Strengthening Ecosystem Conversion Safeguards in Verra’s Version 5

In Verra’s consultation on Version 5 of the Verified Carbon Standard (VCS), Eco Sustainability submitted detailed feedback on Section 1.9: Enhanced Ecosystem Conversion Safeguards. These rules matter because they determine how projects interact with ecosystems, and whether biodiversity and community rights are protected alongside carbon.

We supported the introduction of the “ecosystem integrity” concept. Integrity is broader than “function” because it captures biodiversity, structure, and resilience, not just whether an ecosystem performs a single role. In practice, this matters. A wetland may still filter water (a function) but if its biodiversity is collapsing, calling it healthy would be misleading. Integrity provides a more precautionary basis for classification.

However, definitions alone are not enough. Verra’s proposal relies heavily on qualitative characteristics of degradation, which can be interpreted differently across geographies. For example, one project might classify a heavily logged forest as “low integrity” while another might rate it “medium.” To reduce this subjectivity, we recommended a standardized Ecosystem Integrity Assessment Framework. This could include clear indicators, a tiered scoring system, and consistent evidence requirements such as remote sensing data, species surveys, and participatory input from Indigenous Peoples and local communities.

We also flagged missing characteristics that should be added to the safeguards. Irreversibility, fragmentation, and loss of ecosystem services are critical signals of degradation. These can be evidenced through data such as satellite imagery showing landscape fragmentation, hydrological models, or even shifts in local crop yields when ecosystem services decline. Including these would provide a more complete picture of ecological change.

Another safeguard we supported is the 10-year rule, which prevents recently converted ecosystems from being enrolled as restoration projects. This is an important guardrail against opportunistic land clearing followed by immediate project registration. We recommended that any exemption be supported by third-party evidence, for example satellite data showing abandonment or natural disturbance beyond the proponent’s control.

Finally, we raised concerns about unintended consequences. If the rules are applied too rigidly, ecologically beneficial projects could be excluded. Take a degraded grassland dominated by invasive species. Restoring it into a native peat swamp forest could bring higher carbon storage and biodiversity benefits. Yet under current wording, such a transition might be classified as “natural-to-natural conversion” and disqualified. We recommended clearer guidance to differentiate between harmful conversions and ecologically justified restoration.

Overall, we believe Verra’s move toward ecosystem integrity is the right step. But the safeguards will only build credibility if they are applied with clarity, evidence, and a structured framework. Otherwise, the risk is inconsistency and lost opportunities for genuine restoration.

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