The Conflicted Role of Auditors in Carbon Markets

The voluntary carbon market is poised for rapid growth, with airlines soon required to use offsets for international flights and pressure building on other industries to follow suit. But recent studies show many offsets fail to deliver real climate benefits, raising doubts about their credibility.

Independent offset auditors are promoted as the guarantors of trust, yet their role is shaped by systemic conflicts of interest that make true accountability difficult. Former EPA enforcement chief Cynthia Giles and Penn Law’s Cary Coglianese explore the flaws at the heart of offset auditing—and what they could mean for the future of the offset industry.

Cynthia Giles was the senate-confirmed head of EPA’s enforcement office all eight years of the Obama administration. She wrote a book about making environmental rules more effective, titled Next Generation Compliance: Environmental Regulation for the Modern Era, published by Oxford University Press. During the Biden administration she worked on climate regulations as a senior advisor in the Air office.

Cary Coglianese is the Edward B. Shils Professor of Law and Professor of Political Science at the University of Pennsylvania Carey Law School, where he is also the founding director of the Penn Program on Regulation. He has taught and studied environmental and regulatory law and policy for more than thirty years, and is a member of the advisory committee for the university’s Penn Climate initiative as well as the Water Center at Penn.

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. The global market for voluntary carbon credits appears primed for growth as industries look to offsets to balance their climate emissions. Case in point, in 2027 a new international rule will require airlines to use carbon credits to cover emissions from cross border flights, and pressure is mounting for other sectors, including fossil fuels, to offset a broader share of their supply chain emissions. But this push for expansion comes at a moment of crisis for the offset market itself.

A number of recent studies have shown that the bulk of offsets don’t deliver the climate benefits they promise. Those doubts have raised questions about whether offsets can play a reliable role in cutting emissions. The offset industry has responded to criticism by moving to increase transparency around projects and by taking steps to ensure credit quality. At the center of these efforts are what’s known as independent third party auditors, which are promoted as the bulwark of credibility in the offset market, yet these auditors operate within the same structural pressures and conflicts of interest that challenge the market as a whole.

As today’s guests will argue, the problem isn’t necessarily the presence of bad actors, but of a system that’s built in ways that makes real integrity hard to achieve. Here to explore the issue are today’s two guests, who’ve recently published research that examines the role of auditors in carbon markets. Cynthia Giles was the Senate confirmed head of the EPA’s enforcement office during the Obama administration, and was later a senior advisor in the EPA Office of Air and Radiation. Cary Coglianese is director of the Penn Program on Regulation at the University of Pennsylvania Carey Law School. Cynthia and Cary, welcome to the podcast.

Cynthia Giles: Thanks for having us.

Cary Coglianese: Nice to be here again, Andy,

Stone: So the two of you recently published a paper on the credibility of voluntary carbon markets, and especially the role of auditors in those markets which we’re going to get into. But first to set the stage, I want to say this is a very difficult time for carbon offset markets. And to put this into the simplest of framings, the global offset market peaked at about $2 billion in value in 2021, and by last year 2024, it had shrunk to a quarter of that value, around $500 million. Cary, to get us started, can you tell us a little bit more about what offsets actually are, and what has driven the credibility crisis that the offset industry is facing now?

Coglianese: Well, the basic theory is sort of a common sensical one. If a company wants to reduce emissions, it has two choices. One, it could do it itself, or it can say, “Well, let’s support some effort to reduce emissions somewhere else.” And from the standpoint of emissions of greenhouse gasses in the planet overall, in theory, either approach should work, right? The problem is that the second approach, which is the offset approach, is one that, as you said, has suffered a credibility crisis. It may be one thing if you go with direct emissions reductions, to be able to somehow measure those directly and be assured that that’s actually happening and that we really are on a path toward a net zero economy, if you will.

But when it comes to offsets, the claims are indirect, and you need to show that the reduced emissions that are being claimed from someone else, some third party that the first party is taking credit for, are real ones. And some research has shown that upwards of 80 percent of the claims for reductions in emissions that are being used to offset first party emissions are being over claimed. They don’t exist. They’re not real. One very prominent, infamous example showed that there were 30 times the credits that were being claimed than actual emissions that were being reduced and offset.

So this is the credibility crisis that the offset market has faced. I should just say, to start off with, we should just for simplification purposes identify the key actors that we’ll be talking about in the market too. It might be helpful for your listeners. The project developers are those third parties that are developing projects that they’re claiming are reducing emissions and being used to offset emissions somewhere else. So those are the project developers. And they want to sell those credits to some buyers, those first parties, who want to use that to offset their own emissions.

In between that transaction, there are these registries that actually kind of structure this market and link up the project developers or the credit sellers with the credit buyers. And then there are auditors, and we’re going to be talking about auditors a lot. The registries will often provide a list of certified auditors that can come in and review the project developer’s projects, and see, in theory, whether they are matching the kinds of claims that they’re making, following a set of methodologies that are developed and approved by the registries. The claims that we’re responding to are made by a lot of these market actors, is including the registries, who are saying that the auditors are really the bulwark of credibility, these offsets the credits claimed are actually real and making equivalent emissions reductions to what corresponds to the credits that they’re being awarded.

Stone: So Cynthia, so as Cary kind of just was talking about, the industry is facing this crisis, and the industry has responded by trying to restore trust, and through efforts such as establishing what they call seals of approval and similar mechanisms that certified that methodologies ensure offset integrity. Cary also focused on, or began to talk about these third party auditors. I want to ask a little bit more, what is the defined role of these auditors within the larger offset ecosystem?

Giles: So the auditors play a role in that framework that Cary laid out, and they are tasked with verifying the credits that have been claimed by a project developer before registry approves the credits. So all projects are required, mandated to hire a auditor to check their work, so to speak, and before they issue credits. There’s a little bit of discussion about the roles of the parties that I want to get into for a second, but the registries, developers, and many others claim, as Cary mentioned, that auditors ensure that the claim credits are real and that they reflect actual carbon savings.

Our work presents research showing that auditors selected and paid by the firm being audited, which is how it works in carbon offsets, do not provide an unbiased assessment they’re claimed to provide. Never mind that the auditors have been required for 20 years. That’s since the beginning they’ve been required, and we still have had all the scandals about over claiming. Now, the auditors say that their role is only to check compliance with the methodology. That’s the requirements that the registry lays out for certain project types. But that’s not what’s being claimed by the people promoting carbon offsets. They tell buyers that buyers can rely on auditing to assure credit integrity, and we’re saying they definitely don’t do that. Either way, the narrow frame that auditors like to put forward, or the broad frame that almost everybody else uses to describe auditor’s role, auditors are not unbiased assessors of the facts.

Stone: I want to take a step back on that just for a moment. You know, you describe these two different roles. Is there a contractual basis somewhere or something that says this is really what the auditors are supposed to do?

Giles: It’s mostly described as checking compliance with the methodologies. I would say that’s the most frequent description. But, but at least one registry, Vera, which is the largest one in the voluntary market, has recently been saying other things, both publicly and to the auditors themselves, calling the auditors out for not catching things that are outside of those requirements of the methodology. So I would say there is a gray zone around what is actually expected. But the most important thing from our perspective is that the broad role that auditors ensure that they or guarantee, pick your word, are the bulwark for that credits are actually real. And that is what the registries, the developers, lots and lots of people are saying auditors do.

Coglianese: And by the way, also in the category of sort of level setting here, we should just be clear that we’re using sometimes non-technical terms of art by referring to auditors as auditors. In some settings, they’re called validation and verification bodies, for example. We sometimes use words like complying with the methodologies, and others will use things like conformity or conformity assessment to describe what auditors or validation and verification bodies are doing. But the basic concept here is that, as Cynthia has said, registries and others are saying that, you know, this credibility crisis can be overcome by relying on the bulwark here, being these auditors that are fundamentally being paid by the project developers.

Stone: So Cary, that brings up an obvious conflict here, one of economic self-interest, which you talk about in the paper, but you also bring in a second kind of concept here, and this is what you call self-serving bias. So could you talk about these two phenomena that, you know, I guess, collectively undermine or make it very difficult for these auditors to act in the way that is completely not tethered to any interest other than the integrity of the offsets themselves?

Coglianese: Sure. As you said, there is an obvious sort of conflict of interest, an economic conflict of interest that is at stake when project developers that are in the business of wanting to sell credits, and the more of those that they sell, the more credits that they can claim for their projects, the more money they make. And auditors, if they’re being paid by the project developer, you know, are allied in that interest with the project developer in an economic sense. But there also is a lot of research showing that in situations like this, there is an unconscious self-serving bias that exists as well. It shows up in research where there doesn’t even need to be any actual payments of auditors, but in experimental settings. Just even telling an auditor that they are working for somebody leads systematically — in very sophisticated experimental research, leads systematically to a bias in how they report.

And you know, if there really is 80 percent over claiming of credits by project developers, auditors, whether for their own economic interest or just in their unconscious bias that are missing an awful lot, and that’s why we wanted to just show that, because of these two mechanisms that are well documented and well established in scientific research, it’s understandable that so much is being missed. It’s not surprising. And we should certainly not be going around, as some people are saying, that auditors are going to guarantee that carbon credits are credible, and that they mean exactly what they mean.

There is a bias. And this bias, by the way, doesn’t imply that there’s bad faith or fraud in the market. And now maybe there is. I mean, but that’s not what we’re talking about. We’re just talking about a systemic effect that exists even by people who are acting totally in good faith. And I should say, by the way, one other thing here is that, in these markets, this bias actually pervades all of the actors. It is not just that the project developers benefit when they get more credits to sell, and it’s not just that auditors will have more business when they’re going along with the interests of their clients, but registries make money on the number of credits that are being sold, and the buyers of these credits want more of those credits at lower prices.

And so the more of those there are for everybody, there’s a benefit. And that’s a really troublesome feature of the voluntary offset market. Completely, I think, opposite the kind of optimistic, overly optimistic claims that we hear being made about how auditors are really going to provide the bulwark of credit integrity.

Giles: I just want to underscore the economic situation that auditors are in this market that Cary touched on, especially for listeners who are not aware of how this works, because the auditors are — all of the auditors, and all the major registries are selected and paid by the developers. Auditors are very aware that developers want auditors to sign off on the numbers of credits that they are claiming. The auditors compete for business with the developers, and are acutely aware that if they were to deny or disapprove significant numbers of credits, they’re not likely to be hired again.

So the economic posture that these auditors are in really puts a significant squeeze on them to go along with what the developers are requesting. No one has to say any of this explicitly. Everybody knows it. The market design puts those pressures on the auditors, which are profound.

Stone: I think the really important point here, also, if I can underline it, is, again, you don’t have to be looking for bad actors here, right? There’s the economic self interest. Obviously, if I am a an auditing company, I want to provide, you know, the opportunity for my client, the project developer, to produce as much credits as possible. I mean, even though that’s not really technically my job. My job is to ensure credit integrity, but I understand the business case here, right? So, and that gets to the point of what I think you are all are trying to make in this article, is that, take that bad actor element out, and you have a market that inherently, unconsciously, as you point down in the paper, incentivizes this lack of integrity in the market. I wonder if you could tell us a little bit more about what self-serving bias actually means. Contrast it with that economic self-interest and how it influences the actions of the auditors.

Giles: Self-serving bias is a well developed and recognized cognitive phenomenon that causes everyone, everyone, all people, to reach conclusions that favor their own interests. And this has been well, well documented in many arenas, and especially for the auditing arena for financial auditing of companies. And what the result of it is in the situation of auditing is that it causes the auditors to see the world in the way that aligns with their client’s interests. They’re often not even aware that they’re doing that.

As Cary mentioned, even in an experimental setting, auditors who were told, “Hey, you know, hypothetically, you’re representing the seller in this fake transaction we’re telling you about. Nothing matters here. It’s all hypothetical. We’re in a lab. We’re talking.” And even in that setting, people are not aware that they are inclined to support the view of this hypothetical client over what people who are not representing that client would say. We all do this. It’s a well, well documented phenomenon, to see things the way the client sees them.

Here’s a little interesting anecdote that I found from our research that shows how powerful this is. So there was an experiment done saying, “I wonder if we could counteract this self-serving bias by requiring financial auditors, this was, requiring them to go in front of a little board and explain their thinking and explain their reasoning. And that might cause them to think twice, and it might cause them to be, you know, less biased towards the perspective of their client.” And they found just the opposite, that when you had people go in front of this little mini board to explain their reasoning, it caused them to double down on aligning with the bias, and it caused the bias to be worse.

So this is a very powerful bias that we all carry around, and in a lot — the challenge here in the carbon offsets world is you have that natural bias, and it aligns with this powerful economic interest that these auditors have to reach an auditing conclusion that favors what their client wants. And those things together, they are a very powerful reason why you should not expect these auditors to be able to actually provide an unbiased accounting.

Coglianese: And if I could add to that too, we’re talking about auditing in some very difficult circumstances. I mean, put aside, first of all, that some of these projects are in very remote areas, and that poses its own challenges for reviewing what’s going on. But fundamentally, in the voluntary carbon offset market, we’re expecting that the credit validation process overall is going to provide some assurance against a counterfactual world that can’t be observed. A world that didn’t exist without this project. Would this forest land have actually remained forest land or not? That’s a very difficult question to ask, fundamentally, and that’s one example of the problem of additionality and the problems of what are called permanence to the credits that are being awarded, and their emissions reductions that are being claimed, or their emissions captured that are being claimed.

So we take the natural, unconscious tendencies that Cynthia has described, and then we plop those down in a setting in which it’s actually dependent upon a lot of qualitative judgments. Even if one’s finding that the auditors are doing just some more box checking kind of exercise, they’re often checking boxes that are qualitative in nature. How appropriate, how reliable are the claims that are being made is a it’s a very difficult setting, and one in which this bias, which nobody even has to be aware of or really consciously pursuing, just comes to the fore. And so our point is, it’s not surprising at all that we’ve found the credibility crisis that has, you know, afflicted the carbon offset market.

Stone: Well, there was a great point in the paper that I just want to quote from. It gets to this challenge of the counterfactuals and that kind of the qualitative judgments that the auditors have to use in judging. Would this forest have even continued to exist, even if an offset project supposedly supporting it hadn’t happened? And that’s obviously, you don’t know what the reality would have been the other way, because you can’t experience that reality. But you have this great quote that actually you state in the paper comes from elsewhere, but I want to read it here just for a moment, because I really liked it. And it kind of gets to this core, this problem. And you say that, “Carbon credits are an imaginary commodity created by deducting what you hope happens from what you guess would have happened.” I mean, that kind of sums it up right there, it sounds like.

Giles: One of the things that quote reveals, I think, is that offsets are all about judgments and assumptions. As Cary said, there’s not something you can measure to find out if the credits are real. You can’t take a sample and say, “Here’s how much carbon was saved.” So it is based on, I guess, about the future, really. Would that forest have been cut down or not without your projects? Almost all carbon credits are based on these kinds of unknowable counterfactuals. That means they’re based on judgments and assumptions.

And that’s the place where most of the projects have gone off the rails, according to the researchers, because developers have routinely made the assumptions and the judgments that produce the most credits. Surprise. Like that infamous Kariba Forest protection project that Cary mentioned that was profiled in New Yorker, which had the the wonderful descriptive title, “The Great Cash for Carbon Hustle,” that awarded as much as 30 times the credits it deserved. Four auditors signed off, by the way, on that project, all of which are still auditing today.

Stone: You talk in the paper as well, it’s very interesting, you actually get very quantitative in examining how prevalent this issue is in the offset industry. And you take a look at the assumption that auditors can ensure integrity by looking at some of the projects that were verified by the largest offset registry, and you found quite a lot of evidence of this self-serving bias there. Cary, can you tell us what that was about?

Coglianese: Let me say, first of all, that we really — we do have an empirical component to our paper that we also, by the way, report in our editorial that appeared in Science, where we reviewed 95 projects. But we’re not saying that this empirical component is a test of the prevalence overall in the market of these problems. These 95 projects are not by any means representative of all projects. We’re looking at, first of all, just 95 projects in three areas, forest restoration and preservation, rice cultivation, and cook stoves. Okay, so that’s not all of them.

But second of all, and most importantly, these are 95 projects that have been identified either by registries, Vera, the biggest registry, or by peer reviewed research, as having serious over claiming problems. And what we did is look at these, again, not for the purpose of saying something representative of the market as a whole, but rather to see if the kinds of problems that have emerged in the market about credit integrity are associated with, just say one or two auditors that have been consistently falling down on the job. Is that what’s going on, or is the problem when these scandals and serious cases of over claiming have erupted, is it by a wide range of auditors?

How many auditors have their fingerprints on these very problematic projects? And that’s why we look at these 95 projects. And we find that actually about two thirds, roughly, of the current auditors that are registered by Vera have been associated with and done at least one audit, sometimes many more, of these — of one or more of these 95 projects. This is evidence that’s consistent with what you would expect if this is a systemic problem, consistent with the research, that there is this systemic bias that exists in audit quality and in the ability of auditors to check over claiming. It is for that reason, then, that it’s at least prevalent that there’s a lot of auditors that are involved in these problematic projects.

Stone: You know, Cynthia, Cary had mentioned a little bit earlier in this conversation the fact that, you know, we’re focusing here on the auditors, but this is really a systemic issue at every level of the market. This dynamic that creates pressure throughout the systems. And I guess it also creates a situation that’s very resistant to change as well, is that right?

Giles: Yes. So it certainly is the case that in this market, unlike some other markets, every player in the system really has the same incentive. So in many markets, there’s competing pressures that help to keep things honest, and offset markets don’t have that. As we’ve talked about, everybody wants more credits. Developers obviously want to sell more credits. Registries make more money the more credits they approve. Auditors get more work by approving the requested number of credits. Buyers want more credits for their money. Whenever you have a market where all the interests align, watch out. It’s not in anyone’s interest to point out that the emperor has no clothes. And the result is a market where everyone is advantaged by awarding more credits, and it’s extremely hard to know if the credits are not warranted, as we’ve described. And that makes it completely unsurprising that we get the result we have where the vast majority of credits lack integrity.

Stone: So I want to take a step back here. Cary, some registries claim that they do monitor and even suspend underperforming auditors that they work with. Your paper suggests that these quality checks maybe don’t fix the underlying problem. Can you tell us a little bit more about that?

Coglianese: Well, in the law, we would say res ipsa loquitur. That is a Latin phrase meaning, “the thing speaks for itself.” So yes, there have been quality checks, there are auditors that have been delisted, but nevertheless, we have a bunch of auditors that have approved projects where there’s subsequently been shown to be over claiming. So the thing speaks for itself. And the thing here that is the bias that exists is also backed up with a lot of very solid evidence in the research literature. So we’ve got theory, we’ve got experience, both supporting the reality here that auditors are not the guarantee of credit integrity.

Giles: I agree with what Cary is saying, that the actions by the registries are not going to fix the underlying structure, and some registries claim that they will police auditors. That’s not going to happen. There’s two reasons. One is, registries make more money the more credits that are claimed. It’s a formula written down there in black and white. So it is not in registry’s financial interest to be known as the tough on credits registry. They’re going to lose revenues. People will go off to, you know, other registries.

They might take some superficial actions to appear to be tougher, but they’re not really going to do that, because it’s against their interest to do it. But even if they were willing, which they’re not, okay, but if they were, it wouldn’t matter, because auditors cannot disapprove an entire project or most of its credits, and certainly not the 80 percent level denials that current science suggests would be appropriate. Doing that would be likely fatal to that company, that auditing company. No one would hire them again. So no amount of enhanced oversight can compete with a life and death decision like that.

Stone: Cynthia, you and I had a conversation a few weeks ago, talking about this podcast. In that discussion that we had, I asked you about solutions, and your response was that you’re not really that interested in discussing solutions, at least not yet. That the industry needs to acknowledge the problem, which I’m gathering that it has not, or at least not to the level that you would deem necessary. Why don’t you think that acknowledgement has happened, and what would it look like if it did?

Giles: Well, our work, I think, demonstrates that the auditors selected and paid by the firm being audited have both economic incentives and biases that cause them to align with their client’s interests. The science is there. This is not brand new, okay? This is well established. Plus, in carbon offsets, specifically, we have 20 years of scandal after scandal with projects being awarded credits they didn’t come close to deserving, and auditors signed off on every one. So science and experience are telling us the same thing, and yet, the main market participants continue to say that actual carbon reduction is assured by having auditors look at these projects. We know that’s not the case. The science and our 20 years of experience both tell us that.

But that does not slow them down. And right now, they are trying to just ignore this problem. They want to reassure buyers that auditors provide guarantees of integrity, so they’re going to keep saying that, even though it’s not true. Until the major players admit that there is an issue here, serious efforts to solve it won’t happen. So that’s number one. But number two is there’s no easy fix to this problem. Auditors are not the only problem, as we’ve talked about, and they’re not going to be the only solution either. So we can’t solve offsets without significant redesign, which is going to be challenging. But we are never going to get to that discussion if we don’t have the principal folks first admitting there is a problem, which right now they’re not doing.

Coglianese: And quite frankly, they’re doing the very opposite. I mean, we’ve got claims, and they’re all in our longer paper that accompanies our Science editorial, that has registry Vera saying that auditors are going to ensure that a project’s climate impacts are real and permanent. And other folks are saying that, you know, they provide real confirmation and guarantees that that credits are real. These are delusions, you know? And so let’s — we’ve got to break out of that and have a serious conversation first that acknowledges that this is a fundamental limitation on going forward with a real, credible offset market. And it’s a complicated problem to be solved. It won’t start to be solved unless we first admit that there’s a problem.

Stone: Cynthia and Cary, I think there’s an issue that we’ve been kind of over looking, if that’s the correct word to use, up until this point in our conversation, and that is around the fundamental value of offsets themselves. And obviously here, we’ve been talking about the structural issues in the offset markets that are problematic. There are also questions around the validity of offsets. And I had a very interesting conversation on this podcast about a year ago with Danny Cullenward, who is a Senior Fellow here at the Kleinman Center.

And in one point of that conversation, we were talking about forestry offsets. His point in that conversation was that forestry offsets can actually have a lot of benefit. They may, in an ideal situation, prevent forests that might otherwise be cut down or destroyed from being cut down. They preserve those forests. But the climate benefits, for a lot of reasons that we discussed in that podcast, and I recommend if you’re interested, to go back and listen to that, it’s from July 2024. He said that the claims around the climate benefits from these forestry offsets are a completely different story, and those are much more questionable. So Cynthia, just wonder if you have any thoughts around this.

Giles: Another way of framing that is, why is offset integrity such a big deal? Why does everything we’ve been talking about here, why does it matter? The reason is because, if offsets do not reflect real carbon reductions, but companies use them to excuse definitely real carbon emissions, we are not helping climate. We are even making it worse. And just to underscore, the reason that matters so much, we can’t afford this kind of risk to climate. We’re behind on addressing climate as it is.

If we expand the use of carbon offsets and the offsets don’t reflect real emissions reduction, we’re going to be making the climate problem worse. So this is why offset integrity is not an abstract issue. It has immediate consequences for climate if offsets are not what they claim to be. And the forces that are pushing market expansion, claiming that auditors and sure offsets have real climate benefits, and our point is, no, they don’t. Not close.

Coglianese: I would just add to that a quote that we offer in our paper from the Administrative Conference of the United States, which is a federal agency that offers recommendations for other government agencies about best practices in various governmental functions. And sometimes governments set up programs that are in some ways similar, in that they rely on third party auditing. And so this report that ACUS, the Administrative Conference of the United States prepared, notes, and I quote here, “That when the risks are high, a conformity assessment program should be characterized by high degrees of rigor and independence.”

And for the very reasons that Cynthia has just discussed, it’s hard to imagine any realm that is higher risk today than the future of the planet. And if we have a very large scale offset program that’s really the — if it’s going to become the cornerstone of our pathway toward addressing climate change problems, and it has these fundamental at base difficulties with guaranteeing the reality of the credits that are underlying the market, we’re not doing ourselves the kinds of benefits that are being claimed from the offset market.

Stone: I have a final question for the two of you, and this gets to the fact that even with the credibility concerns that we’ve been talking about, demand for offsets does appear set to grow, through demand from airlines due to Article 6.4 of the Paris Agreement, which will result in a carbon market soon being operationalized within the Paris framework. And also other needs, for example, for scope three emissions. Given all of these pressures to grow the offset market, the question is, can it expand with integrity, and are buyers going to really understand what they’re getting? Cary, I’ll direct that to you.

Coglianese: I think the experience of the last 20 years and the research that we review in our paper and note in our Science editorial are ones that suggest real problems that are not going to get any better if the climate offset market expands. And if it expands dramatically, the challenge is the pressures are only going to get worse.

Giles: I agree with what Cary is saying, and would also add that, because offsets are so incredibly complex, there’s really no way that buyers can be sure that they’re getting what they think they’re getting. So there is an understandable impulse to have someone reliable checking for you, and that’s what auditors are supposedly doing. But the reality is, auditors are not checking for you. And it’s important that the buyers be aware of that, because they cannot count on the auditors to protect them from offsets that will ultimately fail their climate purpose. So buyer beware.

Stone: Cynthia and Cary, thank you both for talking.

Giles: Thanks very much, Andy,

Coglianese: Nice to talk to you again, Andy.

Stone: Today’s guests have been Cynthia Giles and Cary Coglianese. For more Energy Policy research and insights, as well as our archive of nine years of Energy Policy Now, visit the Kleinman Center for Energy Policy website. Our web address is KleinmanEnergy.upenn.edu. Thanks for listening to Energy Policy Now and have a great day.