Who gains from saving nature
Ledger 1 : 33 — For each dollar financing nature-based solutions in 2023, about $33 financed activities harmful to nature. (UNEP)
Cases / Carbon credits · United States · 2020–2025

California forest offsets buffer pool and wildfire

Nature's voice · report
Fires burned my forest on projects whose stored carbon had been credited: the Lionshead fire at Warm Springs and the Bootleg fire at Klamath East.
Did nature suffer? Yes. Harm is on record.
Recorded
  • Losses at the four projects CarbonPlan listed were estimated at 1.38, 1.15, 3.95 and 0.21 million tCO2. CarbonPlan
What the record lacks: 4 none on record · 1 not disclosed · 4 disputed · 2 unclear See the gaps

California's forest offsets programme sets aside credits in a buffer pool to cover losses such as fire. Researchers estimate that fires have used up almost 40% of the pool, against 20% allocated for 100 years of fire risk.

~40% vs 20% estimateBuffer pool consumed by fire vs 100-year fire allocation
CarbonPlan estimate, 2025.

Status As of the latest sources reviewed (September and December 2025): CarbonPlan estimated wildfire had consumed almost 40% of the pool, and Verra's durability pilot allowed insurance in place of buffer contributions from December 2025.

What?
California's forest offset programme sets aside 2–4% of each project's credited carbon in a buffer pool to cover losses such as fire. Researchers estimated that wildfires had used at least 95% of the pool's 100-year fire allocation by 2022 and almost 40% of the whole pool by 2025. Frontiers in Forests and Global Change (Badgley et al.)
Where?
California's forest offset programme, run by the California Air Resources Board (CARB); burned projects include Warm Springs, Klamath East, Colville and Montesol.
When?
Lionshead fire 2020; Bootleg fire 2021; Badgley et al. published 5 August 2022; CarbonPlan called the pool 'effectively insolvent' on 1 December 2022. Nearly 11 million credits lost by 29 November 2023; almost 40% of the pool consumed by 3 September 2025.
Who?
Gained
  • Holders of credits from burned forest projects — Credits lost to fire are replaced from the pool; buyers are not charged CarbonPlan
  • Microsoft — Bought about 240,000–265,000 credits from Klamath East and West in 2020–21; credits already used by buyers stand Inside Climate News
Lost
  • The shared buffer pool — Nearly 11 million credits lost to wildfire out of about 33.5 million ever deposited (2023); almost 40% consumed against 20% allocated for 100 years of fire (2025) CarbonPlan
  • Green Diamond (Klamath East project owner) — Project to be terminated, according to its filings as reported by OPB Inside Climate News
Harmed
  • Warm Springs project forest (Lionshead fire, 2020) — At least 1.38 million tCO₂ lost (CarbonPlan estimate); official figure still undisclosed CarbonPlan
  • Klamath East project forest (Bootleg fire, 2021) — At least 1.15 million tCO₂ lost (CarbonPlan estimate) CarbonPlan
  • Colville project forest — 3.95 million tCO₂ lost (official), plus a further 1.79 million in its seventh reporting period (2023) CarbonPlan
  • Montesol project forest — 0.21 million tCO₂ lost CarbonPlan
Why?
The buffer pool's stated purpose is to replace credits lost when credited forests burn. Badgley et al. found it 'severely undercapitalized': fire losses within about a decade reached at least 95% (upper estimate 114%) of the contributions meant to cover 100 years of fire risk. Frontiers in Forests and Global Change (Badgley et al.)
How?
When a credited forest burns, CARB replaces the lost credits from the shared pool rather than charging the buyer, so credits already used against emissions remain valid. Disclosure lags: Warm Springs' post-fire carbon stock was still undisclosed after about 60 months, although the rules require it within 23 months. CarbonPlan
In proportion Fire had consumed almost 40% of the pool, against 20% allocated for 100 years of fire risk (CarbonPlan, 2025). CarbonPlan
6 of 6 questions answered from the record

What happened

The record, in order.

Forest offset projects in California's programme contribute 2–4% of their credited carbon to a buffer pool for fire risk. When a credited forest burns, the California Air Resources Board (CARB) replaces the lost credits from the pool; buyers are not charged.

A peer-reviewed study by Badgley et al. (CarbonPlan), published on 5 August 2022, estimated wildfire losses of 5.7–6.8 million credits, at least 95% of the pool's 100-year fire allocation (upper estimate 114%). The total pool held about 31.0 million credits.

In December 2022 CarbonPlan estimated losses of at least 1.38 million tCO₂ at Warm Springs (Lionshead fire), at least 1.15 million at Klamath East (Bootleg fire), 3.95 million officially at Colville and 0.21 million at Montesol, and described the pool as "effectively insolvent".

In November 2023 CarbonPlan reported a further 1.79 million tCO₂ lost at Colville and programme-wide wildfire losses of nearly 11 million credits out of about 33.5 million ever deposited. In September 2025 it noted that Warm Springs' post-fire carbon stock was still undisclosed after about 60 months, although the rules require it within 23 months.

Microsoft bought about 240,000–265,000 credits from Klamath East and West in 2020–21. The Klamath East project is to be terminated, according to Green Diamond's filings as reported by OPB.

Verra, which runs a separate voluntary-market buffer pool for agriculture, forestry and other land use, said in a 2021 consultation that cancellations 'may be inadequate'. From December 2025 its durability pilot allows approved insurance policies to be used instead of buffer-pool contributions; CarbonPool and Kita were approved, followed by Artio.

  1. 2020Lionshead fire burns the Warm Springs project
  2. 2021Bootleg fire burns Klamath East; Microsoft credit purchases reported
  3. 2022Badgley et al.: fire losses at least 95% of 100-year allocation (5 Aug); CarbonPlan: pool "effectively insolvent" (1 Dec)
  4. 2023CarbonPlan: nearly 11m credits lost to wildfire of 33.5m deposited (29 Nov)
  5. 2024Lloyd's lineslip for carbon-credit insurance with Apollo, Hiscox and other syndicates (October)
  6. 2025CarbonPlan: almost 40% of pool consumed; Warm Springs stock still undisclosed (3 Sep); Verra durability pilot allows insurance in place of buffer contributions (from December)

What was said

Claims, in the words of those who made them.

“California's forest carbon offsets buffer pool is severely undercapitalized.”

“effectively insolvent”

CarbonPlan, on the buffer pool · 1 December 2022 · CarbonPlan

Where accounts differ

Each party's account, side by side, with its source. The record does not settle these points; it shows them.

Is the buffer pool large enough to cover wildfire losses?
Researchers
Badgley et al. (CarbonPlan)

Wildfire losses were at least 95 percent of the 100-year fire allocation; the pool is severely undercapitalized.

Frontiers in Forests and Global Change (Badgley et al.)
Researchers
CarbonPlan

Wildfire has consumed almost 40% of the pool against 20% allocated for fire over 100 years.

CarbonPlan
Standard-setters and registries
Verra

Its 2021 consultation said buffer cancellations 'may be inadequate'.

International Seabed Authority submission
How large is the pool?
Government and regulators
CARB

Reports 28.3 million buffer credits, a figure that excludes Lionshead.

CarbonPlan
Researchers
CarbonPlan

Estimates about 33.5 million credits were ever deposited, with program-wide wildfire losses of nearly 11 million.

CarbonPlan

How it looked

What was shown, beside what was recorded.

Shown

  • A shared buffer pool, filled from 2–4% of credited carbon for fire risk, as the programme's cover for losses of stored carbon
    California forest-offset programme rules, as described by Badgley et al. · Frontiers in Forests and Global Change (Badgley et al.)
  • Buyers are not charged when burned credits are replaced from the pool
    CarbonPlan's description of the CARB mechanism · CarbonPlan

Recorded

  • Wildfire losses of 5.7–6.8 million credits, at least 95 percent of the 100-year fire allocation (upper estimate 114%)
    Frontiers in Forests and Global Change (Badgley et al.)
  • Program-wide wildfire losses of nearly 11 million credits out of about 33.5 million ever deposited in the buffer
    CarbonPlan
  • Wildfire has consumed almost 40% of the pool, against 20% allocated for fire over 100 years (CarbonPlan estimate)
    CarbonPlan
  • Warm Springs post-fire carbon stock undisclosed after about 60 months; the rules require disclosure 'within 23 months'
    CarbonPlan

Who gained

Money that reached nature, beside money that stayed elsewhere.

Reached nature or the ground

Not published
No figure published.

Gained elsewhere

Not totalled
Currency: · Window: . All figures cover the same period. * Estimate built from cited figures.

Responses on record

  • carb (2025): CARB reported 28.3 million buffer credits, a figure that excludes Lionshead. · CarbonPlan
  • verra (2021; December 2025): In a 2021 consultation, said buffer cancellations 'may be inadequate'; from December 2025 its durability pilot allows approved insurance in place of buffer-pool contributions. · Verra

In court and with insurers

Every proceeding and every insurer decision on record.

Lawsuits and rulings

No court case on record. No court has ruled on this case.

Insurers

  1. 2025Self-insured
    California forest offsets buffer pool (programme self-insurance, administered by CARB) → Holders of credits from burned forest projects

    CARB replaces credits lost to fire from the shared buffer pool; buyers are not charged. CarbonPlan

  2. 2024No policy found
    Lloyd's syndicates including Apollo and Hiscox → Carbon-credit buyers and projects (lineslip)

    A Lloyd's lineslip with Apollo, Hiscox and other syndicates was recorded in October 2024. Verra

  3. 2025No policy found
    CarbonPool, Kita and Artio → Forest-carbon projects under Verra's durability pilot

    Verra's durability pilot, from December 2025, allows insurance in place of buffer-pool contributions. CarbonPool and Kita were approved, then Artio. Verra

What nature saw

Outcomes measured on the ground, and nature's note.

Nature's report opens this page. Below: further outcomes measured on the ground.

Pool consumed by fire
~40%
Against 20% allocated for 100 years (CarbonPlan, 2025)
Fire allocation used
≥ 95%
Badgley et al., 2022
Warm Springs post-fire carbon stock
Undisclosed
After about 60 months; rules require it within 23 months

What we don't know

Undisclosed, unproven, untried: recorded as data.
No court caseUnder standard-setter reviewKey earnings undisclosed

Court

Insurers

  • Unclear Lloyd's syndicates including Apollo and Hiscox: no decision on record.
  • Unclear CarbonPool, Kita and Artio: no decision on record.

Accounts

  • Disputed Is the buffer pool large enough to cover wildfire losses?
  • Disputed How large is the pool?

Record

  • Not disclosed Warm Springs (ACR260) official reversal tonnage is still undisclosed.
  • None on record No CARB buffer data after 2025 was found.
  • Disputed Microsoft's credit volume differs between sources (about 240,000–265,000).
  • None on record No insurer is involved; no commercial insurance claim for burned offset forests was found.
  • None on record The total buffer pool: CARB reported 28.3 million credits, a figure that excludes Lionshead, while the 2022 study put the pool at about 31.0 million credits and CarbonPlan's later figure for credits ever deposited was about 33.5 million.
  • Disputed Oka's approval status under Verra's durability work: reported but not independently verified. A Verra approval is recorded for CORSIA, and the company's own site mentions a 14 October 2026 'Verra durability placement'; the two accounts conflict.

Did the harm stop?

No. Burned credits are replaced from the buffer pool and the credits already used by buyers stand.

Who paid?

The shared buffer pool, which CarbonPlan estimates fire has consumed almost 40% of, against 20% set aside for 100 years.

Sources

Voices on record: — Company or project✓ Government and regulators— Courts✓ Press and investigations— Communities and civil society✓ Researchers✓ Standard-setters and registries

Government and regulators

Press and investigations

Researchers

  1. California's forest carbon offsets buffer pool is severely undercapitalized
    Frontiers in Forests and Global Change (Badgley et al.) · 2022-08-05
  2. Buffer analysis update
    CarbonPlan · 2022-12-01
  3. Buffer update three
    CarbonPlan · 2023-11-29
  4. Lionshead fifth anniversary
    CarbonPlan · 2025-09-03

Standard-setters and registries

Connected cases

Related matters, and cases linked to this one through the same organisations, with the role each played in both.
Terms used on this page

Carbon and conservation finance

Buffer pool
A reserve of credits held back from sale by a carbon programme to cover future losses, such as forest burned or logged after credits were issued. It works as the programme's own insurance.
Carbon credit
A certificate representing one tonne of carbon dioxide (or equivalent) that a project says it reduced, avoided or removed. Buyers use credits to balance their own emissions in climate claims.
Offset
Using carbon credits to balance emissions released elsewhere, so that a buyer can claim lower or zero net emissions.
REDD+
Reducing Emissions from Deforestation and forest Degradation. A UN framework under which forest projects earn carbon credits for deforestation they say they prevented, measured against a projected baseline.
Standard-setter and registry
An organisation that writes the rules for carbon credits, approves projects, and records when credits are issued and retired. Such bodies typically charge fees per credit.

Institutions

CARB
The California Air Resources Board, which runs the state's cap-and-trade programme and its offset credits.

Bonds and banking

Liquidation, insolvency, bankruptcy
Legal processes that apply when a company cannot pay its debts; its assets are sold and claims against it may go unpaid.

Insurance

Captive insurer, self-insurance
A company covering its own risks, either directly or through an insurance company it owns.
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