Clarification Requests

Please submit any clarification request about the interpretation of certain criteria of the CarbonFix Standard to the technical board (mail[Klammeraffe]carbonfix[Punkt]info) of CarbonFix. Provide with your request the background information on your case and state if the background information can be made publicly available. It usually takes 2-3 weeks for the technical board to formulate its clarification.


 
ID: 020
Date: 11. May 2012
CFS version: 3.1 and above
Status: In Process

Clarification Request
The question was raised on “How to proceed in case the project developer is not the owner of the land, and the contract with the owner of the land included a clause which indicates the risk that the land might be used for other purposes than the project activity before the projects crediting period has ended.”   
 
Background Information
N/A 
 
Clarification Statement
N/A

 
ID: 019
Date: 08. March 2012
CFS version: 3.1 and above
Status: Active

Clarification Request
Referring to v3.1, page 22, chapter "12 Land and CO2 Tenure", criterion 3
Does the definition of long-term agreement with a landowner absolutely need to be defined by the number of years in the agreement?

Background Information
v3.1, criterion 12.3
3. Evidence must be given that the project developer is the
   a. Owner of the CO2-rights of the project area AND
   b. Owner of the land (the project area) AND
   c. Owner of the timber AND
   d. Owner of other resources (within the project area)

In case the project developer is not all of the above, evidence must be given that the respective owners agree with the expected long-term project activity.
 
Clarification Statement
No. A defined number must not be given as long as the certification body confirms the conformity of the criterion. According to v3.1, page 25, chapter "G. Certification", criterion 12:

12. The means applied by the certification body in order to confirm criteria of the CarbonFix Standard include, but are not limited to:
• a desk review
• a literature confirmation
• a field visit
• interviews

In reference to this criterion (v3.1, criterion 12.3), the term "long-term" refers at the least to the time of the project's crediting period.


 
ID: 018
Date: 19. January 2012
CFS version: 3.2 and above
Status: Active

Clarification Request
Please clarify whether criterion 7 of chapter 10 still has to be met, in case a project wants to execute a MU certification and is already certified according to CFS v3.0 or earlier?
 
Background Information
With v3.2 of the CarbonFix Standard the following criterion was added:

Page 16, Chapter "10 - Capacities", Financial Capacity, criterion 7
7. If two or more of the following points apply, the project is only allowed to assign 50% of its future CO2-certificates until the first successful monitoring certification - however at the earliest 3 years after the initial certification:
- The project financier has not managed other projects (not necessarily in forestry) of similar financial scale, yet.
- The organization of the project developer was founded earlier than 5 years ago.
- The project is located in a country which is ranked in the second half of Land Property (LP) rating by IPRI.
 
Furthermore, the standard says:
Page 39, Chapter "007 - Adaptation of the Standard", criterion 5
5. Adaptations of the standard shall not discredit earlier certifications of a project.
 
Clarification Statement
The technical board decided to modify the criterion to the following:
 
7. If two or more of the following points apply, the project can only assign, at the most, up to 50% of its future CO2-certificates during the first 2 years after the initial certification:
- The project financier does not have previous experience managing other projects (not necessarily in forestry) of similar financial scale.
- The organization of the project developer was founded more than 2 years ago.
- The project is located in a country which is ranked in the second half of Land Property (LP) rating by IPRI.

With this modification, the technical board avoids any invalidation of projects that have been certified with earlier versions of the CarbonFix Standard.
 
 
 
ID: 017
Date: 13. January 2012
CFS version: all
Status: Active

Clarification Request
Please provide guidance on criterion 2 of the chapter 'Additionality'.
 
Current criterion:
2. Evidence must be given that the most likely without-project-scenario would not lead to an increase of ‘woody biomass’ on the eligible planting area.
If this is not the case, the baseline must refer to the biomass that would have been on the area in the long-term.
 
Background Information
N/A
 
Clarification Statement
The technical board decided to adopt the following criterion: 

New criterion
2. Evidence must be given that the most likely without-project-scenario would not lead to an increase of ‘woody’ or 'non-woody' biomass on the eligible planting area.
If this is not the case, the baseline must reflect the biomass that would have been on the area over the projects crediting period.

 
 
ID: 016
Date: 10. January 2012
CFS version: all
Status: Active

Clarification Request
What settings does an insurance have to fulfill in order to be accepted under the CarbonFix Standard to lower the buffer to 20%? 

Background Information
N/A
 
Clarification Statement
1. An insurance must be able to cover potential losses which effect assigned CO2-certificates. Hereby, buffer CO2-certificates (the remaining 20%) are also considered as assigned CO2-certificates.
2. Potential losses shall be covered by the insurance using one or several of the following means:
    - replanting of the destroyed forest area
    - additional planting of new areas
    - purchasing of CO2-certificates from other CFS certified projects
3. An insurance must be a monetary fund that can only be accessed for the activities described under criterion 2. 

 
 
ID: 015
Date: 13. December 2011
CFS version: all
Status: Active

Clarification Request
Can parts of the inital certification take place even before the pre-validation of a project has successfully been finished?

Background Information
A project developer is asking this question due to a long snow period, where a field visit would not be possible for the certification body.
 
Clarification Statement
The technical board decided to adapt the following criterion: 

Previous criterion:
003 Certification, 4.  The process of the initial certification must start within 3 months after a successful pre-validation.
 
Updated criterion:
003 Certification, 4.  The process of the initial certification must start at the latest 3 months after a successful pre-validation.

With this adaptation, it will be possible for the certification bodies to start the initial certification prior to the completion of the pre-validation.
 
 
 
ID: 014
Date: 25. October 2011
CFS version: all
Status: Active

Clarification Request
Can fruit trees which form a forest gain CFS certification?

Background Information
N/A
 
Clarification Statement
Yes. There is no differentiation made between fruit trees and 'normal' trees. 
 
 
ID: 013
Date: 05. November 2011
CFS version: all
Status: Active

Clarification Request
Can a project use the CarbonFix methodology without generating carbon credits?

Background Information
The owner of a reforestation project in India wants to know how much CO2 is fixed by its tree planting activities.
 
Clarification Statement
Projects are allowed to use the CFS methodology to determine their CO2-fixation without going through a certification process in case the project will not issue or assign any CO2-certificates thereafter. How these projects are able to label their determined amount of CO2-reductions is described by the assisting document ‘Communication Package’.  

The non-profit organization CarbonFix invites these projects to make donations to CarbonFix for its work on developing the methodology.
 
 
ID: 012
Date: 23. September 2011
CFS version: 3.1 and earlier
Status: Active

Clarification Request
How should evidence be given that all tree species are site-adapted under changing climatic conditions? 
(chapter '04 Environmental Aspects').

Background Information
N/A
 
Clarification Statement
The aim of this criterion is to ensure that the project developer becomes aware of the foreseeable climatic changes that will occur on the project area in the following decades. The technical board of CarbonFix realizes that for many tree species it is not possible to find true evidence on how they will react under changing climatic conditions; still with the analysis of climate change tendencies, it is possible to estimate which tree species should be preferred or avoided.
 
 
ID: 011
Date: 05. September 2011
CFS version: 3.0 and earlier
Status: Active

Clarification Request
CFS has changed the frequency of certification in version 3.1. Which frequency is valid for projects certified with earlier versions ?

Background Information
N/A
Clarification Statement
For all projects the frequency of certification of the most recent version is valid.
 

ID: 010
Date: 16. August 2011
CFS version: 3.1
Status: Active

Clarification Request
Is it possible to register a bamboo forest in Mexico under the CFS?
 
Background Information
Definition of forest according to CFS:

Page 7, Chapter: Eligibility
A forest is defined by the Designated National Authority (DNA) of the projects host-country: http://cdm.unfccc.int/DNA. In case no forest definition is yet given by the DNA, the project developer can take the forest definition of the FAO: http://www.fao.org/docrep/003/x6896e/x6896e0e.htm or the national forest definition of the project’s host country.

In the case of Mexico, the DNA has provided a definition of forest according to the criteria of UNFCCC. Still, according to a clarification request (AR-AM_CLA_0003) of the A/R CDM working group (in Apr 2008), the DNA of a country must clarify additional to its regular A/R CDM national forest definition, if it wants to include forest of bamboo or palm trees in its national forest definition.

The DNA of Mexico has not yet decided upon this clarification.

According to the definition of the FAO (http://www.fao.org/docrep/003/x6896e/x6896e0e.htm) bamboo and palms can be considered as trees and can therefore form a forest.
 
Clarification Statement
The technical board has decided upon the following clarification statement:

Without the clarification of the DNA whether bamboo and palm trees are considered a forest, the decision falls back to the criteria of the FAO forest definition. Hence bamboo and palm trees can be considered as forests. 

However, the remaining defining criteria of the DNA still apply: e.g. the crown cover, the minimum land area, and tree height. These criteria must be met by the bamboo or palm tree forests.

Finally, evidence must be given that no other existing national forest definition exists, which excludes forests of bamboo and palm trees.
 

ID: 009
Date: 7. July 2011
CFS version: 3.1
Status: Implemented v3.2

Clarification Request
Can a project developer consist of several parties?
 
Background Information
Current definition of project developer:

The project developer prepares the project information for the certification process and bears the liability towards the CO2-buyer and the CarbonFix Association. He is the main contact person of the project.
 
Clarification Statement
The technical board has decided upon the follow change of the definition of the term project developer:

Previous definition:
The project developer prepares the project information for the certification process and bears the liability towards the CO2-buyer and the CarbonFix Association. He is the main contact person of the project.

Updated definition:
The project developer is a person or legal entity that prepares the project information for the certification process and bears the liability towards the CO2-buyer and the CarbonFix Association. He is the The project developer must identify a main contact person of the project.


As the project developer can be a legal entity, this entity can consist of several parties.


ID: 008
Date: 09. March 2011
CFS version: 3.1
Status: Implemented v3.2

Clarification Request
Is it possible to gain CFS certification for projects where a forested area 
1. has been planted without the vision of becoming a climate project, and
2. where this forested area has not yet reached the 'forest' definition of the projects host-country, and
3. where this forested areas would be cut down (and not be reforested), if the farmer does not get a higher revenue from the forest (e.g. due to carbon money).

Background Information
N/A

Clarification Statement
The technical board is aware that version 3.1 does not clarify this question to its full extent. As these types of projects fulfill the core vision of the CarbonFix Standard to enable 'non-forest' areas to become 'forest' areas due to the additional financial means of carbon money, the following criteria will be adapted in version 3.2 of the CarbonFix Standard and can already now be used for the purpose of certification according to CFS v3.1: 

Terms - 19) Project start
Current: The project start is the date when the planting of the first trees took or will take place.
New: The project start is when the project was firstly seriously considering to start with the project activities. 

Terms - 20) Project lifetime
Current: The lifetime of a project must be minimum 30 years from the year of the project start.
New: The lifetime of a project must be minimum 30 years from the year the project was first certified.

00 Transparency - Criterion 3b)
Current: The certification body may require to upload shapefiles with the following information:  b. Land-use classes of the project area 10 years prior to project start.
New: The certification body may require to upload shapefiles with the following information:  b. Land-use classes of the project area 10 years prior the projects planting time.

01 Eligibility - Criterion 2c)
Current: Planting area is only eligible, if the land:  c. has not been forest within 10 years prior to the project start ...
New: Planting area is only eligible, if the land:  c. has not been forest within 10 years prior to the project's planting time  ...

08 Baseline - Criterion 1)
Current: The baseline is the woody and non-woody biomass on the eligible planting area just before the project start.
New: The baseline is the woody and non-woody biomass on the eligible planting area just before the project's planting time.


ID: 007
Date: 07. February 2011
CFS version: 3.1
Status: Implemented v3.2

Clarification Request
Is it required to conduct an onsite visit of the audit team for a “Management Unit certification” (see section G. 10-12 of CFS v.3.1 and respective sections of previous standards).

Further, please specify, whether the overall project design, including additionality, of the Management Unit in relation to the overall registered project need to be checked in such type of certification.

Background Information
N/A

Clarification Statement
The technical board is aware that Version 3.1 does not clarify whether a field visit has to be executed for the purpose of a "Management Unit certification". In Version 3.2 of the CarbonFix Standard this question will be clarified through an adaption of the standard. Up to the release of Version 3.2, we leave it to the certification body to decide whether a site visit is necessary to assure compliance to the respective criteria.


ID: 006
Date: 09. February 2011
CFS version: 2.1
Status: Implemented v3.1

Clarification Request
... during the resolution of the material issues identified the client has requested to expand the project area to include additional land that was not included in the pre-validated project area.  As such I am not clear if this allowed by the CarbonFix Standard. Following the initial pre-validation by the CarbonFix Standard, can the project area expand?  

Background Information
N/A

Clarification Statement
According to the analysis of the technical board of CarbonFix, Version 2.1 of the CFS does not clarify your question, therefore the technical board has decided upon the following answer of your question:

With v2.1 it is not defined what the output of a pre-validation is. The definition of v3.1 is used.
According to CFS v3.1 "... a pre-validation process assesses whether a project is likely to meet the criteria of the CFS in the certification process."

Also here, it is not defined if a project must submit the same information to the initial certification as to the pre-validation. Still, the underlined word "project" indicates that the definition of a project is leading. According to v2.1 a project is defined in the following way:
A project must consist of planting areas with similar socioeconomic and ecological attributes and similar impacts* to its socioeconomic and ecological environment.
* The impact is judged by the certification body, and in case of dispute by the technical board.

Therefore, the certification body shall evaluate if the newly added MUs lead to an adaptation of the project as defined in v2.1. Therefore, if the new MUs do not change the project definition, they can be added.
 

ID: 005
Date: 07. April 2010
CFS version: 3.0
Status: Implemented v3.1

Clarification Request
Please clarify if under Version 3.0 of the CarbonFix Standard it is the case that the carbon pool „Dead wood” must not be considered when determining the parameter “Leakage”.

Background Information
N/A

Clarification Statement
No, the carbon pool „Dead wood” must not be considered when determining the parameter “Leakage”.

The technical board is aware that Version 3.0 does not include any differentiation of living and dead biomass for the different carbon pools. This was a mistake in the review process and will be revised in Version 3.1.
 

ID: 004
Date: 02. April 2010
CFS version: 2.1
Status: Active

Clarification Request
Please clarify if organic fertilizer (e.g. compost) shall be considered as fertilizer for calculation of project emissions (3.4.2). If this was the case a estimation of nitrogen content would be needed. A default approach might be helpful in this case.
 
Background Information
N/A

Clarification Statement
Yes, organic fertilizer must also be accounted for. 

No differentiation is made between synthetic and organic fertilizer. Applying organic fertilizer requires an estimation of the nitrogen content in the type of fertilizer used.


ID: 003
Date: 17. March 2010
CFS version: 2.1
Status: Inactive - Revision of criterion

Clarification Request
In case ploughing is limited to planting, but area-wide, is a respective project activity not eligible under CFS? (2.1.12)
 
Background Information
N/A

Clarification Statement
In cases where ploughing (spot ploughing or area-wide) is used for the purpose of planting, the planting area is eligible.
 
(The technical board points to the fact that version 3.0 of the CFS states that “Evidence must be given that no project activities will lead to a long-term increase of emissions within the carbon pool ‘soil’.” Future certification must therefore also proof that this criterion is met). 


ID: 002
Date: 17. March 2010
CFS version: 2.1
Status: Inactive - Revision of criterion

Clarification Request
Please define “area-wide” (in the context of ploughing). Is this referring to total project area, planting area, or area of a respective stratum?

Background Information
N/A

Clarification Statement
”Area-wide” refers to the eligible planting area of a project.


ID: 001
Date: 17. March 2010
CFS version: 2.1
Status: Active

Clarification Request
Please clarify what is considered to be “environmental appropriate way” for waste disposal. (2.1.9)

Background Information
N/A

Clarification Statement
The technical board is aware that most projects are located in countries where there are no functioning waste systems in place. The separation of waste into organic and inorganic materials is seen as essential meeting the requirements of an “environmental appropriate way”. The disposal of inorganic materials must be evaluated by the certification body according to the state of the project.