Pierce County Forest Carbon Offsets

Audit Analysis

A Pierce County urban reforestation project under the City Forest Credits standard with verified additionality and a 5% buffer pool, but significant concerns around an unaddressed leakage component, a baseline that was downgraded from jurisdictional to project-specific between PDD versions, 40% tree loss from flooding, and a verified ERR that is roughly 270% of the linear pro-rata expectation for the elapsed period. The VVB is an individual rather than an accredited body, and several key MRV fields remain unreported.

Project Description

Red Flags

• ⚠Leakage deduction is not stated in any available document despite a project type (tree planting in a flood-prone riparian corridor) where displacement of carbon stocks is plausible
• ⚠40% tree loss estimated from 2021 flooding and heatwave (material findings in the verification report) yet no reversal event was formally triggered; the VVB concluded minimum stocking thresholds were still met
• ⚠Verified ERR of 1,835 tCO₂e is approximately 270% of the linear pro-rata expectation (~680 tCO₂e) for the ~3.9-year elapsed period out of a 26-year crediting period, raising over-crediting questions
• ⚠Baseline method changed from 'jurisdictional' in the 2021 PDD to 'project' in the 2025 PDD, a downgrade in baseline rigor
• ⚠The VVB is an individual (Matthew Lee) rather than an accredited verification body, raising independence and capacity concerns

Credit Vintages