CRS comments in response to the Advanced and Indirect Mitigation (AIM) Platform, Intervention Quality, Accounting, and Reporting (QAR) Standard

The Advanced and Indirect Mitigation (AIM) Platform, convened by C2ES, Green Market Activation (GMA), and Gold Standard, has put out its Intervention Quality, Accounting, and Reporting (QAR) Standard for public consultation. CRS’s comments center around four key factors:

• Some requirements do not align with how certain market-based instruments (e.g. EACs) operate in practice.
• Key terms such as “intervention outcome”, “physical”, and “regulatory surplus” are not consistently or clearly defined, creating ambiguity in how to assess whether hosts meet minimum standards.
• Reporting companies may have limited visibility into safeguards such as protections against double selling or co-claiming, which are typically assured through third party certification rather than host-level disclosures.
• Registries often to not collect the data elements referenced in the Standard.

CRS requests clarification on many key elements of the Standard and puts forth recommendations for better alignment to best GHG accounting and reporting practices.