Verification Assessment Report for: Producción ... · PDF fileDate Draft Final Report...

Doc. No. C-57 Jan2011

Verification Assessment Report for:

Producción, Industrialización, Comercialización y Asesoría de Hule Natural, Sociedad Anónima

(PICA) in

Izabal and Suchitepéquez, Guatemala

Verified by:

65 Millet St. Suite 201

Richmond, VT 05477 USA Tel: 802-434-5491 Fax: 802-434-3116

www.rainforest-alliance.org

Carbon Forestry Verification Audit Managed by: Adolfo Lemus

Regional Manager Rainforest Alliance/ SmartWood Program

8a Avenida 15-62, Zone 10 Guatemala, Guatemala Tel: (502) 2383 - 5757 Fax: (502) 2383 - 5788

Contact person: Adolfo Lemus Email: [email protected]

Date Final Report Issued: April 1, 2011 Date Draft Final Report Issued: March 25, 2011 Date Draft Report Issued: March 4, 2011 Audit Dates: January 17-20, 2011 Lead Auditor: William Arreaga Second Audit Team Member: Jared Nunery Senior Internal Reviewer: April 1, 2011

Audit Standard: VCS, 2007.1, Nov 2008

Voluntary Carbon Standard Program Update 21 January 2010

VCS, Tool for AFOLU Methodological Issues, Nov 2008 VCS, Guidance for AFOLU Projects, Nov 2008 VCS, Program Guidelines, Nov 2008 VCS, Tool for AFOLU Non-Permanence Risk Analysis and Buffer Determination, Nov 2008 VCS Program updates.

Verification Code(s): RA-VAL-VCS-014289

Verification Statement Issued: April 1, 2011

Project Latitude/Longitude: Lat: 14.62366 Long: -90.51681

Project Proponent Contact: Ing. Pablo Domínguez Project Proponent Address: 7a Ave., 7-33 Zona 9

Edificio Grupo Financiero de Occidente Ciudad de Guatemala

http://www.rainforest-alliance.org/


Voluntary Carbon Standard 2007 Verification Report Template 19 November 2007

Verification Report:

Name of Verification company: Date of the issue:

Rainforest Alliance April 1, 2011

Report Title: Approved by:

PICA VCS verif 11 Rainforest Alliance, SmartWood Program

Client: Project Title:

Produccion, Industrializacion, Comercializacion y Asesoria de Hule Natural, Sociedad Anonima (PICA)

Promoting Sustainable Development through Natural Rubber Tree Plantations in Guatemala

Summary:


This project is designed to promote sustainable development through the establishment of natural rubber tree plantations in two distinct regions of Guatemala. The proposed project activities involve certifying the proposed project areas under the Forest Stewardship Council (FSC) forest management certification, in addition to the validation and verification of the project as an Afforestation, Reforestation, and Revegetation (ARR) project with the VCS. The project is registered as a validated ARR project VCSR350 Account ID: 682 (see https://vcsregistry1.apx.com/myModule/rpt/myrpt.asp). The project involves the reforestation of 2,366.16 hectares of degraded pastureland, with a variety of clones of Hevea brasiliensis. The Project Design Document (PDD) and supporting documents were designed to conform to the VCS 2007.1 standard, specifically as an ARR project under the AFOLU project types. The project employed an approved CDM Afforestation and Reforestation methodology, AR-ACM0001 v.3. The project was validated by the Rainforest Alliance on the 26th of October 2010. This project aims to be the first FSC certified rubber tree plantation in Guatemala. The project intends to diversify investment opportunities for businesses in Guatemala interested in investing in sustainable rubber production. The project area includes 7 different farms, divided geographically in both the north (3 farms) and the south (4 farms) of Guatemala. Traditional rubber production currently exists in the south of Guatemala, however, this practice is less common in the north, where soils are less productive, and a longer rainy season presents additional challenges with increased impacts of a fungus that affects rubber plantations. The project intends to sequester a net carbon stock benefit of 1,739,855 t CO2e over the course of the 42 year crediting period. The project includes a financial analysis that demonstrates the impact of the sale of carbon credits associated with project activities, resulting in an increased rate of return for investors above a minimum investment threshold that decreases the financial risk of the project making investments in project activities possible. The project asserts that without the sale of carbon credits, it would not be able to meet the minimum investment return threshold. Although rubber production is common in the south with traditional rubber production, this project intends to increase the sustainability of rubber production through certification of FSC, which is not common throughout the entirety of Guatemala. The rubber plantations involved in project activities will be managed for rubber production for a minimum of 36 years, according to interviews with Project Proponents, plantation managers, and management plans. Following this rotation period, the rubber trees will be harvested, and the plantations will be re-planted as rubber tree plantations. The verification of project activities was requested of Rainforest Alliance by PICA. The audit of the Monitoring Report, supporting documentation, field visit, and interviews has provided Rainforest Alliance with the evidence to determine conformance to the VCS 2007.1 standard with a reasonable assurance.

Work carried out by: Number of pages:

Rainforest Alliance 79

https://vcsregistry1.apx.com/myModule/rpt/myrpt.asp


Table of Contents 1 Introduction ..................................................................................................................................................................... 6

1.1 Objective .................................................................................................................................................................. 6 1.2 Scope and Criteria .................................................................................................................................................... 6 1.3 VCS project Description............................................................................................................................................ 6 1.4 Level of assurance ................................................................................................................................................... 7

2 Methodology ................................................................................................................................................................... 8 2.1 Description of the Audit Process ............................................................................................................................... 8 2.2 Audit team ................................................................................................................................................................ 8 2.3 Review of Documents ............................................................................................................................................... 9 2.4 Stakeholder Interviews ........................................................................................................................................... 10 2.5 Resolution of any material discrepancy .................................................................................................................. 11

3 Verification Overview .................................................................................................................................................... 12 3.1 Verification summary .............................................................................................................................................. 12 3.2 Correct Action Requests ......................................................................................................................................... 12 3.3 Observations .......................................................................................................................................................... 16 3.4 Actions taken by the Project Proponent Prior to Report Finalisation ....................................................................... 17

4 Verification Findings ...................................................................................................................................................... 18 4.1.1 Project title, Purposes and Objectives ............................................................................................................. 18 4.1.2 Stratification of Baseline and Project Areas ..................................................................................................... 18 4.1.3 Ownership/Proof of Title/Right of Use .............................................................................................................. 18 4.1.4 Implementation of project activities during monitoring period ........................................................................... 19 4.1.5 Double counting and whether the project participated in another emission trading programme ....................... 20 4.1.6 Observation of local laws and regulations ........................................................................................................ 20

4.2 Completeness of monitoring ................................................................................................................................... 20 4.2.1 Project boundary monitoring ............................................................................................................................ 20 4.2.2 Conformance with PDD Monitoring Protocol .................................................................................................... 21 4.2.3 Baseline carbon stock and emissions monitoring (if applicable)....................................................................... 22 4.2.4 Project carbon stock and emissions monitoring ............................................................................................... 22 4.2.5 Monitoring of leakage (if applicable) ................................................................................................................ 22

4.3 Accuracy of Emission reductions calculations ......................................................................................................... 22 4.3.1 Conformance of ex post calculation with identified methodology and validated PDD ....................................... 22 4.3.2 The correctness and transparency of formulas and factors used ..................................................................... 24 4.3.3 Calculation of emissions in the baseline scenario (ex-post estimate) ............................................................... 24 4.3.4 Calculation of emissions from project activities (ex-post estimate) ................................................................... 24 4.3.5 Calculation of emissions reductions or avoided emissions due to the project (ex-post estimate) ..................... 24 4.3.6 Calculation of emissions from leakage (ex-post estimate) ............................................................................... 25 4.3.7 Calculation of net VCUs to be issued (ex-post estimate) ................................................................................. 25 4.3.8 Appropriate use of default values .................................................................................................................... 26 4.3.9 The assumptions made for calculating GHG emission reductions and/or removals ......................................... 26

4.4 Quality of evidence used to determine emissions reductions .................................................................................. 26 4.4.1 Verification of inventory equipment used to calculate emissions reduction and/or removals ............................ 26 4.4.2 Verification of use of GPS and remote sensing analysis .................................................................................. 26

4.4.3 Assessment of uncertainty .................................................................................................................................. 27 4.4.4 Implementation of sampling plan described in the PDD ................................................................................... 27 4.4.5 Adequacy of sampling intensity ....................................................................................................................... 28 4.4.6 Application of uncertainty deduction (if applicable) .......................................................................................... 28

4.5 Management and Operational Systems .................................................................................................................. 28 4.5.1 Field monitoring roles and responsibilities identified ........................................................................................ 28 4.5.2 Field inventory competency ............................................................................................................................. 29 4.5.3 Field inventory quality management systems .................................................................................................. 29 4.5.4 Data transcription quality management systems .............................................................................................. 30 4.5.5 Inventory data analysis systems ...................................................................................................................... 31


4.5.6 Data management and archival systems ......................................................................................................... 31 4.6 Risk Assessment .................................................................................................................................................... 31 4.6.1 Risk applicable to all project types ...................................................................................................................... 31 4.7 Risk factors applicable to ARR projects .................................................................................................................. 33

4.7.1 Default buffer withholding percentages for ARR projects ................................................................................. 34 5 Verification Conclusion.................................................................................................................................................. 35

5.1 Verification Statement ............................................................................................................................................ 35 Appendix A: Company Details ............................................................................................................................................. 36

5.2 Contacts ................................................................................................................................................................. 36 5.3 On-line Certification Contact ................................................................................................................................... 36

Appendix B : Verification Field Measurements ...................................................................................................................... 37


1 Introduction 1.1 Objective The purpose of this report is to verify the calculated emissions reductions and/or removals of Promoting Sustainable Development through Natural Rubber Tree Plantations in Guatemala, and assess conformance with the requirements of the Voluntary Carbon Standard (VCS) verification standards. The project was developed by PICA S.A., hereafter referred to as “Project Proponent”. The report presents the findings of qualified Rainforest Alliance auditors who have evaluated the Project Proponent‟s monitoring report and performance against the applicable standard(s), identified methodology, and validated Project Design Document (PDD). Section 5 below provides the audit conclusions. The Rainforest Alliance‟s SmartWood program was founded in 1989 to certify forestry practices conforming to Forest Stewardship Council (FSC) standards and now focuses on providing a variety of forest auditing services. In addition to being an ANSI ISO 14065:2007 accredited verifier and validator with VCS, Rainforest Alliance SmartWood program is also a member of the Climate, Community, and Biodiversity Alliance (CCBA) standards, and an approved verification body with a number of other forest carbon project standards. For a complete list of the services provided by Rainforest Alliance see http://www.rainforest-alliance.org/climate.cfm?id=international_standards. Dispute resolution: If Rainforest Alliance clients encounter organizations or individuals having concerns or comments about Rainforest Alliance / SmartWood and our services, these parties are strongly encouraged to contact the SmartWood program headquarters directly.

1.2 Scope and Criteria

Scope: The scope of the verification audit is to verify the emissions reductions and/or removals of PICA's Reforestation project in Guatemala against the VCS 2007.1 standard, the identified methodology and the validated PDD throughout the monitoring period from June 2007 to August 2010 . The objectives of this audit included a verification of the project‟s calculated emissions reductions against the VCS 2007.1 requirements and any additional requirements of VCS AFOLU projects. In addition, the audit assessed the project with respect to the validated baseline scenarios presented in the PDD. The project covers an area of 2,366.16 ha. The land is privately own. The forest type will be reforested to a rubber tree plantation with a variety of clones of Hevea brasiliensis.. During the monitoring period of three years, the Project Proponent has calculated it will reduce and/or remove 13,427.28 tCO2e, of which 2,685.46 tCO2e will be contributed to the VCS buffer pool.

Standard criteria: Criteria from the following documents were used to assess this project:

Voluntary Carbon Standard, 2007.1, Nov 2008

Voluntary Carbon Standard, Tool for AFOLU Methodological Issues, Nov 2008

Voluntary Carbon Standard, Guidance for Agriculture, Forestry and Other Land Use Projects, Nov 2008

Voluntary Carbon Standard, Program Guidelines, Nov 2008

Voluntary Carbon Standard, Tool for AFOLU Non-Permanence Risk Analysis and Buffer Determination, Nov 2008

Applicable Voluntary Carbon Standard Program Updates (http://www.v-c-s.org/policyannounce.html)

Applicable VCS Association Policy Announcements (http://www.v-c-s.org/policyannounce.html)

Voluntary Carbon Standard Validated Project PDD

Identified approved methodology within the PDD Materiality: All stocks and emissions equal to or greater than 5% of the total GHG assertion as defined in section 7.3.1 of the VCS 2007.1 standard.

1.3 VCS project Description The carbon project developed by the Project Proponent, intends to find new ways to promote sustainable development through natural rubber tree plantations in Guatemala. This project aims to become the first FSC certified rubber tree plantation in Guatemala. The project intends to diversify investment opportunities for businesses in Guatemala interested in investing in sustainable rubber production. The project area includes seven different farms, divided geographically in both the north (3 farms) and the south (4 farms) of Guatemala. Traditional rubber production currently exists in the south of Guatemala, however, this practice is less common in the north, where soils are less productive, and a longer rainy season presents additional challenges with increased impacts of a fungus that affects rubber plantations. The project intends to sequester a net carbon

http://www.rainforest-alliance.org/programs/forestry/smartwood/index.html

http://www.rainforest-alliance.org/climate.cfm?id=international_standards

http://www.v-c-s.org/policyannounce.html

http://www.v-c-s.org/policyannounce.html


stock benefit of 1,739,855 tCO2e over the course of the 42 year VCS crediting period. The project includes a financial analysis that demonstrates the impact of the sale of carbon credits associated with project activities, resulting in an increased rate of return for investors above a minimum investment threshold that decreases the financial risk of the project making investments in project activities possible. Without the sale of carbon credits, the project would not be able to meet the minimum investment return threshold. Although rubber production is common in the south with traditional rubber production, this project intends to increase the sustainability of rubber production through certification of FSC, which is not common throughout the entirety of Guatemala. According to interviews with Project Proponents, plantation managers, and review of management plans the rubber plantations involved in project activities will be managed for a minimum one complete rotation with the commitment to replant rubber tree plantations following the culmination of the 36 year rotation period. Following this rotation period, the rubber trees will be harvested, and the plantations will be re-planted as rubber tree plantations.

1.4 Level of assurance The calculated GHG assertion was verified to a reasonable level of assurance. Based on the audit findings, a positive verification statement reasonably assures that the project GHG assertion and monitoring report are materially correct and is a fair representation of the GHG data and information.


2 Methodology

2.1 Description of the Audit Process

In May of 2010 Rainforest Alliance completed the validation audit of the PICA forest carbon project. At this time all documents related to ownership, and ex ante GHG ownerships were assessed. In addition, the validation audit included an initial validation of the project self-risk assessment. Project information, including the self-risk assessment was re-visited during the verification audit. The verification audit was completed by a team of two Rainforest Alliance auditors. The audit was conducted in three (3) of the seven (7) farms within the project area. During the field audit the audit team met with farm managers, monitoring crews, relevant stakeholders, and PICA staff responsible for project management and implementation. On-site inspections of reforestation areas was combined with the re-measurement of 46 plots by the audit team, including two plots where inventory techniques were demonstrated by the PICA monitoring crews. In total 1,380 trees were re-measured by the audit team, representing a total census of 10 sub-strata. In addition to field re-measurements, monitoring inventory techniques and correct use of equipment was observed by the audit team on two farms visited. Field data sheets were also reviewed for all strata, and a random sample from each sub-strata was assessed for correct data entry into excel spreadsheets used to calculate GHG removals. During the field audit, monitoring records were evaluated, and record retention protocols were assessed by the audit team. Following the field audit, several follow up interviews were conducted by the audit team of additional project stakeholders and forest statisticians. Below is a list of relevant information collected during the verification audit.

Location/Facility Date(s) Length of Audit

Auditor(s)

Bello Horizonte Farm 17 Jan 11 8 hours William Arreaga and Jared Nunery

Bello Horizonte Farm 18 Jan 11 5 hours William Arreaga and Jared Nunery

El Horizonte Farm 19 Jan 11 6 hours William Arreaga and Jared Nunery

Asuncion Farm 19 Jan 11 4 hours William Arreaga and Jared Nunery

Asuncion Farm 20 Jan 11 6 hours William Arreaga and Jared Nunery

2.2 Audit team

Auditor(s) Qualifications

William Arreaga, Rainforest Alliance, Forester, SmartWood Central America Region

Lead Auditor

Contact info:

[email protected]

Phone: (502) 2383-5757

William is a Rainforest Alliance Lead Carbon Auditor. Guatemalan; Forestry Specialist, Central American SmartWood Office. Forestry degree from the Escuela Nacional Central de Agricultura, and an engineering degree from USAC; in 2002 he received an M.Sc. in Tropical Forest Management and Biodiversity Conservation from CATIE (Costa Rica). His work has been focused in plantations and natural forests managed in Central America. He also has experience in carbon storage and carbon flows in natural forests and plantations. In 2007, he spent two months at Winrock International as a fellow.

Jared Nunery, Rainforest Alliance, SmartWood Program Carbon Technical Specialist

Audit team member

Contact info:

[email protected]

Phone: +1(802) 434-8732

Jared has led the technical review of multiple validation assessments for the VCS. In addition he has participated in two Improved Forest Management methodological assessments for the VCS. Before joining the Rainforest Alliance, Jared worked as a member of the Carbon Dynamics Lab at the University of Vermont, where he conducted research on the effects of forest management on carbon sequestration. Jared has published multiple scientific articles on forest carbon dynamics as well as general forest ecological processes.

Jared has a B.S. in Environmental Sciences from the University of Vermont and earned his M.Sc. in Forestry from the University of Vermont. Jared has extensive

mailto:[email protected]

mailto:[email protected]


experience in forest stand dynamics, forest carbon dynamics, forest mensuration, GHG quantification, forest growth and yield modeling, and wildlife habitat conservation. In addition Jared is a certified lead auditor with the Climate Action Reserve for Forest and Urban Forest projects.

2.3 Review of Documents The following documents were viewed in the audit process:

Ref Title, Author(s), Version, Date Electronic Filename

1 2010 PICA Monitoring report 2010 PICA Monitoring report

2 Map of Asuncion Project Area Boundary ASUNCION_PROJECT_BND

3 Map of Bello Horizonte Project Area Boundary BELLO_HORIZONTE_PROJECT_BOUND_16dic

4 Map of Concepcion Project Area Boundary CONCEPCION_project_bnd

5 Map of El Horizonte Project Area Boundary HORIZONTE_PROJECT_BND20DIC

6 Map of Los Patos Project Area Boundary LOSPATOS_PROJECT_BOUND

7 Map of Palmeras Project Area Boundary PALMERAS_PROJECTBOUND

8 Map of Rio Frio Project Area Boundary RIOFRIO_PROJECT_BOUNDARUY_6jan

9 Map of Farms of PICA's carbon project Farms of PICA's carbon project

10 PICA - Baseline Report PICA - Baseline Report

11 PICA - Leakage Analysis - Tables PICA - Leakage Analysis - Tables

12 PICA - Leakage Analysis PICA - Leakage Analysis

13 Planting density reports, years 2007, 2008 and 2009 Planting density reports, years 2007, 2008 and 2009

14 Map of Bello Horizonte Planting N1-Bello Horizonte clones distribution

15 Map of Concepcion Planting N3-Concepción plantations distribution

16 Map of Palmeras Planting S1-Palmeras clones distribution

17 Map of Los Patos Planting S2-Los Patos-Clone distribution

18 Map of Asuncion Planting S3-Asunción-clone distribution

19 Map of El Horizonte Planting S4-El Horizonte-clone distribution

20 Map of Asuncion Sampling Plots ASUNCION 2009 presamplinng event

21 Map of Bello Horizonte Pre-inventory Sampling Plots BELLO HORIZONTE 2009 presampling event

22 Map of Concepcion Pre-inventory Sampling Plots CONCEPCION 2009 presampling event

23 Map of El Horizonte Pre-inventory Sampling Plots EL HORIZONTE 2009 presampling event

24 Map of Los Patos Pre-inventory Sampling Plots LOS PATOS 2009 presampling event

25 Map of Palmeras Pre-inventory Sampling Plots PALMERAS 2009 presampling event

26 2009 pre-sampling field sheet 2009 pre-sampling field sheet

27 Sampling plots MIRASILV summaries 2,009 Sampling plots MIRASILV summaries 2,009

28 Bello Horizonte Inventory Monitoring 2007 Planting PSP-N1-07



31 Concepcion Inventory Monitoring 2007 Planting PSP-N3-07



34 Palmeras Inventory Monitoring 2007 Planting PSP-S1-07

35 Palmeras Inventory Monitoring 2008 Planting PSP-S1-08

36 Los Patos Inventory Monitoring 2007 Planting PSP-S2-07

37 Los Patos Inventory Monitoring 2008 Planting PSP-S2-08

38 Asuncion Inventory Monitoring 2008 Planting PSP-S3-08

39 Asuncion Inventory Monitoring 2009 Planting PSP-S3-09

40 El Horizonte Inventory Monitoring 2007 Planting PSP-S4-07



43 2010 Monitoring field sheet 2010 Monitoring field sheet


44 Map of PSP Locations – Bello Horizonte PSPs-N1-2010

45 Map of PSP Locations – Concepcion PSPs-N3-2010

46 Map of PSP Locations – Palmeras PSPs-S1-2010

47 Map of PSP Locations – Los Patos PSPs-S2-2010

48 Map of PSP Locations – Asuncion PSPs-S3-2010

49 Map of PSP Locations – El Horizonte PSPs-S4-2010

50 2010 Monitoring calculations summary 2010 Monitoring calculations summary

51 PICA - Monitoring Plan v.2 2010 PICA - Monitoring Plan v.2 2010

52 AR-ACM0001 v.3 AR-ACM0001 v.3

53 Estimación de una ecuación de biomasa para cuantificar el carbono que fija el arbol de hule (Hevea brasiliensis) en las plantaciones de la Costa Sur de Guatemala, F.A. Morales Ralda, 2000

Morales 2000

54 2010 Monitoring audit entering data sheet 2010 Monitoring audit entering data sheet

55 2010 Monitoring entering data audit 2010 Monitoring entering data audit

56 2010 Monitoring field measurements audit 2010 Monitoring field measurements audit

57 2010 Monitoring field measurement audit 2010 Monitoring field measurement audit

58 2010 Monitoring field audit sheet 2010 Monitoring field audit sheet

59 PICA VCS PD 6th October 2010, v04 PICA VCS PD 6th October 2010, v04

60 IPCC Good Practice Guidance for LULUCF / Chapter 4: Supplementary Methods and Good Practice Guidance Arising from the Kyoto Protocol

GPG-LULUCF-Chp4

61 Field Sampling photos and videos Various photos and videos

62 Laboratory analysis photos Various photos

63 Informe de análisis Laboratory reports and results

64 Procedimiento para realizar medición de peso en campo y peso seco en laboratorio de muestras para proyecto PICA DE HULE NATURAL

Soluciones analísitcas laboratory protocol

65 Sourcebook for AFOLU Projects (Pearson et al, 2005) Winrock-BioCarbon Fund Sourcebook

66 Estimación de una ecuación para cuantificar la cantidad de carbono fijado en árboles de Hule (Hevea brasiliensis), con diámetros menores a 5 centímetros en Guatemala. (Quemé, S. 2010)

Statistical report for developing a new equation.

67 Comparison between models Test of models

68 PICA's methodology of a new equation “Developing a new equation to estimate Carbon stock in rubber trees (Hevea brasiliensis) below 5cms of diameter at breast height (DBH) in Guatemala.” PICA‟s Carbon Project.

PICA's methodology of a new equation

69 2010 PICA Monitoring report v.2 2010 PICA Monitoring report v.2

70 PICA CAR‟s Closure Narrative PICA CAR's closure.docx

71 PICA CAR Closure Spreadsheet PICA's car's closure.xls

72 PICA Monitoring Plan v2 PICA - Monitoring Plan v.2 2010

73 1 PICA-Protocolo para la Custodia de Documentación 1 PICA-Protocolo para la Custodia de Documentación

74 Data archiving-Packing list Data archiving-Packing list

75 2010 Monitoring calculations summary 2010 Monitoring calculations summary.xls

76 PSP-N1-07 PSP-N1-07.xls

2.4 Stakeholder Interviews The following is a list of the people interviewed as part of the audit. The interviewees included those people directly, and in some cases indirectly, involved and/or affected by the project activities.

Audit Date

Name Title

17-19 Luis Alejandro Mejia Caniz Ecobusiness Manager, PICA


January

17-20 January

Pablo Ignacio Dominguez Technical Sustainability and Carbon Manager, PICA (Monitoring coordinator)

18 January

Ronaldo Pasos General Farm Manager (Bello Horizonte)

17-18 January

Miguel Angel López Monitoring Crew Team Leader (Bello Horizonte)

17-18 January

Marlon Alvarado Monitoring Crew Team Member (Bello Horizonte)

17-18 January

Andrés Cabrera Monitoring Crew Team Member (Bello Horizonte)

19-20 January

Waldemar Dell Manager Ingenio Magdalena

19-20 January

Alvaro Mérida Manager Ingenio Magdalena

19-20 January

Macario Canás Monitoring Crew Team Leader (Asunción, El Horizonte)

19-20 January

Abel Flores Monitoring Crew Team Member (Asunción, El Horizonte)

19-20 January

Hugo Ordóñez Monitoring Crew Team Member (El Horizonte)

31 January

Sergio Quemé Pac Statistician consultant

2.5 Resolution of any material discrepancy The audit identified non-conformities to the assessment criteria 4.3.1, 4.4.3, 4.4.6, and 4.6, 4.7. These led to 4 Corrective Action Requests (CARs) that were resolved by the client, as evidenced by findings on CAR closure in this report, section 3.2, and our opinion is that the GHG assertion is free of material discrepancy.


3 Verification Overview Based on Project’s conformance with VCS requirements, the auditor makes the following recommendation:

Final Report Conclusions

Verification approved:

No CARs issued

Verification not approved:

Conformance with CAR(s) required

Draft Final Report Conclusions


No CARs issued

The Project proponent has 7 days from the date of this report to submit any comments related to the factual accuracy of the report or the correctness of decisions reached. The auditors will not review any new material



Draft Report Conclusions


No CARs issued

The Project Proponent has 30 days from the date of this report to revise documentation and provide any additional evidence necessary to close the open corrective action request. If new material is submitted the auditor will review the material and add updated findings to this report and close CARs appropriately. If no new material is received before the 30 day deadline, or the new material was insufficient to close all open CARs the report will be finalised with the CARs open, and verification will not be achieved. If all CARs are successfully addressed, the report will be finalised and proceed towards issuance of a verification statement.



3.1 Verification summary During the field audit, four non-conformances were identified. These non-conformances were identified in the Draft Verification Report as Corrective Action Requests. Following the issuance of the Draft Verification Report, PICA revised the Monitoring report and supporting documents to address identified CARs. The findings relevant to the closure of all CARs are included in section 3.2, whereas the findings from the field audit are included in section 4 below. Following the receipt of the revised Monitoring Report and supporting documents, all CARs were closed. With the closure of all four CARs, Rainforest Alliance now finds the Monitoring Report and project activities in conformance with the VCS 2007.1 standard and can verify the GHG assertion outlined in 5.1 below with a reasonable level of assurance.

3.2 Correct Action Requests

Note: A non-conformance is defined in this report as a deficiency, discrepancy or misrepresentation that in all probability materially affects carbon credit claims. Corrective Action Request (CAR) language uses “shall” to suggest its necessity but is not prescriptive in terms of mechanisms to mitigate the CAR. Each CAR is brief and refers to a more detailed finding in the appendices. CARs identified during draft verification reports must be successfully closed by the Project Proponents before Rainforest Alliance submits the final verification report and opinion to the VCS. Any open CARs will result in a negative verification statement which lists: (a) all corrective action requests, (b) rationale for each request, and (c) impact of each material finding on GHG assertion. Qualified verification statements are not accepted by VCS. Evidence submitted to close CARs were reviewed by the audit team, and findings relevant to the assessment of additional evidence and revised documents is described in this section.


CAR: 01/11 Reference Standard & Requirement: 4.3.1 Conformance of ex post calculation with identified methodology and validated PDD

Non-conformance:

The audit team reviewed every spreadsheet related with ex post calculations (e.g. PSP-N1-07.xls) to make sure the Project Proponent has estimated the total amount of carbon (stock/removals) within the monitoring period (2007-2010) in conformance with the selected methodology and the validated PDD.

The revision revealed that the calculations followed the VCS requirements and the methodology was implemented accordingly. However, in the specific case of PSP number 10, established in Bello Horizonte farm (Plot ID PPM-N1-07-10), the clone was registered as PB-260, while the map of the farm shows differently, clone PB-255.

This could be an error made during the transcription of the information into the spreadsheet. However the audit team considered that if this error were not corrected it could result in unrealistic carbon stock calculations in the clones involved.

Corrective Action Request: PICA shall correctly estimate the mean carbon stock of Bello Horizonte farm (tCO2/ha) taking into account the actual clone.

Timeline for conformance:

Prior to verification

Evidence to close CAR: The audit team reviewed the spreadsheet named PSP-N1-07.xls which corresponds to the specific case of ex post calculations of Bello Horizonte/Plantation year 2007/Clone PB-255. The Project Proponent shows the calculations of all the plots distributed in the farm, now taking into account the real clone of every plantation block. One basic correction was done, then all the calculations were modified automatically since everything is linked with formulas.

Now, in the sheet named “calc.summary” the total tree live biomass of the mistaken data is found in the correct clone, PB-266. Then automatically the following changes appear:

a) PB-266: 42.5 tCO2/ha ± 3.8 of standard deviation (n = 4 plots),

b) PB-255: 41.97 tCO2/ha ± 4.5 of standard deviation (n= 5 plots),

As a result, the correct weighted mean carbon stock of Bello Horizonte also changed from 734.99 tCO2/ha (5.27% of precision at 95% of confidence) to 738.01 tCO2/ha (5.16% of precision at 95% of confidence). Finally, the total carbon stock of the project was updated to 41,017.28 tCO2/ha. Based on these new calculations, the audit team considered that the nonconformance was addressed in an appropriate way.

CAR Status: Closed

Follow-up Actions: No follow up action required

CAR: 02/11 Reference Standard & Requirement: 4.3.1 Conformance of ex post calculation with identified methodology and validated PDD

Non-conformance:

PICA did not clearly state that all documents would be retained for 2 years follow the end of the crediting period as required by the VCS

Corrective Action Request: PICA shall clearly state in the monitoring report that all documents would be retained for two years follow the end of the crediting period as required by the VCS.



Evidence to close CAR: Following the issuance of the Draft Verification Report, PICA revised section 7 of the Monitoring Plan to clearly state:

“According to VCS Standard, data archiving must be done for at least two more years after the end of the project crediting period. The PICA’s project crediting period ends in 2049. PICA has assurance that data archiving and storage will be carried on until year 2051, which is in accordance with the VCS Standard 2007.”

Additionally, section 9.3 PICA‟s QA/QC for data archiving of the Monitoring Report was


revised to clearly state data archival procedures in conformance with the VCS 2007.1.

Finally, PICA also submitted additional documents included in Annex VI QA/QC. These documents include further procedural guidance on the archival of data, including specific guidance on the VCS data archival requirements. This is specifically outlined in Section II of the document titled: “PROTOCOLO PARA LA COSTODIA DE DOCUMENTACIÓN”. The audit team found the revisions to the Monitoring Plan and Monitoring Report to be sufficient to close CAR 02/11.

CAR Status: Closed

Follow-up Actions: Future verification audits should assess conformance with the revised data archival procedures.

CAR: 03/11 Reference Standard & Requirement: 4.4.3, 4.4.6 Quality of evidence used to determine emissions reductions

Non-conformance:

The VCS requires that project proponents include an assessment of uncertainty. As cited in section 6.5.4 of the VCS 2007.1 standard: “The project proponent shall establish and apply quality management procedures to manage data and information, including the assessment of uncertainty, relevant to the project and baseline scenario. The project proponent should reduce, as far as is practical, uncertainties related to the quantification of GHG emission reductions or removal enhancements.”

It is not clear how PICA has assessed uncertainty related to the quantification of GHG emission removals. Specifically, the GHG calculations do not include any quantification of uncertainty associated with GHG removal calculations, or a deduction of associated uncertainty. With no assessment of uncertainty, it is not clear how the GHG assertion is in conformance with the fundamental VCS guiding principles of accuracy and conservativeness outlined in section 5.1 of the VCS 2007.1 standard.

Corrective Action Request: PICA shall include within the monitoring report an assessment of uncertainty.



Evidence to close CAR: During the field audit, quality control procedures were assessed by the audit team, and also verified (see Section 4.5.4 and Appendix B of this report).

Included in the revised Monitoring Report is Section 10 PICA’s Uncertainty Analysis. The revised section includes a comprehensive description of the mechanisms and procedures PICA employed to reduce uncertainty within carbon calculations. The revised Monitoring Report clearly describes the QA/QC procedures, and how the implementation of these procedures addresses the uncertainty requirements of AR-AMS0001 v3 and the VCS 2007.1.

Moreover, section 10 of the revised Monitoring Report includes an assessment of the project activities in conformance with the IPCC Guidance for National Greenhouse Gas Inventories (2006). Section 10 includes Table 21 Summary of PICA‟s uncertainty assessment.

The addition of Section 10 to the Monitoring Report now clearly describes the procedures utilized by PICA to reduce the risk of high uncertainty. These procedures were found by the audit team to be in conformance with the AR-AMS0001 v3 Methodology and the VCS 2007.1 Standard. As such CAR 03/11 is closed.

CAR Status: Closed


Follow-up Actions: No follow up action required.

CAR: 04/11 Reference Standard & Requirement: 4.6 and 4.7 Risk Assessment and Buffer Determination

Non-conformance:

The monitoring report does not include the VCS Non-Permanence Risk Analysis and Buffer Determination.

Corrective Action Request: PICA shall include the completed VCS Non-Permanence Risk Analysis and Buffer Determination within the monitoring report.



Evidence to close CAR: During the field audit, the risk assessment was presented to the audit team for review (see sections 4.6 and 4.7 below), however the risk assessment was not included within the Monitoring Report.

The revised Monitoring Report v2 includes Section 11 Risk Assessment. Section 11 of the revised Monitoring Report includes a comprehensive general risk assessment in conformance with Table 1 of the VCS Tool for AFOLU Non-Permanence Risk Analysis and Buffer Determination. Within the general risk assessment, all criteria are identified as low risk with the exception of the Risk of social instability and Risk of extreme weather events. During the field audit, the audit team assessed the general project risk criteria and found the self-risk ratings to be sufficient. Furthermore, risk mitigation activities such as commitment to FSC certification reduce the risk of social instability through increased communication with impacted stakeholders and required adherence to social responsibility criteria associated with project activities. Risk of extreme weather events is rated as medium, however this was justified to be medium-low due to the relatively large return interval for catastrophic disturbances such as hurricanes within the project region (category 5 hurricane return interval being 33 to 500 years).

Additionally, the revised Monitoring Report includes an ARR project type specific risk assessment in conformance with the VCS Tool for AFOLU Non-Permanence Risk Analysis and Buffer Determination. In this assessment all criteria are identified as low risk with the exception of Project longevity/Commitment period and Ownership type and user rights. The risk of project longevity is mitigated by the commitment to replant following the final harvest of the project area after the 36 year rotation. During the validation field audit in May 2010, the Rainforest Alliance audit team visited additional rubber plantations owned by the Project Proponent not included within the VCS project activities, where long-term management of rubber trees was demonstrated. Furthermore, interviews with project staff and farm employees all confirmed long-term commitment to the carbon project. Additionally, the medium risk of land ownership is the result of one of the project areas being leased by the farm manager. During the field audit, the audit team was presented with clear legal rights to the project areas, and also clear contracts documenting ownership of all carbon rights. The legal lease contracts for 50 year periods by Ingenio Magdalena were reviewed during the validation audit in May 2010 by Rainforest Alliance, and found to provide reduced risk of land ownership disputes.

During the validation audit conducted by Rainforest Alliance in May 2010 the project Non-Permanence Risk Analysis was assessed by Rainforest Alliance and found to be in conformance with the VCS 2007.1 standard. During the verification field audit in January 2011, no change in the identified risk assessment criteria were found (see findings in sections 4.6 and 4.7 below). As such, the audit team determined that the identified self-risk classification of “medium” was found to be appropriate. Furthermore, the use of a 20% buffer was found to be justified, as required by the 13April2010 VCS Program Update, based on the mitigation activities and referenced evidence to justify the use of the lower threshold within the ARR default buffer withholding for Medium ARR Risk Class projects.


CAR Status: Closed

Follow-up Actions: No follow up action required

3.3 Observations

OBS 01/11 Reference Standard & Requirement: 4.1.2 Project implementation

As noted in 2.4.4, the baseline area was divided into two strata, largely defined geographically by the “north” and “south” strata. At the time of validation, it was intended by the project developer to use the same stratification for the project area. However, following initial monitoring results of 2007 and 2008 planted areas conducted in 2009, it became evident that additional stratification was required to account for highly variable growth rates between varying clones planted within each farms. The updating of strata in the project area is explained in section 4.1 of the monitoring report. Ex post stratification of the project area is allowed by AR-ACM0001 v03, as a means of reducing variability and increasing accuracy of sampling. The Monitoring Report describes the ex post stratification as being based on clones planted per planting year. However, during the verification audit, interviews with PICA staff responsible for GHG calculations revealed that clones planted per planting year were used as sub-strata to calculate a weighted average used to calculate mean carbon fixation per farm per planting year. The total carbon fixation per farm per planting year was then summed to calculate total project area carbon fixation, as per equation 14 of the AR-ACM0001 v03. As such, section 4.1.3 of the Monitoring Report incorrectly describes the clones planted per planting year as the ex post strata, when these are actually being used as sub-strata to calculate carbon stocks within the strata.

Observation: PICA should clearly explain how ex post strata and sub-strata are used to calculate project GHG removals.

OBS 02/11 Reference Standard & Requirement: 4.2.1 Project boundary monitoring

During the monitoring period, the project area boundary did not change. As such, PICA is not required to account for changes in the project area. However, discussions with PICA staff revealed confusion over how carbon stock losses are accounted for following a disturbance. It should be noted that it is not appropriate to simply re-calculate the project boundary following a disturbance (excluding those disturbed areas and not accounting for carbon stock loses), but rather the project proponent is responsible for accounting for the carbon stock loses in carbon stocks within the validated project boundary. This was explained to the project proponent during the field audit.

Observation: PICA should be aware of the VCS requirements for calculating carbon stock losses in future verifications.

OBS 03/11 Reference Standard & Requirement: 4.3.1 Conformance of ex post calculation with identified methodology and validated PDD

In the monitoring report, the company defines “removals” as “carbon fixation”, this is incorrect according to the methodology used

Observation: PICA should use the correct definitions of VCS according to the methodology: “removals” instead of “carbon fixation”.


During the field audit, audit team reviewed the Monitoring Report and revealed that the amount of SOC is slightly different from the spreadsheet (2010 Monitoring calculations summary.xls. The total amount of SOC was estimated by PICA for the first three years (2007-2009) as 2,233 tCO2e in the Monitoring Report. However, the spreadsheet 2010 Monitoring calculations summary.xls shows a minimum difference (2,234 tCO2e)

Observation: PICA should align the monitoring report and the spreadsheet 2010 Monitoring calculations summary.xls with the correct soil organic carbon (tCO2e).

Note: Observations are issued for areas that the auditor sees the potential for improvement in implementing standard requirements or in the quality system; observations may lead to direct non-conformances if not addressed. Unlike Corrective Action Requests, Observations are not formally closed.



In the selected methodology, the definition of tequilibrium is: “Time until a new equilibrium in carbon stock in soil organic matter is reached”. The project proponent uses well this definition and the value suggested by the methodology (20

years), however, in the monitoring report calculations use a value of 23 years. The other default value of was

used accordingly.

This is considered by the audit team as a deviation which does not represent a current significant difference while calculating the total SOC within the monitoring period. However it is necessary that the project proponent clarifies for further verifications, why they are using 23 years instead of 20 years for the calculation of tequilibrium.

Observation: PICA should clearly explain in the monitoring report the decision of using 23 years as the time when the equilibrium in the soil is reached, instead of 20 years as mandated by the methodology.

OBS 06/11 Reference Standard & Requirement: 4.3.7 Calculation of net VCUs to be issued (ex-post estimate)

It should be noted that the procedure clearly explains that the buffer percentage shall be multiplied by net GHG credits, meaning the project proponent cannot subtrack leakage before applying the buffer percentage. However, as leakage emissions related to project activities are estimated to be equal to zero (as demonstrated in the validated PDD and supporting documents in Annex I. Baseline), the Project Proponent has calculated the total number of VCUs correctly.

Observation: PICA should note that according to the VCS requirements, the number of VCUs shall be estimated subtracking the leakage after applying the buffer percentage.

3.4 Actions taken by the Project Proponent Prior to Report Finalisation Following the issuance of the Draft Verification Report on March 4th, 2011, PICA revised the Monitoring Report to address CARs identified during the field audit. Following the submission of the Draft Verification Report, PICA contacted Rainforest Alliance on March 7th and March 9th for additional clarification regarding the CARs identified in the Draft Verification. On March 16th, 2011, PICA submitted the revised Monitoring Report, and supporting annexes to Rainforest Alliance for review. The findings related to the closure of all CARs were included in section 3.2.


4 Verification Findings The findings presented in this section represent the findings from the field audit. All non-conformances identified during the field audit are described within this section. Additional evidence submitted following the issuance of the Draft Report was assessed by the audit team, and findings related to the assessment of additional evidence submitted by the Project Proponent to close CARs is described in section 3.1 above.

4.1 Project Implementation The discussion, findings and conclusion regarding the conformity of the actual project activity with the registered project design document should be summarised in this section.

4.1.1 Project title, Purposes and Objectives

Findings from Review on March 4th, 2011

The carbon project title: Promoting Sustainable Development through Natural Rubber Tree Plantations in Guatemala accurately reflects the proposed project. The additionality argument of this carbon project is founded in the financial analyses based on the Project Proponent‟s dedication to promoting sustainable development of rubber plantations in Guatemala. This dedication is expressed in the text on page 3 of the 2007 PICA statement of intent, which declares the Project Proponents dedication to the promotion of Forest Stewardship Council Certification of rubber tree plantations. The primary argument of the project proponent is that by meeting the 10 principals of FSC certification, PICA will be able to increase the sustainability of their rubber plantations both environmentally and economically through the pursuit of new markets for the sale of Non-timber Forest Products (NTFPs).

Conformance Yes No N/A

CAR/OBS No CAR or OBS raised

4.1.2 Stratification of Baseline and Project Areas


As noted in 2.4.4, the baseline area was divided into two strata, largely defined geographically by the “north” and “south” strata. At the time of validation, it was intended by the Project Proponent to use the same stratification for the project area. However, following initial monitoring results of 2007 and 2008 planted areas conducted in 2009, it became evident that additional stratification was required to account for highly variable growth rates between varying clones planted within each farms. The updating of strata in the project area is explained in section 4.1 of the monitoring report. Ex post stratification of the project area is allowed by AR-ACM0001 v03, as a means of reducing variability and increasing accuracy of sampling. The Monitoring Report describes the ex post stratification as being based on clones planted per planting year. However, during the verification audit, interviews with PICA staff responsible for GHG calculations revealed that clones planted per planting year were used as sub-strata to calculate a weighted average used to calculate mean carbon fixation (meaning removals, according to VCS) per farm per planting year. The total carbon fixation per farm per planting year was then summed to calculate total project area carbon fixation, as per equation 14 of the AR-ACM0001 v03. As such, section 4.1.3 of the monitoring plan incorrectly describes the clones planted per planting year as the ex post strata, when these are actually being used as sub-strata to calculate carbon stocks within the strata. (OBS 01/11)

Despite the confusion within the Monitoring Report, review of the annexed document “2010 Monitoring calculations summary” and interviews with PICA staff responsible for GHG calculations, revealed that the ex post stratification of the project area is in conformance with the requirements of the AR-ACM0001 v03 methodology.


CAR/OBS OBS 01/11

4.1.3 Ownership/Proof of Title/Right of Use


The project area consists of seven different farms, located in three zones: Suchitepéquez, Izabal, and Alta Verapaz. PICA S.A. as the project proponent, does not own any of those farms by itself. All the farms belong to different Sociedades Anónimas (LLC), where PICA has the explicit rights to manage and sell the carbon credits.


Land ownership is defined in Table 1 on p.4 of the PDD. Furthermore, land tenure is discussed in section 2.3 of the PICA Monitoring Report, where it is explicitly stated, “PICA does not lease any lands within the project, every farm has its proof of title which is a legal document demonstrating property rights. The legal title is a unique record for each farm recorded at Guatemala’s Cadastral Registry. In the case of Los Patos, Asunción and El Horizonte, all farms are privately owned and managed by Ingenio Magdalena. Los Patos and Asunción are legally leased by Ingenio Magdalena for a period of 50 years. Bello Horizonte, Rio Frio, Concepcion, and Palmeras are privately owned and they are being managed by their original owners (i.e these 4 farms are not leased to anybody).”

During the validation field visit, land tenure documents for project areas were provided by Project Proponents to Rainforest Alliance. At this time a sub-sample of these documents was thoroughly reviewed by auditors. Additionally, at this time PICA had entered into contractual agreements with farm owners, declaring the ownership of the GHG rights for a 20 year period, as per the amendments reviewed on 22 September 2010 during the Rainforest Alliance validation audit. As such, Rainforest Alliance identified clear ownership of the GHG rights for the 20 year. Since the 22 September 2010 validation assessment, there has been no change in the project area ownership. Combined with the clear legal title to the project area lands and the 20 year GHG contracts, the audit team found that PICA has demonstrated clear legal title over all project areas, as stated in the monitoring report.



4.1.4 Implementation of project activities during monitoring period


During the monitoring period, PICA has planted a total of 1,235.7 ha of the proposed 2,355.15 ha project area, as outlined in Table 1 of the Monitoring Report. Planting has followed proposed procedures outlined in the PDD, and unplanted areas are not included within the monitoring.

During the field audit, the audit team observed two of the five monitoring crews used to collect monitoring data. Monitoring crews demonstrated field techniques used to sample PSPs, and were found to be competent and follow the procedures outlined in the monitoring plan.

Several deviations from the validated monitoring plan were included within the ex post monitoring. These deviations were clearly described within the Monitoring Report.

1) The first deviation regarding the ex post stratification of the project area to address high variability identified within planted H. brasiliensis clones, is clearly described in section 4.1 of the monitoring plan. See 4.1.2 for a complete description of the ex post stratification.

2) The second deviation regarding sampling size is described within section 4.1.3.1 of the Monitoring Report. In an effort to address high variability identified during the 2009 pre-monitoring sampling, plot size and numbers were increased beyond the original plan outlined within the validated monitoring plan. The original monitoring called for permanent sample plots (PSP) to include 10 trees, representing 181.18 m2 fixed area plots (area calculated based on planting design and density). During the 2010 monitoring conducted to verify GHG removals, the plot size was increased to 30 trees, increasing the PSP area to 540-588 m2 (plot sizes vary within farms due to varying planting designs and densities, however PSPs always include 30 trees). Additionally, the original number of PSPs was calculated using the CDM tool “Calculation of the number of sample plots for measurements within A/R CDM project activities”. The use of the CDM tool indicated that 30 plots per strata was required, representing a total of 180 plots (see Table 2 in PICA monitoring plan). However during the 2009 pre-monitoring sampling, PICA determined that this number was not sufficient to meet the desired precision level of ±10% at the 95% confidence interval (as identified in 3.4.2 of the PDD). As such the total number of PSPs was increased to 262 (see table 17 of the monitoring report).

The identified deviations were found to be conservative deviations, to increase accuracy of GHG calculations, and as such were found to be appropriate.




4.1.5 Double counting and whether the project participated in another emission trading programme


Section 1.13 of the PDD states:

“The project is not seeking to generate any other environmental credits other than carbon credits associated with the VCS. FSC certification for project activities will not generate environmental credits.”

This is in conformance with the requirements of the VCS standard described in section 5.7 of the VCS 2007.1 standard. This was validated through interviews with PICA staff during the field audit. Conversations with PICA staff during the validation audit revealed that the project proponent does intend to possibly transfer the project to the CDM, following validation to the VCS. As this is not definite, and is based on favourable markets, this was described as a possibility, and the consequences of the transfer (e.g. loss of VCUs contributed to the Buffer) were acknowledge by the Project Proponent, in addition to the VCS double counting rules. Following the verification audit, a remote assessment of other voluntary standards was conducted by the audit team on 02 February 2010, indicate that the project is not registered under the American Carbon Registry (http://www.americancarbonregistry.org/carbon-registry/projects/project-list/acr_atct_topic_view?b_start:int=20&-C=), CarbonFix Standard (http://www.carbonfix.info/Project.html?PHPSESSID=pfqu9pog6k5hpsnfj2ko6vkqp7) or the Gold Standard (https://gs1.apx.com/myModule/rpt/myrpt.asp).



4.1.6 Observation of local laws and regulations


Section 1.10 of the PDD describes the relevant Guatemalan laws, and the demonstration of compliance by the Project Proponent. Included in the annexed documents (see annex C of the PDD), are Environmental Impact Assessments for each of the farms where EIAs are required, and the diagnostic reports for those farms where EIAs are not required. At the time of the verification audit, and throughout the 2007 – 2009 monitoring period, the project appears to be in compliance with all applicable Guatemalan laws.



4.2 Completeness of monitoring

The discussion, findings and conclusion regarding correct application of the monitoring methodologies and the completeness of the monitoring should be summarised in this section.

4.2.1 Project boundary monitoring


It should be noted that at the time of Verification a revised monitoring plan was submitted to Rainforest Alliance for assessment. The revised monitoring plan titled “Monitoring Plan v02, 2010” is a revision of the validated PICA monitoring plan titled “PICA – Monitoring Plan”. The revised monitoring plan was found to remain in conformance with the VCS standard and AR-ACM0001v.3 methodology, and as such, the revised plan was used to evaluate conformance with implemented monitoring activities. Specifically, the primary revisions to the monitoring plan reflect an increased sampling intensity and re-stratification of the project area.

During the monitoring period, the project area boundary did not change. As such, PICA is not required to account for changes in the project area. However, discussions with PICA staff revealed confusion over how carbon stock losses are accounted for following a disturbance. It should be noted that it is not appropriate to simply re-calculate the project boundary following a disturbance, but rather the project proponent is responsible for the carbon stock loses in existing carbon stocks. This was explained to the project proponent during the field audit. (OBS 02/11)

The total planted area was calculated based on planting densities; this area represents a subset of the total project area, as noted in Table 1 of the PICA Monitoring Report. By calculating planting area by planting densities and total trees planted, the project ensures the exclusion of existing vegetated areas within the project boundary such as creeks, border vegetation, and

http://www.americancarbonregistry.org/carbon-registry/projects/project-list/acr_atct_topic_view?b_start:int=20&-C

http://www.americancarbonregistry.org/carbon-registry/projects/project-list/acr_atct_topic_view?b_start:int=20&-C

http://www.carbonfix.info/Project.html?PHPSESSID=pfqu9pog6k5hpsnfj2ko6vkqp7

https://gs1.apx.com/myModule/rpt/myrpt.asp


small pockets of vegetation.

During the field audit, PICA staff further explained the difference between the calculated project boundary through the use of remote sensing techniques and the calculation of planted area through the use of the planting census and the planting densities. During the audit, planting census documents were reviewed by the audit team (Doc 13), and the accuracy of the documents was verified through interviews with farm employees responsible for the completion of the census. This technique was found to be in conformance with the validated technique for calculating planted area and the project boundary.


CAR/OBS OBS 02/11

4.2.2 Conformance with PDD Monitoring Protocol


Below are the findings relative to the outlined procedures in the Monitoring Plan v2, 2010.

PDD Required Monitoring Procedures Findings

3.1 Pre-sampling events Pre-sampling of the plantations established in 2007 and 2008 were pre-sampled in November and December of 2009. This initial pre-sampling was used to estimate the variance between strata, and calculate the necessary sampling intensity and guide re-stratification of the project area.

3.2 Stratification As described in 4.1.2 above, the project area was re-stratified. This re-stratification is allowed by the AR-ACM0001 v03 methodology, and was found by the audit team as a conservative deviation measure.

3.3 Plot distribution During the field audit, interviews with PICA staff revealed that bias in plot placement may have been introduced. The plot distribution is described within the monitoring plan as:

“After a reconnaissance visit, the PICA monitoring coordinator selects the locations of PSPs randomly within the area.” And then goes on to state, “Avoiding bias in physical distribution of PSP‟s, the monitoring coordinator applies the criteria taking into account the representativeness.”

During the field audit it was not clear how the PICA monitoring coordinator avoided bias, and this evidence of random distribution was not demonstrated by PICA. However, through field assessments the audit team verified representative distribution of PSPs throughout the visited project area. Furthermore, the audit team interviewed a Guatemalan statistical expert in forest inventory design, and confirmed that the sample plot distribution was not biased, and would not violate any statistical laws required by the statistical tests used in the project calculations.

3.4 Plot size and shape The increased sampling intensity to 30 trees per plot from the validated monitoring plan is reflected in v02 of the monitoring plan. The increased sampling intensity was verified through field audit re-measurement of 46 plots. In all cases the plot size and shape were in conformance with the monitoring plan.

3.5 Plot establishment During the field audit, the audit team re-measured 46 PSPs which represents 18% of the total. In all cases trees and plot markers were found to be labelled in accordance with the monitoring plan. Furthermore, interviews with monitoring crews confirmed competency and knowledge of plot establishment procedures.

Carbon measurements During the field audit, the audit team interviewed three field crews, and witnessed two crews re-measure PSPs. Through interviews and demonstration of monitoring techniques by the monitoring crew, the audit team confirmed conformance with the monitoring plan.




4.2.3 Baseline carbon stock and emissions monitoring (if applicable)


Baseline carbon stocks were measured and validated during the project validation. Baseline carbon stocks were quantified and assumed to be instantaneously released. As such the baseline carbon stocks are not monitored.


CAR/OBS Not applicable

4.2.4 Project carbon stock and emissions monitoring


As noted in 4.2.2 above, during the field audit the audit team interviewed monitoring crew members from 3 different monitoring crews (note that 5 different monitoring crews were used throughout the entire project area). Of these 3 teams, 2 teams were comprised of similar crew members from Asuncion and El Horizonte farms, due to the close proximity of these two farms.

During the field audit, monitoring crews demonstrated inventory techniques used to measure carbon stocks. Auditors confirmed crews ability to correctly use GPS equipment for the location and georeferencing of PSPs. Additionally, crews demonstrated DBH measurements, and data recording procedures. Additional interviews with monitoring crews confirmed training requirements outlined in the PDD, and competence in monitoring plan design and inventory techniques.



4.2.5 Monitoring of leakage (if applicable)


At the time of validation of the PDD, leakage was determined to be zero through the application of the CDM A/R methodological tool titled “Estimation of GHG emissions related to displacement of grazing activities in A‟R CDM project activity”. The correct application of this tool was demonstrated at the time of the validation of project activities. Furthermore, PICA submitted the document “PICA – Leakage Analysis” as a supporting document to the Monitoring Report. This document demonstrates the application of the CDM tool. As allowed by AR-ACM0001 v03, through the correct application of this tool, PICA has demonstrated that activity shifting leakage from the displacement of cattle from project areas can be assumed to be zero. As such, it is not required that PICA monitors leakage.



4.3 Accuracy of Emission reductions calculations

The discussion, findings and conclusion regarding spreadsheet formulas and connections, conversions, aggregations, consistent use of factors in line with the monitoring plan, possible manual transposition errors between data sets, uncertainty of technology (e.g. metering) and appropriateness of default data where specific source data is lacking should be summarised in this section.

4.3.1 Conformance of ex post calculation with identified methodology and validated PDD


According to the PDD (Version 4/October 6th, 2010), the Project Proponent chose the methodology ““AR-ACM0001 Version 03 „Afforestation and reforestation of degraded land”. A brief summary of the applicability of the methodology is shown in the Monitoring Plan (PICA VCS Monitoring Report 1: December 2010, Version 1). As part of this methodology, the tool “Procedure to demonstrate the eligibility of lands for afforestation and reforestation CDM project activities” was also used.

Both, the PDD and the methodology (+ tool) were assessed during the validation audit and verified during field visit. Due to the fact that the verification visit was done no more than 12 months after the official validation, no significant changes in the parameters were expected to change (baseline, additionality arguments, probable scenarios, other).

The monitoring has been carried out in line with the monitoring plan and PDD without significant deviations. In summary, the


most remarkable findings of the verification are:

Baseline methodology procedures:

a) Each discrete area of land has a unique geographical identification e.g. N1-07-PB255 meaning a plot located in the North (N) region, Bello Horizonte Farm (1), plantation established in 2007 with clone PB-255.

b) Every area is included in the boundary and eligible for and ARR project activity. Aerial photographs and landsat images were used to demonstrate the eligibility of the lands. The monitoring report summarizes the project boundaries of every farm as follows:

SOUTH STRATA (Ha) NORTH STRATA (Ha)

Palmeras Los Patos

Asunción El Horizonte

Bello Horizonte

Concepción Rio Frio

total

179.71 369.28 606.77 106.4 391 94 619 2,366.16

c) Above-ground biomass and below-ground biomass were included as carbon pools in the baseline calculations. Ex-ante stratification was done based on sites, North and South location of the plantations. Ex-post stratification considered more details such as location of the plantation, farm, plantation year, and clone.

d) CH4 from two identified burning events were taken into account (finca Los Patos and Palmeras) in the baseline scenario. No new burning events happened later within the crediting period so far, but the 127 tCO2e were discounted in the removal calculation (according to 2010 Monitoring calculations summary spreadsheet).

e) A robust PSP system was established in the plantations, and the Allometric Equations method was used to determine the mean carbon stocks in trees (based on two allometric equations), by strata. According to the monitoring plan, the equation 18 was used.

f) As a conservative measure, “the total carbon stock was obtained by an average of the weighted mean stock in each stratum I”. This is considered as a deviation since it was not considered in the PDD but it is accepted since it does not affect negatively the accuracy of the calculations of GHG net anthropogenic removals.

g) All parameters were monitored and determined according to the methodology and the validated PDD: DBH (total height was also measured even was not used); plantation density, location of the plots, etc.

h) The audit team reviewed the monitoring report where the Project Proponent explains in detail the steps used to calculate “5.1 Estimation of changes in the carbon stocks”. According to the calculations, the total amount of removals is 41,014.26 tCO2e. (OBS 03/11) see notes below.

i) The monitoring plan shows the results of mean carbon stocks by farm, this is multiplying the project area (effective area) by the weighted mean, e.g. for Bello Horizonte farm, 16.58 ha x 44.33 tCO2e/ha (CAR 01/11) see notes below.

j) The total amount of SOC was estimated by PICA for the first three years (2007-2009) as 2,233 tCO2e in the Monitoring Report. However, the spreadsheet 2010 Monitoring calculations summary.xls shows a minimum difference of one tonn (2,234 tCO2e) (OBS 04/11).

k) According to the monitoring report “The default value of = 0.5 t C ha-1 yr-1 and tequilibrium = 23 years was used.” This

is interpreted by the audit team as a deviation of the methodology since this requires a tequilibrium = 20 years. This deviation is accepted only for this verification process since the total SOC within the monitoring period is not affected,

however PICA should clarify the difference in the following Monitoring Reports. (OBS 05/11).

l) Discussions with PICA revealed that PICA‟s internal policy is to retain files for a 5-year period, however this is not in conformance with the VCS requirements for data archival (CAR 02/11).

Notes:

- In the monitoring report, the company defines “removals” as “carbon fixation”, this is incorrect according to the methodology used (OBS 03/11).

- The audit team determined that the actual mean carbon stock of Bello Horizonte farm is different (CAR 01/11).

- In the monitoring report the SOC is slightly different from the spreadsheet (OBS 04/10).

- PICA should clarify the difference of tequilibrium = 23 years in the following monitoring reports, for the next verification processes (OBS 05/11).

- PICA did not clearly state that all documents would be retained for 2 years follow the end of the crediting period as required by the VCS (CAR 02/11).


CAR/OBS CAR 01/11


CAR 02/11

OBS 03/11

OBS 04/11

OBS 05/11

4.3.2 The correctness and transparency of formulas and factors used


The results of the field measurements were compiled in a file titled “2010 Field data sheets”. In this file PICA submitted one file per farm with a compilation of various spreadsheets corresponding to every stratum.

The audit team reviewed a sample of the spreadsheets presented in order to check the correctness of formulas and factors used. All the information is presented in a template designed by the project proponent assuring the correctness and transparency of the information collected.

Project proponent shows clear information about the farm, measuring date, crew leader, date of plantation, clone and plot identification. Information taken in the monitoring event is shown in a clear way, the project proponent indicates DBH, plot area and scaling factor to get Biomass (kg/ha) per tree, then the correct extrapolation to tCO2e/ha.

The audit team reviewed that every calculation of biomass per tree has been done considering factors such as scaling factor, root-shoot ratio, carbon fraction and ratio of molecular weight of Co2 to carbon. Both allometric equations (Morales, 2000 and PICA 2010) were appropriate used while calculating the above ground biomass.



4.3.3 Calculation of emissions in the baseline scenario (ex-post estimate)


Project proponent estimated the emissions in the baseline scenario during the validation process. By that time, all the exhibits were submitted and then the audit team determined the accuracy of the calculations.

Ex post estimate is not necessary since within the monitoring period (2007-2010) no significance changes were detected. The audit team ratified this based on interviews with employees and staff, and observations.



4.3.4 Calculation of emissions from project activities (ex-post estimate)


As part of the development of the PDD, Project Proponent estimated emissions from one project activity (127 TCO2e): site preparation in two farms, Los Patos (32 ha) and Palmeras (46 ha). The calculations met the requirements of VCS and the chosen methodology.

During the verification field visit, the audit team determined through interviews with workers and staff that fire was not used for site preparation anymore, then it was not necessary to estimate carbon emissions from activities related with burning.



4.3.5 Calculation of emissions reductions or avoided emissions due to the project (ex-post estimate)


The Monitoring Report and the new equation methodology report explain in detail the sequence sampling methods used to determine carbon stocks. Morales 2000 and PICA 2010 allometric equations were used, Morales 2000 for trees +5 cm DBH and the PICA 2010 equation for smaller trees, below 5 cm DBH. Biomass was converted to carbon dioxide equivalent per PSP, and then the project proponent calculated the amount of carbon according to the strata considering a weighted mean due to significant differences among areas.

E.g. Bello Horizonte plantations consist of four different clones planted on 2007 (PB-260, PB-255, PB-280, and RRIM-600) and the preliminary carbon stocks are as follows:

PB-260: 43.25 tCO2e/ha (n = 5 plots)


PB-255: 40.90 tCO2e/ha (n = 4 plots)

PB-280: 59.40 tCO2e/ha (n = 4 plots)

RRIM-600: 34.97 tCO2e/ha (n = 4 plots)

As such, the average for Bello Horizonte farm 2007 is 44.63 tCO2e/ha (the calculations meet the target of 10% of error, and a 95% of significance), and through a weighted analysis the average is 44.33 tCO2e/ha but with an error of 5.27%. (As a reference, see the original sheet named Calc. summary in the spreadsheet PSP-N1-07.xls). This last estimation is considered to be a more accurate and conservative measure. As a result of using the weighted average, another difference can be noticed while calculating the average of all PSP established in Bello Horizonte of 757.32 tCO2e (n = 17 plots) –see sheet General summary in the same spreadsheet-, comparing to 738.01 tCO2e resulting from the weighted method – see Cell C31 in the sheet Calc. summary.

In 2010 Monitoring calculations summary, the company reveals the total amount of carbon (removals) as 41,014.26 tCO2e (n = 6 farms, n = 262 plots), then after considering amount of carbon in soil (SOC), 2,234 tCO2e, the total of removals is 43,249.12 tCO2e. And finally after subtracting baseline (biomass burn, baseline emissions, and baseline removals – 29,823.93 tCO2e), the final removal is 13,425.2 tCO2e.

In summary, the audit team reviewed the calculations, assumptions, factors and other criteria and determined that the impact of the project is accurate.



4.3.6 Calculation of emissions from leakage (ex-post estimate)


In the validation process, the Project Proponent estimated leakage from cattle grazing activities as the dominant land use. This ex ante estimation was done following the Version 02 of the A/R Methodological tool 09 “Estimation of GHG emissions related to displacement of grazing activities in A/R CDM project activity”.

During the field visit the audit team confirmed that no new cattle were purchased by Project Participants, moreover through interviews with workers it was determined that neither Ingenio Magdalena S.A. or PICA S.A. has a verbal policy of not buying cattle anymore, or intentions to lease the land to third parties for crop cultivation. As a result, for the monitoring period (2007-2010) ex-post estimation of leakage is considered to be zero.



4.3.7 Calculation of net VCUs to be issued (ex-post estimate)


The last version of the PDD shows the ex ante net calculation of estimated cumulative anthropogenic GHG removals (See table 15). Based on Table 9 of the PDD, the cumulative project changes in living tree biomass carbon stocks was 3,900,439 tCO2e which is equivalent to an average carbon storage over the crediting period of 1,538,426 tCO2e (maximum number of offsets) or 36,629.19 tCO2e per year within the crediting period (n = 42 years).

The project proponent estimated the VCUs as follows (spreadsheet 2010 monitoring calculations summary):

a) The total amount in 2010 was estimated on 43,249.12 tCO2e corresponding to the monitoring period (2007-2010). This considers the estimated carbon in standing trees (e.g. live fences) of 41,014.26 tCO2e and the Soil Organic Carbon of 2,234 tCO2e.

b) Then the total baseline emissions were estimated as 29,823.93 tCO2e. This considers the biomass burn (127.24 tCO2e), baseline emissions (24,125.36 tCO2e), and baseline removals (5,571.32 tCO2e).

c) Final removals resulted from subtracting the total amount of baseline, equalling 13,425.2 tCO2e

d) Finally, the total VCUs to deliver was estimated as 10,740.16 tCO2e after discounting the 20% buffer (2,685.04 tCO2e). Leakage was considered zero, but it should be noted that the procedure clearly explains that the buffer percentage shall be multiplied by net GHG credits, meaning the project proponent cannot subtract leakage before applying the buffer percentage). (OBS 06/11).

The audit team considers this procedure in line with the VCS requirements explained in detail in the Guidance for AFOLU.


CAR/OBS OBS 06/11


4.3.8 Appropriate use of default values


The Project Proponent used default values (indirect sources) for calculating the GHG removals, only when the specific source data is not available, mainly for the selected species. For example, for ex post estimations of the total live tree biomass (tCO2e/ha) defaults values used are the ratio shoot (22%), carbon fraction (50%) and the value of 44/12 which corresponds to the proportion of the CO2 related with the Carbon. The Project Proponent has also used default values while estimating baseline emissions, leakage, others but according to the audit team, every value is used as a conservative measure. The use of the default values is allowed by the selected methodology and the Project Proponent has justified it well.

No default values were used to estimate the carbon of trees below 5 cm DBH. Instead, the Project Proponent developed its own allometric equation with DBH as the independent variable, and Biomass as the dependent variable. To estimate the biomass, the Project Proponent contracted an independent laboratory to estimate the dry fraction of samples. Prior to the field audit, Rainforest Alliance auditors met with PICA staff to review the developed allometric equation for trees smaller than 5cm DBH. Supporting evidence detailing the process completed by PICA to develop the allometric equation were reviewed by the audit team. PICA submitted Annex V, containing multiple files as supporting evidence to document the development of the new allometric equation. The files reviewed by the audit team (Docs 61-68) were found to be sufficient to support the conservativeness and accuracy of the new equation developed by PICA. Additionally, the Morales 2000 was used to determine the biomass for trees +5 cm DBH.



4.3.9 The assumptions made for calculating GHG emission reductions and/or removals


Multiple assumptions were made during the validation process (leakage assessment and additionality argument), and assessed as part of the validation audit.

As part of the monitoring period, the company did not use assumptions.



4.4 Quality of evidence used to determine emissions reductions The discussion, findings and conclusion related to that the evidence is of sufficient quantity and appropriate quality, the reliability of the evidence and the source and nature of the evidence (external/internal, oral, documented) should be summarised in this section.

4.4.1 Verification of inventory equipment used to calculate emissions reduction and/or removals

Findings from Review on March 4, 2011

The only inventory equipment used to calculate carbon sequestration was a DBH measuring tape and a handheld GPS unit. During the field audit, the PICA DBH monitoring tapes were inspected by the audit team and found to be accurate. Furthermore, the correct use of the GPS equipment to locate PSPs was demonstrated, and original PSP locations were verified through the use of multiple handheld GPS units.



4.4.2 Verification of use of GPS and remote sensing analysis


As noted above, handheld GPS units were verified for accuracy by using multiple handheld GPS devices to verify accuracy of original plot measurements, as well as accuracy between handheld GPS units operated by each farm visited. Furthermore, the project recorded PSP units were verified by the audit team through the use of Google Earth. Following the field audit, a remote assessment of a random selection of PSPs visited by the audit team, where the PSP location was verified by the audit team through the use of handheld devices, was further confirmed by remotely locating original plot locations (confirmed in the field) on Google Earth. All sampled plot locations were found to be accurate.




4.4.3 Assessment of uncertainty


The validated PICA PDD does not address uncertainty. Further, the AR-ACM0001 v03 methodology states the following regarding accounting for uncertainty in GHG calculations:

“In choosing key parameters or making important assumptions based on information that is not specific to the project circumstances, such as in use of default data, PPs should select values that will lead to an accurate estimation of net GHG removals by sinks, taking into account uncertainties. If uncertainty is significant, PPs should choose data such that it tends to under-estimate, rather than over-estimate, net GHG removals by sinks.” The PICA project utilizes local allometric equations for the estimation of biomass in carbon stocks. Two equations are applied in the calculation of carbon stocks, this differs from the validated PDD which only applied the Morales 2000 equations, as a new allometric equation was developed by PICA to quantify biomass in trees <5cm DBH. The Morales 2000 equations are applied to trees >5cm DBH, as the Morales equations have been shown to overestimate biomass in trees <5cm DBH. The use of the Morales 2000, which is a locally developed equation specific to H. brasiliensis (following the guidance for the use of equations in the AR-ACM0001 v03 methodology cited above), was approved during the project validation. The correct application of the Morales equation to only inventoried trees >5cm, was verified by the audit team in review of the project calculation spreadsheets. In order to account for biomass accumulation in trees <5cm DBH, PICA developed their own allometric equation (see Appendix V). The development of this equation was thoroughly documented by PICA, and evidence of the statistical analysis, field sampling techniques, laboratory results, and literature references were submitted to the audit team for review. Additionally, the audit team interviewed the statistician hired by PICA to develop the biomass equations. The development and application of this equation was assessed by the audit team and found to be conservative, and in conformance with the AR-ACM0001 v03 methodological guidance for reducing uncertainty. However, the VCS requires that project proponents include an assessment of uncertainty. As cited in section 6.5.4 of the VCS 2007.1 standard: “The project proponent shall establish and apply quality management procedures to manage data and information, including the assessment of uncertainty, relevant to the project and baseline scenario. The project proponent should reduce, as far as is practical, uncertainties related to the quantification of GHG emission reductions or removal enhancements.” It is not clear how PICA has assessed uncertainty related to the quantification of GHG emission removals. Specifically, the GHG calculations do not include any quantification of uncertainty associated with GHG removal calculations, or a deduction of associated uncertainty. Beyond the outlined requirements in section 6.5.4 of the VCS 2007.1 standard, the VCS also outlines the guiding principles in section 5.1 of the VCS 2007.1 standard. Included in these principles are accuracy and conservativeness. As the Monitoring Report includes no mention of uncertainty, or an assessment of the potential impacts of inherent uncertainty associated with the use of the equations and default values applied to calculate VCUs, it is not clear how the Monitoring Report is in conformance with the VCS guiding principles in relation to the assessment of uncertainty. (CAR 03/11)


CAR/OBS CAR 03/11

4.4.4 Implementation of sampling plan described in the PDD


As noted above, following the 2009 pre-sampling, PICA determined that the original sampling intensity outlined in the PDD and the validated monitoring plan was not sufficient given the high variability between growth in different planted clones. As such the project area was re-stratified, and plot size and the number of installed PSPs was significantly increased. The increased sampling intensity from the validated sampling plan was found to be a conservative deviation from the PDD


monitoring plan. Additionally, PICA submitted a revised monitoring plan (v02, 2010) which reflected the changes in the sampling plan design.

Additionally, as described in 4.2.2 above, the audit team verified the implementation of the sampling plan through witnessing re-sampling of plots by two monitoring crews, and further verified accuracy of field sampling through the re-measurement of 46 PSPs. Re-measurement of PSPs was focused on strata with high variance in the PICA monitoring data. Summary of the re-measured PSPs is presented in Appendix B below.



4.4.5 Adequacy of sampling intensity


As described in 4.4.4 above, the initial sampling intensity calculated by PICA at the time of validation was found by PICA to be insufficient to account for high variability between planted clones. As such PICA increased the total number of sample plots by 45% (see findings in 4.1.4 above), in addition to tripling the size of each PSP. The increased sampling intensity combined with the re-stratification of the project area was found by the audit team to be sufficient to account for variability between planted clones and different farms.



4.4.6 Application of uncertainty deduction (if applicable)


As mentioned in 4.4.3 above, the PICA project did not account for uncertainty in the calculation of GHG emissions. As such PICA did not include a deduction for the quantified uncertainty.


CAR/OBS CAR 03/11

4.5 Management and Operational Systems

The discussion, findings and conclusions regarding the suitability of the management system for monitoring and reporting, i.e. organisational structure, responsibilities, competencies, non-conformance handling, internal audits and management review should be summarised in this section.

4.5.1 Field monitoring roles and responsibilities identified


Both documents, the Monitoring Report and the revised monitoring plan describe in detail the monitoring team (or monitoring crew). PICA has created an eco business department in order specifically implement forest projects, monitoring and reporting. For example in the monitoring report, the Project Proponent clearly defines five activities (Table 7): planting trees as a general activity, carbon monitoring; data processing, monitoring report creation and follow through with verification process; emissions reductions issuance and trading; development and managing VCS PD implementation.

The first activity is done based on the management plan of each farm, designed to meet FSC international standards. Here, the responsible people are the technical managers of each farm. The audit team evaluated this in the fields, determining the operational system was implemented accordingly.

The carbon monitoring and data processing activities are considered by the Project Proponent as the most important activity in the monitoring, and then the coordinator of the Monitoring Unit was assigned as responsible. Main responsibilities are to train personnel on data collection and to lead and supervise the monitoring process (measurements and registries); manage the database, calculate carbon offsets, and GHG emissions or removals. Five monitoring crews were used for carbon monitoring.

The last two activities outlined are more related with trading and implementing the PDD, one specific role is to evaluate and assure fulfilment of commitments within PD of each project participant.

The audit team considers this organisational structure as adequate to meet the VCS requirements.




4.5.2 Field inventory competency


The eco business department created by PICA is composed of three forestry engineers with enough experience to implement a carbon forest project. As part of the monitoring and reporting, this team works closely with farm representatives, also well experienced engineers and experts in different sciences, such as GIS, soils, environment, management plan implementation, statistic analysers, business administration among others.

In the specific case of the sampling methodology, the company applied a randomly stratified method to establish the Permanent Sample Plots (PSP) system within the project boundary. According to the Monitoring coordinator and supported by the statistician (PICA consultant), the way of selecting the place to locale a plot did not violate the basic principles of the statistics, meaning that the final result of the calculation of carbon stocks/removals can be considered as a unbiased number targeting a 95% of significance and less than 10% of standard error.

The monitoring team demonstrated competency also while using the precautionary principle as a technical criteria. The PSP system (inventory) was established considering various conservative methods, even when taking these decisions resulted in the subtraction of tonnes of carbon.

During the verification, the audit team had the opportunity to challenge the monitoring coordinator with questions in a variety of forest topics but related with the field inventory. In all the cases, the answers demonstrated accurate and critical analysis. Furthermore, comparison of estimated variance between the re-measured forest inventory plots and the Project Proponent measured inventory plots confirmed similar degrees of variance in PSP sampling. However, due to rapid growth in planted clones, and the elapsed 6 month period between the project monitoring inventory and the verification inventory, direct statistical comparison between the re-measured plots and the monitoring inventory difficult. A brief description of the statistical comparison conducted is provided in section 4.5.3 below.



4.5.3 Field inventory quality management systems


Basic but important systems were used to demonstrate the Project Proponent quality management. PICA based its field inventory on commonly accepted principles of forest inventory and management, including the selected methodology.

In the monitoring plan and the monitoring report, the Project Proponent reveals its management system as Standard Operation Procedures (SOP), in other words a basic guide of field inventory easy understandable for any crew member in the farms. Standard procedures examples are:

a) Determining pre-sampling size and pre-sampling plots.

b) Plots distribution, size and shape

c) Marking and identification

d) Crew team composition

e) Measuring variables, DBH and Height

f) Data archiving

The Project Proponent designed and used specific templates to record the inventory data.

As a complement, the Project Proponent has a specific section within the Monitoring Report title QA/QC for field measurements, which in summary means all the measurements the company had to implement to assure the accuracy of the data from the field measurements.

The audit team re-measured 46 plots (out of 262) using the standard procedures designed by the company. Several statistical comparisons were done and at the end, statistical parameters (standard deviation, confidence of variance, confidence limits) were used to establish that both measurements had resulted in no significant differences were found.

IPCC Good Practice Guidance for LULUCF was also used as a reference.




4.5.4 Data transcription quality management systems


Section 9.2 of the monitoring report corresponds to QA/QC for data entry, which is a system implemented by the Project Proponent to assure the quality of the database. It should be noted that the data transcription is a crucial management system so the audit team also did a data transcription exercise implementing the procedures the company had designed.

The Project Proponent reviewed data transcription in 40 plots while the audit team 28 plots (around 11% of the total). No major errors were found in both cases.

Some of the management systems related to data transcription are:

a) Use of common sense to evaluate

b) Record the name of the person or crew member who was in charge

c) High communication level among the team to identify and resolve potential errors

d) Cross checking involving a third person

The Project Proponent designed and used specific templates to record the data transcription monitoring. IPCC Good Practice Guidance for LULUCF was also used as a reference.

Furthermore, during the field audit, the audit team conducted a review of data entry accuracy. The table below describes the results of the audit team review of 28 plots.

Verifier Sample

Plot Number Plot Number Clone Data Check

1 PPM-N1-07-10 PB-260 No Errors

2 PPM-N1-08-13 PB-280 No Errors

3 PPM-N1-09-19 RRIC-100 No Errors

4 PPM-N1-09-30 HA-21 No Errors


6 PPM-N3-08-05 IAN-873 No Errors

7 PPM-N3-08-08 RRIC-100 No Errors

8 PPM-N3-09-02 IAN-873 No Errors


10 PPM-S1-07-01 IRCA-230 No Errors

11 PPM-S1-07-03 IRCA-230 No Errors

12 PPM-S1-08-02 PB-280 No Errors





17 PPM-S2-08-01 RRIC-100 No Errors

18 PPM-S2-08-06 RRIM-600 No Errors







25 PPM-S4-08-04 RRIC-100 No Errors





Total Number of Project PSPs 262

Total Plots Sampled 28

Percent Sampled by Verifier 11%



4.5.5 Inventory data analysis systems


The Monitoring Report describes the procedures to analyse data from PSP system. This is basically considered in section 5.3 Estimation of changes in tree biomass, six steps are explained in detail including the statistical analysis of the weighted mean as the final method to estimate the total amount of carbon (stock/removals). The audit team went through each step comparing the spreadsheets and noticed conformance from the beginning; it was also necessary to interact with the statistician consultant (Sergio Quemé, MsC) to double check the accuracy of the interpretation by PICA.

The sampling methods to create the allometric equation for trees under 5 cm DBH were based on the Sourcebook for LULUCF (Pearson, et al 2005), the analysis of the data was done by the statistician consultant along with PICA staff. IPCC Good Practice Guidance for LULUCF was also used as a reference.



4.5.6 Data management and archival systems


The data maintenance and storage systems are explained in the monitoring report in section 9.3 QA/QC for data archival. In summary the procedures the company followed are:

a) The use of different formats and backup copies.

b) Electronic and hard copies were stored in the manager office

c) A copy of the documents was shared with the farm administrators.

According to the selected methodology, the company is expected to archive all the information at least two more years after the finalization of the crediting period. This is a missing system that the company shall design and implement to fully meet the VCS requirements.


CAR/OBS CAR 02/11

4.6 Risk Assessment

4.6.1 Risk applicable to all project types

Risk Factor

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Findings from 30 June 2010 OBS/CAR

Note: Risk factors are determined through a qualitative analysis conducted, following the guidance of the VCS Tool for Non-Permanence Risk Analysis and Buffer Determination, combined with the 13 April 2010 VCS Program Update. Evidence supporting the qualitative assessment must be provided by the project proponent. The risk assessment is subject to the VCS Double Approval Process, as such, the final risk buffer is confirmed after approved by the second verifier.


Risk of unclear land tenure and potential for disputes

Low The farms are privately owned, or are leased by PICA under long-term 50 year contracts. Additionally, a 13 year GHG agreements existed with land owners. There are no new contracts in the monitoring period (2007-2010)

No CAR or OBS raised

Risk of financial failure Low PICA is the largest processor and exporter of rubber and latex in Guatemala, and has extensive experience managing finances. Furthermore, PICA has performed financial analysis on project activity over the project crediting period that show stability within the project.


Risk of technical failure

Low PICA is working with contracted professionals, and has a strong foundational knowledge of rubber plantation production in the region. Monitoring competency has also been demonstrated.


Risk of management failure

Low PICA has extensive experience in rubber production and has a management plans for several of the farms within the project area.


Risk of rising land opp. costs causing reversal of sequestration/protection

Low The PDD describes the alternative landuse of pastureland is unlikely to compete financially with the returns from the sale of rubber. Additionally, the substantial upfront investment in rubber plantations binds land owners to maintain plantations in order to pay off establishment costs.


Risk of political instability Low The PDD cites multiple studies indicating increased stability within Guatemala relative to other Latin America countries.


Risk of social instability

Medium Guatemala has significant security problems, and comparative rankings to other countries show that Guatemala has a high social instability risk. PICA recognizes these risks and proposes an increased medium risk level to reflect these findings.


Risk of devastating fire Low Fire is an infrequent disturbance in the region, and the PDD includes fire prevention tactics. During the verification audit, no new fire events had been identified within the project boundary or surrounded areas.


Risk of pest and disease attacks

Low Plantation forestry increases the risk of pest and disease attacks due to decreased biological diversity and subsequent resiliency. However, common pests and fungi in rubber tree plantations in the area are well known, and preventative actions to mitigate these risks are under way. Additionally, as the loss of trees represents an additional financial loss to project proponents (from loss of rubber production), it is likely that preventative measures discussed in the PDD will be applied.


Risk of extreme weather events (e.g. floods, drought, winds)

Medium PICA recognizes that hurricanes pose a potential risk to rubber tree plantations, and has reflected this through the increased risk rating associated with risk of extreme weather.


Geological risk (e.g. volcanoes, earthquakes, landslides)

Low The justification of low geologic risk in the PDD focuses on earthquakes, which may be a low risk in the region. However, volcanic



eruptions and landslides on steep slopes during heavy rains are potential risks to

project areas. PICA demonstrated through maps that the risk of landslides and volcano activity is low. These maps are part of two independent technical studies performed by IARNA (Environmental and Natural Resources Institute) and MAGA (Agricultural Ministry).

Summary of findings and assessment of risk rating The VCS Non-Permanence Risk Analysis and Buffer Determination was not included within the monitoring report.

CAR/OBS: CAR 04/11

4.7 Risk factors applicable to ARR projects

Risk Factor

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Findings from 30 June 2010 OBS/CAR

Project longevity/ Commitment period

Medium The VCS Tool for AFOLU Non-Permanence Risk Analysis and Buffer Determination defines a long term commitment period as “projects with rotation periods of more than 25 years and a commitment to replant, and those with primarily a forest rotation and habitat emphasis”. Similarly, the tool describes medium-term commitment periods as “projects with rotation periods of more than 25 years, but no commitment to replant”. The crediting period was increased to 42 years during the validation process, including a 36 year rotation within the rubber tree plantations, as well as a commitment to replant.


Ownership type and user rights

Medium The land is privately owned, however during the validation field visit to Los Patos, auditors learned that PICA leased the land from Ingenio Magdalena S.A. The VCS Tool for AFOLU Non-Permanence Risk Analysis and Buffer Determination states that “rented or tenant-operated land” must use a medium risk rating. During the validation, PICA increased the risk to medium since Los Patos and Asunción are leased to Ingenio Magdalena S.A.


Technical capability

Low During the field audit PICA demonstrated their technical capacity to conduct project activities as outlined in the PDD and the monitoring report.


Financial capacity Low PICA has performed a financial analysis No CAR or OBS raised


to identify financial risks, and demonstrate financial capacity to conduct project activities.

Management capacity of project developer

Low The PDD states: “Substantial previous project experience (≥ 5 projects) with on-site management team” This reflects the categories defined in the VCS Tool for AFOLU Non-Permanence Risk Analysis and Buffer Determination. Furthermore, PICA has included additional evidence of the management experience with carbon measurement and quantification. With the clarified text in the PDD and additional evidence as proof of the teams carbon quantification skills, combined with the evidence of PICA‟s management experience reviewed during the field audit, the audit team has obtained enough evidence to assure that PICA is in conformance with this requirement, and “low” is an appropriate risk rating for this category.


Future income

Low The financial analysis conducted by PICA demonstrates the future income associated with the sale of carbon credits as well as the sale of latex and rubber from the plantations.


Future/current opportunity costs

Low Section 2.4 of the PDD describes the likelihood of alternative land uses becoming more financially attractive than the project activities. It is unlikely that other land uses will become more financially viable following the establishment of rubber plantations.


Endorsement of project

Low PICA outlined in the statement of intent its endorsement of the carbon project, and the promotion of sustainable rubber production.


Summary of findings and assessment of risk rating As noted in 4.6 above, the Monitoring Plan does not include the risk assessment.

CAR/OBS: CAR 04/11

4.7.1 Default buffer withholding percentages for ARR projects

Rating/Amount Findings from 30 June 2010

Self Assessment Risk Class Medium As the highest identified risk within the self-assessment is identified as medium, this is now in conformance with the 13April2010 VCS Program Update.

Self Assessment Buffer Withholding Percentage

20% In the revised PDD self-risk assessment in section 1.11, 4 out of 19 self-assessment risk categories are identified as medium. PICA has identified efforts to help mitigate these risks, and reduce the chance of their effect on the project. Recognizing this, a self-assessment risk of 20% is justified, and is appropriate given the level of risk and mitigation effort identified.

CAR/OBS: No CAR or OBS raised


5 Verification Conclusion 5.1 Verification Statement

Verification Scope: See section 1.2 above

Reporting period: a. Reporting period of verified emissions reductions and/or removals within the scope of this audit: June 2007-August 2010 b. Previous verified monitoring period: This assessment represents the initial monitoring period.

c. Has the risk rating increased since the previous reporting period: Yes No Verified emission in the above reporting period: a. Net project emissions reductions/removals 43,250.28 t CO2 equivalents b. Baseline emissions 29,823.93 t CO2 equivalents c. Net emission reductions/removals 13,427.28 t CO2 equivalents d. Credits to be deposited in the buffer account 2,685.46 t CO2 equivalents e. Total number of Verified VCUs 10,741.82 t CO2 equivalents

Confidentiality: As per VCS guidelines, the information in this report is maintained on a public VCS database, except for confidential material explicitly identified by project proponent

To VCSA board: Rainforest Alliance verification audits of carbon forestry projects follow best practice for evaluation of greenhouse gases, which are closely in accordance with ISO 14064 standards. The verification reported upon herein was performed against the VCS standards, validated PDD, and applicable methodology using field forestry protocols based on Intergovernmental Panel on Climate Change (IPCC) guidance. Rainforest Alliance verified the project assertion of 10,741 VCUs to a reasonable level of assurance without limitation or qualification.

Signature Date April 1, 2011

Based on an evaluation of the project proponent‟s management systems and performance in the field across the defined audit scope, the Rainforest Alliance verification audit team concludes that project proponent has:

Demonstrated unqualified compliance/conformance with the standard

Not demonstrated unqualified compliance/conformance with the standard.

Note that all audit conclusions are subject to independent review by the Voluntary Carbon Standard prior to issuance of carbon credits, i.e., Voluntary Carbon Units (VCUs). In addition, VCS requires this audit to undergo a secondary desk audit of the Non-Permanence Risk Analysis and Buffer Determination.


Appendix A: Company Details

5.2 Contacts

Primary Contact for Coordination with SmartWood

Primary Contact, Position: Ing. Pablo Domínguez, Technical Sustainability and Carbon Manager

Address: 7a Ave., 7-33 Zona 9

Edificio Grupo Financiero de Occidente

Ciudad de Guatemala

Tel/Fax/Email: (502) 2279-9000/[email protected]

Billing Contact

Contact, Position: Same as above

Address: Same as above

Tel/Fax/Email: Same as above

5.3 On-line Certification Contact

Note: upon Verification, the SmartWood web site posts and maintains Customer Fact Sheets for companies with the information in the table below at http://www.rainforest-alliance.org/climate.cfm?id=international_standards

Field Text for Customer Fact Sheet Has this Info Changed?

Contact, Title: Ing. Pablo Domínguez, Technical Sustainability and Carbon Manager

Yes No

Address: 7a Ave., 7-33 Zona 9

Edificio Grupo Financiero de Occidente

Ciudad de Guatemala

Yes No

Tel/Fax/Email/Website: (502) 2279-9000/[email protected]

Yes No

Products/Descriptions: N/A Yes No


Appendix B : Verification Field Measurements The following data presents the results of the field inventory conducted by the Rainforest Alliance verification audit team. During the field audit, project permanent sample plots were selected within project defined strata. Those strata with the greatest calculated variance were targeted during verification audit team sampling. Only those criteria used to estimate carbon calculations by the project proponent were measured. The following are summary tables presenting the audit team calculations of total GHG emission removals per PSP.

Table B.1: Summary of re-measured PSPs

Location

Plot Coordinates

Inventory Plot Number Clone

AG Live Tree

Biomass(kg/ha

)

BG Live Tree

Biomass

(kg/ha)

Total Live

Biomass

(kg/ha)

Total live tree

(tCO2e/ha) Lat (N) Long (W)

Bello Horizonte 15 35'40.7" 88 56'15.7" PPMN10722 PB 255

27953.9 6149.8

34103.7 62.5


32635.9 7179.9

39815.8 73.0


33238.6 7312.5

40551.1 74.3


30622.5 6737.0

37359.5 68.5

Bello Horizonte 15 35'46.5 88 56'21.7" PPMN10712 PB 255

28409.8 6250.2

34660.0 63.5


19383.1 4264.3

23647.4 43.4


18200.9 4004.2

22205.1 40.7


18718.2 4118.0

22836.2 41.9

Bello Horizonte 15 36'04.5" 88 57'10" PPMN10822 PB 260

22418.5 4932.1

27350.5 50.1


16245.9 3574.1

19820.0 36.3

Bello Horizonte 15 36'26.9" 88 57'26.0" PPMN10923

RRIC 100 2650.4 583.1 3233.5 5.9


RRIC 100 2226.2 489.8 2716.0 5.0


RRIC 100 1809.5 398.1 2207.6 4.0


RRIC 100 2379.5 523.5 2902.9 5.3


RRIC 100 1895.5 417.0 2312.5 4.2


RRIC 100 1151.1 253.3 1404.4 2.6


RRIC 100 2062.1 453.7 2515.8 4.6

Bello Horizonte 15 36' 39.5" 88 57'28.1"

PPMN10924

RRIC 100 2157.2 474.6 2631.8 4.8

El Horizonte 14 21'16.2" 91 11'40.2" PPMS40905 PB 260 1509.2 332.0 1841.2 3.4






El Horizonte 14 21'05.4" 91 12'00.4" PPMS40710

RRIC 100

40829.7 8982.5

49812.3 91.3

El Horizonte 14 21'01.9" 91 12' 00.0"

PPMS40701

RRIC 100

37067.5 8154.8

45222.3 82.9


RRIC 100

28581.7 6288.0

34869.7 63.9


RRIC 100

33210.5 7306.3

40516.8 74.3


RRIM 901

18749.9 4125.0

22874.8 41.9


RRIM 901

18864.3 4150.1

23014.4 42.2


RRIM 901

19425.1 4273.5

23698.7 43.4


RRIM 901 4224.4 929.4 5153.8 9.4


RRIM 901

16905.2 3719.1

20624.4 37.8

Asunción 14 29'15.4" 91 13'27.0" PPMS30903 PB 280 2564.6 564.2 3128.8 5.7

Asunción 14 29'10.6" 91 13'22.3"

PPMS30904 PB 280 1829.3 402.4 2231.7 4.1

Asunción 14 29'06.2" 91 13'20.5"

PPMS30905 PB 280 3933.8 865.4 4799.2 8.8

Asunción 14 28'59.6" 91 13'27.4"

PPMS30906 IAN 873 2410.5 530.3 2940.8 5.4

Asunción 14 28'53.7" 91 13'20.5"

PPMS30907 IAN 873 1453.9 319.9 1773.8 3.3

Asunción 14 28'49.2" 91 13'18.7"

PPMS300908 IAN 873 1191.7 262.2 1453.9 2.7

Asunción 14 28'32.5" 91 13'46.9"

PPMS30802 PB 217

16840.9 3705.0

20545.9 37.7

Asunción 14 28'23.2" 91 13'35.5"

PPMS30814 PB 217

21812.5 4798.8

26611.3 48.8

Asunción 14 28'22.6" 91 13'20.7"

PPMS30824 PB 217

16756.5 3686.4

20442.9 37.5

Asunción 14 28'24.2" 91 13'29.7"

PPMS30801 PB 217

20807.0 4577.5

25384.6 46.5

Asunción 14 27'57.9" 91 13'44.1"

PPMS30817 IAN 873

15791.7 3474.2

19265.9 35.3

Asunción 14 27'52.5" 91 13'43.4"

PPMS30808 IAN 873

17607.8 3873.7

21481.5 39.4

Asunción 14 27'48.5" 91 13'32.2"

PPMS30822 IAN 873 7255.8 1596.3 8852.1 16.2

Asunción 14 27'50.9" 91 13'21.1"

PPMS30807 IAN 873

12555.5 2762.2

15317.7 28.1

Note that PICA conducted inventory monitoring during the period of July and August 2010. The audit team re-measured a selection of 46 PSPs during the field audit. In total, 1,380 trees were re-measured. The rapid growth of the planted H. brasiliensis clones prevents the direct comparison between the audit team re-measurement and the inventory monitoring.


However, comparison of the re-measured sampling allows the audit team to assess if measured values overestimated DBH measurements, resulting in a potential inflation in GHG emission removals. Of the re-measured trees in all but three trees measured by the audit team had greater DBH, representing growth of planted trees since the monitoring inventory, and a non-overestimate of DBH during inventory monitoring.

Table B.2: Comparison of Rainforest Alliance re-measured DBH to the measured DBH reported by PICA.

Location Inventory

Plot Number Clone

Tree Numbe

r

PICA DBH (cm)

Rainforest Alliance DBH

(cm)

Bello Horizonte PPMN10722 PB 255 1 4.9 6

Bello Horizonte PPMN10722 PB 255 2 6.7 8.6



Bello Horizonte PPMN10722 PB 255 5 7 9

Bello Horizonte PPMN10722 PB 255 6 8 9.9

















Bello PPMN10722 PB 255 23 6.7 8.4


Horizonte























































Bello Horizonte PPMN10923 RRIC 100 1 2.4 3.9



Bello Horizonte PPMN10923 RRIC 100 3 2.3 4





Bello Horizonte PPMN10923 RRIC 100 8 3 4.4





































Bello Horizonte PPMN10920 RRIC 100 10 0 0






























El Horizonte PPMS40905 PB 260 1 3.6 4.6




El Horizonte PPMS40905 PB 260 5 3.5 4




El Horizonte PPMS40905 PB 260 9 3 3.9























El Horzonte PPMS40904 PB 260 1 2.7 2.9

El Horzonte PPMS40904 PB 260 2 2.8 3

El Horzonte PPMS40904 PB 260 3 3 3.6
































El Horizonte PPMS40901 PB 260 5 4 5









































El Horizonte PPMS40710 RRIC 100 1 8.3 11.4

El Horizonte PPMS40710 RRIC 100 2 8 10





El Horizonte PPMS40710 RRIC 100 7 8 10.1















El Horizonte PPMS40710 RRIC 100 21 7.3 11























































El Horizonte PPMS40812 RRIM 901 1 5.8 7.6



El Horizonte PPMS40812 RRIM 901 4 5.4 7






El Horizonte PPMS40812 RRIM 901 10 6 7.5








El Horizonte PPMS40812 RRIM 18 6.7 8.1


901


















































Asuncion PPMS30903 PB 280 1 3 3.6

Asuncion PPMS30903 PB 280 2 3.5 4.2




Asuncion PPMS30903 PB 280 6 3.3 4




Asuncion PPMS30903 PB 280 10 3.5 4.1

Asuncion PPMS30903 PB 280 11 2.3 2.9


Asuncion PPMS30903 PB 280 12 1.4 2.3

Asuncion PPMS30903 PB 280 13 2.8 3.6


Asuncion PPMS30903 PB 280 15 3.1 3.5

Asuncion PPMS30903 PB 280 16 3.4 4.2

Asuncion PPMS30903 PB 280 17 3.6 4.4

Asuncion PPMS30903 PB 280 18 3.6 4.6



Asuncion PPMS30903 PB 280 21 3.1 4.2

Asuncion PPMS30903 PB 280 22 3.7 4.8

Asuncion PPMS30903 PB 280 23 3.6 4.6

Asuncion PPMS30903 PB 280 24 4 5





Asuncion PPMS30903 PB 280 29 3.4 4.4

Asuncion PPMS30903 PB 280 30 2.2 2.9










Asuncion PPMS30904 PB 280 10 3.8 4.7

Asuncion PPMS30904 PB 280 11 2.5 3.3

Asuncion PPMS30904 PB 280 12 3.2 3.7


Asuncion PPMS30904 PB 280 14 3.1 3.8


Asuncion PPMS30904 PB 280 16 2.4 3.5

Asuncion PPMS30904 PB 280 17 2.4 3.1

Asuncion PPMS30904 PB 280 18 2.4 3.4

Asuncion PPMS30904 PB 280 19 2.9 3.5


Asuncion PPMS30904 PB 280 21 3.5 4.7

Asuncion PPMS30904 PB 280 22 3.8 4.7

Asuncion PPMS30904 PB 280 23 3.4 3.9

Asuncion PPMS30904 PB 280 24 3.7 4.9


Asuncion PPMS30904 PB 280 26 3.5 4.5

Asuncion PPMS30904 PB 280 27 2.8 3.6


Asuncion PPMS30904 PB 280 28 2.9 3.6

Asuncion PPMS30904 PB 280 29 3.6 4.5

Asuncion PPMS30904 PB 280 30 2.7 3.4











Asuncion PPMS30905 PB 280 11 4.2 5.7



Asuncion PPMS30905 PB 280 14 3.5 4.3

Asuncion PPMS30905 PB 280 15 3.5 4.4

Asuncion PPMS30905 PB 280 16 3.8 4.5


Asuncion PPMS30905 PB 280 18 2.1 2.7

Asuncion PPMS30905 PB 280 19 3.9 4.5

Asuncion PPMS30905 PB 280 20 3.9 4.6


Asuncion PPMS30905 PB 280 22 4.3 5.5

Asuncion PPMS30905 PB 280 23 3.8 4.6

Asuncion PPMS30905 PB 280 24 4.1 5.3

Asuncion PPMS30905 PB 280 25 3.8 4.8

Asuncion PPMS30905 PB 280 26 3.6 4.7


Asuncion PPMS30905 PB 280 28 3.5 4.3

Asuncion PPMS30905 PB 280 29 3.3 4.1


Asuncion PPMS30906 IAN 873 1 3.6 3.8








Asuncion PPMS30906 IAN 873 9 3.3 4





































Asuncion PPMS30907 IAN 873 15 4 4.4



















Asuncion PPMS300908 IAN 873 3 4 0






































Asuncion PPMS30802 PB 217 10 5.6 6.5

Asuncion PPMS30802 PB 217 11 3.9 5.1

Asuncion PPMS30802 PB 217 12 4.9 6.2

Asuncion PPMS30802 PB 217 13 4.7 6.4

Asuncion PPMS30802 PB 217 14 5.1 6.7

Asuncion PPMS30802 PB 217 15 4.9 5.8

Asuncion PPMS30802 PB 217 16 5.7 7.2


Asuncion PPMS30802 PB 217 18 5.5 6.8

Asuncion PPMS30802 PB 217 19 5.6 7.4

Asuncion PPMS30802 PB 217 20 4.3 6.2

Asuncion PPMS30802 PB 217 21 5.9 7.1



Asuncion PPMS30802 PB 217 24 6.4 7.2

Asuncion PPMS30802 PB 217 25 6.3 7.5



Asuncion PPMS30802 PB 217 28 6.1 8.4

Asuncion PPMS30802 PB 217 29 5.8 8.1

Asuncion PPMS30802 PB 217 30 4.9 6.6










Asuncion PPMS30814 PB 217 10 4.8 6.5

Asuncion PPMS30814 PB 217 11 4.6 6.1


Asuncion PPMS30814 PB 217 12 4.1 5.7

Asuncion PPMS30814 PB 217 13 5.2 6.6

Asuncion PPMS30814 PB 217 14 6.3 7.9

Asuncion PPMS30814 PB 217 15 6.3 8.2

Asuncion PPMS30814 PB 217 16 6.9 8.2


Asuncion PPMS30814 PB 217 18 6.9 8.2

Asuncion PPMS30814 PB 217 19 6.8 8.7

Asuncion PPMS30814 PB 217 20 3.3 4.2

Asuncion PPMS30814 PB 217 21 4.3 5.9

Asuncion PPMS30814 PB 217 22 6.1 7.5

Asuncion PPMS30814 PB 217 23 5.8 7.3



Asuncion PPMS30814 PB 217 26 5.9 7.4

Asuncion PPMS30814 PB 217 27 6.6 8.4

Asuncion PPMS30814 PB 217 28 5.1 6.6

Asuncion PPMS30814 PB 217 29 6.2 7.7












Asuncion PPMS30824 PB 217 11 4.9 6.5

Asuncion PPMS30824 PB 217 12 5.8 7.9

Asuncion PPMS30824 PB 217 13 6.2 7.9

Asuncion PPMS30824 PB 217 14 3.6 4.9

Asuncion PPMS30824 PB 217 15 4.6 6.3

Asuncion PPMS30824 PB 217 16 4.1 5.4

Asuncion PPMS30824 PB 217 17 4.8 5.9

Asuncion PPMS30824 PB 217 18 6.8 8.4

Asuncion PPMS30824 PB 217 19 4.8 6.5


Asuncion PPMS30824 PB 217 21 5.1 6.4

Asuncion PPMS30824 PB 217 22 5.1 6.4

Asuncion PPMS30824 PB 217 23 5.6 7.5

Asuncion PPMS30824 PB 217 24 5.3 6.9



Asuncion PPMS30824 PB 217 27 3.9 5.1


Asuncion PPMS30824 PB 217 28 4.9 6.3

Asuncion PPMS30824 PB 217 29 4.8 6.5

Asuncion PPMS30824 PB 217 30 5.8 7.5










Asuncion PPMS30801 PB 217 10 6.6 8.3




Asuncion PPMS30801 PB 217 14 6.3 7.9

Asuncion PPMS30801 PB 217 15 6.5 8.2

Asuncion PPMS30801 PB 217 16 5.3 6.4

Asuncion PPMS30801 PB 217 17 5.3 6.6

Asuncion PPMS30801 PB 217 18 4.4 5.4

Asuncion PPMS30801 PB 217 19 6.2 7.9

Asuncion PPMS30801 PB 217 20 6.2 7.8

Asuncion PPMS30801 PB 217 21 2.9 3.9

Asuncion PPMS30801 PB 217 22 6.4 7.8

Asuncion PPMS30801 PB 217 23 5.8 7.5

Asuncion PPMS30801 PB 217 24 4.6 6.2


Asuncion PPMS30801 PB 217 26 5.9 7.2



Asuncion PPMS30801 PB 217 29 7.6 9.7

Asuncion PPMS30801 PB 217 30 5.4 6.8


Asuncion PPMS30817 IAN 873 2 0












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