IN FOCUS: Amy Brachio on Carbon Measures and the Incentives That Move Markets

How do we pivot global corporate behavior from making broad climate commitments to deploying capital for deep decarbonization? In this episode of Navigating Net Zero’s In Focus mini-series on Climate Standards and Guidance, host Alexia Kelly sits down with Amy Brachio, the newly appointed CEO of Carbon Measures. Leveraging nearly three decades of institutional experience at EY—including serving as its Global Vice Chair for Sustainability—Brachio argues that the roadblock to global net zero isn't a lack of corporate ambition, but a lack of functional market structures that incentivize scaled finance for low-carbon commodities.

This deep-dive conversation explores the origin and theory behind Carbon Measures, a new greenhouse gas accounting initiative backed by some of the world's heaviest emitters. Brachio outlines their strategy to move past enterprise-wide risk disclosure toward product-level carbon intensity standards for globally traded commodities like steel, cement, and fuels. By standardizing accounting at the "cradle-to-gate" asset level, Carbon Measures aims to help lawmakers design trade-compliant curves that naturally retool the upstream market supply signal.

Creators and Guests

Host

Alexia Kelly

Alexia Kelly has worked for more than 18 years at the intersection of policy and finance to address the climate crisis. Alexia is the Managing Director of the Carbon Policy and Markets Initiative (CPMI) at High Tide Foundation. The CPMI accelerates ambitious climate action and capital mobilization through robust rules and guidance for voluntary corporate action and disclosures, and building the next generation of high-integrity carbon and environmental services markets. She currently serves on the Board of the Integrity Council for Voluntary Carbon Markets (IC VCM) and the Board of the Advanced and Indirect Mitigation Initiative, as well as on the Expert Advisory Group of the Voluntary Carbon Markets Integrity Initiative (VCMI). Prior to joining High Tide Foundation, she served as Director of Net Zero + Nature at Netflix, where she led the company’s inaugural greenhouse gas inventory, renewable energy strategy, Science Based Target and global carbon credit portfolio. Previously, she worked at the U.S. Department of State, where she served as lead negotiator to the UNFCCC on Article 6 of the Paris Agreement. She has also held senior roles at the World Resources Institute, The David and Lucille Packard Foundation, The Climate Trust, and in private equity.

Guest

Amy Brachio

Amy Brachio (BRAY-she-oh) joined Carbon Measures in September 2025 after nearly three decades at Ernst & Young (EY), continuing her leadership in advancing the evolution of how global organizations navigate the complex intersection of climate action, business resilience, and the urgent need for accurate, verifiable data to underpin solid decision-making. ‍ In her most recent role as Partner and Global Vice Chair for Sustainability at EY, she drove EY’s offerings to help thousands of global clients achieve their sustainability goals, led the company's ambitious 40% carbon emission reduction by 2025, and established EY as the global leader in sustainability services.

Producer

Matt Jordan

Matt Jordan is a Director within the High Tide Foundation’s Carbon Policy and Markets Initiative (CPMI). Matt has been working in climate action for more than 15 years, and has a long track record of envisioning, developing and scaling innovative programs and financing tools that deliver lasting global impact. Matt built CLASP’s Clean Energy Access program from a single small project to an integrated portfolio of technical, research, and market stimulation programs with a coherent, issue-defining theory of change and a global team of more than 20. He co-founded Propel Clean Energy Partners, a consulting firm with clients such as the World Resources Institute, the Rockefeller Foundation, the Children’s Investment Fund Foundation, and the Asian Development Bank. Following their acquisition of Propel’s work and team, Matt served as a Director in RMI’s Global South portfolio and led their global clean energy workforce development initiative. He holds a BA in Philosophy from Colgate University, a Master’s in Public Policy Analysis from the University of California, and a Professional Certificate in Financing and Deploying Clean Energy from Yale University.

What is Navigating Net Zero with Alexia Kelly?

Navigating Net Zero is a podcast featuring conversations with practitioners and experts who are working through the complex realities of corporate decarbonization and sustainability.

We demystify and highlight the challenges, opportunities, and real-world experiences faced by the people leading their institutions' net-zero journeys.

Hosted by internationally-renowned climate change expert Alexia Kelly and brought to you by the Carbon Policy & Markets at the High Tide Foundation, Navigating Net Zero hopes to inspire action from this generation of climate leaders and the next.

This transcript has been edited for brevity and clarity.

**Alexia Kelly**:

Good morning, good afternoon, and good evening. I’m Alexia Kelly, your host here at Navigating Net Zero, the podcast where we talk about what’s happening, what’s working, what’s not, and what’s next on the global journey to net zero.

I’m delighted to be joined today by Amy Brachio, CEO of Carbon Measures and a leading voice on the future of corporate sustainability. After nearly three decades at EY, including serving as Global Vice Chair for Sustainability, she has helped shape how some of the world’s largest companies approach climate risk, business resilience, and sustainability performance.

Today, she is focused on advancing the measurement and data systems that underpin credible climate action—an issue near and dear to my heart, and a topic that seems to be on everyone’s mind in the sustainability space.

Amy, it’s wonderful to have you here. Thanks so much for joining me.

**Amy Brachio**:

Thanks so much for having me.

**Alexia Kelly**:

Tell me a little bit about your personal journey and why you decided to make the leap into this big new initiative called Carbon Measures, which has caused quite a stir in the greenhouse gas accounting and sustainability space.

**Amy Brachio**:

I spent 30 years at EY. I’m a certified public accountant by background, and I served in a number of different roles there. What I always loved was the intersection of market opportunity and purpose. So when I had the chance to become EY’s Global Vice Chair of Sustainability, I couldn’t have been more excited to step into that role.

One of the things that struck me as I worked with our clients was that a shortage of ambition was not necessarily what was holding organizations back. Companies could continue investing in everything we need them to invest in, but if there weren’t buyers on the other side purchasing those products and solutions at the necessary scale, we were never going to see impact at the pace and scale required.

When I reached 30 years at EY, there was something meaningful about that milestone, especially because I had started there as an intern. It also coincided with my younger daughter graduating from college. My husband and I both felt that this might be a time to do something different.

When I made the decision to leave, I had no idea what I was going to do. Then this opportunity came my way. It was business-led, and I had spent my entire career in business. It required accounting expertise, and I’m a CPA. And it was focused on solving the problem I saw as a major obstacle to change.

I couldn’t be more excited to take it on.

**Alexia Kelly**:

It’s certainly important work, and I know many people appreciate you staying in the fight. I imagine your husband might have envisioned something that looked less like working 80 hours a week and more like traveling the world and enjoying yourselves. Hopefully that’s on the horizon as well, once we get the greenhouse gas accounting space sorted out.

**Amy Brachio**:

Exactly.

**Alexia Kelly**:

Tell us a little more about Carbon Measures. What was its origin story, and what is it working to do?

We’ll come back to the question of regulatory versus voluntary action, because that theme cuts across many of the conversations we’re having. I think it’s central to understanding how we navigate the next decade or so of climate action.

**Amy Brachio**:

A number of organizations had been thinking about the fact that, while we have made progress in reducing carbon emissions—and we know we’re on a different trajectory than we would have been before the Paris Agreement and before the strong commitments companies made—we are not going to get all the way to where we need to go through those efforts alone.

The challenge is determining how to align market incentives, which are what really drive corporate behavior, with the actions that need to be taken to reduce carbon emissions.

Four companies initially came together to ask whether this was something that others across the ecosystem and across industries would support. A lot of the leadership came from Ana Botín at Banco Santander and Darren Woods at ExxonMobil, as well as leaders from Nucor and Air Liquide.

Through the World Economic Forum’s International Business Council, they began engaging with other CEOs and asking what it would take to create stronger alignment between market incentives and emissions reductions. That was really where the formation of Carbon Measures began.

Our focus is on unlocking demand for the products we need to decarbonize the economy. When I say products, I don’t mean a tube of toothpaste. I mean steel, cement, electricity and fuels, transportation fuels, chemicals, ammonia, and other foundational products at the beginning of the value chain that drive roughly 70% of emissions.

First, you need a target that a product has to meet. Companies are very accustomed to meeting product standards. Think about health and safety requirements. You cannot buy a car without a seatbelt. Companies have to include seatbelts in their cars.

When we addressed the ozone layer or removed sulfur from fuels, it was because rules were established that said certain products could no longer be sold in the same way.

We want to see product-level carbon-intensity standards established at the appropriate points in the value chain. Those standards need to consider trade, competitiveness, affordability, and emissions reductions. They also need to decline over time, so that eventually a product cannot be sold into a given market if it does not meet the required standard.

If you are going to do that, however, you need data that can underpin contracts and regulatory compliance and flow across the value chain. To get there, you need more specificity and comparability than we have in today’s system.

In many areas, companies have options for how they perform the measurements. Carbon Measures was established to help solve that problem.

We launched in October with 19 companies. We’re now up to 26, we have good visibility into reaching 30, and we have a strong pipeline of other organizations reaching out to join us.

**Alexia Kelly**:

For the record, give us the elevator pitch. What is Carbon Measures?

**Amy Brachio**:

We were established to align market incentives with the actions needed to reduce carbon emissions.

We advocate for carbon-intensity standards and are developing the accounting framework needed to underpin those standards.

We do not intend to exist forever. When our job is finished, we will be done. That means we have to be wildly collaborative with others. Success means policymakers enact laws and an accounting framework is put in place that operates at the level of generally accepted accounting principles or IFRS, so that carbon intensity can be treated in a consistent and credible way.

**Alexia Kelly**:

That is such an important point, and I think it’s an area where there is a lot of confusion. I know you bring tremendous expertise to the table.

Let’s start with greenhouse gas accounting, because it matters so much. It really is at the heart of the conversation.

There are obviously many initiatives and standards addressing product-level carbon-intensity measurement. We now have regulation being implemented through the European Union’s Carbon Border Adjustment Mechanism, or CBAM, which includes product-level carbon-intensity requirements.

This space has evolved very quickly and significantly, but there is still a great deal of work to do around alignment among the key standards.

Talk a little about the work you’re doing on the methodological front. How are you thinking about the right methodologies for calculating product-level carbon intensity? I understand you are in the process of developing your own proposed approach.

**Amy Brachio**:

Think about Carbon Measures as a coordinating device.

You are absolutely right that there are many different efforts underway. The problem is that, if data are going to underpin a contract and flow across the value chain, you need comparability and verification.

To make that concrete, I recently spoke with a woman responsible for sustainability at an aluminum company. She has to calculate the carbon intensity of the company’s product in different ways depending on the preferences of each buyer.

It is the same aluminum, produced in the same factory through the same process. I’m not saying that any of those approaches are necessarily wrong. But if you don’t have a consistent approach, the data cannot flow effectively across the value chain.

You add aluminum to steel and concrete and try to make sense of the combined data, and you are not going to be able to do it consistently.

We teamed up with the International Chamber of Commerce for several reasons. It has 42 million members around the world and is present in 170 countries. It had already been hearing from its members that this was a problem that needed to be solved. It also has a long history of working through standard-setting processes.

Together, we created a technical expert panel to drive the development of the framework. We have a strong mix of representatives from academia, nonprofits, and business. We have geographic coverage across the world, sectoral coverage, and a broad range of expertise on the topic.

The first step is a landscape analysis, and that work is underway now. One of the big questions is: what are the different existing frameworks and practices that we can draw from and bring together?

I don’t have the answer yet because the expert panel’s work is still underway. But we do not want to recreate anything that is already good, working, and widely adopted.

What we want to do is bring those elements together cohesively and identify the specific breaking points that prevent data from flowing across the value chain in a generally accepted way.

Another important consideration—and we will probably get into the ledger-based approach—is that much of the work done to date has focused on ledgers within individual organizations. We need to ensure that data can flow across organizations and across the value chain in a cohesive manner.

**Alexia Kelly**:

I agree. We are entering one of those periods in which convergence is necessarily the path forward.

The question becomes: what are we converging around, and who is managing that convergence process?

The Integrity Council for the Voluntary Carbon Market is an interesting example of convergence occurring organically across a sector. We had a large number of highly fragmented standard-setting bodies addressing different parts of the market, each with its own regulatory development processes.

We have been working systematically through the question of how to take the next step and think about this from the perspective of a global threshold benchmark. The goal is to have one comparable set of requirements for methodologies covering specific project types.

I hear frequently from financial and institutional investors that having so many versions of methodologies performing the same core function is a real impediment to orderly market development and management over time.

You need a good governance system. This is all complicated by the fact that we don’t have a strong international governance system for these issues. We’re in a messy, organic process of consolidation around who can bring resources to the table and who is able and willing to move the ball forward.

**Amy Brachio**:

That is a really important point.

When we think about how these efforts come together, it is critical to identify the problem you are trying to solve and the theory of change the data are intended to support.

You and I both come from quantitative backgrounds. We know that better data can lead to better decisions, and that is important. But what we are trying to do very specifically is create data that can underpin transactions.

You should be able to put the carbon-intensity information on an invoice. When someone buys the product, the contract should specify that the information represents the carbon intensity of what is being sold. It should also be fit for regulatory compliance.

When regulations of this type are in place, there will be compliance monitoring and likely fines or other consequences for noncompliance. Companies buying the goods will need confidence that the data meet the relevant regulatory standards.

The products we are focused on are globally traded. You cannot have one calculation in one jurisdiction, another calculation somewhere else, and a third calculation in another market and expect the system to make sense.

**Alexia Kelly**:

That is a key barrier we will have to resolve.

I want to come to the question of financial-market alignment and assurability, because that’s a point you and others have been making consistently. There is a lot of confusion around what that actually means and where the current system falls short.

We do have standards for many of these things today. As a former assurer, help us understand the gap. What would need to change to reach the level of financial assurance you’re describing?

**Amy Brachio**:

I don’t want to suggest that no data produced today could meet the standard I’m describing.

There are a couple of things to think about. First is global consistency. There are a number of methodologies in use today that one could argue provide some degree of global consistency, but there is not necessarily a single mandated approach at this level, and companies still have options.

Different companies choose to calculate things differently. Different product categories have their own standards, and those standards are not necessarily aligned.

A lot of what has been developed to date is more like a recipe for a calculation. It can be adapted for multiple product categories, and companies may have some optionality or subjectivity in how they apply it.

I am not saying financial accounting has solved every issue. But when you read the net income reported on one financial statement and compare it with the net income on another, you understand how those figures were calculated.

That is the level of consistency we are trying to achieve.

Right now, the lack of comparability is as significant a challenge as some of the other issues we discuss. That is why it is so important to learn from what is already working, build on it, and ultimately say: this is the approach we are going to take.

The next question I often get is, “Amy, people have been trying to do this for a long time. Why do you think you can succeed where others have struggled?”

I think this is a moment when many people are looking for a more rationalized approach. As I mentioned earlier, a high level of corporate commitment has run directly into a lack of supportive market incentives. We have to look at the system in a different way.

This is especially important for the types of companies operating at the beginning of the value chain. Their planning horizons are extremely long. They are making investments today that will need to deliver returns 10, 20, or 30 years from now.

If we don’t begin changing the incentive dynamic, we will never achieve the pace and scale of change we need.

We are going to continue growing as an organization. Our partnership with the International Chamber of Commerce, given its breadth and history, is vitally important. But that does not mean we won’t collaborate with others.

As we begin developing the framework, I expect we will increasingly say to other organizations, “You’ve done an amazing job here. How do we connect that work to the broader system?”

Ultimately, we want the framework adopted by established standard setters. There should not permanently be a separate “Carbon Measures framework.” We want to develop a framework that others adopt.

**Alexia Kelly**:

As I’ve shared with you in other conversations, I think the environmental and climate expert communities will ultimately judge this work based on what is actually contained in the methodologies.

That is where the rubber meets the road in delivering the environmental outcomes we need.

But I think there is broad recognition that we need greater consolidation and need to move toward financial-market alignment and assurability.

It’s interesting to hear you emphasize comparability. I’ve been doing a lot of work on this in the carbon markets, and watching the issue emerge has been fascinating.

Often, what you find is that a standard may simply need less flexibility around a specific parameter, more detail in another area, or an explicit provision addressing fraud somewhere else.

For some existing standards, it may be more a question of surgical changes that would enable a Big Four auditor to come in and begin performing assurance, hopefully eventually reaching the reasonable-assurance level that is so important from a reporting perspective.

**Amy Brachio**:

I agree, but this is where it is really important to think about the different objectives of different standards.

At a very high level, the Science Based Targets initiative is critically important because companies have made broad sustainability commitments, and a trusted organization needs to assess whether those commitments are grounded in science.

That is one important role.

Broadly speaking, the Greenhouse Gas Protocol has historically helped organizations understand the enterprise-level risks and impacts associated with greenhouse gas emissions. That purpose is reflected in much of the work that led to its creation.

When you look at frameworks like the Corporate Sustainability Reporting Directive or the International Sustainability Standards Board, the objective is to provide investors with the information they need to assess risk.

Much of the disclosure architecture developed to date has focused on risk assessment. For that purpose, you need information that points you in the right direction. The more accurate it is, the fewer red herrings you chase, but directionally correct information can still be useful.

To underpin a contract, however, the information has to be much more specific because there is a compliance element.

My request of the environmental community—and I consider myself part of that community—is to recognize that we will not succeed unless we have both the regulations that drive emissions reductions and the accounting needed to support them.

For us, the accounting is a tool that enables the regulation. It is the combination of the two that drives emissions reductions.

This is an “and,” not an “or.” It does not mean the other systems and approaches are unimportant or should not continue. But I think we can help unlock the power of the market in a way that has not been unlocked before.

**Alexia Kelly**:

I agree that there is a risk-assessment benefit. I would also argue that many of the standards and methodologies developed in the greenhouse gas accounting space over the last 25 years are intended to measure the emissions impact of an organization’s activities.

They attempt to estimate those impacts as accurately as possible, while recognizing that in many cases primary data are not available.

**Amy Brachio**:

I completely agree. But those systems are not generally underpinning a contract associated with the sale of a physical good.

**Alexia Kelly**:

Unless you are active in the carbon markets—but that’s a different conversation.

**Amy Brachio**:

Absolutely. And that is where all of this becomes so interesting.

If you think back to some of the earlier challenges in the carbon markets, they involved many of the same issues we are talking about now: comparability, validity of data, and the ability to assure information.

We are trying to reach that same level of comparability for the commodities and products at the beginning of the value chain.

**Alexia Kelly**:

I do want to talk about the beginning of the value chain, because Carbon Measures includes a number of heavy emitters.

There has been significant consternation about the prominent role ExxonMobil has played in helping get the organization established.

For the record, I would be delighted to see Exxon’s formidable lobbying power directed toward securing comprehensive regulation around product-level carbon-intensity standards—or any other meaningful emissions regulation and management requirements we can achieve.

That would be an enormous win for all of us. I have been on the receiving end of the company’s lobbying prowess on more than one regulatory occasion over the course of my career. It would be great if we could align around something we could all support.

But let me ask the difficult question, and the one I hear frequently: isn’t this ultimately about allowing heavy emitters to avoid responsibility for their Scope 3 emissions?

To some people, this sounds like a red herring: we will spend another decade developing new measurement systems, then perhaps begin discussing regulation, because everything developed previously is supposedly not good enough—or because the companies involved want an approach that is the opposite of what has been done to date.

How do you respond to that concern?

**Amy Brachio**:

I’ll answer in two parts.

When I was deciding what to do next, I had several different opportunities. I thought long and hard about which role to take.

I have three adult daughters, and I treated this as a family decision. I told them, “If I do this, there may be articles about Mom that you don’t like. I want to make sure we are all comfortable with that.”

My youngest daughter said it perfectly. She said, “If these are the companies that want to get involved and drive the emissions reductions we all need, why wouldn’t you work with them?”

That was the final step in our family’s decision.

On a more substantive level, I ask everyone to judge us based on our actions.

When we think about regulation, we are not looking at it solely on a product-by-product basis. We have partnered with Resources for the Future, a well-respected think tank in this area.

Part of what we believe has held back progress is that climate-policy modeling does not always sufficiently integrate market competitiveness, economic growth, and climate outcomes.

We are looking at where in the value chain emissions standards should be applied to maximize both economic and emissions-reduction outcomes.

Take marine transport as an example. You could regulate the carbon intensity of marine fuel, or you could regulate the carbon intensity of marine transport. Those approaches can produce very different results.

If you set a standard based on the carbon intensity per ton-mile shipped, or whatever the right metric may be, that can drive innovation both in vessels and in fuel sources.

One thing we are unapologetic about is that we are focused on reducing emissions. We are not going to decide that one pathway to reducing emissions is inherently better than another, as long as the outcome is science-based, verifiable, and results in real reductions.

One company might use diesel paired with carbon capture. Another might use ammonia and a sail on the vessel. If both produce the same emissions intensity per nautical mile or per ton shipped, then from the perspective of the standard they have achieved the same result.

I understand the questions we are being asked. It is our responsibility to demonstrate that we are as committed to advancing policy as we are to developing the accounting framework—and to demonstrate that with pace.

**Alexia Kelly**:

Talk a little about what that plan looks like and how it is evolving.

**Amy Brachio**:

I like to remind people that we are just over six months old.

I receive many questions about detailed elements of our work, but when you are building trust, it is important to do the work carefully.

I mentioned the landscape analysis. We are conducting technical deep dives into the accounting systems already in use. It is equally important to do rigorous work on the policy side, which is where our partnership with Resources for the Future comes in.

We are exploring whether there are jurisdictions where we can test some of these concepts. We have global member companies, and part of what our members are willing to do is pilot the work.

That could mean working with policymakers to test an approach for a particular product in a particular market, in partnership with our members, so we can demonstrate how the policy would work in practice.

We will have more to say about that approach, but it is a little premature right now.

**Alexia Kelly**:

I’ll come back to you in a few months.

**Amy Brachio**:

I would love to do this again.

**Alexia Kelly**:

I do think that regulatory advocacy and implementation are incredibly important.

**Amy Brachio**:

And I do want to remind you that we don’t have only one member. We have 26.

What has been amazing is the commitment of our members across the board. We have established a number of advisory groups in which our members come together and help us improve and advance the work across multiple markets.

**Alexia Kelly**:

I do want to come back to the issues of efficiency, upstream intervention, and impact, because I know those ideas have been important in the conversations I’ve been having about this work.

The green premium and the cost differential are also critical.

When I was working to decarbonize my company’s Scope 3 emissions and develop that strategy, I was looking at a long tail of small, highly distributed, almost entirely estimated emissions sources in a supply chain that changed constantly and over which I had very little control.

There are real challenges associated with pushing all of the decarbonization responsibility through that kind of system.

I spent a great deal of time thinking that it would be far more efficient if we could go upstream and focus on the big technological and implementation opportunities that could systematically reduce emissions across an entire sector.

I am very aligned with that approach, and I think it merits more serious consideration in our broader theory-of-change conversations.

That is especially true as we move into the next phase of strategic work and consider what global decarbonization policy should look like in a geopolitical landscape that is more complicated than it has ever been in my professional lifetime.

**Amy Brachio**:

That is exactly what we are trying to do.

I think about my previous role at EY. We were very committed to reducing our own carbon emissions, and we did a great job. I am proud to have been even a small part of it.

But at the end of the day, EY is a professional-services firm. The primary levers are ensuring that offices are powered by renewable energy and reducing business travel.

Until aviation fuel and air transport are addressed, there is only so much more a company like that can do.

If we can put the big building blocks—transport, the built environment, chemicals, and other foundational sectors—on a strong decarbonization trajectory, then every company can focus on the areas where it is uniquely positioned to reduce emissions.

It is important to address another concern. Some people say, “What you are doing pushes responsibility for emissions further down the value chain.”

We are looking at responsibility differently. We are saying: regulate the emissions.

If you regulate the carbon intensity, you change the demand signal for everything that comes before it. Companies can then charge a green premium or monetize over-performance.

I’m not saying nobody monetizes emissions over-performance today. But at the scale required, we are not sufficiently rewarding companies for reducing emissions.

**Alexia Kelly**:

I’ve been having many conversations about this.

A lot of attention over the last several years has focused on the voluntary carbon market and voluntary corporate action. That is partly because we have been largely unsuccessful in establishing global carbon pricing, particularly in major markets such as the United States.

Even Canada, which has carbon pricing, implements it unevenly.

We are nowhere near where we hoped we would be by now in terms of having a globally coherent carbon price sending the signal needed to drive deep decarbonization and economic transformation.

So I am entirely in favor of figuring out how we can align around regulation.

I have had people come up to me and say, “We never really thought voluntary action was the right answer.”

And my response is: “No kidding. None of us did.”

This was not Plan A. It was not even Plan B. We are somewhere around Plan D at this point.

I would welcome a well-structured conversation with heavy emitters and the fossil-fuel industry about regulation. Many of those companies are struggling to justify enormous capital investments in retooling supply chains when the economic environment does not reward them.

It is very difficult for them to recover those investments under the current economic system.

**Amy Brachio**:

You have precisely described the problem we are trying to solve.

The common thread among the organizations that have joined Carbon Measures is that they understand the role corporations play in reducing emissions.

They have invested heavily in low-carbon products and solutions, and they have not received the return necessary to justify continued investment.

These are public companies accountable to their shareholders. We have to change that dynamic, or we are not going to see the necessary transformation.

That does not mean it is one approach or the other. The voluntary commitments companies have made are impressive. Companies have done a great deal of work, and we have seen meaningful results.

But this is a systemic problem.

We have focused significant attention on innovating the products required to reduce carbon emissions. We have not sufficiently innovated the system that would allow those products to thrive.

That is where Carbon Measures is focused.

**Alexia Kelly**:

I think it is incredibly important to maintain a focus on Scope 3 decarbonization.

I have heard many companies say they never would have made some of their expensive upstream investments had it not been for their Scope 3 targets and responsibilities.

Keeping companies accountable for Scope 3 emissions remains very important.

I know that is something we have discussed in relation to the structure of the e-ledger concept and its focus on Scope 1 emissions.

How are you thinking about resolving that tension, and how do you see these systems fitting together?

**Amy Brachio**:

I’m glad we are discussing it, because I need to do a better job articulating our point of view.

We are not necessarily thinking in terms of scopes within our theory of change. That does not mean we are advocating that companies stop thinking in scopes. This is going to require multiple tools.

If you look at the parallel with financial statements, one statement does not answer every question. There is a balance sheet, an income statement, and a cash-flow statement.

They are interoperable. You can do the math between them to develop the complete picture you need.

We are focused on the emissions that went into producing a product.

If we were proposing accounting alone, I would understand the concern that companies could simply stop at the factory gate. If you use a cradle-to-gate approach, particularly for oil and gas products, the obvious question is: who is responsible when the downstream emissions actually occur?

But the pressure we are placing into the system comes through the product-intensity standard.

That is how responsibility is imposed. The demand signal changes because lower-carbon products help the company subject to the standard comply with its obligations.

**Alexia Kelly**:

So the argument is that it matters less where the final emission occurs or on whose books it appears, because the emissions-intensity standard has already addressed it through the product requirements.

**Amy Brachio**:

Right.

As the intensity curve continues to decline, you will not be able to sell a highly emitting product unless someone has figured out how to address those emissions—through carbon capture, a different production process, a different fuel source, or another solution.

The product will become less valuable if it does not meet the required standard.

Another way to think about what we are doing is that we are trying to help companies remain profitable while changing their product portfolios over time to reduce emissions.

**Alexia Kelly**:

The product framing may be part of where some people are getting confused.

You are really focusing upstream on foundational inputs.

What you are proposing resembles a cap-and-trade-style regulation in some respects, although it may be organized less formally and built around product-level emissions-intensity standards rather than an absolute cap and allowance-allocation system.

Those systems are often administered upstream because that is the most practical point of regulation. In many cap-and-trade systems, for example, compliance obligations apply to facilities emitting more than 25,000 tons per year.

An intensity standard could similarly be applied at the product level while having knock-on effects across the major emissions sources.

The central questions then become: where is the intensity level set? How quickly does it decline? How is it calculated? And how is it enforced?

Those are significant challenges.

**Amy Brachio**:

Absolutely. What we are taking on is not easy.

We have to develop an intensity curve that considers competitiveness, the commodities and natural resources available in a country, national circumstances, and the country’s commitments under the Paris Agreement.

What we are doing will not get anyone to net zero on its own. More policies and additional work will be required.

But if we can address these heavy-emitting products at the right point in the value chain, it can do a great deal to change the emissions trajectory.

One important distinction is that we believe the accounting framework needs to be global in nature. If it is going to support global trade and compliance across multiple regulatory frameworks, it has to be consistent and comparable.

The intensity standards themselves, however, should be established by lawmakers at the national level.

Every country has a different economic mix, different national resources, and different community needs. You will likely see different intensity curves and different policy approaches depending on the circumstances of each country.

But taken as a whole, this could become a meaningful tool for reducing emissions—one that does not exist today at a consistent level.

**Alexia Kelly**:

Absolutely. This time has flown by.

I really appreciate the conversation and your candor. What should we expect next from Carbon Measures, and how can people get engaged?

**Amy Brachio**:

We have launched the organization, grown the membership, and hired the team. Now the substantive work is beginning.

People should keep an eye on the work products we release.

The first will include the landscape analysis emerging from the technical expert panel. We will also publish the principles that we believe should guide a framework capable of supporting transactions and regulation.

There will be a draft framework of the accounting policies, followed by a roadmap for adoption.

We will be transparent throughout the process, and we will seek input from people beyond those serving on the expert panel.

We will also release work related to the techno-economic modeling that we believe is needed to underpin the policy side.

I’m sure there will be more beyond that. But I would love to come back, and I want you to hold me accountable. We’ve said we are going to move quickly and avoid getting in the way. You should ask us whether we have done that.

**Alexia Kelly**:

You have certainly been moving quickly. I’ve been watching closely and have been impressed by how rapidly you have built the team and started putting the pieces in place.

I am hopeful that we can work to align these efforts and begin bringing the various rulemaking processes together, so that we are speaking with each other rather than past each other.

In pursuit of our shared objective of reducing emissions, we need to be as aligned as possible. The fragmentation and infighting are hurting us badly, and we do not have time.

**Amy Brachio**:

We don’t have time, and I agree entirely.

There is tremendous complexity here, and the answer is an “and.”

We need well-functioning carbon markets. We need reductions in the emissions associated with the products required to provide energy and materials to the world. We need to ensure that companies can remain profitable through the transition.

As long as each of us is clear about the problem we are trying to solve, the area in which we are going to move quickly, and the points of intersection where we need to coordinate, I think we can move forward faster.

There should not be infighting.

I recognize that Carbon Measures has to demonstrate that we are authentically and fully committed to this work. I understand that.

But infighting does not help anyone. There are many external forces we are trying to navigate, and we need to remain focused on the bigger picture.

From Carbon Measures’ perspective, our goal is to be wildly collaborative and to do our part to drive progress forward.

**Alexia Kelly**:

That is my mantra as well.

Last question: what is getting you up in the morning and keeping you excited about the work?

**Amy Brachio**:

I feel as though I have been given the gift of being able to apply the skills and capabilities I developed over a 30-year career and focus them entirely on driving global impact.

What gets me up every day is asking how I can use that privilege to help create meaningful change.

So far, that has been more than enough motivation. As you know, I’ve been traveling all over the world and working quite a bit.

**Alexia Kelly**:

Thank you so much for joining me today. I appreciate the excellent discussion, and I look forward to following up in a few months.

**Amy Brachio**:

That sounds good. We’ll be in touch.

**Alexia Kelly**:

Thanks so much, Amy.

**Amy Brachio**:

Thank you.