The U.S. Chamber of Commerce (“Chamber”) Center for Capital Markets Competitiveness (“CCMC”) welcomes this opportunity to comment on the proposed guidance issued by the Commodity Futures Trading Commission (“CFTC”) regarding the listing of voluntary carbon credit (“VCC”) derivatives contracts (“Proposed Guidance”).

The Chamber recognizes the potential of voluntary carbon markets (“VCMs”) and VCC derivatives contracts to enable emissions reductions across all sectors of the economy. Businesses will increasingly depend upon robust voluntary offset markets to meet ambitious climate commitments. The Chamber believes that practical, flexible, predictable, and durable market-based solutions and mechanisms are at the core of efforts to address climate risk and are reflected in the actions of the Chamber’s
members. Promoting private sector innovation across industry sectors will be central to solving climate change. As VCMs continue to expand, regulators and market participants alike will have to contemplate baseline transparency and anti-manipulation standards that help bolster confidence in these markets.