Comment No. 1
From: Simon C. Bird <simon@wildlifeworks.com>
Sent: Wednesday, June 5, 2019 23:50 (GMT)
To: kh-pm-pi@jcm.go.jp
Subject: Public inputs (Methodology) KH_PM004
Methodology No.: KH_PM004
Version: Ver1.0
Title: Reducing deforestation and forest degradation through forest conservation in Cambodia
Name: Jeremy Freund and Simon Bird
Affiliated Organization: Wildlife Works
E-mail: simon@wildlifeworks.com
Country: USA
Part of the document (Cover sheet/A/B/C/etc): General
Page of the document: General
Input on the page (including justification of the change): See attached Document
Proposed change (including proposed text): See attached Document

To Whom It May Concern;Thank you for the opportunity to submit input on the JCM methodology KH_PM004 Reducing
deforestation and forest degradation through forest conservation in Cambodia. Please find theattached document containing our input on this methodology.
Thank you
Simon Bird

05 June 2019
To Whom It May Concern;
We appreciate the opportunity to provide comments on the proposed JCM methodology“Reducing deforestation and forest degradation through forest conservation in Cambodia”,version 1.0. We believe that this methodology will be important to the advancement ofREDD+ in Cambodia and ultimately help to conserve the country’s remaining intact forestsand biodiversity therein.
Reviewing the methodology, we are glad to see an approach that references the national
forest reference level (FRL) as submitted by Cambodia to the UNFCCC, as we feel that thisfits well with the prevailing national REDD+ Program design rationale. This supports thenotion that JCM REDD+ project(s) using this methodology align with other non-JCM
REDD+ projects/activities and can correctly nest into Cambodia’s national REDD+Program.
We are, however, concerned about the method prescribed in the methodology to derive theProject’s reference level from the national FRL. These concerns are based on Wildlife
Works’ extensive experience developing REDD+ projects and shepherding them throughthe jurisdictional/sub-national nesting process. It appears that the Project reference levelcalculated in section G is done so independently of a national / sub-national nesting design.
We feel this could lead to nesting problems and specifically make it difficult for JCM
Projects to align with other REDD+ activities within Cambodia’s national REDD+ system.
Firstly, we contend that FRL assignment to nested REDD+ Projects and/or activities should
be determined at the national REDD+ Program level, not at the Project methodology level.
This is to ensure that design decisions surrounding distribution of the FRL are madecentrally and in adherence with Cambodia’s national REDD+ policy and forest conservationneeds.
Secondly, we suggest that FRL allocation to REDD+ Projects and/or activities that iscentrally determined in a spatially explicit manner. This is primarily to ensure that the sumof the reference levels assigned to Projects/activities is not greater than (i.e. “rolls up” to)the total national FRL to be distributed. As currently written in Section G, the Projectreference level is calculated as an application of FRL transition probability, but does so
independently of the total available FRL. Alternatively, if the FRL were allocated to projects
in a spatially explicit manner within the country (i.e. using a FRL map from which eachproject determines its reference level) by a central entity, each Project’s annual
performance would be ensured to roll up to the national level in a manner consistent with
Cambodia’s nesting design. We feel this would result in a more equitable design, ensuringthat Projects’ reference levels reflect local deforestation threat, and that they are allocatedpotential for revenue proportionate to the effort and costs that they face in conserving
forests and biodiversity.
USA Headquarters: 242 Redwood Highway, Mill Valley, CA 94941
T: 415.332.8081 | F: 415.332.8057 | www.wildlifeworks.com

We believe that due to the two issues discussed above could yield inconsistencies in thedetermination emission reductions from the reduction of deforestation in Cambodia, as wellas problems nesting Projects/activities into the national REDD+ system.
We are more than happy to discuss these concerns further with the methodology
developers and provide more detail on suggested alternative methods that can be used toequitably assign the national FRL at the Project/activity level.
Thank you
Jeremy Freund
Vice President Carbon Development
Jeremy@wildlifeworks.com
Simon Bird
Director Forest Science
Simon@wildlifeworks.com

USA Headquarters: 242 Redwood Highway, Mill Valley, CA 94941
T: 415.332.8081 | F: 415.332.8057 | www.wildlifeworks.com