UK Carbon – Code Of Conduct

Written by Doug Wanstall from Re-generation Earth

We are in a climate emergency, it is down to everyone to make a difference and with that in mind a group of land managers, tech and finance experts have come together to ensure that farmers and land managers benefit from the burgeoning carbon market whilst ensuring a robust system of project approval, measure, reporting and verification (MRV) protocols is created.

The idea was borne in 2015 when one of the founders of the system, Doug Wanstall completed a Nuffield study looking at building financial resilience in farm businesses. It happened to coincide with the Paris Climate talks at which there was a lot of chatter about a project called ‘4 per mille’ A group of French scientists had calculated that if all the worlds’ soils increased their organic matter by 0.4% per year they could sequester all anthropological CO2. A massive undertaking but it was the lightbulb moment when Doug realised that land management and more importantly change in land management would play a significant role in the reversal of climate change and biodiversity collapse.

After an exhaustive 5 further years, gathering information, reading reports and putting together a dynamic group the UK Carbon Code of Conduct and its associated block chain enabled carbon tracking, registry and market place is ready to be launched in Q1 2022.

It was important to the group to ensure that the system was robust and capable of being scrutinised by investors, press and those that may wish to accuse carbon credits of being no more than a way that big companies can ‘greenwash’ their operations.

The code and associated immutable information system have been developed to ensure that the carbon credits issued from UKCCC approved projects are fully fungible, investment grade offsets, capable of assuring any customer of their validity. UKCCC approved projects have to uphold the 4 pillars of the code, Assured Permanence, Assured Additionality, Avoidance of Leakage and the Avoidance of negative outcomes. It is of vital importance when developing projects that issue carbon credits that the projects go through a thorough process of approval, otherwise a land manager may run the risk of having to pay back money paid for credits that turn out to be less than robust. 

Sequestered carbon needs to be additional and occurred due to the change in practice that is being rewarded. Projects are long term, usually 25 years and reward a trend in actual, measured sequestration into soils, timber, biomass and biodiversity habitats. Tenants can partake in the process as long as they have a minimum 5-year term. They have to actively engage with their landlord who should give approval to enter a long term agreement. If a tenancy ends then soil tests are taken and the outgoing tenant will be issued the credits accrued to date. The same soil tests then become the baseline for the incoming tenant and the whole project is assigned. So far landlords seem to have been receptive to this approach.

Why write a new code? The answer Doug responds is simple. Globally there are a range of carbon codes with the Clean Development mechanism being amongst the originals and the Gold Standard and Verra following on as the main global leaders. Discussions with all 3 led the team to realise that none of them were going to work in the UK as they were simply too costly and complex, meaning much of the benefit of offset investments was lost in the cost of administering the scheme. In addition, the team, having spoken to a carbon exchange based in Geneva realised that they were buying Gold Standard credits from third world countries for less than $10 per tonne and selling them to their European clients for over $30 dollars per tonne, again delivering little or no benefit to the ones on the ground doing the work IE the land managers.

Back home in the UK there was the Woodland Carbon Code and Peatland carbon codes, both very sector specific. There is talk of a soil carbon code and groups developing grassland, hedgerow, wetland and salt marsh codes, the team decided a single code that could encompass all of these elements was most likely to work and be accepted by the majority of landowners. The UKCCC is a single set of standards that each project has to adhere to, then depending on the elements adopted by the project there are a range of MRV protocols to follow that measure, report and verify the outcomes of the project. This means that whole landholdings and even landscapes can become a single project and benefit from carbon sales. New woodland, wetland creation, a move to regenerative agriculture, carbon cropping, biochar production and use, agroforestry and biodiversity habitat creation can all be approved under a single project. 

The aim is that the UKCCC is nimble and that it adapts to new and innovative ways to remove atmospheric greenhouse gases. The UKCCC will look at all nature-based solutions that can deliver additionality and permanence as long as a suitable MRV protocol have been developed. The code actively responds to the latest UK Climate Change Committee reports and other scientific and research papers, the aim to ensure best practice at all times and to respond to latest climate thinking. The code has a technical committee that works on the version cycle and in the early days new versions will be released as the consultation process continues.

The approval process is simple but robust. The first stage is to appoint a UKCCC approved project developer with whom the project host will develop the project and help the host move through the approval process. The project developer will help identify the opportunities on any farm and will have an in-depth knowledge of regenerative agriculture as well as the UKCCC approval process. The next two steps are vital, firstly to establish the project hosts current net CO2 position and secondly establish the baseline.

No project host can sell carbon without first being carbon neutral. Currently the UKCCC does not insist on any particular carbon calculator use but this is likely to change as the UKCCC looks to build uniformity in the system. Either way, it’s important to be honest with the information that gets logged, the project developer will challenge many of the report findings. Baseline soil tests are one of the most important elements and should be taken as soon as possible, regardless of how, if or when a land manager might be planning to sell excess carbon. One of the main pillars of the UKCCC is additionality and nothing counts before a baseline has been taken. Historic tests can be used but a higher discount factor may be applied depending on the type of test and how many samples were taken.

Once these two elements have been established the project design process can begin. The project developer will walk the landholding with the host and discuss the options, the aim will always be to help maximise the opportunity. They will look at whether the host has a desire to move to more regenerative practices and help the host along that journey, look at how nutrient use can be optimised, where opportunities may exist to convert some land to biodiversity projects, if agroforestry is a desirable option or growing carbon crops that sequester large amounts of CO2.

Once the project detail has been discussed a project plan template is completed along with the associated documentation and an annual monitoring plan completed. Once all this is done the project is forwarded to the UKCCC for final approval or comment. The UKCCC undertakes to approve or make suggestions for amendments within 28 days. Once approved, credits are issued on an annual basis less a discount factor dependant on the risks associated with the project. The discounted credits are held on the registry but in a buffer until successful 5-year verification that measures the actual outcomes of the project. Exceed the planned outcome and more credits are issued, not meet the planned outcome and the required number of credits are deducted from those held in the buffer.

Every year the project developer conducts a light touch audit with the project host to ensure all is on track, update any best practice learnt in the interim and to complete the annual monitoring report. The UKCCC system may seem onerous but it is amongst a small number of carbon credit issuance schemes that will stand up to extreme scrutiny and ensure that neither the project host nor the customer for the credits can be accused of green washing. More often than not reducing carbon emissions makes good business sense in the first instance, the lower a landholdings carbon footprint the greater the opportunity to sell excess carbon. 

The recent announcement of further detail of DEFRAs much vaunted Sustainable Farming Initiative contained no surprises and is actually a big help to those wishing to start the journey of regenerative agriculture. Those entering the scheme will have to test for soil organic matter, something that will help to establish the baseline required to enable carbon sales. A soil health management plan will form part of the UKCCC project design process and will help satisfy the requirements of the SFI.

The UKCCC is onboarding project developers now and these can be individuals, companies, land agents etc. Project developers need to have an in-depth knowledge of regenerative agriculture and have a keen interest in working with the code to continually improve the system. The aim of the UKCCC is that it becomes part of a wider eco system of people, land managers, businesses that all have the shared goals of reversing climate change and biodiversity collapse.

Expressions of interest are being taken now to join the scheme to enable project hosts to start the process in early 2022. In the first instance interested parties, both land managers acting as project hosts and potential project developers should send a short email to info@ to register their interest.