1. Case Study2: Reforestation Project Using Native Species Around AES-Tiete Reservoirs ARNM0002 Comments on Baseline Methodology Fourth Regional Workshop and Training on “Capacity Development for the Clean Development Mechanism” Asian Institute of Technology, Bangkok, 4-6 April 2005 Presented by Heng Chan Thoeun, Team Leader for Capacity Building, CD4CDM Project Ministry of Environment, Cambodia

2. 2 Outline of Presentation 1. Modalities and Procedures for A/R – Establishment of Baseline 2. Modalities and Procedures for A/R – Choice of Carbon Pools 3. Modalities and Procedures for A/R – Choice of Baseline Methodology 4. Definition of the Project Boundary Related to the A/R Methodology 5. Potential Leakage due to A/R Project Activity 6. General Comments 7. Questions for Discussions

3. 3 1. Modalities and Procedures for A/R – Establishment of Baseline (CP/9) Paragraph 20: The baseline net greenhouse gas removals by sinks for a proposed A/R project shall be established: in a transparent and conservative manner taking into account relevant national/sectoral policies and circumstances, such as historical land uses, practices and economic trends.

4. 4 Modalities and Procedures for A/R – Establishment of Baseline (NM0002) The PDD/NMB does not take into consideration existing national circumstances. Brazilian environmental legislation requires a 100 m vegetation strip along reservoirs (legal duty). Reforestation of hydro-electricity dams is the entrepreneur’s duty: the project is not additional.

5. 5 2. Modalities and Procedures for A/R – Choice of Carbon Pools (CP/9) Paragraph 21: projects participants may choose not to account for one or more carbon pools and/or emissions of the greenhouse gases measured in CO 2 equivalents, while avoiding double counting. This is subject to the provision of transparent and verifiable information that the choice will not increase the expected net anthropogenic greenhouse gas removals by sinks.

6. 6 Modalities and Procedures for A/R – Choice of Carbon Pools (NM0002) The terminology for carbon pools used by the PDD differs from the Marrakech Accords terminology. The PDD omits soil carbon, but does not provide transparent and verifiable information that this will not lead to greater carbon credits. It is not clear whether the baseline and the project scenarios use the same carbon pools.

7. 7 3. Modalities and Procedures for A/R – Choice of Baseline Methodology (CP/9) Paragraph 22: select the most appropriate approach and justify the appropriateness of the choice: (a) existing or historical changes in carbon pools in the project boundary (b) changes in carbon pools from a land use that is an economically attractive course of action (c) changes in carbon stocks from the most likely land use at the time the project starts.

8. 8 Modalities and Procedures for A/R – Choice of Baseline Methodology (NM0002) The PDD chooses approach (c) “changes in carbon stocks in the pools within the project boundary from the most likely land use at the time the project starts”. The PDD does not explain why approach (c) is chosen and why the other approaches are not suitable. The PDD does not explain how baseline alternatives have been analysed and how the most likely baseline has been selected.

9. 9 Modalities and Procedures for A/R – Choice of Baseline Methodology (NM0002) The PDD document does not?? explain how the baseline scenario has been chosen. The baseline methodology does not clearly explain how future carbon uptakes will be estimated.

10. 10 4. Definition of the Project Boundary related to the A/R Methodology (CP/9) The project boundary geographically delineates the afforestation or reforestation project activity under the control of the project participants. The project activity may contain more than one discrete area of land.

11. 11 Definition of the Project Boundary related to the A/R Methodology (NM0002) The project boundary is not clearly defined. It is only described as strips of land surrounding four different reservoirs. The legal requirement for a 100 m vegetation strip along the reservoirs is not discussed. It is not clear whether LANDSAT imagery have adequate spatial resolution to determine land eligibility. Landsat Thematic Mapper (28.5m x 28.5m) data used as part of the AR baseline methodology, proposed NMB may not applicable to the project boundary definition.

12. 12 5. Potential Leakage due to A/R Project Activity (CP/9) Leakage is the increase in greenhouse gas emissions by sources which occurs outside the boundary of an afforestation or reforestation project activity under the CDM which is measurable and attributable to the afforestation or reforestation project activity.

13. 13 Potential Leakage due to A/R Project Activity (NM0002) Leakage is not discussed at all in the PDD: “leakage was not identified”. Since the project boundary is not clearly defined, it is impossible to substantiate this claim.

14. 14 6. General Comments PDD/NMB have numerous typographical and grammatical errors, and are generally poorly written. PDD/NMB are not clear. PDD/NMB provide irrelevant information with regards to methodology. PDD/NMB do not provide enough information on proposed new methodology. PDD/NMB do not quote sufficiently from the research literature (e.g satellite imagery interpretation or carbon pools measurements) PDD/NMB do not follow closely CoP modalities.

15. 15 6. General Comments (con’t.) Risk of fire and logging of protected forests are not discussed in the PDD/NMB. PDD/NMB equations do not good guidance practises. Confusion in numbers between comma (,) and column (.)

16. 16 7. Questions for Discussions What can be done when there is limited forest inventory data available? How can land eligibility be demonstrated? Can interviews of local stakeholders be used? In which circumstances is the use of Landsat imagery for 1989 data acceptable? Submetre resolution satellite imagery is not always available for cut-off date, and usually much more costly. However is Landsat spatial resolution adequate for small-scale projects? Is it acceptable to use the EB additionality tool for A/R projects?