01/01/2024

EFM Investments & Advisory, LLC makes the following voluntary disclosures pursuant to the California Voluntary Carbon Market Disclosures Act (VCMDA) requiring businesses to disclose key information if they market or sell voluntary carbon offsets (VCO) within the State of California;

Disclosures 

The VCMDA requires businesses marketing or selling voluntary carbon offsets (VCOs) within the State of California to disclose key information.

As of the date of this disclosure, EFM and certain EFM affiliates engage in the marketing or selling of VCOs, both within and outside the state, in the capacity of a project developer and manager of forestland. These VCO transactions are traded either on an exchange or on an over-the-counter basis. Any carbon offset project which produces VCOs that EFM would market or sell will be registered on one of the following registries and therefore, the VCOs will be developed and calculated according to the particular standards and protocol of that registry, including, but not limited to, the estimated emissions reductions or removal benefits:

Verra Verified Carbon Standard (VCS)
https://registry.verra.org/

Climate Action Reserve (CAR)
https://thereserve2.apx.com/mymodule/mypage.asp

American Carbon Registry (ACR)
https://acrcarbon.org/registry/

In its capacity as a project developer, EFM’s activities include engaging in price quoting, responding to indications of interest, carrying out trade execution, and related activities in VCOs, all of which may be on a solicited or unsolicited basis. EFM does not serve as an agent, fiduciary, advisor or any other similar capacity to potential or actual buyers of VCOs. In this role, EFM does not provide financial or investment advice or specific recommendations to the market or to potential or actual buyers of VCOs. In addition, EFM does not provide representations or warranties as to merchantability or fitness for purpose.

With respect to any VCO which EFM markets or sell within the State of California, the details regarding the VCO (and potentially others) are made available by the registry that evaluated the offset on its publicly available website, for the particular project in question. The links to the registries and information for each EFM project is listed below:

ACR Registry:

• Shackleford IFM:
  https://acr2.apx.com/mymodule/reg/prjView.asp?id1=732
• Whiskey IFM:
  https://acr2.apx.com/mymodule/reg/prjView.asp?id1=733
• Wildcat IFM:
  https://acr2.apx.com/mymodule/reg/prjView.asp?id1=734

Verra Registry:

• EFM Improved Forest Management Group Project
  https://registry.verra.org/app/projectDetail/VCS/1367

Climate Action Reserve Registry:

• Henry Creek Reforestation
  https://climateforward.apx.com/mymodule/reg/prjView.asp?id1=19

The following information is provided via the publicly available documents listed on the registries:

• The protocol used to estimate emissions reductions or removal benefits from the particular project is located on the registry website under “methodology”, “standard”, or similar and associated terms.
• The location of the particular project is publicly available using the applicable registry link above and navigating to “State/Province”, “Project Site Location”, or similar and associated terms.
• The project timeline is located on the registry website under the “crediting period”, “Current Crediting Period Start Date”, “Current Crediting Period End Date”, “Project Timeline”, or similar and associated terms.
• The date when the project started or will start is located on the registry website under “crediting period term”, “Start Date/Offset Project Commencement”, or similar and associated terms.
• The dates and quantities when a specified quantity of emissions reductions or removals started or will start, or was modified or reversed is located on the registry website under “Crediting Period Term”, “canceled offset credits”, “GHG Project Plan”, or similar and associated terms.
• The type of project, including whether the offsets from the project are derived from a carbon removal, an avoided emission, or, in the case of a project with both carbon removals and avoided emissions, the breakdown of offsets from each, is stated or inferred from information located on the registry website under the particular noted “Project Type”, within verification and filing documents, “GHG Project Plan”, or similar and associated terms.
• Whether the project meets any standards established by law or by a nonprofit entity is located on the registry website under the methodology/standards/status term, “Compliance Program Status”, or similar and associated terms.
• Relevant information, if available, regarding the durability period for any project that the seller knows or should know that the durability of the project’s greenhouse gas reductions or greenhouse gas removal enhancements is less than the atmospheric lifetime of carbon dioxide emissions, would reside in varying locations on the registry website, including but not limited to, the miscellaneous documents posted by the project to the registry website, including the “GHG Project Plan”, or similar and associated terms.
  Whether there is independent expert or third-party validation or verification of the project attributes would be per the registry standards available on the registry website, and if specified, may be located on the registry website under the listing of the project validator, verifier, or similar and associated terms.
• Emissions reduced or carbon removed on an annual basis is located on the registry website under the estimated annual emissions reductions section, the “GHG Project Plan”, or similar and associated terms.
• Details regarding accountability measures if a project is not completed or does not meet the projected emissions reductions or removal benefits would be available in the registry’s protocol and noted in the buffer pool account balance, Project Plan, and canceled offset sections, as applicable.
• The pertinent data and calculation methods needed to independently reproduce and verify the number of emissions reduction or removal credits issued using the protocol would be available from the materials available on the registry website.