validation report ccba campoverde 06dec · validation report bosques amazÓnicos sac. validation of...

Validation Report

BOSQUES AMAZÓNICOS SAC.

VALIDATION OF THE CCBS-PROJECT: REFORESTATION WITH NATIVE COMMERCIAL SPE-

CIES ON DEGRADED LANDS FOR TIMBER AND CAR-

BON PURPOSES IN CAMPO VERDE, UCAYALI - PERU

REPORT NO. 1224986 -CCBA

30 November 2010

TÜV SÜD Industrie Service GmbH

Carbon Management Service Westendstr. 199 - 80686 Munich – GERMANY

Validation of the CCB Standards Project: Reforestation with native commercial species on degraded lands for timber and carbon purposes in Campo Verde, Ucayali - Peru

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Report No. Date of first issue Revision No. Date of this revision Certificate No.

1224986-CCBA 4 October 2010 3 30 November 2010 -

Subject: Validation of a CCBS project (as add-on to a VCS audit, Validation Report No. 1224986, dated 20 July 2009)

Accredited TÜV SÜD Unit:

TÜV SÜD Industrie Service GmbH Certification Body “climate and energy” Westendstr. 199 80686 Munich, Germany

TÜV SÜD Contract Partner:

TÜV SÜD Industrie Service GmbH Carbon Management Service Westendstr. 199 80686 Munich, Germany

Project Participants:

Bosques Amazónicos SAC Calle Monterosa 271 Oficina 7B – Chacarilla, Surco – Lima, Perú

AIDER Av. Jorge Basadre 180, Oficina 6 – San Isidro, Lima-Peru.

Project Site(s):

Campo Verde District, Coronel Portillo Province, Ucayali Department, Peru.

Geographic boundaries are provided in PDD and through digital vector files.

Project Title: Reforestation with native commercial species on degraded lands for timber and carbon purposes in Campo Verde, Ucayali – Peru.

Applied Methodology / Version: CCBS / Version No.1

First CCBS PDD Version:

Date of issuance: 21 October 2008

Version No.: 01

Final PDD version:

Date: 02 September 2010

Version No.: 03

Assessment Team Leader:

Sebastian Hetsch

Assessment Team Members:

Juan Chang Hubertus Schmidkte

CB reviewer:

Robert Scharpenberg

Certification Body responsible:

Thomas Kleiser

Summary of the Validation Opinion:

The review of the project design documentation and the subsequent follow-up interviews have provided TÜV SÜD with sufficient evidence to determine the fulfilment of all stated cri-teria. In our opinion, the project meets all relevant CCBS requirements with the Gold Level.

The review of the project design documentation and the subsequent follow-up interviews have not provided TÜV SÜD with sufficient evidence to determine the fulfilment of all rele-vant CCB criteria.


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Abbreviations AFOLU Agriculture, Forestry and other Land Use

AR-ACM Approved Consolidated Methodology for Afforestation and Reforestation

AR-AM Approved Methodology for Afforestation and Reforestation

AR-AMS Approved Methodology Small Scale for Afforestation and Reforestation

CAR Corrective Action Request

CCB (A) Climate Community and Biodiversity (Alliance)

CDM-EB CDM Executive Board

CR / CL Clarification Request

DOE Designated Operational Entity

EIA / EA Environmental Impact Assessment / Environmental Assessment

ER Emission Reduction

FAR FSC

Forward Action Request Forest Stewardship Council

GIS Geographic Information System

GHG Greenhouse Gas(es)

GPS Global Positioning System

IPCC IRL

Intergovernmental Panel on Climate Change Information Reference List

IRR Internal Rate of Return

KP Kyoto Protocol

MP Monitoring Plan

NGO Non Governmental Organisation

PDD Project Design Document

PP Project Participant

TARAM Tool for Afforestation and Reforestation Approved Methodologies (spreadsheet based calculation tool)

TÜV SÜD TÜV SÜD Industrie Service GmbH

UNFCCC United Nations Framework Convention on Climate Change

VCS Voluntary Carbon Standards

VCUs Voluntary Carbon Units

VVM Validation and Verification Manual


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Table of Contents Page

1 INTRODUCTION ........................................................................................................ 5

1.1 Objective 5

1.2 Scope 5

2 METHODOLOGY ....................................................................................................... 7

2.1 Appointment of the Assessment Team 8

2.2 Review of Documents 9

2.3 Follow-up Interviews and visited sites 9

2.4 Resolution of Clarification and Corrective Action Requests 10

2.5 Internal Quality Control 10

3 SUMMARY OF FINDINGS ....................................................................................... 11

3.1 General Section 11

3.2 Climate 14

3.3 Community Section 15

3.4 Biodiversity Section 16

3.5 Summary of CCBS requirements 18

3.6 Comments by Parties, Stakeholders and NGOs 19

3.7 Validation Opinion 20

ANNEX 1

Table 1: CCBS Validation Checklist ....................................................................................... 21

Table 2: Summary of Responses to Corrective Action and Clarification Requests ................ 43

ANNEX 2: Information Reference List .................................................................................... 67


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1 INTRODUCTION

1.1 Objective The validation objective is an independent assessment by a Third Party of the proposed pro-ject activity against all defined criteria as defined by the Climate Biodiversity and Community Alliance (CCBA).

In line with the framework for the validation of a CDM project, corresponding tasks are car-ried by an Independent Operational Entity (DOE). TÜV SÜD is a DOE that is accredited by UNFCCC to validate AR-CDM projects. CCBA recognizes this AR-CDM accreditation.

Validation will finally result in a conclusion by the executing DOE whether a project activity is complying with the CCB Standards and whether this project should be submitted for registra-tion with CCBA. The ultimate decision on the registration of a proposed project activity rests with CCBA.

The project activity discussed by this validation report has been submitted under the project title: “Reforestation with native commercial species on degraded lands for timber and carbon purposes in Campo Verde, Ucayali - Peru”.

For the particular case of this project, a combined validation approach with the Voluntary Carbon Standard (VCS) was conducted. The published report on the TÜV SÜD netinform webpage (http://www.netinform.de/KE/Wegweiser/Guide2.aspx?ID=4954&Ebene1_ID=49&Ebene2_ID=1533&mode=4 ) describes the findings of the validation process conducted for this matter.

The Validation Report No. 1224986, dated 20 July 2009 on the compliance of the same pro-ject with the VCS is considered an integral part of the present CCB Standards audit.

The present report is intended to cover only those criteria, in which the CCB Standards dif-fers and exceeds the requirements of VCS.

1.2 Scope For any CCB project activity the scope is set by:

CCB standards, version 01, as published at www.climate-standards.org

Technical and methodological guidelines and information for best practice in land use based mitigation projects

In case of a CCB project that is also designed to comply with the requirements of an AR-CDM project or methodology the scope includes furthermore the following:

The Kyoto Protocol, in particular § 12

Decision 2/CMP1 and Decision 3/CMP.1 (Marrakech Accords)

Further COP/MOP decisions with reference to the CDM

Decisions by the EB published under http://cdm.unfccc.int

Specific guidance by the EB published under http://cdm.unfccc.int

Guidelines for Completing the Project Design Document (CDM-PDD), and the Proposed New Baseline and Monitoring Methodology (CDM-NM)

The applied approved AR CDM methodology

The AR-CDM additionality tool for afforestation / reforestation projects.

Furthermore, in this case of a CCB project being complimentary to a project activity using the Voluntary Carbon Standard the scope is also set by:


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The Voluntary Carbon Standard 2007.1

Voluntary Carbon Standard Program Guidelines 2007.1

Tool for AFOLU Methodological Issues

Tool for AFOLU Non-Permanence Risk Analysis and Buffer Determination

Guidance for Agriculture, Forestry and Other Land Use Projects

The validation is not meant to provide any consulting towards the client. However, stated re-quests for clarifications and/or corrective actions may provide input for improvement of the project design.

Once TÜV SÜD receives a first PDD version, it is made publicly available on the internet at CCBA’s webpage for a stakeholder consultation process (GSP). In case of any request a PDD might be revised (under certain conditions the GSP will be repeated) and the final PDD will form the basis for the final evaluation as presented by this report. Information on the first and on the final PDD version is presented on page 2.

The only purpose of a CCB validation is to indicate compliance with the CCB Standards and to use the corresponding reports during the registration process with CCBA. Hence, TÜV SÜD cannot be held liable by any party for decisions made or not made based on the valida-tion opinion.


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2 METHODOLOGY The project assessment aims at being a risk based approach and is based on the methodol-ogy developed in the Validation and Verification Manual, an initiative of Designated and Ap-plicant Entities, which aims to harmonize the approach and quality of all such assessments.

In order to ensure transparency, a validation protocol was customised for the project. The protocol shows, in a transparent manner, criteria (requirements), the discussion of each crite-rion by the assessment team and the results from validating the identified criteria. The valida-tion protocol serves the following purposes:

It organises, details and clarifies the requirements that a CCB Standards project is ex-pected to meet;

It ensures a transparent validation process where the validator will document how a par-ticular requirement has been validated and the result of the validation.

The validation protocol consists of several tables. The different columns in these tables are described in the figure below. The completed validation protocol is enclosed in Annex 1 to this report.

Validation Protocol Table 1: CCB - Conformity of Project Activity

Checklist Topic / Question

Reference Comments Conclusion on PDD in GSP

Final Con-clusion

The checklist is organised accord-ing to the sections of the CCBA stan-dard. Each section is then further sub-divided. The lowest level constitutes a checklist question / criterion.

Gives refer-ence to docu-ments where the answer to the checklist question or item is found - in case the comment re-fers to docu-ments other than the PDD or the applied methodology..

The section is used to elaborate and discuss the checklist question and/or the conformance to the question. It is fur-ther used to explain the conclusions reached. In some cases sub-checklist are applied in-dicating yes/no decisions on the compliance with the stated criterion. Any Request has to be sub-stantiated within this col-umn

Conclusions are pre-sented based on the as-sessment of the first PDD version. This is either acceptable based on evidence provided (), or a Corrective Action Request (CAR) due to non-compliance with the checklist question (See below). Clarification Request (CR) is used when the validation team has identified a need for further clarification.

Conclusions are pre-sented in the same man-ner based on the assess-ment of the final PDD and other background documenta-tion version.


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Validation Protocol Table 2: CCB - Resolution of Corrective Action and Clarification Re-quests

Clarifications and Cor-rective Action Re-quests

Ref. to table 1 Summary of project owner response

Validation team conclusion

If the conclusions from table 1 are either a Correc-tive Action Request or a Clarification Request, these are listed in this sec-tion.

Reference to the checklist question number in Table 1 where the Corrective Action Request or Clari-fication Request is ex-plained.

The responses given by the client or other project partici-pants during the communica-tions with the validation team is summarised in this sec-tion.

This section summa-rises the validation team’s responses and final conclusions. The conclusions should also be in-cluded in Table 1, under “Final PDD”.

In case of a denial of the project activity more detailed information on this decision will be presented in Table 3. Table 3 is also used for listing of any Forward Action Request.

Validation Protocol Table 3: Unresolved Corrective Action, Clarification Requests, Forward Action Requests

Clarifications Request, Corrective Action Request, Forward Action Request

Id. of CAR / CR / FAR

Explanation of the Conclusion for Denial, or Background of Forward Action Request

If the final conclusions from ta-ble 2 result in a denial or a For-ward Action Request the refer-enced request is listed in this section.

Identifier of the Re-quest.

This section presents an explanation, why the project is fi-nally considered not to be in compliance with a criterion with a clear reference to the requirement which is not complied with, or the details of the FAR.

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

2.1 Appointment of the Assessment Team According to the technical scopes and experiences in the sectoral or national environment TÜV SÜD has composed a project team in accordance with the appointment rules of the TÜV SÜD Certification Body “climate and energy”. The composition of an assessment team has to be approved by the Certification Body ensuring that the required skills are covered by the team. The Certification Body operates four qualification levels for team members that are assigned by formal appointment rules:

Assessment Team Leader (ATL)

Greenhouse Gas Validator (VAL)

Greenhouse Gas Auditor Trainee (T)

Experts (E)

Reviewer (R)

It is required that the technical area and sectoral scope linked to the applied methodology is covered by the assessment team. The validation team consisted of the following experts (the responsible Assessment Team Leader in written in bold letters):


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Name Qualification Coverage of technical

scope

Coverage of sectoral ex-

pertise

Host country experience

Sebastian Hetsch ATL

Hubertus Schmidtke VAL

Juan Chang VAL

Sebastian Hetsch is a forestry expert and appointed as Assessment Team Leader and GHG validator by the certification body "climate and energy" of TÜV SÜD. Mr Hetsch holds a degree in forest science. He passed extensive training on auditing of GHG projects. Before joining TÜV SÜD he worked for several years in the field of international forest policy.

Hubertus Schmidtke is a GHG auditor for forestry projects appointed by the certification body "climate and energy" of TÜV SÜD. He holds a PhD title in field of forest science special-ized in forest inventory design and the monitoring of carbon pools in afforestation and refor-estation projects. He has received extensive training in CDM related issues and has audited several afforestation and reforestation projects.

Juan Chang is a forestry expert and GHG auditor appointed by the certification body "cli-mate and energy" of TÜV SÜD. He is a forest engineer with more than ten years working ex-perience in forestry and land-use related projects. Since 2007 he participated in more than ten audits as member of the Audit Team for forestry projects under the CDM and different voluntary standards. He has successfully taken part in the training program for GHG auditors developed by TÜV SÜD.

2.2 Review of Documents The first version of the CCB PDD was submitted by the PP to the DOE in July 2008. This PDD version and additional background documents related to the project design and base-line were reviewed to verify the correctness, credibility, and interpretation of the presented information. As a further step of the validation process, information provided by the PP was cross-checked with information from other sources (if available). A complete list of all docu-ments and proofs reviewed is attached as Annex 2 to this report.

2.3 Follow-up Interviews and visited sites In the period of 22-25 February 2009, TÜV SÜD performed interviews on-site with project stakeholders to confirm selected information and to resolve issues identified in the first document review. The area included to the project boundary was visited as part of a field survey. The table below provides a list of all persons interviewed in this context.

Name Organisation

Mrs. Marioldi Sánchez Forest Specialist of AIDER

Mr. Jorge Torres Forest Specialist of BAM

Mr. Walter Nalvarte Forestry Advisor of AIDER

Mr. Percy Recavarren GIS specialist of AIDER


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Mr. Jorge Cantuarias General Manager of SFM BAM

Mrs. Sarah Walker Program Officer Winrock International

In this process of the onsite audit, the selected reforestation sites were visited and interviews with the relevant stakeholders and consultants have been carried out.

2.4 Resolution of Clarification and Corrective Action Requests The objective of this phase of the validation is to resolve the requests for corrective actions and clarifications and any other outstanding issues which needed to be clarified for TÜV SÜD`s positive conclusion on the project design. The Corrective Action Requests and Clarifi-cation Requests raised by TÜV SÜD were resolved during communication between the client and TÜV SÜD. To guarantee the transparency of the validation process, the concerns raised and responses that have been given are summarised in Chapter 3 below and documented in more detail in the validation protocol in Annex 1.

2.5 Internal Quality Control As final step of a validation the report and the protocol have to undergo an internal quality control procedure by the Certification Body “climate and energy”, i.e. each report has to be approved either by the Head of the certification body or his Deputy. In case one of these two persons is part of the assessment team approval can only be given by the other one.

The decision rests at TÜV SÜD’s Certification Body whether a project will be submitted for requesting registration by CCBA or not.

In this particular case, the review process by the Certification Body was carried out by Mr. Thomas Kleiser, Head of the Certification Body, involving Mr. Robert Scharpenberg, as an Expert in the field to cover the scope.


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3 SUMMARY OF FINDINGS Each of the CCB Standards criteria was assessed based on the project design documenta-tion review, follow-up interviews with relevant stakeholders and the review of the background information.

It is underlined that the present CCBS Validation Report focuses on those items and criteria, in which the CCB Standard exceeds VCS requirements as documented by Validation Report No. 1224986, dated 20 July 2009. Thus, the VCS Validation Report shall be considered an integral part of the present final CCB Standards audit report.

The main findings of the project audit in regard to the project design and CCB Standards compliance are summarized in the following sections:

3.1 General Section G.1. Original Condition of Project Site

The project is located in the Campo Verde District, Province of Coronel Portillo, Ucayali De-partment in the central east part of Peru in the Amazon basin. The project activity is con-ducted on 919.3 ha of degraded pastureland which was verified during the onsite visit (IRL 48).

The vegetation cover in the project area is predominantly grassland with disperse trees and small patches of remnant forest close to water courses. These forest patches were excluded from the project boundary as verified onsite and cross checked with the maps included in the PDD and the GIS data provided by the project participants (IRL 18).

The carbon stocks at the project site were estimated and considered for all relevant types of vegetation. For baseline stocks a site specific study was elaborated indicating carbon stocks of 3.54 t CO2/ha in trees and shrubs for the project area (IRL 22). These carbon stocks were discounted in the overall calculations of net anthropogenic removals.

As a part of the baseline studies on community aspects, it was found that 7 rural settlements are located nearby the project area, composed from 80 to 8 families in each settlement (IRL 6). Most of the people are farmers working in agriculture and cattle rearing for subsistence. The average area owned by each family is only 28 ha, from which approximately the half is under agriculture or cattle raising; the other half is degraded land and secondary forest.

A study conducted on January 2007 found that five families were living inside the project boundary based on an agreement with the land owner (IRL 6). A second study conducted on April 2009 describes how the relocation of the families took place confirming that no negative impacts were caused due to it. The evidence provided and the onsite visit allowed the auditor to confirm these facts.

The land is owned by the project participant SFM-BAM. This was sustained with correspond-ing land titles reviewed during the onsite visit (IRL 8-10). It was also confirmed with an his-torical land use analysis based on satellite imagery and interviews with the land owner that the land was abandoned for more than a decade with small grazing activity (IRL 18).

The biodiversity present in the project area was described based on a biophysical study con-ducted in January 2005. A total of 15 non-tree species, 62 fauna species and 33 macro fauna species were found inside the project boundary (IRL 5).

The sampling size was 2000m2 using sub parcels of 100m2 (10x10m) included in a transect of 200m. The flora, fauna and macro fauna were assessed in these parcels whit specific field forms. This approach is considered appropriate taking into account the degraded condition of the land and it´s homogeneous ecological characteristics.


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A description of the biodiversity present in the project area and the threats to biodiversity is provided in the project documents. The studies conducted found no endangered and threat-ened species according to the IUCN Red List Category in the project area, but in the regions of the project.

In conclusion, TÜV SÜD confirms that the project description, as included to the PDD, is suf-ficiently accurate and complete in order to comply with the requirements of the CCBS.

G.2. Baseline Projections

The most likely land-use-scenario in the absence of the project activity is ongoing degrada-tion. Although the current Forest Law and the National Forest Strategy of Peru encourage the establishment of forest plantations, there is no allocation of financial resources for such activity. Data from official sources was used to validate the provided information.

The additionality of the project was demonstrated based on the “Additionality tool for AR CDM” version 2 using barrier analysis. Barriers were assessed against official data as do-cumented in the Annex 2 and the VCS Validation Report. As described in the CCB-PDD, the ongoing degradation will lead to major impact to biodiver-sity in the remnant forest patches, increase of emissions as a result to further deforestation due to the lack of alternative land use scenarios rather than agriculture and cattle grazing. The rationale of this assumption was found credible considering the current degraded status of adjacent areas to the project area as verified onsite and further sustained with published information regarding the patterns of land use change around the project area (IRL 22).

The baseline carbon stocks changes estimated for the above and belowground carbon pools are based on site specific inventory data compiled for this project as well as default values that are consistent and applicable for the relevant field conditions.

For existing shrubs and scattered trees it was conservatively assumed that the increment is similar to a growth rate of secondary forest typical specie. A total amount of 13,651 tCO2 eq was estimated in the “without-project” scenario over a 30 years crediting period.

Good practice in regard to forest inventory and the applied defaults and sources have been followed in the context of the baseline assessment.

As it was previously described in section G.1 above, local communities are mostly farmers working in agriculture and cattle grazing at a subsistence level. The “without-project” scena-rio would be the continuation of the prevailing practices without access to technology and financial resources for more profitable activities like reforestation. It is credible that the con-tinuation of the prevailing land use would lead to the further degradation of the land and therefore reduce its productivity representing less income for the farmers. The onsite visit and the interviews allowed the auditors to verify that job opportunities are scarce since no major industries are found around the project area (IRL 6).

The conversion of the forest land to agricultural land and pasture land are the major drivers of habitat fragmentation and habitat loss around the project area as described in the CCB-PDD. A historical analysis of the fragmentation process was documented by a third party and provided as evidence (IRL 23). It is clear that the continuation of the fragmentation of the remaining patches of forest would increase the rate of loss of biodiversity around the project area. Under the baseline scenario, it is expected that biodiversity would rather decrease as the remaining forest patches around the project area would be impacted by the continuation of the prevailing activities. The acidic condition of the soil at the time the project started is most likely to remain acidic or become more acidic because of the continuation of the degradation process. In regard to the water resources, it is credible to expect an increase in surface runoff water as a result of fur-ther degradation (IRL 21).


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G.3. Project Design & Goals As a result of the project it is expected that a total of 169,971 tons CO2 will be sequestered from the atmosphere and local capacities in forestry practices will be built while providing an alternative land use rather than unproductive agriculture and cattle rearing. The use of native species would also provide habitat and may connect the remaining forest patches allowing mobilization of wildlife (IRL 3). Based on the project characteristics, the achievement of these goals is considered feasible. The described activities in the CCB-PDD include a biophysical and socioeconomic diagnosis prior the establishment of the plantation, plantation techniques as well as project implemen-tation monitoring and promotion of productive projects outside the project boundary with nearby communities. These activities are found to be consistent to achieving the project goals. A more detailed description of the activities can be found in the management plan ela-borated specifically for the project implementation. Maps are included to the CCB-PDD and were also provided in digital to the audit team. The latter allows a clear identification of the project boundary and the project location as verified during the onsite visit with GPS readings (IRL 48). The project is designed for 30 years considering the rotation cycle of the selected species with moderate growth rate. The assumption is credible and verified with the evidence pro-vided. An EIA was conducted for the proposed project activity considering the possible impacts to the quantity and quality of water and soil stability (IRL 37). Additionally the risk of encroach-ment and potential deforestation to adjacent areas to the project was analyzed. Mitigation measures were properly defined to undertake these risks. The main stakeholders identified are the families from the communities nearby the project area who will be employed for the project implementation. There are also two native com-munities located around 20 km distance from the project activity to which no direct contact is expected as a result of the project implementation (IRL 6). The project documentation can be found on the project website (http://www.bosques-amazonicos.com/) and can be also found at the project offices in Spanish. The Sharehold-er´s agreement between SFM Ltd. and SFM-BAM was provided during the onsite visit but are kept confidential (IRL 7). G.4. Management Capacity

It has been demonstrated that the management team has the appropriate experience for the scale of the project. It was confirmed during the onsite visit and with the corresponding con-tracts with the employees that most of the work staff was hired from the local communities and fulfill the requirements for the project implementation (IRL 3).

A joint venture between the Peruvian company Bosques Amazonicos (BAM) and the Bermu-dan company Sustainable Forest Management Limited (SFM Ltd) generated the creation of the company SFM-BAM which is the main responsible for the project implementation count-ing with the technical support of the NGO AIDER and Winrock International. In 2009, SFM Ltd closed its operations and transferred to Asterix Ltd its investments, rights and commit-ments in Bosques Amazonicos. Asterix Ltd. is a company formed by European and American private investment firms with extensive holdings worldwide (the firm is controlled by New York-based Octavian Advisors). Most of Asterix shareholders were SFM Ltd shareholders as well.

G.5. Land Tenure

The land property was sustained with the corresponding land titles and provided to the audi-tors during the onsite visit (IRL 8-10). As previously mentioned in section G.1, five families


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were voluntary relocated since they were using the land for grazing their cattle due to an agreement with the land owner before the project started. This was verified onsite based on field interviews and documented evidence by third parties.

The project participants recognize the possibility of potential in-migration of people due to the increase of expectations for labor in the project area. The approach taken to minimize this risk was first to hire people from the neighbor communities and when more labor is required by the project, people from the next city will be mobilized every day with vehicles. Further-more, it was verified onsite that the project anticipated the construction of camps for their employees if they require to stay longer at the project site (IRL 48).

G.6. Legal Status

The project is considered to comply with the national legislation of Peru as verified with the corresponding oficial documents related to forestry plantations in the country (IRL 41). The project has to be registered to the national authority of Peru after 3 years of the establishment of the plantation which remains to be provided which leads to the necesity to be confirmed by the time of verification.

G.7. Adaptive Management for Sustainability (optional)

The management structure enables the project to provide feedback and to allow adjust-ments. It is indicated that the sustainability of the project beyond its lifetime of 30 years will be secured through production and sale of timber and by the involvement of locals (IRL 3). While complying with the general CCB requirements, the estimates on project future beyond such large timeframes remain uncertain. An additional point is granted.

G.8. Knowledge Dissemination (optional)

The network of collaborators involved in the project is considered to lead the dissemination of specific lessons learnt. It is foreseen to enlarge the plantation area with 20,000 ha of private land, conducted by the land owners (IRL 3). This means an extensive emission of knowledge which shall be documented and evidence shall be provided at time of verification (see FAR 1 in Annex 1). An additional point is granted.

3.2 Climate CL.1.Net Positive Climate Impacts

The AR-AM0003 ver. 04 CDM methodology was applied in order to calculate the net change in carbon stocks as a result of project implementation in accordance with the VCS guidance for AFOLU projects. As indicated in the VCS Validation Report (IRL 68), a total net of 169,971 t CO2 are expected to be sequestered on the eligible planted area, with a VCS AFOLU buffer of 40%, the project would be able to generate 101,982 VCUs within 30 years of the crediting period.

According to the guidance provided by the EB 44 of the UNFCCC, the GHG emissions from fossil fuel combustion as well as from Nitrous oxide (N2O) emissions from decomposition of litter and fine roots from N-fixing trees may be neglected in A/R CDM project activities. Emis-sions from fertilizer application are also considered insignificant according to the decisions provided by EB 42 and therefore these sources were not considered in the calculations and monitoring.

Biomass burning as potential source according to the methodology was considered by the project proponents since it will be used for site preparation. The total amount of 9.03 t of CO2-eq was calculated as a result of biomass burning for site preparation, which is


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considered adequate (IRL 22). No other significant emission sources have been detected in the context of the project audit.

CL.2. Offsite Climate Impacts (“Leakage”)

Regarding potential leakage as a result of the project activity, the following activities were found relevant: a) fuelwood use and b) livestock grazing. The corresponding data was com-piled based on surveys, which have been reviewed by the audit team (IRL 38). Therefore, it was verified that the calculations on the expected amounts of the net positive climate are found to be consistent with the requirements of the CCB Standards. A profound discussion on the emission reduction calculations can be found in the VCS Validation Report (IRL 68) as well as in Annex 1 of this report below.

CL.3. Climate Impact Monitoring

The monitoring plan is compliant with the CCB Standard requirements. A monitoring plan is developed according to the requirements of the applied CDM EB approved methodology AR-AM0003 version 04. The monitoring plan and parameters as well as the designed implemen-tation of the plan were assessed by the audit team. As per applied methodology relevant carbon pools were included, as well as non-CO2 gases if significant.

CL.4. Adapting to Climate Change and Climate Variability (optional)

The considered climate change reports from IPCC show that the precipitation within the pro-ject will decrease and temperatures might increase (IRL 64, 65). The project anticipates po-tential impacts by choosing native tree species from local providence if possible. Nonethe-less, based on the knowledge so far on adaptation of species to climate change it is uncer-tain whether the selected (even) native species will overcome the changes (see. E. Lovejoy and Lee Hannah. Climate Change and Biodiversity). This additional point cannot be granted.

CL.5. Carbon Benefits Withheld from Regulatory Markets (optional)

The project intends to sell credits exclusively in the voluntary market, an additional point is granted.

3.3 Community Section CM1. Net Positive Community Impacts

The CCB Standard requirements are considered to be met in this field. In regard to socio-economic impacts two studies were carried out: one by the NGO “AIDER” in 2004 and a second survey by the consultancy firm “Social Capital Group” in 2007. The methodology ap-plied in both cases consisted on interviews to local authorities and farmers in the surrounding villages of the project. Both surveys were considered in the context of this audit (IRL 6, 20).

In regard to sustainability, the project aims to generate employment opportunities and train-ing in rural area.

Relevant local stakeholders are included in the project planning. This was confirmed by the audited team by reviewing relevant documents (IRL 42, 45) and during the onsite visit of the audit team. The communication method used to invite the stakeholders are appropriate and in line with the CCB Standard guidance.


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CM.2. Offsite Community Impacts

As there are no communities living on the actual project area, potential community impacts are considered offsite. No potential negative impacts are expected. Respective information was reviewed by the audit team and confirmed during the onsite visit (IRL 6).

CM.3. Community Impact Monitoring

In order to reflect the net positive impact of the project, an initial plan is provided as required by the CCB Standards. Main parameters included are i.e. income and housing. The parame-ters included are considered adequate to cover the CCBS requirements of an initial monitor-ing plan. However, a complete community impact monitoring plan remains to be developed (see FAR 2 in annex 1).

CM.4. Capacity Building (optional)

Forestry practices are promoted among villagers through training activities beyond the project boundary. As the training is conducted in the villages, a wide range of groups are ap-proached, including women. The CCBS requirements for capacity building was assessed by the audit team and found in compliance with the standard. An additional point is granted for capacity building.

CM.5. Best Practice in Community Involvement (optional)

The project as such is considered not to be developed based on local customs since large scale reforestations are not considered a common practice activity in the region. Nonetheless local traditions have been considered in the project design (IRL 3). Among others, as men-tioned in section G.4 above, most of the laboring personnel were hired from the local com-munities. It is therefore considered credible that the proposed project uses practices for community involvement which are likely to benefit these communities. Therefore an addition-al point is granted.

3.4 Biodiversity Section B.1. Net Positive Biodiversity Impacts

As it was described for the baseline scenario, it is credible that further degradation in the absence of the project would impact the general conservation status negatively (and with that biodiversity components and ecological processes).

In order to determine the net positive biodiversity impact of the project in future, it is foreseen that key species will be identified with the support of scientific advice which is considerate adequate for this purpose (IRL 67).

A corresponding preliminary assessment as included in the CCB PDD at the time of valida-tion indicates a positive overall project’s impact on biodiversity. It has been assessed that there will not be any negative effect on threatened species that were identified based on the IUCN Red List of Endangered Species (IRL 37).

B.2. Offsite Biodiversity Impacts

Although potential negative offsite biodiversity impacts could be caused due to potential in-migration of temporary workers near the project site, which might cause increasing pressure to wildlife and deforestation. This situation will be mitigated by the inclusion of locals as work-force during project implementation (IRL 39). This approach is considered appropriate to minimize the impacts generated by the project towards biodiversity.


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B.3. Biodiversity Impact Monitoring

An initial monitoring plan is included to the PDD for monitoring flora and fauna, and a com-plete monitoring plan was provided to the audit team. Main parameters included are e.g. tree species, vegetation type, animal species and habitat fragmentation (IRL 67).

The monitoring of flora is combined with the regular sampling layout for carbon sequestra-tion. The approach is considered feasible. Further specification may be necessary after com-pilations of first data sets and analysis of complete time series. In regard to monitoring of fauna, it is explained that transects will be used. It was clarified that future monitoring will track the development of floral biodiversity.

Nonetheless, considering increase of people coming to provide labour to the project activi-ties, parameters for monitoring illegal hunting shall be included in the monitoring plan (see FAR 3 in Annex 1).

B.4. Native Species Use (optional)

Only native species are used on the current eligible areas of this project. The additional point was therefore granted (IRL 3).

B.5. Water and Soil Resource Enhancement (optional)

No negative impacts on water quantity and quality are expected, considering the hydrological regime in the region and the water consumption of the selected native tree species. Native species planted in this project might enhance the ground water availability in relation to the baseline scenario. However no respective evidence was provided at time of validation to sus-tain this statement, thus no additional point was granted for enhancement of water and soil resources.

Nonetheless, an initial plan for monitoring the impacts of the plantation to water resources was elaborated by the PP (IRL 69).


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3.5 Summary of CCBS requirements The following table resumes the compliance of the different sections of the CCB standards:

Section required optional

General Section

G1. Original Conditions at Project Site

G2. Baseline Projections

G3. Project Design & Goals

G4. Management Capacity

G5. Land Tenure

G6. Legal Status

(G7.) Adaptive Management for Sustainability 1

(G8.) Knowledge Dissemination 1

Climate Section

CL1. Net Positive Climate Impacts

CL2. Offsite Climate Impacts (“Leakage”)

CL3. Climate Impact Monitoring

(CL4.) Adapting to Climate Change & Climate Variability -

(CL5.) Carbon Benefits Withheld from Regulatory Markets 1

Community Section

CM1. Net Positive Community Impacts

CM2. Offsite Community Impacts

CM3. Community Impact Monitoring

(CM4.) Capacity Building 1

(CM5.) Best Practices in Community Involvement 1

Biodiversity Section

B1. Net Positive Biodiversity Impacts

B2. Offsite Biodiversity Impacts

B3. Biodiversity Impact Monitoring

(B4.) Native Species Use 1

(B5.) Water & Soil Resource Enhancement -

SUM 6


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3.6 Comments by Parties, Stakeholders and NGOs The project documents have been published on the CCBA website. Comments by stake-holders were invited.

The following table presents all key information on this process:

Webpage: http://www.climate-standards.org/projects/index.html

Comment submitted by:

None

Issues raised:

-

Response by TÜV SÜD:

-


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3.7 Validation Opinion TÜV SÜD has performed a validation of the following proposed CCBS project activity “Refor-estation with native commercial species on degraded lands for timber and carbon purposes in Campo Verde, Ucayali – Peru”.

The review of the project design documentation and the subsequent follow-up interviews have provided TÜV SÜD with sufficient evidence to determine the fulfilment of stated criteria.

In our opinion, the project meets all relevant CCB Standards requirements. According to the scorecard approach introduced by CCBA, TÜV SÜD considers the project to comply with Gold status.

An analysis as provided by the applied CCB Standards demonstrates that the proposed pro-ject activity is not a likely baseline scenario. Emission reductions attributable to the project are hence additional to any that would occur in the absence of the project activity.

Given that the project is implemented as designed, the project is likely to achieve the esti-mated amount of emission reductions as specified within the version of project documents published on the CCBA webpage.

In this context it is underlined that from the auditor’s perspective a combined audit of CCBS and VCS criteria is feasible as CCBA does not foresee the actual issuance of carbon credits. Thus, no immediate risk of double counting is considered to exist. However, TÜV SÜD re-frains from liabilities related to ownership of carbon rights and credit issuance.

The validation is based on the information made available to us and the engagement condi-tions detailed in this report. The only purpose of this report is its use during the registration process as part of the CCBS project cycle. Hence, TÜV SÜD cannot be held liable by any party for decisions made or not made based on the validation opinion, which will go beyond that purpose.

Munich, 30 November 2010

_____________________________

Munich, 30 November 2010

_____________________________

Thomas Kleiser Head of Certification Body

“climate and energy” TÜV SÜD Industrie Service GmbH

Sebastian Hetsch Assessment Team Leader

TÜV SÜD Industrie Service GmbH

Validation of the CCBS project: Reforestation with native commercial species on degraded lands for timber and carbon purposes in Campo Verde, Ucayali – Peru

CCBA Validation Checklist

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ANNEX 1: TABLE 1: CCBS VALIDATION CHECKLIST

CHECKLIST QUESTION Ref. COMMENTS Draft Concl

Final Concl

G. General Section

G.1. Original Conditions at Project Site G.1.1. Are the location of the project and the basic physical

parameters (e.g. soil, geology, climate) clearly described? 2, 6, 28

The physical parameters are well described in the associated VCS Project Document (PD). The project is located in the District of Campo Verde, Province of Coronel Portillo, in the Region of Ucayali (in the central east of the country). Basic physical parameters of the project: tropical climate (22-32°C, 1860 mm perc. dry season Jun-Sep), 150-220 m above sea level. See also section 1.5 of the VCS PD

G.1.2. Is sufficient information provided concerning types and condition of the vegetation?

2, 22, 23

Current vegetation is grass and shrubland with remnant patches of forest. See also section 1.7 of the VCS PD.

G.1.3. Are the current carbon stocks properly explained, e.g. by using approved methodologies for the CDM or from the IPCC Good Practice Guidance?

2, 3, 21, 22, 26, 38

Results of calculations of current (baseline) carbon stocks are presented in section 4.2 of the VCS PD: total carbon stock is 26.1 tCO2e/ha including herbaceous vegetation, and 4.52 tCO2e/ha when only considering woody biomass. The UNFCCC approved methodology AR-AM0003 version04 was used to calculate carbon stocks

See CARs in section D.2 of the VCS checklist (table 1)

CARs in VCS check-

list

G.1.4. Are the communities in and around the project area adequately illustrated including basic socioeconomic in-formation? This should be done using appropriate meth-odologies such as the livelihoods framework.

2, 6, 11

A socioeconomic study is provided in Annex E. Several sur-veys were undertaken in years 2004, 2006 and 2008: 7 rural settlements are located in the vicinity to the project area. A survey of 147 families was conducted in 2004, sub-sequent studies in 2006 and 2008.

Corrective Action Request No 1. In the social study from 2007, it is stated that five families are

CAR 1



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living inside the project area. During onsite visit it was evi-dent, that they are not living there anymore. Please describe how that displacement took place and if it was attributable to the project. Sustain with evidence.

G.1.5. Is the current land use as well as the land tenure at the project site clarified?

2, 8, 9, 10

The project area is a private property. The area was used by the neighbours for grazing their animals (around 500 head of cattle owned by 7 individual farmers) The purchase contracts and the land registry were provided during onsite visit.

G.1.6. Are the current biodiversity conditions and threats to it characterized (using e. g. a key species habitat analysis or a connectivity analysis)?

2, 3, 5, 22, 25

A description of the species of flora and fauna is provided in Annex C with common names. It is mentioned that in com-parison with the original forest habitat there was a high loss of biodiversity. Corrective Action Request No 2. All threats to biodiversity (under baseline conditions) shall be characterized and described in the CCBA PDD (i.e. illegal hunting, illegal logging, burning, etc).

CAR 2

Is substantial and appropriate reference material pro-vided?

2 See CAR 2.

G.1.7. Are species that belong to the IUCN Red List and / or on a nationally recognized list (the latter if available) found within the project boundary? Is a list available? (also B1)

2,5, 6 A list of species under IUCN Red List is provided

G.2. Baseline Projections

G.2.1. a) Is the most likely land-use scenario in the absence of the project activity plausibly identified and described in de-tail?

2, 5, 22, 23,

24

The most likely land use of the area is to continue to be af-fected by fire, encroachment by cattle, subsistence crops and new settlements from neighbouring areas, which will further increase degradation.

See also section 2.4 of the VCS PD and CARs in section B.4 of the VCS checklist.

CARs in VCS check-

list

b) Do existing laws and regulations not require the project activity to be undertaken anyway?

2, 33, 41

No information on legal requirements is given in the PDD. However, the VCS PD indicates that reforestation is not re-

CAR 3



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quired by Peruvian law.

Corrective Action Request No 3.

Provide information in the CCBA document about legal re-quirements regarding the project implementation.

G.2.2. a) Are future carbon stock changes under the scenario in G.2.1. properly anticipated? The timeframe for this should be either the project’s lifetime or its accounting time.

2, 44, 38

The project’s life time has been chosen to be 30 years. Future projections of the baseline scenario are described in chapter 4 and 9 of the VCS PD.

b) Are proofs available evidencing that non-CO2 GHGs such as CH4 or N2O account for more than 15% of the baseline GHG fluxes at the project site (in terms of CO2 equivalents)? If so, are these emissions estimated appro-priately?

2, 24, 31, 38

CH4 and N2O are not considered a relevant source at valida-tion. This has been sustained through onsite visit, and de-tailed spreadsheet estimates (excel file: emission calcula-tion.xlsx in Annex N.)

Corrective Action Request No 4. The chapter describes project scenario. Please describe baseline situation.

CAR 4

G.2.3. Does the baseline scenario describe the effects on the local community in the project area?

2, 6, 32, 42

Fewer opportunities of labour for local people are expected as well as technical knowledge about plantation manage-ment.

G.2.4. Does the baseline scenario describe the effects on bio-diversity in the project area in a sufficient manner?

2, 5, 37

Clarification Request 1.

Since the land is already highly degraded, it is assumed that the biodiversity of plant species in the project area would re-main stable. Some wetlands with high carbon stocks may also be affected from burning. Provide evidence for his statement.

CR 1

G.2.5. Does the baseline scenario describe the effects on the water and soil resources in the project area?

2, 5, 21

A description is provided. It is indicated, that water quality may decrease as a result of increased stream flow. Cattle activity causes soil compaction and damages river banks.


Provide evidence on possible negative impacts on water

CAR 5



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quantity of the baseline situation.

G.3. Project Design & Goals

G.3.1. Are the scope of the project and a summary of the ma-jor climate, community and biodiversity goals demon-strated?

2, 3 Project goals are to reforest degraded land with native spe-cies to replicate native forests, which will enhance biodiver-sity and local economic development.

Corrective Action Request No 6. Provide information and reference to written strategies and management documents of the project, stating climate, community and biodiversity goals.

CAR 6

G.3.2. Is each major project activity (if more than one) and its relevance towards achieving the project’s goal described?

2, 3 Activities are briefly described. Most of them are referred to the plantation establishment.


Provide information on the project activities designed to achieve community goals.

CAR 7

G.3.3. Is the project location clearly described including a map with the major activities and georeferenced boundaries?

2, 8, 9, 10, 18

A map with the project boundaries is included.

G.3.4. a) Is the project’s timeframe clearly characterized?

2 It was established 30 years considering the growth curves of the selected species

b) Is a rationale provided for fixing the project’s lifetime? 2 The lifetime was fixed considering the growth curves of the selected species. Rotation period is 30 years.

c) If applicable, is a reason delivered for the lifetime differ-ing from the accounting period for carbon credits?

N/A

G.3.5. Are likely risks to climate, community and biodiversity benefits outlined?

2, 5, 6, 37

Yes, the risks are identified for water availability, water qual-ity, soil stability, risk of deforestation through in-migration due to the project. No risks are seen for biodiversity or social risks.

Corrective Action Request No 8. Describe any possible influence or risk of the project con-

CAR 9



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cerning the neighboring native communities.

Are measures planned against these risks explained? 2, 37 Measures to mitigate the above mentioned risks are ex-plained: use of lime for water disinfection, choice of appropri-ate machinery and adequate road planning to minimize soil damage, policy to favour local families for employment

See CAR 8

CAR 8

G.3.6. Have the local stakeholders been well defined including documents on this definition?

2, 6, 42

Seven small communities, including one native community, located on the road to Campo Verde are considered as stakeholders. The two native communities are living around 30 km apart from the project area. In between there is forest. The two communities don’t have any contact to the project area or are using it in any kind.

Corrective Action Request No 9. Provide further information and evidence on the exclusion of the two native communities as stakeholders in the CCBA-PDD.

CAR 9

G.3.7. Is transparency secured? Have all project documents been publicly available at or near the project site? Have local stakeholders been informed how the documents can be accessed? Have key documents been made available in local or regional languages? Has information withhold really to be considered confidential?

2, 11 Project documentation is public available from the website and local stakeholders were informed of where documenta-tion could be found during consultations. Shareholder agreements and contracts on purchase of the land are available for the validator but they are considered confidential.

G.4. Management Capacity

G.4.1. Does the management team have enough experience with regard to land management projects? Is documenta-tion on this issue available?

2, 3, 12, 13, 14, 15,

16

The project will be conducted by experienced organizations: the Peruvian NGO AIDER, the Bermudan company SFM Ltd and the Peruvian company SFM BAM. Winrock International is providing technical support for pro-ject implementation and monitoring.

Corrective Action Request No 10. Please provide more detailed information on organizational structure of the management team, the management team,

CAR 10



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the individual functions and skills.

G.4.2. If relevant skills are lacking, will appropriate partners implement the project?

2, 3, 12, 13, 14, 15,

16

15 professionals are working in the SFM BAM office in Lima, 8 professionals from AIDER and 6 from SFM Ltd are involved in the project. No relevant skills are lacking.

See CAR 10

CAR 10

Is the management capacity adequate for the scale of the project?

2, 3, 12, 13, 14, 15,

16

The management capacity is considered adequate. A list of the staff involved is provided in Annex G

G.4.3. Are key technical skills necessary for a successful im-plementation documented? Are members of the manage-ment team or project partners identified who possess ap-propriate skills?

2, 3, 12, 13, 14, 15,

16

Technical skills which are necessary for a successful imple-mentation of the project are listed. A list of the staff and CV’s involved are provided in Annex G.

G.4.4. Is the financial health of the implementing organiza-tion(s) documented?

2, 3, 12, 13, 14, 15,

16

The contractual agreement between SFM BAM and SFM Ltd is explained at the time the project was audited in 2009 which allowed the initial funding for the project jointly with financial support from the FONDAM fund and the Regional Govern-ment of Ucayali. In 2009 SFM Ltd closed its operations and transferred to Asterix Ltd its investments, rights and commitments in Bosques Amazonicos. Asterix Ltd. is a company formed by European and American private investment firms with extensive holdings worldwide (the firm is controlled by New York-based Octavian Advi-sors). Most of Asterix shareholders were SFM Ltd shareholders as well Corrective Action Request No 11. Provide information on the financial health of the project owners.

Corrective Action Request No 12. Use G.4.4 instead of G.4.5 in the header.

CAR 11 CAR 12



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G.5. Land Tenure

G.5.1. Is it guaranteed that the project will not encroach un-wanted on private property, community property, or gov-ernment property?

2, 8, 9, 10

The lands are private property of SFM BAM Evidence on land title is provided and found complete and correct.

G.5.2. Is no relocation of people occurring or, if the case, is any relocation necessary 100% voluntary and helping to resolve tenure problems in the area?

2, 6, 11

Some neighboring farmers where using the area for grazing, a survey analyzed the intensity (annex J). 136 cattle were grazing on 302 ha of project land, which means a density of 0.45 CA per ha. Agreements for displacing the cattle with the farmers were reached without negative reactions and on a voluntary basis.

Corrective Action Request No 13. Describe the process of relocation of the five families living on the project area prior to project start.

CAR 13

G.5.3. Is “in-migration” from surrounding areas likely to take place? If relevant, is the project’s response appropriate?

2, 6 The project’s hiring policy gives preference to local families. Workers from Campo Verde and Pucallpa will be transported every day. In-migration is not occurring inside the project area.

G.6. Legal Status

G.6.1. Is any law violated by the project activity? 2, 33, 41

All activities are under the area’s legal framework.

Corrective Action Request No 14. Please provide references to the mentioned legal framework.

CAR 14

G.6.2. Are all documents available evidencing that the project has or expects to obtain all approvals necessary from the relevant authorities?

2, 33, 41

The official approval is necessary within three years after start of the plantations. The company intends to apply for the approval and registration within the next two weeks. Together with the request documents on land title and management plan must be provided. A field visit is conducted. After that the request goes to Lima. The registration process can take around 3 months.



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G.7. Adaptive Management for Sustainability (optional)

G.7.1. Is it demonstrated that management actions and moni-toring programs are designed to generate reliable feed-back that is used to improve the project’s outcome?

2, 3 Management and monitoring is described in the VCS PD (sections 1.9, 3, 10)

See corresponding CARs in section A.9 and C in the VCS checklist

Clarification Request 2.

It remains to be demonstrated that management actions and monitoring programs are designed to generate reliable feed-back, if it is decided to comply with this optional requirement.

CR 2

G.7.2. Does a management plan exist for documenting deci-sions, actions and outcomes and is this information shared with others within the project team? This should secure that experience is transferred rather than lost when individuals leave the project.

2, 3, 12, 13, 14, 15,

16

SOPs have been developed for all technical procedures (An-nex F).

Corrective Action Request No 15. Please provide SOP on information flow in between man-agement team, if it is decided to comply with this optional requirement.

CAR 15

G.7.3. Is the project design flexible enough to accommodate potential changes? Are processes defined or in place to adjust project activities as needed?

2, 3 Internal periodic meetings will be held in order to discuss the progress of the project. See CAR 15

CAR 15

G.7.4. a) Are proofs available for an initial commitment towards long-term sustainability (beyond the end of initial financ-ing)?

2, 7 No proofs are available for long-term sustainability of the pro-ject.

A shareholder agreement with SFM BAM and SFM Ltd pro-vided at the time of onsite visit in 2009 specified that SFM Ltd pre-purchase the carbon rights from the project area. The results in a strong obligation to conduct the project over the whole life time.

b) Is a new project planned building on the outcomes of the initial one?

2, 3 Additional carbon projects are planned in the region. SFM intends to replicate the project type on 20’000 ha together small land owners.

c) Are payments for ecosystem services secured on a long-term scale?

2, 3 See above



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Final Concl

d) Are micro-enterprises promoted? 2, 3 See above

e) Are alliances established with organizations or compa-nies securing the continuation of sustainable land man-agement?

2, 3 See above

f) Other indicators for long term commitments. 2, 3 See above

G.8. Knowledge Dissemination (optional)

G.8.1. Are relevant or applicable lessons learnt documented sufficiently?

2, 3, 15

It is mentioned that this information is contained in the man-agement plan.

See also CR 2 and CAR 15

Corrective Action Request No 16. A description on the relevant or applicable lessons learned remains to be included in the CCBA PD; if it is decided to comply with this optional requirement.

CR 2 CAR 15 CAR 16

G.8.2. a) Is it described how the generated lessons learned (G.8.1.) are disseminated in order to encourage replica-tion of successful practices?

2, 3, It is foreseen to enlarge the plantation area with 20’000 ha of private land, conducted by the land owners. This means an extensive emission of knowledge. Workshops and site visits to the plantation are foreseen. Also community nurseries are foreseen.

Corrective Action Request No 17. Explain further and sustain with evidence if it is decided to comply with this optional requirement.

CAR 17 FAR 1

b) Will research been undertaken and disseminated that has widespread application?

2, 3 Technical information will be shared in regional, national and international conferences, workshops and articles.

See CAR 17

CAR 17

c) Are training workshops for community members from other locales planned?

2, 3 SFM BAM staff is providing technical assistance to a farmers organization interested in replicating the project activities

See CAR 17

CAR 17

d) Will “farmer to farmer” knowledge-transfer activities be conducted?

2 n/a n/a n/a



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e) Will the project result be linked to regional databases, if existent?

2 n/a n/a n/a

f) Is any cooperation with academic, corporate, govern-mental or non-governmental organizations planned?

2, 3 There is a close collaboration with Winrock International, Agraria University.

Corrective Action Request No 18. Provide further information into the PDD regarding coopera-tion with academic organizations.

CAR 18

g) Are other forms applied to disseminate the lessons learned?

2, 15, 45, 47

On SFM BAM website the information is public available, brochures, CD.

See CAR 18

CAR 18

CL. Climate Section

CL.1. Net Positive Climate Impacts CL.1.1.

a) Is the methodology used to estimate the net change in carbon stocks developed by IPCC GPG or approved by the CDM Executive Board? The net change is equal to carbon stock changes with the project minus the ones without the project.

2, 26, 34, 38,

44

The CDM methodology AR-AM0003 version 04 was used.

Corrective Action Request No 19. Please insert the main results on carbon stock change due to project activities, considering the CARs of the main VCS and the methodology checklist.

CAR 19

b) Are the assumptions about how the project activities will alter carbon stocks over the duration of the project or the project accounting period clearly defined and defend-able?

2, 38 The calculations of ex-ante net GHG removals are described in section 4 of the VCS PD. The CDM methodology AR AM0003 is followed.

c) Are the assumptions about how the project activities will alter non-CO2 GHG emissions over the duration of the project or the project accounting period clearly defined and defendable?

2, 31, 38

The assumptions were made using the CDM methodology AR AM0003.

See CAR 19

CAR 19

CL.1.2. If the non-CO2 gases CH4 and N2O are likely to ac-count for more than 15% (in terms of CO2 equivalents) of the project’s overall GHG impact, are these to gases fac-tored into the net change calculations?

2, 31, 38

Non-CO2 emissions are expected to account for less than 1% of total net anthropogenic GHG removal

CL.1.3. Does the project clearly demonstrate that the net cli-mate impact of the project (including changes in carbon

2, 38 A net positive climate impact is clearly demonstrated: about 169’971 tCO2e are expected to be the actual net anthropo-

CAR 19



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stocks and non-CO2 gases where appropriate) will give a positive result in terms of overall GHG benefits delivered?

genic GHG removal over the project lifetime (30 years).

See CAR 19

CL.2. Offsite Climate Impacts (“Leakage”)

CL.2.1. Are the potential offsite decreases in carbon stocks (increases in emissions or decreases in sequestration) due to project activities properly estimated?

2, 24, 28

Leakage is estimated in the VCS PD, section 4.3.2: Leakage from fencing is calculated to be 161 tCO2e over 32 years, which is considered insignificant and can be ne-glected. Furthermore, this is also considered non significant due to recent EB 44 guidance of the CDM. Displacement of pre-project grazing is estimated zero, since the displacement will be to already existing pastures, no addi-tional GHG emission will occur.

Corrective Action Request No 20. Leakage is calculated in section 4.3.2 of the VCS PD, not section 4.4; please correct.

CAR 20

CL.2.2. a) Are mitigation efforts referring to these negative offsite impacts documented?

2, 6, 20

Corrective Action Request No 21. No negative offsite impacts (leakages) are expected to occur. This is proven with leakage calculations according to the ap-proved CDM methodology. Therefore no mitigation measures are necessary. Please change the PDD accordingly.

CAR 21

b) Is the extent to which such impacts will be reduced adequately estimated?

2, 37 n/a See CAR 21 CAR 21

CL.2.3. Are likely project-related unmitigated negative offsite climate impacts subtracted from the climate benefits claimed by the project? The total net effect (net increase in onsite carbon stocks minus negative offsite climate im-pacts) has to be positive.

2, 37 Net emissions caused by leakage activities are included in the calculation of net GHG removals. There is a net positive impact

See CAR 20 and CAR 21

CAR 20 CAR 21

CL.3. Climate Impact Monitoring

CL.3.1. a) Is an initial monitoring plan in place

2, 14 A monitoring plan is in place, as described in the VCS PD, section 3 and 10. See corresponding CARs and CRs in section C of the VCS



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The CCB Standards accept at this stage of the project de-velopment that some of the plan details are not fully de-fined, especially if a small-scale project.

checklist.

b) Are the corresponding measurements and the sam-pling strategy (including the monitoring frequency) stated?

2, 14 Yes. The measurement technique and sampling strategy is referred to.

c) Are all potential pools (aboveground biomass, litter, dead wood, belowground biomass and soil carbon) in-cluded? Any pool expected to decrease as a result of the project activities must be included.

3, 38 According to the CDM methodology only above and below-ground biomass pools are monitored. Litter, SOC and dead-wood are low and can expect to be insignificant.

d) Are non-CO2 gases part of the monitoring plan? (Only applicable if these gases account for more than 15% of the project’s net GHG impact)

2, 14 The gasses are expected to account for less than 15%, thus this is not relevant for the proposed project activity.

CL.4. Adapting to Climate Change and Climate Variability (op-tional)

CL.4.1. Are likely regional climate change and climate variabil-ity impacts adequately identified using available studies ?

2 According to IPCC 4AR, temperature will rise and precipita-tion will decrease in South America.

Corrective Action Request No 22. Please sustain the statement on regional climate change with more evidence in more geographical detail, if it is decided to comply with this optional requirement.

CAR 22 No point

granted

CL.4.2. Are these potential impacts anticipated by the project (design) and will appropriate measures to minimize the negative consequences be taken?

2, 37

Corrective Action Request No 23. Species planted are adapted to local conditions and pre-dicted climate conditions (variability). Provide refer-ence/evidence for those statements, if it is decided to comply with this optional requirement.

CAR 23 No point

granted

CL.5. Carbon Benefits Withheld from Regulatory Markets (op-tional)

CL.5.1. Will the project proponents not sell at least 10% of the total carbon benefits (including e.g. avoided deforestation)

2 Since the project is applying also for VCS all credits gener-ated will be sold on the voluntary market. A certain amount of



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generated by the project into regulated GHG markets (Kyoto or other regulated markets)? Projects are allowed to sell these carbon benefits in a voluntary market or retire them.

credits will have to be withheld as buffer.

CM. Community Section

CM.1. Net Positive Community Impacts

CM.1.1. a) Were appropriate methodologies (e.g. livelihoods framework) used to estimate the net benefits to communi-ties resulting from planned project activities?

2, 6, 20

Different studies on social and economic conditions of the neighboring communities were carried out. The studies fo-cused on demographic and economic information, as well as on the perception of the communities to the project. Methodology used was a survey (interviews/questionnaire). This is considered adequate.

Corrective Action Request No 24. There are no communities within the project area. The project is implemented on private land only. All studies and stake-holder issues are related to neighboring communities. This shall be indicated in the PDD.

CAR 24

b) Are changes in the community wellbeing included in the net benefits? Are the corresponding assumptions about how social and economic wellbeing will be altered over time clearly defined and defendable?

2, 6, 20, 42

The salaries of local workers in the project are seen as main benefit to the communities. Considering the low average in-come of 0.10 USD per day, the suggested salary of 5 USD per day could add substantially to the local economy (PD cal-culates total of 250’550 USD).

Corrective Action Request No 25. The non monetary benefits like education, health etc. shall be listed in the PDD and evidence provided.

CAR 25

c) Is the net community benefit positive (“with project” scenario compared to baseline scenario of social and economic wellbeing)?

2, 7, 20

See above: the net benefit is a total of 250’000 USD that can stimulate the local economy. In addition to that there are non monetary benefits. See CAR 25

CAR 25

CM.1.2. a) Is the local stakeholder participation documented in the

2, 6, The project is developed on private property. Still local au- CAR 26



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Final Concl

project’s planning, also including potential dialogues? In cases where it is unclear whether a project will be imple-mented or not, it is acceptable to start with a preliminary community consultation, provided there are plans for a full engagement once the project is funded.

20, 42 thorities and NGOs have been involved in the process.


Provide information on the dates of stakeholder meetings (minutes, invitations, pictures, etc) and what kind of influence it had on the project design.

b) If the project occurs in an area with significant local stakeholders, is a diversity of stakeholders engaged in-cluding appropriate subgroups, underrepresented groups and women living in the project vicinity?

2, 6, 20, 42

No subgroups or underrepresented groups were engaged specifically. For no major local stakeholders are from the pro-ject area this is acceptable.

c) Did the stakeholders have the chance to raise concerns about potential negative impacts, to express desired out-comes and to provide input on the project design before the project design was finalized? Has the project proposal been revised or will it be revised based on the input of ac-cordingly?

2, 6, 20, 42

The consultation process gave the opportunity to stake-holders to comment on the project. The results will be presented at a workshop

See CAR 26

Corrective Action Request No 27. Provide information on how stakeholders / families were cho-sen for the interviews.

CAR 26 CAR 27

CM.1.3. a) Is a clear process defined for dealing with unresolved conflicts and grievances that arise during the planning and implementation?

2, 39 An office dedicated to community relations is foreseen to be incorporated in SFM BAM structure. It is not implemented yet. A procedure for handling conflicts is defined (9 steps).

Clarification Request 3. Provide information and evidence of the “office” to handle community relations (employees, address, how it is inte-grated in SFM, how it is financed, etc).

CR 3

b) Did the project design include a process for hearing, responding to and resolving community grievances within a reasonable time period? Has the grievance process been publicized to local stakeholders?

2, 45, 47

Project documents are available in the internet (CCBA homepage and TÜV SÜD Homepage), the documents are also available as hardcopy in the SFM offices in Pucallpa, Campo Verde and Lima) Information about submitting grievance will be communicated to all communities. Comments will be replied to in 30 days

CAR 28



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and TÜV will be notified.

Corrective Action Request No 28. The procedure on stakeholder consultation is defined in a SOP. It shall be referred to in the PDD. The implementation of the community relationship office shall be announced to the validation team.

c) Have attempts been undertaken to resolve all reason-able grievances raised and have written response to grievances been provided within 30 days?

2, 39 A positing was created to deal with grievance; every three month the community relation manager will meet with local authorities

See CAR 28

CAR 28

d) Have the grievances and the project responses been documented?

2, 15 No grievance has been documented so far and no complaints were recorded.

See CAR 28

CAR 28

CM.2. Offsite Community Impacts

CM.2.1. Have any potential negative offsite community impacts been identified that the project is likely to cause?

2, 37 No negative offsite community effects have been identified. Potential negative impacts are: - in-migration - displacement of grazing - conflicts between foreign and local workers

CM.2.2. Are the mitigation efforts concerning these negative so-cial and economic impacts properly described?

2, 37 Mitigation measures are developed, see also section G5

See CAR 28

CAR 28

CM.2.3. Is the net social and economic effect of the project posi-tive when comparing the social and economic benefits within the project boundaries with likely unmitigated nega-tive offsite impacts?

2, 6, 20

Potential negative social and economic offsite effects seem unlikely. No people are living on the private land of the pro-ject area. Offsite positive socio-economic effects are addi-tional income for local workers. Therefore, a net positive eco-nomic and social effect can be expected. The net benefit is a total of 250’000 USD that can stimulate the local economy. In addition to that there are non monetary benefits.



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CM.3. Community Impact Monitoring

CM.3.1. Is an (initial) plan available for how community variables to be monitored are selected? Potential variables include income, health, roads, schools, food security, education and inequality. The CCB Standards accept if at this stage of the project development some of the monitoring plan details are not fully defined, especially if the project is a small-scale pro-ject.

2, 11 Parameters related with the project activity to be monitored have been defined: income, food security, wild fauna, fire-wood, housing, community organization

Corrective Action Request No 29. Please elaborate how the monitoring will be conducted. Pro-vide methodology (SOP).

CAR 29

CM.3.2. Is the monitoring frequency clarified? 2, 11 Yes, all parameters are to be monitored triennial, apart from income (annually)

CM.3.3. Are community variables at risk of being negatively im-pacted by the project activities included in the monitoring plan?

2, 11 Not described in the PDD.

Corrective Action Request No 30. Include parameters on potential negative impacts, or explain why they are not included in the monitoring.

CAR 30 FAR 2

CM.4. Capacity Building (optional)

CM.4.1. Is the capacity building structured in a way that the needs of communities (not only of the project) are met?

2, 3 Training will be offered to employees of the plantation. Les-sons learned from the project can also be adopted to new plantations outside the project area, which might also qualify for CDM. Technical support is foreseen be offered on other topics: Plantations on private land, Guave as soil improving species, fire prevention, first aid.

CM.4.2. Is the capacity building targeted to a wide range of groups, not just elites?

2, 3 No. Capacity building is related to field work and respective know how. This is not elite specific.

CM.4.3. Is the capacity building targeted to increase the partici-pation of women?

2, 3 The company’s hiring practices are non-discriminatory in re-gard to gender. 40% of the workforce is female.

CM.4.4. Is the capacity building aimed to increase the commu-nity participation in the project implementation?

2, 3 Corrective Action Request No 31. There is no specific capacity building to increase the commu-

CAR 31



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nity participation in the project implementation, which is a project on private land only. The stakeholder participation may influence the decisions of the company indirectly. Please revise the PDD Chapter CM.4.4 accordingly.

CM.5. Best Practices in Community Involvement (optional)

CM.5.1. Was the project developed with a strong knowledge of local customs? Is the project compatible with local cus-toms?

2, 3 Knowledge on native tree species was required for the pro-ject. However no strong knowledge of local custom was there in advance of the project.

CM.5.2. a) Will local stakeholders fill all employment positions (in-cluding management) if the job requirements are fulfilled?

2, 3 All SFM staff hired for the project lived in the region before joining the company.

Corrective Action Request No 32. Please indicate in the CCBA PDD that there are no restric-tions for local employees if they fulfil the job requirements, if it is decided to comply with this optional requirement.

CAR 32

b) Is the manner explained by which local stakeholders are selected for positions? Do traditionally underrepre-sented stakeholders and women get a fair chance to fill positions for which they can be trained?

2, 3 Women were 40% of the workforce in 2007 and 20% in 2008 and 8.5% of the workforce comes from a indigenous commu-nity (1 out of seven communities in the project’s vicinity)

CM.5.3. a) Are workers informed about their rights by the project proponents?

2, 3

Corrective Action Request No 33. No information is provided if workers are informed on their rights. Please describe this in the PDD and sustain it with evidence.

CAR 33

b) Does the project comply with international rules on worker rights?

2, 32 No information is provided on international workers rights. SFM BAM complies with national Peruvian worker law, and the respective requirements for permanent and temporary workers. For the latter the company has signed agreements with health centers. Safety conditions on the project area were considered ade-quate during check at onsite visit (safety equipment for use of herbicide).

CAR 34



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There are contracts with health centers nearby to cover health requirements of the workers. The company pays the health insurance of the workers. Reports from the health cen-ters were provided.

Corrective Action Request No 34. The different employment conditions shall be described in the PDD.

CM.5.4. a) Are situations and occupations that pose a substantial risk to worker safety comprehensively assessed?

2, 12

Corrective Action Request No 35. There are several high risky activities like work with herbi-cides or chain saw. Please list them in the PDD.

CAR 35

b) Is a plan in place to inform workers of potential risks and to explain how to minimize such risks?

2, 12 Workers are equipped with personal protection equipment. There are periodic trainings on labor risks, first aid proce-dures. Refer to all identified high risk activities.

See CAR 35

CAR 35

c) Are risks being minimized using best work practices, where worker safety cannot be guaranteed?

2, 12 See CAR 35 CAR 35

B. Biodiversity Section

B.1. Net Positive Biodiversity Impacts

B.1.1. a) Are the methodologies (e.g. key species habitat analy-sis, connectivity analysis) used to estimate the changes in biodiversity resulting from planned project activities ap-propriate?

2, 5 The methodology used in the EIA is based on the Leopold Matrix, a qualitative environmental impact assessment method used to identify the potential environmental impact of the project on the environment.

Corrective Action Request No 36. Sustain the choice of the qualitative methodology instead of any other quantitative one. Explain the five criteria (magni-tude, duration, accumulation, extent and fragility) in more de-tails, how the necessary field data will be gathered and how the results will be used (G.3.5 does not list biodiversity).

CAR 36



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b) Are the assumptions for this estimate clearly defined and defendable?

2, 5 See CAR 36 CAR 36

c) Is the net biodiversity benefit positive (“with project” scenario compared to baseline biodiversity scenario)?

2, 5 Applying the above mentioned methodology, a positive net biodiversity benefit can be expected

See CAR 36

CAR 36

B.1.2. a) Are possible adverse effects of non-native species on the area’s environment described (including impacts on native species and disease introduction or facilitation)?

2, 3 N/A. The Project is using only native species

b) If the impacts are substantial, is the necessity of using non-native species over native species justified?

2 N/A

B.1.3. Is a list of threatened species available (G.1.8)? Is documentation available showing that the project activities will not be detrimental in any way to these species?

2, 5, 25

Chapter G.1.7 provides a list of threatened species under IUCN Red List. The project will establish Mahogany which is in risk of extinction under CITES. The monitoring designed by AIDER is described in section B.3.1

Corrective Action Request No 37. Include the list of threatened species under national list and explain why the activities of the project will not affect them.

CAR 37

B.1.4. Are all species to be used by the project identified? Will no known invasive species be used?

2, 3, 34, 35,

36

Only native species will be used: Scientific Name Common name Swietenia macrophylla King Mahogany Tabebuia serratifolia (Vahl) Nichols.

Ipe

Simarouba amara Aubl. Marupa Dipteryx odorata (Aubl.) Willd.

Cumaru

Inga edulis Mart. Guaba

B.1.5. Is it guaranteed that no genetically modified organisms will be used to generate carbon credits?

2, 3, 34, 35,

36

There is no, nor are there any plans, to use any GMOs in any aspect of the project



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B.2. Offsite Biodiversity Impacts

B.2.1. Are potential negative offsite biodiversity impacts that the project is likely to cause identified?

2, 5, 37

The main risks to biodiversity are related to deforestation or degradation caused by local migration and the quality of river water affected by the presence of people working.

Corrective Action Request No 38. Deforestation or degradation and decrease of water quality is unlikely to happen. Please modify the section to real potential negative offsite impacts, if there are any.


Explain whether hunting by workers will cause offsite biodi-versity impacts.

CAR 38

CAR 39

B.2.2. Are the mitigation efforts concerning these negative biodiversity impacts properly described?

2, 5, 37

In section G.3.5 it is described the mitigation efforts of the negative impacts.

B.2.3. Is the net biodiversity effect of the project positive when comparing the biodiversity benefits within the project boundaries with likely unmitigated negative offsite im-pacts?

2, 5, 37

See CAR 38

CAR 38

B.3. Biodiversity Impact Monitoring

B.3.1. a) Is a plan available for how biodiversity variables to be monitored are selected? Potential variables include spe-cies abundance and diversity, landscape connectivity, for-est fragmentation, habitat area and diversity. The CCB Standards accept if at this stage of the project development some of the monitoring plan details are not fully defined, especially if the project is a small-scale pro-ject.

2, 67 A biophysical analysis was conducted prior to implementation of the project and will be repeated every 3 years in order to monitor biodiversity. Corrective Action Request No 40.

Provide information on the methodology for monitoring the parameters, why the parameters where chosen (explain why flora is not monitored) and how the data will be gathered.

Corrective Action Request No 41. The monitoring plan should also include variables for moni-toring threats to biodiversity (i.e. fire, hunting?).

CAR 40,

CAR 41

FAR 3

b) Is the monitoring frequency clarified? 2, 67 The monitoring frequency is set to 3 years.



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c) Are biodiversity variables at risk of being negatively im-pacted by the project activities included in the monitoring plan?

2, 67 See CAR 40 CAR 40

B.4. Native Species Use (optional)

B.4.1. Is it proven that the project will only use species being native to the region? …OR…

2, 3 Only native species to the region will be used, see B1.4.

B.4.2. If non-native species are planned to occur, is their use justified by being superior to native species for generating concrete biodiversity benefits (e. g. for rehabilitating de-graded areas unlikely to support natives or for producing fuel wood that reduces logging pressure on intact ecosys-tems)?

2 N/A

B.5. Water and Soil Enhancement (optional)

B.5.1. Are project activities that are likely to enhance water and soil resources identified?

2, 3, 64

Regarding soil resources, the project will use nitrogen fixing species to improve soil quality. The introduction of trees assists to stabilize system nutrient levels. Nutrients are stored in the trees themselves, but trees also reduce leaching and erosion rates. The results of the implementation of the hydrologic monitor-ing plan shall be provided at time of verification. The analysis of the results shall discuss the direct cause-effect of the project activity to the quality and quantity of water and sus-tained with evidence

Corrective Action Request No 42. No specific activities are described to enhance water re-sources. Please describe the positive effect of the trees and forest on the water regime in comparison with the water re-gime of the degraded grassland (baseline) and provide refer-ences, if it is decided to comply with this optional require-

CAR 42 No point

granted



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Final Concl

ment.

B.5.2. Is it credibly demonstrated that these activities are likely to improve water and soil resources compared to the baseline?

2, 3 It is sustained with literature that the use of nitrogen fixing species will improve soil quality and that establishment of forests improve the water regime.

See CAR 42

CAR 42 No point

granted

B.5.3. Do justifiable assumptions about cause and effect as well as relevant studies support the statements in B.5.2.?

2, 3 See CAR 42 CAR 42 No point

granted


Summary of Responses to Corrective Action and Clarification Requests

page 43

Table 2: Summary of Responses to Corrective Action and Clarification Requests

Clarifications and Corrective Action Requests by Validation Team

Ref. to tables 1

Summary of Response Validation Conclusion

Corrective Action Request #1 The social study from 2007 5 families are mentioned to live inside the project area. Actually they are not living there anymore. Please describe how that displacement took place and sustain with evidence.

G.1.4. Project team 19.05.09: Describes displacement and actions taken by the project Audit team 24.05.09: A report on the displaced families was provided and considered credible by the audit team. The CAR is closed.

Corrective Action Request #2 All threats to biodiversity shall be characterized and de-scribed in the CCBA PDD (i.e. illegal hunting, illegal log-ging, burning, etc).

G.1.6. Project team19.05.09:

A summary of biophysical conditions is provided together with the results of a connectivity analysis and the 2005 biophysical survey, showing that a very significant loss of biodiversity has already taken place and the current biodiversity in the project area is very low, compared with the original forest habitats present before the land was cleared.

Audit team 24.05.09: The only threat identified is habitat fragmentation because of agri-culture and grazing, but it is referred as only occurring on neighboring properties.

- Further description regarding threats to biodiversity shall be included to the PDD.

- The connectivity and fragmentation analysis referenced as evidence are lacking of consistency (a map indicating the project area and the protected areas nearby is not a connectivity analysis, in regard to fragmentation contains mostly general literature). A proper methodology shall be described.

Project team: A connectivity analysis was completed for the property containing the project area as part of the development of the project biodi-versity monitoring plan. The analysis indicated that forest cover in



page 44


Ref. to tables 1


the project area is insufficient to establish a corridor for wildlife between the project area and the surrounding forests and three State protected areas, representing a threat to biodiversity in the project area. Other threats to biodiversity in the project area identified during the development of the biodiversity monitoring plan were illegal hunting in the property and fires. These threats as well as meth-ods to monitor and mitigate them are further described in the bio-diversity monitoring plan. Audit team: The provided document (monitoreo de biodiversidad) concludes that the project area could facilitate the connectivity between the remnants of forest patches around the project area under the pro-ject scenario but does not provide robust evidence on the connec-tivity between the Protected Areas as indicated in the PDD. The discussion on connectivity shall be moved to section B.1 as this is related to project scenario not to baseline. Clarify that this refers only to the remnants of forests patches around the project area and not to the State Protected Areas.

- The species mentioned as “key species” in the document “Estudio de Impacto Ambiental” are not suitable for moni-toring changes in biodiversity due to the proposed project activity. Some of these species are indicators of conserva-tion status of primary forest (Atheles spp) and some other have no clear indication on the purpose (i.e. “Aguajales” Mauritia flexuosa is widely distributed in the Amazon is not specific to the project area). Consider excluding entire paragraph or providing a proper assessment on Key Spe-cies and sustain with evidence.

- Use scientific names for referring the species. - For the entire document, the references indicated as An-

nex D, C, etc, shall be mentioned in the footnotes (these will not be uploaded to CCBA website).

- According to the biodiversity monitoring document 40



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Ref. to tables 1


species are under the UICN red list, while the PDD indi-cates 25 (in section G.1.7). Clarify and ensure consis-tency.

Project team (02.09.10): As it is mentioned previously, the connectivity analysis concludes that the forest cover will be insufficient to establish a corridor with the surrounding forests and protected areas. More clarification has already included indicating that the project could not guaran-tee a safe movement of wild fauna from the closest protected ar-eas (many kilometers far away), considering a fragmented land-scape. The discussion on connectivity has been moved to chapter B.1. Paragraph referred to EIA has been deleted, scientific names have been included and references to Annexes have been men-tioned. The PDD has been corrected, the difference is explained because UICN updates their list every six months and the EIA didn’t have the scientific names for all the species as the Biodiversity Monitor-ing Plan does. Audit team 15.09.10: The answer provided and the updated PDD is sufficient to close the request.

Corrective Action Request #3 Provide information about law requirements regarding the project implementation.

G.2.1 Project team:

The owner of the forestry plantation shall register the project be-fore the Regional Authority for Forestry and Fauna three years after the plantation project has started. A managing plan, a spe-cial permit and paying the corresponding fee are required in case the holder intends to commercialize wood grown within the plan-tation.

Audit team 24.05.09: Law requirements for project implementation are not referred on the project document.

- Provide an indication whether the project activities would



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Ref. to tables 1


have been taken anyway if required by the existing laws. Project team: There are no laws in Peru that require reforestation activities. Al-though there is a national reforestation plan, there are insufficient funds for implementation. Therefore the project activities would not have taken place anyway in the absence of the project. Audit team: According to the legislation of Peru, there are no legal obligations on reforestation activities in private lands. Evidence was provided and considered sufficient.

Corrective Action Request #4 The chapter describes project scenario. Please describe baseline situation.

G.2.2. Project team:

G.2.2. added Under the baseline situation the project area con-tains degraded lands that are currently being grazed at a low level.

Audit team 24.05.09: The baseline projections are provided as well as the description of the condition in the “without project” scenario. The CAR is closed

Corrective Action Request #5 Provide evidence on possible negative impacts on water quantity of the baseline situation.

G.2.5. Project team: Deleted text referring to water quantity Audit team: No evidence on possible negative impacts on water quantity of the baseline situation was provided.

- Include a statement regarding impact on water quantity and sustain with evidence.

Deletion of the word quantity in the referred chapter ended up messing the sense of the phrase: “The ‘without-project’ land-use scenario of further land degradation in the project area is likely to have no positive impacts and possible negative impacts both on water quality.” Project team: The ‘without-project’ land-use scenario of further land degradation in the project area is likely to have no positive impacts and possi-



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Ref. to tables 1


ble negative impacts on water quality. The population growth rate surrounding the project area in the ‘without-project’ land use sce-nario is not known; however, it is unlikely to result in any positive impacts on water or soil resources. Audit team: Under the baseline scenario, the land is expected to be subject to further surface water evaporation due to the lack of ground cover. Avoid duplicated sentences in the description: “The population growth rate surrounding the project area...” See last paragraph. Project team 02.09.10 The paragraph has been deleted. Audit team 15.09.10: Corrections were made as requested.

Corrective Action Request #6 Provide information and reference to written strategies and management documents of the project, stating climate, community and biodiversity goals.

G.3.1. Project team: Mission and goals of the project described. Audit team: Community goals not mentioned in this chapter, however they are mentioned in G.3.2; according to this section of PD community goals include “increasing monetary incomes, developing technical skills and changing unsustainable agriculture for agroforestry sys-tems”. Reference to community goals must be included in this chapter. Project team: Finally, with this project, the company is also proud to contribute to local development and community goals by increasing mone-tary incomes, developing technical skills and changing unsustain-able agriculture for agroforestry systems in neighbouring commu-nities. Audit team: Agroforestry activities will be promoted among local villagers be-sides the employment generation.

Corrective Action Request #7 G.3.2. Project team:



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Ref. to tables 1


Provide more information on the activities towards achiev-ing the community goal.

Described how project activities will contribute to achieving com-munity goals. Audit team: Project proponents mention: “productive projects with neighbour-ing communities such as the replication of plantation model in 20 thousand hectares in plots of rural families, and other crops”, as the principal activities to be carried out in order to achieve the community goals.

Corrective Action Request #8 Describe any possible influence or risk of the project con-cerning the neighboring Native Community.

G.3.5. Project team: Benefits to the community of Santa Teresita as well as the neutral influence on Nuevo Paraiso described. Audit team: Proponents identify a positive impact for Santa Teresita popula-tion, based on the project’s labor-force demand, which offers in-come opportunities to the community. No impact is foreseen re-garding Nuevo Paraiso as the distance to the project area.

Corrective Action Request #9 Provide further information and evidence for the exclusion of the two native communities as stakeholders in the CCBA-PDD.

G.3.6. Project team: Benefits to the community of Santa Teresita as well as the neutral influence on Nuevo Paraiso described. Audit team: Rationale explaining exclusion of Nuevo Paraiso (30Km-distant from the project) was discarded as stakeholder considering the geographic location. For the case of Santa Teresita, it is foreseen that labor force will be hired there, being considerable as stake-holder.

Corrective Action Request #10 Please provide more detailed information on organization structure of the management team, the management team, the individual functions and skills.

G.4.1. Project team: Experience and qualifications of key management personnel de-scribed. Audit team: Detail is provided about the general background of the organiza-tions that take part in the project, with emphasis on SFM Ltd., SFM-BAM and AIDER.



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Ref. to tables 1


Although, detailed information is missing about the structure of the management team for the project itself. Project team: The structure of the project management team is further described in the Project Management Plan and now referenced in this sec-tion of the PD. A diagram of the project management structure is included in the Management Plan. Audit team: The management plan includes an organization chart of the pro-ject. This document was provided to the audit team as evidence.

Corrective Action Request #11 Please provide information on the financial health of the project owners.

G.4.4. Project team: Updates to the Assignment Agreement as well as financial model-ling described. Audit team: Description of the Assignment Agreement provided in 2009 in-cludes the investment commitment of 10 USD million for the op-erations. Financial modelling is mentioned, as supporting the assignment agreement terms. However in 2009 SFM Ltd closed its operations and transferred to Asterix Ltd its investments, rights and commitments in Bosques Amazonicos. Asterix Ltd. is a com-pany formed by European and American private investment firms with extensive holdings worldwide (the firm is controlled by New York-based Octavian Advisors). Most of Asterix shareholders were SFM Ltd shareholders as well.

Corrective Action Request #12 Use G.4.4 instead of G.4.5 in the header.

G.4.4. Project team: Made correction Audit team: Corrective action implemented

Corrective Action Request #13 Describe the process of relocation of the five families living on the project area prior to project start.

G.5.2. Project team: Describes relocation process Audit team: The chapter states that although 5 families were living within the



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Ref. to tables 1


property, the specific locations are not included in the project area. Also states that they agreed to move their homes back to their own lands, also moving their animals back to their own pas-tures.

Corrective Action Request #14 Please provide references to the mentioned legal frame-work.

G.6.1. Project team:

The plantation project is developed under the following legal framework:

Legislative Decree N° 1090, Forestry and Fauna Law, modi-fied by Law N° 29317

Supreme Decree N° 002-2009-AG, regulation of Legislative Decree N° 1090.

Law for the Promotion of Private Investment in Reforestation and Agroforestry (N° 28852)

The abovementioned regulations allow activities involving forestry resources in forestry plantation projects. For that purpose, the holder of the forestry plantation shall register the project before the Regional Authority for Forestry and Fauna three years after the plantation project has started. A managing plan, a special permit and paying the corresponding fee are required in case the holder intends to commercialize wood grown within the plantation. Audit team: The references to the legal framework were provided and included to the PDD.

Corrective Action Request #15 Please provide SOP on information flow in between man-agement team, if it is decided to comply with this optional requirement.

G.7.2 Project team: SOP included in Annex F Audit team: SOPs on information flow were provided to the audit team. The CAR is closed.

Corrective Action Request #16 A description on the relevant or applicable lessons learned remains to be included in the CCBA PD; if it is decided to comply with this optional requirement.

G.8.1. Project team: Relevant lessons learned are listed. Audit team: List of lessons learned is included in this section. The figure in



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Ref. to tables 1


section G.8.1 must be translated into English and the duplicated one must be removed Project team: Figure translated to English and the duplicate has been removed. Audit team: Section of the PDD translated to English as requested.

Corrective Action Request #17 Explain further and sustain with evidence if it is decided to comply with this optional requirement.

G.8.2. a)

Project team: Capacity building plan for program implementation is outlined. Audit team: Information is included on the chapter. The intention to expand the plantation area to replicate the model on private land clearly indi-cates the dissemination of information beyond the project bound-ary. FAR 1: The inclusion of private owners in reforestation practices and the reforested area on their lands will have to be checked by the time of verification.

FAR 1

Corrective Action Request #18 Provide further information into the PDD regarding coopera-tion with academic organizations.

G.8.2. f)

Project team:

G.8.2.f added During this phase of the project technical support was provided by Agraria University Technology Institute, Lima. Winrock International provided support to project design and de-velopment.

Audit team:

A paragraph including the collaboration with Winrock International and the Agraria University was inserted.

Corrective Action Request #19 Please insert the main results on carbon stock change due to project activities, considering the CARs of the main and the meth. checklist

CL.1.1. Project team: Summary information and table was inserted Audit team: The table must be updated based on the latest calculations. Project team: Tables 1 and 3 of the CCB PD have been updated based on the last calculations for the VCS PD.



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Ref. to tables 1


Audit team: - The table 2 included is not correct; the values are not in

the corresponding column. Check for same inconsisten-cies in all tables related to Climate in correspondence to the latest VCS PD (i.e. table in section G.1.3).

Project team: The values in Table 1 of the CCB PD were corrected based on the values in Table 22 of the VCS PD. The values in Table 2 of the CCB PD were corrected based on the values in Table 24 of the VCS PD. The values in Table 3 of the CCB PD are correct based on the values in Table 35 of the VCS PD. The long term average of net anthropogenic GHG removals by sinks was added to Table 3 of the CCB PD. Audit team 15.09.10: The updated PDD has amended the inconsistencies, thus the CAR is closed.

Corrective Action Request #20 Leakage is calculated in section 4.3.2 of the VCS PD, not section 4.4; please correct.

CL.2.1. Project team: Made correction Audit team: In order to assure transparency, include a summary of the leak-age analysis due to displacement of grazing Project team: The following summary of the leakage analysis was included: 136 animals of neighbors were found in the leakage analysis, be-tween cows and lambs grazing in 302 hectares of the project area in the baseline, with an average of 0.45 animals per hectare. The survey found that the farmers have 220 ha of free lands to allo-cate the animals displaced and this area is enough based on the grazing capacity in a traditional system. These free areas were located and will be monitored during the first 5 years of implemen-tation. Audit team: Information on leakage included to the CCB PDD. A detailed



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analysis can be found in the VCS PD.

Corrective Action Request #21 No negative offsite impacts (leakages) are expected to oc-cur. This is proofed with leakage calculations according to the approved CDM methodology. Therefore no mitigation measures are necessary. Please change the PDD accord-ingly.

CL.2.2. Project team: CL.2.2 added no negative offsite impacts (leakages) are expected to occur as proofed with leakage calculation therefore no mitiga-tion measures are necessary. and deleted description of mitiga-tion measures for grazing Audit team: Reference to no offsite impacts is included in the text.

Corrective Action Request #22 Please sustain the statement on regional climate change with more evidence in more geographical detail, if it is de-cided to comply with this optional requirement.

CL.4.1. Project team: Added reference to WRI Climate Analysis Indicators Tool Audit team: Reference to “WRI climate analysis indicators tool” is included in this section

Corrective Action Request #23 Species planted are adapted to local conditions and pre-dicted climate conditions (variability). Provide refer-ence/evidence for those statements, if it is decided to com-ply with this optional requirement.

CL.4.2. Project team: Reference provided Audit team: Reference to the native precedence of the species used was in-cluded. Nonetheless, based on the knowledge so far on adapta-tion of species to climate change it is uncertain whether the se-lected (even) native species will overcome the changes (see. E. Lovejoy and Lee Hannah. Climate Change and Biodiversity). This additional point cannot be granted.

No additional point granted

Corrective Action Request #24 There are no communities within the project area. The pro-ject is implemented on private land only. All studies and stakeholder issues are related to neighboring communities. This shall be indicated in the PDD.

CM.1.1. a)

Project team: Stated that the project activities take place on private land owned by SFM BAM and only stakeholder issues related to neighboring communities are considered. Audit team: Reference is included in the PDD

Corrective Action Request #25 The non monetary benefits like education, health etc. shall be listed in the PDD and evidence provided.

CM.1.1. b)

Project team: Non monetary benefits including health care and holidays are de-scribed



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Audit team: Reference is made to no-monetary benefits.

Corrective Action Request #26 Provide information on the dates of stakeholder meetings (minutes, invitations, pictures, etc) and what kind of influ-ence it had on the project design.

CM.1.2. a)

Project team: Included table of stakeholders and describes the process by which stakeholder leaders are chosen. Audit team: Names and village of origin of the participants in certain meeting are the only references provided. Information is missing on the dates of stakeholder meetings (minutes, invitations, pictures, etc) and the kind of influence their participation had on the project de-sign. Project team: As a result of the stakeholder consultations, a positive relationship was developed between SFM BAM and the communities sur-rounding the project area. SFM BAM has provided support to the local communities through the implementation of activities that have mutual benefits such as the improvement of roads in Agua Blanca. SFM BAM has also provided technical support to public works in the communities. Invitations to SFM BAM to participate in community events further demonstrate the positive relationship that has developed between the company and local stakeholders. Documentation of stakeholder meetings and impact on project design including photographs of community improvement activi-ties implemented by the project has been added to the supple-mentary documents and referenced in this section. Audit team: Evidence on the stakeholder meetings and further evidence on the relationships with the communities near the project area was provided.

Corrective Action Request #27 Provide information on how stakeholders / families were chosen for the interviews.

CM.1.2. c)

Project team:

Information on how stakeholders and families were chosen for the interviews is found in CM.1.3.a.



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Audit team:

A reference to CM1.3.a is made. However, no reference is men-tioned in CM1.2 or CM1.3 about how the families were chosen for the interviews.

Project team:

Information on how stakeholders and families were chosen for the interviews is found in CM.1.2.a and CM.1.1.a, respectively.

Audit team:

Local leader representatives were chosen for the interviews as they are elected by each community members.

Corrective Action Request #28 The procedure on stakeholder consultation is defined in a SOP. It shall be referred to in the PDD. The implementation of the community relationship office shall be announced to the validation team.

CM.1.3. b)

Project team: Referenced Community Relations Office Guidelines and included document in Annex O. Audit team: Reference to Community Relations Office was included, as cre-ated in April 2009.

Corrective Action Request #29 Please elaborate how the monitoring will be conducted. Provide methodology (SOP).

CM.3.1. Project team: Updated table and included new SOP in Annex F Audit team: SOPs were developed and provided to the audit team

Corrective Action Request #30 Include parameters on potential negative impacts, or ex-plain why they are not included in the monitoring.

CM.3.3. Project team: Considered positive and possible negative impacts. Audit team: 6 Variables are included in a chart, with indicators and frequency of monitoring FAR 2: A complete monitoring plan with specific socio-economic parameters (considering the parameters used to describe the baseline scenario) and methods used for data collection shall be provided at time of first verification.

FAR 2

Corrective Action Request #31 CM.4.4. Project team:



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There is no specific capacity building to increase the com-munity participation in the project implementation, which is a project on private land only. The stakeholder participation may influence the decisions of the company indirectly. Please revise the PDD Chapter CM.4.4 accordingly.

Explained that the project will focus on building technical capacity but stakeholder input will be considered in company decisions. Audit team: Reference included as requested. Periodic workshops will be conducted as part of the social action plan of the company.

Corrective Action Request #32 Please indicate in the CCBA PDD that there are no restric-tions for local employees if they fulfill the job requirements, if it is decided to comply with this optional requirement.

CM.5.2. Project team:

Added: There are no constraints to local families to fill employ-ment positions of the company if they apply with technical re-quirements.

Audit team: Reference is included as requested and clarified that there are no limitations for local families to be employed.

Corrective Action Request #33 No information is provided if workers are informed on their rights. Please describe this in the PDD and sustain it with evidence.

CM.5.3. a)

Project team: SFM-Bam has developed a document that delimits the rights and obligations of the company and workers that will be published in May. Audit team: Evidence is missing on the fact that SFMBAM developed and dis-tributed informative material for the workers to know their rights. Project team: The signed attendance sheets verifying workers’ participation in training are included in the supplementary documents and now referenced in this section. Audit team: Signed participation lists were provided to the audit team as evi-dence on workers’ rights.

Corrective Action Request #34 The different employment conditions shall be described in the PDD.

CM.5.3. b)

Project team: The two different types of employment contracts are described in the PDD. Audit team: Reference to the two different employment conditions (permanent



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and temporary) is included to the PDD.

Corrective Action Request #35 There are several high risky activities like work with herbi-cides or chain saw. Please list them in the PDD.

CM.5.4. Project team: Risky activities are described as well as procedures to lower the level of risk associated with these activities. Audit team: A list of high- and medium- risk activities is included in the PDD

Corrective Action Request #36 Sustain the choice of the qualitative methodology instead of any other quantitative one. Explain the five criteria (magni-tude, duration, accumulation, extent and fragility) in more details, how the necessary field data will be gathered and how the results will be used (G.3.5 does not list biodiver-sity).

B.1.1. Project team: Main methods to identify environmental impacts are explained and sources cited. Audit team: A list, adapted from (Leal, 1997), was included, showing the dif-ferent “methods to identify environmental impacts”. It will not be possible to trace the changes in biodiversity as a re-sult of the project implementation based on the EIA impact as-sessment described in the PDD. Appropriate methods shall be selected and described. Some key species are mentioned in sec-tion G.1.6, however some of these species are indicators of pri-mary forest and it is very unlikely that these will occur in the pro-ject area. Nonetheless whether these species will be used they will have to be included in the initial monitoring plan. Also, detail on how the necessary field data will be gathered and how the results will be used. Project team: New research was conducted to develop a comprehensive biodi-versity monitoring plan for the project. The key indicators and measurement methods are now described in this section of the PD. The results of the biodiversity monitoring will be used to mod-ify project activities in order to mitigate any unforeseen negative impacts on biodiversity in the project area. Audit team: As already indicated, the EIA impact assessment described in the PDD provides only qualitative information on impacts, not in spe-



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cies diversity, abundance and distribution. This is not considered an adequate method to estimate changes in biodiversity as a re-sult of the project activity. Furthermore the EIA clearly indicates that the project will cause negative impact on fauna as well as for natural regeneration of flora based on the application of this method.

- Clarify in the PDD, based on appropriate methods the net positive impacts on biodiversity of the project implementa-tion.

- The text in the PDD also refers to results described in chapter G.3.5 in regard to the application of this method but it is not consistent with the text in the mentioned chap-ter. Ensure consistency among the document.

- The indicators mentioned in the table are not adequate since are not specific to the project and too general. Fur-thermore ß diversity would only be adequate if a compari-son between different sites will be conducted. The dis-cussion on parameters to monitor biodiversity shall be moved to section B.3 (after updating the PDD with proper variables).

Project team 02.09.10 The EIA has been corrected to not generate any confusion about the conclusion of the survey on net balance of the impacts of the project on biodiversity and a clarification has been added in the PDD. Consistency has been verified with an update text in chapter G.3.5 Beta diversity indicator has been excluded and the monitoring will use only the other variables already checked. Audit team 15.09.10: The updated PDD is consistent with the Biodiversity Monitoring Plan and corrections were made as requested.

Corrective Action Request #37 B.1.3. Project team:



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Include the list of threatened species under national list and explain why the activities of the project will not affect them.

Added information explaining the temporary presence of species in the project area and described how the project will have posi-tive impacts on threatened species Audit team: “Almost threatened” and “vulnerable” species (according to na-tional list) are listed as they occur in the project area.

Corrective Action Request #38

Deforestation or degradation and decrease of water quality is unlikely to happen . Please modify the sec-tion to real potential negative offsite impacts, if there are any.

B.2.1. Project team: Eliminated the risk caused by migration. Audit team: Project proponents identified: “deforestation or degradation and the quality of river water affected caused by temporary workers that comes from Pucallpa and Campo Verde” as main risks to biodiversity. This section also point out chapter G.3.5 as contain-ing “specific strategies designed to minimize these risks” which are not clearly indicated in such chapter Project team: Specific measures to minimize the risks to biodiversity caused by temporary workers is now included in G.3.5 – these measures include the use of trash cans to manage waste produced by plan-tation workers, wells, sanitary latrines, and transportation of work-ers back to the city on weekends. Audit team: The provided evidence “Plan de manejo de riesgos ambientales” contains a list of activities to be implemented to mitigate potential offsite biodiversity impacts.

Corrective Action Request #39 Explain wether hunting by workers will cause offsite biodi-versity impacts.

B.2.1. Project team: Explained that hunting is unlikely to happen because the company prohibits hunting activities. Audit team: A prohibition given by the company to the workers regarding hunt-ing is mentioned. This consideration leads to the necessity to in-clude parameters for monitoring hunting activities in the project



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area.

Corrective Action Request #40 Provide information on the methodology for monitoring the parameters, why the parameters where chosen (explain why flora is not monitored) and how the data will be gath-ered.

B.3.1. a)

Project team: Explained that the project is located in a degraded ecosystem therefore it is difficult at this time to establish the relevant vari-ables for monitoring, including flora. Explained how variables will be determined over time and referenced monitoring form in Annex M. Audit team: Explanation is provided on how the parameters were chosen and the permanent regime of monitoring which is proposed. Flora was discarded as it is mentioned that the management procedures applied to the plantation will restrain the development of native flora, other than the planted.

Corrective Action Request #41 The monitoring plan should also include variables for moni-toring threats to biodiversity (i.e. fire, hunting?).

B.3.1. a)

Project team: Explained that the project is located in a degraded ecosystem therefore it is difficult at this time to establish the relevant vari-ables for monitoring, including flora. Explained how variables will be determined over time and referenced monitoring form in Annex M. Audit team: The monitoring plan should also include variables for monitoring threats to biodiversity (i.e. fire, hunting?). Project team: Regarding risk monitoring, a plan to evaluate the incidence of fires and illegal hunting based on actions that are already being devel-oped in the field has been designed. A chart with details on risk monitoring is included in this section of the PD. Audit team: The biodiversity monitoring plan provided as evidence is not con-sistent with the text included to the PDD: i.e. flora monitoring and threatened species monitoring (mentioned in the monitoring plan not in the PDD). Monitoring flora shall be consistent with the VCS PD, especially for the areas aimed to sequester carbon through

FAR 3



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assisted natural regeneration. - Ensure consistency among the documents and provide a

description of the initial monitoring plan and variables se-lected.

- The IUCN red list is not “calculated”. Use proper terms to ensure clarity.

Project team: A clarification about consistency between VCS and CCBA about flora monitoring has been done. Indicators have been changed and the ones proposed in EIA will not be used anymore and have been replaced by the proposal developed in Biodiversity Monitoring Plan. The term “calculated” about IUCN red list has been changed ap-propriately. Audit team 15.09.10: The Biodiversity monitoring for the CCBS indicated in the PDD does not consider flora as a taxa to be monitored considering the type of project (reforestation). A complete set of indicators and methods are provided in the Biodiversity Monitoring Plan. FAR 3: Parameters to monitor illegal activities (i.e. hunting) shall be included to the monitoring plan

Corrective Action Request #42 No specific activities are described to enhance water re-sources. Please describe the positive effect of the trees and forest on the water regime in comparison with the water regime of the degraded grassland (baseline) and provide references, if it is decided to comply with this optional re-quirement.

B.5.1. Project team: No documentation could be found to describe how the trees and the forest will have a positive impact on the water regime. There-fore, if required, the project will not seek this optional point. Audit team: It is mentioned In the PDD that no activities are designed as to enhance the water resources but evidence was missing. No addi-tional point is granted. However, an initial hydrologic monitoring plan was provided in order to record the impacts of the proposed project activity to water resources. The results of the implementation of the hydrologic monitoring plan shall be provided at time of verification. The analysis of the

No additional point granted



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results shall discuss the direct cause-effect of the project activity to the quality and quantity of water and sustained with evidence

Clarification Request #1 Since the land is already highly degraded, it is assumed that the biodiversity of plant species in the project area would remain stable. Some wetlands with high carbon stocks may also be affected from burning. Provide evidence for his statement.

G.2.4. Project team: There are no wetlands in the project area so deleted the refer-ences to wetlands. Audit team: No reference to wetlands is found in this chapter since these are excluded from the project boundary, thus the request can be closed.

Clarification Request #2 It remains to be demonstrated that management actions and monitoring programs are designed to generate reliable feedback.

G.7.1. Project team: A document describing the functions of the Office of Community Relations was created and added to Annex P. Audit team: Feedback from the monitoring program and its use to better im-plement management actions is not restricted to community rela-tions and reference on this process needs to be included in PDD. Project team: As it is explained in G.8.1, one of the roles of the monitoring plan is to generate on time information that can be used and is being used to adjust the field work. Periodical meetings between SFM BAM and AIDER teams are planned to discuss lessons learned. Some proofs the usefulness of this system are listed in section G.8.1. Audit team: The purpose of any monitoring plan is to provide feedback to the implementation of the project. It remains to be further clarified how the process will be conducted. Follow the guidance provided by the CCB Standards on this matter:

“Nyberg (1999). An Introductory Guide to Adaptive Management” Project team: The application of Nyberg’s principles to project monitoring are described in G.8.1



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Audit team 15.09.10: The updated PDD contains the guidance indicated by the CCBS, thus the CAR is closed.

Clarification Request #3 Provide information and evidence of the “office” to handle community relations (employees, address, how it is inte-grated in SFM, how it is financed, etc).

Project team: A document describing the functions of the Office of Community Relations was created and added to Annex P. Audit team: The community relationship policy of the company was provided as evidence.

Corrective Action Request #43 Headers of tables shall be consistent among the entire document. See “table 2”.

CL 1.1 Project team: Table headers have been amended so that they are consistent throughout the entire document. Audit team 15.09.10: Headers of tables are consistent among the entire document

Corrective Action Request #44 Include a description in section CL 1.3 in order to comply with the requirement.

CL 1.3 Project team: The following text has been added in CL 1.3: The figures in Table 3 demonstrate that the net climate impact of the project will give a positive result in terms of overall GHG bene-fits delivered. The net climate impact considers carbon stock changes within the project area as well as carbon stock changes outside the project area as a result of leakage. As explained in CL.1.2 non-CO2 gases are neglected as allowed by paragraph 35 of EB 42. Audit team 15.09.10: Included text complies with the CCBS requirement.



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Corrective Action Request #45 Provide a description in section CL 2.3 or refer to the corre-sponding table where it is noted that the requirement was complied(to allow easy reading of the document)

CL 2.3 Project team: Text was added to CL 2.3 so that the section now reads: As previously noted, the net emissions caused by leakage activi-ties are considered in the calculation of net CO2 reductions in section CL.1.1 demonstrating that the net increase in onsite car-bon stocks minus negative offsite climate impacts is positive. Audit team 15.09.10: Included text complies with the CCBS requirement.

Corrective Action Request #46 - Ensure consistency among the document. Section

G.1.4 indicates that the average monthly income is US$ 123, while section CM.1.1.b indicates a yearly income of 1453 Nuevos Soles (aprox US$500),

- The table referring Economic Activities and income levels is not correct in currency change since the values are the same in both Nuevos Soles and US$.

- Update section CM 1.1c after rectifying the values used for the estimation of community benefits.

CM.1.1.b Project team: Average monthly income has been corrected in Section G.1.4 in order to be consistent with data estimated in section CM.1.1.b, where the table has also been changed for more clarification. Audit team 15.09.10: Corrections in the updated PDD cover the request.

Corrective Action Request #47 - The variable Wildlife fauna availability is not consis-

tent with the project activities described in other sections of the document, where it is indicated that hunting will not be allowed

- Firewood availability and housing are not necessar-ily related to the project implementation, thus not adequate variables. Indicators must be specific to project implementation

B.1.3 Project team: Local robbery has been deleted as it is a variable out of control of project developer, and not linked with project activities. Firewood and wildlife fauna availability is still considered but changed to extraction, not in the sense that workers will hunt (what is forbid-den) but in the expectation that higher income and consciousness increase should reduce this kind of practices. Housing quality is another variable that should be improved as a consequence of better incomes from participating in the project activities. Audit team 15.09.10: Corrections in the updated PDD cover the request.



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Corrective Action Request #44 Additional information included to section B.1.3 leads to further request: In section G.1.7 it is indicated that 25 spe-cies are under IUCN, section B.1.3 indicates 24 and the biodiversity monitoring plan indicates 40. Clarify and ensure consistency.

B.1.3 Project team: The number and reference have been updated and corrected. Audit team 15.09.10: It was clarified that the differences were due to unidentified spe-cies with their corresponding scientific names. The corrections made in the PDD are now consistent with the biodiversity monitor-ing plan.



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Table 3: Forward Action Requests

Forward Action Request ID of FAR Explanation of the Conclusion for Denial, or Background of Forward Action Request

The inclusion of private owners in reforesta-tion practices and the reforested area on their lands will have to be checked by the time of verification.

FAR 1 In order to comply with the additional requirement of knowledge dissemination (sec-tion G.8) the project participants propose to promote reforestation outside the pro-ject boundary to 20,000 ha of private land.

A complete monitoring plan with specific socio-economic parameters (considering the parameters used to describe the baseline scenario) and methods used for data collec-tion shall be provided at time of first verifica-tion.

FAR 2 Main parameters to monitor community impact monitoring are included to the PDD. The parameters included are considered adequate for the covering the CCBS re-quirements of an initial monitoring plan. However, a complete community impact monitoring plan shall be developed.

Parameters to monitor illegal activities (i.e. hunting) shall be included to the monitoring plan

FAR 3 In order to avoid negative impacts to biodiversity due to the increase of people com-ing to provide labour to the project activities, strict rules to avoid hunting inside the project area are included; however this needs to be monitored.

Validation of the CCBS project: Reforestation with native commercial species on degraded lands for timber and car-bon purposes in Campo Verde, Ucayali – Peru

Information Reference List

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Ref. No.

Document or Type of Information

1. On-site interviews at the offices and the project site of the “Reforestation of pastures in Campo Verde with native species, Pucallpa, Peru“, during 22nd to 25th Feb-ruary 2009. Validation team on site:

Hubertus Schmidtke Auditor, TÜV SÜD Industrie Service GmbH Juan Chang Auditor, TÜV SÜD Industrie Service GmbH

Interviewed persons: 1. Marioldi Sánchez Forest Specialist of AIDER

2. Jorge Torres Forest Specialist of AIDER

3. Walter Nalvarte Advisor in forestry related issues for AIDER

4. Percy Recavarren GIS specialist of AIDER

5. Jorge Cantuarias General Manager of SFM BAM

2. CCBS – PD version 3 dated 02 September 2010.

3. SFM-BAM 2008, Management Plan of the Campo Verde Plantation

4. SFM-BAM, Fire Prevention Plan of the Campo Verde Plantation

5. AIDER, GOREU, FONAM 2005, Biophysical diagnosis of the Campo Verde Area.

6. SCG, 2007. “Evaluación de Riesgos Sociales del Proyecto de Manejo Forestal en Areas Degradadas con Fines de Certificación para la Venta a Futuro del Vuelo Forestal” (Social Risk Analysis of the Project)

7. Shareholder Agreement between SFM Ltd and SFM-BAM dated 31 July 2007

8. Land Title and registry 1: Predio “Marianita:08.03.85

9. Land Title and registry 2: Campo Verde 14.09.92

10. Land Title and registry 3: Predio “Selva Maestra” 14.11.2000

11. Monitoring Plan of the Social Impact of the project

12. Lam et al, 2009. Standard Operations Procedures for the Campo Verde Forestry Plantation. AIDER, Lima – Peru 11pp

13. Standard Operation Procedures for monitoring the permanent plots of the Campo Verde project.

14. Aguila, E; M. Sanchez, M. 2009. Standard Operations Procedures for the Monitoring Plan Implementation of the Campo Verde project. AIDER, Lima – Peru 42pp.

15. Aguila, E; M, Sanchez, M. 2009. Standard Operation Procedures for QC/QA of the management of the information of the Campo Verde project. AIDER, Lima –



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Peru 6pp.

16. Standard Operation Procedures for controlled burns for site preparation

17. Walker, S. et al. 2009. Standard Operation Procedures for the Campo Verde project. Winrock International, 22pp.

18. GIS files of the Campo Verde Project in WGS 84.

19. Excel spreadsheet of the GPS coordinates of the project boundary

20. SFM-BAM. Report on Social Consultation to the Communities close to the project area

21. AIDER, 2008. Soil Carbon Analysis of the Campo Verde Project area.

22. AIDER, 2008. Consolidated Baseline Assessment Report of the Campo Verde Project.

23. Huerta, P. 2008. Satellite Image Analysis and Land Cover Map of the Campo Verde Project area. SFM-BAM. Lima, Peru. 13pp.

24. La Torre, L. 2007. Cattle inventory of the Campo Verde project area. SFM-BAM. Lima, Peru. 5pp.

25. List of endangered species of Peru.(Law number D.S. Nº 034-2004-AG)

26. Chave et al. 2005 Tree allometry and improved estimation of carbon stocks and balance in tropical forests. Ecosystem Ecology. Oecologia (2005) 145: 87–99 DOI 10.1007/s00442-005-0100-x

27. Cole, T.; Ewel, J. 2006. Allometric equations for four valuable tropical tree species. Forest Ecology and Management 229 (2006) 351–360

28. WWF Peru. 2003. Analisis de cambios de paisaje: Tournavista-Campo Verde y su area de influencia. Pérdida y Fragmentación de Bosques : (1963 – 2000). (Landscape change analysis in Tournavista – Campo Verde from 1963 to 2000)

29. Dance, J., 2006. Estrategia Nacional de Desarrollo Forestal en el Peru. ENDF, Instituto Nacional de Recursos Naturales, Ministerio de Agricultura de Peru, 2005. Plan Nacional de Reforestacion. (National Forestry Strategy)

30. Elgegren, J. 2005. Power point presentation of the deforestation in Peru. “La deforestacion en el Peru”.

31. Palm, C. A., J. C. Alegre, L. Arevalo, P. K. Mutuo, A. R. Mosier, and R. Coe, Nitrous oxide and methane fluxes in six different land use systems in the Peruvian Amazon, Global Biogeochem. Cycles, 16(4), 1073, doi:10.1029/2001GB001855, 2002.

32. Programa de Estadisticas y Estudios Laborales, Ministerio de Trabajo y Promocion del Empleo del Peru, 2007. Encuesta de Hogares Especializada en Niveles de Empleo 2007. (Employment Levels in Peru) http://www.mintra.gob.pe/peel/publicaciones/informes/PEEL_Empleo_LIMA_METROPOLITANA_2007.pdf

33. INRENA 2005. National Reforestation Plan. Ministry of Agriculture. (http://www.inrena.gob.pe/iffs/pnr/proyecto_pnr-v151205v1.pdf), accessed on 4 June 2009

34. Pennington, T.D. 1998. Growth and biomass production of Inga species. In The genus Inga Utilization. Chapter 2: 6-15. Eds: Pennington, T.D. and Fernanades, E.C.M

35. Toledo, E.; Rincon, C. 1999. Utilización Industrial de Nuevas especies Forestales en el Perú. Organización Internacional de las Maderas Tropicales (OIMT), Cámara Nacional Foresta, Instituto Nacional de Recursos Naturales (INRENA). Lima. 240 p

36. Acevedo, M.; Kikata, Y. 1994. Atlas de Maderas del Perú. Universidad Nacional Agraria La Molina, Universidad de Nagoya Japón. Lima. 202 p.

37. Environmental Impact Assessment of the Campo Verde Project, 2008



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38. Excel calculation spreadsheets of the Campo Verde Project

39. Internal Procedures of SFM-BAM on Community Relationships

40. Manta, M, 2006. Global Forest Resources Assessment 2005 – Report on Fires in the South American Region. FAO. Rome, Italy 42pp.

41. DS 002 2009 AG Aprueban Reglamento DL 1090 Ley Forestal y de Fauna Silvestre; Ley Forestal D.L. Nº 1090; LEY 29317.modifica e incorpora arts. a la ley Forestal y de fauna Silvestre; tupa2008 INRENA.pdf (Forestry Law of Peru)

42. Files of the interviews with local people

43. Carrillo, J. 1997. Manejo de un Rodeo de Cría

44. Sourcebook for Land Use, Land-Use Change and Forestry Projects. 2005. Timothy Pearson, Sarah Walker and Sandra Brown. BiocarbonFund and Winrock

45. Brochures and Video of the Project developed by SFM

46. Report of the health Centre of the diseases to the workers of Campo Verde

47. Brochures of the Project used for the CarbonExpo Fair in 2004

48. Field forms of the audit team during the onsite visit to Campo Verde

49. INRENA 2001-2007 Statistics of the Forestry Sector in Peru. Ministry of Agriculture – Peru

50. Signed Statement of Project Proponents on Double Counting

51. The platform for environmental markets www.tz1market.com accessed 20th June 2009

52. UNFCCC Tool for the demonstration and assessment of additionality in A/R CDM project activities. Vers 2

53. Foreign investment in Peru by sector: (http://www.proinversion.gob.pe/0/0/modulos/JER/PlantillaSectorHijo.aspx?ARE=0&PFL=0&JER=3365), accessed on 4 June 2009

54. Legislation regarding promotion of private investment in Peru (http://faolex.fao.org/docs/pdf/per65942.pdf), accessed on 4 June 2009

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62. Fire Information for Resource Management System, University of Maryland, 2009. Web Fire Mapper: South America. http://maps.geog.umd.edu/firms/

63. SINADECI, 2005. Compendio Estadístico del SINADECI 2003 y 2004; SINADECI, 2008. Compendio Estadístico de Prevención y Atención de Desastres 2005, 2006 y 2007. (Statistics on disasters in Peru)

64. National Drought Mitigation Center, University of Nebraska – Lincoln, 2009. Understanding ENSO and Forecasting Drought. http://drought.unl.edu/whatis/elnino.htm

65. Peruvian Geophysical Institute, 2009. Marco Geologico y Geodinamico; Peruvian Geophysical Institute, 1998. Areas de peligrosidad por caidas de tefras volcan ubinas; Centro Nacional de Datos Geofisicos de Peru, 2009. Datos de sismologia.

66. Excel spreadsheet of the cash flow of the Campo Verde Project “Carbon sequestration model – Oct 2008.xls” dated 10/11/2008

67. BAM, 2010. Biodiversity Monitoring Plan.

68. TÜV SUD, 2009. VCS Validation Report available in http://www.netinform.de/KE/Wegweiser/Guide2.aspx?ID=4954&Ebene1_ID=49&Ebene2_ID=1533&mode=4

69. BAM, 2010. Hydrologic Monitoring Plan of the Campo Verde plantation.