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PROJECT REVIEW REPORT

PROJECT REVIEW REPORT

Project ID 738

Carbon Project in the Emas-Taquari Biodiversity Corridor, Goiás and Mato


Project Name
Grosso do Sul, Brazil

Program(s) VCS and CCB

Project Proponent Oréades Núcleo De Geoprocessamento Renato Moreira


AR-AMS0001: “Simplified baseline and monitoring methodologies for
Methodology small-scale afforestation and reforestation project activities under the
clean development mechanism implemented on grassland and croplands”
Sectoral Scope(s) 14. Agriculture, Forestry and Other Land Use (AFOLU)

Validation/Verification
Earthood Services Private Limited
Body (VVB)

Assessment Criteria VCS Standard, v4.1, CCB Standard, v3.1, AR-AMS0001/Version 5


Date of First Issue 17 February 2022
Date of Final Issue 03 May 2022

Summary:

An accuracy review of the Carbon Project in the Emas-Taquari Biodiversity Corridor, Goiás and Mato
Grosso do Sul, Brazil verification approval has been conducted by Verra in accordance with Section 4.3
of the VCS Registration and Issuance Process and Section 4.3.28 - 4.3.30 of the CCB Program Rules.
The accuracy review has raised 35 assessment findings and one minor finding, detailed below. The VVB
is hereby required to respond to the assessment findings presented in Section 1. The assessment
findings must be addressed to the satisfaction of Verra.
This project review report will be made publicly available. Confidential information may be provided as
separate attachments.

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1. ASSESSMENT FINDINGS

Finding 1
Section 3.5.5 of the CCB Program Rules v3.1 states that project proponents shall adhere to all
instructional text within the project description and monitoring report templates.
Section 1.2 of the CCB &VCS Monitoring Report Template, CCB v3.0, VCS v3.4 states “For each metric,
quantify the net benefit the project has achieved during the monitoring period covered by this report and
since the beginning of the project lifetime (if this is the project’s first verification report, the two columns
will be the same). Insert “not applicable” where the metric does not apply and “data not available” where
the metric does apply but there are no means of quantification.”
For each metric, under Section 1.2 of the monitoring report, the project proponent quantifies the net
benefits of the project. However, the section on livelihoods has no information. Additionally, the species
name instead of the number of globally Critically Endangered or Endangered species benefiting from
reduced threats is presented.
The project proponent is requested to include the relevant information on livelihoods and specify the
number of globally Critically Endangered or Endangered species benefiting from reduced threats. The VVB
is required to assess the updates accordingly.
PP response: The table of standardized benefits in Section 1.2 was actualized to attend this raising
assessment.
VVB Response: The audit team confirms the full completion of section 1.2 of the document
"MIR_Emas_2nd verification_CCB_VCS_v.3_VCSv3.5_v200322.pdf" as well as the correct compliance
with the relevant information on livelihoods and specifying the number of critically endangered species or
endangered globally that benefit from reduced threats.

Verra Response: The information on livelihood and globally critically endangered species benefiting from
reduced threats has been included and verified by the VVB. This finding is now closed, and no further
response is required.

Finding 2
Section 3.5.5 of the CCB Program Rules v3.1 states that project proponents shall adhere to all
instructional text within the project description and monitoring report templates.
Section 2.1.7 of the CCB & VCS Monitoring Report Template, CCB v3.0, VCS v3.4 states, “Indicate the
project location and geographic boundaries (if applicable) including geodetic coordinates. Coordinates
may be submitted separately as a KML file.”
Under Section 2.1.7 of the monitoring report, the project proponent provides a map of the project location.
However, the project area boundaries are not demarcated on the map from Figure 1.
The project proponent is requested to demarcate the boundaries of the project area on the map in the
monitoring report. The VVB is required to assess the updates accordingly.
PP response: The Figure 1 was updated to include the boundaries of the first activity instance, including
the geographic boundaries and geodetic coordinates of each rural properties. Also, the KML file will be
updated at Verra registry including all limits.
VVB Response: The audit team confirms the full completion of section 2.1.7 “Project Location” of the
document "MIR_Emas_2nd verification_CCB_VCS_v.3_VCSv3.5_v200322.pdf", where the PP includes
the improved “Figure 1” where the Project area can be easily identified. In addition, the PP included a
table of geodetic coordinates in accordance with the audit visit, land ownership and others. KML files is

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Finding 2
available in https://drive.google.com/drive/folders/1B4xEqN_ZDZ3FoOI0xerPX8TYiYYygg2o?usp=sharin

Verra Response: Figure 1 has been updated to include the boundaries of the first activity instance and as
well provided an updated KML file. The updated map and KML file have been verified by the VVB. This
finding is now closed, and no further response is required.

Finding 3
Section 3.5.5 of the CCB Program Rules v3.1 states that project proponents shall adhere to all
instructional text within the project description and monitoring report templates.

Section 2.1.10 of the CCB & VCS Monitoring Report Template, CCB v3.0, VCS v3.4states, “Describe how
the project contributes to achieving any nationally stated sustainable development priorities, including any
provisions for monitoring, and reporting same.”

The project proponent, under Section 2.1.10 of the monitoring report describes how the project
contributes to achieving any nationally stated sustainable development priorities. However, the project
proponent does not specify the exact SDGs that the project contributes to. Additionally, the provisions for
monitoring and reporting same are not included.

The project proponent is requested to specify the exact SDGs that the project contributes to along with
the provisions for monitoring and reporting same. The VVB is required to assess the updates accordingly.

PP response: to compliance this was added at Section 2.1.10 a table and description which specify and
relates the project activities contributions to the sustainable development goals (SDGs) and the indicators
of results and monitoring actions of each one.
VVB Response: Section 2.1.10 was adapted to expand the information on the SDGs to include the exact
SDGs to which the project contributes, along with the monitoring and reporting provisions correlated in a
table with each sustainable goal. The above was supported in “Annex Q_project activities update_section
3.2 of the CCBPD_v.21022022.xlsx” during the audit process and corroborated on field through interviews
with locals and partners.

Verra Response: A description of how the project activities contribute to the SDGs and the indicators for
monitoring the same have been added and verified by the VVB. This finding is now closed, and no further
response is required.

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Finding 4
Section 3.5.5 of the CCB Program Rules v3.1 states that project proponents shall adhere to all instructional
text within the project description and monitoring report templates.

Section 2.2.3 of the CCB & VCS Monitoring Report Template, CCB v3.0, VCS v3.4 states, “Document any
community or biodiversity changes to project design not requiring a project description deviation that occurred
during the monitoring period compared with the validated project description. Include justification for the
changes and demonstration that the changes are in conformance with the requirements of the Climate,
Community & Biodiversity Standards criteria, and indicators.”

The project proponent, under Section 2.2.3 of the monitoring report documents the changes to the project
design. However, the project proponent does not include a justification for the changes. Additionally, the project
proponent does not demonstrate that the changes are in conformance with the requirements of the Climate,
Community & Biodiversity Standards criteria, and indicators.

The project proponent is requested to include a justification for the changes and demonstrate that the changes
are in conformance with the requirements of the Climate, Community & Biodiversity Standards criteria, and
indicators. The VVB is required to assess the updates accordingly.
PP response: to address this finding, additional information was included in section 2.2.3 and annex Q was
updated To have access to the updated MIR and annexes referred in this document, please refer to the
shared folder https://drive.google.com/drive/folders/1B4xEqN_ZDZ3FoOI0xerPX8TYiYYygg2o?usp=sharing
VVB Response: Section 2.2.3 has been updated from “MIR_Emas_2nd
verification_CCB_VCS_v.3_VCSv3.5_v200322.pdf”. This VVB reviews the updated documents where the
changes are justified and demonstrates that the changes meet the requirements of the Climate, Community
& Biodiversity Standards criteria, and indicators.

Verra Response: The VVB confirms that the changes meet the requirements of the Climate, Community &
Biodiversity Standards criteria, and indicators. This finding is now closed, and no further response is required.

Finding 5
Section 3.5.5 of the CCB Program Rules v3.1 states that project proponents shall adhere to all instructional
text within the project description and monitoring report templates.

Section 2.2.4 of the CCB & VCS Monitoring Report Template, CCB v3.0, VCS v3.4 states, “Describe any project
description deviations applied during this monitoring period, identify which section(s) of the project description
has been updated and explain the reasons for the deviation.”

The project proponent, under Section 2.2.4 of the monitoring report documents states that the project goes
from single to grouped project. However, the project proponent does not explain how the new potential areas
to be added are complying with the Grouped projects requirements.

The project proponent is requested to demonstrate how this project deviation complies with the Grouped
project requirements. The VVB should assess this as well. The VVB highlights in the verification report that the
project complies with the requirements for Grouped projects, but the project proponent doesn’t show how the
project is complying with the group projects requirements.

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Finding 5

PP response: New text was add to the section 2.2.4 and section 2.2.5 in order to align the project to the scope
of grouped project. The new insertions include explanation how the new potential areas to be added are
complying with the Grouped projects requirements. In the other hand it is important to note that the project, by
the time of its 2nd verification, did not include new areas (or new instances), and when it does, these new
areas (new instances) must undergo the same eligibility, additionality and risk assessment, applied to the initial
areas (PAI#1), as explained in details in section 2.2.5. The baseline, additionality, leakage and risk assessment
will be evaluated on a case-by-case, for each one of the new areas, in order to identify any distinction between
the parameters and assumptions assumed for the first instance. Once significant differences have been
identified in these parameters, a new geographic area, within the scope of the grouped project, must be defined
for the purposes of risk, baseline and additionality analysis. To have access to the updated MIR and annexes
referred in this document, please refer to the shared folder
https://drive.google.com/drive/folders/1B4xEqN_ZDZ3FoOI0xerPX8TYiYYygg2o?usp=sharing

VVB Response: The PP adjusted point 2.2.4 and 2.2.5., which clarifies that the “new instances must undergo
the same eligibility and additionality assessment, applied to the initial areas” and establishes the compliance
of the new instances with the grouped project concept, described in 2.2.5 of MIR. On the other hand, in
numeral 3.5 of the document “CB_VCS_Verification_Report_Template_CCBv3.0_VCSv3.4_EMAS_V2.0”, this
VVB reported that the PP has proposed and justified how to expand the scope from a single project to a
grouped project to allow the inclusion of new instances in subsequent verifications also It has been
corroborated through interviews with them. No new project areas or communities were included in this
second verification. This audit team validated the eligibility criteria described in described in Section 2.2.5, 3)
of the Monitoring Report for future instances.
Verra Response: Information on how the project should comply with the group projects requirements has been
provided and verified by the VVB. This finding is now closed, and no further response is required.

Finding 6
Section 3.5.5 of the CCB Program Rules v3.1 states that project proponents shall adhere to all instructional
text within the project description and monitoring report templates.

Section 2.2.6 of the CCB & VCS Monitoring Report Template, CCB v3.0, VCS v3.4 states, “Describe actions
needed and implemented to mitigate likely natural and human-induced risks to the expected climate,
community, and biodiversity benefits during this monitoring period.

The project proponent, under Section 2.2.6 of the monitoring report documents that the project area has faced
two events of fire, one in July 2015 and the other in September 2020. These fires do not seem to have been
reported. Yet Section 3.2.15 of the VCS standard v4.1 states “Where an event occurs that is likely to qualify as
a loss event (see the VCS Program document Program Definitions for the definition of loss event), the project
proponent shall notify Verra within 30 days of discovering the likely loss event. The non-permanence risk tool
is also missing.

The project proponent is requested to clarify if Verra was notified of the fire event as per the requirements of
Section 3.2.15 of the VCS standard v4.1. The VVB is required to assess the updates accordingly. The project
proponent is also requested to share a copy of the non-permanence risk tool.

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Finding 6

PP response: the fire event occurred in September 2015 did not configure a reversal event, as evidenced by
the analysis carried out in the field by the audit team, please refer to section "8.2 Quality of Evidence to
Determine GHG Emission Reductions or Removals" of the first verification report
(CCB_VERIF_REP_ENG_738_06DEC2010_10JUL2015. pdf), that stated: "Besides the size of the area affected
by the fire, the damage within the project area has not caused a big impact in terms of tree mortality. In fact,
more than 90% of sampled individuals in the affected area were alive, in state of regeneration or even intact,
a condition which was attributed to the natural resistance of Cerrado trees to fire". Anyway, the Loss Event
Report was made, according to the Loss Event Report Template, v3.1 and presented to the audit team by the
time of first verification, detailing what happened and presenting evidence to support the non-reversal
approach, (see Annex E_1st Emas_VCS Loss Event Report Template, v3.1).
Regarding the second fire event, as it occurred prior to the 2nd forest inventory in a small area (less than 10%
of the project area, with very low carbon stock rate per hectare if compared to the average of the project areas),
it was not counted as a loss event, once the losses resulting from the fire were automatically captured by the
2nd inventory itself. To support this assumption please refer to annex S v.2 (2nd monitoring period ex-post
calculation) and the Annex R_police report for the 2nd fire event_Mirassol de furnas farm.jpeg. Please also
refer to annexes D and D1, risk tool and risk report, respectively.
Finally, considering that the project, until the moment of its 2nd verification, did not issue any VCUs, the
reversal event is uncharacterized, leaving only to the PP to quantify the climatic benefits achieved by the
project until the moment of its 2nd forest inventory (2nd verification), for the purpose of VCUs issuance. To
have access to the updated MIR and annexes referred in this document, please refer to the shared folder
https://drive.google.com/drive/folders/1B4xEqN_ZDZ3FoOI0xerPX8TYiYYygg2o?usp=sharing

VVB Response: According to the definition of loss events in Program-Definitions_v4.1 “any event that results
in a loss of more than five percent of previously verified emission reductions and removals due to losses in
carbon stocks in pools” the first event occurred six years ago, the impacts of which were assessed in the first
verification process “the damage within the project area has not caused a big impact in terms of tree mortality.
In fact, more than 90% of sampled individuals in the affected area were alive.” On the other hand, six years is
enough time to restore the overall composition, structure and function of the ecosystem as identified by this
VVB team in situ.
According to the definition of loss event of Program-Definitions_v4.1 “Examples include catastrophic events”
whose definition is “A type of reversal caused by disasters such as hurricanes, earthquakes, flooding, drought,
fires, tornados or winter storms, or man-made events over which the project proponent has no control such as
acts of terrorism or war”, these two events cannot be classified as catastrophic according to the above
definition, and even in any case, the project has submitted the “Annex Y_PPRA_compressed oreades” on a
program for environmental risks, as well as Table 4 of the verification report the director of the EMAS Park was
interviewed “He talked about his knowledge of the Carbon Project, the activities and the coherence with the
National Park projects and programs, as well as the importance of the project for the Emas forest, the fauna
and also minimize the risk of fire”, and in Table 8 of the verification report states “The VVB finds that the
mitigation measures are appropriate to cover risk” this VVB reviewed and evaluated the Fire risks monitoring,
fire brakes maintenance and commitment of no using fire as management tool, signed between PP and
landowners.
Now according to G. Durigan & J. A. Ratter “Cerrado ecosystems depend on the historical fire regime to
maintain their structure, biodiversity and functioning. The suppression of fire has transformed savanna

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Finding 6
vegetation into forests, causing biodiversity losses and drastic changes in ecological processes.”1 Means that
fire in the Cerrado biome is a natural process that contributes to its development as a special feature of this
ecosystem. The paper also suggests that “the future of the Cerrado depends on clear fire management
strategies based on the experience and science-based knowledge”.
The second fire event was considered as an independent stratum for the biomass calculation after the fire
event was over. This can be confirmed in CAR 03 of the verification report, where the project owner answers
“Thus, the 4 plots measured in the mirassol da furna farm were included in the "E_1_2_3_4_AM_2021_Fogo"
stratum”…
Section 3.2.15 of the VCS Standard v4.1 states that “Where VCUs have been previously issued, a loss event
report shall be prepared and submitted to the Verra Registry” however, no VCU this project has been claimed
so far.

Verra Response: The VVB confirms that no VCUs have been previously issued in the area with the fire event.
This finding is now closed, and no further response is required.

Finding 7
Section 3.5.5 of the CCB Program Rules v3.1 states that project proponents shall adhere to all instructional
text within the project description and monitoring report templates.

Section G3.2 of the CCB Standards v3.1 states “Explain how relevant and adequate information about potential
costs, risks and benefits42 to communities has been provided to them in a form they understand and in a timely
manner prior to any decision they may be asked to make with respect to participation in the project.”

Section 2.3.4 of the CCB & VCS Monitoring Report Template, CCB v3.0, VCS v3.4 states, “Demonstrate how
relevant and adequate information about potential costs, risks, and benefits to communities – identified using
a participatory and transparent process – has been provided to communities in an understandable form and
in a timely manner prior to any decision they may have been asked to make with respect to participation in the
project.”

The project proponent, under Section 2.3.4 of the monitoring report lists the different positive impacts of the
project to the different communities identified during the participatory process and highlights that the project
has not had any negative impacts. However, the project proponent does not demonstrate how this information
has been provided to communities in an understandable form and in a timely manner

The project proponent is requested to demonstrate how the information on the project benefits, obtained
during the participatory process, has been provided to communities in an understandable form and in a timely
manner.

1
G. Durigan & J. A. Ratter. The need for a consistent fire policy for Cerrado conservation ©2015 The Authors. Journal of Applied
Ecology©2015 British Ecological Society, Journal of Applied Ecology.
https://besjournals.onlinelibrary.wiley.com/doi/epdf/10.1111/1365-2664.12559

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PP response, in order to demonstrate how the information, the project benefits were obtained during
participatory process, were added at section 2.3.4 “For this verification, given the situation of the pandemic
caused by the coronavirus, the strategies for performance of the DRP (annex P) needed to be changed,
because it was not possible to gather the residents of the settlements as had been done in previous years.
The strategy used to overcome this challenge was the use of other tools, that could reflect and analysed over
time the indicators that have been monitored. So, the research was carried out in person, with each family
being visited individually, to cover at least the communities and community groups engaged in the project
activities, as well as the stakeholders directly affected. The information gathering step was carried out from
the following tools: Participant observation, Semi-structured interviews, questionnaire application, document
History Search, photographic and audio-visual records.” To have access to the updated MIR and annexes
referred in this document, please refer to the shared folder
https://drive.google.com/drive/folders/1B4xEqN_ZDZ3FoOI0xerPX8TYiYYygg2o?usp=sharing

VVB Response: The audit team interviewed local community members on site (see Table 4 of Verification report)
and confirmed that the statements at Monitoring Report were accurate and that there had been no potential
negative impacts on the community. The audit team verified the reported results through on-site inspections
and interviews with project participants. All participants related their experiences and knowledge of the project
from their perspective and in their role, as academics, landowners, beneficiaries, public entities, and others. It
was also confirmed by Dr. Lidiane de Fatima Vilela, who spoke in the interview about how the Document
“Relatório de Monitoramento Dos Impactos Sociais2” in Portuguese language or Social impact Monitoring
report, was developed and the results of the social monitoring, confirming that the communities were informed
about the project through an appropriate methodology.
Verra Response: The strategies for communicating with the local community members have been verified by
the VVB. This finding is now closed, and no further response is required.

Finding 8
Section 3.5.5 of the CCB Program Rules v3.1 states that project proponents shall adhere to all instructional
text within the project description and monitoring report templates.

Section G3.6 of the CCB Standards v3.1 states “Describe the measures needed and taken to enable effective
participation, as appropriate, of all communities, including all the community groups that want and need to be
involved in project design, implementation, monitoring and evaluation throughout the project lifetime, and
describe how they have been implemented in a culturally appropriate and gender-sensitive manner.”

Section 2.3.10 of the CCB & VCS Monitoring Report Template, CCB v3.0, VCS v3.4 states, “Describe the
activities and/or processes implemented to enable the effective participation, as appropriate, of all
communities. Demonstrate the culture- and gender-sensitivity of implementation of such actions.”

The project proponent, under Section 2.3.10 of the monitoring report states” Please refer to section 2.3.1,
2.3.4, 2.3.8, above”. However, the sections referred to do not include the activities and/or processes
implemented to enable the effective participation, as appropriate, of all communities. Additionally, the sections
referred to do not include the culture- and gender-sensitivity of implementation of such actions.

The project proponent is requested to update the section accordingly and the VVB is required to assess the
updates accordingly.

2
Annex P_Relatório DRP2021_Projeto Carbono Emas

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Finding 8

PP response: The project activities applied the Participatory Rural Diagnosis (DRP) as a monitoring and
communication mechanism (please refer to annex G and table 27 of CCB PD - annex F). In the DRP, participants
were able to share experiences and analyse their knowledge in order to improve their planning and action
skills. The engaged communities were involved in all stages of the project activities, were 51 rural families were
benefited directly and 19 indirectly, also 9 quilombolas families, and a group of 34 temporary employees hired
up to work with planting activities. In all these cases the culture- and gender-sensitivity was applied, prioritizing
the formalization of partnerships with female leaders.
For more information regarding communities and stakeholders’ consultation and engagement, comments
received, and processes implemented to enable the effective participation of all communities, please refer to
sections G.3.8, G.3.9 and G.3.10 of registered CCB PD and sections 6.1, 6.2 and 6.3 of the registered VCS
PD, as well as Annex G. To have access to the updated MIR and annexes referred in this document, please
refer to the shared folder
https://drive.google.com/drive/folders/1B4xEqN_ZDZ3FoOI0xerPX8TYiYYygg2o?usp=sharing
VVB Response: The said annexes were reviewed for this VVB in desk review stage before the onsite visit (See
Table 3 of verification report) and it was corroborated through interviews to the community specially women,
the asseveration of the PP “In all these cases the culture- and gender-sensitivity was applied, prioritizing the
formalization of partnerships with female leaders” was corroborate through interviews on site (See table 4 of
verification report) where the community leaders said .
Karla Simone and Maria Divina “They also related about the training/capacitation they received due the carbon
project activities and the importance of the project for the employment of local women”
Lucely Morais Pio “A leading senior woman who talked long about the Carbon project due to her knowledge
and strong involvement as a community leader but also as beneficiary of the project activities” (…)” And she
spoke about the strong women participation and the introduction of youth and children´s participation”
Priscila “She told the VVB how the bakery project gave local women economic freedom”

Verra Response: The VVB confirms the activities and/or processes implemented to enable the effective
participation. This finding is now closed, and no further response is required.

Finding 9
Section 3.5.5 of the CCB Program Rules v3.1 states that project proponents shall adhere to all instructional
text within the project description and monitoring report templates.
Section G3.11 of the CCB Standards v3.1 states “Submit a list of all relevant laws and regulations covering
worker’s rights in the host country. Describe measures needed and taken to 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.”

Section 2.3.15 of the CCB & VCS Monitoring Report Template, CCB v3.0, VCS v3.4 states, “List all relevant
laws and regulations covering worker’s rights in the host country and provide assurance that the project has
met or exceeded each.”

The project proponent, under Section 2.3.15 of the monitoring report lists the relevant laws and regulations
covering workers’ rights in the host country. However, the project proponent does not provide assurance that
the project has met or exceeded each.

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The project proponent is requested to provide assurance that the project has met or exceeded each. The VVB
is required to assess the changes accordingly.
PP response: To complement the aforementioned relevant laws and regulations covering workers’ rights,
demonstrating compliance and application of the same, is available in the list of employees (Annex W) and the
PP negative certificates of labor debts (Annex Z), with a positive effect on the organization. To have access to
the updated MIR and annexes referred in this document, please refer to the shared folder
https://drive.google.com/drive/folders/1B4xEqN_ZDZ3FoOI0xerPX8TYiYYygg2o?usp=sharing
VVB Response: This VVB reviewed the said annexes where the city hall certified negative certificates of labor
debts.

Verra Response: The VVB confirms that they reviewed the annexes in the city hall certified negative certificates
of labor debts. This finding is now closed, and no further response is required.

Finding 10
Section 3.5.5 of the CCB Program Rules v3.1 states that project proponents shall adhere to all instructional
text within the project description and monitoring report templates.
Section G3.12 of the CCB Standards v3.1 states “Comprehensively assess situations and occupations that
might arise through the implementation of the project and pose a substantial risk to worker safety.”

Section 2.3.16 of the CCB & VCS Monitoring Report Template, CCB v3.0, VCS v3.4 states, “Provide an
assessment of substantial risks to worker safety that have arisen due to project implementation. Describe
activities and/or processes implemented to inform workers of risks and minimize such risks. Show how risks
have been minimized.”
Under Section 2.3.16 of the monitoring report, the project proponent states the “project team is promoting the
adoption of formal protocols towards the reduction of labor risks and accidents avoidance, always prioritizing
workers’ health and safety.” However, they do not illustrate what entails formal protocols.

The project proponent is requested to elucidate what entails the formal protocols that they mention. The VVB
is required to assess the updates accordingly.
PP response: In order to elucidate the formal protocols towards the reduction of labor risks was updated in
shared folder the Environmental Risk Prevention Program (Annex Y), aimed at presenting and informing
Oréades employees about the environmental risks existing in activities and workplaces, as well as the adoption
of preventive and corrective measures. The Program is linked to the Regulatory Norms of the Ministry of Labor
- in particular the Medical Control and Operational Health Program (PCMSO) - provided for in NR07. Also,
actualized at section 2.3.16 at 2nd Monitoring Report. To have access to the updated MIR and annexes referred
in this document, please refer to the shared folder
https://drive.google.com/drive/folders/1B4xEqN_ZDZ3FoOI0xerPX8TYiYYygg2o?usp=sharing
VVB Response: This VVB reviewed the said annexes and the updated numeral 2.3.16 of MIR and finds the
answers are appropriated.

Verra Response: Section 2.3.16 of MIR has been updated accordingly. This finding is now closed, and no further
response is required.

10

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Finding 11
Section 3.5.5 of the CCB Program Rules v3.1 states that project proponents shall adhere to all instructional
text within the project description and monitoring report templates.
Section G4.2 of the CCB Standards v3.1 states “Document key technical skills required to implement the
project successfully, including community engagement, biodiversity assessment and carbon measurement and
monitoring skills.”

Section 2.4.2 of the CCB & VCS Monitoring Report Template, CCB v3.0, VCS v3.4 states, “Document the
management team’s expertise and prior experience implementing land management and carbon projects at
the scale of this project.”
The project proponent, under Section 2.3.15 of the monitoring report states, “Please refer to annex H.”
However, there are no Annexes in the monitoring report.

The project proponent is requested to update this section accordingly. Alternatively, the project proponent can
provide annex H. The VVB is required to assess the updates accordingly.
PP response: annex H is available in the shared folder
https://drive.google.com/drive/folders/1B4xEqN_ZDZ3FoOI0xerPX8TYiYYygg2o?usp=sharing
VVB Response: Annex H is part of the requirements of Section 2.4.1 and 2.4.2 and is integrated into the project
management system. It describes the Management Team´s the experience in AFOLU carbon projects and fulfils
the requirements. The technical expertise of the Project team was clearly evident during the audit process.

Verra Response: The information in Annex H has been verified by the VVB. This finding is now closed, and no
further response is required.

Finding 12
Section 3.5.5 of the CCB Program Rules v3.1 states that project proponents shall adhere to all instructional
text within the project description and monitoring report templates.
Section G5.4 of the CCB Standards v3.1 states “Identify any illegal activities that could affect the project’s
climate, community, or biodiversity impacts (e.g., illegal logging) taking place in the project zone and describe
measures needed and taken to reduce these activities so that project benefits are not derived from illegal
activities.”

Section 2.5.4 of the CCB & VCS Monitoring Report Template, CCB v3.0, VCS v3.4 states, “Identify any illegal
activities that could affect the project’s impacts. Describe activities and/or processes implemented to reduce
these activities so that project benefits are not derived from illegal activities.”
The project proponent, under Section 2.5.4 of the monitoring report, demonstrates that the project is not
violating any laws instead of identifying any illegal activities that could affect the project’s impacts.
The project proponent is requested to identify any illegal activities that could affect the project’s impacts. The
VVB is required to assess the updates accordingly.
PP Response: the only illegal occurrence identified so far within the project areas was the occurrence of two
fire events, as described in annex E and section 2.2.1 of the 2nd MIR. However, both were accidental events,
in any case the incident report was made (annex R). Section 2.5.4 was adjusted to include this description.
To have access to the updated MIR and annexes referred in this document, please refer to the shared folder
https://drive.google.com/drive/folders/1B4xEqN_ZDZ3FoOI0xerPX8TYiYYygg2o?usp=sharing
VVB Response: This VVB reviewed the said annexes in desk review phase (see Table 3 of Verification report)
and the updated numeral 2.3.16 of MIR and finds the answers corresponds to the requirement.

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Verra Response: Section 2.5.4 of the monitoring report has been updated accordingly. This finding is now
closed, and no further response is required.

Finding 13
Section 3.5.5 of the CCB Program Rules v3.1 states that project proponents shall adhere to all instructional
text within the project description and monitoring report templates.

Section 3.1.3 of the CCB & VCS Monitoring Report Template , CCB v3.0, VCS v3.4 states, “Describe the process
and schedule followed for monitoring the data and parameters set out in Section 3.1.2 (Data and Parameters
Monitored) above during this monitoring period, including details on the following:
● The organizational structure, responsibilities, and competencies of the personnel that
carried out the monitoring activities.
● The methods used for generating/measuring, recording, storing, aggregating, collating,
and reporting the data on monitored parameters.
● The procedures used for handling any internal auditing performed and any non-
conformities identified.
● The implementation of sampling approaches, including target precision levels, sample
sizes, sample site locations, stratification, frequency of measurement, and QA/QC
procedures. Where applicable, demonstrate whether the required confidence level or
precision has been met.”
Under Section 3.1.3 of the monitoring report, the project proponent describes the process and schedule
followed for monitoring the data and parameters. However, the project proponent does not include the
organizational structure, responsibilities, and competencies of the personnel that carried out the monitoring
activities, the procedures used for handling any internal auditing performed and any non-conformities
identified, and the implementation of sampling approaches, including target precision levels, sample sizes,
sample site locations, stratification, frequency of measurement and QA/QC procedures.
The project proponent is requested to include the organizational structure, responsibilities, and competencies
of the personnel that carried out the monitoring activities, the procedures used for handling any internal
auditing performed and any non-conformities identified, and the implementation of sampling approaches,
including target precision levels, sample sizes, sample site locations, stratification, frequency of measurement
and QA/QC procedures. The VVB is required to assess the updates accordingly.
PP response: The organizational structure of the monitoring and the methodology for obtaining data can be
found in Annex K. The data obtained in analog spreadsheets are transferred to an electronic spreadsheet,
available in the annex, undergoing an internal double check in order to avoid typing errors. The electronic
spreadsheet is stored in cloud files along with the scanned file of the field spreadsheets. The outsourced team
responsible for the forest inventory was monitored by a forestry engineer belonging to one of the communities
involved in the project, responsible for reporting to BRcarbon on the progress of activities, typo and outlier data
revision, as well as any non-compliance in the process.
To have access to the updated MIR and annexes referred in this document, please refer to the shared folder
https://drive.google.com/drive/folders/1B4xEqN_ZDZ3FoOI0xerPX8TYiYYygg2o?usp=sharing
VVB Response: about the compliance of the monitoring activities, the procedures used for handling any
internal auditing performed and any non-conformities identified, and the implementation of sampling
approaches, including target precision levels, sample sizes, sample site locations, stratification, frequency of
measurement and QA/QC procedures, the Project Proponent provided the “Annex K_Forest inventory
SOP_Roteiro metodológico para realização do inventário florestal do projeto agrupado de carbono no
cerrado.docx” (See Table 3 of Verification report), that was reviewed in desk review phase of the audit process,

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Finding 13
verified on field and used as a tool among other documents, for the audit sampling effort (See Appendix 2 of
Verification report). The “organizational structure, responsibilities, and competencies of the personnel that
carried out the monitoring activities” was reviewed in annex H of PP and corroborated on site visit, through the
office audit and interviews with people on charge of the monitoring (See Table 4 of Verification report).

Verra Response: The VVB confirms that the required information is provided in Annex K. This finding is now
closed, and no further response is required.

Finding 14
Section 3.5.5 of the CCB Program Rules v3.1 states that project proponents shall adhere to all instructional
text within the project description and monitoring report templates.
Section CL4.2 of the CCB Standards v3.1 states “Disseminate the monitoring plan and any results of monitoring
undertaken in accordance with the monitoring plan, ensuring that they are made publicly available on the
internet and summaries are communicated to the communities and other stakeholders through appropriate
means.”

Section 3.1.4 of the CCB &VCS Monitoring Report Template , CCB v3.0, VCS v3.4 states, “Describe how any
results of monitoring undertaken in accordance with the monitoring plan, have been disseminated and made
publicly available on the internet. Describe the means by which summaries (at least) of the results have been
communicated to the communities and other stakeholders.”
Under Section 3.1.4 of the monitoring report, the project proponent states, “……. The PP is always updating its
partners, providing access to project documents and results…….” However, the project proponent does not
clarify how partners are updated and how access to documents is given.
The project proponent is requested to clarify how partners are updated and how access to documents is given.
The VVB is required to assess the updates accordingly.
PP response: the PP informs and gives access to all project documents and results whenever a particular
project activity is implemented (e.g. forest inventory, fauna monitoring, etc.), including project submission for
verification and results. of the forest and fauna inventory. As state in section 2.3.3: The interface with local
communities and stakeholders is mainly carried out by phone calls, WhatsApp, e-mail and field visits. It is
noteworthy that the information is transmitted in an accessible language, so that it can be understood by the
communities and other stakeholders. For addition information, consult the Annex V.
To have access to the updated MIR and annexes referred in this document, please refer to the shared folder
https://drive.google.com/drive/folders/1B4xEqN_ZDZ3FoOI0xerPX8TYiYYygg2o?usp=sharing
VVB Response: The Project proponent included to the management documentation of the project the “Annex
V_Stakeholdercommunication” providing that the community was informed of the monitoring plan and results
and updated the corresponding numeral. This was an available way to communicate the results in the context
of the pandemic COVID 19. This Audit team finds that the responses meet the stated requirement and the
reality of the project.
Verra Response: The VVB confirms that the information is included in the management documentation of the
project the Annex V. This finding is now closed, and no further response is required.

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Finding 15
Section 3.5.5 of the CCB Program Rules v3.1 states that project proponents shall adhere to all instructional
text within the project description and monitoring report templates.

Section 3.2.2 of the CCB & VCS Monitoring Report Template, CCB v3.0, VCS v3.4 states, “Quantify project
emissions and removals providing sufficient information to allow the reader to reproduce the calculation. Attach
electronic spreadsheets as an appendix or separate file to facilitate the verification of the results.”
Under Section 3.2.2 of the monitoring report, the project proponent states, “emissions are considered
insignificant and therefore neglected.” However, the project proponent does not quantify the project removals
providing sufficient information to allow the reader to reproduce the calculation.
The project proponent is requested to include the quantification of the project removals providing sufficient
information to allow the reader to reproduce the calculations and to provide the calculation spreadsheets used.
The VVB is required to assess the changes accordingly.
PP response: Annex S (forest inventory analysis and ex-post calculation) is available the shared folder
https://drive.google.com/drive/folders/1B4xEqN_ZDZ3FoOI0xerPX8TYiYYygg2o?usp=sharing
VVB Response: This audit team reviewed, in desk review phase of the audit plan” all the calculation
spreadsheets (See table 3 of verification report) included the attached “Annex S
v.3_IFC_EMAS_Incerteza_22_12_2021” and found (See numeral 4.4.4 of verification report) that “ESPL was
able to confirm that the equations, sources, assumptions, parameters, and statistical procedures, meet the
methodological and standard requirements. Procedures for quantifying the removals of GHG were carried
out in accordance with the applied methodology”

Verra Response: The VVB confirms that the equations, sources, assumptions, parameters, and statistical
procedures, meet the methodological and standard requirements. This finding is now closed, and no further
response is required.

Finding 16
Section 3.5.5 of the CCB Program Rules v3.1 states that project proponents shall adhere to all instructional
text within the project description and monitoring report templates.

Section 3.2.3 of the CCB & VCS Monitoring Report Template, CCB v3.0, VCS v3.4 states, “Quantify leakage
emissions providing sufficient information to allow the reader to reproduce the calculation. Attach electronic
spreadsheets as an appendix or separate file to facilitate the verification of the results.”
Under Section 3.2.2 of the monitoring report, the project proponent highlights that there was no displacement
of local people due to project activities and thus leakage is zero. However, the project proponent does provide
evidence that there is no displacement as per the requirements of the methodology
The project proponent is requested to provide evidence that there is no displacement as per the requirements
of the methodology
PP response: The project areas are in private rural properties. As aforementioned at section 2.3.5 about
clarifying the project’s lack of negative impacts: The project activities did not negatively affect those locally
involved with the project, since it did not cause the need for moving (reallocation), neither other conflict related
to the use of important natural resources that are essential to the subsistence of surrounding communities.
On the contrary, according to the benefits described on section G3.2 of the Design Document CCB Standard in
2010 (annex F), the project has not only positively affected the local communities, but also indirectly benefited
other communities and local stakeholders in the project region. This was made possible because of the
knowledge dissemination, effective communication and valuing of the Cerrado and its traditional ways of life
spread out by the project implementers.

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Finding 16
To have access to the updated MIR and annexes referred in this document, please refer to the shared folder
https://drive.google.com/drive/folders/1B4xEqN_ZDZ3FoOI0xerPX8TYiYYygg2o?usp=sharing
VVB Response: The leakage value was developed in accordance with the ARA-AMS0001 methodology and the
assumption that the “not displacement of local people due to project activities” was confirmed by the
interviews and the site inspection during the field trips.

Verra Response: The VVB confirms that there was no displacement of local people due to project activities.
This finding is now closed, and no further response is required.

Finding 17
Section 3.5.5 of the CCB Program Rules v3.1 states that project proponents shall adhere to all instructional
text within the project description and monitoring report templates.
Section CM2.1 of the CCB Standards v3.1 states “Use appropriate methodologies99 to assess the impacts100,
including predicted and actual, direct and indirect benefits, costs and risks, on each of the identified community
groups (identified in G1.5) resulting from project activities under the with-project scenario. The assessment of
impacts must include changes in well-being due to project activities and an evaluation of the impacts by the
affected community groups.”

Section 4.1.1 of the CCB & VCS Monitoring Report Template, CCB v3.0, VCS v3.4 states, “Complete the table
below to describe all the impacts on each community group resulting from project activities under the with-
project scenario. Impacts must include all those identified in the project description and any other unplanned
impacts. Explain and justify key assumptions, rationale, and methodological choices. Explain how the affected
groups have participated in the evaluation of impacts. Provide all relevant references. Copy and paste the table
as needed.”

Under Section 4.1.1 of the monitoring report, the project proponent describes all the impacts on different
communities, not necessarily community groups. The project proponent does not explain how the affected
groups have participated in evaluating impacts.

The project proponent is requested to clarify the community groups and explain how the affected groups have
participated in evaluating impacts. The VVB is required to assess the updates accordingly.
PP response: additional information were included in section 4.1.1, please refer to table 13 of the 2nd MIR
VVB Response: The PP updated the numeral 4.1.1. of the monitoring report v3.0, which differentiates
benefits for each community, and refers to Annex P as part of the review of the document by the audit team.

Verra Response: The relevant information has been included. This finding is now closed, and no further
response is required.

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Finding 18
Section 3.5.5 of the CCB Program Rules v3.1 states that project proponents shall adhere to all instructional
text within the project description and monitoring report templates.

Section 4.1.3 of the CCB & VCS Monitoring Report Template, CCB v3.0, VCS v3.4 states, “Demonstrate that
the net well-being impacts of the project are positive for all identified community groups compared with their
well-being conditions under the without-project land-use scenario. Projects validated at the Gold Level for
climate change adaptation benefits: demonstrate how the project activities have assisted communities in
adapting to the probable impacts of climate change.”

Under Section 4.1.3 of the monitoring report, the project proponent states that the net well-being impacts of
the project are positive. However, the project proponent does not demonstrate how the project activities have
assisted communities in adapting to the probable impacts of climate change.

The project proponent is requested to demonstrate how the project activities have assisted communities in
adapting to the probable impacts of climate change. The VVB is required to assess the updates accordingly.
PP response: At Section 3.3.1, the table 12 demonstrated the mitigation of climate change impacts due to
project activities. In addition of that, as it described at section 4.2.1 “Once the micro basins forest cover
restoration, reduces soil erosion and river silting, promoting the infiltration of the rain in the water table
through the root system of planted trees. therefore, the effects of reforestation activities promote greater
resilience to the ecosystem and water sources, positively and directly affecting the ability of communities to
adapt to climatic extremes caused by climate change”

In order to clarifying this question, was added at section 4.1.3 the most important action of project which
contributes for climate change adaptation with the hydraulic system in three settlements, allowing access to
potable water for human, animal, vegetable gardens and nurseries.
Link to shared results at social media: https://incragoias.wordpress.com/2014/09/19/familias-implantam-
e-administram-sistema-de-abastecimento-de-agua-em-assentamentos-de-mineiros-go/
https://www.facebook.com/watch/?v=991870524774698&ref=sharing
VVB Response: The project proponent improves the explanation, of how the project activities have assisted
communities in adapting to the probable impacts of climate change in the updated the numeral 4.1.3. This is
consistent with what was found in the field. Through interviews (see table 4 of verification report), the VVB
was able to confirm the participation of locals in training, courses, and technical assistance, and also confirm
the water supply infrastructure.
In Table 4 of verification report:
-Maria Divina and her husband Antonio Oliveira “They took up the issue of the water supply provided by the
project due the community needs and the nursery work”
- Lázaro Pereira Rocha “He spoke about the water supply benefits his family received through Oreades and
he worked in the nursery”
- Priscila: “and the water supply her family and other local women started a bakery as a first business idea
for locals”

Verra Response: The VVB confirms the participation of locals in training, courses, and technical assistance,
and additionally confirmed the water supply infrastructure. This finding is now closed, and no further
response is required.

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Finding 19
Section 3.5.5 of the CCB Program Rules v3.1 states that project proponents shall adhere to all instructional
text within the project description and monitoring report templates.
Section CM2.4 of the CCB Standards v3.1 states “Demonstrate that no high conservation values (identified in
CM1.2) are negatively affected by the project.”

Section 4.1.4 of the CCB & VCS Monitoring Report Template, CCB v3.0, VCS v3.4 states, “Demonstrate that
none of the HCVs related to community well-being in the project zone identified in the project description are
negatively affected by the project.”

Under Section 4.1.4 of the monitoring report, the project proponent describes the positive impacts of project
activities on HCVS but does not demonstrate that none of the HCVs related to community well-being in the
project zone identified in the project description are negatively affected by the project.

The project proponent is requested to demonstrate that none of the HCVs related to community well-being in
the project zone identified in the project description are negatively affected by the project. The VVB is required
to assess the updates accordingly.
PP response: new text was included in section 4.1.4 in order to clarify that none of the HCVs related to
community well-being in the project zone identified in the project description are negatively affected by the
project.
VVB Response: The Project proponent improves the statements in numeral 4.1.4 of the monitoring report
which argue how none of the HCVs related to community well-being will be affected negatively by the project.
This Audit team finds the statement conclusive and responds to the numeral.

Verra Response: Section 4.1.4 of the monitoring report has been updated accordingly. This finding is now
closed, and no further response is required.

Finding 20
Section 3.5.5 of the CCB Program Rules v3.1 states that project proponents shall adhere to all instructional
text within the project description and monitoring report templates.

Section 4.3.1 of the CCB & VCS Monitoring Report Template, CCB v3.0, VCS v3.4 states, “Present the results
of the community impact monitoring which should include:

● All communities, community groups, other stakeholders, and HCVs related to community well-being
identified in the monitoring plan.

● Dates, frequency, sampling methods used, and other information regarding the monitoring process.

● Results and evaluation of monitoring, including evaluations by the affected communities.”

Under Section 4.3.1 of the monitoring report, the project proponent presents the results of the community
impact monitoring. However, the communities, community groups, other stakeholders, and HCVs related to
community well-being identified in the monitoring plan are not included.

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Finding 20

The project proponent is requested to include the communities, community groups, other stakeholders, and
HCVs related to community well-being identified in the monitoring plan. The VVB is required to assess the
updates accordingly.

PP response: new wording added to section 4.3.1, and annex P (social monitoring report) is now available. To
have access to the updated MIR and annexes referred in this document, please refer to the shared folder
https://drive.google.com/drive/folders/1B4xEqN_ZDZ3FoOI0xerPX8TYiYYygg2o?usp=sharing
VVB Response: The Project proponent has identified the HVCs in relation to the community in numeral 4.3.1
of the monitoring report. On the other hand, the attached document “Annex P_Relatório DRP2021_Projeto
Carbono Emas” was reviewed for the audit team in the desk review phase and confirmed to be compliant.

Verra Response: Section 4.3.1 of the monitoring report has been updated accordingly. This finding is now
closed, and no further response is required.

Finding 21
Section 3.5.5 of the CCB Program Rules v3.1 states that project proponents shall adhere to all instructional
text within the project description and monitoring report templates.

Section 4.3.2 of the CCB & VCS Monitoring Report Template, CCB v3.0, VCS v3.4 states, “Describe how any
results of monitoring undertaken in accordance with the monitoring plan have been disseminated and made
publicly available on the internet. Describe how summaries (at least) of the monitoring results have been
communicated to the communities and other stakeholders.”

Under Section 4.3.2 of the monitoring report, the project proponent states, “the PP is always updating partners,
stakeholders, and communities engaged in the project activities. In addition, the PP informs and provides
access to all project documents and results whenever a given project activity is put in place.” However, the
project proponent does not clarify how partners, stakeholders, and communities are updated and how access
to documents is granted.

The project proponent is requested to clarify how partners, stakeholders, and communities are updated and
granted access to documents. The VVB is required to assess the updates accordingly.
PP response, as state in section 2.3.3 “The interface with local communities and stakeholders is mainly
carried out by phone calls, WhatsApp, e-mail and field visits. It is noteworthy that the information is
transmitted in an accessible language, so that it can be understood by the communities and other
stakeholders”. To address this question, the same citation was added at section 4.3.2. The final results are
made available in analog and digital form on the oreades facebook web page and website, communication
via whatsapp with project stakeholders is also carried out with the presentation of the summary and cover
sheet for each monitoring period, as can be found at Annex V.
To have access to the updated MIR and annexes referred in this document, please refer to the shared folder
https://drive.google.com/drive/folders/1B4xEqN_ZDZ3FoOI0xerPX8TYiYYygg2o?usp=sharing
VVB Response: The project proponent clarified how partners, stakeholders, and communities are updated
and granted access to documents in numeral 4.3.2 of monitoring report and attached in document
management system the “Annex V_Stakeholdercommunication”. The VVB finds it consistent with field
information.

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Finding 21

Verra Response: The VVB confirms that partners, stakeholders, and communities are updated and granted
access to documents. This finding is now closed, and no further response is required.

Finding 22
Section 3.5.5 of the CCB Program Rules v3.1 states that project proponents shall adhere to all instructional
text within the project description and monitoring report templates.

Section 5.1.1 of the CCB & VCS Monitoring Report Template, CCB v3.0, VCS v3.4 states, “Complete the table
below to describe all the changes in biodiversity resulting from project activities under the with-project scenario
in the project zone during this monitoring period.”
Under Section 5.1.1 of the monitoring report, the project proponent describes several impacts on biodiversity,
including an increase in the number of bird species registered in the project areas, an increase in the number
of bird families registered in the project areas, an increase in the number of bird orders registered in the project
area, an increase in the number of endangered bird species recorded in the project areas, and increase in the
occurrence of medium and large mammals’ species in the project area. However, the project proponent does
not clarify if the presented changes result from project activities.

The project proponent is requested to clarify whether the presented changes result from project activities. The
VVB is required to assess the updates accordingly.
PP Response: The positive impacts described in section 5.1.1, is still in the field of hypotheses, since it is not
possible to establish a direct causal relationship between the restoration activities and the increase in the
species, genera or families registries of birds, with only two monitoring points in time. It is expected that in
the future, with the continuity of fauna monitoring, the causal relationship can be statistically proven,
evidencing the benefits of the project activities to biodiversity, not only of birds, but also of mammals. By now,
what is defended by the PP is the hypothesis that with the increase in forest cover, which serves as food and
shelter for the fauna, there will be an increase in the number of vertebrate and invertebrate species in the
project areas. In addition, with the increase in forest cover and the progressive connection of forest
fragments, a direct response is expected in the increase of species transiting in the project areas, for more
information, please refer to annex U. To have access to the updated MIR and annexes referred in this
document, please refer to the shared folder
https://drive.google.com/drive/folders/1B4xEqN_ZDZ3FoOI0xerPX8TYiYYygg2o?usp=sharing
VVB Response: The Project proponent explained in numeral 5.1.1 of the monitoring report how their activities
have increased the number of individuals, as well as, the number of species, because of the food supply and
security provided by the forest. The audit leader interviewed Giselle Bastos Alves, who is responsible for the
biodiversity surveys and monitoring reports. (See Table 4 in the verification report), where she also explained
this statement using a power point presentation (See Annex O_Programa de monitoramento da
biodiversidade).

Verra Response: The VVB has clarified the information accordingly. This finding is now closed, and no further
response is required.

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Finding 23
Section 4.3.15 of the CCB Program Rules v3.1 states that the validation/verification body shall adhere to all
instructional text within CCB & VCS Verification Report Template.
Section 2.1 of the CCB & VCS Verification Report Template, CCB v3.0, VCS v3.4 states, “Demonstrate that
the team conducting the audit includes expertise in the following areas:

● Proficiency in a relevant local or regional language for the project location.

● Relevant agriculture, forestry, and other land use experience in the project country or region.

● Relevant social and cultural expertise.

● Relevant ecological and biodiversity expertise.”


Under Section 2.1 of the verification report, the VVB indicates the roles of the team conducting the audit and
the expertise of the lead author. Proficiency in a relevant local or regional language for the project location is
not included.
The VVB is requested to include proficiency in a relevant local or regional language for the project location.
VVB Response: Proficiency in a relevant local or regional language for the project location is included in the
section 2.1 of the verification report v3.0. It was added:

“Ricardo Lopes: native Brazilian, and therefore a native Portuguese speaker, understands the local culture
and is familiar with local legislation. He holds a post-graduation diploma in international management with
technical education in data processing.

He has a wide professional experience in Latin America, having participated in over a hundred audits of GHG
projects (CDM/VCS/GS, Social Carbon, etc.) across the region, from Mexico”
Verra Response: The information has been updated accordingly. This finding is now closed, and no further
response is required.

Finding 24
Section 4.3.15 of the CCB Program Rules v3.1 states that the validation/verification body shall adhere to all
instructional text within CCB & VCS Verification Report Template.

Section 2.2 of the CCB & VCS Verification Report Template CCB v3.0, VCS v3.4 states, “Describe the method
and criteria, including the sampling plan, used for undertaking the verification. Where sampling plans are used
as a part of the verification, including a description of the sampling approach, important assumptions, and
justification of the chosen approach.”
Under Section 2.2 of the verification report, the VVB describes the method used for undertaking the verification.
However, the sampling plan and the important assumptions and justification of the chosen approach are not
included.
The VVB is requested to include the sampling plan and the important assumptions and justification of the
chosen approach.
VVB Response: The sampling plan and the important assumptions and justification of the chosen approach
are included in the section 2.2 of the verification report v3.0. It was added:
“The sampling plan included review of 100% of project documents, spreadsheets, cartographic information,
land ownership certificates, and all documents provided as support for the second monitoring period. In

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Finding 24
addition, field inspections (see Table 5 and Figure 1) and interviews with relevant stakeholders, were planned
(see Table 4).
The monitoring report and nonpermanence risk analysis were reviewed for consistency with the criteria
described in Sections 1.2 and 1.3 of this report. The audit team identified potential risks of errors, omissions,
and misstatements related to the verification criteria. Based on the approach taken, the audit team considers
the sample design selected to be sufficient to make a decision on the analysis of the project and its compliance
with the applicable requirements.”
Verra Response: The sampling plan has been included. This finding is now closed, and no further response is
required.

Finding 25
Section 4.3.15 of the CCB Program Rules v3.1 states that the validation/verification body shall adhere to all
instructional text within CCB & VCS Verification Report Template.

Section 3.3 of the CCB & VCS Verification Report Template, CCB v3.0, VCS v3.4 states, “Identify any project
description deviations applied to the project and describe the steps taken to validate each deviation. Assess
whether the proposed deviation impacts any of the following, documenting the assessment of each separately:

The applicability of the methodology.

Additionality.

The appropriateness of the baseline/without-project scenario.

Provide an assessment of whether each deviation is appropriately described and justified and whether the
project remains in compliance with the CCB Version 3 and VCS rules.

Provide an overall conclusion regarding whether each project description deviation is valid.”
Under Section 3.3 of the verification report, the VVB describes the project descriptions. However, the VVB does
not assess whether the proposed deviations impact the additionality.
The VVB is requested to provide an assessment on whether the proposed deviations impact the additionality.
PP comment: the 3 proposed amendments do not have any impact on the additionality analysis. specifically
regarding the scope expansion from a single project to a grouped project, it is worth mentioning that each
new instance must undergo an independent additionality analysis.
VVB Response: Section 3.3 of the verification report v 3.0 contains the evaluation of the impact on the
additionality of the deviations proposed by the project proponent. It was added:
“The scope expansion from a single project to a grouped project. ESPL has reviewed the VCS requirements
for a grouped project through document review (adjustments in the PDD), cartographic analysis, and site
inspections. The addition of new areas under this grouped project follows the same baseline scenario
approach used for the first instance areas, as indicated the methodology used. Each new instance must
undergo an independent additionality analysis and therefore has no impact on the additionality of the
project.
- A new second project proponent. ESPL has verified through legal review, interviews, and site inspections
that the addition of a new partner (BRCarbon) will have a positive impact on the project. BRCarbon will
oversee the next verification process and the search, assessment, and inclusion of new areas as part of the

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Finding 25
framework of the grouped project. This expansion will rely on local partnerships with implementation
partners and upfront funding from the carbon market, to finance the implementation of the new project
activities. This change has not negatively impacted the project ́s outcomes or its additionality.
- Inclusion the methodological option that predicts the non-existence of leakage in line with the applied
methodology (AR AMS0001 v.5). ESPL has verified the evidence through on-site inspections of the
implementation of the activities to prevent leakage and the leakage options offered by the methodology. This
deviation does not affect the additionality of the project”

Verra Response: The VVB has provided an assessment on whether the proposed deviations impact the
additionality. This finding is now closed, and no further response is required.

Finding 26
Section 4.3.15 of the CCB Program Rules v3.1 states that the validation/verification body shall adhere to all
instructional text within CCB & VCS Verification Report Template.
Section 3.4 of the CCB & VCS Verification Report Template, CCB v3.0, VCS v3.4 states, “Identify any minor
changes applied to the community and biodiversity elements of the project design. Describe the steps taken
to assess whether the change is justified as a minor change or whether it should be considered a project
description deviation. Provide an assessment as to whether minor changes are appropriately described and
justified, and whether the project remains in compliance with the project’s validated design.”
Under Section 3.4 of the verification report, the VVB describes the minor changes and the steps taken to
validate the minor changes. However, the VVB does not provide an assessment as to whether minor changes
are appropriately described and justified and whether the project remains in compliance with the project’s
validated design.
The VVB is requested to assess whether minor changes are appropriately described and justified and whether
the project remains in compliance with the project’s validated design.
VVB Response: Section 3.4 of the verification report contains the assessment as to whether minor changes
are appropriately described and justified and whether the project remains in compliance with the project’s
validated design. It was added:
“ESPL has evaluated the implementation of the project activities and during the site visit identified the need
to structure the goals and objectives of some activities. During implementation, the project proponent
identifies adjustments needed in accordance with the validated project design. Minor changes are
appropriately described and justified by the project proponent and the project remains in compliance with
the validated project design. The audit team validated the minor changes considering the Rules 3.5.6 of the
document CCB-Program-Rules-v3.1as part of the verification engagement described in this report”

Verra Response: The VVB has updated the verification report accordingly. This finding is now closed, and no
further response is required.

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Finding 27
Section 4.3.15 of the CCB Program Rules v3.1 states that the validation/verification body shall adhere to all
instructional text within CCB & VCS Verification Report Template.
Section 4.3.1 of the CCB & VCS Verification Report Template, CCB v3.0, VCS v3.4 requires the VVB to identify
the implementation status of the project activities steps taken to assess the implementation status. The
template also requires the VVB to provide an overall conclusion regarding whether the project has been
implemented as described in the project description.
Under Section 4.3.1 of the verification report, the VVB describes the implementation status of the project
activities. However, the VVB does not define the steps to establish the implementation status. In addition, the
VVB does not provide an overall conclusion regarding whether the project has been implemented as described
in the project description.
The VVB is requested to describe the steps taken to establish the implementation status and provide an overall
conclusion regarding whether the project has been implemented as described in the project description.
VVB Response: Section 4.3.1 of the verification report v3.0contain the description and conclusion about the
steps taken to establish the implementation status of the project. It was added, belong the Table 7.
“Through onsite visit observations, interviews, and document assessment, the audit team confirmed no
material discrepancies between the project implementation and the project description. In conclusion, the
audit team finds that the project has been implemented as described in the project description”

Verra Response: The VVB describes the steps taken to establish the implementation status and provide an
overall conclusion regarding whether the project has been implemented as described in the project
description. This finding is now closed, and no further response is required.

Finding 28
Section 4.3.15 of the CCB Program Rules v3.1 states that the validation/verification body shall adhere to all
instructional text within CCB & VCS Verification Report Template.

Section 4.3.5 of the CCB & VCS Verification Report Template, CCB v3.0, VCS v3.4 states, “Describe the steps
taken to verify the project proponent consulted stakeholders on project implementation in accordance with
G3.4 – G3.5, specifically:
● Community groups and other stakeholders have influenced project implementation through
effective consultation.
● Stakeholder input on project implementation has been documented.
● The project’s plan for continued communication is being carried out.
● All consultation and participatory processes have been undertaken directly with communities
and other stakeholders or through their legitimate representatives.

Include details of documentation assessed and observations made during the site visit. Provide and justify an
overall conclusion about whether the project carried out an effective community consultation.”
Under Section 4.3.5 of the verification report, the VVB highlights that the project activities were done within
private properties. All interested communities participate in democratic spaces and are open to the public of
interest. However, the VVB does not describe the steps to verify this information. Additionally, the VVB does not
provide an overall conclusion about whether the project carried out an effective community consultation.
The VVB is requested to describe the steps taken to verify the project proponent consulted stakeholders on
project implementation and provide an overall conclusion about whether the project carried out an effective
community consultation.

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Finding 28

VVB Response: Section 4.3.5 of the verification report v 3.0 contain the description and conclusion about
community consultation. In addition, all kind of stakeholders were interviewed on field, taking into account
communities, environmental entities, beneficiaries, landowners, women leaders, among others relevant (See
Table 4 of verification report). It was added:
“The audit team verified through field observations and interviews that the project proponent communicated
with and consulted stakeholders (the landowners, communities, and other project stakeholders such as
universities, schools, and local authorities) on project implementation.
The audit team interviewed the relevant stakeholders and found that they were involved in project design
through effective consultations. In light of the observations made during the site visit, interviews conducted,
and the documentation assessed, the audit team concludes that the project ́s stakeholder engagement was
sufficiently effective in meeting the requirements of G3.4 and G3.5”

Verra Response: The VVB describes the steps taken to verify the project proponent consulted stakeholders on
project implementation and provide an overall conclusion about whether the project carried out an effective
community consultation. This finding is now closed, and no further response is required.

Finding 29
Section 4.3.15 of the CCB Program Rules v3.1 states that the validation/verification body shall adhere to all
instructional text within CCB & VCS Verification Report Template.

Section 4.3.6 of the CCB & VCS Verification Report Template, CCB v3.0, VCS v3.4 states, “Describe the steps
taken to verify the project proponent has enabled effective participation of all communities that want and need
to be involved in project implementation, monitoring, and evaluation. Include details of documentation
assessed and observations made during the site visit. Provide and justify an overall conclusion as to whether
the project enabled community participation in project implementation.”
Under Section 4.3.6 of the verification report, the VVB states, “The project activities applied the Participatory
Rural Diagnosis (DRP) as a monitoring and communication mechanism in decision making and
implementation.” However, the VVB does not describe the steps taken to reach this conclusion.
The VVB is requested to describe the steps taken to verify that the project proponent has enabled effective
participation of all communities that want and need to be involved in project implementation, monitoring, and
evaluation.
VVB Response: Section 4.3.6 of the verification report v3.0 contain the description community participation
in project implementation. It was added:

“The audit team verified that stakeholder participation in decision making and implementation was
developed in a collaborative manner that ensured stakeholders were included. In the field, the audit team
interviewed stakeholders across the project area and confirmed that communication occurred in an
appropriate and participatory manner (see table 4).”
Verra Response: The relevant information has been provided accordingly. This finding is now closed, and no
further response is required.

Finding 30

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Section 4.3.15 of the CCB Program Rules v3.1 states that the validation/verification body shall adhere to all
instructional text within CCB & VCS Verification Report Template.

Section 4.3.8 of the CCB & VCS Veication Report Template, CCB v3.0, VCS v3.4 states, “Describe the steps
taken to verify the project proponent has implemented the project’s feedback and grievance redress
procedure.”
Under Section 4.3.8 of the verification report, the VVB states, “In 10 years of implementation project activities,
no grievance was reported regarding to the project activities or project staff.” However, the VVB does not
describe the steps take to reach this conclusion.
The VVB is requested to describe the steps taken to verify the project proponent has implemented the project’s
feedback and grievance redress procedure.”
VVB Response: Additional information has been added to section 4.3.8 of the verification report v 3.0 where
contain the description of the steps taken to verify the project proponent has implemented the project’s
feedback and grievance redress procedure.

Verra Response: The VVB has described the steps taken to verify the project proponent has implemented the
project’s feedback and grievance redress procedure. This finding is now closed, and no further response is
required.

Finding 31
Section 4.3.15 of the CCB Program Rules v3.1 states that the validation/verification body shall adhere to all
instructional text within CCB & VCS Verification Report Template.

Section 4.4.4 of the CCB & VCS Verification Report Template, CCB v3.0, VCS v3.4 states, “Describe the steps
taken to verify the actions taken to disseminate the results of climate monitoring in accordance with the
monitoring plan. Include details of documentation assessed and observations made during the site visit.
Provide and justify an overall conclusion as to whether the results of climate monitoring were disseminated in
accordance with the validated project description.”
Under Section 4.4.4 of the verification report, the VVB states, “The project proponent ensures that the
partners, stakeholders, and communities involved in project activities are up to date on the monitoring plan,
the monitoring reports, and the project summary. However, they do not describe the steps taken to come to
this conclusion.”
The VVB is requested to describe the steps taken to verify the actions taken to disseminate the results of
climate monitoring in accordance with the monitoring plan.
VVB Response: Section 4.4.4 of the updated verification report contain the description of the steps taken to
verify the actions taken to disseminate the results of climate monitoring in accordance with the monitoring
plan. It was added:

“The monitoring plan and monitoring results were disseminated through websites and interactions of the
project proponent with relevant stakeholders during the monitoring period, which the audit team verified
through interviews with project beneficiaries.

Finally, based on its field observations, the audit team concludes that the results of climate monitoring
results were disseminated in accordance with the validated project design”
Verra Response: The description of the steps taken to verify the actions taken to disseminate the results of
climate monitoring in accordance with the monitoring plan has been included in the verification report. This
finding is now closed, and no further response is required.

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Finding 32
Section 4.3.15 of the CCB Program Rules v3.1 states that the validation/verification body shall adhere to all
instructional text within CCB & VCS Verification Report Template.
Section 4.5.2 of the CCB & VCS Verification Report Template, CCB v3.0, VCS v3.4 states, “Describe the steps
taken to verify the actions taken to mitigate any negative well-being impacts on communities and for
maintenance or enhancement of the high conservation values attributes. Include details of documentation
assessed and observations made during the site visit. Provide and justify an overall conclusion as to whether
the mitigation actions were implemented in accordance with the validated project description.”
Under Section 4.5.2 of the verification report, the VVB states “The audit team has verified that the project did
not result in any net negative impact on the well-being of the communities and other stakeholder groups”
However, the VVB does not highlight the steps taken to reach this conclusion.
The VVB is requested to describe the steps taken to verify the actions taken to mitigate any negative well-being
impacts on communities and for maintenance or enhancement of the high conservation values attributes.
VVB Response: Section 4.5.2 of the verification report V3.0 contain the description of the steps taken to
verify the actions taken mitigate any negative well-being impacts on communities.

“The audit team interviewed local community members on site and confirmed that the information in
Monitoring Report was accurate and that there had been no potential negative impacts on the community.
The audit team verified the reported results through on-site inspections and interviews with project
participants”

Please refer to table 4 of the updated verification Report 3.0.


Verra Response: The VVB has included the steps taken to verify the actions taken to mitigate any negative
well-being impacts on communities and for maintenance or enhancement of the high conservation values
attributes. This finding is now closed, and no further response is required.

Finding 33
Section 4.3.15 of the CCB Program Rules v3.1 states that the validation/verification body shall adhere to all
instructional text within CCB & VCS Verification Report Template.
Section 4.5.3 of the CCB & VCS Verification Report Template, CCB v3.0, VCS v3.4 states, “Describe the steps
taken to verify that the net the impacts of project activities on all identified community groups are positive.
Include details of documentation assessed and observations made during the site visit. Provide and justify an
overall conclusion as to whether the net impact of project activities on community groups is positive.”
Under Section 4.5.3 of the verification report, the VVB states, “The audit team verified that the net impacts of
project activities on the community are positive.” However, they do not describe the steps taken to reach this
conclusion.
The VVB is requested to describe the steps taken to verify that the net impacts of project activities on the
community are positive.
VVB Response: Section 4.5.3 of the verification V3.0report contain the description of the steps taken to verify
that the net impacts of project activities on the community are positive.

“The audit team verified that the net impact of project activities on the community is positive. This was
demonstrated during the site visit and through interviews with the project beneficiaries”
Verra Response: The VVB has included the steps taken to verify that the net impacts of project activities on
the community are positive. This finding is now closed, and no further response is required.

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Finding 34
Section 4.3.15 of the CCB Program Rules v3.1 states that the validation/verification body shall adhere to all
instructional text within CCB & VCS Verification Report Template.
Section 4.5.6 of the CCB & VCS Verification Report Template states, “Describe the steps taken to verify that
the community impact monitoring has been carried out in accordance with the project’s validated design.
Include details that identify:
● The dates, frequency, and sampling methods used are in accordance with the validated project description.
● The results of monitoring.
● The evaluation of monitoring, including evaluations by the affected communities.
● The effectiveness of measures taken to maintain or enhance all identified high conservation values related
to community well-being.”
Under Section 4.5.6 of the verification report, the VVB states, “The audit team verified that the community
impact monitoring carried out in accordance with the project’s validated design.” However, the VVB does not
provide details on the steps taken to verify that the community impact monitoring has been carried out in
accordance with the project’s validated design, including the details required.
The VVB is requested to describe the steps taken to verify that the community impact monitoring has been
carried out in accordance with the project’s validated design, including required details.
VVB Response: Section 4.5.6 of the verification report V3.0 contain the description of the steps taken to
verify that the community impact monitoring has been carried out in accordance with the project’s validated
design.

“The audit team verified that:

- On-site and through interviews, the audit team confirmed that the dates, frequency and sampling
methods used were consistent with the validated project description.

- The audit team confirmed the results and assessment of monitoring through on-site observations
and interviews.

- The audit team confirmed the effectiveness of actions taken to maintain or improve all identified
high conservation values related to community well-being.

The audit team verified the reported results through analyzing documents and interviews with project
participants. The audit team understands that the project was successfully implemented. Given the
assessment documentation, interviews and site observations, the audit team concludes that the results of
the monitoring plan are consistent with the validated project design”
Verra Response: The VVB has added the steps taken to verify that the community impact monitoring has
been carried out in accordance with the project’s validated design. This finding is now closed, and no further
response is required.

Finding 35
Section 4.3.15 of the CCB Program Rules v3.1 states that the validation/verification body shall adhere to all
instructional text within CCB & VCS Verification Report Template.

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Finding 35

Section 4.6.1 of the CCB & VCS Verification Report Template, CCB v3.0, VCS v3.4 states, “Describe the steps
taken to verify the reported changes in biodiversity in the project zone due to project activities. Describe the
steps to verify the project’s impacts, including:
● The accuracy and appropriateness of monitored data.
● The justification used to attribute biodiversity changes to the project’s activities.

Include details of documentation assessed and observations made during the site visit. Provide and justify an
overall conclusion as to whether the project’s assessment of changes in biodiversity resulting from project
activities in the project zone during the monitoring period are accurate.”
Under Section 4.6.1 of the verification report, the VVB states, “The audit team verified the reported changes in
biodiversity in the project zone due to project activities.” However, the VVB does not describe the steps taken
to verify the projects’ impacts, including the accuracy and appropriateness of monitored data and the
justification used to attribute biodiversity changes to the project’s activities.
The VVB is requested to describe the steps taken to verify the projects’ impacts, including the accuracy and
appropriateness of monitored data and the justification used to attribute biodiversity changes to the project’s
activities.
VVB Response: Section 4.6.1 of the verification report v 3.0 contain the description of the steps taken to
verify the projects’ impacts, including the accuracy and appropriateness of monitored data and the
justification used to attribute biodiversity changes to the project’s activities.
“During the monitored period, the audit team verified in on-site inspections that the conservation of the
project areas allows the maintenance or increase of biodiversity in relation to the species registered of fauna
and sighted during the field trips”

Verra Response: The VVB has added the steps taken to verify the projects’ impacts, including the accuracy
and appropriateness of monitored data and the justification used to attribute biodiversity changes to the
project’s activities. This finding is now closed, and no further response is required.

2. MINOR FINDINGS
The project proponent frequently refers to Annexes in the monitoring report. However, Annexes are not
included in the current version of the monitoring report and are not uploaded to the registry. The PP is
requested to include the Annexes accordingly.

PP response: all annexes associated with the findings raised by the Verra review, which have not yet been
uploaded to the registry platform, will be made available, the annexes are D, D1 (updated with minor
changes), E, F, H, P, Q (updated after verra findings adjustments), R and S
https://drive.google.com/drive/folders/1B4xEqN_ZDZ3FoOI0xerPX8TYiYYygg2o?usp=sharing

VVB Response: Numeral 4.3.6, 4.3.8, and 4.6.11 in the verification report v3.0 were also improved and
updated.
The links to the Annexes have been provided.

3. ASSESSMENT CONCLUSION

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On 17 February 2022, Verra sent the project review report with 35 assessment findings and one minor
finding to Earthood Services Private Limited and Oréades Núcleo De Geoprocessamento Renato Moreira.

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