Biomass Feedstock Accounting

1.0 Introduction

This module (Independent components of Isometric Certified Protocols which are transferable between and applicable to different Protocols.) establishes requirements associated with the use of biomass feedstocks as part of 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 frameworkenhancement providedof biological or geochemical sinks and direct air capture (DAC) and storage, but excludes natural CO₂ uptake not directly caused by human intervention.)) projects. This includes setting out eligibility criteria for biomass feedstocks in Sectionrelation to market leakage, counterfactual storage and dedicated energy feedstock considerations. This module also provides requirements for quantification of counterfactual storage to determine eligible biomass ([math: CO_{2}e_{Counterfactual}]), and market leakage to determine emissions associated with replacement of biomass ([math: CO_{2}e_{Leakage}]).5.2.

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 Isometricproject. Standard, enables project proponents (The organization that develops and/or has overall legal ownership or control of a Removal or Reduction Project.) to establish their GHG (Those gaseous constituents of the atmosphere, both natural and anthropogenic (human-caused), that absorb and emit radiation at specific wavelengths within the spectrum of terrestrial radiation emitted by the Earth’s surface, by the atmosphere itself, and by clouds. This property causes the greenhouse effect, whereby heat is trapped in Earth’s atmosphere (CDR Primer, 2022).)baseline (A set of data describing pre-intervention or control conditions to be used as a reference scenario for comparison.) through determining what the most likely counterfactual (An assessment of what would have happened in the absence of a particular intervention – i.e., assuming the Baseline scenario.) scenarios would have been in the absence of a project (An activity or process or group of activities or processes that alter the condition of a Baseline and leads to Removals or Reductions.) for a given biomass feedstock. This module is applicable to projects utilizing the following biomass feedstocks:

• Agricultural residues
• Forestry thinnings or other byproducts of forestry operations
• Industrial biomass residues

Every project must determinebe their GHG baseline and consider specific alternative uses of biomass that would have occurred in the absence of the project. The GHG baseline must also consider the baselineconsidered relative to each feedstock used if the project utilizes multiple feedstock types, in line with Section 2.5.2. of the Isometric Standard.

This module details requirementsRequirements for biomass feedstock eligibility (are provided in Section 2) and counterfactualquantification emissionrequirements calculationare (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 (A calculation, series of calculations or simulations that use input variables in order to generate values for variables of interest that are not directly measured.) like GREET and CCLUB for life cycle analysis developed at Argonne National LabLaboratory, 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 (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.) 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 CounterfactualBiomass DefinitionsFeedstock Considerations

The Project Proponent must consider counterfactualthe scenariosfollowing that may have occurredfactors in theassessing absencehow ofa theparticular projectbiomass feedstock affects their net carbon dioxide equivalent (CO₂e) removal. CounterfactualsThese considerations may vary based on the impacts of feedstock use in a given project.

These scenariosimpacts are defined below in Table 1:

Table 1

2.0 Biomass Feedstock Eligibility

Feedstock eligibility is determined by both its potential market leakage (The increase in GHG emissions outside the geographic or temporal boundary of a project that results from that project's activities.) 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 protocolsProtocols 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 behaviorbehaviour 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 effectschange 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. IfDemonstrating any one of EC1 through EC4 satisfies both requirements in full. Demonstrating any one of EC5-EC7 satisfies the followingindirect market criteria holdsand true,demonstrating any one of EC8-E12 satisfies the feedstockdirect ismarket eligiblecriteria.

Table for use under this module:2

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

Table 3

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

Table 4

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, at this moment, this information is not currently required for the determination of eligibility.

1. 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.
2. Tillage practices: for crop residues sourced from row crop agriculture, collect evidence from the feedstock supplier thaton 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.
3. 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

AccountingBiomass forstores counterfactualCO₂ lossas inorganic carbon storage, forC. exampleA in soils, through the usequantity of certain feedstocksC can be difficultconverted andto manyunits approachesof leadCO₂ 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 useemissions of a1 formton of tonneCO₂. yearThe accountingGWP for CH₄ is 27.9 for GWP100. In this section CH₄ is presented in terms of CO₂e.

InsteadEligibility criteria is set out for biomass feedstocks in Table 5 which determines how much of this,the thisCO₂e frameworkstored requiresas part of the feedstockRemoval activity is eligible to meetcount thetowards followingCrediting. 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

If onlyall aof the biogenic C would have been released from storage within 15 years, [math: CO_{2}e_{Counterfactual}] = 0.

The portion of the feedstockstored biogenic C that is expectedeligible tounder this framework is the lesser of two values that must be stablydemonstrated maintained for longer than this threshold,by the percentageProject 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 decayedcounterfactually beforebeen thereleased 15within year50 threshold is not eligible under this framework and the carbon content of this biomass must be subtracted from the LCA (An analysis of the balance of positive and negative emissions associated with a certain process, which includes all of the flows of CO₂ and other GHGs, along with other environmental or social impacts of concern.)years (see Equation 21).

[math:  CO_2e_{DecayCounterfactualCounterfactual,\ pn} =
 CO_2e_{Feedstock} \times-
 δ_CO_2e_{StorageCounterfactualDiscountEmissionsCounterfactual}]

(Equation 1)

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

(Equation 2)

Where:

• [math: CO_CO_2e_{2}e_{DecayCounterfactualCounterfactual,\ pn}] = the total quantity ofcounterfactual CO₂e that is ineligible duefor to the decay rate of the feedstockCrediting as laid out in EC10EC13, for batch n, in tonnes of CO₂e
• [math: CO_2e_{Feedstock}] = the CO₂e content of the biomass feedstock used, calculated by converting C into CO₂ units based on C content, for batch n, in tonnes CO₂e
• [math: 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
• [math: CO_2e_{StorageCounterfactualEmissions15}] = the CO₂e counterfactually released from the biomass over 15 years, for batch n, in tonnes of CO₂e
• [math: δ_{StorageCounterfactualDiscount50}] =  the discount applied to the carbon contentshare of thebiogenic biomassC feedstock.that Forwould example, if 95% of the biomass was shown tonot have likelybeen decayedcounterfactually beforereleased thewithin threshold50 valueyears, infor EC10batch then [math: δ_{StorageCounterfactualDiscount}] = 0n.05

This discount can arise through two different mechanisms:

• Biomass that wouldn'’t have decayedreleased stored C until after the15 threshold time is ineligible and must be discountedyears;
• Biomass that would have decayedreleased stored C before the threshold15 timeyears may still leadbe topartially a discountineligible if a portion of the decayed 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 carbonfor removalCDR.

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

Table 6

3.0 Biomass Feedstock Counterfactual Emission CalculationCalculations

Specific emission calculations associated with a project’s counterfactual storage scenario(s) and market leakage, as required in Section 7.2 of protocolsProtocols applicable to this module, are determined as described below.

3.1 Calculation of CO₂e_{Counterfactual, n}

As biomass sourcing typically operates onFor a batchspecific basis; the total counterfactual GHGremoval, emissions associatedmust withbe a removal are calculated from the sum of all counterfactual GHG emissionsaggregated across all feedstock production batches, [math: p], within that removal, where [math: Nn] is the total number of batches:

[math: CO_2e_{Counterfactual,\ Rn} = \sum_{p=1}^{Nn}CO_{2}e_{Counterfactual,\ p}]

(Equation 23)

Where:

• [math: CO_2e_{Counterfactual,\ Rn}] = the total quantity of counterfactual GHGCO₂ emissions,that is ineligible for Crediting as totallaid netout greenhousein gas emissionsEC13, for ainjection removalbatch [math: R]n, in tonnes of CO₂e, see Equation (1)
• [math: CO_{2}e_{Counterfactual,\ p}] = the total quantitycounterfactual CO₂ that is ineligible for Crediting as laid out in EC13, for production batch p, in tonnes of counterfactualCO₂e

3.2 GHGCalculation of CO₂e_{Leakage, p}

For eligible feedstocks, emissions associated with market leakage will be equal to the total emissions associated with replacement material, as totalother netforms greenhouseof gasmarket emissionsleakage are assessed to be 0 for eligible feedstocks. Thus, market leakage for a production batch [math: pn], is given by the following equation:

[math: CO_2e_{Leakage,\ n} = CO_{2}e_{Replacement,\ n}]

(Equation 4)

• [math: CO_2e_{Leakage,\ n}] = the total GHG emissions associated with market leakage for injection batch 𝑛, in tonnes of CO₂e,
• [math: CO_{2}e_{Replacement,\ n}] = the total GHG emissions associated with Replacement for injection batch 𝑛, in tonnes of CO₂e, see Equation (35)

Counterfactual emissions associated with an individual production batch, [mathNote: p], can be calculated as follows:

[math: CO_2e_{Counterfactual,\ p} = CO_2e_{Energy\ Counterfactual,\ p} + \\ CO_2e_{Replacement,\ p}+ CO_2e_{DecayCounterfactual,\ p}]

(Equation 3)

Where:

• [math: CO_2e_{Energy Counterfactual,pLeakage}] = the net change in GHG emissions associated with energy consumption from baseline to project for a production batch [math: p], in tonnes of CO2e, see Section 3.1
• [math: CO_2e_{Replacement,p}] = the net change in GHG emissions associated with replacing the function of the feedstock removed for a production batch [math: p], in tonnes of CO2e, see Section 3.2, Equation (4)
• [math: CO_{2}e_{Decay Counterfactual,\ p}] = the net amount of GHG storage ineligible due to the decay rate of the feedstock for a production batch [math: p], in tonnes of CO2e, see EC10 Equation (1)

3.1 Calculation of CO2eEnergy Counterfactual, p

Emissions associated with energy usage for processes including but not limited to the growth, harvest, and collection of the biomass feedstock must be accounted for by all feedstocks.

The emissions of interest are the net change in energy emissions from baseline to project, which may be calculated in one of two ways, depending on the Project Proponent preference and available data sources:

• Determination and accounting of full baseline emissions associated with energy usage for feedstock sourcing deducted from full project emissions associated with energy use for feedstock sourcing;
• Determination and accounting for energy usage only for the project activities that occur which are in addition to any sourcing activities that would occur in the counterfactual scenario (e.g., additional fuel usage for equipment used to collect biomass that would normally be left in field, electricity use for shredding and bailing equipment, fuel use for loading biomass onto a truck)

Emissions may originate from, but are not limited to, the following sources:

• Emissions from electricity usage, CO2eFeedstock Electricity for all feedstock used in each production batch [math: p]
• Emissions from fuel combustion to produce heat or thermal energy in primarily non-road mobile equipment, such as forklifts and other material handling equipment or any other fuel used in the growth, harvest, and collection process, CO2eFeedstockFuel for all feedstock used in each production batch [math: p].

Energy related emissions must be measuredconsidered in the context of all cradle-to-grave project activities, calculatedas set out in the relevant protocol, and documentednot inonly accordancelimited withto Energybiomass Usefeedstock Accounting Moduleconsiderations.

3.2 Calculation of CO2eReplacement, f

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 (​​Considering 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.) emissions accounting for the life cycle of the replacement product. For example emissions for the production, transportation and use of the material.

[math: CO_{2}e_{Replacement,\ fn}] can be calculated as follows:

[math: CO_2e_{Replacement,\ fn} =  CO_{2}e_{Energy\ m_{Replacement,\ fn} \times+ EF_CO_{2}e_{Embodied\   Replacement,\ n} + \\ CO_{2}e_{Transportation\ Replacement,\ fn}]

(Equation 45)

Where:

• [math: m_CO_{2}e_{Replacement,\ fn}] = the masstotal GHG emissions associated with Replacement for injection batch 𝑛, in tonnes of the replacement product required to provide the equivalent service as the mass of the project feedstock for a functionCO₂e
• [math: EF_CO_{Embodied2}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.
• [math: CO_{2}e_{Embodied\ Replacement,\ n}] = the total life-cycle embodied emissions (Life cycle GHG emissions associated with production of materials, transportation, and construction or other processes for goods or buildings.) factorassociated forwith the production and use of the replacement product for injection batch 𝑛, seein tonnes of CO₂e. See Embodied Emissions Accounting Module for calculation approach details and emission factor requirements.
• [math: CO_{2}e_{Transportation\ Replacement,\ fn}] = the total CO₂ equivalente emissions associated with transportation and delivery of the replacement product for a functionfeedstock [math:for f]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 counterfactualemissions

The replacement counterfactualemissions for the Project Proponent feedstock is determinedassumed 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 counterfactualreplacement 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 CO₂e_{Replacement, pn}

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

Table 7

3.2.3 Measurements - CO₂e_{Replacement, p}

Calculation of [math: CO_{2}e_{Replacement, p}] requires, but is not limited to, the following measurements:

• [math: m_{Replacement,\ p}] (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, [math: m_{Replacement,\ p}], 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 (Nitrogen [N], Phosphurus [P], and Potassium [K] are three nutrients essential to crop growth.)) content. Feedstock NPK (Nitrogen [N], Phosphurus [P], and Potassium [K] are three nutrients essential to crop growth.) content must be determined by sampling of the feedstock(s) for each production batch [math: p], or from available scientific literature.

The amount of fertilizer replacement in the counterfactual scenario must account for replacing the same amount of NPK (Nitrogen [N], Phosphurus [P], and Potassium [K] are three nutrients essential to crop growth.) 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 - CO₂e_{Replacement, pn}

The projectProject proponentProponent must maintain the following records as evidence of CO[math: CO_{2e}e_{Replacement, pn}] calculations:

• If the feedstock provided an environmental service either: (1)
  • documentation on how N, P, K values were determined from relevant literature, (2)
  • for new or unique feedstocks, a per-feedstock lab analysis of N, P and K values, or (3)
  • for highly variable feedstocks a per-batch lab analysis of N, P and K values.
• Feedstock weigh scale tickets for each production batch, [math: p], or other equivalent records to support calculation of [math: m_{Replacement,\ p}]

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 moduleModule:

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

5.0 Definitions and Acronyms

Independent components of Isometric Certified Protocols which are transferable between and applicable to different Protocols.

The organization that develops and/or has overall legal ownership or control of a Removal or Reduction Project.

Those gaseous constituents of the atmosphere, both natural and anthropogenic (human-caused), that absorb and emit radiation at specific wavelengths within the spectrum of terrestrial radiation emitted by the Earth’s surface, by the atmosphere itself, and by clouds. This property causes the greenhouse effect, whereby heat is trapped in Earth’s atmosphere (CDR Primer, 2022).

A set of data describing pre-intervention or control conditions to be used as a reference scenario for comparison.

An assessment of what would have happened in the absence of a particular intervention – i.e., assuming the Baseline scenario.

An activity or process or group of activities or processes that alter the condition of a Baseline and leads to Removals or Reductions.

A calculation, series of calculations or simulations that use input variables in order to generate values for variables of interest that are not directly measured.

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.

A set of data describing pre-intervention or control conditions to be used as a reference scenario for comparison.

A calculation, series of calculations or simulations that use input variables in order to generate values for variables of interest that are not directly measured.

Describes 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”.

The increase in GHG emissions outside the geographic or temporal boundary of a project that results from that project's activities.

An entity that purchases Removals or Reductions, often with the purpose of Retiring Credits to make a Removal or Reduction claim.

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.

TheSustainable amountUsage ofRate: timethe carbonrate at which a feedstock can be removed from a location without affecting the atmospherefeedstock's byenvironmental anbenefits interventionor –availability for example,alternative a CDR project – is expected to reside in a given Reservoir, taking into account both physical risks and socioeconomic constructs (such as contracts) to protect the Reservoir in question.

An analysis of the balance of positive and negative emissions associated with a certain process, which includes all of the flows of CO₂ and other GHGs, along with other environmental or social impacts of concernuses.

​​Considering 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.

Life cycle GHG emissions associated with production of materials, transportation, and construction or other processes for goods or buildings.

Purposefully erring on the side of caution under conditions of Uncertainty by choosing input parameter values that will result in a lower net CO₂ Removal or GHG Reduction than if using the median input values. This is done to increase the likelihood that a given Removal or Reduction calculation is an underestimation rather than an overestimation.

Nitrogen [N], Phosphurus [P], and Potassium [K] are three nutrients essential to crop growth.

SustainableThe Usageperiod Rate:of thetime rate atover which a feedstockProject canDesign Document is valid, and over which Removals or Reductions may be removedVerified, fromresulting ain locationIssued without affecting the feedstock's environmental benefits or availability for alternative usesCredits.

6.0 Appendix 1: Calculating replacement mass for manure

This section outlines how to calculate the replacement mass of fertilizer, [math: m_{Replacement,\ p}], 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

• [math: ObservedCounterfactual] - quantity of manure (tonnes) from a supplier that is currently used for nutrient source.
• [math: QuantityProcured] - quantity of manure (tonnes) procured for CDR by the Project Proponent from within the [math: SupplyRegion].
• [math: QuantityGenerated] - total quantity of manure (tonnes) generated in a supply region.
• [math: 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.
• [math: 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.
• [math: PrimaryCrop] - The largest crop by acreage included in the [math: Acres] value
• [math: NutrientsReq_{f}] - necessary quantity of nutrient [math: f] (N or P) per cropland acre for the [math: PrimaryCrop].
• [math: ManureNutrient_f] - quantity of nutrient [math: f] (N or P) in 1 tonne of manure.
• [math: FertiliserEmissions_f] - the emissions, (in tonnes CO₂e), generated in the production of 1kg of nutrient [math: f] (N or P) in fertilizer.

The Sustainable Use Rate (SUR) (Sustainable 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.) 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 (Sustainable 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.) can be calculated as follows:

[math: SUR] = [math:QuantityGenerated\ QuantityGenerated]-[math:\ ObservedCounterfactual]

(Equation 56)

In this case, the [math: SupplyRegion] is the feedlot, thus [math: 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 (Sustainable 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.) can be calculated at the feedlot level. In this case, variables are calculated in the following manner:

Then the SUR (Sustainable 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.) is provided by the following calculation:

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

(Equation 67)

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 (Sustainable 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.) can be computed using Equation 67 above, but with variables are calculated in the following manner:

6.5 Replacement emissionsm

Replacement mass is calculated as follows:

If

[math: QuantityProcured \leq SUR]

then:

[math: m_{Replacement,\ p}=0]

Otherwise, the appropriate replacement emissionsmass value is:

[math: \begin{align*}
m_{Replacement,\ p} &= \left\
(QuantityProcured-SUR\right) \\
&\quad \times \left(ManureNutrient_{N} \cdot FertiliserEmissions_{N}\\ + ManureNutrient_{P} \cdot FertiliserEmissions_{P}\right)
\end{align*}]

(Equation 78)

Potential additional data sources:

• [math: NutrientsReq_{cf}] - N, P needs per farmland acre from AESL at UGA (K is assumed to not be limiting).
• [math: 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 (The period of time over which a Project Design Document is valid, and over which Removals or Reductions may be Verified, resulting in Issued Credits.), 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.

8.0 Appendix 3: FertilizerEmissions_{f}]TheAcceptable emissionsForest 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 (CO2eBCCS) generatedor Biomass with Carbon Removal and Sequestration (BiCRS) project, subject to other eligibility criteria outlined in the productionIsometric of 1kg of nutrient f (N or P) in fertilizer.Under certain conditionsEq. 4 (Biomass Feedstock Accounting Module)AssessmenttonnesEcoinventmodule. 3.9.1Two withadditional biomass certifications, SBP and RSB, provide eligibility subject to an additional requirement that Project Proponents provide information on the TRACIregion 2(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.1 methodAt 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.