Pillar II · Framework

Built like an institutional commodity.

Measurement rigor at OGMP 2.0 Level 5. Independent ISO 14065 verification. Issuer-level integrity instruments administered by a Collateral Agent. Cryptographic retirement on Solana Token-2022.

The six layers

Stacked. Independent. Documented.

  1. 01
    Verification logic

    OGMP 2.0 Level 5 + Independent ISO 14065 VVB

    Measurement to OGMP 2.0 Level 5 — the highest-tier UNEP-recognized methane MRV framework — combining source-level dMRV continuous sensors and OGI with site-level satellite reconciliation. Independent ISO 14065 verification by The Kent Group Associates (KG/GHG0083125) under EPA Subpart W and ISO 14064. Probabilistic uncertainty quantified by Monte Carlo simulation per ISO 14064-3 §7.3 (figure subject to engineering confirmation — see pre-execution item F).

  2. 02
    Issuance controls

    29-Gate Mint Checklist · Non-delegable CEO sign-off

    Issuance of any CAT requires completion of the 29-Gate Mint Checklist, with non-delegable CEO sign-off at the final gate (per White Paper §08.1). Multisig signer composition and threshold subject to engineering and counsel confirmation (pre-execution item E). No bespoke transfer-hook program is deployed; compliance controls are enforced at the Fireblocks Tokenization platform and custody policy layers (per White Paper §04.4).

  3. 03
    Retirement process

    Token-2022 native burn · Pinata + IPFS-anchored record

    Retirement is executed by Token-2022 native burn on Solana. A non-transferable NFT certificate is minted at the burn block, recording the retiring wallet, quantity, timestamp, purpose, verification statement hash, and documentation CIDs. Each retirement event is content-addressed and pinned to IPFS through Pinata, with the CID committed to on-chain metadata for permanence. A Big Four attestation engagement on the retirement function is planned, subject to engagement-letter execution.

  4. 04
    Digital settlement

    Solana Token-2022 · Fireblocks Tokenization

    Token-2022 settlement on Solana with Fireblocks Tokenization providing the issuance, custody, and policy-engine controls. T+0 transfer; T+2 spot settlement for institutional counterparties. MPC-CMP custody. Compliance controls enforced at the Fireblocks platform and policy layers, not at a bespoke on-chain program.

  5. 05
    Project standards

    9-barrier P&A · Recorded VPP · UCC-1 perfected

    Christopher Unit #1: 9-barrier wellbore isolation architecture (500–600% above TRRC §3.14 minimum). Abernathy Unit #1: 14-barrier cement plug architecture, including 8 environmental cement plugs. Both projects target the deep formation system below the base of Wolfcamp (Atoka, Pennsylvanian) under recorded Voluntary Production Prohibition covenants in Loving County. UCC-1 perfected security held by an independent Collateral Agent.

  6. 06
    Issuer-level integrity instruments

    Three issuer-level instruments · Independent Collateral Agent

    Three issuer-level integrity instruments are administered by an independent Collateral Agent for the purpose of supporting protocol environmental integrity (per White Paper §03.3 and §10.1). The CCCi Lloyd's of London policy (CCCi-0120125) is issued at the issuer entity for a $100M policy limit (rider terms subject to broker confirmation — pre-execution item C). CAT holders do not hold equity, distributions, voting rights, or creditor claims; they do not hold direct claims on insurance proceeds, foreclosure recoveries, or covenant remedies.

A factual contrast

CAT structure vs. typical registry-issued credit.

The CAT is structurally distinct from a registry-issued voluntary carbon credit. The contrasts below describe each side factually, without implying that registry credits are deficient or that the CAT is a substitute for any particular regulatory instrument.

AttributeRegistry-issued creditLMCX CAT
PermanenceBuffer pool, registry-administeredRecorded VPP covenant in Loving County · UCC-1 perfected security held by an independent Collateral Agent · CCCi Lloyd's of London policy at the issuer entity
Verification independenceRegistry-approved VVB using registry methodologyIndependent ISO 14065 VVB (Kent Group Associates) on OGMP 2.0 Level 5 / EPA Subpart W / ISO 14064
Registry survival riskCredits depend on continued registry operationRecorded VPP runs with the land in perpetuity; project entity records held at Wyoming SOS
Double-count preventionRegistry serial-number databaseToken-2022 native burn on retirement — cryptographically irreversible
SettlementPortal-based; T+2 to T+5T+0 transfer on-chain; T+2 spot settlement
Audit trailRegistry portal dataWyoming SOS · Loving County records · EPA Subpart W filings · on-chain block records
Issuer characterizationNo issuer-level legal characterizationAffirmative multi-jurisdictional classification — U.S. (consistent with SEC/CFTC Joint Release No. 2026-30; not a security under Howey or Reves) · EU (MiCA Title II “other crypto-asset”; not ART, not EMT, not MiFID II financial instrument) · UAE (VARA / ADGM FSRA non-financial Virtual Asset; not a Security Token, Derivative, or Specified Investment). No regulator has ruled.
Holder posture

What a CAT holder does — and does not — hold.

A CAT holder, purchaser, acquirer, or owner of record holds a digital environmental commodity unit corresponding to one verified metric tonne of methane avoidance (GWP28 basis). The holder may transfer, retire, or hold the unit subject to the applicable custody and policy controls.

CAT holders do not hold equity, debt, partnership interests, or beneficial interests in the issuer (Christopher Unit 1 IMCSS, LLC), Last Mile Production LLC, Last Mile Capital Partners LLC, the Collateral Agent, or any affiliate. CAT holders do not hold direct claims on insurance proceeds, foreclosure recoveries, covenant remedies, or any issuer-level integrity instrument. The integrity instruments are administered by an independent Collateral Agent for the purpose of supporting protocol environmental integrity.

Continue

Layer-by-layer documentation — Mint Checklist gate detail, Fireblocks policy-engine controls, Collateral Agent administration of issuer-level instruments, and project-standards engineering records — is available to qualified recipients under separate cover.

→ See /protocol for the full pillar overview