Methodology Assessment Report - Verra

Methodology AssessmentReport

ASSESSMENT OF THE VCS METHODOLOGY:“BASELINE AND MONITORING METHODOLOGY FOR

THE REWETTING OF DRAINED PEATLANDS USED FORPEAT EXTRACTION, FORESTRY OR AGRICULTURE

BASED ON GESTS”

REPORT NO. 10280SH

09 JUNE 2017

TÜV SÜD South Asia Pvt. Ltd.Environmental Technology, Carbon Management Service

Solitaire, I.T.I. Road, Aundh, Pune- 411007, INDIA

METHODOLOGY ELEMENT ASSESSMENT REPORT: VCS Version 3

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Methodology Title Baseline and monitoring methodology for the rewetting of drained peatlandsused for peat extraction, forestry or agriculture based on GESTs

Version Version 8/15/2016

Methodology Cate-gory

Methodology X

Methodology Revision

Module

Tool

Sectoral Scope(s) Scope 14 (WRC-RWE)

Report Title Methodology Assessment Report “Baseline and monitoring methodology forthe rewetting of drained peatlands used for peat extraction, forestry or agricul-ture based on GESTs”

Report Version 3

Client Silvestrum

Pages 107

Date of Issue 09/06/2076

Prepared By “Environment and Energy”, TÜV SÜD South Asia

Contact TÜV SÜD South Asia Pvt. Ltd.Environmental Technology, Carbon Management ServiceSolitaire, I.T.I. Road, Aundh, Pune- 411007, India

Approved By Eswar Murty (Certification Body “Environment & Energy”)Viyayanand, Martin Seitz (Technical Reviewers)

Work Carried Out By Audit Team: Sebastian Hetsch, Martin Opitz, Matthias Drösler

Summary:

TÜV SÜD South Asia Pvt Ltd (TÜV SÜD) performed the second assessment of proposed Verified CarbonStandard (VCS) methodology “Baseline and monitoring methodology for the rewetting of drained peat-lands used for peat extraction, forestry or agriculture based on GESTs”.

The assessment was conducted on the basis of the VCS Standard version 3.5, respective guidancedocuments and clarifications obtained by VCS. The assessment was performed by means of a documentreview, follow-up interviews, and the resolution of outstanding issues.

Findings raised are summarized in this report and detailed in Annex 1 of the report. A total of 13 Correc-tive Action Requests and 10 Clarification requests were issued.

No uncertainties arose associated with the assessment.


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In summary, TÜV SÜD concludes that the final version of the methodology (Version 8/15/2016) meth-odology meets current relevant VCS requirements and recommends the methodology to be acceptedby the VCSA.


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Abbreviations

AFOLU Agriculture, Forestry and Other Land UseCAR Corrective Action RequestCB TÜV SÜD Certification Body “climate and energy”CDM Clean Development MechanismCR Clarification RequestDOE Designated Operational EntityER Emission ReductionGEST Greenhouse gas Emission Site TypeGHG Green House Gas(es)GPG Good Practice GuidanceIPCC Intergovernmental Panel on Climate ChangeIRL Information Reference ListLULUCF Land-Use, Land-Use Change and ForestryNEE Net Ecosystem ExchangeNEP Net Ecosystem ProductionPD Project DocumentPP Project ParticipantSOP Standard Operating ProcedureTÜV SÜD TÜV SÜD South Asia Pvt LtdUNFCCC United Nations Framework Convention on Climate ChangeVCS Verified Carbon StandardVCU Verified Carbon UnitVVB Validation, Verification Body


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Table of Contents

1 Introduction ...................................................................................................................................... 5

1.1 Objective .................................................................................................................................. 5

1.2 Scope ...................................................................................................................................... 5

1.3 Summary Description of the Methodology ................................................................................. 5

2 Assessment Approach ...................................................................................................................... 5

2.1 Method and Criteria .................................................................................................................. 5

2.2 Document Review .................................................................................................................... 7

2.3 Interviews ................................................................................................................................. 7

2.4 Assessment Team.................................................................................................................... 7

2.5 Resolution of Findings .............................................................................................................. 8

2.6 Internal Quality Control ............................................................................................................. 8

3 Assessment Finding ......................................................................................................................... 9

3.1 Relationship to Approved or Pending Methodologies ................................................................ 9

3.2 Stakeholder Comments ............................................................................................................ 9

3.3 Structure and Clarity of Methodology ........................................................................................ 9

3.4 Definitions .............................................................................................................................. 10

3.5 Applicability Conditions ........................................................................................................... 10

3.6 Project Boundary .................................................................................................................... 11

3.7 Baseline Scenario .................................................................................................................. 14

3.8 Additionality............................................................................................................................ 14

3.9 Quantification of GHG Emission Reductions and Removals .................................................... 14

3.9.1 Baseline Emissions ............................................................................................................ 14

3.9.2 Project Emissions ............................................................................................................... 15

3.9.3 Leakage ............................................................................................................................. 15

3.9.4 Net GHG Emission Reductions and Removals .................................................................... 15

3.10 Monitoring .............................................................................................................................. 16

4 Assessment Conclusion.................................................................................................................. 21

5 report reconciliation ........................................................................................................................ 22

6 Evidence of fulfilment of VVB eligibility requirements....................................................................... 22

7 Signature ........................................................................................................................................ 22

Annex 1: Assessment Protocol .................................................................................................. Annex I -1

Table 1: VCS Methodology Assessment Protocol .................................................................. Annex I - 1

Table 2: Summary of Requests and Responses by Methodology Developer ........................ Annex I - 49

Annex 2: Information Reference List ........................................................................................ Annex II - 1


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1 INTRODUCTION

1.1 ObjectiveThe company Silvestrum has commissioned TÜV SÜD to conduct the second assessment of its proposedAFOLU methodology “Baseline and monitoring methodology for the rewetting of drained peatlands usedfor peat extraction, forestry or agriculture based on GESTs” with regard to the relevant VCS requirements.The evaluation objective is an assessment by a Third Party (VVB) of the proposed new methodologyagainst all defined criteria set for methodology approvals under the VCS.

In particular, the baseline methodology, it’s consistence with the monitoring methodology, emission reduc-tion calculations and the methodology’s compliance with the requirements of the VCS standard are evalu-ated. This report summarizes the findings of the evaluation. The present report represents the secondapproval within the double approval process as defined by VCS. The first assessment was carried out bySCS global services.

1.2 ScopeThe scope of evaluation of proposed new methodology is defined as an independent and objective reviewof the baseline and monitoring methodology and other relevant documents.

The information in these documents is reviewed against the requirements of the VCS, in particular:

VCS standard version 3.5;

VCS AFOLU Requirements version 3.4;

VCS Methodology Approval Process version 3.6;

Technical expertise relevant to the scope and technical area of WRC projects.

1.3 Summary Description of the MethodologyThe proposed project type covered by this methodology is aimed at reducing greenhouse gas emissionsresulting from rewetting of drained peatlands in temperate climatic regions due to past land uses. Themethodology accounts for GHG emission reductions from drained rewetted peatlands as well as for GHGemissions from changes in carbon stocks in selected non-peat carbon pools. The methodology applies theGEST (GEST: Greenhouse gas Emissions Site Type) approach for the estimation of emissions reductions.This approach uses ground vegetation composition and water table depth as proxies for peatland GHGemissions.

2 ASSESSMENT APPROACH

2.1 Method and CriteriaThe methodology assessment applies standard auditing techniques to assess the correctness of the in-formation provided by the project participants. The work starts with the appointment of the team coveringthe technical scope(s) and sectoral scope(s) for evaluating the VCS methodology activity. Once the meth-odology is received, members of the team carry out the desk review, office session with the developers,resolution of issues identified and finally preparation of the assessment report. The prepared assessment


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report and other supporting documents then undergo an internal quality control by the Certification Body“Environment and Energy” of TÜV SÜD, before final submission of the assessment report.

In order to ensure transparency, assumptions are clear and explicitly stated; the background material isclearly referenced. TÜV SÜD developed methodology-specific checklists and protocols customised for theassessment. The protocol shows, in a transparent manner, criteria (requirements), the discussion of eachcriterion by the assessment team, and the results from validating the identified criteria.The assessment protocol serves the following purposes:

To organize the details and provision of clarifications on the requirements of which a VCS method-ology is expected to meet

To elucidate how a particular requirement has been validated as well as to document the results ofthe assessment and any adjustments made to the methodology document.

The assessment protocol consists of two tables. The different columns in these tables are described inthe figure below.

Assessment Protocol Table 1: Conformity of Methodology

VCS Re-quirement

Reference Comments Draft Conclusion Final Conclu-sion

The checklistis organisedin sectionsfollowing thearrangementof the respec-tive VCS re-quirementsfor methodol-ogies.

Gives ref-erence todocumentswhere theanswer tothe check-list ques-tion or itemis found.

The section is used toelaborate and discuss thechecklist question and/orthe conformance to thequestion. It is used to ex-plain the conclusionsreached. In some casessub-checklist are appliedindicating yes/no deci-sions on the compliancewith the stated criterion.Any Request has to besubstantiated within thiscolumn

Conclusions are pre-sented based on the as-sessment of the firstmethodology version.This is either acceptablebased on evidence pro-vided ( ), or a Correc-tive Action Request(CAR) due to non-com-pliance with the check-list question (See be-low).Clarification Request(CR) is used when thevalidation team identi-fied a need for furtherclarification.

Conclusionsare presentedin the samemanner basedon the assess-ment of the fi-nal methodol-ogy versionand furtherdocuments in-cluding as-sumptions pre-sented in thedocumentation.


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Assessment Protocol Table 2: Summary of Requests and Responses of Methodology Developer

Clarifications andCorrective ActionRequests

Ref. to VSCrequire-ments

Summary of responseby methodology devel-oper

Conclusion by Audit Team

Corrective Action orClarification Requestsfrom table 1 are listedin this section.

Reference tothe respec-tive VCS re-quirement.

The responses given bythe client or other projectparticipants during thecommunications with thevalidation team shouldbe summarised in thissection.

This section summarises the dis-cussion on and revision to meth-odology together with the auditteam’s responses and final con-clusions. The conclusions is alsoreflected in Table 1, under “FinalConclusion”.

The completed validation protocol is enclosed in Annex 1 to this report.

2.2 Document ReviewA first version of the Methodology was submitted to TÜV SÜD in October 2014. This methodology versionand additional background documents related to the methodology were reviewed to verify the correct-ness, credibility and interpretation of the presented information, furthermore a cross-check between infor-mation provided and information from other sources was carried out as initial step of the assessment pro-cess. A complete list of all documents and proofs reviewed is attached as Annex 2 to this report.

2.3 InterviewsDuring the period of the assessment several conference calls were set up to discuss with the methodol-ogy developer and relevant expert who contributed to the methodology to confirm relevant informationand to resolve issues identified in the first document review.

Name Organisation

Dr. Igino Emmer SilvestrumJohn Couwenberg Greifswald University

2.4 Assessment TeamAccording to the technical scopes and experiences in the sectoral or national business environment, TÜVSÜD has composed an assessment team in accordance with the appointment rules of the TÜV SÜD certi-fication body “Environment and Energy”.

The composition of an assessment team has to be approved by the Certification Body (CB) to assure thatthe required skills are covered by the team. The CB TÜV SÜD operates the following qualification levelsfor team members that are assigned by formal appointment rules:

Assessment Team Leader (ATL);

Validator (VAL);

Validator Trainee (T);

Technical Experts (TE).


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It is required that the sectoral scope(s) and the technical area(s) linked to the methodology and projecthave to be covered by the assessment team. For this particular methodology the assessment team mem-bers are presented in the table below. The respective appointment certificates are attached to this reportas annex 3.

Assessment Team:

Name Qualification Coverage ofscope

Coverage oftechnical area

Coverageof financial

aspect

Sebastian Hetsch ATL

Martin Opitz VAL

Dr. Matthias Drösler TE

Technical Reviewers are Vijayanand and Martin Seitz (covering the respective Technical Area).

2.5 Resolution of FindingsThe objective of this phase of the assessment is to resolve the requests for corrective actions and clarifi-cations and any other outstanding issues which needed to be clarified for TÜV SÜD`s positive conclusionon the methodology. All Corrective Action Requests and Clarification Requests raised by TÜV SÜD wereresolved during communication between the client and TÜV SÜD. To guarantee the transparency of theassessment process, the concerns raised and responses that were given are summarised in chapter 3below and documented in more detail in the validation protocol in Annex 1.

The methodology that was submitted in August 2016 served as the basis for the final assessment pre-sented herewith.

2.6 Internal Quality Control

Internal quality control is the final step of the assessment process and is conducted by the CertificationBody (CB) “Environment and Energy”. The CB checks the final documentation, which includes the assess-ment report and annexes.

Technical Reviewers appointed by the CB carry out corresponding review work. The completion of thequality control indicates that each report submitted has been approved either by the head of the CB or thedeputy. In projects where either the Head of the CB or his/her deputy is part of the assessment team, theapproval is given by the one not serving on the project team.


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3 ASSESSMENT FINDING

3.1 Relationship to Approved or Pending MethodologiesThe proposed methodology analysed the relationship of existing approved VCS methodologies that ac-count for emission reductions resulting from rewetting of peatland respectively its restauration.

By applying the GEST-approach the proposed methodology includes procedures that are not covered byany approved or pending methodology under the Wetlands Restoration and Conservation project cate-gory of the VCS. Thus, approved methodologies could not reasonably be revised to serve the same pur-pose at the proposed methodology.

3.2 Stakeholder Comments

Period of the global stakeholder consultation process:13-12-2011 until 12-01-2012

Comment submitted by:Peter SchlesingerCarbon Decisions Interna-tionalPeru

Issues raised:

Methodology calls for "remotely sensed data of adequate resolution" p. 6,and elsewhere "high spatial resolution" p. 59, but never defines "adequate"or "high". Also, there is no accuracy assessment of the remote sensingclassifications, which doesn't meet good practice guidelines. The imageryclassification methods offered are insufficient. Calls for: use of good prac-tice, but doesn't suggest any; and, following accuracy requirements, butdoesn't recommend any.

Response by methodology developer:General Comments:

According to the information received from the methodology developer no formally respond with a dedi-cated written answer was provided, but rather the methodology amended in response to the comment. Onthat basis SCS (1st assessor) closed respectively responded to the comment.

Response by TÜV SÜD:

This comment was significant at the time of issuance. Section 9.3.6 lists additional criteria for spatial reso-lution, accuracy assessment as well as well-defined procedures for imagery classification.

TÜV SÜD concludes that the proposed methodology has been satisfactorily been revised to address pub-lic comments.

3.3 Structure and Clarity of MethodologyThe methodology is written in line with VCS requirements:

The methodology developer followed the instructions provided in the methodology template pro-vided. Criteria and procedures for the application of the methodology are provided in the appropri-ate sections of the methodology template.

The terminology used is consistent with that used in the VCS Program respectively in the GHGaccounting in general.


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Firm requirements, (non-mandatory) recommendations and permissible or allowable options areclearly defined by using respective modal verbs.

Criteria and procedures provided in the methodology are written in an understandable, readily andconsistently manner so that the methodology can be applied by potential project developers.

The manner criteria and procedures are provided in the methodology allows potential VVBs tounambiguously validate/verify projects against the methodology.

The methodology complies with essential requirements in terms of terminology used, unambiguousness ofrequirements demanded and clarity of criteria and procedures provided. Thus, the methodology offers thestructure and clarity required to be thoroughly applicable.

3.4 DefinitionsKey terms are clearly and appropriately defined, and consistently used throughout the methodology. Thedefinitions provide sufficient clarity in order to prevent any kind of misapprehension. Key terms are listed inalphabetical order as required. Terms already defined under the VCS Program are not repeated as re-quired. Terms and definitions used in the methodology are listed on page 5 of the methodology.

3.5 Applicability ConditionsThe methodology provided a set of 12 applicability conditions determining:

types of land use in the baseline and the project scenario requirements for side selection and boundaries abiotic risks

The applicability conditions provided are appropriate for the project activities targeted and the quantificationprocedures set out by the methodology. As a whole, the applicability conditions clearly determine whichproject activities are eligible and which are not under the methodology. The applicability conditions as awhole are consistent and correlating.

In the following table, the applicability conditions are listed and clarified if:

a) the applicability condition is written in a sufficiently clear and precise manner and if it can be deter-mined whether the project activity meets with the condition

b) Conformance with the condition can be demonstrated at the time of the project validation.

No Applicability Condition a) b)

a. Project activities aim at the rewetting of peatlands that have been drained for forestrythat is not or no longer profitable (as determined on the basis of annual reports, annualaccounts, market studies, government studies, or land use planning reports and docu-ments), or peat extraction that has been abandoned at least 2 years prior to the projectstart date, or agriculture that has been abandoned at least 2 years prior to the projectstart date or will be continued in the project scenario, or where drainage of additionalpeatland for new agricultural sites will not occur or is prohibited by law. Post-rewettingland use is limited to forestry (including biomass production but excluding IFM and

Yes yes


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REDD activities), agriculture (excluding ALM activities), nature conservation/recreation,or a combination of these activities. Peat extraction does not occur.

b. Harvesting in the baseline scenario within the project boundary does not occur or isnon-commercial in nature and is then not accounted for. Carbon storage in wood prod-ucts in the project scenario is conservatively not accounted for.

Yes yes

c. The collection of firewood for non-commercial use in the baseline scenario may occurbut is not accounted for.

Yes yes

d. The burning of biomass as a project activity does not occur. Biomass burning in thebaseline scenario may occur but GHG emissions are conservatively not accounted for.

Yes yes

e. The project boundary must be designed such that the project GHG benefits are not neg-atively affected by drainage activities that occur outside the project area.

Yes yes

f. Leakage caused by activity shifting, market effects and hydrological connectivity areavoided by project design and site selection.

Yes yes

g. Live tree vegetation may be present and subject to carbon stock changes (e.g. due toharvesting) in both the baseline and project scenarios.

Yes yes

h. The burning of peat as a project activity in the project scenario does not occur. Yes yes

i. For claiming GHG emission reductions from reducing peat fires, (A) it must be demon-strated that a threat of frequent on-site fires exists. Procedures for performing a full (e.g.tier-3) assessment of the GHG emissions due to peat fires in the baseline scenario arenot provided. If the default procedure provided cannot be used, such baseline emis-sions are conservatively not accounted for; and (B) peatland rewetting must be com-bined with fire management.

Yes yes

j. It must be demonstrated by referring to peer-reviewed literature and by sufficient re-wetting that N2O emissions will not increase in the project scenario compared to thebaseline scenario. Therefore, N2O emissions need not be accounted for.

Yes yes

k. N-fertilizers are not used in the project scenario. Yes yes

l. In the baseline scenario the peatland is drained. Yes yes

3.6 Project BoundaryThe proposed methodology distinguished between temporal and geographic boundaries.

Temporal boundaries

Temporal boundaries are defined by project crediting period, project crediting period start date and pro-ject start date as well as the peat depletion time (PDT) which is derived from peat depth and rate of peatloss due to subsidence and fire.


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Geographic boundaries

Geographical boundaries describe the physical boundaries of the project area based on a stratificationdue to peat depth, vegetation cover and accuracy requirements respectively.

The boundaries have to be determined following clear guidelines and requirements detailed in the pro-posed methodology in compliance with the VCS requirements. Further information is specified in Annex I& II of this report.

The methodology contains the following carbon pools in accordance with the VCS AFOLU requirements asdescribed below:

Carbon pool Included? Comment assessment team

Aboveground treebiomass Yes Required for inclusion by VCS AFOLU Requirements Section 4.3.1.

Aboveground non-tree biomass Yes

Optional carbon pool in accordance with VCS AFOLU Require-ments, Section 4.3.1.

Belowground bio-mass Yes

Optional carbon pool in accordance with VCS AFOLU Require-ments, Section 4.3.1

Litter YesDoes not have to be included as carbon pool in accordance withVCS AFOLU Requirements, Section 4.3.1. Nevertheless the litterlayer is included if it forms part of a GEST.

Deadwood NoOptional carbon pool in accordance with VCS AFOLU Require-ments, Section 4.3.1

Soil Yes Required for inclusion by VCS AFOLU Requirements Section 4.3.1.

Wood Products NoOptional carbon pool in accordance with VCS AFOLU Require-ments, Section 4.3.1

The methodology contains the following GHG sources in accordance with the VCS AFOLU requirementsas described below:

Source Gas Included? Justification/Explanation

Bas

elin

e

Changes in stocks incarbon pools in biomass

CO2 Yes Potential major source of removals; consideredas carbon pool in compliance with VCS AFOLURequirements.

Oxidation of drainedpeat

CO2 Yes Main source and gas to be addressed by pro-ject activities.

May be conservatively excluded in the baselinescenario in accordance with VCS AFOLU Re-quirements, Section 4.3.4.


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CH4 Yes Required for inclusion within the project bound-ary by the VCS AFOLU Requirements, Section4.3.23.

May be conservatively excluded in the baselinescenario in accordance with VCS AFOLU Re-quirements, Section 4.3.4.

N2O No Required for inclusion within the project bound-ary by the VCS AFOLU Requirements, Section4.3.24.

Excluded in the baseline scenario in accord-ance with VCS AFOLU Requirements, Section4.3.3. as per applicability condition.

Burning of biomass

CO2 No Conservatively excluded in the baseline sce-nario in accordance with VCS AFOLU Require-ments, Section 4.3.4.

CH4 No

N2O No

Peat burning

CO2 Yes Fire may occur in the baseline scenario and isaccounted for with a default approach (Fire Re-duction Premium) in accordance with VCSAFOLU Requirements, Section 4.5.34

CH4 No Conservatively excluded in the baseline sce-nario in accordance with VCS AFOLU Require-ments, Section 4.3.4.

N2O No

Pro

ject

The production of me-thane by bacteria

CH4 Yes Potential major source of emissions in the pro-ject in low salinity and freshwater areas. In-cluded in accordance with VCS AFOLU Re-quirements, Section 4.3.23.

Accumulation of peat inproject scenario

CO2 No Conservatively excluded in the project scenarioin accordance with VCS AFOLU Requirements,Section 4.3.4.

Burning of biomass

CO2 No Excluded in the project scenario in accordancewith VCS AFOLU Requirements, Section 4.3.3.as per applicability condition.

CH4 No

N2O No

Fossil fuel combustionfrom transport and ma-chinery use in project ac-tivities

CO2 No Deemed de minimis in accordance with VCSAFOLU Requirements, Section 4.3.3(3)CH4 No

N2O No


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Peat burning

CO2 Yes Fire may occur in the project scenario and isaccounted for with a default approach (Fire Re-duction Premium) in accordance with VCSAFOLU Requirements, Section 4.5.34

CH4 No Not included in the Fire Reduction Premium ap-proach

N2O No Not included in the Fire Reduction Premium ap-proach

3.7 Baseline ScenarioThe methodology uses a project method to identify the baseline scenario. The methodology requires theapplication of the latest version of the CDM “Combined tool to identify the baseline scenario and demon-strate additionality in A/R CDM project activities” in order to identify potential alternative baseline land usescenarios. In case there is a conflict between the CDM tool requirements and the VCS rules, the VCSProgram Methodology requires that VCS rules must be followed, as outlined in AFOLU Guidance: “Addi-tional guidance for VCS Afforestation, Reforestation and Revegetation projects using CDM Afforesta-tion/Reforestation Methodologies”

Relevant non-human induced rewetting such as natural damming of waterways and the long term climatevariables influencing the water table are accounted for. Thus conformance with Section 4.4.11 of the VCSAFOLU Requirements is accomplished. For further details see also ANNEX 1.

In summary, the procedures for determining the baseline scenario are appropriate, adequate and in com-pliance with the VCS rules for WRC projects.

3.8 AdditionalityThe methodology uses a project method determine additionality. The methodology requires the applica-tion of the latest version of the CDM “Combined tool to identify the baseline scenario and demonstrateadditionality in A/R CDM project activities” in order to demonstrate additionality. The tool is appropriate forproject activities covered by the methodology as the proposed project activities are AFOLU activities.Thus conformance with Section 4.6.2 of the VCS Standard Requirements is accomplished. For furtherdetails see also ANNEX 1.

In summary, the tool for demonstrating additionality is appropriate, adequate and in compliance with theVCS rules for WRC projects.

3.9 Quantification of GHG Emission Reductions and Removals

3.9.1 Baseline EmissionsBaseline emissions are quantified by determining carbon stock changes in non-peat carbon pools, GHGemissions as a result of peat oxidation due to drainage or a combination of both. In addition, emissions asa result of peat combustion due to peatland fires can be determined.


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Section 8.1.2 provides procedures to estimate net carbon stock changes in non-peat carbon pools. Theprocedures provided are consistent with Volume 4, Chapter 2 of IPCC 2006 Guidelines.

Section 8.1.3 provides procedures to estimate provides procedures to estimate GHG Emission due topeat drainage following the GEST approach. The GEST approach utilizes documented relationships be-tween CO2 emissions and vegetation types which is consistent with Section 4.5.27 of the VCS AFOLURequirements. For further details see also ANNEX 1.

The Peat depletion time as part of the baseline has to be reassessed latest every 10 years in accordancewith section 4.5.25 of the VCS AFOLU Requirements.

In summary all criteria and procedures described section 8.1 of the methodology are appropriate for pro-ject activities covered by the methodology. The procedures for calculating baseline emissions and remov-als cover all GHG sources, sinks and reservoirs. All algorithms, equations and formulas presented areappropriate and without error. All models and default values are appropriate an in conformance with VCSrequirements.

3.9.2 Project EmissionsThe procedures provided for estimating the project emissions are similar to those for the estimation of thebaseline emissions.

Besides the mentioned procedures the VCS Program Methodology provides in section 8.2.3.2 an alterna-tive procedures to estimate GHG emission. The procedure is following the GEST approach but estimatesthe project emissions on bases of a conversion of a GEST.

In summary all criteria and procedures described section 8.2 of the methodology are appropriate for pro-ject activities covered by the methodology. The procedures for calculating baseline emissions and remov-als cover all GHG sources, sinks and reservoirs. All procedures, algorithms, equations and formulas pre-sented are appropriate and without error. All models and default values are appropriate an in conform-ance with VCS requirements.

3.9.3 LeakageDue to the applicability conditions the VCS Program Methodology does not account for leakage of anykind. In order to ensure that no leakage will occur, the VCS Program Methodology provides requirementsin terms of project design and side selection.

In summary all requirements described section 8.4 in terms of project design are appropriate to avoid allpotential leakage sources covered by WRC.

3.9.4 Net GHG Emission Reductions and RemovalsThe calculation of the net GHG Emission Reductions and Removals are appropriate for the project activi-ties covered by the methodology comply with Section 4.7.1 and 4.7.2 of the VCS Standard. All algorithms,equations and formulas provided are appropriate and without error.

In accordance with section 4.1.4 of the VCS Standard the methodology allows an uncertainty of +/- 30%at a 95% or a +/-20% at a 90% confidence level. In the case confidence interval exceeds 30% or 20% re-spectively a deduction is required (section 8.5.2). The uncertainty is calculated based on the uncertaintyassessment of in the baseline (Part 1) and uncertainty in the project scenario (Part 2).


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In summary all algorithms, equations and formulas used are appropriate and without error. Any uncertain-ties associated with the quantification of net GHG emissions reductions and removals are addressed ap-propriately and in compliance with the VCS rules for WRC projects.

3.10 MonitoringThe specification for monitored and not monitored data and parameters are set out in sections 9.1 and9.2 of the methodology element. For data and parameters that require measurement appropriate proce-dures for measurements are provided in section 9.3.

In the following table, the parameters available at validation provided in section 9.1 of the methodology arelisted and clarified if they appropriate in terms of:

a) Data unitb) Source of datac) Value appliedd) Justification of choice of data or description of measurement methods and procedures to be appliede) Purpose of data

Parameter Description a) b) c) d) e) Comments

Depthpeat-

BSL,i

Peat depth above thedrainage limit in thebaseline scenario instratum i at projectstart

yes yes yes yes yes Depthpeat-BSL,i,t0 = Depthpeat-WPS,i,t0

This parameter must be re-assessed to-gether with the re-assessment of thebaseline scenario.

Depthpeat-

WPS,i

Peat depth above thedrainage limit in theproject scenario instratum i at projectstart

yes yes yes yes yes Only for ex-ante assessment

Depthpeat-BSL,i,t0 = Depthpeat-WPS,i,t0

Ratepeatloss-

BSL,i

Rate of peat loss dueto subsidence and firein the baseline sce-nario in stratum i

yes yes yes yes yes The use of a relatively low value for aconstant rate of peat loss may not beconfused with a relatively high valuewhen determining the need for stratifica-tion of peat depth.This parameter must be re-assessed to-gether with the re-assessment of thebaseline scenario.

Ratepeatloss-

WPS,i

Rate of peat loss dueto subsidence in theproject scenario instratum i

yes yes yes yes yes Only for ex-ante assessment


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VCpeat Volumetric carboncontent of peat

yes yes yes yes yes none

ABSL,i,t Area of baseline stra-tum i in year t

yes yes yes yes yes In Equations 2, 7, 8 and 11 the parame-ter is denoted as ABSL,i,t100, which is thearea of baseline stratum i at t=100.

Rj Root:shoot ratio fortree species j


CFj Carbon fraction of drymatter for species j


Iv,j,i,t Average annual incre-ment in merchantablevolume for species j instratum i in year t


Dj Basic wood density forspecies j


BEF1,j Biomass expansionfactor for conversion ofannual net increment(including bark) in mer-chantable volume tototal above-ground bi-omass increment forspecies j

yes yes yes yes yes BEFs are age dependent, and they areusually large for young stands and quitesmall for old stands; BEFs in IPCC liter-ature and national inventory data areusually applicable to closed canopy for-est. If applied to individual trees growingin open field it is recommended that theselected BEF be increased by a further30%.

Kph Alexeyev coefficient,converts volumes ofabove ground growingstock (m3ha-1) toabove, below groundand bark dry biomass(t d.m. ha-1)

yes yes yes yes yes May be used instead of Rj and BEFj

Vj,i,t Stem volume of treespecies j in stratum i inyear t

yes yes yes yes yes Note that volume tables from which Vj,i,t

are obtained may or may not include al-lowance for losses due to harvesting ormortality. Such losses may be conser-vatively neglected when estimatingbaseline removals in pre-project trees.Otherwise CBSL-tree-AB,j,i,t must be esti-mated on the basis of credible andtransparent information on the rate at


v3.1 18

which pre-project activities (and mortal-ity, if applicable) are reducing carbonstocks in existing live trees (e.g., due toharvesting for local timber consumption,or for fuelwood).

BEF2j Biomass expansionfactor for conversion ofstem biomass toabove-ground tree bio-mass for species j


nTRj,i,t Tree stand density ofspecies j in stratum i inyear t


fj(X, Y, …) Allometric equation forspecies j linking meas-ured tree dimensionvariables (e.g. diame-ter at breast height(DBH) and possiblyheight (H)) to above-ground biomass of liv-ing trees.

yes yes yes yes yes Used for trees known at validation

GHGGESTbsl-

CO2,i,t

Emission of CO2 frombaseline GEST in stra-tum i in year t

yes yes yes yes yes This parameter must be re-assessed to-gether with the re-assessment of thebaseline scenario.

GHGWLbsl-

CO2,i,t

Emission of CO2 re-lated to water tabledepth in the baselinescenario in stratum i inyear t


GHGGESTbsl-

CH4,i,t

Emission of CH4 frombaseline GEST in stra-tum i in year t


GHGWLbsl-

CH4,i,t

Emission of CH4 re-lated to water tabledepth in the baselinescenario in stratum i inyear t


VI,j,j,sp,t Stem volume of tree lof species j in plot sp



v3.1 19

in stratum i in year t

Apeatburn Statistics and/or mapsin official reportsand/or remotes sens-ing data


AP Total project area yes yes yes yes yes none

In the following table, the parameters to be monitored provided in section 9.2 of the methodology are listedand clarified if they appropriate in terms of:

a) Data unitb) Source of datac) Description of measurement methods and procedures to be appliedd) Frequency of monitoring/recordinge) QA/QC procedures to be appliedf) Purpose of datag) Calculation method.

Parameter Description a) b) c) d) e) f) g) Comments

AWPS,i,t Area of project stratum i in year t yes yes yes yes yes yes yes In Equations2, 7, 8 and11 the pa-rameter isdenoted asAWPS,i,t100,which is thearea of pro-ject stratum iat t=100.

Asp,i Total area of all sample plots in stra-tum i

yes yes yes yes yes yes yes none

fj(X, Y, …) Allometric equation for species j link-ing measured tree dimension varia-bles (e.g. diameter at breast height(DBH) and possibly height (H)) toabove-ground biomass of living trees.

yes yes yes yes yes yes yes Used fortrees moni-tored

DBH Diameter at breast height of tree yes yes yes yes yes yes yes none

H Height of tree yes yes yes yes yes yes yes none


v3.1 20

GHGGEST-

wps-CO2,i,t

Emission of CO2 from project GESTin stratum i in year t


GHGGEST-

wps-CH4,i,t

Emission of CH4 from project GESTin stratum i in year t


GHGWLwps-

CO2,i,t

Emission of CO2 related to water ta-ble depth in the project scenario instratum i in year t


GHGWLwps-

CH4,i,t

Emission of CH4 related to water ta-ble depth in the project scenario instratum i in year t


Water tabledepth

Sub-soil or above soil surface of wa-ter, relative to the soil surface


t2 and t1 Years of the monitoring activity yes yes yes yes yes yes yes T = t2 - t1

In summary, the specification for monitored and not monitored data and parameters is appropriate, ade-quate and in compliance with the VCS rules.


v3.1 21

4 ASSESSMENT CONCLUSION

TÜV SÜD performed an assessment validation of the proposed VCS methodology: “Baseline and moni-toring methodology for the rewetting of drained peatlands used for peat extraction, forestry or agriculturebased on GESTs”. Standard auditing techniques have been used for the assessment of the methodology.A VCS scope-specific protocol for the methodology was prepared to conduct the assessment process in atransparent and comprehensive manner.

The review of the methodology documentation, subsequent follow-up interviews, and further verificationof references have provided TÜV SÜD with sufficient evidence to determine the fulfilment of stated crite-ria in the protocol. In the opinion of TÜV SÜD, the methodology meets all relevant VCS requirements ifthe underlying assumptions do not change. TÜV SÜD recommends the methodology to be accepted bythe VCSA.

The assessment was performed following the requirements of the latest version of the VCS Standard andon the basis of the contractual agreement. The single purpose of this report is its use during the registra-tion process as part of the VCS methodology approval cycle.


v3.1 22

5 REPORT RECONCILIATION

NA

6 EVIDENCE OF FULFILMENT OF VVB ELIGIBILITY REQUIREMENTS

In line with VCS requirements as stated in the VCS Methodology Approval Process v.3.5, section 4, TÜVSÜD is eligible to conduct this methodology assessment:

TÜV SÜD is accredited to conduct audits in the sectoral scope 14;

TÜV SÜD has completed over 10 project validations in the sectoral scope 14, including in particularnumerous CDM validations;

In addition Professor Drösler, an internally recognized WRC expert, and IPCC lead author for peat-land was included in the audit team. He is however not formally appointed under VCS.

7 SIGNATURE

Pune, 09/06/2017

___________________________________Eswar Murty

Certification Body “Environment and Energy”TÜV SÜD South Asia

Summary of Request and Responses by Methodology DeveloperBaseline and monitoring methodology for the rewetting of drained peatlands used for peat extraction, forestry or agriculture based

on GESTs

Annex 1 - 1

ANNEX 1: ASSESSMENT PROTOCOL

Table 1: VCS Methodology Assessment Protocol

VCS Requirement Ref COMMENTSDraftConcl

FinalConcl

General Requirements (Meth template v3.3)TITLE PAGE: All items in the box at the bottom of the firstpage must be completed using Arial 10pt, black, regular(non-italic) font. The box must appear on the first page ofthis document until the methodology or methodology revi-sion is approved.

2 All items are in Arial 10pt, black and regular.The box appears on the first page as requested

METHODOLOGY:The proposed methodologies must demonstrate that no ap-proved or pending methodology under the VCS Program oran approved GHG program could reasonably be revised tomeet the objective of the proposed methodology.

2 On the VCS Webpage there is no comparable meth-odology listed to quantify GHG emission reductionfrom rewetting drained peatlands used for peat extrac-tion, forestry or agriculture based on GEST

All sections must be completed using Arial 10pt, black, reg-ular (non-italic) font. Sections which are not applicable maybe left blank but should NOT be deleted from the final docu-ment.

2 All sections are in Arial 10pt, black and regular.

General requirements (VCS v3.5 Section 4.1)Does the VCS Program methodology use the VCS Method-ology Template?

2 The VCS Program methodology uses the VCS Meth-odology Template as requested.

a) Does such a VCS Program methodology use the VCSMethodology Template for the framework document andthe VCS Module Template for the modules and tools?

b) Does the framework document clearly state how themodules and/or tools are to be used within the context ofthe VCS Program methodology?

In Case of Methodologies employing a modular approach inwhich a framework document provides the structure of themethodology and separate modules and/or tools are usedto perform specific methodological tasks.

2 a) The VCS Program methodology uses the VCSMethodology Template as requested. Modules arenot explicitly developed by the PP. Neverthelessthe VCS Program methodology requires the appli-cation of registered tools and modules

b) The methodology clearly states how tools andmodules are to be used within the context of theVCS Program methodology

Does the VCS Program methodology clearly state the as-sumptions, parameters and procedures that have significant

1 The VCS Program Methodology allows a broad rangeof input parameters to be applied when estimating


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uncertainty, and describe how such uncertainty shall be ad-dressed?

emission following the GEST approach. This leads toan uncertainty directly related to the source of the in-put parameters chosen.As hardly any assumptions, parameters and proce-dures can lead to uncertainty none is especially high-lighted as of significant uncertainty.In order to provide guidance the VCS Program Meth-odology dedicates sections 9.3.2 (Uncertainty andquality management) and 9.3.3 (Expert judgment) tothe topic of uncertainty and how to deal with it in orderto minimize it respectively. Especially section 9.3.3 isof importance as the expert judgment is mentioned assource of information on many places of the methodol-ogy.

Where applicable, do elements of the VCS Program meth-odology provide a means to estimate a 90 or 95 percentconfidence interval?

1 The VCS Program methodology allows the applicationof both means to estimate a 90 or a 95 percent confi-dence interval

Where a 90 percent confidence interval is applied and thewidth of the confidence interval exceeds 20% of the esti-mated value or where a 95 percent confidence interval isapplied and the width of the confidence interval exceeds30% of the estimated value, does the VCS Program Meth-odology apply an appropriate confidence deduction?

1 The methodology provides an equation for deductionin case the confidence interval exceeds 30% by a 95%confidence level or 20% by a 90% confidence level.

See also comment above.

Are the methods for estimating uncertainty used by the VCSProgram Methodology based on recognized statistical ap-proaches such as those described in IPCC Good PracticeGuidance and Uncertainty Management in National Green-house Gas Inventories?

1 The methods for estimating uncertainty to be appliedare based on recognized statistical approaches.See also comments further below.

Do confidence deductions applied by the VCS Programmethodology use conservative factors such as those speci-fied in the CDM Meth Panel guidance on addressing uncer-tainty in its Thirty Second Meeting Report, Annex 14?

1 A appropriate confidence deduction is applied by theVCS Program Methodology.

In the case the VCS Program methodology mandates theuse of specific models to simulate processes that generateGHG emissions (ie, the project proponent is not permitted

1 No specific models are used by the VCS ProgramMethodology.Hydrological models can be used in order to predicte.g. water level of the project area. Requirements for


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FinalConcl

to use other models), is the following applied, given thenote below:

1) Models shall be publicly available, though not neces-sarily free of charge, from a reputable and recognizedsource (eg, the model developer’s website, IPCC orgovernment agency).

2) Model parameters shall be determined based uponstudies by appropriately qualified experts that identifythe parameters as important drivers of the model outputvariable(s).

3) Models shall have been appropriately reviewed andtested (e.g., ground-truthed using empirical data or re-sults compared against results of similar models) by arecognized, competent organization, or an appropriatepeer review group.

4) All plausible sources of model uncertainty, such asstructural uncertainty or parameter uncertainty, shall beassessed using recognized statistical approaches suchas those described in 2006 IPCC Guidelines for Na-tional Greenhouse Gas Inventories, Volume 1, Chapter3.

5) Models shall have comprehensive and appropriate re-quirements for estimating uncertainty in keeping withIPCC or other appropriate guidance, and the modelshall be calibrated by parameters such as geographiclocation and local climate data.

6) Models shall apply conservative factors to discount formodel uncertainty (in accordance with the requirementsset out in Section 4.1.4), and shall use conservative as-

models are not further specified (e.g. methodologypage 22).


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sumptions and parameters that are likely to underesti-mate, rather than overestimate, the GHG emission re-ductions or removals.

Note – The criteria set out in (2)-(6) above are targeted atmore complex models. For simple models, certain of thesecriteria may not be appropriate, or necessary to the integrityof the methodology. Such criteria may be disregarded,though the onus is upon the methodology developer todemonstrate that they are not appropriate or necessary.In the case the VCS Program methodology uses defaultfactors and standards to ascertain GHG emission data andany supporting data for establishing baseline scenarios anddemonstrating additionality, is the following applied:

1) Where the methodology uses third party default factorsand/or standards, such default factors and standardsshall meet with the requirements for data set out in Sec-tion 4.5.6, mutatis mutandis.

2) Where the methodology itself establishes a default fac-tor, the following applies:a) The data used to establish the default factor shall

comply with the requirements for data set out inSection 4.5.6, mutatis mutandis.

b) The methodology shall describe in detail the studyor other method used to establish the default factor.

c) The methodology developer shall identify defaultfactors which may become out of date (i.e., thosedefault factors that do not represent physical con-stants or otherwise would not be expected tochange significantly over time). Such default factorsare subject to periodic re-assessment, as set out inVCS document Methodology Approval Process.

1 The VCS Program Methodology does not require touse default factors. Nevertheless, the VCS ProgramMethodology provides requirements on the selectionof default factors in order to minimize uncertainty insection 9.3.2 and 9.3.3 respectively.


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3) Where methodologies allow project proponents to es-tablish a project-specific factor, the methodology shallprovide a procedure for establishing such factors.

In the case proxies are used, is it demonstrated that theyare strongly correlated with the value of interest and thatthey can serve as an equivalent or better method (eg, interms of reliability, consistency or practicality) to determinethe value of interest than direct measurement of the valueitself?

1 GEST (Greenhouse gas Emission Site Type), whichincludes also the water table in case of bare peat, canbe used as proxy to estimate GHG emissions and re-ductions.

Clarification Request 1.Clarify how it is ensured that the correlation betweenGEST types and emissions in a particular project areactually given:

Clarify if validation of the models are required

Clarify how well GEST types reflect successionprocess (e.g. in terms of rewetting of previouslydrained area or vice versa (in the baseline)

CR

Does the VCS Program methodology use a standardizedmethod (i.e., performance method or activity method) or aproject method to determine additionality and/or the credit-ing baseline,and does the VCS Program methodology state which typeof method is used for each?

A project method is a methodological approach that uses aproject-specific approach for the determination of addition-ality and/or crediting baseline.

1 For the determination of the additionality and the base-line the methodology requires the application of a toolapproved by the VCS.Thus, the methodology uses a project method to de-termine additionality and the crediting baseline.

Methodologies may use any combination of project, perfor-mance or activity methods for determining additionality andthe crediting baseline.

Does the VCS Program methodology provide only onemethod (i.e., a project method or performance method) fordetermining the crediting baseline (i.e., methodologies shallnot provide the option of using either a project method or aperformance method for the crediting baseline)?

1 The methodology uses only a project method for de-termining the crediting baseline as required by thestandard.


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General requirements (AFOLU v3.4 Section 4.1)Are the standards and factors used by the VCS Programmethodology to derive GHG emissions data as well as anysupporting data for baseline scenarios and additionalitypublicly available and come from a reputable and recog-nized source, such as IPCC 2006 Guidelines for NationalGHG Inventories or the IPCC 2003 Good Practice Guide-lines for Land Use, Land-Use Change and Forestry?

1 The VCS Program methodology does not provide fac-tors to be used by the methodology.Potential PPs are free to use default factors. The VCSProgram Methodology provides requirements on theselection of default factors in order to minimize uncer-tainty in section 9.3.2 and 9.3.3 respectively.

Eligible AFOLU Wetlands Restoration and Conservation(WRC) Category (AFOLU v3.4 Section 4.2)Do the applicability conditions of the VCS Program method-ology allow WRC activities that increase net GHG removalsby restoring wetland ecosystems or that reduce GHG emis-sions by rewetting or avoiding the degradation of wetlands?

Does the VCS Program methodology require that the pro-ject area meets an internationally accepted definition ofwetland, such as from the IPCC, Ramsar Convention onWetlands, those established by law or national policy, orthose with broad agreement in the peer-reviewed scientificliterature for specific countries or types of wetlands?

Common wetland types include peatland, salt marsh, tidalfreshwater marsh, mangroves, wet floodplain forests, prairiepotholes and seagrass meadows. WRC activities may becombined with other AFOLU project categories, as furtherexplained in Section 4.2.20 of the AFOLU requirements.

1 The applicability conditions allow WRC activities thatincrease net GHG removals by restoring wetland eco-systems.

The VCS Program Methodology requires that the pro-ject area meets the definition of peatland provided bythe VCS Program Definitions Version 3.5.

CR 3

Avoiding the degradation or conversion of a wetland can re-duce GHG emissions by preventing the release of carbonstored in wetland soils and vegetation. Many wetlands relyon a natural supply of sediments to support soil formation.Sediment supply may be interrupted by a physical alterationto the landscape, such as a river diversion, canal construc-tion or isolation of wetlands behind man-made structures(eg, road or rail embankments, levees or dams).

1 The methodology requires that project activities affectthe hydrology of the project area. It is assumed, that,by affecting the hydrology soil carbon stock will beaccumulate or maintained.


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Restoring wetland ecosystems reduces and/or removesGHG emissions by creating the necessary physical, biologi-cal or chemical conditions that enhance carbon sequestra-tion.

Do the applicability conditions of the VCS Program method-ology allow activities that affect the hydrology of the projectarea and the changes in hydrology result in the accumula-tion or maintenance of soil carbon stock?Does the VCS Program methodology fall under the AFOLUproject category Wetlands Restoration and Conservation(WRC) / Restoring Wetland Ecosystems (RWE) as it in-cludes:1) Activities that reduce GHG emissions or increase car-

bon sequestration in a degraded wetland through resto-ration activities. Such activities include enhancing, cre-ating and/or managing hydrological conditions, sedi-ment supply, salinity characteristics, water qualityand/or native plant communities. For the purpose ofthese requirements, restoration activities are those thatresult in the reestablishment of ecological processes,functions, and biotic and/or abiotic linkages that lead topersistent, resilient systems integrated within the land-scape, noting the following:

a) Restoration or management of water table depth(eg, the rewetting of peatlands, the reintroduction ofriver flows to floodplains, or the reintroduction oftidal flows to coastal wetlands) implies long-termand measurable changes in water table depth thatsequester carbon and/or reduce emissions. Meth-odologies shall establish the appropriate change inwater table depth (such as raising, lowering or re-storing hydrological function) that is expected for el-igible project activities, considering the followingbaseline scenario conditions:

1 The methodology falls under the AFOLU project cate-gory Wetland Restoration and Conservation (WRC) /Restoring Wetland Ecosystems (RWE) as it aims toreduce net GHG emissions by reducing oxidation anddecreasing the rate of peat subsidence through the es-tablishment of a permanent higher water level ondrained peatlands.


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i. Drained wetlands have a water table depth thatis lower than the natural average annual watertable depth due to accelerated water loss or de-creased water supply resulting from human ac-tivities and/or construction, either on- and/or off-site. Baseline activities include purposefuldraining through pumping, ditching, streamchannelization, levee construction, and pur-poseful decreases in water supply throughdams and water diversions. Examples of this in-clude selectively logged peatland swamp for-ests in Southeast Asia impacted by logging ca-nals or wetlands with water tables lowered foragriculture.Activities shall raise the average annual watertable depth in a drained wetland by partially orentirely reversing the existing drained state. Re-wetting does not require the restoration of theaverage annual water table depth to the level ofthe soil or peat surface. However, RWE pro-jects shall raise the water table depth close tothe surface in order to be eligible to generateGHG credits. A clear relationship between GHGemissions and water table depth in wetlands,including peatlands4 has been established inscientific literature with most changes in emis-sions occurring with water table depths close tothe surface. This relationship is most dramaticon highly-organic soils (eg, peatland). On suchsites, activities that establish a higher water ta-ble depth compared to the baseline scenariocan be eligible where they measurably de-crease the rate of soil subsidence due to oxida-tion to decrease or cease within the projectcrediting period, and where the permanence re-quirements set out in Section 4.5.27 can be sat-isfied.


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ii. Impounded wetlands have a water table thathas been artificially raised, intentionally or unin-tentionally, as a result of impaired natural drain-age behind a constructed feature and can resultin CH4 emissions. Examples of impounded wet-lands include flooded areas behind artificial bar-riers to natural drainage (such as road or railembankments or levees), flooded areas for thepurpose of subsidence reversal, man-madereservoirs and fish and shrimp ponds.Activities that restore hydrological function to animpounded wetland or lower the water tabledepth shall restore hydrological flow, consider-ing the dynamics of the system and the hydro-logical connectivity necessary to maintain car-bon stock and GHG fluxes.

iii. Open water is an area continuously flooded orsubject to natural periods of flooding, without in-situ vegetation contributing to soil carbon accu-mulation. Wetlands convert to open water in re-sponse to impaired sediment supply, sea levelrise and/or impaired water quality.Activities that restore hydrological function to anopen water wetland shall restore the hydrologi-cal flow, considering the dynamics of the sys-tem and the hydrological connectivity neces-sary to maintain carbon stock and GHG fluxes.

b) RWE projects may generate GHG credits from thereduction of GHG emissions associated with avoid-ing peat fires on drained or partially drained peat-lands. Fire-related activities on peatlands that ex-clude rewetting as part of the project are not eligi-ble, because fire reduction activities on drained


on GESTs

Annex 1 - 10


FinalConcl

peatland are unlikely to be effective over the longterm without rewetting.

1. SourcesDoes the VCS Program methodology indicate key docu-ments, methodologies and/or projects upon which the pro-posed methodology /revision is based?Are any modules or tools identified to which the methodol-ogy/revision refers?Is information on author of methodology/revision included, ifdesired?

1 The methodology makes use of (part of) the followingapproved methodologies and methodological tools: A/R CDM consolidated baseline and monitoring

methodology AR-ACM0001 “Afforestation or refor-estation of degraded land”

A/R CDM Methodological tool “Combined tool toidentify the baseline scenario and demonstrate ad-ditionality in A/R CDM project activities”

A/R CDM methodological tool: “Calculation of thenumber of sample plots for measurements withinA/R CDM project activities”

A/R CDM methodological tool: “Tool for testingsignificance of GHG emissions in A/R CDM pro-ject activities”

In case there is a conflict between the CDM toolrequirements and the VCS rules, the VCS ProgramMethodolgy requires that VCS rules must be followed,as outlined in AFOLU Guidance: “Additional guidancefor VCS Afforestation, Reforestation and Revegetationprojects using CDM Afforestation/ReforestationMethodologies”

This methodology uses the latest versions of the fol-lowing module: VCS module VMD0019 “Methods to project future

conditions”

2. Summary Description of the MethodologyDoes the VCS Program methodology provide a brief sum-mary description of the methodology/revision, including themain methodological steps?

1 The methodology provides a brief summarydescription of:1. Scope2. Proxies to be applied


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3. Procedures to be applied4. Inclusion of transient peaks of CH3 that might

occur5. Addressing of anthropogenic peat fires6. Leakage7. Determination of project’s net GHG benefits

Does the VCS Program methodology indicate in the tablebelow whether the methodology uses a project, perfor-mance or activity method for determining additionality, anda project or performance method for determining the credit-ing baseline (see the VCS Standard for further informationon these methods)?

Additionality<Project/Performance/Activity Method>

CreditingBaseline

<Project/PerformanceMethod>

1 The methodology uses a project methodology todetermine additionality and the crediting baseline. Thetable foreseen for the mentioned indication is used asrequired.

3. DefinitionsDoes the VCS Program methodology provide definitions ofkey terms and acronyms that are used in the methodol-ogy/revision?

1 Corrective Action Request 1.Ensure that all key terms and acronyms used in themethodology are listed as required e.g. PDT, NEE,NEP, etc.

CAR

4. Applicability ConditionsApplicability conditions (VCS v3.5 Section 4.3)Does the VCS Program methodology identify the project ac-tivities to which it applies?

1 The methodology clearly identifies that it applies to:Projects that rewet peatlands that have been drainedfor forestry that is not or no longer profitable (asdetermined on the basis of annual reports, annualaccounts, market studies, government studies, or landuse planning reports and documents), or peatextraction that has been abandoned at least 2 yearsprior to the project start date, or agriculture that has

CR


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been abandoned at least 2 years prior to the projectstart date or will be continued in the project scenario,or where drainage of additional peatland for newagricultural sites will not occur or is prohibited by law.Post-rewetting land use is limited to forestry (includingbiomass production but excluding IFM and REDDactivities), agriculture (excluding ALM activities),nature conservation/recreation, or a combination ofthese activities. Peat extraction does not occur.

Clarification Request 2.Applicability condition (page 5-6):

a) Define the term “agriculture”; clarify what kind of im-pact agriculture will have on uncertainty when ap-plying the GEST approach

c) Clarify how it is ensured that collection of fire wooddoes not lead to leakage

d) i) l) Specify the consequence if burning of biomassand peatland or the use of N-fertilizer does occur inthe project scenario (e.g. how can a project lose itseligibility after starting?) Clarify if these are actuallyapplicability conditions, or should rather be moni-tored

e) f) g) j) Clarify if these requirements are applica-bility conditions (it might rather be a description ofthe project implementation than an applicabilityconditions)

k) Clarify the meaning of “can” in the applicability con-dition k


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Clarify if N2O emissions will generally decline un-der all preconditions in terms of dryness at start ofrewetting activity

Clarify if further applicability conditions are required toencompass the limitations of GEST (e.g. water tablesbelow 30 cm)

Does the VCS Program methodology establish criteria thatdescribe the conditions under which the methodology can(and cannot, if appropriate) be applied?

1 The methodology lists 13 applicability conditions underwhich the methodology is applicable

Does the VCS Program methodology apply any applicabilityconditions set out in tools or modules?

1 n.a. n.a. n.a.

5. Project BoundaryProject boundary (VCS v3.5 Section 4.4)Does the VCS Program methodology include determinationcriteria or procedures for describing the project boundary?

1 The methodology distinguishes between geographicboundaries and temporal boundaries.

Temporal boundaries:

Project Crediting Period.PPs have to determine the project crediting period, theproject crediting period start date and the project startdate. Further are PPs obliged to provide evidenceshowing that the area was not drained or converted tocreate GHG credits unless a conversion took place be-fore 1 January 2008.

Peat Depletion TimePeat depletion may be accelerated by peat fires and isattained if the peat has disappeared or if a stablewater table inhibits further oxidation of the peat.

Geographic boundaries:As geographic boundaries are determined by:

1. Stratification

CR 6


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Strata are to be defined on the basis of peat depth ,water table depth (e.g. at 0 cm defining a level of zeroemission, a deep water table depth defining the highend of emissions, and arbitrary levels in between), treecover and/or vegetation composition, or expectedchanges in these.The project area is require to be stratified by peatdepth. The methodology provides requirements a) toc) for the stratification.Requirements are provided to create a peat depthmap.Strata must be spatially discrete and identifiablerespectively.Baseline stratification must remain fixed until areassessment of the baseline scenario occurs.The area of channels and ditches must be quantifiedand treated as separate strata.

2. Peatland areas eligible for carbon creditingThe maximum eligible quantity of GHG emissionreductions by rewetting is limited to the differencebetween the remaining peat carbon stock in theproject and baseline scenarios after 100 years (totalstock approach), or the difference in cumulativecarbon loss in both scenarios over a period of 100years since project start (stock loss approach).

3. Buffer zonesUnder the applicability condition of this methodology,the project boundary must be designed such that theproject GHG benefits are not affected by drainageactivities that occur outside the project area (e.g.enhanced drainage, groundwater extraction, andchanging water supply). This can be achieved either


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by an appropriate design (e.g. by establishing animpermeable dam) or by a buffer zone within theproject boundary for which conservatively no GHGbenefits are accounted. This buffer zone, if employed,must be mapped and is not eligible for carboncrediting.

Clarification Request 3.Ad 1: Stratification: Clarify why it is conservative to include areas that

are shallower than required as long as they areconnected to areas that meet the requirements?

Ad 3 Buffer zones (p 11/12): Provide guidance for the establishment of a buffer

zoneClarify which parameters need to be monitored inorder to ensure/proof, that extensive drainage out-side the project are does not affect the water levelwithin the project area.

Does the VCS Program methodology include determinationcriteria or procedures for identifying and assessing GHGsources, sinks and reservoirs relevant to the project (con-trolled by the project proponent, related to the project or af-fected by the project) and the baseline scenarios?

1 The methodology provides procedures for identifyingand assessing GHG sources, sinks and reservoirsrelevant to the project activity and the baselinescenario.

Does the VCS Program methodology give a justification forGHG sources, sinks and reservoirs included or excluded?

1 The methodology gives plausible justifications for theGHGs selected.

In identifying GHG sources, sinks and reservoirs relevant tothe project does the VCS Program methodology set out cri-teria and procedures for identifying and assessing GHGsources, sinks and reservoirs that are controlled by the pro-ject proponent, related to the project or affected by the pro-ject (i.e., leakage)?

1 The methodology provided and explains possiblesources of leakage in Section 8.4.


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In identifying GHG sources, sinks and reservoirs relevant tothe baseline scenario, does the VCS Program methodol-ogy:

1) Set out criteria and procedures used for identifying theGHG sources, sinks and reservoirs relevant for the project?

2) Where necessary, explain and apply additional criteria foridentifying relevant baseline GHG sources, sinks and reser-voirs?

3) Compare the GHG sources, sinks and reservoirs identi-fied for the project with those identified in the baseline sce-nario, to ensure equivalency and consistency?

1 Requirements 1) and 2) see comments above.

Corrective Action Request 2.Apply the table format provided by the VCS Methodol-ogy Template

CAR

B 3 Project Boundary (AFOLU v3.4 Section 4.3)Does the VCS Program methodology include the relevantcarbon pools as per VCS requirement?

Aboveground tree biomass YAbove-ground non-tree biomass OBelow-ground biomass OLitter NDead wood OSoil YWood products O

Y: Carbon pool shall be included.S: Carbon pool shall be included when significantN: Carbon pool does not have to be included,O: Carbon pool is optional

1 The methodology includes aboveground tree biomass,aboveground non-tree biomass as part of GEST,below ground tree biomass, Litter as part of GESTand soil in line with the VCS requirement for PRCmethodologies.

Corrective Action Request 3.Provide description why pools” Wood products” and“Dead Wood” are optional for project developers ap-plying the methodology); or provide justification whycarbon pools can be excluded.

CAR

Does the VCS Program methodology establish the criteriaand procedures by which a pool or GHG source may be de-termined to be de minimis (less than 5% of total GHG bene-fit)?

1 The methodology provides criteria and proceduresby which a pool of GHG source may be determinedto be de minimis.This might be either peer reviewed literature or theCDM A/R methodological tool “Tool for testing


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For example, peer reviewed literature or the CDM A/Rmethodological tool for testing significance of GHG emis-sions in A/R CDM project activities may be used to deter-mine whether decreases in carbon pools and increases inGHG emissions are de minimis

Further, the following GHG sources may be deemed deminimis and need not be accounted for:

2) ARR, IFM, REDD, ACoGS and WRC: GHG emissionsfrom the removal or burning of herbaceous vegetation andcollection of non-renewable wood sources for fencing of theproject area.

3) ARR, IFM, REDD, ACoGS and WRC: Fossil fuel com-bustion from transport and machinery use in project activi-ties. Where machinery use for selective harvesting activitiesmay be significant in IFM project activities as compared tothe baseline or where machinery use for earth moving activ-ities may be significant in WRC project activities as com-pared to the baseline, emissions shall be accounted for ifabove de minimis, in accordance with this Section 4.3.4.Fossil fuel combustion from transport and machinery use inrewetting of drained peatland and conservation of peatlandproject activities need not be accounted for.

significance of GHG emissions in A/R CDM projectactivities”.

Does the VCS Program methodology establish criteria andprocedures by which a project proponent may determine acarbon pool or GHG source to be conservatively excluded?

Specific carbon pools and GHG sources do not have to beaccounted for if their exclusion leads to conservative esti-mates of the total GHG emission reductions or removals gen-erated.

1 The methodology conservatively neglectedaccumulation of peat in the project scenario.Burning of biomass is conservatively not accounted forin the baseline.

Reductions of N2O and/or CH4 emissions are eligible forcrediting if in the baseline scenario the project area would

1 n.a. n.a. n.a.


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have been subject to livestock grazing, rice cultivation, burn-ing and/or nitrogen fertilization.Reductions of CH4 emissions are eligible for crediting if firewould have been used to clear the land in the baseline sce-nario.

1 Burning of biomass is conservatively not accounted forin the baseline.

Does the VCS Program methodology include CH4 emis-sions in the project boundary?

As transient peaks of CH4 may arise after rewetting peatland.

1 CH4 is accounted for as emission spike upon re-wetting is likely to occur during the transient period.

Corrective Action Request 4. Clarify if CH4 emissions occur exclusively in a

transient phase or if under certain circumstances apermanent CH4 emisson can be launched byrewetting activities.

Provide procedures for the quantification ofpossible spikes of CH4 emission.

Clarify if the exclusion of CH4 emissions of chan-nels and ditches in the project scenario is in com-pliance with IPCC guidelines and conservative

CAR 5

Does the VCS Program methodology establish the criteriaand procedures by which the CH4 source may be deemedde minimis or conservatively excluded (see also require-ments above)?

1 See comment above. See com-mentabove

Does the VCS Program methodology establish the criteriaand procedures by which the N2O source may be deemedde minimis or conservatively excluded (see also require-ments above)?

For RWE projects, N2O emissions shall be included in theproject boundary.

1 N2O is not accounted for, as those emissions will de-cline in the project scenario compared to the baselinescenario. Therefore, N2O emissions are assumed notto be accounted for.Potential PPs are obliged to demonstrated the declineof N2O emissions under the project circumstances

Corrective Action Request 5.Specify the process/requirements to demonstrate thedecline N2O in the project scenario as assumed in themethodology

CAR 6

6. Procedures for Determining the baseline scenario


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Baseline Scenario (VCS v3.5 Section 4.5)Does the VCS Program methodology establish criteria andprocedures for identifying alternative baseline scenariosand determining the most plausible scenario, taking into ac-count:

1) The identified GHG sources, sinks and reservoirs.2) Existing and alternative project types, activities and

technologies providing equivalent type and level ofactivity of products or services to the project.

3) Data availability, reliability and limitations.4) Other relevant information concerning present or fu-

ture conditions, such as legislative, technical, eco-nomic, socio-cultural, environmental, geographic,site-specific and temporal assumptions or projec-tions?

1 The methodology requires the application of the mostrecent version of the VCS Tool: “Tool for thedemonstration and assessment of additionality in VCSagriculture, forestry and other land use (AFOLU)project activities” for identifying the potentialalternative baseline land use scenarios in the projectboundary


Baseline Scenario (AFOLU v3.4 Section 4.4)Does the VCS Program methodology follow an internation-ally accepted GHG inventory protocol, such as the IPCC2006 Guidelines for National GHG Inventories when deter-mining and establishing a baseline scenario?

1 See comment above

Do the criteria and procedures identified by the VCS pro-gram methodology for identifying alternative RWE baselinescenarios take into account:

1) The current and historic hydrological characteristics ofthe watershed or coastal plain, and the drainage sys-tem in which the project occurs.

2) The long-term average climate variables influencingwater table depths and the timing and quantity of waterflow. The long-term average climate variables shall bedetermined using data from climate stations that arerepresentative of the project area and shall include atleast 20 years of data.

1 1) The methodology requires the application of themost recent version of the VCS Tool: “Tool for thedemonstration and assessment of additionality inVCS agriculture, forestry and other land use(AFOLU) project activities” for identifying thepotential alternative baseline land use scenariosin the project boundary

2) The VCS Project Methodology requires the inclu-sion of long-term average climate variables up toat least 20 years


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3) Planned water management activities (such as damconstruction)?

Do the criteria and procedures identified by the VCS pro-gram methodology for identifying alternative RWE baselinescenarios also consider relevant non-human induced re-wetting brought about by:

1) Collapsing dikes or ditches that would have naturallyfailed over time without their continued maintenance.

2) Progressive subsidence of deltas or peatlands leadingto a rise in relative water table depths, thus reducingCO2 emissions but possibly increasing CH4 emissions infreshwater systems.

3) Non-human induced elevation of non-vegetated wet-lands to build vegetated wetlands. Deltaic systems withhigh sediment load from rivers often do this naturally,and this should be counted as part of the baseline?

1 In section 8.1.3.1 the VCS Program Methodologyrequires:1) In case of abandonment of pre-project land use in

the baseline scenario, the baseline scenario mustalso consider - based on expert judgment takingaccount of verifiable local experience and/orstudies and/or scientific literature and in aconservative way - non-human induced rewettingbrought about by collapsing dikes or ditches thatwould have naturally closed over time, andprogressive subsidence, leading to raising relativewater levels, increasingly thinner aerobic layersand reduced CO2 emission rates.

2) Unless alternative evidence is provided, annualsubsidence (as derived from subsidence - watertable observations or models) must be assumed toresult in a 1:1 proportional rise the water tablerelative to the surface in the area between ditches.

Clarification Request 4.Explain the 1 : 1 proportional rise assumed.

3) N.a.

CR

Do the criteria and procedures identified by the VCS pro-gram methodology for identifying fire in the baseline sce-nario require: to demonstrate with fire maps and historical databases

on fires that the project area is now and in future wouldbe under risk of anthropogenic fires?

to consider any relevant current and planned land useconditions that may affect the occurrence of fire in order

1 THE VCS Program Methodology addressesanthropogenic peat fires occurring in drained peatlandand establishes a conservative default value, basedon fire occurrence and extension in the project area inthe baseline scenario, so as to avoid the directassessment of GHG emissions from fire in thebaseline and the project scenarios.

To do so PPs have to provide:


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to establish the most plausible scenario for fire in thebaseline.

evidence using statistics and/or maps in officialreports and/or remotes sensing data over the 10-year period ending 2 years before the project startdate;

current and historic fire statistics and/or fire mapsfor the project area, in combination withinformation on current and future land use in orderto prove that the project area is now, and in futurewill be, under risk of anthropogenic peat fires, asdemonstrated by

Many land use activities on wetlands (eg, aquaculture andagriculture) involve the exposure of wetland soils to aerobicdecomposition through piling, dredging (expansion of exist-ing channels) or channelization (cutting through wetlandplains). Where relevant, WRC baseline scenarios shall ac-count for such processes as they expose disturbed carbonstocks to aerobic decomposition thus increasing the rate oforganic matter decomposition and GHG emissions that maycontinue for years from the stockpiles.

Does the VCS Program methodology include credible meth-ods for quantifying and forecasting GHG emissions fromsuch degradation?

1 Activities involving the exposure of wetland soils toaerobic decomposition are not allowed by theapplicability conditions defined by the methodology

Where relevant, are PPs required to take account of hydro-logical processes that lead to increased carbon burial andGHG reductions within the project area when identifying theWRC baseline scenarios?

Such processes include changes in the landscape form (ie,construction of levees to constrain flow and flooding pat-terns or dams to hold water) and changes in land surface(i.e., forest clearing, and ditching or paving leading to inten-sified run-off).

1 PPs are required to collect data historic data of land useand drainage systems, etc.

Where relevant, are PPs required to take account of pro-cesses within the project area that reduce sediment supply

1 See above


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associated with changes in the landscape (e.g., construc-tion of upstream dams or stabilization of eroding feedercliffs along the coast) when identifying the WRC baselinescenario?

The supply of sediment varies over time and the time-aver-aged delivery of sediment shall be considered.Where relevant, does the VCS Program methodology es-tablish criteria and procedures for identifying wetland ero-sion and/or migration resulting from sea level rise in thebaseline scenario on the basis of wetland maps, historicaltrend data, future projection of sea level rise and howchanges in management would impact carbon stocks.

1 n.a.

Where relevant, do the criteria and procedures identified bythe VCS program methodology for identifying alternativebaseline scenarios require the project proponent to takeinto account current and historic management activities out-side the project area that have significantly impacted or maysignificantly impact the project area, including the following:

1) Disruption to or improvement of natural sediment deliv-ery, as this will alter the rate and magnitude of coastalwetlands response to sea level rise.

2) Upstream dam construction, as this will alter water andsediment delivery, as well as salinity in coastal low-lands.

3) Construction of infrastructure inland of coastal wet-lands, as this will impair wetland capacity to migratelandwards with sea level rise.

4) Construction of coastal infrastructure, as this can impairsediment movement along shorelines causing wetlandloss and increasing risk of carbon emissions with sealevel rise.

1 Under the applicability condition of this methodology,the project boundary must be designed such that theproject GHG benefits are not affected by drainage ac-tivities that occur outside the project area (e.g. en-hanced drainage, groundwater extraction, and chang-ing water supply).


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7. Procedure for demonstrating additionalityA 5 Additionality (VCS v3.5 Section 4.6)Does the VCS Program methodology assess additionalityby doing one of the following:1) Referencing and requiring the use of an appropriate ad-

ditionality tool that has been approved under the VCSor an approved GHG program;

2) Developing a full and detailed procedure for demon-strating and assessing additionality directly within themethodology; or

3) Developing a full and detailed procedure for demon-strating and assessing additionality in a separate tool,which shall be approved via the methodology approvalprocess, and referencing and requiring the use of suchnew tool in the methodology?

1 The methodology requires the application of the mostrecent version of the VCS Tool: “Tool for thedemonstration and assessment of additionality in VCSagriculture, forestry and other land use (AFOLU)project activities” for identifying the potentialalternative baseline land use scenarios in the projectboundary


8. Quantification of GHG emissions and removalsQuantification of GHG emission reduction and remov-als (VCS v3.5 Section 4.7)Does the VCS Program methodology establish criteria andprocedures for quantifying GHG emissions and/or removalsand/or carbon stocks, for the selected GHG sources, sinksand/or reservoirs, separately for the project (including leak-age) and baseline scenarios?

1 The VCS Program methodology establish criteria andprocedures for quantifying GHG emissions and/or re-movals and/or carbon stocks, for the selected GHGsources, sinks and/or reservoirs, separately for theproject (including leakage) and baseline scenarios.For further details see comments below

8.1 Baseline emissionsB 5 Baseline and Project Emissions/Removals (AFOLUv3.4 Section 4.5)Does the VCS Program methodology establish proceduresto quantify the GHG emissions or removals for the baselinescenario?Does the VCS Program methodology use The IPCC 2006Guidelines for National GHG Inventories or the IPCC 2003Good Practice Guidance for Land Use, Land-Use Change

1Baseline emissions are quantified by determining car-bon stock changes in non-peat carbon pools, GHGemissions as a result of peat oxidation due to drainageor a combination of both. In addition, emissions as a

CAR 6CAR 7


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and Forestry as guidance for quantifying increases or de-creases in carbon stocks and GHG emissions?Does the VCS Program methodology require to follow theIPCC Guidelines in terms of quality assurance/quality con-trol (QA/QC) and uncertainty analysis?

The IPCC 2006 Guidelines for National GHG Inventoriesmay be referenced to establish procedures for quantifyingGHG emissions/removals associated with the following car-bon pools including:

1) Litter;

2) Dead wood;

3) Soil (methodologies may follow the IPCC guidelines forthe inclusion of soil carbon, including the guidelines that arein sections not related to forest lands); and

4) Belowground biomass (estimated using species-depend-ent root-to-shoot ratios, the Mokany et al. ratios and equa-tions, or the Cairns equations).

result of peat combustion due to peatland fires can bedetermined.

In section 8.1.2.2 of the VCS Program Methodologyprovides procedures to calculate net carbon stockchanges in tree biomass (aboveground/belowgroundbiomass) consistent with Volume 4, Chapter 2 of IPCC2006 GuidelinesIn section 8.1.3.1 and 8.1.3.2 the VCS Program Meth-odology provides procedures to estimate GHG Emis-sion due to peat drainage following the GEST ap-proach. The GEST approach utilizes documented rela-tionships between CO2 emissions and vegetationtypes which is consistent with Section 4.5.27 of theVCS AFOLU Requirements.

In section 9.3.2 of the VCS Program Methodologyguidance regarding quality assurance/quality controlmethods are provided that are consistent with Volume1, Chapter 6 of IPCC 2006 Guidelines

In sections 8.5.2 and 9.3.2 of VCS Program Methodol-ogy guidance regarding uncertainty analysis and re-duction of uncertainties are provided that follows Vol-ume 1, Chapter 3 of IPCC 2006 Guidelines

Section 9.3.3 of the VCS Program Methodology spe-cifically references Volume 1, Chapter 2 of IPCC 2006Guidelines with respect to uncertainties arising fromexpert judgment

Corrective Action Request 6.Modeling / predicting future baseline condition (pages21-22):

Provide a minimum set of requirements for the


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modeling/predicting of the water level in order toapply the GEST approach or the estimation ofGHG emissions based on water level respectively.

Define which parameters are required to calibratethe water table. Ensure that these parameters areincluded in section 9.1 of the methodology.

Provide description how future GEST types areestimated in particular over time

Corrective Action Request 7.Procedure to determine GHG emissions in the base-line with GEST (pages 21-22 and 65-69)

Provide clear procedures how to define a SiteType for GEST in the field (e.g. if vegetation isused to define a site type, which criteria must befulfilled to determine the boundary of a site type? Itshall be clearly describe to enable project devel-oper and auditors to apply such a procedure

Provide clear procedures how to determine GHGemissions in a site type (of GEST) – parametersGHGGESTbsl-CO2 and GHGGESTbsl-CH4. It shall beclearly describe to enable project developer andauditors to apply such a procedure.Clarify if additional procedure and description isrequired for natural succession, cultivated landand bare peat.

Include clear procures how to validate GHGGESTbsl-

CO2 and GHGGESTbsl-CH4

Provide clear procedures how to establish project-specific values for GHGWLbsl-CO2 and GHGWLbsl-CH4

(stepwise procedures)


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Clarify if it is required to validate emissions basedon GEST or project specific values for GHGWLbsl-

CO2 and GHGWLbsl-CH4

Provide a description on how to determine the un-certainty for GHG emission estimation related tothe GEST approach / Specify the conditions underwhich the GEST approach leads to estimations ofGHG emissions with an acceptable certainty

Provide procedures to define and justify theaccuracy defined or conservativeness in the casevalues from appropriate literature sources areapplied for GHGWLbsl-CO2 and GHGWLbsl-CH4

Emissions from fire in the baselineSee comments on page 34 below,

Where carbon would have been lost in the baseline sce-nario due to land use conversion or disturbance, GHGemissions from soil carbon, belowground biomass, woodproducts and dead wood carbon pools generally occur overa period of time following the event. It shall not be assumedthat all GHG emissions from these carbon pools in the pro-ject categories specified below occur instantaneously orwithin a short period of time.

Does the VCS Program methodology set out criteria andprocedures to reliably establish the pattern of carbon lossover time using empirical evidence, such as studies thatuse primary data or locally calibrated models,or does the VCS Program methodology apply an appropri-ate decay model (such as a linear or exponential decayfunction) that is scientifically sound, based on empirical evi-dence and not likely to overestimate early carbon losses?

1 Section 5.1 of the VCS Program Methodology pro-vides procedures to estimate the PDT.

Where appropriate, belowground biomass, soil carbon anddead wood decay models shall be calibrated.

1 n.a. n.a. n.a.


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Where models are calibrated using measurement plots ordata from research plots does the VCS Program methodol-ogy require sound and reliable measurement methods to beapplied (as set out in Section 4.8.3.)?As the Soil carbon pool is included in the project boundary,does the VCS Program methodology opt to comply with therequirement to establish a pattern of carbon loss over timeby incorporating the following procedure:

3) Is the pattern of carbon loss modeled based upon a 20-year linear decay function, taking into account the depthof affected soil layers and the total portion of the poolthat would have been lost?

1 n.a. n.a. n.a.

Does the VCS Program methodology establish criteria andprocedures for quantifying GHG emissions/removals in thebaseline scenario that:

1) For WRC activities on peatland the peat depletion time(PDT) shall be included in the quantification of GHGemissions and removals in the baseline scenario, andfor non-peat wetlands, the soil organic carbon depletiontime (SDT) shall be included in the quantification ofGHG emissions and removals in the baseline scenario,noting the following:

a) PDT is the time it would have taken for the peat tobe completely lost due to oxidation or other losses,or for the peat depth to reach a level where no fur-ther oxidation or other losses occur. No GHG emis-sion reductions may be claimed for a given area ofpeatland for longer than the PDT. The procedurefor determining the PDT shall conservatively con-sider peat depth and oxidation rate within the pro-ject boundary and may be estimated based on therelationship between water table depth, subsidence

1 1) Section 5.1 of the VCS Program Methodology pro-vides procedures to estimate the PDT. The PDThas to be reassessed every 10 years as outlinedin Section 6.2.

2) The VCS Program Methodology uses the GESTapproach and the water level to estimate GHGemissions.

3) Net baseline GHG emissions are based on the pa-rameters/values estimated as described in 1) and2)


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(eg, using peat loss and water table depth relation-ships established in scientific literature), and peatdepth in the project area. The PDT is consideredpart of the baseline and thus shall be reassessedwith the baseline in accordance with Section 3.1.10.

b) SDT is the time it would have taken for the soil or-ganic carbon to be lost due to oxidation or to reacha steady stock where no further losses occur. NoGHG emissions reductions may be claimed for agiven area of wetland for longer than the SDT. Theprocedure for determining the SDT shall conserva-tively consider soil organic carbon content and oxi-dation rate within the project boundary and may beestimated based on the relationship between watertable depth and soil organic carbon content in theproject area. Where wetland soils are subject tosedimentation or erosion, the procedure for deter-mining the SDT shall conservatively account for theassociated gain or loss of soil organic carbon. Thisassessment is not mandatory in cases where soilorganic carbon content on average may be deemedde minimis as set out in Section 4.3.4.

2) Any applicable and justifiable proxies, as established inscientific literature, for GHG emissions projectedthroughout the project crediting period shall be esti-mated.

3) Net baseline GHG emissions during the project credit-ing period, including emissions associated with the esti-mated water table depths, salinity or another justifiableproxy for GHG emissions, plus emissions from otheractivities such as biomass loss or fires, as well as car-bon sequestration, where applicable, shall be esti-mated.


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Does the VCS Program methodology require to estimatethe Baseline emissions conservatively and to consider thatthe water table depth in the project area may rise during theproject crediting period due to any or all of the causes iden-tified in alternative baseline scenarios as set out in Section4.4.11. of the AFOLU Requirements?

1 In section 8.1.3.1 the VCS Program Methodologyrequires:

In case of abandonment of pre-project land use in thebaseline scenario, the baseline scenario must alsoconsider - based on expert judgment taking account ofverifiable local experience and/or studies and/orscientific literature and in a conservative way - non-human induced rewetting brought about by collapsingdikes or ditches that would have naturally closed overtime, and progressive subsidence, leading to raisingrelative water levels, increasingly thinner aerobiclayers and reduced CO2 emission rates.

Unless alternative evidence is provided, annualsubsidence (as derived from subsidence - water tableobservations or models) must be assumed to result ina 1:1 proportional rise the water table relative to thesurface in the area between ditches.

The procedure for quantifying CO2 emissions for the base-line emissions may be estimated through hydrological mod-eling or the modeling of proxies for GHG emissions in placeof direct on-site gas flux measurements. The proceduremay include estimation through well-documented relation-ships between CO2 emissions and other variables such asvegetation types, water level or subsidence, or remotesensing techniques that adequately assess and monitor soilmoisture. Because of the dominant relationship betweenwater level and CO2 emissions, drainage depth can beused as a proxy for CO2 emissions in the absence of emis-sions data.

Where relevant, does the VCS Program methodology re-quire that the micro-topography of the project area (i.e., theproportion of hummocks and hollows and vegetation pat-terns) is considered?

1 The VCS Program Methodology does not require theconsideration of the micro-topography.

Clarification Request 5.Clarify why the micro-topography does not need to beconsidered e.g. in form of a digital terrain model whenmodeling/estimating the water table.

CR 5


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Does the VCS Program methodology calculate net GHGemissions reductions using the same methods that areused for the baseline estimates, but using monitored data.

1 Emission reductions from the project activity areestimated the same way as for the baseline scenarioon following the GEST approach and water levels inthe project area.

Where relevant, does the VCS Program methodology as-sess the fate of transported organic matter as a result ofsedimentation, erosion and oxidation conservatively basedon peer-reviewed literature and considering the following:

1) It is conservative to not account for the loss of sedimentfrom the project area in the baseline scenario.

2) It is conservative to not account for further sedimenta-tion in the project area in the project scenario. Wheresoil carbon is included in the project boundary, sedi-mentation shall be accounted for so that carbon se-questration resulting from the growth of vegetation canbe estimated separately from carbon accumulated insedimentation. In the absence of the project activity,such high carbon silt would be washed out to sea andwould not have been emitted in the baseline and assuch carbon accumulated in sedimentation is not eligi-ble for crediting

1 No loss of sediment can expected. Amounts of POCsis limited.

With respect to the soil carbon pool, the maximum quantityof GHG emission reductions that may be claimed by theproject shall not exceed the net GHG benefit generated bythe project 100 years after its start date. This limit is estab-lished because in wetlands remaining partially drained ornot fully rewetted, or where drainage continues, the soil car-bon will continue to erode and/or oxidize leading to GHGemissions and eventually depletion of the soil carbon. Todetermine this long-term net GHG benefit, projects shall es-timate the remaining soil carbon stock adjusted for any pro-ject emissions and leakage emissions in both the baselineand project scenarios at the 100-year mark, taking into ac-

1 In section 5.2 of the VCS Program Methodology a sig-nificant difference in the net GHG benefit betweenthe baseline and project scenarios for at least 100years is required.

Clarification Request 6.Specify how “significant differences” can be identified

CR 6


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count uncertainties in modeling and using verifiable as-sumptions. Projects with a PDT or SDT in the project sce-nario of less than 100 years or unable to establish anddemonstrate a significant difference in the net GHG benefitbetween the baseline and project for at least 100 years arenot eligible for crediting of the soil carbon pool.

Does the VCS Program methodology require to establishand demonstrate a significant difference in the net GHGbenefit between the baseline and project for at least 100years?Emissions of CH4 from drained or saline wetlands may beexcluded in the baseline scenario where it may be deemedde minimis (as set out in Section 4.3.4 of the AFOLU re-quirement) or conservatively excluded (as set out in Section4.3.4 of the AFOLU requirement)

1 Emissions of CH4 in the baseline scenario are ex-cluded

As WRC activities are likely to influence CH4 emissions,does the VCS Program methodology establish proceduresto estimate such emissions, and establish the criteria andprocedures by which the source may be deemed de mini-mis (as set out in Section 4.3.4) or conservatively excluded(as set out in Section 4.3.4)?

Where relevant, does the VCS Program methodology con-sider the micro-topography of the project area (ie, the pro-portion of hummocks and hollows and vegetation patterns)?

1 n.a. n.a. n.a.

Does the VCS Program methodology in case of RWE pro-jects on peatland that include an activity designed specifi-cally to reduce incidence and severity of fires deduct theamount of peat assumed to burn when estimating peat de-pletion times?

Where peat depletion times are estimated based only onoxidation rates due to drainage, the outcome would be alonger period than when first subtracting the amount of peatthat is considered to burn in the baseline.

1 Section 5.1 of the VCS Program Methodology definesa parameter to quantify peat loss due to subsidenceand fire in the baseline scenario. Project specific peatdepletion is calculated based on the value of the pa-rameter.

Clarification Request 7.Clarify if Ratepeatloss-BSL,i is constant or will vary over timedue to sagging and oxidation.

CR 7


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Does the VCS Program methodology in case of RWE pro-jects on peatland explicitly addressing anthropogenic peat-land fires occurring in drained peatlands establish proce-dures for determining or conservatively estimating the base-line emissions from peatland fire occurring in the projectarea using defensible data (such as fire maps, historical da-tabases on fires, and where appropriate, combined withtemperature and precipitation data)?

Methods for estimating GHG emissions from fire may bebased on the IPCC 2006 Guidelines for National GHG In-ventories, or other methods based on scientific, peer-re-viewed literature.

1 Section 8.3 of VCS Program Methodology contains aprocedure for estimating baseline emissions from peatland fires based on current and historic fire statisticsand or fire maps.A “Fire Reduction Premium” can be added to the totalnet GHG emission reduction if:

1. Over the 10-year period ending 2 years before theproject start date, the cumulative area of peatburnt exceeded 10% of the project area (whererepeated burning of the same area adds to thepercentage). Evidence must be provided usingstatistics and/or maps in official reports and/orremotes sensing data; and,

2. In the baseline scenario the area is now, and infuture will be, under risk of anthropogenic peatfires, as demonstrated by current and historic firestatistics and/or fire maps for the project area, incombination with information on current and futureland use; and,

3. The fire management plan proposed by the projectproponent at validation reflects the best practicesavailable with respect to fire prevention andcontrol and takes into account specific projectcircumstances; and,

4. At each verification, documentation is provideddemonstrating that fire management activitieshave been implemented according to theproposed plan.

In the case of fire the Fire Reduction Premium needsto be cancelled unless the fire event is “catastrophic”and a) the rewetting of the peatland and b) a bestpractice fire management is implemented.

Clarification Request 8.

CR 8


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Specify how “peat fire” is defined in terms of inten-sity of the fire and amount of peat burned in orderto be accountable for Fire Reduction Premium

Clarify what parameters need to be available atvalidation in order to quantify the fire reduction

Clarify based on what VCS requirements carboncredits can be generated for improved fire man-agement in the project activity, without actuallyquantifying the emission:

- As per VCS Standard 3.4 section 4.1.8 prox-ies used must be strongly correlated with thevalue of interest: clarify how this is the casewith the fire reduction premium

- VCS Standard 3.4 section 4.7.2 states that amethodology shall establish criteria and proce-dures for quantifying emissions generated bythe project, and which shall be calculated asthe difference between baseline and projectemissions. Clarify how this approach is in linewith the respective VCS requirement

Area burnt and emissions from fire shall be in-cluded as monitoring parameter in line with VCSStandard 3.4 section 4.7.2. Include formulas re-quired and define which parameters need to be in-cluded, including procedures for determining theparameters.

If emissions from fire in the baseline shall be in-cluded in the methodology, include clear proce-dure, formulas and parameters how to calculatethese baseline emissions.

Note:


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pg. 35; “Ex-ante estimate of Fire Reduction Pre-mium: The estimate of GHGwps-CO2,i,t in Equa-tion 52 must be taken from ex-ante calculations(Section 8.2.3.2)” Section 8.2.3.2 does not exist!pg. 30; Equation (41) the parameters should beGHGGESTwps,i,t and GHGWLwps-CO2,i,t respectively

Where relevant, does the VCS Program methodology es-tablish procedures to account for any changes in carbon se-questration or GHG emission reductions resulting from lat-eral movement of wetlands due to sea level rise, or coastalsqueeze associated with any structures that prevent wet-land landward migration and cause soil erosion?

1 n.a. n.a. n.a.

8.2 Project emissions / removalsBaseline and Project Emissions/Removals (AFOLUv3.4 Section 4.5)Does the VCS Program methodology establish proceduresto quantify the GHG emissions or removals for the baselinescenario?Does the VCS Program methodology use The IPCC 2006Guidelines for National GHG Inventories or the IPCC 2003Good Practice Guidance for Land Use, Land-Use Changeand Forestry as guidance for quantifying increases or de-creases in carbon stocks and GHG emissions?Does the VCS Program methodology require to follow theIPCC Guidelines in terms of quality assurance/quality con-trol (QA/QC) and uncertainty analysis?

The IPCC 2006 Guidelines for National GHG Inventoriesmay be referenced to establish procedures for quantifyingGHG emissions/removals associated with the following car-bon pools including:

1) Litter;

2) Dead wood;

1 See respective comments in section 8.1

Project emissions are quantified by determining car-bon stock changes in non-peat carbon pools, GHGemissions as a result of peat oxidation due to drainageor a combination of both. For details respective com-ments in section 8.1.

Besides the mentioned procedures the VCS ProgramMethodology provides in section 8.2.3.2 an alternativeprocedures to estimate GHG emission. The procedureis following the GEST approach but estimates the pro-ject emissions on bases of a conversion of a GEST.

Corrective Action Request 8.Estimation of project emissions:

Provide clear procedures to monitor Site Type forGEST in the field

Provide clear procedures how to monitor GHG

CAR 8 /CR 9


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3) Soil (methodologies may follow the IPCC guidelines forthe inclusion of soil carbon, including the guidelines that arein sections not related to forest lands); and

4) Belowground biomass (estimated using species-depend-ent root-to-shoot ratios, the Mokany et al. ratios and equa-tions, or the Cairns equations).

emissions for a GEST type (GHGGESTwps-CO2) andhow QA/QC procedures are applied in detail

Provide a description of the uncertainty related toGHG emission estimation using the GEST ap-proach. Clarify if validation is required.

In this regards clarify how well GEST reflectchanging conditions over time (considering thatthe vegetation need time to adopt to different siteconditions)

Provide clear procedures to establish project-spe-cific values for GHGWLwps-CO2 and GHGWLwps-CH4

(stepwise procedures)

Provide procedures to define and justify theaccuracy defined or conservativeness in the casevalues from appropriate literature sources areapplied for GHGWLwps-CO2 and GHGWLwps-CH4

Clarification Request 9. Clarify how emissions from fire in the project sce-

nario is accounted for

Where carbon would have been lost in the baseline sce-nario due to land use conversion or disturbance, GHGemissions from soil carbon, belowground biomass, woodproducts and dead wood carbon pools generally occur overa period of time following the event. It shall not be assumedthat all GHG emissions from these carbon pools in the pro-ject categories specified below occur instantaneously orwithin a short period of time.

Does the VCS Program methodology set out criteria andprocedures to reliably establish the pattern of carbon loss

1 See respective comments in section 8.1


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over time using empirical evidence, such as studies thatuse primary data or locally calibrated models,or does the VCS Program methodology apply an appropri-ate decay model (such as a linear or exponential decayfunction) that is scientifically sound, based on empirical evi-dence and not likely to overestimate early carbon losses?Where appropriate, belowground biomass, soil carbon anddead wood decay models shall be calibrated.

Where models are calibrated using measurement plots ordata from research plots does the VCS Program methodol-ogy require sound and reliable measurement methods to beapplied (as set out in Section 4.8.3.)?

1 n.a. n.a. n.a.

As the Soil carbon pool is included in the project boundary,does the VCS Program methodology opt to comply with therequirement to establish a pattern of carbon loss over timeby incorporating the following procedure:

3) Is the pattern of carbon loss modeled based upon a 20-year linear decay function, taking into account the depthof affected soil layers and the total portion of the poolthat would have been lost?

1 See respective comments in section 8.1 n.a. n.a.

The procedure for quantifying CO2 emissions for the base-line emissions may be estimated through hydrological mod-eling or the modeling of proxies for GHG emissions in placeof direct on-site gas flux measurements. The proceduremay include estimation through well-documented relation-ships between CO2 emissions and other variables such asvegetation types, water level or subsidence, or remotesensing techniques that adequately assess and monitor soilmoisture. Because of the dominant relationship betweenwater level and CO2 emissions, drainage depth can beused as a proxy for CO2 emissions in the absence of emis-sions data.

1 See respective comments in section 8.1 CR 9


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Where relevant, does the VCS Program methodology re-quire that the micro-topography of the project area (i.e., theproportion of hummocks and hollows and vegetation pat-terns) is considered?

Does the VCS Program methodology calculate net GHGemissions reductions using the same methods that areused for the baseline estimates, but using monitored data.

1 See respective comments in section 8.1 n.a.

Where relevant, does the VCS Program methodology as-sess the fate of transported organic matter as a result ofsedimentation, erosion and oxidation conservatively basedon peer-reviewed literature and considering the following:

1) It is conservative to not account for the loss of sedimentfrom the project area in the baseline scenario.

2) It is conservative to not account for further sedimenta-tion in the project area in the project scenario. Wheresoil carbon is included in the project boundary, sedi-mentation shall be accounted for so that carbon se-questration resulting from the growth of vegetation canbe estimated separately from carbon accumulated insedimentation. In the absence of the project activity,such high carbon silt would be washed out to sea andwould not have been emitted in the baseline and assuch carbon accumulated in sedimentation is not eligi-ble for crediting

1 No loss of sediment can expected. Amounts of POCsis limited.

n.a.

With respect to the soil carbon pool, the maximum quantityof GHG emission reductions that may be claimed by theproject shall not exceed the net GHG benefit generated bythe project 100 years after its start date. This limit is estab-lished because in wetlands remaining partially drained ornot fully rewetted, or where drainage continues, the soil car-bon will continue to erode and/or oxidize leading to GHGemissions and eventually depletion of the soil carbon. To



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determine this long-term net GHG benefit, projects shall es-timate the remaining soil carbon stock adjusted for any pro-ject emissions and leakage emissions in both the baselineand project scenarios at the 100-year mark, taking into ac-count uncertainties in modeling and using verifiable as-sumptions. Projects with a PDT or SDT in the project sce-nario of less than 100 years or unable to establish anddemonstrate a significant difference in the net GHG benefitbetween the baseline and project for at least 100 years arenot eligible for crediting of the soil carbon pool.

Does the VCS Program methodology require to establishand demonstrate a significant difference in the net GHGbenefit between the baseline and project for at least 100years?As WRC activities are likely to influence CH4 emissions,does the VCS Program methodology establish proceduresto estimate such emissions, and establish the criteria andprocedures by which the source may be deemed de mini-mis (as set out in Section 4.3.4) or conservatively excluded(as set out in Section 4.3.4)?

Where relevant, does the VCS Program methodology con-sider the micro-topography of the project area (ie, the pro-portion of hummocks and hollows and vegetation patterns)?

1 In sections 8.2.3.1 and 9.3.6 of the VCS ProgramMethodology procedures to estimate CH4 emissionsare provided.

Section 5.4 of the VCS Program Methodology GHGcontains procedures by which sources/emissions canbe deemed de minimis in compliance with Section4.3.3 VCS AFOLU v. 3.4

Does the VCS Program methodology in case of RWE pro-jects on peatland that include an activity designed specifi-cally to reduce incidence and severity of fires deduct theamount of peat assumed to burn when estimating peat de-pletion times?

Where peat depletion times are estimated based only onoxidation rates due to drainage, the outcome would be alonger period than when first subtracting the amount of peatthat is considered to burn in the baseline.



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Where relevant, does the VCS Program methodology es-tablish procedures to account for any changes in carbon se-questration or GHG emission reductions resulting from lat-eral movement of wetlands due to sea level rise, or coastalsqueeze associated with any structures that prevent wet-land landward migration and cause soil erosion?

1 n.a. n.a. n.a.

8.3 LeakageLeakage (AFOLU v3.4 Section 4.6)Does the VCS Program methodology establish proceduresto quantify all significant sources of leakage?

1) Market leakage occurs when projects significantly re-duce the production of a commodity causing a changein the supply and market demand equilibrium that re-sults in a shift of production elsewhere to make up forthe lost supply.Projects shall account for market leakage where theproduction of a commodity (eg, timber) is significantlyaffected by the project.

2) Activity shifting leakage occurs when the actual agentof deforestation and/or forest of wetland degradationmoves to an area outside of the project boundary andcontinues its deforestation activities elsewhere.

3) Ecological leakage occurs in WRC projects where aproject activity causes changes in GHG emissions orfluxes of GHG emissions from ecosystems that are hy-drologically connected to the project area.

1 The VCS Program Methodology does not account forleakage as under the applicability conditions as definedby the methodology (Section 4) leakage does not occur.

Section 8.4 requires potential PPs to provide verifiableinformation (such as laws and bylaws, managementplans, market reports) that in case the pre-project landuse is: forestry, this forestry is non-commercial in nature peat extraction, this activity has been abandoned

at least 2 years prior to the project start date agriculture, crop production has been abandoned

at least 2 years prior to the project start date, orwill continue in the project scenario, or drainage ofadditional peatland for new agricultural sites willnot occur or is prohibited by law

fuel wood extraction, the activity is non-commercial in nature.

The non-existence of ecological leakage is required tobe proven based on appropriate design (impermeabledam/buffer zone)

Does the VCS Program methodology determine GHG emis-sions from leakage directly from monitoring, or indirectlywhen leakage is difficult to monitor directly but where scien-tific knowledge provides credible estimates of likely impact?

1 n.a. n.a. n.a.


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Does the VCS Program methodology require that Projectsaccount for market leakage in cases where the productionof a commodity (e.g., timber, aquacultural products or agri-cultural products) is significantly affected by the project?

The significance of timber production is determined as setout in Section 4.3.4 above or as set out in Section 4.6.15.

1 n.a. n.a. n.a.

Does the VCS Program methodology quantify leakage oc-curring outside the host country (international leakage)?

International leakage does not need to be quantified.

1 n.a. n.a. n.a.

In case of leakage mitigation measures including tree plant-ing, aquacultural intensification, agricultural intensification,fertilization, fodder production, and/or other measures toenhance cropland and/or grazing land areas,, leakage man-agement zones or a combination of these does the VCSProgram methodology account for any significant increasein GHG emissions associated with these activities, unlessdeemed de minimis (as set out in Section 4.3.4 AFOLUv3.2) or can be conservatively excluded (as set out in Sec-tion 4.3.4 AFOLU v3.2)?

1 n.a. n.a. n.a.

Does the VCS Program methodology account for positiveleakage?

Projects shall not account for positive leakage (i.e., whereGHG emissions decrease or removals increase outside theproject area due to project activities).

1 n.a. n.a. n.a.

RWE projects involving rewetting of forested wetlands arelikely to reduce the productivity of the forest or make har-vesting more difficult, which could lead to fewer forest prod-ucts and thus result in leakage (ie, GHG emissions fromlogging and drainage elsewhere).

In case the VCS Program methodology allows projects toresult in activity shifting of forest products are the applicablerequirements for leakage in IFM or REDD project activities

1 n.a. n.a. n.a.


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followed, accounting for both activity-shifting and/or marketleakage?

In case the VCS Program methodology allows projects toresult in the shifting of drainage activities or other activitiesthat would lower the water table, are the expected GHGemissions from a lower water table also accounted for?

Does the VCS Program methodology require that in case ofRWE projects on peatland to assume that the PDT of leak-age activities occurs over the length of the project creditingperiod if the PDT is longer than the project crediting period?Rewetting in the project area may lead to higher water tabledepths in some areas beyond the project boundary, andconsequently leading to lower water table depths in down-stream areas further beyond the project boundary (eg, inthe case of project activities that reverse subsidence), orcause transportation of organic matter to areas beyond theproject boundary.In such cases, does the VCS Program methodology requirethe project proponent to demonstrate that such changes inwater table depths or export caused by the project do notlead to increases in GHG emissions outside the projectarea, or to identify the affected areas and to quantify and toaccount for the resulting leakage?

1 n.a. n.a. n.a.

In case of the wetland restoration project includes fire re-duction activities, does the VCS Program methodology re-quire to follow the requirements for accounting for fire underREDD, where land use changes are identified as the cause(or one of the causes) of anthropogenic fires in the projectregion?

1 n.a. n.a. n.a.

8.4 Summary of GHG Emission Reduction and/or Re-movals


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Does the VCS-Program methodology describe the proce-dure for quantifying net GHG emission reductions and/or re-movals, as a function of baseline emissions, project emis-sions and leakage, as follows:

ER = BE PE LE

Where:ERy = Net GHG emissions reductions and/or removalsin year yBEy = Baseline emissions in year yPEy = Project emissions in year yLEy = Leakage in year y

1 Total net GHG emissions are calculated in line withthe requirements of the standard as:

NERRDP = GHGBSL – GHGWPS + Fire Reduction Pre-mium – GHGLK

or according to the alternative procedure:

NERRDP = CBSL – CWPS + GHGrewetting + Fire Reduc-tion Premium – GHGLK

Corrective Action Request 9. Explain the difference between the “normal” and

the “alternative” procedure as both refer to thesame parameters.

Clarify if CBSL and CWPS (alternative procedure)need to be multiplied by 44/12

CAR

Quantification of GHG emission reduction and remov-als (VCS v3.5 Section 4.7)Does the VCS Program methodology establish criteria andprocedures for quantifying net GHG emission reductionsand removals generated by the project, which are quantifiedas the difference between the GHG emissions and/or re-movals, and/or as the difference between carbon stocks,from GHG sources, sinks and reservoirs relevant for theproject and those relevant for the baseline scenario?

Where appropriate, are net GHG emission reductions andremovals, and net change in carbon stocks, quantified sep-arately for the project and the baseline scenarios for eachrelevant GHG and its corresponding GHG sources, sinksand/or reservoirs?

1 The VCS Project Methodology describes potential cri-teria and procedures for quantifying net GHG emissionreductions and removals generated by the projectwhich are quantified as the difference between theGHG emissions and removals, and as the differencebetween carbon stocks from GHG sources, sinks andreservoirs relevant for the project and those relevantfro the baseline scenario.

Net GHG emission reductions and removals, and netchange in carbon stocks, are quantified separately forthe project and the baseline scenarios for each rele-vant GHG and its corresponding GHG sources.

Corrective Action Request 10.

CAR


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Provide clear procedures (detailed stepwise ap-proach) how to establish GESTs in order to esti-mate GHG emissions (see also CAR 8)

Based on the procedures provide information onformulas and parameters available at validationand to be monitored in order to establish GESTs

Provide clear procedures (detailed stepwise ap-proach) to establish project-specific values forGHGWLbsl-CO2 and GHGWLbsl-CH4 (see also CAR 8)

Based on the procedures provide information onformulas and parameters available at validation anto be monitored to establish project specific valuesfor GHGWLbsl-CO2 and GHGWLbsl-CH4

Quantification of GHG emission reductions and remov-als (AFOLU v3.4 Section 4.7)Does the VCS Program methodology establish proceduresfor quantifying net GHG emission reductions and removals(the net GHG benefit), which shall be quantified as the dif-ference between the GHG emissions and/or removals fromGHG sources, sinks and carbon pools in the baseline sce-nario and the project scenario?

1 See comment above See com-mentabove

Does the VCS Program methodology require that the GHGemissions and/or removals in the project scenario are ad-justed for emissions resulting from project activities andleakage?

1 The GHG emissions and/or removals identified for theproject scenario result from project activities as re-quired.

Does the VCS Program methodology establish proceduresfor quantifying the net change in carbon stocks, so that thenumber of buffer credits withheld in the AFOLU pooledbuffer account and market leakage emissions may be quan-tified for the project?

1 The methodology provides procedures to quantify thenet change in carbon stocks as required.

9. Monitoring9.1 Data and Parameters Available at ValidationDoes the VCS Program methodology provide specificationfor data and parameters not monitored (i.e., that will be

1 The methodology provides specification for data andparameters not monitored.

CAR


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available at validation). Is the table copied for each dataunit/parameter?

Data Unit / Parameter:

Data unit:

Description:

Source of data:

Justification of choice of data or descriptionof measurement methods and proceduresapplied:

Any comment:

The table provided by the methodology template v3.2is applied as required.


List all parameters available at validation are in-cluded e.g. waterways, fire, drainage structures,climate variables, etc.

Clarify if Root Shoot Ratios to be found in IPCCGPG 2003, Annex 3.A1, Table 3A1.8 are applica-ble for wetland conditions.

Ensure that detailed descriptions of procedures tobe applied are provided (in particular for GHG-GESTbsl-CO2,i,t, GHGWLbsl-CO2,i,t,

9.2 Data and Parameters MonitoredDoes the VCS Program methodology provide specificationfor data and parameters monitored (i.e., that will be availa-ble at validation. Is the table copied for each data unit/pa-rameter?

Data Unit / Parameter:

Data unit:

Description:

Source of data:

Description of measurement methods andprocedures to be applied:

Frequency of monitoring/recording:

QA/QC procedures to be applied:

Any comment:

1 The methodology provides specification for data andparameters not monitored.The table provided by the methodology template v3.2is applied as required.


List if all parameters to be monitored are listed.E.g. water, leakage, fire, etc.

Ensure that detailed descriptions of procedures tobe applied at monitoring are provided (in particularfor GHGGESTwps-CO2,i,t, GHGWLwps-CO2,i,t, insufficientinformation is provided regarding obtaining thisdata, assessing uncertainty, etc)

CAR


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Does the VCS Program methodology identify how thedata/parameter is measured? Is equipment specificationsprovided, if applicable?

1 The VCS Program methodology identify how thedata/parameter is measured.Equipment specifications provided, where applicable.

Does the VCS Program methodology identify measurementand recording frequency

1 The VCS Program methodology identifies measure-ment and recording frequency.

Does the VCS Program methodology identify calibration in-formation such as frequency, date of last calibration and va-lidity

1 n.a. n.a. n.a.

Data and Parameters (VCS v3.5 Section 4.8.1)Does the VCS Program methodology describe the data andparameters to be reported, including sources of data andunits of measurement?

1 The VCS Program methodology describes the dataand parameters to be reported, including sources ofdata and units of measurement.

Do standards and factors used by the VCS Program meth-odology to derive GHG emission data meet the following re-quirements?1) Be publicly available from a reputable and recognized

source (e.g., IPCC, published government data, etc).2) Be reviewed as part of its publication by a recognized

competent organization.3) Be appropriate for the GHG source or sink concerned.4) Be current at the time of quantification.

1 In section 9.3.2 of the VCS Program Methodology re-quirements regarding the sources of data/parame-ters/values applied that are consistent with Volume 1,Chapter 2 of IPCC 2006 Guidelines.Guidance regarding quality assurance/quality controlmethods are provided that are consistent with Volume1, Chapter 6 of IPCC 2006 Guidelines

When highly uncertain data and information are relied upon,does the VCS Program methodology select conservativevalues that ensure that the quantification does not lead toan overestimation of net GHG emission reductions or re-movals?

1 In section 9.3.2 of the VCS Program Methodologyguidance regarding quality assurance/quality controlmethods are provided that are consistent with Volume1, Chapter 6 of IPCC 2006 Guidelines.

Section 9.3.3 of the VCS Program Methodology spe-cifically references Volume 1, Chapter 2 of IPCC 2006Guidelines with respect to uncertainties arising fromexpert judgment.

Does the VCS Program methodology use metric tonnes asthe unit of measure?

1 The methodology uses metric tonnes as unit of meas-urement as required.


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Does the VCS Program methodology convert the quantity ofeach type of GHG to tonnes of CO2e?Consistent with UNFCCC accounting, the six Kyoto Proto-col greenhouse gases shall be converted using 100 yearglobal warming potentials derived from the IPCC’s SecondAssessment Report (which are also available and reprintedin the Fourth Assessment Report). Ozone-depleting sub-stances shall be converted using 100 year global warmingpotentials from the Fourth Assessment Report, which pro-vides a full set of factors relevant to ODS methodologiesand projects.

1 The methodology convert the quantity of each type ofGHG to tonnes of CO2e

Corrective Action Request 13.Clarify if CBSL and CWPS need to be multiplied by44/12

CAR

Does the VCS Program methodology establish criteria andprocedures for monitoring, which shall cover the following:

1) Purpose of monitoring.2) Monitoring procedures, including estimation, modelling,

measurement or calculation approaches.3) Procedures for managing data quality4) Monitoring frequency and measurement procedures.

1 See comments above in section 9.1 Data and Param-eters Available at Validation and 9.2 Data and Param-eters Monitored.

CAR 12,CAR 13

Monitoring (AFOLU v3.4 Section 4.8)Does the VCS Program methodology establish criteria andprocedures for monitoring, and specify the data and param-eters to be monitored, as set out in the VCS Standard?

1 See comments above in section 9.1 Data and Param-eters Available at Validation and 9.2 Data and Param-eters Monitored.

CAR 12,CAR 13

Does the VCS Program methodology require to monitorLeakage as set out in Section 4.6.?

1 Leakage does not occur due to applicability conditions.

Where measurement plots or data from research plots areused to calibrate belowground biomass, soil carbon anddead wood decay models (as described above in Section4.5.3), does the VCS Program methodology require to ap-ply sound and reliable methods for monitoring changes incarbon stocks, including representative location of sam-plings sites and sufficient frequency and duration of sam-pling shall be applied?

1 n.a. n.a. n.a.


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In addition, does the VCS Program methodology requirethat plots used to calibrate soil carbon models are meas-ured considering appropriate sampling depths, bulk densityand the estimated impact of any significant erosion (or plotswith significant erosion shall be avoided)?

1 n.a. n.a. n.a.

Does the VCS Program methodology require that data usedto calibrate belowground biomass and dead wood modelshave to consider an estimation of oven-dry wood densityand the state of decomposition?

1 n.a. n.a. n.a.

9.3 Description of the Monitoring PlanDoes the VCS Program methodology describe the criteriaand procedures for obtaining, recording, compiling and ana-lyzing data and information important for quantifying and re-porting GHG emissions and/or removals relevant for theproject and baseline scenario?

1 The VCS Program Methodology provides: general requirements for the monitoring (section

9.3.1) requirements to deal with uncertainty and quality

management (section 9.3.2) requirements for the application of expert judge-

ments (section 9.3.3) requirements for the monitoring of project imple-

mentation (section 9.3.4) requirements for the stratification and sampling

framework (section 9.3.5) requirements for estimating GHG emissions on

the basis of GEST and water table depth (section9.3.6)

requirements for monitoring of fire events in theproject scenario (section 9.3.7)

Clarification Request 10. Section 9.3.3: Clarify and justify for which parame-

ters/input values an expert judgement is sufficientto obtain reliable estimates of GHG emissions.

Section 9.3.4: Clarify if all parameters listed in arelisted in the respective section regarding “parame-ters to be monitored”

CR


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Section 9.3.4: Specify “small and isolated events”of fire

Section 9.3.4: Clarify if the cancelling of the FireReduction Premium reflects the potential emissionof GHG due to such an event.

Section 9.3.6: Clarify if the procedures provided inthis section are obligatory for potential PPs in or-der to estimate GHG emission on basis of GESTand water table depth in compliance with themethodology?

10. References and other informationDoes the VCS Program methodology include any relevantreferences and any other information relevant to the meth-odology/revision?

1 The methodology provides reference and informationrelevant for the methodology as required.


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Table 2: Summary of Requests and Responses by Methodology Developer

RequestReferenceto VCS re-quirement

Question/ Suggestion to theMethodology Developerfrom VCS&Additional Comment or Clar-ification

Summary of Response by Methodol-ogy Developer

Conclusion by AuditTeam

Clarification Request 1.Clarify how it is ensured thatthe correlation between GESTtypes and emissions in a par-ticular project are actuallygiven:

a) Clarify if validation of themodels are required

b) Clarify how well GESTtypes reflect successionprocess (e.g. in terms ofrewetting of previouslydrained area or vice versa(in the baseline)

General re-quirements(VCS v3.4Section 4.1)VCS Stand-ard Section4.1.6

A) Please clarify if individualprojects are required tovalidate the model, and ifso how? Or can the modelbe validated (now duringthe assessment) to coverspecific geographic areaand landscape types (eg,FVS model is appropriatefor use with all foreststypes in the US)

B) As this is related to howwell vegetation types areactualy able to reflectchanging conditions. (e.g.after a re-wetting process,or in a drainage process)please clarify how themethodology acocunt forthe lag time for vegetationto respond, which isdepended on theecosystm. It might benecessray to reflect it inthe applicabilityconditions. The studiesquoted in the methodologyare mainly from Central

A) The procedure in 9.3.6 ensuresthat there is a correlation betweenGESTs and GHG emissions. Thecorrelation as such is notquantified, see 9.3.6 DeterminingGESTs step 6. In the GESTapproach GHG fluxes and theirproxies are treated and delineatedin an integrative manner.Added to 9.3.6: “The results of thisprocedure must be described inthe PD”. Note that by following theprocedure (7 steps) the results areimplicitly justified.

B) A vegetation succession is usuallya gradual process, which isreflected by GESTs if changes aresufficient for moving from one typeto the next. We cannot indicate apriori how well GEST types mayreflect vegetation succession. Thisis dependent on how GESTs areestablished and how well GESTsrepresent specific successionalstages. Subsequent successionalstages may be captured by asingle GEST, which implies thatthere is no implicit change is GHG

A) Potential PPs are notobligated to follow theprocedures desribed in9.3.6 as it is left opento use the desribedapproach. Clarify ifresults of otherprocedures than thosedesribed have to bedesribed in the PD aswell.

B) No information on howfar GEST types canreflect successionprocesses. Thisdependes highly onthe qualitiy of theGESTs identified.Based on theclarfication provided byVCS (Mail: AndrewBeauchamp / Mi29.06.2016 21:27CET) the final verdictover the qualitiy of theGESTs is up to theassessing auditor.Request closed.


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Europe. The methodlogyhas no limitation in termsof geography or climaticconditions

characteristics between thesesstages.

A) As stated in section 8.1.3.2 page26, the alternative to using theprocedure in 9.3.6 is applyingvalues from appropriate literaturesources pertaining to land useclasses, water table depths orwater table depth classes andsimilar project circumstances. Themethodology then states that forsuch values the accuracy must bedefined and conservativenessjustified. We added that this mustbe presented in the PD.

A) Besides thedevelopement ofproject specificprocedures followingthe proceduresdescirbed in 9.3.6project developers areallowed to apply valuesfrom appropriateliterature which have tobe described/justied inthe PD obligatorly.Request closed.

Corrective Action Request 1.Ensure that all key terms andacronyms used in themethodology are listed as re-quired e.g. PDT, NEE, NEP,etc.

General Re-quirements(Meth tem-plate v3.3)

We understand from earlier experiencewith VCS methodology developmentthat we do not need to provide defini-tions for terms already defined in theProgram Definitions. E.g. PDT. Wehave added NEE and NEP and wehave not identified other terms thatneed to be added to Ch3.

Key terms are added as re-quired, Request closed.

Clarification Request 2.Applicability condition (page 5-6):

a) Define the term “agricul-ture”; clarify what kind ofimpact agriculture willhave on uncertainty when

Applicabilityconditions(VCS v3.4Section 4.3)VCS Stand-ard Section4.3.1 (for all,a – k)

For example, can this be cropproduction as well as animalhusbandry?

Agriculture: food, fodder or fiber pro-duction on land.Type and intensity of land use are inte-grated into the GEST approach, see9.3.6 Determining GESTs step 6.

According to the methodol-ogy developer, agriculturein connection with themethodology comprisesfood, fodder or fibre pro-duction.The final verdict over thequalitiy of the GESTs is up


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applying the GEST ap-proach

to the assessing auditor.Request closed.

Clarify how it is ensured thatcollection of fire wood does notlead to leakage

‘Conservative’ removed from this (andthe previous) applicability condition. Ifthere is no displacement of this activ-ity, not accounting for this activity isconservative, but if there would be dis-placement, this displacement has nonet negative effect on the project’sGHG benefits.

Fire wood was conserva-tively removed from themethodology. Requestclosed.

i) l) Specify the consequenceif burning of biomass and peat-land or the use of N-fertilizerdoes occur in the project sce-nario (e.g. how can a projectlose its eligibility after start-ing?) Clarify if these are actu-ally applicability conditions, orshould rather be monitored

As written as a applicabilitycondition without aquantification mechanism, if aproject were to be validatedand user of fertiziler orbiomass burning ended upoccuring the project wouldbecome ineligble. Therefore,would it worth includingquantification parameters forthis pool in case fertilization orbiomass burning does occur?

The project proponent is expected tobe in control of project activities and ifthese happen to include biomassburning, N-fertiliser use or peatburning, and this is revealed duringvalidation/verification, the project is setto fail. The VCS has procedures forthis. There is therefore no need toinclude accounting procedures.These are applicability conditions,because the methodology has noaccounting procedure and theseactivities must be avoided.

According to theinformation provided, theincidence of one of thementioned conditions willlead to a failure of theproject activity incompliance with respectiveVCS procedures. Requestclosed.

f) g) j) Clarify if these re-quirements are applicabilityconditions (it might rather be adescription of the project im-plementation than an applica-bility conditions)

Though these arerequirements for themethodology, a project doesnot necessary have to meetthis requirements and thus arethey appropraite asapplicability conditions?

e can indeed be droppedf, g, j must be met because otherwisethe methodology cannot be used.

According to theinformation provided thementioned conditions needto be ensured otherwisethe applicability of themethodology is notpossible. Request closed.


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l) Clarify the meaning of“can” in the applicabilitycondition k

Clarify if N2O emissionswill generally decline un-der all preconditions interms of dryness at start ofrewetting activity

Clarify whether further ap-plicability conditions arerequired to encompass thelimitations of GEST (e.g.water tables below 30 cm)

VCS requires the use of ‘must’or and ‘may’, please changeusage of ‘can’ to may.

Replaced with ‘must’ and sentenceotherwise slightly amended.

From deeply drained to fully rewettedthere we be no increase in N2O, butfrom deeply drained to rewetting to eg.some 40 cm below the soil surfaceN2O may increase. This is due to atransition of conditions too dry for N2Oproduction to moist conditions condu-cive to N2O production. However, theproject proponent must justify that thisis not relevant, eg. by aiming at full re-wetting. Hence, ‘and by sufficient re-wetting’ was added.

This applicability condition is aboutN2O. GESTs have no limitations in thisrespect because GESTs do not involveN2O. The GEST approach can be ap-plied to situations with water tables be-low 30 cm because data on emissionsexist of situations where drainage isbeyond 30 cm. Therefore, no applica-bility conditions are needed to excludesuch conditions.

“Can” has been replacedby “must”

Further specification is pro-vided to ensure that N2Oemissions can be ne-glected as a sufficient re-wetting is clearly required.The final verdict over thequality of the sufficiency ofthe rewetting is up to theassessing auditor. Requestclosed.

Clarification Request 3.Ad 1: Stratification:a) Clarify why it is conserva-

tive to include areas that

Projectboundary(VCS v3.4Section 4.4)

Reworded by TUV SUD

Buffer Zones:

a) In the procedure we say: “In caseshallow peat areas are conservativelyneglected” and “It is conservative toomit shallow peat strata in accounting”.

a) In the methodology itsays: “Areas with apeat layer at project


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are shallower than re-quired (ie, do not meet thepeatland definition) as longas they are connected toareas that meet the re-quirements?

Ad 3 Buffer zones (p 11/12):b) Provide guidance for the

establishment of a bufferzone

c) Clarify which parametersneed to be monitored inorder to ensure/proof, thatextensive drainage outsidethe project are does not af-fect the water level withinthe project area.

VCS Stand-ard Section4.4.1/4.4.2

b) Please clarify if there areother features that arerequired of the buffer zoneto ensure it is appropriate?Eg, does the area have tobe peatland and comparableto the project area? Wherethe project is outside theboundary is it required to beadjacent to the project area(AFOLU req 3.4.3(3)(a)).Perhaps update to say‘width and size’ to match thelangauge of the AFOLUrequirement

c) Section 9.3.4 of the methdoes discuss what needs tobe monitored, but are therespecific paramaters relatedto these items that arerequired to be monitored(eg, water table level in thebuffer zones?)

We do not mention the conservative in-clusion of shallow peat areas.Note that shallow peat areas can be in-cluded because the PDT ensures thatif the peat is depleted there is no emis-sion in the baseline, avoiding overesti-mation of emission reductions.

b) Guidance exists in 5.2: “The width ofthe buffer zone must be determined onthe basis of quantitative hydrologicalmodeling, or expert judgment.” ‘Width’is now replaced with ‘size and shape’as in requirement 3.4.3(3a).Note that the methodology requires thebuffer zone to be inside the projectboundary.

c) New procedures are provided insection 9.3.4, combined with proce-dures for buffer zone against leakage.

start shallower than re-quired by the adopteddefinition of peatlandmay be include if suchareas are connectedwith areas that meetthe definition”.No answer was pro-vided to CR3 Ad 1.Further clarification isrequired.

b) Guidance is providedin compliance with re-quirements of thestandard. Requestclosed.

c) No information is pro-vided regarding spe-cific monitoring param-eters. This is due tothe fact, that the meth-odology does not pro-vide describe distinctprocedures but an ap-proach. Based on theclarification providedby VCS (Mail: AndrewBeauchamp / Mi29.06.2016 21:27 CET)


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the final verdict overthe applicability of theapproach chosen bythe project developersis up to the assessingauditor. Requestclosed.

a) There are two ways of interpretingthis CR. One is that the CR as-sumes that the methodologyclaims that including shallowerpeat is conservative. The other isthat it is not demonstrated/ensuredthat if shallower peat is includedthe result is conservative.We responded earlier to the firstcase that there is no claim that in-clusion of shallow peat areas isconservative, and the question asto why it is conservative to includethem seemed therefore moot.On the second possibility we notethe following: Drained peatlandsmay show considerable areas ofshallow peat at their edges or, de-pending on the relief of the under-lying mineral soil, elsewhere. Withthe PDT procedure in place it ispossible to include this potentiallysignificant pool in accounting and

Clarification was pro-vided. Due to the PDTprocedures, the shal-lower peat areas willnot be accounted foras emission sourceonce totally depleted.Request closed.


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avoid the need for exclusion of ar-eas intricately related to thethicker peat. As a general princi-ple, pools (here: shallow peat) canbe included as long as they can besensibly (and conservatively) ac-counted. Whereas it is notstrictly conservative to includeshallow peat areas (or any otherpool), they can be accounted fol-lowing available procedures andmust be treated conserva-tively once included. As stated, thePDT limits the baseline emissionsthat can be claimed from this shal-low peat. This is consistent withprocedures for thicker peat.

Corrective Action Request 2.Apply the table format pro-vided by the VCS MethodologyTemplate

Projectboundary(VCS v3.4Section 4.4)VCS Meth-odologytemplate in-structions

Table 5.2 adjusted to VCS template VCS table format appliedas requested. Requestclosed.

Corrective Action Request 3.Provide description why pools”Wood products” and “DeadWood” are optional for projectdevelopers applying the meth-

B 3 ProjectBoundary(AFOLU v3.4Section 4.3)VCS Stand-ard Section

These pools are excluded and the mo-tivation is that they are optional as perthe VCS requirements. Therefore,there is no need for their inclusion.

Pools are excluded in com-pliance with the standard.Request closed.


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odology); or provide justifica-tion why carbon pools can beexcluded.

4.4.1,AFOLU reqSection4.3.1 (Table2)

Corrective Action Request 4.a) Under certain

circumstances CH4emissions can occur aspermanent emisson afterrewetting activities, andnot exclusively in atransient phase

b) Provide procedures for thequantification of possiblespikes of CH4 emission.

c) CH4 emissions of chan-nels and ditches in theproject scenario shall be incompliance with IPCCguidelines and conserva-tive

B 3 ProjectBoundary(AFOLU v3.4Section 4.3)VCS Stand-ard Section4.4.2,AFOLU reqSection4.3.23

Reworded by TUV SUD. a) In such cases (without a spike) theGEST procedure must be applied. Thisincludes situations where soil condi-tions are such that CH4 are perma-nently high. See the definition ofGEST; any such situation can be de-fined as a GEST with a specific emis-sions factor.

b) The methodology states the follow-ing: “For the quantification of possiblespikes of CH4 emission during a transi-ent period after rewetting where dyingoff vegetation may lead to substantialmethane emissions, for which theGEST approach cannot be used, con-servative estimates from appropriateliterature sources must be used. Theproject proponent must demonstrateapplicability of that literature on the ba-sis of similarity with respect to pre-pro-ject land use (e.g. forestry, peat min-ing, agriculture) and land use intensity(esp. fertilization), superficial peattypes (esp. nutrient conditions), andclimatic zone.”

a) Based on the clarifica-tion provided by VCS(Mail: Andrew Beau-champ / Mi29.06.2016 21:27 CET)the final verdict overthe quality of theGEST and respectiveemission factors elabo-rated is up to the as-sessing auditor. Re-quest closed.

b) See comment undera). It is the responsibil-ity of the auditor tojudge whether the con-servative estimatesfrom literature are ap-plicable for the projectactivity to be assessed.Request closed.

c) See comment undera). It is the responsibil-ity of the auditor tojudge whether the CH4emissions of channels


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c) Unclear what is meant here. Whichpart of the procedure is not compliantwith which IPCC guideline?

and ditches in the pro-ject scenario arescaled and calculatedcorrectly. Requestclosed.

Corrective Action Request 5.Specify theprocess/requirements todemonstrate the decline N2Oin the project scenario asassumed in the methodology

B 3 ProjectBoundary(AFOLU v3.4Section 4.3)AFOLU reqSection4.2.3.24

This is provided in the methodology asfollows.8.1.1: “It must be demonstrated (e.g.by referring to peer-reviewed literature)that under the project circumstancesN2O emissions are insignificant or de-crease in the project scenario com-pared to the baseline, and thereforeN2O emissions need not be accountedfor.”8.2.1: “To demonstrated that N2Oemissions are a) insignificant or b) de-crease compared to the baseline sce-nario, and therefore N2O emissionsneed not be accounted for, a) use theCDM A/R methodological tool: “Toolfor testing significance of GHG emis-sions in A/R CDM project activities”, orb) refer to peer-reviewed literature, re-spectively”.

The process/requirementsto demonstrate the declineN2O in the project scenarioas assumed in themethodology are providedas requiered. Requestclosed.

Clarification Request 4.Explain the 1 : 1 proportionalrise assumed. (Methodologypage 22)

BaselineScenario(AFOLU v3.4Section 4.4)

Please provide justification forthis 1:1 proportional rise

This means that if subsidence is 10 cmthe relative rise of the water table is 10cm.This is based on the assumption thatthe local drainage base is not alteredby subsidence ie. the absolute water

Clarification is provided.Request closed.


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AFOLU reqsection4.4.11

table does not change and the relativewater table increases the same rate asthe subsidence rate.To avoid confusion we removed thephrase “Unless alternative evidence isprovided,”.

Corrective Action Request 6.Modeling / predicting futurebaseline condition (pages 21-22):

a) Provide a minimum set ofrequirements for the mod-eling/predicting of the wa-ter level in order to applythe GEST approach or theestimation of GHG emis-sions based on water levelrespectively.

b) Define which parametersare required to calibratethe water model for the ta-ble. (Modeling of water ta-ble is required to predictthe baseline GHG emis-sions in this methodologyas stated e.g. on page 22,second paragraph.) En-sure that these parametersare included in section 9.1

B 5 Baselineand ProjectEmis-sions/Re-movals(AFOLU v3.4Section 4.5)AFOLU reqSection4.5.3

a) Please provide procedureto calibrate the hydologicalmodel discussed in themethodology as requiredby Section 4.5.3.Procedure must includespecific parameters tocalibrate the project areawith the model

b)reworded by TUV SUD

a) Guidance from the VCS (quote): “Inregards to CAR 6, after discussion weagreed that Section 4.5.3 is meant fordetermining carbon decay and theserequirements would not be appropriatefor the water table modeling. That said,the secondary aspects of the findingare still relevant related to ensuringthat parameters are included to cali-brate the model.” (end quote)Also it seems that the term quantitativehydrological modelling is misunder-stood. The term refers to a type of nu-merical simulation model that allowsfor depicting the outcome of complexinteractions, including non-stationarysituations. Whether such a model isneeded and how complex it must be, isup to the expert involved in the assess-ment. In simple situations, an expertwill be able to provide good guidancedirectly, in complex situations he willresort to modelling. The involvement ofan expert is indispensable. We there-fore rephrased to: ‘...must be assessed

a) Based on the clarifica-tion provided by VCS(Mail: Andrew Beau-champ / Mi29.06.2016 21:27 CET)the final verdict overthe applicability of theapproach chosen bythe project developersis up to the assessingauditor. Requestclosed.

b) See comment above.Request closed.

c) The description pro-vided is sufficient. Re-quest closed.


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of the methodology.

c) Provide description howfuture GEST types are es-timated in particular overtime

on the basis of expert judgment and ina conservative manner. Justificationmay be based on hydrological models.’

b) We have downscaled the necessityof a model and moreover do not wantto prescribe a specific software pack-age. The principle is that a certain wayof quantification is adopted as outlinedunder a) above.

c) The methodology does describe thisas follows: “Based on the assessmentof changes in water table depth, timeseries of vegetation composition mustbe derived (ex ante), based on vegeta-tion succession schemes in drainedpeatlands from scientific literatureand/or expert judgment, by definingtime series of GESTs, with time stepsof e.g. 5 years to allow for the inherentdiscrete character of the GESTs.”

Corrective Action Request 7.Procedure to determine GHGemissions in the base-line withGEST (pages 21-22 and 65-69)

a) Provide clear procedureshow to define a Site Typefor GEST in the field (e.g. if

B 5 Baselineand ProjectEmis-sions/Re-movals(AFOLU v3.4Section 4.5)

VCS methodologies are re-quired to be be understanda-ble without an additional paper(considering also that this isnot an approved VCS tool).The reference to the paper isalso not quite clear. Pleaseclarify if it is supposed to be

We refer to discussions with the VCS.We understand from the VCS that theconcern that the audit team had issueswith the science behind the paper isnot needed and that the validator iscomfortable with that aspect of refer-encing the paper. They stated that itappears that the finding was raisedmore as an interpretation of VCS rules

Based on the clarificationprovided by VCS (Mail: An-drew Beauchamp / Mi29.06.2016 21:27 CET) thefinal verdict over the ap-plicability of the approachchosen by the project de-


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vegetation is used to definea site type, which criteriamust be fulfilled to deter-mine the boundary of a sitetype? It shall be clearly de-scribe to enable project de-veloper and auditors to ap-ply such a procedure

background information, or ac-tual requirements of the meth-odology? If the latter is thecase it must be further defined,as the paper is a scientific arti-cle and cannot be directly usedby a methodology for a VCSproject.

The comments on the stepsdescribed in 9.3.6 in details:

1. How shall the GHGfluxes be determinedfor developing regres-sion models (I assumethis would be a param-eter that is required,and it shall be pre-sented in line withVCS requirements)

2. (no comment, but itmight be easier to un-derstand if it was re-ferred to the text onpage 66 last para. andpage 67

3. Please clarify what is"sufficiently similar"vegetation type? Whatare limits for a vegeta-

and the aesthetics of methodologymeaning that a methodology quantify-ing a GEST should include the proce-dure for developing a GEST and notreference another paper. They furthernoted that the validator agreed that theusers of the methodology would needto have a certain level of expertise todevelop a project, and therefore coulddetermine the procedure/method fromthe paper and would not require furtherrefining of the methodology presentedin the paper. VCS confirmed to providea clarification in writing to referencethat an academic paper is appropriatefor the procedural requirements.

Re. The comments on the steps de-scribed in 9.3.6 in details:

1. The methodology states in9.3.6: “For the analysis ofemissions, only data on yearlynet emissions, based on year-round measurements or onsound model extrapolationsare used. With respect to CO2fluxes, care has to be taken toinclude only net CO2 balances(NEE or NEP) from reliablemodels using light and dark

velopers is up to the as-sessing auditor. Requestclosed.


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tion type to be as-cribed to a GHG emis-sion value from litera-ture? How is it en-sured that the valuefits at all? So far theresearch quoted byCouwenberg for vege-tation is mainly in Cen-tral Europe. The meth-odology has howeverno geographic limita-tion or in ecosystem /site condition. Thiscan have huge im-pacts on the finalamount of credits gen-erated per unit of area

4. Please clarify if a bet-ter description of howwater table can beused to verify the GHGemissions (fluxes)

5. Please see commenton "sufficient similar-ity" in step 3.

6. The "expert option"leaves potential roomfor fraud

7. (no comment)

fluxes as input.” We have writ-ten 'flux' instead of 'emission'where we thought confusionmay have arisen.

2. -3. We added “Similarity is de-

fined on the basis of floristiccomposition or plant functionaltypes and expert judgementand must be justified”.

4. This is only a verification andrefinement step. We added“The results of step 3 may beverified and refined by …”.

5. We added “(see above)”.6. If an expert is selected using

the procedures provided in themethodology (based on IPCCguidance) the project propo-nent may assume that the per-son will provide scientific andreliable advice.

7. –

We added (see Section 9.3.6 for addi-tional guidance on each of thesesteps)” to the 4 steps in Section8.1.3.1.


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Further, the steps on page 21could be linked to the steps onpage 65, in order to help thereader following the methodol-ogy. e.g.

1. step 1 on page 21could refer to page 65

2. step 2 refer to page66/67

Another topic that requires fur-ther detailed description / pro-cedures is the determination /quantification of the baselinescenario.It is mentioned on page 21 instep 3 and 4 that "time seriesof GEST development for eachstratum" shall be derived, andit is referred to section 6.2. and6.1. Further description is pro-vided on page 22.

A detailed stepwise procedurewould increase the ease of un-derstanding the methodology.In any case the audit team isof the opinion that too littleguidance is provided howbaseline and project scenario

The methodology refers to moduleVMD0019 because it provides the re-quested step-wise guidance for estab-lishing the baseline. The methodologythen provides additional guidance incompliance with VCS WRC require-ments (points 1 and 2).


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is determined in regards to ac-tual GEST types(e.g. is modelling of the watertable always required? - in par-ticular for the project scenarioprobably yes? If so a morestructured approach might behelpful, e.g. what are requiredparameters to be used, per-haps refer to existing modelsfor water table.Please clarify if the water tableis used to predict vegetationtypes, and vegetation typesused to predict GHG emis-sions, is it not easier to justuse the water table at least forthe baseline, considering thata monitoring of the baseline isnot possible? (if that was thecase, step 3 on page 21 wouldnot be required)

The papers from Couwenberg(2011) gives a description ofthe methodology applied forderiving at proxies for GHGemissions based on publishedliterature (mainly from studiesin central Europe).


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The papers provide sound sci-entific background to the pro-posed methodology. The pa-per does however not presentfurther details in regards to thetopics raised above, i.e. thepractical application of themethodology for a project de-veloper - in particular if a pro-ject would be outside of Cen-tral Europe.The papers have certain limita-tions due to the study sites andreferences that were used.These limitation are not neces-sarily reflected in the proposedVCS methodology (i.e. applica-bility conditions)The main conclusion regardingthe Couwenberg papers is,that it is not clear if it shall beactual part of the methodology.The way the methodology iscurrently worded, the auditteam assumed that it is back-ground material, but not actualpart of the methodology (i.e.no actual requirements definedthere). Therefore, please clar-ify if the paper is supposed to


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be used a background or if fur-ther applicability conditions arerequired?

b) Provide clear procedureshow to determine GHGemissions in a site type (ofGEST) – parameters GHG-GESTbsl-CO2 and GHG-GESTbsl-CH4. It shall beclearly describe to enableproject developers to applysuch a procedure.

b) : The request raised by theaudit team is regarding thequestion how a projectdeveloper can come up withthe parameter GHGGESTbsl-CO2and GHGGESTbsl-CH4. Nodetailed information isprovided in the methodologyon this topic. I assume thatsome kind of procedure shouldbe defined that can be appliedby the project developer.So, no procedure is requiredhow the parameter shall bevalidated (I deleted the part re-garding auditors from the sen-tence to avoid confusion).Currently, it is only stated onpage 52 and 53 "Data can beobtained from peer reviewedliterature or from own meas-urements". In my understand-ing that a VCS methodologyshould give guidance to a de-veloper on how to derive atthese crucial parameters. (In

The procedure for determining GESTsis provided in Couwenberg et al 2011.This comment has in part been dealtwith under a) above. In addition, wehave made clearer how GHG fluxesare established. See also e) below.

Equations 26 and 27 determine thatparameters are quantified for eachstratum i and time step t. GESTs foreach stratum and time step are deter-mined using procedures in 8.1.3.1.

In 8.1.3.2 we added:Procedures for the determinations ofGHG fluxes and water table depthmeasurements are provided in Section9.3.6.

In 9.3.6 we added:Determining CO2 and CH4 emissions

For project-specific flux values the pro-ject proponent may carry out directmeasurements of GHG fluxes, such asclosed chamber and eddy covariance

Based on the clarifica-tion provided by VCS(Mail: Andrew Beau-champ / Mi29.06.2016 21:27 CET)the final verdict overthe applicability of theapproach chosen bythe project developersis up to the assessingauditor. Requestclosed.


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addition if no guidance is givenother than best practice, itmakes it difficult for auditors tovalidating such approaches.)

For further clarification, pleasesee comments above onsection 9.3.6 / Couwenbergpapers

measurements. Applied techniquesmust follow international standards ofapplication as laid out in pertinent sci-entific literature (e.g., Matson & Har-riss, 1995, Pattey et al. 2006, Alm etal. 2007, Evans et al. 2011).

This is an expansion of the text weused in the tables in 9.1, where it is de-leted. The tables for the parameters re-fer to 9.3.6 at the top of “Justification ofchoice of data or description of meas-urement methods and procedures ap-plied:”.

c) Clarify if additional proce-dure and description is re-quired for natural succes-sion, cultivated land andbare peat.

The procedures in the methodologycan be used for all initial conditions,whether they are a nature area, arableland or a peat excavation site.


d) Include clear procures howto validate GHGGESTbsl-CO2 and GHGGESTbsl-CH4

GEST determination itself has a valida-tion procedure (9.3.6). Baseline estab-lishment is based on application ofmodule VMD0019 and this is per-formed under the scrutiny of VCS rules

Based on the clarifica-tion provided by VCS(Mail: Andrew Beau-champ / Mi29.06.2016 21:27 CET)


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and project validator, who assesseswhether the step-wise procedure in themodule is carefully followed. We maymisunderstand the term ‘validate’ inthe comment.

the final verdict overthe applicability of theapproach chosen bythe project developersis up to the assessingauditor. Requestclosed.

e) Provide clear procedureshow to establish project-

See also b) above.

Equations 26 and 27 determine thatparameters are quantified for eachstratum i and time step t. GESTs foreach stratum and time step are deter-mined using procedures in 8.1.3.1.

In 8.1.3.2 we added:Procedures for the determinations ofGHG fluxes and water table depthmeasurements are provided in Section9.3.6.

In 9.3.6 we added:Determining CO2 and CH4 emissions

For project-specific flux values the pro-ject proponent may carry out directmeasurements of GHG fluxes, such asclosed chamber and eddy covariancemeasurements. Applied techniquesmust follow international standards of



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application as laid out in pertinent sci-entific literature (e.g., Matson & Har-riss, 1995, Pattey et al. 2006, Alm etal. 2007, Evans et al. 2011).

This is an expansion of the text weused in the tables in 9.1, where it is de-leted. The tables for the parameters re-fer to 9.3.6 at the top of “Justification ofchoice of data or description of meas-urement methods and procedures ap-plied:”.

f) specific values forGHGWLbsl-CO2 andGHGWLbsl-CH4 (stepwiseprocedures)


g) Clarify if it is required tovalidate emissions basedon GEST or project specificvalues for GHGWLbsl-CO2and GHGWLbsl-CH4

See d) above Based on the clarifica-tion provided by VCS(Mail: Andrew Beau-champ / Mi29.06.2016 21:27 CET)the final verdict overthe applicability of the


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approach chosen bythe project developersis up to the assessingauditor. Requestclosed.

h) Provide a description howto determine the uncer-tainty for GHG emissionestimation related to theGEST approach /

It is necessary for the method-ology to provide procedures todetermine uncertainty (as perVCS Standard). The methodol-ogy does not appear to havespecific requirements for esti-mating uncertainty from theGEST model. If the GESTmodel has a method for calcu-lating uncertainty, that wouldbe useful. However, as its cur-rently explained in the method-ology, it is not clear that if theuncertainty cannot be calcu-lated, the GEST model wouldneed to be re-run with con-servative numbers. In fact, thecurrent language seems to im-ply that if uncertainty cannotbe calculated from the GESTmodel, the PP only needs tojustify why it is conservative.This is entirely different fromactually being conservative.

The methodology allows for a quantifi-cation of uncertainty as well as for theapplication of conservative values.Quantifying uncertainty:Section 8.5.2: “This procedure allowsfor estimating uncertainty in the esti-mation of emissions and carbon stockchanges, i.e. for calculating a precisionlevel and any deduction in credits forlack of precision following project im-plementation and monitoring, by as-sessing uncertainty in baseline andproject estimations”.There is no procedure in the methodol-ogy that excludes emissions associ-ated with GESTs from the need toquantify uncertainty as outlined in8.5.2.Conservative values:In 9.3.2 the methodology states: “If un-certainty is significant, project propo-nents must choose data such that it in-disputably tends to under-estimate, ra-ther than over-estimate, net GHG pro-ject benefits”.

Clarify if conservative-ness in GHG emis-sions reductions basedon GESTs “can” or“must” be establishedby applying too low fluxvalues to GESTs in thebaseline.


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Added: “Conservativeness in GHGemission reductions based on GESTscan be established by applying too lowflux values to GESTs in the baseline.The conservativeness of the value(e.g. applying the value of the nextwetter GEST) must be demonstrated.”The methodology states that if uncer-tainty is significant, PPs must choosedata such that it indisputably underesti-mates GHG reductions. One possibilityprovided by the methodology is tochoose too low flux values in the base-line. Other options remain open aslong as conservativeness is demon-strated. For clarity we reworded theprocedure and added to the procedure:“or any alternative way of ensuringconservativeness”.

Conservativeness inGHG emissions reduc-tions based on GESTsmust be demonstrated.Request closed.

i) Specify the conditions un-der which the GEST ap-proach leads to estimationsof GHG emissions with anacceptable certainty

i)Reworded by TUV SUD These conditions would include aproper literature or vegetation surveyand sufficient GHG flux data for indi-vidual GESTs. This is covered by themethodology.

For project-specific fluxvalues the methodologyallows, that directmeasurements of GHGfluxes are carried out, suchas closed chamber andeddy covariancemeasurements. Appliedtechniques must followinternational standards ofapplication as laid out inpertinent scientific


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literature.

Based on the clarificationprovided by VCS (Mail: An-drew Beauchamp / Mi29.06.2016 21:27 CET) thefinal verdict over the ap-plicability of the approachchosen by the project de-velopers is up to the as-sessing auditor. Requestclosed.

Clarification Request 5.Clarify why the micro-topogra-phy does not need to be con-sidered e.g. in form of a digitalterrain model when model-ing/estimating the water table.

B 5 Baselineand ProjectEmis-sions/Re-movals(AFOLU v3.4Section 4.5)AFOLU req4.5.31

Please clarify why themethodologiy does notconsider the micro-topographyof the project area as requiredby Section 4.5.31 of theAFOLU requirements

If different micro-topographical ele-ments have different GHG flux charac-teristics, these can be captured in dif-ferent GESTs.

Based on the clarificationprovided by VCS (Mail: An-drew Beauchamp / Mi29.06.2016 21:27 CET) thefinal verdict over the ap-plicability of the GESTselaborated by the projectdevelopers is up to the as-sessing auditor. Requestclosed.

Clarification Request 6.Specify how “significant differ-ences” can be identified


Please specify procedure forhow a ‘signifcant differencee’between baseline and projectemission of 100 years can bedetermined as required bySection 4.5.29 fo the AFOLUreq.

Equation 7 includes a factor 1.05which determines that the differencemust be 5% or greater.We added ’ ( 5%)’ to the text in 5.2.

Significant difference isspecified as differenceequal or greater 5%. Re-spective information is pro-vided in the Methodology.Request closed.


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AFOLU reqSection4.5.29

Clarification Request 7.Clarify if Ratepeatloss-BSL,i is con-stant or will vary over time dueto sagging and oxidation.

B 5 Baselineand ProjectEmis-sions/Re-movals(AFOLU v3.4Section 4.5)AFOLU req4.5.25

Indeed in this case a conservative(high) value MUST be applied. Textamended.

In order to consider thevariation of peat loss due tosagging and oxidation a“conservative” high value isrequired. Request closed.

Clarification Request 8.a) Specify how “peat fire” is

defined in terms of inten-sity of the fire and amountof peat burned in order tobe accountable for FireReduction Premium


These findings can be closeddue to VCS’ clarification toTuev Sued. Note,methodology must be updatedto include language developedfor VM0007 to satify anyprevious concerns raised.

Difficult to assess where the critical dif-ference between the methodology andmodule VMD0046 is. The proceduresare essentially the same. Some editsare made (see in track changes).

Closed after discussionwith VCS.

b) Clarify what parametersneed to be available at val-idation in order to quantifythe fire reduction

Closed after discussionwith VCS

c) Clarify based on what VCSrequirements carbon cred-its can be generated forimproved fire managementin the project activity, with-out actually quantifying the



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emission:

- As per VCS Standard3.4 section 4.1.8 prox-ies used must bestrongly correlatedwith the value of inter-est: clarify how this isthe case with the firereduction premium

- VCS Standard 3.4section 4.7.2 statesthat a methodologyshall establish criteriaand procedures forquantifying emissionsgenerated by the pro-ject, and which shallbe calculated as thedifference betweenbaseline and projectemissions. Clarify howthis approach is in linewith the respectiveVCS requirement

d) Area burnt and emissionsfrom fire shall be includedas monitoring parameter inline with VCS Standard 3.4



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section 4.7.2. Include for-mulas required and definewhich parameters need tobe included, including pro-cedures for determiningthe parameters.

e) If emissions from fire in thebaseline shall be includedin the methodology, in-clude clear procedure, for-mulas and parametershow to calculate thesebaseline emissions.


Note:pg. 35; “Ex-ante estimateof Fire Reduction Pre-mium: The estimate ofGHGwps-CO2,i,t in Equa-tion 52 must be taken fromex-ante calculations (Sec-tion 8.2.3.2)” Section8.2.3.2 does not exist!pg. 30; Equation (41) theparameters should beGHGGESTwps,i,t andGHGWLwps-CO2,i,t respec-tively

Done

Corrective Action Request 8.Estimation of project emis-sions:

Baselineand Project

Further clarification provided inCAR 7 is also applicable here.

The field monitoring procedures forGESTs are provided in 9.3.6 (As-sessing the spatial distribution of

Based on the clarificationprovided by VCS (Mail: An-drew Beauchamp / Mi


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a) Provide clear proceduresto monitor Site Type forGEST in the field

Emis-sions/Re-movals(AFOLU v3.4Section 4.5)

GESTs). This section also providesprocedures for water table depthmeasurements.

29.06.2016 21:27 CET) thefinal verdict over the ap-plicability of the approachchosen by the project de-velopers is up to the as-sessing auditor. Requestclosed.

b) Provide clear procedureshow to monitor GHG emis-sions for a GEST type(GHGGESTwps-CO2) andhow QA/QC proceduresare applied in detail

GHG emissions are not monitored di-rectly, GESTs are monitored, see a)above. QA/QC procedures are pro-vided in 9.3.2. See also response toCAR 7(h) above.


c) Provide a description of theuncertainty related to GHGemission estimation usingthe GEST approach. Clar-ify if validation is required.

See response to CAR 7(h) above. Based on the clarificationprovided by VCS (Mail: An-drew Beauchamp / Mi29.06.2016 21:27 CET) thefinal verdict over the ap-plicability of the approachchosen by the project de-velopers is up to the as-sessing auditor. Requestclosed.

d) In this regards clarify howwell GEST reflect changingconditions over time (con-sidering that the vegetation

We do not see how this is relevant fora methodology. This needs to be as-sessed by the project proponent by us-ing the methodology.

Based on the clarificationprovided by VCS (Mail: An-drew Beauchamp / Mi29.06.2016 21:27 CET) the


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need time to adopt to dif-ferent site conditions)

final verdict over the ap-plicability of the approachchosen by the project de-velopers is up to the as-sessing auditor. Requestclosed.

e) Provide clear proceduresto establish project-specificvalues for GHGWLwps-CO2and GHGWLwps-CH4 (step-wise procedures)

f) Provide procedures to de-fine and justify the accu-racy defined or conserva-tiveness in the case valuesfrom

We refer to the response to CAR 7(e)above. A similar response applieshere. See tables in 9.2 for these pa-rameters for edits, as well as 9.3.6.

Clear procedures are notprovided but the methodol-ogy requires that potentialproject developers have todocument the process ofidentifying GESTs and cor-responding GHG valuesneed to be documented inthe PD. Thus, it is left tothe auditor to criticallyjudge whether the proce-dures followed are feasibleor not and thus, the valuestaken to calculated projectemission reductions areconservative and realistic.Based on the clarificationprovided by VCS (Mail: An-drew Beauchamp / Mi29.06.2016 21:27 CET) thefinal verdict over the ap-plicability of the approachchosen by the project de-


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g) appropriate literaturesources are applied forGHGWLwps-CO2 andGHGWLwps-CH4

Inclusion of language fromVM0007 which includedmonitoring of fire andunderground fire subsidencefor 3 years should besufficienct to close this finding

See responses to CAR 7 (h) and (j)above

Our finding was some-how reworded. Re-quest closed.

Clarification Request 9.Clarify how emissions from firein the project scenario is ac-counted for

Baselineand ProjectEmis-sions/Re-movals(AFOLU v3.4Section 4.5)

This is outlined in Section 8.3 and ap-plicability condition (j). The assumptionis that there will be no fires due to therewetting activity and project failure oc-curs as described in 8.3 in which caseno premium is awarded.

According to the applicabil-ity conditions, fire is not al-lowed to occur. Thus a pro-ject were fire occurred afterproject start loses its eligi-bility

Corrective Action Request 9.a) Explain the difference be-

tween the “normal” and the“alternative” procedure asboth refer to the same pa-rameters.

b) Clarify if CBSL and CWPS

(alternative procedure)need to be multiplied by44/12

8.4 Sum-mary ofGHG Emis-sion Reduc-tion and/orRemovals(Meth tem-plate v3.3)

a) This is explained in 8.2.3.2 as indi-cated in 8.5: “GEST conversion as-sessments may provide direct con-servative estimates of emission reduc-tions due to rewetting, e.g. a conver-sion of GEST type a to type b is asso-ciated with a given emission reductionwith a given uncertainty, or the emis-sion reduction is estimated conserva-tively.” This means that a GEST con-version assessment can directly pro-vide the value for the rewetting compo-nent GHGrewetting ofGHGBSL – GHGWPS

a) Clarification is pro-vided. Equations wererevised accordingly.Request closed

b) 44/12 was added asrequired. Requestclosed.


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The equation 55 is thus rewritten to in-clude

CBSL – CWPS + GHGrewetting

in equation 56.

b) Correct. We added 44/12 to equa-tions 42 and 56.

Corrective Action Request 10.a) Provide clear procedures

(detailed stepwise ap-proach) how to establishGESTs in order to esti-mate GHG emissions (seealso CAR 8)

Quantifica-tion of GHGemission re-duction andremovals(VCS v3.4Section 4.7)

Reworded by TUV SUD - Based on the clarificationprovided by VCS (Mail: An-drew Beauchamp / Mi29.06.2016 21:27 CET) thefinal verdict over the ap-plicability of the approachchosen by the project de-velopers is up to the as-sessing auditor. Requestclosed.

b) Based on the proceduresprovide information on for-mulas and parametersavailable at validation andto be monitored in order toestablish GESTs

These are listed in Sections 9.1 and9.2 respectively. What is the question?



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c) Provide clear procedures(detailed stepwise ap-proach) to establish pro-ject-specific values forGHGWLbsl-CO2 andGHGWLbsl-CH4 (see alsoCAR 8)

Is this the same question as in CAR7(e)?


d) Based on the proceduresprovide information on for-mulas and parametersavailable at validation anto be monitored to estab-lish project specific valuesfor GHGWLbsl-CO2 andGHGWLbsl-CH4

See response to CAR 7(e) Based on the clarificationprovided by VCS (Mail: An-drew Beauchamp / Mi29.06.2016 21:27 CET) thefinal verdict over the ap-plicability of the approachchosen by the project de-velopers is up to the as-sessing auditor. Requestclosed.

Corrective Action Request 11.a) List all parameters availa-

ble at validation are in-cluded e.g. waterways,fire, drainage structures,climate variables, etc.

9.1 Data andParametersAvailable atValidation(Meth tem-plate v3.3)

There are examples ofparameters that are mentionedin the methodology but notlisted in the parameter sectionsuch as the following:

waterways, / drainagestructures- mentionedon page 22 for watertable modelling

Some are examples of parameters thatmay be used in hydrological modelling.Hydrological modelling is optional. Ifmodels are applied the parameters willbe assessed as specified by themodel’s input requirements. Hence dif-ficult to provide tabular informationhere. Some may be relevant for stratifi-cation and are not strictly parameters.



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Further parametersfor water table model-ling listed at the bot-tom of page 22

climate variables(page 22)

(parameters related tofire – which is now ex-cluded)

b) Clarify if Root Shoot Ra-tios to be found in IPCCGPG 2003, Annex 3.A1,Table 3A1.8 are applicablefor wetland conditions.

The procedures follows the ones pro-vided in CDM tool 14 for trees andshrubs (referenced in both AR-ACM0003 and AR-AM0014 Wetlands)which do not distinguish between treeson terrestrial or peatland sites.


c) Ensure that detailed de-scriptions of procedures tobe applied are provided (inparticular for GHGGESTbsl-

CO2,i,t, GHGWLbsl-CO2,i,t,

See responses to CARs 7 and 8above.



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Corrective Action Request 12.a) List if all parameters to be

monitored are listed. E.g.water, leakage, fire, etc.

b) Ensure that detailed de-scriptions of procedures tobe applied at monitoringare provided (in particularfor GHGGESTwps-CO2,i,t,GHGWLwps-CO2,i,t, insufficientinformation is provided re-garding obtaining thisdata, assessing uncer-tainty, etc)

9.2 Data andParametersMonitored(Meth tem-plate v3.3)

There was a typo here in thesection for which therequirements were refering.This is supposed to be forparameters to be monitored(and has been updated toreflect so), same as above ifappplicable (in particular firewas an parameter that souldhave been monitored, but asper VCS decision is no longerrelevant).However waterways formodelling water table might berequired, monitoring ofleaackage(see comments intheapplicability section)

a) See response to CAR 10(a) above.

b) See responses to CAR 8. BUT: pa-rameters relevant for buffer zones(leakage and outside effects) will beadded


Corrective Action Request 13.Clarify if CBSL and CWPSneed to be multiplied by 44/12

Data andParameters(VCS v3.4Section4.8.1)

Done Multiplication by 44/12 wasadded as required. Re-quest closed.

Clarification Request 10.a) Section 9.3.3: Clarify and

justify for which parame-ters/input values an expertjudgement is sufficient toobtain reliable estimates ofGHG emissions.

9.3 Descrip-tion of theMonitoringPlan(Meth tem-plate v3.3)

Need clarification of the comment.Wherever expert judgement is neededit is clearly indicated.



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b) Section 9.3.4: Clarify if allparameters listed in arelisted in the respectivesection regarding “param-eters to be monitored”

Separate table for each of the parame-ters or can it be summarised? Items intables are quite detailed.


c) Section 9.3.4: Specify“small and isolated events”of fire

Added: ‘with de minimis effects onGHG emissions’


d) Section 9.3.4: Clarify if thecancelling of the Fire Re-duction Premium reflectsthe potential emission ofGHG due to such anevent.

Not entirely sure what is meant here.As in the case of catastrophic fires, an-thropogenic fires are assumed to haveoccurred in the baseline as well and sono accounting is needed.



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e) Section 9.3.6: Clarify if theprocedures provided inthis section are obligatoryfor potential PPs in orderto estimate GHG emissionon basis of GEST and wa-ter table depth in compli-ance with the methodol-ogy?

Not entirely sure what is meant here.The methodology refers to 9.3.6 in var-ious instances. The PP is thus sup-posed to apply procedures in 9.3.6 asinstructed.


Information Reference ListBaseline and monitoring methodology for the rewetting of drained peatlands used for peat extraction, forestry or agriculture based

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Annex II - 1

ANNEX 2: INFORMATION REFERENCE LIST

Ref.No.

Author/Edi-tor/ Issuer Title, Type of Document Date

1. Interviewed Persons:Name Position, OrganisationDr. Igino Emmer SilvestrumJohn Couwenberg Greifswald University

2. PP Baseline and monitoring methodology for the rewetting of drained peatlands used for peat extraction, for-estry or agriculture based on GESTs

Version8/15/2016

3. VCS AFOLU Requirements v.3.4 Oct 2013

4. VCS VCS Standard v.3.5 Mar 2015

5. VCS VMD0046 Methods for monitoring of soil carbon stock changes and greenhouse gas emissions andremovals in peatland rewetting and conservation project activities (M-PEAT)

Mar 2015

6. IPCC 2006 IPCC Guidelines for National Greenhouse Gas Inventories 2006

7. Couwenberget al

Assessing greenhouse gas emissions from peatlands using vegetation as a proxy. Hydrobiologia, 674,67-89.

2011

Methodology Assessment Report - Verra

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