Analysis of projects generating 80% of total offset credits issued by ARB under its U.S. Forest projects offset protocol shows that 82% of the credits generated by these projects likely do not represent true emissions reductions, due to the protocol’s leakage accounting methods. The total quantity of over-crediting across these 36 projects equals approximately 80 million tons of CO2. For context, the U.S. Forest Protocol has generated 80% of the offset credits in California’s cap-and- trade program; the estimated over-crediting is equal to one third of the total expected effect of California’s cap-and-trade program on emissions during 2021-2030.