Biomass Feedstock Accounting v1.2

1.0

Introduction

This module establishes requirements associated with the use of biomass feedstocks as part of carbon dioxide removal (CDR) projects. This includes setting out eligibility criteria for biomass feedstocks in relation to market leakage, counterfactual storage and dedicated energy feedstock considerations. This module also provides requirements for quantification of counterfactual storage to determine eligible biomass ( $CO_{2}e_{Counterfactual}$ ), and market leakage to determine emissions associated with replacement of biomass ( $CO_{2}e_{Leakage}$ ).

This module is applicable to the following biomass feedstocks:

Agricultural residue
Forestry thinnings or other byproducts of forestry operation
Industrial biomass residues

Every project must consider specific alternative uses of biomass that would have occurred in the absence of the project. The baseline scenario must be considered relative to each feedstock used if the project utilizes multiple feedstock types, in line with Section 2.5.2. of the Isometric Standard.

Requirements for biomass feedstock eligibility are provided in Section 2 and quantification requirements are included in Section 3.

1.1

Future Versions

This module was developed based on the current state of the art and publicly available science regarding the land use changes that result from payments for biomass feedstock. This module is based in part on literature and models like GREET and CCLUB for life cycle analysis developed at Argonne National Laboratory, and Global Trade Analysis Project (GTAP) for general equilibrium economic impacts developed at Purdue University. More specific modeling for the use case of biomass residue as a feedstock for CDR will be done in the future.

The current approach outlined in this module provides additional sustainable sourcing criteria that aim to minimize the risk of potential land use effects, whilst accounting for limited data availability when only a relatively small volume of feedstock is sourced.

To extend the functionality of this module, future work will be undertaken to apply the GTAP model to scenarios involving payments made for biomass residues for use in CDR and this module will be updated accordingly.

This module will be reviewed on an annual cadence in line with the Isometric Standard.

1.2

Biomass Feedstock Considerations

The Project Proponent must consider the following factors in assessing how a particular biomass feedstock affects their net carbon dioxide equivalent (CO₂e) removal. These considerations may vary based on the impacts of feedstock use in a given project.

These impacts are defined below in Table 1:

Table 1

Impact	Definition
Market Leakage	By providing payment for a feedstock, a supplier may induce market changes that shifts feedstock producer behavior in a way that results in increased GHG emissions. Market leakage may lead to a change in feedstock producer behaviour that results in land use change. In this version of the module, the land use change impact is assessed to be 0 when a feedstock is eligible for use in Section 2. A second form of market leakage, Replacement Emissions, occurs from any additional activities necessary to replace any environmental or marketable services the feedstock would have otherwise provided need to be accounted for (e.g. nutrient provision). Any emissions associated with the production and use of the replacement materials must be accounted for in the Leakage assessment. For example, if manure that was previously spread on land as a fertilizer is diverted for use as a feedstock, a replacement fertilization method must be evaluated. Quantification requirements are provided in Section 3.2.
Counterfactual Storage	The counterfactual storage considers the CO₂ stored in the biomass feedstock that would have remained durably stored in the biomass in the absence of the project. This is known as ineligable biomass as the CO₂ would have remained stored in the biomass in the absence of the CDR project and is therefore not eligible to count towards Crediting. Quantification requirements are provided in Section 2.2 and Section 3.1.

Impact

Definition

Market Leakage

By providing payment for a feedstock, a supplier may induce market changes that shifts feedstock producer behavior in a way that results in increased GHG emissions.

Market leakage may lead to a change in feedstock producer behaviour that results in land use change. In this version of the module, the land use change impact is assessed to be 0 when a feedstock is eligible for use in Section 2.

A second form of market leakage, Replacement Emissions, occurs from any additional activities necessary to replace any environmental or marketable services the feedstock would have otherwise provided need to be accounted for (e.g. nutrient provision). Any emissions associated with the production and use of the replacement materials must be accounted for in the Leakage assessment. For example, if manure that was previously spread on land as a fertilizer is diverted for use as a feedstock, a replacement fertilization method must be evaluated. Quantification requirements are provided in Section 3.2.

Counterfactual Storage

The counterfactual storage considers the CO₂ stored in the biomass feedstock that would have remained durably stored in the biomass in the absence of the project. This is known as ineligable biomass as the CO₂ would have remained stored in the biomass in the absence of the CDR project and is therefore not eligible to count towards Crediting. Quantification requirements are provided in Section 2.2 and Section 3.1.

2.0

Biomass Feedstock Eligibility

Feedstock eligibility is determined by its potential market leakage impact (see Section 2.1), its counterfactual CO₂ storage scenario (see Section 2.2) and whether it’s a purpose-grown feedstock (see Section 2.3). To be eligible under Protocols applicable to this module, a given feedstock must meet the requirements in all three Sections. Eligibility requires satisfying an acceptable combination (as outlined below) of EC1-EC12, satisfying one of EC13-EC14, and, if applicable, satisfying EC15.

2.1

Eligibility Criteria for Biomass Feedstocks with Potential Market Leakage Impacts

Creating a market for biomass feedstocks may generate new revenue in the source sector that alters producer behaviour in ways that result in additional GHG emissions. For example, increased profit may lead to changes in forest treatment or agronomic management activity to increase biomass yield or changes to livestock management to consolidate waste.

The framework outlined in this module sets outsourcing criteria that qualify the feedstock as eligible for use in a way that minimizes the emissions impact of possible market leakage effects. Market leakage can be classified into two types:

Indirect market leakage: when biomass feedstock procurement affects the market price of the feedstock and leads to land use change or other market shifts that affect GHG emissions.
Direct market leakage: when payments to the biomass feedstock supplier directly affect that supplier's behavior in a manner that increases GHG emissions.

Project Proponents must demonstrate that both indirect and direct market leakage have been minimized or appropriately accounted for. Demonstrating any one of EC1 through EC4 satisfies both requirements in full. Demonstrating any one of EC5-EC7 satisfies the indirect market criteria and demonstrating any one of EC8-E12 satisfies the direct market criteria.

Table 2

Eligibility Criteria satisfying direct and indirect market leakage requirements		Documentation required
EC1	Project Proponent does not pay for the feedstock used	Feedstock purchase records between Project Proponent and feedstock supplier demonstrating price paid, amount, buyer, seller and date.
EC2	Project Proponent is paid a “tipping fee” to remove the feedstock.	Feedstock removal records between Project Proponent and feedstock supplier demonstrating price paid, amount, buyer, seller, and date.
EC3	Project Proponent paid for their feedstock but can show that the amount they paid is lower than the total recovery and replacement cost of new activities related to the new use of this feedstock. This cost can be composed of, but not limited to: Harvesting - a feedstock owner engages in additional harvesting activities Collection - a feedstock owner must put in additional time and labor to collect any harvested or existing materials Transport - a feedstock owner moves, or pays for the movement of, any collected biomass to a new area due to the project needs Replacement - a feedstock owner incurs some cost when they attempt to replace the use a feedstock that was previously being used for	Feedstock removal records between the Project Proponent and feedstock supplier demonstrating price paid, amount, buyer, seller, and date. Plus records of the recovery and replacement of the feedstock, including: Costs for alternative use, including, but not limited to: Harvesting costs of biomass, such as removal of residual corn stover from fields or chipping and shredding of forest residues. Transportation costs to end user or disposal site. Spreading costs or similar end of delivery offloading or application costs (i.e. manure spreading or stover burning and char spreading). Above costs may be demonstrated by provision of invoices, bills of lading, purchase records, or other similar documentation provided by the feedstock supplier or other end users. Alternatively, costs may be referenced from scientific literature or data specific to the locality or region where the feedstock is produced (i.e. average market prices for biomass shipping in a region). The literature used will be subject of review by a competent Validation & Verification Body to ensure that best available scientific information with an established body of scientific research is used. Calculations of total recovery and replacement of feedstock, linked to the above source data, and compared to the price paid to the feedstock supplier or 3rd party intermediary.
EC4	Project Proponent paid for their feedstock, but this was paid to a 3rd party and not the entity responsible for biomass growth or harvesting, if this 3rd party also didn’t pay the producing/harvesting entity above total recovery and replacement cost.	A signed statement from the 3rd party and/or the feedstock supplier indicating that the 3rd party is not providing the supplier additional payment for the feedstock.

Any one of the criteria in Table 3 is sufficient to demonstrate minimal indirect market leakage:

Table 3

Eligibility Criteria satisfying indirect market leakage requirement		Documentation required
EC5	Feedstock is a forest residue¹.	The Project Proponent must demonstrate that the feedstock is an non-marketable wood product. For example, beetle kill, sticks and twigs, mill residues, etc.
EC6	Feedstock is an agricultural crop residue or an animal waste.	The Project Proponent must demonstrate that the feedstock is an agricultural residue or waste whose production is ancillary to the production of the primary marketable product.
EC7	Feedstock is a biogenic product that is a non-marketable waste product created within an industrial production process turning forest biomass into some other marketable good.	The Project Proponent must demonstrate that the feedstock is a waste product that would have no marketable use absent the Project. This can be evidenced by demonstrating that the material is currently being disposed of or, for new facilities, that similar materials at other sites do not market the feedstock material

Any one of the criteria in the following Table 4 is sufficient to demonstrate minimal direct market leakage:

Table 4

Eligibility Criteria satisfying direct market leakage requirement		Documentation required
EC8	Applicable to forest residues or downstream wood wastes only: Biomass originates from a regulated forest management project.	The Project can provide a reference that the feedstock came from either: a NEPA, or state level equivalent², planned project or a government regulated forest management project or a state or federal funded or managed forest management activity In each case, the project with the associated harvest plan will be subject to competent Verification & Validation Body to ensure adherence to the criteria.
EC9	Applicable to forest residues or downstream wood wastes only: Forest biomass results from forest management activities³ in historically stable or increasing forest carbon stocks.	The following evidence is required to meet this criteria: Biomass shall be certified under one of the acceptable certification schemes listed in Appendix 3 or be obtained through a NEPA project and/or other forest management and chain-of-custody certification programs with demonstrably equivalent forest management and chain-of-custody oversight and principles.⁴ Additionally at least one of the following types of evidence is required to meet this criteria: Independent, third-party assessment of forest carbon stocks in the Sourcing Area which is based on public inventory data. This assessment must demonstrate that the forest carbon stock has not decreased during the last 5 years for which data are available, compared to the average forest carbon stock in the previous 5-year period. Data for live, aboveground biomass (standing stocking level) must be included. Project Proponents may elect to include deadwood pools, if reliable data are available.⁵ Land Use, Land-Use Change, and Forestry (LULUCF) emissions from the forestry sector in the country, or state/province, of harvest do not exceed removals. This requirement is met if, over the last 10 years, the average net emissions from the forestry sector are zero or negative, as reported in national greenhouse gas emissions to the UN Convention on Climate Change. In countries of harvest greater than five million square kilometers, an additional evidence is required that forest carbon stocks in the Sourcing Area are not decreasing over the same period.⁶
EC10	Applicable to forest residues or downstream wood wastes only: Forest biomass resulting from forest management activities where Sourcing Area carbon stocks may be decreasing, but the forest management activity had to be carried out regardless.	Biomass shall be certified under FSC, SFI, PEFC-endorsed forest management schemes and/or other forest management and chain-of-custody certification programs with demonstrably equivalent forest management and chain-of-custody oversight and principles.⁷ Documentation must be provided to demonstrate the specific nature of the disturbance, the legislative requirement, such as to promote healthy tree growth, or the ecological necessity of the wood removal⁸
EC11	Applicable to agricultural crop residues only: The purchase contract signed between a Project Proponent and a feedstock supplier commits the Project Proponent to not purchase feedstock from a given acreage in consecutive years. Alternatively, feedstock may be sourced from the same acreage in sequential years if evidence is presented that the acreage has been monocropped (no crop rotation) for at least 5 years.	Feedstock purchase contract between Project Proponent and feedstock supplier.
EC12	Applicable to animal waste feedstocks only: Project Proponent paid a positive amount for their feedstock, but are able to demonstrate there is a surplus of feedstock available in the region and additionally are able to: Obtain data from the 2 years prior to the procurement date on the annual output/utilization factor of the biomass source. To ensure payments do not incentivize additional feedstock production, the Project Proponent must demonstrate that the total annual amount of feedstock the Project Proponent contracts for the current year for will be at or below the levels of total output 2 years earlier. By linking eligibility to past production, we ensure that increasing production for the purposes of receiving additional payments would incur losses for at least 2 years. Given the low margins in agricultural production and current costs of capital, this delay period likely makes these decisions economically infeasible.	Feedstock purchase contract between Project Proponent and feedstock supplier. Historical data on the output/utilization factor of the biomass source. Regional data on Sustainable Use Rate.

Thus, to establish eligibility under market leakage criteria, the Project Proponent must demonstrate either:

The feedstock meets at least one of EC1 through EC4; or
The feedstock meets at least one of EC5 through EC7 and the feedstock meets at least one of EC8 through EC12.

2.1.1

Recommended sourcing principles

It is recommended that where feasible a Project Proponent collects farm-specific information as part of their sustainable sourcing practices. However this information is not currently required for the determination of eligibility.

Historical land use: purchase feedstock only from acreages that have been used to grow corn either continuously or in rotation with another crop for the past 10 years.
Tillage practices: for crop residues sourced from row crop agriculture, collect evidence from the feedstock supplier on the intensity of cultivation practices on the acreage from which the corn stover is sourced. Project Proponents are recommended to maintain records on whether fields engage in conventional tillage, reduced tillage, or no tillage.
Sustainable feedstock harvest: collect evidence from the feedstock supplier that the rate of biomass harvest on the acreage from which the feedstock is sourced does not exceed the sustainable rate of removal.

2.2

Counterfactual Storage Eligibility

Biomass stores CO₂ as organic carbon, C. A quantity of C can be converted to units of CO₂ using the atomic mass of both elements. In this section C in biomass is described in terms of CO₂, presented as CO₂e in equations for consistency.

When C decomposes it can release CO₂, but also potentially methane (CH₄) under anaerobic conditions. Non-CO₂ GHGs can be converted to CO₂e values based on their global warming potential (GWP) in order to measure how much energy the emissions of 1 tonne of a gas will absorb over a given period of time, relative to the emissions of 1 ton of CO₂. The GWP for CH₄ is 27.9 for GWP100. In this section CH₄ is presented in terms of CO₂e.

Eligibility criteria is set out for biomass feedstocks in Table 5 which determines how much of the CO₂e stored as part of the Removal activity is eligible to count towards Crediting. This eligibility criteria is in place to ensure that the CO₂ stored would not have remained stored as CO₂ in the absence of the project. This ensures that Crediting is conservative and the project passes environmental additionality. The eligibility criteria includes consideration of the counterfactual fate of the biomass. If the biomass is anticipated to have decomposed in the absence of the project, the potential for CH₄ emissions are also considered. Methane has a short term global warming impact with a high GWP and as such the benefits of avoiding methane emissions are included within the eligibility criteria.

Table 5

Eligibility Criteria		Documentation required
EC13	Biomass where the most likely counterfactual fate would release all stored biogenic C sooner than 15 years from when a project uses it, is eligible under this Module. If the counterfactual fate of the biomass includes the stored biogenic C being emitted as GHGs with a GWP100>1, the total biomass eligible is equal to the minimum of: (1) the CO₂e (evaluated at GWP100) of counterfactually released GHGs emitted within 15 years (2) the total stored CO₂ in the biomass minus the CO₂ in biomass that would not have counterfactually been released within 50 years. Landfilled wood is not an eligible feedstock, unless the Project Proponent can demonstrate the counterfactual fate would release all stored biogenic carbon within 15 years.	To assess the counterfactual fate of the biomass at least one of the following pieces of evidence should be provided by the Project Proponent: An affidavit or record of a contractual clause in the purchase records confirming that the counterfactual fate of the biomass would result in release of CO₂e within the threshold Historical evidence of the counterfactual fate of the biomass over the last 5 years provided by the feedstock supplier A qualitative assessment that the expected fate of the biomass would have a durability lower than the threshold given the most economically viable option in a given Sourcing Area. Project Proponents who cannot demonstrate that all of the stored C would have been counterfactually released within 15 years, must make an assessment of the release of CO₂e (evaluated at GWP 100) in the counterfactual scenario at 15 years: Provide an assessment of the estimated amount of stored biogenic C released and conservatively estimated quantities of GHGs that would have been emitted. These estimates can be used to calculate the CO₂e (evaluated at GWP 100) of all GHGs counterfactually emitted within 15 years; Provide an assessment of the estimated amount of stored biogenic C that would have remained stored after 50 years.
EC14	Feedstocks that are sourced through government managed or funded wildfire mitigation or restoration activities will be assigned a counterfactual storage value of 0.	Project Proponent should provide a government source demonstrating that the funding or management of the biomass collection or harvesting was required, funded, or managed by a federal or state government body and was done for the purpose of wildfire mitigation or post-wildfire ecosystem restoration.

If all of the biogenic C would have been released from storage within 15 years, $CO_{2}e_{Counterfactual}$ = 0.

The portion of the stored biogenic C that is eligible under this framework is the lesser of two values that must be demonstrated by the Project Proponent: the total CO₂e (evaluated at GWP 100) emitted by the feedstock within 15 years; or the total CO₂ content of the biomass feedstock minus CO₂ in biomass that would not have counterfactually been released within 50 years (see Equation 1).

 $CO_2e_{Counterfactual,\ n} = CO_2e_{Feedstock} - CO_2e_{EmissionsCounterfactual}$

(Equation 1)

 $CO_2e_{EmissionsCounterfactual} = min(CO_2e_{StorageCounterfactualEmissions15}, (1-δ_{50})\\ \times CO_2e_{Feedstock})$

(Equation 2)

Where:

$CO_2e_{Counterfactual,\ n}$ = the total counterfactual CO₂ that is ineligible for Crediting as laid out in EC13, for batch n, in tonnes of CO₂e
$CO_2e_{Feedstock}$ = the CO₂ content of the biomass feedstock used, calculated by converting C into CO₂ units based on C content, for batch n, in tonnes CO₂e
$CO_2e_{EmissionsCounterfactual}$ = the lesser of the total CO₂e emitted by the feedstock within 15 years; or the total CO₂ content of the biomass feedstock minus CO₂ in biomass that would not have counterfactually been released within 50 years, for batch n, in tonnes of CO₂e
$CO_2e_{StorageCounterfactualEmissions15}$ = the CO₂e counterfactually released from the biomass over 15 years, for batch n, in tonnes of CO₂e
$δ_{50}$ = the share of biogenic C that would not have been counterfactually released within 50 years, for batch n.

This discount can arise through two different mechanisms:

Biomass that wouldn’t have released stored C until after 15 years;
Biomass that would have released stored C before the 15 years may still be partially ineligible if a portion of the biomass would have led to durable storage, such as corn stover decay leading to increases in soil organic carbon. This effect may be nonlinear and the Project Proponent may provide evidence that at the removal rates they have sourced feedstock from this effect is negligible.

2.3

Dedicated Energy Feedstock Eligibility

The intent of this criterion is to avoid situations in which the biomass could have been used for energy production instead of for CDR.

The feedstock must meet the eligibility criteria in Table 6 in order to be eligible for use under this Module:

Table 6

Eligibility Criteria		Documentation required
EC15	Applicable to non-forestry feedstocks: The biomass feedstock was not grown for the purposes of energy production and does not have a likely counterfactual energy production use.	Project Proponent must conduct an analysis of the regional use for the type of biomass they are sourcing. This analysis must show that biomass meets one of the following conditions: The Project Proponent must demonstrate that less than 50% of the total harvested biomass, by both volume and value, is allocated for energy production in the counterfactual usage of the biomass.⁹ This analysis must either demonstrate that the feedstock is not sourced from with 50 kilometers of an ethanol plant that relies on exclusively cellulosic feedstocks or, alternatively, the Project Proponent may provide farm-level documentation that the procured feedstock supplier was not previously supplying the relevant biomass to any cellulosic ethanol plant.¹⁰ The biomass has already fulfilled its energy generation uses (e.g. post anaerobic digestion manure).

3.0

Biomass Feedstock Calculations

Specific emission calculations associated with a project’s counterfactual storage scenario and market leakage, as required in Protocols applicable to this module, are determined as described below.

3.1

Calculation of CO|2|e|Counterfactual, n

Calculation of CO₂e_{Counterfactual, n}

For a specific removal, emissions must be aggregated across all feedstock production batches, $p$ , within that removal, where $n$ is the total number of batches:

 $CO_2e_{Counterfactual,\ n} = \sum_{p=1}^{n}CO_{2}e_{Counterfactual,\ p}$

(Equation 3)

$CO_2e_{Counterfactual,\ n}$ = the total counterfactual CO₂ that is ineligible for Crediting as laid out in EC13, for injection batch n, in tonnes of CO₂e, see Equation (1)
$CO_{2}e_{Counterfactual,\ p}$ = the total counterfactual CO₂ that is ineligible for Crediting as laid out in EC13, for production batch p, in tonnes of CO₂e

3.2

Calculation of CO|2|e|Leakage, p

Calculation of CO₂e_{Leakage, p}

For eligible feedstocks, emissions associated with market leakage will be equal to the total emissions associated with replacement material, as other forms of market leakage are assessed to be 0 for eligible feedstocks. Thus, market leakage for a batch $n$ , is given by the following equation:

 $CO_2e_{Leakage,\ n} = CO_{2}e_{Replacement,\ n}$

(Equation 4)

$CO_2e_{Leakage,\ n}$ = the total GHG emissions associated with market leakage for injection batch 𝑛, in tonnes of CO₂e,
$CO_{2}e_{Replacement,\ n}$ = the total GHG emissions associated with Replacement for injection batch 𝑛, in tonnes of CO₂e, see Equation (5)

Note: $CO_2e_{Leakage}$ emissions must be considered in the context of all cradle-to-grave project activities, as set out in the relevant protocol, and not only limited to biomass feedstock considerations.

Where feedstock may be diverted from an alternate use, emissions associated with replacing the function of the feedstock removed for use in the project must be accounted for. Exemptions are listed in Section 3.2.2.

The emissions associated with the replacement material, as determined by the feedstock framework and the counterfactual definition, must include full cradle-to-grave emissions accounting for the life cycle of the replacement product. For example emissions for the production, transportation and use of the material.

$CO_{2}e_{Replacement,\ n}$ can be calculated as follows:

 $CO_2e_{Replacement,\ n} = CO_{2}e_{Energy\ Replacement,\ n} + CO_{2}e_{Embodied\ Replacement,\ n} + \\ CO_{2}e_{Transportation\ Replacement,\ n}$

(Equation 5)

Where:

$CO_{2}e_{Replacement,\ n}$ = the total GHG emissions associated with Replacement for injection batch 𝑛, in tonnes of CO₂e
$CO_{2}e_{Energy\ Replacement,\ n}$ = the total GHG emissions associated with energy consumption related to Replacement activities for injection batch 𝑛, in tonnes of CO₂e. See Energy Emissions Accounting Module for calculation approach details.
$CO_{2}e_{Embodied\ Replacement,\ n}$ = the total life-cycle embodied emissions associated with the production and use of the replacement product for injection batch 𝑛, in tonnes of CO₂e. See Embodied Emissions Accounting Module for calculation approach details and emission factor requirements.
$CO_{2}e_{Transportation\ Replacement,\ n}$ = the total CO₂e emissions associated with transportation and delivery of the replacement product for a feedstock for injection batch 𝑛, in tonnes of CO₂e. See Transportation Emissions Accounting Module for calculation approach details.

If the replacement product is performing an environmental service, such as fertilizing, the amount of replacement product used must account for the equivalent amount of service that the Project feedstock provided. See Section 3.2.3.1 for further calculation details.

3.2.1

Method of determining replacement emissions

The replacement emissions for the Project Proponent feedstock is assumed to be the economically highest value use of the feedstock in a given state.

The Project Proponent may be able to provide evidence leading to a different replacement feedstock being used. This can be done by demonstrating:

An affidavit, or other credible records, from the feedstock supplier outlining the past use of their biomass over the last 5 years
Evidence that the highest value use is not representative of the feedstock end uses for the source region. This can be done by presenting evidence of the historical behaviors of feedstock suppliers and justifying that these do not apply in the case of the feedstock in question. For example, it may be determined that bioenergy is the highest value alternative use for a feedstock, however, if a Project Proponent can demonstrate that feedstocks are not typically moved over a certain distance to bioenergy facilities and there are no bioenergy facilities within this radius of the feedstock source this would be satisfactory evidence that this alternative use is not applicable.

3.2.2

Exemptions to CO|2|e|Replacement, n

Exemptions to CO₂e_{Replacement, n}

Replacement emissions can be considered 0 where any of the following conditions in Table 7 are met:

Table 7

Condition		Documentation required
C1	If the feedstock currently serves no purpose, such as mill residues in a stockpile or forest residues sitting on the forest floor, there are deemed to be no replacement emissions.	Evidence of the historical use of the feedstock or lack thereof, such as: Shipments of waste to disposal sites or to application / end use sites Documentation of on-site stockpiles, including size, mass, or other relevant information (e.g. total stockpile volume (size) or stockpile mass records, such as reports provided to regulatory agencies or weigh scale tickets for inputs and outputs) Documentation of other feedstock uses, such as on-site energy recovery and amounts used Where data and supporting records are not available, at minimum: A signed affidavit must be provided from the feedstock supplier outlining the historical use of their specific feedstock; Third party verification of the feedstock prior use must also be provided which can be done as a site-visit by a VVB
C2	For project feedstock that is replaced by a feedstock that meets condition C1.	Records of the qualitative assessment of the local market and the availability of suitable feedstocks that can be considered waste products and can serve as a replacement for the feedstock used by the Project, including: Documentation of all assumptions used in the study or analysis. Documentation or listing of references and data sources for information used. All documentation as required in this section to demonstrate that the replacement feedstock meets the C1 condition.
C3	For project feedstock usage above the percentage of what is theoretically possible to use for a given purpose (the ‘Sustainable Use Rate’) the feedstock would be considered true waste and therefore not require calculation of replacement emissions.	Where feedstocks do have an alternative use, either the full amount or partial amounts, evidence should be provided to demonstrate a Sustainable Use Rate. The Project Proponent must demonstrate that the amount of feedstock taken from a specific location and used for the project is lower than what has historically been used for that prior use in a given area and therefore would not need to be replaced. The following principles should be considered in this determination: Conservative assumptions and high quality regional data must be used to quantify this. Documentation of all assumptions used in the study or analysis. Documentation or listing of references and data sources for information used. For fertilizer: projects must calculate the total county requirement for nitrogen, phosphorus and potassium (NPK) content for the amount of land that has historically been applied with manure, then ensure sufficient manure to meet the limiting nutrient requirements is still available after procurement. For example: Manure - anything in excess of the amount of manure that can sustainably be applied to cropland in the feedlot’s region. Preferably, this is achieved by subtracting the sustainable application rate from the feedlot’s manure production to obtain the maximum volume that can be procured. In some circumstances, procurements above this level may be allowed if there is strong evidence that the feedlot’s region has a consistent surplus of manure. Corn stover - amounts in excess of the maximum possible use of corn stover to meet nutritional needs of cattle or for animal bedding within a specific county or radius from feedstock source.

3.2.3

Measurements - CO|2|e|Replacement

Measurements - CO₂e_Replacement

Calculation of $CO_{2}e_{Replacement}$ requires, but is not limited to, the following measurements:

$m_{Replacement}$ (mass of replacement material)

3.2.3.1

Mass of replacement material

For replacement of fertilizer function provided by the Project feedstock, the mass of fertilizer accounted for in emission calculations, $m_{Replacement}$ , must account for the equivalent amount of service that the Project feedstock provided.

The total fertilizer capacity previously provided by the Project feedstock must be calculated based on the feedstock(s) nitrogen, phosphorus and potassium (NPK) content. Feedstock NPK content must be determined by sampling of the feedstock(s) for each production batch $p$ , or from available scientific literature.

The amount of fertilizer replacement in the counterfactual scenario must account for replacing the same amount of NPK as in the project feedstock, using the most limiting factor (either N, P, K) to determine the mass of fertilizer required. This is likely to be a very conservative estimate, since not all nutrition will be able to be utilized. As better data & evidence is built, a lower estimate can be used when well evidenced with scientific literature.

3.2.4

Required Records & Documentation - CO|2|e|Replacement, n

Required Records & Documentation - CO₂e_{Replacement, n}

The Project Proponent must maintain the following records as evidence of $CO_{2}e_{Replacement, n}$ calculations:

If the feedstock provided an environmental service either:
- documentation on how N, P, K values were determined from relevant literature,
- for new or unique feedstocks, a per-feedstock lab analysis of N, P and K values, or
- for highly variable feedstocks a per-batch lab analysis of N, P and K values.
Feedstock weigh scale tickets for each production batch, $p$ , or other equivalent records to support calculation of $m_{Replacement}$

Records must be maintained and provided for verification purposes for a period of five years.

4.0

Acknowledgements

Isometric would like to thank following contributors to this Module:

Kevin Fingerman, Ph.D. (Cal Poly Humboldt)
Tim Hansen (350 Solutions)

5.0

Definitions and Acronyms

BaselineA set of data describing pre-intervention or control conditions to be used as a reference scenario for comparison.
Carbon Dioxide Removal (CDR)Activities that remove carbon dioxide (CO₂) from the atmosphere and store it in products or geological, terrestrial, and oceanic Reservoirs. CDR includes the enhancement of biological or geochemical sinks and direct air capture (DAC) and storage, but excludes natural CO₂ uptake not directly caused by human intervention.
ConservativePurposefully erring on the side of caution under conditions of Uncertainty by choosing input parameter values that will result in a lower net CO₂ Removal than if using the median input values. This is done to increase the likelihood that a given Removal calculation is an underestimation rather than an overestimation.
Cradle-to-GraveConsidering impacts at each stage of a product's life cycle, from the time natural resources are extracted from the ground and processed through each subsequent stage of manufacturing, transportation, product use, and ultimately, disposal.
Crediting PeriodThe period of time over which a Project Design Document is valid, and over which Removals may be Verified, resulting in Issued Credits.
Embodied EmissionsLife cycle GHG emissions associated with production of materials, transportation, and construction or other processes for goods or buildings.
LeakageThe increase in GHG emissions outside the geographic or temporal boundary of a project that results from that project's activities.
ModelA calculation, series of calculations or simulations that use input variables in order to generate values for variables of interest that are not directly measured.
ModuleIndependent components of Isometric Certified Protocols which are transferable between and applicable to different Protocols.
NPKNitrogen [N], Phosphurus [P], and Potassium [K] are three nutrients essential to crop growth.
SURSustainable Usage Rate: the rate at which a feedstock can be removed from a location without affecting the feedstock's environmental benefits or availability for alternative uses.
StorageDescribes the addition of carbon dioxide removed from the atmosphere to a reservoir, which serves as its ultimate destination. This is also referred to as “sequestration”.
Validation and Verification Bodies (VVBs)Third-party auditing organizations that are experts in their sector and used to determine if a project conforms to the rules, regulations, and standards set out by a governing body. A VVB must be approved by Isometric prior to conducting validation and verification.

6.0

Appendix 1: Calculating replacement mass for manure

This section outlines how to calculate the replacement mass of fertilizer, $m_{Replacement}$ , for a specific quantity of sourced manure from a single location. The actual replacement emissions depend on various variables related to the nutrient composition of the sourced manure and the nutrient requirements of the cropland surrounding the manure source location.

6.1

Relevant variables

$ObservedCounterfactual$ - quantity of manure (tonnes) from a supplier that is currently used for nutrient source.
$QuantityProcured$ - quantity of manure (tonnes) procured for CDR by the Project Proponent from within the $SupplyRegion$ .
$QuantityGenerated$ - total quantity of manure (tonnes) generated in a supply region.
$SupplyRegion$ - the geographic area considered when calculating relevant manure supply. Typically, this will include a 5-mile radius around the manure source. Under certain circumstances, this may be limited to the manure source.
$Acres$ - the number of relevant acres using manure. This can be estimated using the county-level share of total acres that use manure fertilizer multiplied by the total area of farmland within a 15-mile radius of the manure source.
$PrimaryCrop$ - The largest crop by acreage included in the $Acres$ value
$NutrientsReq_{f}$ - necessary quantity of nutrient $f$ (N or P) per cropland acre for the $PrimaryCrop$ .
$ManureNutrient_f$ - quantity of nutrient $f$ (N or P) in 1 tonne of manure.
$FertiliserEmissions_f$ - the emissions, in tonnes CO₂e, generated in the production of 1kg of nutrient $f$ (N or P) in fertilizer.

The Sustainable Use Rate (SUR) is the quantity of manure that can be taken without the need to calculate replacement emissions. There are three potential cases:

6.2

Case 1: There exists an observed counterfactual

If the source can demonstrate through manure management plan records and/or an affadavit or other documentation the quantity of manure that was used for fertilization purposes either on- or off-farm, the SUR can be calculated as follows:

 $SUR = QuantityGenerated\ -\ ObservedCounterfactual$

(Equation 6)

In this case, the $SupplyRegion$ is the feedlot, thus $QuantityGenerated$ is total quantity of manure produce annually at the source feedlot

6.3

Case 2: No observed counterfactual, but eligible to use the source farm as the supply region and acres serviced

If the source can demonstrate through manure management plan records and/or through a signed affadavit that no manure has left the property of the feedlot for at least the prior two years, the SUR can be calculated at the feedlot level. In this case, variables are calculated in the following manner:

Variable	Calculation
SupplyRegion	The source feedlot.
Acres	The total number of cropland acres that is operated by the feedlot owner.
QuantityGenerated	The quantity of manure produce annually at the source feedlot.
PrimaryCrop	The largest crop by acreage of all cropland operated by the feedlot owner and in the vicinity of the manure source.

Then the SUR is provided by the following calculation:

 $SUR = \max\left[\frac{{Acres \cdot NutrientsReq_{cN}}}{{ManureNutrient_{N}}}, \frac{{Acres \cdot NutrientsReq_{cP}}}{{ManureNutrient_{P}}}\right]$

(Equation 7)

6.4

Case 3: No observed counterfactual and not eligible to use the source farm as the supply region and acres serviced

If there does not exist an observed counterfactual and the source farm can not demonstrate that no manure has left the farm within the past 2 years, a regional estimate of the SUR can be computed using Equation 7 above, but with variables are calculated in the following manner:

Variable	Calculation
SupplyRegion	The region within a 5-mile radius of the manure source.
Acres	The total number of cropland acres that are within a 15-mile radius of the manure source multiplied by the share of the county's acres that are fertilized with manure.
QuantityGenerated	The quantity of manure produced within a 5-mile radius of the manure source, including the manure source.
PrimaryCrop	The largest crop by acreage of all cropland operated by the feedlot owner and in the vicinity of the manure source.

6.5

Replacement m

Replacement mass is calculated as follows:

 $QuantityProcured \leq SUR$

then:

 $m_{Replacement,\ p}=0$

Otherwise, the appropriate replacement mass value is:

 $m_{Replacement,\ p} = \\ (QuantityProcured-SUR)\\ \times (ManureNutrient_{N} \cdot FertiliserEmissions_{N}\\ + ManureNutrient_{P} \cdot FertiliserEmissions_{P})$

(Equation 8)

Potential additional data sources:

$NutrientsReq_{cf}$ - N, P needs per farmland acre from AESL at UGA (K is assumed to not be limiting).
$ManureNutrient_{f}$ - N, P generated from cow manure in the county from Utah State University Extension.

7.0

Appendix 2: Monitoring Plan Requirements

This appendix details how the Project Proponent must monitor, document and report all metrics identified within this Module to calculate counterfactual emissions. Following this guidance will ensure the Project Proponent measures and confirms carbon dioxide removed and long-term storage compliance, and will enable quantification of the emissions removal resulting from the Project activity during the Project Crediting Period, prior to each Verification.

This methodology utilizes a comprehensive monitoring and documentation framework that captures the GHG impact in each stage of a Project. Monitoring and detailed accounting practices must be conducted throughout to ensure the continuous integrity of the carbon dioxide removals and crediting.

The Project Proponent must develop and apply a monitoring plan according to ISO 14064-2 principles of transparency and accuracy that allows the quantification and proof of GHG emissions removals.

Parameter	Parameter Description	Required	Equation	Parameter Type	Units	Data Source	Measurement Method	Monitoring Frequency	QA/QC Procedures	Required Evidence	Reference
$CO_2e_{StorageCounterfactualEmissions15}$	Emissions that would have counterfactually been released within 15 years or the biomass sourcing date.	Under certain conditions	Eq. 1 (Biomass Feedstock Accounting Module)	Assessment	tonnes		The Project Proponent will produce evidence or analysis that outlines the expected counterfactual fate of their biomass feedstock. This analysis will either suggest that all of the carbon content of the biomass would have been rereleased into the atmosphere before the threshold time, that part of the carbon content would have been rereleased as GHG, or that none of it would have.	Each feedstock source	Transparency on rationale for chosen type of evidence	Report relying on one or more of the data sources	2.2 (Biomass Feedstock Accounting Module)
$δ_{50}$	Share of carbon in feedstock that would not have counterfactually returned to the atmosphere within 50 years	Under certain conditions	2.2 (Biomass Feedstock Accounting Module)	Assessment	unitless		The Project Proponent will produce evidence or analysis that outlines the expected counterfactual fate of their biomass feedstock.	Each feedstock source	Transparency on rationale for chosen type of evidence	Report relying on one or more of the data sources	2.2 (Biomass Feedstock Accounting Module)
$m_{Replacement,\ p}$	The mass of the replacement product required to provide the equivalent service as the mass of the project feedstock for a function	Under certain conditions	N/A	Measured	kg	Determined based on most likely replacement product. Total fertilizer capacity previously provided by the Project feedstock must be calculated based on the feedstock(s) NPK content.	Must account for the equivalent amount of service that the Project feedstock provided. The replacement counterfactual for the feedstock is determined to be the economically highest value use of the feedstock in a given state Feedstock NPK content must be determined by sampling of the feedstock(s) for each production batch or from available scientific literature. The amount of fertilizer replacement in the counterfactual scenario must account for replacing the same amount of NPK as in the project feedstock, using the most limiting factor (either N, P, K) to determine the mass of fertilizer required.	Each feedstock source	ISO 17025 accredited laboratory OR acceptable citations for region and feedstock. Input parameter transparency and analysis.	Feedstock weigh scale tickets for each production batch or other equivalent records to support calculation. Replacement product analysis documentation.	3.2.3 (Biomass Feedstock Accounting Module)
$CO_{2}e_{Energy\ Replacement,\ n}$	The total life-cycle embodied emissions associated with the production and use of the replacement product for injection batch 𝑛.	Under certain conditions	Eq. 5 (Biomass Feedstock Accounting Module)	Measured	tonnes CO₂e	Argonne National Laboratory GREET Model, California Air Resources Board modified GREET model (CA-GREET), Ecoinvent database, US Federal Life Cycle Inventory database or LCA Commons, or from similar databases used in common LCA practices or tools	N/A	Each feedstock source	Transparency on rationale for chosen type of evidence	GHG Statement	3.2 (Biomass Feedstock Accounting Module)
$CO_{2}e_{Transportation\ Replacement,\ n}$	The total CO₂e emissions associated with transportation and delivery of the replacement product for a feedstock for injection batch 𝑛.	Under certain conditions	Eq. 5 (Biomass Feedstock Accounting Module)	Measured	tonnes CO₂e	See calculations for transportation and choice of emission factors in "Transportation Module" as applied during the "Operations" aspect of project	On-line mapping systems using origin and departure from shipping documents, odometer readings AND fuel flow meters, fleet management system data, vehicle on board diagnostics, miles traveled & vehicle type, or similar; OR fuel flow meters, fleet management system data, vehicle on board diagnostics, miles traveled & vehicle type, or similar	Each feedstock source	Transparency on rationale for chosen type of evidence	GHG Statement	3.2 (Biomass Feedstock Accounting Module)
$CO_{2}e_{Embodied\ Replacement,\ n}$	The total life-cycle embodied emissions associated with the production and use of the replacement product for injection batch 𝑛.	Under certain conditions	Eq. 5 (Biomass Feedstock Accounting Module)	Measured	tonnes CO₂e	See calculations for embodied emissions accounting and choice of emission factors in "Embodied Emissions Accounting Module"	See calculations for embodied emissions accounting and choice of emission factors in "Embodied Emissions Accounting Module"	Each feedstock source	Transparency on rationale for chosen type of evidence	GHG Statement	3.2 (Biomass Feedstock Accounting Module)
$Quantity\ Procured$	Quantity of manure procured for CDR from a manure source.	Always	Eq. 6 (Biomass Feedstock Accounting Module)	Measured	tonnes	Determined from purchase contract.	The Project Proponent will report the amount of manure procured from a source.	Each feedstock source	N/A	Feedstock purchase contract	Appendix 1 (Biomass Feedstock Accounting Module)
$Quantity\ Generated$	Total quantity of manure generated at a manure source.	Under certain conditions	Eq. 5 (Biomass Feedstock Accounting Module)	Measured	tonnes	Determined from feedlot records.	The Project Proponent will report the total amount of manure generated from a source.	Each feedstock source	Thorough documentation from records across multiple months.	Feedlot records	Appendix 1 (Biomass Feedstock Accounting Module)
Region	The geographic area considered when calculating the sustainable application rate, typically the county of the manure source (broader definitions may apply to sources near county borders, and narrower definitions for exceptionally large counties).	Under certain conditions	Eq. 5 (Biomass Feedstock Accounting Module)	Assessment	N/A	Typically defined as the county containing the feedlot.		Each feedstock source	N/A		Appendix 1 (Biomass Feedstock Accounting Module)
Acres	Acres using manure source for crop c within the region of the manure source.	Under certain conditions	Eq. 5 (Biomass Feedstock Accounting Module)	Assessment	Acres	Most recent Census of Agriculture report	Based on USDA survey results regarding the number of acres in a county that apply manure and data on the most common crop grown in a county.	Each feedstock source	N/A		Appendix 1 (Biomass Feedstock Accounting Module)
$NutrientsReq_{f}$	Necessary quantity of nutrient f (N or P) for crop-type c per cropland acre.	Under certain conditions	Eq. 5 (Biomass Feedstock Accounting Module)	Assessment	tonnes	University of Georgia Nutrient Needs Cropsheet		Each feedstock source	N/A		Appendix 1 (Biomass Feedstock Accounting Module)
$ManureNutrients_{f}$	Quantity of nutrient f (N or P) in 1 tonne of manure	Under certain conditions	Eq. 4 (Biomass Feedstock Accounting Module)	Assessment	tonnes			Each feedstock source	N/A		Appendix 1 (Biomass Feedstock Accounting Module)

8.0

Appendix 3: Acceptable Forest Certification Programs for EC9

Forest certifications can help ensure that biomass used for CDR activities does not incentivize forestry activities that reduce global carbon stocks. Four certifications provide a high degree of confidence through supply chain visibility and regular auditing: FSC, PEFC, SFI, and ATFS. Biomass certified under these four certifications are eligible for any Biogenic Carbon Capture and Sequestration (BCCS) or Biomass with Carbon Removal and Sequestration (BiCRS) project, subject to other eligibility criteria outlined in the Isometric Biomass Feedstock Accounting module. Two additional biomass certifications, SBP and RSB, provide eligibility subject to an additional requirement that Project Proponents provide information on the region (US state-level or equivalent is acceptable) from which the biomass is sourced and provide evidence that forestry carbon stocks in these regions are stable or increasing. At this time, risk-based approaches that do not conduct site audits are eligible if they are provided through FSC or PEFC. FSC Mix certified biomass is eligible, but should not constitute more than 50% of the biomass sourced for a project.

Certification	Projects types eligible for:	Additional documentation required
Forest Stewardship Council (FSC) 100%	All BCCS and BiCRS	None
Program for the Endorsement of Forest Certification (PEFC) 100%	All BCCS and BiCRS	None
Sustainable Forestry Initiative (SFI)	All BCCS and BiCRS	None
American Tree Farm System (ATFS)	All BCCS and BiCRS	None
Sustainable Biomass Program (SBP)	Eligible only for processes where the CDR is not the primary product produced.	Information on the region (US state-level or equivalent is acceptable) from which the biomass is sourced. Evidence that forestry carbon stocks in these regions are stable or increasing.
Roundtable for Sustainable Biomass (RSB)	Eligible only for processes where the CDR is not the primary product produced.	Information on the region (US state-level or equivalent is acceptable) from which the biomass is sourced. Evidence that forestry carbon stocks in these regions are stable or increasing.
FSC Controlled Wood Sources	Eligible only for processes where the CDR is not the primary product produced.	Submitted PPDs should target having FSC Mix account for no more than 25% of project biomass.
PEFC Controlled Sources	Eligible only for processes where the CDR is not the primary product produced.	Submitted PPDs should target having FSC Mix account for no more than 25% of project biomass.

A forest residue is defined as non-marketable wood, for example, beetle kill, sticks and twigs, mill residues, etc. ↩
Allowed State level alternative programs are outlined here ↩
Such as wood removal from areas affected by windfall, fires, insect, or disease attacks, or where wood is removed for widely-recognized ecological reasons (e.g., to reduce wildfire hazard). ↩
Criterion 1.1, Sustainable Biomass Sourcing for Carbon Dioxide Removal, Version 1.1, October 2023 ↩
Criterion 3.4, Sustainable Biomass Sourcing for Carbon Dioxide Removal, Version 1.1, October 2023 ↩
Criterion 1.1, Sustainable Biomass Sourcing for Carbon Dioxide Removal, Version 1.1, October 2023 ↩
Criterion 3.4, Sustainable Biomass Sourcing for Carbon Dioxide Removal, Version 1.1, October 2023 ↩
Criterion 4.2, Sustainable Biomass Sourcing for Carbon Dioxide Removal, Version 1.1, October 2023 ↩
Cellulosic biorefinery locations and capacities can be obtained from the Renewable Fuels Association: https://ethanolrfa.org/resources/ethanol-biorefinery-locations. If the feedstock is listed as “Cellulosic Biomass”, then we assume 100% of harvested-for-sale corn stover within 50 km has an alternative fate of an ethanol production use. At present, given the small total production of cellulosic biofuel, facilities where “Cellulosic Biomass” is listed as only one potential feedstock among multiple (e.g., “Corn/Cellulosic Biomass”) will be assumed to be primarily corn and stover procured from these areas will be assumed to not have an alternative use as an energy crop. ↩
The verifier may provide third party verification during the verification site visits via on-site review of feedstock practices, utilization, and records, including observation of feedstock stockpiles, deliveries, applications, or other uses. ↩

Contributors

Matt Gammans, Ph.D.

Neil Hacker

Clare Leckie

Ola Sitarska

Christie Patel

Chris Podgorney

Changelog

Impact	Definition
Market Leakage	By providing payment for a feedstock, a supplier may induce market changes that shifts feedstock producer behavior in a way that results in increased GHG emissions. Market leakage may lead to a change in feedstock producer behaviour that results in land use change. In this version of the module, the land use change impact is assessed to be 0 when a feedstock is eligible for use in Section 2. A second form of market leakage, Replacement Emissions, occurs from any additional activities necessary to replace any environmental or marketable services the feedstock would have otherwise provided need to be accounted for (e.g. nutrient provision). Any emissions associated with the production and use of the replacement materials must be accounted for in the Leakage assessment. For example, if manure that was previously spread on land as a fertilizer is diverted for use as a feedstock, a replacement fertilization method must be evaluated. Quantification requirements are provided in Section 3.2.
Counterfactual Storage	The counterfactual storage considers the CO₂ stored in the biomass feedstock that would have remained durably stored in the biomass in the absence of the project. This is known as ineligable biomass as the CO₂ would have remained stored in the biomass in the absence of the CDR project and is therefore not eligible to count towards Crediting. Quantification requirements are provided in Section 2.2 and Section 3.1.

Impact

Definition

Market Leakage

Counterfactual Storage

Eligibility Criteria satisfying direct and indirect market leakage requirements

Documentation required

EC1

Project Proponent does not pay for the feedstock used

Feedstock purchase records between Project Proponent and feedstock supplier demonstrating price paid, amount, buyer, seller and date.

EC2

Project Proponent is paid a “tipping fee” to remove the feedstock.

Feedstock removal records between Project Proponent and feedstock supplier demonstrating price paid, amount, buyer, seller, and date.

EC3

Project Proponent paid for their feedstock but can show that the amount they paid is lower than the total recovery and replacement cost of new activities related to the new use of this feedstock. This cost can be composed of, but not limited to:

Harvesting - a feedstock owner engages in additional harvesting activities
Collection - a feedstock owner must put in additional time and labor to collect any harvested or existing materials
Transport - a feedstock owner moves, or pays for the movement of, any collected biomass to a new area due to the project needs
Replacement - a feedstock owner incurs some cost when they attempt to replace the use a feedstock that was previously being used for

Feedstock removal records between the Project Proponent and feedstock supplier demonstrating price paid, amount, buyer, seller, and date. Plus records of the recovery and replacement of the feedstock, including:

Costs for alternative use, including, but not limited to:

Harvesting costs of biomass, such as removal of residual corn stover from fields or chipping and shredding of forest residues.
Transportation costs to end user or disposal site.
Spreading costs or similar end of delivery offloading or application costs (i.e. manure spreading or stover burning and char spreading).

Above costs may be demonstrated by provision of invoices, bills of lading, purchase records, or other similar documentation provided by the feedstock supplier or other end users.
Alternatively, costs may be referenced from scientific literature or data specific to the locality or region where the feedstock is produced (i.e. average market prices for biomass shipping in a region). The literature used will be subject of review by a competent Validation & Verification Body to ensure that best available scientific information with an established body of scientific research is used.
Calculations of total recovery and replacement of feedstock, linked to the above source data, and compared to the price paid to the feedstock supplier or 3rd party intermediary.

EC4

Project Proponent paid for their feedstock, but this was paid to a 3rd party and not the entity responsible for biomass growth or harvesting, if this 3rd party also didn’t pay the producing/harvesting entity above total recovery and replacement cost.

A signed statement from the 3rd party and/or the feedstock supplier indicating that the 3rd party is not providing the supplier additional payment for the feedstock.

Eligibility Criteria satisfying indirect market leakage requirement

Documentation required

EC5

Feedstock is a forest residue¹.

The Project Proponent must demonstrate that the feedstock is an non-marketable wood product. For example, beetle kill, sticks and twigs, mill residues, etc.

EC6

Feedstock is an agricultural crop residue or an animal waste.

The Project Proponent must demonstrate that the feedstock is an agricultural residue or waste whose production is ancillary to the production of the primary marketable product.

EC7

Feedstock is a biogenic product that is a non-marketable waste product created within an industrial production process turning forest biomass into some other marketable good.

The Project Proponent must demonstrate that the feedstock is a waste product that would have no marketable use absent the Project. This can be evidenced by demonstrating that the material is currently being disposed of or, for new facilities, that similar materials at other sites do not market the feedstock material

Eligibility Criteria satisfying direct market leakage requirement

Documentation required

EC8

Applicable to forest residues or downstream wood wastes only: Biomass originates from a regulated forest management project.

The Project can provide a reference that the feedstock came from either:

a NEPA, or state level equivalent², planned project or

a government regulated forest management project or

a state or federal funded or managed forest management activity

In each case, the project with the associated harvest plan will be subject to competent Verification & Validation Body to ensure adherence to the criteria.

EC9

Applicable to forest residues or downstream wood wastes only: Forest biomass results from forest management activities³ in historically stable or increasing forest carbon stocks.

The following evidence is required to meet this criteria:

Biomass shall be certified under one of the acceptable certification schemes listed in Appendix 3 or be obtained through a NEPA project and/or other forest management and chain-of-custody certification programs with demonstrably equivalent forest management and chain-of-custody oversight and principles.⁴

Additionally at least one of the following types of evidence is required to meet this criteria:

Independent, third-party assessment of forest carbon stocks in the Sourcing Area which is based on public inventory data. This assessment must demonstrate that the forest carbon stock has not decreased during the last 5 years for which data are available, compared to the average forest carbon stock in the previous 5-year period. Data for live, aboveground biomass (standing stocking level) must be included. Project Proponents may elect to include deadwood pools, if reliable data are available.⁵
Land Use, Land-Use Change, and Forestry (LULUCF) emissions from the forestry sector in the country, or state/province, of harvest do not exceed removals. This requirement is met if, over the last 10 years, the average net emissions from the forestry sector are zero or negative, as reported in national greenhouse gas emissions to the UN Convention on Climate Change. In countries of harvest greater than five million square kilometers, an additional evidence is required that forest carbon stocks in the Sourcing Area are not decreasing over the same period.⁶

EC10

Applicable to forest residues or downstream wood wastes only: Forest biomass resulting from forest management activities where Sourcing Area carbon stocks may be decreasing, but the forest management activity had to be carried out regardless.

Biomass shall be certified under FSC, SFI, PEFC-endorsed forest management schemes and/or other forest management and chain-of-custody certification programs with demonstrably equivalent forest management and chain-of-custody oversight and principles.⁷
Documentation must be provided to demonstrate the specific nature of the disturbance, the legislative requirement, such as to promote healthy tree growth, or the ecological necessity of the wood removal⁸

EC11

Applicable to agricultural crop residues only: The purchase contract signed between a Project Proponent and a feedstock supplier commits the Project Proponent to not purchase feedstock from a given acreage in consecutive years. Alternatively, feedstock may be sourced from the same acreage in sequential years if evidence is presented that the acreage has been monocropped (no crop rotation) for at least 5 years.

Feedstock purchase contract between Project Proponent and feedstock supplier.

EC12

Applicable to animal waste feedstocks only: Project Proponent paid a positive amount for their feedstock, but are able to demonstrate there is a surplus of feedstock available in the region and additionally are able to:

Obtain data from the 2 years prior to the procurement date on the annual output/utilization factor of the biomass source.
To ensure payments do not incentivize additional feedstock production, the Project Proponent must demonstrate that the total annual amount of feedstock the Project Proponent contracts for the current year for will be at or below the levels of total output 2 years earlier. By linking eligibility to past production, we ensure that increasing production for the purposes of receiving additional payments would incur losses for at least 2 years. Given the low margins in agricultural production and current costs of capital, this delay period likely makes these decisions economically infeasible.

Feedstock purchase contract between Project Proponent and feedstock supplier.
Historical data on the output/utilization factor of the biomass source. Regional data on Sustainable Use Rate.

Eligibility Criteria

Documentation required

EC13

Biomass where the most likely counterfactual fate would release all stored biogenic C sooner than 15 years from when a project uses it, is eligible under this Module.

If the counterfactual fate of the biomass includes the stored biogenic C being emitted as GHGs with a GWP100>1, the total biomass eligible is equal to the minimum of:

(1) the CO₂e (evaluated at GWP100) of counterfactually released GHGs emitted within 15 years

(2) the total stored CO₂ in the biomass minus the CO₂ in biomass that would not have counterfactually been released within 50 years.

Landfilled wood is not an eligible feedstock, unless the Project Proponent can demonstrate the counterfactual fate would release all stored biogenic carbon within 15 years.

To assess the counterfactual fate of the biomass at least one of the following pieces of evidence should be provided by the Project Proponent:

An affidavit or record of a contractual clause in the purchase records confirming that the counterfactual fate of the biomass would result in release of CO₂e within the threshold
Historical evidence of the counterfactual fate of the biomass over the last 5 years provided by the feedstock supplier
A qualitative assessment that the expected fate of the biomass would have a durability lower than the threshold given the most economically viable option in a given Sourcing Area.

Project Proponents who cannot demonstrate that all of the stored C would have been counterfactually released within 15 years, must make an assessment of the release of CO₂e (evaluated at GWP 100) in the counterfactual scenario at 15 years:

Provide an assessment of the estimated amount of stored biogenic C released and conservatively estimated quantities of GHGs that would have been emitted. These estimates can be used to calculate the CO₂e (evaluated at GWP 100) of all GHGs counterfactually emitted within 15 years;
Provide an assessment of the estimated amount of stored biogenic C that would have remained stored after 50 years.

EC14

Feedstocks that are sourced through government managed or funded wildfire mitigation or restoration activities will be assigned a counterfactual storage value of 0.

Project Proponent should provide a government source demonstrating that the funding or management of the biomass collection or harvesting was required, funded, or managed by a federal or state government body and was done for the purpose of wildfire mitigation or post-wildfire ecosystem restoration.

CO_2e_{Counterfactual,\ n} = CO_2e_{Feedstock} - CO_2e_{EmissionsCounterfactual}

CO_2e_{EmissionsCounterfactual} = min(CO_2e_{StorageCounterfactualEmissions15}, (1-δ_{50})\\ \times CO_2e_{Feedstock})

Eligibility Criteria

Documentation required

EC15

Applicable to non-forestry feedstocks: The biomass feedstock was not grown for the purposes of energy production and does not have a likely counterfactual energy production use.

Project Proponent must conduct an analysis of the regional use for the type of biomass they are sourcing. This analysis must show that biomass meets one of the following conditions:

The Project Proponent must demonstrate that less than 50% of the total harvested biomass, by both volume and value, is allocated for energy production in the counterfactual usage of the biomass.⁹ This analysis must either demonstrate that the feedstock is not sourced from with 50 kilometers of an ethanol plant that relies on exclusively cellulosic feedstocks or, alternatively, the Project Proponent may provide farm-level documentation that the procured feedstock supplier was not previously supplying the relevant biomass to any cellulosic ethanol plant.¹⁰
The biomass has already fulfilled its energy generation uses (e.g. post anaerobic digestion manure).

CO_2e_{Replacement,\ n} = CO_{2}e_{Energy\ Replacement,\ n} + CO_{2}e_{Embodied\ Replacement,\ n} + \\ CO_{2}e_{Transportation\ Replacement,\ n}

Condition

Documentation required

If the feedstock currently serves no purpose, such as mill residues in a stockpile or forest residues sitting on the forest floor, there are deemed to be no replacement emissions.

Evidence of the historical use of the feedstock or lack thereof, such as:

Shipments of waste to disposal sites or to application / end use sites
Documentation of on-site stockpiles, including size, mass, or other relevant information (e.g. total stockpile volume (size) or stockpile mass records, such as reports provided to regulatory agencies or weigh scale tickets for inputs and outputs)
Documentation of other feedstock uses, such as on-site energy recovery and amounts used

Where data and supporting records are not available, at minimum:

A signed affidavit must be provided from the feedstock supplier outlining the historical use of their specific feedstock;
Third party verification of the feedstock prior use must also be provided which can be done as a site-visit by a VVB

For project feedstock that is replaced by a feedstock that meets condition C1.

Records of the qualitative assessment of the local market and the availability of suitable feedstocks that can be considered waste products and can serve as a replacement for the feedstock used by the Project, including:

Documentation of all assumptions used in the study or analysis.
Documentation or listing of references and data sources for information used.
All documentation as required in this section to demonstrate that the replacement feedstock meets the C1 condition.

For project feedstock usage above the percentage of what is theoretically possible to use for a given purpose (the ‘Sustainable Use Rate’) the feedstock would be considered true waste and therefore not require calculation of replacement emissions.

Where feedstocks do have an alternative use, either the full amount or partial amounts, evidence should be provided to demonstrate a Sustainable Use Rate. The Project Proponent must demonstrate that the amount of feedstock taken from a specific location and used for the project is lower than what has historically been used for that prior use in a given area and therefore would not need to be replaced. The following principles should be considered in this determination:

Conservative assumptions and high quality regional data must be used to quantify this.
Documentation of all assumptions used in the study or analysis.
Documentation or listing of references and data sources for information used.
For fertilizer: projects must calculate the total county requirement for nitrogen, phosphorus and potassium (NPK) content for the amount of land that has historically been applied with manure, then ensure sufficient manure to meet the limiting nutrient requirements is still available after procurement.

For example:

Manure - anything in excess of the amount of manure that can sustainably be applied to cropland in the feedlot’s region. Preferably, this is achieved by subtracting the sustainable application rate from the feedlot’s manure production to obtain the maximum volume that can be procured. In some circumstances, procurements above this level may be allowed if there is strong evidence that the feedlot’s region has a consistent surplus of manure.
Corn stover - amounts in excess of the maximum possible use of corn stover to meet nutritional needs of cattle or for animal bedding within a specific county or radius from feedstock source.

Variable

Calculation

SupplyRegion

The source feedlot.

Acres

The total number of cropland acres that is operated by the feedlot owner.

QuantityGenerated

The quantity of manure produce annually at the source feedlot.

PrimaryCrop

The largest crop by acreage of all cropland operated by the feedlot owner and in the vicinity of the manure source.

SUR = \max\left[\frac{{Acres \cdot NutrientsReq_{cN}}}{{ManureNutrient_{N}}}, \frac{{Acres \cdot NutrientsReq_{cP}}}{{ManureNutrient_{P}}}\right]

Variable

Calculation

SupplyRegion

The region within a 5-mile radius of the manure source.

Acres

The total number of cropland acres that are within a 15-mile radius of the manure source multiplied by the share of the county's acres that are fertilized with manure.

QuantityGenerated

The quantity of manure produced within a 5-mile radius of the manure source, including the manure source.

PrimaryCrop

The largest crop by acreage of all cropland operated by the feedlot owner and in the vicinity of the manure source.

m_{Replacement,\ p} = \\ (QuantityProcured-SUR)\\ \times (ManureNutrient_{N} \cdot FertiliserEmissions_{N}\\ + ManureNutrient_{P} \cdot FertiliserEmissions_{P})

Parameter

Parameter Description

Required

Equation

Parameter Type

Units

Data Source

Measurement Method

Monitoring Frequency

QA/QC Procedures

Required Evidence

Reference

CO_2e_{StorageCounterfactualEmissions15}

Emissions that would have counterfactually been released within 15 years or the biomass sourcing date.

Under certain conditions

Eq. 1 (Biomass Feedstock Accounting Module)

Assessment

tonnes

The Project Proponent will produce evidence or analysis that outlines the expected counterfactual fate of their biomass feedstock. This analysis will either suggest that all of the carbon content of the biomass would have been rereleased into the atmosphere before the threshold time, that part of the carbon content would have been rereleased as GHG, or that none of it would have.

Each feedstock source

Transparency on rationale for chosen type of evidence

Report relying on one or more of the data sources

2.2 (Biomass Feedstock Accounting Module)

δ_{50}

Share of carbon in feedstock that would not have counterfactually returned to the atmosphere within 50 years

Under certain conditions

2.2 (Biomass Feedstock Accounting Module)

Assessment

unitless

The Project Proponent will produce evidence or analysis that outlines the expected counterfactual fate of their biomass feedstock.

Each feedstock source

Transparency on rationale for chosen type of evidence

Report relying on one or more of the data sources

2.2 (Biomass Feedstock Accounting Module)

m_{Replacement,\ p}

The mass of the replacement product required to provide the equivalent service as the mass of the project feedstock for a function

Under certain conditions

N/A

Measured

Determined based on most likely replacement product. Total fertilizer capacity previously provided by the Project feedstock must be calculated based on the feedstock(s) NPK content.

Must account for the equivalent amount of service that the Project feedstock provided. The replacement counterfactual for the feedstock is determined to be the economically highest value use of the feedstock in a given state Feedstock NPK content must be determined by sampling of the feedstock(s) for each production batch or from available scientific literature. The amount of fertilizer replacement in the counterfactual scenario must account for replacing the same amount of NPK as in the project feedstock, using the most limiting factor (either N, P, K) to determine the mass of fertilizer required.

Each feedstock source

ISO 17025 accredited laboratory OR acceptable citations for region and feedstock. Input parameter transparency and analysis.

Feedstock weigh scale tickets for each production batch or other equivalent records to support calculation. Replacement product analysis documentation.

3.2.3 (Biomass Feedstock Accounting Module)

CO_{2}e_{Energy\ Replacement,\ n}

The total life-cycle embodied emissions associated with the production and use of the replacement product for injection batch 𝑛.

Under certain conditions

Eq. 5 (Biomass Feedstock Accounting Module)

Measured

tonnes CO₂e

Argonne National Laboratory GREET Model, California Air Resources Board modified GREET model (CA-GREET), Ecoinvent database, US Federal Life Cycle Inventory database or LCA Commons, or from similar databases used in common LCA practices or tools

N/A

Each feedstock source

Transparency on rationale for chosen type of evidence

GHG Statement

3.2 (Biomass Feedstock Accounting Module)

CO_{2}e_{Transportation\ Replacement,\ n}

The total CO₂e emissions associated with transportation and delivery of the replacement product for a feedstock for injection batch 𝑛.

Under certain conditions

Eq. 5 (Biomass Feedstock Accounting Module)

Measured

tonnes CO₂e

See calculations for transportation and choice of emission factors in "Transportation Module" as applied during the "Operations" aspect of project

On-line mapping systems using origin and departure from shipping documents, odometer readings AND fuel flow meters, fleet management system data, vehicle on board diagnostics, miles traveled & vehicle type, or similar; OR
fuel flow meters, fleet management system data, vehicle on board diagnostics, miles traveled & vehicle type, or similar

Each feedstock source

Transparency on rationale for chosen type of evidence

GHG Statement

3.2 (Biomass Feedstock Accounting Module)

CO_{2}e_{Embodied\ Replacement,\ n}

The total life-cycle embodied emissions associated with the production and use of the replacement product for injection batch 𝑛.

Under certain conditions

Eq. 5 (Biomass Feedstock Accounting Module)

Measured

tonnes CO₂e

See calculations for embodied emissions accounting and choice of emission factors in "Embodied Emissions Accounting Module"

Each feedstock source

Transparency on rationale for chosen type of evidence

GHG Statement

3.2 (Biomass Feedstock Accounting Module)

Quantity\ Procured

Quantity of manure procured for CDR from a manure source.

Always

Eq. 6 (Biomass Feedstock Accounting Module)

Measured

tonnes

Determined from purchase contract.

The Project Proponent will report the amount of manure procured from a source.

Each feedstock source

N/A

Feedstock purchase contract

Appendix 1 (Biomass Feedstock Accounting Module)

Quantity\ Generated

Total quantity of manure generated at a manure source.

Under certain conditions

Eq. 5 (Biomass Feedstock Accounting Module)

Measured

tonnes

Determined from feedlot records.

The Project Proponent will report the total amount of manure generated from a source.

Each feedstock source

Thorough documentation from records across multiple months.

Feedlot records

Appendix 1 (Biomass Feedstock Accounting Module)

Region

The geographic area considered when calculating the sustainable application rate, typically the county of the manure source (broader definitions may apply to sources near county borders, and narrower definitions for exceptionally large counties).

Under certain conditions

Eq. 5 (Biomass Feedstock Accounting Module)

Assessment

N/A

Typically defined as the county containing the feedlot.

Each feedstock source

N/A

Appendix 1 (Biomass Feedstock Accounting Module)

Acres

Acres using manure source for crop c within the region of the manure source.

Under certain conditions

Eq. 5 (Biomass Feedstock Accounting Module)

Assessment

Acres

Most recent Census of Agriculture report

Based on USDA survey results regarding the number of acres in a county that apply manure and data on the most common crop grown in a county.

Each feedstock source

N/A

Appendix 1 (Biomass Feedstock Accounting Module)

NutrientsReq_{f}

Necessary quantity of nutrient f (N or P) for crop-type c per cropland acre.

Under certain conditions

Eq. 5 (Biomass Feedstock Accounting Module)

Assessment

tonnes

University of Georgia Nutrient Needs Cropsheet

Each feedstock source

N/A

Appendix 1 (Biomass Feedstock Accounting Module)

ManureNutrients_{f}

Quantity of nutrient f (N or P) in 1 tonne of manure

Under certain conditions

Eq. 4 (Biomass Feedstock Accounting Module)

Assessment

tonnes

Each feedstock source

N/A

Appendix 1 (Biomass Feedstock Accounting Module)

Certification

Projects types eligible for:

Additional documentation required

Forest Stewardship Council (FSC) 100%

All BCCS and BiCRS

None

Program for the Endorsement of Forest Certification (PEFC) 100%

All BCCS and BiCRS

None

Sustainable Forestry Initiative (SFI)

All BCCS and BiCRS

None

American Tree Farm System (ATFS)

All BCCS and BiCRS

None

Sustainable Biomass Program (SBP)

Eligible only for processes where the CDR is not the primary product produced.

Information on the region (US state-level or equivalent is acceptable) from which the biomass is sourced. Evidence that forestry carbon stocks in these regions are stable or increasing.

Roundtable for Sustainable Biomass (RSB)

Eligible only for processes where the CDR is not the primary product produced.

Information on the region (US state-level or equivalent is acceptable) from which the biomass is sourced. Evidence that forestry carbon stocks in these regions are stable or increasing.

FSC Controlled Wood Sources

Eligible only for processes where the CDR is not the primary product produced.

Submitted PPDs should target having FSC Mix account for no more than 25% of project biomass.

PEFC Controlled Sources

Eligible only for processes where the CDR is not the primary product produced.

Submitted PPDs should target having FSC Mix account for no more than 25% of project biomass.

Contents

Introduction

Future Versions

Biomass Feedstock Considerations

Biomass Feedstock Eligibility

Eligibility Criteria for Biomass Feedstocks with Potential Market Leakage Impacts

Recommended sourcing principles

Counterfactual Storage Eligibility

Dedicated Energy Feedstock Eligibility

Biomass Feedstock Calculations

Calculation of CO2eCounterfactual, n

Calculation of CO2eLeakage, p

Method of determining replacement emissions

Exemptions to CO2eReplacement, n

Measurements - CO2eReplacement

Mass of replacement material

Required Records & Documentation - CO2eReplacement, n

Acknowledgements

Definitions and Acronyms

Appendix 1: Calculating replacement mass for manure

Relevant variables

Case 1: There exists an observed counterfactual

Case 2: No observed counterfactual, but eligible to use the source farm as the supply region and acres serviced

Case 3: No observed counterfactual and not eligible to use the source farm as the supply region and acres serviced

Replacement m

Appendix 2: Monitoring Plan Requirements

Appendix 3: Acceptable Forest Certification Programs for EC9

Footnotes

Contributors

Changelog

Contents

Introduction

Future Versions

Biomass Feedstock Considerations

Biomass Feedstock Eligibility

Eligibility Criteria for Biomass Feedstocks with Potential Market Leakage Impacts

Recommended sourcing principles

Counterfactual Storage Eligibility

Dedicated Energy Feedstock Eligibility

Biomass Feedstock Calculations

Calculation of CO2eCounterfactual, n

Calculation of CO2eLeakage, p

Method of determining replacement emissions

Exemptions to CO2eReplacement, n

Measurements - CO2eReplacement

Mass of replacement material

Required Records & Documentation - CO2eReplacement, n

Acknowledgements

Definitions and Acronyms

Appendix 1: Calculating replacement mass for manure

Relevant variables

Case 1: There exists an observed counterfactual

Case 2: No observed counterfactual, but eligible to use the source farm as the supply region and acres serviced

Case 3: No observed counterfactual and not eligible to use the source farm as the supply region and acres serviced

Replacement m

Appendix 2: Monitoring Plan Requirements

Appendix 3: Acceptable Forest Certification Programs for EC9

Footnotes

Contributors

Changelog

Calculation of CO₂e_{Counterfactual, n}

Calculation of CO₂e_{Leakage, p}

Exemptions to CO₂e_{Replacement, n}

Measurements - CO₂e_Replacement

Required Records & Documentation - CO₂e_{Replacement, n}

Calculation of CO₂e_{Counterfactual, n}

Calculation of CO₂e_{Leakage, p}

Exemptions to CO₂e_{Replacement, n}

Measurements - CO₂e_Replacement

Required Records & Documentation - CO₂e_{Replacement, n}