Glossary

Cost-Saving Strategies for California and Quebec Regulated Emitters

by: Derek Six | Chief Business Officer | June 29, 2021

November 1, 2021, is the compliance deadline for emitters covered under the California and Quebec Cap-and-Trade programs. By November 1st, emitters are required to submit the compliance instruments representing their full triennial (2018-2020) emissions. One of the simplest compliance cost-saving strategies is for entities to take full advantage of their ability to substitute offsets for up to 8% of their total obligation. However, for the previous compliance period covering 2015-2017, California entities surrendered only 6.36% of the possible 8% offsets, and Quebec entities surrendered only 3.5% of the possible 8% offsets. Why did emitters leave so much potential savings on the table? With offsets currently selling at a historically large discount to allowances, will entities again leave substantial savings on the table, or will they utilize new offset buying options to help them realize all of the possible savings?

Missing Out on Potential Savings

Allowances (permits for one metric ton of CO2e) are currently priced at approximately US$21.77. Offsets are currently priced between US$13.00 and US$15.00, depending on type and risk profile, providing emitters a discount of 30-40%. It should be hard to ignore such significant cost savings, but there may be a few possible reasons emitters would choose not to maximize their savings:

In previous compliance periods, information about offsets may have not been available or widely understood
Market access to offsets may have been limited
Perceived risks may have prevented buyers from utilizing offsets

While the first two explanations may have been valid in the past as emitters became accustomed to the program, we suspect that it is the last possibility of perceived risks that had the greatest impact on offset utilization. Would-be buyers of offsets may have been dissuaded by the complexity of California’s invalidation rules, and their accounting departments may have warned them about the difficulty of accounting for the possibility of invalidation. While less than 0.1% of California-issued offsets have been invalidated, such a possibility may have outweighed the cost savings for some buyers.

Understanding the Risk

Before emitters consider a solution, it is important for them to understand the various types of offset buying options that currently exist in the market:

Quebec-issued Offsets: these offsets do not have buyer liability, but because Quebec has issued only 1.05 million offsets, this category is not an available buying choice.
California CCO-8s: when initially issued, California has regulations that would allow them to invalidate offsets for up to 8 years if a regulatory compliance violation is later discovered.
California CCO-3s: offsets whose invalidation period has been reduced to 3 years.
California GCCOs: offsets exposed to invalidation risk but sold by a seller offering to replace them if they are ever invalidated.
California CCO-0s: offsets whose invalidation period has expired.

Confusing, no doubt, and definitely likely to dissuade many buyers. However, one option in this list is relatively new to buyers that offers no risk and a simple transaction.

Consider California CCO-0s

California CCO-0s, the final category in our list above, are California compliance offsets that are not exposed to the possibility of invalidation because their invalidation period has expired. CCO-0s are the most expensive of the quality levels, currently at US$15.00 or a 30% discount to allowances, but they cannot be invalidated. Because the risk period has expired, there is no need to enter into complicated GCCO (Golden/Guaranteed California Compliance Offset) contracts where the buyer relies on the contractual promises of the seller and the quality of the seller’s financial credit. CCO-0 purchase contracts are simple and easy to execute.

Some buyers will find that the price savings of purchasing CCO-8s or CCO-3s outweigh the risks, but the CCO-0 offsets represent an exciting new opportunity to reduce upcoming compliance costs for many emitters.

If you would like to learn more about your options or purchase CCO-0s, please feel free to contact us. We are happy to help and currently have CCO-0s available for purchase.

About the Author

Derek Six serves as Chief Business Officer at ClimeCo, where he leads the company’s cross-cutting business functions, the firm’s ODS management program, and a private equity fund ClimeCo manages. He holds an MBA in Investment Management and Portfolio Analysis from Pennsylvania State University’s Smeal College of Business.

The Need for Trees

by: Taylor Marshall, Director of Sustainable Programs, Restore the Earth Foundation | May 27, 2021

When we talk about all the ways to combat greenhouse gasses, one method that is gaining a lot of attention recently is reforestation. Not only does reforestation help sequester future carbon, but it provides many additional benefits for surrounding communities that make reforestation a win/win type of project. Planting trees adds vital nutrients to the soil, enabling other vegetation to thrive; they also create a habitat for animals to flourish in, protect waterways, prevent flooding, and create a healthier ecosystem. It seems simple to plant trees, but in order to achieve the large scale and long-term permanence required to realize the greatest impact and value, it takes partnerships, a major funding investment, and resources to make it happen.

Procuring Funding and Partners

So, we need trees, but how do we pay for them? How do we find partners who want to support a reforestation project? This is where Restore the Earth Foundation, Inc. (REF) steps in. REF is a not-for-profit organization with a mission to restore the Earth’s essential forest and wetland ecosystems. They work together with partners to bring solid solutions to deliver successful restoration projects that meet strategic environmental, social, and economic objectives.

Many people know that the United States Department of Agriculture’s (USDA) Natural Resource Conservation Service (NRCS) is on the ground in every region in the U.S., working with conservation partners. These partners consist of private industry, non-government organizations, Native tribes, state and local governments, soil and water conservation districts, and universities. The Regional Conservation Partnership Program (RCPP) is a standalone program that offers $330 million yearly to support locally-driven partnerships that address climate change, improve water quality, combat drought, enhance soil health, support wildlife habitat, and protect agricultural viability in the United States. Each year, only 85 projects are selected to receive this money. In 2020, REF focused on applying to this program to pilot its private/public investment model to reforest 1 million acres in the Mississippi River Basin, the third-largest watershed on Earth. We are pleased to announce that in April 2021, REF was awarded $7.4 million in grant money from RCPP.

“RCPP is a public-private partnership working at its best,” said Terry Cosby, Acting Chief for USDA’s NRCS. “These new projects will harness the power of partnership to help bring about solutions to natural resource concerns across the country while supporting our efforts to combat the climate crisis.”

In addition to the grant, REF secured additional private investment partners to match and amplify the grant funding for a total of $19 million. Their hard work to find funding and the right partners has paid off. Now, REF can support a unique pilot project that will extend permanent conservation easements to reforest and protect critical land. This additional funding increases impact and provides measurable environmental, social, and economic outcomes.

Developing the Project

The funds secured will support restoring 5,000 acres of marginal land in a floodplain in Arkansas to its previous forested condition. With this pilot project, REF and the NRCS will apply innovative approaches to the wetland reserve easement process to engage more landowners, focusing on overcoming historically underserved landowner participation barriers. Conservation easements restore and protect land for future generations, while allowing landowners to retain private property rights, enabling them to live on and use their land at the same time.

To accomplish this, REF will develop an easement template with NRCS to emphasize water quality and acknowledge carbon sequestration while amplifying wildlife and biodiversity benefits. The project envisions accelerating the easement process and resources, providing more landowner participation to restore the land to the previous native forested condition. NRCS will hold the easements to assure the integrity, permanence, and long-term benefits of the investment.

The Benefits

As a result of this reforestation, NRCS will address climate change and achieve significant environmental, social, and economic co-benefits beyond their regular funding. High-yielding croplands will not be taken out of production.

In addition to the restoration of the forest, the newly planted native trees will generate 1,000,000 mt (CO₂e) of carbon emission reductions. REF will recapture funds through revenues generated by ClimeCo, which will market the greenhouse gas reductions. In addition to a payment for the easements and reforested land, participating landowners will receive a share of these revenues. The balance will be reinvested by REF into additional projects to scale the program.

“Through the USDA’s Regional Conservation Partnership Program, we’re excited to be engaging more of those interested landowners to ensure that wildlife, habitat, and communities are enhanced in a restored, healthy, self-sustaining system,” said PJ Marshall REF, Co-Founder and Executive Director. “The restored ecological systems provide for public benefits that include erosion control, improved soil and water quality, wildlife habitat, groundwater recharge, flood reduction, and carbon sequestration.”

Arkansas has a substantial backlog of landowners interested in conservation easements; this project will help make a meaningful dent in the backlog. Project partners have committed to purchasing carbon emission reductions in the form of Forecasted Mitigation Units (FMUs) or credits associated with project activities.

We are excited about this project. Both REF and ClimeCo believe that these large-scale, collaborative projects, focusing on regional water quality, carbon sequestration, and local impacts, provide a tangible path for achieving big-picture climate solutions. These projects also go beyond environmental improvements to provide significant regional and local benefits through ground engagement.

To learn more about this project or if you have an Arkansas Landowner interested in participating in this project, please contact Taylor Marshall, tam@restoretheearth.org.

About the Author

Taylor Marshall is the Director of Sustainable Programs at REF. She has dedicated her professional life to identifying and promoting solutions and opportunities to address national and international environmental issues. Taylor manages partner relationships, represents REF at local, national and international workshops, meetings and conferences. She has been responsible for securing major grants and funding for REF and is the chief “in the mud” coordinator of all of REF’s corporate and community volunteer planting events. Taylor fills a key role in coordinating with all REF’s partners in implementing strategic communications, outreach and educational plans related to all projects.

Prior to joining Restore the Earth, Taylor was with The Water Institute of the Gulf in Baton Rouge, Louisiana, where she applied her expertise in integrated water resource management to develop and promote community-based approaches to protecting and restoring the Gulf coast communities from storm risk and land loss and enhancing community resilience.

Taylor has a Masters of Science from McGill University in BioResource Engineering with a concentration in Integrated Water Resource Management (IWRM).

A Story About Circular Restoration

by: Chris Parker, Director of Plastics Program | April 28, 2021

This blog provides a fictional story about a town called San Maya on the Central American Caribbean coast. Even though the town is fictional, as well as the project in this story, it is based on real activities that are currently happening in different locations all around the world. We have combined these activities into a single story to provide you a glimpse into what it could look like if we used innovation, determination, and cooperation together to address our plastic waste problem.

The Story of San Maya

For generations, the small town of San Maya on the Central American Caribbean coast made its living from fishing. In the 1990s, tourists from all over the world began coming to experience the local culture, scuba dive, bird watch, and fish. Residents enjoyed new employment opportunities and rising incomes. During the 2000s, they were able to build a new school, clinic, and water treatment plant. Plans were put in place to protect the mangrove forests, waterways, and reefs, as these were the economic resources providing new prosperity.

Today, San Maya’s beaches, estuaries, and reefs are covered with plastic waste that flows down the Rio Jaguar river from the city. The mangroves are dying from the combination of plastic toxicity, climate change, and removal. Tourists stopped arriving a few years ago due to the town’s inability to manage the volume of plastic from the river, which litters the community. With the loss of tourism income, local anglers returned to their boats for commercial fishing, yet most of their trips resulted in catching more plastic than fish. Today, the people are moving away from San Maya in search of work; they have become plastic refugees.

A Time to Restore

The future of San Maya depends on the restoration of its fishery ecosystem. This requires removing plastic waste from its environment, diverting future ocean bound plastic, and creating a waste management infrastructure. San Maya’s plastic waste has unrealized value and, once it becomes valued, the city can help create a more circular economy in the region.

The emergence of the plastic credit market has created an opportunity to help San Maya. ClimeCo can work with the community to fund the removal of plastic waste and start a recycling operation to upcycle collected material into next-use construction products while helping to restore the mangrove forests. Local industry can be approached to solicit their support in the project to reduce the business risk associated with increased economic and societal disruption from plastic waste. Because this local industry is currently focused on new carbon neutrality commitments and goals for addressing their plastic footprint, this represents a unique opportunity for them.

Creating the Rio Jaguar Project

The upfront funding from ClimeCo’s partnering company can be used to build a small recycling facility and hire San Maya residents to collect, measure, sort, and record the recovered plastic – thus creating the Rio Jaguar Project. From the project’s plastic collection and recycling operations, ClimeCo would develop and register new plastic credits through Verra’s Plastic Waste Reduction Program. Each credit represents one tonne of recovered or recycled plastic, which upon issuance, a company can purchase to support frontline efforts tackling the plastic waste crisis.

Part of the agreement with our Rio Jaguar project’s industry partner is that they will receive a portion of the generated plastic credits, which can be used to offset part of their plastic footprint. ClimeCo will sell the remaining credits, and the proceeds can fund the purchase of a river trap to collect ocean bound plastic debris, as well as the expansion of the San Maya recycling facility. As the area’s ecosystem gets restored, the Rio Jaguar project will move into phase 2 – ClimeCo providing capital to hire additional workers to plant thousands of mangrove seedlings.

Mangroves are very efficient at sequestering and storing carbon compared to their terrestrial counterparts, up to 10 times better. ClimeCo will develop and register carbon offsets through Verra’s Blue Carbon Conservation methodology from the new mangrove plantings. As part of our industry partner’s carbon neutrality program, they will purchase a portion of the mangrove-issued carbon offsets, which will be used to help address its manufacturing facility’s greenhouse gas emissions.

Conclusion and Potential Co-Benefits

Plastic credit projects can address various interrelated problems: ecosystem degradation, inadequate waste management, biodiversity loss, health and economic risks, and carbon-fueled climate change. These projects can also support a menu of UN Sustainable Development Goals, including:

No Poverty
Decent Work & Economic Growth
Industry, Innovation & Infrastructure
Sustainable Cities & Communities
Climate Action
Life Below Water
Partnerships for Goals

Success for these types of projects requires establishing working partnerships to the benefit of all stakeholders. Unfortunately, the problems seen in this story are being replicated all over the globe, yet the efforts of government and philanthropy are not matching the scale of these problems. One key component is for private sector companies to use their vision and capital to initiate circular economics. The development of plastic credits and carbon offsets in this story gave our industrial partner the market-based financing mechanisms to deploy its capital and help create relationships to benefit its ESG programs. Plastic recovery and mangrove restoration provide the value to move a restoration and circular business economy forward. Partnerships will make it sustainable.

To learn more about plastic waste, Verra’s Plastic Waste Reduction Program, or discuss an idea for a project, please feel free to contact us. We would love to help you become part of a circular restoration project.

About the Author

Chris Parker has 20+ years of experience in energy and commodity markets, sustainability, conservation, and ESG. He leads ClimeCo’s plastic market program, which partners with projects worldwide to recover and recycle plastic waste. Prior to joining ClimeCo, Chris had been consulting and leading projects in both the corporate and environmental nonprofit sectors to create business solutions for a sustainable economy. Chris holds a Bachelor of Science in Corporate Finance & Investment Management from the University of Alabama. He loves to spend his free time surfing, climbing, fishing, and playing chess.

A Chat About Sustainability

by Kendall Bedford, Project Manager | March 31, 2021

Background

This blog flourished while two ClimeCo colleagues sat down to enjoy a virtual cup of joe while discussing a topic that inspires them – Sustainability.

Long-time Project Manager (and part-time master’s student), Kendall Bedford, and her team leader, Emily Damon, VP of Sustainability, Policy and Advisory discussed what they love about sustainability and what they see in the marketplace. Their responses have been edited for conciseness and clarity.

A Journey in Sustainability

To some, “Sustainability” can be a loaded word due to its multiple definitions and implications in the business world. For myself, it simply implies an opportunity to ensure longevity within our society for our peers, our planet, and our work. As a young professional and master’s student, these topics are meaningful to me. Through the work I am currently doing at ClimeCo, and Sustainability’s intersection with Business, which I am studying at UPenn, I hope to become a future leader in this space and help to unite various priorities and people while working to create real progress under a shared goal.

Today, I am speaking to a leader who is impacting the sustainability field, and one I am lucky to call my teammate, Emily Damon. Below, Emily and I discuss her previous work in the Environmental, Social, and Governance (ESG) space and why she continues to enjoy it, the challenges she encounters, and how this space has evolved and will continue to change over time.

Kendall: So, let’s start off with you telling me a little bit about yourself and why you chose to build a career in the sustainability field.

Emily: I suppose the short answer is … *laughs* …frisbee. I played competitive ultimate frisbee for most of my life, and I chose my college so that I could play for one of the best women’s teams. Then I chose my major based on my teammates. Many of them were majoring in Earth Systems, an interdisciplinary degree with a focus on climate change. I liked science and cared about climate change, so I gave that a try. I ended up liking the engineering approach to climate change even more, so I shifted over partway through. I have stayed in this field because I’m making an impact, learning new things, and working with teams. The daily work gives me a steady drip of optimism for the future.

Kendall: I completely get that. As someone who is in school for this subject now, it’s nice preparing to work in an evolving field! You’ve been working in this space for a significant amount of time, how has your perspective on ESG work changed?

Emily: When I finished my degree, I felt that the solutions for climate change were clear. Over time, I have come to appreciate that seeing the optimal solution is only half the battle. Getting very-human business mechanisms to change is hard, slow, and important work. It can feel sluggish, but I think it’s the kind of change that sticks around.

Kendall: What about the field itself – how have you seen that develop over time? Do you think the changes have been for the better?

Emily: When I first started out doing this work, I was often supporting a smaller, independent sustainability department within organizations. Within the last 4-5 years, their ties to the rest of the company, especially to the C-Suite, have grown significantly. I think that’s a wonderful thing! It acknowledges that the drivers for sustainability are more significant, and the benefits of pursuing sustainability are more obvious.

Kendall: I love that! Buy-in from executive leadership and company board members is something we discuss in class all the time; it’s so important because it offers credibility to the work the sustainability teams are doing and can even help garner more support from stakeholders.

Emily: You know, without the ties to the C-Suite, smaller teams could sometimes be more nimble, at least when it came to things like measuring impacts, reporting, and making small commitments. But the connections to the leadership became essential when those sustainability teams were ready to change the organization’s behavior and needed funding for projects. As connections to leadership strengthen, processes change and new governance takes shape. It can sometimes seem as if things have slowed down, but it’s usually just a phase of growing pains. It’s an interesting dynamic! *laughs*

Kendall: When it comes to sustainability and communication, especially now that you get to work with more organizations with a higher-level team, there are many different definitions for sustainability floating around, and it can be a “triggering” term for some. How do you level the playing field and communicate sustainability (the idea) to your teams and clients?

Emily: I start with a very broad definition and with the understanding that any company I’m working with probably has its own, so I’m flexible. ESG is what I see typically falling under a company’s sustainability umbrella. To me, it’s a logical review of everything a company touches. So, what are our impacts on the planet (E) and on people (S), and how have we set up our structures and processes to ensure we can be improving those impacts (G)?

Kendall: That being said, something I’ve heard is that it’s a bit harder for companies to wrap their head around certain aspects of ESG work. In your experience, what has been the hardest concept for a business to learn about and improve on?

Emily: This is one with a lot of variety. It’s a common story to get on the phone with someone who started out working in an environmental role and then had a sustainability role pushed their way. That trajectory can leave companies with a blind spot regarding stakeholder’s “S” and “G” expectations.

Kendall: What do you recommend to those who find themselves in this position?

Emily: Even when companies have things like great employee training programs or hiring practices designed to increase workforce diversity, these initiatives aren’t always linked with the sustainability program. One thing that can often help a company in this position is a materiality assessment, a structured process for looking at a wide range of possible sustainability topics and determining the company’s priorities based on a diverse set of stakeholder perspectives.

Kendall: Why do you think ClimeCo is uniquely positioned to participate in this kind of work?

Emily: Oh, I think ClimeCo is in an amazing position to help companies with sustainability! Companies have a lot that they need to be doing right now, from communicating their progress or measuring their impacts to creating new strategies and executing them across the ESG space. What’s unique to ClimeCo is that we can support companies through more of these steps than other firms can. We have teams that advise, measure, and communicate, but also teams that can execute by developing emission reduction projects or transacting environmental commodities. It’s a natural progression! Many companies are doing each of those things, but none do all three as well as we do.

Closing Thoughts

In the classroom and at the office, Sustainability has been an almost constant discussion subject for me within the past year. In speaking with Emily, not only was I able to validate some of my suspicions about how broad-reaching and impactful the ESG field can be, but I was able to confirm my beliefs about the exciting work I have gotten to do at ClimeCo. In my (almost) four years of working here, the idea of “we can do it all, and do it well” has rung true. Even more so now, I am exceptionally excited about everything that the team, and Emily with her expertise and passion, will be able to accomplish in this space.

To find out more about the ClimeCo’s Sustainability, Policy and Advisory team’s great work, please contact us by visiting, www.climeco.com.

About the Author

Kendall Bedford started off at ClimeCo in 2017 specializing in managing the data associated with ClimeCo’s extensive network of biogas destruction projects. She now dedicates her expertise to the team in the form of assisting with Sustainability consulting work and working closely with the environmental crediting process. She is currently pursuing a dual degree Master’s in Environmental Studies and MBA at the University of Pennsylvania.

Creating Carbon Offsets – It Starts With A Methodology

by David Priddy, VP of Business Development | February 24, 2021

With the continued push by businesses in recent years to establish more stringent sustainability goals with lower GHG thresholds, there’s been a corresponding rush by corporations, project developers, technology providers, and charitable foundations to implement emission reduction solutions to help meet this growing demand. This has led to a plethora of innovative ideas and concepts from entities seeking to utilize carbon financing to bring their ideas to life. As a leader in the carbon emission reduction and sequestration space, ClimeCo will frequently field requests on how to implement these ideas to generate and sell carbon offsets, which incentivizes continued investment in project activities that deliver emission reductions. But after listening to entities pitch their ideas, the question that I most often hear is: “Can we create carbon offsets?” Well, the answer to that question can depend on many factors, but it all starts with an appropriate methodology.

Carbon Offset Methodologies

A carbon offset methodology is a framework document that defines the quantification and parameters that are required to generate carbon offsets throughout the life of a project. It establishes the project’s baseline, identifies qualifying practice changes to reduce carbon, and defines the monitoring requirements necessary to ensure that the reductions are real, quantifiable, verifiable, and additional to what would have happened in the absence of the project.

There are seemingly as many different offset methodologies available today as there are carbon reduction project ideas, but continuous innovation in this space keeps challenging that theory. Voluntary registries, along with those carbon compliance programs that allow for the use of offsets, generally utilize their own protocols and methodologies. In the North American voluntary market, we primarily work with three voluntary offset registries: The Climate Action Reserve (CAR), American Carbon Registry (ACR), and Verra; these three registries offer more than 100 established methodologies. Most of these existing methodologies can be classified into one of several primary categories, including industrial, agricultural, energy efficiency, waste, transportation, and renewable energy; however, the requirements for a particular methodology are usually written for a specific project activity, such that there is little room for interpretation or variance. This often results in the need to modify an existing methodology or create a new one to support a proposed project’s activities if those activities do not precisely fit the parameters of an existing methodology.

Methodology Development

To ensure the integrity of carbon offsets, credible methodologies employ best practices based on the ISO 14064 standard, providing guidelines for quantifying, monitoring, reporting, and verifying GHG emissions and reductions. These standards require that each project conducted under a methodology is calculated in a way that is relevant, complete, consistent, accurate, and transparent, and meets the aforementioned key crediting criteria (real, quantifiable, verifiable, and additional). Therefore, the development of a new methodology requires a significant amount of input from the scientific community and various stakeholders, including industry groups, NGOs, and the legal and environmental justice communities. The process can be lengthy and will typically include an individual proponent or group that authors the draft methodology, the formation of a stakeholder working group that provides technical and legal review, and a public comment period. In our experience, it is quite common for a methodology development effort to take at least 12 months and cost hundreds of thousands of dollars in fees to complete.

Lessons Learned

The ClimeCo team has been involved in developing several project methodologies, either as an author/co-author or by serving on a working group. Our experience ranges from methodologies focused on industrial gases, such as the destruction of ozone-depleting substances (ODS) and the abatement of nitrous oxide (N₂O) from Nitric Acid and Adipic Acid production, to avoided methane emissions from organic waste composting and agricultural methane destruction. We are also working with clients on the development of some new methodologies that hold significant promise. Through all of this, we have learned that the process is best served by a collaborative and transparent effort between the project proponent and the registry that balances scientific integrity, conservativeness, and financial viability to ensure a robust, practical, and defensible methodology.

The Bottom Line

As companies continue to ratchet down on their GHG commitments, the voluntary carbon market is poised for significant growth. Buyers in this market have become increasingly savvy; they are demanding more from the offset projects they support, including a sharper focus on those that align with their businesses and produce various co-benefits. This opens opportunities for creative thinking and project innovation in areas that existing offset methodologies may not serve. To maximize the potential for success, a project owner/proponent should align themselves with an experienced consultant like ClimeCo to guide them through this process.

About the Author

Dave Priddy is ClimeCo’s Vice President of Business Development. He has more than 30 years of experience in the environmental management field and is responsible for the firm’s strategic market initiatives and the evaluation of new project opportunities. David holds a B.S. in Engineering from the University of Louisiana, Lafayette.

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Next Entries »

Glossary

Cost-Saving Strategies for California and Quebec Regulated Emitters

Cost-Saving Strategies for California and Quebec Regulated Emitters

The Need for Trees

The Need for Trees

A Story About Circular Restoration

A Story About Circular Restoration

A Chat About Sustainability

A Chat About Sustainability

Creating Carbon Offsets – It Starts With A Methodology

Creating Carbon Offsets – It Starts With A Methodology

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