VCS 2007.1 - Validation Report – Forest Carbon Offsets – Boden Creek

Validation Report:
Name ofVerification company:

Date of the issue:

Scientific Certification Systems

June 24, 2011

Report Title:

Approved by:Report of the Validation of the Boden
Creek Ecological Preserve Forest Carbon
Project

Todd Frank

Client:Project Title:

Forest Carbon Offsets, LLC (representing
the Boden Creek Ecological Preserve)

Boden Creek Ecological Preserve Forest Carbon
Project

Summary:This validation assessed the conformance of the Boden Creek Ecological Preserve Forest
Carbon Project (“the Project”) to the Voluntary Carbon Standard 2007.1 and its supporting
documents, including the selected methodology element. The validation activities included
a field visit to the project area as well as interviews with relevant personnel, remeasurement of forest carbon plots, and validation of the Project’s methodology forquantifying greenhouse gas (GHG) reductions.
The Project is a REDD Avoided Planned Deforestation project. The objective of the Projectis to avoid GHG emissions from deforestation of 3,980 ha of forestland in the Toledo
District of Belize. The Project’s start date is January 1, 2005, and the Project’s crediting
period is from 2005-2029.
The review of Project documentation, the completion of the site visit and the information
obtained from subsequent follow-up interviews with project personnel have provided the
SCS Lead Verifier with sufficient evidence to determine the fulfilment of the stated criteria.
The Project correctly applies the selected methodology element and is in conformancewith all applicable requirements of the Verified Carbon Standard (VCS). The Project isdesigned to lead to reductions of GHG emissions that are real, measurable and give longterm benefits to the mitigation of climate change.
In summary, it is the opinion of the SCS Lead Verifier that the Project, as described in the
project description (PD) document dated May 16, 2011, meets all relevant Voluntary
Carbon Standard 2007.1 requirements and correctly applies the selected methodology.

Work carried out by:

Number of pages:

Ryan Anderson (Lead Validator) Zane
Haxton (Validator)
Percival Cho (Technical Expert)
Robert J. Hrubes (Technical Reviewer)

50

1VCS 2007.1 - Validation Report – Forest Carbon Offsets – Boden Creek

Table of Contents
1 Introduction ............................................................................................................... 3
1.1 Objective...........................................................................................................................3
1.2 Scope and Criteria ............................................................................................................3
1.3 VCS Project Description ....................................................................................................4
1.4 Level of Assurance ............................................................................................................4

2 Methodology .............................................................................................................. 4
2.1 Review of Documents .......................................................................................................4
2.2 Site Visit ............................................................................................................................5
2.3 Quantitative Analysis ........................................................................................................6
2.4 Follow-up Interview ..........................................................................................................6
2.5 Final Review and Report Drafting .....................................................................................6
2.6 Resolution of Any Material Discrepancy ..........................................................................6

3 Validation Findings................................................................................................... 6
3.1 Project Design ...................................................................................................................6
3.2 Baseline.............................................................................................................................9
3.3 Monitoring Plan ..............................................................................................................10
3.4 Calculation of GHG Emissions .........................................................................................11
3.5 Environmental Impact Assessment ................................................................................14
3.6 Comments by Stakeholders ............................................................................................14
3.7 Risk Assessment..............................................................................................................15

4 Validation Conclusion ............................................................................................ 21
Appendix A ................................................................................................................. 222

VCS 2007.1 - Validation Report – Forest Carbon Offsets – Boden Creek

1

Introduction

1.1 Objective
The validation objective is an independent assessment by SCS of the proposed Project
activity against the VCS 2007.1 and its supporting documents, including the selected VCSapproved methodology. Validation has resulted in a conclusion by SCS as to whether the
Project is compliant with the requirements of these program documents and whether the
Project should be submitted for registration. SCS understands that the ultimate authority topermit the registration of the Project rests with the VCS Board.

1.2 Scope and Criteria
SCS assessed the completeness of the Project Description (PD) to ensure that all
requirements of the VCS standards have been addressed. SCS assessed whether or not the
PD respects the principles of the VCS standards. Assessment included evaluation of
additionality, project design, baseline, monitoring plan, and calculation of baseline GHG
emissions.
The scope of the validation audit encompassed desk and site validation activities for the
Project against the following requirements of the VCS:
•
•
•
•
•
•

Voluntary Carbon Standard 2007.1
Voluntary Carbon Standard Program Guidelines 2007.1
Tool for AFOLU Methodological Issues
Tool for AFOLU Non-Permanence Risk Analysis and Buffer Determination;
The selected methodology, “Approved VCS Methodology VM0007”
Relevant Program Updates.

The selected methodology included the following required and optional documents:• REDD Methodology Framework (REDD-MF)• REDD Methodological Module CB-AB• REDD Methodological Module CB-W
• REDD Methodological Module BL-PL• REDD Methodological Module BL-DFW• REDD Methodological Module LK-ASP• REDD Methodological Module LK-ASU• REDD Methodological Module LK-ME• REDD Methodological Module LK-DFW• REDD Methodological Module E-BB
• REDD Methodological Module E-FFC• REDD Methodological Module M-MON• REDD Methodological Module X-STR• REDD Methodological Module X-UNC
The validation and verification process involved:•••

Assessment of the management systems, data handling as well as estimation
methods used in calculating and reporting emissions data;
Assessment of baseline methodology and determination;
Assessment of and issuance of an opinion on issues of leakage and additionality;

3

VCS 2007.1 - Validation Report – Forest Carbon Offsets – Boden Creek•

Assessment of data accuracy and any assumptions made in the manipulation of thatdata;
• Validation that the organization is operating according to the methodology
approved by VCS; and• A determination as to whether the Project could reasonably be expected to achieve
the claimed GHG reduction/removals.
The validation assessment was performed using the client-supplied Project Description andother supporting documentation.

1.3 VCS Project Description
As described in Section 1.5 of the PD, the Project consists of 3,980 ha of tropical forest
located in the Toledo District of Belize. The objective of the Project is to prevent conversionof the area to agricultural use. As described in Section 1.6 of the PD, the start date of the
project is January 1, 2005, and the crediting period extends from January 1, 2005 to
December 31, 2029. As described in Section 1.15 of the PD, the Boden Creek Ecological
Preserve (BCEP) is the project proponent. BCEP has retained Forest Carbon Offsets to“develop the strategy, implementation, and monitoring of the carbon credits generated bythis project.” Forest Carbon Offsets has contracted SCS to provide validation services, andtherefore Forest Carbon Offsets will be referred to as “the Client” hereafter.

1.4 Level of Assurance
The validation of the Project was conducted to a reasonable level of assurance, as isrequired by Section 7.3.1 of the Voluntary Carbon Standard 2007.1.

2

Methodology

SCS began reviewing the Project in January 2011, beginning with a thorough desk review of
the PD and communication with Forest Carbon Offsets personnel. The PD was audited forcompliance with the protocols listed in Section 1.2 of this report. In the course of thisreview, New Information Requests (NIRs) and Non-Conformity Reports (NCRs) were issued
by the SCS Lead Verifier to Forest Carbon Offsets personnel. NIRs were issued when new
information was needed to determine the conformity of the Project to the applicablestandards, while NCRs were issued when non-conformities were identified. The details ofthese findings can be found in an appendix to this report.

2.1 Review of Documents
The following documents provided by the Client were reviewed for conformance against the
program documents listed in Section 1.2 of this report (where multiple versions of adocument were reviewed, only the most recent version is listed here):
Project Documents• BCEP VCS PDD Final ver 4.docx (the PD)• BCEP VCS Monitoring Plan Ver 2.docx (the Monitoring Plan)• Proxy Area Methods.docx (summary of the methodology used for the proxy area
analysis conducted by the Client in conformance with Module BL-PL of the selected
methodology)

4

VCS 2007.1 - Validation Report – Forest Carbon Offsets – Boden Creek
Legal Documents• 3-379(1) Certificate & Representation Agreement (Scanned).pdf (an agreement
attesting that BCEP has clear title to the GHG reductions of the Project, and that the
Client has undertaken the Project with the consent of BCEP)• BCEP%20Block%20131%20Title%20Document.pdf (the “Transfer Certificate of Title”
document for “Block 131”, comprising 7,118 acres [2880.65 ha] of land, some ofwhich comprises part of the Project area)• BLE-Block-131.jpg (another version of the “Transfer Certificate of Title” documentfor “Block 131”, with revised information under the “Notings” header);• BCEP%20Block%20131A%20Title%20Document.pdf (the Transfer Certificate of Title”
document for “Block 131A”, comprising 527.614 acres [213.525 ha] of land, some ofwhich comprises part of the Project area)• BLE Block 131A.jpg (another version of the “Transfer Certificate of Title” documentfor “Block 131A”, with revised information under the “Notings” header)• BCEP%20Recorded%20Deed%20of%20Conveyance%205,230.79.pdf (a “Deed ofConveyance” between Harold Whitney, the prior owner of the Project area, andBCEP, for a third block of land comprising 5,230.79 acres [2,116.90 ha], some ofwhich comprises the project area)
Spatial Documents• BLE-PropertyMap131.jpg (a map illustrating the location of Blocks 131 and 131A)• BCEP Proxy Areas.zip (a ZIP archive containing images of the proxy areas used toestimate the baseline deforestation rate in accordance with Module BL-PL of theselected methodology)
Financial Documents• BCEP Business Plan.xls (financial projections provided to demonstrate financial
additionality of the project scenario)• BLE Only Revenue Projections 4 26 10 JLW with double the occupance andstaffing.xlsx (financial projections provided to demonstrate financial additionality ofthe project scenario)• BLE Only Revenue Projections 4 26 10 JLW.xlsx (financial projections provided todemonstrate financial additionality of the project scenario)
Several versions of many of these documents were reviewed by the audit team. Only themost recent version of each is included here.

2.2 Site Visit
Following the satisfaction of the majority of the initial findings and an adequate
demonstration of preparedness on the part of the Client, the validation team comprised of
Ryan Anderson and Zane Haxton was authorized by SCS to conduct a formal site visit, fromFebruary 20-22, 2011. During the site visit, the validation team interviewed relevant
personnel, toured the Project area, and re-measured six carbon inventory plots. The
validation team was accompanied by local Technical Expert Percival Cho during the site visit.
Following the site visit, additional NIRs and NCRs were issued; subsequently, responses fromthe Client were received and reviewed by the validation team.

2.3 Quantitative Analysis
The third step of the verification process focused on an assessment of the quantitative
analyses undertaken by the Project Proponent to define the baseline scenario and to5

VCS 2007.1 - Validation Report – Forest Carbon Offsets – Boden Creek
estimate the net carbon benefits of the Project. This included a complete review of
calculations made by the Project Proponent. Additionally, the validation team generated
estimates of carbon stocks from the field data collected during the site visit and comparedthose estimates to data reported by the Client.

2.4 Follow-up Interviews
The following personnel were interviewed during the course of validation activities:
•
•
•
•
•
•

Jeff Waldon, Forest Carbon Offsets: Interviewed during site visit and follow-up
phone discussions
Gabriel Thoumi, Forest Carbon Offsets: Interviewed during site visit
Verl Emrick, Conservation Management Institute: Interviewed during site visit
Kenneth Karas, Boden Creek Ecological Preserve: Interviewed during site visit
Carolyn Ching, Verified Carbon Standard: Provided guidance regarding interpretationof the methodology and the VCS definition of materiality
Naomi Swickard, Verified Carbon Standard: Provided guidance regarding
interpretation of the methodology and the VCS definition of materiality

2.5 Final Review and Report Drafting
The last step in the verification process included a final review of the submitted data anddrafting of the Validation Report. The validation report was based on the results of thevalidation assessment. The draft Validation Report was presented to an internal SCS
Technical Reviewer who subsequently determined that the Validation Opinion is justified
given the evidence presented. The report and opinions contained therein were thenpresented to the Client for review and comment.

2.6 Resolution of any material discrepancy
Throughout the validation/verification process, there were iterative exchanges between SCS
and the Client to gather additional information for review and examination. This exchange
included Findings—New Information Requests (NIR), Non-Conformity Reports (NCR) and
Opportunities for Improvement (OFI)—that were issued by SCS to the Client. The Client was
required to respond to all NIRs and NCRs in order for SCS to render a verification opinion.
With issuance of this validation report, all findings have been appropriately addressed by the
Client and subsequently closed by SCS. Following the closure of all NIRs and NCRs, SCS is
prepared to issue a positive validation opinion for the Project.

3

Validation Findings

3.1 Project Design
The Project is a REDD Avoided Planned Deforestation project that seeks to avoid theconversion of forestland to agricultural use. Section 1.8 of the PD describes the Project andits major activities. The Project’s design is consistent with the definition of Avoided Planned
Deforestation as articulated in the VCS “Tool for AFOLU Methodological Issues” and“Guidance for Agriculture, Forestry and Other Land Use Projects”. As described in Section
1.9 of the PD, “the primary technology employed to achieve the desired results is patrols of
the property to prevent incursions and illegal removal of biomass.” The validation team6

VCS 2007.1 - Validation Report – Forest Carbon Offsets – Boden Creekobserved that Project managers had access to a team of dedicated, competent employees
who were capable of carrying out patrols of the property and other needed maintenance.
As described in Section 1.6 of the PD, the start date of the project is January 1, 2005, and thecrediting period extends from January 1, 2005 to December 31, 2029. Baseline resets are tooccur during 2015 and 2025. The project start date, crediting period, and dates of baseline
reset are consistent with the protocols defined in the REDD Methodology Framework (REDDMF) and the VCS “Guidance for Agriculture, Forestry and Other Land Use Projects”.
As described in Section 1.4 of the PD, the property is owned by the Boden Creek Ecological
Preserve (BCEP). SCS was able to verify ownership by observing a recorded Deed ofConveyance between Harold Whitney, the prior owner, and BCEP, which describes: “all thatpiece or parcel of land comprising of 5230.79 acres situate along the East side of theSouthern Highway in the vicinity of mile 78…”. In addition, Transfer Certificate of Title
documents were provided for two blocks of land, Block 131 and Block 131A, comprising2,880.65 ha and 213.525 ha, respectively. When totalled with the previously discussed
parcel, the sum total property area is approximately 5,211 ha. Section 1.5 states that: “theproperty boundary consists of 5,213 ha of which 3,980 ha are considered the project area.”
The Project boundary was confirmed by the validation team, as required by the January 21,
2010 VCS Program Update. This was done by visiting selected locations along the boundary
and taking/recording GPS coordinates, which were checked against the coordinates
provided by the Client.
Section 1.13 of the PD states that the Project has not created any other form ofenvironmental credit. Section 1.14 of the PD also states that the Project has not been
rejected by any other GHG program. The validation team did not identify any evidence tothe contrary. Thus, we conclude that the Project is an eligible REDD Avoided Planned
Deforestation project, and is in compliance with all stated requirements for such projects.
The project meets each of the applicability conditions of the selected methodology. The
Client demonstrated that land in the project area has qualified as forest for at least ten years
before the Project start date using a combination of satellite imagery and reasonable
inferences based on the existing inventory data. The project area does not contain peatsoils, as was verified during a site visit by the validation team. Control over the project area
and ownership of carbon rights was demonstrated as described above. The baseline
scenario described by the Client and validated as documented in this report does not consistof temporarily unstocked land, nor does it constitute reforestation. The project includes no
specific leakage avoidance activities, and thus does not include any of the activities
prohibited by the methodology’s applicability conditions.
The selected methodology also contains several applicability conditions specific to the
avoidance of planned deforestation. The Client demonstrated that conversion of forested
lands to a deforested condition is legally permitted in Belize. However, during the site visit,
it was discovered that the laws of Belize require an environmental impact assessment (EIA)
prior to clearing of land greater than 300 acres. The methodology further requires that,
where government approval is required for deforestation to occur, the intention to deforest
within the project area must be demonstrated by evidence of recent approval from relevant
government department (local to national) for conversion of forest to an alternative land
use or documentation that a request for approval has been filed with the relevant
government department for permission to deforest and convert to an alternative land use.
Initially, the Client had identified a specific individual, the previous landowner, as the agent

7

VCS 2007.1 - Validation Report – Forest Carbon Offsets – Boden Creekof deforestation. Based on this identification, no evidence was available to demonstratethat the government of Belize had recently approved conversion of the project area, or thata request for approval (i.e., initiation of the EIA process) had been filed with the relevant
government department. However, for reasons described in NIR 38A, and independent of
the assessment of this requirement of the methodology, the validation team determinedthat the analysis of a class of agents of deforestation was more appropriate than theidentification of a specific agent. The validation team consulted the VCSA with regards towhether the requirement of demonstration of government approval or filing for approval
applied to classes of deforestation agents. As communicated in an email from Carolyn Chingto the validation team dated 11 April 2011, the VCSA ruled that “where the agent of
deforestation is a class of agents it would not be possible to get governmental approval so it
would not be necessary [to demonstrate approval].” Consequently, the validation teamdetermined that the Client had adequately demonstrated that the project area could be
legally converted to a non-forest land use.
The methodology additionally requires that documentation must be available to clearly
demonstrate with credible evidence and documentation that indeed the land would havebeen converted to non-forest use if not for the REDD project. Although no written plan orsimilar documents were available to support the planned baseline land use, themethodology, in the case of identification of a class of deforestation agents, allows adocumented history of similar planned deforestation activities by a class of agents, ofplanned deforestation within the five years previous to without-project deforestation.
While visiting the project area, the validation team observed many citrus plantations in thesurrounding area. Additionally, the validation team observed portions of the project area
(which are excluded from carbon accounting) on which citrus and bananas had been grownby the previous landowner. The previous landowner had a history of land clearing that was
documented in a biodiversity assessment contracted by the project proponent (BowenJones 2001). Consequently, the validation team determined that there was adequate
evidence that the land was likely to have been cleared in the absence of the project.
The validation team concluded that the project is in compliance with the eligibility
requirements of the selected VCS methodology.
Conformance:

Yes

No

Non-Conformity Reports:

NCR 2011.4
NCR 2011.5

New Information Requests:

NIR 2011.1
NIR 2011.2
NIR 2011.3
NIR 2011.18
NIR 2011.24
NIR 2011.25
NIR 2011.45
NIR 2011.46

Opportunities for Improvement:

None

3.2 Baseline

8

N/A

VCS 2007.1 - Validation Report – Forest Carbon Offsets – Boden Creek
As required by the REDD Methodology Framework (REDD-MF), the client applied the VCS“Tool for the Demonstration and Assessment of Additionality in VCS Agriculture, Forestry
and Other Land Use (AFOLU) Project Activities” to demonstrate the additionality of the
Project. Application of the Tool is described in Section 2.4 of the PD. In accordance with the
Tool, the Client presented three credible land-use scenarios: conversion to agriculture,purchase of the land to operate eco-tourism lodges, and purchase of the land as aconservation area. The Client adequately demonstrated that conversion to agriculture is themost likely scenario. The tool requires a common practice analysis, by which the extent ofsimilar activities in the immediate vicinity of the project is assessed. Several privately owned
lands managed for conservation purposes do exist in the vicinity of the project area. The
Client identified lack of access to funding as an essential distinction between the project andexisting similar activities in the surrounding area. Financial analyses prepared by the Client
and reviewed during the audit confirmed that the project proponent would likely be unable
to implement the project in the absence of carbon finance.
Quantification of GHG emissions and removals was conducted by the Client according therequirements of the BL-PL Module and is described in Section 4.2 of the PD. While a numberof possible agricultural uses, such as pasture for livestock and row crop production, werediscussed during the site visit, the Client felt that conversion to citrus production was a
feasible baseline scenario that was conservative (in the sense of carrying the highest averagecarbon mass per ha of any agricultural crop). The validation team indeed observed citrus
plantations in the vicinity of the project area during the site visit, and agreed with thisassessment. The baseline carbon stock in post-deforestation land use was estimated by the
Client based on available literature, with some modifications from published stocks made toensure conservativeness. The validators performed an independent literature review toconfirm the conservativeness of the assumed baseline carbon stock in citrus plantations.
Common practice for land clearing in Belize, as described by the technical expert contracted
by the audit team, is to harvest merchantable species prior to burning of remaining biomass.
The project includes emissions from biomass burning using the protocol described in module
E-BB, but does not account for baseline carbon stored in wood products. The Clientdemonstrated that, because of the relatively young age of the forest in the project area, theamount of carbon stored in wood products, as calculated using the procedures in the CP-W
module, would be less than 5% of the anticipated total carbon benefits over the life of the
project. Consequently, the wood products pool was excluded from all calculations ofbaseline and project carbon stocks, in accordance with VCS guidance for assessing thesignificance of carbon pools.
The baseline scenario also accounts for avoided emissions from the use of fertilizer as
described in the CDM tool “Estimation of direct nitrous oxide emission from nitrogen
fertilization.”
The baseline fertilizer application rate was determined based onrecommendations published by the Belize Citrus Growers Association. The conservativenessof the selected fertilizer application rate was assessed by the verifiers by comparison withpeer-reviewed literature. Although no peer-reviewed literature specific to Belize wasavailable, the listed rates were judged to be conservative in comparison to fertilizer
application rates published from studies in the United States.
As described in Section 1.7 of the PD, it was determined during validation that it would be
most appropriate to conduct the baseline analysis by identifying a “class of deforestation
agents” in line with Part 1.1 of the BL-PL Module. Because a valid verifiable plan did not exist

9VCS 2007.1 - Validation Report – Forest Carbon Offsets – Boden Creek
for determining the rate of deforestation in the baseline scenario, a proxy analysis was
conducted in accordance with the BL-PL module.
No deviations were sought or approved with regard to the setting of the baseline scenario.
Conformance:

Yes

Non-Conformity Reports:

NCR 2011.35

New Information Requests:

NIR 2011.9
NIR 2011.10
NIR 2011.11
NIR 2011.20
NIR 2011.21
NIR 2011.22
NIR 2011.23
NIR 2011.26
NIR 2011.27
NIR 2011.31
NIR 2011.38A
NIR 2011.40
NIR 2011.46

Opportunities for Improvement:

None

3.3

No

N/A

Monitoring Plan

The project will be monitored in conformance with approved VCS methodology VM0007.
Pools selected for monitoring include above and below ground biomass in live trees. The
Client has elected to exclude the dead wood, litter and soil organic carbon pools. The wood
products pool and emissions from fuelwood extraction were estimated to be de minimus
based on ex-ante estimates of project carbon benefits. Activity shifting leakage is accounted
for using the LK-ASP module.
The methodology requires ongoing monitoring of biomass stocks and land cover within the
project area. The monitoring methodology is described in Appendix A of the PD. The
methodology makes use of a network of permanent nested fixed area sample plots.
Biomass of sampled trees is computed using allometric equations reported by Chave et al(2005). Specifically:
AGB=ρ*EXP(1.239+1.98*LN(DBH)+0.207*(LN(DBH))^2 - 0.0281*(LN(DBH))^3)
Where ρ is a species-specific density factor. Belowground biomass is computed using theallometric equation reported by Pearson et al (2005):
BGB = =EXP(-1.0587+0.8836*LN(DBH))
The validation team determined, on the basis of available scientific literature, that theseequations were appropriate for the project area. Additionally, the Client conducted avalidation exercise as required by the CP-AB module. Monitoring of biomass stocks is to be
conducted annually, and is the responsibility of the landowner, with third party verification
occurring, at a minimum, every five years. The monitoring plan is consistent with the10VCS 2007.1 - Validation Report – Forest Carbon Offsets – Boden Creek
selected methodology and provides sufficient information to estimate changes in carbon
sinks in the project and baseline scenarios.
The following parameters are required to be monitored by the approved VCS methodology
and are applicable to the project:
Asp
N
DBH
AdefLK,i,t

Area of sample plots
Number of sample plots
Diameter at breast height of each tree in a sample plot
The total area of deforestation by the baseline agent or class of agent of theplanned deforestation in stratum i at time t

Project Forest
Cover
Monitoring Map

Map showing the location of forest land within the project area at the
beginning of each monitoring period. If within the Project Area some forest
land is cleared, the benchmark map must show the deforested areas at eachmonitoring event

Aburn,i,tArea burnt in stratum i at time t

ADefPA,i,t

Area of recorded deforestation in the project area in stratum i at time tAi
UBSL,SS

Total area of stratum i
Percentage uncertainty (expressed as 95% confidence interval as a percentageof the mean where appropriate) for carbon stocks and greenhouse gas sourcesin the baseline case
Percentage uncertainty (expressed as 95% confidence interval as a percentageof the mean where appropriate) for carbon stocks and greenhouse gas sourcesin the project case

UP,SS

All other parameters used in the methodology are either used as listed in the methodology,
or are estimated at validation and held constant in project carbon accounting.
Conformance:

Yes

Non-Conformity Reports:

None

New Information Requests:

NIR 2011.13
NIR 2011.37

Opportunities for Improvement:

3.4

No

N/A

None

Calculation of GHG Emissions

Greenhouse gas sources and sinks included in the project are described in Section 2.3 of thePD. The Project includes the following greenhouse gas sources, sinks, and reservoirs: aboveand belowground biomass, emissions of CH4 from biomass burning, and emissions of N2O
from biomass burning and the use of fertilizer. Carbon stocks in the dead wood, litter, andsoil organic carbon, as well as emissions from fossil fuel burning were conservatively
excluded from the project boundary. Carbon in harvested wood products and fuel wood
were analyzed by the Client and determined to collectively represent less than 5% of the
cumulative estimated net GHG benefits of the project. The Client elected to exclude these11

VCS 2007.1 - Validation Report – Forest Carbon Offsets – Boden Creek
pools from the project, in conformance with the VCS standard. The validation teamassessed the appropriateness of these pools in the project’s GHG accounting anddetermined that included pools and emissions sources were in conformance with therequirements of the VCS standard and the selected methodology.
Project personnel calculated baseline and Project scenario greenhouse gas emissions using
the equations given in the approved VCS methodology selected by the Client. The following
project-specific parameters are used in this quantification:
Parameter
Aplanned,i

Value
Selected
3980 ha

D%planned,i,t

10.8%

LKCP-ME

0.4

PFc

0.645

Validation Notes
This represents the total area of planned deforestation overthe baseline period, and is representative of the total areaof land eligible within the project area. This assumes thatthe entire project area would be converted to a non-forest
land use. Though there was no verifiable conversion plan
available to substantiate this assumption, the validationteam found it to be reasonable compared to other land
uses observed in the project area. This area was adjusted
down from the total area of forest land controlled by the
project proponent to account for areas that were previously
cleared, streamside buffers, and to account for differencesin area between title documents and areas calculated by
GIS analysis of the project area.
The projected annual proportion of land that will be
deforested was calculated by the Client using an analysis of
six proxy areas as described in section 1.3 of the BL-PL
module. The proxy areas ranged in size from 554 hectares
to 4046 hectares and meet the applicability criteria
provided in section 1.3 of the BL-PL module. The validationteam notes that, because the methodology limits analysis ofproxy areas to sites that have been deforested in the last 10
years, it is impossible to arrive at a deforestation rate of lessthan 10% per year, regardless of the size of the project
area. The technical expert hired by the audit teamcommented that such a rate, sustained over a decade,would be unusual in Belize. The Client showed that clearing
at this rate is feasible by providing an email from acontractor in Belize and also showed one proxy area ofcomparable size to the project area(4046 hectares) anddemonstrated, using satellite imagery, that the clearing ofthat area had taken place over ten years. Consequently, thevalidation team determined that the estimation of thisparameter was in conformance with the guidance provided
by the methodology.
The selection of this parameter followed the guidance in
Step four of the LK-ASP module, and assumes that the
project area is similar with regard to soil type, elevation,and precipitation to other areas in Belize suitable for citrus
production.
The proportion of available area for production of

12

VCS 2007.1 - Validation Report – Forest Carbon Offsets – Boden Creek

MSFi,t0.193593
tonnes/year

NCSFi

0.19

commodity c that is currently forested was assessed by theclient using an independently prepared land cover analysis
of Belize.
The mass of synthetic nitrogen fertilizer applied in thebaseline scenario is based on recommendations publishedon the Belize Citrus Grower’s Association website andconservative assumptions regarding the number of citrus
trees per acre that would be planted in the baseline
scenario. The validation team compared both figures tothose found in relevant peer reviewed literature and foundthem to be conservative.
The fertilizer recommendations on the Belize Citrus
Growers website assume the use of fertilizer with a 19-9-19
N-P-K rating. Thus, the percent nitrogen, by mass, is 19%.

Other parameters used in the quantification are either provided by the approved
methodology, monitored in the project area as discussed in section 3.3, or are derived fromthese parameters. All calculations were implemented in an excel spreadsheet titled “BCEP
Final Carbon Table 2011.xlsx.” The validation team checked all calculations performed by the
Client to ensure that they were conducted correctly and in accordance with themethodology. The PD reports the results of baseline and ex-ante project emissions in Table
2. SCS confirmed that the estimates in this table were made using the equations provided
by the methodology.
Ex-ante estimates of changes in carbon stocks in above and below ground biomass are basedon a study in Mexico by Hughes et al. (1999). The validation team determined that, given
the limited availability of growth data in recently hurricane affected tropical forests in Belize,
the Hughes study offered a reasonable proxy for the forest in the project area, but notesthat these ex-ante estimates of project carbon benefits are subject to high uncertainty. This
uncertainty does not affect ex-post estimates of carbon stocks in the baseline or project
scenario, as, under the selected methodology, changes in biomass stocks are determined bydirect monitoring. The Client has calculated the uncertainty of the baseline and project
scenario in conformance with the X-UNC module, as described in sections 4.2 and 4.4 of the
PD and as documented in the “BCEP Final carbon Table 2011.xlsx” spreadsheet. As of theconclusion of the spring 2011 monitoring event, the uncertainty in the baseline includes a25.33% contribution from biomass inventory and a 7.43% contribution from proxy area
analysis of the baseline deforestation rate for a total baseline uncertainty of 26.39%. The
project scenario uncertainty includes a 25.33% contribution from forest inventory
uncertainty. All other pools and emission sources were calculated using assumptions
deemed indisputably conservative by the Client and validated as such by the validation
team. The total uncertainty for the project, as of the time of issuance of this report, is36.58%. The ex-ante estimates of net avoided emissions reported in Table 2 of the PD
contain an uncertainty deduction calculated as described by equation 8 of the X-UNC
module. All uncertainty calculations were checked by the validation team and determined
to have been applied in conformance with the methodology.
Conformance:

Yes

No

Non-Conformity Reports:

NCR 2011.15
NCR 2011.29
NCR 2011.30

13

N/A

VCS 2007.1 - Validation Report – Forest Carbon Offsets – Boden Creek
NCR 2011.32
NCR 2011.33
NCR 2011.34
New Information Requests:

NIR 2011.6
NIR 2011.7
NIR 2011.8
NIR 2011.12
NIR 2011.14
NIR 2011.16
NIR 2011.28
NIR 2011.36
NIR 2011.38B
NIR 2011.39
NIR 2011.41
NIR 2011.42
NIR 2011.43
NIR 2011.44

Opportunities for Improvement:

None

3.5 Environmental Impact Assessment
Requirements for an Environmental Impact Assessment are not applicable to the project
activity, as the laws of Belize do not require an environmental impact assessment prior to
projects designed to conserve forest land. The proposed baseline scenario would haverequired an environmental impact assessment, which was not conducted, as described in
section 3.1 of this report.. A discussion of potential environmental impacts of the Project isprovided in Section 5.0 of the PD. The validation team agrees with the Client that nonegative biodiversity impacts are anticipated within the area surrounding the Project.
Conformance:

Yes

No

Non-Conformity Reports:

None

New Information Requests:

NIR 2011.17

Opportunities for Improvement:

None

N/A

3.6 Comments by stakeholders
No comments by stakeholders were received by the validation team. However, comments
by stakeholders were assessed during the Project’s validation against the CCBA standards in2010. A list of comments and an assessment of those comments can be reviewed in thevalidation report from that audit, available at:https://s3.amazonaws.com/CCBA/Projects/Boden_Creek_Ecological_Preserve_Project/CCB_
FCO_BodenCreek_RPT_ValidationReport_071410.pdf
Conformance:

Yes

No

14

N/A

VCS 2007.1 - Validation Report – Forest Carbon Offsets – Boden Creek
Non-Conformity Reports:

None

New Information Requests:

None

Opportunities for Improvement:

None

3.7 Risk assessment

Risk Factor
justification

andproject

proponent

Self Assessment
Risk Rating

The following material is reprinted from SCS’s report from the First Assessment in the Nonpermanence Risk Assessment Double Approval process dated 13 April 2011:

Risk of unclear land tenure and potential for Low
disputes:

Findings

Title documents confirm clear title toland. Low risk assigned.

Independent third-party title search has
confirmed title is held by BCEP with noliens. See section 8.0 Ownership.
Risk of financial failure:Low

BLE has proven track record of repaying
loans to FFI, et al. Project proponent
manages eco-tourism business that isdependent on protected forest for
tourism income.

Risk of technical failure:

Low

FCO and CMI have proven long-term trackrecord of designing, implementing, andmonitoring high quality ecosystemmanagement projects and forest carbon
projects.
Risk of management failure

Low

FCO and CMI have proven long-term trackrecord of designing, implementing, and15

Review of financial documents for the
project and the associated ecotourism
venture show that the project is highly
dependent on income from carbon
finance. The associated ecotourism
venture is not capable of financiallysustaining the project.
However, projections of VCUs to begenerated from the project show that
anticipated carbon revenue should be
adequate to fund project activities. Low
risk assigned.
Past history of implementation of
ecosystem management projects was
discussed with project proponents. The
technical
complexityofproject
implementation
is
low.
The
combination of the project developer’s
past experience and the low projectcomplexity support a low risk rating.
Interviews with project proponents
supported a low risk of management
failure.

VCS 2007.1 - Validation Report – Forest Carbon Offsets – Boden Creek
monitoring high quality ecosystemmanagement projects and forest carbon
projects.
Risk of rising land opp. costs causing reversal Low
of sequestration/protection

Project proponent manages eco-tourism
business that is dependent on protected
forest for tourism income.

Risk of political instability:

Low

Belize has low regional political instability.
The project area does not include local
communities. Local communities are notreliant upon the project area for essential
food, fuel, fodder, medicines or building
materials where such resources are notreadily available elsewhere, or where theproject area includes areas of cultural,
ecological,
economicor
religious
significance.

Land pressures in the surrounding
region were obvious upon visitation andinclude clearing for citrus growing andrangelands.
Elsewhere in project
documentation, the project proponent
suggests that a deed restriction has
been agreed to for the project area.
Such a restriction would indeed
significantly reduce this risk factor, but
is not currently in place.
However, given that the land is ownedbyadedicatedconservation
organization (Boden Creek Ecological
Preserve), a low risk level has been
assigned.
Low risk of political instability in Belize
was confirmed by reviewing the CIA
World Factbook.

Low
Risk of social instability :Belize has low regional social instability. The
project area does not include local
communities. Local communities are notreliant upon the project area for essential
food, fuel, fodder, medicines or building
materials where such resources are notreadily available elsewhere, or where theproject area includes areas of cultural,
ecological, economic or religious significance.
See Table 9: Belize Worldwide GovernanceIndicators.

After visiting the site and consultingwith a technical expert who has
knowledge of the area, the validationteam agrees that the risk of reversal due
to social instability is low.

Risk of devastating fire:

The project is located in a wet tropicalclimate. Review of existing literaturescientific literature and consultation
with local technical experts confirmsthat the risk of a devastating forest fireis low.

BCEP has nodevastating fire.

recordedLowhistoryof16VCS 2007.1 - Validation Report – Forest Carbon Offsets – Boden Creek
Risk of pest and disease attacks:

Low

BCEP has no recorded history of pest anddisease attacks.
Risk of extreme weather events (e.g. floods, Low
drought, winds) :BCEP has hurricane occurrence recordedroughly every 50 to 100 years.
Also:
The southern region of Belize has one of thelowest frequencies of hurricane landfall in the
Caribbean with an average of one landfall
every 23 years (Lugo et al. 2000). Since theforest is recovering from Hurricane Iris in
2001, and the trees are smaller and less prone
to breakage, the risk of reversal as a result of
hurricanes is low for the life of the project.

Consultation with a local technicalexpert confirmed that the forest type in
the project area is not susceptible todevastating pest and disease attacks.
Low risk assigned.
The verification team was unable to findthe hurricane frequency of one landfall
every 23 years in the cited Lugo et al2000 paper.
However, data
independently obtained by the audit
team from the website of the NOAA
hurricane research division suggeststhat the mean occurrence of named
storms within 100 miles of the project
are from 1944-1997 was approximately
0.2 storms per year (1 storm every five
years on average). This same data
source suggested that the hurricane
return interval in the area isapproximately 25-50 years, withcategory 4 and category 5 storms on a100+ year return interval. This places
the project in an area prone tohurricane impacts, but the risk is lower
than many other parts of the Caribbean.
Notably, a category 4 hurricane struck
the project area in 2001, causing
extensive damage to the forest.

Geological risk (e.g. volcanoes, earthquakes, Low
landslides):BCEP has no recorded history of geologicalrisk.
Overall Risk Rating
Self
Assessment:
Low

17

The audit team felt the project’s
location in a hurricane prone region did
not constitute grounds for assignmentof the lowest risk rating. Medium risk
level assigned; see additional discussion
below.
Consultation with local technical expert
confirmed no known geological risk inthe project area. Low risk level assigned.

Verifier Assessment: MediumSelf Assessment
Risk Rating

VCS 2007.1 - Validation Report – Forest Carbon Offsets – Boden Creek

Risk Factor

Land ownership was confirmed byreview of title documents. Very
Low risk assigned.

Land ownership / land
management typeLand owned by private
conservation
organization, BCEP, witha good track record in
Very Low
forestconservation
activities and able toobtainandenforcenationallyrecognizedlegal protection of theland.
Technical capability of
project developer
BCEP, CMI, and FCO have
proven capacity to design
andsuccessfully
implement activities that Very low
are likely to ensure thelongevityofcarbonbenefits (e.g., effectively
managing
protected
areas).
Net revenues/financial
returns from the project
toallrelevant
stakeholders
Higher to pre-project orsimilar to alternativeland-uses. Land owned byprivateconservation
Low
organization, BCEP, witha good track record inforestconservation
activities and able toobtainandenforcenationallyrecognizedlegal protection of theland.
Infrastructure and natural resources

Findings

Past history of implementation of
ecosystem management projects
was discussed with project
proponents.
The technicalcomplexityofproject
implementation is low.
The
combination of the project
developer’s past experience andthe low project complexity support
a low risk rating.

The landowner is a conservationgroup (BCEP). For conservationgroups, this risk rating is low,
regardless of pre-project andalternative land uses.

Low

Opinion of local technical expert

18

VCS 2007.1 - Validation Report – Forest Carbon Offsets – Boden Creek
confirmed low risk rating.

Low likelihood of newroad(s)/rails being built
near the BCEP projectboundary.
BCEP
isbordered on two sides
with protected areas.
Land owned by private
conservation
organization, BCEP, witha good track record inforestconservation
activities and able toobtainandenforcenationallyrecognizedlegal protection of theland.
No high-value non-forest
related natural resources(oil,minerals,etc.)
known to exist within
BCEP project area. Landowned
byprivateconservation
organization, BCEP, with Low
a good track record inforestconservation
activities and able toobtainandenforcenationallyrecognizedlegal protection of theland.
Nohydroelectric
potential within BCEP
project area. Land owned
by private conservation
organization, BCEP, witha good track record in
Low
forestconservation
activities and able toobtainandenforcenationallyrecognizedlegal protection of theland.
Population surrounding
theprojectarea
Low
Decreasing or increasing,but with low population

Opinion of local technical expert
confirmed low risk rating.

Opinion of local technical expert
confirmed low risk rating.

Visitation of the project area
confirmed low population density.

19

VCS 2007.1 - Validation Report – Forest Carbon Offsets – Boden Creek
density(e.g., <50 people/km2).
BCEP
project
area
population is estimatedto be less than <50
people/km2.
Incidence of crop failure
on surrounding lands
from severe droughts,
Low
flooding
and/orpests/diseases
Frequent (>1 in 10 years)

This risk rating is classified as low
or very low for all APD REDD
projects.

Low

Review of financial documents forthe project and the associatedecotourism venture show that the
project is highly dependent on
income from carbon finance. The
project developer has stated plansto fund an investment trust, but atpresent such a trust has not yet
been established, as it relies on
anticipated income from carbon
finance.
Projections of VCUs to begenerated from the project showthat anticipated carbon revenue
should be adequate to fund project
activities. However, financial risks
remain if actual revenues are lessthan projected revenues, perhaps
because of a natural disturbance ora decrease in future demand for or
price of forest carbon offsets.

Project financial plan
Crediblelong-term
financial strategy in place(e.g.,
endowment,
annuity-paying
investments, and thelike). Funding BCEP willfund investment trustwith annuity payment
with guaranteed income
for employees of BCEP
for lifetime of project.

The legal easement discussed forprotection of land title is not
currently in place.
At present, the validator assigns a
medium risk level to this category,but future establishment of a legal
easement or evidence that an
adequate trust to fund project
activities is in place may reduce therisk rating at a future assessment.
MediumBCEP has legal easementfor ongoing protectiontied to land title in place.
Overall Risk Rating

Low

20

VCS 2007.1 - Validation Report – Forest Carbon Offsets – Boden Creek
VCS requires that projects be given the overall risk rating associated with the highest risk
factor from the analysis above. The highest risk rating from the categories above is“medium”, so a medium risk rating is assigned to the Project.
The specified buffer contribution range for medium risk avoided planned deforestation
projects is 10-20%. The VCS program update from 13 April 2010 specifies that the required
buffer withholding percentage shall be the maximum percentage in the buffer range for thedetermined risk class, unless justification for a lower withholding percentage can bedemonstrated. Given that the largest risk element for the project is hurricane impacts, thatthe relatively young age of the existing forest somewhat mitigates the extent of damage to
be expected in the event of a hurricane strike, and that the project area, while hurricane
prone, is of relatively low risk when compared to other portions of the Caribbean prone tohurricanes, SCS believes that less than the maximum withholding percentage for the
medium risk class is appropriate. Accordingly, SCS assigns a buffer rating at the midpoint of
the range specified for the medium risk category: 15%.
Conformance:

Yes

Non-Conformity Reports:

None

New Information Requests:

NIR 2011.19

Opportunities for Improvement:

None

4

No

N/A

Validation Conclusion

Through a review of project documentation, supporting information also provided by the
Client, a site visit, and an iterative exchange of audit findings, SCS has determined that the
Project meets all relevant criteria for REDD Avoided Planned Deforestation projects under
VCS. In addition, the Project is in conformance with the selected methodology and its
associated modules, as listed in Section 1.2 of this document. We conclude that the Projectis likely to achieve the estimated emission reductions and, as such, no qualifications orlimitations should be added to the validation outcome. Thus, it is the opinion of Scientific
Certification Systems that the Project is eligible for registration under the applicable VCS
standard.

Name: Ryan Anderson
Name: Todd Frank
Title: Lead Auditor
Title: Program Manager, GHG Verification
Company: Beartooth Forest Carbon Consulting Company: Scientific Certification Systems
Date: June 24, 2011
Date: June 24, 201121

VCS 2007.1 - Validation Report – Forest Carbon Offsets – Boden Creek

Certification for a Sustainable World ™

Appendix A:
FOREST PROJECT VALIDATION
LIST OF FINDINGSVALIDATION UNDER THE
VOLUNTARY CARBON STANDARD

Reporter/Member:
Forest Carbon Offsets
Project:
Boden Creek REDD Project

22

VCS 2007.1 - Validation Report – Forest Carbon Offsets – Boden Creek
NIR Number 2011.1 of 50 dated 1/11/2011
Standard Reference: REDD‐MF II I ‐ Scope
Document Reference: NA
Finding: The methodology requires that reference to the REDD
‐MF framework and themodules used to construct the project‐specific methodology be given in the VCS PD. Pleaseprovide a single, comprehensive list of modules used for the project.
Proponent Response: A complete list of the modules used is included in section 2.1
REDD Methodology Modules (http://www.v‐c‐s.org/methodology_rmm.html). In particular
the following methodology modules were used for this project:
REDD‐MF
M-MON
T-ADD
T-BAR
X-UNC
X-STR
Auditor Response: The Proponent’s response adequately addresses the finding inaccordance with The VCS 2007.1 Protocol and selected methodology.

NIR Number 2011.2 of 50 dated 1/11/2011
Standard Reference: Voluntary Carbon Standard Tool for AFOLU Methodological Issues, Sec.
2, Step 1
Document Reference: BCEP Carbon PDD ver 2.doc, Sec.2.2. p13
Finding: Please provide evidence that the project boundary only includes land qualifying as
forest, using an internationally accepted definition, for a minimum of ten years prior to theproject start date.
Proponent Response: We used a definition based on the FAO Forest Resource Assessmentof 2000:
Land with tree crown cover (or equivalent stocking level) of more than 10 percent and areaof more than 0.5 hectares (ha). The trees should be able to reach a minimum height of 5
meters (m) at maturity in situ.
We excluded the part of the property previously converted to bananas and currently
recovering. Based on satellite imagery (see below) and plot data indicating, based on tree
sizes, that the forest must have been forest in 2000, we considered the project boundary to
only include forest land according to this definition. The land cover study is attached.
Auditor Response: The definition applied is in conformance with the requirements of thestandard. The imagery provided by the Client, as well as observations made by the audit
team in the field support the claim that the project area has qualified as forest for at leastten years. The Proponent’s response adequately addresses the finding in accordance withThe VCS 2007.1 Protocol and selected methodology.

NIR Number 2011.3 of 50 dated 1/11/2011
Standard Reference: Voluntary Carbon Standard Guidance for AFOLU; REDD‐MF II, step 1(a);VCS 2007.1 section 5.7, page 15

23

VCS 2007.1 - Validation Report – Forest Carbon Offsets – Boden Creek
Document Reference: BCEP Carbon PDD ver 2.doc, Sec.1.5 p5
Finding: Please provide geographic coordinates of each polygon vertex defining the project
area along with documentation of their accuracy.
Proponent Response: Vertices of project boundary provided at site visit.
Auditor Response: The Client provided a shapefile that contained all vertices of the projectboundary during the site visit. Though no documentation of the accuracy of these points
was provided, the audit team verified a sample of points along the project boundary bycomparison with GPS coordinates independently collected during the site visit. The
Proponent’s response adequately addresses the finding in accordance with The VCS 2007.1
Protocol and selected methodology.

NCR Number 2011.4 of 50 dated 1/11/2011
Standard Reference: REDD-MF II step 1(b)Document Reference: BCEP Carbon PDD ver 2.doc, Sec.1.6 p7
Finding: The starting date of the historical reference period must be between 9 and 12 years
in the past and the end date must be within two years of the project start. The specified
historical reference period end date is 2008. This is not within two years of the project start,
as the project start date is defined as February 19, 2004.
Proponent Response: This is a revised and updated response to this NIR.
•

Historical reference period January 1995 through December 2004•

Funding secured for carbon project and developer signed September 2009.

•

Start of project 1/1/2005•

Crediting period 2005 to 2029.

•

Baseline reset 2015 and 2025.

•

Project end date is December 31, 2029.

Auditor Response: The project proponent has adjusted the project’s reference period to beconsistent with the requirements of the methodology. The Proponent’s response
adequately addresses the finding in accordance with The VCS 2007.1 Protocol and selected
methodology.

NCR Number 2011.5 of 50 dated 1/11/2011
Standard Reference: REDD‐MF II step 1(b)Document Reference: BCEP Carbon PDD ver 2.doc, Sec 1.6 p7
Finding: The methodology requires that projections of baseline emissions be presented forten year periods after the start of the project and that the baseline be revised every ten
years after the project start. The project start date is in 2004, so the baseline must be reevaluated in 2014. The baseline reset year of 2019 described in the PDD is not consistent
with the methodology.
Proponent Response: This is a revised and updated response to this NIR.

24

VCS 2007.1 - Validation Report – Forest Carbon Offsets – Boden Creek•

Historical reference period January 1995 through December 2004•

Funding secured for carbon project and developer signed September 2009.

•

Start of project 1/1/2005•

Crediting period 2005 to 2029.

•

Baseline reset 2015 and 2025.

•

Project end date is December 31, 2029.

Auditor Response: The dates have been adjusted to be in accordance with the requirementsof the methodology. The Proponent’s response adequately addresses the finding inaccordance with The VCS 2007.1 Protocol and selected methodology.

NIR Number 2011.6 of 50 dated 1/11/2011
Standard Reference: REDD‐MF II step 1 ( c)Document Reference: BCEP Carbon PDD ver 2.doc, Sec 2.3 p14
Finding: The methodology requires that table 2 from REDD
‐MF with selection of carbon
pools and appropriate justification for each be presented in the VCS PD. Please provide thisinformation.
Proponent Response: The table on the following page is inserted in the PDD.
Auditor Response: The requested table has been provided. The Proponent’s response
adequately addresses the finding in accordance with The VCS 2007.1 Protocol and selected
methodology.
NIR Number 2011.7 of 50 dated 1/11/2011
Standard Reference: REDD‐MF II step 1 (d)Document Reference: BCEP Carbon PDD ver 2.doc, Sec 2.3 p14
Finding: The methodology requires that table 3 from REDD
‐MF with selection of sources
and appropriate justification for each be presented in the VCS PD. Please provide thisinformation.
Proponent Response: The following table will be added to the PDD.
[Table not copied into list of findings to avoid redundant data. Table is found in the PD]
Auditor Response: The requested table has been provided. The Proponent’s response
adequately addresses the finding in accordance with The VCS 2007.1 Protocol and selected
methodology.
NIR Number 2011.8 of 50 dated 1/11/2011
Standard Reference: BL‐PL I. Applicability
Document Reference: BCEP Carbon PDD ver 2.doc Sec 4.2
Finding: Provide written documentation of the application of the application of the
‐SIG
T

25

VCS 2007.1 - Validation Report – Forest Carbon Offsets – Boden Creek
tool to verify that fuel wood collection does not significantly impact carbon pools forbaseline or leakage accounting.
Proponent Response: According to Estimation of baseline carbon stock changes andgreenhouse gas emissions from planned deforestation (BL-PL), if pre-Project, unsustainable
fuelwood collection was occurring within the Project boundaries modules BL-DFW and LKDFW shall be used to determine potential leakage. While BCEP pre-Project, limited fuelwood
extraction may have been occurring on the 50 ha parcel of the property that is next to Indian
Creek Village and Golden Stream Village alongside the Southern Highway that is excluded
from the above-ground biomass carbon pool, the removals on this thin buffer strip along theSouthern Highway across from Indian Creek Village and Golden Stream Village would havebeen de minimis. Population estimates pre-Project were roughly, at the very most, 750
individuals (Table 1: 1997 estimated populations).
Using annual fuelwood consumption per capita (Schulte-Bisping 1999) for Belize at 0.15 ton
oil equivalent (TOE) and FAO conversion factor of 0.26 for one m3 fuelwood (solid 20–30%
moisture content) / TOE yields 0.58 m3 fuelwood per capita per year.
After applying Tool for testing significance of GHG emissions in A/R CDM project activities(Version 01) (T-SIG), the impact on this carbon pool was de minimis and substantially lessthan 5%. Therefore, according to the Tool for testing significance of GHG emissions in A/R
CDM project activities (Version 01) (T-SIG), the GHG emissions by sources, possible
decreases in carbon pools and leakage emissions measured by this occasional fuelwood
extraction on this boundary parcel is considered insignificant. Furthermore, according tovillage records, there has been no traditional fuelwood collection that occurred on the
Project site (Toledo Maya Cultural Council 1997). Some collection of debris wood left overfrom agricultural operations may have occurred alongside the Project area on a parcel that is
not part of the Project, yet the total carbon anthropogenic emissions from this source is deminimis and insignificant (Table 2: FGBSL, i, t Variables and Equation 1: FGBSL, i, t Equation).
Auditor Response: The validation team reviewed the assumptions of this analysis and foundthem reasonable. Additionally, the validation team spoke with Bonifacio Tut, a local tree
identification expert who was hired by the validation team to assist with field work,
regarding the volumes of fuel wood used by people who live in the area. Mr. Tut’s estimates
were consistent with the assumptions made in the analysis by the project proponent. The
Proponent’s response adequately addresses the finding in accordance with The VCS 2007.1
Protocol and selected methodology.
NIR Number 2011.9 of 47 1/11/dated 2011
Standard Reference: BL‐PL 1.2
Document Reference: BCEP Carbon PDD ver 2.doc Sec 4.2 p19
Finding: The methodology requires documentary proof of legality of deforestation. The PD
states that legal permissibility is assumed because similar deforestation occurs today andbecause previous deforestation was well known, but this does not constitute documentary
proof. Please provide such proof.
Proponent
Response:
The
BelizePrivateForests
Act(http://www.belizelaw.org/lawadmin/index2.html) requires that for conversion to takeplace for agriculture, no permits are required if trees under 2 feet in circumference are to befelled and burned in place. To fell trees over 2 feet in circumference requires a permit fromthe Forest Department. The term tree is defined as mahogany and cedar.
Provided that no such application or permission shall be necessary to fell trees under twofeet girth measured at one foot above the buttresses during the clearance of land for
agriculture but no tree so felled may be sold as timber without a permit from the Chief

26

VCS 2007.1 - Validation Report – Forest Carbon Offsets – Boden Creek
Forest Officer
We have found no evidence to indicate that 2 foot circumference or larger mahoganies orcedars were removed by the deforesting agent therefore we presume that the deforestation
for agricultural conversion was performed legally prior to acquisition by the current
landowner. Regardless after the hurricane of 2003, no trees of any size were left, so clearing
could have proceeded legally at that point.
No cedars or mahoganies were detected in the field data, however mahogany and cedar
does occur rarely on the property. If at any time, the deforesting agent encounteredmahoganies or cedars, he could have left them standing in the field or gotten a permit fromthe Forest Department to remove them.
Auditor Response: The validation team found that, though conversion of privately owned
forest land to agriculture is legal in Belize, local laws require an environmental impact
assessment prior to clearing of greater than 300 acres. See response to NIR 2011.46. After
NIR 2011.46 was resolved, the Proponent’s response adequately addressed the finding inaccordance with The VCS 2007.1 Protocol and selected methodology.
NIR Number 2011.10 of 50 dated 1/11/2011
Standard Reference: BL‐PL 1.2
Document Reference: BCEP Carbon PDD ver 2.doc Sec 4.2 p19
Finding: The methodology requires that suitability for conversion to alternative non‐forest
land use include documentary proof of access to relevant markets, suitability of soils,
topography, and climate. Observing that the property was in the process of being converted
to alternative use does not constitute documentary proof of these elements. Please provide
such proof.
Proponent Response: Documentary proof:
Access to markets: see attached report “Report of damage by Hurricane Richard to theCitrus Industry of Belize By Luis G.Tzul”
Suitability of soils: See Bowen‐Jones 2001 attached that is documentary proof of suitability(see section on land use history).
Auditor Response: Adequate evidence of suitability for alternative use was provided inconformance with the requirements of the methodology. The Proponent’s response
adequately addresses the finding in accordance with The VCS 2007.1 Protocol and selected
methodology.
NIR Number 2011.11 of 50 dated 1/11/2011
Standard Reference: BL‐PL 1.3‐1.5
Document Reference: BCEP Carbon PDD ver 2.doc Sec 4.2 p20
Finding: Provide evidence that the eight proxy areas for which data is presented in table 1
meet criteria 1‐6 in section 1.3 of module BL‐PL (page 5). Additionally, please provide
verifiable documentation of the calculation of the deforestation rate in each proxy area.
Demonstrate that none of the proxy areas have been abandoned as described in section 1.5.
Proponent Response: A metadata record is attached for the new proxy area analysis.
Auditor Response: After issuance of this finding and discussions during the site visit, theproxy analysis was repeated. Evidence of the required criteria were presented with therevised proxy area analysis. The Proponent’s response adequately addresses the finding inaccordance with The VCS 2007.1 Protocol and selected methodology.

27

VCS 2007.1 - Validation Report – Forest Carbon Offsets – Boden Creek
NIR Number 2011.12 of 50 dated 1/11/2011
Standard Reference: BL‐PL 2.2
Document Reference: BCEP Carbon PDD ver 2.doc Sec 4.2 p20
Finding: Provide a copy of the reference used to determine the maximum carbon stock of
citrus plantations. Demonstrate that this stock includes all selected and required pools,
including aboveground and belowground biomass.
Proponent Response: The reference used to determine the maximum carbon stock of citrus
plantations is:Food and Agriculture Organization of the United Nations. 2003. Belize; Facing the Climate
Change.
CentralAmericanseriesonforestandclimatechange.
http://www.fao.org/DOCREP/006/AD438E/AD438E00.HTM
In this study the static approach is used to measure the baseline. This approach assigns staticor fix rate for carbon uptake at the start of the project and uses the same rate for the
lifetime of the project.
Auditor Response: The reference was provided. A review of the reference showed that the
carbon stock indicated in the FAO publication was not based on measured data, but was
rather an assumption made for the purpose of making country-level estimates. The
verification team determined that the reference did not meet the requirements of themethodology for estimating post deforestation carbon stocks. NIR2011.36 was issued in
response. After NIR2011.36 was resolved, the Proponent’s response adequately addressed
the finding in accordance with The VCS 2007.1 Protocol and selected methodology.
NIR Number 2011.13 of 50 dated 1/11/2011
Standard Reference: Voluntary Carbon Standard 2007.1, Sec. 5.11; REDD‐MF II step 3
Document Reference: BCEP Carbon PDD ver 2.doc, Appendix A
Finding: The monitoring plan must be consistent with the methodology as described in
REDD‐MF step 3, including descriptions of items a‐f for each monitoring task. Additionally,
the VCS standard requires that the project proponent establish and maintain criteria andprocedures for obtaining, recording, compiling, and analyzing data. These monitoringprocedures must include:• purpose of monitoring;• types of data and information to be reported ‐ including units of measurement;• origin of the data;• monitoring methodologies, including estimation, modeling, measurement or
calculation approaches;• monitoring times and periods, considering the needs of intended users;• monitoring roles and responsibilities;• GHG information management systems, including the location and retentionof stored data
Please provide a monitoring plan that is consistent with the methodology and that more
completely the data monitored, including units, origin, measurement methodology,
monitoring times, and information systems. The monitoring plan states that measurements
must be conducted according to relevant standards. To make this requirement verifiable,please list the standards that will be used for each measurement type. In order to permit
replication of the sampling methodology, the monitoring plan should also include thefollowing:‐ Methodology by which inventory plots are monumented‐ Size and type of inventory plot used
‐ A list of variables measured

28

VCS 2007.1 - Validation Report – Forest Carbon Offsets – Boden Creek‐ Minimum diameter at breast height used, if any‐ A list of tools used to measure trees in inventory plots‐ Any applicable conditions under which diameter at breast height was measured at a point
other than 1.3 vertical meters above the ground surface‐ The point on the tree stem that was used to determine whether a tree was on or off theplot‐ A list of any species or other categories of live trees that may have been excluded fromsampling, if applicable‐ Any edge correction procedures used, if applicable‐ Any other useful information for this purpose
Proponent Response: See attached revised monitoring plan. The inventory was conductedaccording to the techniques described in the monitoring plan.
Auditor Response: A revised monitoring plan was submitted. Review of the monitoring plan
showed that it provided all requested details of project monitoring protocols. Afterobservation of plots installed in the project area, some additional details were requested in
NIR 2011.44. The Proponent’s response adequately addresses the finding in accordancewith The VCS 2007.1 Protocol and selected methodology.
NIR Number 2011.14 of 50 dated 1/11/2011
Standard Reference: CP‐AB Section III p12
Document Reference: Appendix A, p34
Finding: The methodology requires that allometric equations be validated. Please provide
evidence of validation of allometric equations according to the procedure given on pages
12‐14 of CP‐AB.
Proponent Response: The allometric equations were validated for Belize by Brown et. al.
2005. A copy of the paper has been attached
Auditor Response: The document provided by the Proponent described validation of theequations in a different forest type in Belize. The methodology requires direct site specificvalidation of allometric equations. NIR2011.38 was issued in response. After NIR2011.38
was closed, The Proponent’s response adequately addressed the finding in accordance withThe VCS 2007.1 Protocol and selected methodology.
NCR Number 2011.15 of 50 dated 1/11/2011
Standard Reference: X‐UNC p2
Document Reference: BCEP Carbon PDD ver 2.doc Sec 4.2 p20
Finding: The methodology allows indisputably conservative estimates to be used instead of
uncertainties, provided they are based on verifiable literature sources or expert judgement.
The analysis of deforestation rate based on proxy areas is based on a sample of datacollected and analyszed by the project proponent, rather than a verifiable literature sourceor expert judgement, so uncertainty analysis is required. Please provide such analysis. The
reference to r2 in ‐UNC
X
page 3 is for unplanned deforestation and is not relevant toassessing planned deforestation. No regression is prescribed by the methodology forpredicting the deforestation rate for planned deforestation.
Proponent Response: This is a revised response:
The rate of conversion is set at 10.8% based on proxy area analysis. The uncertainty
associated with the rate is 7.43%.
The inventory uncertainty was determined to be 24.88%. To calculate total project
uncertainty we used the formula in module X‐UNC on page 8. This results in a total project29

VCS 2007.1 - Validation Report – Forest Carbon Offsets – Boden Creek
uncertainty of 35.96%.
Proxy area analysis and inventory were provided as attachments for other NIRs.
The other sources of uncertainty are presumed to be 0 based on literature and expert
opinion that the proposed amounts are indisputably conservative. See below for the project
uncertainty calculations.
Auditor Response: The calculation of uncertainty was reviewed by the validation team. The
Proponent’s response adequately addresses the finding in accordance with The VCS 2007.1
Protocol and selected methodology.
NIR Number 2011.17 of 50 dated 1/11/2011
Standard Reference: Voluntary Carbon Standard 2007.1 Section 3.4
Document Reference: NA
Finding: The Standard requires that AFOLU projects identify potential negativeenvironmental and socio‐economic impacts and take steps to mitigate them prior to
generating VCUs. Please provide documentation of any potential negative impacts and thesteps taken to mitigate those impacts.
Proponent Response: The Project does not anticipate any negative biodiversity impacts
within the area surrounding the Project. Offsite impacts will be positive since larger habitat
and forest areas will improve the long‐term viability of fauna and flora populations offsite.
Avoiding conversion to agriculture also avoids release of sediment and agricultural chemicals
into waterways and the Port Honduras Marine Sanctuary. If any negative impact is
identified, the BCEP team and the community representative will address such problems
with fast and effective solutions. The issue will be discussed and mitigation actions will be
designed.
The Project is not expected to have negative social impacts on the communities surrounding
the Project area. It is not expected that the Project will negatively impact any of offsitecommunities. In the case of any potential negative impacts, representatives of the impacted
community will bring it to the attention of the conflict resolution coordinator. No
unmitigated social or economic impacts are expected from the Project.
According to personal interviews and official correspondence, Indian Creek Village has nevertraditionally used the BCEP property for hunting, medicinal plant collecting, or otheractivities. All hunting has traditional occurred west and north of the village (Toledo Maya
Cultural Council 1997).
According to personal interviews and official correspondence, Golden Stream Village has
never used the BCEP property for hunting, medicinal plant collecting, or other activities(Toledo Maya Cultural Council 1997).
The Pine Hill Mennonite Community, a Kleine Gemeinde Mennonite community, is reclusive
and interacts minimally with others from outside their community. They have no record ofusing the BCEP property for hunting or other activities. Currently, they receive from BCEP
road access to their property through BCEP property.
Project has been awarded Gold Level certification by the Climate, Community, andBiodiversity Alliance.
Auditor Response: The supplied analysis is appropriate, and is consistent with the analysis
validated against the CCB standards in 2010. The Proponent’s response adequately
addresses the finding in accordance with The VCS 2007.1 Protocol and selected
methodology.

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VCS 2007.1 - Validation Report – Forest Carbon Offsets – Boden Creek
NIR Number 2011.18 of 50 dated 1/11/2011
Standard Reference: VCS 2007.1 Section 5.7 p 15
Document Reference: BCEP Carbon PDD ver 2.doc Sec 8.1
Finding: Please provide copies of the proof of title documentation described in section 8.1 of
the PD.
Proponent Response: See attached copies of title documents.
Auditor Response: Adequate evidence of title was provided by the project proponent. The
Proponent’s response adequately addresses the finding in accordance with The VCS 2007.1
Protocol and selected methodology.

NIR Number 2011.19 of 50 dated 1/11/2011
Standard Reference: ACS AFOLU Program Update 8 Sep 2010
Document Reference: BCEP Carbon PDD ver 2.doc Sec 8.1
Finding: The VCS program update from 8 September 2010 requires‐practice
best fire
prevention measures to justify a low risk rating for REDD projects. Please provide a
description of fire prevention measures for the project area.
Proponent Response: This ecosystem is a wet tropical system with a range of 90 mm/monthin the dry season to 750 mm/month in the wet season. Fires in this system are rare events. A
superb discussion of fire (Meerman and Sabido 2001) in Belize may be viewed at
http://biological‐diversity.info/fire.htm
Note that the project area is in the lowest fire risk category.
The best practices for fire prevention in Belize are primarily excluding humans from theproperty through patrols as is proposed in the project plan.
Auditor Response: Consultation with the local technical expert hired by the audit teamconfirmed that, in these forest types, fires are primarily anthropogenic in origin and that few
fire prevention measures are required. The Proponent’s response adequately addresses thefinding in accordance with The VCS 2007.1 Protocol and selected methodology.
NIR Number 2011.20 of 50 dated 1/11/2011
Standard Reference: REDD Methodological Module BL‐PL, Sec. 1.1
Document Reference: NA
Finding: The Module requires that the agent of planned deforestation be identified.
However, the identity of the agent of deforestation is not clear upon reading the
proponent's PDD. Please clearly identify the agent of planned deforestation.
Proponent Response: The agent of deforestation is the previous landowner Mr. Harold O.
Whitney. He was in the process of converting the property when the current landowner, Mr.
Ken Karas purchased the property. See Bowen‐Jones 2001 for a land use history.
Auditor Response: The project proponent has identified a specific agent of deforestation.
However, no specific evidence of Mr. Whitney’s intent to personally convert the area toagriculture was available. Though there was evidence that Mr. Whitney had previously
converted portions of the property, interviews with the current landowner showed that Mr.
Whitney was actively attempting to sell the property, and that he had received at least one
other serious offer to purchase the property apart from that of the current landowner.
Consequently, the audit team determined that it was not appropriate to identify Mr.
Whitney as the specific agent of deforestation, as implementation of the project prevented

31

VCS 2007.1 - Validation Report – Forest Carbon Offsets – Boden Creek
deforestation by alternate purchasers as well as by Mr. Whitney. NIR 2011.38 was issued in
response. Subsequently, an analysis of a class of deforestation agents was undertaken, as
described by the methodology. After resolution of NIR 2011.38, the Proponent’s response
adequately addressed the finding in accordance with The VCS 2007.1 Protocol and selected
methodology.
NIR Number 2011.21 of 50 dated 1/11/2011
Standard Reference: Voluntary Carbon Standard Tool VT0001, Sec. 2.2.1
Document Reference: BCEP Carbon PDD ver 2.doc, Sec. 2.4
Finding: The Tool requires that any identified alternative land uses be realistic and credible,
and that for all land uses that are not currently occuring or have not occurred within thepast 10 years, credibility shall be justified.
Sufficient information has not been provided for the assessor to determine whether the"Conversion of Forest Land to Settlements" land use is credible. While information has been
provided about population increase in the Toledo District, this increase will not necessarily
result in development pressure for the project area.
Likewise, credibility has not been demonstrated for the "Logging of Timber for Local andDomestic Use" land use, given that illegal logging was also identified as a potential land use
and that the project proponent has stated that no timber of merchantable size remains after
the recent hurricane. If this land use would be illegal in the baseline scenario, this should be
explicitly stated and the appropriate guidance in the Tool shall be implemented. If this land
use would be legal, please explain the mechanisms by which this land use would be
economically feasible.
Proponent Response: PDD has been revised to remove the two offending alternatives.
Auditor Response: The Proponent’s response adequately addresses the finding inaccordance with The VCS 2007.1 Protocol and selected methodology.
NIR Number 2011.22 of 50 dated 1/11/2011
Standard Reference: Voluntary Carbon Standard Tool VT0001, Sec. 2.2.2
Document Reference: BCEP Carbon PDD ver 2.doc, Sec. 2.4
Finding: The Tool requires that, where a land‐use alternative does not comply with all
mandatory applicable legislation, the proponent demonstrate that "applicable mandatory
legal or regulatory requirements are systematically not enforced and that non‐compliancewith those requirements is widespread, i.e., prevalent on at least 30% of the area of thesmallest administrative unit that encompasses the project area." Demonstrate that this is
the case, specifically that illegal logging occurs on at least 30% of the area of the smallest
administrative unit that encompasses the project area.
Proponent Response: The illegal logging scenario has been removed from the PDD.
Auditor Response: The Proponent’s response adequately addresses the finding inaccordance with The VCS 2007.1 Protocol and selected methodology.
NIR Number 2011.23 of 50 dated 1/11/2011
Standard Reference: Voluntary Carbon Standard Tool VT0001, Sec. 2.3.1
Document Reference: BCEP Carbon PDD ver 2.doc, Sec. 2.4
Finding: The Tool requires that, if the VCS AFOLU project generates no financial or economic
benefits other than VCS related income, either investment comparison analysis or thebenchmark analysis must be used. Regardless of whether or not eco‐tourism activities have

32

VCS 2007.1 - Validation Report – Forest Carbon Offsets – Boden Creek
turned a profit, they have generated revenue. Therefore, one of the two previously
mentioned analysis methods must be used to determine the most financially attractive landuse.
Proponent Response: The ecotourism operation is a separate entity. No financial resources
are planned for transfer from the ecotourism operation to the carbon project. At present theecotourism operation is negative. No income is expected from the carbon project. Simple
financial analysis would indicate that without the carbon income the financial situation will
be negative. The baseline scenario of agriculture and particular citrus is considered positivesince a. it was underway at the time of the purchase of the project (see Bowen‐Jones 2001)
and the citrus industry is a healthy part of the Belizean economy (Tzul 2010). Therefore atleast one of the baseline scenarios is more profitable than the project scenario excluding thecarbon project income.
Financial plans for both the ecotourism operation and the carbon project will be madeavailable to the auditors.
Auditor Response: The validation team determined that, even though the ecotourism
operation is not financially linked to the carbon project, protection of the forest throughcarbon finance generates financial benefits for the ecotourism operation, and therefore thefinancial analysis required by the standard was still required. NCR 2011.35 was issued in
response. After resolution of NCR 2011.35, the Proponent’s response adequately addressed
the finding in accordance with The VCS 2007.1 Protocol and selected methodology.
NIR Number 2011.24 of 50 dated 1/11/2011
Standard Reference:NA
Document Reference: BCEP Carbon PDD ver 2.doc
Finding: Please provide more information regarding the deed restriction to be implemented
as part of the project activity. Address what sort of activities will be prohibited by thisrestriction and how the restriction will contribute to the project's goals.
Proponent Response: The deed restriction is envisioned as a commitment by the landowneron the title to comply with the project plan over the life of the project. The purpose of thistitle restriction is (in the unlikely event that the land changes hands) to bind any new owners
to compliance with the CCB and VCS project plans e.g. no removal of forest, regularmonitoring, patrols, outreach to the local communities, etc…
Auditor Response: After discussions during the site visit, it was determined that no deed
restriction currently exists on the property. No restriction is required by the standard, andthe envisioned, but not yet implemented restriction was not considered in assessing the
project’s risk of reversal. The Proponent’s response adequately addresses the finding inaccordance with The VCS 2007.1 Protocol and selected methodology.
NIR Number 2011.25 of 50 dated 1/11/2011
Standard Reference:NA
Document Reference: BCEP Carbon PDD ver 2.doc, Sec. 9.1
Finding: Provide more information regarding the "legal easement" mentioned at the bottomof p 29.
Proponent Response: The deed restriction is envisioned as a commitment by the landowneron the title to comply with the project plan over the life of the project. The purpose of thistitle restriction is (in the unlikely event that the land changes hands) to bind any new owners
to compliance with the CCB and VCS project plans e.g. no removal of forest, regularmonitoring, patrols, outreach to the local communities, etc…

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VCS 2007.1 - Validation Report – Forest Carbon Offsets – Boden Creek
Auditor Response: After discussions during the site visit, it was determined that no legal
easement currently exists on the property. No easement is required by the standard, andthe envisioned, but not yet implemented easement was not considered in assessing the
project’s risk of reversal. The Proponent’s response adequately addresses the finding inaccordance with The VCS 2007.1 Protocol and selected methodology.
NIR Number 2011.26 of 50 dated 1/11/2011
Standard Reference: Voluntary Carbon Standard Tool for AFOLU Non‐Permanence Risk
Analysis and Buffer Determination
Document Reference: BCEP Carbon PDD ver 2.doc, Sec. 9.1
Finding: One risk factor required to be addressed by the Tool, for REDD projects, is:"population surrounding the project area." The proponent has provided information
regarding the population inside the boundaries of the project area, which is not germane tothis risk factor. Please provide information regarding the population surrounding the project
area, and re‐evaluate the risk factor if necessary.
Proponent Response:
The following is added to the PDD:
Population Surrounding the Project Area
The population density in the surrounding area is very low. It is < 50 people / km2. The
Project’s boundaries are defined by the 931 ha Pine Hill Mennonite Community, the7,516 ha Seven Hills Estate, the 2,192 ha Manatee Creek Parcel, the 3,866 ha Golden
Stream Parcel, and Indian Creek Village for a total of 14,505 ha. There are threecommunities located in the Project Zone. The communities are Indian Creek Village,
Golden Stream Village, and Pine Hill Mennonite Community. The population of threecommunities is roughly 1,250 individual (Table 1: Population surrounding the Project
area 2008 midyear population estimates). Population density is roughly 8.6 individuals
per km2. Population density in the surrounding area is very low risk.
Table 1: Population surrounding the Project area 2008 midyear population estimates[This table was not able to be added, please see the Proponent Response.]
Auditor Response: The population densities described here are consistent with thoseobserved by the validation team during the site visit. The Proponent’s response adequately
addresses the finding in accordance with The VCS 2007.1 Protocol and selected
methodology.
NIR Number 2011.27 of 50 dated 1/11/2011
Standard Reference: VCS 2007.1 Section 5.5
Document Reference: BCEP Carbon PDD ver 2.doc, Sec. 4.2
Finding: Please provide justification for the assumed growth rate of 6.3% per year.
Proponent Response: A copy of the document is attached.
Auditor Response: The project uses an assumed growth rate from a similar forest in Mexico.
No literature was available for tropical forests in Belize recovering from hurricane
disturbances. The validation team found the literature reference to be appropriate, butnotes that application of this study in Belize is likely to result in high uncertainty in ex-anteestimates of forest growth rates. The Proponent’s response adequately addresses thefinding in accordance with The VCS 2007.1 Protocol and selected methodology.

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VCS 2007.1 - Validation Report – Forest Carbon Offsets – Boden Creek
NIR Number 2011.28 of 50 dated 1/11/2011
Standard Reference: NA
Document Reference: NA
Finding: Please clarify the role of the existing inventory used to determine the 2009 starting
point of 54.06 tons C/ha, as compared to the planned inventory for VCS validation.
Proponent Response: The starting point of 54.06 tons C/ha is calculated from the plot data.
The monitoring plan calls for re-measurement of each tagged tree on each plot at eachmonitoring event which will provide an opportunity to confirm the growth rate assumption
as well as detecting unplanned reversals. The 2009 data is the only data proposed forvalidation and will be made available upon request.
Re-measurement of the plots in January of 2011 will be conducted to support theverification of vintage years 2009 and 2010.
Auditor Response: Initial communications with the Project Proponent indicated that
additional inventory work was to be conducted after the beginning on the audit. This finding
was issued to clarify which data should be assessed during the validation audit. The initiallyprovided data was assessed with a check cruise during the site visit. The results of thatcheck led to issuance of NCR 2011.48, which was resolved by re-measurement of inventorydata. The data validated in this report were measured in 2011. The Proponent’s response
adequately addresses the finding in accordance with The VCS 2007.1 Protocol and selected
methodology.
NCR Number 2011.29 of 50 dated 1/19/2011
Standard Reference: CP‐AB, Sec. 2, Part 1
Document Reference: PDD Appendix A, p6
Finding: The Module requires that “representative random or systematic” sampling be
employed in locating sample plots. Five sample plots (plots 6, 11, 15, 21, and 22) werelocated based on their proximity to a passable trail, rather than randomly. The resulting
sample does not constitute a valid basis with which to estimate carbon stocks in the BCEP in
accordance with the Module, as certain portions of the project area were systematicallyomitted from sampling by moving the plots that fell in those areas.
Proponent Response: The sample size required to achieve the desired precision andconfidence is 20 forest inventory plots. However, to ensure that the full range of variability
was captured in the ‘Forest Land’ – the Lowland Broad Leafed Wet Forest ‐ class on the
project site, a total of 26 forest inventory plots were allocated. Plots were randomly
allocated within the ‘Forest Land’ land‐use and land cover (LULC) class using geographic
information systems (GIS) and identified by specific XY coordinates (Table 10: UTM locationsof forestry plots used to determine aboveground biomass (coordinates are in WGS 84 zone16) and Figure 2: Location of forest sample plots at BCEP). However, due to high rainfall
events during the field season 5 plots were inaccessible due to flooding. These plots were: 6,11, 15 (originally allocated approximately south of current locations), 21, and 22 (originallyallocated north east of the current locations). FCO allocated these inaccessible plots using a
passable trail as a transect and randomly choosing 5 points along the trail, then randomly
choosing an azimuth and distance (between 50 and 750 m from the trail) to locate the plot.
Plot ID was randomly assigned to each location.
Since 20 plots are required and 21 plots were randomly allocated, the sample is valid. The
additional plots may or may not be biased. By randomly assigning distances and azimuths
from the trail, the possibility of bias is lessened. The standard also allows for systematic
sampling so the door is open for other procedures of assigning plot location rather thanstrict random assignment.

35

VCS 2007.1 - Validation Report – Forest Carbon Offsets – Boden Creek
Auditor Response: The location 20 out of 26 plots in a random way does not eliminate therisk of bias introduced from locating the other 5 plots in a way that is not representative of
the entire project area. The validation team notes that the use of sample size estimation
equations to determine the sample size required to attain a given precision level isapproximate, and depends on the accuracy of available data regarding variability within theforest prior to the sample. As reflected in the results of the uncertainty calculations
required by the methodology, 20 plots were not sufficient to attain the initially desired
precision. The validation team also noted that the number of initial plot locations that were
excluded from sampling was high in comparison to the total number of plots sampled (5/26= 19%). Because of the continued possibility for bias by excluding these areas from sample,
NCR2011.30 was issued. After NCR2011.30 was resolved, the Proponent’s response
adequately addressed the finding in accordance with The VCS 2007.1 Protocol and selected
methodology.
NCR Number 2011.30 of 50 dated 1/21/2011
Standard Reference: CP‐AB, Sec. 2, Part 2
Document Reference: PDD Appendix A, p7; Response to NCR 2011.29
Finding: This NCR is in response to NCR 2011.29. The Module requires that “representative
random or systematic” sampling be employed in locating sample plots. Regardless of thenumber of plots for which the original location was maintained, the method for locating
sample plots was not representative of the entire project area. Even if the plots which weremoved are not considered, the sample is not representative of the project area, as the areasthat were flooded at the time of the previous field season had a zero percent chance ofbeing included in the sample. The remaining plots would only be representative of thenon‐flooded portion of the project area. Five out of 26 plots (19%) fell in areas that were
excluded from sampling, suggesting that the unsampled area represents a substantial
portion of the total project area. A representative sample must be used to estimate carbon
stocks in the entire project area.
Proponent Response: See revised response in NCR 29. The five plots that were moved forsafety issues will be measured and added to the inventory and new statistics including theadditional 5 plots will be included.
Auditor Response: The initial locations of the 5 initially excluded plots were measured by
the project proponent. The Proponent’s response adequately addresses the finding inaccordance with The VCS 2007.1 Protocol and selected methodology.

NCR Number 2011.31 of 50 dated 1/21/2011
Standard Reference: BL‐PL 1.2
Document Reference: Response to NIR10
Finding: The Tzul report adequately establishes access to markets. However, theBowen‐Jones report does not discuss soil suitability. Rather, it states that the land wasowned from the 1980s until 1998 by a logger from north America who “extended theclearance of land near the road (for citrus and banana) whilst using it as a base for his
logging operations throughout the Golden Stream watershed.” This does not constitute“documentary proof” of suitability of soils for agriculture. Please provide additional
information supporting the suitability of soils for agriculture.
Proponent Response: Soils in the project area are as described (in our BCEP CCB PDD):“Soils throughout the Project Area are derived rfom mudstones, sandstones limestone36

VCS 2007.1 - Validation Report – Forest Carbon Offsets – Boden Creek
deposits. Soils are moderately shallow clays that are fairly well drained (Baillie 1993). The
soils are underlain by flat-bedded mudstones with some minor sandstones and limestones.
Most soils are clay and well-drained while calcium and magnesium are present. The soils aremoderately acidic (Ballie 1992).”
According to:
1. http://www.greenstone.org/greenstone3/nzdl;jsessionnid=08426020AFACE171F78
81ES4797F22BF?a=d&c=hdl&d=HASHaa250f8d90a80dea58551b&dt=hierarchy&p.a=b&p.s=ClassifierBrowse
2. http://www.agnet.org/library/bc/52004/
Citrus soils need:
1. To be moderately acidic (yes)
2. Well‐drained (yes)3. Without a deficiency of calcium and magnesium.
In other words, the soils on the Project site are sufficient according to Baillie and others for
citrus growing.
Auditor Response: Adequate evidence of soil suitability was provided. The Proponent’s
response adequately addresses the finding in accordance with The VCS 2007.1 Protocol andselected methodology.

NCR Number 2011.32 of 50 dated 1/25/2011
Standard Reference: X‐UNC
Document Reference: Response to NIR 16
Finding: Equation 5 of the Module X‐UNC requires that the uncertainty in each carbon poolbe calculated. The different pools are listed in REDD
‐MF, Table 1. Uncertainty for a given
pool can be assigned as 0 if it can be shown that carbon estimates in that pool are
indisputably conservative. The proponent has stated that "The with‐project carbon stocks
estimate does not include soils or litter. Again based on expert opinion, we are claiming thatthese estimates are indisputably conservative."
The fact that proponents have decided not to monitor carbon in the "soil organic carbon" or"litter" pools does not affect the uncertainty in the "above‐ and below‐ground biomass inlive trees" pool. The proponent's estimate of biomass in live trees is based upon sampling
and therefore has its own sampling error. It is not indisputably conservative. Therefore, theuncertainty in this estimate must be computed and incorporated into all applicable
equations.
Proponent Response: Uncertainty for the above ground and belowground live biomass has
been calculated and found to be 23.48% Since exclusion of the other pools is considered
undeniably conservative, their uncertainty is calculated at 0% leaving the uncertainty for theabove and below ground biomass at 23.48%. Without project biomass uncertainty is still
considered to be undeniably conservative and is considered 0%.
Appropriate changes have been made in the PDD.
Auditor Response: Appropriate calculations were made to estimate uncertainty due tosampling error. These calculations were checked by the validation team. The Proponent’s
response adequately addresses the finding in accordance with The VCS 2007.1 Protocol andselected methodology.

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VCS 2007.1 - Validation Report – Forest Carbon Offsets – Boden Creek
NCR Number 2011.33 of 50 dated 1/25/2011
Standard Reference: X‐UNC Sec. 2, p3
Document Reference: Response to NCR 15
Finding: The proponents have calculated the uncertainty associated with the proxy area
analysis using the width of the 95% confidence interval derived from the estimateddeforestation rate in the individual proxy areas. The methodology requires this uncertainty
to be expressed as a percentage of the mean deforestation rate observed across all proxyareas.
Proponent Response: A new proxy area analysis was performed to satisfy concerns that thefirst attempt did not capture deforested properties that were of a similar size to the project
area. Jpegs and metadata summaries are attached. The results are as follows:[This table was not able to be added, please see the Proponent Response.]
Auditor Response: The new deforestation proxy rate analysis appropriately estimateduncertainty in conformance with the methodology. The Proponent’s response adequately
addresses the finding in accordance with The VCS 2007.1 Protocol and selected
methodology.
NCR Number 2011.31 of 50 dated 1/31/2011

Standard Reference: BL‐PL 1.2
Document Reference: Response to NIR10
Finding: The Tzul report adequately establishes access to markets. However, the Bowen‐Jones report does nountil 1998 by a logger from north America who “extended the clearance of land near the road (for citrus andStream watershed.” This does not constitute “documentary proof” of suitability of soils for agriculture. Please pro
Proponent Response:
Soils in the Project area are described as (in our BCEP CCB PDD):"Soils throughout the Project Area are derived from mudstones, sandstones limestone deposits. Soils are modera
by flat‐bedded mudstones with some minor sandstones and limestones. Most soils are clay and well‐drained1993)."
According to:
1.http://www.greenstone.org/greenstone3/nzdl;jsessionid=08426020AFACE171F7881E54797F22BF?a=d&c=hdl&
2. http://www.agnet.org/library/bc/52004/
Citrus soils need:1.
To be moderately acidic (yes)2.
Well‐drained (yes)3.
Without a deficiency of calcium and magnesium.
In other words, the soils on the Project site are sufficient according to Baillie and others for citrus growing.

Auditor Response: equate evidence of soil suitability was provided. The Proponent’s response adequately amethodology.

NCR Number 2011.34 of 50 dated 1/31/2011
Standard Reference: REDD‐MF, E‐BB
Document Reference: Response to NIR1, Response to NIR 7
Finding: Module E‐BB is mandatory according to REDD‐MF Table 1, page 4. Even if fire isunlikely in the area and no biomass burning is planned as part of project activities, emissions

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VCS 2007.1 - Validation Report – Forest Carbon Offsets – Boden Creek
from CH4 and N2O must be included in the project in the event that a fire occurs, andaccounted for using the E‐BB module as described on page 1 of E‐BB.
Proponent Response: NIR language is:
The table in the PDD that displays the proposed credits by vintage will be updated toaccount for CH4 and NO2 emissions from biomass burning, and a separate column will be
added to explicitly state the contribution of CH4 and NO2. Once the new data arrives next
week we will add the new column to the new version of the spreadsheet and forward it to
you to review.
A line in the PDD will be added:
In the event of ex‐post fires occurring, the REDD Methodological Module: Estimation ofgreenhouse gas emissions from biomass burning (E‐BB) Sectoral Scope 14 will be applied.
Auditor Response: The Proponent’s response adequately addresses the finding inaccordance with The VCS 2007.1 Protocol and selected methodology.
NCR Number 2011.35 of 50 dated 1/31/2011
Standard Reference: Voluntary Carbon Standard Tool VT0001, Sec. 2.3.1
Document Reference: BCEP Carbon PDD ver 2.doc, Sec. 2.4; Response to NIR 23
Finding: The project activity (protection of the BCEP property from conversion toagriculture) generates financial benefits other than VCS related income. Regardless ofwhether the carbon project and the ecotourism business are interlinked financially,
protection of the property as native forest allows ecotourism enterprises to operate in amanner that could not continue if the BCEP property were converted to agriculture. It isapparent that this activity will generate financial benefits, regardless of the identity of thebeneficiary. Therefore, either investment comparison analysis or benchmark analysis, as
defined in the Tool, must be used to conduct the investment analysis.
Proponent Response: The standard says in T‐ADD 2.3 Determine whether the proposed
project activity, without the revenue from the sale of GHG credits is economically or
financially less attractive than at least one of the other land use scenarios. Our definition ofproject activities is anything we plan to do that has a direct or indirect impact on the carbon
pools of the project. Our project activities for the VCS project are pretty clearly defined in
the PDD, and they don’t include the ecotourism activities. We’ve already said the ecotourism
activities won’t generate income for BCEP. The ecotourism operation is operating at a loss
right now. See attached very confidential revenue and expense spreadsheet and budget for
project.
The landowner has four lodges. Three are not in the project area, Indian Creek, Jungle
Lodge, and Mojo Key. The other one is on the edge of the project area (Balum Na). The big
attraction at Balum Na is the jaguar enclosure. Since three of the lodges are not in the
project area, clearly BLE does not need the BCEP forest to run lodges. In fact, there are
multiple nearby areas where BLE takes it guests to walk in much bigger jungle, as advertisedon the BLE website. Furthermore, BLE does just that by taking them for hiking and cave
exploration elsewhere in the Toledo District. Eco‐tourism lodges in Belize do not usually
have their own adjacent forested property and instead the business model in Belize is totake eco‐tourism lodge guests to visit Belize’s significant protected public lands.
Auditor Response: The project proponent provided confidential financial records thatshowed the the requirements for demonstration of financial additionality had been met.
The Proponent’s response adequately addresses the finding in accordance with The VCS
2007.1 Protocol and selected methodology.

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VCS 2007.1 - Validation Report – Forest Carbon Offsets – Boden Creek
NIR Number 2011.36 of 50 dated 1/31/2011
Standard Reference: BL‐PL 2.2
Document Reference: Response to NIR12
Finding: The citrus carbon stock referenced in the FAO “Belize: facing the climate change”
document is not based on measured data. Rather, the authors made generic assumptions inorder to estimate the carbon sequestration potential for the country as a whole. Relevant
text from the document is below:"There is no data on carbon sequestered in the various types of agricultural operations in
the country, and therefore in the analysis of the baseline values a generic rate of 10 tons ofcarbon per hectare of pastureland is used, while a higher figure of 20 tons of carbon perhectare is assigned to cultivated fields such as those producing annual crops like rice andcorn. In higher yielding citrus plantations is assigned a value of 25 tons of carbon perhectare."Based on this report, it is not clear whether the assumed carbon stock includes both aboveand belowground biomass, or only aboveground biomass. Further, the conservativeness orquantitative basis of the assumption is not discussed. The assumption that growth occurs
immediately is part of the methodology(BL‐PL, page 8‐9, “where stocks accumulate throughtime the ultimate (highest) stock shall be used”), and not part of the justification for theconservativeness of the stock; this assumption is made by the methodology regardless of thesource of data used to estimate the final carbon stock. A review of scientific literature by theaudit team suggests that 25 tons/ha is a plausible carbon stock for a citrus plantation, butalso that higher stocks are consistent with the literature as well. Insufficient evidence has
been provided to demonstrate that the estimate of 25 tons/ha is indisputably conservative
and thus has no associated uncertainty.
Proponent Response: Total GHG emissions from citrus include agronomic practices,transportation, storage, etc… per Spreen et.al. (2010) and Dasberg (1987). At present, weare conservatively excluding those additional emissions which can be substantial (123 tons
C/ha‐year according to Spreen, et al 2010). Feigenbaum (1987) reports the greatest weight
for an individual tree at 319.7 kg/tree dry matter. This study only measured two trees that
had been a part of a long term fertilization study and based on a more recent summary by
Morgan et al (2006), this number appears to be an outlier. A far better reference in ourestimation is Morgan et al 2006 that summarizes studies with much larger sample sizes.
They found an average of 94 kg/tree for mature trees. Based on the best available literature,
we feel an undeniably conservative estimate is 50% above the average found in Morgan et al2006 or 141 kg/tree dry weight. Converting that weight to tons C/ha requires a presumptionof tree density which is provided in Spreen et. al. (2010) as 107 trees/acre at year 20. That
estimate then works out to 37 tons C/ha.
As you note, the methodology says “where stocks accumulate through time the ultimate(highest) stock shall be used”. Just because this is a requirement of the methodology it does
not follow that it is not conservative. Indeed it is conservative, and being a requirement
doesn’t make it less so. So we contend that the 37 tons C/ha figure is undeniably
conservative because it is 50% higher than the best available information from the literatureand it ignores the obvious growth pattern that any cultivated orchard would undergo. We
also have no intention of including diesel use, pesticide use, and other baseline emissions
that according to Spreen et. al. (2010) can also be substantial.
Based on our further review of the situation triggered by your question, we note a majoromission in our model, the avoided emissions from nitrogen fertilizer use. The lowest rate
recommended by the Belize Citrus Growers Association is 2.2 lbs of fertilizer(19‐9‐19)/tree‐year. Running that number through the CDM tool for fertilizer impacts results
in a mtCO2e figure of 46.75 mtCO2e/hectare‐year avoided emissions. We will adjust our

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VCS 2007.1 - Validation Report – Forest Carbon Offsets – Boden Creek
model and provide a new version asap once the new data from the additional plots isincorporated.
Auditor Response: New estimates of citrus carbon stocks were made based on a review ofadditional literature. The estimates were shown to be indisputably conservative in nature.
The Proponent’s response adequately addresses the finding in accordance with The VCS
2007.1 Protocol and selected methodology.
NIR Number 2011.37 of 50 dated 1/31/2011
Standard Reference: VM0007
Document Reference: NA
Finding: Please clearly indicate the selected value and source for each of the parameters
used by the methodology, but not monitored by the project (for example, in the CP‐AB
module, the carbon fraction, allometric equation, and root to shoot ratio selected for eachspecies or species group).
Proponent Response: See attached list of variables.
Auditor Response: The variables selected were clearly reported and assessed by thevalidation team. The selected values for project-specific variables are reported in thevalidation report. The Proponent’s response adequately addresses the finding in accordancewith The VCS 2007.1 Protocol and selected methodology.
NIR Number 2011.38A of 50 dated 1/31/2011
Standard Reference: CP‐AB p12
Document Reference: Response to NIR 14
Finding: The methodology requires "direct site‐specific" validation of allometric equations.
Please provide evidence of this validation from the project site.
Proponent Response: Site specific validation is complete. See attached data spreadsheet
and graph below:[ please see the Proponent Response for graph]
Auditor Response: The validation exercise was conducted in conformance with therequirements of the methodology. The Proponent’s response adequately addresses thefinding in accordance with The VCS 2007.1 Protocol and selected methodology.
NIR Number 2011.38B of 50 dated 3/4/2011
Standard Reference: BLPL p 2-3
Document Reference: PDD section 1.7
Finding: It was determined through interviews during the on-site audit that the previous
property owner was actively trying to sell the property prior to its purchase for conservationand carbon project development, and that other interested buyers actively tried to aquire
the land. Consequently, the appropriate agent of deforestation is not limited to theprevious landowner, but also includes other potential purchasers of the property. The
analysis of the agent and area of baseline deforestation, consequently, must assess this"class of deforestation agents" using the criteria of BLPL section II 1.1 and 1.2. Additionally,leakage must be assessed based on this class of deforesting agents.
Proponent Response: This is a revision to this NIR response

While we can speculate as to what the previous landowner might or might not havedone in the absence of an offer of purchase by the current landowner, the fact remains

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VCS 2007.1 - Validation Report – Forest Carbon Offsets – Boden Creek
that the previous landowner was deforesting the property. There is no way to know if
another buyer might have appeared to buy the property at a price that would haveinduced the previous owner to sell to another deforesting agent or if the previous
owner would have continued deforesting the property to this day. Recall the one
buyer that was negotiating with the previous landowner didn’t follow through whichleft the property available for the current landowner. We should also take into
account that hearsay evidence from the current owner doesn’t constitute documentary
evidence. The previous owner could have told the current owner quite a few things toinstigate a higher sale. Getting into a guessing game as to how things might haveturned out differently is beyond the scope of the standard or the audit. Regardless ofwhat might have happened, what did happen was that the current landownerpurchased the property and ended the deforestation activities by the previous owner.
The methodology requires that a class of deforestation agent be identified “if theagent is not yet defined”. In this case, the agent is clearly defined as he was the guy
driving the bulldozer so identifying a different “class of agent” is not appropriate or
arguably even allowed within the methodology.
Despite all this, in the interests of moving the audit along, we will acquiesce to the supposition that
another landowner could have appeared on the scene and could have bought the property anddeforested it. Since that landowner is unknown, a class of deforestation agents will be cited in the PDD
as a the agent of deforestation.
That also triggers a change in the leakage calculation component of the project and the use of module
LK-ASP. The leakage calculation for the with project scenario is incorporated in the model (andreviewable in the spreadsheet model already submitted). The variables for the analysis are:D%planned: This was generated by evaluating proxy areas (10.8%/year)
PFc: This number (64.5%) was determined utilizing available landcover data for Belize and a
description of the procedure is below.
LK: The leakage factor was determined conservatively to be .4 as most of the best lands suitable andavailable for agriculture are already converted leaving less suitable lands for conversion.
C bsl: This variable was determined in module CP-AB
Determining PFc
CMI determined the potential using the 'Belize Ecosystems Shapefile (v.2004c)' and the 'Belize
Protected Areas (Polygon) Dataset (2008)' shapefiles, downloaded from the Biodiversity &Environmental Resource Data System (BERDS) website(http://www.biodiversity.bz/mapping/warehouse/). Analysts performed all process steps in ArcGIS
9.3.
The ‘Belize Ecosystems’ shapefile contains landcover for the entirety of Belize (Table 1.). We
removed areas of forest already under protection using the ‘Erase’ tool in ArcGIS to intersect the‘Ecosystems’ shapefile and the ‘Protected Areas’ shapefile. Acreage was then recalculated for the newpolygons. The next step reclassified the remaining area into ‘Forest’, ‘Agriculture’, or ‘Other’. The
sum of the forest and agriculture polygons gave the total potential area for agriculture. The percent of
this area that is forested was calculated from this total potential area and determined to be 64.5%.

Auditor Response: The audit team and project proponent disagreed with regard to theanalysis of the appropriate agent of deforestation in this case. Ultimately, there is no
definitive documentation of what would have happened in the project area in the absenceof the project. Evidence that the previous landowner had cleared portions of the property
for conversion to agriculture was evident at the project site. However, his intentions for theproperty had it not been acquired by the project proponents were not documented.
Interviews with the current landowner indicated that the previous landowner was actively

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VCS 2007.1 - Validation Report – Forest Carbon Offsets – Boden Creek
trying to sell the property at the time of purchase by the project proponent, and that there
were credible offers made by other parties. The current landowner identified a specificindividual, apart from the previous landowner, who had attempted to acquire the property
at the same time as the acquisition by the project proponent. If the project had not been
implemented (i.e. BCEP had not purchased the land in order to conserve it), it was not clear
whether the land would have been sold to this individual, someone else, or would haveremained under the control of the previous landowner. The technical expert hired by theaudit team indicated that the other individual known to have made a credible attempt toacquire the property is widely known in Belize to have cleared other areas of forest land forconversion to agriculture in recent years. Consequently, the audit team determined thatspecifically attributing baseline deforestation to the prior landowner, and thus accounting
for leakage as zero, was not conservative. The project proponent disagreed with theauditors, but made changes to the project that are in conformance with the standard,
including assessing potential leakage as described in the methodology . The Proponent’s
response adequately addresses the finding in accordance with The VCS 2007.1 Protocol andselected methodology.

NIR Number 2011.39 of 50 dated 3/4/2011
Standard Reference: Tool for AFOLU Methodological Issues p5
Document Reference: PDD p20
Finding: The wood products pool and the fuelwood leakage emissions source have been
excluded from the project as insignificant. It was determined that fuelwood leakagecollection and would be likely to occur in the project area under the baseline scenario
described. Additionally, commercially valuable timber was found within the project area, so
the clearing described by the baseline scenario would be expected to generate wood
products. According to the VCS Tool for AFOLU Methodolgical Issues, the sum of decreases
in carbon pools and increases in GHG emissions that may be neglected must be less than 5%of the total CO2‐eq benefits generated by the project. Please demonstrate that the sum ofthese pools and emissions sources is less than 5% of project carbon benefits or appropriately
account for them in project baseline and monitoring.
Proponent Response: After analyzing the inventory and looking for commercial trees
defined as trees over 25 cm dbh and either identified as a commercial species or not
identified to species, we determined that the total tons biomass/ha attributable to thesepotentially commercial trees (see attached list) are 4.6 tons aboveground biomass/ha.
Conservatively assuming that the entire amount constitutes the mean stock of extracted
biomass (presuming sawn wood as no market exists for pulp and no trees are big enough tobe peeled for veneer) that allows jumping to Step 3 of Option 1.
Carbon stock in wood products pool = 4.6 tons C x (1‐ Wood Waste Fraction at Mill) x (1‐Fraction of wood products emitted in 5 years) * ‐(1Fraction of wood pr oducts emitted in
5‐100 years). The wood waste fraction at the mill is provided in the methodology as .24. The
fraction of wood products emitted in 5 years is provided in the methodology at .2. The
fraction of wood products emitted in 5‐100 years is provided in the methodology at .84.
Result is 4.6 x (1‐0.24) x (1 ‐ 0.2) * (1 ‐ 0.84) = .447 tons / ha. Multiply that times 4792
hectares and times 44/12 gives a result of 7,862 mtCO2e emission avoided as a result of thewood products pool for the life of the project. Our current model for total avoided emissions
over the life of the project exceeds 3 million tons so the total contribution from the wood
products pool is less than 0.26%.
The other de minimis pool is fuel wood collection which was estimated (see NIR 8) at 28,736
mtCO2e which is 0.9% of the estimated total avoided carbon dioxide emissions for the life of43

VCS 2007.1 - Validation Report – Forest Carbon Offsets – Boden Creek
the project.
Both pools in sum are less than 5% and are insignificant. Note that increasing the amount ofbiomass attributable to commercial wood extraction by a factor of 10x still does not result ina significant pool.
Auditor Response: The latest version of project calculations includes detailed calculations ofthese two sources of emissions. The calculations and their underlying assumptions wereassessed by the validation team. Collectively, both pools amount to less than 5% of the total
anticipated carbon benefits of the project, and can thus be excluded from project accounting
under VCS rules. The Proponent’s response adequately addresses the finding in accordancewith The VCS 2007.1 Protocol and selected methodology.
NIR Number 2011.40 of 50 dated 3/4/2011
Standard Reference: Tool for Demonstration and Assessment of Additionality
Document Reference: PDD section 2.4
Finding: Several other privately owned conservation reserves exist in the immediate vicinityof the project area, yet the potential for purchase of the project area for conservation
purposes was not included in the potential baseline scenarios identified in section 2.4 of the
PDD. This potential baseline scenario must be assessed in determining the most likely
baseline scenario using the criteria provided by the methodology and applicable VCS tools.
Proponent Response: The following paragraph is added in section 2.4 as an alternative land
use.
Purchase of the Land as a Conservation Area
There are privately owned protected areas in the area and throughout Belize. Most
landowners, and the landowner at BCEP, that own these properties are members of theBelize Association of Private Protected Areas (BAPPA). Landowners purchase properties forconservation for a variety of reasons. Some establish non-profit companies to hold theproperty and some simply hold onto the property out of a desire to protect the biodiversity
or other values of the site. There is no inherent financial income stream from owning a
private protected area while there are several required expenses. The initial purchase price,annual taxes, maintenance, and protection from trespass are all expenses that can run into
the millions of dollars. Landowners that pursue this strategy are required to be relatively
wealthy or have outside sponsors or pursue a strategy of income generation that is
consistent with conservation such as ecotourism.
Auditor Response: Reasonable justification that purchase of land for use as a conservation
area (without carbon finance) is unlikely in the region was provided. The Proponent’s
response adequately addresses the finding in accordance with The VCS 2007.1 Protocol andselected methodology.
NIR Number 2011.41 of 50 dated 3/4/2011
Standard Reference: CP‐AB p.11‐12
Document Reference: NA
Finding: The CP‐AB module provides a prioritized list of sources for selecting allometricequations (CP‐AB p12). An equation from the lowest priority equation source (Pan‐tropicalforest type‐specific) was chosen. However, equations from sources of higher priority areavailable, including equations that incorporate a species specific wood density parameterand equations from neighboring countries with similar conditions. The project must apply
allometric equations selected in a way that is consistent with the priorities given by themethodology.

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VCS 2007.1 - Validation Report – Forest Carbon Offsets – Boden Creek
Proponent Response: This is an updated response. After speaking with the auditors andreviewing the proposed allometric equations from Chave et. al. 2005, we assigned a newvariable in the inventory for specific gravity for all known trees for which a specific gravity
figure is published. For unidentified species or species that don’t have published specificgravity figure available, we used a weighted average specific gravity for all known species on
the project (.64).
A spreadsheet of all the specific gravity figures and their references is attached. We thenused the wet forest (without Height) equation found on page 93 of Chave et. al. (2005) topredict biomass for each tree and each plot, and develop a mean and confidence interval forthe project. The spreadsheet with these calculations is attached.
Auditor Response: The revised choice of allometric equations is consistent with thosedeemed most applicable for the project area by the technical expert hired by the audit team,and is in conformance with the priority for selecting equations given by the methodology.
The Proponent’s response adequately addresses the finding in accordance with The VCS
2007.1 Protocol and selected methodology.
NIR Number 2011.42 of 50 dated 3/4/2011
Standard Reference: CP‐AB p.11‐12
Document Reference: NA
Finding: CP‐AB requires validation of the applicability of allometric equations using themethods provided on pages CP‐AB 12‐14. Please demonstrate that the equations selected forpalm and cecropia species are applicable to the project area.
Proponent Response: This is a revised response to NIR 42:
The cecropia validation is presumed to be impossible since the height and dbh requirements
have not been met by finding enough individual trees of adequate size in the field. We willremove the cecropia from the calculations and cite another conservative reduction in the
projected biomass.
For the purposes of these calculations, cohune palm should be treated as a “non-tree woody
species”. This is more in line with the biology of the species. If we can acquire the original
data from the Brown et. al. study in Belize
http://www.winrock.org/ecosystems/files/WI_Belize_ClosedForest_M3DADI_Report_2005.pdf
to do the equation validation we’ll include the palms in a a new section entitled “Aboveground non-tree biomass pool” where only the palms will be included. Otherwise we’ll
conservatively omit the palms as well. If that’s the case, we’ll need to plan on doing our own
destructive sampling effort to deal with palms on this and future projects in Belize.
For the purposes of this audit, presume that the palms are conservatively removed from theanalysis.
Auditor Response: Cecropia and palms were conservatively omitted from project biomass
accounting. The Proponent’s response adequately addresses the finding in accordance withThe VCS 2007.1 Protocol and selected methodology.
NIR Number 2011.43 of 50 dated 3/4/2011
Standard Reference: Voluntary Carbon Standard 2007.1, Sec. 5.11; REDD‐MF II step 3
Document Reference: BCEP Carbon PDD ver 2.doc, Appendix A; NIR13
Finding: Please provide a monitoring plan written with sufficient detail to ensure consistent45

VCS 2007.1 - Validation Report – Forest Carbon Offsets – Boden Creek
measurements throughout the lifetime of the project. In addition to the items described in
NIR 13, this plan should include (but is not limited to):‐Measurement techniques for fallen trees with new shoots growing vertically from the fallen
bole‐How the location of the diameter measurement point on each tree was determined‐measurement techniques applied for palms‐how trees were determined to be within the plot (i.e. distance to the face or center of thebole)‐consistent methods for dealing with butt swell or imperfections at the diametermeasurement point
Proponent Response: See attached new copy of PDD with monitoring plan incorporated as
appendix A.
Auditor Response: Additional details regarding the methods for monitoring biomass were
provided and assessed by the validation team. The Proponent’s response adequately
addresses the finding in accordance with The VCS 2007.1 Protocol and selected
methodology.

NIR Number 2011.44 of 50 dated 3/4/2011
Standard Reference: Voluntary Carbon Standard 2007.1, Sec. 5.11
Document Reference: Monitoring Plan
Finding: Field observations demonstrated that some biomass estimation plots were
measured using a methodology that differed from that described in the monitoring plan,that these deviations were not well documented, and that tree tags on these plots appearedinconsistent with both the written plan and the verbal description provided by the project
team. Please provide a detailed written account of the actual procedures used for all plotmeasurements, demonstrate that correct carbon stock calculations were made for theseplots, and provide a plan for ensuring that consistent measurements will be made in future
monitoring events.
Proponent Response: Originally the field methods were to measure all trees > 5cm occurring
within a 14m radius of plot center. After the initial two plots were installed and measured 19
and 16, it was determined that a complete measurement of all trees > 5 cm would require
far more time than planned and budgeted so a revised methodology was implemented thatis described in this manual.
Plot 16 was remeasured during the survey using the revised methods and trees tagged
outside of the plot boundary were not included in the database. Plot 19 was inventoried in
the originally intended manner and the area expansion for that plot reflects the area used in
the original methods. The expansion factor for that plot was 616 meters which is the area of
a 14 meter radius circle making it equivalent to the other plots.
Auditor Response: After issuance of NCR 2011.48, all monitoring plots were re-measured.
Those measurements were checked by a validation cruise. No evidence of methodologicalinconsistencies was found as a result of that validation exercise. The Proponent’s response
adequately addresses the finding in accordance with The VCS 2007.1 Protocol and selected
methodology.
NIR Number 2011.45 of 50 dated 3/4/2011
Standard Reference: REDD‐MF p. 5, M‐MON
Document Reference: Spatial Data Provided, Field observations

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VCS 2007.1 - Validation Report – Forest Carbon Offsets – Boden Creek
Finding: Land in the project area must have qualified as forest for at least 10 years prior to
the project start date. The audit team noted a line cut through the property that was not
excluded from the project area. Additionally, it was not clear where all of the areas cleared
for agriculture by the previous landowner were located, whether they were cleared in theten years prior to the project start date, and whether they were included in the projectboundary. Finally, the Southern Highway has been paved since the land survey provided by
the project team, resulting in clearing of some forest area immediately adjacent to the road.
Please provide a revised delineation of the project area that excludes all ineligible land anddemonstrate that the classification accuracy meets the requirements of‐MON
the M
module.
Proponent Response:(Describe and provide objective evidence)
The revised classification follows. Land in the project area was classified using imagery from1993 and prior and using the BERDS boundary file:[Table excluded to save space]
The Forest class area is the only part of the property included in the project. The BERDS
boundary file results in a slightly larger land area than that recorded on the deeds, so we
reduced the Forest class area to 3,980 hectares. The data used was from an analysis
performed by MDA Federal for 1993. The report is attached detailing classification accuracy(95.8%).
Auditor Response: The validation team reviewed the revised project area and found it to bea conservative estimate of the area of forested land in the project area. The Proponent’s
response adequately addresses the finding in accordance with The VCS 2007.1 Protocol andselected methodology.
NIR Number 2011.46 of 50 dated 3/22/2011
Standard Reference: BLPL p 4
Document Reference: NA
Finding: The BL‐PL module requires that "if government approval is required for
deforestation to occur, the intention to deforest within the project area must be
demonstrated by evidence:o Recent approval from relevant government department (local to national) for conversionof forest to an alternative land use; oro Documentation that a request for approval has be filed with the relevant government
department for permission to deforest and convert to alternative land use;"
The Belize Environmental Impact Assessment (Amendment) Regulations (2007), schedule I,
item (14)(d) and (g) requires an environmental impact assessment for clearing of land over
300 acres.
As a piece of the project area was acquired in 2008, the year following the year in which the
EIA regulations were amended, please provide either (a) a demonstration that the project
meets the requirements of the methodology as outlined above; or (b) a demonstration that
the Environmental Impact Regulations cited above are not applicable to the project.
Proponent Response: Presumably all lands cleared over 300 acres in Belize are subject tothis law. Belize common practice is to ignore the law in its entirety, or common practice is toprovide a waiver from the law since there are no published reports of EIAs being conducted
for agricultural land clearing in Belize (http://www.doe.gov.bz/EIAs.html), and there are no
published reports of EIAs being declined in Belize (http://www.doe.gov.bz/EIAs.html).
Regardless, this law has clearly not been a barrier to clearing land as evidenced by theextensive land clearing that has gone on in the country since 2007. Given the monumental

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VCS 2007.1 - Validation Report – Forest Carbon Offsets – Boden Creek
effortBelizeisundergoingtosupportagriculture(http://www.agriculture.gov.bz/PDF/Policy_Document.pdf) and the national policy
supportingtheexpansionof
agriculture(http://www.embassyofbelize.org/belize‐profile/economy.html)
includingtechnical,
financial, and international development assistance, it is unlikely at best that any restriction
would be placed on land clearing for agriculture if an EIA or study were required. If an EIA or
environmental study were required it would be conducted and approved. For example, theBalam Jungle Estates EIA approved by the Government of Belize on October 26, 2007 would
clear 25,784 acres and commercially log another 44,345 acres, for a total of 70,129 acres ofcleared lowland tropical moist forest, in the same ecozone as BCEP.
Since the agent of deforestation is a “class of deforesting agents”, Belize laws do not requirethat “classes of deforesting agents” apply for an EIA since only a single institution can apply
for an EIA, as demonstrated by Balam Jungle Estates government approved EIA to clear
70,129 acres. So professional judgment would lead us to believe that since there are no
substantive barriers to land clearing by a single institution, even at scales that are 7x times
the scale of BCEP as evidenced by Balam Jungle Estates EIA approval granted by theGovernment of Belize October 26, 2007, it is clear that EIAs are routinely approved for ascale 7x that of BCEP for a single institution and would be approved for “classes ofdeforestation agents”.
Auditor Response: The validation team asked the technical expert hired by the audit teamto assess common practice with regard to environmental impact laws in Belize. He
responded as follows:
It is never common practice to not enforce environmental laws in Belizeeven though it may be common practice to ignore the laws. I think thatthe standards are clear that if government approval is required for
deforestation to occur that it should be obtained. Only if it is common
practice for the government to relax the requirement should it not be
required under the standards, and this is clearly not the case. I would
agree that most EIA's are approved but that is not surprising as the idea
behind an EIA is to ensure that development occurs properly but occurs
none-the-less. It is neither logical nor legally correct to say that because no
EIA's are rejected that one does not need an EIA. The first and second
paragraphs of FCO’s response are therefore irrelevant. I am not entirely
clear with where FCO was going with the third and final paragraph of their
response. It is clear that the class of deforesting agents (those deforestinglands in excess of 300 acres) are required to obtain an EIA, as specified in
the law.
I verified whether EIAs are required for forest clearing in excess of 300
acres and whether any entities have submitted EIAs recently, and I
received positive responses from the Department of the Environment. You
can email them at evirodept@btl.net attn: Mr. Anthony Mai. The
Department recently moved so they do not have phone lines installed asyet. The person I spoke to said that if they came across anyone clearing
forest in excess of 300 acres they would be fined. I asked whether it iscommon practice to allow deforestation in excess of 300 acres without an
EIA and the response was a clear no.
Subsequently, The validation team consulted the VCSA with regards to whether therequirement of demonstration of government approval or filing for approval applied toclasses of deforestation agents. As communicated in an email from Carolyn Ching to thevalidation team dated 11 April 2011, the VCSA ruled that “where the agent of deforestation

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VCS 2007.1 - Validation Report – Forest Carbon Offsets – Boden Creek
is a class of agents it would not be possible to get governmental approval so it would not benecessary [to demonstrate approval].”Consequently, though it appears that an EIA is indeed required for legal conversion of the
project area to nonforest land and none was sought, based on VCS ruling, when the specificagent of deforestation cannot be identified, evidence of government approval or intent toseek government approval is not required. The Proponent’s response adequately addresses
the finding in accordance with The VCS 2007.1 Protocol and selected methodology.

NCR Number 2011.47 of 50 dated 4/11/2011
Standard Reference: A/R Methodological tool "Estimation of direct nitrous oxide emission
from nitrogen fertilization"; LK-ASP Module
Document Reference: BCEP Final Carbon Table.xlsx
Finding: The following errors were identified in the BCEP Final Carbon Table spreadsheet:-The nitrogen content of synthetic fertilizer (parameter SFiNC) was calculated from its N-P-K
rating incorrectly (fertilizer tab, cell B27).
-The ∆CBSL,i parameter in the leakage module equation (7) refers to the parameter calculated
in equation (3) of the BL-PL module. In row 21 of the leakage tab on the excel spreadsheet
provided, the parameter calculated in equation (1) of the BL-PL module is used instead of
the parameter calculated in equation (3) of BL-PL.
-The PFc parameter is specified in cell B5 as 100%, but as 0.645 in row 18 of the project
leakage table. Please use consistent parameter values and provide a justification for theselected parameter.
Please provide an updated version of the carbon calculation spreadsheet with these errors
corrected.
Proponent Response: We stand corrected on the NPK issue. We assumed incorrectly that
19-9-19 was parts not percentages.
The leakage calculation is adjusted.
The reference to the percentage of land remaining for leakage still forested is corrected andmade consistent.
A new version of the spreadsheet and PDD are attached.
Auditor Response: The required corrections were made. An additional error was discoveredin the SFiNC parameter, which resulted in the issuance of NCR 2011.49. That error was
subsequently corrected as well. The Proponent’s response adequately addresses the findingin accordance with The VCS 2007.1 Protocol and selected methodology.
NCR Number 2011.48 of 50 dated 4/11/2011
Standard Reference: VCS 2007.1 7.3.1
Document Reference: Inventory Data
Finding: Based on comparison to data collected by the validations team, the project's carbon
inventory did not meet the accuracy standards of the VCS. The inventory must be correctedprior to issuance of a positive validation opinion.
Proponent Response: See attached new inventory and final version of PDD.
Auditor Response: All plots in the project area were re-measured. The accuracy of therevised inventory was assessed with a validation cruise on May 23 and 24, 2011, in which
seven plots were re-measured. The accuracy of the reported data was found to be within
the requirements of the VCS standard. The Proponent’s response adequately addresses thefinding in accordance with The VCS 2007.1 Protocol and selected methodology.

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VCS 2007.1 - Validation Report – Forest Carbon Offsets – Boden Creek

NCR Number 2011.49 of 50 dated 4/11/2011
Standard Reference: A/R Methodological tool “Estimation of direct nitrous oxide emission
from nitrogen fertilization”
Document Reference: BCEP Final Carbon Table.xlsx
Finding: The parameter SFiNC is expressed as a number of grams in project calculation
worksheets. Correct application of the tool requires the parameter to be expressed as aproportion.
Proponent Response: See attached new inventory and final version of PDD.
Auditor Response: The Proponent’s response adequately addresses the finding inaccordance with The VCS 2007.1 Protocol and selected methodology.
Note: Due to a numbering error by the lead validator, two findings were assigned thenumber 2011.38. There is no missing finding 2011.50.

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