VCS FINAL VALIDATIONREPORTWILDLIFE WORKS KASIGAUCORRIDOR REDD PROJECTPHASE I – RUKINGASANCTUARYREPORT NO. 2011-9036
REVISION NO. 01

DET NORSKE VERITAS

VCS PROJECT VALIDATION REPORT

Date of first issue:

Project No.:

3 February, 2011

PRJC-285203-2011-CCS-USA

Approved by:

Organizational unit:

Miguel Rescalvo
Regional Manager. North Americal

Sustainability and Innovation
Climate Change Services USA

Client:Client ref.:Wildlife Works Inc.

Jeremy Freund

DET NORSKE VERITAS(U.S.A.) INC.
Climate Change &Environmental Services
One Bush Street, 12th Floor
San Francisco, CA 94104
Tel: +1 415-318-3900
Fax: +1 415-318-3901
http://www.dnv.com

Det Norske Veritas (U.S.A.), Inc. (DNV) has performed a validation of the “The Kasigau
Corridor REDD Project Phase I – Rukinga Sanctuary” (hereafter called “the project”) in
Kenya on the basis of Voluntary Carbon Standard 2007.1 (VCS), as well as criteria forconsistent project operations, monitoring and reporting. This validation report summarizes thefindings of the validation.
The validation consisted of the following three phases: i) a desk review of the project design,
the baseline and the monitoring plan, ii) follow-up interviews with project stakeholders andthe issuance of the finding list, and iii) the resolution of outstanding issues and the issuance ofthe final validation report and opinion.
The total emission reductions from the project are estimated to be 4 525 767 tCO2e over the
30-year crediting period (1 January, 2005 to 31 December, 2034). This includes projectemissions, the total confidence deduction, a 20% leakage deduction applied to years 20112034, and the VCS AFOLU buffer deductions currently assessed at 20%. This estimate
assumes the baseline does not change during the baseline reevaluation.
In summary, it is DNV’s opinion that the “The Kasigau Corridor REDD Project Phase I –Rukinga Sanctuary” as described in the VCS Project Document dated 31 January 2011 meetsall relevant VCS 2007.1 requirements and correctly applies the VCS approved methodology
element VM0009 – Methodology for Avoided Mosaic Deforestation of Tropical Forests
Version 1.0.
Report No.:

Date of this revision:Rev. No.

Key words:

2011-9036

3 February, 2011

No. 1

VCS
Project Validation
REDD
Kenya

Report title:

VCS Validation Report – Wildlife Works
Kasigau Corridor REDD Project Phase I –Rukinga Sanctuary
Work carried out by:

Sam Stevenson
Gordon Smith
Work verified by:

Guy Pinjuv

No distribution without permission fromthe Client or responsible organizational
unit
Limited distribution
Unrestricted distribution

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VCS PROJECT VALIDATION REPORT

Abbreviations
AFOLU
Guidelines
CAR
CCBA
CDM
CL
CO2
DNA
DNV
DR
EB
GHG
GPG
LULUCF
GWP
m
MED
MoV
PD
REDD
SCS
tCO2e
VCS
VCSA
VCU
WBCSD
WRI

Agriculture, Forestry and Other Land Uses Section of Guidelines for National
Greenhouse Gas Inventories 2006
Corrective Action Request
Climate Community and Biodiversity Alliance
Clean Development Mechanism
Clarification Request
Carbon Dioxide
Designated National Authority
Det Norske Veritas
Document Review
Executive Board
Greenhouse Gas(es)Intergovernmental Panel on Climate Change’s Good Practice Guidance forLand-Use Land Use Change and Forestry
Global warming potential
Meters
Methodology Element Documentation
Means of Verification
Project Document
Reduced Emissions from Deforestation and Degradation
Scientific Certification Systems
Tonnes CO2 equivalent
Voluntary Carbon Standard
VCS Association
Voluntary Carbon Unit
World Business Council for Sustainable Development
World Resources InstitutePage 1

DET NORSKE VERITAS
Report No: 2011-9036, rev. 01
VCS PROJECT VALIDATION REPORTTABLE OF CONTENTS
1INTRODUCTION .............................................................................................................................................. 3
1.1
1.2
1.3
1.4

2

METHODOLOGY ............................................................................................................................................. 4
2.1
2.2
2.3

3

REVIEW OF DOCUMENTS .............................................................................................................................. 6
FOLLOW-UP INTERVIEWS ............................................................................................................................. 8RESOLUTION OF ANY MATERIAL DISCREPANCY.......................................................................................... 9

VALIDATION FINDINGS................................................................................................................................ 9
3.1
3.2
3.3
3.4
3.5
3.6

4

OBJECTIVE ................................................................................................................................................... 3
SCOPE AND CRITERIA................................................................................................................................... 3
VCS PROJECT DESCRIPTION ........................................................................................................................ 3
LEVEL OF ASSURANCE ................................................................................................................................. 4

PROJECT DESIGN .......................................................................................................................................... 9
BASELINE ................................................................................................................................................... 11
MONITORING PLAN .................................................................................................................................... 18
CALCULATION OF GHG EMISSIONS AND REDUCTIONS .............................................................................. 19
ENVIRONMENTAL IMPACT ......................................................................................................................... 21
COMMENTS BY STAKEHOLDERS ................................................................................................................. 22

VALIDATION CONCLUSION ...................................................................................................................... 23

Appendix A: Validation Protocol
Appendix B: Resolution of Corrective Action and Clarification Requests

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1 INTRODUCTION
Wildlife Works, Inc. (Wildlife Works) has commissioned Det Norske Veritas (U.S.A.),
Inc. (DNV) to validate the “Kasigau Corridor REDD Phase I – Rukinga Sanctuary” in
Kenya. This report provides a description of the steps involved in conducting thevalidation and the findings of the validation based on the Voluntary Carbon Standard
2007.1 (VCS), as well as criteria for consistent project operations, monitoring andreporting.
The validation team consisted of the following personnel:
Role/Qualification
Last NameFirst Name
Project manager
Stevenson
SamuelVCS Validator / VCS
Smith
GordonREDD AFOLU Expert
Technical reviewer
PinjuvGuy

Country
USA
USA
USA

1.1 Objective
The purpose of a validation is to have an independent third party assess the project
design. In particular, the project’s baseline, monitoring plan, and the project’s
compliance with the VCS 2007.1 are validated. This is to ensure that the project design,
as documented, is reasonable and meets the identified criteria. Validation is a requirement
for all VCS projects and is seen as necessary to provide assurance to stakeholders of thequality of the project and its intended generation of emission reductions.

1.2 Scope and Criteria
The validation scope is defined as an independent and objective review of the VCS
Project Description (VCS PD). The VCS PD is reviewed against the criteria stated in the
Voluntary Carbon Standard 2007.1 (VCS), and the approved VCS methodology VM0009
Methodology for Avoided Mosaic Deforestation of Tropical Forests, version 1.0.
The validation is not meant to provide any consulting for the project participants.
However, stated requests for clarifications and/or corrective actions may have provided
input for improvement of the project design.

1.3 VCS Project Description
The “Kasigau Corridor REDD Project Phase I – Rukinga Sanctuary” has been developed
by Wildlife Works Inc., a project proponent based in California, USA. The project is
implemented on land known as the Rukinga Sanctuary, which is wholly owned by the
Rukinga Ranching Co., Ltd. The leasehold on the title will be due for renewal in 2038, at
which point it can be renewed once again for up to 99 years under Kenyan law.
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VCS PROJECT VALIDATION REPORTThe project proponent is Wildlife Works, Inc. and the project developer is Wildlife
Works Carbon LLC. DNV has confirmed that Wildlife Works, Inc. has the right to all
and any reductions generated by the Project during the Project Crediting Period /2/.
The project is 30 169 hectares with an average canopy cover of 39%, with mature treeheights ranging from 5-10 meters (m), and therefore conforms to the latest VCS
definition of “forest” /26/ (see pg 13).
The main project activity is to prevent deforestation caused by subsistence farming
activities. The objective of the project activity is to prevent the conversion of forest to
cropland for annual crops, typically maize that ultimately results in net greenhouse gas(GHG) emissions into the atmosphere. The primary agents of deforestation are thegrowing population of the local Taita and Kamba people living in the Reference Area.
Agricultural clearing in the Reference and Leakage Areas is permanent and cultivation
activities do not shift.
The project start date is 1 January, 2005, which is the date Wildlife Works assumed
financial responsibility for the project area and began specific GHG mitigation activities
within the project area /4/. The selected crediting period is from 1 January, 2005 to 31
December, 2034. The total emission reductions from the project are estimated to be 4 525
767 tCO2e over the 30-year crediting period. This includes project emissions, total
confidence deduction, a 20% ex-ante leakage deduction applied to years 2011-2034 as
per VM0009 and the VCS AFOLU buffer deductions currently assessed at 20%. Thisestimate assumes the baseline does not change during the baseline re-evaluation.

1.4 Level of Assurance
DNV provides reasonable assurance that the emission reduction estimations for the“Kasigau Corridor REDD Project Phase I – Rukinga Sanctuary Project” are conservativeand meet the VCS criteria and approved methodology, VM0009.
Estimating a leakage rate at the project outset is highly uncertain. Wildlife Works has
determined an ex-ante leakage rate for the project crediting period at 20% and it is ourassessment given a lack of past project data that this is appropriate given the conditionsof the project and find the assessment to conform to the requirements in the approved
methodology VM0009.
To ensure complete transparency, DNV has included any clarification or corrective
actions that were raised in this validation report in Appendix A.

2 METHODOLOGY
The validation consisted of the following three phases:
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VCS PROJECT VALIDATION REPORT•••A desk review of the project design and the baseline and monitoring
methodology.
Site visit and interviews with project stakeholders.
The resolution of outstanding issues and the issuance of the final validation reportand opinion.

In order to ensure transparency, a validation protocol was customized for the project. The
protocol used shows in a transparent manner the criteria, means of verification and theresults from validating the identified criteria. The validation protocol serves the following
purposes:• It organizes, details and clarifies the requirements a VCS project is expected tomeet.
• It ensures a transparent validation process where the validator will document how
a particular requirement has been validated and the result of the validation.
The validation protocol consists of two tables. The different columns in these tables aredescribed in Figure 1. The completed validation protocol for the “Kasigau Corridor
REDD Project Phase I – Rukinga Sanctuary”” is enclosed in Appendix A to this report.
Findings established during the validation can either be seen as a non-fulfilment ofvalidation protocol criteria or where a risk to the fulfilment of project objectives is
identified. Corrective Action Requests (CAR) are issued where:• Mistakes have been made with a direct influence on project results.
• Validation protocol requirements have not been met.
• There is a risk that the project would not be accepted as a VCS project or thatemission reductions will not be certified.
The term Clarification (CL) may be used where additional information is needed to fully
clarify an issue.

Validation Protocol Table 1: Requirement Checklist
Checklist Question
Reference
Means of verification(MoV)
Explains how
The various
Gives
requirements in Table 1
reference toconformance with the
documents
checklist question isare linked to checklist
investigated.
questions the project
where theshould meet. The
answer to
Examples of means ofchecklist is organized in
the checklist verification arequestion or
document review (DR)seven different sections.
Each section is thenitem isor interview (I). N/Afurther sub-divided. The
found.
means not applicable.
lowest level constitutes a

Comment
The section is used
to elaborate anddiscuss thechecklist question
and/or theconformance to thequestion. It isfurther used to
explain the
conclusions

Draft and/or Final
Conclusion
This is either
acceptable based onevidence provided(OK), or a Corrective
Action Request (CAR)
due to non-compliancewith the checklist
question (See below).A
request for
Clarification (CL) is

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VCS PROJECT VALIDATION REPORT
checklist question.

reached.

used when thevalidation team has
identified a need forfurther clarification.

Validation Protocol Table 2: Resolution of Corrective Action Requests and Requests for Clarification
Draft report corrective
Ref. To Table 1
Project participants’
Final conclusion
action requests andresponserequests for clarifications
If the conclusions from the Reference to the
The responses given byThis section should summarise
draft Validation are either checklist question
the project participants
the validation team’s
a Corrective Action
number in Table 1during the
responses and final
communications with the conclusions. The conclusions
Request or a Clarification where the Corrective
Request, these should be
Action Request or
validation team should
should also be included in
Clarification Request is be summarized in thisTable 1, under “Finallisted in this section.
explained.
section.
Conclusion..

Figure 1: Validation Protocol Tables

2.1 Review of Documents
The project document /1/, dated 31 January, 2011 and previous versions for “Kasigau
Corridor REDD Phase I – Rukinga Sanctuary” was submitted by Wildlife Works, Inc.,
along with additional background documents related to the project design and baseline,
which were assessed as part of the validation. The project documentation followed theguidance set out in VCS 2007.1.
The following table lists the documentation that was assessed during the validation:
Documents provided that relate directly to the project:/1/
Wildlife Works Carbon LLC, VCS PD for Kasigau Corridor REDD Project
Phase I – Rukinga Sanctuary” with VCS template and supporting
document, 31 January, 2011 and previous versions.
/2/“Carbon Rights Agreement” between Wildlife Works Inc. and Rukinga
Ranching Company – 15 Febuary, 2009.
/3/
Leasehold title to Rukinga Ranch – 1 January, 1971.
/4/
Re: - Management Authority for Rukinga Ranch (1 January, 2005).
/5/
Audit Report of Wildlife Works EPZ by Kenya National Environmental
Management Authority – December, 2006.
/6/
Shareholder list, Rukinga Ranching Company – Effective from AGM
meeting minutes on 9 December, 2009.
/7/
Rukinga Ranch Company/ Wildlife Works Inc. / Wildlife Works EPZ
financial statements and projections – As of 13 January, 2011.
/8/
CCB validation report conducted by Scientific Certifications Systems – 20
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VCS PROJECT VALIDATION REPORT/20/

December, 2009.
Image Classification Protocol (as of 14 January, 2011).
How to Use the Classification Tool (as of 14 January, 2011).
Logistic regression model for deforestation (as of 14 January, 2011).
Field measurement protocol – Standard Operating Procedure Biomass (asof 14 January, 2011).
Field measurement protocol – Standard Operating Procedure Soils (as of 14
January, 2011).
Soil lab report of measured soil carbon concentrations (Rukinga 1m Soil
Analysis, 14 January, 2011).
Forest Biomass Data (Rukinga Carbon trees Shrubs Grass v7.xlsm, 14
January, 2011).
Forest biomass sampling quality control comparisons (QC report.xlsx, 14January,2011).
Data used to develop tree biomass allometric equations(AllometricFormulasPower.xlsx, 14 January, 2011).
Letters to shareholders of Rukinga Ranching Co. Ltd. Pertaining to an
Extraordinary General Meeting of Rukinga Ranching Co Ltd. To be held atFree World Country Club, Voi at 10:00am Wednesday December 9th, 2009.
Wildlife Works Inc. Tool for AFOLU Non-Permanence Risk Analysis andBuffer Determination for the Kasigau Corridor REDD Project, Phase I –Rukinga (14 January, 2011).
Rukinga return analysis v4.xlsx (27 January, 2011)/21/

Leakage Model Expanded (14 January, 2011).

/22/

Grid Data RefArea flaggedPointsv2.xlsx (14 January, 2011).

/9/
/10/
/11/
/12/
/13/
/14/
/15/
/16/
/17/
/18/

/19/

Background documents related to the design and/or methodologies employed in thedesign or other reference documents:

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/23/
/24/

Approved VCS methodology: “VM0009 Methodology for Avoided
Mosaic Deforestation of Tropical Forests version 1.0” 11 January, 2011.
VCS Association, Voluntary Carbon Standard 2007.1, November 2008.

/25/

VCSA, VCS Sectoral Scopes (http://www.v-c-s.org/sectoral_scopes.html)/26/

VCSA, Guidance for Agriculture, Forestry and Other Land Use Projects,
18 November, 2008.
VCSA, Tool for AFOLU Non-Permanence Risk Analysis and Buffer
Determination, 18 November, 2008
VCSA, Update to the VCS 2007.1: Tool for Non-Permanence Risk
Analysis and Buffer Determination, 8 September, 2010.
VCS VT0001 Tool for the Demonstration and Assessment of Additionality
in VCS Agriculture, Forestry and Other Land Use (AFOLU) Project
Activities Version 1.0, 21 May, 2010.
CAR Forest Project Protocol version 3.2 August 31, 2010

/27/
/28/
/29/

/30/

2.2 Follow-up Interviews
During 10-14 January, 2011, DNV performed interviews with project stakeholders at the
project site in Rukinga, Kenya to confirm selected information and to resolve issues
identified in the document review. Representatives of Wildlife Works, Inc. wereinterviewed. The main topics of the interviews are summarized in Table 1.
Table 1 Interview Topics
Interviewed Organization
Wildlife Works, Inc.

Interview Topics
 Project start date.
 Demonstration of additionality.
 Emission reduction estimates.
 Monitoring plan.
 Baseline determination.
 Buffer determination.
 Leakage rates.
 Resources, training, procedures of management
structure.

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Table 2. Participants at Project Site (Rukinga, Kenya)
Name
Mike Korchinsky
Jeremy Freund
Rob Dodson
Patrick Kabatha
Hassan Sachedina
Laura Crown

Position
President
VP, Carbon Development
General Manager
Biodiversity Specialist
VP, Conservation Enterprise
Office Manager

Organization
Wildlife Works, Inc.
Wildlife Works Carbon LLC
Wildlife Works, Inc.
Wildlife Works, Inc.
Wildlife Works Carbon LLC
Wildlife Works, Inc.

2.3 Resolution of Any Material Discrepancy
To guarantee the transparency of the validation process, the concerns raised by DNV andthe response provided by the project proponent and the consultant are documented inTable 2 of the Validation Protocol in Appendix A.

3 VALIDATION FINDINGS
3.1 Project Design
The project avoids deforestation and forest degradation caused by clearing for
subsistence agriculture. Clearing is often preceded by degradation in the form of removalof larger trees with dense wood during illegal charcoal making operations. The projectencompasses a variety of activities to monitor and protect project lands, provide local
people with alternative ways of sustaining themselves, and providing sustainably
produced charcoal.
Quantification of deforestation was performed by human interpretation of a time series of
LANDSAT images of the reference area, classifying each point of a sample as forest,
non-forest, built, cloud/shadow or no image. Methods described in approved VCS
Methodology VM0009, Version 1.0 were used to statistically weight each forest state
observation and calculate a logistic curve representing cumulative baseline deforestation
over time.
Starting vegetation and soil carbon stocks were measured within the project area.
Vegetation sampling was stratified by vegetation type. Soil carbon was measured using
unstratified random sampling. Destructive sampling of trees and shrubs was used toconstruct allometric equations to predict tree biomass as a function of diameter and shrub
biomass as a function of height. Loss of soil carbon was estimated by measuring carbon
stocks in farmed fields and finding the difference between stocks in fields and inundisturbed forest.

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VCS PROJECT VALIDATION REPORTThe project avoids deforestation within the project boundary by controlling project lands
through ranger patrols and relationships between Wildlife Works staff and members ofsurrounding communities. The project provides alternatives to subsistence agriculture to
avoid leakage in the form of displacing land clearing from within the project boundary tooutside the project boundary. The project is developing a sustainable charcoal production
program to avoid displacement of charcoal production from within the project boundary
to other locations.
Baseline emissions are calculated as a function of the baseline area predicted to be
deforested each year, multiplied by the carbon stock per hectare in woody biomass, soil
carbon loss as a decay function since conversion to agriculture. The project avoids
emissions to the extent that monitored deforestation is less than predicted baseline
deforestation, adjusted for changes in biomass carbon stocks.
The project is eligible for crediting under the VCS because it meets the applicability
requirements of approved VCS Methodology VM0009 as explained in section 3.2.1
below.
DNV finds that the project does conform to VCS AFOLU guidance /26/, as well as
conforming to the applicability requirements of VCS Methodology VM0009. DNV also
finds that the project proponent has appropriately defined a reference area, appropriately
measured deforestation over time within the reference area, and appropriately monitored
starting biomass and soil carbon stocks within the project boundary. DNV has also
confirmed that the project is implementing leakage mitigation activities and has
performed baseline measurements needed to quantify whether or not leakage occurs overtime.
Project Boundary
The project area covers 100% (30,169 hectares) of the Rukinga Sanctuary. At the time ofthe project start date, 93% of the project area was forested for 10 years prior to the project
start date. The project boundary was confirmed by DNV by reviewing the two
documents provided by Wildlife Works, the leasehold title to Rukinga Ranch /2/ and theCarbon Rights Agreement between Wildlife Works Inc. and Rukinga Ranching Co. /3/.
Project Duration, Crediting Time and Project Start Date
Wildlife Works took financial responsibility for all conservation activities within the
Rukinga Sanctuary (Project Area) on 1 January, 2005. As such, the project start date andproject crediting period is 1 January, 2005 – 31 December, 2034. Although Wildlife
Works was performing conservation activities centered around the ecofactory prior to
2005, all activities were located outside of the Project Area and thus do not affect the
project start date or project crediting period of Phase I of this project. DNV confirmed
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that the project start date and project crediting period was determined properly throughreviewing the contract signed between Wildlife Works EPZ and Rukinga RanchingCompany, Ltd. /4/ and the Carbon Rights Agreement /2/. A 30-year crediting period wasselected, with 1 January, 2005 as the start date. The project will therefore end on 31
December, 2034.
Project Ownership
DNV can confirm the project ownership by Wildlife Works by reviewing two documents
provided by Wildlife Works /2/ and /3/. In addition, DNV can confirm that the project is
not included in any emission trading program and is not subject to binding greenhousegas (GHG) emissions limits /1/.
Project Eligibility Under the VCS
This project has not applied to nor been rejected by other GHG crediting systems.

3.2

Baseline

The project falls into sectoral scope 14 as defined by VCS /24/ . The project start date is 1
January, 2005. The project applies a new VCS methodology VM0009 “VM0009
Methodology for Avoided Mosaic Deforestation of Tropical Forests Version 1.0” /25/,
which was approved on 11 January, 2011. The project baseline is constructed according
to the approved methodology. The project proponent elected to use the linear model
baseline alternative provided within VM0009.

3.2.1 Applicability
DNV was able to verify that the project meets all applicability criteria of themethodology through document review and interviews /1/:
• DNV confirmed that in fact the primary driver of deforestation is the conversionof forest to cropland for annual crops and harvesting of wood to support theillegal charcoal trade by visiting the project site. Evidence of forest conversion toagriculture was evident both in the reference area and in the immediatesurroundings of the project area. The existence of an illegal charcoal trade wasvery evident through makeshift roadside charcoal sellers.
• DNV confirmed that the project area has been tropical dryland forest for at least
20 years with the review of Landsat imagery dating back to 1987.
• DNV confirmed that the project area meets the FAO 2010 and residing designatednational authority’s (DNA) definition of “forest” for the project country for aminimum of 10 years prior to the project start date /24/.
• DNV confirmed that the project is located in a semi-arid tropical region throughits site visit to Rukinga, Kenya.

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•

•
•
•
•
•
•
•
•

DNV confirmed that the project is not mandated by any enforced law, statute, orother regulatory framework by reviewing the relevant laws and regulations
outlined in the project document, leasehold title, management authority agreement,
and the audit report performed by the Kenya National Environmental
Management Authority /1/ /3/ /4/ /5/.
DNV confirmed by reviewing soil maps (/1/ section 6.5) and field observationthat the project area does not contain organic or peat soils.
DNV confirmed that the reference area meets the requirements outlined in section
6.3.1 and 6.3.2 of the approved VCS methodology, “VM0009, “Methodology for
Avoided Mosaic Deforestation of Tropical Forests.”
DNV confirmed that as of the project start date, historic imagery in the reference
region exists, with sufficient coverage to meet the requirements of section 6.4.2 of
VM0009.
DNV confirmed that a wide range of project activities have been implemented tomitigate deforestation by addressing the agents and drivers of deforestation as
described in section 10.1 of VM0009 (see section 6.1 in Project Document).
DNV confirmed that the project start date and end date and crediting period areclearly defined in the Project Document (see Section 6.3) /1/.
DNV confirmed that the project proponent has access to the leakage area byrandomly visiting a leakage plot used to create the leakage model during the site
visit.
DNV confirmed that no activity-shifting leakage had occurred prior to theestimation of the lag period /1/.
DNV confirmed that the project area does not include lands designated for legally
sanctioned logging activities by reviewing the title for the Rukinga Sanctuary /3//4/.

3.2.2 Baseline Scenario
The selected baseline scenario is ongoing deforestation from subsistence agriculture. The
rate of deforestation was calculated by defining a reference area that is near the project
area and has similar conditions and drivers of deforestation and then observing the
proportion of the reference area that is deforested at each of several points in time,
ranging from 1987 to 2005.
DNV concludes that the selected baseline scenario appropriately applies to the project
area because:• There are settlements to the west and north of the project area and active
deforestation is occurring on the outskirts of these settlements.

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VCS PROJECT VALIDATION REPORT• There is a major highway near the eastern boundary of the project area andvalidators observed large amounts of locally produced illegal bush charcoal forsale and being transported along this highway.
• Observations of time-series land cover images show rapid deforestation
continuing to occur within the reference region.
• Prior to the project start date, subsistence farmers had begun clearing land forfarms within the project area, near the western boundary of the project, with thesettlement apparently terminated by coordination with local village leaders andincreased ranger patrolling of project lands beginning around the time of the
project start.
It is DNV’s opinion that the selection of the continuation of the pre-project practice of theconversion of forest to cropland as the baseline scenario is deemed to be appropriate.
3.2.2.1 The Cumulative Deforestation Model
A pilot study estimated the variance of land cover state observations. The project
calculated that fewer than 1 900 observation points would be needed to meet statisticalprecision goals. The project elected to observe 2 000 points. Points were assigned by GIS
software, in a regular grid pattern within the project boundary. LANDSAT imagery was
obtained for the area, for 11 different years from 1987 to 2005. To build the Cumulative
Deforestation Model, imagery was used from 1987 until the project start date (2005). For
some years, images from different times within the year were tiled to create complete or
relatively complete coverage of the project area. The project developed an image
interpretation protocol and the protocol was used to guide classification of each point at
each time for which imagery was obtained. 8 821 vegetation state observations weremade.
In the region where the project is located, most deforestation occurs in a mosaic pattern.
A key element of the methodology is having a consistent decision rule for distinguishing(a) areas of forest with nearby deforested fields, from (b) remnant patches of trees among
fields that are classified as deforested. The image classification protocol states that if theforest fragment is surrounded by cleared area and the point is within a forest fragment but
is less than one field width from the edge of the fragment, the point is classified as
deforested.
Points that switched back and forth between forest and non-forest were identified. 164
points were flagged as having unlikely state transitions. Imagery for each flagged point
was reviewed, and inconsistencies were removed.
Each vegetation state observation was given a weight, using the procedure described in
VM0009. A commercial statistical software package was used to fit a logistic curve to the
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observed changes in forest state over time. The statistical uncertainty in the logistic
model is 5.9% at the 95% confidence level.
Population was tested to see if it added explanatory power to the model. Population did
not add power and was left out of the final deforestation model.
As allowed by the methodology, the project developer elected to be credited according toa linear deforestation rate that is cumulatively less than the logistic model at all times
within the project life.
3.2.2.2 The Soil Carbon Loss Model
Soil carbon stocks were measured to a one-meter depth in undisturbed forest within the
project boundary and in fields near the project that had been in agricultural use for at least
10 years. The average carbon stock was calculated for forest soil and for agricultural soil
and the difference assumed to be the loss resulting from deforestation and conversion toagriculture. The observed 45% loss of forest soil carbon is within the common range ofsoil loss given in published studies of other locations around the world. Carbon loss was
assumed to occur at a declining exponential rate, starting from the date of deforestation.
The exponential rate was chosen to match the rate graphed in Figure 10 of Methodology
VM0009.
During the validation process, the project proponent and validator became aware of aninconsistency in stated soil loss rates between the text of the approved methodology
VM0009 Version 1.0 and the rate graphed in Figure 10 of the methodology. The validator
will work with the methodology developer to write a corrected version of themethodology that eliminates this inconsistency.
3.2.2.3 Baseline Scenario for Selected Carbon Pools
The project developer has elected to count aboveground and belowground carbon in live
trees and shrubs, aboveground and belowground carbon in herbaceous vegetation, andcarbon in the top meter of soil.
No commercial harvesting of wood for long-lived wood products occurs within the
project area. Very small amounts of wood are retained in subsistence use. Branches areused in wattle-and-daub walls of farm huts. Few trees are suitable for using as posts, andfew posts are used in local construction or farming.
The cumulative deforestation model provides the baseline rate of deforestation for the
project area. When a hectare is deforested, the carbon in woody biomass is assumed to be
emitted to the atmosphere as CO2.
The project is expected to reduce burning of stumps during clearing, which may reduce
emission of methane from the burning. However, the project does not claim avoided
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methane from biomass burning as an emission reduction. Not claiming the avoided
emission is conservative. Relatively small amounts of biomass are burned during land
clearing in this area. Tree trunks appear to be left to decompose on site, used for domestic
fuel, or removed prior to deforestation during illegal charcoal production. The project
counts decomposition as emission and done not claim to reduce total wood fuel andcharcoal emissions. Most tree branches are moved to the edges of fields to function as
fencing. Because the amount of biomass burned is small, not counting avoided methane
emissions from burning does not cause material inaccuracy in emissions accounting.
Woody debris decomposition rates in the area are not well documented. When asked how
long some individual pieces of woody debris on tree measurement plots had been dead,local field staff gave estimates ranging from six to eighteen months for Class Two andClass Three woody debris. Pieces that local staff identified as being dead for at least 12
months were very light—for example, a few kilograms for a 20-cm diameter, 4-meterlong tree trunk. Decomposition of buried dead wood is even less well documented. Soilsampling pits in forest revealed significant amounts of tough, live roots between 0.5 and2 cm in diameter. However, hand tilling soil within a year of deforestation did not appear
to be impeded by roots. As is common, it appears that decomposition of buried deadwood is faster than decomposition of aboveground dead wood.
Especially when trees with dense wood (and presumably slower decomposing wood) areremoved for charcoal before land clearing for farming, it appears that little carbon stock
remains in woody debris one year after clearing. Counting woody debris pieces on acouple of sites gave densities on the order of 20 pieces per hectare greater than 15-cm indiameter. Even if the points where woody debris was counted had unusually high woody
debris mass, it is unquestionable that within one year of deforestation the carbon stock in
the remaining wood is substantially less than the carbon stock in the dead wood in
undisturbed forest. Because the project elected not to count avoided emissions fromwoody debris in the forest, it is conservative not to count any carbon that may remain
stored in biomass that survives more than a year after deforestation.
Soil carbon stocks in undisturbed forest and in fields that had been cleared at least 10
years previously were measured by sampling. The difference between the average soil
carbon stock in forest and the average soil carbon stock in tilled fields was taken to be thesoil carbon loss on clearing. Soil carbon loss dynamics are not well documented in thisecosystem. As noted above, the soil carbon loss function used to calculate soil emissions
after deforestation was set to match Figure 10 in the approved methodology.

3.2.3 Project Boundary
The project area covers 100% (30,169 hectares) of the Rukinga Sanctuary. At the time ofthe project start date, 93% of the project area was forested for 10 years prior to the project
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start date. The project boundary was confirmed by DNV by reviewing the two
documents provided by Wildlife Works, the leasehold title to Rukinga Ranch /2/, theCarbon Rights Agreement between Wildlife Works, Inc. and Rukinga Ranching Co. /3/.

3.2.4 Additionality Assessment
As per the approved VCS methodology, “VM0009 – Methodology for Avoided Mosaic
Deforestation of Tropical Forests Version 1.0,” the additionality of the project isdemonstrated through the latest version of the VT0001 VCS Tool for the Demonstration
and Assessment of Additionality in VCS Agriculture, Forestry and Other Land Use(AFOLU) Project Activities /24/.
Identification of Alternative Land-use Scenarios
DNV has confirmed that the alternative land use scenarios identified by Wildlife Works
are appropriate. It was also determined that the identified alternative land uses are
consistent with enforced mandatory laws and regulations.
DNV confirmed that the project is not mandated by any enforced law, statute, or otherregulatory framework by reviewing the relevant laws and regulations outlined in the
project document, leasehold title, management authority agreement, and the audit report
performed by the Kenya National Environmental Management Authority /1/ /3/ /4/ /5/.
Investment Analysis
DNV confirmed the project proponent’s simple cost analysis. DNV reviewed thefinancial statements for Wildlife Works and has confirmed that the project proponent has
been spending approximately USD$300 000-$400 000 per year without any significant
income to offset the costs to implement mitigation activities such as school building,scholarships, ranger patrols, and reforestation of deforested indigenous forests /7/. It istherefore DNV’s conclusion that without the revenue from the sale of GHG credits, theproject activities are economically unsustainable
Step 4: Common Practice Analysis
Though it is common practice to protect wilderness areas and provide sustainable
development support for rural African communities in Africa, governments and donor
agencies do not have a history of protecting the private lands. This project is the first
AFOLU Project Activity of its type in Kenya. As such, it can be reasonably concluded
that the project is not common practice.
In summary, it is demonstrated that the project activity is not a likely baseline scenario
due to the need of financial revenues to offset mitigation activities, and that the emission
reductions are additional to what would have happened in the absence of the project
activity.
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3.2.5 Leakage
Following methodology VM0009, the project developer has randomly located plots formeasuring leakage. Baseline amounts of degradation and deforestation have beenmeasured on these plots. The needed number of plots was calculated using the observed
variance of forest state observations across the reference area.
Leakage model parameters were calculated from the field measurements and compared tothe cumulative deforestation model. The leakage lag was calculated as the difference
between the deforestation curve and the leakage curve, and was given in the Project
Document.
As required by the methodology VM0009, leakage is measured empirically post project
start date from the shifted leakage curve. At the time of the next verification of offsets
generated by the project, the leakage plots can be re-measured and the change indegradation and deforestation calculated. These measurements and calculations are
expected to support quantification of the amount of leakage, if any, that has occurred.
Thus leakage will be empirically assessed during the next verification cycle.
As part of the project validation, the validator is to assess the project proponent’s leakage
ex-ante estimation that is likely to occur during the life of the project. Leakage is defined
as displacement of deforestation from within the project area to outside the project area.
This project will quantify leakage by measuring the rate of deforestation observed overtime within the leakage area. The leakage area is selected as equivalently accessible todrivers of deforestation that would have deforested the project area. Any deforestation on
the leakage area that is greater than the baseline rate of deforestation is counted asleakage.
The project is implementing a variety of leakage mitigation activities that are providing
alternative livelihoods to local people. Leakage mitigation activities include employment
in a clothing factory, work on project monitoring and Rukinga sanctuary protection,
development projects through a local women's center, a sustainable charcoal program,schooling, and other activities. These activities are scheduled to be expanded in the
future, using funding from the sale of the initial tranche of offsets generated by the
project. DNV does not have data on the complete number of people who benefit fromleakage mitigation activities, and does not know if these people would have cleared forest
for subsistence agriculture in the absence of the project. Also, it is not possible to know
for certain the scale at which leakage mitigation activities will be implemented in the
future.

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If leakage mitigation activities are less than the displaced demand for land, leakage islikely to occur. The current baseline deforestation is 955 hectares per year within the
project area. If each farm were to clear 2.5 hectares (the area estimated by the project
proponent), this would mean that the project should avoid the establishment of 382 newfarms each year to avoid leakage. If the baseline rate of deforestation is adjusted down in
the future, clearing for fewer farms would need to be avoided.
We have been unable to find historical leakage observations for any other REDD projects
and have no historical data on which to make actuarial projections for this project. As areference point, we assessed The Climate Action Reserve’s default leakage risk for crop
displacement activities is identified as 24 percent /30/. As noted, we do not have data on
the exact number of people involved in leakage mitigation activities, and do not know theextent to which leakage mitigation activities will be implemented over the life of the
project. Also, DNV is unable to determine if people involved in leakage mitigation
activities would have cleared forest if they did not participate in leakage mitigation
activities.
In the absence of past project data, any estimate of future leakage thus needs to rely on
the conditions observed during site visitation, knowledge of other ecosystems, assessmentof the agents and drivers of deforestation when judging the appropriateness of ex-anteleakage estimation of this project.
Estimating a leakage rate at the project outset is highly uncertain. Wildlife Works has
determined an ex-ante leakage rate for the project crediting period at 20% and it is ourassessment that this is appropriate given the conditions of the project and is consistent
with values proposed by The Climate Action Reserve. DNV thus finds the leakage
assessment to conform to the requirements in the approved methodology VM0009.

3.3 Monitoring Plan
The project applies the approved VCS “VM0009 Methodology for Avoided Mosaic
Deforestation of Tropical Forests Version 1.0.” The monitoring plan is in accordancewith the methodology. The monitoring plan specifies how to measure and document real,achieved emission reductions over the life of the project. As required by themethodology VM0009, leakage will be measured ex post from the shifted leakage curve.
All the variables defined in VCS, “VM0009 Methodology for Avoided Mosaic
Deforestation of Tropical Forests Version 1.0” are measured in order to determine andaccount for emission reductions. Each carbon pool monitored is a separate variable, withthe exception that the project has elected to count large and small live trees together.
The baseline is calculated ex-ante. The current baseline is reported in the project
document.
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Although VCS addresses leakage separately from monitoring, it is useful to consider thisproject’s leakage monitoring as a part of the overall monitoring program. The project
document reports computation of a “lag” variable, used to find correspondence between
the baseline deforestation model curve and the observed degradation and deforestation
measured on leakage plots. Remeasurement of the leakage plots in the future, calculationof total degradation and deforestation on the leakage area, and adjustment by the lag
factor will yield a cumulative actual deforestation number that can be compared to thebaseline deforestation proportion for the date of the leakage measurement.
At future times when offsets are to be verified, the project developer will map any
deforestation that may occur within the project boundary. Biomass carbon stocks will be
re-measured using the same protocols as used for the original measurement. Change incarbon stocks within the project area are included in the calculation on net emission
reductions as the CPE term of Equation 34 of the approved methodology. Projectemissions may be positive (emissions) or negative (a sink resulting from forest growth).
Consistent with the VCS requirements for grouped projects, the data management
systems used by Wildlife Works, Inc. are centralized. The general responsibility andauthority for registration, monitoring, measurement and reporting activities are defined inthe VCS PD. Wildlife Works Inc. has a contract with the landowner, Rukinga Ranching
Co. Ltd., to measure, monitor, report, and register offsets generated by avoiding
deforestation within the project area. The agreement was ratified in a general meeting of
the shareholders of the landowning company. DNV has reviewed this documentation /2/.
The parameters being monitored were discussed with the project proponent. The project
proponent has developed sufficient guidance for image classification and monitoringcarbon in soils and biomass in order to ensure that reliable field data is collected/9//12//13/.
The frequency of the data collection depends on the specific parameter included in themonitoring plan. DNV found that these are in line with the requirements of themethodology, VM0009.

3.4 Calculation of GHG Emissions and Reductions
DNV considered the VCS Standard /24/, VCS AFOLU guidance /26/, VCS approved
methodology VM0009 /23/, conditions observed during site visitation, and knowledge ofother ecosystems and forest projects when judging the appropriateness of GHG emission
reduction calculations of this project. DNV concludes that all significant emission
sources are included in project emission calculations. Calculation equations are publishedin VM0009. DNV reviewed the calculations in detail and, with the corrections made in
response to the CARs, calculations are correctly applied as specified by the VM0009.
Factors used in calculations are stated in the project document and are derived from local
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measurements, VM0009, or widely-referenced public sources. Equations for specifying
statistical confidence intervals are specified in VM0009. Statistical confidence intervals
are calculated for the baseline deforestation function, allometric equations developed to
predict tree biomass, and carbon stocks estimated from sampling. As with any sampling,
unbiased measurement and classification errors are expected to increase the statisticalerror observed in sampling. DNV found no potential sources of bias in counting, otherthan the conservative exclusions described above. Statistical confidence levels meetrequired precision levels.
The GHG Sources Determination
GHG sources that are counted are live trees aboveground and belowground biomass,
shrub aboveground and belowground biomass, herbaceous aboveground biomass, andsoil carbon. Emissions that are negligible or conservatively omitted include woody
debris, methane from biomass burning, and fuel consumed in land management. Any sinkin long-term wood products is negligible. Credible justification of the selection of the
carbon pools are included within the Project Document and DNV assessed that selection
conforms to the requirements set out in VM0009.
The Correctness and Transparency of Formulas and Factors Used
The approaches to estimate emission reductions for years 2005-2010 are described in the
VCS Project Document. DNV can confirm that the approaches conform to therequirements in the VCS approved methodology “VM0009 Methodology for Avoided
Mosaic Deforestation of Tropical Forests Version 1.0.”
Estimated Cumulative Project Lifetime Emission Reductions
As part of the project validation, the validator is to express its estimate of a conservative
amount of offsets the project is likely to generate through the life of the project. The
project proponent estimates that the project will generate 4 525 767 metric tons CO2e ofoffsets over the project life. This estimate is calculated using by:• Extending the current baseline deforestation rate through the project life,• Assuming that the carbon stock within the project boundary does not change(there is no net tree growth or loss, soil carbon stock change, and no deforestation
within the project area), and• Assuming 20% leakage in years 2011-2034.
• Applying a 20% AFOLU buffer deduction through the entire project crediting
period.
There is a high likelihood that at least one of these three factors will change over the
project life. The baseline deforestation rate has limited chance of increasing because
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approximately 95% of the project area is assumed to become deforested by the end of the
project life. The baseline could be revised downward if less deforestation is observed
over time in the reference area. If the baseline deforestation rate is revised down, theproject would generate fewer offsets, all other things remaining unchanged. The carbon
stock within the project area could rise or fall over time. A portion of the project area had
been deforested in the past and is now re-growing, and is likely to have carbon stockincrease. However, even if this formerly deforested area increases to the carbon densityof the average stock of the forest in the project area, it would be only about a 6% increasein the total project carbon stock. It is possible that because of drought or disturbance theexisting forest carbon stock could decline. Increasing carbon stock within the project area
would increase the number of offsets generated by the project, and decreasing carbon
stock would decrease the number of offsets generated. There is a chance that the leakage
mitigation activities executed by the project will not succeed in mitigating all the demand
for land displaced by the project, and leakage may occur. The project may not receive
credit for positive leakage, so if there is any leakage it can only reduce the amount ofoffsets generated by the project.
DNV is to express its opinion as to a conservative amount of offsets the project is likely
to generate over the project lifetime. To be conservative, the estimate must be a number
such that it is likely that the project will not generate less than the estimated amount ofoffsets. We note that the factors that could result in increased generation of offsets arehighly unlikely to cause an increase in offset generation greater than a few percent. At thesame time, it is possible that the factors that could result in the project generating fewer
offsets could result in a large reduction in benefits. We have been unable to find historicalleakage observations for any other REDD projects and have no historical data on which
to make actuarial projections for this project.
In the absence of project data, estimating a leakage rate at the project outset is highly
uncertain. Wildlife Works has determined an ex-ante leakage rate for the projectcrediting period at 20% and it is our assessment that this is appropriate given theconditions of the project and is consistent with values proposed by the Climate Action
Reserve.
DNV therefore can confirm that the calculation equations and input values are proper as
described above, and hence can confirm that the emission reduction estimates are proper,
which are on the average 4 525 767 tCO2e per year over the selected 30 year crediting
period.

3.5 Environmental Impact
The environmental and socio-economic impacts of the project activities have beenassessed within the context of the Audit report conducted by the Kenya National
Environmental Management Authority in December, 2006 /5/ and the Climate,
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Community, and Biodiversity Alliance (CCBA) validation that Wildlife Works, Inc.
underwent in 2009 with Scientific Certifications Systems (SCS) /8/. DNV has reviewed
all documentation pertaining to the environmental audit and the CCBA validation. Insummary, DNV concluded that no negative environmental or socio-economic impacts are
expected from project activities.

3.6 Comments by Stakeholders
The relevant stakeholders identified for this project activity include members of the Taita
community, the Duruma tribe, and local employees tasked with the implementation andmaintenance of the Rukinga REDD project. A local stakeholder process was carried out
by soliciting public comments through the internet and postings on local area noticeboards. DNV reviewed all comments and found that the process complies with VCS
requirements. In addition, DNV reviewed the CCBA project validation report conductedby SCS in 2009 /8/ and stakeholder comments received during the CCBA process /8/.
The project area underwent a CCBA project validation on 22 December, 2009. Feedback
from such stakeholders regarding the REDD project was very positive /8/.

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4 VALIDATION CONCLUSION
Det Norske Veritas (U.S.A.), Inc. (DNV) has performed a validation of the “The Kasigau
Corridor REDD Project Phase I – Rukinga Sanctuary” in Kenya on the basis of
Voluntary Carbon Standard 2007.1 (VCS), as well as criteria for consistent project
operations, monitoring and reporting.
The project proponent is Wildlife Works, Inc. DNV has confirmed that Wildlife Works,
Inc. has the right to all and any reductions generated by the Project during the Project
Crediting Period 1 January, 2005 – 31 December, 2034.
The review of the project design documentation and the subsequent follow-up interviews
have provided DNV with sufficient evidence to determine the fulfillment of stated criteria.
The project correctly applies the approved VCS methodology element VM0009 –Methodology for Avoided Mosaic Deforestation of Tropical Forests Version 1.0.
The main project activity is to prevent deforestation caused by slash and burn andsubsistence farming activities. The project results in reductions of GHG emissions thatare real, measurable and give long-term benefits to the mitigation of climate change andhave clear socio-economic benefits to the communities surrounding the project area.
Emission reductions attributable to the project have been shown to be additional to any
that would occur in the absence of the project activity.
The total emission reductions from the project are estimated to be 4 525 767 tCO2e overthe 30-year crediting period (1 January, 2005 to 31 December, 2034). This includes
project emissions, total confidence deduction, a 20% leakage deduction applied to years
2011-2034 as per VM0009, and the VCS AFOLU buffer deductions currently assessed at
20%. This estimate assumes the baseline does not change during the baseline
reevaluation.
Estimating a leakage rate at the project outset is highly uncertain. Wildlife Works has
determined an ex-ante leakage rate for the project crediting period at 20% and it is ourassessment given a lack of past project data that this is appropriate given the conditionsof the project and find the assessment to conform to the requirements in the approved
methodology VM0009.
The approaches to estimate emission reductions are assessed to conform to therequirements in the VCS and approved methodology VM0009.
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Adequate training and monitoring procedures have been implemented.
In summary, it is DNV’s opinion that the “The Kasigau Corridor REDD Project Phase I– Rukinga Sanctuary” in Kenya as described in the VCS PD of 31January, 2011, meetsall relevant VCS 2007.1 requirements and correctly applies the VCS approved
methodology element VM0009 – Methodology for Avoided Mosaic Deforestation of
Tropical Forests Version 1.0.

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Report No: 2011-9036, rev. 01
VCS PROJECT VALIDATION REPORTAPPENDIX A
Validation Protocol

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DET NORSKE VERITAS

Table 3 Requirements Checklist
Checklist Question

Draft
Concl

Final
Concl

Ref

MoV* Comments

/1/

DR

Section 5.2 - The project area covers 100%
(30,169 ha) of the Rukinga Sanctuary. At
the time of the project start date, 93% of
the project area was forested for 10 years
prior to the project start date. The projectboundary was confirmed by DNV byreviewing the two documents provided by
Wildlife Works, the leasehold title to
Rukinga Ranch /2/, the Carbon Rights
Agreement between Wildlife Works Inc.
and Rukinga Ranching Co. /3/.

OK

/1/

DR, I

The project design outlines current bestpractices for implementing the project
activities. While onsite, DNV witnessed
fully operational nurseries, ranger force, a
local GIS analyst, and engagement with theOK

A. General Description of Project Activity
The project design is assessed.

A.1. Project Boundaries
Project Boundaries are the limits and borders defining the
GHG emission reduction project.
A.1.1. Are the project’s spatial and temporal boundaries
clearly defined?

A.2. Technology to be employed
Validation of project technology focuses on the projectengineering, choice of technology and competence/
maintenance needs. The validator should ensure thatenvironmentally safe and sound technology and know-how is
used.
A.2.1. Does the project design reflect current goodpractices?

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DET NORSKE VERITAS

Checklist Question

Ref

MoV* Comments

A.2.2. Does the project use state of the art technology or
would the technology result in a significantly better
performance than any commonly used technologies?
A.2.3. Is the project technology likely to be substituted byother or more efficient technologies within the
project period?

/1/

DR, I

/1/

DR, I

A.2.4. Does the project require extensive initial training andmaintenance efforts in order to work as presumed
during the project period?

/1/

DR, I

A.2.5. Does the project make provisions for meeting
training and maintenance needs?

/1/

DR, I

/1/

DR, I

Draft
Concl

Final
Concl

community surrounding the project area.
The project proponent uses state of the art
GIS and modelling techniques.

OK

Wildlife Works is working with the REDD
Focal Point within the Government of
Kenya on future REDD legislation to
include sub-national nesting rules.
Yes – Procedures outlined within the How
to Use the Classification Tool (as of 14
January, 2011), Standard Operating
Procedure Biomass (as of 14 January,2011), Standard Operating Procedure Soils(as of 14 January, 2011) are sufficient.
Yes – Procedures outlined within the, How
to Use the Classification Tool (as of 14
January, 2011), Standard Operating
Procedure Biomass (as of 14 January,2011), Standard Operating Procedure Soils(as of 14 January, 2011) are sufficient.

Ok

OK

OK

B. Project Baseline
The validation of the project baseline establishes whether theselected baseline methodology is appropriate and whether theselected baseline represents a likely baseline scenario.

B.1. Baseline Methodology
It is assessed whether the project applies an appropriate
baseline methodology.
B.1.1. Is the baseline methodology previously approved by
the VCS?

Yes – VM0009 Methodology for Avoided
Mosaic Deforestation of Tropical Forests

OK

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DET NORSKE VERITAS

Checklist Question
B.1.2. Is the baseline methodology the one deemed mostapplicable for this project and is the appropriatenessjustified?

Ref

MoV* Comments

/1/

DR, I

/1/

I

Draft
Concl

Final
Concl

Version 1.0.
Yes – VM0009 was developed specificallyfor this project.

OK

B.2. Baseline Determination
The choice of baseline will be validated with focus onwhether the baseline is a likely scenario, whether the
project itself is not a likely baseline scenario, and whether
the baseline is complete and transparent.
B.2.1. Has the baseline been determined using conservative
assumptions where possible?

As with any sampling, unbiased
measurement and classification errors are
expected to increase the statistical error
observed in sampling. DNV found nopotential sources of bias in counting, otherthan the conservative exclusions describedabove. Statistical confidence levels meetrequired precision levels.

CAR 5,
6, 7

CAR 5
The coefficients for the deforestation
model given in the PD must be corrected
to match the coefficients produced by themodel and used in calculations of
cumulative deforestation.
CAR 6
The PD should describe the method used
to determine bulk density of disturbed soil
samples, and document that the protocol

Page 3

OK

DET NORSKE VERITAS

Checklist Question

Ref

MoV* Comments

Draft
Concl

Final
Concl

is well established.
CAR 7
The PD should specify the acceptable
degree of error allowed in forest
measurements, and how errors larger than
acceptable amounts shall be dealt with.
B.2.2. Has the baseline been established on a projectspecific basis?

/1/

DR, I

B.2.3. Does the baseline scenario sufficiently take into
account relevant national and/or sectoral policies,
macro-economic trends and political aspirations?

/1/

DR

B.2.4. Is the baseline determination compatible with theavailable data?
B.2.5. Is it demonstrated/justified that the project activity
itself is not a likely baseline scenario?

/1/B.2.6. Have the major risks to the baseline been identified?

/1/

/1/

DR

Yes – The baseline is specific to thecharacteristics of the reference region thathave similar drivers of deforestation.
The PD identifies possible risks that could
have an impact on the project baseline,
including change in legislation. The
government of Kenya has shown support
for the project and has no recent history of
expropriation of private conservation
lands.
See section 3.2

OK

OK

OK

Encroachment of subsistence farming (theprimary driver of deforestation) to theborders of the project area were evident.
It was demonstrated to DNV that the
project activity, conservation of forest, was
not a likely baseline scenario in the projectarea.
Yes – The following risks have been
identified: change in legislation, income,crop failure, invasion of cattle grazers due

OK

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DET NORSKE VERITAS

Checklist Question

B.2.7. Are all literature and sources clearly referenced?

Ref

MoV* Comments

/1/

DR

/1/

DR, I

Draft
Concl

Final
Concl

to famine in adjacent communities,
drought, wildlife, cash crops, and fireYes - Factors used in calculations using
literature and sources are clearly widelyreferenced public sources.

OK

C. Duration of the Project/ Crediting Period/project proponent
It is assessed whether the temporary boundaries of the project areclearly defined.
C.1.1. Are the project’s starting date and operational
lifetime clearly defined and reasonable?

C.1.2. Is the assumed crediting time clearly defined?

/1/

DR, I

C.1.3. Is the project proponent identified and has it been
confirmed to be an individual or organization that has
overall control and responsibility for a greenhousegas project?

/1/

DR, I

The project start date is 1 January, 2005,
which is the date Wildlife Work,s Inc.
assumed financial responsibility for the
project area and began specific GHG
mitigation activities. The selected crediting
period is from 1 January, 2005 to 31
December, 2034.
CAR 3
The justification of the project start datemust conform to VCS requirements.
The selected crediting period is from 1
January, 2005 to 31 December, 2034.
Yes – Wildlife Works, Inc. is the project
proponent for this project. Wildlife Works,
Inc. assumed financial responsibility forthe project area and began specific GHG
mitigation activities on 1 January, 2005
when the company entered into anagreement with Rukinga RanchingCompany, Ltd.

CAR 3

OK

OK
OK

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DET NORSKE VERITAS

Checklist Question

Ref

MoV* Comments

D.1.1. Is the monitoring methodology previously approvedby the VCS?

/1/

DR

D.1.2. Is the monitoring methodology applicable for thisproject and is the appropriateness justified?
D.1.3. Does the monitoring methodology reflect goodmonitoring and reporting practices?
D.1.4. Is the discussion and selection of the monitoring
methodology transparent?

/1/

DR

/1/

DR

/1/

DR

/1/

DR, I

Draft
Concl

Final
Concl

D. Monitoring Plan
The monitoring plan review aims to establish whether all relevant
project aspects deemed necessary to monitor and report reliable
emission reductions are properly addressed (blue text contains
requirements to be assessed for optional review of monitoring
methodology prior to submission and approval by CDM EB).

D.1. Monitoring Methodology
It is assessed whether the project applies an appropriate
baseline methodology.
Yes – VM0009 Methodology for Avoided
Mosaic Deforestation of Tropical Forests
Version 1.0.
Yes – The monitoring methodology wasdeveloped specifically for this project.
Yes – VM0009 outlines sufficient practices
for a monitoring methodology.
Yes – VM0009 outlines sufficient practices
and is transparent.

OK

OK
OK
OK

D.2. Monitoring of Project Emissions
It is established whether the monitoring plan provides forreliable and complete project emission data over time.
D.2.1. Does the monitoring plan provide for the collection
and archiving of all relevant data necessary for
estimation or measuring the greenhouse gas
emissions within the project boundary during thecrediting period?

Yes – Procedures outlined within the How
to Use the Classification Tool (as of 14
January, 2011), Standard Operating
Procedure Biomass (as of 14 January,2011), Standard Operating Procedure Soils(as of 14 January, 2011) are sufficient

OK

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/1/

DR, I

Yes – Procedures outlined within the, How
to Use the Classification Tool (as of 14
January, 2011), Standard Operating
Procedure Biomass (as of 14 January,2011), Standard Operating Procedure Soils(as of 14 January, 2011) are sufficient.

OK

D.4.1. Does the monitoring plan provide for the collection
and archiving of all relevant data necessary for
determining baseline emissions during the crediting
period?

/1/

DR, I

Yes – Procedures outlined within the, How
to Use the Classification Tool (as of 14
January, 2011), Standard Operating
Procedure Biomass (as of 14 January,2011), Standard Operating Procedure Soils(as of 14 January, 2011) are sufficient.

OK

D.4.2. Is the choice of baseline indicators, in particular forbaseline emissions, reasonable?

/1/

DR, I

The selected baseline scenario is ongoing
deforestationfromsubsistence
agriculture. The rate of deforestation was
calculated by defining a reference areathat is near the project area and has
similar conditions and drivers ofdeforestation and then observing the
proportion of the reference area that isdeforested at each of several points intime ranging from 1987 to 2005.

OK

D.3. Monitoring of Leakage
It is assessed whether the monitoring plan provides forreliable and complete leakage data over time.
D.3.1. Does the monitoring plan provide for the collection
and archiving of all relevant data necessary for
determining leakage?

D.4. Monitoring of Baseline Emissions
It is established whether the monitoring plan provides forreliable and complete project emission data over time.

The

parameters

of

the

cumulative

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deforestation model are in line with therequirements outlined in VM0009.
D.4.3. Will it be possible to monitor / measure the specified
baseline indicators?

/1/

DR, I

All the variables defined in VCS, “VM0009
Methodology
for
AvoidedMosaicDeforestation of Tropical Forests Version
1.0” are measured in order to determine
and account for emission reductions. Eachcarbon pool monitored is a separate
variable, except that the project has
elected to count large and small live trees
together.

OK

D.4.4. Will the indicators give opportunity for realmeasurements of baseline emissions?

/1/

DR, I

At future times when offsets are to beverified, the project developer will map
any deforestation that may occur within
the project boundary. Biomass carbon
stocks will be re-measured using the same
protocols as used for the original
measurement.

OK

/5/

DR, I

The environmental and socio-economic
impacts of the project activities have beenassessed within the context of the Audit
report conducted by the Kenya NationalOK

D.5. Environmental Impacts and Stakeholders Comment
It is checked to determine if any additional environmental
permits are required and if sufficient documentation ofenvironmental impacts are provided.
It is checked if any comments received from stakeholders
are summarized properly
D.5.1. Are any additional environmental permits needed forthe project activity? If yes, is there any approval
documentation provided?

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Environmental Management Authority inDecember, 2006. DNV has reviewed all
documentation
pertaining
totheenvironmental audit.
D.5.2. Any comments received from stakeholders should besummarized in the VCS PD.

/8/

DR, I

A local stakeholder process was carried out
by soliciting public comments through theinternet and posting on local area noticeboards. DNV reviewed all comments andfound that the process complies with VCS
requirements.

OK

Yes – Procedures outlined within the, How
to Use the Classification Tool (as of 14
January, 2011), Standard Operating
Procedure Biomass (as of 14 January,2011), Standard Operating Procedure Soils(as of 14 January, 2011) are sufficient.
Yes – Procedures outlined within the, How
to Use the Classification Tool (as of 14
January, 2011), Standard Operating
Procedure Biomass (as of 14 January,2011), Standard Operating Procedure Soils(as of 14 January, 2011) are sufficient.
Yes – Standard Operating Procedure
Biomass (as of 14 January, 2011), Standard
Operating Procedure Soils (as of 14
January, 2011) are sufficient.

OK

D.6. Project Management Planning
It is checked that project implementation is properly
prepared for and that critical arrangements are addressed.
D.6.1. Is the authority and responsibility of project
management clearly described?

/1/

D.6.2. Is the authority and responsibility for registration,
monitoring, measurement and reporting clearly
described?

/1/

D.6.3. Are procedures identified for training of monitoring
personnel?

/1/

OK

OK

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D.6.4. Are procedures identified for maintenance ofmonitoring equipment and installations?

/1/

D.6.5. Are procedures identified for monitoring,measurements and reporting?

/1/

D.6.6. Are procedures identified for day-to-day records
handling (including what records to keep, storage
area of records and how to process performance
documentation)
D.6.7. Are procedures identified for review of reported
results/data?

/1/

MoV* Comments
Yes – Standard Operating Procedure
Biomass (as of 14 January, 2011), Standard
Operating Procedure Soils (as of 14
January, 2011) are sufficient.
Yes – Standard Operating Procedure
Biomass (as of 14 January, 2011), Standard
Operating Procedure Soils (as of 14
January, 2011) are sufficient.
Yes – Standard Operating Procedure
Biomass (as of 14 January, 2011), Standard
Operating Procedure Soils (as of 14
January, 2011) are sufficient.
Yes – Standard Operating Procedure
Biomass (as of 14 January, 2011), Standard
Operating Procedure Soils (as of 14
January, 2011) are sufficient.

/1/

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OK

OK

OK

OK

E. Calculation of GHG Emissions by Source
It is assessed whether all material GHG emission sources are
addressed and how sensitivities and data uncertainties have beenaddressed to arrive at conservative estimates of projected
emission reductions.

E.1. Project GHG Emissions
The validation of ex-ante estimated project GHG emissions
focuses on transparency and completeness of calculations.
E.1.1. Are all aspects related to direct and indirect GHG
emissions captured in the project design?

/1/

DR, I

GHG sources that are counted are live tree
aboveground and belowground biomass,
shrub aboveground and belowgroundbiomass,
herbaceous
abovegroundbiomass, and soil carbon. Emissions thatare negligible or conservatively omitted

OK

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CAR 10OK

include woody debris, methane frombiomass burning, and fuel consumed inland management. Any sink in long-termwood products is negligible. Credible
justification of the selection of the carbon
pools are included within the PD and DNV
assessed that it was in line with therequirements set out in VM0009.

E.2. Leakage
It is assessed whether leakage effects i.e. change ofemissions which occurs outside the project boundary andwhich are measurable and attributable to the project) havebeen properly assessed and estimated ex-ante.
E.2.1. Are potential leakage effects beyond the chosen
project boundaries properly identified?

/1/

Following methodology VM0009, theproject developer has randomly locatedplots for measuring leakage. Baselineamounts of degradation and deforestation
have been measured on these plots. The
needed number of plots was calculatedusing the observed variance of forest state
observations across the reference area.
CAR 10Please provide a justification for theestimation of the ex-ante leakage rate forthe project crediting period as per therequirements of VM0009 (pg 69, pg 70).

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E.3.1. Have the most relevant and likely operational
characteristics and baseline indicators been chosen
as the reference for baseline emissions?

/1/

DR, I

E.3.2. Are the baseline boundaries clearly defined and dothey sufficiently cover sources and sinks for baseline
emissions?

/1/

DR, I

E.3.3. Are the GHG calculations documented in a complete
and transparent manner?

/1/

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E.3. Baseline Emissions
The validation of ex-ante estimated baseline GHG
emissions focuses on transparency and completeness of
calculations.
DNV finds that the project proponent has
appropriately defined a reference area,
appropriately measured deforestation
over time within the reference area, andappropriately monitored starting biomass
and soil carbon stocks within the projectboundary.
DNV finds that the project proponent has
appropriately defined a reference area,
appropriately measured deforestation
over time within the reference area, andappropriately monitored starting biomass
and soil carbon stocks within the projectboundary.
The approaches to estimate emission
reductions for years 2005-2010 are
described in the VCS Project Document.
DNV can confirm that the approaches
conform to the requirements in the VCS
approved
methodology“VM0009
Methodology
for
AvoidedMosaicDeforestation of Tropical Forests Version
1.0” and that a conservative approach has
been taken.

OK

OK

CAR 4

CAR 4

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The factor for the root:shoot ratio for trees
should be from the appropriate vegetation
type for the project location. The
vegetation type should be taken from an
authoritative public source.
Accepted and Corrected.
The FAO Africover dataset classifies the
Project Area as Tropical Dry Shrubland forwhich the root:shoot ratio for Trees is 0.4.
We have changed our root:shoot ratio forLarge and Small Trees to 0.4.

E.3.4. Are uncertainties in the GHG emission estimatesproperly addressed in the documentation?

/1/

DR, I

The statistical uncertainty in the logistic
model is 5.9% at the 95% confidence level.

OKE.3.5. Have the project baseline(s) and the projectemissions been determined using the same
appropriate methodology and conservative
assumptions?

/1/

DR, I

The approaches to estimate emission
reductions for years 2005-2010 are
described in the VCS Project Document.
DNV can confirm that the approaches
conform to the requirements in the VCS
approved
methodology“VM0009
Methodology
for
AvoidedMosaicDeforestation of Tropical Forests Version
1.0” and that a conservative approach has
been taken

OK

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DR, I

Draft
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CAR 8,
9OK

E.4. Emission Reductions
Validation of ex-ante estimated emission reductions.
E.4.1.

Will the project result in fewer GHG emissions thanthe baseline scenario?

The total emission reductions from the
project are estimated to be 4 525 767
tCO2e over the selected 30-year crediting
period (1 January, 2005 to 31 December,2034). This includes project emissions, thetotal confidence deduction, 20% ex-anteleakage estimate, and the VCS AFOLU
buffer determination of 20%.
CAR 8
The table of NERs and uncertainty
calculations should be updated in the PD
to reflect the amounts and final
calculations as verified.
CAR 9
Equations for baseline emissions are notproperly applied in the spreadsheet"Rukinga NER analysis v4.xlsx." Theincorrectly applied equations address
above and belowground biomass of trees
and non-tree vegetation, and soil. The
incorrectly applied equations arenumbered in the methodology as
equations 21, 23, 24, 26, and 26. The error
is that when calculating 2006 emissions(column D in the spreadsheet), cumulativeemissions as of the prior period are notsubtracted from the cumulative emissions

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Concl

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CL 1-3OKof the current monitoring period. The
terms in the equations that are missing
from the calculations are for monitoring
period m-1 (for biomass) and i-1 (for soil).
Numbers for these terms must be added
to the calculations. These terms appear tobe properly included and counted insubsequent years, in columns E throughAG of the spreadsheet. In the spreadsheet,this error is manifested in cells D24, D25,
D28, D29, and D33.

E.5. ISO 14064-2:2006 clause 5.2: Does the VCS PD contain the/1/

following essential elements?
E.5.1. Does the VCS PD contain the following essential
elements as set out in ISO 14064-2:2006 clause 5.2.
E.5.1.1. Project title, purpose(s) and objective(s)?

/1/

CL 1
Please include a reference to the final
approved VCS methodology, “VM0009
Methodology for Avoided Mosaic
Deforestation of Tropical Forests.”
CL 2
Please finalize all references to documents,
including the title, version, and date.
CL 3
Within the AFOLU Non-Permanence Risk
Analysis and Buffer Determination, areference to the project name should be

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included within the title.
E.5.2. Type of GHG project.

/1/

E.5.3. Project location, including geographic and physicalinformation, allowing for the unique identificationand delineation of the specific extent of the project.
E.5.4. Conditions prior to the project initiation
E.5.5. A description of how the project will achieve GHG
emission reductions and/or removal enhancements
E.5.6. Project technologies, products, services and the
expected level of activity.

/1/

DR

/1/
/1/

Yes – The project activity falls under VCS
sectoral scope 14 (AFOLU) REDD Mosaic
Deforestation.
Project location and delination of thespecific extent of the project is made clear.

OK

DR
DR

Section 6.1
Section 61

OK
OK

/1/

DR, I

OK

E.5.7. Aggregate GHG emission reductions and removalenhancements, stated in tonne of CO2e, likely tooccur from the GHG project.

/1/

DR, I

Project activities include: 1) Wildlife Works
Sustainable Development Initiatives 2)
Organic Greenhouse 3) Dryland farming
scheme 4) REDD Forest and Biodiversity
monitoring 5) Ranger force team 6)
Ecotourism 7) School construction andbursary scheme
The total emission reductions from the
project are estimated to be 7,542,945
tCO2e over the selected 30 year crediting
period (1 January 2005 to 31 December2034). This includes project emissions andthe total confidence deduction but does
not include the VCS AFOLU buffer
determination of 20% and assumes
leakage to be 0.

E.5.8. Identification of risks that may substantially affectthe project’s GHG emission reduction or removal

/1/

Dr

Section 1.11 - Yes – The following risks
have been identified: Change in legislation,

OK

OK

CAR 2

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income, crop failure, invasion of cattlegrazers due to famine in adjacentcommunities, drought, wildlife, cash crops,
and fireenhancements.

CAR 2
It is our assessment that the buffer
determination is a medium and the final
buffer withholding percentage should beshould be 20% (see Section 3.7“Buffer Risk
Determination” in DNV VCS Verification
Report / Verification Statement Revision 1
31 January 2011 )E.5.9. Roles and responsibilities, including contact
information of the project proponent other project
participants, relevant regulator(s) and/or
administrators of any GHG Program(s) to which the
GHG project subscribes.
E.5.10. Any information relevant for the eligibility of a GHG
project under a GHG Program and quantification of
GHG emission reductions or removal enhancements,
including legislative, technical, economic, sectoral,socio-cultural environmental, geographic, sitespecific and temporal information.

/1/

DR

Section 1.15 – The project proponent is
Wildlife Works Inc. Appropriate contact
information is included within the project
document.

OK

/1/

DR, I

The project area covers 100% (30,169 ha)of the Rukinga Sanctuary. At the time ofthe project start date, 93% of the project
area was forested for 10 years prior to theproject start date. The project boundary
was confirmed by DNV by reviewing thetwo documents provided by Wildlife
Works, the leasehold title to Rukinga
Ranch /2/, the Carbon Rights Agreement
between Wildlife Works Inc. and Rukinga
Ranching Co. /3/.

OK

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E.5.11. A summary of environmental impact assessment
when such an assessment is required by applicablelegislation or regulation.

/1/

The environmental and scoio-economic
impacts of the project activities have beenassessed within the context of the Audit
report conducted by the Kenya National
Environmental Management Authority inDecember DNV has reviewed all
documentation
pertaining
totheenvironmental audit.

OK

E.5.12. Relevant outcomes from stakeholder consultations
and mechanisms for on-going communication.

/1/

OK

E.5.13. Chronological plan for the date of initiating project
activities, date of terminating.

/1/

A local stakeholder process was carried out
by soliciting public comments through theinternet and posting on local area noticeboards. DNV reviewed all comments andfound that the process complies with VCS
requirements.
The project start date is 1 January 2005,
which is the date Wildlife Works Inc.
assumed financial responsibility for the
project area and began specific GHG
mitigation activities. The selected crediting
period is from 1 January 2005 to 31
December 2034.

E.5.14. Notification of relevant local laws and regulations
related to the project and demonstrate compliancewith them.

/1/

DR, I

OK

E.5.15. Does the VCS PD contain a Proof of Title which
includes either a legislative right, right under local

/1/

DR, I

Section 1.10 – Wildlife Works Inc.
documents the relevant local laws andregulations and was found to be incompliance with these regulations.
Section 8.1 – Rukinga Ranching Company
Ltd has legal title to the project area land.

OK

CL 4

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DET NORSKE VERITAS

Checklist Questioncommon law, ownership of land, or a contractual
arrangement with the owner of the land

Ref

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Concl

Final
Concl

A copy of the title deed was provided to
DNV. Wildlife Works Inc acquired thecarbon rights from the landowner in 2009.
CL 4
It would help to communicate to thereader if the PD were to include a graphicthat lists the organizations involved in the
project (Rukinga Ranching, WW Inc, WW
EPZ, WW Sanctuary, WW Carbon) shows
the relationship between them.

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APPENDIX B
Resolution of Corrective Action and Clarification Requests

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Table 4 Resolution of Corrective Action and Clarification Requests
Draft report corrective action requests and requests
for clarifications

Summary of project participants’ response

CAR 1
The monitoring report must be a stand alone
document from the project documentation. (VCS
Program Normative Document: Double Approval
Process Version 1.1 Section 6.2.1)

Accepted. Monitoring report broken out as a standalone
document. The document is entitled 'VCS Monitoring
Report Version 1.0’

Final conclusion
CAR closed.

Title page should be included with monitoring period(Jan 1 2005- December 31, 2010), client name, date,name of project, and version number on front cover.
CAR 2
It is our assessment that the buffer determination isa medium and the final buffer withholding
percentage should be should be 20%(see Section 3.7“Buffer Risk Determination” in DNV
VCS Verification Report / Verification Statement
Revision 1 31 January 2011 )Accepted and changed to 20%.

CAR 3
The justification of the project start date must
conform to VCS requirements.

The January 1, 2005 project start
Accepted and completed. The following text wasdate is valid because Wildlife
inserted into Section 5.2 in the PD.
Works Inc. took financial
responsibility for the project land
“Wildlife Works took financial responsibility for all
in 2005 and began implementing
conservation activities within the Project Area as ofproject actions within the project
January 1st 2005, as a result of the agreement between
area only after this.
Wildlife Works and Rukinga Ranching Company, Ltd., the(see Section 3.7“Buffer Risk
Determination” in DNV VCS
Verification Report / Verification
Statement Revision 1 31 January
2011 )CAR closed.

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Draft report corrective action requests and requests
for clarifications

Summary of project participants’ response

Final conclusion

landowner, a copy of which was provided to the
Validators.

Prior to 2005, conservation
activities implemented by
Wildlife Works Inc. were
implemented outside the projectarea.

Wildlife Works began conservation activities, centeredaround our ecofactory, prior to 2005, but those activities
were located outside the Project Area.
The VCS rule for AFOLU projects starting after Jan 1 2002
is that they have no specific time requirement forvalidation and verification. Language exists in the MED toclarify the type of project activities that qualify a project
for a historical project start date.

CAR closed

Wildlife Works fully conforms to these MED
requirements.”
CAR 4
The factor for the root to shoot ratio for trees shallbe from the appropriate vegetation type for the
project location. The vegetation type should be takenfrom an authoritative public source.

Accepted and corrected.

CAR 5
The coefficients for the deforestation model given in
the PD must be corrected to match the coefficients
produced by model and used in calculations of
cumulative deforestation.

Accepted and corrected.

The FAO Africover dataset classifies the Project Area as
Tropical Dry Shrubland for which the root:shoot ratio for
Trees is 0.4. We have changed our root:shoot ratio forLarge and Small Trees to 0.4.

The sources used for the root toshoot ratios and vegetation types
are appropriate.
CAR closed.

Coefficients in the PD werechanged and now match outputsof the statistical program used to
The coefficients previously listed in the PD were the calculate the coefficients of theresult of an obsolete version of the grid classification logistic model of deforestation.
data file. The new and correct coefficients now match The linear model coefficients also
the CDM model.
were changed, and meet thecriteria that the cumulative
deforestation predicted by thelinear model is less that the

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Draft report corrective action requests and requests
for clarifications

Summary of project participants’ response

Final conclusion
cumulative deforestation
predicted by the logistic model ineach year of the project life.
Further, the linear coefficientswere revised to reflect theclarification of the methodology,
that the accrual of offsets is at aconstant rate, starting from thecarbon stock within the projectboundary at the time of the startof the project. This clarification
avoids the assumption that, inthe first year of the project, thecumulative baseline
deforestation within the projectrises to match the cumulative
deforestation in the reference
area.

CAR 6
The PD shall describe the method used to determine
bulk density of disturbed soil samples, and documentthat the protocol is well established.

Accepted and completed. Text inserted into the PD:“The Bulk Density method used by the outside laboratorythat performed the soil testing for the PD is an official
FAO methodology for measuring Bulk Density of
disturbed soil samples.”A copy of the FAO approved protocol was provided to
the Validators.

CAR 7
The PD shall specify the acceptable degree of error

Accepted and done. Text inserted into the PD:
Quality Control (QC) for Biomass plots was conducting

CAR closed.
The addition of the following
language on page 66 is sufficient:“The Bulk Density method usedby the outside laboratory that
performed the soil testing for the
PD is an official FAO methodology
for measuring Bulk Density of
disturbed soil samples”
CAR closed.
Quality control guidance wasinserted into Section 13.14 of the

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Draft report corrective action requests and requests
for clarifications
allowed in forest measurements, and how errors
larger than acceptable amounts shall be dealt with.

Summary of project participants’ response

Final conclusion

using the following protocol;

PD.

1. An independent QC team not involved in the original CAR closed.
plot sampling of each plot is given coordinates for theplot centers for 5% of the original plots. The Independent
QC team is also given blank plot data recording sheets,plot radius for each carbon pool, a copy of the plot
sampling “Standard Operating Procedure – Biomass”,
dbh tape, compass and long tape, and sent out tomeasure the plots as though they were doing it for the
first time.
2. The QC team returns to headquarters with data
sheets which are given to a third party analyst, who areneither on the original nor the QC plot team, forcomparison against the original plot data sheets.
3. Any discrepancies are noted, and when all sheets
have been compared, the two plot teams are brought
together with the VP African Field Operations or his
deputy the Operations Manager to discuss and explain
any significant variances (±15%)4. The monitoring team lead is informed if more than 1
QC plot contains significant discrepancies from theoriginal data sheets, and further QC plots may berequired to establish the extent of the quality errors.
5. The Monitoring Team Lead and/or senior carbon
staff makes a determination as to whether a plot needs
to be revisited:
For a given plot, the number of trees that fall outside thePage 24

DET NORSKE VERITAS

Draft report corrective action requests and requests
for clarifications

Summary of project participants’ response

Final conclusion±15% threshold for change since original measurement iscounted. If greater than 10% of trees in that plot falloutside the threshold, and QC has been performed on
the plot within 1 year from original measurement, theplot must be re-measured. If QC has been performed ona plot greater than 1 year after original measurement,
the threshold described above shall be relaxed to 15%.
CAR 8
The table of NERs and uncertainty calculations
should be updated in the PD to reflect the amounts
and final calculations as verified.

Accepted and updated.
The table of NERs now matches the final calculations asverified.

CAR 9

Alternative Changes Applied

Equations for baseline emissions are not properly
applied in the spreadsheet "Rukinga NER analysis
v4.xlsx". The incorrectly applied equations address
above and belowground biomass of trees and nontree vegetation, and soil. The incorrectly applied
equations are numbered in the methodology as
equations 21, 23, 24, 26, and 26. The error is thatwhen calculating 2006 emissions (column D in the
spreadsheet) cumulative emissions as of the priorperiod are not subtracted from the cumulativeemissions of the current monitoring period. The
terms in the equations that are missing from thecalculations are for monitoring period m-1 (forbiomass) and i-1 (for soil). Numbers for these terms
must be added to the calculations. These terms
appear to be properly included and counted insubsequent years, in columns E through AG of theAfter discussing this CAR with the validators, it wasagreed that this CAR is not applicable. However, it led tosome clarifying language in the PD to ensure that a
conservative linear deforestation rate was used.

CAR closed.

The
projectbaselineisconstructed according to theapproved methodology. The
project proponent elected to use
the linear model baseline
alternative
provided
within
VM0009. As allowed by themethodology,
theproject
developer elected to be credited
accordingtoalineardeforestation rate that iscumulatively less than the logistic
model at all times within the
project life.
CAR Closed.

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Draft report corrective action requests and requests
for clarifications
spreadsheet. In the spreadsheet, this error ismanifested in cells D24, D25, D28, D29, and D33.

Summary of project participants’ response

CAR 10Accepted and competed.
Please provide a justification for the estimation of
the ex-ante leakage rate for the project crediting
period as per the requirements of VM0009 (pg 69, pg
70).

The following language was added to the Section 11.3
'Estimation of Ex-ante NERs' in the PD:
The project activities described in detail in Section 10
Leakage and Section 6.1 Baseline Scenario Overview,
were specifically designed to mitigate deforestation andhuman-wildlife conflict, and therefore by default serve to
mitigate leakage and uphold project permanence.
Wildlife Works is of the opinion that the project will
suffer little to no leakage, due to our exceptional
attention to leakage mitigation. However, in the absenceof precedent for estimating ex-ante leakage emissions,Wildlife Works chose to use a conservative value of 20%.
Applying this factor to gross NERs yields an estimate of
total net NERs over the project lifetime of:Final conclusion

Estimating a leakage rate at the
project outset is highly uncertain.
Wildlife Works has determined
an ex-ante leakage rate for the
project crediting period at 20%
and it is our assessment that thisisappropriate
given
the
conditions of the project and isconsistent with values proposedby The Climate Action Reserve.
DNV thus finds the leakage
assessment to conform to therequirements in the approved
methodology VM0009.

CAR 10 Closed.

Ex-Ante NERs=7,542,945-(7,542,945*0.20)
Ex-Ante NERs=6,034,356
This analysis is available as a spreadsheet and accounts
for an estimate of 20% leakage. It includes projectemissions and a total confidence deduction. A chart ofthe projected NERs over the life of the project ispresented below. Actual leakage values will be measured
empirically at each monitoring period, and will vary fromthese conservative ex-ante estimates.

Page 26

DET NORSKE VERITAS

Draft report corrective action requests and requests
for clarifications

Summary of project participants’ response

CL 1
Please include a reference to the final approved VCS
methodology, “VM0009 Methodology for Avoided
Mosaic Deforestation of Tropical Forests.”

Completed.

CL 2
Please finalize all references to documents including
the title, version, and date.

Completed.

CL 3Within the AFOLU Non-Permanence Risk Analysis andBuffer Determination, a reference to the project
name should be included within the title.

Completed.

CL 4
It would help to communicate to the reader if the PD
were to include a graphic that lists the organizations
involved in the project (Rukinga Ranching, WW Inc,WW EPZ, WW Sanctuary, WW Carbon) shows therelationship between them.

Accepted and completed.

CL 5
Please fix the typo on page 45 bullet point 2 from“lara” to “laws”.

Done.

CL 6
Page 26. “No Image” bullet: Before the last twowords, insert “not”?

Done.

Final conclusion
CL closed.

Included a reference to the final approved VCS
methodology, “VM0009 Methodology for Avoided
Mosaic Deforestation of Tropical Forests.”
Abbreviated to MED after the first instance.
CL closed.

CL closed.

CL closed.

Graphic added in section 5.3.2

CL closed.

CL closed.

Page 27

DET NORSKE VERITAS

Draft report corrective action requests and requests
for clarifications
CL 7
Page 43. Capitalize “co” in CO2e.

Summary of project participants’ response

Final conclusion

Done

CL closed.

CL 8Page 43. Section 6.6.4. First paragraph is truncatedand incomplete.

Done

CL closed.

CL 9Page 76. What are the units for the total area?
Hectares?

Accepted.
Changed table values to ha to match total.
Changed unit of measure to ha.

CL closed.

Page 28