Dear Kurt,
A short ask, with the artifacts you'd need to evaluate it.
Proof-pack-equivalent evidentiary records for CRCF-eligible removal units
We're asking for your reaction. The framing below is the regulatory-design path we believe holds up under scrutiny; we want to know where it doesn't.
The ask
- Read the schema-compatibility brief (linked below) — it's six pages, designed for DG-level review, not implementation detail.
- Tell us, candidly, whether per-tonne evidentiary disclosure as we've described it maps cleanly onto CRCF operational rulemaking, or whether you see gaps.
- If there's a path forward, the agent on this page can capture your concerns or counter-arguments and route them to the working group preparing the operational specification.
If the answer is "no, here's why" — that's also a useful response, and the same agent will capture it.
Why we're asking you specifically
You sit at the operational level where this matters: DG CLIMA owns the CRCF rulemaking, and the post-2035 ETS-removals integration question runs through your office. We're not asking for endorsement. We're asking for the kind of pressure-test only a regulator with operational responsibility can apply.
The case we're trying to make is: property-based per-tonne disclosure preserves technology neutrality, minimises compliance burden, and raises the evidentiary floor. The argument is the same in every compliance market — regulators should prescribe properties, not technologies. But the EU is the venue where this gets decided first.
What we're showing you
CRCF interoperability specification
Schema-level mapping of per-tonne proof-pack records onto CRCF-eligible removal-unit documentation. Includes a schema-compatibility analysis prepared with the operational rulemaking constraints in mind. Designed for review by Beatriz Holzleitner's unit alongside DG-level signal.
Open the technical brief →Carbon Release Arsenal — full proof-pack roster
Index of the full set of proof-pack examples across compliance-market regulators, exchanges, industry associations, and academic reviewers. Useful for triangulation: how does the schema look from California ARB, EEX, IETA, and the CDR research community?
Browse the proof-pack roster →Trellison carbon-capture research portfolio
The methodology audit work that sits under the proof-pack approach — research-grade analysis of integrity standards across CDR pathways. We rate methodology, not conclusions.
Open the research portfolio →What you can do on this page
Use the agent at the bottom-right to react in any way that's useful — a sentence, a list of concerns, a counter-proposal, an introduction to someone we should talk to instead, or a clean "no, and here's why."
Whatever you say is appended to the working notes block below in real time, so we have a single source of truth for your feedback that you and the working group can both reference. Nothing on this page is shared beyond the small group preparing the response.
With respect for your time and operational scope,
Rob Stillwell · Founder, Artrellion / DaedArch
· On behalf of the carbon-climate working group
Working notes
A live record of feedback collected via the agent on this page. Visible to you and to the working group; not shared beyond.