From Corporate Standard to Climate Policy: The Greenhouse Gas Protocol

The Greenhouse Gas Protocol is the global standard for how companies measure and report their greenhouse gas emissions. It is used by most large companies worldwide and increasingly underpins climate disclosure requirements in places like the European Union and California.

Originally developed outside of government, the Protocol filled a gap at a time when policymakers had not agreed on how emissions should be measured. But its role has evolved, and what began as a voluntary reporting tool is now becoming embedded in climate policy.

As its influence has grown, so has scrutiny. Questions about how emissions are counted have persisted. More recently, attention has turned to how the Protocol itself is governed, including how decisions are made, who has influence, how scientific input is handled, and how transparent the process is.

Danny Cullenward, senior fellow at the Kleinman Center and a member of the Greenhouse Gas Protocol’s Independent Standards Board, discusses how the Protocol was developed, how its role has evolved, and the challenges it faces as it takes on a more central role in climate policy. He also examines whether recent governance changes go far enough, and what is at stake as the Protocol continues to shape how emissions are measured and reported.

Full Transcript

Andy Stone: Welcome to the Energy Policy Now podcast from the Kleinman Center for Energy Policy at the University of Pennsylvania. I’m Andy Stone.

When companies report their greenhouse gas emissions, they usually follow a common set of rules. Those rules come from the  Greenhouse Gas Protocol, which was developed more than two decades ago and is now the global standard for corporate emissions accounting. It’s used by most large companies worldwide, and increasingly, it also underpins climate disclosure requirements in places like the European Union and California. The protocol was created outside of government by a partnership between an environmental group and a business association. At the time, policymakers hadn’t agreed on how companies should measure and report emissions, so the private sector stepped in to fill that gap.

But the protocol is no longer just a voluntary reporting tool. It’s increasingly finding its way into climate policy. And as its role has grown, so has the scrutiny. Questions about how emissions are counted have persisted, particularly around accounting approaches that can make companies look cleaner on paper than in reality. More recently, concern has expanded to how the protocol itself is governed, including questions around who is involved in decision making, how scientific input is handled, and how transparent the process is. In response, the protocol has taken steps to formalize its governance, creating new bodies to oversee how standards are developed and updated. But there is debate around whether those changes adequately address concerns at a time when confidence in the protocol matters more than ever.

Here to explore governance concerns relating to the protocol is today’s guest, Danny Cullenward. Danny is a senior fellow with the Kleinman Center and a member of the  Greenhouse Gas Protocol’s Independent Standards Board. He has written a report available on the Kleinman Center’s website about how the protocol is governed and the challenges it faces as it takes on a larger role in climate policy. Danny, welcome back to the podcast.

Danny Cullenward: Thanks, Andy. It’s great to be here. Nice to talk with you, as always.

Stone: So let’s start this rather complicated project with a level set here. I want to ask you, just to start out, how do you usually explain the  Greenhouse Gas Protocol to someone who’s never heard of it? And what problems was it originally trying to solve?

Cullenward: Yeah, it’s a great question. The simplest way to think about it is, it’s a rule book for how companies can report their own greenhouse gas emissions. It’s important to contextualize this. This is about corporate emissions reporting. So this is not an accounting system for how countries manage their emissions or how treaty processes work, but it’s about how companies do those same kinds of activities. And it’s a set of rules that explains how companies can and should do that.

That’s also— in a certain sense, it’s a permission structure. So imagine you’re a company that for whatever reason wants to make these disclosures. Maybe you want to do it, maybe you’re compelled to do it. This is a structure that says here’s how to do it. And it’s okay if I’m following these rules because I’m not going out on my own. I’m doing what a process and a system that a lot of people have now bought into says it’s okay and appropriate. So it’s a way to sort of coordinate the problem of how companies should do this, to give them permission and confidence that they’re doing it in a standardized way that will give them respect and authority.

Stone: The protocol didn’t come out of government. It came from what’s been called an example of, quote, “entrepreneurial private authority.” What was going on at the time that allowed this to develop?

Cullenward: Back in the early days of the United Nations Framework Convention on Climate Change—  that’s the 1992 treaty that set up all of the international negotiations around climate— there was a lot of attention focused on how governments should do their accounting and their reporting, including under the first major effort to reduce emissions under the UNFCCC Treaty, which is called the Kyoto Protocol. That came out in 1997.

So governments who were negotiating these issues spent a lot of time on how governments should report their emissions to the UNFCCC as part of this treaty process. And there was actually quite a bit of debate and specificity on how that was to be done under the Kyoto Protocol. There wasn’t an agreement and there wasn’t nearly as many outcomes as would apply to the corporate sector. So there was basically no agreed upon way to do this.

And in that vacuum, there was both a challenge and an opportunity. So if you were a company at the time thinking about these issues who wanted to lead, you might want to sort of start to disclose emissions or demonstrate that you’re taking actions to reduce your emissions. But there was no standardized way to do that. And there was no broadly accepted way to do it. So even if you wanted to do this for all the right reasons, you faced risks as a first mover going out on your own.

And for other kinds of companies that maybe had a more neutral or even negative attitude towards climate policy, they might nevertheless think, “Hey, something’s coming. And we need to figure out how to do this in a standardized way so that we’re prepared and we get ready internally to work with climate policy systems that may emerge in the future and may apply to corporate emissions in the future.”

So I think both of those sets of interests combined to create demand from the business community for some kind of standard or approach. And exactly as you said, my colleague Jessica Green, who is a political scientist at the University of Toronto, she studied this question of private authority and climate policy. And she’s called this private entrepreneurial authority. Because in this gap of regulatory policymaking, a private effort emerged that tried to address the same kind of issue you might think a government would do, but it emerged out of the private sector because there was no government agreement and it sort of filled that gap with a new approach.

Stone: In the intervening years, this has been very successful, very widely adopted. It’s used by most major companies. I believe 90% or more Fortune 500 companies now use the GHGP. And it’s also showing up ever more in regulation. How did it earn that level of trust over those years to be so widely adopted?

Cullenward: And I think it’s really important to start with, it is widely adopted. It’s remarkable how broadly adopted this accounting standard is. Very few approaches to standardization ever reach that level of coherence and adoption. And I think it begins with, basically, the partnership of the two co-host organizations that sponsor this protocol. So we talk about the Greenhouse Gas Protocol. That’s the rulebook, that’s the process. It’s not actually a separate entity. It’s a project of two other organizations, as you mentioned earlier. The World Business Council on Sustainable Development, or WBCSD. And that’s a business association based in Geneva. And the World Resources Institute, an environmental NGO and think tank that’s based in Washington DC.

And I think these two organizations brought the combined legitimacy that was necessary to create those conditions. WBCSD’s involvement helped give the protocol legitimacy within the broader business community. So I think that’s really essential to the outreach and diffusion of the standards adoption. Meanwhile, WRI is more associated both with environmental work and their research products. Their technical expertise, along with the expertise of hundreds of volunteer technical experts who helped develop the protocol over years, that’s what helped give the protocol legitimacy in the nonprofit world in civil society. And I think it’s the combination of those two sort of stakeholder groups that reflect the adoption rates you mentioned earlier.

Stone: One of the issues that comes up and has come up over the years is a tension between being scientifically rigorous and actually having a framework that is also workable for companies. So I want to ask, where do you see that tension showing up? Can you give us a concrete example of where maybe emissions numbers might look better for a company or organization on paper than what’s actually happening in reality?

Cullenward: Sure. Let me give you an example from sort of the legacy world of the standards— the existing standards, not the process to update them that’s currently ongoing. And we’ll get into some of the newer challenges as we go. I would say at a high level, the answer to your question is, this issue was handled organically and sort of informally, because the protocol was previously lacking a formal governance structure. It was an organic creation of its co-host organizations and again, the many hundreds of people who volunteered to provide input.

And I’ll give you an example where the old standards, broadly agreed in the academic community, don’t produce the most accurate information. And that has to do with the treatment of electricity sector emissions. In the electricity sector, under the legacy rules, companies can report either so-called physical emissions or market-based emissions. And many of them choose to report or choose to set targets based on the market-based emissions. And what this means in practice is that companies can buy renewable energy certificates and other environmental attributes and claim to have zero emissions associated with their corporate footprint, with their consumption of electricity.

Now, I think everybody agrees it’s good to encourage renewable energy, it’s good to promote solutions, and there’s an important connection between what one allows a company to report and the outcomes it creates in the world. But I think there’s been pretty broad criticism of the way this reporting element works in the status quo. Renewable energy certificates can come from very distant places that don’t physically deliver power to where a company is actually using that power. There’s no temporal matching. So for example, you could claim to be using solar electricity at night, which we know is not physically what is happening on the grid, but it’s nevertheless allowed in the accounting terms under the status quo. And there’s also no additionality requirements. So you can buy existing clean resources and say you don’t have emissions, even though those resources already existed before you started consuming electricity.

So there’s a number of tactical issues with the way that’s reported. And a lot of companies who use this reporting method say they have essentially zero emissions in the electricity sector, when we know, even if they’re helping to make progress, nobody’s really quite there yet.

Stone: The role of the protocol has changed from being still, I guess, primarily, a voluntary reporting tool, to something that regulators and markets are increasingly relying on. What’s driving that shift? And I want to ask, where is the  Greenhouse Gas Protocol actually showing up in government-driven regulation?

Cullenward: Yeah. It’s an interesting situation, because when the protocol first started, it was all for voluntary applications. And I think in that environment, of course, everybody’s seeking accuracy and comparability of data. But you can imagine that more tolerance from imperfection is okay. The idea that we’re experimenting and we’re learning and we’re trying to get better over time.

But you’re seeing more and more applications where companies not only are doing this sort of categorically, this disclosure activity, but they’re also being required to disclose. And my two favorite examples, the European Union has been integrating this into their financial regulatory structure. And here in California, where I’m based, California has a law that’s going to require basically all large companies to report their emissions using the protocol’s accounting framework. So this is moving from a voluntary application to a mandatory compliance application. And in parallel, the protocol began setting up, a couple years ago, a new governance structure that was designed to formalize the way this process is governed to put some structure and rules, which you tend to see in mature, private, standard setting organizations. But of course, not when they first begin. Typically, they begin more informally. And as they mature and including as they’re adopted into government policies, you tend to see maturation of the governance process. And that’s what we see here.

Stone: So these accounting rules are already in place and governments have adopted them. It sounds like a very efficient way to get those rules into regulation.

Cullenward: Yeah. I mean, if things are going well, this becomes a way to surface all of the technical complexities to bring them into a multi-stakeholder process. And again, if it’s all gone well, you produce a reasonable set of answers that can be incorporated into a government policy. So if you think this is all going well, you simply adopt the protocol, right? And that absolves the government regulator of the need to build all of this accounting infrastructure from scratch. And you can imagine that’s a very attractive proposition to resource-constrained policymakers who are looking to build more accounting information and more disclosure, but maybe don’t want to spend 20 years doing it.

Stone: Okay. You mentioned also the issue of governance. And this is really getting into the heart of our conversation today. So I want to ask you just point blank, why does this shift now start to raise some governance concerns?

Cullenward: Well, I would say there’s two main things that call for more governance. One is that as this protocol is being integrated into formal regulations, there needs to be, I think, more confidence that the system is being governed well. It’s one thing for a private disclosure system to be privately regulated. But if it’s going to be part of a mandatory disclosure regime, you can imagine it’s important to be able to demonstrate that the process has integrity, that there’s rules and structure, and that the overall quality assurance and process rules are being followed.

Another reason that it’s important to have more governance is, as the scope and complexity of the issues grows, so too do the governance concerns. So the protocol’s recently released guidance on how to handle emissions and carbon removals in the land sector, as well as carbon removals more generally. And those are technically complicated areas where having some additional governance structure can help provide assurance that the process is going well and that rules aren’t being created out of thin air. So I think those are sort of two reasons that there’s a demand for more governance and why there’s sort of higher expectations on the protocol’s process overall.

Stone: There is a stakeholder process by which the accounting rules and the rules for the  Greenhouse Gas Protocol are made. And that’s really important to the governance here and understanding some of the issues we’re going to be getting into. Could you walk us through how decisions are actually made today? And if something important changes in the rules, where exactly do those changes happen, or where are they made?

Cullenward: Yeah, it’s a great question. Maybe let me start with how it used to be. And to be fully transparent, I wasn’t involved in the predecessor regime, so I can only speak very loosely. But my sense is it was relatively informal. And there were what are called technical working groups of volunteer experts. They might come from industry, they might come from the research community, they might come from NGOs or civil society. And they would collectively advise on the rule setting process, which was managed by what we call the secretariat, meaning the staff of the two organizations, WBCSD and WRI, who co-host this process. And that was a fairly informal exchange between those two communities. Under the current governance regime, which is much more formalized, there are now four separate actors.

Stone: And that was changed in 2024? Is that when this new governance structure came into place, just to make sure I understand that?

Cullenward: I think it was 2022. I’m trying to remember when they announced this. And the board of which I’m a part was constituted in 2024. So it’s a recent transformation for sure.

Stone: So that’s when the formalization happened.

Cullenward: Correct. Yeah. So we now have four different actors. There’s the secretariat— again, the staff level contributors from the two co-host organizations. Their job is to coordinate the process and to develop the regulatory text. We have bodies called technical working groups, which are these multi-stakeholder groups. They can be a couple of dozen up to many dozens of technical experts intended to represent a broad range of perspectives relevant to each of the topics they work on. And these technical working groups, they develop recommendations and provide technical input to the secretariat in the drafting process. They’re the main source of external expertise.

We also have what’s called an Independent Standards Board. And that’s the body of which I’m a part. The Independent Standards Board appoints the technical working groups. It provides guidance to their work and to that of the secretariat. And it ultimately makes decisions if there isn’t consensus or agreement at the level of the technical working groups. Those decisions are taken and made by the Independent Standards Board.

And above all of this sits the fourth body, a steering committee, whose job is to ratify the process and to ensure that the rules were followed. So there’s a bunch of rules now about the process and the roles. And the steering committee is in charge of ensuring that everything is operating according to those rules with that new layer of the board underneath them, providing more formal governance structure and substantive oversight over the original work of the secretariat and the technical working groups.

Stone: And you are on the Independent Standards Board.

Cullenward: Correct.

Stone: The protocol does talk a lot about being multi-stakeholder. I want to understand, what are the different stakeholder groups that are involved in work around the protocol? And I guess a key question that arises from that, in practice, who really wields the most influence in the process?

Cullenward: I would call out three broad stakeholder groups. And I don’t mean to dismiss anybody else, but just to give listeners a sense of the sort of main groups. There are industry communities, there are environmental NGOs and other elements of civil society, and there’s scientific or research community members. And I think of those as the three main stakeholder groups. Again, people might fit better in one or the other, and there might be other cases, but those are the three main ones.

And the general concept behind the protocol is that we want to have representation in the technical working groups that’s reasonably balanced across the different stakeholder groups. We also, in theory, have a decision-making hierarchy that applies to all of the decisions in this process that says science comes first. So, at least in theory, if there’s a disagreement, if there’s consensus around the science, that’s supposed to carry the day.

I think, in practice, it’s a little bit more challenging. You don’t see, necessarily, equal representation on the technical working groups. They tend to be a little tilted toward the industry side. And there’s sometimes questions about balance within industry.

So, let me give you an example. We’ll talk later about an issue involving forest carbon accounting and questions about how we attribute emissions and removals to forestry-related activities. If you look at the technical working group that was appointed for that body, you will see representatives from the landowner community, including NGOs and industry groups that own forest lands. You will see scientists, and even a couple of environmental NGOs. But what you won’t see is industries that represent competitors with forest products. So, you could imagine we use timber to build buildings, but we also use cement and steel. And you could imagine that cement or steel would have an interest in ensuring that there’s an accurate treatment of forest emissions and removals, because if their competitors get preferential treatment, that’ll be bad for them.

So, I just raised this as an interesting example of balance. It’s actually really hard to achieve. And the closer you look, I think the more you see that balance is often a challenge, and you can quickly get less-than-complete views in these groups.

Stone: So, the absence of stakeholders from, say, the cement industry. Help me understand why are they not present?

Cullenward: You know, I don’t have an answer to that. I can say that they’re not present in the technical working groups. And I think if you’re taking a step back and looking at this, you would want to say is industry represented? Of course, you want to have industry represented in the process. But representing multiple industries who might have perspectives on the same issue is often important. And that’s a detail that I think in this case wasn’t necessarily fully addressed.

Stone: To emphasize the point here, the most recent accounting rules deal specifically with forest carbon accounting. So, this becomes a particular issue right now.

Cullenward: Yeah. So, this is one of the areas that’s under discussion right now where there hasn’t been a decision reached. I guess the point I’m trying to make is, of course, the forestry industry and landowners who have an interest in this outcome are one of the stakeholder communities that matter. And I’m suggesting another stakeholder community that matters are business interests that are competitors with that industry. And that’s maybe missing.

If I could just take a step back. I just described one of the balance issues of the level of the technical working groups. But there’s two other balance issues just to call up really quickly. We have the Independent Standards Board on which I serve, which is charged with making substantive decisions. And there’s no environmental NGOs on that board. So, I think one of the concerns that arises in that context is if there’s a dispute about the right way to do it, it can quickly politicize science and turn the substantive debate into industry versus science, which I think can be a really unproductive mode of collaboration.

There’s also, at the steering committee level, that top-level body that’s trying to ensure overall process coherence— there are no scientists on that body. And so, if there’s an issue that relates to the scientific integrity of the decision-making process, one might be concerned that the steering committee doesn’t have that representation, doesn’t have that strength in terms of its understanding of how scientific issues are debated and resolved.

Stone: Tell me a little bit more about that. I mean, what happens when there is disagreement, especially if an industry interest is up pushing in a different direction than a scientific perspective? How has that resolved at this point?

Cullenward: There’s very little I can say. I mean, I can describe the formal rules. But the answer is, the formal rules don’t really tell you the answer to that question. And I’d love to say more about how that happens in practice, but I am bound by a strict non-disclosure agreement, so I can’t comment on what actually happens in practice. And that’s actually part of the motivation for me to have written about the process and the rules. Because basically it’s a bit of a black box.

One thing I can tell you is that when there is a conflict between scientific integrity issues and industry preferences, that conflict plays out directly between scientists and industry, because there’s no environmental organizations that might say, “From our perspective, we think this is the wrong approach.” And that’s an advocacy question for them. And in effect, it ends up kind of politicizing science, because science becomes the point of opposition that might contrast with an industry perspective. And I think that that has really challenging implications for the stated criteria that, in theory, this process is trying to follow the science. I think it’s much harder to do when the science is politicized.

Stone: So science, in a sense, becomes a stakeholder itself, it seems like.

Cullenward: Yeah. And at least in theory, the governance structure says it’s a principle rather than a stakeholder community. But in practice, the way the governance structure is designed is it becomes like a stakeholder. And, again, I think that’s a concern.

Stone: Okay, so we’ve talked about the representation on the protocol. But you also just mentioned this issue of transparency, which you’ve written about in the report that we just referenced. Where do you see the gaps in terms of transparency, particularly in how the process is supposed to work versus what actually happens?

Cullenward: So again, this is an issue where I can’t say very much on account of my NDA, but I can reference publicly available information. And one of the sources for information on this comes from a recent story from a journalist called Emily Pontecorvo, who writes for Heatmap. And she covered both the report I released as well as some specific information from other people involved in the process.

And in Emily’s story, she references the experience of Kate Dooley, who’s one of the technical working group scientists involved in this forestry carbon accounting issue. And according to Dr. Dooley, there was a complaint from industry representatives in this process as to the competence and representation of the scientists involved in the technical working group. And that complaint, she says, was made in April of 2025.

According to Dr. Dooley, that complaint then led to outside experts being invited into the process. And in January of this year, she and her colleagues wrote a letter to the board chair requesting more information and the opportunity to respond. She says she never received a reply. So I can’t comment on the veracity. I can’t confirm or deny those statements, can’t say what happened at the board level.

But there are a couple of things I can say. One is that it’s been a year since the technical working group proposed various options for how to treat the forestry carbon accounting issue. Those documents are not yet available, unlike every other workstream in the protocols process. And it’s been several years since the protocol completed pilot testing of the proposal put forward by the industry representatives in that group. And that information hasn’t been made public either.

I also, as a result of this process, ended up filing a 200-plus-page complaint with another member of the board in relation to these issues. And unfortunately, I can’t discuss the content of that complaint, other than to say that I filed it.

Stone: Just looking at my notes on this. There are a lot of details here. But one of the interesting points here is that voting on the Independent Standards Board has been by secret ballot. Votes are not attributed to members. There’s no public record of board votes. Yet it seems that it would be essential to know if proposals are supported by members with science or business backgrounds. I wonder if you could talk a little bit about that transparency issue.

Cullenward: It is currently the case that there are not any meeting minutes from the Independent Standards Board. And if you read the terms of reference for the Independent Standards Board, they require meeting minutes to be prepared for every meeting. And the board has been meeting since late 2024. So this is not a small gap. This is a pretty significant gap. I’m hopeful that will change. But there are no meeting minutes available.

And that means nobody outside of the board of the steering committee has direct visibility into the decisions and process steps that are involved pretty much at any stage of this. Some of the technical working group activities include information about what the board has been doing. So the secretary might present a presentation to the technical working group and say, “Hey, at a recent board meeting, we talked about X, Y and Z. And here’s the feedback we got.” But that’s fairly informal. And we don’t have these formal board minutes. So it’s actually pretty much impossible at this point in time for anybody to say, objectively, the actions the board has or has not taken, because there are very few documents that record the board’s official actions.

Stone: Also with the technical working groups, members are listed on the  Greenhouse Gas Protocols website. But for these new joint working groups— and I wonder if you could explain to us what that is the joint working groups with the International Organization for Standardization, or ISO—  there is no requirement for membership disclosure in the joint working groups, again, working with ISO. Tell us about that evolution, working with the ISO, and this transparency issue.

Cullenward: Yeah. So there’s been a call broadly in the corporate community to align the standards that the  Greenhouse Gas Protocol puts out with those of the ISO. Both address corporate and product-level reporting-related issues. And of course, if they’re different, that’s a challenge for the user community. And if they’re harmonized, that’s a benefit. So there’s a broader announcement that there’s an intention for these two standard setting processes to coordinate and align their work. And recently, the Greenhouse Gas Protocol approved changes to its rules.

Historically, these technical working groups we’ve been discussing so far, that’s the several dozen to many dozens of people representing a broad range of stakeholders. That’s the primary source of external technical input. There are requirements under the status quo to make those groups balanced between stakeholder groups. And their public membership is listed on the protocol’s website.

The new rules that will apply to the coordination between the ISO and the Greenhouse Gas Protocol no longer require the public disclosure of membership in these groups. And my understanding is that as a practice, the ISO does not disclose the members working on a particular project. And it also eliminates the mandatory requirements for balance. So there’s no longer a clear mandate to achieve balance between science, industry and civil society. So that lack of a mandate plus the lack of transparency means there’s no public accountability to the structure and composition of those groups.

One quick thing to mention. I mentioned that in the Heatmap story reporting on the forest carbon issue, Dr. Dooley said that there had been a complaint filed by industry saying maybe the scientists weren’t as representative of broader scientific opinion in that process. To the extent those kinds of concerns about representation are valid, you would assume they’re also quite valid in the context of who gets to be in the technical working group in the first place. And we’ll never know the answer to that under the current rule structure for these new collaborative joint working groups.

Stone: What are your concerns around what this may do to the credibility of the protocol?

Cullenward: My number one concern is with respect to the scientific integrity and substance of the work. And I think if that’s not handled well, or if it’s made non-transparent, that will have implications for credibility. As I mentioned to you, we haven’t had any board meeting minutes since 2024. I had filed this long technical complaint with another board member. That was recently actually adjudicated, and that complaint has now been sealed. The chair of the steering committee has decided that the public will not know what has happened to the forest scientists or how scientific information was presented to a decision-making board that is comprised primarily of non-scientists. And I’m not even allowed to share the official response I got with other board members, even though all of us are under NDAs. I’m still not allowed to share that response with them.

So this is all concerning. And I think it’s particularly concerning for an organization like the World Resources Institute, one of the two co-host organizations. I think there’s some significant questions here about whether WRI is comfortable lending its name and reputation to a process that treats scientists and science in this manner. I’m, frankly, quite disturbed about what’s going on and unfortunately unable to say more about what’s going on.

Stone: Let me ask you a related question here. There is a land sector and removal standard upon which conclusions were published recently. You and a colleague, as you mentioned earlier, filed complaints concerning the scientific integrity of the deliberations on this issue. Those concerns were not noted in the standard as it was published. Tell us what’s going on there.

Cullenward: Yeah. Let me quickly give an overview of the governance rules. Whenever we produce a standard, and in this case it’s the land sector removal standard, there’s also a basis for conclusions document that gets produced and published that explains the rationale for the board’s actions and approval and is certified by the steering committee as following all the appropriate process.

And so when it came time to publish the land sector removal standard— which, by the way, is the first official product that’s come out of this new governance regime. So this is the first new standard that says, “Now here are the rules for this sector in this application.” The standard covers the treatment of agricultural issues. It covers the treatment of carbon removals more broadly. But it doesn’t cover the forest carbon accounting issue we’ve talked about previously. And when it came time to prepare the basis for conclusions document, a colleague and I both expressed a formal objection as to the scientific integrity of the forest carbon deliberations. And those objections were not recorded in the basis for conclusions document, even though the rules say that’s supposed to happen. So that’s an example of a process issue that that I think speaks to these broader transparency and accountability issues.

Stone: Danny, as we’ve talked about, the protocol is quite central to how we think about climate accountability these days. It’s increasingly being adopted as a framework by policymakers. These credibility governance issues must be addressed. What are some of the key solutions? And again, we’ve talked about representation. We’ve talked about transparency. What are some of the key solutions you’re thinking about?

Cullenward: Let me address two sets of solutions. One is oriented around the specific issue we’ve talked about around forest carbon accounting and the dilemma there. And then a second set will be about the broader governance structure, because I think these issues repeat and will be unaddressed if there isn’t a broader solution.

On the question of how to handle the forest carbon accounting issue, it’s my position that the complaint should be made public, the response should be made public, there should be transparency around these issues. And at a minimum, the proposals that were made by the technical working group, all of the materials from the technical working group, should be made public as they have been for every other technical working group, but have not for forest carbon.

I also think the protocol needs to disclose the pilot testing results that do exist for the industry proposal, because I think they will add substantial clarity as to the substance of the positions. And I think it’s really important that that information may be made publicly accessible.

I think on the broader question of the governance structure of this body, part of what motivated me to write this report for the Kleinman Center was that I think there are some structural imbalances that need to be corrected and can be addressed, in part, through solutions. So one solution is to require environmental NGO representation on the decision-making board. The absence of environmental NGOs, I think, politicizes science unnecessarily and unhelpfully. And including them in the decision-making process, I think, would improve the credibility and representation of the protocol.

Similarly, I think there need to be scientist representatives on the steering committee to make sure that the science process is all in order. I think the protocol needs to require transparent member-level votes and produce meeting minutes so that there’s accountability for how decisions are made. And if there is a dispute over science, that there’s clarity on which board members are taking which positions to better inform the public about the nature of those deliberations.

I think we also need to have mandatory transparency and balance in all of the collaborative technical working group streams, whether those are just for the protocol only or the collaborative work streams between the protocol and the ISO.

And finally, the fact that board members like myself are under strict NDAs means that there can’t really be any public accountability if something goes wrong from the perception of one of those board members. And I think the protocol really needs to consider removing NDAs, so that there can be a greater level of confidence in the integrity of the overall process.

So those are my structural suggestions for how to make this a better position. And given the importance of this protocol and of this issue, I think there’s opportunities to land this in a good place. But with all of the materials being kept behind confidentiality agreements, I just have to say it’s very concerning. And I hope that’s not where this process ends.

Stone: Are you optimistic? Will these changes be made? And if they’re not, what does it mean for the future relevance of the protocol?

Cullenward: Well, so— you know, no, I’m not optimistic. I think the decision has been taken that everything will stay confidential. That’s a decision that could be revisited. And I’m concerned that if that’s the mode of operation, I think that has impacts for the credibility of the work going forward.

Stone: Is there going to be pressure coming on the protocol from outside sources to make this happen politically?

Cullenward: My role as a board member is to follow the rules and to put my hand up when I see the rules are not being followed. And I’m doing as much as I can in that role, given my constraints. It’s not appropriate for me to speculate, but I have concerns about a process that muzzles the science as this is being done right now. And I would very much like to see this land in a better place because it is so important. And there’s been so much work invested, not just in the last two years, but over the course of a couple of decades, to build up a more robust reporting system. And I think that’s essential to the success not just of this effort, but of a broader number of climate efforts that presume the availability of a reasonable reporting structure. And this is the leading example. So I would like to see it improve. But I think its status quo presents pretty big challenges that need to be taken seriously.

Stone: Danny, thank you for talking.

Cullenward: My pleasure, Andy. Thanks for having me on.