Enclosed below is the public consultation feedback for the Standard Update 5.0.

The public consultation launched following the Standard Update webinar in October 2021 and closed in late November. We welcomed all constructive comments and feedback, with the aim of strengthening and improving the Standard accordingly. 

Please direct any questions or queries regarding this feedback to [email protected] 

 

Category Feedback Response/ Action
Verification & Validation

“All Projects must be Verified within 5-years of Validation, at least once in every 5- years period throughout the Crediting Period, and there must be a final Verification at the end of the Crediting Period.”


Can you elaborate why this is relevant and how this works in practice? What if the crediting period stops just one year after the last verification has taken place?

In this example a final Verification is necessary to verify the Carbon Benefits achieved in the final year of the project. Projects should therefore structure their crediting period and Verification schedule with this in mind.

Verification & Validation

The definitions seem that they are for an individual, rather than organisation. A VVB may have multiple people in the auditing team (e.g., lead auditor, technical reviewer, SME, the person who takes decision on the certification).

Kindly consider modifying the definitions. 

Definitions have been modified to clarify that a VVB may have multiple people in the auditing team.

Verification & Validation

‘Approval as a Designated Operational Entity (DOE) under UNFCCC-CDM (Scope 14)’: PVF should also DOE accredited for sectoral scope 15 (agriculture) as PVF has a scope of AFOLU. These can be approved under PV as per their accreditation. 

CDM DoE's accrediting to Scope 15 have been added to the VVB criteria for certification of agriculture projects.

Verification & Validation

Materiality limits: 300,000 seems to be high of a number of 5% materiality. Maybe 5% can be for ERRs up to 100,000 and from 100,001 - 299,999 it can be 2% and above 300,000 it should be 1%. Requesting consideration. 

We will consider this suggestion prior to publishing the Validation and Verification Guidance.

Verification & Validation

We suggest clarification is needed regarding the classification of Microscale projects and their validation and verification requirements for certain project types. In general there may be value in developing further guidance for grouped projects. 

The microscale threshold applies at the project level, so includes all project areas within a grouped project.

Verification & Validation

I am concerned by a mind set on terrestrial ecosystems written in a way that will confuse the reader into what the foundation supports. For example the statements of "land cover". 

 

Requirement 1.1.1 has been updated to "Project Interventions must protect, restore, or improve management of land or marine areas; provide long-term increases in carbon storage or reductions in greenhouse gas emissions; and have positive impacts on local livelihoods and ecosystems.

Methodology Requirements

Will previously approved technical specifications qualify as approved methodologies? If not, what is the process for review / upgrade?

Existing methodologies and technical specifications will need to be reviewed and approved under the new Methodology Approval process.

Methodology Requirements

Is it possible to apply a carbon methodology to a Plan Vivo project that has been approved by another Standard but not Plan Vivo? What would be the process for approval by Plan Vivo?

Details of when and how external methodologies can be used will be provided in the Methodology Approval process. CDM A/R methodologies are likely to meet all new methodology requirements.

Methodology Requirements

 Is Plan Vivo considering methodology royalty/compensation for the methodology developer? Similar to what is done by VCS?

This is not currently being considered. Plan Vivo will publish Methodology Frameworks that can be used by Projects. Projects will also be able to submit their own modules or methodologies that will be published on the Plan Vivo webpage and will be available for use by other projects.

Methodology Requirements
A section of requirements on parameters fixed ex-ante and monitored through the CP should be included.

The General Requirements for models, default factors and proxies apply to parameters fixed ex-ante. Methodologies must include details of how sources of uncertainty that cannot be readily quantified are controlled.

Methodology Requirements
A section on additionality - e.g., standardized methods, should be included. 

A section on additionality has been added to the Methodology Requirements.

Methodology Requirements
Our current project periods are 30 years. Do projects with 30-year project periods and permanence systems (e.g. protected area legislation) need to be extended before the next verification period?

Crediting Periods can be between 10 and 50-years. Monitoring and verification is required throughout the crediting period. Non-permanence risk must be assessed over a 50-year period. If the licence for the project expires within 50-years of the project start date, the risk that the licence will not be renewed must be considered in the Non-Permanence Risk Assessment.

Glossary
Is 'methodology' replacing the term 'approved approaches'?

Yes

General
Please maintain consistency in the language of the definitions. Some of the definitions are beginning with an article (A, An or The) whereas others with nouns. It is preferred that the definition begin with an appropriate article.

Language in the definitions has been reviewed and updated for consistency.

General 
May be for the purpose of increased scrutiny and maintaining impartiality high standards of carbon benefits, Plan vivo should consider having a mandatory requirement for projects with less than 10,000 tCO2e capacity to engage VVB after every 2 internal audits (validation and verification). Could be added to Validation and Verification Guidance.
This is not planned for version 5.0 but may be considered for future updates. If microscale projects expand to issue more than  10,000 tCO2e per year, verification by a VVB will be required.
General  Will existing projects be grandfathered under existing buffers? Existing projects will be required to comply with all the requirements in the new version of the Standard at the time of migration.
Project Requirements
The guidance for project interventions should also include grasslands under improved land management.
Guidance note has been expanded to include reference to improved management of grasslands, wetlands and marine areas.
Project Requirements
   
Maybe livestock management (such as those related to enteric methane) should also be considered, as essentially livestock management is part of agriculture.
This is not included in Version 5.0 but may be added in future updates.
Project Requirements
There should be guidance for projects where a project intervention is not included in the scope. I.e., manure management where animal waste first goes through biogas production and the slurry is applied to the agricultural land to replace nitrogen based/chemical fertilizers. PVF should clarify if such projects would be eligible or not.
Such details should be included in Methodologies and could be considered on a case-by-case basis if there are emissions or emission reductions associated with an eligible intervention.
Project Requirements
There should be guidance on conducting stakeholder consultation workshop - invitation to stakeholders, collecting comments and maintaining records. 
To be included in Project Development Guidance document.
Project Requirements

‘The requirements exclude commercial land managers and companies as Project Participants but not small-scale and subsistence farmers that make use of seasonal labour’:

Clarification of what is considered as 'small - scale' would be appreciated. Is it linked to the 10,000tCO2/year limit?

Thresholds for small-scale production will vary by production system and location; and proposals for internationally applicable thresholds rely on data that may not be readily available in all countries e.g. https://unstats.un.org/unsd/statcom/49th-session/documents/BG-Item3j-small-scale-food-producers-definition-FAO-E.pdf . The assessment of small-scale production is therefore somewhat subjective. The following definition (based on the FAO proposal) is being considered. The size of land holding of project participants should be in the bottom 40% of the of the cumulative distribution of land size at national level (measured in hectares); and Project Participants should obtain an annual economic revenue from agricultural activities falling in the bottom 40 percent of the cumulative distribution of economic revenues from agricultural activities per production unit at national level. Where data are unavailable to accurately demonstrate this Project may make use of expert judgement to demonstrate that thresholds have been met. Other options are also being considered.

Project Requirements

There must be provision to update the baseline at a regular interval and not only when there is change in policy or regulations. There might be scenarios where policy/regulations have not changed for a long term and the baseline becomes redundant. E.g., a baseline update/reassessment is required at every 10 years.

Requirement to update the Baseline Scenario at least every 10-years has been added.
Project Requirements

Please also mention explicitly that buffer is only for those projects (or part of project) that have a removal (e.g., SOC, A/R) or avoidance (e.g., avoided deforestation) as a GHG benefit. This section is not relevant for emission reduction (e.g., reduction in n2o emissions due to better nitrogen management practices).

The buffer is currently applied to all Carbon Benefits. The proposed change will be considered for future updates.
Project Requirements

Market leakage should also be considered (or maybe it is but not explicitly mentioned). This could be very relevant for IFM projects that increases the time between logging as demand for wood/timber is met by sources beyond the control of project proponents. Either project requirements or methodology requirements can provide guidance on this or provide a conservative default. 

Guidance has been added for when market leakage needs to be considered. Modules for determining Leakage Discount will be included in the Methodologies.
Project Requirements

Please consider making specific rules, requirements and guidelines for leakage buffer in the project requirements (or a specific tool like that for buffer).

See above. 
Project Requirements

If CP is seen as renewal by Plan Vivo up to 50 years, there must be a time limit for a CP to be renewed. E.g., each CP can be of 10 years, renewable up to 4 times (i.e., up  to 50 years), this can be clubbed with baseline reassessment as well.

Crediting Periods can be any duration from 10 to 50 years, and can be renewed for a maximum Crediting Period of 50-years. Crediting Period duration can be changed during the project e.g. to have an initial 30-year Crediting Period followed by a 20-year period.
Project Requirements

Other requirements and procedures should also be mentioned. E.g., things that need to be updated in the PDD, to see if a relevant version of methodology is used, amongst others. Also, CP renewal should be validated.

Guidance on areas of the PDD that will be re-assessed a Verification is provided in the "Reporting, Validation and Verification" sections under each set of requirements.
Project Requirements  3.15.2: It is unclear what is the rationale behind 60%, maybe this should be clarified.

Although (like all thresholds) the 60% threshold is somewhat arbitrary; it is an established feature of the Plan Vivo Standard to help ensure that Project Participants receive a fair share of the benefit from their projects. Experience from existing projects has shown that this threshold is acceptable to Project Participants and manageable by Project Coordinators.

Project Requirements

   3.15.2: the language should be more clear, it should also include that profit should be considered after carbon certification cost.  

Guidance on allocation of project costs in the benefit sharing mechanism is under development.
Project Requirements

It is unclear what is the rationale behind restricting the expansion of project activities to new project areas within the same project region(s) as at the start of the project. It is understood that introducing activities to new regions may have differing results. However this restriction to the initial Project Region(s) may stifle potential project growth as well as limit aggregation projects to project regions that may have a small pool of potential future participating landowners/beneficiaries. Plan Vivo could create a procedure for the expansion to new project regions via desk and/or site visit either by auditors or PV Program Officers. The FSC Forest Management Groups Standard (FSC-STD-30-005) is a good example of how new group members may be added and their certification confirmed.

Definition of a Project Region is necessary to determine whether Project Requirements that relate to the project landscape have been met. This enables projects to expand by adding project areas within the project region without the need for a separate validation. Adding a new Project Region to a PDD would require Validation. Alternative procedure may be considered for future updates.
Project Requirements

If the Stakeholder analysis must be validated then that should also be explicit. Similar comment throughout (e.g. 2.2.b).

Conformance with all numbered requirements must be Validated.
Project Requirements Would suggest adding "The Project Coordinator must seek and consider input in project activity planning from people who would likely be affected by management activities."

Requirement 2.4.1 specifies that project Coordinators must work directly with representatives of all Primary Stakeholders in the development of Project Interventions and in defining the Project Logic … to ensure that their concerns and aspirations are consistently understood and considered.

Project Requirements Customary rights are a sticky issue.  In the United States indigenous peoples have customary rights over land and resources yet have been displaced so long ago that engaging them in an FPIC process now may not be fruitful in a meaningful way.  Sites of special cultural, ecological, economic or religious meaning to indigenous people may not be readily identified by the present landowners or perhaps even by the tribes themselves.  In such a case there must be some recognition that actual cooperation and consultation is out of the control of the landowner regardless of any good faith efforts that are made to invite such cooperation and consultation.

Plan Vivo FPIC requirements pertain to Indigenous Peoples and local communities with statutory or customary rights to land and/or resources in the project area (s). Therefore it is the responsibility of the project to identify all stakeholders and rightsholders, which would include people with a current rights claim to the land or resources within this area. This would most commonly be achieved through stakeholder identification, analysis and engagement, and through conducting a socioeconomic baseline. Based on this analysis and due diligence, the stakeholder engagement strategy or plan would then look to engage those identified stakeholders and rightsholders in a manner that is commensurate with the project's impacts (and other factors such as influence, impact, etc), including FPIC for identified Indigenous Peoples and local communities.

In project areas where there are Indigenous Peoples or local communities who have been historically displaced, but where there are no known land or resource claims (based on the stakeholder engagement outlined above), this would be defined as a legacy issue. Plan Vivo cannot advise on how the risks associated with legacy issues should be managed, as this requires a case by case assessment. However, where the stakeholder engagement and socio economic baseline work does not identify any existing land or resource claims or conflicts (due to historically resettled communities), there is no expectation that the project will seek out such groups for an FPIC process. However, note that the stakeholder engagement would not be limited to the project proponent or landowner, but would include a variety of interested and affected parties, including civil society organizations.

In project areas where there are historically displaced Indigenous Peoples and local communities, who have a claim to land and resources within the project area, these groups should be consulted as part of the project's initial stakeholder engagement. Again, the Plan Vivo Foundation cannot advise on how legacy issues should be treated as there are case by case factors to consider, but if there are Indigenous Peoples or local communities with legitimate and existing claims to land and natural resources, who have not provided their FPIC to the current landowner or project proponent, this would not be aligned with the Plan Vivo FPIC requirements and would require resolution.

Project Requirements

Would suggest to add a requirement for projects to identify all possible scenarios for the project area, and eliminate each to show the baseline scenario is a) possible and b) most likely, and providing required counter evidence for other baseline scenarios. Additionally, a requirement is needed to set out conditions for the reassessment of baselines and time periods this must occur. The stakeholder engagement requirements (section 2) are robust and strong. However some further work is required to make sure terminology is defined and consistent in relation to stakeholder and benefit sharing. Under 3.9.8 (and 5.1.2), the new requirement is for “local stakeholders” but have previous only defined “Primary and Secondary Stakeholders” – it would be better to say whether this requirement applies to one or both of those previously defined groups. Similarly, under that requirement, it says “losses to stakeholders must be compensated” and “losses should only be allowed (even if compensated) with the full consent of those stakeholders” which all required clarification of which stakeholders are being referenced.

We are reviewing the definitions of different types of stakeholder with the aim of clarifying these points.
Project Requirements

Benefit sharing – the requirements stipulate that the benefits need to be distributed to “project participants” (who were previously defined as the ones implementing the project). It’s not clear what the venn diagram is between “project participants” and “primary stakeholders” (those with statutory or customary rights to land or resources within the Project Area(s)). So the benefit sharing mechanism needs to be developed in partnership with “project participants” AND “primary stakeholders” (3.15.1) and must specify how “primary stakeholders” are compensated for project benefits derived from the resources they have rights to (3.15.3 and 3.15.4)

We are reviewing the definitions of different types of stakeholder with the aim of clarifying these points.
Project Requirements

Would suggest adding:

"…allowing for regeneration after harvest such that growth rates exceeds harvest rates over a [Plan Vivo designated]  year period".  Would suggest 10 years rolling average similar to the FSC's Forest Management Standard's well defined concept of Annual Allowable Cut.

Requirements for carbon accounting with different types of harvest cycle are included in the Methodology Requirements.
Project Requirements

An approach to assessing additionality may be methodology-specific in its appropriateness.  This should be considered in the Project's justification for use of the same approach if the methodology is different from that which the approach originated.

A section on additionality has been added to the Methodology Requirements.
Project Requirements

Plan Vivo should consider requiring a review and possibly an update of the TS specifications once every 10 years during the project period at a minimum. This is the industry standard duration of a forest management plan prior to full revision.

Requirement to update Technical Specification at least every 10-years has been added.
Project Requirements

If PV establishes a flat 20% buffer contribution what is the purpose of the non-permanence risk tool other than to identify risks and mitigate them? Should 'low-risk' projects contribute the same as a 'high-risk' project?

The Non-Permanence Risk Tool will be used to establish whether the project is low enough risk to be accepted into the programme. Projects with high risk will be required to implement risk mitigation activities to reduce risk to an acceptable level.
Project Requirements

Would suggest adding "Land Management Plans must undergo a comprehensive review and, if necessary, updated at least once every ten (10) years."

We will include this as a recommendation, consult with projects on the feasibility of this approach and it will be considered for future updates.
Project Requirements

Would suggest adding "The Monitoring Plan must undergo a comprehensive review and, if necessary, be updated at least once every ten (10) years."

Requirement to review/update the Monitoring Plan every 10-years has been added.
Project Requirements

“Net-greenhouse gas emissions under the Baseline Scenario must be estimated for each year of the Project Period using an approved Methodology.”
Can you be more specific all GHG emissions need to be reported annually?

This is a project design requirement. The Project Design Document must include an estimate of net GHG emissions under the Baseline Scenario from all included carbon pools and emission sources for each year of the Project Period.
Project Requirements

“The Project Logic must describe the causal links between project activities and expected outcomes and identify key assumptions.”
Expectations regarding this logic concept remains a bit vague, can you give examples?

Examples will provided in the forthcoming Project Design Guidance.
Project Requirements

“Project Interventions must not be feasible for Project Participants to implement in the absence of the Project.”
Can you explain/ clarify with regards to implementation and management. For example a farmer already has 3 different trees on his/her farm and holds a cow, this is already seen as an existing agroforestry system. However Acorn would suggest to further improve this system. Would a farmer no longer be additional even if no recent trees have been planted nor finance was available to do so?

To be additional it should not be feasible for the Project Participant to make the improvements to the agroforestry system in the absence of the Project. The existing agroforestry system would likely then be the Baseline Scenario against which benefits are assessed.
Project Requirements How are we r.e Standard Update document templates? Will commercial entities, government landowners or private landowners be eligible project participants if they provide benefits to traditional land holders surrounding the project area? We would anticipate that the landowner entities would also want to be beneficiaries, otherwise they will not want to participate.

The requirement that Project Participants are smallholder or community groups and not commercial land managers is a fundamental feature of the Plan Vivo Standard. Projects can be carried out on privately owned/managed land if the land owner/manager is willing to allocate rights to the Project Participants and develop a benefit sharing mechanism that meets the Plan Vivo requirements. We are happy to consider alternative approaches for future updates of the Standard.

Project Requirements

The document refers to many tools/frameworks/templates are these available as well? I.e. Baseline scenario Tool, activity Exclusion List, Environmental and Social Policy Framework.

These are under development and will be released soon after the revised Standard is published.
Plan Vivo Certificates (PVCs)

‘Note that fPVCs can only be issued for removals that are expected to be achieved within a 50-year period’:

The language may not be very clear, it sounds as if the crediting period is 50 years. Also, requesting to consider issuing only part ex-ante credits and have safeguards for that. (Maybe GS PER could be a good reference). 

fPVCs can be issued for Carbon Benefits expected to be achieved within a Forward Crediting Period of up to 50-years. The minimum monitoring period for all Project Areas is 10-years. Language in the Glossary and Project requirements has been updated to clarify this. A 50-year Forward Crediting Period has been adopted to provide a viable funding mechanism for projects with high upfront costs and slow rates of accrual of Carbon Benefits. If monitoring is not carried out throughout the Forward Crediting Period it will not be possible to convert fPVCs to rPVCs or vPVCs.

Plan Vivo Certificates (PVCs)

Is there any way for end clients to have some way to claim a fPVC in the registry?
Will ‘allocation to a buyer’ replace current ex-ante retirements?

fPVCs can be allocated to buyers, they cannot be retired until they have been converted into vPVCs.
Buffers

Is Plan Vivo considering a pathway to transform ex-ante credits into ex-post credits under the existing standard?  If so, please delineate this process in the standard

There will be no process for transforming ex-ante credits issued to a project registered under the 2013 version of the standard to ex-post credits.

  

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