Environmental and Social Safeguards

This Module details the requirements for Environmental and Social Safeguards (ESS) for all Carbon Dioxide Removal (CDR) projects Crediting under the Isometric Standard. This Module identifies ESS requirements that are applicable for all projects. Some Projects may have additional, process specific considerations for safeguarding the environment and local communities, which are detailed in the relevant Isometric Protocol and/or Module.

Information provided by the Project Proponent will be reviewed by the Project's Validation and Verification Body (VVB), in consultation with Isometric. Some safeguards listed in this Module may have broad implications. For this reason, this Module describes risks to the environment and local communities that Project Proponents must consider when initiating a CDR project, but will not provide an exhaustive list of how risks may be safeguarded. A holistic approach will be taken to confirm that Environmental and Social Safeguards are upheld across all projects Credited under the Isometric Standard and pathway Protocols. Risks associated with project activities must be weighed alongside risks of climate change to support responsible innovation. The safeguards listed in this Module are a minimum set to consider, which the Project Proponent and Isometric may add to as needed, on a project-by-project basis.

The safeguards outlined in this Module encompass a wide range of considerations, including environmental protection, social equity, community engagement and respect for cultural values. Assessments and mitigation strategies must consider these environmental and social risk indicators at all project locations, from a Project’s construction, operation, decommission, and post-closure.

CDR Projects that are retrofitted within existing industrial operations must comply with the principles of Environmental and Social Safeguarding outlined in this Module for all activities beyond baseline industrial activities. Activities above the baseline must be identified in accordance with the system boundary diagram defined in the relevant Protocol and submitted in the Project Design Document (PDD).

This Module will be updated with changes in international regulation and policy, and as new social and scientific literature on the breadth and extent of environmental and social risks are better understood.

Environmental and social risks and co-benefits must be assessed at initial project validation, every subsequent re-validation, and whenever project operations or local conditions change significantly, in which case the Project Proponent must inform Isometric of the results of the reassessment. This assessment must include a discussion of project closure and post-closure.

Environmental and Social Safeguards must include, but are not limited to, the following ICVCM Core Carbon Principles¹:

Compliance: Project Proponents must comply with all national and local laws, regulations and policies. In the absence of stringent national regulations, Project Proponents must identify international conventions or standards governing human rights and uses of the environment relevant to their project activities to serve as guidance.

• Official Permitting: Project Proponents must document Project activities that require environmental permits, such as injection, encroachment, landfill or waste management permits, access agreements, or any federal, state or local air, water, or restricted land use operating permits. Project Proponents must provide a list of all permits or approvals submitted, current status, and compliance history.

Risk Identification: Project Proponents must fully assess the potential environmental and social risks of project activities within the geographical project area. Risk identification, impact assessment and mitigation plans must:

• be developed by subject matter experts, as evidenced by education, training, or experience².
• include, at a minimum, a discussion of resource efficiency, pollution prevention, labor rights and working conditions, land acquisition and involuntary resettlement, and environmental and social justice, including human rights and indigenous land rights.

Risk identification, impact assessment and mitigation plans should:

• include perception of risk. Community support of new projects and technologies is important for project success.
• be developed in collaboration with local communities.
• be reviewed by knowledgeable groups on behalf of the local communities.

Impact Assessment and Mitigation: Project Proponents must conduct an impact assessment and strategy for mitigation for each risk identified above. The impact of potential harms must be considered along with the positive climate benefit and potential co-benefits of CDR projects. Impact assessments may be qualitative or quantitative.

Project Proponents must include measures to avoid the risk in project design. Where the risk is demonstrably not avoidable, a strategy for risk mitigation must be established for all identified risks.

Project Proponents must demonstrate that Project activities do not harm communities situated near the Project area, as identified in the stakeholder engagement plan outlined in Section 7. Further, any adverse impacts must not disproportionately harm marginalized groups, or groups that were historically excluded from decision-making and resource control. Project Proponents should strive to benefit marginalized groups.

Monitoring and Adaptive Management: Implementation of risk mitigation measures must also be accompanied by a robust monitoring plan to ensure efficacy. ESS data collected for a project must be used to inform ongoing operational practices. Relevant data may be collected to comply with this Module, or from third party screening assessments, such as an Environmental and/or Social Impact Assessment (E/SIA). The Project Proponent must be prepared to adjust project operations based on monitoring results and feedback from environmental studies and community engagement.

• Project Proponents must preemptively develop a remediation plan in the case that the identified risks occur and result in harm to the environment or society. Remediation plans must include contingency plans for emergency response and conditions for stopping or pausing a deployment, which must be reported in the Project Design Document (PDD). The following is a non-exhaustive list of risks that may require contingency plans, if applicable to project activities:

  • Instrument malfunctions that lead to data-gaps, posing material concerns for human and environmental health
  • Regulatory non-compliance is reached as a result of environmental contaminants exceeding safety thresholds
  • Contamination levels in effluents, co-products, etc. exceed thresholds identified in the PDD
  • Danger to ecosystem health is detected by the local community, government agency, or other stakeholder
  • The health and safety of workers or local stakeholders is compromised
  • Regional natural disasters

No Net Harm: Project Proponents must demonstrate that, at a minimum, any harm to terrestrial and aquatic ecosystems, biodiversity, or local communities is fully mitigated, or remediated if mitigation is not possible³, in accordance with Section 3.7 of the Isometric Standard. No net harm is considered across the scope of the full system boundary, and considers project co-benefits.

• In some jurisdictions, demonstration of environmental net gain, or fully mitigating and remediating unavoidable adverse impacts to terrestrial and aquatic ecosystems and biodiversity and leaving the natural environment in a measurably better state than before, is required in line with local policy and regulation. All Projects are encouraged to strive towards demonstrating environmental net gain regardless of local policy and regulation.

Project Validation and subsequent Credit issuance under the Isometric Standard are contingent on the implementation, transparent reporting and independent verification of ESS requirements.

Failure to comply with ICVCM core principles may result in the cessation of Credit issuances, in accordance with Sections 3.7.1 and 3.7.2 of the Isometric Standard.

Primary environmental and social data generated as a result of this ESS Module must be made publicly available and easily accessible to local communities so long as the data confers no privacy concerns or risk to communities, ecosystems, protected species, or the Project Proponent. Any data used to support claims of environmental or social co-benefits must be made publicly available.

Data must be collected and interpreted by subject matter experts. Projects that are situated within active operations may utilize data generated by a partner operator.

Project Proponents are required to consider the safe handling, containment, disposal, and risk mitigation of potentially harmful substances used or generated in project operations, such as feedstocks, carbon-storage products, and co- or by-products. This must include, but is not limited to, the following risks to safeguarding outlined in the ICVCM Core Carbon Principles¹:

• Pollutant emissions to air, water, and soil.

• Disturbances of noise, light and vibration.

• Generation of waste and release of hazardous materials, chemical pesticides and fertilizers.

  • Project Proponents using or producing hazardous materials must provide documentation of safety programs and compliance, especially as related to the production and handling of extractive waste products.
  • Projects generating hazardous waste must include a plan for safe handling, containment, and disposal in the PDD, in addition to all requirements for hazardous materials.

Project Proponents must first defer to the local (e.g., federal, provincial/state, municipal) regulatory frameworks for a definition of 'hazardous materials' to identify and ensure full compliance with local regulations. In the event that no clear local regulations or frameworks are present, the Project Proponent must then identify an international standard, such as the UN Recommendations on the Transport of Dangerous Goods or the EU Waste Framework Directive (Directive 2008/98), that provides a definition of 'hazardous material'. ‘Hazardous waste’ is a hazardous material which is also a waste product. We note that some waste products may not meet 'hazardous' classification thresholds when considering single disposals, but repeat release or disposal to previously contaminated lands may result in hazardous conditions. Project Proponents must consider the full context of repeat dosing and the receiving environment when creating hazardous materials disposal plans.

There may be other sources of pollution upstream of the Project’s system boundary such as shipping, mining, electricity usage, and other operational or supply chain-related activities. While Project Proponents are not expected to account for pollution outside of the system boundary, we encourage Project Proponents to consider upstream supply-chain pollution in the Project planning phase.

This section discusses materials utilized across CDR pathways that may be considered hazardous such as rock, mineral, and alkaline feedstocks and solvents and sorbents.

This section outlines potential pollution and safe handling risks associated with rock, mineral and alkaline feedstocks, including impacts to local ecosystems or communities, as a result of the sourcing, production, preparation, storage, distribution, and neutralization (if applicable) of feedstock in CDR activities. Impacts may include land degradation, noise and dust pollution, and localized watershed or soil contamination.

Weathering of rock, mineral or alkaline feedstocks may be associated with the release of materials of potential concern, which may pose an environmental risk. To prevent or mitigate such risks, the Project Proponent must complete the following:

• A comprehensive feedstock characterization conducted in accordance with local regulations and international standards, as well as Isometric's Rock and Mineral Feedstock Characterization Module v1.1
• Consider feedstock safety and handling in the context of the removal activity process and system. Removal activity process and system can generally be categorized into open and closed system projects, as discussed below. The system type of the Project may dictate feedstock selection in terms of risk tolerance and suitability to achieve CDR.

  • Open Systems - Project Proponents operating in open systems must select rock, mineral or alkaline feedstocks that minimize the risk of soil, groundwater and surface water contamination and potential for ecotoxicity. Risk minimization must consider dosing or repeat deployments, if applicable. Projects operating in open systems must maintain a monitoring system to regularly check for the following changes in concentration of materials of potential concern in both soil and water:

    • Salinity or total dissolved solids (TDS), which may increase due to leaching from crushed material, particularly in water-abundant, humid regions. Monitoring must include both soils where feedstocks are applied and any surface water runoff or groundwater leaving the application site
    • Suspended solids and turbidity, especially where feedstocks are applied in areas with high runoff or erosion potential
    • pH & EC (electrical conductivity) fluctuations, as a general indicator of changes in soil pore water and surface/ground water chemistry associated with weathering reactions
    • Chemical Oxygen Demand (COD) and Biological Oxygen Demand (BOD) in water systems, to assess oxygen availability for aquatic life, monitor water contamination, and detect pollution from sources such as agricultural runoff, sewage, and industrial discharge
    • Acidic and/or metalliferous drainage (AMD). This is commonly referred to as Acid Rock Drainage (ARD)
    • Heavy metals (above baseline conditions and local regulatory limits)
    • Asbestiform minerals
    • Increased acidity production, from the dissolution of feedstocks containing sulfide minerals that oxidize at standard surface conditions

  • Closed Systems - Projects operating in closed systems, such as enclosed reactors or electrochemical processing units, must present a control strategy to prevent release of hazardous materials to the environment.

    • Electrochemical alkalinity production systems must develop and implement a comprehensive acid management plan that includes:

      • Safe storage of acid byproducts in appropriate containment systems
      • Neutralization procedures and/or beneficial use pathways for acid streams
      • Monitoring of acid storage integrity and any potential leakage
      • Documentation of acid quantities produced and final disposition

    • Establish emergency response procedures to address accidental releases, including immediate containment, environmental remediation, and compliance with regulatory reporting requirements, in accordance with Section 2.0

    • Safely dispose of water, solid wastes and chemical byproducts generated during project activities in accordance with applicable environmental regulations

    • Document leaks or breaches of system integrity and corrective remediation actions taken

The above safeguards will likely involve periodic sampling and analyses by subject matter experts alongside field monitoring for removals. The concentration of metals in soil and water must not exceed the limits established by the local authority where the Project is located. In the absence of regional regulations, the Project Proponent must adhere to the most stringent of the standards set by the European Union (EU) or the United States Environmental Protection Agency (US EPA) for each parameter of potential concern identified. In this case, the Project Proponent must state the guidance from the selected governing body that will be followed in the PDD.

Project Proponents utilizing solvents or sorbents must document emissions and demonstrate that emissions of the following types are below applicable regulatory limits:

• amines (volatilized or in aerosol form)
• ammonia
• volatile organic compounds (VOCs)
• nitrosamines and nitramines
• particulate matter (solid sorbents or suspended droplets)
• other hazardous substances, as defined by the authority of the geography where the Project is located or the most stringent of relevant standards worldwide, for example by the EPA, that may be released as a result of sorbent or solvent degradation, volatilization, or aerosolization.

If sovlent or sorbent emissions are measured as part of regular operating procedures, measurements must follow standard testing and sampling methods. Project Proponents must identify if the local authority prescribes a test method regulation. Otherwise, emissions testing must comply with NIST, ASTM, or similar methodologies, and must be completed by a qualified testing organization. Project Proponents must keep these results on file and must repeat testing when substantial changes occur to solvent or sorbent formulations or in operating conditions that may impact emissions.

Project Proponents must demonstrate that waste solvents or sorbents are disposed of appropriately according to local hazardous waste regulations. In the absence of regional regulations, Project Proponents must identify and comply with a disposal process that is globally recognized as stringent, for example the EU Waste Framework Directive 2008/98/EC or the U.S. EPA’s Steps in Complying with Regulations for Hazardous Waste for each parameter of potential concern identified. Safe disposal of solvents and sorbents must be included in the post-closure plans submitted in the PDD.

Project Proponents must monitor water consumption in project activities above the baseline scenario. Project Proponents drawing water as part of project operations must provide a qualitative assessment of water usage and availability beyond baseline conditions. The following indicators must be discussed to demonstrate that water availability and consumption were considered in the Project plan:

• Local access to clean drinking water and recreational water usage
• Existing water intensive operations in the Project area and local communities, such as agriculture or industrial operations

This qualitative assessment must include a justification that the Project activities will not preclude the above indicators. This must include how the Project Proponent plans to monitor Project water usage, such as through water meters or utility bills.

Project Proponents must meet the following eligibility criteria relative to the baseline scenario to safeguard biodiversity and living natural resources and remain in compliance with the ICVCM Core Carbon Principles:¹

• avoid or minimize negative impacts on terrestrial and marine biodiversity and ecosystems
• protect the habitats of rare, threatened, and endangered species⁴, including areas needed for habitat connectivity or migratory pathways
• avoid all key biodiversity areas⁵ and endangered or irreplaceable habitats/ecosystems as defined on international, regional or local scales
• minimize soil degradation and soil erosion

The High Conservation Value screening is a desktop exercise designed by the HCV Network to identify species, habitats, and communities at risk in land-use change and development, and is a helpful tool to ensure that above criteria are met. HCV screenings are required if project activities result in land use change on land in a previously natural state, as defined by Land & Carbon Lab's Natural Lands Maps. When evaluating the presence of HCV areas, Project Proponents must use at least the following data sources to identify if the Project area overlaps with any potential rare, threatened, or endangered species and/or habitats:

• IUCN Red List of Threatened Species
• World Database of Protected Areas
• Key Biodiversity Areas (KBAs)
• IUCN Red List of Ecosystems
• Ecologically & Biologically Significant Areas (EBSAs)
• Natura 2000 sites (Europe only)

Project Proponents must comply with all health and safety procedures as required by the authority of the geography where the Project is located, but not less stringent than the standards set in the Social Accountability International’s SA8000 Standard.

To safeguard labor rights and working conditions, Project Proponents must demonstrate the following codes of conduct for all employees and contracted third party personnel:

• Provide safe working conditions and take reasonable steps to protect workers from harm
• Conduct health and safety risk assessments and adopt mitigation strategies in accordance with local, national and international laws and guidelines as required for each stage of their operations
• Provide fair treatment and equal opportunities to all employees regardless of age, gender, race, ethnicity, religion, disability, sexual orientation, sexual identity, education, national origin, or any other distinguishing characteristic or trait
• Prohibit the use of forced labor, child labor or labor by trafficked persons

Projects that require employees to handle hazardous materials as defined in Section 4 must demonstrate that workers are well informed of dangers posed by the material, are properly trained on hazardous material safety and handling, and are provided protective equipment.

Isometric understands environmental justice to encompass the protection of human rights, upholding of environmental law, and responsible conduct of project developers. To uphold principles of Environmental Justice, Project Proponents should consider their impacts on and relationships with affected people, communities, and ecosystems⁶. Methods of upholding environmental justice are diverse and will vary across CDR projects. Isometric encourages means of addressing justice that are rooted in the Project’s local geographic, social, and environmental contexts. Project Proponents are encouraged to consult resources such as those from the United Nations Development Programme or Carbon180 for more information.

Project Proponents must demonstrate adherence to the following requirements in order to comply with principles of Environmental Justice.

Stakeholder Identification

Project Proponents must conduct a stakeholder identification process. This process, including Local stakeholders situated in the vicinity of the Project site may contribute an in-depth understanding of the local system and provide invaluable insights and recommendations on the potential risks, necessary safeguards and specific monitoring needs. The stakeholder identification process must be submitted in the PDD. Refer to Section 3.5 of the Isometric Standard for more information on the Stakeholder input process.

Stakeholder Engagement

Risks to environmental justice can stem from procedural aspects of Project planning and implementation. This may include the extent to which rightsholders and stakeholders have meaningful opportunities to participate in decision-making, the effectiveness of a grievance mechanism, and the use of free, prior, and informed consent (FPIC), where required. This risk is especially pertinent to groups that were historically marginalized or excluded from decision-making and resource control. Principles for stakeholder engagement, including grievance processes, are outlined in Section 3.5 of the Isometric Standard.

Project Proponents must demonstrate active stakeholder engagement throughout project planning and operation, ensuring that all risk mitigation strategies contribute to sustainable project outcomes. The Project Proponent is responsible for identifying relevant stakeholder groups, and should consider, at minimum, groups whose daily livelihoods may be impacted by project operations. Project Proponents must demonstrate that the Stakeholder Engagement Process allows for stakeholder contributions to environmental and social risk identification and mitigation planning, in alignment with the guidance outlined in Section 3.5 of the Isometric Standard. Evidence of meetings and summaries of stakeholder responses must be included in the PDD, including the date and time of meetings and photographic evidence where possible. Meetings must be held at times and locations that are accessible to local stakeholders. ESS reports and monitoring plans must be made available to stakeholders in accessible formats, including translated into local languages and delivered using methods of communication that are commonly practiced in the local community.

Social License to Operate (SLO)

Social License to Operate (SLO) is the sustained acceptance of Project activities by the local community and other stakeholder groups.^{7, 8} Robust stakeholder engagement processes may increase a Project Proponent’s likelihood of reaching SLO, whereas inability to reach SLO from the local community increases chances of project abandonment and may result in other adverse outcomes, such as reputational damage or operational pauses, and their associated costs.⁷ For that reason, SLO is necessary not only to manage projects ethically and responsibly, but to improve chances of project success.

In some cases, such as Reforestation projects, SLO may even increase a Project’s ability to sequester carbon efficiently, because local stakeholder groups bring different perspectives and knowledge sets of the surrounding ecosystem that impact the carbon sequestration process. Similarly, lack of community buy-in has been cited as a leading factor in project failure among reforestation projects⁹, with deeper community engagement correlating with project success.

Respect for Human Rights

Project Proponents must ensure human rights are maintained and respected throughout the Project activities, in accordance with the United Nations International Bill of Human Rights.

Land Acquisition and Resettlement

Project Proponents must take measures to prevent land acquisition or voluntary resettlement, including actively avoiding physical or economic displacement, or if not possible, minimizing the amount and the impact. In these cases, Project Proponents must also demonstrate meaningful deliberations with affected parties, including if, or in what form, compensation is warranted.

Involuntary resettlement is not permitted under this Module. Involuntary resettlement is defined as land acquisition where displaced groups do not have the right to refuse their removal.¹⁰ Involuntary resettlement may come in the form of physical or economic displacement. Isometric recognizes the Food and Agricultural Organization (FAO) of the UN’s definition of physical displacement as “relocation, loss of residential land, or loss of shelter" and economic displacement as “loss of land, assets, or access to assets leading to loss of income sources or other means of livelihood". Use of involuntary resettlement to access project sites will render a Project ineligible for crediting.

Indigenous Peoples and Local Communities

To promote environmental justice and prevent negative impacts to Indigenous Peoples (IP), Local Communities (LC) and cultural heritage, the Project must:

• Identify IPLCs living in or dependent on the Project area
• Identify any direct or indirect impacts on IPLCs, including to health and food systems, economies and livelihoods, cultural values, and statutory or customary rights to management and use of land, waters, and natural resources
• Consider historical inequities in the siting of infrastructure and recreational land use, and the resulting disproportionate allocation of amenities and disamenities in project planning
• Recognize, respect and promote the protection of the IPLCs’ rights in line with applicable international human rights laws and UN Declarations, including the United Nations Declaration on the Rights of Indigenous People
• Preserve and protect cultural heritage and ancestral knowledge aligned with IPLCs and any UNESCO World Heritage Conventions

Project Proponents must demonstrate, where relevant, how Project activities are consistent with relevant United Nations Sustainable Development Goals (SDG) objectives. The SDGs are a set of 17 global interconnected goals established by the UN in 2015 to address a wide range of social, economic, and environmental issues. Some jurisdictions have local targets or indicators to support the UN SDGs-- for example, the UN Sustainable Development Goals in Ghana. Project Proponents in such jurisdictions should review how Project activities promote regional goals as well.

Project Proponents must explain alignment of Project activities with SDGs in the PDD. If applicable, a qualitative assessment should be included for any positive impacts identified in relation to SDGs other than SDG13 (climate action). Project Proponents should provide information on any assessment tools and methods used as part of this explanation.

Isometric would like to thank the following reviewers of this Module:

• Holly Buck, Ph.D. (University at Buffalo)

• Liliana Bastian, Ph.D.

1. Section 4: Assessment Framework - Core Carbon Principles 2023, The Integrity Council for the Voluntary Carbon Market. from https://icvcm.org/core-carbon-principles ↩ ↩² ↩³

2. United States Department of Energy ↩

3. United Nations Framework Convention on Climate Change (2023). Development of a sustainable development tool for Article 6.4 of the Paris Agreement. Concept note, p. 20 from (https://unfccc.int/sites/default/files/resource/a64-sb007-aa-a07.pdf) ↩

4. The IUCN Red List of Threatened Species, Protected Area and Key Biodiversity Area data downloaded from the Integrated Biodiversity Assessment Tool (IBAT) (http://www.ibat-alliance.org). Provided by BirdLife International, Conservation International, IUCN and UNEP-WCMC. Please contact ibat@ibat-alliance.org for further information (https://hackmd.io/4VxbbJkdTPO2p5U4_GT33Q?view#fnref4 ↩

5. IUCN (2016) A Global Standard for the Identification of Key Biodiversity Areas, Version 1.0. IUCN, Gland, Switzerland. https://portals.iucn.org/library/node/46259 ↩

6. United Nations Development Programme (2022). Environmental Justice: Securing Our Right to a Clean, Healthy and Sustainable Environment. Technical Paper from (https://www.undp.org/publications/environmental-justice-securing-our-right-clean-healthy-and-sustainable-environment) ↩

7. Stuart, A., Bond, A., Franco, A. M., Baker, J., Gerrard, C., Danino, V., & Jones, K. (2023). Conceptualising social licence to operate. Resources Policy, 85, 103962. ↩ ↩²

8. Australian Institute of Company Directors. Social License to Operate from www.aicd.com.au/company-policies/corporate-social-responsibility/socially-responsible-companies/social-license-to-operate.html ↩

9. Di Sacco, A., Hardwick, K. A., Blakesley, D., Brancalion, P. H., Breman, E., Cecilio Rebola, L., ... & Antonelli, A. (2021). Ten golden rules for reforestation to optimize carbon sequestration, biodiversity recovery and livelihood benefits. Global Change Biology, 27(7), 1328-1348. ↩

10. International Finance Corporation (2012). Performance Standards on Environmental and Social Sustainability from https://www.ifc.org/content/dam/ifc/doc/2010/2012-ifc-performance-standards-en.pdf ↩