MCC-NPRT — Non-Permanence Risk Tool

Document control

Field	Value
Document code	MCC-NPRT
Title	Non-Permanence Risk Tool
Version	1.0-draft
Status	DRAFT — FOR CONSULTATION
Date of this draft	3 September 2026
Tier	Tier 4 (tools and calculators, per FD-2026-09-03 item D5); companion instrument to MCC-BPM v2.0-draft
Effective date	None. This document is not in force. It takes effect only on adoption under §11.1.
Document owner	Programme Administrator (transitional, until a Secretariat is staffed — FD-2026-10-01 Schedule 1, C3)
Approved by	Not approved. Prepared for public consultation.
Decision basis	Founder Decisions FD-2026-09-03, items D1–D8 (recorded in the decision register as attested by the founder, with no executed copy filed); audit findings SYS-05 (missing referenced tool), SYS-13, BUF-03, BUF-05
Supersedes	Nothing. The predecessor suite referenced a "Non-Permanence Risk Assessment Methodology" (Buffer Policy v1.0 clause 0045) that was never published (SYS-05); this Tool is the first controlled draft. The predecessor's risk-matrix clauses (0037–0069) are superseded by MCC-BPM and this Tool jointly.
Language convention	British English; RFC-style normative verbs per MCC-001 clause 3.1
Classification	Public — consultation draft
Consultation period	30 days (FD-2026-10-01 Schedule 1, C4), from the opening recorded on the consultation register (FD-2026-09-04 item 2; FD-2026-10-01 item 5)

NOTE (non-normative). This Tool is the instrument that MCC-100 clause 11.10, MCC-200 clause 9.4 and Methodology Template MCC-200-T1 §9.3 reference, and it consumes exactly the input specification those clauses define. Until it is adopted, no stored-carbon methodology can complete its dossier and no stored-carbon issuance can occur — a deliberate, disclosed gate (MCC-001 clause 2.5). Every numeric parameter in this draft is either carried from the predecessor as a consultation proposal or is a structural rule; no parameter is presented as operationally calibrated, because no MCC operational data exists. Points the Programme has not decided, or on which it proposes a rule for comment, are listed under Consultation questions below and marked in the text.

Consultation questions

Each point below is open for comment. A proposal is the administration's proposal, put to consultation under founder direction FD-2026-10-01; it is not a rule in force. The suite is to be adopted as one instrument once its longest consultation period has closed (FD-2026-10-01 Schedule 1, C4). Because it includes the Constitution, whose amendment is within the competence of the constituted Governing Board (FD-2026-08-24 item D11, recorded in the decision register as attested by the founder, with no executed copy filed), each point below is decided by the Governing Board on adoption of the suite; a clause of this text that provides another route for adopting it alone is itself open to comment.

1. Clause 5.1 — Cap on mitigation adjustments. Proposed: evidenced mitigation may reduce a category score by up to 0.5 points per category. Basis: carried from predecessor clause 0059 as the consultation proposal; FDP-2026-001 Part 3 (the non-permanence risk tool's thresholds go to public consultation); FD-2026-10-01 item 4. Decided by: the Governing Board on adoption of the suite. Comments are invited on the size of the cap.

2. Clause 6.2.2 — Ineligibility threshold. Proposed: a project is ineligible for stored-carbon issuance where its composite risk score (CRS) is 4.3 or higher. Basis: carried from predecessor clause 0051 as the consultation proposal; FDP-2026-001 Part 3; FD-2026-10-01 item 4. Decided by: the Governing Board on adoption of the suite. Comments are invited on the threshold.

3. Clause 7.1 — Mapping of the CRS to the buffer contribution rate. Proposed: the mapping in the table of clause 7.1 — 10, 20, 30 and 40 per cent across the CRS bands, and ineligible from 4.3. Basis: carried from predecessor clauses 0047–0051 as the consultation proposal, re-based onto the conservative CRS of §6.1; it is not calibrated on MCC operational data, of which none exists; FDP-2026-001 Part 3; FD-2026-10-01 item 4. Decided by: the Governing Board on adoption of the suite. Comments are invited on the bands and rates.

4. Clause 8.1 — Maximum interval between full reassessments. Proposed: a full reassessment at each verification event, and in any case at least every five years. Basis: carried from predecessor clauses 0053 and 0061 as the consultation proposal; FDP-2026-001 Part 3; FD-2026-10-01 item 4. Decided by: the Governing Board on adoption of the suite. Comments are invited on the five-year maximum.

§1. Purpose, scope and application

1.1 This Tool SHALL be the single programme instrument for assessing the non-permanence (reversal) risk of stored carbon and deriving each project's buffer contribution rate within the band of MCC-BPM clause 7.4.

1.2 This Tool applies to every project crediting stored carbon (families F01 and F02, and any stored-carbon component an F03 methodology defines); it SHALL NOT be applied to flow-based outcomes or MCC-MOU outcomes, which carry no buffer participation (MCC-200 clauses 9.6–9.7).

1.3 An assessment under this Tool SHALL be completed and verified before any issuance for the project (MCC-100 clause 11.10; MCC-BPM clause 6.1); there is no default rate and no provisional issuance (BUF-03).

1.4 This Tool assesses reversal risk only; baseline and quantification uncertainty, leakage, safeguards risk and compliance risk are excluded and handled where MCC-BPM clause 3.3 states.

§2. Inputs and interfaces

2.1 The assessment SHALL consume exactly the following inputs, and no others:

2.1.1 the methodology-defined inputs of MCC-200 clause 9.4: the activity-specific risk factors relevant to the family (including natural disturbance, tenure, financial, management and community-dependence factors), the evidence required for each factor, and the treatment of unassessable factors as maximum-risk, as set out in the methodology's MOD-08 module (Template MCC-200-T1 §9.3);

2.1.2 the project's durability class and enforceable commitment period (ECP) under MCC-BPM Schedule 1;

2.1.3 the project evidence submitted against each factor's evidence requirement; and

2.1.4 for reassessments, the project's monitoring data and reversal history.

2.2 Where a methodology's MOD-08 module defines additional factors for its activity type, those factors SHALL be scored within the applicable category of §3; a methodology MAY add factors and MAY tighten evidence requirements, but SHALL NOT remove a §3 factor, relax a §5 or §6 rule, or alter the aggregation, mapping or exclusion rules of this Tool.

2.3 Every factor SHALL be assessed over the full ECP, not only the crediting period (MCC-BPM clause 6.5; Schedule 1 §5.1).

2.4 An input that is missing, unverifiable or outside the assessor's competence to evaluate is unassessable and SHALL be scored at the maximum (score 5) per MCC-200 clause 9.4; an unassessable factor therefore drives the project towards ineligibility under §6, which is the intended conservative effect — the remedy is evidence, not estimation.

§3. Risk categories and factors

3.1 Risk SHALL be assessed in six categories; within each category, every listed factor (plus any methodology-added factor) SHALL be scored separately.

Category	Factors	Minimum evidence base
N — Natural disturbance	(a) storm and cyclone exposure; (b) thermal stress (marine heatwaves, bleaching); (c) disease and pest outbreak; (d) erosion, subsidence and sediment dynamics; (e) flooding and hydrological change	Historical event frequency/severity records for the site or region (≥30 years where available); hazard maps; peer-reviewed regional studies; site geomorphological/hydrological survey
C — Climate trajectory	(a) projected warming and marine heatwave frequency over the ECP; (b) ocean acidification trajectory; (c) relative sea-level rise and inundation/squeeze exposure; (d) projected extreme-weather intensification	Published downscaled climate projections for the region covering the ECP under at least two scenarios, cited; site elevation/bathymetry data; published ecosystem climate-sensitivity literature
T — Tenure and legal security	(a) strength and registrability of tenure/use rights; (b) competing claims and disputes; (c) regulatory and policy stability affecting the commitment; (d) enforceability of the conservation commitments against successors	Title/lease/licence/customary-right instruments; registry searches; legal opinion on enforceability; documented dispute history; the Schedule 1 element evidence
E — Enforcement and governance capacity	(a) capacity to detect and prevent encroachment, illegal harvest and damaging use; (b) effectiveness of the responsible authority or manager; (c) jurisdictional governance quality	Patrol/enforcement records or plans with funding; managing-body track record; published governance assessments and, where indices are used, at least two independent sources with documented justification
F — Financial	(a) proponent financial viability over the commitment; (b) security of monitoring funding (escrow/endowment status); (c) durability of benefit-sharing and community-funding arrangements	Audited accounts; funding instruments; escrow/endowment documentation; benefit-sharing agreements
M — Management and community	(a) technical and management capacity and track record; (b) reversal history of the proponent or site; (c) community dependence on, and support for, the project (livelihood displacement pressure); (d) continuity and succession arrangements	CVs and organisational history; documented prior-programme performance including any reversal record; stakeholder-consultation outputs under the safeguards process; succession plan

3.2 The predecessor's five categories (Internal, External, Natural, Climate, Longevity — clauses 0039–0043) map into this structure as follows: Internal → F and M; External → T and E; Natural → N; Climate → C; Longevity is retired as a scored category — durability now operates through the enforceable commitment period and Schedule 1, and a crediting period may never exceed the ECP (MCC-200 Annex B-6), so misalignment between claim and commitment is an eligibility failure, not a score (SYS-09).

3.3 Country-level indices and developer age SHALL NOT be used as standalone score determinants; they are blunt proxies (BUF-05) and MAY inform the E and M category factors only alongside project-specific evidence.

§4. Scoring

4.1 Each factor SHALL be scored as a whole number from 1 (lowest risk) to 5 (highest risk) against the anchored descriptors of §4.2, by the independent assessor, with the supporting evidence, data, citations and reasoning for each score recorded.

4.2 Score anchors (applied per factor, over the full ECP):

Score	Anchor
1	Risk source absent or negligible over the ECP; strong, evidenced controls; no adverse history
2	Risk source present but low; adequate evidenced controls; minor or fully remediated adverse history
3	Material risk source; controls present but with evidenced gaps; some adverse history or data limitations
4	High risk source; weak or unproven controls; significant adverse history, active dispute or material data gaps
5	Severe or unmanageable risk source; controls absent or failed; ongoing serious adverse events — or the factor is unassessable (§2.4)

4.3 A factor SHALL be scored on evidence, not assertion: each score SHALL cite the specific records relied on, and a score of 1 or 2 SHALL NOT be assigned to any factor whose minimum evidence base (§3.1) is incomplete.

4.4 A proponent or site with a verified reversal in this or any prior crediting programme SHALL score no lower than 4 on factor M(b), and the reversal record SHALL be disclosed in the assessment.

4.5 Category score. Each category's score SHALL be the highest of its factor scores (before any §5 adjustment): a category is only as strong as its weakest evidenced control. Averaging across factors within a category is prohibited.

§5. Mitigation adjustments

5.1 Evidenced risk-mitigation measures — for example insurance covering reversal replenishment, long-term conservation easements beyond the minimum, independently held endowments, engineered protection works, or co-management agreements with dependent communities — MAY reduce a category score by up to 0.5 points per category. (Consultation question 1.)

5.2 A mitigation adjustment SHALL be granted only for a measure that is executed and funded (not planned), that survives proponent default where financial, and whose effect on the specific scored risk is explained.

5.3 No mitigation adjustment SHALL reduce a category score of 5, reverse an ineligibility outcome under §6, or reduce the stress-test floor of §7.4.

5.4 Additional mitigation evidence submitted by the proponent within the thirty-day window of MCC-BPM clause 6.7 SHALL be evaluated under this Section before the assessment is finalised.

§6. Aggregation, floors and hard exclusions

6.1 The composite risk score (CRS) SHALL be:

CRS = max( mean(N, C, T, E, F, M), Cmax − 1.0 )

where the six values are the category scores after any §5 adjustment and Cmax is the highest of them; the CRS is recorded to one decimal place.

NOTE — why this formula. The predecessor used a pure arithmetic mean (clause 0046), which lets one catastrophic category be diluted by low scores elsewhere — the audit's BUF-05 finding. The floor term (Cmax − 1.0) guarantees that a single category at 5 yields a CRS of at least 4.0 and a single category at 4 yields at least 3.0, whatever the other categories score: dilution is structurally impossible while balanced moderate risk still maps proportionately. The category-maximum rule of §4.5 applies the same logic within categories. Conservativeness is thus built into the arithmetic at both levels rather than left to assessor judgement.

6.2 Hard exclusions. A project SHALL be ineligible for stored-carbon issuance where any of the following holds:

6.2.1 any category score is 5 after mitigation adjustment (which includes any unassessable factor, per §2.4 and §4.5);

6.2.2 the CRS is 4.3 or higher (Consultation question 2.); or

6.2.3 the stress-test floor of §7.4 exceeds the band maximum of MCC-BPM clause 7.4 (§7.5).

6.3 An ineligibility outcome SHALL be recorded with reasons, is subject to the decision and appeal rights of MCC-700, and MAY be cured only by new evidence and a fresh assessment; no body may waive it.

6.4 Any category score of 4, or CRS of 3.5 or higher, SHALL trigger: (a) blind peer review of the assessment by a second independent expert who has not seen the first assessor's scores before forming their own (carried from predecessor clause 0068); and (b) a documented risk-remediation plan agreed before first issuance.

6.5 Where the two blind assessments differ by more than 0.5 in CRS or in any category score by more than 1, the higher scores SHALL stand unless the reviewers document an agreed resolution.

§7. Mapping to the buffer contribution rate

7.1 The CRS SHALL map to a buffer contribution rate within the MCC-BPM clause 7.4 band as follows:

CRS	Buffer contribution rate
1.0 – 1.8	10%
1.9 – 2.6	20%
2.7 – 3.4	30%
3.5 – 4.2	40%
4.3 – 5.0	Ineligible (§6.2.2)

NOTE. This mapping is carried from predecessor clauses 0047–0051 as the consultation proposal, re-based onto the conservative CRS of §6.1; it is not calibrated on MCC operational data (none exists) and is confirmed or varied on adoption. A rate below 15% additionally requires the justification of MCC-BPM clause 7.9. (Consultation question 3.)

7.2 Where MCC-BPM clause 7.4's band is narrowed per family on approval, this mapping SHALL be re-scaled into the narrowed band by the same amending decision, not by the assessor.

7.3 Stress test. The assessor SHALL model the largest plausible single-event loss for the project — at minimum the worst regional storm/cyclone, thermal-stress and disease scenarios evidenced in the N and C category data over the ECP — expressed as a percentage of the project's credited carbon stock, with the modelling basis recorded.

7.4 The final buffer contribution rate SHALL be the greater of the §7.1 mapped rate and the §7.3 modelled single-event loss percentage rounded up to the next whole percentage point (the stress-test floor).

7.5 Where the stress-test floor exceeds the band maximum, the project SHALL be referred for ineligibility review under §6.2.3: a project whose plausible single event can consume more than the maximum contribution is not insurable by a pooled buffer at that rate, and the deficiency SHALL NOT be hidden by capping (BUF-05).

7.6 The final rate, its derivation (category scores, CRS, mapped rate, stress-test floor) and the evidence index SHALL be stated in the assessment report and applied per MCC-BPM Section 7.

§8. Reassessment triggers and frequency

8.1 A full reassessment SHALL be performed at each verification event, and in any case at least every five years (Consultation question 4.).

8.2 A reassessment SHALL additionally be triggered, within ninety calendar days of the trigger event, by any of:

8.2.1 a change in project ownership, management or the managing body;

8.2.2 a major modification of project scope, boundary or design;

8.2.3 a natural disturbance or climate event at or materially affecting the project site, whether or not a reversal is suspected;

8.2.4 a verified reversal at the project (mandatory before any further issuance — MCC-BPM clause 9.14);

8.2.5 a verified reversal at another project in the same family and region, where the adequacy assessment identifies correlated exposure;

8.2.6 a significant change in the host jurisdiction's regulatory, tenure or governance environment;

8.2.7 a downgrade, lapse or impairment of any Schedule 1 durability-class element (Schedule 1 §4.6);

8.2.8 entry into the final five years of the current crediting period; and

8.2.9 monitoring data materially deviating from the monitoring plan's expected ranges.

8.3 Rate changes from reassessment apply per MCC-BPM clauses 7.6–7.8: upward automatically and prospectively; downward only with independent reassessment, VVB verification and Registry Oversight Committee confirmation.

§9. Worked example

NOTE — ILLUSTRATIVE ONLY. Every number in this example is a placeholder invented to demonstrate the arithmetic of §§4–7. It describes no real project, site, jurisdiction or datum, and none of its values may be cited as a benchmark, precedent or default.

9.1 Setting (illustrative). An F01 mangrove-restoration project; crediting period 20 years; enforceable commitment period evidenced at 32 years; durability class D-30 (Schedule 1 §S4.2: 20 + 10 = 30 ≤ 32). Verified quantity after MCC-100 clause 9.9 steps (a)–(c): 48,712 tCO2e.

9.2 Factor and category scores (illustrative).

Category	Factor scores	Category score (§4.5: maximum)
N	storms 3; thermal 2; disease 2; subsidence 2; flooding 2	3
C	warming 2; acidification 1; sea-level rise 2; extremes 2	2
T	tenure 2; claims 1; regulatory 2; enforceability 2	2
E	detection 2; authority 2; governance 2	2
F	viability 3; monitoring funding 2; benefit-sharing 2	3
M	capacity 2; reversal history 1; community dependence 2; succession 2	2

No mitigation adjustment is claimed.

9.3 Aggregation (illustrative). mean(3, 2, 2, 2, 3, 2) = 2.33; Cmax − 1.0 = 3 − 1.0 = 2.0; CRS = max(2.33, 2.0) = 2.3. No hard exclusion applies (no category 5; CRS < 4.3). Because no category scores 4 and CRS < 3.5, §6.4 blind peer review is not triggered.

9.4 Mapping and stress test (illustrative). CRS 2.3 maps to 20% (§7.1). The assessor models the worst evidenced regional cyclone scenario as a plausible single-event loss of 22% of credited stock; the stress-test floor is 22% (§7.4). Final rate = max(20%, 22%) = 22% — within the 10–40% band, so no §7.5 referral.

9.5 Contribution (illustrative). Buffer contribution = 22% × 48,712 = 10,716.64 → rounded up to 10,717 MCC-CC into the buffer pool; net issuance = 48,712 − 10,717 = 37,995 MCC-CC to the project (MCC-BPM clause 7.3). The sum equals the verified quantity, and the 15%-justification duty of MCC-BPM clause 7.9 is not engaged.

§10. Assessors, independence and process

10.1 Assessments SHALL be performed by an independent, qualified assessor with documented expertise in carbon permanence, the relevant marine ecosystem and the applicable methodology; the assessor SHALL disclose conflicts of interest and SHALL have no financial interest in the project outcome (MCC-BPM clause 6.4).

10.2 The assessor's evidence file SHALL permit full recomputation of every score, the CRS, the stress test and the final rate by a third party from the recorded evidence alone.

10.3 The completed assessment SHALL be verified by the project's VVB as part of validation (and at reassessment, verification), including checks that no factor was omitted, no unassessable factor was scored below 5, and the arithmetic of §§6–7 was applied exactly.

10.4 The proponent's thirty-day response window, publication, redaction and validity rules are those of MCC-BPM clauses 6.6–6.8.

10.5 Assessment records SHALL be retained per the Record Retention Schedule; pending its publication, no assessment record SHALL be destroyed (MCC-BPM clause 15.3).

§11. Adoption, versioning and review

11.1 This Tool SHALL be adopted under the decision type of MCC-700 Annex A row 3 (as a Tier 4 tool accompanying the Tier 3 standard) — during the transitional period, by Founder Decision recorded and tabled for ratification under MCC-700 Section 23 — following public consultation; it takes effect no earlier than MCC-BPM v2.0.

11.2 This Tool SHALL be reviewed at least every two years against accumulated assessment and reversal data and the published approaches of other crediting programmes, as a design reference and not an alignment claim (MCC-001 clause 8.8; MCC-BPM clause 12.9).

11.3 Versioned test cases, including §9 recomputed, SHALL be published with each version so that implementations can be machine-checked (mirroring the MCC-200 clause 6.6 pattern).

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End of MCC-NPRT version 1.0-draft. Status: DRAFT — FOR CONSULTATION. Not in force. Points the Programme has not decided, or on which it proposes a rule for comment, are listed under Consultation questions above and marked in the text.