You have found yourself at the Reversing Climate Change podcast. I'm Ross Kenyon, I'm the host. Before we get started today, I want to tell you about the sponsors of this episode. I'm so grateful we have a new one, which is cool. Cdr Jobs, surely if you work in carbon removal or aspire to, you have been on the Cdr Jobs website. They are the place to find all of the Cdr jobs. No adulteration, no other adjacency. It's carbon removal.
So that's the place to look. One of the things that is very cool about being ACDR job posting site is that they get a lot of data on employment in Cdr and they have not slept on their data duties. In fact, last year they did ACDR salary report, which details how much people make in the space, if there's any discrepancies across gender or race, of which countries, where are jobs being created in carbon removal.
They gathered over 800 data points, 400 individual responses, and 400 salaries from job openings, which represents only a partial sample size. But even still, that report was generated A4 figure amount, which is a lot of times to download a report. People want this information and they're doing another survey this year. They're doing another survey this year. So recently I put out a small episode about why I think this kind of work is important, about HR decisions, about pay
transparency. Why I think that's on net a good strategy if you are an employer and also if you're an employee, why you should talk to your colleagues about salary and destigmatize conversations around that topic and why they can be really useful. And I think the Cdr Jobs 2025 salary survey is a really powerful way to anchor that conversation, to give you something to talk about because it makes sure that employers are creating a trustful environment.
And it's also making sure that employees are not being taken advantage of in any way. I don't suspect that is happening. Cdr is a small place that is very mission driven, but it is beneficial for us to work together to make sure that, you know, our peers are taken care of or we ourselves are taken care of. And if you are in a position of power, that you are creating a kind of environment where people really want to love the company that they're at. And this is potentially one way
that you can do that. So I would say if you are already working inside of carbon removal, please go fill out the 2025 salary survey. The link is in the show notes. And also if you're looking for a job in carbon removal, Cdr jobs dot Earth, that's where they are. Go look through them, go apply for them. If you're at a company and you want to sponsor their work, that's also a possibility where you can get better visibility for your jobs. So thank you.
New sponsor means a lot. Thank you, Cdr jobs team. I appreciate your work and hope it continues for a long time. We also have our beloved longtime sponsor, Arbonics is
back again. Arbonics is fascinating forestry work in the EU, primarily in the Baltic States, and they just released a new report on the state of European forest carbon credits in 2025. It's a practical guide to how forest credits are generated, verified, and how developers handle permanence, leakage, and social integrity in a European
context. What's cool about it is that it also breaks down how methodologies differ and how pricing differs between these methodologies and why the timing matters in the supply constrained market. Unless you are a deep, very special type of nerd, this content is hard to parse, but I think the work that Arbonics is doing to try to make this easily graspable by busy people is really important. And you know, there's. Really just not that many European horse carbon credits.
With demand rising and a four station projects taking years to mature, many high quality credits are sold out before issuance, which I'm sure you've seen this or at least heard about it. This report is a timely overview of bottlenecks in the space and the actors who are looking to solve it. You can find this report in the show notes. In any case, thank you Cdr Jobs and our Bionics for your sponsorship means so much to me, and now we will allow the show to begin in earnest.
Hey, thanks for listening to the reversing climate change podcast. This is Ross Kenyon speaking. I am the host of the reversing climate change podcast. Been involved in climate tech and carbon removal for nearly a decade now. No intention of leaving despite the winds of change a blowing. Today's show is complex. Lot of big questions about conflict of interest. We get into the differences between the common law and civil law traditions and which route carbon removal should take as we
move ahead. My guest today is Peter Miner, who is the Co founder and CEO of Absolute Climate. Absolute Climate made a fascinating design decision where most people think that registries produce methodologies. A registry in carbon markets is where the carbon credits actually live, where the status of those credits are tracked. It's the source of truth, and registries often also have scientific teams that develop methodologies through which carbon credits can be issued and
then be on that registry. Those are functions that have historically been combined. That isn't always the case. They're often consultancies that will work with project or tech developers to develop new methodologies to serve them and then look for them to have a home on a registry. That's a nice happens too. But overall, methodologies are developed by registries, and that's true both in legacy carbon market and also new ones that focus on carbon removal.
The contrarian take here is what if registries actually didn't do methodology development because they're always trying to attract project developers to work with them. And registries therefore will face downward pressure to reduce quality to attract more project developers who don't necessarily want the extra work or expense or both of developing higher
quality credits. And so Absolute Climate's thesis is that if methodology development could be done by an entity that is not the registry, this potentially creates a better system of checks and balances to make sure that we are scientifically on track to develop meaningful carbon assets independently of whether this works or not. It's the kind of thing that I I like. I like platform and format innovation.
I think being able to relax restrictions or add new ones and having enough room to operate in this space is very valuable. I'm not sure that we have found the ideal configuration of all of the parties within carbon removal and carbon markets. I think we need more space to explore those ideas openly and make sure that we're doing it in a way that it gets us where we're going, increases trust, makes it easier to develop high quality carbon assets, and make sure that what we're doing is
actually meaningful. I'll put some links in the show notes if you'd like to learn more about the civil law and common law traditions if you want to read about the Napoleonic. Code. Well, you're. Listening to Reversing Climate Change, so presumably you're at least half interested in some of the weird crap that comes up on this show. So I'll put a little link if you want to.
If you want a tiny taste to dive further into legal history and if you love things like that, if you can't get it anywhere else and that's why you're here, a great rating and review on Apple Podcast or Spotify would be amazingly helpful. Also, it's $5 a month through Spotify, and you actually don't need to be on Spotify to get it, but $5 a month gets you ad free listening. Except for the sponsorships by paid sponsors that I read myself at the beginning of the show.
You can get away from the programmatic ads that Spotify puts into the show. Thank you for listening. You have a lot of choices out there. The fact that you're spending time with me honors me immensely. I'm so happy that you're here. Thanks for listening and here is your show. Thanks for being here, Peter. My pleasure. Always great to see you, Ross. Yeah, it's good. Is there some what? Is there some clicking noise? Oh, does that mean? Is it this thing?
Oh, is it like a fidget spinner friend? Yes. It's literally a fidget spinner thing. I just I'm a fidgeter and so I like play with this, but I will not do that for the extent of the podcast. I didn't hear it. That's that's. Good, the good. Audio that's impressive. Oh yeah, that's OK, That's fun. Well, you're, you're a fidgeter, which means you want to do the most detail oriented, laborious task possible in your life. So you're writing carbon removal standards?
That sounds about right. Yeah, Yeah. I mean, I think carbon removal standards are going to be the rules under which we decide whether carbon removal has the impacts that it wants or it doesn't. And so I think, yeah, but my team tends to be very detail oriented and a little bit OCD that kind of makes us good at what we do. But yeah, I mean, I feel like the mission of carbon removal is so much about impact, right? And so how we measure those impacts is paramount to whether
we're successful or not. And it sounds like absolute the climate started because of a concern that we've lost sight of this or maybe commercial interests are distorting what you view as the correct way to set standards and methodologies. Is that a quick read of of your take on this? It's definitely something I've been concerned about. I think it all started when I was at carbon 180. I was the director of science and innovation there.
And this is like a little bit before DAC hubs were about to be announced. We had heard about the program and we were thinking through like, OK, 4 facilities, 1,000,000 tons per year each. Like that's real carbon, right? Like this is not just an idea anymore, but we're doing it at a scale where it's actually being something. And so the question of how do we actually measure success? How do we decide, you know, whether it's being done in an
accountable way? Like how do we think about how we connect the projects to the atmospheric impacts that they're going to have all of a sudden became very clearly important and the sort of best practices are on MRV, what it should look like, what how it should be done hadn't really been established yet. And so that was something that me and my team decided to dig into and we put out some sort of what we thought were best practices around accountable carbon removal from an MRV perspective.
But I think what really struck me in getting to your point is that, you know, we think of carbon removal as this distinct industry compared to avoidance or distinct from forestry who put, you know, both of which have had some pretty high profile failures. And that's true to some extent, right? Like Cdr fixes some issues around durability in some cases. And you know, there are others.
But but the conflict of interest part like the the incentive design piece, which I would argue has actually been the core failure points of those other industries. He's no different in carbon gleanable that they'll still same failure mechanism still exist. And So what I think the core concern that I had was how do we build MRV in a way that is not accountable just today, but over
the long term, right? How do we make sure that at the million and billion ton scale, you're still accounting for this in a way that means something you know is accurately tied to what the atmosphere is seeing. And I think the system as designed today is not set up for that, that I think it tends to be a race to the bottom. Two big points I want to respond
with. The first one I don't know if it's as. Important as the second, should a system be built at its early stages to accommodate million or billion ton pass through? Is it appropriate to design all of that so far in advance? Maybe I'll just let you answer that because I want to ask about this topic, this question. I think that's going to drive a lot of the show. No, I mean, I think you're asking a really important
question. I think that's one that is part of the challenge that we need to try to solve today, because there's a tension between these two things that we need to be somehow solving. I mean, I think in most industries, what's going to happen is you're doing a bunch of R&D, you're doing innovation. We're trying to figure out like what's this great new problem that we're going to solve, this new technology we're going to solve it with?
Once I kind of figure out how it works, then I build it, then I scale it, then I make it happen, right? In Cdr, we have the unenviable position where we need to do the science, understand how it works and scale it exactly the same time, which is not a situation that I would recommend to literally anyone else. But that is the situation that we're in. And so there is a tension between how do we think about building IMRB and building credibility for the long term, right?
What how do we create a North Star so we can make sure the industry is going in the right direction while simultaneously dealing with the fact that we're not there today. And actually, in many cases for some of these early and first of a kind projects, it probably doesn't make sense to deploy requirements around MRV that are needed for the ability to on scale, right? Like that's a waste of resources
and time. But I think without that, what happens is if you allow just for the lowest common denominator, you remove all incentive to do better, right? They, there's so much work that we need to do around better quantification methods, better sensing, better models. And if the standards don't require that, if there isn't value in doing better, then there's going to be very little incentive for people to actually invest the time and resources.
And actually what happens is almost literally the opposite, where if you are a project developer, your incentives are to go with the standard that gives you the most credits, right? Like that's, that's why you're doing this. Like there has to be an economic incentive for them. And so they're going to pick the thing that gives them the most credits.
And if, you know, let's say 1 standard is low, has low requirements and gets away with it, then every other standard needs to meet that because they need to stay competitive in this market. And so you're sort of ratcheting down piece by piece lower and lower and to the point where it doesn't mean anything at all anymore. And so that's the challenge is like without that North Star clarity on in in an ability to measure when something is truly better than MRV inherently will fall apart.
It's just a question of when, not if. I have some anecdotal experience of project developers choosing registries and methodologies not based upon the number of credits that they would earn and the revenue, but also the speed of issuance. I've seen him decide upon just general reputational effects of choosing one registry over
another. It hasn't purely been about short term revenue based thinking, but it sounds like you're making a very conceptual A prioritistic argument about self interested people choosing low effort high reward. The tendency is towards that way of decision making. Is that how you see it? I'd be more just like tasks we have in front of us is incredibly hard, right?
I mean, like scaling up this industry that is the equivalent of Lito taking a few drops of ink into a pool and then trying to remove those drops of ink again. That isn't an incredibly difficult technical challenge, especially considering we're in an industry where cost is the driver of almost everything. And so any sort of efficiencies you can gain any way that you can sort of simplify the problem, make it easier to scale, that's incredibly important for for project developers.
Like I think it's a good thing that we are seeking what is most efficient. I think that's important, but we also need to realize that there's sometimes when we do create efficiencies that are reducing the quality of the outcome, that the atmospheric impacts are less certain or there are more risks involved and that needs to be accounted
for also. And that's just something that the voluntary market and in some cases I think compliance markets are just not good at value that I think that we tend to want to just treat these things all the same and say like, hey, this is Best Buy. And so, you know, that's good enough. Actually, no other industry in
the world operates that way. That when any industry that cares about quality, quality assurance processes are designed for very specific performance outcomes, like they're trying to measure a thing. You know, if I'm trying to say I am going to build a new wind turbine, I'm not going to say, oh, I only can use this one grade of steel.
I'm going to say it has to have this yield strength and this sort of, you know, you know, toughness, basically these different types of performance specifications. And I can use different grades of steel. I can use aluminium, I can use carbon fiber. There's lots of materials I can use as long as they meet these requirements. It's based on the outcomes that we measure success. And Cdr is maybe the only industry in the world where that is actually not the case.
It's possible that we're just at the stage 1 rocket scale or we're just trying to get off the ground and then maybe some of the stuff can come later. Like do I need to have the soil water measurements for enhanced weathering fully thought through before we start commercializing enhanced weathering? Might not be what you're you're arguing for potentially. I have seen people argue that we shouldn't be commercializing tech like this until we really know answers to those questions.
But we don't really have a lot of time to be dealing with this for carbon removal. We're we're in overshoot territory. Like we're people I know are talking very seriously about solar radiation management coming online like, so we don't have a lot of time to get things perfect. How should we be thinking about that? This is why it's so tricky because that's absolutely right, you know, like we do need to be building and scaling. We can't let the perfect be the
enemy of the good. And there are just some of these questions that are going to just take time for us to develop the technology to solve or the science to solve. And we, you know, we need the time to do it while scaling. So that's right. And so I think, but I don't think that's incompatible with sort of the other side of this, which is I think one thing we forget is we're not just scaling projects and technologies, we're also scaling political economies
with this. Like we need to convince lawmakers this is worth investing in. We need to build, you know, jobs that and create workforces. And these are things that are very hard to change afterward that once you actually convince something someone that we should build this, you get the political economies going, going back later, you're saying, OK, we're going to increase the standards. And now this whole segment of this industry, oops, like those all have to go away.
Now we got the fire, all those people and all of a sudden this thing that made sense doesn't make sense anymore. It's just not things that you can walk back afterward. And this has been a the classic challenge that we've had in in in climates where we assume we can do what's directionally correct and then not think about the longer term repercussions and think longer, you know, think have a North Star that we're really trying to shoot for.
And that's been us on the butts almost every single time. There's an example I've heard this might be apocryphal. I'm not even sure if it's true, but whatever the the point behind it is is true even if the example's false. But after the Clean Air Act passed under Nixon, there was a specific filter or a scrubber for exhaust coming out of manufacturing facilities. Because it was named specifically in the legislation or or the administrative policy
that came afterwards. It just stayed there for decades longer than it needed to, even though the tax surpassed. It. Did that actually happen? That that is a true story, Yeah. I mean. If that is true or not true, there are plenty of examples of that ethanol in our gasoline. The whole intention originally was that cars tended to run rich, which means they had more fuel. So to do combustion you need a mixture of air and fuel you want. So there's like a perfect ratio where you get perfect
combustion. Usually cars would run a little bit rich, which means they have more fuel than air. And it was more of like a safety thing. And so the idea was if you take ethanol, it has more like oxygenation in it than it would normal gasoline does. So you're basically like tricking the engine to absorbing or, you know, having more oxygen in there. So it would run leaner, so more efficiently.
So they're like, yeah, this is so smart, like basically going to trick it. It was like literally a few years later car manufacturers built and introduced oxygen sensors into the combustion process so they could detect this and then immediately correct for it. So why do we still have ethanol in our gasoline? Political Economy. Political economies, political capture, We decided this is something we want to support and
it's been impossible to change. Ever since this has been my long standing anxiety about policy because I've slept on policy for a long time and Nori was not a very policy forward company. We're very much BCM is the way to go. And part of it was knowing that no matter how policy gets written from these political economies will be established. There's vested interest. They're very hard to change once people are are making money off of something.
And we are not an industry that can lobby successfully against Agri business or oil and gas or other people that have a lot of influence. So I've always been very cautious about how much policy we want for that reason. It's not like you're saying there's no way out of it basically. But should we be setting those up for carbon removal now? Like, do you want that kind of power in your own hands? A lot of responsibility. It's kind of scary saying, oh wow.
I mean, yes, I think so. I mean, I think the reason why this matters is because I think there is a better way to set standards than we do today. Like today, like you sort of are choosing between either maximum flexibility or I can have like some say more rigor, but then usually gets hard coded on specific approaches like if you use this sensor, if you use this like. Modeling approach or you have to
gather this kind of data. And I actually think there's a way that you can kind of bridge the gap between those two things where, you know, our standard, the way it applies is we have one single assessment approach for all types of CARP that we do the exact same way for everybody.
And one of the big advantages there is that we can set what that sort of quality requirements are in terms of like what data you capture, baselines need to be what best practices, even the definition of storage is not, is not compatible for pretty much any other standard. We have a consistent way of approaching that. What's nice is you can say like, OK, you need to meet this quality bar, and this is how you actually measure that
specifically with data. But now how you do that, what models do you use, what sensors use? That's up to you. You can now decide on a project scale, like what works best for you. And we're just going to measure you against how you meet our criteria. And so there's a way that we can build better policy that historically has been sort of hard coded to types of Cdr or types of approaches which tend
to be very brittle. And we can design it based on performance because that's what the thing we care about, right? What we care about is how many carbon dioxide molecules are in the atmosphere and how many of them are we actually moving and putting into durable storage to, you know, long enough time that it actually has an impact on climates. Like that's the only thing that actually matters.
And so if we put the requirements on that, then you don't have to have that same problem that we've seen in the past. Do you feel pressure to? Get to 100% perfection and what you're doing, no. No, I think. You might be distorting it if you if you don't get there though, in a way that is likely to persist because you'll make people very angry if they have to change, I think. I think, I think there's.
So are you talking specifically about how do we set the right standards for the future long term or just how are we assessing it today and making sure that it is accurate in terms of what impacts it has on climate? I think it relates to both of those questions essentially, basically. The. Example I come back to often is I would not want to be at SBTI. Whatever you do is going to make someone really mad.
Depending on how you determine the LCA project boundaries in a general way is going to, you know, if you're really strict about it, some companies are going to love you because you're going to harm their rivals and others are going to be really upset because you harmed their business. Like how, how are you able to? I don't know the tough position to be in, but I wouldn't want to that seat personally is what I'm
trying to say. I mean, I think that's actually what we're trying to to fix here, which is not just like, like right now, what the right boundary is or what is the right, you know, level of quality. That's basically just someone's opinion, right? Like someone is deciding that some hopefully very smart scientist is saying like, this is what we think is the best practice or here's what we think is, is rational or makes sense.
But then a completely different scientist does that for a different project, even in the same pathway or certainly does it differently for a different pathway. And so we just have basically a mix of different opinions and we can spend all day long arguing who's right, who's wrong, and you're right, Like we're never going to make progress there. Like ultimately just becomes a series of of political
arguments. And I do think like there is that we're never going to be able to get away from all of those. Like some things are going to be completely subjective and that, you know, we'll have to deal with that in the political ways. But I think there are ways that we can be not just more objective, but maybe more importantly more consistent where if we're at least applying the same rules for everybody, maybe the rules are right, maybe
they're wrong. Like maybe you could argue that, but if they're at least consistent for everybody, like everyone is, we're measuring quality and we're measuring success exactly the same way for everybody, then at least you can say like everyone has the fair chance.
And I think maybe part of what I'm getting to with this, and maybe what you're getting to is I think Cdr has had this belief that, you know, we we need all solutions, like we should do everything and there's going to be room for everything. I'm not sure that's actually true long term. In the short term, absolutely true.
We have no idea which is going to be the type of technology that scales and is going to be the thing that we should really be doing and getting just a gigaton scale, I certainly don't have the answer to that. I think all of them have a fair shot at that today. But if you look at how we build and deploy technologies in the world, you need to have a point in which you have consolidation, where the supply chains need to be, you know, invested in and grown to be able to get to the
scale that we need. That doing the, you know, 10 different supply chains to 10 different methods and, you know, across different jurisdictions. It's a point it's not going to make sense forever. Wow, Peter, are you allowed to break with Canon on that? You know what? I often hear people say that in public and then privately I'll hear someone be like, I'll be like, what? I'm like you just. Said you just said we already got solutions. What does that?
Mean, I'm obviously gonna have to bleep that out, but I'll and then I'll hear them be like, it's all it's all nonsense that doesn't even work. I'm just like, OK. I will be honest about this and you can actually put this on the podcast. I'm actually happy with this. I will always be honest about this and I will be consistent about this. Like, I genuinely don't know what the answer is. Like I think what's so amazing about Cdr is that our capacity for innovation is still massive,
right? Like not just because we have such smart people, but because we aren't really, there's so much room to continue to make improvements. Like I was actually at this technical webinar today where folks were talking about new modeling approaches in marine Cdr where they solve on some fundamental problems.
Like how do you actually get things like uncertainties, like how do you measure, like how good the model is in a case where you have, you're sort of over constrained the problem, like you have too much data and you're not sure like which is the right data to use. Like historically, what that means, it's like, OK, we don't really know what kind of model to you is. We just have to rely back on experts, you know, like who's opinion is that 1 is better than
the other? And this is a new approach that says no, no, no, no. Like we can actually propagate those uncertainties through. And we have a way for actually like calculating a score of how well the model works based on that set of data. And that is transformational for Marines here. That's something that they
haven't really had. And so that's just one of many examples where the type of innovation that we're going to need to build more trust, to build more certainty to scale Cdr, a lot of it doesn't exist today. And that's a good thing. It means that we the fact that we don't know which is the solutions that are going to actually really work long term is a good thing. It means our capacity for improvement is still massive.
Maybe just set out the vision for absolute climate and restate the problem that you're trying to solve and why you think, Especially if you're expressing doubt about your ability to know, which is a characteristic I respect. But the job that you've undertaken is seemingly to be the knower and something. Maybe you disagree with that, or maybe maybe you don't, but how do you feel about that?
I think my job, the job that I think we should have, and I think I personally think the entirety of the MRV field should have, and I don't think everyone takes this in the same way. May disagree with me, but I think I feel pretty strongly about this is our job is not to make a determination of what's good and what's not. Like there are going to be some decisions that society needs to make. I'm like, where do we want to allocate resources?
How much certainty or uncertainty are we comfortable with? And, and just are there other reasons that we may want to scale some solutions or others? Like those are societal decisions that I think live should should live outside of the purview of MRV, defeat conflicts of interest to make sure the incentives are aligned and to make sure that I think we're doing our job well.
MRV should be purely about how are we accurately and transparently assessing what the atmospheric impacts are of these projects. And there may be a political decision after that of like, okay, we understand this and we don't care. We're gonna do this anyway despite this uncertainty or this is something that we think is important. And so let's go forward.
Despite what we understand about how the minister is being impacted, Like maybe we decide, okay, we know that it takes 1000 years for the removal to really match the emissions damage that is being caused, but maybe we don't care about that. Like we should just do 100 years. I think it doesn't mean we don't think about the thousand year time frame. We should still be evaluating the atmospheric impacts from that perspective.
But then there could be a political decision after that that says like, OK, but you know what? We're going to do this anyway, even though we know this isn't a perfect match. Interesting. So your attempt is to be values neutral. Otherwise, without that, then my incentives are going to be to change the rules and change my standards to be as attractive as possible to project developers or governments even right, who actually struggle from the same incentive problems.
Like the only way I think for us to keep the standards honest and to make sure that MRV is giving us the information we need is to take them out of the political process. Like they should be tools for policy. They should not be dictating for policy. Interesting. Do you know much about the common versus civil law traditions? Is this familiar ground for you? I don't think so. So OK, I'll probably have to do this in the intro just so people can get a good basis for understanding it.
But the Anglo American tradition is primarily a common law, which is judge made law. People would bring cases to judges, judges with discover new law, they would apply it in new ways. And we build on it on precedent and stereo diseases where you're building up a case history, that of decisions that can be pointed back to. But the civil law tradition is famous from Napoleon of coming in and trying to state by statute basically everything.
And so rather than trying to find and discover new precedents or, or go back to older precedents, that's very much about referring to statute in textual analysis. And I tend to have more faith in the common law tradition because I like the ability and the flexibility of working from general principles and and learning. In law in that way that always. Intuitively, that makes sense to me. Where is that? The Napoleonic Code and civil law?
The goal was to take legal discretion out and to make it all about technicians of merely applying the law. There are trade-offs, of course, because there are trade-offs and everything. And I'm wondering to what degree do you prefer something like how the civil law tradition was just described or if like me, there is some value in maintaining a common law tradition within carbon removal.
Or maybe maybe we don't know exactly how alkalinity and wastewater treatment should be dealt with right now. We're going to adjudicate it and then we're come to a general principle and that will come into it later. But not everything needs to be decided as early as possible for a generalizable totalizing standard, which I face a serious risk of the political economies that you mentioned. Yeah, I think that's generally true.
I think there's one sort of, at least for me, like this driving challenge that makes the common law. I think it's actually a really good example that makes that a challenge, which is tell me if I'm wrong about this. I'm not a legal expert, but my understanding of common law is that the challenges to it are driven by farms, right? Like if someone has been hurt, that is the basis for how you challenge a common law, you know, an existing common law, it
was priority, right? Like you say, like, hey, this isn't working. Here are examples of how that's not working. That is generally the process we use across a lot of society, right? That is uniquely challenging in carbon markets. And that's because the harms are extremely diffuse. They're not felt by any specific individuals. And the lag in which we we experience them is extreme in in very hard to attribute to one source or another, right? Like the harms we're going to see will be decade.
If we're wrong, let's say we are massively over credited, we're getting this wrong. We're not going to really know from a first principles perspective until a decade or more later after we've had so much unbelievable harm that is accumulated from this mistake that we're actually seeing it in global models or, or our experience in how the climate is changing. And so now attributing that that that harm to now an individual or a specific action becomes
almost impossible. Like we can't get around the fact that CO2, like you and I are both sitting in rooms that are filled with carbon dioxide and it's invisible and it's a nerd and it's highly diffuse. And so if we could do a better job of establishing those harms and then saying like, hey, like we see this problem and now we need to change it, then that
would work better. But I think alkalinity is a great example where right now, if you look at how most standards are built and how we deal with those uncertainties, it's we'll do something like make your best guess. And in some cases, like maybe discount away what we think is sort of a conservative confidence interval. But in many cases, we're not sure if that actually is
conservative or not. And then we're going to pretend like it's not a problem anymore where that actually isn't the scenario where it gives us much room to say like, yeah, like this actually is a problem. Like we need to keep innovating on this. Like this, our certainty around this is not enough for us to actually really build the whole industry on top of this. And so we should be transparent
about that. We should be clear that this is an unknown and not pretend like we can sort of deal with it even though we don't have the solution today. They're good points and the the point you make about torts and tortious claims are why regulation tends to step in in place of torts in common law tradition, because it's too diffuse and it cannot be proven in court.
And it's not the same as so and so dumped something terrible on your property and you can point to that doesn't work that way. And so yeah, something something more statue based may just make more sense for this. Just. Given the the vested interest portion of this, just like how do you build in a system that has some amount of flexibility that we don't end up with ethanol or that GE filter or scrubber, but also allows people to plan very far in the future.
Because we don't want to be like decide right now that OK, Fikers is the most important or the worst of all Cdr methods and we're just now stuck in that forever. How do we learn and grow in a system that does have a totalizing impact? I think from my perspective, there's only one answer to that question. I think it's just we should based on performance, like a lot of policy today has been based on like, I want to support this pathway, a lot of it going to direct air capture.
Is that right? Is that not, I don't know. I can tell you that a lot of it was designed based on like that pathway specifically. And if what we care about is really climate impacts, then what we should care about is climate impacts and how we measure those. And so why not build policy, build approaches, build MRV based on performance. And what's nice is like, yes, you do have to set sort of like here's the bar, right? Like here's what we think is the right performance.
But if we're wrong about that, that is something that can be adjusted over time, right? We can decide like actually maybe we're overzealous or maybe we weren't tight enough, but we are clear about what is needed and how it was needed and a project has flexibility in how we get there. We don't have to hard code that to any specific pathway or
approach. You might have to choose some things like if the ultimate determinant would be success or failure being linked to parts per million in the atmosphere versus radiative forcing or something is is determined to success. Granted, these two things are there's a relationship between them and ideally you could
specify that and convert. But is there not some sort of fundamental like disagreement that people could go one way or another on a certain issue like that that will distort the outcomes of what kind of carbon removal is built or not built, right? There are probably some cases of that. Yes, definitely. And this is gonna be a situation where it's gonna be impossible for us to find some perfect solution. Unfortunately, across all climate, including an MRV, there
are no silver bullets. There are only more lead bullets. And so I think there is a way that there are always gonna be cases where we have to just sort of do our best and try our best to may changes later. But I think we should just acknowledge how hard that is. But that's not a simple trivial thing.
And if there are opportunities for us to be looking at the bigger picture, creating consistency and setting the north star of what we think good looks like today and making that very clear to projects like, hey, it's okay that you can't meet this today, but probably at some point you're gonna need to. And if you can't, that's gonna be a problem.
But if we don't make that clear today, we build that into policy, we are likely to get that lock in on subpar solutions that are politically popular for one reason or another, but actually may not help us get to what the climate impacts we're looking for. I'm so intrigued by you and this approach, Peter. I like that you're trying to not add in more judgment that is necessary to your job.
Well, because if you had very strong opinions about some of these matters, it might feel just as political or self-serving as as many others who are trying to set their own standards. But it doesn't feel like that is as prominent here. And I think now is the appropriate time to get into conflict of interest. Question. Everyone talks about it. It's either not that big of a deal or they made some innovation so that it's less of a big deal.
How should we be thinking about conflict of interest in carbon removal? It's maybe the hardest problem that we need to solve. I think actually much harder than the science or the engineering or anything else. Like I think like we are in this, I think like difficult position where when we're removing carbon dioxide from the atmosphere, whoever's buying that is not getting an Amazon package filled with CO2, you know, like they can then measure
and check on afterward. Like there actually really is no products. Like what you're getting is the data, The M, you know, the MRV truly is the products. And so all they can really assess is, you know, what that data looks like in the back. The reason it very rarely is this the source of truth. And that just makes our job
really hard. I think where, you know, it makes it much easier to be in a situation where now, again, to be competitive, you might have folks who degrade standards to just make it sort of more attractive or, you know, making mistakes and then, you know, maybe even like unintentional mistakes. But then not wanting to have to look your customers or your stakeholders in the eye and say, oh, yeah, I made a mistake here. And, you know, now I'm going to do this hard thing around fixing it.
I mean, won't have any names, but there was recently a big registry who had an issue with, you know, one class of their credits that, you know, academia had pointed out. And it took them half a decade to acknowledge and, and actually fix it. It took a really long time. And why did it take long? Like, why did they not fix it sooner? There is no reason to, there's no incentive. There's nothing that held them to make that change. There's no there was no downside
to being wrong. And so I think the unfortunate challenge is like, I would love to say like again, silver bullet if we just fix this one, You know, this one little trick like negative incentives hate when you do this. It's just not like that. Like incentives are like every organization has incentives for profit, nonprofit, academic, civil society, governments, everyone has incentives. And so the trick is, is how do you build a system that aligns those incentives in all the right ways?
So that's, you know, hopefully one definitely the climate is getting what they're paying for, but also, you know, like the people, whoever's purchasing, purchasing this is getting what they're paying for. And so it's a it's a complex challenge. I don't think no one for being honest with each other. No one has the full solution to yet. Can't you undermine my follow up question? I was hoping you were going to tell me what's the point of this conversation, people?
I mean, I can tell you ideas. I can tell you how we think about this. What do we do about this? Absolutely be friendly. This is an incomplete solution. There's more that needs to be done. But for example, like, you know, I think one of the core challenges we have is who is actually designing and building these, these standards or who's deciding what quality is right? Like in, in a lot of cases, it's singular organizations, right?
I mean, and we are definitely in that bucket right now too, where I, I think like, you know, there's one person's opinion on what you think is right or wrong. And I think that problem actually gets compounded in this, in this scenario, the sort of market that we have today where the folks who are generally building these standards are also the folks who are running registries or selling or brokering credits. And from our perspective, that's just a massive competitive interest.
It's the same people who are deciding what's good enough or the same people who are then, you know, issuing or selling credit. It's like, it's sort of like if you were in school. And it's like I write the test and I grate myself against that test. It's like, you know, like it's a single point of failure. Like one organization could decide I want to reduce quality in order to issue more credits. And there's just no check and balance against that. And so we're trying to fix that.
For example, where we are intentionally deciding to not have a registry. We're not obviously doing anything around selling or broking credits. You know, we are specifically quality assurance. That's our job. Our job is to think through and, and you know, be accountable for how we just determine whether the atmospheric impacts are happening. And then we partner with registry, we partner with other folks who can then adopt our standard.
And so. Well, again, acknowledging that that is not a perfect solution, but it does create now a separation of power without there's not one organization if you just decide to make a change and they're not accountable to anyone, there is at least one layer of accountability. And so that's an example of something that we're doing that we think will hope hopefully put us in in the right direction.
I have so much. To say and to ask about this and I suspect much of it will find its way into the introduction. But so with Nori, we were vertically integrated and we're a registry. We developed our own methodologies. We're like a quasi project developer too because we had credits being issued and also just obviously a marketplace. This type of integration put us out of step with ICRO and ICDCM. So we could just not qualify for
those stamps. And then very famously, Puro was originally a competitor of ours, but then disaggregated. And I'm wondering because if you are a registry and if you choose to remain only a registry, the only Moat that you have is the methodologies that you develop and issue credits through. And that is a direct response to ICROA setting these ex ante
rules. Or maybe it's better to even say a prioritistic rather than ex ante, sort of like precautionary principle based rules of this is just an incorrect format. In order to legitimately do this activity, you cannot do both of these things. Unfortunately, it means that registries have to own methodologies and pay well them
and issue credits through them. So one of the things that we were able to brag about is that we released our methodologies under a very permissive Creative Commons license because we are vertically integrated and did not need to pay well the methodology portion to run a successful business. It about. I mean there's conflicts of interest in any type of organizational structure, but the one that you're describing is basically baked in by the quasi regulatory bodies that oversee BCM.
Do you agree with that characterization and how much of a problem is it actually? I think that is how things have worked out. And yeah, maybe those have come through these these accreditation bodies like they had sort of led the way. I think, I don't think I have enough information to say either way. It's certainly like sort of the, the, the business model first choice for a registry is like we build proprietary systems and to use our systems you need to live in our all wild card, right?
That's just the way it works. But I don't think it has to be done. And I think we're trying to demonstrate a way that's different because if you really think about it, what are the roles and responsibilities that exist when you're talking about credit certification? I think there are sort of two very distinct roles that usually
a registry plays both roles. You know, 1 is the quality assurance, like how do we assess like whether this is actually a quality thing and, you know, buyers getting what they're paying for it. And then the second step is credit issuance. It's running a registry, making sure there isn't double accounting, you know, make sure that the tool is in place so buyers can, you know, retire them and, you know, make that process really easy.
And these really are actually like very different skill sets, like the two, like being great at one doesn't necessarily make you create at the other one, but both are creating very specific value. Like those are both important to the process. And So what we're doing is actually quite simple. It's just we're going to split those up where for the quality assurance part like we do that and and there we get paid for that work because it is important work that needs to be done.
And then our registry partners do the credit issuance and credit management and that's also important work and they get paid for that. And so I think we just, we've gotten comfortable in the in a model where we take these two very different things, smash them together and we expect that they should be together. But but why is that? Like is there a reason why they're somehow actually better or more efficient when they're actually put together?
And would love to hear counter arguments if you have them, but it's not clear to me that they are better. Oh no, I, I it's very empirical for me. I, I don't love the a prioritistic saying that certain business models are inherently unworkable necessarily because there are also cases where vertical integration works very successfully and has very high quality. And I, I tend to for the same common law type of evolutionary
faith. I, I think I want to make sure that we don't winnow out too many design pathways that might lead to things that are unexpected in the future where, oh, I wish we didn't just say that this is just inherently wrong. We, no one should ever investigate this or build a business in this way. I like that you're doing things differently. I also like that it's because you are a commercial entity. Yeah, correct is to to make some money and good for you.
I hope you hope you all do. That's a really interesting thing. I imagine though your thesis is is very antagonistic to the way things are done now, which is neither good or bad and something about your disposition or how you're presenting this. It's because your business is inherently a criticism of the way things in carbon markets are done. Which is fine. I mean, Nori wouldn't exist if that weren't the case too.
In fact, you probably shouldn't start a business if you don't have a criticism of the way things are done now. What would even be the point? Yeah, but I imagine it probably doesn't always win you the most friends, especially when people like Isometric. I've heard them talk about the way they structure who pays for the registry services as deconflicting the process to an acceptable amount, and it sounds like your business is inherently a challenge to that saying No
it's not. I mean, I mean, I think there is no one solution. It's probably going to be a series of a multiple different changes made to be made. But I think the proof is in the pudding, right? Like I think a model where we connect the registry and the standards is one that we've tested many times and it is effectively always been the point of failure. Like that is where it has fallen down every single time.
And so to think that somehow Cdr is going to be magically different, I think that is just, it is magical, is magical thinking. And so I think there are structural changes that need to be made. And we obviously have very strong opinions on those. People may have different opinions. And I don't think it's clear what's right. Like, I think it's good for us to try different things.
I guess I would maybe challenge anyone who said like, hey, we do this one thing and all of a sudden everything's better. Like I think the challenge would be like, show us that's better. Like show us that that's the case. And in my experience, like there's so many different dimensions to conflicts of interest that are just, it's hard to say like one thing is going to somehow fix anything. Maybe it makes it better and, you know, maybe it's good enough for now, but with a separate argument.
But the idea that this is not a problem, I think is a mistake. I think this is something that'll be a problem for the duration of this market even exists. OK, let's put on our white hat hacker hats for a second. How do we break absolute? Like how do we thoroughly corrupt your institution and ruin what you're trying to achieve? Like what's the weak?
Great question. I think one weak point that we have is that we are still as of now, like the sole primary authors of, of our standards obviously work with academia, we work with experts, you know, you know, we gauge with those folks too. And so, you know, the end result is something that we, we feel is, is the culmination of expertise and, and knowledge across the industry.
But like, we are the sole, like we, we decide, you know, like what's good enough, like we are the sole decision makers there. And I think very likely that's something that's gonna have to change at some points. And so like, you know, from a corruption perspective, like we could decide like, hey, we don't really care about climate anymore more. We want to now just make a Better Business and be more attractive to project developers.
Like there's a lot that we could change to corrupt the way that we think about creating, you know, quality outcomes and consistent outcomes that would be much better from a commercial perspective. And so that is, and there's literally just a decision that we could make at some point. We are not making that decision and we have no intention to make
that decision, but we could. And so that is like, you know, a fifth failure report that exists across the entire industry where like there are these single points of failure where it's very difficult for there to be checks and balances in place. I mean, we recently saw this. I also won't name any names.
Like we saw a situation recently where there was an NGO who called out an issue with a specific set of standards and nothing happened basically that that sort of warning was ignored and credits were issued anyway and buyers accepted the credits. And so just like for me, it was like such a example of where this can go wrong, where if we can, you know, if the industry itself decides like, hey, we don't care about this problem, we think this is good enough, we're going to move forward.
What's the stop then? I mean, that's a question for you. I mean, I don't know, really hard question. I'm sort of surprised whenever I hear things like that, that buyers aren't more persnickety about it. You would think they would defend their interest more because they're going to be the ones left holding the bag if it falls apart. I mean, for some of these things that are more innovation oriented that are small numbers of credits, you can just say like it's a write off, write our best.
It's an early industry kind of thing. We're not using it against our fossil emissions or something like that. But I don't know, that's like partially OK, I guess. It's tricky, right? I mean, in some cases, I think there are unfortunately I think a problem that we have in the space right now. There's a small number of buyers who have the technical capacity and time honestly to do enough diligence to say what's right or
what's wrong right. Like they're very, very small number of buyers who have very strong opinions. And that's, that's actually a problem, right? Like, again, that doesn't exist in any other industry. We're like, if you go to, I was in Zurich, Switzerland last summer, Lint, you know, lint chocolates. They had a little a factory there, like a factory tour where you can go as a, as a, a visitor.
It's very cool. Like it's very cool to see a lot of the Swiss engineering, you get to eat a lot of chocolate. One of the things that I love the most is they had a whole little section on effectively like their version of MRV. So quality assurance. And they talk about like, how do we make sure that we, you know, from a, a, a very wide variety of different inputs, like different feedstocks that come in from different parts of the world.
How do we make sure that our chocolate is great every single time, that every single bar meets our quality criteria and that our, our, you know, our customers are going to going to love and enjoy it. How do we make sure? And they do an intense number of different things, but a lot of it is that they are not, they rely on standards, but they
don't rely on them entirely. Like they make sure that they are double checking the results like they are in some cases, like checking every bag of cacao beans with sensors to make sure that it meets their bar of quality. And so I think there's a sort of a problem here where the buyers don't get to see what they're getting. It's really hard for them to check to make sure that like the quality has been delivered as promised.
And it gives a lot of leeway to Sanders organizations to project developers, to the industry as a whole to kind of do what they think is best. Surprising though, where it carbon Plan or any of the various watchdog organizations write a. Piece about something like that. And you would expect some of the big buyers to take that pretty seriously. Or maybe they just have. Maybe it's like the British royal family where you never,
never complain, never explain. And you're just sort of like, I don't want to Streisand affect this and draw more attention to it by referencing it. Like, maybe maybe it's better for the company to take this one on the chin, but also also not to draw too much attention to it. That might be the charitable explanatory way of behaving. I mean, it's a challenge, right? Like I don't think we're in this situation right now. Like the buyers are all doing
like are all very thoughtful. We're very lucky to have this set of buyers who are thinking so critically about this. And a lot of them I think are are willing to take risks like they are intentionally doing this really hard, really risky thing because I think it's they think it's better for the world.
And so we're very lucky. Like it's like that could maybe explain a lot of it, but I think there's this other part where like I think long term we also need to recognize that the buyers incentives, you're right or not to hold the bag, but there's lots of different ways to not to hold the bag. 1 is like make sure you're buying stuff that's unassailable. But the other way is buy stuff that's really hard to prove that it's low quality. It is shown to be low quality.
Like don't talk about it. Like like that also allows them to not hold the bag. And so I think like instead they get back to the incentives being really complex. There isn't just like a people have this one very clear incentive. There can be multiple different shades of that, some of which are great, some of which can be disastrous. Yeah. There's, there's so much here, Peter. You're working with the registry right now though. Yeah, you're commercializing. How's that going?
It's going amazingly. We feel really lucky to have them as a partner. So they're a company called Evidence. They are historically coming from the renewable energy credit REC space where they've been operating for two decades. They've issued more than a billion credits in 60 countries on thousands of projects. So they're one of the big players there.
And I think an organization that really understands how to do credit issuance and certification incredibly well and they end up really trustworthy, high accountability way and they now are expanding into carbon removal. And so to do that, you know, I think they share a lot of the values that we have around the importance of trust and consistency. And so they've adopted our
standards. So they're using our quality assurance approach, our standards and modules to you know do that the credit issuance on their registry. Is direct our capture and storage going to be the first methodology? That has been our first methodology. So actually the we just released it for public consultation that just closed and we now need to do all the responses to the great comments that we got.
So that's kind of the next big thing on our list, but we're actually already working on other pathways. So I think one we can mention because we've made the announcement publicly, we're going to be doing coastal alkalinity enhancement with a company called Besta. So I think one of the sort of most interesting ways for adding alkalinity to the ocean in a way that like is actually quite
measurable. I think Besta has some really interesting innovations around how they can get better data that aligns for really well with our standard. But we're actually already now starting more than one other pathway in parallel that we'll be hopefully really seeing in the next. Several months and those will have credits issued through them on evidence is the plan. So, yes, the plan right now, so right now they're the only registry that we are partnered with.
But that is that is not our model. Our model is that we think competition is generally very good in our industry, like we should be competing on price and we should be competing on scale. So one thing that we think is bad, that this is where the race to the bottom comes in. We don't think we should be competing on the definition of quality, that we think that should be something that is
consistent across all industry. And so our model and our registry partners know this and are actually quite appreciative of this is that we want to partner with other registries too and in other types of organizations that we think that sort of this quality layer should be the thing that is ubiquitous and consistent across all the different market mechanisms that we'll be dealing with with Cdr. Did you ever read the book The Wide Lens? Do you know about this? No.
Just pick up a copy. If it's, it's a, it's a collection of case studies about ecosystem plays and when they succeed and when they fail. And what you're doing is so interesting because it's one of those things where I could see project developers not necessarily wanting to flock to you for their own reasons. The registry that you compete with don't necessarily want to fire their science teams in and outsource a lot of that responsibility to you and pay
you as well. And then they have less assets that are valuable in case of line down. What do you do in a case like that? You can see you start over with a new registry that's looking to break into it. I mean, they're old, but like they're breaking into carbon removal. But is the goal to have pureo and isometric and reverse come come hang with you? I'm not sure that's your goal, but tell you, is that a likely outcome? I mean, I think definitely like we want to work with everyone
eventually. That is definitely our goal. And I think like the way I think about this is there's sort of short term benefits in competition and there's long term benefits in competition and the short term, sure. Like we're in the industry that we are today. It's a sort of this dogfight in the Wild West of like, oh, mine is better than yours, except I can't prove that. And you know, like just my opinions are smarter than you're better than your opinions. So fine, like that is where we
are today. But if you don't take this approach and you send it out to where we are likely to be going, which is I think integrating Cdr into governments and cap and trade in compliance markets, then you can sort of better see what the challenge that we're going to be facing there where like we have the same dynamic that's happening. There's two sort of outcomes that happen here that I think
I'm deeply afraid of personally. 1 is we're going to see the same sort of like mindset of like everything needs to be built one off, get custom in house. We do it our way because like we're smarter than everyone else. And we're going to end up with this 100 different countries who have integrated Cdr to their, you know, government structure rates, but they're all going to do it differently.
And that's not just bad from like a climate perspective, Like we'll have actually no idea how much climate progress we're happening because everyone's going to be measuring this completely differently. But now imagine that from a project developer's perspective, like imagine you have to comply with 100 different types of standards. It's insanity. And you know, there are mechanisms for maybe fixing that like Arc 6 and and and whatnot, and you know, maybe even SPTI. But they're not 1010.
They're not moving in the direction where actually it looks like they're actually try to solve this. So that's the one thing I'm really afraid of. The second thing is we forget that Article 6 isn't just about how we measure quality, but also has other things, for example, builds, things like emissions training capabilities, which I think can actually be a really good thing.
There should be certain types of jurisdictions or certain parts of the world where they might be better at director Capture, they might be better at Hanford Weather. They see this as an opportunity to build new industry, which I
think it's good. Like that's the way we're going to actually get adoption of Cdr. The challenge though, is that same race to the bottom mechanic that we've seen in the voluntary market without really rigorous consistent standards across governments and across like how we think about this, that could actually replicate itself at national scales where countries will want to compete to bring product developers and bring
economic opportunities. And they might think like, hey, maybe I'll just make slightly weaker standards because they'll make an issue more credits and that'll look great. And all of a sudden, like that same race to the bottom mechanic, he's spread across the globe at gigatons. That is the nightmare scenario that I really spend time thinking about, worrying about. Dang, this one really made me think. Peter, I asked you hard
questions too. I hope you don't feel on the defensive, No. These are great questions, I love them. Yeah, I'm fascinated by what you're trying to build. I'm glad there's more people thinking about this. I also just respect that you took an orthogonal view to everyone. Else like. Do you even have any competitors besides just the registries who are integrated in the way that you describe? Even them like I, I imagine that they are not our competitors, like we are happy to be partners
with them. Like, you know, like we're effectively like they are our customers, like that's how we integrate. And so we're happy to work with them when they are ready. I think you're probably generally right that right now it's sort of hard to say like we don't, we have a, we used to have opinions on this, but maybe we don't anymore. Like I think we have more work to do to demonstrate that like there's value in this and creating consistency across the industry is going to be
beneficial. And I think that's absolutely true. Like, you know, one of the sort of hard facts that we need to grapple with in this industry is we effectively have like 2, you know, maybe if you want to be generous, like 5 buyers and that's it. Like, you know, those five buyers are basically putting the entire industry on their shoulders. And that is really problematic. Like that's a, that should be, I think it is like, like it is alarm bells for almost
everybody. But I think one thing that we need to do a better job of is asking ourselves this question of why, why are there not more buyers? And I think part of it is definitely like cost, it's expensive and there's sort of no reason to do this. We know until we have regulation, that's not going to
happen. So I think another thing that has been highlighted to me in the conversations I've had with buyers is also that they've seen this rodeo before that like when they bought forestry, when they bought avoidance and had that go wrong for them, have to go poorly for them. It's because they, it was the MRV wasn't sorted because it wasn't consistent, because it was very clear that they weren't able to get, they weren't necessarily going to get what
they were paying for. They can see the complexity in trying to determine whether I should support one project or another. And they're not fools. They're actually quite smarts. And so if you're going to be putting down millions of dollars, do you want to do that in a situation where you like, you're confident that you're actually going to be able to make a claim in the long term? Or, you know, are you OK with massive uncertainties?
And it turns out we're very lucky to have a small number who are OK with massive uncertainties. But actually maybe that's not the model for the larger market that we're going to have to build. Very rarely do I come away from a show with more questions than I started. There's so much to talk about here. We'll pick another one of you some other time. Peter, thanks for being on.
Thanks for enduring the the barrage of questions for for waiting in the legal theory I'm trying to compare to legal reviews. Thank you. It's been my pleasure, Ross, like always fun to talk to you. I think this has been one of the more stimulating conversations I've had in a while. And like, getting this level of complexity is how we should think about this. Like, if we want to succeed in Cdr, it's the question we should be asking ourselves is how do we make it more like legal theory
in law? How do we make it more like, you know, financial regulation? How do we make this a system that the the rest of the world has already shown us is needed to build scale, to build trust? We should be thinking more in those terms. And that's how we solve this larger problem.