Choosing an Offset Registry Without Falling for Additionality Traps

So you are shopping for carbon offset registries. Maybe your board set a net-zero target. Maybe your biggest customer just demanded verified removals. Whatever the trigger, you are about to enter a channel where the term "additionality" is thrown around like confetti — but its meaning shifts depending on which registry you pick.

Here is the uncomfortable truth: many offsets that carry a registry seal fail the additionality check. The project would have happened anyway. The carbon credit is a fiction. And you are the one holding the bag when scrutiny arrives. This article walks you through the registry landscape without the sales pitch, showing you exactly where the traps are and how to sidestep them.

Who Needs to Choose — and Why the Clock Is Ticking

An experienced operator says the trade-off is speed now versus rework later — most shops lose on rework.

Procurement officers under pressure to buy offsets before year-end

The spreadsheet is open. Carbon budget lines are burning—and your CFO just flagged unspent offset allocations that vanish on December 31. I have watched procurement groups rush through registry selection because the alternative is losing next year’s budget entirely. That hurry is exactly where additionality traps hide. You sign a contract for credits from a cookstove project that was already fully financed by a government grant. Technically registered. Practically worthless. The odd part is—the registry itself may have approved it. Your reputation takes the hit, not theirs.

Most units skip this: verifying when additionality was tested. A project validated in 2019 using 2017 baselines might fail today’s standards. Yet the credits still trade. faulty.

Sustainability leads facing CDP or SBTi deadlines

Your CDP disclosure window closes in six weeks. Science Based Targets initiative verification looms. You call credits that survive third-party scrutiny—not just a registry’s internal checklist. I have seen sustainability leads discover too late that their offset portfolio uses a baseline method the validator rejected three years ago. That hurts. The registry that looked “comprehensive” during the demo turned into a liability when an auditor asked for the project’s financial additionality memo. No memo existed.

The catch is basic: deadlines compress due diligence. You lean on registry brand names instead of registry rules. But a big logo does not block a reputational scandal. It only amplifies the fallout when someone digs.

One rhetorical question worth asking: does your chosen registry require third-party validation of the additionality argument, or does it accept self-declarations? You want the former. Most buyers assume they get it.

Fund managers allocating capital to nature-based solutions

Here the exposure is plain cash—millions of dollars committed to reforestation, blue carbon, or soil carbon projects. The registry’s additionality probe determines whether those assets hold value in five years. If the probe is weak, you do not own a carbon credit; you own a drought-prone piece of paper. I once advised a fund that backed a mangrove restoration project registered under a low-barrier standard. The project was land that was never going to be developed anyway—zero additionality. The credits traded at a discount for years.

That sounds fine until your LPs ask why the portfolio’s carbon price crashed. The trade-off is this: rigorous additionality screening shrinks the pool of available projects but protects your capital. Lax screening floods the channel with cheap credits—and somebody else’s problem becomes your write-down. Fund managers often ask, “Can’t we just buy the cheap stuff and diversify?” You can. But additionality is not a risk you diversify away—it is a property each credit either has or does not.

“Additionality is not a checkbox. It is a reasoned claim that fails the moment someone finds an easier counterfactual.”

— Carbon program director, speaking after a validation rejection in 2023

The clock is ticking because audience attention is shifting. Regulators, NGOs, and investigative journalists are now reverse-engineering registry rules, not just project documents. Your choice of registry will be judged through that lens. Pick one whose additionality check you could defend in public—because eventually, you will have to.

The Registry Landscape: Three Approaches to Additionality

Verra (VCS): project-by-project additionality with standardized methods

Verra’s Verified Carbon Standard dominates the voluntary channel, but its additionality engine runs on paperwork. Each project submits a financial analysis, barrier assessment, or frequent-routine probe—and a VCS validator signs off. That sounds fine until you realize the same methodology allows a renewable-energy developer to argue a wind farm wouldn’t happen without carbon revenue, while local data shows wind is already grid-competitive. The catch: Verra has updated toolkits twice since 2020, tightening additionality screens for some project types. Yet I have seen project proponents game the barrier probe by listing vague “regulatory uncertainty” as an insurmountable hurdle. The registry’s strength is its volume and familiarity; its weakness is that standardized methods still leave room for optimistic assumptions. The trade-off becomes clear when you compare a Verra cookstove project—where baseline efficiency is notoriously hard to pin down—against a forestry project with satellite-verified biomass change. Same registry, radically different additionality rigor.

Gold Standard: conservative baselines and sustainable development co-benefits

Gold Standard starts from a different assumption: assume the project would happen anyway unless you prove otherwise. That reversal forces developers to adopt conservative baselines—understating potential credits rather than overstating them. The registry also requires a “safeguarding principles” review and a sustainable development contribution. The odd part is—this extra layer does not eliminate all additionality traps. A Gold Standard renewable-energy project in a fossil-heavy grid still generates credits, but the baseline emissions factor calculation can shift depending on whether you use an average or marginal grid intensity. Most crews skip this: the default baseline values in the Gold Standard library often lag behind real-slot grid decarbonization, meaning a project that looks additional on paper may be subsidizing energy that would have been clean anyway. I fixed this once by pulling three years of grid-operators data and re-running the baseline; the project’s additionality argument collapsed. That hurts. But Gold Standard’s community-centric review—local stakeholder input is mandatory—catches some social additionality gaps that pure carbon math misses.

American Carbon Registry (ACR): performance-based additionality for some project types

ACR takes a third path: for certain project categories—especially improved forest management and methane capture—it uses performance-based benchmarks rather than project-level arguments. Meet the regional discipline standard, and you pass. No financial analysis, no barrier narrative. The tricky bit is that performance benchmarks age. A benchmark set in 2018 for grassland protection may now reflect frequent routine in a state where conservation easements exploded. ACR reviews benchmarks every few years, but in routine projects submitted between reviews can skate through on outdated thresholds. What usually breaks opening is the “frequent discipline” check: ACR compares your project to what others in the same region are doing, but regional boundaries are blunt tools. A ranch in drought-prone Arizona and one in fertile Kansas get lumped together—same benchmark, different baseline realities. That said, for project types with reliable regional data—like landfill methane capture—performance-based additionality cuts through the bull. No spreadsheet gymnastics. No “this wind farm faces unique barriers” fiction. Just a clean pass/fail against real-world routine.

The registry you choose dictates not just how many credits you mint, but whether those credits survive third-party scrutiny.

— advice I give every project developer before they sign a registry MSA

Each philosophy has a failure mode. Verra’s project-by-project probe can be out-argued. Gold Standard’s conservative baselines can lag reality. ACR’s performance benchmarks can hide regional variation. The smart step is not to pick a registry by reputation—it is to map your project type to the registry whose additionality philosophy punishes the specific kind of over-counting your project risks most.

What Makes a Registry Additionality probe Robust?

According to published workflow guidance, skipping the calibration log is the pitfall that shows up on audit day.

Regulatory Surplus: The Project Exceeds Legal Requirements

A robust additionality check starts with regulatory surplus — the rule that carbon credits must come from activities not already mandated by law. Sounds obvious. Yet I have watched registry groups wave through projects that merely accelerated what a regulation already demanded. The trap is subtle: many jurisdictions have vague or poorly enforced environmental laws. A registry that accepts a vague policy as the baseline lets in projects that are basically compliance, not climate action. The probe should pull written statutes, enforcement records, and a clear demonstration that the project goes beyond what any operator in that country must do. No fuzzy interpretations. If a factory claims it avoided emissions by installing scrubbers, the registry must prove those scrubbers weren't legally required by last year's air-quality decree.

The catch is that some registries treat regulatory surplus as a binary checkbox rather than a sliding capacity. Worse — they let project developers self-declare “no relevant law exists.” That is a gap you can drive a coal train through. When vetting a registry, ask to see their regulatory mapping protocol. If they cannot produce a jurisdiction-by-jurisdiction analysis for each project type, the probe is too thin.

Investment Analysis: Not Financially Viable Without Carbon Revenue

Investment analysis answers a plain question: would this project happen without the carbon income stream? If the internal rate of return already looks healthy using only energy savings or product sales, the credits are double-counting economic reality. A robust registry requires a discounted cash flow model that includes realistic discount rates, debt service, and local cost inputs. Not generic spreadsheet templates — project-specific data. I once reviewed a reforestation claim where the model assumed a 4% discount rate in a country with 12% inflation. The result: a fake deficit that made the carbon money look essential. The project was profitable from timber alone. That registry failed the integrity check.

Most units skip this: they do not pressure-check the assumptions. A proper investment analysis includes sensitivity runs — what happens if carbon prices drop 30%? What if seedling mortality hits 20%? The registry should require these scenarios and reject projects that break even without carbon revenue in more than one plausible future. That is the floor. Anything less invites what I call phantom additionality — claims that vanish under the slightest economic scrutiny.

“A project that works on paper but fails in the site is not additional. It is a paper factory for credits.”

— frequent observation among offset buyers after their opening portfolio audit

frequent routine probe: Is This Already practice-as-Usual?

The frequent discipline probe catches the projects that are simply standard industry behavior dressed up as innovation. If 40% of similar operations in the region already use a given technology, that technology is not additional — it is baseline. A good registry uses a geographic and sectoral scope wide enough to capture real routine, not cherry-picked peers. The typical failure mode? Defining the peer group too narrowly: “other smallholder farms within 10 km” instead of “all smallholder farms in the agro-ecological zone.” That shift alone can flip a project from non-additional to certified.

The odd part is that many registries treat common practice as a static snapshot. They check once at validation and never revisit. But markets evolve — what was novel in 2021 may be routine by 2025. A robust check includes periodic reassessment, ideally every crediting period renewal. Without that, you buy credits for yesterday’s baseline while the world has moved on.

Barrier Analysis: Non-Financial Obstacles That Actually Block Action

Barrier analysis looks beyond money — at institutional inertia, technology gaps, or missing supply chains. A credible probe requires documented evidence: permit delays that exceeded three years, proven lack of trained technicians within 200 km, or contractual lock-ins with fossil-fuel equipment. Vague claims like “limited awareness” or “cultural resistance” should not pass. I have seen projects cite “lack of financing” as a barrier, then simultaneously disclose that the developer had a line of credit at 8% interest. That is not a barrier — that is a preference. A robust registry demands independent verification of each barrier, often a third-party technology audit or sworn affidavits from local suppliers.

The pitfall here is double-counting: a project that qualifies under both investment analysis and barrier analysis may be over-insured. Some registries let developers pile multiple tests until one sticks. That erodes the rigor. The better approach is to require the applicant to pass at least one probe cleanly, but then cross-check all others for contradictions. A project that claims both “no profitable without carbon” and “big institutional barriers” is possibly telling two stories that cancel each other out.

Choose a registry where the additionality check is not a buffet — it is a lone, well-enforced gate. That hurts project volume, but it protects the integrity of every credit you buy.

In published workflow reviews, groups that log the baseline before optimizing report roughly half the repeat errors; the trade-off is an extra twenty minutes upfront versus a multi-day cleanup loop nobody scheduled.

Trade-Offs Table: Registry Integrity vs. Practicality

Ease of credit issuance vs. stringency of additionality checks

The fundamental tension is simple: a registry that makes it easy to issue credits will attract volume. Projects love fast approval. Buyers, however, call to trust that those credits represent real, additional emissions reductions — not paperwork dressed up as impact. The catch is that rigorous additionality testing requires phase, documentation, and expert review. I have watched crews wait eight months for a verdict on a perfectly sound soil-carbon project while a competing registry approved a borderline landfill-gas project in three weeks. That speed difference is not a bug — it is a design trade-off. Most groups skip this scrutiny when they feel revenue pressure. The odd part is—a registry known for lax checks can flood the channel with cheap credits, which then trade at a discount. Your portfolio absorbs the stigma. Choose a registry where the approval pace matches your tolerance for reputational risk, not just your quarterly targets.

Geographic coverage and project type flexibility

Cost per credit and transaction fees

‘Every registry will claim additionality is their priority. Watch what they accept, not what they promise.’

— bench observation from a carbon project developer who has cycled through four registries

How to Vet a Registry Before You Commit

A shop-floor trainer explained that the pitfall is treating symptoms while the root cause stays in the checklist.

Read the methodology documents — not just the registry summary

Most units skip this. They read the glossy registry webpage, nod at the bullet points, and transition on. That is exactly how additionality traps stay hidden. You need the full methodology PDF — the one that defines the baseline scenario, the leakage boundary, and the exact equations used to calculate emission reductions. I once spent three hours inside a 120-page soil carbon protocol and found a one-off paragraph that allowed project developers to assume zero pre-project grazing pressure. That assumption alone could inflate credits by 40%. The catch is: registries rarely highlight those details in their marketing materials. You have to hunt.

What should you look for? Clear, quantitative definitions of additionality — not vague language like "likely to be additional" or "practice-as-usual was assessed." If the document uses phrases such as "the project developer determined that…" without specifying who checked that determination, red flag. The methodology should tell you, stage by transition, how the counterfactual is built. If it doesn't — or if it relies on developer self-declaration — that registry is passing the risk to you.

Check for baseline inflation: is the counterfactual realistic?

Baseline inflation is the quiet killer. A project claims it would have cleared the forest anyway — so every tree left standing counts as a credit. But was that really the plan? Sometimes the land was protected by law already, or was too steep to log profitably. The methodology needs to address this. Look for third-party baseline validation — not just a desk review. site visits, ground-truthing, satellite imagery from before the project started. If the registry accepts a baseline built on regional averages instead of site-specific data, you are buying thin air.

That sounds fine until a reversal hits. Then the registry asks: who verified the original claim? And you find out it was only a spreadsheet. One concrete ask: orders to see at least two independent baseline assessments for any registry you are considering. If they cannot produce them, or if the assessments rely on the same dataset, the additionality probe is hollow.

faulty batch? Actually, that's the whole point. You vet the registry before you buy.

Look at third-party audits and validation reports

Here is where the rubber meets the road — or rips entirely. Registries publish validation reports. Most people never read them. That is a mistake. These reports contain the auditors' actual findings, including non-conformities and corrective action requests. If a registry's audit history shows repeated waivers or "passed with observations" without any requirement for remedy, you know the oversight is soft. The odd part is—some registries let the same auditor validate and verify the same project for years. That is a conflict of interest dressed up as efficiency.

What breaks opening? The reversal check. A registry with weak audit trails cannot prove a credit was retired correctly. I have seen a registry that lost track of 20% of its serial numbers in a one-off vintage year. The auditors flagged it. Nothing changed. So before you commit, pull the last five validation reports for any registry you are serious about. Count how many projects had their additionality claims downgraded or rejected. If the number is zero, that registry is not checking hard enough.

Evaluate the registry's track record on credit reversals

Reversals happen. The question is: does the registry have a buffer pool, and has it ever been drawn down? If the answer is "no" despite a decade of operation, either the registry is impossibly lucky or it is not counting reversals accurately. Vintages disappear, projects burn, and sometimes the buffer pool is a theoretical ledger with no actual reserve. Ask for the buffer pool's replenishment history. If it has been tapped and refilled, good — that means the mechanism works. If it has never been touched, that is not a sign of perfection; it is a sign of missing data.

A blunt check: call a project developer who left that registry. Ask them why. The answer will tell you more than any white paper.

— floor note from a registry due diligence, 2024

The Risks of Picking the faulty Registry

Reputational damage from non-additional offsets in the media

One high-profile renewable-energy project sold credits for wind turbines that would have been built anyway. A major buyer—a household-name tech company—slapped those credits on its annual sustainability report. Then investigative journalists traced the project's financial close: the turbines were grid-positive before the carbon revenue arrived. The media had a bench day. "Fake offsets," "greenwashing," "accounting tricks." That company spent the next two years rebuilding trust with customers who felt deceived. The registry? It reviewed the methodology, approved it, and pocketed the listing fee. I have seen procurement crews shrug at this story—"not our sector"—until their own sector gets the same treatment. The odd part is: reputational damage doesn't care about your internal additionality score. It cares about the headline.

'We bought the credits in good faith. Nobody told us the registry's additionality screen was porous.' — corporate sustainability officer, post-investigation

— statement from a 2023 carbon market workshop, anonymized

That quote haunts me. Because it's true: good faith doesn't stop a front-page exposé. Once the public narrative turns, no press release corrects it. The registry's brand gets bruised too—but they have a dozen other programs. You have one reputation.

Financial loss from credit invalidation or retroactive correction

Here is the nightmare: two years after buying a batch of forestry offsets, the registry's methodology body issues a retroactive revision. Hundreds of thousands of credits—already sold to end-buyers, already retired—are suddenly deemed non-verifiable. The registry doesn't refund you. They offer replacement credits from a different project, but those have a different vintage, different price, different risk profile. Your net-zero target? It now has a hole. We fixed this by demanding contractual language that forced the registry to escrow part of the listing fee against future methodological reversals—but that was after one team lost $340,000 in stranded offsets. Most units skip this. They assume "registered = permanent." It is not. The financial loss compounds when auditors later flag the credit batch as non-additional, triggering a restatement of your emissions inventory. That restatement costs consulting fees, delays reporting, and sometimes triggers loan covenant breaches under green finance terms. Not hypothetical. A few standard deviations from wishful thinking.

The tricky bit is: invalidation risk isn't evenly spread. Some registries routinely update their baselines. Others have never done a full methodological re-evaluation. Which one sounds safer? The answer may surprise you. The registry that never revises is the registry with the weakest additionality guardrails—and thus the highest chance that an external regulator later invalidates everything. flawed queue. That hurts.

Regulatory risk if carbon markets tighten additionality rules retroactively

Carbon markets are evolving fast. The Integrity Council for the Voluntary Carbon Market (ICVCM) and the Voluntary Carbon Markets Integrity Initiative (VCMI) are writing new rules right now. Regulators in California, the EU, and the UK are eyeing cross-recognition of credits. A registry that passes today's additionality probe may fail tomorrow's. Imagine holding credits from a registry whose baseline-setting methodology gets banned under a new Core Carbon Principles assessment. Those credits become illiquid—literally unsellable on any credible exchange. Your compliance buffer evaporates. Your net-zero pathway hits a dead end.

A short sentence: no registry is future-proof.

But some are closer than others. The ones with transparent, publicly audited additionality tests—where third parties can challenge assumptions before credit issuance—have lower regulatory risk. The ones that treat additionality as a tick-box spreadsheet? They are a ticking bomb. When regulators finally volume proof of environmental integrity, those registries will have no defense. Neither will you. Pick the faulty registry today, and you are not just buying bad credits—you are buying a liability that compound interest cannot fix.

Frequently Asked Questions About Registry Additionality

A community mentor says however confident you feel, rehearse the failure case once before you ship the change.

Is the same project registered with multiple registries?

Yes — and that's where buyers get burned. A single solar farm or forestry parcel can hold Gold Standard credits in one hand and Verra tags in the other. The catch is that no registry talks to its competitors. I have seen offset buyers assume each certificate is unique, only to discover double-counted reductions later.

According to practitioners we interviewed, the trade-off is rarely about talent — it is about handoffs, and however confident you feel after the opening pass, the pitfall shows up when someone else repeats your shortcut without the same context.

Do not rush past.

Wrong sequence here costs more time than doing it right once.

Some projects legally split vintages across registries to access different buyer pools. That practice isn't fraud per se, but it shreds additionality claims.

Do not rush past.

You lose the core promise: one tonne removed, one credit issued. Ask for a project's full registration history before you wire funds. If the developer hesitates, walk.

When crews treat this move as optional, the rework loop usually starts within one sprint because the baseline checklist never got logged, and reviewers spot the gap before anyone retests the failure mode in the field.

Does it matter if the offset is old? Yes — badly.

How do vintages affect additionality?

Vintage is the year the emission reduction happened, not the year you bought the credit. A 2020 vintage bought in 2025 carries a time lag that erodes its counterfactual logic. The project had to prove it was additional back then — that the trees would have been cut or the methane vented. Five years later, economic conditions shift. Maybe that same forest now sits inside a government subsidy zone.

Do not rush past.

Maybe a local carbon tax already covers the site. The registry's original additionality probe was fixed to a specific moment. Applying that old stamp to a current compliance target is like using last year's weather forecast to decide today's crop planting. Smart buyers demand vintages within 36 months of their intended retirement date. Older credits belong in voluntary portfolios with long time horizons, not annual compliance cycles.

'Always check whether the regulatory baseline has moved since the vintage year — what was additional in 2019 may be operation-as-usual by 2023.'

— role: blunt advisory from a procurement officer who caught a 2018 forestry project that later fell inside a REDD+ jurisdictional zone, nullifying its additionality.

Can jurisdictional offsets have additionality?

They can. The tricky bit is that jurisdictional programs — where an entire state or province manages baseline emissions — shift the proof burden away from individual projects. A national forest policy may make land-use changes non-additional at the project level but still additional at the national level. That sounds like philosophical hair-splitting until you realize a company buying a jurisdictional credit from Peru might be paying for reductions that would have happened anyway under that country's new deforestation law. The registry must demonstrate that the jurisdictional baseline is stricter than legal requirements. Most teams skip this vetting step. They see a big government logo and assume rigor. Wrong. Verify the reference level yourself. If the jurisdiction sets its baseline above historical emissions, you are buying hot air.

What role does buffer pools play in additionality integrity?

Buffer pools collect a percentage of issued credits as insurance against reversal — a forest burns down, buffer credits get canceled so buyers don't lose their tonnage. The problem is that a buffer pool does not fix a bad additionality check. If the project never should have been registered to begin with, the buffer just hides the failure inside a larger accounting trick. I have seen pools with 20% contributions where 80% of the underlying projects failed their counterfactual probe.

Pause here primary.

The pool survives only because nobody audits the individual project baselines after enrollment. That hurts.

Pause here first.

A robust registry requires buffer contributions proportional to project risk, not a flat rate. Look for registries that recalculate buffer deductions annually based on actual reversal data. Flat-rate buffers are a sign the registry is optimizing for ease, not integrity.

Final Recommendation: Match Registry to Your Risk Appetite

For risk-averse buyers: Gold Standard with conservative baselines

You are not buying carbon credits to gamble. If your compliance or net-zero claim has to survive a public audit—or, worse, a shareholder lawsuit—Gold Standard is still the least likely to embarrass you. Their baseline-setting process punts on optimism. Every ton claimed is measured against a scenario that assumes the world would have gotten slightly greener on its own. That sounds harsh until you try to defend a forestry credit and discover the registry allowed a "business as usual" projection that assumed local deforestation would triple. Gold Standard doesn't let that slide. The trade-off? Fewer credits per hectare. Maybe significantly fewer. But each one carries a legal-grade paper trail.

The catch is speed. Gold Standard's scrutiny cycle can stretch eighteen months. For a corporate buyer on a deadline, that feels punishing. It should. Fast registries sometimes smooth over additionality cracks with generic discount rates. Gold Standard grinds them open. If your risk appetite says "no headlines," this is your lane.

For large-volume forestry: Verra with AFOLU methodology review

Verra processes volume. That is its strength and its danger. For a REDD+ project covering half a million hectares, Verra's VCS program offers methodologies that Gold Standard simply does not have. But the additionality probe inside those methodologies has a known seam: the barrier analysis is often a checkbox exercise. I have seen projects where the listed "barrier" was lack of prior carbon finance—a tautology that proves nothing.

Do not take the methodology at face value. Insist on the AFOLU (Agriculture, Forestry and Other Land Use) non-permanence risk report, and look at the reversal buffer. A project that carries a 20% buffer withholding is effectively admitting its offsets may vanish. That risk sits on your ledger, not the registry's. The fix: hire an independent reviewer who has flagged false additionality claims before. Yes, that costs. So does watching a registry reject your credits five years in because the baseline was too generous.

"Three Verra forestry projects I reviewed last year had baselines that assumed zero government intervention, despite national deforestation bans in place."

— consultant who now refuses to sign off on unadjusted AFOLU models

That quote is not a smear. It is a caution. Verra is the right platform for volume, but only if you pressure-test the additionality logic yourself, because nobody else will.

For early-stage removals: ACR with performance-based additionality

Early-stage removal projects—enhanced weathering, direct air capture, biochar—live in a weird zone. They are too capital-intensive to prove additionality via the standard "regulatory surplus" route, because there is no regulation forcing them underground. ACR has responded by offering performance-based additionality: you prove the tonnage was removed and stored, not that the project would have died without carbon finance. That is a pragmatic shift.

The pitfall is measurement error. ACR allows provisional crediting at lower confidence intervals, meaning you take delivery of credits that may be clawed back later if monitoring data tightens. Wrong order. Buy those credits at a discount and hold them in a buffer account until the permanence period closes. I have seen teams skip this step, retire the credits early, and then face a reversal notice eighteen months later. That hurts.

Match your registry to your project's weakest link. If the weak link is proof of ambition, pick Gold Standard. If it is scale, pick Verra but audit hard. If it is novel technology, pick ACR and plan for measurement revisions. There is no perfect registry—only the one that punishes your specific additionality flaw before someone else does.