Include per-tonne evidentiary property prescription in any EPA voluntary-market guidance. Convene a public process on per-tonne evidentiary standards.
Why this recipient benefits: Regan's May 2024 VCM Principles are the federal framing proof-pack disclosure operationalises. A follow-on EPA technical guidance specifying per-tonne evidentiary properties as one acceptable substantiation path reinforces the existing Principles without new rulemaking.
Why now: 12 months post-Principles release is the natural guidance-update cadence.
The ask: EPA briefing on per-tonne evidentiary property prescription. Draft guidance language; state-programme alignment analysis.
Clean Air Act implementation; voluntary-market guidance; greenhouse-gas reporting programme.
Include per-tonne evidentiary property prescription in any EPA voluntary-market guidance. Convene a public process on per-tonne evidentiary standards.
EPA's voluntary-market guidance sets expectations for state-level programmes (CA ARB, RGGI, others). Property-based prescription is the regulatory-design approach that preserves agency neutrality on technology while raising the evidentiary floor.