The next climate-disclosure rule should prescribe properties, not technologies
Why this recipient benefits: A property-based per-tonne evidentiary disclosure story lands directly in the federal-policy implementation beat Goldfarb's desk already covers. The story arc — 'here is what federal procurement of carbon removal would look like if taxpayers were actually protected' — fits the Post's DC readership precisely.
Why now: FY27 federal procurement cycle opens in 2026; EU CRCF operational rulemaking in same window.
The ask: 30-minute off-the-record briefing. We will provide the proof-pack schema, the academic evaluator roster, and the list of federal agencies evaluating the instrument.
The Post sits closest to federal policy. Its readership includes the federal regulators, congressional staff, and executive-branch officials who will decide whether proof-pack-equivalent disclosure becomes a DOE procurement requirement, an EPA reporting rule, or an SEC climate-disclosure expectation.
Dear Editor,
The US federal government is now the largest single buyer of carbon removal in the world. The Department of Energy's Carbon Negative Shot targets dollar-per-tonne thresholds. The Department of Agriculture is funding climate-smart commodities. The Environmental Protection Agency is reporting on the policy-signal value of voluntary markets. The Securities and Exchange Commission's climate-disclosure rule is moving through its post-adoption life.
All of these activities share a common dependency: a per-tonne evidentiary record that is trustworthy, auditable, and comparable across pathways. That record does not exist today. Registries issue serial numbers. Methodologies are documented but project-level data is not. Costs are published only in aggregate. Environmental impacts are attested on a methodology basis, not a project basis.
A January paper in npj Climate Action by Christopher Reinhard and Noah Planavsky prescribed what a credible record should expose: methodology, dollar-per-ton cost decomposition, co-benefit data, independent verification pathway, and environmental-impact disclosure. Trellison Institute has been building a reference implementation. We call it a proof pack.
What the federal government could do, at zero cost to the taxpayer, is prescribe the properties of per-tonne disclosure in procurement and regulatory reporting without specifying the technology. DOE could require a Carbon Negative Shot winner to publish a per-tonne disclosure record meeting a minimum set of properties — the specific schema chosen by the operator. USDA could do the same for climate-smart commodity partnerships. EPA could reference such properties in any voluntary-market guidance. The SEC could treat such properties as one acceptable way to substantiate climate claims.
This is a regulatory design a conservative administration can support on market-discipline grounds and a progressive administration can support on integrity grounds. It does not pick a winner. It prescribes a floor for evidence.
The federal government is going to find itself deciding this question in the next twelve months, one agency at a time, with or without coordination. Coordinated property-based disclosure is cheap, technology-neutral, and politically defensible. Fragmented agency-by-agency rules are expensive and produce avoidable compliance cost.
Proof packs are one possible instrument. The conversation worth having publicly is whether the federal government treats per-tonne evidentiary disclosure as a policy question at all. We think it should.
— Rob Stillwell
Director, Trellison Institute
[email protected]