Buyer-Side Due Diligence Checklist

Emissions Avoidance Project

This checklist is designed for institutional buyers, investment teams, auditors, legal counsel, insurers, and compliance officers conducting due diligence on the emissions avoidance projec tlocated in Los Angeles County, California, USA (onshore)

due diligence

It is organized to align with investment committee review, audit requirements, and regulatory scrutiny, not voluntary market marketing norms.

1. Project Classification & Claim Integrity

Confirm the fundamental nature of the project

  • Project is classified as emissions avoidance, not offset or removal
  • Emissions are prevented at the source through non-extraction
  • Claims do not rely on future sequestration, ecosystem performance, or technology uptime
  • Public-facing claims match technical documentation

 

Key question:

Are emissions avoided because activity is prohibited, not because outcomes are modeled?

2. Asset Ownership & Control

Verify ownership-based authority

  • Clear documentation of ownership/control of mineral and subsurface rights
  • Singular decision-making authority over extraction
  • No third-party operators whose behavior affects permanence
  • Legal restrictions on extraction are binding and durable

 

Asset reference: The project located in Los Angeles County, California, USA (onshore)

Key question:

Who can lawfully decide to extract—and are they prohibited from doing so?

3. Permanence & Reversal Risk

Assess whether permanence is enforced or assumed

  • Permanence is achieved through legal and operational prohibition of extraction
  • No buffer pools, insurance pools, or probabilistic permanence assumptions
  • No ongoing operational activity required to maintain climate benefit
  • No identifiable reversal pathway

 

Key question:

What would have to fail for emissions to occur—and is that legally possible?

4. Baseline Credibility & Additionality

Evaluate whether avoidance is meaningful

  • Baseline represents economically viable production, not marginal or speculative output
  • Baseline supported by historical production data and reserve analysis
  • No regulatory requirement forcing non-production
  • Decision to forgo production is voluntary and documented

 

Key question:

Could production reasonably have occurred absent the project?

5. Methodology & Quantification

Review technical rigor

  • Methodology aligned with ISO 14064-2 principles
  • Lifecycle emissions accounted for across Scope 1, 2, and 3
  • Conservative assumptions applied where uncertainty exists
  • Quantification avoids over-crediting

 

Key question:

Can an independent third party reproduce the calculations from source data?

Buyer-Side Due Diligence

6. Independent Validation & Assurance

Confirm third-party review

  • Methodology and application validated under ISO 14064-3
  • Validator is independent and accredited
  • Validation scope includes baseline, additionality, and permanence
  • Validation report is available for review

 

Key question:

Has an external party challenged the assumptions and documentation?

7. Monitoring, Reporting & Ongoing Verification

Assess post-validation controls

  • Monitoring focuses on confirming continued non-extraction
  • Ownership and boundary integrity are periodically confirmed
  • Records are maintained for audit and legal review
  • No reliance on self-reporting without documentation

 

Key question:

How is the absence of activity confirmed over time?

ESG Due Diligence

8. Double Counting & Claim Exclusivity

Evaluate claim control mechanisms

  • Singular authority over emissions avoidance claims
  • No parallel registry claims unless explicitly disclosed
  • No contractual structures enabling multiple parties to assert the same benefit
  • Clear chain of custody for claims

 

Key question:

Could another party credibly claim the same avoided emissions?

9. Disclosure & Greenwashing Risk

Align claims with evidence

  • Public statements are constrained by validated documentation
  • No qualitative superiority claims without substantiation
  • Limitations and assumptions are disclosed
  • ESG disclosures align with financial and risk disclosures

 

Key question:

Would the claim remain defensible under regulatory or legal challenge?

10. Regulatory & Litigation Readiness

Stress-test defensibility

  • Documentation retained for retrospective review
  • Claims do not depend on voluntary market norms alone
  • Structure remains defensible if standards tighten
  • Legal counsel review is supported by clear evidence

 

Key question:

How would this claim be evaluated five years from now?

11. Counterparty & Transaction Considerations

Transaction-level review

  • Clear articulation of what is being transferred (claim, right, or representation)
  • No implied guarantees beyond documented scope
  • Risk allocation is explicit and understood
  • Alignment with internal ESG, audit, and compliance policies
Summary for Buyers

Bottom Line

A buyer should conclude due diligence satisfied only if:

  • Permanence is enforced, not modeled
  • Claims are ownership-based, not registry-dependent
  • Quantification is conservative and reproducible
  • Validation is independent and documented
  • Disclosure is aligned with audit and legal standards

The project is structured to meet these criteria.