California Air Resources Board

The Program for Recognition of Early Action Offset Credits was a program for issuing ARB offset credits to early action offset projects.  Although the early action program has ended, ARB offset credits that were issued pursuant to the early action program continue to be valid for compliance in the Cap-and-Trade Program.

The early action requirements were previously described in subarticle 14 of the Cap-and Trade Regulation.  The requirements provided a path for early action offset projects using an approved voluntary quantification methodology to convert their early action offset credits into ARB offset credits.  The requirements specified that only early action offset credits for GHG emission reduction and removal enhancements prior to January 1, 2015 could be converted to ARB offset credits.  Furthermore, it required that any ARB offset credits recognizing early action must be issued by August 31, 2016.  Regulatory amendments effective October 1, 2017 removed the description of the Program for Recognition of Early Action Offset Credits from subarticle 14, although the provisions regarding invalidation of ARB offset credits issued for early action still apply.

The Program for Recognition of Early Action Offset Credits allowed some GHG emission reductions and removal enhancements from qualified existing offset projects to become eligible for use in the Cap-and-Trade Program.  Recognizing existing projects supported the requirements of AB 32 to ensure that voluntary reductions receive appropriate credit and helped create an initial supply of offset credits for the Cap-and-Trade Program.

Section 95990 of the Cap-and-Trade Regulation provided the requirements that early action offset credits had to meet to be eligible for compliance use.  ARB allowed only early action offset credits that had not been retired or used to meet another obligation.

Approved Voluntary Quantification Methodologies

The Cap-and-Trade Regulation included requirements to allow early action offset credits issued under approved voluntary quantification methodologies to convert to ARB offset credits and be used for compliance in the Cap-and-Trade Program.  Specifically, section 95990(c)(5) included a current list of approved quantification methodologies that could be used for early action, including the following voluntary quantification methodologies:

• Climate Action Reserve U.S. Livestock Project Protocol versions 1.0 through 3.0
• Climate Action Reserve Urban Forest Project Protocol versions 1.0 through 1.1
• Climate Action Reserve U.S. Ozone Depleting Substances Project Protocol version 1.0
• Climate Action Reserve Forest Project Protocol versions 2.1 and 3.0 through 3.2
• Climate Action Reserve Coal Mine Methane Project Protocol versions 1.0 and 1.1
• Verified Carbon Standard VMR0001 Revisions to ACM0008 to Include Pre-drainage of Methane from an Active Open Cast Mine as a Methane Emission Reduction Activity Methodology v1.0
• Verified Carbon Standard VMR0002 Revisions to ACM0008 to Include Methane Capture and Destruction from Abandoned Coal Mines Methodology v1.0
• American Carbon Registry Voluntary Emission Reductions in Rice Management Systems Parent Methodology, version 1.0
  • American Carbon Registry Voluntary Emission Reductions in Rice Management Systems - California Module, version 1.0
  • American Carbon Registry Voluntary Emission Reductions in Rice Management Systems - Mid-South Module, version 1.0

Early Action Projects

Projects that were issued voluntary offsets must be listed with CARB to become early action projects.  Early action projects were issued ARB offset credits if specific requirements in the Cap-and-Trade Regulation are met.  After a voluntary project submits listing information to CARB, the offset project was listed on the Early Action Projects webpage, with general information about the offset project.

Early Action Offset Programs

Early action offset credits must be issued by Early Action Offset Programs that are approved under the Cap-and-Trade Regulation. The Regulation includes requirements in section 95990(a) that a program must meet to act as an Early Action Offset Program. An Early Action Offset Program may or may not also be approved as an Offset Project Registry. Three Early Action Offset Programs were approved:

• American Carbon Registry
• Climate Action Reserve
• Verified Carbon Standard

Regulatory Verification for Early Action

AB 32 requires regulatory verification of all GHG emission reductions and removal enhancements used for compliance purposes; therefore, the Cap-and-Trade Regulation established requirements for regulatory verification of early action offset credits.  All GHG emission reductions and removal enhancements achieved by early action offset projects must be verified by a CARB accredited verification body and the verification body must be different than the one that performed the original verification under the Early Action Offset Program. 

Early Action Guidance and Frequently Asked Questions (FAQs)

More information about early action provisions and their implementation is in CARB's Instructional Guidance Document.  CARB provided FAQs on the early action program as they were developed.

• Early Action Offsets Deadline    
• Early Action Transition Guidance 
• Early Action FAQs
• Guidance for U.S. Forest Projects Transitioning from Early Action to Compliance
• Supplemental Information on Early Action Project Review
• Early Action Offset Program Guidance - June 2013

Transition to CARB Compliance Offset Protocols

Early action offset credits were only issued for GHG emission reductions and removal enhancements achieved through 2014.  Beginning in 2015, all offset projects operating under approved voluntary quantification methodologies were required to transition to CARB’s Compliance Offset Protocols to continue to be eligible for the compliance offset program.  Section 95990(k) of the Cap-and-Trade Regulation previously included the requirements for project transition to Compliance Offset Protocols, including baseline transition, registration, listing, and verification requirements.

For questions or comments, contact Stephen Shelby at (916) 570-7953.