PEM Publication March 2022

The Trouble with Carbon Protocols Explained (CARB, CAR, VERRA, ACR, CDM)

Fig. 3. CARB-CAR (orange), ACR (grey) and CDM (green) histograms in gC m−2 y−1 are shown with A) Annual FLUXNET2015 NEE (blue), and C) Annual Reco (red), and GPP (purple). Only values between −1500 and 1500 gC m−2 y−1 are shown, with a bin size of 30 gC m−2 y−1. All VERRA (yellow) histograms with B) Daily FluxNet2015 NEE (blue), and D) Daily Reco (red), GPP (purple), for carbon sequestration values between −5 and 5 gC m−2 d−1. The bin size is 0.0025 gC m−2 d−1. Front panel histograms are slightly transparent to allow the visualization of the overlapping values from the histograms plotted on the background. Each panel histogram order, from back to front, is A) NEE (back), CARB-CAR (middle-back), ACR (middle-front) and CDM (front) B) Daily NEE (back) and VERRA complete (front) C) Reco (back), GPP (middle-back), CARB-CAR (middle), ACR (middle-front), CDM (front) D) Daily Reco (back), Daily GPP (middle), and VERRA complete (front).



October 5, 2021
Update: October 10, 2021
Planetary Emissions Management Inc., Cambridge, MA, USA
Bruno D.V. Marino, CEO

The California Air Resources Board defends beleaguered forest carbon offsets by contradicting peer-reviewed science. This did not work in 2019, and their actions are now more relevant than ever.                                                                                               

“…immediately revise the title of your publication to more accurately reflect its conclusions, and that you immediately halt your misleading marketing campaign…”California Air Resources Board                                                                                                                                                                                                           

This is a story about intimidation and threat by the California Air Resources Board (CARB) against a small US business seeking to improve forest carbon protocols for social, economic, and planetary benefits.

Forest carbon offsets (e.g., voluntary and compliance) created by estimation-based protocols may pose risks and uncertainties, as described in publications and news reports provided below.

Alternative viewpoints should be considered when undertaking forest carbon programs including voluntary offsets for private and municipal landowners with fiduciary responsibility for projects.

Likewise, claims of net-zero and carbon-neutral status, as well as the assessment of carbon offsets, are difficult if not impossible to validate, lacking direct measurement of CO2 and related greenhouse gas material balance.

Schedule a presentation or participation in a meeting or hearing regarding verification of carbon offsets here:

(Note: The term invalidation, as used herein, is based on an academic comparative analysis, and does not reflect the status of CARB or any other offset credits.)



The complete CARB and PEM letters, the original and related publications,
and news media can be found here:

For convenience, this information is also provided below.

FOR MORE INFORMATION CONTACT:, +1 855-254-5055, Ext 101

PEM published a peer-reviewed paper in 2019 (California air resources board forest carbon protocol invalidates offsets“) characterizing issued CARB forest carbon offsets and received a threatening letter from CARB demanding that we revise the published paper. PEM responded by refusing to make changes, defending our First Amendment rights to freedom of speech despite intimidation and threat. The PEM 2019 publication foreshadowed the now frequent news stories and publications calling CARB forest carbon offsets into question. Released here for public view is an inside look—far from the glitz of media pronouncements, secret news reviews, and pundits—at how legislated cap-and-trade forest carbon, as a material, measurable entity, is dissociated from the fundamental laws of plant physiology and accepted scientific methods, in part by intimidation and threat.The 2019 publication introduced an alternative, widely employed scientific method, direct measurement of forest CO2, and compared it with CARB protocols that exclude COrevealing significant differences. Over 600 scientific peer-reviewed publications have reported direct CO2 measurement results for net forest carbon sequestration from diverse global locations and are freely available as raw and processed data in centralized databases.

PEM is releasing this information to the public to share the urgent need to respond to climate change more effectively—to “get it right” and to voice “truth to carbon offsets”—and to educate the public and all stakeholders about the evolving carbon offset process and its role in managing climate change. As the demand for efficient and cost-effective carbon offset products increases, concerns over inadequate quality and a lack of transparency have intensified.

It is clear that carbon credit and offset providers must evolve to meet the growing concerns of buyers and to validate the actual net reduction of atmospheric CO2. Standard and harmonized methods are needed to integrate the fractious commercial forest carbon offset market, bridging the gap between science and commerce. The 2019 publication also emphasizes the importance of including methane (CH4) and nitrous oxide (N2O), both potent GHG’s with comparatively large global warming potentials, in forest GHG budgets, readily incorporated using eddy covariance methods.

Given the fundamental importance of standardized measurement for carbon offsets, we propose that this topic be added to the COP26 agenda.

Publication and Response Details

Planetary Emissions Management Inc. submitted a manuscript, “California air resources board forest carbon protocol invalidates offsets,” to the peer-reviewed journal, PeerJ, on April 12, 2019. This article was published on September 23, 2019.  (Note: The term invalidation, as used herein, is based on an academic comparative analysis, and does not reflect the status of CARB or any other offset credits.)

On October 15, 2019, we received a surprising letter from Jason Gray, CARB’s Chief of the Climate Change Program Evaluation Branch (Industrial Strategies Division), calling our results into question by labeling them erroneous via an internet alert, still active on CARB’s website, threatening to “explore legal action” against PEM if it did not “immediately revise the title of [its] publication to more accurately reflect its conclusions” and to “immediately halt [PEM’s] misleading marketing campaign.” The alert does not provide a link to the 2019 publication limiting access to the data by readers of the alert.

We found the letter astonishing at the time, and, in light of CARB’s forest carbon offsetsand forest offsets in general—being increasingly called into question as of late, we find it more relevant than ever to improve management of climate change through science-based policy action.
The CARB letters and our responses, prepared by the Dhillon Law Group in San Francisco, are provided in their entirety via the link below. PEM and non-PEM literature citations and relevant news reports are also provided here:


The CARB & Dhillon Law Group Letters



Summary Points

  • The validity of the forest carbon offsets produced by the California Air Resources Board (CARB) forest carbon protocol has been called into question by peer-reviewed studies and the press and; however, the underlying biological causes of disagreement have been ignored and have not been tested experimentally.
  • In the 2019 publication, PEM set out to test the validity of forest carbon offsets with research CO2 data from published field studies. Our research reveals an underlying conflict between the laws of nature and the laws shaping cap-and-trade legislation. Currently, as reported in the publication, incomplete carbon accounting has fragmented the process of verifiably quantifying the net climatic benefit of forest carbon sequestration and storage. The publication proposed using a widely published and applied relationship between ecosystem photosynthesis, representing carbon uptake, and ecosystem respiration, representing carbon release, based on directly measured COexchanges, or flux, between the forest and atmosphere.
  • The CARB CO2-excluded measurement protocols, if lacking a complete carbon accounting,  have given rise to empty carbon offset products, over-crediting, and market risk, consistent with the findings of other publications and news reports (exampled provided below).
  • We propose improving commercial forest carbon protocols using basic forest science and emerging research to harmonize and catalyze the role of forests in managing complex climate change through nature-based climate solutions benefitting stakeholders while emphasizing the importance of equity and justice for all landowners.
  • A direct measurement forest carbon protocol verifies net carbon sequestration (e.g., one metric ton CO2 equivalent) across a project area, a metric of in situ additionality, regardless of unprovable counterfactual arguments, and the figure of merit for carbon trading.
  • When measurements are employed, nature-based climate solutions such as forest carbon offsets can be quantified and managed in alignment with the goals of the Paris Accord to limit the increase in the global average temperature to well below 2°C compared with preindustrial levels—and to further limit the temperature increase to 1.5°C (IPCC, 2021).
  • We emphasize that the purpose of sharing this material is to provide a reality check on the carbon offset development process and to reveal and document the challenges standing in the way of improving the methods that quantify the net benefit of climate change management—improvements that are worthy of the public trust now and in the future.
  • The lessons of the Montreal Protocol teach us that inaction in addressing a global threat to humanity such as the ozone hole would severely harm people and the biosphere, disrupting societies across the planet—but this did not happen. PEM advocates an appropriate version of the Montreal Protocol for forest carbon and climate change management and to provide technical  GHG methods and measurement foundation for green policies such as the Green New Deal.
  • Claims of net-zero and carbon neutrality status are announced daily but should be considered as provisional, pending verification of claims by measurement and independent third parties. This suggests an expanded role for direct measurement in assessing environmental, social, and governance criteria.
  • Entrepreneurs have a special role to play in managing climate change but need basic and applied science to shape commerce that can make a difference for people everywhere. Our intent is to bridge the gap between science and viable commercial enterprises in the spirit of collaboration, a point we emphasize in our publication.
  • Commercial products proven to reduce greenhouse gasses can be shared and transacted across the planet, uniting forest communities of the Congo and the Amazon, for example, and people everywhere via cell phones, the internet, and social media. Electronic transactions must be as trustworthy as those used in the banking industry.

Related Publications

Systematic over-crediting in California’s forest carbon offsets program. Grayson Badgley, Jeremy Freeman, Joseph J. Hamman, Barbara Haya, Anna T. Trugman, William R.L. Anderegg, Danny Cullenward.

Neeff, Till, “What is the risk of overestimating emission reductions from forests – and what can be done about it?,” Clim. Change, vol. 166, no. 1–2, pp. 1–19, May 2021,

Reiersen, G., Dao, D., Lütjens, B., Klemmer, K., Zhu, X., & Zhang, C. (2021). Tackling the Overestimation of Forest Carbon with Deep Learning and Aerial Imagery.

Haya, B., Cullenward, D., Strong, A. L., Grubert, E., Heilmayr, R., Sivas, D. A., & Wara, M. (2020). Managing uncertainty in carbon offsets: insights from California’s standardized approach. Climate Policy, 20(9), 1112-1126.

West, T. A., Börner, J., Sills, E. O., & Kontoleon, A. (2020). Overstated carbon emission reductions from voluntary REDD+ projects in the Brazilian Amazon. Proceedings of the National Academy of Sciences117(39), 24188-24194.

Related Media Citations

Carbon offsetting is not warding off environmental collapse – it’s accelerating it
The Guardian, January 26, 2022

How to repair the world’s broken carbon offset market
GreenBiz, January 10, 2022

California’s carbon-offset disaster reveals why COP26 was a big disappointment
Desert Sun, November 27, 2021

How to Repair the World’s Broken Carbon Offset Markets
Yale Environment360, November 18, 2021

How wildfires could unravel California’s climate progress
Grist, October 27, 2021

California is banking on forests to reduce emissions. What happens when they go up in smoke?
Grist, October 27, 2021

Carbon Offsets Are Nothing But a ‘Dangerous’ Con Job, Warns Climate Group
Common Dreams, October 22, 2021

A dangerous distraction – the offsetting con
Friends of the Earth, October 22, 2021

“Avoid emissions first:” Offsets needed for net zero, but they must be real
RenewEconomy, October 10, 2021

Greenpeace says carbon offsets are “greenwash” and should end
Data Centre Dynamics Ltd, October 8, 2021

Greenpeace calls for end to carbon offsets
CNBC, October 7, 2021

‘Indispensible’: Can the carbon offset market bolster its credibility?
BusinessGreen, September 28, 2021

How a California climate program lets companies keep polluting
The Philadelphia Inquirer, September 27, 2021

Carbon offset. If it looks like an illusion, it is
The HeraldScotland, September 27, 2021

Seeking Net Zero? You Should Know Not All Carbon Offsets Are The Same
Forbes, September 22, 2021

Burned trees and billions in cash: How a California climate program lets companies keep polluting, September 17, 2021

Burned trees and billions in cash: How a California climate program lets companies keep polluting
LA Times, September 8, 2021

Lisa Song?!  Lisa Wrong!
Carbon Offsets to Alleviate Poverty, 2021

Americans deserve better coverage of carbon finance
Carbon Offsets to Alleviate Poverty, 2021

Climate Progress Is On Fire
Dailyposter, August 30, 2021

Fiddling with carbon offsets while California burns
San Francisco Examiner, August 26, 2021

Carbon-Offset Forests Are Burning Up in Wildfires
Planetizen, August 26, 2021

Wildfires are ravaging forests set aside to soak up greenhouse gases
The New York Times,  August 23, 2021

Lawmakers Question California Cap and Trade Policies, Citing ProPublica Report
ProPublica, August 20, 2021

Amazon: regrowing forests have offset less than 10% of carbon emissions from deforestation
The Conversation, August 20, 2021

CARB Chair Randolph Response to California Senate Letter
August 12, 2021

California Senate Letter to CARB Chair Randolph
August 6, 2021

US Forest Fires Threaten Carbon Offsets as Company-Linked Trees Burn
Inside Climate News, August 4, 2021

Carbon offset programs of companies like Microsoft, BP go up in smoke as wildfires decimate forests
The Independent, August 4, 2021

False solutions: To achieve net zero, carbon offsetting would use up all global farmland
Oil Change International, August 3, 2021

Tackling the Overestimation of Forest Carbon with Deep Learning on Aerial Imagery
Climate Change AI, July 23, 2021

Bootleg Fire is burning up carbon offsets
CNN, July 22, 2021

Carbon Offsets/ What Are They? And Do They Work?
Rolling Stone, July 8, 2021

“Massive Over-Crediting” of California’s forest offsets? 4 Alarm Fire or False Alarm?
Pacific Forest Trust, June 21, 2021

To Ward Off Climate Disaster, Fix Carbon Markets
Barrons, June 14, 2021

Forests: Good Intentions but Mixed Results
WSJ, June 9, 2021

Five ways ‘green’ carbon policies damage forests – and how we can fix the problem
The Conversation, June 9, 2021

California Not Doing as Well as It Thinks in Reducing Carbon, Investigation Finds
KQED, June 7, 2021

The five biggest reasons carbon offsetting schemes can fail
Africa News, June 2, 2021

Turning Carbon Offsets Into Catnip for Commodities Traders
BloombergQuint, June 2, 2021

Wall Street’s Favorite Climate Solution Is Mired in Disagreements
BloombergQuint, June 2, 2021

The sleight of hand of costly carbon credits
Orange County Register, May 30, 2021

NCX Creates the Largest U.S. Forest Carbon Project
Business Wire, May 26, 2021

ACR Testifies before the U.S. Senate on the State of U.S. Forest Carbon Markets
American Carbon Registry, May 20, 2021

Rethinking Forest Carbon Offsets
The Cary Institute of Ecosystem Studies, May 19, 2021

The California Air Resources Board Challenges Our Carbon Credits Investigations. We Respond.
ProPublica, May 12, 2021

Statement in Response to Article Critical of Our Carbon Offset Project
Mass Audubon, May 10, 2021

CARB Statement to ProPublica
California Air Resources Board, May 10, 2021

A nonprofit promised to preserve wildlife. Then it made millions claiming it could cut down trees
ProPublica, May 10, 2021

A nonprofit promised to preserve wildlife. Then it made millions claiming it could cut down trees
MIT Technology Review, May 10, 2021

BP’s Suspicious Support for a Carbon Market in Washington State
The New Republic, May 6, 2021

Carbon offsets used by major airlines based on flawed system, warn experts
The Guardian, May 4, 2021

California program overestimates climate benefits of forest offsets-study
Reuters, April 30, 2021

The math isn’t adding up on forests and CO2 reductions
The Verge, April 29, 2021

CARB responses to questions from ProPublica on California’s Forest Offset Protocol
California Air Resources Board, April 29, 2021

The Climate Solution Actually Adding Millions of Tons of CO2 Into the Atmosphere
ProPublica, April 29, 2021

The Climate Solution Actually Adding Millions of Tons of CO2 Into the Atmosphere
MIT Technology Review, April 29, 2021

Systematic over-crediting of forest offsets
CarbonPlan, April 29, 2021

Systematic over-crediting in California’s forest carbon offsets program (Pre-Print)
bioRxiv, April 29, 2021

California’s ‘climate leadership’ does more harm than good
San Bernardino Sun, April 24, 2021

The Carbon Market Gold Rush in American Agriculture
BloombergQuint, April 21, 2021

The Yurok Tribe Is Using California’s Carbon Offset Program to Buy Back Its Land
Yes! Magazine, April 19, 2021

This “Journalism” From The Guardian And Greenpeace Threatens Forest Conservation
VERRA, April 14, 2021

Top airlines’ promises to offset flights rely on ‘phantom credits’
Unearthed, April, 5 2021

A Top U.S. Seller of Carbon Offsets Starts Investigating Its Own Projects
Financial Post, April 5, 2021

Shaping policy to cut carbon
The Nature Conservancy in Washington, March 15, 2021

Carbon Conundrum:
A Native Alaskan company’s promise to save its forests benefits local ecosystems, but given the zero-sum game that’s carbon offsets, it delays meaningful action on climate change.
Earth Island Journal, Winter 2021

State auditor’s office has been on a roll
CalMatters, February 28, 2021

Carbon offsets gird for lift-off as big money gets close to nature
Zawya, February 25, 2021

Statement from Members of the Offset Protocol Task Force Regarding Member Resignations
California Air Resources Board, February 24, 2021

California Air Resources Board:
Improved Program Measurement Would Help California Work More Strategically to Meet Its Climate Change Goals
Auditor of the State of California, February 23, 2021

The No CARB Diet: Should the California State Legislature Cut the California Air Resources Board Out of Its Emissions Reduction Regulatory Scheme?
Ecology Law Quarterly, February 16, 2021

California to review carbon trading program as part of climate roadmap
Calmatters, February 16, 2021

2 California environmental justice leaders resign from carbon offset task force
POLITICO Pro, February 11, 2021

Environmental Justice Members Resign from CARB Task Force on Carbon Offsets
STREETSBLOG CAL, February 11, 2021

Advocates Resign from Illegitimate CARB Offsets Taskforce
California Environmental Justice Alliance, February 9, 2021

Neil Tangri, Ph.D., Environmental Justice Representative, CARB Compliance Offset Protocol Task Force – Resignation Letter
February 8, 2021

Brian Nowicki, Center for Biological Diversity, Environment al AdvocatesRepresentative, CARB Compliance Offset Protocol Task Force – Resignation Letter
February 8, 2021

Native Alaskan Company Involved in Controversial Carbon Offsets Project to Quit Logging
Earth Island Journal, January 21, 2021

These Trees Are Not What They Seem:
How the Nature Conservancy, the world’s biggest environmental group, became a dealer of meaningless carbon offsets.
Bloomberg Green, December 9, 2020

Can California’s Cap and Trade Actually Address Environmental Justice?
Yes! Magazine, November 20, 2020

The Hidden Disequities of Carbon Trading: Carbon Emissions, Air Toxics, and Environmental Justice
Frontiers in Environmental Science, November 10, 2020

This Oregon forest was supposed to store carbon for 100 years. Now it’s on fire.
Grist, September 18, 2020

Overstated carbon emission reductions from voluntary REDD+ projects in the Brazilian Amazon
Proceedings of the National Academy of Sciences of the United States of America, September 14, 2020

Overstated carbon emission reductions from voluntary REDD+ projects in the Brazilian Amazon
PNAS, August 12, 2020

Carbon Offset Industry Stack
Memohub Blog,

Opinion: Why California’s climate solution isn’t cutting it
LA Times, January 2, 2020

Carbon Offset Programs Are Failing As Climate Solutions
The Real News Network, December 2, 2019

Carbon Offsets Will Only Carry You So Far
Kiplinger, November 22, 2019

Cap and Trade Is Supposed to Solve Climate Change, but Oil and Gas Company Emissions Are Up
ProPublica, November 15, 2019

‘Flight shaming’ could help unleash billions in airline cash to protect the Amazon and other tropical forests
San Diego Union-Tribune, September 15, 2019

If forests go up in smoke, so can carbon offsets
The Verge, September 13, 2019

The world is watching as California weighs controversial plan to save tropical forests
LA Times, September 13, 2019

Carbon Offsets: Privileged Pollution?
Climate One Podcast, The Commonwealth Club, August 30, 2019

Researchers Press California to Strengthen Landmark Climate Law
KQED, August 27, 2019

Whoops! California’s carbon offsets program could extend the life of coal mines
MIT Technology Review, August 26, 2019

California’s forestry offset protocol defense lacks academic support, new report claims
Carbon Pulse, July 12, 2019

California’s pollution enforcers would like to save tropical forests. But at what cost?
CALmatters, July 8, 2019

California Legislators Urge Caution, but Greenlight a Plan That Could Lead to the Widespread Use of Forestry Offsets
ProPublica, June 21, 2019

These 4 Arguments Can’t Overcome the Facts About Carbon Offsets for Forest Preservation
ProPublica, May 31, 2019

What ProPublica’s forest carbon credits story still gets wrong – and right (with update)
Environmental Defense Fund, May 23, 2019

An Even More Inconvenient Truth: Why Carbon Credits For Forest Preservation May Be Worse Than Nothing
ProPublica, May 22, 2019

Refuting claims against California’s Forest Offset Protocol
Pacific Forest Trust, 2019

California’s “lenient leakage accounting” means that emissions reductions from forest offsets may never happen
REDD Monitor, May 9, 2019

California legislators ask ARB to conduct review of forestry offset protocol amid leakage concerns
Carbon Pulse, May 8, 2019

California forestry offsets vastly overstate emission reductions, report finds
Carbon Pulse, May 7, 2019

New paper: State’s cap-and-trade program is falling short of goals
Berkeley News, May 7, 2019

Landowners are earning millions for carbon cuts that may not occur
MIT Technology Review, April 18, 2019

How Carbon Trading Became a Way of Life for California’s Yurok Tribe
The New Yorker, October 10, 2018

The Office of the Auditor General of Norway’s investigation of Norway’s International Climate and Forest Initiative
The Office of the Auditor General of Norway, May 15, 2018

PEM Publication April 2020

PEM Publication April 2019

Eddy Covariance As A Service (ECaaS)

Presentation Ameriflux Meeting, 6 October 2020

Bruno D.V. Marino Ph.D. CEO, Planetary Emissions Management Inc.

Discussion break-out session: Private sector involvement in providing low cost, high precision EC platforms across the US and internationally for the dual purpose of science and verified carbon trading.


PEM Publication December 2020

Special Issue “Soil Carbon Sequestration: Bridging the Gap between Science and Commerce”



PEM Publication March 2021