The ACUPCC Voluntary Carbon Offset Protocol

Latest Version, November 2008:

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Project Overview

The ACUPCC Voluntary Carbon Offset Protocol (the “Protocol”) project is a coordinated effort of the American academic community to develop a formal voluntary protocol to guide ACUPCC institutions and others through the process of evaluating and investing in the voluntary carbon offset market. This project is being developed by College of the Atlantic through its participation in the ACUPCC with coordination and support services provided by Second Nature. It is bringing together interested parties from the over 590 ACUPCC institutions, as well as experts in finance, policy, energy, land-use, climate science, and other relevant arenas. For more information, see the Process section below.


Working Group:

  • David Hales, President, College of the Atlantic (Chair)
  • Judith Ramaley, President, Winona State University
  • David Shi, President, Furman University
  • Jennifer Andrews, Campus Program Manager, Clean Air – Cool Planet
  • Jim Buizer, Special Assistant to the President, Arizona State University
  • Andy Coghlan, LEED AP, Sustainability Specialist, UC Office of the President
  • Tony Cortese, President of Second Nature
  • Julian Dautremont-Smith, Associate Director, AASHE
  • Georges Dyer, Senior Fellow at Second Nature
  • Amanda Eichel, Climate Protection Advisor, City of Seattle
  • Jeremy Friedman, Sustainability Officer, New York University
  • Kari Hewitt, Research Associate at Second Nature
  • Jennifer Jenkins, Rubenstein School of Environment and Natural Resources and the Gund
  • Institute for Ecological Economics, University of Vermont
  • Susan Kidd, Senior Advisor for Sustainability, Agnes Scott College
  • Irving Mintzer, Principal of MEGLLC
  • Dave Newport, Director Environmental Center, UC Boulder
  • David Orr, Special Assistant to the President, Oberlin College

Advisory Group

The drafts of the Protocol are sent to representatives at the following organizations, however not all of confirmed that they will provide comment or feedback. Other organizations, experts, and the general public are encouraged to review the drafts of the Protocol and provide comment as well. Please send all comments to

  • AACC - American Association of Community Colleges
  • AASCU - American Association of State Colleges and Universities
  • AASHE - Association for the Advancement of Sustainability in Higher Education
  • ACORE - American Council on Renewable Energy
  • ACPA - College Student Educators International
  • ACSA - Association of Collegiate Schools of Architecture
  • ACUHO-I - The Association of College and University Housing Officers International
  • AGB - Association of Governing Boards of Universities and Colleges
  • Agnes Scott College
  • All ACUPCC Signatories and their Implementation Liaisons
  • Anaconda Carbon
  • APPA - Association of Higher Education Facilities Officers APX, Inc.
  • Arizona State University
  • Au Sable Institute of Environmental Studies
  • Business for Social Responsibility
  • California Air Resource Board
  • CantorCO2e
  • Cape Cod Community College
  • Carbon Concierge
  • Carbon Credit Capital
  • Carbon Project Solutions
  • CCAR General Reporting Protocol
  • CCBS - Climate, Community, and Biodiversity Standards
  • CCCU - Council for Christian Colleges & Universities
  • Chicago Climate Exchange
  • City of Seattle
  • Clean Air - Cool Planet
  • ClearSky Climate Solutions
  • Climate Change Capital
  • Climate Clean
  • Climex
  • Clinton Climate Initiative
  • College of the Atlantic
  • Conservation Strategy, LLC
  • Cornell University
  • Econergy
  • Ecosecurities
  • Ecosystem Marketplace
  • Ed Holt & Associates
  • Emory & Henry College
  • Emory University
  • Environmental Resources Trust (ERT)
  • EPA Office of Atmospheric Programs
  • EPA’s Green Power Partnership
  • Factor Global
  • Federal Trade Commission
  • First Environment
  • FTC Bureau of Consumer Protection
  • Furman University
  • GHG Experts Network
  • Gold Standard
  • Goshen College
  • Green Mountain College
  • Green-e Climate
  • GreenLife Organization, LLC
  • Harvard University
  • Honeywell
  • Interface RAISE
  • Interface, Inc.
  • International Carbon Action Partnership (icap)
  • International Carbon Reduction and Offset Alliance
  • International Emissions Trading Association (IETA),
  • IT Power
  • Johns Hopkins University
  • JP Morgan Chase
  • LA Community College District
  • Michigan State University
  • Middlebury College
  • NACA - National Association for Campus Activities
  • NACUBO - National Association of College & University Business Officers
  • NAEP - National Association of Educational Procurement
  • National Renewable Energy Laboratory (NREL)
  • Native Energy
  • NCSE – National Council for Science and the Environment
  • New York University
  • NIRSA - National Intramural-Recreational Sports Association
  • NJHEPS - New Jersey Higher Education Partnership for Sustainability
  • Noble Group
  • Northern Arizona University
  • Nserve
  • Oberlin College
  • Offset Quality Initiative
  • Pacific Lutheran
  • Paul Smith’s College
  • Policy Solutions
  • Pratt Institute
  • Resources for the Future (RFF)
  • Sasaki & Associates
  • SCUP - Society for College & University Planning
  • Second Nature
  • Southern New Hampshire University
  • SouthPole Carbon
  • Sterling Planet
  • Stockholm Environment Institute (SEI)
  • The CarbonNeutral Protocol
  • The Climate Trust
  • The GHG Protocol (WRI/WBCSD)
  • Trading Emissions PLC
  • UC Boulder
  • UNC Chapel Hill
  • Unity College
  • University at Buffalo
  • University of California
  • University of California, Santa Barbara (UCSB)
  • University of Florida
  • University of Pennsylvania
  • University of Vermont
  • US Green Building Council
  • Van Ness Feldman
  • Vertis Finance
  • Voluntary Carbon Standard
  • Warner, Norcross & Judd
  • William & Mary
  • WindStreet Energy
  • Winona State University
  • Winrock International
  • World Resources Institute (WRI)

Carbon Offset Frequently Asked Questions

What is an offset?

A carbon offset is a reduction or removal of carbon dioxide equivalent (CO2e) greenhouse gas (GHG) emissions that is used to counterbalance or compensate for (“offset”) emissions from other activities; offset projects reducing GHG emissions outside of an entity’s boundary generate credits that can be purchased by that entity to meet its own targets for reducing GHG emissions within its boundary. Generally, offsets fall into two categories: 1) emissions reductions or avoidance, such as replacing a diesel generator with solar panels, and 2) sequestration, or removing GHGs from the atmosphere, such as planting trees that will absorb CO2 as they grow. There are many different types of projects that generate offsets in both categories, however different offset markets and offset standards only recognize certain project types as acceptable.

Why should an ACUPCC signatory consider purchasing offsets?

ACUPCC signatories have an end-goal of achieving GHG neutrality for their institution. During the ongoing process of developing and modifying its Climate Action Plan, each institution will conduct a GHG inventory and develop plans to make internal GHG reductions. After planning and initiating these internal reduction strategies, a signatory has the option to consider the purchase of carbon offsets to get it closer to reaching its end goal of GHG neutrality. Offsets can drive real emissions reductions, potentially at lower cost than is immediately feasible on campus. Offsetting also serves to internalize some of the true costs associated with GHG emissions, providing an additional incentive for eliminating emissions. However, ACUPCC institutions will not necessarily include offset investments in their climate action plans. See “Carbon Offsets and the ACUPCC: A Strategic Approach” in “Investing in Carbon Offsets: Guidelines for ACUPCC Institutions” (the “Guidelines document”) for more information.

Isn’t offsetting just buying your way out of real reductions?

Voluntary carbon offsetting is not without controversy. It has been viewed by many as an opportunity to “greenwash” or to pay for someone else to make GHG reductions while continuing with business-as-usual practices. There are also many concerns raised about the quality of offsets themselves and how to ensure absolute reductions in atmospheric GHGs are being made. See “Project Quality Concerns” in the Guidelines document for more information. The ACUPCC emphasizes that GHG neutrality is an end-goal, and that internal reductions are the primary responsibility of each institution. Investing in offsets can be a short-term tool for reducing an institutions carbon footprint after efforts to avoid and reduce internal emissions have been initiated, but it should be of secondary focus. The purpose of the Protocol and the accompanying guidance document are to assist signatories in understanding and addressing the quality concerns around offset purchasing.

What is carbon neutrality?

For purposes of the ACUPCC, climate neutrality is defined as having no net GHG emissions, to be achieved by minimizing GHG emissions as much as possible, and using carbon offsets or other measures to mitigate the remaining emissions if necessary. The sources of emissions covered under the ACUPCC are Scope 1, Scope 2, and two elements of Scope 3: commuting, and air travel paid by the institution. The concept of “carbon neutrality,” “climate neutrality,” or “GHG neutrality” has been evolving and there is currently no universally agreed upon definition of the term. Signatories should be aware that these terms are often used interchangeably, and for the purposes of the ACUPCC the above definition is used for all three terms.

If my institution buys offsets, can it claim neutrality?

To achieve GHG neutrality under the terms of the ACUPCC, all Scope 1 and 2 emissions, as well as those Scope 3 emissions from commuting and from air travel paid for by or through the institution, must be neutralized. In this definition, Scopes 1, 2, and 3 refer to the Scopes laid out by the World Resources Institute/World Business Council on Sustainable Development Greenhouse Gas Protocol Initiative. A recent report from Clean Air-Cool Planet and Forum for the Future called “Getting to Zero: Defining Corporate Carbon Neutrality,” also provides some clear guidance on institutional carbon neutrality claims.

How much do offset credits cost?

The price of carbon offsets varies a great deal by project type, wholesale vs. retail price, offset provider, and any verification/standards processes. Please see the matrix comparing offset standards in the appendix of the Guidelines document. Offset prices can range from as little as $2 to more than $50 per metric ton of CO2e. Some projects are cheaper to carry out than others. For example, ocean sequestration can be quite expensive, as can large wind or hydro projects, while industrial gas destruction and some energy efficiency projects can be inexpensive, but cost is not the only important consideration in choosing offset projects.

How do I know my purchase is creating real emissions reductions? How do I gauge the quality of an offset?

There are a number of quality factors for offsets that should be considered to help ensure real reductions in atmospheric GHG emissions are made. These quality considerations include additionality, measurement, verification, transparency, permanence, vintage, and ownership. These are described in more details in the guidance document and are the typical considerations in carbon offset standards, a number of which have emerged in recent years in an attempt to stabilize the growing voluntary carbon market. There is also more detail on the most common offset standards in the voluntary market in the Guidelines document under the “Existing Offset Standards” section.

How is this different from cap & trade?

A cap and trade system is a regulatory scheme that can operate on a local, regional, national, or international scale. The basic concept is that a cap is placed on emissions per some entity (facilities, business, individuals, etc.) and the total emissions cannot exceed a given level. However, some entities will be in a better position to reduce their emissions and can then sell their credits with those that are less able (or it is less in their economic interest) to make reductions. Those entities, in effect, purchase the credits or the right to emit GHGs above the cap. In the voluntary carbon market, a similar trade happens without the cap. It is not a regulatory scheme, but a voluntary mechanism for reducing the overall level of GHGs. As greenhouse gas regulation has become more urgent and imperative, we are seeing an increase in the emergence of regulatory schemes, such as the Western Climate Initiative, the Regional Greenhouse Gas Initiative (RGGI), and the EU-Emissions Trading Scheme. The U.S. is likely to see some form of a cap and trade scheme on a national scale in the near future.

What are the projects?

Offset projects include activities that avoid, reduce, eliminate or sequester greenhouse gas emissions. Projects that avoid GHG emissions can include renewable energy projects, such as wind and solar. Projects that reduce emissions can include fuel switching and industrial gas destruction. Finally, sequestration projects capture greenhouse gases through either technological or biological processes to remove them from the atmosphere. The details of these project types as well as their strengths and weaknesses are described in the “Project Types” section in the Guidelines document.

How do I know how many credits my institution needs to buy?

One of the initial stages of the Presidents’ Climate Commitment is for the institution to conduct a greenhouse gas inventory. From this inventory, the institution will establish their emissions baseline, and from there, it can create its Climate Action Plan and determine its goals for reduction. In the context of this plan, each institution will decide when and how many metric tons of CO2e might be appropriate to purchase in offsets, if any, in achieving its goals. Most providers deal in metric tons of CO2e. However, there are some exceptions to this. For example, the Chicago Climate Exchange deals in CFIs, which are equal to 100 metric tons of CO2e. Signatories should pay attention to the units so that they purchase the appropriate amount to offset their own emissions.

Are there benefits beyond reducing GHG emissions?

There are potentially many benefits to investing in carbon offsets aside from the reduction of global greenhouse gases in the atmosphere. No matter what offset projects are invested in, the purchase of them is putting a price on carbon. Putting a price on GHG emissions is an important step in reducing them and eventually eliminating them. Offset projects are also beneficial in growing the market for less carbon intensive or carbon-free technologies and practices, such as the renewable energy market. Depending on the type and location of a project, there can also be numerous cascading social, economic, and environmental benefits, such as improved air quality, reduced costs, bringing communities onto an energy grid, job opportunities, etc. And finally, a significant benefit for higher education institutions is that there are educational benefits that can arise from working directly on an offset project or for students, staff, and faculty to engage in this growing market.

What does “additionality” mean?

Additionality is considered by most to be a fundamental test of legitimacy for carbon offsets. Tests for additionality attempt to determine whether a project would or would not have happened without the financial incentive, or other motivating factors, provided by carbon offset purchases. In other words, is the project “additional” or would it have happened under a “business-as-usual” scenario if the possibility of generating offset credits did not exist? Additionality is a complex feature to determine. To qualify as additional a project must be beyond any regulatory or legal compliance and pass project-based, performance-based, or financial additionality tests. These tests are described in the Guidelines document.

What is a registry and how do I choose the right one?

Registries play an important role in the offset markets by tracking credits and maintaining clear ownership and chain of custody of credits. They make information publicly available, demonstrate ownership, and through demonstration of ownership, can avoid double-counting. The ACUPCC Protocol calls for credits to be registered with a well-regarded registry. While the standards for what makes up a strong registry are not universally agreed upon, and are likely to change, desirable characteristics around serialization, transparency, scope of coverage, documentation, verification, etc. are described in the Guidelines document.

Does location matter?

The Protocol does not prescribe any location preferences for offset projects. However, the ACUPCC has identified four areas of consideration that could have implications for choosing projects in one geographic location over another: educational value, transparency, co-benefits, and the service mission of higher education. In general, the trend amongst US institutions is to give a preference towards local projects, and many are evaluating those options.

On the other hand, it is possible for projects in less industrialized nations to meet the above criteria, and could potentially have additional benefits, such as:

  • Greater GHG reductions per dollar invested
  • A larger sustainable development dividend in terms of meeting basic needs more effectively
  • Encouraging technology transfer and leap-frogging investments in dirty infrastructure
  • Cross-cultural, international educational opportunities

Furthermore, the concept of what constitutes an institution’s “immediate community” is not necessarily limited by geographic constraints. For example, many institutions have very close ties to international locations through long-time study abroad programs. Still, there can be risks associated with international projects, such as stakeholders not embracing or benefiting from the project, uncertainty around regulations, economic and political uncertainty, etc.

Are RECs offsets?

Renewable Energy Credits (RECs) are not the same as carbon offsets and the two terms should not be used interchangeably. Currently most projects that generate RECs would not meet the criteria of the Protocol. However, if a developer builds a grid-connected renewable energy project with the intent of generating offsets, and demonstrates it is additional, it results in a measurable reduction in GHG emissions that will not be double-counted, and it meets the rest of the criteria laid out in the Protocol, a renewable energy project could generate offsets. Please see the “Renewable Energy Credits” section of the Guidelines document for more details.


General resources, reports, and organizations involved in the voluntary carbon offset markets. This list is far from comprehensive and does not indicate any endorsement or partnership by the ACUPCC.


The Process

The Protocol was developed through a highly collaborative and transparent process between March and November, 2008. The section below describes the goals, process and outcome of the project, including the first and second drafts of the Protocol and Guidelines documents, each of which were available for public comment. A summary of feedback from each is also available below.

Second Draft

First Draft


The project will assist ACUPCC institutions in evaluating carbon offsets as they develop their Climate Action Plans by developing standards for determining the quality and effectiveness of different types of offsets. The process and its results will represent valuable contributions to the international public by bringing to bear upon the nascent offset markets the focused and coordinated intellectual scrutiny of the American academic community.


The project will establish a formal, voluntary protocol for evaluating and investing in carbon offsets, approved by the Steering Committee of the ACUPCC, as well as develop and disseminate educational materials relating to the scientific validity of offsets and considerations which must be taken into account in their investment and use.

The Challenge

Hundreds of campuses across the United States have accepted the challenge of reducing greenhouse gas emissions by changing their own practices and by financing practices by others (“investing in offsets”) that reduce the global generation and release of GHGs so that their own emissions are partially or wholly “offset”. A recent study by ICF International found that the voluntary market for greenhouse gas emission offset credits will grow to 220 million tonnes in 2012 from just 20 million in 2006. There is widespread concern that many “offset” products do not result in real and permanent emissions reductions and/or result in negative unintended side-effects. There are approximately 30 sets of standards, certification schemes, and protocols, in development or recently released, that aim to strengthen the emerging offset market. Currently, colleges are by and large wrestling with these decisions independently, with a minimum of knowledge sharing and cooperation.

The Opportunity

The ACUPCC proposes to develop and adopt a common Protocol to guide institutions in evaluating offsets and offset providers, purchasing offsets, and developing offset projects. The Protocol will not only strengthen the integrity of our own commitments but also serve as a guide for other organizations and individuals who are willing to act to reduce GHG emissions and who are seeking effective ways to do so. It would be the first coordinated effort of the American academic community to express a collective evaluation of the carbon offset market, and provide an effective and necessary vehicle for navigating this emerging space.

The Protocol will establish clear, rigorous guidelines for higher education to invest in the purchase of offsets that are real – measurable, verifiable, additional, enforceable, permanent – make meaningful, ongoing contributions to the development of the offset market, and catalyze movement towards climate neutrality. The process will include an educational capacity-building element through which ACUPCC signatories will get a solid understanding of the concept of GHG offsetting, the state of the market, and the common issues. It would also include an evaluation of the existing and emerging standards put forth by other groups, and could possibly include adopting such standards to guide the Protocol. The final result would be a clear statement of principles to be used in incorporating offsets into Climate Action Plans that would serve as a position statement on offsets by the signatories of the ACUPCC. It could include adopting an existing protocol or set of standards, developing a new protocol or set of standards, or some other form to serve this function.

This Protocol will remove uncertainty for ACUPCC signatories developing their Climate Action Plans, and provide clarity for other schools as they evaluate the ACUPCC and consider signing.

The Process

  • A Working Group, Chaired by David Hales, President of College of the Atlantic, develops a draft protocol during the period of February through April of 2008 collaborating via email and conference calls.
  • In March of 2008 an invitation is issued to signatories of the ACUPCC and offset experts to serve on the Working Group.
  • In March and April of 2008 an Advisory Group made up of a broad range of experts in higher education, sustainability, and the carbon markets is established.
  • In May of 2008 a preliminary draft is released to signatories of the ACUPCC and the Advisory Group for initial comment.
  • A half-day meeting of the Working Group is hosted by the Wege Foundation on June 5, 2008. An invitation would be made to all of the ACUPCC signatories to attend and participate in developing the Protocol.
  • In June the second draft is sent out for comment to all of the ACUPCC signatories and the Advisory Group.
  • In July comments are gathered and evaluated by the Working Group.
  • The final consultation and adoption of the Protocol via email by the ACUPCC Steering Committee.
  • In September, the Protocol is published and distributed, followed by an educational capacity-building package for ACUPCC signatories.
  • The follow-up to the Protocol extends through the end of 2008, during which time the Protocol is distributed and promoted, leveraged as a draw for new ACUPCC signatories, and used as a resource and a model for other sectors. During this time next steps are evaluated, with a specific focus on developing an Offset Purchasing Consortium and/or Offset Trust for ACUPCC signatories

The Outcome

The final product of this process would be a document laying out the Protocol–a clear statement of principles to be used in evaluating the role of offsets in Climate Action Plans. This document would be published and disseminated to the ACUPCC signatories, and made available to the public. A package of educational capacity building materials on offsets would also be developed and disseminated to ACUPCC signatories.


  • March 10 – ACUPCC signatories and select carbon offset experts are invited to serve on the Working Group
  • March 21 – Potential members of the Advisory Group are identified
  • April 2 – Informational primer on offsets and a preliminary outline of the Protocol is distributed to the Working Group
  • April 18 – Conference call of the Working Group to develop content and direction of the Protocol is held
  • April 28 – Draft of the Protocol is compiled and distributed to Working Group
  • May 1 – First draft is distributed to Working Group
  • May 5 – Comments from Working Group on first draft are due
  • May 15 – Announcement of the first draft is sent to the Advisory Group and to all Signatories in the monthly update with a link to the draft for review and comment by May 27
  • May 27 – Deadline for comments from Signatories and Advisory Group on the first draft
  • June 5 – The Working Group and other signatories meet at the ACUPCC Climate Leadership Summit in Grand Rapids
  • June 16 – Comments are incorporated into the second draft
  • July 14 – The second draft is sent to the Advisory Group and Signatories for comment
  • August 1 – Deadline for comments from Signatories and Advisory Group on the second drafts
  • August 5 – Working Group incorporates public comments into final draft
  • August 8 – Working Group to review the final draft and indentify gaps that need to be addressed
  • Mid-August – The Steering Committee review, ratify, and adopt the Protocol via electronic meetings
  • November 10 – The Protocol is publically launched at the AASHE 2008 conference along with a press release. The final version is distributed to Signatories and participants in the process
  • November 10 - December 31 – Protocol is promoted and publicized