Climate, Community and Biodiversity Design Standards ......Climate, Community and Biodiversity ... project proponents, review of supporting records and reports. ... Municipality to

Climate, Community and Biodiversity Project Design Standards

(Second Edition – December 2008)

Project Validation Report: Buffelsdraai Landfill Site Community Reforestation Project

Version: 1

Validation Report Date: 24 July 2014

Validation Conducted by:

Environmental Services, Inc. Forestry, Carbon, and GHG Services Division

Corporate Offices at: 7220 Financial Way, Suite 100 Jacksonville, Florida 32256

Phone: 904‐470‐2200; Fax: 904‐470‐2112

Project No. VO11053.00

Buffelsdraai Landfill Site Community Reforestation Project

068‐FOR‐CCBA Validation Report Template – final – v3 2 Controlled Document 21 June 2013

TableofContents Introduction ..................................................................................................................................... 4

Contact Information ........................................................................................................................ 4

Validation Details ........................................................................................................................... 5

Validation Standard .................................................................................................................... 5

Validation Criteria ...................................................................................................................... 5

Level of Assurance ..................................................................................................................... 5

Validation Date(s) ....................................................................................................................... 6

Materiality ................................................................................................................................... 6

Site Visits .................................................................................................................................... 6

Final Documents from Client ...................................................................................................... 6

Public Comment Period on CCBA ............................................................................................. 6

Number of Comments Received ................................................................................................. 6

Project Description .......................................................................................................................... 6

Executive Summary of Validation Results ..................................................................................... 7

Validation Findings ......................................................................................................................... 7

G1 Original Conditions in the Project Area ........................................................................... 7

G2 Baseline Projections ....................................................................................................... 13

G3 Project Design and Goals ............................................................................................... 17

G4 Management Capacity and Best Practices ..................................................................... 22

G5 Legal Status and Property Rights ................................................................................... 26

CL1 Net Positive Climate Impacts ..................................................................................... 28

CL2 Offsite Climate Impacts (“Leakage”) ......................................................................... 33

CL3 Climate Impact Monitoring ........................................................................................ 36

CM1 Net Positive Community Impacts ............................................................................... 38

CM2 Offsite Stakeholder Impacts ....................................................................................... 39

CM3 Community Impact Monitoring .................................................................................. 40

B1 Net Positive Biodiversity Impacts .................................................................................. 42

B2 Offsite Biodiversity Impacts .......................................................................................... 44

B3 Biodiversity Impact Monitoring ..................................................................................... 46

Gold Level Section ....................................................................................................................... 48

GL1 Climate Change Adaptation Benefits ......................................................................... 48



GL2 Exceptional Community Benefits ............................................................................... 49

Public Shareholder Comments ...................................................................................................... 52

Local Shareholder Comments ................................................................................................... 52

CCB Public Comment Period ................................................................................................... 52

Public Meetings ........................................................................................................................ 53

Validation Conclusion .................................................................................................................. 53

Submittal Information ................................................................................................................... 53

Appendix A – Documents Reviewed / Received .......................................................................... 55



Climate, Community & Biodiversity Alliance Buffelsdraai Landfill Site Community Reforestation Project Validation

Report

Introduction This report presents the findings of an audit conducted by Environmental Services, Inc., (ESI), to validate that the claims made by Wildlands Conservation Trust conform to the Climate, Community and Biodiversity Project Design Standards (Second Edition- December 2008). ESI is accredited by the American National Standards Institute (ANSI) under ISO 14065:2007 for greenhouse gas validation and verifications bodies and is approved by the Climate, Community & Biodiversity Alliance (CCBA) to perform such validations.

Contact Information Client Name Address Phone Website

Wildlands Conservation Trust P.O. Box 1138 Hilton, South Africa 3245 033-343-6380 www.wildlands.co.za

Contact Name Address Phone

Andrew Whitley P.O. Box 1138 Hilton, South Africa 3245 033-343-6380

3rd Party Auditors Environmental Services, Inc. Lead Validator Stewart McMorrow – ([email protected] / 530-525-2232) Validation Team Shawn McMahon – Validation Team Member([email protected] /

330-833-9941) Caitlin Sellers – Validation Team Member ([email protected] / 904-

361-8227) Richard Scharf – Validation Team Member ([email protected] / 252-

402-7354) Janice McMahon – QA/QC ([email protected] / 330-833-9941)



Validation Details Validation Standard Climate, Community and Biodiversity Project Design

Standards (Second Edition – December 2008)

Validation Criteria The criteria will follow the validation guidance documents provided by CCBA located at www.climate-standards.org. These documents include the following: a) Project Design Standards (Second Edition,

December 2008) b) Rules for the use of the Climate, Community &

Biodiversity Standards, December 2013.

Level of Assurance The level of assurance was used to determine the depth of detail that the validator placed in the validation plan to determine if there were any errors, omissions, or misrepresentations (ISO 14064-3:2006). ESI selected samples of data and information to be validated, to provide reasonable assurance.

Validation Scope The scope of the validation included the review of all project documentation provided by the project developer and the appropriate level of fact finding by the validator during the on-site visit. The validator used evidence such as, but not limited to, interviews with stakeholders and project proponents, review of supporting records and reports.



Validation Date(s) 07 October 2011 – 21 July 2014

Materiality Materiality is a concept that errors, omissions and misrepresentations could affect the project design assertions and influence the intended users. CCB does not specifically outline a materiality threshold, but ESI used a 5% threshold for evidence. . However, for PDD validations, the specific level of materiality does not apply. The materiality of a CCBA validation is based on an evaluation of whether or not the proposed project design (PDD) is consistent with the CCB Project Design Standards criteria (Second Edition). If a non-conformance is discovered, the project developer is given the opportunity to correct the non-conformance to the PDD within a reasonable timeframe (within 30 days). If the non-conformance is corrected, the level of assurance has been met, the project design is recommended for validation approval. If the non-conformance cannot be met, the project design will not be validated. For this project, all non-conformances were corrected, so the project design is herewith validated.

Site Visits 2 November 2014 – 4 November 2014

Final Documents from Client CCBA_PDD_Buffelsdraai_with_NCR3_v2.docx

Please see Appendix A for a complete list of documents received/reviewed during this validation.

Public Comment Period on CCBA

Number of Comments Received

15 October-14 November 2011 – Project listing on CCB website for public comment Second public comment period- June 24 - July 24, 2013

0

Project Description The Buffelsdraai Landfill Site Community Reforestation Project was initiated by the eThekwini Municipality to offset GHG emissions generated by hosting the FIFA World Cup in Durban, in 2010. The project site is within the Buffelsdraai Landfill buffer zone, and will reduce emissions and increase sequestration of atmospheric carbon in biomass and soils by converting cropland to native forest. Over 500 hectares of sugarcane land is being planted, in phases, with 61 locally occurring indigenous tree species.



It would also increase biodiversity by increasing natural habitat, reduce soil erosion and provide employment during the years of planting operations.

Executive Summary of Validation Results Criterion Required/

Optional Conformance Y/N or N/A

G1 Original Conditions in the Project Area Required Y G2 Baseline Projections Required Y G3 Project Design and Goals Required Y G4 Management Capacity and Best Practices Required Y G5 Legal Status and Property Rights Required Y CL1 Net Positive Climate Impacts Required Y CL2 Offsite Climate Impacts (“Leakage”) Required Y CL3 Climate Impact Monitoring Required Y CM1 Net Positive Community Impacts Required Y CM2 Offsite Stakeholder Impacts Required Y CM3 Community Impact Monitoring Required Y B1 Net Positive Biodiversity Impacts Required Y B2 Offsite Biodiversity Impacts Required Y B3 Biodiversity Impact Monitoring Required Y GL1 Climate Change Adaptation Benefits Optional Y GL2 Exceptional Community Benefits Optional Y GL3 Exceptional Biodiversity Benefits Optional N/A

Validation Findings

G1 Original Conditions in the Project Area Indicator 1 – The location of the project and basic physical parameters (e.g. soil, geology, climate).

The Project Description (PDD) provides a detailed description of the location of the Buffelsdraai Landfill Site Community Reforestation Project, located in the province of KwaZulu-Natal, South Africa, approximately 25km north of Durban. The PDD also provides a detailed narrative of soils, geology and climate.

Evidence Used to Assess Conformance:

PDD, field visit and discussions/demonstration of project location with field staff.

Findings: Validation findings supported the information provided in the PDD.



Indicator 2 – The types and condition of vegetation within the project area.

The PDD provides a description of the existing regional vegetation, which is broadly described as KwaZulu-Natal Coastal Belt Grassland. The project areas are primarily cultivated land which consists of sugar cane cropland and grassland with a few scattered tree clumps.


PDD, vegetation summary worksheet, field visit and discussions with the project proponent and field staff.


Request to address non-conformance (NCR):

n/a

Date issued n/a Project proponent response/actions and date

n/a

Evidence used to close CAR n/a Date closed n/a Indicator 3 – The boundaries of the project area and the project zone.

The PDD discusses the project area, buffer zone and greater project zone. The boundaries for these areas are mapped in GIS format and are sufficient to confirm location and boundaries.


PDD, Figures 1, 4 and 5, field visit, discussions/demonstration of parcel boundaries with field staff.

Findings: Validation findings supported the information provided in the PDD, However, this section of the PDD does not detail the exact project area.


Please provide detail as to the exact area of the project area in this section. Is the landfill site (116 ha) part of the project area?

Date issued 27 October 2011 Project proponent response/actions and date

Statement added to page 6 of PDD

Evidence used to close NCR Section G1.3 now clearly states that the project area does not include the landfill site, but only the buffer area.

Date closed 22 May 2014 Indicator 4 - Current carbon stocks within the project area(s), using stratification by land-use or vegetation type and methods of

The PDD describes two aspects of the project areas as they relate to current practices for use of the cultivated lands. These are active sugar cane production areas and fallow areas. Carbon stocks are



carbon calculation (such as biomass plots, formulae, default values) from the Intergovernmental Panel on Climate Change’s 2006 Guidelines for National GHG Inventories for Agriculture, Forestry and Other Land Use5 (IPCC 2006 GL for AFOLU) or a more robust and detailed methodology.

considered to be zero based on current activities.


PDD description.

Findings: Project description does not appear to use a method of calculation for the assumption that current carbon stocks are considered to be zero.


Please apply a method for carbon calculation from the Intergovernmental Panel on Climate Change’s 2006 Guidelines for National GHG Inventories for Agriculture, Forestry and Other Land Use (IPCC 2006 GL for AFOLU) or a more robust and detailed methodology.


IPCC 2006 Guidelines for AFOLU was used, with calculations based on peer-reviewed literature. Aboveground woody biomass will be estimated through measurements, as yet unspecified. Belowground woody biomass uses an IPCC ratio. SOC will be conservatively excluded due to the cost of monitoring. Herbaceous carbon, deadwood and carbon in the litter layer are also conservatively excluded. Current C stocks are the default tier 1 value for perennial cropland in dry, tropical areas. Data and conversion ratios for sugar cane biomass were taken from various referenced sources.


Please confirm that sugarcane is grown as a perennial crop on these lands. In several places, the PDD indicates the land may be cleared annually. Also, please provide sources referenced in Table 2.

Date issued: 05 June 2014 Project proponent response/actions and date:

Sugarcane is grown is a perennial crop, the harvesting of which involves removing the above



ground biomass (the sugarcane), the plant then regrows through coppicing from the root stock. Copies of sources referenced in Table 2 submitted


Carbon content of sugarcane dry matter is 42.46%, according to de Figueriredo et al. Root:shoot ratio of 0.21% not found in Smith, et al. Please fix the typo regarding the sugarcane dry matter content. Please point out where the 0.21% root:shoot ratio can be found in Smith.

Evidence used to close NCR: The project proponent confirms sugarcane is grown as a perennial crop. References provided for table 2, typos corrected. Root to shoot ratio was corrected to be 18%, which represents the average across the lifespan of the sugarcane crop. This was confirmed in the Smith, et. al. paper. Issue is addressed.

Date closed 21 July 2014 Indicator 5 - A description of communities located in the project zone, including basic socio-economic and cultural information that describes the social, economic and cultural diversity within communities (wealth, gender, age, ethnicity etc.), identifies specific groups such as Indigenous Peoples8 and describes any community characteristics.

The PDD includes a description of the structure of the communities in the project zone and provided info regarding distribution by gender, distribution by age, ethnicity, marital status, HIV infection levels, literacy levels, occupational status, and annual income.


PDD, discussions with project proponent.

Findings: Project description does not appear to identify any specific groups as indigenous peoples.


Please provide information regarding the presence or absence of any indigenous peoples or communities in the project area. Under CCB, ‘Indigenous Peoples’ are defined as distinct, vulnerable, social and cultural groups whose members identify themselves as belonging to an indigenous cultural group.



Evidence used to close NCR: The PDD now includes a statement that no indigenous peoples live within the project area.



Date closed 05 June 2014 Indicator 6 - A description of current land use and customary and legal property rights including community property in the project zone, identifying any ongoing or unresolved conflicts or disputes and identifying and describing any disputes over land tenure that were resolved during the last ten years (see also G5).

The PDD describes the land as being owned by the eThekwini Municipality while a portion is still leased to the previous owner, Tongaat Hulett. The area has long been under this type of property ownership, and there are no land claims or unresolved property disputes within the project area. Other documentation provided further details this relationship of ownership and lease agreement.


PDD, Appendix C attachments A, B and C. Discussions with project proponent pending regarding final lease termination dates.

Findings: Validation findings supported the information provided in the PDD and appendices.

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

The PDD provides a description of the current biodiversity within the project areas and project zone, and how it has been drastically impacted by sugar cane production and invasive nonnative plant infestation.


PDD and Appendix A, Biodiversity Assessment conducted by Eco-Pulse Environmental Consultants

Findings: Validation findings supported the information provided in the PDD and supporting documents.

Indicator 8 - An evaluation of whether the project zone includes any of the following High Conservation Values (HCVs) and a description of the qualifying attributes. Indicator 8.1 - Globally, regionally or nationally significant concentrations of biodiversity values: a. protected areas

b. threatened species

c. endemic species

d. areas that support significant

The PDD provides details of how the project zone meets high conservation values for threatened and endemic species and threatened ecosystems. Many portions of the project area have been largely transformed, and as a result, the distribution and abundance of naturally occurring species has been significantly disturbed. PDD indicates that large parts of the project zone have a mandatory conservation status. Attached documents detail the findings of biodiversity surveys and show maps from Ezemvelo KZN Wildlife.



concentrations of a species during any time in their lifecycle (e.g. migrations, feeding grounds, breeding areas). Indicator 8.2 - Globally, regionally or nationally significant large landscape-level areas where viable populations of most if not all naturally occurring species exist in natural patterns of distribution and abundance. Indicator 8.3 Threatened or rare ecosystems. Indicator 8.4 - Areas that provide critical ecosystem services (e.g., hydrological services, erosion control, fire control). Indicator 8.5 - Areas that are fundamental for meeting the basic needs of local communities (e.g., for essential food, fuel, fodder, medicines or building materials without readily available alternatives). Indicator 8.6 - Areas that are critical for the traditional cultural identity of communities (e.g., areas of cultural, ecological, economic or religious significance identified in collaboration with the communities). Evidence Used to Assess Conformance:

PDD, Appendix A, Table 4 and Table 5. Biodiversity Assessment conducted by Eco-Pulse Environmental Consultants




G2 Baseline Projections Indicator 1 - Describe the most likely land-use scenario in the absence of the project following IPCC 2006 GL for AFOLU or a more robust and detailed methodology,

describing the range of potential land use scenarios and the associated drivers of GHG emissions and justifying why the land-use scenario selected is most likely.

The PDD provides a discussion of the current land use practices, lease agreement and assumption that this situation would continue without change under the current iteration. Given this history of land use, the PDD determines that the most likely land-use scenario is sugar cane production under a lease agreement with the previous land owner.


PDD and Appendix C.

Findings: Project description does not appear to use IPCC 2006 GL for AFOLU or a more robust and detailed methodology.


Please apply a method for determining a most likely land use scenario from the IPCC 2006 Guidelines for National GHG Inventories for Agriculture, Forestry and Other Land Use (IPCC 2006 GL for AFOLU) or a more robust and detailed methodology.


Statement added to PDD see page20

Evidence used to close NCR: In section G2.1 of the updated PDD the project proponent states that the eThekwini Municipality developed plans for the area. It is assumed the land use plan envisioned leaving the land in present sugarcane production.


Please provide the pertinent parts of the eThekwini Municipality Development Plan.

Date issued: 05 June 2014 Project proponent response/actions and date:

Northern Spatial Development Plan (2012/2013 revision) submitted Refer to Landuse Map (figure 24 on page 60)

Evidence used to close NCR: According to the land use map in the NSDP document, the land is envisioned as remaining in agriculture.

Date closed 21 July 2014 Indicator 2 - Document that project benefits would not have occurred in the absence of the project, explaining

PDD describes alternative land use scenarios, investment analysis, barrier analysis and common practice analysis. These analyses describe the most



how existing laws or regulations would likely affect land use and justifying that the benefits being claimed by the project are truly ‘additional’ and would be unlikely to occur without the project.

likely possible future use of the project area, describe limitations on land use practices to agricultural use within buffer zones of landfills and describe the current land use GHG emissions from these activities.


PDD and Appendix C, copy of lease agreement between Municipality and previous property owner.

Findings: Project description does not appear to completely outline the difference between the with-project and without-project scenarios from a financial analysis point of view.


While it is understood that the project description provides financial analysis for the without project scenario, please provide a financial analysis for the with-project scenario for comparison showing costs and revenues, if any.


Reforestation cashflow spreadsheet attached

Evidence used to close CAR Reforestation Cashflow spreadsheet indicates the cost of planting and maintaining the land in the with-project scenario.

Date closed 05 June 2014 Indicator 3 - Calculate the estimated carbon stock changes associated with the ‘without project’ reference scenario described above. This requires estimation of carbon stocks for each of the land-use classes of concern and a definition of the carbon pools included, among the classes defined in the IPCC 2006 GL for AFOLU. The timeframe for this analysis can be either the project lifetime (see G3) or the project GHG accounting period, whichever is more appropriate. Estimate the net change in the emissions of non-CO2 GHG emissions such as CH4 and N2O in the ‘without project’ scenario. Non-CO2

The PDD describes, under the baseline scenario, the estimated emissions from continued cultivation of sugarcane in the project area. While the net change in the carbon pool located in the biomass of the sugar cane crop is assumed to be zero, the actions associated with that cultivation is assumed to be generating carbon emissions. The PDD also details the non-CO2 GHG emissions from Baseline Activity.



gases must be included if they are likely to account for more than 5% (in terms of CO2-equivalent) of the project’s overall GHG impact over each monitoring period. Projects whose activities are designed to avoid GHG emissions (such as those reducing emissions from deforestation and forest degradation (REDD), avoiding conversion of non-forest land, or certain improved forest management projects) must include an analysis of the relevant drivers and rates of deforestation and/or degradation and a description and justification of the approaches, assumptions and data used to perform this analysis. Regional-level estimates can be used at the project’s planning stage as long as there is a commitment to evaluate locally-specific carbon stocks and to develop a project-specific spatial analysis of deforestation and/or degradation using an appropriately robust and detailed carbon accounting methodology before the start of the project. Evidence Used to Assess Conformance:

PDD pages 18-20 and Table 6 showing potential carbon emissions from the cultivation of 520.6 ha for the production of sugarcane.

Findings: The project description does not detail the carbon stock changes associated with the biomass of the sugar cane crop itself. There appears to be an error in the statement of 448 ha on line 4 page 20.


Please provide calculations that estimate the carbon stock changes associated with the ‘without project’ reference scenario for each of the land-use classes of concern and a definition of the carbon pools included, among the classes defined in the IPCC 2006 GL for AFOLU. Further, please correct the equation or mis-statement on page 20 under “Non-CO2 GHG Emissions from Baseline Activity.”

Date issued 27 October 2011



Project proponent response/actions and date

Section re-written see pages 21-26 of PDD

Evidence used to close NCR: The project developer states that sugar cane production does not lead to significant changes in SOC or the below ground biomass pool, and are therefore not included in the calculation of changes in carbon stock. Only the change in perennial cropland biomass is considered.


While sugarcane is often grown as a perennial crop, this section sometimes describes a cultivation scenario for an annual crop. "The net change in the carbon pool located in the biomass of a sugar cane crop over a year is considered to be zero, as it is burnt, harvested and the land is cleared at the end of each growing season." On one hand, factors for perennial crops are used. On the other, biomass is assumed to be zero, because sugarcane is claimed to be an annual crop. Please confirm whether sugarcane should be treated as an annual crop or a perennial woody crop and provide reasoning.

Date Issued: 05 June 2014 Project proponent response/actions and date:

In this situation sugarcane has been considered a perennial crop as the plant does not die annually and is not replanted annually. The harvesting of sugar cane involves removing the above ground biomass (the sugarcane) annually but the plant then regrows through coppicing from the below ground biomass.

Evidence used to close NCR: It is now clear that sugarcane was grown as a perennial crop in the project area.

Date closed 21 July 2014 Indicator 4 - Describe how the ‘without project’ reference scenario would affect communities in the project zone, including the impact of likely changes in water, soil and other locally important ecosystem services.

The PDD details the negative aspects of the baseline scenario that include denial of access to the land, job losses and the loss or deterioration of ecosystem services from the continued cultivation of sugar cane and the associated activities.


PDD, site visit (pending), discussion with project proponents.




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

The PDD sufficiently demonstrates how the without project scenario would affect biodiversity in the project zone, providing that the indigenous trees and additional forest cover will have a positive effect by improving connectivity and corridors among the protected natural areas.


PDD, Appendix A, Biodiversity Assessment performed by Eco-Pulse.

Findings: Validation findings supported the information provided in the PDD

G3 Project Design and Goals Indicator 1 - Provide a summary of the project’s major climate, community and biodiversity objectives.

The PDD clearly outlines the project’s major climate, community and biodiversity objectives, which include: To restore forest habitats that are strategic from a biodiversity protection and management perspective. To assist the municipality in offsetting the climate change impact of hosting the 2010 FIFA World Cup. To provide employment and income opportunities to impoverished communities living adjacent to the project area. To restore catchment areas with the intention of improving the management of water flow and sediment flows that is important to down-stream estuaries and tourist beaches.


PDD


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

The PDD sufficiently details the project activities, including

The establishment of a network of Tree-preneurs

The establishment of a market for the trees propagated by the Tree-preneurs

Establishment of GREEN TEAMS that use the Trees propagated by the Tree-preneurs to green the Programme’s communities

Baselines and data collection, including



community workshops, outreach Planting Biomass Assessments Tree Planting


PDD

Findings: Validation findings supported the information provided.

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

PDD includes a map that sufficiently identifies the project location, boundaries, where projects will occur and of additional communities affected by the project.


Page 26 of PDD and map Figure 9

Findings: PDD and supporting map confirms compliance with G.3.3.

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

PDD provides the project accounting period of 20 years starting in 2008 and ending in 2028. PDD states the area will be maintained as a nature preserve indefinitely after 2028. Implementation of planting starting in 2008 is outlined in Table 7 and lists the planting schedule and anticipated carbon sequestration rates. PDD does not state key dates or milestones.


Pages 27 and 39 of PDD and Table 7 (page 39).

Findings: PDD defines the project lifetime, start date and accounting period, but does not state specific key dates or milestones.


Please clarify when final planting will be complete and when nature preserve status is expected to be attained. Please define an implementation schedule for additional project activities besides planting, with key dates and milestones in the project’s development.




Information added, see page 32 of PDD. Table 7 has been removed, but is still referred to. This section is not complete enough to address this element.


Please replace the Table 7 that appears to have been removed from this section of the PDD. Please define an implementation schedule for additional important project activities besides planting, with key dates and milestones in the project’s development.

Date issued 05 June 2014 Project proponent response/actions and date

Table 7 has not been removed it is still in section CL1.1 where it is was previously (pg 46) Additional milestones added

Evidence used to close NCR: Table outlining schedule and milestones added to G3.4. Request to replace Table 7 is withdrawn.

Date closed 21 July 2014 Indicator 5 - Identify likely natural and human-induced risks to the expected climate, community and biodiversity benefits during the project lifetime and outline measures adopted to mitigate these risks.

PDD sufficiently describes natural and human caused risks. These risks include illegal harvest of trees, fire, drought and invasive species. Mitigations to each of these risks are described. Fire management is attained by an onsite fire crew and regular maintenance of fire breaks. Illegal tree harvest is controlled through limiting access to the site. Drought is managed by planting the trees during optimum growth conditions and invasive plant species is controlled by having laws that dictate removals of such. Finally, the property is owned by a public entity, and thus the risk of development is nonexistent.


PDD pages 27 and 28, Appendix D

Findings: PDD and supporting documents confirm compliance with G.3.5.

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

PDD describes several measures that the project proponents intend to apply. These include reversals of biodiversity through plantings of native trees rather than production of sugar cane, removal of alien plants, registration of the project site as a conservancy and formal nature preserve and through existing fire management program. It is unclear however what the legal protections and long term funding associated with being a nature preserve will



entail. Evidence Used to Assess Conformance:

PDD page 28.

Findings: PDD describes elements of compliance with G.3.6. However, some supporting documentation is needed.


Please provide details, timeframe and funding involved in creation of conservancy and/or nature preserve status.


Information added see page 34 of PDD

Evidence used to close NCR: A national law provides the guidelines for proclaiming protected areas, which will be followed to formally protect the project area as a preserve. Funding will be provided by local governments.

Date closed 05 June 2014 Indicator 7 - Describe the measures that will be taken to maintain and enhance the climate, community and biodiversity benefits beyond the project lifetime.

PDD describes the intention of the eThekwini Municipality’s intention to register the entire buffer zone as a formal nature preserve. Further, this status will continue to provide employment for fire protection and invasive species reduction.


PDD page 28

Findings: As stated previously, further information is needed to describe the details of registration as a nature preserve.


See G 3.6


As above

Evidence used to close NCR: As described above, the land will be formally declared a nature preserve, and will be maintained by local governments.

Date closed 05 June 2014 Indicator 8 - Document and defend how communities and other stakeholders potentially affected by the project activities have been identified and have been involved in project design through effective consultation, particularly with a view

This program is a completely voluntary program for individuals who are interested in becoming tree-preneurs. Several meetings have been held in order to sign up interested parties and disseminate information. Participation is open to any local residents. Community leaders have been involved in selection of workers and facilitators from local



to optimizing community and stakeholder benefits, respecting local customs and values and maintaining high conservation values. Project developers must document stakeholder dialogues and indicate if and how the project proposal was revised based on such input. A plan must be developed to continue communication and consultation between project managers and all community groups about the project and its impacts to facilitate adaptive management throughout the life of the project.

communities are now being used to help recruit temporary workers from the local communities. This represented a change from previous practices in hiring and is now the current approach. Local ward Councilors and Committee members have attended and are still invited to all management meetings.


Pages 28 and 29 of PDD, Appendix D.


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

Project proponents will advertise the intent to apply for a CCBA validation in local newspapers, notices placed at community centers in local communities, copies of the document will be made available to local stakeholders, community members, and the local civic centers. Ward committee members and community facilitators will receive comments and will report to the CCBA via the project manager.


Page 29 of the PDD

Findings: PDD confirms compliance with G.3.9. Indicator 10 - Formalize a clear process for handling unresolved conflicts and grievances that arise during project planning and implementation. The project design must include a process for hearing,

The project area has been owned and operated by a public entity on public land, and therefore has not displaced any residents nor has it been used by any local residents for agriculture or harvesting of non-timber products. A project steering committee has been established that consists of a diverse array of



responding to and resolving community and other stakeholder grievances within a reasonable time period. This grievance process must be publicized to communities and other stakeholders and must be managed by a third party or mediator to prevent any conflict of interest. Project management must attempt to resolve all reasonable grievances raised, and provide a written response to grievances within 30 days. Grievances and project responses must be documented.

interest groups and is in place to respond to situations that arise as a result of this project. There exists a monitoring committee that meets regularly with the local councilor acting as a member and voice for local community members. Thus far no objections have been received. Legal contracts are in place between project partners that allows for conflict resolution. Employment disputes are covered under the South African Labour Department and adherence to these laws is a condition of contract between project partners.


PDD pages 29 and 30, Appendix C and E


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

The eThekwini Municipality has identified the Buffelsdraai Landfill site project and subsequent registration of the landfill site buffer zone as a nature conservancy as a long term objective. Official documentation is provided from the Municipality stating this long term commitment.


Page 30 of the PDD, Appendix D and C.

Findings: PDD and supporting documents support the requirement of G.3.11.

G4 Management Capacity and Best Practices Indicator 1 - Identify a single project proponent which is responsible for the project’s design and /aimplementation. If multiple organizations or individuals are involved in the project’s development and implementation the governance structure, roles and responsibilities of each of the organizations or

The project proponent is eThekwini Municipality and is the entity that provides funding for the reforestation project. The Wildlands Conservation Trust is implementing the reforestation aspects of the project. PRUNIT is employed to handle the planting and clearing of alien plants.



individuals involved must also be described. Evidence Used to Assess Conformance:

PDD page 30 and 31 and organogram in Figure 10 of the PDD.

Findings: Project documentation adequately addresses the requirements of G.4.1.

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

Project proponents have demonstrated their experience as managers in the various aspects of this project through describing the roles, responsibilities and experience of the key team members. Further, the team members have successfully managed this project for at least two years to date. No information is included in regards to carbon stock measurement or monitoring experience.


PDD pages 31 and 32 and Appendix D.

Findings: Documentation demonstrates compliance with most of G.4.2., However, specific carbon stock monitoring or measurement experience is not listed.


Please provide any information regarding team members experience with carbon stock measurement or monitoring.


Section added, see pages 38‐39 of PDD

Evidence used to close NCR: The project developer hired consultants Tony Knowles and Leon-Jacques Theron of the Cirrus Group, and listed some of their education, experiences and publications. These indicate considerable experience in the development of carbon projects.

Date closed 05 June 2014 Indicator 3 - Include a plan to This PDD lists a thorough and diverse orientation and



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

training program.


Pages 32 and 33 of PDD and Table 6

Findings: Project documentation adequately addresses the requirements of G.4.3.


n/a

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

The PDD describes an inclusive and open hiring process that includes men, women and youths. Tree-prenuers are on a voluntary basis and are therefore no impacted by employment equity issues. The project proponent has demonstrated that is does not discriminate based on gender, education or social status.


Page 33 and 34 of PDD

Findings: The project is in compliance with G.4.4. Indicator 5 - Submit a list of all relevant laws and regulations covering worker’s rights in the host country. Describe how the project will inform workers about their

PDD describes all relevant laws and describes how contracts and work agreements make these laws and rights clear to workers. Adherence to the relevant labor laws is a condition of all contracts between the Municipality and the Wildlands Conservation Trust.



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. Evidence Used to Assess Conformance:

PDD pages 34 and 35, Appendix E.

Findings: PDD addresses compliance with G.4.5. Indicator 6 - Comprehensively assess situations and occupations that pose a substantial risk to worker safety. A plan must be in place to inform workers of risks and to explain how to minimize such risks. Where worker safety cannot be guaranteed, project proponents must show how the risks will be minimized using best work practices.

PDD assures that all workers are provided with necessary safety training and equipment to address safety.


Page 35 of PDD.

Findings: PDD adequately describes compliance with G.4.6. Indicator 7 - Document the financial health of the implementing organization(s) to demonstrate that financial resources budgeted will be adequate to implement the project.

PDD indicates sound financial solvency and yearly auditing as well as project inclusion in yearly Municipal budgets. PDD does not include any financial statements. However, it does indicate that financial statements are provided to auditors.


PDD

Findings: While the PDD does state financial solvency and regular provision of financial statements to auditors, a current financial statement showing budget inclusion is needed.


Please provide a current financial statement that shows inclusion of this project.


The project is not specifically listed in the current financial statements but, the “Reforestation Project”



which includes Buffelsdraai and Inanda is included in the eThekwini Municipality’s Medium Term Expenditure Framework (attached) on pages 4.8, 20 and 23

Evidence used to close CAR It is clear, from the above-described document that the municipality is dedicated to conservation projects like this one, and Buffelsdraai is specifically mentioned in the budget.

Date closed 05 June 2014

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

The PDD provides sufficient detail regarding all relevant national and local laws, and any applicable national or international obligations.


PDD

Findings: PDD adequately addresses the provisions of G.5.1. Indicator 2 - Document that the project has approval from the appropriate authorities, including the established formal and/or traditional authorities customarily required by the communities.

PDD includes a letter of approval by the eThekwini Municipality


PDD page 36 and Appendix C

Findings: Project documents appear to adequately address G.5.2.

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

Project proponent adequately describes the property ownership. The project will only take place on the property of the project proponent. Project will not encroach on land owned by other entities.




PDD page 36

Findings: Project documentation confirms compliance with G.5.3.

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

The PDD sufficiently discusses that the project does not require the involuntary relocation of people or of the activities important for the livelihoods and culture of the communities affected. The project area has been under sugar cane production since at least 1934. The previous owner sold the property to the Municipality under its own free will, and thus there have thus no relocations or forced removals of people.


PDD page 36

Findings: Project appears to be in compliance with G.5.4. Indicator 5 - Identify any illegal activities that could affect the project’s climate, community or biodiversity impacts (e.g., logging) taking place in the project zone and describe how the project will help to reduce these activities so that project benefits are not derived from illegal activities.

PDD describes only limited opportunities for illegal activity associated with this project. Collection of medicinal plants, arson and illegal harvest of trees. The PDD states that access is historically restricted, and further, the project has developed good will amongst the communities who have developed a sense of ownership over the project. There is a fire management prevention plan in place.


PDD page 36, site visit (pending)

Findings: Validation findings support the information provided in the PDD.

Indicator 6 - Demonstrate that the project proponents have clear, uncontested title to the carbon rights, or provide legal documentation demonstrating that the project is

Project proponents have demonstrated clear uncontested title to the carbon rights generated from this project.



undertaken on behalf of the carbon owners with their full consent. Where local or national conditions preclude clear title to the carbon rights at the time of validation against the Standards, the project proponents must provide evidence that their ownership of carbon rights is likely to be established before they enter into any transactions concerning the project’s carbon assets. Evidence Used to Assess Conformance:

PDD page 36 and Appendix C

Findings: PDD and Appendix C prove compliance with G.5.6.

CL1 Net Positive Climate Impacts Indicator 1 - Estimate the net change in carbon stocks due to the project activities using the methods of calculation, formulae and default values of the IPCC 2006 GL for AFOLU or using a more robust and detailed methodology. The net change is equal to carbon stock changes with the project minus carbon stock changes without the project (the latter having been estimated in G2). This estimate must be based on clearly defined and defendable assumptions about how project activities will alter GHG emissions of carbon stocks over the duration of the project or the project GHG accounting period.

PDD outlines a net carbon stock change over 20 years of 42214.0 tCO2e and a yearly average sequestration rate per year of 2110.7 tCO2e. These figures are based on information gathered during an inventory of adjacent forests as well as experience in the restoration of similar forests in the region. This information was compared to past inventory information by Glenday (2007) and carbon stocks estimations compared favorably to the actual carbon stocks measured during the project proponent’s inventory. Information presented appears to have relevance, however it is not clear that the methodology presented is similar or more robust than the methods, formulae and default values used in the IPCC 2006 GL for AFOLU.


PDD pages 37-39, Table 7, Figure 11 and Figure 12.

Findings: While a result is presented using a seemingly detailed methodology, there is not corresponding supporting documentation showing comparisons, default values or calculations to compare against stated standard methodologies.


Please either provide reference and supporting materials that detail the methodologies, values,



formulas and calculations that support the methodologies used to calculate net change in carbon stocks, or provide access information for our review. We need to see that this methodology is equal to or more robust than the stated standard approach. Alternatively please use the IPCC 2006 GL for AFOLU methodologies for this section.


Section re‐written see pages 44‐47 of PDD

Evidence used to close CAR The project is using a simple carbon stock change method from the IPCC 2006 guidelines. Project is incorporating AG, BG and perennial cropland biomass pools. The project uses data from (Glenday 2007) as a means for estimating the average per hectare carbon stock increase value for planted trees. “Glenday (2007) determined the rehabilitation and reforestation potential of various sites within the municipality as part of the inventory and concluded that project site had the potential to return to Dry Valley Thicket/Broadleaf Woodland, although a small portion might have the potential to return to Coastal Scarp Forest which has a significantly higher mean carbon density (Glenday 2007). “ For the perennial cropland biomass pool used to reduce potential emissions from tree planting, the project area is calculated as 520 ha, but the project area is 520.6 ha. The calculation in section CL1.1 indicates the change in carbon due to cropland biomass is 1.19tCha, but this equates to 619.51, not 618.8 as listed in the PDD and based on the total project area of 520.6 rather than only 520 ha. It is unclear how the calculations are being conducted in table 7. Please offer an explanation of all the variables that are being combined and calculated. Please provide a live calculation spreadsheet so validators can replicate these calculations.


Please provide a description of the elements that make up the calculations in Table 7. Please provide a live calculation spreadsheet so validators can replicate these calculations. Please correct calculations that use the total project



area so that the correct project area figure is used (520.6 ha)


Description of elements added to Live calculations spreadsheet submitted Calculations corrected to use 520.6 ha as total project area

Evidence used to close NCR: Live calculation spreadsheet provided, with a description of the elements. 520.6 ha used as total project area.

Date closed 21 July 2014 Indicator 2 - Estimate the net change in the emissions of non-CO2 GHG emissions such as CH4 and N2O in the with and without project scenarios if those gases are likely to account for more than a 5% increase or decrease (in terms of CO2-equivalent) of the project’s overall GHG emissions reductions or removals over each monitoring period.

PDD estimates 2589 tCO2 e of emissions generated through farming activities, application of fertilizers, herbicides and the burning of cane prior to harvest will be avoided as this project is implemented.


Page 40 of PDD, Calculations in G.2.3., Pages 18-20 of PDD.

Findings: PDD does not show calculations that estimate carbon stock changes associated with the biomass contained in the above or below ground stocks of sugar cane.


Please provide calculations that estimate the carbon stock changes associated with the ‘without project’ reference scenario for each of the land-use classes of concern and a definition of the carbon pools included, among the classes defined in the IPCC 2006 GL for AFOLU.


calculations added to page 47 of PDD

Evidence used to close NCR: Baseline greenhouse gas emissions from the cultivation of 520.6 ha for the production of sugarcane are presented in Table 6 and emissions due to the pre-harvest burning of cane Calculations for these elements are all included in section G2.3 of the PDD. These are transcribed into section CL1.2 as just the totals. These changes in non-co2 GHG emissions



are due to the halt of fires and preparation for planting of sugar cane. The project has adequately accounted for the net change in these sources.

Date closed 05 June 2014 Indicator 3 - Estimate any other GHG emissions resulting from project activities. Emissions sources include, but are not limited to, emissions from biomass burning during site preparation, emissions from fossil fuel combustion, direct emissions from the use of synthetic fertilizers, and emissions from the decomposition of N-fixing species.

PDD estimates GHG emissions generated from project activities from the planting of trees and subsequent delivery of those trees to the planting site. No fertilizers will be used, nor will there be any burning. PDD does not state what will occur during the invasive species eradication phase of site preparation or from ongoing maintenance.


Page 40 of PDD, site visit (pending).

Findings: PDD shows calculations for vehicle emissions but does not state any further emissions due to site preparation activities.


Please state what actions are taken and estimate the carbon effects from invasive species eradication and site preparation.


Statement added to pages 47-48 of PDD

Evidence used to close NCR The project indicates that the site preparation is done using hand tools and a small brushcutter. The validators agree that the use of a small gas powered brushcutter is unlikely to result in emissions that are material enough to warrant the calculation of these emissions. Issue is addressed.

Date closed 05 June 2014 Indicator 4 - Demonstrate that the net climate impact of the project is positive. The net climate impact of the project is the net change in carbon stocks plus net change in non-CO2

GHGs where appropriate minus any other GHG emissions resulting from project activities minus any likely project-related unmitigated negative

The PDD demonstrates that the net reduction in atmospheric GHG’s due to the project activity over 20 years will be 45007.8 tCO2e. This figure is shown as the change in carbon emissions verses the sequestrations due to the project activities. No unmitigated negative offsite climate impacts are listed.



offsite climate impacts (see CL2.3). Evidence Used to Assess Conformance:

Pages 40 and 41 of PDD, including calculations from previous sections.

Findings: Calculations support the finding of net climate benefits from the project activities and related emissions reductions, however the calculations used in this section are based on previous sections where more info is needed.


Please apply calculations needed to correct sections G.1.4 and G.2.3.and use to recalculate this section.


Section re-written see pages 48 of PDD

Findings: Calculations support the finding of net climate benefits from the project activities and related emissions reductions, however the calculations used in this section are using whole numbers and thus are not correct as the input values are not including the decimal place values found in each.


Please recalculate these figures using the actual figures found in each of the input values. Please label Table X appropriately since there is already a Table X in G2.3.

Date issued 05 June 2014 Project proponent response/actions and date:

Table re-numbered

Evidence used to close NCR: Table X is now Table 8. GHG emissions from pre-harvest fire changed, reflecting use of actual figure from section G2.3.

Date closed: 21 July 2014 Indicator 5 - Specify how double counting of GHG emissions reductions or removals will be avoided, particularly for offsets sold on the voluntary market and generated in a country with an emissions cap.

The PDD sufficiently demonstrates that measures will be taken to avoid double counting of GHG removals. Specifically, announcements will be posted on the websites of both the Municipality and the Wildlands Conservation Trust as well as project details will be communicated to the national climate change office for inclusion in South Africa’s next National Communication to the UNFCCC as a project scale land use based emission reduction activity.


PDD page 41



Findings: PDD description supports validation of CL.1.5.

CL2 Offsite Climate Impacts (“Leakage”) Indicator 1 - Determine the types of leakage that are expected and estimate potential offsite increases in GHGs (increases in emissions or decreases in sequestration) due to project activities. Where relevant, define and justify where leakage is most likely to take place.

PDD sufficiently outlines the types and potential leakage sources and demonstrates that leakage is not anticipated from these sources. These sources include shift in sugar cane productions from lost fields, firewood harvesting and fire. PDD does not provide written proof from Tongaat Hulett that they do not plan to shift sugar cane production elsewhere.


Statements in PDD page 41, site visit (pending), discussions with project proponent.

Findings: PDD discusses potential leakage and findings support validation, except provision of written proof of cessation of sugar cane production on other lands.


Please provide written assurance from Tongaat Hulett that they do not plan to shift sugar cane production elsewhere due to loss of project area fields.


Statements added to page 49 of PDD

Findings: The project description does not offer any kind of assurance that Tongaat Hulett will not purchase more land and shift agricultural activities to another location in response to removing the project areas from production.


Please provide some level of reasonable evidence that supports the claim that leakage will not occur due to activity shifting in the form of total acres owned before and after the project or other direct statement from Tongaat Hulett. Verifiers need more specific descriptive information on the nature of the relationship with this entity for confirmation.


According to official statistics provided by the Department of Agriculture, Forestry and Fisheries, the total area planted to sugar cane in South Africa in the growing season prior to the project start (2007/2008) was 423000 hectares in the, 2012/2013 season the area planted was 372000 hectares (DAFF – Abstract of agricultural statistics, 2013, Table 27). This supports the statement that total area planted to



sugar cane has reduced over the project implementation period

Evidence used to close NCR:

According to the agricultural statistics, the area planted to sugarcane has been decreasing each year since the 2005/2006 season, and similar decreases are seen with other crops. Clearing native vegetation for agricultural conversion is an expensive process, and a grower seeking to replace crop land would most likely seek land presently in agricultural production. In addition, table 6 of the agricultural statistics show a steadily decreasing number of farm units and total area under agricultural production in South Africa, making it even more unlikely that the grower would need to clear native vegetation to replace cropland. Verifiers have examined the data provided by the project as well as considered the evidence gained during the site visit and find this issue to be reasonably confirmed.

Date closed 21 July 2014 Indicator 2 - Document how any leakage will be mitigated and estimate the extent to which such impacts will be reduced by these mitigation activities.

The PDD lists controlling access and fire control and mitigation efforts as mitigations to any potential leakage. PDD does not state how it will garner assurance from Tongaat Hulett regarding shifting of sugar cane operations elsewhere.


PDD, Page 42 site visit (pending), discussion with project proponent

Findings: PDD adequately addresses most issues, with exception to the potential for leakage due to displacement of sugar cane operations.


Please provide written assurance from Tongaat Hulett that they do not plan to shift sugar cane production elsewhere due to loss of project area fields.



Findings: The project description does not offer any kind of assurance that Tongaat Hulett will not purchase more land and shift agricultural activities to another location in response to removing the project areas from production.




Please provide some level of reasonable evidence that supports the claim that leakage will not occur due to activity shifting in the form of total acres owned before and after the project or other direct statement from Tongaat Hulett. Verifiers need more specific descriptive information on the nature of the relationship with this entity for confirmation.


According to official statistics provided by the Department of Agriculture, Forestry and Fisheries, the total area planted to sugar cane in South Africa in the growing season prior to the project start (2007/2008) was 423000 hectares in the, 2012/2013 season the area planted was 372000 hectares (DAFF – Abstract of agricultural statistics, 2013, Table 27). This supports the statement that total area planted to sugar cane has reduced over the project implementation period

Evidence used to close NCR: According to the agricultural statistics, the area planted to sugarcane has been decreasing each year since the 2005/2006 season. In addition, the land area dedicated to agriculture in South Africa is shrinking. If the grower moves production to other lands, it would likely be to land already under agricultural production, and therefore not constitute leakage.

Date closed 21 July 2014 Indicator 3 - Subtract any likely project-related unmitigated negative offsite climate impacts from the climate benefits being claimed by the project and demonstrate that this has been included in the evaluation of net climate impact of the project (as calculated in CL1.4).

PDD states that no offsite negative climate impacts will occur.


Page 42, PDD

Findings: Pending results of CL2.2. Request to address non-conformance (NCR):

Pending results of CL2.2.

Date issued 27 October 2011 Project proponent response/actions n/a



and date Evidence used to close NCR Indicator CL2.2 was adequately addressed. No

negative offsite climate impacts should be expected from a project of this nature in this area.

Date closed July 2014 Indicator 4 - Non-CO2 gases must be included if they are likely to account for more than a 5% increase or decrease (in terms of CO2-equivalent) of the net change calculations (above) of the project’s overall off-site GHG emissions reductions or removals over each monitoring period.

PDD states that no offsite negative non-CO2 climate impacts will occur.


Page 42, PDD, site visit (pending), discussion with project proponents

Findings: Validation confirms compliance with CL.2.4 Corrective Actions Requests (CAR)Request to address non-conformance: (NCR):

Pending results of CL2.2.

Date issued Pending results of CL2.2. Project proponent response/actions and date

27 October 2011

Evidence used to close NCR Indicator CL2.2 was successfully addressed. No negative offsite climate impacts should be expected from a project of this nature in this area.

Date closed July 2014

CL3 Climate Impact Monitoring Indicator 1 - Develop an initial plan for selecting carbon pools and non-CO2 GHGs to be monitored, and determine the frequency of monitoring. Potential pools include aboveground biomass, litter, dead wood, belowground biomass, wood products, soil carbon and peat. Pools to monitor must include any pools expected to decrease as a result of project activities, including those in the region outside the project boundaries resulting from all types of leakage identified in CL2. A plan

PDD describes the purposes of the monitoring plan as ensuring the net reduction of GHG emissions is estimated in a robust manner, leakage is measured and reported, changes in GHG emissions and carbon stocks are measured. The PDD lists the methods for estimating current carbon emissions and future increases in carbon stocks. PDD lists the use of Glenday (2007) as a means for monitoring woody biomass annually.



must be in place to continue leakage monitoring for at least five years after all activity displacement or other leakage causing activity has taken place. Individual GHG sources may be considered ‘insignificant’ and do not have to be accounted for if together such omitted decreases in carbon pools and increases in GHG emissions amount to less than 5% of the total CO2-equivalent benefits generated by the project. Non-CO2

gases must be included if they are likely to account for more than 5% (in terms of CO2-equivalent) of the project’s overall GHG impact over each monitoring period. Direct field measurements using scientifically robust sampling must be used to measure more significant elements of the project’s carbon stocks. Other data must be suitable to the project site and specific forest type. Evidence Used to Assess Conformance:

Page 42 of PDD

Findings: The PDD does not include details of the Glenday (2007) methodology, nor does it list frequency for monitoring. The PDD does not list methods for leakage monitoring for at least 5 years.


Please include details of the Glenday (2007) methodology as well as frequency for monitoring, leakage monitoring details, and list all pools that will be monitored.


Information added to page 50 of PDD

Findings: Only the above-ground woody biomass will be monitored, along with GHGs emitted during reforestation and management operations. It will be repeated every 12 months. Glenday articles provided.

Date Issued: 05 June 2014 Indicator 2 - Commit to developing PDD describes that the project proponent is



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

committed to develop a detailed monitoring plan within 12 months of validation and lists that this plan will be available for peer review.


Page 42 of PDD

Findings: Most elements of CL.3.2 are met, however PDD does not list methods for communicating results as per CL.3.2.


Please include methods used to make results of monitoring plan available to communities and stakeholders.



Evidence used to close NCR: The monitoring plan and results will be made available on the Wildlands website, the project office and it will also be distributed at the monitoring committee for the landfill site.

Date closed: 05 June 2014

CM1 Net Positive Community Impacts Indicator 1 - Use appropriate methodologies to estimate the impacts on communities, including all constituent socio-economic or cultural groups such as indigenous peoples (defined in G1), resulting from planned project activities. A credible estimate of impacts must include changes in community well-being due to project activities and an evaluation of the impacts by the affected groups. This estimate must be based on clearly defined and defendable assumptions about how project activities will alter social and economic well-being, including

The PDD and PIR sufficiently estimate the impacts on communities, resulting from the planned project activities. The estimate is based on clearly defined and defendable assumptions about how project activities will alter social and economic well-being, including potential impacts of changes in food supply job creation, access to education and ecosystem services identified as important by the communities. Some of the community benefits resulting from the project activities include job creation, access to infrastructure resources, increased cohesion levels within the community, access to education, food security, improved natural resource benefits, and environmental awareness and education. Negative impacts were considered and these seem to



potential impacts of changes in natural resources and ecosystem services identified as important by the communities (including water and soil resources), over the duration of the project. The ‘with project’ scenario must then be compared with the ‘without project’ scenario of social and economic well-being in the absence of the project (completed in G2). The difference (i.e., the community benefit) must be positive for all community groups.

have been mitigated. These included loss of permanent jobs from displaced sugar cane production, but these jobs were relocated to other operations within the company resulting in net zero job losses. Temporary job losses from sugar cane productions were somewhat replaced by temp jobs in reforestation.


Pages 43 -52 of PDD and Tables 8 and 9, Figures 13-21, Appendix B, site visit (pending)

Findings: Validation is confirmed based on information and findings for CM1.1.

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

The PDD sufficiently states that the project will have no negative impact on HCV areas. This is primarily because the project takes place on private lands that have been under sugar can cultivation for generations. Project activities (planting of trees) do not cause displacement or move activities to the HCV areas since the project area was never included in those activities historically. The planting of woodlots on previously impacted agricultural lands improves biodiversity and helps connect dispersed HCV areas with canopy.


Page 52 of PDD, site visit (pending), discussion with project proponent.

Findings: Information provided and validation findings support conformance with CM1.2.

CM2 Offsite Stakeholder Impacts Indicator 1 - Identify any potential negative offsite stakeholder impacts that the project activities are likely to cause.

The PDD sufficiently considers potential negative impacts on stakeholders. Because the project takes place on private lands and tree planting is economically beneficial to local communities, there are few potential impacts to offsite stakeholders. These include limited access to the buffer zone due to it becoming a conservation area.



Displacement of sugar cane farming Community discontent around the limitation for new community members to join the program.


Page 53 of PDD, Table 10, Discussion with project proponent and field staff.

Findings: Validation findings support conformance with CM2.1.

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

PDD describes possible mitigation measures for each of the possible negative offsite social and economic impacts. These include a management plan for community input and consultation regarding status of the buffer zone. Analysis of potential job losses from sugar cane production displacement. Strengthening community communications regarding expectation management for future program development and expansion.


Page 53 of PDD, Table 10, discussion with project proponent and field staff.


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

PDD states that the reduction in sugar cane production is the only possible impact on other stakeholders groups, and as listed previously, job losses were only seen in the temporary jobs market which is being mitigated through new job creations in reforestation. Due to the farms small size and low productivity, this is stated to be an insignificant impact.


PDD page 53, site visit (pending), discussion with field staff.

Findings: Information presented and validation findings support conformance with CM 2.3.

CM3 Community Impact Monitoring Indicator 1 - Develop an initial plan for selecting community variables to be monitored and the frequency of monitoring and reporting to ensure that monitoring variables are directly

The PDD proposes an initial plan sufficient for selecting community variables to be monitored and the frequency of monitoring and reporting.



linked to the project’s community development objectives and to anticipated impacts (positive and negative). Evidence Used to Assess Conformance:

PDD page 53-55, Table 10, site visit (pending) discussion with project proponent.


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

The PDD states that there are no areas of High Conservation Value related to community well-being within the project area. This is detailed in Tables 4 and 5, page 16, G.1.8.


PDD page 55, Page 16, Tables 4 and 5.

Findings: Validation findings and information in PDD support conformance with CM 3.2.

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

PDD describes that the project proponent is committed to develop a detailed monitoring plan within 12 months of validation and lists that this plan will be available for peer review.


Page 55 of PDD, site visit (pending), discussion with project proponent.

Findings: Most elements of CM 3.3.are met, however PDD does not list methods for communicating results as per CM 3.3.


Please include methods used to make results of monitoring plan available to communities and stakeholders.





Evidence used to close NCR: Statements added to page 64 (not 65) say the monitoring plan and results will be posted to the Wildlands website, printed copies will be available at the project office, and they will be presented at the monitoring committee meeting for the landfill site.


B1 Net Positive Biodiversity Impacts Indicator 1 - Use appropriate methodologies to estimate changes in biodiversity as a result of the project in the project zone and in the project lifetime. This estimate must be based on clearly defined and defendable assumptions. The ‘with project’ scenario should then be compared with the baseline ‘without project’ biodiversity scenario completed in G2. The difference (i.e., the net biodiversity benefit) must be positive.

The PDD sufficiently demonstrates that appropriate methodologies were utilized to estimate changes in biodiversity. The project areas are grasslands or croplands on private lands owned by a public municipality They have a history of sugar cane production and accordingly the baseline biodiversity is extremely low. Planting the abandoned sugar cane fields with indigenous trees will improve the connectivity of wildlife between natural forests.


Pages 56-58 of PDD, Appendix A, Biodiversity Assessment by Eco-Pulse

Findings: The PDD appears to appropriately compare the project scenario to the baseline without project scenario, demonstrating a positive change, though the PDD and the corresponding attachment A do not appear to reference the “potential tools and strategies” recommended by CCB in Appendix A.


Please discuss why the “potential tools and strategies” recommended by CCB in Appendix A were not referenced in the study produced by Eco-Pulse.


Section added to page 66 of PDD

Evidence used to close CAR The section added to page 67 states that the tools recommended by CCB are international tools, while the local conservation authority has developed a locally relevant tool, the KwaZulu-Natal Terrestrial Systematic Conservation Plan, which was used, along with the IUCN Red List and South Africa's red list.




Indicator 2 - Demonstrate that no High Conservation Values identified in G1.8.1-3 will be negatively affected by the project.

The PDD states that no areas of High Conservation Value will be negatively impacted and that conservation of neighboring areas is likely to be enhanced through increasing habitat connectivity between threatened ecosystems. The PDD does not reference any supporting documentation to further secure conformance with this statement.


PDD page 58, site visit (pending) and discussion with project proponent.

Findings: Conformance with B.1.2 needs additional supporting documentation.


Please add reference to supporting documentation to demonstrate this statement.


Reference to appendix added, see page 67 of PDD

Evidence used to close NCR: Reference to supporting documentation in appendix A was provided. The biodiversity assessment concludes that no negative biodiversity impacts are anticipated as a result of the project.

Date closed 05 June 2014 Indicator 3 - Identify all species to be used by the project and show that no known invasive species will be introduced into any area affected by the project and that the population of any invasive species will not increase as a result of the project.

PDD states and lists species that will be used for reforestation on the project area. Further the PDD states the legal obligations for clearing alien species in the project area and the ongoing efforts as such.


Page 58 of PDD, Table 12, page 57.

Findings: The PDD provides the list of species that will/have been planted, and references a law which prevents the planting of invasive species, but does not provide the name of or reference to the law for confirmation.


Please provide the name of or reference to the law prohibiting planting of native species for confirmation.


Information added to page 66 of PDD

Evidence used to close CAR The PDD now cites the Conservation of Agricultural Resources Act 43 of 1983.



Date closed 05 June 2014 Indicator 4 - Describe possible adverse effects of non-native species used by the project on the region’s environment, including impacts on native species and disease introduction or facilitation. Project proponents must justify any use of non-native species over native species

The PDD sufficiently describes that under no circumstances will nonnative species be used.


PDD, page 58, site visit (pending), discussion with project proponent.

Findings: The PDD sufficiently describes that under no circumstances will nonnative species be used.

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

PDD guarantees no GMO’s will be used and that only seeds from local, indigenous trees are used in the project for reforestation.


Page 58, PDD, site visit (pending)

Findings: Validation findings support the information provided in the PDD. Site visit (pending)

B2 Offsite Biodiversity Impacts Indicator 1 - Identify potential negative offsite biodiversity impacts that the project is likely to cause.

PDD states that the project is not envisaged to result in any negative offsite biodiversity impacts. PDD does not reference any demonstration or evaluation resulting from project activities.


Page 58, PDD. Site visit (pending)

Findings: PDD needs to indicate how this was evaluated or reference evaluation performed.


Please demonstrate how this indicator was evaluated. CCB Standards Manual States under B2 “The project proponents must evaluate and mitigate likely negative impacts on biodiversity outside the project zone resulting from project activities.”


see page 66 of PDD

Evidence used to close CAR The PDD refers to the biodiversity study, which



states that no negative offsite impacts are anticipated Date closed 05 June 2014

Indicator 2 - Document how the project plans to mitigate these negative offsite biodiversity impacts.

PDD states that the project is not envisaged to result in any negative offsite biodiversity impacts, therefor no mitigations are needed. PDD does not reference any demonstration or evaluation resulting from project activities.


PDD, pages 58



Please demonstrate how this indicator was evaluated. CCB Standards Manual States under B2 “The project proponents must evaluate and mitigate likely negative impacts on biodiversity outside the project zone resulting from project activities.”


see page 67 of PDD

Evidence used to close CAR The biodiversity study, now referenced, states no negative impacts are anticipated, therefore no mitigation is planned. Negative impacts are highly unlikely in a project of this nature.

Date closed 05 June 2014 Indicator 3 - Evaluate likely unmitigated negative offsite biodiversity impacts against the biodiversity benefits of the project within the project boundaries. Justify and demonstrate that the net effect of the project on biodiversity is positive.

PDD states that the project is not envisaged to result in any negative offsite biodiversity impacts and that the net biodiversity impact will be positive. PDD does not reference any demonstration or evaluation of net project benefits resulting from project activities.


PDD, page 58



Please rename this section to an appropriate heading that mirrors the CCB Standards section B.2.3. Please demonstrate how this indicator was evaluated. CCB Standards Manual States under B2 “The project proponents must evaluate and mitigate likely negative impacts on biodiversity outside the



project zone resulting from project activities.” Date issued 27 October 2011 Project proponent response/actions and date

see page 67 of PDD

Evidence used to close NCR: Section was renamed. The PDD now refers to the study in appendix A, concluding no negative impacts are expected.


B3 Biodiversity Impact Monitoring Indicator 1 - Develop an initial plan for selecting biodiversity variables to be monitored and the frequency of monitoring and reporting to ensure that monitoring variables are directly linked to the project’s biodiversity objectives and to anticipated impacts (positive and negative).

PDD and supporting documents describe the initial plan for selecting biodiversity variables to be monitored and the frequency of monitoring and reporting.


PDD page 59 and Appendix A, Section 8

Findings: PDD and supporting documents describe the initial plan for selecting biodiversity variables to be monitored and the frequency of monitoring and reporting. However the potential tools and strategies” recommended by CCB in Appendix A were not referenced in the study (location of the plan) produced by Eco-Pulse.


Please discuss why the “potential tools and strategies” recommended by CCB in Appendix A were not referenced in the study produced by Eco-Pulse.

Project proponent response/actions and date

see page 67 of PDD

Evidence used to close NCR: The recommended tools were not referenced because a locally developed planning tool was more appropriate.

Date closed 05 June 2014 Indicator 2 - Develop an initial plan for assessing the effectiveness of measures used to maintain or enhance

PDD and supporting documents discuss the requirements to develop an initial plan for assessing effectiveness of measures used to maintain or



High Conservation Values related to globally, regionally or nationally significant biodiversity (G1.8.1-3) present in the project zone.

enhance High Conservation Values related significant biodiversity present in the project zone.

Findings: PDD and supporting documents discuss the requirements to develop an initial plan for assessing effectiveness of measures used to maintain or enhance High Conservation Values related significant biodiversity present in the project zone.


Page 59, PDD, Appendix A, Section 8

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

PDD states that the project developer is committed to development of a detailed monitoring plan within 12 months of validation and to make the plan available for peer review. PDD does not state how the plan will be made publicly available on the internet and communicated to the communities and other stakeholders, nor how the results of monitoring will be made available.


PDD page 59

Findings: PDD does not state how the plan will be made publicly available on the internet and communicated to the communities and other stakeholders, nor how the results of monitoring will be made available.


Please state how the plan will be made publicly available on the internet and communicated to the communities and other stakeholders, nor how the results of monitoring will be made available.


see page 68 of PDD

Evidence used to close CAR Plans for distributing the monitoring plan and its results include posting on the Wildlands website, making printed copies available at the project office, and presenting the plan and results at the monitoring committee meeting for the landfill site.




GoldLevelSectionGL1 ClimateChangeAdaptationBenefits Indicator 1 - Identify likely regional climate change and climate variability scenarios and impacts, using available studies, and identify potential changes in the local land-use scenario due to these climate change scenarios in the absence of the project.

PDD describes possible climate change attributes for the region and gives reference materials for studies that have occurred. PDD does not list potential changes in local land use scenarios due to these climate change scenarios in the absence of the project.


PDD, page 60, supporting documents listed for reference, Web sites listed as supporting documents.

Findings: PDD does list predicted climate change impacts, but does not list potential changes in the local land use as a result of these changes.


Please describe or provide supporting documentation to describe potential changes in local land use as a result of climate change in the absence of the project. Reference to information found in GL.1.4.


Statement added to PDD, see page 68

Evidence used to close NCR: The updated PDD states that increased temperatures are expected to increase yields from sugar crops. Therefore the land is likely to remain in sugarcane production in the absence of the project.

Date closed 05 June 2014 Indicator 2 - Identify any risks to the project’s climate, community and biodiversity benefits resulting from likely climate change and climate variability impacts and explain how these risks will be mitigated.

PDD lists examples of biodiversity and community benefit risks as being unlikely to negatively affect the project benefits. The PDD explains that the local communities do not rely on subsistence farming and thus are not anticipated to deforest this project site for agriculture. Further, the project area will benefit surrounding species richness and abundance by providing corridors and suitable habitat for species that may need to shift geographic range due to climate change.


PDD pages 60 and 61.

Findings: PDD description confirms conformance with GL.1.2. Indicator 3 - Demonstrate that current PDD sufficiently details possible climate change



or anticipated climate changes are having or are likely to have an impact on the well-being of communities

and/or the conservation status of biodiversity in the project zone and surrounding regions.

impacts to the greater eThekwini municipal area and gives reference to supporting documentation, however does not list specific or likely impacts on communities and biodiversity.


PDD page 61

Findings: PDD section GL.1.3 does not specifically list impacts or likely impacts on communities or biodiversity and references section GL. 1.1, however the impacts appear to be provided in detail in section GL. 1.4..


Please include a reference to section GL. 1.4 as this section lists the likely impacts on communities and biodiversity.


Reference to section GL1.4 included

Evidence used to close NCR: Reference added, but please fix typo: "above" should be changed to "below."

Date closed 05 June 2014 Project proponent response/actions and date

Typo fixed

Evidence used to close NCR: The typo was fixed. Date closed 21 July 2014 Indicator 4 - Demonstrate that the project activities will assist communities53 and/or biodiversity to adapt to the probable impacts of climate change.

The PDD sufficiently demonstrates that project activities will assist communities and biodiversity to adapt to the probable impacts of climate change.


PDD pages 61 and 62 and reference to section GL.1.1.

Findings: Information and reference material is adequate for conformance with GL.1.4.

GL2 ExceptionalCommunityBenefits Indicator 1 - Demonstrate that the project zone is in a low human development country OR in an administrative area of a medium or high human development country in which at least 50% of the population

PDD demonstrates that the project is within a Medium development country and lies within the province of KwaZulu-Natal where 54.3% of the population lives below the national poverty line.



of that area is below the national poverty line. Evidence Used to Assess Conformance:

PDD page 62 and reference to information in Indicator G.1.5.

Findings: Validation findings support conformance with GL.2.1Request to address non-conformance (NCR):

Please renumber indicator numbers in this section (they indicate GL1 however this is section GL2).

Date issued: 27 October 2011 Project proponent response/actions Section renumbered, see pages 71-72 of PDD Evidence used to close CAR: Sections have been renumbered. Date closed: 05 June 2014 Indicator 2 - Demonstrate that at least 50% of households within the lowest category of well-being (e.g., poorest quartile) of the community are likely to benefit substantially from the project.

The PDD adequately addresses that the project is contributing to reducing poverty and enhancing the sustainable livelihood of some of the most vulnerable and poor groups in South Africa society, however it does not make specific reference to the materials used to support these claims.


PDD pages 62 and 63

Findings: PDD makes suitable claims towards conformance to this indicator, however needs to add reference material.


Please add reference to specific the study done to confirm claims made.

Date issued: 27 October 2011 Project proponent response/actions reference added Evidence used to close NCR: The PDD now references appendix B, Final report to

Wildlands Conservation Trust: social assessment of the Buffelsdraai Landfill Site Community Reforestation Project.

Date closed 05 June 2014 Indicator 3 - Demonstrate that any barriers or risks that might prevent benefits going to poorer households have been identified and addressed in order to increase the probable flow of benefits to poorer households.

PDD states that anyone within the project zone is welcome to participate in the program and there are no barriers preventing poorer households from receiving benefits from the project.


PDD page 63

Findings: PDD makes suitable claims towards conformance to



this indicator, however needs to add reference material.


Please add suitable references to demonstrate claims made in this indicator.

Date issued: 27 October 2011 Project proponent response/actions Statement and reference added to page 71 of PDD Evidence used to close NCR: The PDD provides a reference to appendix D, which

includes a detailed description of the effort to recruit "tree-preneurs." This kind of effort is clearly designed to include all interested parties.

Date closed 05 June 2014 Indicator 4 - Demonstrate that measures have been taken to identify any poorer and more vulnerable households and individuals whose well-being or poverty may be negatively affected by the project, and that the project design includes measures to avoid any such impacts. Where negative impacts are unavoidable, demonstrate that they will be effectively mitigated.

PDD describes that possible job losses from reduction in sugar cane farming may impact poor and vulnerable households but that these will be mitigated by increases in job opportunities from this project. Also stated is the community leadership selection of poorer households as being identified for employment.


PDD page 63 and Indicator GL.1.2.

Findings: The PDD does not give enough evidence of demonstration of this indicator.


Please reference supporting documentation that demonstrates that this indicator is being fulfilled.

Date issued: 27 October 2011 Project proponent response/actions Statement and reference added to page 71 of PDD Evidence used to close NCR: The PDD now references appendix B (the social

assessment), which indicates the project will create 21 or more permanent jobs, while only 8 jobs will be lost.

Date closed 28 May 2011 Indicator 5 - Demonstrate that community impact monitoring will be able to identify positive and negative impacts on poorer and more vulnerable groups. The social impact

PDD lists surveys that have been developed for community impact monitoring that record monthly household income which will allow for a differentiated approach to the monitoring. PDD does not list any reference material or link to the survey



monitoring must take a differentiated approach that can identify positive and negative impacts on poorer households and individuals and other disadvantaged groups, including women.

document.


Page 63 of the PDD

Findings: PDD does not list any reference material or link to the survey documents that would support this statement.


Please demonstrate through supporting documentation of this survey method and plans.

Date issued: 27 October 2011 Project proponent response/actions Reference added to page 71 of PDD Evidence used to close CAR The PDD references the annual survey tool in the

social assessment in Appendix B. Date closed 05 June 2014

Public Shareholder Comments Public comments for CCBA were solicited in two ways; posting of the PDD to the CCBA website, announcements at the Monitoring Committee meetings and posted at several public locations throughout the communities near the project area. ESI confirms that all comments were addressed and is satisfied with the results of the public shareholder/stakeholder meetings outreach programs.

Local Shareholder Comments The PDD was made available at two libraries (KwaMashu and Verulam Libraries) and the eThekwini Environmental Planning and Climate Protection Department, as well as on the CCBA website. Meetings were held where the content of the PDD was presented and explained. Community members were given the opportunity to discuss, question and provide feedback. Community members were encouraged to submit written comments to community coordinators. (see Public Meetings info below.)

CCB Public Comment Period The project PDD was posted to the CCBA website for the formal 30-day public comment period (15 October – 14 November 2011). No comments were received. The PDD was reposted to the CCBA on 24 June 2013. No comments were received.



Public MeetingsWildlands Conservation Trust Monitoring Committee held several public meetings in response to the need to publicize the project and to gather public input. There is a monitoring committee for the Buffelsdraai landfill site that meets regularly (as required by legislation). The committee members represent the relevant stakeholders, and these committee meetings are used as the forum to distribute documents and information and to address queries from the stakeholders. The PDD was presented at committee meetings that were held during the comment periods. A meeting on October 6th, 2011 was used to present the initial project design and a second was held on June 6, 2013, followed by a site visit where stakeholders were informed again about the reforestation project and the public comment process.

Validation Conclusion ESI confirms all validation activities, including objectives, scope and criteria, level of assurance and the PDD adherence to the CCB Project Design Standards, Second Edition, as documented in this report are complete. ESI concludes without any qualifications or limiting conditions that the CCB Project Design Documentation Buffelsdraai Landfill Site Community Reforestation Project (21 July 2014), meets the requirements of the CCB Project Design Standards (Second Edition – December 2008) and two Gold Level Benefits, including Climate Change Adaptation and Exceptional Community Benefits.

Submittal Information Report Submitted to: Andrew Whitley

c/o Wildlands Conservation Trust P.O. Box 1138 Hilton, South Africa 3245 Climate, Community& Biodiversity Alliance

Report Submitted (CCBA-Approved Verifier) by:

Environmental Services, Inc. 7220 Financial Way, Suite 100 Jacksonville, Florida 32256

Lead Validator and Regional Technical Manager (QA/QC) Names and Signatures:

Stewart McMorrow – Lead Validator



Janice McMahon – Vice President and Regional Technical Manager Forestry, Carbon, and GHG Services Division

Date: 24 July 2014

RS/SPM/JPM/rbVO11053.00/ CCB Val Report_Final 24July2014.doc K:pf 07/24/14f



Appendix A – Documents Reviewed / Received Documents received 07 July 2011

Buffelsdraai_Landfill_CCBA_PDD_Climate DRAFT.pdf Appendix 3 - Project Fact Sheet.pdf Appendix 5 - Buffelsdraai leaflet 2010.pdf

Documents received 28 September 2011

CCBA_PDD_Buffelsdraai.pdf Documents received 10 October 2011

CCBA_PDD_Buffelsdraai.pdf Documents received 11 October 2011

APPENDIX A Buffelsdraai Biodiversity Assessment.pdf APPENDIX B Buffelsdraai Social Assesment.pdf APPENDIX C Letter from eThekwini Municiplaity.pdf Appendix C.A - Sale Agreement Appendix C.B - Lease Termination Notices.pdf Appendix C.C - DSW-THG MoU with map.pdf Appendix C.D - GHG Emissions.pdf APPENDIX D Buffelsdraai Phase1 Report.pdf

Documents received 28 October 2011

Glenday2007 eThekwini carbon stock report.pdf Glenday2007 eThekwini carbon report appendices.pdf

Documents received 02 November 2011

Knowles 2009.pdf Documents received 07 November 2011

doc20111107101101 (budget allocation).pdf Documents received 09 November 2011

Reforestation Cashflow - Buffels- Revised for Financial Years - minimum cost estimate.xls Documents received 09 December 2012

Buffelsdraai PDD NCRs - Carbon.docx Documents received 22 February 2013

Wildlands round1 NCR's - WCT comments.pdf CCBA_PDD_Buffelsdraai REVISED incl NCRs.docx

Documents received 23 May 2013



CCBA_PDD_Buffelsdraai Version2.docx Documents received 31 October 2013 (from site visit)

Wildlands-2009-2010 Annual Financial Stmt.pdf Wildlands-operating procedures and work plan.pdf Appendices.pdf Biodiversity Assessment.pdf Buffelsdraal-environmental management plan.pdf Buffelsdraal-portion of lease.pdf Carbon Storage+Sequestration Analysis.pdf Development Planning Memo.pdf Maps.pd Maps-2.pdf Phase 1 Report.pdf Procurement + Infrastructure-Appointment.pdf Project Design Document.pdf Summary Review-Ethekwini Municipality.pdf Sustainable Develop-DanidaFunding.pdf


Wildlands round1 NCR's Final_reissue 29-10-2013 (2).docx CCBA_PDD_Buffelsdraai_with_NCR1.docx Medium Term Revenue and Expenditure Framework 2013.2014.pdf Reforestation Cashflow - Buffels - Revised for Financial Years - minimum....xls


Wildlands round1 NCR's Final_reissue 29-10-2013 (2).docx Reforestation Cashflow - Buffels - Revised for Financial Years - minimum....xls

Documents received 14 July 2014

Wildlands Round 3 NCRs.docx Agricultural_Statistics_2013.pdf NSDP_Final_Draft_2012_17_Oct_2012_Revision.pdf Gupta2010.pdf DeFiguerirido_etal_2010.pdf Smith et al. 2005.pdf CCBA_PDD_Buffelsdraai_with_NCR3.docx CL1-1_Table7_calcs.xlsx

Documents received 21 July 2014

CCBA_PDD_Buffelsdraai_with_NCR3_v2.docx