In my work developing environmental projects, I am often asked a variation of the same question by funders, auditors, and potential partners. It comes in different forms—”What is your baseline scenario?”, “Can you prove this isn’t just business-as-usual?”—but it always boils down to one simple, piercing inquiry: “Would you have done this anyway?”
It’s a question with a universe of complexity behind it, and it gets to the heart of the most challenging and essential principle in the carbon market: additionality.
At its core, additionality is the “but for” test. It is the gatekeeper that ensures carbon finance is funding new climate action, not just subsidizing activities that were already profitable or standard practice. A project must rigorously prove that the carbon removal would not have occurred but for the existence of the carbon market incentive.
This sounds straightforward. In practice, it can be a philosophical minefield. How do you prove a negative? How do you definitively document a future that, because of your intervention, will never exist? Consider a sawmill with a mountain of sawdust. If they process it into biochar, is that a savvy waste-management decision or a climate action? The answer is often “both,” and this is where the clean lines of theory smudge into the messy canvas of reality.
The Vulnerabilities of Additionality
Yet, for all its importance, the subjectivity inherent in proving a counterfactual creates vulnerabilities. Where there is complexity, there is opportunity for creative interpretation, and a skilled consultant can sometimes frame a project to fit the criteria, even when its spirit is violated. This can manifest in several ways:
- Creative Financial Modeling: A project may be profitable on its own, but one could construct a financial model with inflated “risk premiums,” pessimistic revenue forecasts, or high operational cost estimates. This manufactured model would then “prove” that the project is not viable without the carbon revenue, thus qualifying it as additional.
- Strategic Baseline Selection: The “business-as-usual” scenario is often a matter of interpretation. A project developer could choose the most carbon-intensive possible baseline from a list of approved methodologies—such as assuming open-field burning of a residue—even if the actual, pre-project practice was something less emissive, like composting.
- The Regulatory Timing Game: If a new environmental law is announced that will eventually mandate a certain practice, a project can be rushed to registration before the law takes effect. Technically, at the moment of registration, the action is “surplus to regulations” and thus additional, even though it will soon become standard practice.
Why the Principle Still Matters
Acknowledging these vulnerabilities is not to say the principle is broken. On the contrary, it highlights why rigorous, honest application is paramount. From my vantage point, working to restore degraded land and support smallholder communities, the principle of additionality is the foundational pillar that makes essential ecological work possible.
For a farmer in East Nusa Tenggara, the standard practice for agricultural residue is to burn it. The shift to converting that waste into stable biochar requires new equipment, new training, and new labor—costs that are simply not viable without the carbon revenue stream. In these contexts, the “but for” test is answered with resounding clarity. But for this intervention, the carbon would have been lost. The project is unequivocally additional.
Navigating the complexities of additionality can be frustrating. It demands meticulous proof and forces us to confront uncomfortable questions. But this rigor, this relentless questioning, is not a bug; it’s the system’s core feature. It is the very mechanism, however imperfect, that guards the integrity of the market and ensures that every dollar spent and every credit issued represents a genuine, additional step forward for the climate.
