CRCF Narrow System Boundary BECCS Biomass Feedstock Accounting v1.0

1.0

Introduction

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

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

1.1

Applicability

This Module is only applicable to bioenergy retrofit/additive CCS Activities, where the energy use for carbon capture is provided by any combination of the following sources:

Grid import;
A reduction or change in energy export (e.g., a portion of export shifted from power to heat); and
Behind-the-meter external energy generation.

2.0

Sustainability Criteria

All biomass, biofuel, bioliquid or biomass fuel that is used to generate the CO₂ captured by the activity or as a feedstock for biochar co-production must comply with one of the following sets of requirements, depending on the feedstock characteristics.

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

3.0

Appendix A

Table A1
Approved Forestry Management/Certification Programs
Certification/Management Program	Additional Documentation Required
Forest Stewardship Council (FSC) 100% or FSC 100% chain-of-custody
National Members of the Program for the Endorsement of Forest Certification (PEFC) 100% (e.g., SFI 100%, ATFS, SGEC, SAFAS etc.).
An equivalent forestry management/certification and chain-of-custody program. Acceptable certification programs differ depending on the Activity characteristics and sourcing.	The Operator must provide a detailed analysis of how the program is equivalent to the above programs, including forestry management principles and an auditable chain-of-custody.
Demonstrable compliance with the most up-to-date EU RED sustainability criteria. This must include upstream sourcing for mill residues, which is currently beyond the scope of the RED. This includes third-party verifications of compliance with the EU RED sustainability criteria, such as SURE and SBP, as well as recognised national schemes such as Sweden's Hållbarhetsbesked.	Demonstration that all forestry residues and primary mill residues (timber processing, excluding post-consumer/post-industrial wood waste) have been sourced from forestry management practices compliant with the sustainability criteria within the EU RED.
A government mandated, managed or otherwise supported wildfire mitigation program.
Sustainable Biomass Program (SBP)	The Operator must provide all of the following: Evidence that the forest carbon stocks are stable or increasing in the sourcing region. A risk assessment of the sourcing area demonstrating there is no clear risk of sourcing from primary forests.
Roundtable for Sustainable Biomaterials (RSB)	The Operator must provide all of the following: Evidence that the forest carbon stocks are stable or increasing in the sourcing region. A risk assessment of the sourcing area demonstrating there is no clear risk of sourcing from primary forests.
FSC Controlled Wood Sources	The Operator must provide all of the following: Evidence that the forest carbon stocks are stable or increasing in the sourcing region. A risk assessment of the sourcing area demonstrating there is no clear risk of sourcing from primary forests.
FSC Mix	The Operator must provide all of the following: Evidence that the forest carbon stocks are stable or increasing in the sourcing region. A risk assessment of the sourcing area demonstrating there is no clear risk of sourcing from primary forests.
PEFC Controlled Sources	The Operator must provide all of the following: Evidence that the forest carbon stocks are stable or increasing in the sourcing region. A risk assessment of the sourcing area demonstrating there is no clear risk of sourcing from primary forests.

4.0

Isometric CRCF Glossary

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

Contributors

Chris Pollard

Jeni Reeve, Ph.D.

Michael Shell

Isometric

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

Criteria

Documentation Required

SC1

Activities using forestry residues and downstream wood processing residues must comply with all the following criteria:

SC1.1

The feedstock must be sourced from an approved forestry certification or management program listed in Table A1 or from a region subject to an equivalent risk assessment.

The Operator must provide all of the following:

Evidence that the feedstock is sourced from an area or entity under a listed certification or management program, including evidence of the certification applicability and chain-of-custody. Where this cannot be evidenced, the Operator must provide an independent, third-party, risk based determination of low risk that a feedstock from the sourcing area is non-compliant with the principles equivalent to the FSC Forestry Management Principles and Criteria, in consultation with Isometric.
Any additional documentation as required in Table A1.

SC1.2

Operators must demonstrate that woody biomass feedstocks - including both forestry residues and downstream wood processing (mill) residues - are sourced from areas of stable or increasing forest carbon stocks.

The Operator must provide one of the following:

Evidence that the feedstock sourcing complies with the requirements in Article 29, paragraph 7 of Directive (EU) 2018/2001. Note that this paragraph within the Directive does not apply to mill residues, while Isometric mandates that mill residues must also demonstrate stable or increasing carbon stocks in the sourcing region.

An independent third-party assessment that demonstrates the forest carbon stocks encompassing the sourcing region[^1] has not experienced a net decrease over the last 5 years compared to the 5 years previous to that.

Where this assessment cannot be provided, the following may be considered with appropriate justification: Evidence that the average LULUCF of the state/country does not exceed the regeneration of the forest carbon stocks over the last 5 years. This is demonstrated if the net emissions are zero or under, as reported in the UNFCCC. In countries where the harvesting exceeds 5 million km², additional evidence that forest carbon stocks have not decreased over the previous 10 years is required.

SC1.3

Operators must demonstrate that woody biomass feedstocks, including both forestry residues and downstream wood processing (mill) residues, are not sourced from a primary forest.

The Operator must provide one of the following:

Evidence that the feedstock sourcing complies with the requirements in Article 29, paragraph 6 of Directive (EU) 2018/2001. Note that this paragraph within the Directive does not apply to mill residues, while Isometric mandates that mill residues must also demonstrate stable or increasing carbon stocks in the sourcing region.

Evidence that the sourcing region, or wider jurisdiction does not contain any primary forests.

An independent. risk based sourcing area assessment confirming no clear risk of sourcing from primary forests.

Chain of custody documentation tracing the residue to its sourcing region and an assessment, referencing datasets such as Global Forest Watch or equivalent, confirming the sourcing region contains no primary forests.

SC3

Activities using crop residues must comply with all the following criteria:

SC3.1

The feedstock must not be sourced from land converted to agriculture in the past 5 years.

Evidence that the sourcing region has been agricultural land for at least 5 years prior to the Operator's first procurement date. This must be demonstrated through historical crop plans, output records or remote sensing.

SC3.2

The feedstock must not be sourced from the same acreage in consecutive years unless monocropping can be demonstrated for the previous 5 years.

The Operator must provide one of the following:

Feedstock purchase contracts between the Operator and the feedstock supplier.
The output/utilisation data of the acreage for 5 years prior to the Operator's first procurement date.

SC4

Activities using animal agriculture residues must comply with the following criterion:

SC4.1

The feedstock is not sourced above the Baseline Feedstock Generation Rate (See Appendix 4 of the Biomass Feedstock Accounting Module for details).

Data from 2 years prior to the Operator's first procurement date demonstrating the Baseline Feedstock Generation Rate and the proposed mass to be procured by the Operator.

SC5

Activities using food processing, landscaping or other industry residues must comply with the following criterion:

SC5.2

The feedstock must not be sourced above the Baseline Feedstock Generation Rate (See Appendix 4 of the Biomass Feedstock Accounting Module for details).

Data from 5 years prior to the Operator's first procurement date demonstrating the Baseline Feedstock Generation Rate and the proposed removal rate by the Activity.

SC6

Activities using municipal waste must comply with the following criterion:

SC6.1

The feedstock must be designated as a municipal waste.

Evidence that the feedstock was obtained, produced or diverted from a municipal waste facility. This could include evidence of waste classification and a site waste permit, or a waste management contract with a local authority.

SC7

Activities using invasive species must comply with all the following criteria:

SC7.1

The feedstock sourcing must include sufficient safeguards to ensure there is a low risk of spreading the invasive species to other ecosystems.

Evidence of the harvest plan for the invasive species detailing approaches to ensure the risk of spreading is minimised.

SC7.2

The feedstock sourcing must be part of a broader ecosystem management activity taken by local, state or federal governments, non-profit organisations or private landowners.

The Operator must provide all of the following:

Evidence of the invasive species (native or non-native) classification by an authority for the feedstock to be sourced.
Documentation of management activities for the purpose of invasive species removal. All biomass, biofuel, bioliquid or biomass fuel that is used to generate the CO₂ captured by the activity or as a feedstock for biochar production and any additional biomass, biofuel, bioliquid or biomass fuel consumed to produce energy for the activity must comply with one of the following sets of requirements, depending on the feedstock sourcing practices.

Table A1
Approved Forestry Management/Certification Programs
Certification/Management Program	Additional Documentation Required
Forest Stewardship Council (FSC) 100% or FSC 100% chain-of-custody
National Members of the Program for the Endorsement of Forest Certification (PEFC) 100% (e.g., SFI 100%, ATFS, SGEC, SAFAS etc.).
An equivalent forestry management/certification and chain-of-custody program. Acceptable certification programs differ depending on the Activity characteristics and sourcing.	The Operator must provide a detailed analysis of how the program is equivalent to the above programs, including forestry management principles and an auditable chain-of-custody.
Demonstrable compliance with the most up-to-date EU RED sustainability criteria. This must include upstream sourcing for mill residues, which is currently beyond the scope of the RED. This includes third-party verifications of compliance with the EU RED sustainability criteria, such as SURE and SBP, as well as recognised national schemes such as Sweden's Hållbarhetsbesked.	Demonstration that all forestry residues and primary mill residues (timber processing, excluding post-consumer/post-industrial wood waste) have been sourced from forestry management practices compliant with the sustainability criteria within the EU RED.
A government mandated, managed or otherwise supported wildfire mitigation program.
Sustainable Biomass Program (SBP)	The Operator must provide all of the following: Evidence that the forest carbon stocks are stable or increasing in the sourcing region. A risk assessment of the sourcing area demonstrating there is no clear risk of sourcing from primary forests.
Roundtable for Sustainable Biomaterials (RSB)	The Operator must provide all of the following: Evidence that the forest carbon stocks are stable or increasing in the sourcing region. A risk assessment of the sourcing area demonstrating there is no clear risk of sourcing from primary forests.
FSC Controlled Wood Sources	The Operator must provide all of the following: Evidence that the forest carbon stocks are stable or increasing in the sourcing region. A risk assessment of the sourcing area demonstrating there is no clear risk of sourcing from primary forests.
FSC Mix	The Operator must provide all of the following: Evidence that the forest carbon stocks are stable or increasing in the sourcing region. A risk assessment of the sourcing area demonstrating there is no clear risk of sourcing from primary forests.
PEFC Controlled Sources	The Operator must provide all of the following: Evidence that the forest carbon stocks are stable or increasing in the sourcing region. A risk assessment of the sourcing area demonstrating there is no clear risk of sourcing from primary forests.

Table A1

Approved Forestry Management/Certification Programs

Certification/Management Program

Additional Documentation Required

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

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

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

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

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

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

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

Sustainable Biomass Program (SBP)