I must respond by saying no, I do not agree with the position that farmers should not get credit for early action, but I also totally empathize with the officials and understand why that's their starting place. We just have to give them the tools they need to make sure that's not where they end up.

There are a couple of things. First, in terms of solution, in the Nori marketplace any decision you make or anyone makes will be a compromise. We surveyed a bunch of very interested market buyers and secured support among that buyer community for the idea that we would issue credits, and there are two tests. For soil carbon, a stock change is arising from changes in practices that might have been implemented any time after December 31, 1999. I like Bryan Gilvesy's Kyoto 1997 start date a lot. We picked 1999 in the U.S. just because we found we had data availability issues before that and that was our binding constraint, but we also said we would only issue a maximum of five years' worth of grandfather credits to any project.

When you're doing that design, separate the question of what the “not before” date is for the investment that triggers the incremental carbon stock change versus how many years of crediting you are getting. Any decision we'll make will be arbitrary, but I think it's really important that we struggle with that and reach consensus on a decision that does give early adopters credit.

The other point I'd like to make is that in every—outside Canada, anyway—variation on cap and trade rules, any oil producer or refinery operator that has an emissions intensity that's lower than their peers gets surplus and marketable allowances in exchange for that performance, even if they have been performing in that manner for 25 years.

Why would we give credit for early action to oil refineries and not to farmers? I don't get that one.

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