Final CCBA Project Validation Report...Final CCBA Project Validation Report CARBON EMISSIONS REDUCTION PROJECT IN THE FOREST CORRIDOR AMBOSITRA-VONDROZO (COFAV), MADAGASCAR 15 DECEMBER

CCB_CI_COFAV_FinalRPT_Validation_122913

Final CCBA Project Validation Report CARBON EMISSIONS REDUCTION PROJECT IN THE FOREST CORRIDOR AMBOSITRA-

VONDROZO (COFAV), MADAGASCAR

15 DECEMBER 2013

Assessment Conducted by:

SCS Global Services Greenhouse Gas Verification Program

2000 Powell Street, Suite 600, Emeryville, CA 94608 USA (Tel.) 1.800.326.3228 • (Fax) 510.236.8598

http://www.scsglobalservices.com/

http://www.scsglobalservices.com/

CCB_CI_COFAV_FinalRPT_Validation_122913

Table of Contents Final CCBA Project Validation Report ........................................................................................... 1 1. Executive Summary ................................................................................................................. 1 1.1. Objective .............................................................................................................................. 1 1.2. Scope and Criteria ................................................................................................................ 1 1.3. Level of Assurance ............................................................................................................... 1 1.4. Summary Description of the Project .................................................................................... 1 1.5. Audit Process ....................................................................................................................... 2 1.6. Auditor Qualifications .......................................................................................................... 4 2.0 Stakeholder Comments ....................................................................................................... 5 2.1. Review of CCB Requirements ............................................................................................... 5 2.2. General Section .................................................................................................................... 6

2.2.1. G1 – Original Conditions in the Project Area ........................................................... 6 2.2.2. G2 – Baseline Projections ...................................................................................... 10 2.2.3. G3 – Project Design and Goals .............................................................................. 12 2.2.4. G4 – Management Capacity and Best Practices .................................................... 17 2.2.5. G5 – Legal Status and Property Rights .................................................................. 19

2.3. Climate Section .................................................................................................................. 22 2.3.1. CL1 – Net Positive Climate Impacts ....................................................................... 22 2.3.2. CL2 – Offsite Climate Impacts (‘Leakage’) ............................................................. 24 2.3.3. CL3 – Climate Impact Monitoring .......................................................................... 25

2.4. Community Section ............................................................................................................ 27 2.4.1. CM1 – Net Positive Community Impacts ............................................................... 27 2.4.2. CM2 – Offsite Stakeholder Impacts ....................................................................... 28 2.4.3. CM3 – Community Impact Monitoring .................................................................. 28

2.5. Biodiversity Section ............................................................................................................ 29 2.5.1. B1 – Net Positive Biodiversity Impacts .................................................................. 30 2.5.2. B2 – Offsite Biodiversity Impacts ........................................................................... 31 2.5.3. B3 – Biodiversity Impact Monitoring ..................................................................... 32

2.6. Gold Level Section .............................................................................................................. 33 2.6.1. GL1 – Climate Change Adaptation Benefits .......................................................... 33 2.6.2. GL2 – Exceptional Community Benefits ................................................................ 34 2.6.3. GL3 – Exceptional Biodiversity Benefits ................................................................ 36

3.0 CCB Validation Conclusion ................................................................................................. 37 3.1. Resolution of Any Non-conformance and Other Issues ..................................................... 37 4.0 Findings .............................................................................................................................. 37 Appendix A Stakeholder Comments Appendix B CCBA Compliance Checklist

CCB_CI_COFAV_FinalRPT_Validation_122913 1

1. Executive Summary This report presents the findings of an assessment conducted by SCS Global Services (SCS), to confirm the claim that the Carbon Emissions Reduction Project in the Forest Corridor Ambositra-Vondrozo (COFAV), Madagascar (“the Project”) conforms to the Climate, Community and Biodiversity Project Design Standards (Second Edition) at the Gold level. SCS has been approved by the Climate, Community & Biodiversity Alliance (CCBA) to provide such assessment services. The process consisted of a thorough desk review of Project documentation, including contracts and carbon accounting workbooks. In addition the audit team performed a site visit in order to visit portions of the Project area, conduct interviews with communities and other stakeholders, and evaluate the quality of the Project’s management systems.

1.1. Objective The validation audit is an independent assessment by SCS of the proposed Project activity against the assessment criteria. Validation has resulted in a conclusion by SCS as to whether the Project activity is compliant with the assessment criteria and whether the Project should be approved under the CCB Standards.

1.2. Scope and Criteria The scope of the audit consisted of the Project, its activities, and its geographic extent, as described within the Project Design Document (PDD). The assessment was conducted against the criteria set out within the following guidance documents:

• Climate, Community and Biodiversity Project Design Standards, Second Edition (“CCB Standards”)

• Rules for the use of the Climate, Community & Biodiversity Standards, Version 21 June 2010 (“CCB Standards Rules”)

The Project was assessed against all required criteria of the CCB Standards in order to determine whether the Project could be validated at the “Approved” level. In addition, the Project was assessed against at least one optional criterion, as set out by the CCB Standards, in order to determine whether the Project could be validated at the “Gold” level. 1.3. Level of Assurance SCS performed this assessment based on the guidance described by the Rules for the Use of the CCB Standards to determine whether there is a reasonable level of assurance that the Project design addresses each requirement of the CCB Standards. 1.4. Summary Description of the Project From the Introduction of the Carbon Emissions Reduction Project in the Forest Corridor Ambositra-Vondrozo (COFAV), Madagascar PDD,


The Ambositra-Vondrozo Forest is located in the southern half of the humid eastern forest biome of Madagascar and is a narrow strip approximately 300 km long. A new protected area, the Ambositra-Vondrozo Forest Corridor Natural Resource Reserve is being created in this area, 135,212 hectares of which forms the project area of Carbon Emissions Reduction Project in the Forest Corridor Ambositra-Vondrozo (COFAV), Madagascar (hereafter “the project”). The project lies on Madagascar’s eastern escarpment and links Ranomafana National Park in the north and Andringitra National Park in the south. The Project’s main objective is to create a new protected area, the Ambositra-Vondrozo Forest Corridor Natural Resource Reserve that provides benefits including:

providing sustainable use zones

Promoting farming alternatives to tavy;

Providing technical support for improved agriculture techniques (feeding, transport, commercialization, etc.)

Constructing dams, irrigation and drainage systems

Establishing new revenue-generating activities that don’t cause deforestation (ecotourism, nursery management for reforestation activities, etc.)

Marketing the products of revenue-generating activities;

Streamlining of the management transfer process for natural resources

Supporting communities to establish partnerships and funding for development projects;

Preventing infectious diseases and promoting local health The proposed REDD project aims to implement a unique strategy of combating deforestation in COFAV through a co-managed protected area in which local community groups are an essential actor in the governance structure. Linking forest protection to the betterment of local communities will ensure the long term success of the project. 1.5. Audit Process SCS commenced the validation of the Project during April 2013.

The audit process included the following steps:

Kick-off meeting Conservation International (via phone conference) Desk review of initial documentation, including the Project Design Document (PDD), preliminary

monitoring plans, and Project manuals Issuance of desk review findings Discussions (via phone conference) between SCS and Conservation International about the

Project documentation Site visit between 4 June and 16 June 2013, that included:

o Project overview by Conservation International


o Meetings at the CI office in Antananarivo to discuss the PDD, including discussions of the without Project scenario, the communities in the Project Zone and the Project design (Table 1)

o Interviews with local government officials from Direction Generale des Forêts (Table 1) o Interviews with communities in the Project Zone: Modioran, Tolongoina,

Sahavondronana, Ambatovaky, Androy, and Vinanitelo (Table 1) o Closing meeting in Anatananarivo with CI staff

Issuance of site visit findings Continued document review, review of finding responses, closure of findings, and report

preparation Internal review and approval of the draft validation report Issuance of the draft validation report to CI Issuance of the final validation report to CI and the CCBA

Table 1. Interviews Conducted During the Site Visit Participant Affiliation Date

Interviewed James Mackinnon Former Director – CI Madagascar 6-7 June 2013

Chris Tuite Senior Advisor, Carbon Fund – CI 6-7 June 2013

Fabiano Godoy Director REDD Projects - CI Throughout

Bruno Rajaspera Project Coordinator – CI Madagascar Throughout

Rasolohery Andriambolantsoa GIS Analyst, Land Use modelling, Inventory Specialist – CI Madagascar

Throughout

Timothy Wright GIS Analyst and Land use modelling - CI

Throughout

Jean Razafitsotra Sustainable Development Advisor - CI-Madagascar

6-7 June 2013

Jeannicq Randrianarisoa Sustainable Finance Coordinator - CI-Madagascar

6-7 June 2013

Tolotra Ratsimandresy Head of Sector - CI-Madagascar Throughout

Andoniaina Rambeloson Biodiversity Scientist – CI Madagascar

6-7 June 2013

Rejela Razakanjoelina Director of COFAV 13 June 2013

N’Aina Zatovonirina Health, Population, Environment Coordinator – CI Madagascar

8-13 June 2013

Michel Randriambololona Regional Conservation Coordinator – CI Madagascar

8-13 June 2013

RaholisorimangaVoahangy Direction Generale des Forêts 6 June 2013

Andriantoandro Hanitra B Direction Generale des Forêts 6 June 2013


Ramiandrarivo Liva H. Direction Generale des Forêts 6 June 2013

Randriambanona Herizo Andrianatoandro Biomass Team – CI Madagascar 8-13 June 2013

Randrianasolo Sitrakiniavo Paul Biomass Team – CI Madagascar 8-13 June 2013

Andrianarivelo ny Aina Biomass Team – CI Madagascar 8-13 June 2013

Jean Claude Razafimahaimodison Team Manager – Centre Valbio 12 June 2013

Pascal Rabeson Coordinator of Monitoring – Centre Valbio

12 June 2013

Individual(s) residing in the community listed under “affiliation and role”

Madiorano Week of 9 June 2013


Tolongoina Week of 9 June 2013

Individual(s) residing in the community listed under “affiliation

Sahavondronana Week of 9 June 2013


Ambatovaky Week of 9 June 2013


Androy Week of 9 June 2013


Vinanitelo Week of 23 September 2013

1.6. Auditor Qualifications Lead Auditor: Francis Eaton, SCS Global Services Verification Forester Mr. Eaton holds a Masters of Forest Science from the Yale School of Forestry and Environmental Studies and received his B.S. in Forestry from Northern Arizona University. The focus throughout his studies was forest management with emphases on sampling design and statistical analysis. He spent three years working collecting field data and completing data analysis on forest restoration projects with the Ecological Restoration Institute. His work experience also includes complete biophysical inventories and estimation of timber volume for two 3000 acre properties, as a forest consultant in northern New Mexico. Mr. Eaton is well versed in editing sampling designs and auditing field campaigns as a teaching fellow for masters-level management plan courses. Mr. Eaton currently works as a Verification Forester for SCS and has completed forest carbon projects under the Verified Carbon Standard (VCS), the Climate Action Reserve (CAR), and the Climate, Community, and Biodiversity Alliance (CCBA). Moreover, Mr. Eaton is accredited by the California Air Resources Board as Lead Offset Verifier and is also certified by the Board in the US Forest Project and Urban Forest Protocols. He is also certified as Lead Verifier under the Climate Action Reserve.


Local Experts: Social Contact, Harijaona Niaina Forester, Linjanatenaina Rakotomalala Forester, Ratovo Olitinina Technical Reviewer: Zane Haxtema, SCS Global Services Senior Verification Forester Mr. Haxtema holds a M.S. in Forest Resources from Oregon State University and a B.S. from The Evergreen State College. A well-rounded forestry professional, Mr. Haxtema held a wide variety of positions in forest research and management before coming to SCS, ranging from work on logging and tree planting crews to experience as a biological sampling technician and research assistant. Mr. Haxtema is a specialist in forest inventory, with areas of expertise including sampling design, inventory management and the use of growth and yield models to evaluate potential management regimes. Through his work at SCS, Mr. Haxtema has worked on forestry projects in both the northern and southern hemisphere that span four countries. Mr. Haxtema is well versed in methodologies for Avoided Planned Deforestation, Improved Forest Management, and Afforestation, Reforestation and Revegetation projects, with experience working in tropical and temperate forests alike. Mr. Haxtema is currently a verifier under the Climate Action Reserve, the Verified Carbon Standard and the Climate, Community and Biodiversity Standard.

2.0 Stakeholder Comments The Project Design Document (PDD) was posted on the CCBA website 24 May 2013 and the public comment period extended through 23 June 2013. Based on the professional judgment of the audit team, the project chose to undergo a second public comment period beginning on 10 July, 2013 and ending on 9 August, 2013. Comments received throughout each of the two public comment periods are discussed in Appendix A of this report.

2.1. Review of CCB Requirements This assessment report addresses each of the CCBA criteria and indicators. For each criterion, the CCBA indicators are listed along with a description of the evidence that was considered. When assessing the conformance of each indicator to the CCB Standards, SCS may issue findings to the Project Proponent. These findings can include Non-Conformity Reports (NCRs), Opportunities for Improvement (OFIs) and New Information Requests (NIRs), compiled in Section 4. In the case of non-conformance, a Non-Conformity Report stipulates the deficiency and its relation to the CCB protocol. NCRs indicate non-conformance at the criterion level that must be satisfied prior to Project validation. An Opportunity for Improvement is often an indication of something that may become a non-conformity if not given proper attention. OFI’s are considered by the audit team to be closed upon issuance, and a response to this type of finding is not necessary. New Information Request indicates when additional information is necessary to complete the assessment. It should be noted that conformance to the criteria for each indicator regarding climate, risk, and additionality were successfully validated under the Rules of the VCS Standard and VCS AFOLU


Requirements. Whereas the audit team has provided evidence for each indicator, the evidence for each of these indicators will include a reference to the associated VCS Validation report. 2.2. General Section The General Section of the CCB Standards addresses original conditions in the Project are baseline Projections, Project design and goals, management capacity and best practices, and legal status and property rights. 2.2.1. G1 – Original Conditions in the Project Area The original conditions at the Project Area and the surrounding Project Zone before the Project commences must be described. This description, along with baseline Projections (see G2), will help to determine the likely impacts of the Project. G1 - Original Conditions in the Project Area

Indicator 1 - The location of the Project and basic physical parameters (e.g., soil, geology, climate).

SCS was able to confirm the information provided in the PDD during the desk review and through ground truthing during the site visit.

Conformance - Y Indicator 2 - The types and condition of vegetation within the Project Area.

During the site visit, the audit team was able to confirm the description of vegetation provided by the Project documents. Observations in and around the Project Zone and re-measurements of forest inventory plots were consistent with the claims of the COFAV PDD. In addition, the audit team was able to conduct interviews with members of the CI staff in country, as well as community members near the project area, further confirming the claims of the PDD.

Conformance - Y

Indicator 3 - The boundaries of the Project Area and the Project Zone.

The Project Area is defined by a strict conservation zone and sustainable use areas. The Project Zone consists of the Project Area, as well as a non-forest community management zone, in which leakage mitigation activities will take place. The audit team was able to confirm the boundaries of both the Project Area and the Project Zone during the time spent on site and found them to be in agreement with the evidence provided in the PDD. Interviews with community members confirmed a strong knowledge of the differences in uses area boundaries, as well as the

Conformance - Y


public consultation process for determining such boundaries. While onsite, government officials from the Direction Generale des Forêts (DGF) also corroborated the documentation of these boundaries.

Indicator 4 - Current carbon stocks within the Project Area(s), using stratification by land-use or vegetation type and methods of carbon calculation (such as biomass plots, formulae, default values) from the Intergovernmental Panel on Climate Change’s 2006 Guidelines for National GHG Inventories for Agriculture, Forestry, and Other Land Use or a more robust and detailed methodology.

Carbon stocks within the Project Area were determined on a per hectare basis using the following methodology: VCS methodology VM0015 “Methodology of Avoided Unplanned Deforestation (AUD).” The use of this methodology demonstrated that the Project design will generate net positive climate benefits. Further details regarding the work undertaken to confirm the carbon stock values reported in the PDD can be found within the VCS validation report for the project.

Conformance - Y Indicator 5 - A description of communities located in the Project Zone, including basic socio-economic and cultural information that describes the social, economic and cultural diversity within communities (wealth, gender, ethnicity, etc.), identifies specific groups such as Indigenous Peoples and describes any community characteristics.

Communications by the audit team with representatives from six communities within the Project Zone verified that the information presented in the PDD and provided by the Project Proponent is accurate. In addition, interviews with the DGF further confirmed the accuracy of the information provided in the PDD. The information provided is in conformance with the requirements of this indicator.

Conformance - Y Indicator 6- A description of current land use and customary and legal property rights including community property in the Project Zone, identifying any ongoing or unresolved conflicts or disputes and identifying and describing any disputes over land tenure that were resolved during the last ten years (see also G5).

The Project documentation includes an accurate description of current land use and customary and legal property rights in the Project Zone. During the site visit, the Project Proponent and the local government officials confirmed that there are no current land tenure disputes. Whereas, it should be noted that land tenure has been historically honored for community members who consistently occupy the land (10 year occupancy) in the project area, interviews with local communities near the project area confirmed that this practice is no longer honored in the project area.

Conformance - Y


Indicator 7 - A description of current biodiversity within the Project Zone (diversity of species and ecosystems) and threats to that biodiversity, using appropriate methodologies, substantiated where possible with appropriate reference material.

The Project documentation, including the MEF 2010 provides an adequate description of the current biodiversity in the Project Zone. The audit team determined this information to be appropriate and supported by their observations in the field and through their interviews with CI staff and members of the local communities. In addition, the audit team was able to conduct interviews with members of the Valbio Biodiversity Centre, near Ranomafana, further confirming the description of biodiversity and threats to biodiversity in the Project Zone. Conformance - Y

Indicator 8 - An evaluation of whether the Project Zone includes any of the following High Conservation Values (HCVs) and a description of the qualifying attributes:

While the standards refer to the definition of HCVs provided by the High Conservation Value Resource Network, assessing the evaluation of HCVs requires professional judgment on the part of the audit team. Evidence provided in the PDD is consistent with observations made by the audit team, based on the audit team’s technical understanding of HCVs.

Indicator 8.1 - Globally, regionally or nationally significant concentrations of biodiversity values; a. protected areas b. threatened species c. endemic species d. areas that support significant concentrations of a species during any time in their lifecycle (e.g. migrations, feeding grounds, breeding areas).

The audit team was able to confirm the presence of globally, regionally, and nationally significant concentrations for each of the criteria listed in this indicator through a review of the results presented in the PDD and a review of the species listed in the on the CITES and the IUCN Red List websites. The audit team also interviewed staff form the Valbio Biodiversity Centre and the information to support the conformance of this indicator was reconfirmed.

Conformance - Y Indicator 8.2 - Globally, regionally or nationally significant large landscape-level areas where viable populations of most if not all naturally occurring species exist in natural patterns of distribution and abundance;

The audit team was provided with a suite of scientific literature (Olson and Dinerstein, 2002; Kremen et al., 2008; Birdlife, 2013) confirming the claims of the PDD. Claims that the endemism of humid forests of eastern Madagascar is 80 to 90 percent is consistent with the professional knowledge of the audit team.

Conformance - Y


Indicator 8.3 - Threatened or rare ecosystems

During the site visit, the audit team was presented with evidence showing the extent of deforestation across Madagascar, including the unique ecosystems (low, mid, and high-altitude forests) occurring only in this region of the country. Claims in the PDD of the threats and rarity of these ecosystems were further confirmed through interviews with the DGF.

Conformance - Y

Indicator 8.4 - Areas that provide critical ecosystem services (e.g., hydrological services, erosion control, fire control);

Observations made by the audit team during the site assessment confirmed the claims in the Project documentation. The COFAV corridor is an essential watershed for five administration regions in Madagascar. Interviews with communities in the Project Zone, as well as the DGF confirmed the importance of the project area for drinking water and agricultural irrigation. In addition the hydroelectric dam at Ranomafana is fed almost exclusively by the COFAV corridor and provides essential electricity to the region.

Conformance - Y

Indicator 8.5 - Areas that are fundamental for meeting the basic needs of local communities (e.g., for essential food, fuel, fodder, medicines or building materials without readily available alternatives); and

While onsite, the audit team was able to confirm that the communities near the Project Area are subsistence driven. Villagers in the Project Zone informed the audit team that the Project Area provides essential resources for their livelihoods. Additionally, the audit team was able to observe the collection of plants and fuel wood, as well as hunting and fishing taking place in the sustainable use zones. Finally, it was obvious to the audit team that the lack of other forested areas near the Project Zone has resulted in total reliance on the Project Area by the local communities.

Conformance - Y

Indicator 8.6 -Areas that are critical for the traditional cultural identity of communities (e.g., areas of cultural, ecological, economic or religious significance identified in collaboration with the communities).

The audit team was able to interview representatives from communities throughout the Project Zone. Community members verified the claims in the Project documentation that the Project meets the criteria of this indicator. Additionally, community members informed the audit team that the forest includes many burial sites of their ancestors, as well as that all mountain peaks are considered scared.

Conformance - Y


2.2.2. G2 – Baseline Projections A baseline Projection is a description of expected conditions in the Project Zone in the absence of Project activities. The Project impacts will be measured against this ‘without-Project’ reference scenario. Indicators The Project Proponents must develop a defensible and well-documented ‘without-Project’ reference scenario that must: G2 - Baseline Projections Indicator 1 - Describe the most likely land-use scenario in the absence of the Project following IPCC 2006 GL for AFOLU or a more robust and detailed methodology, describing the range of potential land use scenarios and the associated drivers of GHG emissions and justifying why the land-use scenario selected is most likely.

As described in the PDD, the steps 4 and 5 of the VCS VM0015 Methodology were used to determine the baseline scenario. The audit team affirms that this methodology is a more robust and detailed methodology than the IPCC 2006 GL for AFOLU, as it provides guidance that is specific to reforestation projects. The audit team was able to confirm that the methodology was appropriately applied and verified the assertion that slash and burn agriculture (tavy) was the most likely scenario in the absence of the project. This was not only obvious to the audit team while onsite, but also supported in the scientific literature (Styger et al., 2007, 2009). In addition, interviews with members of the DGF resulted in an understanding that AUD activities have been implemented in the past, however current funding is not sufficient to support such activities. The audit team was also provided with literature consistent with these claims (MacKinnon et al., 2009; World Bank 2010). The PDD clearly provides the rationale that would support tavy as the most likely land-use scenario and every interview with Project stakeholders confirmed this analysis. Further details regarding the work undertaken to confirm the most likely land-use scenario in the absence of the Project reported in the PDD can be found within the VCS validation report for the project.

Conformance - Y


Indicator 2 - Document that Project benefits would not have occurred in the absence of the Project, explaining how existing laws or regulations would likely affect land use and justifying that the benefits being claimed by the Project are truly ‘additional’ and would be unlikely to occur without the Project.

The audit team confirms that the project appropriately applied the VCS Tool VT0001 “Tool for the Demonstration and Assessment of Additionality in VCS Agriculture, Forestry and Other Land Use (AFOLU) Project Activities” in assessing that Project benefits would not have occurred in the absence of the Project. Similarly, the leakage mitigation activities were developed in cooperation with affected communities in the Project Zone and would not have occurred in the absence of the Project as they are not required by law. The audit team verified conformance to the requirements of this indicator through interviews with CI, the DGF, and community representatives of the Project Zone. Further details regarding the work undertaken to confirm the additionality reported in the PDD can be found within the VCS validation report for the project.

Conformance - Y

Indicator 3 - Calculate the estimated carbon stock changes associated with the ‘without Project’ reference scenario described above. This requires estimation of carbon stocks for each of the land-use classes of concern and a definition of the carbon pools included, among the classes defined in the IPCC 2006 GL for AFOLU.19 The timeframe for this analysis can be either the Project lifetime (see G3) or the Project GHG accounting period, whichever is more appropriate. Estimate the net change in the emissions of non-CO2 GHG emissions such as CH4 and N2O in the ‘without Project’ scenario. Non-CO2 gases must be included if they are likely to account for more than 5% (in terms of CO2-equivalent) of the Project’s overall GHG impact over each monitoring period. Projects whose activities are designed to avoid GHG emissions (such as those reducing emissions from deforestation and forest degradation (REDD), avoiding conversion of non-forest land, or certain improved forest management Projects) must include an

The estimated carbon stock changes associated with the ‘without project’ scenario have been estimated, for the Project GHG accounting period, using the VCS methodology VM0015 “Methodology of Avoided Unplanned Deforestation (AUD).” The audit team affirms that this methodology satisfies the requirements of this indicator. Through a thorough review of relevant spreadsheets, and other relevant information, the audit team confirmed the accuracy of the values reported within the PDD. Specifically, the Non-CO2 emissions, such as CH4, were determined to be appropriately estimated through a review of fire emissions using IPCC default values for the fraction of vegetation burned. The estimate of Non-CO2 emissions is in line with the requirements of the selected VCS methodology. Finally, the audit team can confirm that the relevant drivers and rates of deforestation were adequately justified by the remote sensing analysis and supported in the scientific literature (Styger et al., 2007, 2009). Additionally, the procedures for performing these


analysis of the relevant drivers and rates of deforestation and/or degradation and a description and justification of the approaches, assumptions and data used to perform this analysis. Regional-level estimates can be used at the Project’s planning stage as long as there is a commitment to evaluate locally-specific carbon stocks and to develop a Project-specific spatial analysis of deforestation and/or degradation using an appropriately robust and detailed carbon accounting methodology before the start of the Project.

analyses are consistent with the requirements of the methodology. Further details regarding the work undertaken to confirm the estimated carbon stock change reported in the PDD can be found within the VCS validation report for the project. Thus, the Project is in conformance with the requirements of this indicator.

Conformance - Y Indicator 4 - Describe how the ‘without Project’ reference scenario would affect communities in the Project Zone, including the impact of likely changes in water, soil and other locally important ecosystem services.

The Project documentation provides an adequate description of how the ‘without Project’ scenario would affect communities in the Project Zone. The audit team found this description to be in agreement with observations made by the audit team onsite.

Conformance - Y Indicator 5 - Describe how the ‘without Project’ reference scenario would affect biodiversity in the Project Zone (e.g., habitat availability, landscape connectivity and threatened species).

The PDD provides an adequate description of biodiversity in the ‘without project’ scenario. During the site visit, the audit team observed an array of tavy stages in the Project Zone from previous deforestation events. The audit team agrees that biodiversity is promoted with larger swaths of intact forest and that fragmentation, through tavy, negatively impacts biodiversity. Interviews with CI and the Valbio Biodiversity Centre also supported this claim in the PDD.

Conformance - Y

2.2.3. G3 – Project Design and Goals The Project must be described in sufficient detail so that a third-party can adequately evaluate it. Projects must be designed to minimize risks to the expected climate, community and biodiversity benefits and to maintain those benefits beyond the life of the Project. Effective local participation in Project design and implementation is key to optimizing multiple benefits, equitably and sustainably. Projects that operate in a transparent manner build confidence with stakeholders and outside parties and enable them to contribute more effectively to the Project. G3 - Project Design and Goals Indicator 1 - Provide a summary of the The PDD provides an adequate summary of the


Project’s major climate, community and biodiversity objectives.

Projects’ major climate, community, and biodiversity objectives. The summary is consistent with the interviews with the Project Proponent and supported by interviews with community members and other Project participants such as the DGF during the site visit.

Conformance - Y

Indicator 2 - Describe each Project activity with expected climate, community and biodiversity impacts and its relevance to achieving the Project’s objectives.

Evidence presented during the office meeting in Antananarivo and observations in and around the Project Zone was consistent with the Project activity descriptions provided in the PDD. Whereas, many communities have yet to receive grant funding from the project, activities described in the PDD are consistent with the needs of the communities. Conversations with community members also affirmed claims by CI that the Project has aimed to enhance livelihoods in the Project Zone.

Conformance - Y

Indicator 3 - Provide a map identifying the Project location and boundaries of the Project Area(s), where the Project activities will occur, of the Project Zone and of additional surrounding locations that are predicted to be impacted by Project activities (e.g. through leakage).

The audit team confirmed the locations of the Project Area, Project Zone, and surrounding locations that are predicted to be impacted by Project activities (through leakage) via discussions with the CI team, site reconnaissance, and interviews with Project stakeholders. Supported by information provided in the PDD, these interviews are consistent with the professional knowledge of the audit team. The Project was verified to be in conformance with the requirements of this indicator.

Conformance - Y Indicator 4 - Define the Project lifetime and GHG accounting period and explain and justify any differences between them. Define an implementation schedule, indicating key dates and milestones in the Project’s development.

The definitions of the Project lifetime and the GHG accounting period provided in the PDD were determined to be adequate for adhering to this CCB requirement. The Project start date indicates the date of the first consultations about the project with local communities and government officials. The PDD states that the GHG accounting period begins in 1 November, 2008. The GHG accounting period and project lifetime are both set at 30 years. The proposed implementation schedule is consistent with the current management plan for the project. The audit team can confirms that certain milestones have been achieved, while future milestones are consistent with the current financial

Conformance - Y


budget and consistent with the professional knowledge of the audit team, as well as the expectations of the government of Madagascar.

Indicator 5 - Identify likely natural and human-induced risks to the expected climate, community and biodiversity benefits during the Project lifetime and outline measures adopted to mitigate these risks.

Several risks have been identified by the Project Proponent and each has been mitigated through a detailed plan. Both the risks and mitigation plans as detailed in the PDD were verified to be appropriate and sufficient through professional judgment, interviews, and observations during the site visit. Further details regarding the work undertaken to confirm the likely natural and human induced risks reported in the PDD can be found within the VCS validation report for the project.

Conformance - Y

Indicator 6 - Demonstrate that the Project design includes specific measures to ensure the maintenance or enhancement of the high conservation value attributes identified in G1 consistent with the precautionary principle.

The PDD contains an appropriate description of the measures to ensure the maintenance or enhancement of the high conservation value attributes identified in G1. The audit team agrees that the measures described in the PDD will be sufficient to ensure the maintenance or enhancement of high conservation value attributes.

Conformance - Y Indicator 7 - Describe the measures that will be taken to maintain and enhance the climate, community and biodiversity benefits beyond the Project lifetime.

The PDD provides an adequate description of the measures that will be taken to maintain and enhance the climate, community, and biodiversity benefits beyond the Project lifetime. The goal of the Project is to ensure the benefits in these three areas in perpetuity and the measures as well as the potential risks to these measures are well-documented in the PDD.

Conformance - Y

Indicator 8 - Document and defend how communities and other stakeholders potentially affected by the Project activities have been identified and have been involved in Project design through effective consultation, particularly with a view to optimizing community and stakeholder benefits, respecting local customs and values and maintaining high conservation values. Project developers must document stakeholder dialogues and indicate if and how the Project proposal was revised based on such input. A plan must be developed to continue communication and consultation between Project managers and all

The audit team reviewed the PDD and interviewed several Project participants and community members about the manner and process for which stakeholders were consulted about the Project. The team was provided with evidence from planning meetings involving stakeholders such as documentation of meeting minutes, lists of attendees, and logs of interactions with communities. CI also spoke in great detail about community engagement and community participation in reforestation and livelihood enhancement activities. It was clear that stakeholders were informed and broadly engaged using socially and culturally appropriate methods. The Project Proponent


community groups about the Project and its impacts to facilitate adaptive management throughout the life of the Project.

frequently visits the villages within the Project Zone and meetings are widely publicized, conform to social and cultural practices of the region, and are held in the relevant local language (Malagasy). Community members are encouraged to provide feedback to CI orally and this feedback was recorded and duly considered in the design and implementation of the Project. During the site visit, members of each of the communities indicated that they were consulted and their input was considered in the design and implementation of the Project. Additionally, CI regularly visits the communities in the Project Zone and community members confirmed that the lines of communication are open and welcomed by the Project Team.

Conformance - Y

Indicator 9 - Describe what specific steps have been taken, and communications methods used, to publicize the CCBA public comment period to communities and other stakeholders and to facilitate their submission of comments to CCBA. Project Proponents must play an active role in distributing key Project documents to affected communities and stakeholders and hold widely publicized information meetings in relevant local or regional languages.

During onsite activities, which included interviews with representatives from villages within the Project Zone, the audit team was able to confirm that CI visited communities in the Project Zone and informed them of the CCBA public comment period. Key Project documents were made available to Project stakeholders and discussions about the Project and the CCBA public comment period was presented in the locally relevant language. The work performed by the project was obvious in the comments submitted to the CCBA. Whereas many community representatives were knowledgeable of the public comment period, the lack of understanding by the average villager raised concern with the audit team. Discussions between the project and audit teams resulted in the project opening a second public comment period to ensure a strong working knowledge among all community members. Upon completion of the second comment period, a local audit team member re-evaluated the level of publicity of the comment period and confirmed that the project had widely publicized the CCBA public comment period and addressed a number of new comments received during that time period. While the audit team holds some reservations about the ability of the project to address every concern among

Conformance – Y


communities in the Project Zone, the audit team also understands that this is more a function the customary ways in which information is disseminated from community elders to other members and not a failure of the project. The Project is in conformance with the requirements of this indicator.

Indicator 10 - Formalize a clear process for handling unresolved conflicts and grievances that arise during Project planning and implementation. The Project design must include a process for hearing, responding to and resolving community and other stakeholder grievances within a reasonable time period. This grievance process must be publicized to communities and other stakeholders and must be managed by a third party or mediator to prevent any conflict of interest. Project management must attempt to resolve all reasonable grievances raised, and provide a written response to grievances within 30 days. Grievances and Project responses must be documented.

The processes for handling unresolved conflicts and grievances that arise during Project planning and implementation and are described in the PDD, are adequate to adequate for meeting the criteria of this indicator. Given the history of community outreach and suites of grievance processes over the years; however, it was apparent to the audit team that the process was not clear to a number of community members during the initial site visit by the audit team. Based on the findings from the initial site visit, the audit team requested that the project team conduct community visits to re-educate communities on the process for handling unresolved conflicts and grievances that arise during Project planning and implementation. Upon completion of the second comment period, a local audit team member re-evaluated the level of understanding of the grievance process and confirmed that the process was in place and being used by communities in the Project Zone. While the audit considers the project in conformance with this indicator currently, there is concern that ongoing communication is necessary to ensure conformance in the future.

Conformance - Y

Indicator 11 - Demonstrate that financial mechanisms adopted, including Projected revenues from emissions reductions and other sources, are likely to provide an adequate flow of funds for Project implementation and to achieve the anticipated climate, community and biodiversity benefits.

During the site visit, the audit team reviewed the grant funding contracts, most notably with the World Bank and the Dell corporation and verified that there would be an adequate flow of funds for Project implementation and to achieve the Project benefits stated in the PDD. In addition to the grant funding, the audit team was able to review the project financial model used to budget project implementation and confirms that the projected revenues from emission Conformance - Y


reductions are conservative based on current carbon market trends. Further details regarding the financial mechanisms reported in the PDD can be found within the VCS validation report for the project.

2.2.4. G4 – Management Capacity and Best Practices The success of a Project depends upon the competence of the implementing management team. Projects that include a significant capacity-building (training, skill building, etc.) component are more likely to sustain the positive outcomes generated by the Project and have them replicated elsewhere. Best practices for Project management include: local stakeholder employment, worker rights, worker safety and a clear process for handling grievances. G4 - Management Capacity and Best Practices Indicator 1 -Identify a single Project Proponent which is responsible for the Project’s design and implementation. If multiple organizations or individuals are involved in the Project’s development and implementation the governance structure, roles and responsibilities of each of the organizations or individuals involved must also be described.

The Project Proponent for the COFAV Forest Corridor is the Government of Madagascar; however, project management has been delegated to Conservation International (CI). CI has a long history in Madagascar and maintains good relations with the local and national governments, natural resource agencies, and other Project stakeholders, who collaborate on the Project design and implementation.

Conformance – Y Indicator 2 - Document key technical skills that will be required to implement the Project successfully, including community engagement, biodiversity assessment and carbon measurement and monitoring skills. Document the management team’s expertise and prior experience implementing land management Projects at the scale of this Project. If relevant experience is lacking, the proponents must either demonstrate how other organizations will be partnered with to support the Project or have a recruitment strategy to fill the gaps.

The key technical skills required for Project implementation are appropriately documented within the PDD. The audit team confirmed that the experience of the CI team, as documented within the PDD, is sufficient to carry out all necessary tasks for Project success. CI Has successfully designed and implemented large scale carbon projects and has been working towards conservation on a global scale for 25 years. Interviews with the DGF confirmed that project management would not be transferred from CI until such a time that a suitable candidate was available for a transfer of responsibilities.

Conformance - Y


Indicator 3 - Include a plan to provide orientation and training for the Project’s employees and relevant people from the communities with an objective of building locally useful skills and knowledge to increase local participation in Project implementation. These capacity building efforts should target a wide range of people in the communities, including minority and underrepresented groups. Identify how training will be passed on to new workers when there is staff turnover, so that local capacity will not be lost.

The training and orientation plan described in the PDD is consistent with other documentation reviewed throughout the audit process (e.g. training manuals and presentations, the Project’s Operations, Health and Safety Manual, etc.). The audit team was also able to evaluate the plan through interviews with community members who were trained as chef sectors (community envoys to CI). The statements from these individuals support the Project Proponent’s claim that that the training and orientation plan will likely result in the successful implementation of the Project. In addition, the audit team was able to review the terms of employment for project employees on file in the CI Fianarantsoa office, confirming claims that training is job specific.

Conformance - Y

Indicator 4 - Show that people from the communities will be given an equal opportunity to fill all employment positions (including management) if the job requirements are met. Project Proponents must explain how employees will be selected for positions and where relevant, must indicate how local community members, including women and other potentially underrepresented groups, will be given a fair chance to fill positions for which they can be trained.

During the site visit, the audit team encountered many situations in which community members were displeased with the lack of job opportunities; however, this is not unexpected given the large populations and few numbers of project employment. The audit team conducted interviews with community representatives from six villages and it was confirmed that representatives and other Project stakeholders will be given an equal opportunity to fill all employment positions. In addition, CI provided the audit team with the procedures for selecting employees from applicant pools, confirming adherence to the requirements of this indicator. In all, over 70% of the current project staff is local community members.

Conformance - Y

Indicator 5 - Submit a list of all relevant laws and regulations covering worker’s rights in the host country. Describe how the Project will inform workers about their rights. Provide assurance that the Project meets or exceeds all applicable laws and/or regulations covering worker rights and, where relevant, demonstrate how compliance is achieved

A thorough list of relevant laws and regulations covering worker’s rights in Madagascar was included in the PDD. In addition, the audit team was able to access the Project’s Operations, Health and Safety Manual, which includes workers’ rights through the CI website SCS employed a local expert to review this list and it was confirmed that the Project design is in conformance with all relevant worker’s rights and protections. Conformance - Y


Indicator 6 - Comprehensively assess situations and occupations that pose a substantial risk to worker safety. A plan must be in place to inform workers of risks and to explain how to minimize such risks. Where worker safety cannot be guaranteed, Project Proponents must show how the risks will be minimized using best work practices.

The audit team was able to confirm that the Project’s Operations, Health and Safety Manual and trainings were sufficient to meet this requirement. This was confirmed through interviews with Project employees during the visits to various villages in the Project Zone.

Conformance - Y Indicator 7 - Document the financial health of the implementing organization(s) to demonstrate that financial resources budgeted will be adequate to implement the Project.

The audit team confirmed the financial health of CI through a review of the 2012 annual report. Additional assurance was gained through the annual financial auditing CI undergoes by a third-party auditing firm. During the office meeting in Antananarivo, the audit team was able to view copies of the grant funding contracts, which demonstrate that adequate financial resources are in place to implement the Project. The result of these reviews is that the Project is in conformance with the requirement of this indicator. Further details regarding the work undertaken to confirm the financial health of the implementing organization(s) reported in the PDD can be found within the VCS validation report for the project.

Conformance - Y

2.2.5. G5 – Legal Status and Property Rights The Project must be based on a solid legal framework (e.g., appropriate contracts are in place) and the Project must satisfy applicable planning and regulatory requirements. During the Project design phase, the Project Proponents should communicate early on with relevant local, regional and national authorities in order to allow adequate time to earn necessary approvals. The Project design should be sufficiently flexible to accommodate potential modifications that may arise as a result of this process. In the event of unresolved disputes over tenure or use rights to land or resources in the Project Zone, the Project should demonstrate how it will help to bring them to resolution so that there are no unresolved disputes by the start of the Project.


Indicators G5 - Legal Status and Property Rights Indicator 1 - Submit a list of all relevant national and local laws and regulations in the host country and all applicable international treaties and agreements. Provide assurance that the Project will comply with these and, where relevant, demonstrate how compliance is achieved.

The audit team, in coordination with a local technical expert, was able to confirm that the list of laws applicable to the Project provided in the PDD was both exhaustive and relevant. Additionally, during interviews with government officials, the audit team discussed the national and local laws related to forest land and confirmed that the Project is in conformance with this indicator. Conformance - Y

Indicator 2 - Document that the Project has approval from the appropriate authorities, including the established formal and/or traditional authorities customarily required by the communities.

During the site visit, the audit team identified the government of Madagascar as the project proponent and that the forest lands in the project area are indeed owned by the government therefore establishing approval from the appropriate authorities. Additionally, during the visits to several villages in the Project Zone, the approval from traditional authorities such as kings and elders was also confirmed.

Conformance - Y

Indicator 3 - Demonstrate with documented consultations and agreements that the Project will not encroach uninvited on private property, community property, or government property and has obtained the free, prior, and informed consent of those whose rights will be affected by the Project.

The Project occurs on lands which are owned by the government of Madagascar. CI has undertaken documented consultations with each of the villages in the Project Zone. Moreover, the boundaries of the project were determined through community consultation, specifically to avoid such instances. In addition, CI intends to sign conservation agreements with each of the participating villages to define the roles and responsibilities of each party during the Project lifetime and to transfer management of the leakage management zones.

Conformance - Y


Indicator 4 - Demonstrate that the Project does not require the involuntary relocation of people or of the activities important for the livelihoods and culture of the communities. If any relocation of habitation or activities is undertaken within the terms of an agreement, the Project Proponents must demonstrate that the agreement was made with the free, prior, and informed consent of those concerned and includes provisions for just and fair compensation.

As previously stated, the Project Area is located entirely on government property, so the Project will not require the relocation of peoples or activities. The audit team verified this through interviews with the Project Proponent, CI, and through discussions with village members.

Conformance - Y Indicator 5 - Identify any illegal activities that could affect the Project’s climate, community or biodiversity impacts (e.g., logging) taking place in the Project Zone and describe how the Project will help to reduce these activities so that Project benefits are not derived from illegal activities.

The main illegal activity taking place is tavy. The project is designed to combat this practice through improved agriculture and alternative livelihoods. Whereas, the audit team cannot say definitively that illegal logging does not take place on the project, interviews with community members and visits to random portions of the Project Area revealed that illegal logging was not occurring at such a scale as to affect the Project’s climate, community or biodiversity impacts. In addition, the audit team observed many of the lumber mills around the Project Zone and can confirm that the majority of wood products are eucalyptus and pine from plantations in the region and not hardwoods from the Project Area The audit team affirms that, given the circumstances surrounding the Project, there is little to no likelihood that Project benefits would be derived from illegal activities. The audit team also observed that the Project Proponent’s frequent visits to the communities in the Project Zone would promote the identification and communication about the existence of illegal activities, should they occur. Given the above, the Project is in conformance with the requirements of this indicator.

Conformance - Y


Indicator 6 - Demonstrate that the Project Proponents have clear, uncontested title to the carbon rights, or provide legal documentation demonstrating that the Project is undertaken on behalf of the carbon owners with their full consent. Where local or national conditions preclude clear title to the carbon rights at the time of validation against the Standards, the Project Proponents must provide evidence that their ownership of carbon rights is likely to be established before they enter into any transactions concerning the Project’s carbon assets.

As previously stated, the Project Area is owned by the project proponent (government of Madagascar), and therefore, the project proponents clear, uncontested title to the carbon rights

Conformance - Y 2.3. Climate Section 2.3.1. CL1 – Net Positive Climate Impacts The Project must generate net positive impacts on atmospheric concentrations of greenhouse gases (GHGs) over the Project lifetime from land use changes within the Project boundaries. Indicators CL1 - Net Positive Climate Impacts Indicator 1 - Estimate the net change in carbon stocks due to the Project activities using the methods of calculation, formulae and default values of the IPCC 2006 GL for AFOLU or using a more robust and detailed methodology. The net change is equal to carbon stock changes with the Project minus carbon stock changes without the Project (the latter having been estimated in G2). This estimate must be based on clearly defined and defendable assumptions about how Project activities will alter GHG emissions or carbon stocks over the duration of the Project or the Project GHG accounting period.

The estimated net change in carbon stocks due to Project activities have been estimated, for the Project GHG accounting period, using the VCS methodology VM0015 “Methodology of Avoided Unplanned Deforestation (AUD).” The audit team confirmed that this methodology is a more robust and detailed methodology than the IPCC 2006 GL for AFOLU, as it provides guidance that is specific to reforestation Projects. In addition, the methodology is sufficiently rigorous to require clearly defined and defendable assumptions about how Project activities will alter GHG emissions or carbon stocks over the duration of the Project GHG accounting period. Through a thorough review of relevant spreadsheets, and other relevant information, the audit team confirmed the accuracy of the values reported within the PDD. Further details regarding the work undertaken to confirm the estimate of the net change in carbon stocks due to the Project activities reported in the PDD can be found within the VCS validation


report for the project.

Conformance - Y Indicator 2 - Estimate the net change in the emissions of non-CO2 GHG emissions such as CH4 and N2O in the with and without Project scenarios if those gases are likely to account for more than a 5% increase or decrease (in terms of CO2-equivalent) of the Project’s overall GHG emissions reductions or removals over each monitoring period.

As previously stated (G2.3), the summary provided in the PDD is consistent with the requirements of the methodology (VM0015 section 6.2 and 7.2). CH4 from slash and burn agriculture is accounted for in the project scenario. Further details regarding the work undertaken to confirm the estimate of the net change in emissions of non-CO2 GHG emissions such as CH4 and N2O in the with and without Project scenarios reported in the PDD can be found within the VCS validation report for the project. The Project meets the requirements of this indicator.

Conformance - Y

Indicator 3 - Estimate any other GHG emissions resulting from Project activities. Emissions sources include, but are not limited to, emissions from biomass burning during site preparation, emissions from fossil fuel combustion, direct emissions from the use of synthetic fertilizers, and emissions from the decomposition of N-fixing species.

Whereas, some communities will receive livestock as part of the project activities/community benefits, increases in non-CO2 emissions are expected as a result. Furthermore, the use of fertilizer should not increase above baseline levels. The Project meets the requirements of this indicator.

Conformance - Y Indicator 4 - Demonstrate that the net climate impact of the Project is positive. The net climate impact of the Project is the net change in carbon stocks plus net change in non-CO2 GHGs where appropriate minus any other GHG emissions resulting from Project activities minus any likely Project-related unmitigated negative offsite climate impacts (see CL2.3).

A review of carbon calculations by the audit team verified that the net climate impact of the Project is positive. The audit team was able to confirm that the calculations were undertaken in conformance with the selected VCS methodology. The accuracy of the reported values was confirmed through a review of Project Proponent-supplied spreadsheets, and other documentation. Further details regarding the work undertaken to confirm that the net climate impact of the project is positive as reported in the PDD can be found within the VCS validation report for the project.

Conformance - Y


Indicator 5 - Specify how double counting of GHG emissions reductions or removals will be avoided, particularly for offsets sold on the voluntary market and generated in a country with an emissions cap.

The audit team can confirm that the project has not been registered under any other carbon accounting standard other than the VCS. Interviews with government officials confirmed that Madagascar has no national emissions cap. The Project is in conformance with the requirements of this indicator.

Conformance - Y

2.3.2. CL2 – Offsite Climate Impacts (‘Leakage’) The Project Proponents must quantify and mitigate increased GHG emissions that occur beyond the Project Area and are caused by Project activities (commonly referred to as ‘leakage’). Indicators CL2 - Offsite Climate Impacts (Leakage) Indicator 1 - Determine the types of leakage that are expected and estimate potential offsite increases in GHGs (increases in emissions or decreases in sequestration) due to Project activities. Where relevant, define and justify where leakage is most likely to take place.

The audit team can confirm that market leakage is not applicable to the project, as no commercial harvesting takes place in the Project Area. Activity shifting leakage is expected as a result of project activities. While onsite, the audit team was able to observe the process for determining and justifying where leakage is most likely to take place. The process for monitoring leakage is the same process for monitoring deforestation in the Project Area and is consistent with the requirements of the methodology. Further details regarding the work undertaken to confirm the estimated leakage reported in the PDD can be found within the VCS validation report for the project.

Conformance - Y

Indicator 2 - Document how any leakage will be mitigated and estimate the extent to which such impacts will be reduced by these mitigation activities.

The audit team confirmed that leakage will be monitored during the Project lifetime. Should such leakage occur, the leakage will be measured and assessed during monitoring for CL2. In addition, the audit team was able to review conservation agreements for which communities are paid for forest conservation, as well as provided with support to develop alternative livelihoods to tavy. Further details regarding the work undertaken to confirm the leakage mitigation reported in the PDD can be found within the VCS validation report for the project. The Project is in conformance with the requirements of this indicator.

Conformance - Y


Indicator 3 - Subtract any likely Project-related unmitigated negative offsite climate impacts from the climate benefits being claimed by the Project and demonstrate that this has been included in the evaluation of net climate impact of the Project (as calculated in CL1.4).

The audit team reviewed relevant spreadsheets and confirmed that the summary provided in the PDD has been calculated correctly and that any unmitigated negative offsite climate impacts have been subtracted from the net climate impact of the project. Further details regarding the work undertaken to confirm the project emissions reported in the PDD can be found within the VCS validation report for the project. The Project is in conformance with the requirements of this indicator.

Conformance - Y

Indicator 4 - Non-CO2 gases must be included if they are likely to account for more than a 5% increase or decrease (in terms of CO2-equivalent) of the net change calculations (above) of the Project’s overall off-site GHG emissions reductions or removals over each monitoring period.

As previously stated, leakage from project activities are monitored in the same fashion as deforestation in the Project Area. The audit team reviewed relevant spreadsheets and confirmed that the summary provided in the PDD has been calculated correctly and that any unmitigated negative offsite climate impacts have been subtracted from the net climate impact of the project. The Project is in conformance with the requirements of this indicator. Further details regarding the work undertaken to confirm the Non-CO2 gases reported in the PDD can be found within the VCS validation report for the project

Conformance - Y

2.3.3. CL3 – Climate Impact Monitoring Before a Project begins, the Project Proponents must have an initial monitoring plan in place to quantify and document changes (within and outside the Project boundaries) in Project-related carbon pools, Project emissions, and non-CO2 GHG emissions if appropriate. The monitoring plan must identify the types of measurements, the sampling method, and the frequency of measurement. Since developing a full monitoring plan can be costly, it is accepted that some of the plan details may not be fully defined at the design stage, when Projects are being validated against the Standards. This is acceptable as long as there is an explicit commitment to develop and implement a monitoring plan. CL3 - Climate Impact Monitoring


Indicator 1 - Develop an initial plan for selecting carbon pools and non- CO2 GHGs to be monitored, and determine the frequency of monitoring. Potential pools include aboveground biomass, litter, dead wood, belowground biomass, wood products, soil carbon and peat. Pools to monitor must include any pools expected to decrease as a result of Project activities, including those in the region outside the Project boundaries resulting from all types of leakage identified in CL2. A plan must be in place to continue leakage monitoring for at least five years after all activity displacement or other leakage causing activity has taken place. Individual GHG sources may be considered ‘insignificant’ and do not have to be accounted for if together such omitted decreases in carbon pools and increases in GHG emissions amount to less than 5% of the total CO2 -equivalent benefits generated by the Project. Non-CO2 gases must be included if they are likely to account for more than 5% (in terms of CO2 -equivalent) of the Project’s overall GHG impact over each monitoring period. Direct field measurements using scientifically robust sampling must be used to measure more significant elements of the Project’s carbon stocks. Other data must be suitable to the Project site and specific forest type.

The audit team affirms that the Project Proponent has developed an initial monitoring plan for selecting carbon pools and non-CO2 GHGs, which includes descriptions of direct measurements and frequencies of data collection. Overall, the initial monitoring plan conforms to the requirements of this indicator. Further details regarding the work undertaken to confirm the climate monitoring plan reported in the PDD can be found within the VCS validation report for the project.

Conformance - Y

Indicator 2 - Commit to developing a full monitoring plan within six months of the Project start date or within twelve months of validation against the Standards and to disseminate this plan and the results of monitoring, ensuring that they are made publicly available on the internet and are communicated to the communities and other stakeholders.

The full climate monitoring plan is described in the PDD and will be disseminated along with the results to each village in the Project Zone as well as to Project stakeholders. Further details regarding the work undertaken to confirm the climate monitoring plan reported in the PDD can be found within the VCS validation report for the project.

Conformance - Y


2.4. Community Section 2.4.1. CM1 – Net Positive Community Impacts The Project must generate net positive impacts on the social and economic well-being of communities and ensure that costs and benefits are equitably shared among community members and constituent groups during the Project lifetime. Projects must maintain or enhance the High Conservation Values (identified in G1) in the Project Zone that are of particular importance to the communities’ well-being. CM1 - Net Community Impacts Indicator 1 - Use appropriate methodologies to estimate the impacts on communities, including all constituent socio-economic or cultural groups such as indigenous peoples (defined in G1), resulting from planned Project activities. A credible estimate of impacts must include changes in community well-being due to Project activities and an evaluation of the impacts by the affected groups. This estimate must be based on clearly defined and defendable assumptions about how Project activities will alter social and economic well-being, including potential impacts of changes in natural resources and ecosystem services identified as important by the communities (including water and soil resources), over the duration of the Project. The ‘with Project’ scenario must then be compared with the ‘without Project’ scenario of social and economic well-being in the absence of the Project (completed in G2). The difference (i.e., the community benefit) must be positive for all community groups.

The audit team affirms that the methodologies for estimating the impacts of the Project on communities, such as Land Use Planning workshops and socio-economic surveys, based on the Open Standards for the Practice of Conservation, are appropriate. The audit team reviewed the description of community impacts in the PDD along with other supporting documentation and confirmed that methodologies include criteria for assessing the effect of the Project on natural resources and ecosystem services identified to be important by communities in the Project Zone. The interviews with Project stakeholders and the villages in the Project Zone corroborate the assessment provided in the PDD.

Conformance - Y Indicator 2 - Demonstrate that no High Conservation Values identified in G1.8.4-6 will be negatively affected by the Project.

The PDD provides a description of the Project’s potential impact on High Conservation Values (HCVs), along with claims that’s the Project with result in net positive impacts for climate, community, and biodiversity. The audit team agreed that AUD Projects, by design, maintain and enhance HCVs.

Conformance - Y


2.4.2. CM2 – Offsite Stakeholder Impacts The Project Proponents must evaluate and mitigate any possible social and economic impacts that could result in the decreased social and economic well-being of the main stakeholders living outside the Project Zone resulting from Project activities. Project activities should at least ‘do no harm’ to the well-being of offsite stakeholders. CM2 - Offsite Stakeholder Impacts Indicator 1 - Identify any potential negative offsite stakeholder impacts that the Project activities are likely to cause.

The PDD claims that the Project is not expected to have a negative effect on offsite stakeholders. This assertion was verified during the site visit through interviews with the Project Proponent, villages in the Project Zone, and Project stakeholders, as well as a review of the Environmental and Social Impact Assessment (PGESS) utilized by the Project. Conformance - Y

Indicator 2 - Describe how the Project plans to mitigate these negative offsite social and economic impacts.

The nature of the project activities, as well as the size of the Project Zone leads the audit team to agree with the project that a mitigation plan is not necessary, given the lack of ‘offsite’ stakeholder impacts. The Project is in conformance with the requirements of this indicator.

Conformance - Y

Indicator 3 -Demonstrate that the Project is not likely to result in net negative impacts on the well-being of other stakeholder groups.

Through a review of the PDD and other documentation, as well as, conducting a site visit, it was verified that the Project as designed would not likely result in net negative impacts on the well-being of other stakeholder groups.

Conformance - Y 2.4.3. CM3 – Community Impact Monitoring The Project Proponents must have an initial monitoring plan to quantify and document changes in social and economic well-being resulting from the Project activities (for communities and other stakeholders). The monitoring plan must indicate which communities and other stakeholders will be monitored, and identify the types of measurements, the sampling method, and the frequency of measurement. Since developing a full community monitoring plan can be costly, it is accepted that some of the plan details may not be fully defined at the design stage, when Projects are being validated against the


Standards. This is acceptable as long as there is an explicit commitment to develop and implement a monitoring plan. CM3 - Community Impact Monitoring Indicator 1 - Develop an initial plan for selecting community variables to be monitored and the frequency of monitoring and reporting to ensure that monitoring variables are directly linked to the Project’s community development objectives and to anticipated impacts (positive and negative).

As reported in the PDD, an initial plan was established for selecting variables to be monitored, along with the frequency of monitoring and reporting. The PDD contains an initial monitoring plan that contains a list of indicators and methods for monitoring that will take place with respect to the community development objectives within the Project Zone. The audit team verified that the initial plan for monitoring is in accordance with the requirements of this indicator.

Conformance - Y Indicator 2 - Develop an initial plan for how they will assess the effectiveness of measures used to maintain or enhance High Conservation Values related to community well-being (G1.8.4-6) present in the Project Zone.

The initial plan for the monitoring of HCVs related to community well-being in the Project Zone is based on the initial baseline studies carried out in the PGESS in the Project Zone. The initial plan describes how these HCVs will be maintained or enhanced and is thus in conformance with the requirements of this indicator.

Conformance - Y Indicator 3 - Commit to developing a full monitoring plan within six months of the Project start date or within twelve months of validation against the Standards and to disseminate this plan and the results of monitoring, ensuring that they are made publicly available on the internet and are communicated to the communities and other stakeholders.

The PDD states that the full monitoring plan for the community component of the Project will be completed by the end 2013 and will be disseminated to each village in the Project Zone and to Project stakeholders. This plan is in accordance with the requirements of this indicator.

Conformance - Y 2.5. Biodiversity Section


2.5.1. B1 – Net Positive Biodiversity Impacts The Project must generate net positive impacts on biodiversity within the Project Zone and within the Project lifetime, measured against the baseline conditions. The Project should maintain or enhance any High Conservation Values (identified in G1) present in the Project Zone that are of importance in conserving globally, regionally or nationally significant biodiversity. Invasive species populations must not increase as a result of the Project, either through direct use or indirectly as a result of Project activities. Projects may not use genetically modified organisms (GMOs) to generate GHG emissions reductions or removals. GMOs raise unresolved ethical, scientific and socio-economic issues. For example, some GMO attributes may result in invasive genes or species. B1 - Net Positive biodiversity Impacts Indicator 1 -Use appropriate methodologies to estimate changes in biodiversity as a result of the Project in the Project Zone and in the Project lifetime. This estimate must be based on clearly defined and defendable assumptions. The ‘with Project’ scenario should then be compared with the baseline ‘without Project’ biodiversity scenario completed in G2. The difference (i.e., the net biodiversity benefit) must be positive.

As described in the PDD, the wealth of information provided in the literature (MEF, 2010, Brand and Pfund 1998, Styger et al., 2007, 2009) and the inherent relationship between forest connectivity and biodiversity will serve as the baseline for gauging changes in biodiversity throughout the life of the project. Utilizing monitoring of deforestation, paired with the continued presence of CI in the region will sufficiently estimate the changes in biodiversity as the result of the Project over its lifetime. The audit team agrees with the assumption by the Project Proponent that the avoiding deforestation will likely have a net positive impact on biodiversity.

Conformance - Y

Indicator 2 -Demonstrate that no High Conservation Values identified in G1.8.1-348 will be negatively affected by the Project.

As previously stated in this report (CM1.2), the PDD provides a description of the Projects impacts on High Conservation Values (HCVs), along with claims that the Project will result in net positive impacts for climate, community, and biodiversity. The audit team verified that this AUD Project will maintain and enhance HCVs.

Conformance - Y


Indicator 3 - Identify all species to be used by the Project and show that no known invasive species will be introduced into any area affected by the Project and that the population of any invasive species will not increase as a result of the Project.

The COFAV Forest Corridor will not involve reforestation and therefore no species will be introduced as part of the project activities. Addit

Conformance - Y Indicator 4 - Describe possible adverse effects of non-native species used by the Project on the region’s environment, including impacts on native species and disease introduction or facilitation. Project Proponents must justify any use of non-native species over native species.

Not Applicable.

Conformance - Y Indicator 5 - Guarantee that no GMOs will be used to generate GHG emissions reductions or removals.

The audit team verified the claims in the PDD that no GMOs will be used to generate GHG emissions reductions or removals. Observations made during the site visit supported these claims.

Conformance - Y 2.5.2. B2 – Offsite Biodiversity Impacts The Project Proponents must evaluate and mitigate likely negative impacts on biodiversity outside the Project Zone resulting from Project activities. Indicators B2 - Offsite Biodiversity Impacts Indicator 1 - Identify potential negative offsite biodiversity impacts that the Project is likely to cause.

The audit team agrees with the Project Proponent that AUD activities will enhance biodiversity and therefore, the project is not likely to result in negative offsite biodiversity impacts.

Conformance - Y Indicator 2 - Document how the Project plans to mitigate these negative offsite biodiversity impacts.

As previously stated, the Project is not likely to result in negative offsite biodiversity impacts. It should be noted, however, that the project is located between two protected areas to the south and a national park to the north. Through interviews with the project proponents, as well as the DGF confirmed that the Conformance - Y


project will be conducted in the context of Madagascar’s overall strategy for biodiversity protection and climate change mitigation.

Indicator 3 - Evaluate likely unmitigated negative offsite biodiversity impacts against the biodiversity benefits of the Project within the Project boundaries. Justify and demonstrate that the net effect of the Project on biodiversity is positive.

Given the lack of expected likely negative offsite biodiversity impacts, combined with the Project’s mitigation strategy, the audit team agrees that net effect of the project on biodiversity is positive. The Project is in accordance with the requirements of this indicator. Conformance - Y

2.5.3. B3 – Biodiversity Impact Monitoring The Project Proponents must have an initial monitoring plan to quantify and document the changes in biodiversity resulting from the Project activities (within and outside the Project boundaries). The monitoring plan must identify the types of measurements, the sampling method, and the frequency of measurement. Since developing a full biodiversity-monitoring plan can be costly, it is accepted that some of the plan details may not be fully defined at the design stage, when Projects are being validated against the Standards. This is acceptable as long as there is an explicit commitment to develop and implement a monitoring plan. B3 - Biodiversity Impact Monitoring Indicator 1 - Develop an initial plan for selecting biodiversity variables to be monitored and the frequency of monitoring and reporting to ensure that monitoring variables are directly linked to the Project’s biodiversity objectives and to anticipated impacts (positive and negative).

The audit team reviewed the initial monitoring plan and verified that the plan includes justification for the selected variables, as well as the temporal guidelines for implementation. This plan is in conformance with the requirements of this indicator.

Conformance - Y Indicator 2 - Develop an initial plan for assessing the effectiveness of measures used to maintain or enhance High Conservation Values related to globally, regionally or nationally significant biodiversity (G1.8.1-3) present in the Project Zone.

The audit team agrees that the plan to include HCV’s as conservation targets, as described in the PDD is sufficient for meeting the criteria of this indicator. The audit team interviewed members from the Valbio Biodiversity Centre in Ranamanofana on 12 June 2013, who further supported the plan for assessing effectiveness, as described in the PDD.

Conformance - Y


Indicator 3 - Commit to developing a full monitoring plan within six months of the Project start date or within twelve months of validation against the Standards and to disseminate this plan and the results of monitoring, ensuring that they are made publicly available on the internet and are communicated to the communities and other stakeholders.

The PDD states that the full monitoring plan for the biodiversity component of the Project is in development and will be disseminated to each village in the Project Zone and to Project stakeholders. This plan is in accordance with the requirements of this indicator.

Conformance - Y 2.6. Gold Level Section 2.6.1. GL1 – Climate Change Adaptation Benefits This Gold Level Climate Change Adaptation Benefits criterion identifies Projects that will provide significant support to assist communities and/or biodiversity in adapting to the impacts of climate change. Anticipated local climate change and climate variability within the Project Zone could potentially affect communities and biodiversity during the life of the Project and beyond. Communities and biodiversity in some areas of the world will be more vulnerable to the negative impacts of these changes due to: vulnerability of key crops or production systems to climatic changes; lack of diversity of livelihood resources and inadequate resources, institutions and capacity to develop new livelihood strategies; and high levels of threat to species survival from habitat fragmentation. Land-based carbon Projects have the potential to help local communities and biodiversity adapt to climate change by: diversifying revenues and livelihood strategies; maintaining valuable ecosystem services such as hydrological regulation, pollination, pest control and soil fertility; and increasing habitat connectivity across a range of habitat and climate types. Indicators GL1 - Climate Change Adaptation Benefits Indicator 1 -Identify likely regional climate change and climate variability scenarios and impacts, using available studies, and identify potential changes in the local land-use scenario due to these climate change scenarios in the absence of the Project.

The audit team was presented with scientific literature (MEFT 2008:2009; Harper et al 2007), including a national assessment of the impacts of climate change on “Madagascar’s Biodiversity and livelihoods.” The audit team confirms that the literature supports the claims of the PDD predicting the effect of climate change on the project area.

Conformance: N/A


Indicator 2 - Identify any risks to the Project’s climate, community and biodiversity benefits resulting from likely climate change and climate variability impacts and explain how these risks will be mitigated.

The audit team agrees with the claims in the PDD the greatest risk to project benefits from climate change will be to local communities. Observations onsite, combined with interviews with local communities confirmed that the improved agriculture activities will best mitigate these risks.

Conformance: N/A

Indicator 3 - Demonstrate that current or anticipated climate changes are having or are likely to have an impact on the well-being of communities51 and/or the conservation status of biodiversity52 in the Project Zone and surrounding regions.

The explanation provided in the PDD regarding the likely effects of climate change on the project zone and surrounding regions is well supported in the scientific literature. While onsite, the audit team interviewed local communities, as well as government officials, providing further support of these claims.

Conformance: N/A

Indicator 4 - Demonstrate that the Project activities will assist communities and/or biodiversity to adapt to the probable impacts of climate change.

Whereas, this indicator is best evaluated during the verification phase of the project, the audit team was able to witness activities occurring during the site visit that are clearly designed to assist communities and biodiversity adapt to the possible impacts of climate change. Successful forest protection has cascading impacts on the availability of resources such as food and water for both wildlife and people. In addition, improving agricultural techniques is resulting in improved food security.

Conformance: N/A

2.6.2. GL2 – Exceptional Community Benefits This Gold Level Exceptional Community Benefits criterion recognizes Project approaches that are explicitly pro-poor in terms of targeting benefits to globally poorer communities and the poorer, more vulnerable households and individuals within them. In so doing, land-based carbon Projects can make a significant contribution to reducing the poverty and enhancing the sustainable livelihoods of these groups. Given that poorer people typically have less access to land and other natural assets, this optional criterion requires innovative approaches that enable poorer households to participate effectively in land-based carbon activities. Furthermore, this criterion requires that the Project will ‘do no harm’ to poorer and more vulnerable members of the communities, by establishing that no member of a poorer or more vulnerable social group will experience a net negative impact on their well-being or rights. Indicators


GL2 - Exceptional Community Benefits Indicator 1 - Demonstrate that the Project Zone is in a low human development country OR in an administrative area of a medium or high human development country in which at least 50% of the population of that area is below the national poverty line.

The audit team confirmed the validity of the claims in the PDD that Madagascar is classified as a low human development country. The audit team independently accessed the latest UNDP Human Development Report and confirmed that Madagascar is indeed ranked 151 of 186 countries.

Conformance: N/A

Indicator 2 - Demonstrate that at least 50% of households within the lowest category of well-being (e.g., poorest quartile) of the community are likely to benefit substantially from the Project.

It is the professional judgment of the audit team that the process for determining the most vulnerable 50% of households in the project zone is appropriate for this indicator. While onsite it was apparent that the project activities substantially benefit these households. Community members in this category expressed a strong concern that the project is a necessary component of their livelihoods. Additionally, the project design includes guidelines to ensure community activities are prioritized to those communities in the greatest need.

Conformance: N/A

Indicator 3 -Demonstrate that any barriers or risks that might prevent benefits going to poorer households have been identified and addressed in order to increase the probable flow of benefits to poorer households.

Based on observations while onsite, it is apparent that the process for targeting the poorest and therefore the most vulnerable households is a direct function of understanding the barriers that would prevent the prioritization of this category of communities.

Conformance: N/A

Indicator 4 - Demonstrate that measures have been taken to identify any poorer and more vulnerable households and individuals whose well-being or poverty may be negatively affected by the Project, and that the Project design includes measures to avoid any such impacts. Where negative impacts are unavoidable, demonstrate that they will be effectively mitigated.

During the site visit the audit team reviewed the project design, as it pertains to potential negative impacts of the project on communities in the project zone. The projects’ social safeguards plan provides a detailed process for ensuring that no negative impacts will result as a product of project activities. Whereas, this indicator will better assessed during verification, it is the professional judgment of the audit team that plan, in design, contains measures to ensure that the most vulnerable households will not be negatively impacted by the project. Finally, in cases where negative impacts are unavoidable, the plan includes

Conformance: N/A


activities to compensate for such impacts. Indicator 5 - Demonstrate that community impact monitoring will be able to identify positive and negative impacts on poorer and more vulnerable groups. The social impact monitoring must take a differentiated approach that can identify positive and negative impacts on poorer households and individuals and other disadvantaged groups, including women.

As previously stated (CM3) the project has identified initial variables to be monitored and intends to implement the plan by the end of 2013. The community monitoring plan will focus on the communities with the greatest needs, as these communities will be prioritized for activities it is to be expected that positive and negative impacts of these communities will be identified.

Conformance: N/A 2.6.3. GL3 – Exceptional Biodiversity Benefits All Projects conforming to the Standards must demonstrate net positive impacts on biodiversity within their Project Zone. This Gold Level Exceptional Biodiversity Benefits criterion identifies Projects that conserve biodiversity at sites of global significance for biodiversity conservation. Sites meeting this optional criterion must be based on the Key Biodiversity Area (KBA) framework of vulnerability and irreplaceability. These criteria are defined in terms of species and population threat levels, since these are the most clearly defined elements of biodiversity. These scientifically based criteria are drawn from existing best practices that have been used, to date, to identify important sites for biodiversity in over 173 countries. Indicators Project Proponents must demonstrate that the Project Zone includes a site of high biodiversity conservation priority by meeting either the vulnerability or irreplaceability criteria defined below: GL3 - Exceptional Biodiversity Benefits Indicator 1 - Vulnerability - Regular occurrence of a globally threatened species (according to the IUCN Red List) at the site:

See Below

Indicator 1.1 - Critically Endangered (CR) and Endangered (EN) species - presence of at least a single individual; or

Whereas, the CCB Standards do not define the term “regular occurrence,” the audit team was able to verify that the list of species presented in the PDD is consistent with the current IUCN Red list. Additionally, the audit team interviewed biodiversity specialists from the Valbio Biodiversity Centre in Rananomafana (12 June 2013), who provided additional support for the presence of these species in the project area.

Conformance - Y


Indicator 1.2 - Vulnerable species (VU) - presence of at least 30 individuals or 10 pairs.

N/A

Conformance: N/A 3.0 CCB Validation Conclusion Following completion of SCS’ duly-accredited validation process, it is our opinion that the Reduced Emissions from Deforestation in the Ambositra-Vondrozo Forest Corridor (COFAV) – Madagascar Project conforms to the CCBA Climate, Community and Biodiversity Project Design Standards (Second Edition) at the Gold Level (See Appendix B).

3.1. Resolution of Any Non-conformance and Other Issues Any potential or actual non-conformance and other issues identified during the assessment process were resolved through the issuance of findings. The types of findings issued by SCS were characterized as follows: Non-Conformity Report (NCR): An NCR signified a material discrepancy with respect to a specific requirement. This type of finding could only be closed upon receipt by SCS of evidence indicating that the identified discrepancy had been corrected. Resolution of all open NCRs was a prerequisite for issuance of a verification statement. New Information Request (NIR): An NIR signified a need for supplementary information in order to determine whether a material discrepancy existed with respect to a specific requirement. Receipt of an NIR did not necessarily indicate that the project was not in compliance with a specific requirement. However, resolution of all open NIRs was a prerequisite for issuance of a verification statement. Opportunity for Improvement (OFI): An OFI indicated an area that should be monitored or ideally, improved upon. OFI’s were considered to be an indication of something that could become a non-conformity if not given proper attention, and were sometimes issued in the case that a non-material discrepancy was identified. OFIs were considered to be closed upon issuance. All findings issued by the audit team during the verification process have been closed. In accordance with Section 3.6 of the Verification Program Manual, all findings issued during the verification process, and the impetus for their closure, are described in a separate List of Findings that is a private document.

4.0 Findings Please see section 3.1 of this report for descriptions of the types of findings. It should be noted that all language under “Client Response” is a verbatim transcription of responses provided to the findings by project personnel.


NIR 2013.1 dated 05/30/2013 Standard Reference: CCB Standards Second Edition, Section G1.5 Document Reference: COFAV CCB PDD, pg. 18 Finding: The CCB Standards require that the project proponents provide a description of communities located in the project zone, including basic socio-economic and cultural information that describes the social, economic and cultural diversity within communities (wealth, gender, age, ethnicity etc.), identifies specific groups such as Indigenous Peoples and describes any community characteristics." The COFAV CCB PDD states that "Unless otherwise specified, all the information provided in section G1.5 comes from socio-economic surveys commissioned by Conservation International at the start of the project and conducted by three local non-governmental organizations: Hoanasoa, Sahala and Accademis. The original reports of these organizations have been provided to the auditors. “These reports have not been provided to the audit team; please provide these reports. Client Response: digital copies of the Socio Economic surveys done by Accademis, Haonasoa, Sahala in 2008 were provided to the validator during the field visit. Auditor Response: As stated in the client response, the audit team was provided with the missing reference documents, therefore resolving this issue. Closing Remarks: The Client’s response adequately addresses the finding. NIR 2013.2 dated 05/30/2013 Standard Reference: CCB Standards Second Edition, Section G2.1, The Rules for the Use of the Climate, Community and Biodiversity Standards, pg. 6. Document Reference: COFAV CCB PDD, pg. 54 Finding: The CCB Standards require that "The project proponents must develop a defensible and well-documented ‘without-project’ reference scenario that must: Describe the most likely land-use scenario in the absence of the project following IPCC 2006 GL for AFOLU or a more robust and detailed methodology, describing the range of potential landuse scenarios and the associated drivers of GHG emissions and justifying why the land-use scenario selected is most likely." Additionally, the Rules for the Use of the Climate, Community and Biodiversity Standards state that "There is no mandatory format or template for the PDD, but it must be prepared in a way that facilitates assessment by the public and the auditor." Whereas, the PDD provides the most likely land use scenario in the absence of the project, including a reference to the methodology used to assess these criteria, the PDD does not provide a description of the range of potential landuse scenarios and the associated drivers of GHG emissions and justifying why the land-use scenario selected is most likely. In order to facilitate assessment by the public and the auditor for this indicator, please update the PDD to include this information. Client Response: Text in the section G2.1 of the PD was update to describe the range of potential land-use scenarios and the associated drivers of GHG emissions. Auditor Response: The COFAV PDD has been updated to include an adequate description of the range of potential land use scenarios and the associated drivers of GHG emissions, therefore resolving this issue. Closing Remarks: The Client’s response adequately addresses the finding.


NIR 2013.3 dated 05/30/2013 Standard Reference: CCB Standards Second Edition, Section G2.3, The Rules for the Use of the Climate, Community and Biodiversity Standards, pg. 6. Document Reference: COFAV CCB PDD, pg. 54-55 Finding: The CCB Standards require that "The project proponents must develop a defensible and well-documented ‘without-project’ reference scenario that must: Document that project benefits would not have occurred in the absence of the project, explaining how existing laws or regulations would likely affect land use and justifying that the benefits being claimed by the project are truly ‘additional’ and would be unlikely to occur without the project." Additionally, the Rules for the Use of the Climate, Community and Biodiversity Standards state that "There is no mandatory format or template for the PDD, but it must be prepared in a way that facilitates assessment by the public and the auditor." Whereas, the audit team agrees that the VCS Tool VT0001 “Tool for the Demonstration and Assessment of Additionality in VCS Agriculture, Forestry and Other Land Use (AFOLU) Project Activities” is an acceptable methodology for assessing additionality; the requirements of this indicator are not documented in the PDD. In order to facilitate assessment by the public and the auditor for this indicator, please update the PDD to "document that project benefits would not have occurred in the absence of the project, explaining how existing laws or regulations would likely affect land use and justifying that the benefits being claimed by the project are truly ‘additional’ and would be unlikely to occur without the project." Client Response: Text in the section G2.2 of the PD was update to include details of the additionality assessment. Auditor Response: The COFAV PDD has been updated to include the results of the test for additionality using the VCS Tool VT0001, therefore resolving this issue. Closing Remarks: The Client’s response adequately addresses the finding.


NIR 2013.4 dated 05/30/2013 Standard Reference: CCB Standards Second Edition, Section G2.2, The Rules for the Use of the Climate, Community and Biodiversity Standards, pg. 6. Document Reference: COFAV CCB PDD, pg. 55 Finding: The CCB Standards require that "The project proponents must develop a defensible and well-documented ‘without-project’ reference scenario that must: Calculate the estimated carbon stock changes...Projects whose activities are designed to avoid GHG emissions (such as those reducing emissions from deforestation and forest degradation (REDD), avoiding conversion of non-forest land, or certain improved forest management projects) must include an analysis of the relevant drivers and rates of deforestation and/or degradation and a description and justification of the approaches, assumptions and data used to perform this analysis." Additionally, the Rules for the Use of the Climate, Community and Biodiversity Standards state that "There is no mandatory format or template for the PDD, but it must be prepared in a way that facilitates assessment by the public and the auditor." Whereas, the PDD provides a summary of the carbon stock changes in the "without project" scenario, including a reference to the methodology used to perform these calculations, the PDD does not include an analysis of the relevant drivers and rates of deforestation and/or degradation and a description and justification of the approaches, assumptions and data used to perform this analysis. In order to facilitate assessment by the public and the auditor for this indicator, please update the PDD to include an analysis of the relevant drivers and rates of deforestation and/or degradation and a description and justification of the approaches, assumptions and data used to perform this analysis. Client Response: Text in the section G2.3 of the PD was update to include description of the analyses of agents and drivers of deforestation, rates of deforestation and brief description of data and assumptions Auditor Response: The COFAV PDD has been updated to include analysis of the relevant drivers and rates of deforestation and/or degradation and a description and justification of the approaches, assumptions and data used to perform this analysis. The updates to the PDD are sufficient for closing this finding. Closing Remarks: The Client’s response adequately addresses the finding. NIR 2013.5 dated 05/30/2013 Standard Reference: CCB Standards Second Edition, Section G3.4 Document Reference: COFAV CCB PDD, pg. 73-75 Finding: The CCB Standards require that "The project proponents must: Define the project lifetime and GHG accounting period and explain and justify any differences between them. Define an implementation schedule, indicating key dates and milestones in the project’s development." The PDD does not define the "project lifetime," please update the PDD to include a definition of the project lifetime and explain and justify any differences between the project lifetime and the GHG accounting period. Client Response: The GHG accounting period and the project lifetime will cover 30 years from the project start date. Text in the PD was updated to clarify those periods. Auditor Response: As stated in the client response, the COFAV PDD has been amended to clearly define the project lifetime and GHG accounting period. The update to the PDD is sufficient for closing this finding. Closing Remarks: The Client’s response adequately addresses the finding.


NCR 2013.6 dated 06/24/2013 Standard Reference: CCB Standards Second Edition, Section G3.9 Document Reference: COFAV CCB PDD, pg. 80-81 Finding: The CCB Standards require that "The project proponents must: Describe what specific steps have been taken, and communications methods used, to publicize the CCBA public comment period to communities and other stakeholders and to facilitate their submission of comments to CCBA. Project proponents must play an active role in distributing key project documents to affected communities and stakeholders and hold widely publicized information meetings in relevant local or regional languages." Whereas, the PDD describes the process by which the project had publicized the public comment period; however, during the site visit, it was apparent to the audit team that the majority of community members interviewed by the audit team were, by all accounts, ignorant of the public comment process. This lack of knowledge regarding the public comment period is not in conformance with the requirements of the CCB standards. Client Response: Based on the information of this finding, the audit team requested that a second public comment period be implemented for the project. Evidence of the second public comment (7/10713 -08/09/13) period was provided to the audit team outside of the cover of this workbook. Auditor Response: The audit team performed a second site visit (9/17/13 - 9/20/13) upon the completion of second public comment period and found that the public comment period has been successfully carried out. In addition, the client provided the audit team with a detailed report of all of the public comments received, including if and how they were addressed in the COFAV PDD. The evidence provided in the report is consistent with the comments provided to the audit team from the CCBA. Whereas, the evidence and activities provided by the client sufficiently address this non-conformance, certain comments received during the second public comment period have yet to be address in the COFAV PDD, resulting in the issuance of NIR # Closing Remarks: The Client’s response adequately addresses the finding.


NCR 2013.7 dated 06/24/2013 Standard Reference: CCB Standards Second Edition, Section G3.10 Document Reference: COFAV CCB PDD, pg. 81-82 Finding: The CCB Standards require that "The project proponents must: Formalize a clear process for handling unresolved conflicts and grievances that arise during project planning and implementation. The project design must include a process for hearing, responding to and resolving community and other stakeholder grievances within a reasonable time period. This grievance process must be publicized to communities and other stakeholders and must be managed by a third party or mediator to prevent any conflict of interest. Project management must attempt to resolve all reasonable grievances raised, and provide a written response to grievances within 30 days. Grievances and project responses must be documented." The COFAV PDD provides a detailed description of the process for handling and responding to grievances. Additionally, there is clear evidence that some community members are aware of the process, as is evident by use of the grievance logs in the communities visited during the site visit. During the site visit; however, it was apparent to the audit team that the majority of community members interviewed by the audit team were, by all accounts, ignorant of the grievance process and therefore not in conformance with the criteria of the CCB Standards. Client Response: Based on the information of this finding, the audit team requested that a second public comment period be implemented for the project. Evidence of the second public comment (7/10713 -08/09/13) period was provided to the audit team outside of the cover of this workbook. Auditor Response: The audit team performed a second site visit (9/17/13 - 9/20/13) upon the completion of second public comment period and found that the public comment period has been successfully carried out. Whereas, there is still some confusion as to how to voice grievances, the majority of community members interviewed were knowledgeable of the grievance process. The activities carried out during the second site visit are sufficient for resolving this non-conformance. Closing Remarks: The Client’s response adequately addresses the finding.


NIR 2013.8 dated 11/15/2013 Standard Reference: CCB Standards Second Edition, Section G3.9; The Rules for the Use of the CCB Standards pg. 7 Document Reference: COFAV CCB PDD, pg. 80-81 Finding: The CCB Standards require that "The project proponents must: Describe what specific steps have been taken, and communications methods used, to publicize the CCBA public comment period to communities and other stakeholders and to facilitate their submission of comments to CCBA. Project proponents must play an active role in distributing key project documents to affected communities and stakeholders and hold widely publicized information meetings in relevant local or regional languages." Additionally, the Rules for the Use of the CCB Standards state that "The CCBA collates and publishes any comments that it receives and sends them to the auditor and the project proponent. The auditor must assess how the project proponent has responded to the issues raised by public comments. The project proponents may respond to public comments through revisions to the PDD or other documented efforts." During the site visit, the audit team reviewed a number of comments in which community members cite a lack of management within the community organizations. Whereas the audit team is aware that responsibilities are defined in the conservation agreements between the communities and CI, there exists some confusion among community members. Additionally, while the project is designed to utilize co-management by communities, CI is listed as the "technical lead" by the project proponent. Please update the COFAV PDD to clearly define how CI will provide oversight to co-managed areas in the project zone. Client Response: As stated in the section G.4.3 CI is the main project developer, responsible to provide technical and financial support to the project development and implementation. CI has a constant preoccupation to increase management capacity of local members, which would increase the success, minimize risks and build sustainability of the project. CI maintains a program, namely Organization Development and Institutional Development (DODI as its acronym in French), to improve community organization skills on management and project implementation, including technical and financial aspects. The trainings are provided in a range of types, e.g. chief of sectors provides one-to-one training, specific trainings are delivered by consultants and or specialized partners. CI is also responsible to overseen and assess the performance of partners, including community organizations (text on page 67 and 83 were updated) and any irregularities or poor performances are addressed accordingly, by discussing the issues and finding solutions with communities. In addition, the conflict resolution mechanism and the physical presence of the chiefs of sectors in the communities, accelerates the identification of poor management and of allow to be addressed in time manner. Evidences of trainings were provided to the validators Auditor Response: The rationale provided by the client is congruent with the professional knowledge of the audit team. As this is the validation stage of the project, the audit team agrees that this process will evolve through adaptive management and is therefore sufficient for resolving this issue. Closing Remarks: The Client’s response adequately addresses the finding.


OFI 2013.9 dated 11/15/2013 Standard Reference: NA Document Reference: NA Finding: During the review of public comments, the were a number of instances where communities had either requested new activities or complained that activities were not being implemented. The audit team is aware that this is not unusual as projects progress through time and that budgetary constraints do not always allow for ALL activities to be implemented at once. Additionally, during the site visit, the audit team was able to observe communities in which activities we indeed being implemented successfully. Whereas, this issue is understandable to the audit team during the validation phase of the CCB project, a failure to address these issue may lead to non-conformance in the future. Client Response: Auditor Response: Closing Remarks: The Client’s response adequately addresses the finding. NIR 2013.10 dated 11/15/2013 Standard Reference: The Rules for the Use of the CCB Standards pg. 7 Document Reference: NA Finding: The Rules for the Use of the CCB Standards state that "The CCBA collates and publishes any comments that it receives and sends them to the auditor and the project proponent. The auditor must assess how the project proponent has responded to the issues raised by public comments. The project proponents may respond to public comments through revisions to the PDD or other documented efforts." During the review of public comments, the were a number of instances where communities stated that they did not trust CI's local partners. The audit team is unable to ascertain how the project has addressed these comments. Please provide evidence that the project has considered these comments in the project design or a justification of why these comments have not been addressed. Client Response: Similarly to the conservation agreements, in which describes the rights and responsibilities of local communities, CI has contracts with local partners, stating their activities, expected deliverables and indicators that outcomes were achieved. CI is responsible to overseen and assess the performance of partners, (text on page 67 and 83 were updated) and any irregularities or poor performances are addressed accordingly. CI staff in Fianarantsoa reviews the financial and technical reports, while the chiefs of sectors verify the activity implementation in the field. The comments related to local partners were brought to the attention to the respective chiefs of sectors, who are assessing fundamentals of the comments. Evidences of contracts and reports were provided to the validators. Auditor Response: The audit team has been in communication with the project personnel to ensure that the project is managed in a way that results in net positive benefits for the communities in the project zone. The rationale provided in the client response is consistent with the professional understanding of the audit team. As this is the validation stage of the project, it is not uncommon for project activities and management to evolve through adaptive management and oversight. The audit team considers this issue resolved. Closing Remarks: The Client’s response adequately addresses the finding.


NIR 2013.11 dated 11/15/2013 Standard Reference: The Rules for the Use of the CCB Standards pg. 7 Document Reference: NA Finding: The Rules for the Use of the CCB Standards state that "The CCBA collates and publishes any comments that it receives and sends them to the auditor and the project proponent. The auditor must assess how the project proponent has responded to the issues raised by public comments. The project proponents may respond to public comments through revisions to the PDD or other documented efforts." During the review of public comments, members of the community of AMBOHIMAHASOA cited issues with fertilizer and seed supplies. The audit team is unable to ascertain how the project has addressed these comments. Please provide evidence that the project has considered these comments in the project design or a justification of why these comments have not been addressed. Client Response: As these comments were very specific they are considered in general terms in the Increased adoption of farming alternatives to tavy subsection in CM1.1. Due to some delays in delivering seeds and inputs to the communities in time manner, the community was not able to obey the cultivation calendar. Such delay was caused for external factors and the problem was discussed with the communities. As described in the evidences a solution was agreed and is currently being implemented. Auditor Response: As the project is currently in the validation stage of the CCB process, it is not uncommon for activities to evolve through adaptive management and oversight. The impetus for this finding was to ensure that all comments are being addressed throughout the life of the project and not to confirm implementation of project activities. The audit team confirms that the project has considered the comment covered by the finding and therefore considers this issue closed. Closing Remarks: The Client’s response adequately addresses the finding. OFI 2013.12 dated 11/15/2013 Standard Reference: CCB Standards Second Edition, Section G4.3 Document Reference: NA Finding: The CCB Standards require that "The project proponents must: Include a plan to provide orientation and training for the project’s employees and relevant people from the communities with an objective of building locally useful skills and knowledge to increase local participation in project implementation. These capacity building efforts should target a wide range of people in the communities, including minority and underrepresented groups. Identify how training will be passed on to new workers when there is staff turnover, so that local capacity will not be lost." During the site visit; however, the audit team received comments from community members citing the need for improving living conditions of vulnerable groups such as single women and youth. Whereas, the audit team is aware that the COFAV PDD includes language to ensure the targeting of activities toward women and other underrepresented groups, the comments received during the site visit raise concerns that non-conformities may arise during verification. Client Response: Auditor Response: Closing Remarks: The Client’s response adequately addresses the finding.


Appendix A: Response to Public Comments In accordance with the CCB Standards Rules, the actions taken (if necessary) to address each of the public comments received during the period from 4 to 16 June 2013 and from 17 to 19 September 2013 are discussed below. As a result of discussions between the audit team and the project proponents, comments received during the public comment period were categorized and addressed in a report titled “Rapport sur les campagne CCBS_revu_2013_10_08.” The audit team reviewed the comments, along with the report to ensure each comment had been considered and addressed in the PDD where applicable. The audit team was able to confirm that the project design has conformed to all of the requirements of the Standard.. Whereas, many comments were submitted to the CCBA, the following is a summary of comments reinforced by interviews during the site visit. Improving living conditions of vulnerable groups such as single women and youth Lack of trust of implementing partners by communities Poor management by CBO leaders Insecurity of communities within the project zone Need for outreach/research from local universities

As previously stated the audit team was able to confirm that the project successfully conforms to all of the requirements of the CCB Standards. Additionally, all public comments have been appropriately considered by the project proponents. Specifics of the actions taken in response to the validation are located in section 4.0 of this report. It should be noted, however, that given the timing of the validation activities, many of the comments received fall under the scope of project implementation. It is the professional opinion of the audit team that the comments received during the initial and second public comment period should be revisited as such time that the project undergoes verification. A complete list of comments can be found on the CCBA website https://s3.amazonaws.com/CCBA/Projects/Reduced_Emissions_from_Deforestation_in_the_Ambositra-Vondrozo_Forest_Corridor_(COFAV)-Madagascar_Project/Comments_received_on_COFAV.pdf.

https://s3.amazonaws.com/CCBA/Projects/Reduced_Emissions_from_Deforestation_in_the_Ambositra-Vondrozo_Forest_Corridor_(COFAV)-Madagascar_Project/Comments_received_on_COFAV.pdf

https://s3.amazonaws.com/CCBA/Projects/Reduced_Emissions_from_Deforestation_in_the_Ambositra-Vondrozo_Forest_Corridor_(COFAV)-Madagascar_Project/Comments_received_on_COFAV.pdf


General Section Conformance G1. Original Conditions in the Project Area (Required) Yes No G2. Baseline Projections (Required) Yes No G3. Project Design and Goals (Required) Yes No G4. Management Capacity and Best Practices (Required) Yes No G5. Legal Status and Property Rights (Required) Yes No Climate Section CL1. Net Positive Climate Impacts (Required) Yes No CL2. Offsite Climate Impacts (“Leakage”) (Required) Yes No CL3. Climate Impact Monitoring (Required) Yes No Community Section CM1. Net Positive Community Impacts (Required) Yes No CM2. Offsite Community Impacts (Required) Yes No CM3. Community Impact Monitoring (Required) Yes No Biodiversity Section B1. Net Positive Biodiversity Impacts (Required) Yes No B2. Offsite Biodiversity Impacts (Required) Yes No B3. Biodiversity Impact Monitoring (Required) Yes No Gold Section GL1. Climate Change Adaptation Benefits (Optional) Yes No GL2. Exceptional Community Benefits (Optional) Yes No GL3. Exceptional Biodiversity Benefits (Optional) Yes No CCBA Validation Level Attained: APPROVED (all requirements met) GOLD (all requirements and also at least one optional Gold Level criterion met

Documents

Final CCBA Project Validation Report...Final CCBA Project Validation Report CARBON EMISSIONS REDUCTION PROJECT IN THE FOREST CORRIDOR AMBOSITRA-VONDROZO (COFAV), MADAGASCAR 15 DECEMBER