Roundtable on Validation and Verification Issues in LULUCF Projects The World Bank, Washington DC August 24-25, 2009 Issues in Validation of A/R Projects

BioCF Experience in Validation of A/R BioCF Experience with validation of A/R based on: Two registered A/R projects Four projects submitted for registration Five projects currently in validation Five projects preparing for validation Communication with DNAs, DOEs and project entities Participation in validation site visits of projects Contribution of inputs to VVM and to other regulatory aspects of A/R

Overview Project boundary Land eligibility Carbon rights Additionality Leakage Environmental and social impacts Role of DNA VVM and Completeness Check Overall experience

Project Boundary Difficulties in demonstrating control over 2/3 rd area in projects with small land holders Delay in project start date due to difficulties in identifying land parcels until the year of planting High transaction costs in field surveys to ascertain control of land parcels Outcome: Small size of project with the burden of large transaction costs in field surveys and boundary delineation

Land eligibility Satellite data is expensive to acquire and interpret Satellite data is of limited use for assessing 1990 eligibility of small land parcels Costs increase with number of land parcels for a similar project size Limited technical skills in interpreting satellite data in most developing country contexts Outcome: Significant transaction costs to demonstrate land eligibility as per 1990 rule

Land eligibility (2) Lands to be eligible for A/R activity to be below the thresholds of forest definition (crown cover, height, area) – as per Annex 18,EB 35 Changes in carbon stocks of existing vegetation to be done at project, parcel or stratum level – as per Annex 16, EB46 Outcome: Inconsistency in EB guidance contribute to delay in validation as some DOEs interpret land eligibility at the level of minimum area, e.g., 0.05 ha Request for clarification submitted to EB and AR WG and guidance is anticipated in September/October meetings Request for clarification submitted to EB and AR WG and guidance is anticipated in September/October meetings

Carbon Rights Land tenure and title is the basis for carbon rights In some countries, customary tenure is recognized, but title is not provided in the name of individuals/ communities Outcome: The project validation is likely to get delayed because of lack of clarity on land title and resulting carbon rights AR WG should provide guidance on carbon rights taking into account the land tenure systems of developing countries

Additionality Documentary evidence on barriers is difficult to procure as many barriers are observable on the ground but official agencies can not issue documentary support as they do not have recorded information on barriers Outcome: Delay in validation until documentary evidence is satisfactory to DOE

Leakage Census data on livestock and other documentary evidence to assess grazing leakage is not available Tool on grazing assessment is cumbersome and data to calculate the grazing leakage using the tool is difficult to obtain Assessment of fuelwood use through surveys is costly and time consuming Outcome: High transaction costs in organizing surveys to collect data for leakage assessment

Role of DNA Limited familiarity of DNAs with AR-CDM Varying DNA policies on LoA Issuance Delays in communication of forest definition 39 countries communicated forest definitions to UNFCCC 20 out of 39 countries that communicated forest definition have BioCF projects For small scale projects - DNA notifies definition of low income community. Misinterpretation with regard to participation of low income communities Outcome: Delays in procuring DNA support to projects

Environmental and Social Impacts Evidence on degraded and degrading status of lands not often available Evidence on compliance of national EIA rules and regulations Proof on the participation of low income communities in small scale projects Proof of stakeholder consultations Outcome: Information on environmental and social impact requires detailed information

VVM and Completeness Check Documentation requirements of validation are high Although VVM streamlined validation procedure, time required for collecting the required information and for preparing relevant documentation is high Request for review for minor issues could be avoided by seeking relevant clarification and information from DOE/PP Project entities not aware of recent completeness check guidance prior to registration (Annex 60, EB 48)

Overall Experience Validation requires significant commitment of project participant resources Average time for completing validation is months DOE work load and accreditation status influence the time taken to complete validation Request for review for minor issues further delays the registration

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