This report summarizes the process and work completed to develop and successfully submit an MRV plan to EPA. This work used the lessons learned from various MRCSP tasks to demonstrate the geologic understanding of the Niagaran reefs, successful monitoring and accounting methodologies, understanding of potential risks and leakage pathways, and mass balance of CO2 baseline and net storage. The plan currently encompasses 10 reefs and also provides a reporting plan for future reef development.