ART’s Controversial Certification of Carbon Credits to the Government of Guyana: A Case Study on Challenges for “High-Integrity” Labels in Carbon Markets

First published on apaguyana.com

The voluntary carbon market has come under intense scrutiny over concerns around the environmental and social integrity of the carbon credits being sold. Even certification bodies are seemingly incapable of delivering on their promise to certify “high-integrity” credits. The certification of jurisdictional REDD+ carbon credits by the Architecture for REDD+ Transactions (ART) to the Government of Guyana (GoG) in December 2022 provides an important case study on the challenges facing the high-integrity carbon market.

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ART claims to be a program that “ensures the environmental and social integrity of” emission reductions and removals credits through requiring compliance with its standard, The REDD+ Environmental Excellence Standard (TREES). TREES incorporates the Cancún Safeguards and requires that ART program participants respect, protect, and fulfill the rights of indigenous peoples. The GoG submitted its proposal for carbon credits certification to ART in December 2020 without any prior consultation with indigenous peoples and their communities. It proposed to sell carbon credits generated from all forests in the country, including forests on indigenous peoples’ traditional lands, some of which are titled under national law.

The GoG held several information-sharing sessions regarding its national Low Carbon Development Strategy 2030 – of which its proposal to ART was one component – with communities, but did not conduct consultations with indigenous peoples within the meaning of international human rights law. No indigenous peoples were asked for nor gave their free, prior, and informed consent to the proposal. The National Toshaos Council endorsed the policy framework within which the ART proposal formed one component, but it does not have the authority to give consent on behalf of indigenous peoples to such a program.

Aster Global Environmental Services, Inc., conducted the validation and verification process for the GoG’s proposal. Although Aster did interview civil society representatives and visit some indigenous communities, ART’s validation and verification standard only required Aster to evaluate the GoG’s own reported compliance with TREES. Aster’s completed validation and verification found that the GoG’s self-reporting showed that it met ART’s program requirements, and ART subsequently certified credits to the GoG. A portion of the credits were then sold to an oil company, Hess Corporation.

A national indigenous peoples’ advocacy organization, the Amerindian Peoples Association (APA), filed a complaint with ART’s internal grievance mechanism in March 2023, arguing that ART’s program requirements had not been met. The APA also noted several concerns with the design of the grievance mechanism, notably the lack of independence of the mechanism from the ART Secretariat and Board. In May 2023, the ART Secretariat dismissed the APA’s complaint without considering any of the substantive concerns raised. The same day, ART issued its new Complaints Guidance. In the subsequent appeal filed in June 2023, the ART Secretariat rebuffed the APA’s attempts to discuss the appeal process to ensure its fairness, transparency, and independence. The ART Secretariat dismissed the APA’s appeal in October 2023 without ever considering the substantive issues raised and without addressing the concerns the APA brought forth about ART’s grievance mechanism.

This case study highlights some of the challenges high-integrity carbon credits certification bodies face and lessons learned. It discusses the failures of certification bodies to guarantee high-integrity credits with respect to indigenous peoples’ land rights, participation rights, and right to determine adequate benefit-sharing mechanisms. Certification bodies must do more to ensure that their standards can guarantee full respect for human rights.

Certification bodies must:

• Require participants to demonstrate compliance with international human rights standards.
• Not rely on government self-reporting in validation and verification processes.
• During validation and verification processes, employ experts in indigenous peoples’ rights and experts in the relevant national context, and consult affected indigenous peoples.
• Have grievance mechanisms that meet the internationally accepted criteria for non-State-based grievance mechanisms.