, they all have to sign many, many documents and agree to many things.

Mike Toffel:

Yeah, you see the wisdom of having someone with legal training at the head of this organization. It's mighty complex. The other piece about the stakeholder engagement that I wanted to double down on is the idea of indigenous communities being a key stakeholder. That's one of the things I noticed in your organization was an emphasis that more so than I've seen in others in this space. So I wonder if you can talk about the genesis of that and what that looks like.

Amy Merrill:

Yeah, absolutely. I think at COP27, a group of Indigenous leaders came to the ICVCM team that were there and said there needs to be a voice space for Indigenous peoples. This is a market in which there is no platform for Indigenous voices engaging with them, with our Indigenous board members,

We created the design for a self-led hosted forum that was launched last year. And that's a forum of indigenous leaders representing indigenous people's local communities who have worked on developing their priority areas for the carbon markets and who are going to use that platform and that forum in a way that helps those communities to build out their voice, their understanding, their ability to interact, negotiate, engage on specific issues that are really crucial to making carbon markets high integrity from the social and human perspective. They have seven priority areas at the moment, and one of them, for example, is traditional ecological knowledge and the carbon market as a whole has not looked at that issue. And so, we're going to have a really rich experience of hearing from them and engaging with them as they build out the work they want to do. And ICVCM hosts them and is supported by a number of other partners.

Mike Toffel:

So how could their engagement and stronger incorporation of their perspectives actually affect the future of the carbon credits market?

Amy Merrill:

I think one of the things that we've seen generally in the last few years is the understanding that things that used to be called core co-benefits are core benefits, right? And understanding that carbon markets are scalable and usable for delivering carbon finance only where all the human and social and sustainable development issues are well understood and well incorporated and well managed. I can't speak for what the forum will do with their work or how they will choose to make issues that are important to them mainstream in the carbon markets. But we'll certainly be supporting that work and working alongside all those other initiatives that are looking to make sure that we understand that carbon markets need to be holistic in their nature in order to scale.

Mike Toffel:

Yeah. So, let's step up. This has been really helpful deep dive into the organization, but I wanted to step up as we exit our time together and just talk about progress and outlook. So, compared to when your organization was formed to now and then looking forward, what are some of the major trends you're seeing in the voluntary card markets? I mean, you're focused mostly on the supply side, right? On what is a credit and what counts and what should count. But if you have thoughts on the demand side as well, I'd welcome your perspectives.

Amy Merrill:

Yeah, I think one of the things that's really improving and changing is the recognition among governments of the role of carbon finance through carbon markets in delivering their policy mix for delivering their Paris Agreement obligations, what we call their NDCs, their nationally determined contributions, or their local regional decarbonization plans, resilience plans, adaptation plans.

And what will continue to happen is regional governments, national governments around the world are integrating carbon markets into their decision making. And the ICVCM is working with many governments to help them co-opt high quality supply through the ICVCM and make use of it for delivering on their own goals. So, we are seeing the market become less distinct in terms of supply and demand. ICVCM helps ensure the high integrity of independent carbon supply and it could end up in carbon being used by a company for a carbon tax. And we see that in Colombia, we see what Singapore is doing, we see numerous countries trying to use the whole carbon market alongside international carbon markets under the Paris Agreement to deliver finance into mitigation. And I think the next few years we'll see more of that.

And where governments are choosing to act, also know that that enables companies to choose to act. And one of the enduring challenges of climate change as a whole is getting companies to know that it's time to act and to choose to act beyond what they are required to do. And so, one of the things I think we'll see in the next few years is governments indicating just how much they do support carbon markets.

They all agreed them under the Paris Agreement. That was a universal agreement that carbon markets have a role. And getting companies to a place where they can really invest and play their part in their own emission reductions inside their business and using carbon credits in the right way as part of their decarbonization journey. So, I think it could be a really interesting few year.

Mike Toffel:

Great. And what about the future of your organization? Where is ICVCM heading? How many employees do you have now around the world?

Amy Merrill:

We're about 30 at the moment. We are all working very hard. We are distributed over about 10 or 15 countries now. And we've gone from being a startup to being widely recognized and endorsed by governments, having the support of most stakeholders. And importantly, the programs that were operating in the market before us, the big ones have all applied. And so, we have managed through this stakeholder process to bring everyone together and align towards the shared vision we all have for a scaled market that delivers good carbon credits, high quality, high integrity carbon credits and really unlocks private finance. And so, as an organization, we're very mission driven and I think we'll continue to be mission driven and work to deliver on all our work areas to support scale in this market.

Mike Toffel:

Great. And my final question that I ask all guests is, what advice do you have for those interested in learning more about this space?

Amy Merrill:

I think if you're a banker, you should start looking into all sorts of sustainability, finance, green bonds, climate bonds, those things. You should really understand how you can use financial spaces to leverage action. If you're a lawyer working on corporate transactions and projects on renewable and investment structures that reward green investment, that's really interesting. And then I think if you're in the kind of commercial auditing space, sustainability reporting and disclosure is a really interesting area. And generally, if you're in any commercial space at the moment, there is a part of your business that is looking at its emissions, how to reduce its emissions, its decarbonization plan, and its net zero, what it's going to do towards getting to net zero. And so, I think there's a real opportunity for really highly trained professionals and really committed individuals to actually use the system to engage in helping build awareness of just all the tools that we do have. We have many tools in different spaces to enable companies to take on decarbonization in a manageable way. And we have a lot of climate finance that we need to deploy through the private sector.

Mike Toffel:

Yeah. For those interested in the policy angle on this, where in the world would you say is the most exciting space to be engaging there? Is it at the UN level or COPs, or is it at the national or state or local levels, and where around the world?

Amy Merrill:

Right now, there's a lot going on in individual countries, particularly in the Asian region. There's a lot happening as countries try to bring carbon markets into their policy mix actively. Some of that's because of EU regulation. Some of that's because of specific regional incentives. But I think if you're in the policy space, you really need to look at what the business’s signals to government are in the country you're in and start trying to get involved in that agenda.

Mike Toffel:

So, what's the evolution of the voluntary carbon markets with public policy and the mandatory markets that governments are setting up?

Amy Merrill:

In the last few years, we've seen what really quite separate markets were start to all deliver in the same direction. And part of that is because of the integrity agenda within the voluntary carbon market, making it consistent and comparable and reputable and trustworthy and something that's investable. And part of it is also governments looking to find ways to broaden their policy mix and the levers they can pull on to bring mitigation in their own country, bring inward investment with carbon finance and meet their obligations under the Paris Agreement. And as different countries are looking at their policy mix and how to enable as much mitigation as possible, we start to see these markets converging and independent supply is being used in a number of countries to help companies meet compliance obligations, and there are a number of countries looking at bringing together voluntary demand and compliance, demand incentives. And that shows that when you start to think ahead for the implementation of policies throughout the world, these tools all need to be deployed, and they all need to be working together.

Mike Toffel:

Well, Amy, thank you so much for joining us. I've really learned a lot from our conversation.

Amy Merrill:

Thanks.