MCC-M008 Amendment 1 — Provenance of credited gear, and the prevention limb v1.0-draft

Document control

Field	Value
Document code	MCC-M008 Am.1
Title	Amendment 1 — Provenance of credited gear, and the prevention limb
Amends	MCC-M008 — Marine Gear Loss Prevention (Ghost Gear Recovery) v1.1, adopted on 1 September 2026 as editorial codification by FD-2026-09-01 item D1 (recorded in the decision register as attested by the founder, with no executed copy filed). FD-2026-09-03 item D6 (likewise recorded as attested by the founder, with no executed copy filed) sets M001–M010, M008 included, to CONCEPT/DRAFT; the methodology register still records MCC-M008 v1.1 as APPROVED
Version	1.0-draft, revised 6 September 2026 (clause 3 rewritten on a corrected premise — see the erratum in the note below)
Status	DRAFT — FOR CONSULTATION
Date of this draft	4 September 2026; clause 3 and clause 5.1 revised 6 September 2026
Tier	Tier 4 (methodology). Approval of a methodology or an amendment to one is reserved to the body MCC-200 names; this Amendment decides nothing.
Effective date	None. This Amendment is not in force. Until it is, MCC-M008 v1.1 stands as adopted, including the defects it records.
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	PAR-2026-001 findings F2 and F3; MCC-M008 v1.1 MOD-01 items 1 and 3, MOD-02 item 1, MOD-03 items 1 and 5, MOD-04, MOD-10 item 2; MCC-200 cl. 0023–0034; MCC-100 cl. 0041–0043; Claims and Use of Credits Policy v1.1 ss. 1.3.1, 3.1; FD-2026-08-24 item D6 (recorded in the decision register as attested by the founder, with no executed copy filed); Definitions Register v1.0 (D6); F04 Applicant Guidance v1.1 §§1–4.
Language convention	British English; RFC-style normative verbs (SHALL/MUST = mandatory; SHOULD = recommended, deviation to be documented; MAY = optional). One requirement per numbered clause.
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 Amendment narrows the methodology. That is the point.

MCC-M008 is the only methodology the Programme's methodology register records as APPROVED (v1.1), although FD-2026-09-03 item D6 sets M001–M010, M008 included, to CONCEPT/DRAFT; both projects in the register sit in its family. Two defects were found on 4 September, and neither is a drafting slip.

First, nothing in the methodology says where the gear came from. The eligibility conditions at MOD-01 item 3 require a legal right to operate, a chain of custody from the recovery event, an additionality test and a boundary. They do not require that the gear was in the sea before the project, that it was lost by somebody other than the proponent, or that it was lost at all. A programme that pays a fixed sum per hundred kilograms recovered, and does not ask where the kilograms came from, has written an incentive it cannot see. This is the first question a serious external reviewer asks, and MCC-M008 v1.1 has no answer in it.

Second, the methodology admits an activity it does not itself measure. MOD-01 item 1 brings within scope "activities that demonstrably prevent gear loss". MOD-03 item 1 then defines the unit as "100 kg of recovered and documented gear". The methodology contains no quantification rule for prevention, no monitoring rule — MOD-04 logs recovery events — and no evidence rule. A VVB reading MCC-M008 alone must refuse prevented mass.

Erratum, 6 September 2026. This draft as first published went further and said that no prevention rule existed to be adopted, that the loss literature does not report in mass, and that a mass-denominated prevention baseline "does not exist". That was wrong, and it was wrong because one instrument was read and the corpus was not. F04 Marine Pollution Prevention: Applicant Guidance v1.1 is ADOPTED (FD-2026-08-24 item D6) and supplies exactly such a rule: delivery is verified mass removed or prevented; "Forebygget: baseline-tapsrate × dokumentert reduksjon (f.eks. redskapsmerking som reduserer tap fra X til Y tonn/år); reduksjonen må være målt, ikke antatt"; and its worked example credits 6 tonnes prevented alongside 62 tonnes recovered, through the same 10 per cent buffer and the same 0.1 t/MCU divisor. The rule is mass-denominated, it is adopted, and it was in force when this draft said it did not exist. PAR-2026-001 F3 is retracted to that extent.

What is actually wrong is a hierarchy defect, and it is still serious. The calculation rule for one limb of the unit sits in applicant guidance rather than in the methodology, when MCC-200 cl. 0026 requires MOD-03 to define the calculation methods, data sources and quality requirements. Two adopted instruments therefore give a VVB opposite answers on the same issuance: the guidance says prevented mass is creditable, MOD-03 item 1 says the unit is recovered mass. And the guidance's rule, right in principle, is not yet verifiable: "målt, ikke antatt" states the correct standard but supplies no test of what a measured baseline loss rate is, over what period, against what control, or how the reduction is attributed to the intervention rather than to a change in effort or weather. Nothing monitors it, because MOD-04 logs recovery events.

The response is therefore not to suspend the limb. It is to lift the adopted rule into the methodology where it belongs and to write the evidence and monitoring rules it lacks, so that the limb becomes verifiable rather than merely permitted. Clause 3 does that. Until this Amendment is in force, MOD-03 item 1 as adopted governs and prevented mass is not creditable under MCC-M008 — which is the existing state of the methodology, not a suspension this draft imposes.

Neither defect has cost anything yet: no credit of any kind has ever been issued, and credit_units holds no rows. The whole value of fixing it now is that it is free to fix now.

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 2.3 — Look-back for the proponent's own losses. Proposed: gear lost by the proponent, an affiliate or a vessel under the proponent's operational control is not credited where the loss occurred within the crediting period or in the thirty-six months preceding the project start date. Basis: aligned with the look-back period of the Register of Interests draft (MCC-ROI s. 3.6), the same 36 months that FD-2026-10-01 Schedule 1 (Q7) proposes for the conflict-of-interest look-back; FD-2026-10-01 item 4. Decided by: the Governing Board on adoption of the suite. Comments are invited on the period: a different period is defensible; a period of zero is not, because it would make the rule inoperative.

2. Clause 3.9 — Uncertainty buffer for prevented mass. Proposed: no proposal is made — no figure for a different buffer exists in the record. As drafted, prevented and recovered mass are summed before the ten per cent buffer of FD-2026-08-24 item D6 is applied (clause 3.2); the drafter's view, recorded in clause 3.9 and not decided, is that the buffer for prevented mass should be higher and the F04 Applicant Guidance worked example revised with it. Basis: FD-2026-08-24 item D6; FD-2026-10-01 item 4. Decided by: the Governing Board on adoption of the suite. Comments are invited on whether prevented mass, which is inferred from a rate, should carry a higher buffer than recovered mass, which is weighed at landing, and at what level.

3. Clause 4.3 — Further enforcement of the contribution-only claim. Proposed: no proposal is made — the text cites only the control that exists (clause 4.2), and no further layer has been decided. Basis: clause 4.2 of this Amendment. Decided by: the Governing Board on adoption of the suite. Comments are invited on whether a portal-side check or a contractual term at retirement should be required.

4. Clause 5.1 — Wording of the unit definition. Proposed: no proposal is made — this Amendment leaves the text of MOD-03 item 1 unchanged and governs the prevention limb through the new MOD-03 item 6, and leaves open whether the unit definition itself should read "recovered or prevented". Basis: clause 5.1; FD-2026-10-01 item 4. Decided by: the Governing Board on adoption of the suite. Comments are invited on whether the unit definition should be amended.

5. Clause 5.2 — Differentiating the unit by ghost-fishing potential. Proposed: no proposal is made — it is the most substantive open question about the unit and not a drafting matter, and this Amendment puts forward no basis for a differentiation. Basis: clause 5.2; FD-2026-10-01 item 4. Decided by: the Governing Board on adoption of the suite. Comments are invited on whether, and on what evidence, the unit should be differentiated by material, gear type or ghost-fishing potential.

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1. Purpose and effect

1.1 This Amendment SHALL insert a provenance requirement into MCC-M008, SHALL bring the prevention limb into the methodology by adopting into MOD-03 and MOD-04 the quantification rule already adopted in the F04 Applicant Guidance v1.1 together with the evidence and monitoring rules that rule lacks, and SHALL correct two citations in MOD-10 that do not say what the text relies on them to say.

1.2 This Amendment introduces no crediting that the adopted corpus does not already provide for. The provenance provisions narrow eligibility; the prevention provisions do not widen the unit — the F04 Applicant Guidance v1.1, adopted, already credits prevented mass — but subject it, for the first time, to an evidence standard, a monitoring obligation and a verification test, each of which narrows what may be issued against it. Where this Amendment and MCC-M008 v1.1 conflict, this Amendment prevails on entry into force; until then MCC-M008 v1.1 stands as adopted.

1.3 Nothing in this Amendment alters the unit definition (1 MCC-MCU = 100 kg; renamed MCC-MOU by FD-2026-09-03 item D1, recorded in the decision register as attested by the founder, with no executed copy filed; the Definitions Register records the rename on adoption of its amendment), the 10 per cent uncertainty buffer, or the prohibition on any climate claim for an MCU. Those are settled by FD-2026-08-24 item D6 and are not reopened here.

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2. Provenance of credited gear (new MOD-01 items 5 to 11)

Insert after MOD-01 item 4:

2.1 5. Provenance is an eligibility condition. A recovery event SHALL NOT be credited unless the project evidences that the gear, before the recovery event, was lost, abandoned or otherwise discarded in the marine or coastal environment by a person other than the project proponent or an affiliate of the proponent.

2.2 6. Placed gear is never eligible. Gear introduced to the marine environment by any person for the purpose of being recovered SHALL NOT be credited, and the introduction of gear for that purpose is a material breach of the Programme's rules by every party who participates in it.

2.3 7. The proponent's own losses. Gear lost by the project proponent, or by an affiliate, or by a vessel under the proponent's operational control, SHALL NOT be credited where the loss occurred within the crediting period or in the thirty-six months preceding the project start date. (Consultation question 1.)

2.4 8. Submersion. Gear SHALL have been submerged, beached or afloat in the marine or coastal environment. Gear held on land, in a store, at a landfill, at a port reception facility or in a waste stream SHALL NOT be credited, whatever its origin. Land-based waste is already out of scope under MOD-01 item 4; this clause states the boundary at the point where it is tested.

2.5 9. Evidence of provenance. For every recovery event the project SHALL record, in addition to the data required by MOD-03 item 5: (a) the condition of the gear on recovery, with photographic documentation sufficient to show fouling, degradation or marine growth consistent with the claimed period of submersion; (b) the depth or position from which it was recovered; (c) any identifying marks, tags or gear-marking information present, and, where the gear is identifiable to an owner, the steps taken to establish that the owner is not the proponent or an affiliate.

2.6 10. Declaration. The project proponent SHALL declare, for each issuance request, that no credited gear was placed for recovery and that no credited gear falls within clause 7. A false declaration is a ground for cancellation under MCC-800 arts. 51–52 and for suspension of the project.

2.7 11. Verification. The VVB SHALL test provenance as a distinct assertion, and SHALL state in the verification report whether the provenance evidence supports the mass claimed. A verification that does not address provenance is not a verification of this methodology.

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3. The prevention limb (amendment to MOD-01 item 1, new MOD-03 item 6, new MOD-04 item 7)

3.1 MOD-01 item 1 is amended by inserting after "and to activities that demonstrably prevent gear loss" the words: "; prevented loss is quantified, monitored and evidenced under MOD-03 item 6 and MOD-04 item 7, and no unit may be issued for prevented loss otherwise".

3.2 Insert as MOD-03 item 6 — quantification of prevented loss. "Prevented loss SHALL be quantified as the baseline loss rate for the fishery or area, multiplied by the documented reduction in that rate attributable to the project intervention, expressed in kilograms over the monitoring period. The reduction SHALL be measured and SHALL NOT be assumed. Prevented mass and recovered mass are summed before the uncertainty buffer at MOD-03 item 5 is applied, and the resulting creditable mass is converted at the unit definition at MOD-03 item 1. This item adopts into the methodology the delivery rule already in force at F04 Applicant Guidance v1.1 §2, and the methodology and that Guidance are to be read as one."

3.3 Insert as MOD-03 item 6(a) — evidence standard for the baseline loss rate. "A baseline loss rate is measured, and not assumed, only where it is derived from: (i) at least twenty-four consecutive months of loss records for the same fishery, gear type and area, from an independent source or a source auditable by the VVB; or (ii) a documented gear-census or loss-reporting scheme covering at least eighty per cent of the vessels or operators in the boundary over at least twelve months. A baseline derived from a literature value for a different fishery, a regional average, or the proponent's own unverified estimate is an assumed baseline and SHALL NOT support issuance. Where the available record is shorter than twenty-four months or covers less than eighty per cent of operators, the baseline SHALL be set at the lower bound of its range and the shortfall disclosed in the PDD."

3.4 Insert as MOD-03 item 6(b) — attribution. "The reduction SHALL be attributed to the project intervention against a control: a comparable fishery, area or vessel cohort outside the boundary and not subject to the intervention, monitored over the same period; or, where no control is available, a documented before-and-after series with an explicit adjustment for effort, fleet composition and weather, and the adjustment method stated in the PDD and reproducible by the VVB. A reduction coincident with a fall in fishing effort SHALL NOT be credited to the extent of that fall."

3.5 Insert as MOD-03 item 6(c) — no double counting between the limbs. "Gear counted as prevented loss SHALL NOT also be counted as recovered mass, in the same or any later monitoring period, by this project or by any other project. Where a project operates both limbs in the same boundary, the PDD SHALL state how the two are kept separate and the VVB SHALL test it."

3.6 Insert as MOD-04 item 7 — monitoring of prevented loss. "A project crediting prevented loss SHALL monitor and report, for each monitoring period: the loss records or census returns constituting the baseline and their source; coverage of the scheme as a percentage of operators and vessels in the boundary; the intervention actually deployed, with quantities and dates (marking coverage, retrieval-system deployments, reception-facility throughput); the control series or the effort adjustment; and the resulting loss rate with its dispersion. Monitoring frequency is annual, coincident with the recovery-event log at MOD-04 items 1 to 6."

3.7 Verification. "The VVB SHALL test the baseline loss rate against MOD-03 item 6(a), the attribution against item 6(b) and the separation of the limbs against item 6(c), and SHALL state in the verification report the prevented mass it verifies and the mass it declines, with reasons. Where the VVB cannot verify attribution, the prevented mass is not creditable in that period; it does not accrue and it SHALL NOT be carried forward."

3.8 The prevention limb does not narrow the baseline for the recovery limb. MOD-02 item 1 continues to require the documented loss rate for the area or fishery, because the counterfactual for a recovery project is that the gear remains in the sea and more is lost. Where the same loss rate serves both limbs it SHALL be stated once and used consistently.

3.9 Whether the prevention limb should carry a higher uncertainty buffer than the ten per cent set for recovery at FD-2026-08-24 item D6 is not decided by this Amendment. Prevented mass is inferred from a rate; recovered mass is weighed on a calibrated scale at landing. Treating the two identically at ten per cent is a decision about conservativeness, not a drafting matter, and it is put to consultation with this text; the Standards Committee that would consider it is not constituted (FD-2026-09-04 item 1.1). The drafter's view, recorded and not decided: the buffer for prevented mass should be higher, and the F04 Guidance worked example — which applies the same ten per cent to both — should be revised with it. (Consultation question 2.)

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4. Two citation corrections in MOD-10

4.1 MOD-10 item 2 cites "Claims Policy §4" as the basis of the contribution-only claim. It is not. Article 4.2 of the Claims and Use of Credits Policy v1.1 expressly contemplates a permitted neutrality claim where the claimant documents its own reduction, and s. 3.3 sets out VCMI tier claims as permitted. The categorical contribution-first prohibition is at ss. 1.3.1 and 3.1. MOD-10 item 2 is amended to cite ss. 1.3.1 and 3.1.

4.2 MOD-10 item 2 states that the prohibition is "enforced in three layers". One control enforces it: the database trigger enforce_claim_language on the retirements table, rewritten on 4 September 2026 and extended on 7 September 2026 to read the retirement purpose the portal writes. MOD-10 item 2 is amended to say so, and to name the control. A methodology that overstates its own enforcement is the same defect as a claim that overstates an outcome.

4.3 Whether a second or third enforcement layer — a portal-side check, or a contractual term at retirement — should be added is not decided. If one is, it is to be built before it is cited; until it exists, the text does not describe it. (Consultation question 3.)

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5. What this Amendment does not do

5.1 It resolves the "recovered or prevented" conflict in favour of recovered or prevented, which is the answer the weight of adopted instruments already gives: the Definitions Register v1.0, which prevails on conflict; the F04 Applicant Guidance v1.1 §§1–2, which not only says it but supplies the calculation; and the document_register note. MOD-03 item 1 of the methodology, saying recovered, is the outlier, and clause 3 brings it into line rather than reading the majority down. This draft as first published proposed the opposite — suspending the limb — on the mistaken view that no prevention rule existed anywhere in the corpus; see the erratum in the opening note. What is not resolved here is whether the unit definition at MOD-03 item 1 should itself be textually amended to read "recovered or prevented", or left as it is with MOD-03 item 6 governing the second limb; that is for the body competent to approve the methodology. (Consultation question 4.)

5.2 It does not differentiate the unit by material or gear type. One hundred kilograms of nylon gillnet and one hundred kilograms of steel trap are not the same environmental outcome, and the ghost-fishing literature is clear that they do not go on killing at the same rate. Whether MCC-MCU should be differentiated by ghost-fishing potential is not decided: it is the most substantive open question about the unit, and it is not a drafting matter. (Consultation question 5.)

5.3 It does not create a registry-level control against the same gear being credited twice by different projects. boundary_geojson is null on both projects in the register, so no overlap test is presently possible even in principle. A boundary is required for each project, without which MOD-01 item 3(d) is unmet; both projects are at SUBMITTED and neither has passed the completeness check (Evidence Register ER-2026-001 §A3).

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6. Entry into force

6.1 This Amendment SHALL enter into force on the date stated in the instrument that adopts it, and not before.

6.2 On entry into force, clauses 2 and 3 apply to every issuance request submitted thereafter, including requests relating to recovery events that occurred earlier. No unit has been issued under MCC-M008, so no issued unit is affected and no transitional provision is required.

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MCC-M008 Amendment 1 v1.0-draft, 4 September 2026; clauses 1.1, 1.2, 3 and 5.1 revised 6 September 2026 following PAR-2026-002, which found that the premise of the original clause 3 was false — the F04 Applicant Guidance v1.1, adopted, supplies the prevention rule this draft said did not exist. PAR-2026-001 F3 is retracted to that extent and the erratum is served in the opening note rather than the change being made silently. Prepared by programme administration. Every provision narrows eligibility, subjects existing crediting to an evidence standard, or corrects a reference; none widens the unit. Approval of a methodology amendment is reserved to the body MCC-200 names, and this draft decides nothing.