CRCF Biomass Feedstock Accounting v1.0

1.0

Introduction

This Module establishes the additional requirements associated with the use of feedstocks as part of carbon dioxide removal Activities. This Module is exclusively for use in combination with the relevant CRCF compliant Protocol to ensure that any carbon credits generated in accordance with the given methodology are also compliant with the requirements as laid out in the Isometric Biomass Feedstock Accounting Module.

For more information and increased guidance on demonstrating compliance with the criteria outlined below, please see the Isometric Biomass Feedstock Accounting Module.

This Module establishes the requirements associated with the use of feedstocks as a part of carbon dioxide removal Activities. This includes setting out criteria for feedstocks in relation to sustainability, counterfactual storage and market leakage. This Module also provides methods for the quantification of counterfactual storage and market leakage to determine eligible feedstocks. This Module is currently applicable to the following feedstocks:

Forestry residues and downstream wood processing residues
Agricultural residues
Industrial residues
Municipal wastes
Invasive species

Every Operator must consider specific alternative uses of feedstocks that would have occured in the absence of the Activity. The baseline scenario must be considered relative to each feedstock used if the Activity utilizes multiple feedstock types, in line with the relevant section of the Isometric Standard. If an Activity uses any feedstock that is deemed ineligible by this Module, this feedstock will not count towards Crediting. If an Activity utilizes ineligible biomass for alternative uses in excess of 25% of the feedstock mass in a given Certification Period, removals within the Certification Period will not be Credited by Isometric.

The current approach outlined in this Module provides:

Sustainable sourcing criteria that aim to ensure feedstocks are sourced without threatening the sustainability of the upstream resource, environment or community.
Counterfactual storage criteria to ensure removals provide near-term climate benefits.
Market leakage criteria to assess the full emissions impact of feedstock utilisation outside the system boundary.

2.0

Sustainability Criteria

All biomass, biofuel, bioliquid or biomass fuel that is used to generate the CO₂ captured by the activity or as a feedstock for biochar production and any additional biomass, biofuel, bioliquid or biomass fuel consumed to produce energy for the activity must comply with one of the sets of requirements in Table 1. Applicable requirement sets depend on the feedstock characteristics and source. The documentation required must be submitted as part of each re-certification audit to ensure continued sustainability, the operator must either produce new evidence that the relevant sustainability criteria are met, or ensure the existing evidence submission is up-to-date.

Table 1

Sustainability Criteria
ID	Criteria	Documentation Required
SC1	Activities using forestry residues and downstream wood processing residues must comply with all the following criteria:
SC1.1	The feedstock must be sourced from an approved forestry certification or management program listed in Table A1 or from a region subject to an equivalent risk assessment.	The Operator must provide all of the following: Evidence that the feedstock is sourced from an area or entity under a listed certification or management program, including evidence of the certification applicability and chain-of-custody. Where this cannot be evidenced, the Operator must provide an independent, third-party, risk based determination of low risk that a feedstock from the sourcing area is non-compliant with the principles equivalent to the FSC Forestry Management Principles and Criteria, in consultation with Isometric. Any additional documentation as required in Table A1.
SC1.2	Operators must demonstrate that woody biomass feedstocks - including both forestry residues and downstream wood processing (mill) residues - are sourced from areas of stable or increasing forest carbon stocks.	The Operator must provide one of the following: Evidence that the feedstock sourcing complies with the requirements in Article 29, paragraph 7 of Directive (EU) 2018/2001. Note that this paragraph within the Directive does not apply to mill residues, while Isometric mandates that mill residues must also demonstrate stable or increasing carbon stocks in the sourcing region. An independent third-party assessment that demonstrates the forest carbon stocks encompassing the sourcing region[^1] has not experienced a net decrease over the last 5 years compared to the 5 years previous to that. Where this assessment cannot be provided, the following may be considered with appropriate justification: Evidence that the average LULUCF of the state/country does not exceed the regeneration of the forest carbon stocks over the last 5 years. This is demonstrated if the net emissions are zero or under, as reported in the UNFCCC. In countries where the harvesting exceeds 5 million km², additional evidence that forest carbon stocks have not decreased over the previous 10 years is required.
SC1.3	Operators must demonstrate that woody biomass feedstocks, including both forestry residues and downstream wood processing (mill) residues, are not sourced from a primary forest.	The Operator must provide one of the following: Evidence that the feedstock sourcing complies with the requirements in Article 29, paragraph 6 of Directive (EU) 2018/2001. Note that this paragraph within the Directive does not apply to mill residues, while Isometric mandates that mill residues must also demonstrate stable or increasing carbon stocks in the sourcing region. Evidence that the sourcing region, or wider jurisdiction does not contain any primary forests. An independent. risk based sourcing area assessment confirming no clear risk of sourcing from primary forests. Chain of custody documentation tracing the residue to its sourcing region and an assessment, referencing datasets such as Global Forest Watch or equivalent, confirming the sourcing region contains no primary forests.
SC2	Retrofit/additive Activities using forestry residues and downstream wood processing residues must comply with all the following criteria:
SC2.1	The feedstock must be sourced from an approved forestry certification or management program listed in Table A1 or Table A2 or from a region subject to a equivalent risk assessment.	The Operator must provide all of the following: Evidence that the feedstock is sourced from an area or entity under a listed certification or management program, including evidence of the certification applicability and chain-of-custody. Where this cannot be evidenced, in consultation with Isometric, the Operator must provide an independent, third-party, risk based determination of low risk that a feedstock from the sourcing area is non-compliant with the principles equivalent to those considered by the programs listed in Table A1 or Table A2. Any additional documentation as required in Table A1 or Table A2.
SC2.2	The Baseline Feedstock Consumption Rate and associated feedstock sourcing for the facility must be demonstrated.	The Operator must provide one of the following: Evidence of the facility feedstock input data, including feedstock sourcing and quantity, for the previous 5 years prior to the installation of retrofit infrastructure. Evidence that the Baseline Emission Rate is greater than the Maximum Biogenic Carbon Utilization Rate (See Appendix 4 of the Biomass Feedstock Accounting Module for details) and evidence of any feedstocks sourced to meet the parasitic load energy demands/reductions in primary output and how these are accounted for.
SC2.3	Any feedstock that is sourced over the Baseline Feedstock Consumption Rate must adhere to SC1 in order to be eligible for Crediting (See Appendix 4 of the Biomass Feedstock Accounting Module for details). This includes any material sourced to meet the parasitic energy load or reductions in primary output that result from the retrofit infrastructure. Activities that cannot satisfy this criteria are still eligible for crediting for removals corresponding to the baseline feedstock.	The Operator must provide one of the following: Evidence that there is no change to the feedstock sourcing behavior of the facility. Evidence demonstrating that the excess feedstock is assessed as a separate feedstock adhering to SC1. Evidence of the quantity of excess ineligible feedstock sourced over the Baseline Feedstock Consumption Rate and a demonstration of how this will be subtracted from gross removals. Evidence that the Baseline Emission Rate is greater than the Maximum Biogenic Carbon Utilization Rate (See Appendix 4 for details) and that sufficient feedstocks to meet the parasitic load energy demands/reductions in primary output are assessed as a separate feedstock adhering to SC1.
SC3	Activities using crop residues must comply with all the following criteria:
SC3.1	The feedstock must not be sourced from land converted to agriculture in the past 5 years.	Evidence that the sourcing region has been agricultural land for at least 5 years prior to the Operator's first procurement date. This must be demonstrated through historical crop plans, output records or remote sensing.
SC3.2	The feedstock must not be sourced from the same acreage in consecutive years unless monocropping can be demonstrated for the previous 5 years.	The Operator must provide one of the following: Feedstock purchase contracts between the Operator and the feedstock supplier. The output/utilisation data of the acreage for 5 years prior to the Operator's first procurement date.
SC4	Activities using animal agriculture residues must comply with the following criterion:
SC4.1	The feedstock is not sourced above the Baseline Feedstock Generation Rate (See Appendix 4 of the Biomass Feedstock Accounting Module for details).	Data from 2 years prior to the Operator's first procurement date demonstrating the Baseline Feedstock Generation Rate and the proposed mass to be procured by the Operator.
SC5	Activities using food processing, landscaping or other industry residues must comply with the following criterion:
SC5.2	The feedstock must not be sourced above the Baseline Feedstock Generation Rate (See Appendix 4 of the Biomass Feedstock Accounting Module for details).	Data from 5 years prior to the Operator's first procurement date demonstrating the Baseline Feedstock Generation Rate and the proposed removal rate by the Activity.
SC6	Activities using municipal waste must comply with the following criterion:
SC6.1	The feedstock must be designated as a municipal waste.	Evidence that the feedstock was obtained, produced or diverted from a municipal waste facility. This could include evidence of waste classification and a site waste permit, or a waste management contract with a local authority.
SC7	Activities using invasive species must comply with all the following criteria:
SC7.1	The feedstock sourcing must include sufficient safeguards to ensure there is a low risk of spreading the invasive species to other ecosystems.	Evidence of the harvest plan for the invasive species detailing approaches to ensure the risk of spreading is minimised.
SC7.2	The feedstock sourcing must be part of a broader ecosystem management activity taken by local, state or federal governments, non-profit organisations or private landowners.	The Operator must provide all of the following: Evidence of the invasive species (native or non-native) classification by an authority for the feedstock to be sourced. Documentation of management activities for the purpose of invasive species removal. All biomass, biofuel, bioliquid or biomass fuel that is used to generate the CO₂ captured by the activity or as a feedstock for biochar production and any additional biomass, biofuel, bioliquid or biomass fuel consumed to produce energy for the activity must comply with one of the following sets of requirements, depending on the feedstock sourcing practices.

3.0

Counterfactual Criteria

When feedstocks are used for Activities, each eligible unit of stored carbon will be Credited as CO₂e. However, not all removed and stored carbon is considered environmentally additional from a climate impact perspective. To accurately determine an Activity's climate impact, the Operator must assess if the feedstock's biogenic carbon would have been released into the atmosphere in the near term (e.g., through burning or rapid decay), termed $CO_2e_{CounterfactualEmissions}$ , or if this carbon would have remained durably stored, termed $CO_2e_{Counterfactual}$ . Only the fraction that would have been emitted in the absence of the Activity will be Credited as an environmentally additional removal.

Accounting for counterfactual storage ensures Credits accurately reflect the Activity's actual climate impact, preventing overstatement of removals by accounting for carbon that would have stayed out of the atmosphere for long periods regardless of the Activity.

Operators must demonstrate that the counterfactual fate has been properly assessed and the counterfactual storage has been appropriately quantified. Once a feedstock's counterfactual fate has been established, it's determined fate is valid for the Activity Period provided the feedstock sourcing does not change. Under exceptional circumstances where Isometric identifies a significant change to the understood counterfactual fate, Isometric reserves the right to conduct an audit to ensure feedstocks continue to meet the criteria laid out in this Module. Typically the historical fate of the feedstock is a good indicator of the future counterfactual fate of the feedstock absent the Activity. To assess the counterfactual fate of the feedstock, at least one of the following pieces of evidence must be provided by the Operator:

Historical evidence of the counterfactual fate of the feedstock over the last 5 years provided by the feedstock supplier.
Purchase records or a contractual clause in purchase records confirming the counterfactual fate of the feedstock over the last 5 years.
Regulatory enforcement that shifts the counterfactual fate.
An assessment of the expected fate over the last 5 years of the feedstock given the most economically viable option in a given sourcing area, including all data, documentation and assumptions used.
Retrofits can evidence the counterfactual as the pre-retrofit scenario (e.g., combustion with emissions released for bioenergy Activities).
In some cases, an affidavit from the feedstock supplier confirming the counterfactual fate of the feedstock may be considered.

All feedstocks eligible for crediting must meet one of the criteria listed in Table 2 to evaluate counterfactual storage.

Where $CO_2e_{Counterfactual} \gt 0$ :

$CO_2e_{Counterfactual}$ must be subtracted directly from $CR_{total}$ .

Table 2

Counterfactual Storage Criteria
ID	Criteria	Documentation Required
Operators must demonstrate compliance with at least one of the following criteria for each feedstock. Notable examples where more than one must be satisfied include a BioCCS retrofit that can reference combustion for the consumption of feedstock for the underlying facility, but increases the demand for biomass to satisfy a parasitic energy requirement and therefore must reference a different counterfactual fate for this marginal biomass.
CC1	The $CO_2e_{Counterfactual}$ of the feedstock is quantified.	The Operator must provide a quantification of $CO_2e_{Counterfactual}$ including all documentation, data-sets, references and assumptions associated with the calculation of counterfactual storage.
CC2	Feedstock is sourced through a government managed, funded or otherwise supported wildfire mitigation program. The $CO_2e_{Counterfactual}$ of these feedstocks is 0.	The Operator must provide evidence that the feedstock originates from a government mandated, managed or otherwise supported wildfire mitigation program, including evidence of program participation and chain-of-custody.
CC3	The feedstock is rapidly oxidised or reduced such as in a high temperature environment in the counterfactual, such as an incinerator or open pit burn, resulting in negligible durable carbon storage in the counterfactual. This can include Operators that retrofit existing facilities that combust feedstock. The $CO_2e_{Counterfactual}$ of these feedstocks is 0.	The Operator must provide evidence of the feedstocks rapid oxidation/reduction in the counterfactual, such as disposal/end-use records, supplier affidavits or records of existing feedstock consumption at baseline facilities in the case of retrofits. In the case of retrofits/additive facilities, Operators must ensure that increased feedstock sourcing due to the Activity, such as to provide heat or electricity for the capture facility, is accounted for under another counterfactual criteria.

Feedstocks that do not meet CC1 or CC2 within Table 2 must quantify counterfactual storage. Biogenic carbon that would likely remain stored in the biomass in the counterfactual is considered counterfactually stored. Counterfactual storage is a quantified measurement of stored biogenic carbon, and takes into account the amount of biogenic carbon within the feedstock and the emissions associated with the release of the biogenic carbon.

Counterfactual storage is reported in CO₂e units. Counterfactual emissions are evaluated as the CO₂e using the 100-year Global Warming Potential (GWP), GWP₁₀₀, of all released GHGs within 15 years. The most recent volume of the IPCC Assessment Report should be used (currently the Sixth Assessment Report) to represent the GWP₁₀₀ of GHGs.

If all stored biogenic carbon within the feedstock would be emitted within 15 years in the counterfactual, then $CO_2e_{Counterfactual} = 0$ . If CO₂e emissions within 15 years exceed the equivalent stored biogenic carbon within the feedstock at 15 years, counterfactual storage can be quantified by the amount of biogenic CO₂e that is stored after 50 years. This is to increase the eligibility of feedstocks that have a disproportionately large near-term release of GHGs with a GWP₁₀₀ >1 in the counterfactual.

Equation 1 and equation 2 must be used to quantify the total CO₂e that is ineligible for Crediting.

 $CO_2e_{Counterfactual,\ x}\ \ = \ \ CO_2e_{Feedstock} \ \ - \ \ CO_2e_{CounterfactualEmissions}$

(Equation 1)

 $CO_2e_{CounterfactualEmissions} \ \ = \ \ min(CO_2e_{CounterfactualEmissions15}, \ \ CO_2e_{Feedstock}\ \ - \ \ CO_2e_{CounterfactualStorage50})$

(Equation 2)

Where:

$CO_2e_{Counterfactual,\ x}$ - The mass of biogenic carbon that is ineligible for crediting, in tonnes of CO₂e, for batch $x$ .
$CO_2e_{Feedstock}$ - The mass of biogenic carbon within the feedstock, in tonnes of CO₂e, for batch $x$ .
$CO_2e_{CounterfactualEmissions}$ - The mass of biogenic carbon eligible to count towards gross removals, in tonnes of CO₂e, for batch $x$ .
$CO_2e_{CounterfactualEmissions15}$ - The mass of CO₂e emissions that would be emitted from the feedstock in the counterfactual within 15 years, for batch $x$ .
$CO_2e_{CounterfactualStorage50}$ - The mass of biogenic carbon within the feedstock that would remained stored in the counterfactual after 50 years, in tonnes of CO₂e, for batch $x$ .

For each Certification Period, $CO_2e_{Counterfactual}$ must be aggregated across all feedstock batches, where $n$ is the total number of batches:

 $CO_2e_{Counterfactual}\ \ =\ \ \sum_{x=1}^{n}\ CO_2e_{Counterfactual,\ x}$

(Equation 3)

Where:

$CO_2e_{Counterfactual}$ - The total mass of biogenic carbon that is ineligible for crediting, in tonnes of CO₂e.

4.0

Permissible Feedstocks

Certain feedstocks are deemed ineligible by this Module due to the associated high risk of significant market leakage. These include cases where the feedstock was cultivated for the purpose of food, feed, energy or use in BiCRS as well as materials used in long-lived wood products such as construction materials and furniture. There are exceptions under specific circumstances. To establish feedstock eligibility, the feedstock must meet the relevant criterion outlined in Table 3. Once a feedstock has demonstrated compliance with the relevant criterion, this is valid for the Activity Period.

Table 3

Permissible Feedstock Criteria
ID	Criteria	Documentation Required
PF1: All Activities utilising non-woody feedstocks must demonstrate compliance with both of the following criteria for each feedstock.
PF1.1	The feedstock must not have been produced for bioenergy applications. This does not affect the use of residues that have fulfilled their purpose for energy generation (e.g., post anaerobic digestion manure).	The Operator must provide evidence that the feedstock was not produced for bioenergy use for 2 years prior to the Operator's first procurement date.
PF1.2	The feedstock must not have been used for food or feed in the counterfactual.	The Operator must provide evidence that the feedstock was not produced for food or feed use for 2 years prior to the Operator's first procurement date.
PF2: All Activities using woody feedstocks must demonstrate compliance with the of the following criterion for each feedstock:
PF2.1	The feedstock must not be diverted from use as a component of long-lived wood products or pulpwood (e.g, construction materials, furniture, fiberboard etc.). Feedstocks that have fulfilled their use as long-lived wood products or pulpwood are eligible if they cannot be further repurposed. Residues from wood processing are eligible if non-marketable or marketed only for bioenergy, landscaping or mulch over the previous 2 years.	Operators must provide one of the following: Evidence of the feedstock lifecycle including generation and utilisation/disposal for 2 years prior to the Operator's first procurement date. Evidence that the feedstock characteristics make the feedstock unsuitable for use in long-lived wood products or pulpwood. Evidence that the feedstock is sourced by, or to meet the clear goals of, a government supported wildfire mitigation program, including evidence of program participation and chain-of-custody.

5.0

Market Leakage

Sourcing feedstocks for the purpose of BiCRS Activities can lead to an increase in GHG emissions resulting from changes to the supply and demand equilibrium, also called market leakage. For example, the sourcing of a feedstock above the Baseline Feedstock Generation Rate could lead to increased feedstock production (e.g., land use change). This can also occur when removed feedstocks exceed the Sustainable Usage Rate, leading to demand for a replacement product (e.g., fertilizer).

All feedstocks must select a market leakage assessment and meet all criteria within the selected assessment as laid out in Table 4 (e.g., ML5.1 and ML5.2) for the evaluation of market leakage emissions, termed $CO_2e_{MarketLeakage}$ . Once a feedstock has demonstrated compliance with the relevant criterion, this is valid for the Activity Period.

Where $CO_2e_{MarketLeakage} \gt 0$ :
Market leakage must be aggregated across all relevant CRCF Isometric Modules and subtracted from the quantification of $CR_{total}$ by adding the term $CO_2e_{MarketLeakage}$ to $GHG_{associated}$ .

Table 4

Market Leakage Criteria
ID	Criteria	Documentation Required
All Operators must demonstrate compliance with one of the following criteria sets for each feedstock.
ML1: All Activities that cannot demonstrate zero market leakage for their feedstocks using the other criteria within this table must quantify market leakage to demonstrate compliance with this criterion.
ML1.1	The $CO_2e_{MarketLeakage}$ of the feedstock is quantified.	The Operator must quantify the emissions associated with market leakage and provide the documentation used in this quantification including references, data sets and assumptions.
ML2: BioCCS retrofit/additive Activities that can demonstrate the capture capacity of the Activity would be reached by the pre-Activity emission generation rate of the underlying facility. For feedstocks that comply with this criteria, $CO_2e_{MarketLeakage}$ = 0.
ML2.1	The Maximum Biogenic Carbon Utilisation Rate of the CCS infrastructure does not meet or exceed the Baseline Emission Rate. This criteria allows for the qualification of a feedstock mass that does not exceed the Maximum Biogenic Carbon Utilisation Rate, after subtracting both the Baseline Emission Rate and any parasitic load of the retrofit infrastructure. All values are expressed in feedstock equivalent units.	The Operator must provide documentation demonstrating the Baseline Emission Rate over the last 5 years and an evidenced calculation of the Maximum Biogenic Carbon Utilisation Rate of the CCS infrastructure (See Appendix 4 in the Biomass Feedstock Accounting Module for calculation requirements).
ML3: Retrofit/additive Activities that can reference the consumption of the underlying facility as the fate of some/all of the feedstock prior to the Activity. For feedstocks that comply with this criteria, $CO_2e_{MarketLeakage}$ = 0.
ML3.1	The feedstock consumption of the underlying facility is clearly defined.	The Operator must provide one of the following: Evidence of the baseline feedstock consumption rate for the underlying facility including quantity and sourcing. A demonstration that the Activity will not alter the underlying feedstock demand for feedstock such as a bioenergy facility that can demonstrate how the energy requirements for the facility will be satisfied, through Activity attributable facility upgrades or other power import/generation.
ML3.2	All feedstock sourced over the baseline, specifically sourced to generate additional CDRs or power the capture infrastructure must be accounted for under a different market leakage criteria.	The Operator must provide one of the following: A demonstration that the marginal feedstock has been accounted for under a separate market leakage criteria with all documentation requirements satisfied. A demonstration that the Activity will not alter the underlying feedstock demand for feedstock such as a bioenergy facility that can demonstrate how the energy requirements for the facility will be satisfied, through Activity attributable facility upgrades, changes to the the energy export or other power import/generation.
ML4: Activities that do not contribute significantly to the revenue of the feedstock supplier must demonstrate compliance with the following criterion. For feedstocks that comply with this criteria, $CO_2e_{MarketLeakage}$ = 0.
ML4.1	The Activity provides limited upstream incentives to the feedstock supplier, including aspects such as feedstock payments, revenue sharing or service provision.	The Operator must provide one of the following: A purchase agreement demonstrating no revenue contribution is made to the feedstock supplier beyond recovery and transportation costs of the feedstock. This includes cases where the feedstock is received free of charge, or the Operator is paid a tipping fee to take the feedstock. A signed affidavit from the feedstock supplier or feedstock aggregator demonstrating there is no revenue contributions exceeding the recovery and transportation costs made to the feedstock supplier.
ML5: The feedstock serves an economic purpose where supply exceeds demand. For feedstocks that comply with this criteria, $CO_2e_{MarketLeakage}$ = 0.
ML5.1	The Operator can demonstrate a local supply excess (e.g., stable or growing stockpiles), that the Activity won't exceed.	The Operator must provide one of the following: Historical contracts between the feedstock supplier and the end-use/disposal sites demonstrating disposal of a volume of feedstock equivalent to Activity demand. A quantification of the Baseline Feedstock Generation Rate over the previous 5 years (See Appendix 4 of the Biomass Feedstock Accounting Module for details) demonstrating supply exceeds demand, including pre-Activity off-takes and Activity demand. Periods of less than 5 years will be assessed on a case-by-case basis. Evidence of a standing stockpile that is equivalent or greater in mass than the Activity demand. This must be demonstrated as a persistent stockpile. Historical look-back periods depend on the feedstock. An affidavit from the feedstock supplier demonstrating the historical fate of the feedstock, subject to third-party verification, with corroborating evidence such as literature, interviews or time-series observations.
ML5.2	The contribution made by the Operator to the feedstock supplier do not incentivise increased production of the feedstock.	The Operator must provide one of the following: An affidavit from the feedstock supplier confirming that the revenue contributed by engagement with the Activity does not shift feedstock production practises corroborated by purchase agreements or other evidence. Evidence of all marketed products associated with the feedstock production, a quantification of marketed products production per unit of feedstock and an evidenced price point for the sum of the products produced demonstrating that revenue contributions constitute less that 5% of the feedstock supplier's revenue.
ML6: The feedstock has no economic purpose. For feedstocks that comply with this criteria, $CO_2e_{MarketLeakage}$ = 0.
ML6.1	The feedstock will not be used above the rate at which it is generated.	The Operator must provide one of the following: Historical contracts between the feedstock supplier and the end-use/disposal sites demonstrating disposal of a volume of feedstock equivalent to Activity demand. A quantification of the Baseline Feedstock Generation Rate over the previous 5 years (See Appendix 4 of the Biomass Feedstock Accounting Module for details) demonstrating supply exceeds Activity demand. An affidavit from the feedstock supplier demonstrating the historical fate of the feedstock, subject to third-party verification (e.g., a Certification Body), with corroborating evidence such as literature, interviews or time-series observations.
ML6.2	The contribution made by the Operator to the feedstock supplier do not incentivise increased production of the feedstock.	The Operator must provide one of the following: An affidavit from the feedstock supplier confirming that the revenue contributed by engagement with the Activity does not shift feedstock production practises corroborated by purchase agreements. Evidence of all marketed products associated with the feedstock production, a quantification of marketed products production per unit of feedstock and an evidenced price point for the sum of the products produced demonstrating that revenue contributions constitute less that 5% of the feedstock supplier's revenue.
ML7: The feedstock is currently in economic use but can be obtained at or below a Sustainable Usage Rate. For feedstocks that comply with this criteria, $CO_2e_{MarketLeakage}$ = 0.
ML7.1	The feedstock is demonstrated to serve an economic purpose and the Operator is able to demonstrate that the Activity will not exceed the Sustainable Usage Rate of the feedstock.	The Operator must provide a robust, conservative demonstration of the Sustainable Usage Rate including considerations for crop rotations, crop types, soil types etc. including all references, assumptions and data sets used.
ML7.2	The contribution made by the Operator to the feedstock supplier do not incentivise increased production of the feedstock.	The Operator must provide one of the following: An affidavit from the feedstock supplier confirming that the revenue contributed by engagement with the Activity does not shift feedstock production practises corroborated by purchase agreements. Evidence of all marketed products associated with the feedstock production, a quantification of marketed products production per unit of feedstock and an evidenced price point for the sum of the products produced demonstrating that revenue contributions constitute less that 5% of the feedstock supplier's revenue.

6.0

Appendix A

Table A1
Forestry Certification/Management programs suitable for all BiCRS Activities
Certification/Management Program	Additional Documentation Required
Forest Stewardship Council (FSC) 100% or FSC 100% chain-of-custody.
National Members of the Program for the Endorsement of Forest Certification (PEFC) 100% (e.g., SFI 100%, ATFS, SGEC, SAFAS etc.).
An equivalent forestry management/certification and chain-of-custody program. Acceptable certification programs differ depending on the Activity characteristics and sourcing.	The Operator must provide a detailed analysis of how the program is equivalent to the above programs, including forestry management principles and an auditable chain-of-custody.
A government mandated, managed or otherwise supported wildfire mitigation program.
NEPA or equivalent mandated, managed or otherwise supported forestry management and chain-of-custody program.	The Operator must provide evidence that the government collection plan is NEPA equivalent in principles and chain-of-custody oversight.

Table A2
Additional Certification/Management Programs Eligible for use by retrofit/additive Activities for feedstock sourcing directly attributable to the underlying facility and not the CDR Activity.
Certification/Management Program	Additional Documentation Required
Demonstrable compliance with the most up-to-date EU RED sustainability criteria. This must include upstream sourcing for mill residues, which is currently beyond the scope of the RED. This includes third-party verifications of compliance with the EU RED sustainability criteria, such as those provided by SURE and SBP, as well as recognised national schemes such as Sweden's Hållbarhetsbesked.	Demonstration that all forestry residues and primary mill residues (timber processing, excluding post-consumer/post-industrial wood waste) have been sourced from forestry management practices compliant with the sustainability criteria within the EU RED.
Sustainable Biomass Program (SBP)	The Operator must provide all of the following: Evidence that the forest carbon stocks are stable or increasing in the sourcing region. A risk assessment of the sourcing area demonstrating there is no clear risk of sourcing from primary forests.
Roundtable for Sustainable Biomaterials (RSB)	The Operator must provide all of the following: Evidence that the forest carbon stocks are stable or increasing in the sourcing region. A risk assessment of the sourcing area demonstrating there is no clear risk of sourcing from primary forests.
FSC Controlled Wood Sources	The Operator must provide all of the following: Evidence that the forest carbon stocks are stable or increasing in the sourcing region. A risk assessment of the sourcing area demonstrating there is no clear risk of sourcing from primary forests.
FSC Mix	The Operator must provide all of the following: Evidence that the forest carbon stocks are stable or increasing in the sourcing region. A risk assessment of the sourcing area demonstrating there is no clear risk of sourcing from primary forests.
PEFC Controlled Sources	The Operator must provide all of the following: Evidence that the forest carbon stocks are stable or increasing in the sourcing region. A risk assessment of the sourcing area demonstrating there is no clear risk of sourcing from primary forests.

7.0

Isometric CRCF Glossary

This glossary provides a side-by-side comparison of terminology used in the EU Carbon Removal Certification Framework (CRCF) and Isometric Protocols and Module.

Contributors

Chris Pollard

Michael Shell

Neil Hacker

Emma Marsland

Sebastian Green, Ph.D.

Counterfactual Storage Criteria

Criteria

Documentation Required

Operators must demonstrate compliance with at least one of the following criteria for each feedstock. Notable examples where more than one must be satisfied include a BioCCS retrofit that can reference combustion for the consumption of feedstock for the underlying facility, but increases the demand for biomass to satisfy a parasitic energy requirement and therefore must reference a different counterfactual fate for this marginal biomass.

CC1

The $CO_2e_{Counterfactual}$ of the feedstock is quantified.

The Operator must provide a quantification of $CO_2e_{Counterfactual}$ including all documentation, data-sets, references and assumptions associated with the calculation of counterfactual storage.

CC2

Feedstock is sourced through a government managed, funded or otherwise supported wildfire mitigation program. The $CO_2e_{Counterfactual}$ of these feedstocks is 0.

The Operator must provide evidence that the feedstock originates from a government mandated, managed or otherwise supported wildfire mitigation program, including evidence of program participation and chain-of-custody.

CC3

The feedstock is rapidly oxidised or reduced such as in a high temperature environment in the counterfactual, such as an incinerator or open pit burn, resulting in negligible durable carbon storage in the counterfactual. This can include Operators that retrofit existing facilities that combust feedstock. The $CO_2e_{Counterfactual}$ of these feedstocks is 0.

The Operator must provide evidence of the feedstocks rapid oxidation/reduction in the counterfactual, such as disposal/end-use records, supplier affidavits or records of existing feedstock consumption at baseline facilities in the case of retrofits.

In the case of retrofits/additive facilities, Operators must ensure that increased feedstock sourcing due to the Activity, such as to provide heat or electricity for the capture facility, is accounted for under another counterfactual criteria.

CO_2e_{Counterfactual,\ x}\ \ = \ \ CO_2e_{Feedstock} \ \ - \ \ CO_2e_{CounterfactualEmissions}

CO_2e_{CounterfactualEmissions} \ \ = \ \ min(CO_2e_{CounterfactualEmissions15}, \ \ CO_2e_{Feedstock}\ \ - \ \ CO_2e_{CounterfactualStorage50})

CO_2e_{Counterfactual}\ \ =\ \ \sum_{x=1}^{n}\ CO_2e_{Counterfactual,\ x}

Permissible Feedstock Criteria

Criteria

Documentation Required

PF1: All Activities utilising non-woody feedstocks must demonstrate compliance with both of the following criteria for each feedstock.

PF1.1

The feedstock must not have been produced for bioenergy applications. This does not affect the use of residues that have fulfilled their purpose for energy generation (e.g., post anaerobic digestion manure).

The Operator must provide evidence that the feedstock was not produced for bioenergy use for 2 years prior to the Operator's first procurement date.

PF1.2

The feedstock must not have been used for food or feed in the counterfactual.

The Operator must provide evidence that the feedstock was not produced for food or feed use for 2 years prior to the Operator's first procurement date.

PF2: All Activities using woody feedstocks must demonstrate compliance with the of the following criterion for each feedstock:

PF2.1

The feedstock must not be diverted from use as a component of long-lived wood products or pulpwood (e.g, construction materials, furniture, fiberboard etc.).

Feedstocks that have fulfilled their use as long-lived wood products or pulpwood are eligible if they cannot be further repurposed.

Residues from wood processing are eligible if non-marketable or marketed only for bioenergy, landscaping or mulch over the previous 2 years.

Operators must provide one of the following:

Evidence of the feedstock lifecycle including generation and utilisation/disposal for 2 years prior to the Operator's first procurement date.

Evidence that the feedstock characteristics make the feedstock unsuitable for use in long-lived wood products or pulpwood.

Evidence that the feedstock is sourced by, or to meet the clear goals of, a government supported wildfire mitigation program, including evidence of program participation and chain-of-custody.

Market Leakage Criteria

Criteria

Documentation Required

All Operators must demonstrate compliance with one of the following criteria sets for each feedstock.

ML1: All Activities that cannot demonstrate zero market leakage for their feedstocks using the other criteria within this table must quantify market leakage to demonstrate compliance with this criterion.

ML1.1

The $CO_2e_{MarketLeakage}$ of the feedstock is quantified.

The Operator must quantify the emissions associated with market leakage and provide the documentation used in this quantification including references, data sets and assumptions.

ML2: BioCCS retrofit/additive Activities that can demonstrate the capture capacity of the Activity would be reached by the pre-Activity emission generation rate of the underlying facility. For feedstocks that comply with this criteria, $CO_2e_{MarketLeakage}$ = 0.

ML2.1

The Maximum Biogenic Carbon Utilisation Rate of the CCS infrastructure does not meet or exceed the Baseline Emission Rate.

This criteria allows for the qualification of a feedstock mass that does not exceed the Maximum Biogenic Carbon Utilisation Rate, after subtracting both the Baseline Emission Rate and any parasitic load of the retrofit infrastructure. All values are expressed in feedstock equivalent units.

The Operator must provide documentation demonstrating the Baseline Emission Rate over the last 5 years and an evidenced calculation of the Maximum Biogenic Carbon Utilisation Rate of the CCS infrastructure (See Appendix 4 in the Biomass Feedstock Accounting Module for calculation requirements).

ML3: Retrofit/additive Activities that can reference the consumption of the underlying facility as the fate of some/all of the feedstock prior to the Activity. For feedstocks that comply with this criteria, $CO_2e_{MarketLeakage}$ = 0.

ML3.1

The feedstock consumption of the underlying facility is clearly defined.

The Operator must provide one of the following:

Evidence of the baseline feedstock consumption rate for the underlying facility including quantity and sourcing.

A demonstration that the Activity will not alter the underlying feedstock demand for feedstock such as a bioenergy facility that can demonstrate how the energy requirements for the facility will be satisfied, through Activity attributable facility upgrades or other power import/generation.

ML3.2

All feedstock sourced over the baseline, specifically sourced to generate additional CDRs or power the capture infrastructure must be accounted for under a different market leakage criteria.

The Operator must provide one of the following:

A demonstration that the marginal feedstock has been accounted for under a separate market leakage criteria with all documentation requirements satisfied.

ML4: Activities that do not contribute significantly to the revenue of the feedstock supplier must demonstrate compliance with the following criterion. For feedstocks that comply with this criteria, $CO_2e_{MarketLeakage}$ = 0.

ML4.1

The Activity provides limited upstream incentives to the feedstock supplier, including aspects such as feedstock payments, revenue sharing or service provision.

The Operator must provide one of the following:

A purchase agreement demonstrating no revenue contribution is made to the feedstock supplier beyond recovery and transportation costs of the feedstock. This includes cases where the feedstock is received free of charge, or the Operator is paid a tipping fee to take the feedstock.

A signed affidavit from the feedstock supplier or feedstock aggregator demonstrating there is no revenue contributions exceeding the recovery and transportation costs made to the feedstock supplier.

ML5: The feedstock serves an economic purpose where supply exceeds demand. For feedstocks that comply with this criteria, $CO_2e_{MarketLeakage}$ = 0.

ML5.1

The Operator can demonstrate a local supply excess (e.g., stable or growing stockpiles), that the Activity won't exceed.

The Operator must provide one of the following:

Historical contracts between the feedstock supplier and the end-use/disposal sites demonstrating disposal of a volume of feedstock equivalent to Activity demand.

A quantification of the Baseline Feedstock Generation Rate over the previous 5 years (See Appendix 4 of the Biomass Feedstock Accounting Module for details) demonstrating supply exceeds demand, including pre-Activity off-takes and Activity demand. Periods of less than 5 years will be assessed on a case-by-case basis.

Evidence of a standing stockpile that is equivalent or greater in mass than the Activity demand. This must be demonstrated as a persistent stockpile. Historical look-back periods depend on the feedstock.

An affidavit from the feedstock supplier demonstrating the historical fate of the feedstock, subject to third-party verification, with corroborating evidence such as literature, interviews or time-series observations.

ML5.2

The contribution made by the Operator to the feedstock supplier do not incentivise increased production of the feedstock.

The Operator must provide one of the following:

An affidavit from the feedstock supplier confirming that the revenue contributed by engagement with the Activity does not shift feedstock production practises corroborated by purchase agreements or other evidence.

Evidence of all marketed products associated with the feedstock production, a quantification of marketed products production per unit of feedstock and an evidenced price point for the sum of the products produced demonstrating that revenue contributions constitute less that 5% of the feedstock supplier's revenue.

ML6: The feedstock has no economic purpose. For feedstocks that comply with this criteria, $CO_2e_{MarketLeakage}$ = 0.

ML6.1

The feedstock will not be used above the rate at which it is generated.

The Operator must provide one of the following:

Historical contracts between the feedstock supplier and the end-use/disposal sites demonstrating disposal of a volume of feedstock equivalent to Activity demand.

A quantification of the Baseline Feedstock Generation Rate over the previous 5 years (See Appendix 4 of the Biomass Feedstock Accounting Module for details) demonstrating supply exceeds Activity demand.

An affidavit from the feedstock supplier demonstrating the historical fate of the feedstock, subject to third-party verification (e.g., a Certification Body), with corroborating evidence such as literature, interviews or time-series observations.

ML6.2

The contribution made by the Operator to the feedstock supplier do not incentivise increased production of the feedstock.

The Operator must provide one of the following:

An affidavit from the feedstock supplier confirming that the revenue contributed by engagement with the Activity does not shift feedstock production practises corroborated by purchase agreements.

ML7: The feedstock is currently in economic use but can be obtained at or below a Sustainable Usage Rate. For feedstocks that comply with this criteria, $CO_2e_{MarketLeakage}$ = 0.

ML7.1

The feedstock is demonstrated to serve an economic purpose and the Operator is able to demonstrate that the Activity will not exceed the Sustainable Usage Rate of the feedstock.

The Operator must provide a robust, conservative demonstration of the Sustainable Usage Rate including considerations for crop rotations, crop types, soil types etc. including all references, assumptions and data sets used.

ML7.2

The contribution made by the Operator to the feedstock supplier do not incentivise increased production of the feedstock.

The Operator must provide one of the following:

An affidavit from the feedstock supplier confirming that the revenue contributed by engagement with the Activity does not shift feedstock production practises corroborated by purchase agreements.

Table A1
Forestry Certification/Management programs suitable for all BiCRS Activities
Certification/Management Program	Additional Documentation Required
Forest Stewardship Council (FSC) 100% or FSC 100% chain-of-custody.
National Members of the Program for the Endorsement of Forest Certification (PEFC) 100% (e.g., SFI 100%, ATFS, SGEC, SAFAS etc.).
An equivalent forestry management/certification and chain-of-custody program. Acceptable certification programs differ depending on the Activity characteristics and sourcing.	The Operator must provide a detailed analysis of how the program is equivalent to the above programs, including forestry management principles and an auditable chain-of-custody.
A government mandated, managed or otherwise supported wildfire mitigation program.
NEPA or equivalent mandated, managed or otherwise supported forestry management and chain-of-custody program.	The Operator must provide evidence that the government collection plan is NEPA equivalent in principles and chain-of-custody oversight.

Table A1

Forestry Certification/Management programs suitable for all BiCRS Activities

Certification/Management Program

Additional Documentation Required

Forest Stewardship Council (FSC) 100% or FSC 100% chain-of-custody.

National Members of the Program for the Endorsement of Forest Certification (PEFC) 100% (e.g., SFI 100%, ATFS, SGEC, SAFAS etc.).

An equivalent forestry management/certification and chain-of-custody program. Acceptable certification programs differ depending on the Activity characteristics and sourcing.

The Operator must provide a detailed analysis of how the program is equivalent to the above programs, including forestry management principles and an auditable chain-of-custody.

A government mandated, managed or otherwise supported wildfire mitigation program.

NEPA or equivalent mandated, managed or otherwise supported forestry management and chain-of-custody program.

The Operator must provide evidence that the government collection plan is NEPA equivalent in principles and chain-of-custody oversight.

Table A2
Additional Certification/Management Programs Eligible for use by retrofit/additive Activities for feedstock sourcing directly attributable to the underlying facility and not the CDR Activity.
Certification/Management Program	Additional Documentation Required
Demonstrable compliance with the most up-to-date EU RED sustainability criteria. This must include upstream sourcing for mill residues, which is currently beyond the scope of the RED. This includes third-party verifications of compliance with the EU RED sustainability criteria, such as those provided by SURE and SBP, as well as recognised national schemes such as Sweden's Hållbarhetsbesked.	Demonstration that all forestry residues and primary mill residues (timber processing, excluding post-consumer/post-industrial wood waste) have been sourced from forestry management practices compliant with the sustainability criteria within the EU RED.
Sustainable Biomass Program (SBP)	The Operator must provide all of the following: Evidence that the forest carbon stocks are stable or increasing in the sourcing region. A risk assessment of the sourcing area demonstrating there is no clear risk of sourcing from primary forests.
Roundtable for Sustainable Biomaterials (RSB)	The Operator must provide all of the following: Evidence that the forest carbon stocks are stable or increasing in the sourcing region. A risk assessment of the sourcing area demonstrating there is no clear risk of sourcing from primary forests.
FSC Controlled Wood Sources	The Operator must provide all of the following: Evidence that the forest carbon stocks are stable or increasing in the sourcing region. A risk assessment of the sourcing area demonstrating there is no clear risk of sourcing from primary forests.
FSC Mix	The Operator must provide all of the following: Evidence that the forest carbon stocks are stable or increasing in the sourcing region. A risk assessment of the sourcing area demonstrating there is no clear risk of sourcing from primary forests.
PEFC Controlled Sources	The Operator must provide all of the following: Evidence that the forest carbon stocks are stable or increasing in the sourcing region. A risk assessment of the sourcing area demonstrating there is no clear risk of sourcing from primary forests.

Table A2

Additional Certification/Management Programs Eligible for use by retrofit/additive Activities for feedstock sourcing directly attributable to the underlying facility and not the CDR Activity.

Certification/Management Program

Additional Documentation Required

Demonstrable compliance with the most up-to-date EU RED sustainability criteria. This must include upstream sourcing for mill residues, which is currently beyond the scope of the RED. This includes third-party verifications of compliance with the EU RED sustainability criteria, such as those provided by SURE and SBP, as well as recognised national schemes such as Sweden's Hållbarhetsbesked.

Demonstration that all forestry residues and primary mill residues (timber processing, excluding post-consumer/post-industrial wood waste) have been sourced from forestry management practices compliant with the sustainability criteria within the EU RED.

Sustainable Biomass Program (SBP)

The Operator must provide all of the following:

Evidence that the forest carbon stocks are stable or increasing in the sourcing region.

A risk assessment of the sourcing area demonstrating there is no clear risk of sourcing from primary forests.

Roundtable for Sustainable Biomaterials (RSB)

The Operator must provide all of the following:

Evidence that the forest carbon stocks are stable or increasing in the sourcing region.

A risk assessment of the sourcing area demonstrating there is no clear risk of sourcing from primary forests.

FSC Controlled Wood Sources

The Operator must provide all of the following:

Evidence that the forest carbon stocks are stable or increasing in the sourcing region.

A risk assessment of the sourcing area demonstrating there is no clear risk of sourcing from primary forests.

FSC Mix

The Operator must provide all of the following:

Evidence that the forest carbon stocks are stable or increasing in the sourcing region.

A risk assessment of the sourcing area demonstrating there is no clear risk of sourcing from primary forests.

PEFC Controlled Sources

The Operator must provide all of the following:

Evidence that the forest carbon stocks are stable or increasing in the sourcing region.

A risk assessment of the sourcing area demonstrating there is no clear risk of sourcing from primary forests.

CRCF Biomass Feedstock Accounting

Contents

Introduction

Sustainability Criteria

Counterfactual Criteria

Permissible Feedstocks

Market Leakage

Appendix A

Isometric CRCF Glossary

Contributors

Contents

Introduction

Sustainability Criteria

Counterfactual Criteria

Permissible Feedstocks

Market Leakage

Appendix A

Isometric CRCF Glossary

Contributors