Biomass Feedstock Accounting

1.0 Introduction

This Module establishes the requirements associated with the use of feedstocks as a part of carbonBiomass dioxideCarbon removalRemoval and Storage (BiCRS)Projects. This includesModule settingensures out criteria foreligible feedstocks are sourced in relationcompliance towith rigorous scientific and economic standards, covering sustainability, counterfactual storage and market leakage, and, for feedstocks harvested or cultivated for CDR, quantifying direct and indirect land-use change. This Module alsoprovides providesrobust methods for calculating the GHG impacts associated with market leakage, and methods for the quantification of counterfactual storage to ensure carbon removals generated from biomass reflect a real, beneficial and markettangible leakageclimate to determine eligible feedstocksimpact. 

This Module is currently applicable to the following feedstocks:

• ForestryWood production residues1 such as silvicultural residues, plantation residues and downstream wood processing residues2.
• AgriculturalIn-field agricultural residues such as crop residues and manure.
• Controlled wastes such as municipal solid waste, biosolids and pharmaceutical waste.
• Industrial and commercial residues such as food/beverage processing residues, textile residues, landscaping residues and post-consumer woody residues.
• MunicipalBiofuel wastesCO₂ byproduct streams.
• InvasiveEcosystem speciesconservation and management residues, such as wildfire mitigation and habitat restoration residues.
• Purpose-Grown Feedstocks, namely feedstocks cultivated for CDR specifically, or where CDR revenue is a sufficient financial aspect that stimulates, increases or maintains feedstock cultivation.
• Standing Stock Feedstocks, namely biomass harvested for CDR from an existing stock that was not cultivated or established by the Project (such as a plantation or invasive stand), including restoration removals and sustained-yield harvests.

EveryThe following feedstocks are ineligible under this Module:

• Palm oil, feedstock derived from palm oil or palm fatty acid distillate. This does not restrict the eligibility of residues such as oil palm fronds, press fiber, palm kernel shells/cake, empty fruit bunches, declinant palm stems or palm mill effluent.
• Peatland drainage/clearance biomass.
• Woody feedstocks that are suitable for, and in demand for, use in wood-based products (see CU1.1 and SSC1.4).
• Feedstocks otherwise used in food or feed applications (see CU2.1 and SSC2.6).

All feedstocks must comply with the requirements in Section 1.5 and Section 1.6. Residue Feedstocks must be accounted for using the requirements in Section 2. Purpose-Grown Feedstocks must be accounted for using the requirements in Section 3, and Standing Stock Feedstocks using the requirements in Section 4. Indirect land-use change for Purpose-Grown Feedstocks is quantified under Section 3.5; Standing Stock Feedstocks must not displace productivity and are not assessed for indirect land-use change (see SSC1.4 and SSC2.6).

Purpose-Grown Feedstocks are feedstocks cultivated for CDR whose production would not have occurred at the same scale in the absence of CDR revenue, for example switchgrass cultivated on non-agricultural land or algae grown in bioreactors. Standing Stock Feedstocks are biomass removed from an existing stock not cultivated by the Project that would have remained in a living carbon stock, such as an abandoned plantation stand, rather than being harvested in the absence of CDR revenue. This includes cases where a Project performs wildfire mitigation itself rather than absorbing residual biomass streams from existing activities (see Appendix E.2). A feedstock must be treated as Purpose-Grown or standing stock, rather than as a Residue, where either (a) the biomass would not have been grown in the counterfactual, or (b) the biomass would have remained in a living carbon stock rather than being harvested. Conversely, biomass whose removal was already scheduled or legally committed and funded independently of CDR revenue (a pre-committed removal) is a Residue, even where the Project performs or takes over the removal, and must be assessed under SC7 in Section 2.3.7.

A Residue Feedstock is defined as a product that is not an economic driver of the process it is produced in. Where Project demand may increase the marginal production of a residue, for example sourcing feedstock above a traceable surplus level, without changing the traceable supplier's behavior, land area or harvested stock, the feedstock remains a Residue, but the Project must account for the resulting upstream production emissions in line with the Isometric GHG Accounting Module. Where the induced increase would require additional land, removal of standing stock or a change in the primary process's output, the marginal feedstock is considered Purpose-Grown or standing stock.

1.1 Applicability

This Module applies to all pathways wishing to register Certificates with Isometric using biomass feedstocks to sequester carbon. All feedstocks utilized by a Project must be registered with Isometric and comply with all applicable criteria within this Module. The rules for a Project to follow updated Module requirements can be found in the relevant section of the Isometric Standard, and vary based on Project stage.

Certificates registered with Isometric are always verified by a VVB. Some requirements outlined in this Module are only necessary to assess at Project initiation, known as Validation Requirements, while some requirements necessitate ongoing evidence submission applicable to each Reporting Period, known as Verification Requirements. The type of requirement can be found adjacent to the requirement text. Validation Requirements are valid for the duration of the Crediting Period, found in the relevant Protocol. Verification Requirements are assessed at the end of each Reporting Period, prior to the issuance of Certificates. Where evidence to comply with a Verification Requirement contains no novel information (e.g., carbon stock inventories, sustainability assurance certificates), the Project Proponent must considerattest specificthat alternativeno usesmore recent version of feedstocks that wouldevidence exists or has been produced.

Social safeguards such as strict adherence to legality, international labor laws, and the principles of Free, Prior, and Informed Consent (FPIC) are essential to ensuring feedstock sourcing for BiCRS Projects is both equitable and sustainable. Consequently, Projects have occureda inclear the absence of the Project. The baseline scenario must be considered relativeresponsibility to eachensure feedstockfull used if the Project utilizes multiple feedstock types, in linecompliance with Sectionall 2.5.2environmental ofand social safeguards defined in the Isometric Standard., Ifas awell Projectas usesthose anyoutlined feedstock that is deemed ineligible bywithin this Module, this feedstock will not count towards Crediting. If a Project utilizes ineligible biomass for alternative uses in excess of 25% of the feedstock mass in a given Reporting Period, removals within the Reporting 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.
• Counterfactual storage criteria that aim to ensure removals provide near-term climate benefits.
• Market leakage criteria that aim to assess the full emissions impact and additionality of feedstock use while accounting for limited data availability in some feedstock sourcing scenarios.

1.12 Future Versions

This Module waspresents developeda basedreliable, onpractical, and stringent approach to accounting for feedstock inputs in BiCRS Projects. Developed in collaboration with leading scientists and economists, this methodology is grounded in the current state of the art and publicly available science regardingconcerning biomass feedstock carbon accounting. As the Carbon Dioxide Removal (CDR) industry grows, the challenge of sourcing sustainable biomass for Biomass Carbon Removalintensifies, and Storage (BiCRS) Projects. This Module is based in part on the most up-to-date literature and models at the time of publication. Thisthis Module will continuebe adapted to address these challenges.

This Module takes a conservative stance on feedstock accounting and will be updatedaltered in future versions as scientific and& economic understanding developsimproves.

Future work to include additionalAdditional feedstocks, such as purpose-grown BiCRS feedstocks, willmay be undertakenadded as necessitated by demand and the development of robust accounting methodologies.

1.3 How to Use This Module

This Module accounts for the biomass entering a Project: whether a feedstock is eligible, the change in carbon stocks and flows driven by the Project and what the Project's demand for feedstock changes elsewhere. It does not quantify the removal itself. It is applied alongside the relevant Protocol, which sets the Crediting Period and the pathway-specific requirements.

The unit of assessment is the feedstock, not the Project. The Project Proponent prepares a feedstock submission for each feedstock the Project uses, or for each group of feedstocks meeting the conditions in Section 1.3.2, and asworks enabledthrough this Module once per submission. Sections 1.5 and 1.6 apply to every feedstock. Beyond that, the route through the Module is set by improvedits researchclassification. A feedstock is a Residue, accounted for under Section 2, a Purpose-Grown Feedstock, accounted for under Section 3, or a Standing Stock Feedstock, accounted for under Section 4.

Requirements are set out in criteria tables. Each criterion carries an ID, states whether it is a Validation Requirement, a Verification Requirement or both, and modelinglists the documentation a Project Proponent must provide to demonstrate compliance. Where several documentation options are given, the criterion states whether one or all are required. Validation Requirements are assessed once and hold for the Crediting Period; Verification Requirements are assessed every Reporting Period. The row introducing each set of criteria states which of them apply, and on what condition. Criteria are cited by ID throughout: FC (Feedstock Characterization), FS (Feedstock Storage), CU (Cascading Use), SC and ML (residue Sustainability Criteria and Market Leakage), CF and CS (Counterfactual Fate and Counterfactual Storage), PSC and SSC (Purpose-Grown and Standing Stock Sustainability Criteria), and LUD, DLUC and ILUC (Land Use Declaration, Direct Land-Use Change and Indirect Land-Use Change), each prefixed P for Purpose-Grown or S for Standing Stock Feedstocks (Standing Stock Feedstocks have no ILUC criteria), for example PDLUC1 and SDLUC2.

ThisThe table below maps each feedstock type to the criteria sets that apply to it.

Table 1 – Feedstock Pathway Summary

1.3.1 Alternative Evidence

While this Module is designed to apply to all Projects and feedstocks, some Projects may not be able to demonstrate compliance with a given criterion through the presented evidence options, while still being able to sufficiently demonstrate that the purpose behind a requirement has been met. Project Proponents presenting alternative evidence to demonstrate compliance with a given criterion may be eligible, subject to a case-by-case review with Isometric and the VVB. The alternative evidence must: (a) be demonstrably equivalent to, or greater than, the listed evidence options for the given criterion in demonstrating compliance with a given requirement, or purpose behind the given requirement, assessed against the specific risk the criterion is designed to address; and (b) be independently verifiable by the VVB to a standard comparable to that of the listed options, rather than relying on the Project Proponent's assertion. Isometric will document the applicable requirement, the evidence submitted, the justification for why the evidence is considered equivalent and any conditions attached to its ongoing use (e.g., expiry, revalidation date) which will be reviewed by the VVB and transparently and publicly presented on anthe annualProject's cadencepage on the Isometric registry, as well as subject to review in linethe public comment period for the PDD. Some alternative evidence for demonstrating compliance with a given Validation Requirement may necessitate the submission of ongoing evidence, necessitating coordination with Isometric and the VVB.

1.3.2 Grouped Feedstocks

All feedstocks must be separated by applicable criteria to ensure they comply with the Isometricrequirements Standard.

2.0laid Feedstockout Eligibility

The framework outlined inby this Module. setsFeedstocks outmay sourcingbe grouped into a single feedstock submission when they are the same feedstock type from the same Sourcing Region as specified by FC1.2, and are eligible under the same criteria thatusing qualifythe same evidence options. Where grouped feedstocks asdo eligiblenot share the same counterfactual fate and the per-tonne values of [math: CO_2e_{Counterfactual}] and [math: CO_2e_{Leakage}] differ across the group, the most conservative value must be applied to the whole group. These values must be assessed in tandem, ensuring that the counterfactual storage and market leakage associated with each given fate are quantified together and the most conservative of the combined fates, representing one consistent fate, must be selected and applied. Grouped submissions must identify every supplier and the volume attributable to each; compliance evidence must be collected for useeach insupplier BiCRSand Projectsrefreshed ineach Reporting Period where the requirement is a wayVerification Requirement. Should a single supplier or a subset of suppliers cease to comply with the requirements during the Crediting Period, the volume attributable to that ensuressupplier sustainableis sourcing and accountsineligible for the emissionsReporting impactsPeriod thatin result from market leakage. These considerations vary based onwhich the characteristicsnon-compliance arose, and sourcingall activitiessubsequent ofReporting thePeriods feedstock.

Feedstockuntil eligibilitycompliance requiresis established by the Project Proponent and verified by the VVB.

In the case where grouped feedstock characteristics (e.g., total organic carbon, moisture content) may affect the durability of the processed material (e.g., biochar), grouped feedstocks must be used in a consistent mix, or demonstrated to be consistent enough to not affect storage durability, in consultation with Isometric and the VVB. It is worth noting this is included here for guidance/visibility for assessing how to group feedstocks, while the actual durability testing is required at the Protocol level.

Where feedstock suppliers fluctuate frequently, the Project must discuss this with Isometric and the VVB prior to Validation, and all feedstock submissions must be kept up to date throughout the Crediting Period unless an aggregator is used and is contractually obliged to source from suppliers that would meet the given feedstock requirements. Where changes in suppliers during the Crediting Period are covered by existing evidence provided by the Project Proponent, the change will be assessed as a Verification event. Where changes in suppliers during the Crediting Period are not covered by the existing evidence package (e.g., where a supplier-specific affidavit or dataset is relied on), updated evidence must be submitted and assessed by the VVB prior to the issuance of Certificates. Whenever a feedstock materially changes (e.g., change/expansion of a Sourcing Region, change to the feedstock characteristics, change to the understood counterfactual fate) the Project Proponent must notify Isometric and the VVB at the earliest opportunity. In such cases, the feedstock will be revalidated unless the Project Proponent can demonstrate that the change is immaterial to Project accounting, subject to a case-by-case review by Isometric.

If a feedstock compliesis collected by the Project or from an aggregator who sources across multiple source lots (>10), the Project Proponent may collect evidence based on a statistically significant representative group of source lots in consultation with Isometric and the VVB. Such a sampling approach must meet all of the following minimum requirements:

1. The group must be defined, consistent with the Sustainabilityabove Criteriarequirements (Sectionregarding 2.1)feedstock characteristics, eligibility and Sourcing Regions.
2. The Project must provide a complete register of upstream suppliers or lots, consistent with the Prohibitedrequirements Feedstockunder CriteriaFC1.1 and FC1.3.
3. The subsample frequency must be calculated in accordance with the following equation:

[math: n_S = max\left( 10, \left\lfloor \left( 1 - (Section1 4- CL)^{\dfrac{1}{D}} \right) \cdot \left( N_S - \dfrac{D - 1}{2} \right) + 0.5 \right\rfloor \right)]

(Equation 1)

Where:

• [math: n_S] = The number of suppliers or lots that must be assessed.
• [math: N_S] = The total number of suppliers or lots that supply the given feedstock.
• [math: D] = The detection threshold multiplied by [math: N_S], set at 10%, therefore [math: D = 0.1) \cdot N_S].
• [math: CL] = The confidence level, set at 0.9.

4. The VVB must select the sample at random, with a probability proportional to establishsupplier eligibilityvolume, from the register. EligibleWhere appropriate, the random sample may be stratified according to the VVB's discretion. The VVB must document the method. The Project Proponent must not be told the selection prior to the register being submitted to the VVB.
5. Feedstock sourced from a non-compliant supplier is ineligible for generating removals. Non-compliant suppliers must be carried forward in the sampling approach and therefore the sampling frequency must be increased to support the above confidence of compliance given the non-compliance, or every supplier must be assessed.
6. The Project Proponent must submit a sampling plan clearly documenting the above, which Isometric must approve before evidence is collected. Upon completion, this sampling plan must be attached to FC1.1 and referenced throughout the feedstock submission to demonstrate compliance with a given requirement.

1.3.3 Module Decision Logic

This Module is intended to cover a broad range of feedstocks mustand thentherefore undergomany furtherof evaluationthe criteria that follow are specific to assesscertain their counterfactual storage (Section 3) and market leakage (Section 4.2) valuesfeedstocks. Guidance of how to use this documentThis can be seen in Figureboth 1the below.

• Sustainability Criteria: Requirements to ensure thatgiven feedstock sourcingmust comply only with the criteria set which is sustainable.applicable Thesebased criteria are reviewed every Reporting Period. See Section 2.1 for details.
• Counterfactual Storage: Counterfactual storage considers the CO2e stored inon the feedstock thatsource wouldand havecharacteristics. remainedIn durablyaddition, storedthe inModule absenceprovides multiple criteria sets as options for a Project to demonstrate compliance with a given concept. An example is, for Residue Feedstocks, Projects must demonstrate compliance with one of four counterfactual storage criteria, CS1, CS2, CS3 or CS4. This optionality is presented to the Project activities.Proponent Thisthroughout feedstockthe fraction does not count towards Crediting. Counterfactualcounterfactual storage assessmentssection are valid for 10 years. See Section 3 for details.
• Prohibited Feedstocks: Some feedstocks are deemend ineligible for crediting under this Module. This is due toand the significant risk of market leakage associatedsection withfor sourcing these feedstocks. This applies to feedstocks that meet the other criteria outlined within this module.Residue Feedstocks suchand as food/feed cropsdirect and purpose grown BiCRS feedstocks are not detailed here as they have no path through the Module. Feedstocks must meet one of the criteria within this section to establish the feedstock as eligible. See Section 4 for details.
• Market Leakage: Increased demand for a feedstock driven by sourcing by a Project Proponent may cause market changes that increase GHG emissions through additional activities to replace feedstock services, or changes in market supply leading toindirect land-use change orfor otherPurpose-Grown marketand shiftsStanding Stock Feedstocks. MarketFinally, leakagefeedstock assessmentscharacterization and feedstock storage criteria are validmandatory forregardless 10of yearsfeedstock and Project. SeeThis logic flow can be seen in the below decision tree.

  SectionFigure 41 for details.

2.1 Sustainability Criteria

For use byguides a Project Proponentthrough what criteria apply to its feedstock.

Figure 1 – Module Decision Logic

[Image: BFAv1.4Figure1v5]

1.4 Core Accounting Concepts

To ensure precise communication and minimize ambiguity while maintaining a concise text length, this Module utilizes specific technical terms. The primary concepts referenced throughout the document are outlined below.

Feedstock
The raw material that is used for CreditingCO₂ Removal.

Feedstock Supplier
The entity from which the Project Proponent obtains the feedstock, and to which any payment for the feedstock sourcingis made. This may be the entity that physically produces the feedstock (for example a farmer generating corn stover, a conservation organization clearing invasive species, or an oat hulling facility) or an intermediary such as an aggregator or broker. Where an intermediary is used, certain requirements such as the revenue tests in Section 2.5.1 must be deemedapplied sustainableto the entity whose production, sourcing or management behavior could be influenced by the payment, rather than the intermediary.

Sourcing TheRegion
A followingregion sectioncovering outlinesthe howarea from which a Project Proponentfeedstock is required to assess whether their feedstock sourcing is sustainable and provide evidence of sustainability for their feedstock type. In some instances, sustainabilityor criteriacould also include an evaluation of market leakage (e.g.be, SC5.1).

The following information must be submitted as part of the verification for each Reporting Period:

• The Project Proponent must establish sustainable sourcing practices for the Sustainability Criteria relevant to their feedstock typesourced. A feedstockgiven Sourcing Region must satisfyrepresent allan criteriaarea associatedof withsimilar ecological characteristics such as biodiversity, and subject to the same regulatory requirements.

  Feedstock Batch
  A batch is a discrete unit of feedstock. This is defined as a specific feedstock type (e.g., SC1sawdust) grouped by the volume that is used in a given Reporting Period (e.g., 1 month). Each batch is automatically assigned a unique ID for traceability in the Isometric Certify platform.

  Feedstock Submission
  Similar to a PDD, but specifically for a feedstock. A feedstock submission contains all relevant documentation for a Project Proponent to demonstrate compliance with the applicable criteria within this Module. See Section 1.3.2 for the conditions under which feedstocks may be grouped into a single submission.

  Residue
  A product that is not an economic driver of the process it is produced in.

  Purpose-Grown Feedstock
  Feedstocks cultivated for CDR specifically, or where CDR revenue is a sufficient financial aspect that stimulates, increases or maintains feedstock cultivation.

  Standing Stock Feedstock
  Biomass removed for CDR from an existing stock that was not cultivated or established by the Project, such as a plantation or invasive stand, where CDR revenue is a sufficient financial aspect that stimulates, increases or maintains the harvest. Includes restoration removals and SC1sustained-yield harvests performed by or for the Project.

  Nameplate Capacity
  The maximum, full-load output that a given generator or facility can sustain under ideal conditions.

  Eligible Retrofit Project
  A Project in which an underlying facility, established to produce non-CDR Primary Product(s), is subsequently modified to capture, or improve the capture of, carbon dioxide. Waste streams from the existing process are utilized for CDR and the demand for biomass feedstock is demonstrated to exist independently of the CDR Project. Projects must demonstrate compliance with the requirements in Appendix E.1 to be considered an Eligible Retrofit Project.

  Eligible Integration Project
  A CDR Project that incorporates a CDR process into a newly or recently constructed industrial or engineered process. Waste streams from the process are utilized for CDR and the demand for biomass feedstock is demonstrated to exist independently of the CDR Project. Projects must demonstrate compliance with the requirements in Appendix E.1 to be considered an Eligible Integration Project.

  Sustainable Usage Rate (SUR)
  The rate at which a feedstock can be removed from a location or process without affecting the feedstock's environmental benefit.

  Baseline Feedstock Generation Rate
  The rate at which a feedstock is generated by a producer, facility or process in the absence of the Project.

  Baseline Feedstock Consumption Rate
  For Eligible Retrofit and Integration Projects, the rate at which the underlying facility consumes a given feedstock.

  Counterfactual
  What would have happened in the absence of the Project.

  Carbon Stock
  The quantity of carbon held within a given reservoir or landscape. This often refers to the aboveground biomass, belowground biomass and the organic carbon contained within soil in a given area.

  Direct Land-Use Change (dLUC)
  The physical conversion of a given parcel of land from one management category, or natural state, to another.

  Indirect Land-Use Change (ILUC)
  The effect of using previously productive land or an agricultural commodity for an alternative use, shifting the Pre-Project Productivity to another, often untraceable, land parcel. A form of market leakage.

1.5 Feedstock Characterization & Tracking

Upon submission to Isometric, Project Proponents must provide the following information to Isometric and the VVB at Validation, and ensure this list is up to date at each Verification:

Table 2 – Feedstock Characterization Criteria

[math: CO_2e_{FeedstockIn, i} = FeedstockMass_i \cdot CarbonFraction_i \cdot \dfrac{44}{12}]

[math: CO_2e_{BioStorage,RP} = \sum_{i=1}^{N_D} \dfrac{16.04}{44} \cdot 0.0013 \cdot GWP_{CH_4}\ \cdot CO_2e_{FeedstockIn,i}\ \cdot \ max\left( 0, StorageMonths_i - 1 \right)]

2.3.7 Conservation and Management Residues (SC7)

The feedstock is a Residue from established environmental management activities, such as routine habitat maintenance, disaster mitigation, disaster recovery debris and invasive species removal. Feedstocks that meet this description must demonstrate compliance with SC7.1 and SC7.2 and SC7.3.

Feedstocks from invasive species that are cultivated purposefully, such as plantations cultivating eucalyptus for timber, are not eligible under this criterion and must comply with SC1. Feedstock cultivated for CDR must comply with all the Purpose-Grown Feedstock criteria in Section 3, and feedstock harvested from a standing stock for CDR, such as by Projects taking an active role in clearing invasive species or establishing wildfire corridors, must comply with all the Standing Stock Feedstock criteria in Section 4.

Table 12 – Conservation and Management Residue Sustainability Criteria (SC7)

2.4 Residue Counterfactual Accounting

Carbon Certificates generated through Biomass Carbon Removal and Storage Projects only represent a genuine climate benefit when they reflect a measurable reduction in atmospheric carbon dioxide concentrations relative to what would have occurred in the absence of the Project within a defined timeframe. This principle is foundational to carbon accounting. This aligns with bodies such as the UNFCCC Article 6.4 Supervisory Body⁴, the EU Expert Group on Carbon Removals and the leading carbon removal buyers that define removals as the net change in GHG reservoirs, calculated by subtracting the sum of the change in GHGs stored in each applicable GHG reservoir in the baseline scenario from the sum of the change in GHGs stored in each applicable GHG reservoir in the Project scenario.

AccountingIn forplain counterfactualterms, storagea ensurescarbon Creditsremoval accuratelymust reflect the difference between the Project's actualscenario climateand impact,the preventingbaseline overstatementscenario. Accounting simply for the gross quantity of removalscarbon captured – and assuming "carbon neutrality" by accountingdefault for– carries risks of claiming carbon removals that in actuality are shifts in carbon between durable sinks.

Biomass often serves as a carbon sink absent any human intervention. A pile of slowly decomposing coarse woody debris in boreal forests, structural timber that would otherwise remain in use, or biotic soil amendments that would remain below the soil surface all hold carbon that would have stayedremain out of the atmosphere for longmeaningful periods regardlessin the absence of any Project intervention, sometimes exceeding the duration of carbon removals issued under other pathways.

Ignoring this feature of the biomass's lifecycle can lead to overstated claims of atmospheric benefits of a CDR Project. Consider the example of a BECCS Project sourcing biomass from slowly decomposing wood with a half-life of several decades. Without counterfactual accounting, assuming carbon neutrality, the Project has limited atmospheric benefit for the first several decades, compounded by establishment emissions and capture inefficiencies that accelerate carbon release, rather than halting it in the near term.

We exercise this requirement through the term "counterfactual storage". We define counterfactual storage as the carbon that would have remained stored in the biomass in the absence of the Project's intervention. ThisOnly isthe alsofraction toof ensurebiomass Projectcarbon activitiesthat would have abeen measurable impactreleased in mitigatingthe near- term climaterepresents changean additional atmospheric benefit when captured and todurably incentivize the use of feedstocks with the most near-term impactsstored.

3

2.4.1 Residue Counterfactual Fate

To Evidencinginform Requirements

Projectthe Proponentscounterfactual storage assessment, all Projects must demonstrate thatdefine the counterfactual fate hasof beentheir properlyfeedstock, assesseddefined as what most likely would have happened to the feedstock in the absence of Project intervention, by demonstrating compliance with the following Counterfactual Fate (CF) criteria. This is integral to carbon accounting and theinforms both counterfactual storage hasand beenmarket appropriately quantifiedleakage. OnceCritically, this is a consideration for what would most likely have happened to the feedstock's counterfactualin the absence of the Project based on evidence, not an assumption of what could have happened given the feedstock characteristics. Isometric recognizes the complications of predicting feedstock utilization across a future scenario and encourages Project Proponents to take into account the historical fate hasof beenthe establishedfeedstock, it'sregulatory determinedshifts fateand isdeclining/growing industries.

Counterfactual storage assessments are valid for 10the yearsduration of the Crediting Period, provided the feedstock sourcing does not materially change. UnderA exceptionalmaterial circumstanceschange whereis defined as a change in Sourcing Region, feedstock specification or counterfactual fate, or an increase in feedstock consumption that invalidates the existing assessment, which voids the assessment and requires resubmission. Where the Project or Isometric identifies a significant change to the understood counterfactual fate of a feedstock, Isometric reservesmay therequire rightreassessment toand may conduct an audit to ensureconfirm feedstocksthat continuethe feedstock continues to meet the criteria laid out in this Module. TypicallyA Project Proponent may request reassessment on the grounds of drastic market shifts, regulatory shifts or the evolution of modeling approaches.

Table 13 – Counterfactual Fate Criteria

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2.4.2 Residue Counterfactual Criteria

Storage

Some Residue Feedstocks carry negligible risk of counterfactual storage and, with robust evidence, do not need to quantify counterfactual storage. All feedstocks eligible for creditingProjects must meetdemonstrate compliance with one of the following criteria listed in Table 2 to evaluatedetermine whether counterfactual storage.

[math: CO_2e_{Counterfactual,i} = CO_2e_{Feedstock,i} - min(CO_2e_{CFEmissions,i,(0,15)}, \\ CO_2e_{Feedstock,i} - CO_2e_{CFStorage,i,50})]

3.3 Counterfactual Storage Calculation Requirements

Feedstocks that do not meet CC1 or CC2 within Table 2 must quantify counterfactual storage. Biogenic carbon that would likely be stored in the biomass for the next 15 years 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.

Biomass decay that would leadProtocol to additional carbon storage in the landscape is taken into account (e.g., soil organic carbon gains from biomass decay). This effect may be nonlinear and Project Proponents can provide evidence of its negligibility at the feedstock removal rates.

Counterfactual storage is reported in CO2e units. Counterfactual emissions are evaluated asrepresent the CO₂e using the 100-year Global Warming Potential (GWP), GWP100,content of allfeedstocks releasedto GHGsgenerate withinremovals (e.g., in subsurface biomass storage pathways).

[math: 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. Example calculations can be found in Appendix 6.

Equation 1 and equation 2 must be summed across all feedstock batches used in a given Reporting Period prior to quantifybeing subtracted from removals at the totalProtocol CO2elevel thatusing isthe ineligiblefollowing for Crediting.equation:

[math: CO_2e_{Counterfactual,\  xRP}\ \  = \ \sum_{i=1}^{N_B} CO_2e_{Feedstock} \ \ - \ \ CO_2e_{CounterfactualEmissionsCounterfactual,i}]

(Equation 15)

[math: CO_2e_{CounterfactualEmissions} \ \ = \ \ min(CO_2e_{CounterfactualEmissions15}, \ \  CO_2e_{Feedstock}\ \ - \ \ CO_2e_{CounterfactualStorage50})]

(Equation 2)

Where:

• [math: CO_2e_{Counterfactual,\ xRP}] - The mass of biogenic carbon that is ineligible for crediting, in tonnes of CO2e, for batch [math: x].
• [math: CO_2e_{Feedstock}] - The mass of biogenic carbon within the feedstock, in tonnes of CO2e, for batch [math: x].
• [math: CO_2e_{CounterfactualEmissions}] - The mass of biogenic carbon eligible to count towards gross removals, in tonnes of CO2e, for batch [math: x].
• [math: CO_2e_{CounterfactualEmissions15}] - The mass of CO2e emissions that would be emitted from the feedstock in the counterfactual within 15 years, for batch [math: x].
• [math: 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 [math: x].

For each Reporting Period, [math: CO_2e_{Counterfactual}] must be aggregated across all feedstock batches, where [math: n] is the total number of batches:

[math: CO_2e_{Counterfactual}\ \  =\ \  \sum_{x=1}^{n}\ CO_2e_{Counterfactual,\  x}]

(Equation 3)

Where:

• [math: CO_2e_{Counterfactual}] - The total mass of biogenic carbon that is ineligible forto creditinggenerate removals in the Reporting Period, in tonnes of CO₂e.
• [math: N_B] = The number of feedstock batches used within the Reporting Period.

Where [math: CO_2e_{Counterfactual}] is less than 1% of the biogenic carbon contained within the feedstock batch at the point of utilization, the counterfactual storage for that feedstock batch may be recorded as zero. This is due to the recognized uncertainty associated with determining a stable counterfactual fate across the Crediting Period, the associated uncertainty and conservative parameterization of counterfactual decay modeling, together with increasing global temperatures, extreme weather events, as well as increased biomass utilization projections.

2.4.5.1 Dynamic Counterfactual Storage

Where a feedstock acts as a counterfactual carbon sink, and Equation 4 results in counterfactual storage greater than the carbon that would remain stored at year 50, the Project Proponent may choose to account for counterfactual emissions dynamically over the Crediting Period, in addition to the upfront issuance determined under Equation 4. This is not a default requirement, but may be pursued by the Project Proponent when desired. The upfront issuance is unchanged: it remains the eligible biogenic carbon determined by the counterfactual emissions evaluated over the first 15 years, subject to the 50-year storage ceiling. Thereafter, the Project may accrue the residual biogenic carbon, determined by the counterfactual emissions that would have been released after year 15 in the counterfactual, as the Project persists, up to a counterfactual horizon of 50 years. This issuance is known as a tail issuance. Biogenic carbon that would have remained stored in the counterfactual beyond 50 years is considered durably stored and is never eligible to generate removals.

To quantify the residual tail issuances, the following equations must be used:

[math: CO_2e_{Tail,i,n} = min\left( CO_2e_{CFEmissions,i,\left( 15,T_n \right)}, CO_2e_{Counterfactual,i} - CO_2e_{CFStorage,i,50} \right)\ \\ - min\left( CO_2e_{CFEmissions,i,\left( 15,T_{n - 1} \right)}, CO_2e_{Counterfactual,i} - CO_2e_{CFStorage,i,50} \right)]

(Equation 6)

Where:

• [math: CO_2e_{Tail,i,n}] = The residual tail removal volume issued for feedstock batch [math: i] at timestep [math: n], expressed in tonnes of CO₂e.
• [math: CO_2e_{CFEmissions,i,\left( 15,T_n \right)}] = The GHG emissions that would have been counterfactually emitted from batch [math: i], between year 15 and year [math: T_n], expressed in tonnes of CO₂e.
• [math: n] = The number of Reporting Periods since batch [math: i] was utilized. For batch [math: i] in Reporting Period [math: m], [math: n = m - m_i]. For each feedstock batch at utilization [math: n = 0].
• [math: MarketT_n] Leakage= EmissionsThe residual tail assessment endpoint, where [math: T_n\ = \ min(15\ + n\Delta t, 50)]. Tail issuances for timestep [math: n \geq 1] are assessed as the counterfactual emissions that would have occurred between [math: T_{n - 1}] and [math: T_n]. No tail issuance accrues at [math: n = 0].
• [math: \Delta t] = The Reporting Period timestep size, expressed in years. For monthly issuance, [math: \Delta t = \frac{1}{12}].

[math: CO_2e_{Tail,m} = \sum_{i:\, m_i < m} CO_2e_{Tail,i,m - m_i}]

Sourcing(Equation feedstocks7)

Where:

• [math: CO_2e_{Tail,m}] = The total tail issuance to be issued in Reporting Period [math: m], expressed in tonnes of CO₂e.
• [math: m] = The Reporting Period index for the purposeProject, unitless, where [math: m = 0] for the first Reporting Period of the Project.
• [math: m_i] = The Reporting Period in which feedstock batch [math: i] was utilized.
• [math: \{i : m_i < m\}] = The set of feedstock batches [math: i] utilized in a Reporting Period before [math: m] (i.e., [math: m_i < m]), over which the sum is taken.

Tail issuances will only be issued to the Project while the Project is registered with Isometric.

2.4.6 Residue Counterfactual Storage Modeling

The quantification of [math: CO_2e_{CFEmissions,i,(0,15)}], [math: CO_2e_{CFStorage,i,50}] and, where dynamic tail issuance is used, [math: CO_2e_{CFEmissions,i,(15,T_n)}] requires modeling based on the counterfactual fate. Across all modeling approaches the following requirements apply:

• Parameters must be selected conservatively, so that the model produces a quantification of counterfactual storage that does not overstate the atmospheric benefits of the Project. Where parameter ranges exist, the selection of the lowest counterfactual emission estimate must be applied unless justified by Project-specific data.
• For feedstock comprising multiple components with different decay kinetics (e.g., lignin, hemicellulose), the decay rate of the most recalcitrant component must be used as the basis for counterfactual storage modeling unless a multi-pool model is applied.
• All inputs, parameter sources, assumptions and outputs must be fully documented and reproducible by an auditor. Modeling must be traceable to peer-reviewed literature or published national inventory methodology.
• Custom/proprietary models may be used by the Project Proponent; however, sufficient documentation must be provided to Isometric and the VVB to verify model structure, inputs and outputs.
• Climate parameters must be representative of the Sourcing Region and drawn from a recognized meteorological dataset, public climate classifications or from peer-reviewed literature.
• For forestry residues left to decay on the forest floor and agricultural residues left in-field in the counterfactual, counterfactual decay may lead to additional carbon storage in the landscape, such as the stabilization of biogenic carbon into soil carbon pools. This must be considered in the quantification of [math: CO_2e_{CFStorage,i,50}] (e.g., decay rates must represent the release of GHGs to the atmosphere, rather than simply the decay rate of the feedstock). This effect may be non-linear with the feedstock removal rate, and the Project Proponent may exclude it only by providing cited evidence of its negligibility at the Project's removal rate for the relevant soil and climate.

Project Proponents may apply published default decay rates and emission factors from frameworks without bespoke modeling. Currently acceptable sources are as follows, subject to a demonstration of feedstock and fate equivalence. Other sources may be evaluated on a case-by-case basis:

• IPCC 2006 Guidelines for National GHG Inventories, Volume 4 (AFOLU) and Volume 5 (Waste), and the 2019 Refinement.
• National GHG inventory submissions to the UNFCCC where country-specific Tier 2 or Tier 3 values are published for the relevant feedstock and climate category.

The following models are capable of producing central to conservative estimates when parameterized in accordance with the general requirements above and are therefore recommended by Isometric.

Table 15 – Recommended Model Frameworks

Where the models listed above are inappropriate for the feedstock type or regional context, Project Proponents may propose alternative models with appropriate justification. Proposals must demonstrate that the model is peer-reviewed and validated against field-measured data, and that conservative parameterization is achievable and documented.

2.5 Residue Market Leakage

When a BiCRS Project sources a feedstock, it can lead to an increase in GHGgreenhouse gas emissions resultingthat fall outside the Project's system boundary by removing a feedstock from changesits toexisting market, or generating new demand which causes adjustments in the supply and demand equilibrium, also called market leakage. ForThe example,indirect 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). Feedstocks that do not meet the criteria establishedincrease in TableGHG 3emissions arecaused deemed ineligible under the current Module due to high risks of significant market leakage. Market leakage must be evaluated in all cases using the criteria within Table 4.

Onceby a Project's effect on feedstock markets is known as "market leakage".

For example, a Project that sources constrained woody residues that would otherwise have been used for bioenergy displaces energy production that will likely be backfilled by a fossil fuel generator. In this context, the Project's removals overstate its net climate impact if these displacement effects are ignored.

Isometric requires an assessment of this emissions impact. Consistent with consequential life-cycle assessment and with partial-equilibrium displacement modeling of biomass markets, the default assumption, identical to counterfactual storage, is that the marginal replacement product – the most economic alternative use of the feedstock, or the material existing users would switch to in its absence – determines the relevant leakage pathway, as this reflects the most probable market response to its removal. Displacement need not be one-for-one: where a Project quantifies leakage under ML1 it must state and justify the displacement factor applied. This assumption is changed if the Project provides sufficient evidence in Section 2.4.1 to demonstrate an alternative fate of the feedstock.

Isometric determines that there are no market leakage emissions associated with certain feedstock sourcing situations. This includes situations where the revenue provided to the supplier for the feedstock is identifiedinsufficient to influence sourcing behavior or divert from productive use, when there is a demonstrable history of disposal of that feedstock or absence of alternative uses, or when a Project is an Eligible Retrofit or Integration Project as eligibledefined in Appendix E.1.

This is independent of the counterfactual storage requirements. A feedstock with zero counterfactual storage – one that would have been combusted immediately in the counterfactual – may still carry market leakage if its combustion would have served a useful energy function. Conversely, a feedstock with significant counterfactual storage, such as woody debris in an arid climate, may have zero market leakage if it maintainshad it'sno eligibilityalternative use.

This section contains two parts. The first part provides requirements for a periodfeedstock to demonstrate zero leakage associated with feedstock sourcing, or the requirement for Projects to quantify the market leakage associated with their feedstock. The second part provides detailed steps for a Project to quantify the market leakage associated with their feedstock sourcing. Projects that must quantify the market leakage associated with sourcing may still qualify for zero market leakage emissions, depending on the outcome of 10the yearsmarket providedleakage assessment.

2.5.1 Residue Market Leakage Criteria

All feedstock submissions must demonstrate compliance with one of the following market leakage (ML) criteria to determine if Project feedstock sourcing doesbehavior notcan change.be Underassigned exceptional circumstances where Isometric identifies a significant risk of substantialzero market leakage, Isometricemissions reservesor the rightProject is required to conductquantify anmarket auditleakage emissions. ML2 - ML7 each allow a Project to ensuredemonstrate feedstocksthat continuetheir tofeedstock meetsourcing produces no market leakage emissions, depending on the criteriascenario. laidWhere outa Project cannot comply with one of these, the Project Proponent must quantify market leakage emissions in thisline Modulewith ML1. A quantification of market leakage emissions may still result in zero market leakage emissions depending on the Project scenario.

The following informationdecision musttree can be submitted every 10 years:

• Project Proponents must demonstrate that feedstocks adhereused to oneassist in the selection of the criteria within Table 3 to be eligible under this Module.
• Project Proponents must demonstrate that feedstocks adhere to one of the criteria within Table 4, to evidence thatappropriate market leakage hascriterion.

  Figure been2 evaluated– Market Leakage Decision Logic

  Table 16 – Market Leakage Criteria

  [Image: BFAv1.4Figure2V5]

  Criterion In cases where the feedstock is not considered to generate market leakage, evidence must be provided against the relevant criteria to demonstrate 0 market leakage emissions. 4.1 Prohibited 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 materialsID and furniture. There are exceptions under specific circumstances. To establish feedstock eligibility, the feedstock must meet the relevant criterion outlined in Table 3Type. Table 3 Prohibited Feedstocks Criteria Requirement Documentation RequiredRequirements PF1 Applicable ML1: to non-woody feedstocks:  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 Project Proponent must providequantify evidencemarket thatleakage emissions associated with the feedstock wassourced. notThis producedcriterion foronly bioenergy use for 2 years priorapplies to thefeedstock Project'ssubmissions firstthat procurementare datenon-compliant with ML2 - ML7. PF2 ML1.1Validation and Verification Requirement Applicable to woody feedstocks:  The feedstock must not be suitable for use as a component of long [R-lived wood products or pulpwood (e.g68S0-1, 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. The Project Proponent must provideconservatively evidence ofquantify the market leakage emissions associated with feedstock lifecycle including generation and utilization/disposal for 2 years prior to the Project's first procurement datesourcing.  Feedstocks sourced from wildfire mitigation programs are exempt from this requirement if the] The Project Proponent canmust provideconservatively evidence thatquantify the feedstock was sourced by, or to meet the clear goals of, a government supported wildfire mitigation program, including evidence of program participation and chain-of-custody. 4.2 Evaluating Market Leakage 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 [math: CO_2e_{Leakage}], associated with feedstock sourcing, in accordance with Section 2.5.2. Table 4 ML1: Quantify Market Leakage [/R-68S0-1] Criteria Documentation [G-X3CC-0, Required ML1The Project Proponent must demonstrate that market leakage has been quantified.1 ] The Project Proponent must provide all of the following: A referenced, conservative quantification of [math: CO_2e_{Leakage}] per tonne of feedstock in accordance with the feedstockmethodology isin quantified (SeeSection Section2.5.2. All 4.3 for details). The Project Proponent must quantify the emissions associated with market leakagedocumentation and provide the documentationliterature used in this quantification including references,. All data- sets and assumptions used in this quantification. ML2: A CCS retrofits where baseline facility emissions exceed capture capacity. For feedstocks that meet bothjustification of any conservative adjustments made to account for uncertainty, identifying the followingspecific criterialeakage risk pathway and feedstock market characteristics the adjustment addresses, with sensitivity analysis demonstrating the adjustment effect on the quantified [math: CO_2e_{Leakage}\] =\where applicable. [/G-X3CC-0]. Criteria Documentation Required ML2.1 The Maximum Biogenic Carbon Utilization 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 Utilization Rate, after subtracting both the Baseline Emission Rate and any parasitic load of the retrofit infrastructure. All values are expressed in feedstock equivalent units. Documentation demonstrating the Baseline Emission Rate over the last 5 years and an evidenced calculation of the Maximum Biogenic Carbon Utilization Rate of the CCS infrastructure (See Appendix 4: for calculation requirements). ML2.2 All feedstock sourced outside the baseline, including any feedstock sourced to meet parasitic energy requirements or reductions in the facility's primary outputs, must be accounted for under another market leakage criteria. A quantification of the parasitic load, and/or any decrease in the primary output of the facility due to the retrofit infrastructure and evidence of how this is accounted for. ML3: Retrofit baseline feedstocks. For feedstocks that meet both of these criteria, [math: CO_2e_{Leakage}\ =\ 0]. Criteria Documentation Required ML3.1 The facility feedstock consumption remains consistent in mass and sourcing compared to the pre-retrofit baseline. A quantification of the Baseline Feedstock Consumption Rate for the facility for 5 years prior to the retrofit installation (See Appendix 4 for calculation requirements). ML3.2 All feedstock sourced outside the baseline, including any feedstock sourced to meet parasitic energy requirements or reductions in the facility's primary outputs, must be accounted for under another market leakage criteria. A quantification of the parasitic load, and/or any decrease in the primary output of the facility due to the retrofit infrastructure and evidence of how this is accounted for. ML4: The Project Proponent does not contribute significantly to the revenue of the feedstock supplier. For feedstocksFeedstocks that meetdemonstrate thiscompliance criteriawith ML2.1 are considered to have no market leakage emissions, therefore [math: CO_2e_{Leakage}\] =\ 0] for every batch of the feedstock. Criteria Documentation Required ML4 ML2.1Validation Requirement [R-17BZ-1, The Project Proponent's contribution to the revenue of the feedstock supplier is negligible, with no other upstream incentives (e.g., revenue sharing, side payments, or in-kind benefits) provided to the supplier.] The Project Proponent's contribution to the revenue of the feedstock supplier is negligible, with no other upstream incentives (e.g., revenue sharing, side payments, or in-kind benefits) provided to the supplier. Where the feedstock supplier is a related party2 of the Project Proponent, this criterion cannot be used. Where feedstocks have a demonstrable counterfactual economic use, this option is unavailable. [/R-17BZ-1] [G-GR81-0, The Project Proponent must demonstrate one ofthat the following: Therepayment, wasrevenue nocontribution paymentor benefit sharing made to the feedstockupstream supplier forwill thenot feedstock. The payment made to theinfluence feedstock supplier is equal toproduction or lower than the recovery, transportation and replacement costs6diversion. The Project Proponent was paid for the removal of the feedstock, such as a tipping fee. The Project Proponent paid a third party, whose sourcing activities also adhere to one of the above. ] The Project Proponent must provide one of the following: Purchase Evidence that the Project receives the feedstock for free, and no other revenue/removalbenefit recordssharing betweenis made upstream. Evidence that revenue contributed to the feedstock supplier, including revenue sharing and in-kind benefit, is equivalent to, or less than, the cost of feedstock recovery and transportation. Evidence that the Project Proponent andis paid a tipping/gate fee to accept the feedstockmaterial, supplierwith demonstratingno other upstream incentives such as revenue sharing or in-kind benefit. A benchmarked market analysis of the priceco-products paidproduced by the supplier, calculated per unit of feedstock produced, which demonstrates that revenue contributions, including revenue sharing or in-kind benefit, are equal to or lower than the cost of recovery and evidence of how this adheres to this criteriatransportation. A signedlegally binding affidavit from thea qualified, independent third party with specific regional and industry experience, verifying that payments of this scale and nature to these types of suppliers in the given sector and region would not reasonably affect sourcing, production, or management practices, backed by supporting evidence such as customary local transaction patterns. [/orG-GR81-0] ML3: There is a surplus of feedstock supplierthat is not in demand or that the thirdmarket partycannot isabsorb. notFeedstocks providingthat paymentdemonstrate exceeding the recovery, transportation and replacement costs. ML5: There is an excess supply of feedstockcompliance with anML3.1 economicand purposeML3.2 Forare feedstocksconsidered thatto meethave bothno ofmarket theleakage followingemissions, criteria,therefore [math: CO_2e_{Leakage}\] =\ 0] for every batch of the feedstock. Criteria Documentation Required ML5 ML3.1Validation Requirement [R-MW7M-1, The feedstock is demonstratedin to serve an economic purpose7 andsurplus: the Projectvolume Proponentavailable can demonstrate a local supply excess (e.g., stablemeets or growing stockpiles), that theexceeds Project won'tdemand. exceed. TheThis Projectis Proponentdemonstrated musteither provide all of the following: Historical contracts betweenbecause the feedstock supplierserves no counterfactual economic purpose and theis end-use/disposalnot sites. Asourced quantification ofabove the Baseline Feedstock Generation Rate, overor because regional supply exceeds demand and the previousmarket 5cannot yearsabsorb (Seethe Appendixsurplus.] The 4 for details). Where this detailfeedstock is unavailable,in ansurplus: affidavitthe fromvolume available meets or exceeds Project demand. This is demonstrated either because the feedstock supplierserves demonstratingno counterfactual economic purpose and is not sourced above the historicalBaseline fateFeedstock ofGeneration Rate, or because regional supply exceeds demand and the feedstockmarket maycannot beabsorb consideredthe surplus. [/R-MW7M-1] [G-4D3P-0, subject to third-party verification (e.g., a VVB). ML5.2 The Project Proponent must demonstrate that the pricesupply paid toof the feedstock supplier was not significant, leading to increased production. This must be demonstrated by one ofmeets the following: Ademand demonstrationfor thatexisting users plus the priceProject paiddemand toat the feedstock supplier for the feedstock does not exceed 5% of the total revenue generated from the feedstock supplier's operationsscale. A demonstration that the price paid to the feedstock supplier does not exceed 2x the cost the feedstock supplier would have paid for disposal.  A demonstration that the price paid to the feedstock supplier for the feedstock is less than 5% of the total benchmark-priced revenue. This revenue is derived from all marketed products and calculated per unit of residue produced. ] The Project Proponent must provide one of the following: Purchase/removal records between the Project Proponent and the feedstock supplier demonstrating the price paid and evidence of how this adheres to this criteria. 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. Where this detail is unavailable, an affidavit from the feedstock supplier that documents payments made for the feedstock by the Project Proponent do not constitute a large share of upstream operations revenue. ML6: Excess residue productions with no economic purpose. For feedstocks that meet both of the following criteria, [math: CO_2e_{Leakage}\ =\ 0]. Criteria Documentation Required ML6.1 The feedstock is demonstrated to serve no economic purpose and the Project Proponent will not use the feedstock above the-level Baseline Feedstock Generation Rate, demonstrated over the look-back period set out in Appendix D. The2, showing that the surplus available after existing offtakes meets or exceeds Project Proponentdemand. Evidence mustthat providea allregional production surplus of the followingfeedstock has been sustained for a minimum of three years and meets or exceeds Project demand, net of other existing and committed offtakes. This could be established through: Historical contracts between the feedstock supplier and the end-use/disposal sites. A quantificationprovision of thea Baselinelegally Feedstockbinding Generationaffidavit Ratewith overcorroborating theevidence previousof 5 years (See Appendix 4 for details). Where this detail is unavailable,stockpiles; an affidavit from an industry expert with relevant regional experience, regional waste statistics or data; government data on feedstock generation; or an independent third-party audit. Evidence that the feedstock supplieris subject to a statutory or regulatory obligation requiring disposal, such that no alternative use is available. Contracts or disposal records demonstrating that the feedstock has had no market purchasers for a minimum of three years prior to the Project start date, and that the feedstock was not transferred (free of charge or otherwise) to a productive use such as energy recovery, animal bedding or soil amendment. Evidence that the feedstock is a controlled waste at the terminal point of its value chain, such as waste classification or waste disposal records, demonstrating the historicalcounterfactual fateuse ofis thenot feedstock may be considered, subject to third-party verificationproductive (e.g., in the absence of the Project the feedstock would not have been used for energy production or for Refuse-Derived Fuel (RDF)). Evidence that the market price for the feedstock has been negative for the last three years, such that the feedstock supplier or generator is required to pay for its removal, and that the disposal route involves no energy or material recovery (e.g., landfill without landfill-gas-to-energy, open burning, or incineration without energy recovery) (e.g., tipping fee records or disposal invoices). Evidence that removal of the feedstock is mandated under an environmental, safety, or land management permit, order, or plan (e.g., hazard mitigation, invasive species control, or wildfire fuel load reduction), demonstrating that retaining the feedstock in its current state would be ecologically or environmentally detrimental, together with evidence that, once removed, the feedstock would be disposed of without productive use. An independent ecological or technical assessment that the feedstock, if left in its current state and location, would provide no economic or environmental function. Evidence of an operational or physical storage/handling constraint requiring disposal of the feedstock – such as a VVBlegally binding attestation from the facility operator, corroborated by dated inventory or photographic records demonstrating that on-site storage capacity has been reached or is imminently exceeded, and that no additional storage or handling capacity is reasonably available. Evidence that the feedstock is certified under the RSB Low ILUC Risk Biomass Module (RSB-STD-04-001) (satisfying Criterion 1.1 and either (a) Criterion 1.2 or (b) Criteria 1.3 and 1.4), demonstrating the material is an eligible waste/residue that is generally discarded via landfilling or incineration in the region where it is generated, or was not previously used for electricity generation, heat and power, soil inputs, or as food, feed, or fiber. Equivalent schemes, accompanied by a demonstration that the scheme's criteria are equivalent in scope and rigor to RSB-STD-04-001, may be considered on a case-by-case basis. [/G-4D3P-0] ML6 ML3.2Validation Requirement [R-QQ1Y-0, The Project Proponent's financial contribution to the feedstock supplier is below the threshold that would reasonably incentivize changes in feedstock production, sourcing or management behavior.] The Project Proponent's financial contribution to the feedstock supplier is below the threshold that would reasonably incentivize changes in feedstock production, sourcing or management behavior. Where the feedstock supplier is a related party2 of the Project Proponent, this criterion cannot be used. [/R-QQ1Y-0] [G-R1ZB-0, The Project Proponent must demonstrate the price paid to the feedstock supplier was not significant, leading to increased production. This must be demonstrated by one of the following: A demonstration that the pricepayment, paidrevenue tocontribution theor feedstockbenefit suppliersharing made upstream for the feedstock doeswould not exceedreasonably 5%incentivize an increase in production of the total revenue generated from the feedstock supplier's operations. A demonstration that the price paid to the feedstock supplier does not exceed 2x the cost the feedstock supplier would have paid for disposal.  A demonstration that the price paid to the feedstock supplier for the feedstock is less than 5% of the total benchmark-priced revenue. This revenue is derived from all marketed products and calculated per unit of residue produced. ] The Project Proponent must provide one of the following: Purchase/removal Evidence recordsthat betweenpayments from the Project Proponentconstitute and10% or less of the total revenue generated by the feedstock supplier. demonstratingThis may include: feedstock supplier financial records; or a benchmarked market analysis of the price paid and evidence of how this adheres to this criteria. Evidence of all marketed co-products associatedproduced withby the feedstock productionsupplier, a quantification of marketed products productioncalculated per unit of feedstock andproduced, anwhich evidenceddemonstrates price point forthat the sumProject's revenue contributions constitute 10% or less of the productstotal producedrevenue generated by the feedstock supplier. Where Evidence thisthat detailthe ispayments unavailable,would annot alter feedstock generation behavior. This could include: a legally binding affidavit from the feedstock supplier; evidence that documentsthe paymentsprice madepaid for the feedstock is at or near the cost of its transport, handling, and/or disposal, such that the payment does not exceed what the supplier would otherwise have spent to dispose of the material; or a legally binding affidavit from an industry expert with relevant regional experience. Evidence that the Project's total annual payment to an individual feedstock supplier does not exceed 10% of the average annual income per person in the supplier's country, as measured by the ProjectWorld ProponentBank's doGNI notper constitutecapita, PPP6 (current international figure used). [/G-R1ZB-0] ML4: The feedstock serves an economic use, but can be extracted/diverted at a large share of upstream operations revenue. ML7: Sustainable Usage Rate. ofFeedstocks feedstocksthat demonstrate compliance with anML4.1 economicand purposeML4.2 Forare feedstocksconsidered thatto meethave bothno ofmarket theleakage followingemissions, criteria,therefore [math: CO_2e_{Leakage}\] =\ 0] for every batch of the feedstock. Criteria Documentation Required ML7 ML4.1Validation or Verification Requirement [R-W5YY-1, The feedstock ismust demonstratednot tobe serveextracted/diverted an economic purpose andabove the Sustainable Usage Rate.] The feedstock must not be extracted/diverted above the Sustainable Usage Rate. [/R-W5YY-1] [G-BPV0-0, The Project Proponent is able tomust demonstrate that the Project will not exceed the Sustainable Usage Rate ofat which the feedstock can be extracted and adhere to this limit. ] The Project Proponent must provide all of the following: A conservativea quantification of the Sustainable Usage Rate, overdemonstrating that existing services fulfilled by the previousfeedstock 5will yearsnot be impacted by feedstock extraction/diversion, with evidence that the Project's contracted volume does not exceed the SUR. This quantification must be conducted using one of the following: A recognized, field-specific erosion and soil-quality modeling methodology (Seee.g., AppendixUSDA 4NRCS's RUSLE2 and Soil Conditioning Index, RUSLE/USLE, WEPP, EPIC/APEX, or a national soil conservation model), applying site-specific soil, slope, climate, tillage, and yield inputs, conducted or reviewed by a qualified agronomist or NRCS-certified Technical Service Provider (or regional equivalent). An alternative quantification methodology, with a referenced justification of its suitability for details). Allthe data-setsfeedstock, assumptions,previous referencesapplication and documentation usedregion in question, subject to a review from Isometric. Where the quantificationexisting service fulfilled by the feedstock is a non-market competing demand (e.g., manure relied upon locally for fertilization), the competing demand Sustainable Usage Rate set out in Appendix D.1.2. [/G-BPV0-0] ML7 ML4.2Validation Requirement [R-Z0S8-0, The Project Proponent's financial contribution to the feedstock supplier is below the threshold that would reasonably incentivize changes in feedstock production, sourcing or management behavior.] The Project Proponent's financial contribution to the feedstock supplier is below the threshold that would reasonably incentivize changes in feedstock production, sourcing or management behavior. Where the feedstock supplier is a related party2 of the Project Proponent, this criterion cannot be used. [/R-Z0S8-0] [G-ZBPN-0, The Project Proponent must demonstrate the price paid to the feedstock supplier was not significant, leading to increased production. This must be demonstrated by one of the following: A demonstration that the pricepayment, paidrevenue tocontribution theor feedstockbenefit suppliersharing made upstream for the feedstock doeswould not exceedreasonably 5%incentivize an increase in production of the total revenue generated from the feedstock supplier's operations. A demonstration that the price paid to the feedstock supplier does not exceed 2x the cost the feedstock supplier would have paid for disposal.  A demonstration that the price paid to the feedstock supplier for the feedstock is less than 5% of the total benchmark-priced revenue. This revenue is derived from all marketed products and calculated per unit of residue produced. ] The Project Proponent must provide one of the following: Purchase/removal Evidence recordsthat betweenpayments from the Project Proponentconstitute and10% or less of the total revenue generated by the feedstock supplier. demonstratingThis may include: feedstock supplier financial records; or a benchmarked market analysis of the price paid and evidence of how this adheres to this criteria. Evidence of all marketed co-products associatedproduced withby the feedstock productionsupplier, a quantification of marketed products productioncalculated per unit of feedstock andproduced, anwhich evidenceddemonstrates that the Project's revenue contributions constitute 10% or less of the total revenue generated by the feedstock supplier. Evidence that the payments would not alter feedstock generation behavior. This could include: a legally binding affidavit from the feedstock supplier; evidence that the price pointpaid for the sumfeedstock is at or near the cost of its transport, handling, and/or disposal, such that the payment does not exceed what the supplier would otherwise have spent to dispose of the productsmaterial; producedor a legally binding affidavit from an industry expert with relevant regional experience. Where Evidence thisthat detailthe Project's total annual payment to an individual feedstock supplier does not exceed 10% of the average annual income per person in the supplier's country, as measured by the World Bank's GNI per capita, PPP6 (current international figure used). [/G-ZBPN-0] ML5: The feedstock is unavailableobtained from Eligible Wildfire Mitigation activities. Feedstocks that demonstrate compliance with ML5.1 and ML5.2 are considered to have no market leakage emissions, therefore [math: CO_2e_{Leakage}] = 0 for every batch of the feedstock. ML5.1Validation Requirement [R-JNMX-0, The feedstock is a Residue from wildfire mitigation activities.] The feedstock is a Residue from wildfire mitigation activities. [/R-JNMX-0] [G-K0JA-0, The Project Proponent must provide evidence that the feedstock is sourced from Eligible Wildfire Mitigation activities as defined in Appendix E.2.] The Project Proponent must provide evidence that the feedstock is sourced from Eligible Wildfire Mitigation activities as defined in Appendix E.2. [/G-K0JA-0] ML5.2Validation Requirement [R-6AGJ-0, The feedstock does not have a competing use.] The feedstock does not have a competing use. [/R-6AGJ-0] [G-6NDZ-0, The Project Proponent must demonstrate that the feedstock would not have otherwise been used for an economic purpose.] The Project Proponent must provide one of the following: A signed affidavit from the feedstock supplier confirming the feedstock had no alternative economic/environmental use, corroborated by evidence such as evidence of previous disposal (disposal records, timestamped & geotagged photographic/videographic evidence). Evidence demonstrating there is a regional surplus of such residues that documentsmeets paymentsor madeexceeds the Project's demand. This may include instances where the Project or underlying facility for an Eligible Retrofit or Integration Project is specifically contracted to reduce the high-hazard fuel burden of a given region such as the BioRAM program. Evidence demonstrating the feedstock holds a negative market value in the given Sourcing Region over the preceding three years. Evidence that revenue contributed to the feedstock supplier, including revenue sharing and in-kind benefit, is equivalent to, or less than, the cost of feedstock recovery and transportation. Evidence of regional stockpiles or disposal data that meet or exceed the Project's demand for the feedstock over the preceding three years. [/G-6NDZ-0] ML6: The Project is an Eligible Retrofit or Integration Project that does not change the rate at which the feedstock is consumed by the underlying facility or the source of the feedstock and does not decrease the outputs of the underlying facility. Feedstocks that demonstrate compliance with ML6.1 and ML6.2 and ML6.3 are considered to have no market leakage emissions, therefore [math: CO_2e_{Leakage}] = 0 for every batch of the feedstock. ML6.1Validation Requirement [R-SXMN-1, The Project is an Eligible Retrofit or Integration Project.] The Project is an Eligible Retrofit or Integration Project. [/R-SXMN-1] [G-1M0Y-0, The Project Proponent must demonstrate compliance with the requirements laid out in Appendix E.1.] The Project Proponent must demonstrate compliance with the requirements laid out in Appendix E.1. [/G-1M0Y-0] ML6.2Validation and Verification Requirement [R-DJGA-1, The Baseline Feedstock Consumption Rate for the underlying facility is defined and remains unchanged by the Project.] The Baseline Feedstock Consumption Rate for the underlying facility is defined and remains unchanged by the Project. [/R-DJGA-1] [G-N8WK-0, The Project Proponent must provide a quantification of the Baseline Feedstock Consumption Rate as defined in Appendix D.3 and continue to report this for each Reporting Period to ensure the Project does not affect the rate at which the underlying facility sources feedstock.] The Project Proponent must provide a quantification of the Baseline Feedstock Consumption Rate as defined in Appendix D.3 and continue to report this for each Reporting Period to ensure the Project does not affect the rate at which the underlying facility sources feedstock. [/G-N8WK-0] ML6.3Validation and Verification Requirement [R-8JTV-0, The rate of production of the outputs of the underlying facility remains unchanged by the Project.] The rate of production of the outputs of the underlying facility remains unchanged by the Project. [/R-8JTV-0] [G-8XR8-0, The Project Proponent must provide evidence that the Project does not change the production rate/volume of the underlying facility's Primary Products.] The Project Proponent must provide one of the following: An assessment of the input-to-output ratios of the underlying facility confirming the Project has not affected the production efficiency of the underlying facility. Monitoring data demonstrating that the output rate of all products has not been changed by the Project compared to the pre-intervention baseline over the five years prior to the Project intervention. Shorter look-back periods may be considered with appropriate justification in agreement with Isometric and the VVB. [/G-8XR8-0] ML7: The feedstock is consumed by the underlying facility regardless of the Project and the Project is an Eligible Retrofit or Integration Project. Feedstocks that demonstrate compliance with ML7.1 and ML7.2 are considered to have no market leakage emissions for the corresponding feedstock, therefore [math: CO_2e_{Leakage}] = 0 for every batch of the feedstock. This criterion set is specifically designed for Projects which Retrofit or Integrate an underlying facility with a heterogeneous feedstock baseline or where feedstock consumption can be reliably attributed to the demand for Primary Product production, where a continuous (pre- and post-Project) feedstock consumption rate cannot reasonably be assessed. ML7.1Validation Requirement [R-SZC7-0, The Project is an Eligible Retrofit or Integration Project.] The Project is an Eligible Retrofit or Integration Project. [/R-SZC7-0] [G-TA9M-0, The Project Proponent must demonstrate compliance with the requirements in Appendix E.1 and provide a justification for why ML6 cannot be complied with.] The Project Proponent must demonstrate compliance with the requirements in Appendix E.1 and provide a justification for why ML6 cannot be complied with. [/G-TA9M-0] ML7.2Validation and Verification Requirement [R-DM7W-0, The Project must account for any changes to feedstock sourcing, energy generation or changes in the export of Primary Products that are introduced by the Project to the underlying facility.] The Project must account for any changes to feedstock sourcing, energy generation or changes in the export of Primary Products that are introduced by the Project to the underlying facility. Where a Project results in a change to the export of the Primary Products of the underlying facility, the feedstock submission must account for this under ML1 and is ineligible for ML7, unless the facility operates within a binding emissions trading scheme in which increases in marginal power generation are met by a corresponding abatement of emissions, in which case the Project may reference this to remain compliant under this criterion. This includes where a bioenergy Retrofit or Integration reduces the quantity of energy exported to the grid compared to a non-capture baseline. The marginal reduction in export must be the basis for the leakage calculation. Where a Project increases or sustains the demand for feedstock, the marginal feedstock volumes must be conservatively quantified and assessed as a separate feedstock submission without invoking any documentation options afforded to Eligible Retrofit or Integration Projects. This includes cases where the Project draws energy from the underlying facility and, to compensate, the underlying facility sources more biomass. Where a Project introduces a parasitic load to the system that will be compensated by grid import or behind-the-meter, non-biomass-based energy generation, the feedstock is eligible under this criterion subject to robust accounting of the associated emissions in the Project's LCA. [/R-DM7W-0] [G-DZ59-0, The Project Proponent must demonstrate any impacts the Project has on the underlying facility and account for them where necessary.] The Project Proponent must provide evidence covering each of the effects listed in the Requirement column that is applicable to the Project, selecting from the following. Where an effect is not applicable, the Project Proponent domust notstate constitutewhy: Design specification demonstrating no parasitic load. Design specification demonstrating the energy requirements for the Retrofit or Integration Project and a large sharedeclaration of upstreamhow operationsthese revenuewill be accounted for by grid import or non-biomass behind-the-meter energy generation. 4.3 A Calculationlegally ofbinding Leakagestatement Emissions Iffrom the underlying facility or chief engineer confirming that the Project's introduces no parasitic load to the underlying facility, corroborated by a single independent site inspection or engineering sign-off, conducted after commissioning, confirming that no additional load-drawing equipment has been installed as part of the Project. Continuous monitoring data demonstrating no parasitic load before and after the Project intervention. Grid import/export records, combined with feedstock onlyinput qualifiesand forPrimary ML1Product withinoutput Tabledata 4demonstrating consistent volumes before and after Project establishment. Documentation demonstrating the method under which the parasitic load will be compensated, and the emissions associated with the production of the energy required to compensate for the parasitic load accounted for in the LCA. A conservative calculation demonstrating the marginal feedstock volumes required to compensate for the parasitic load and/or drop in Primary Product export, accompanied by a separate feedstock submission for the increased feedstock consumption that does not invoke any documentation options afforded to Eligible Retrofit or Integration Projects. This may be assessed directly as the change in continuous sourcing volumes of the underlying facility or through a bottom-up assessment of the relevant feedstock-to-energy ratio, using the assessed shortfall in energy output resulting from the Project divided by the energy content of the feedstock, correcting for any conversion inefficiencies. A demonstration that the power requirements of the Retrofit or Integration will be compensated for solely through a change in the export of electricity or heat, and the underlying facility exists within a binding emissions trading scheme approved under the Isometric BioCCS Protocol, such that any increase in emissions due to marginal energy generation will be met with a corresponding abatement. This includes the EU ETS when the Market Stability Reserve (MSR) does not trigger. Other emissions trading schemes may be eligible subject to a case-by-case review from Isometric. [/G-DZ59-0]