By a Certified Forest Steward, Master of Science in biomedical engineering, and Human Factors Engineer who can provide supporting citations to peer-reviewed scientific articles.

Depiction of how carbon credit is estimated. The individual must have offset her own environmental impact before she may claim to have carbon credit.

Figure 1.
Any individual may use her carbon removal activities to offset her lifetime environmental impact, as depicted by the green line. She may accumulate carbon credit only after she has thus become lifetime climate-neutral. She becomes a carbon creditor as soon as she so accumulates carbon credit depicted by the yellow line.

Other types of carbon tokens include the supply chain token representing one gram of CO2 removed and the carbon emissions avoidance offset token representing one ton CO2 emissions avoided.
Carbon credit = lifetime GHG removal minus lifetime emission.
One carbon credit = 1 tonne carbon dioxide emissions removed = 1 tCO2e
One supply chain Green Token = 0.001 carbon credit.
One comprehensive lifetime environmental credit = 1 tCO2e of all environmental impact
Emissions avoidance = zero carbon credit.
Corporate fabricated carbon token = zero carbon credit.
Government carbon token = zero carbon credit.
Carbon tax = zero carbon credit.
Carbon emissions token = one metric tonne CO2 emitted.

A climate-neutral agent conducts an activity of generating/producing carbon credit by protecting the environment that removes carbon dioxide from the atmosphere. An agent generating/producing carbon emissions tokens by emitting carbon dioxide into the atmosphere. All asset backed tokens are transferred at the expense of the recipient of the token from the generator/producer. Thus, the net emitter who is seeking credit pays for all of the research, verification, validation, and transaction fees. If the carbon creditor has paid for any of those services, the net emitter repays her through a fee tacked onto the true cost price which is represented by the token.

On blockchain, each carbon credit is represented by a NonFungible Token or a unique token ID to prevent double counting. Lifetime climate-neutral individuals have the right to trade carbon credits as we please. However, once the credit reaches a net emitter, it is used to offset her emissions which takes it out of circulation. The beneficiary is the final recipient of the token or NFT. The beneficiary may present her token ID to her government along with her estimated greenhouse gas emissions which may be verified by NASA or NOAA satellite data. The government may accept the carbon credit token to offset her greenhouse gas emissions or as payment of carbon tax on emissions. All goverments must check each token ID with a registry of previously paid tokens for uniqueness to prevent double counting. Blockchain solutions exist for this purpose.

Assigning agency to organizations but not to individuals risks corruption by individuals who have nothing to lose by disabling the organization from compliance with the law that is based upon natural law. For example, some corporate executives do not count environmental costs in their accounts. The thereby fabricated profit and related bonus for executives and stock dividends for shareholders are not adequately taxed to pay for environmental repairs. A healthy conscience is required to voluntarily contribute to pay for environmental repairs. Therefore, an individual is more likely than a corporation to voluntarily contribute to pay for environmental repairs.

Taxing an organization might require enormous externally applied energy to create compliance. A government has a huge environmental impact that may be too complicated to measure. An organization mignt be too big to fail and may lack a conscience as an intrinsic motivator. For example, Patagonia has chosen a business model that channels some finances to a 401(c)4 lobbying firm. That firm could try to convince legislators to develop law in favor of the corporation or the climate required to create a demand for the corporation's products. Or, it could contribute directly to payment for environmental repairs to protect its revenue stream from selling camping equipment to customers who require a healthy or stable environment for camping. Different corporate products require different climates to manufacture demand for their products. One corporation could sell more outdoor hiking gear if the atmosphere were conducive to outdoor hiking. Another corporation could sell more oxygen generators if the atmosphere lacked enough oxygen to sustain human life.

Legislators should legislate climate for habitability by bare individuals instead. Individuals need oxygen and moderate temperatures to survive. Organizations are not environmental stakeholders because they do not. Governments and other organizations are operated by individuals. The individual is the stakeholder and, therefore, has standing to make a claim upon the Environmental Protection Agency Fund or any carbon tax. Thus, the basic unit of agency is the living individual. The individual carbon creditor has postponed climate change. Therefore, any fund should be administered by and benefit the individual carbon creditor.

Specifically, the standard agent is a living, breathing, being of flesh and blood. Everything else in the analysis of her activities is her environment. She is accountable for the consequences of her past activities that changed the state of her environment. Her environmental impact includes the health improvement or detriment caused by all of her activities. It includes her activities on behalf of any organization. For every automated activity, she is responsible for the environmental impact in direct proportion to her financial support of the automated activity. For example, the agent who caused the activity of a device or robot is responsible for the resulting state change. Specifically, the individual who uses the cell phone is responsible for the environmental impact of using the cell phone while the individual who mined the gold to integrate into the cell phone is responsible for the environmental impact of the mining. Therefore, every individual is responsible for the environmental damage she causes through her choice of activities. Consequently, an organization may pay the carbon tax or offset for its individuals (officers, employees, contractors, etc.) only by paying the individual who may then pay the carbon tax or offset.

Net positive environmental impact includes the effects of poaching, vandalism, workplace mobbing, human trafficking, and other activities that change the lifespan and healthspan of living organisms. It includes the number of deaths caused by the emissions of one additional metric ton of CO2. In the baseline emissions scenario, the 2020 MCC is 0.000226 excess deaths per metric ton of 2020 emissions.

A net positive impact on the environment is only possible through sustainable environmental stewardship. Every living human has a negative impact on the environment. She has a negative impact when she emits carbon dioxide into an already overburdened atmosphere. She may reproduce genotypes or only phenotypes through influence alone. She has an impact upon the environment and biodiversity through reproducing her genotype. For example, having one fewer child prevents 58.6 tonnes CO2-equivalent emissions per year for developed countries on average (Seth Wynes and Kimberly Nicholas 2017 Environ. Res. Lett. 12 074024). Sustainable environmental stewardship requires positive environmental impact that fully compensates for the negative environmental impact, as depicted in Figure 1. As explained above, only a living agent with lifetime net positive environmental impact has any standing to claim carbon credit. Therefore, carbon credit is only available from individual carbon creditors.

A net emitter does not have carbon credit but may offset some of her lifetime emissions with the carbon credit she pays for. Whether on blockchain or off, the transfer of a carbon credit to a net emitter converts the creditor's carbon credit into the net emitter's carbon offset. As stated above, the net emitter pays for the research, verification, validation, and transfer of carbon credit. Each net emitter must accept carbon credit at the rate extimated by hard science without conflict of interest. A carbon credit is worth $10,000 to $750,000 per ton based on details of the geophysical and economic scenarios (Archer, Kite and Lusk, Climactic Change, July 15, 2020. DOI: 10.1007/s10584-020-02785-4 University of Chicago news).

All functional goverments reward/enforce either offsetting or taxation of each individual on all of her "greenhouse gas" emissions above a quota to sustain environmental health and stability. That emissions quota must be limited in order to restore wildlife habitats and genetic diversity to their states in existence in 1965, as much as possible. If everyone had refused to work in the fossil fuel and cattle industries since 1965, then the demand would have been for alternatives instead. News publications provided notice https://www.climatefiles.com/climate-change-evidence/presidents-report-atmospher-carbon-dioxide/ for individuals to begin accounting for and reducing emissions in 1965. Thus, only the people conceived before November 5 in 1965 were excusably oblivious to the climate change that results from human activities.

Those 3.4 billion people alive in August of 1966 https://en.m.wikipedia.org/wiki/World_population were already increasing global warming with a carbon footprint of 12 billion tonnes CO2e/y total, https://www.c2es.org/content/international-emissions/ which is 3.53 tCO2e/y each. Thus, the annual carbon quota for each of those seniors (over 55 years of age) may be a value between 3 and 3.5 tCO2e/y. That quota may be determined only by unanimous consent of a team of experts from all hard sciences without conflict of interest.

Each of the above mentioned seniors may relinquish to her closest blood relative her annual carbon quota upon retirement or death, to maintain genetic diversity. Upon her death, her government's social safety net shall divide her quota among her children (or closest blood relatives not involved in her death, if she has no children).

The annual carbon quota is exempt from taxation. The annual carbon quota for each individual born after August 5 of 1966 is equal to the annual carbon quota transferred to her. Thus, she must offset or pay carbon tax on all of her emissions if no such quota has been transferred to her.

The carbon tax on net emissions above the quota pays only for high integrity verification, including all costs of verifying direct (Scope 1) carbon emission and removal since 1965 for every individual. Thus, government officials transfer all of the EPA Fund and all collected and owed carbon tax to living, breathing, individual carbon creditors for (1) a safety net upon retirement or (2) verifying environmental impact within the scope of their certification using equipment that runs on zero-emissions power. Therefore, there is no need to calculate any emissions besides Scope 1.

Each high integrity verifier should serve for a maximum of six months to maximize the quality of work and to prevent corruption or office politics. Validity is maximized by verification that follows the advice provided by the most-cited expert from each hard science discipline who lacks conflict of interest with the environment. These scientists set and update standards for CREP and other federal programs that are already geared for environmental crediting without conflict of interest. Hard science sets
carbon pricing standards,
standards for authorization of verifiers including field inspectors,
standard measuring and monitoring methods,
measuring equipment operating procedures, and
program standards that include comprehensive lifetime environmental impact outcomes in reporting.

Those scientists also standardize units of measurement for all asset-backed tokens and cryptocurrency. For example, the environmental creditor may use the carbon credit token to represent extended lifespan and all other types of environmental assets.

Governments facilitate all functions related to authorizing individuals to operate nodes or platforms. These individuals are the agents who may change the state of the blockchain or other reliable record-keeping platform. The authorization defines their role. Their activities may include to issue, hold, transfer at standard but not market rates, and verify proof of stake, authority, and humanity (KYC checks). The things they may act upon include crypto instruments or tokens that are backed by any asset. Responsible government agencies remain separate from each other with no revolving door or other obstacle to the appearance of justice. Only human environmental creditors may operate high integrity platforms that assist users to verify and certify high integrity carbon credits.

An individual could prove to a court that she owned the public key associated with a transaction. To determine jurisdiction, she would need to know the citizenship of the other person involved in the transaction. Because, any individual with standing may bring a claim for fraud in any court of appropriate jurisdiction. It would be unfair for a corporation to accumulate tokens. It could fold or change its name. It could claim to lose tokens during a hack. Court proceedings impair the health of the individual in court against a team of corporate attorneys. Thus, any individual but no organization may hold, receive, use, or be the beneficiary of crypto instruments or tokens. Therefore, high integrity asset backed cryptocurrency transactions require proof of humanity and citizenship to establish standing and jurisdiction. Those and the associated public keys comprise the only information that need be made publicly available about crypto instrument or token holders.

Standard permanence is one year since standard carbon dioxide removal by trees is measured in tonnes per year. Thus, ten carbon credits are worth ten tonnes of CO2 removed per year or ten years of removal of one tonne per year. The cost of permanence enforcement may include security guard patrol which may cost about $600,000/year, which might also cover the cost of social integrity enforcement. These hazardous occupations are crucial for extended permanence because poachers and vandals dissipate or hide assets and refuse to become climate-neutral or to pay any tax.

Most organizations must hire human factors engineers to design facilities and operations for permanence enforcement or social integrity enforcement. Why didn't the Shell and Tokyo Electric Power Company engineers design the Niger Delta and Fukushima facilities to prevent damage from vandalism and tsunami? How do local prosecutors prevent poaching, vandalism, and workplace mobbing? Where they fail, who verifies whether human trafficking or workplace mobbing took place? Which government or other organization counts human factors and environmental factors?

The above is a draft of the consultation I am obliged to provide to https://icvcm.org and https://verra.org both of which demanded that the public provide consultation and may compensate us therefore, or may attempt to use our silence as consent if we do not. You may likewise provide your consultation at https://icvcm.org/public-consultation by September 27, 2022, and at https://verra.org/public-consultation-verras-approach-to-third-party-crypto-instruments-and-tokens/ by Sunday, 2 October 2022, 11:59 pm Eastern time.

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