Info Report Check
Submission incomplete:
1: The PoA-DD (page 16) indicates that the CME will review the management system on regular basis as a measure to ensure continuous improvement of the PoA system. However, no information is provided regarding timeframes for these reviews.


2: The PoA-DD (page 4) mentions that Government policies have supported self-sufficiency in food production, which saw conversion of mangroves to rice paddies. CME/DOE shall provide information on how the Government policies on self-sufficiency in food production have been taken into account in conducting the socio-economic analysis of the A/R programme. In doing so, please provide (under section F.3 of the PoA-DD) a description of the planned monitoring and remedial measures to address this impact, if deemed applicable to this programme.


3: The PoA-DD (page 2) indicates that lands selected for restoration are new land created as a result of combination of siltation and landscape changes due to the 2004 tsunami and subsequent storms; and human activities (i.e. overharvesting). The CME/DOE shall demonstrate that the land at the start of the project activity does not contain forest in line with the applicable A/R Tool (Demonstration of eligibility of lands for A/R CDM project activities ver. 02.0, paragraph 8 (a)(iii) and (b)) which requires demonstrating that the land is not part of forest area that is temporarily un-stocked as a result of human intervention and natural causes and the criteria described in the paragraph 8 (a) were met on 31 December 1989.


4: The PoA-DD (page 18) has identified two credible alternative land-uses (i.e. continuation of pre-programme land use and restoration/reforestation or afforestation of mangroves on the lands within the project boundary without being registered as a CDM programme). However, the PoA-DD (page 4) mentions that 88% of the mangrove loss was due to conversion to grow rice because the Government policies have supported self -sufficiency in food production. CME/DOE shall provide information to justify exclusion of “conversion of degraded mangrove land into rice paddies” from the list of the credible alternative land-uses since paragraph 9 of the AR Tool: combined tool to identify the baseline scenario and demonstrate additionality in A/R CDM project activities, ver. 01) states that “The scenarios should be feasible for the project participants or similar project developers taking into account relevant national and/or sectoral policies and circumstances, such as historical land uses, practices and economic trends”.


5: The PoA-DD (pages 49/51) has considered a value of 1.62 tc/ha/year for the parameter “rate of change in soil organic carbon (dSOCt)” which is based on an article Titled “Methodological Guidance on Lands with Wet and Drained Soils, and Constructed Wetlands for Wastewater Treatment”. It is observed that this value (1.62 tc/ha/year), as stated in Table 4.12 of the referenced Article, (i) represents an emission factor associated with rewetting on aggregated organic and mineral soils and (ii) is extracted from another published document “Breithaupt et al. 2012” which is not accessible thus its information cannot be verified. The CME/DOE shall provide information to substantiate how it considered that the applied value (1.62 tc/ha/year) (i) represents “rate of change in soil organic carbon (dSOCt)” and (ii) complies with paragraph 17 (AR-AM0014 ver. 03) which requires a default (0.5 tc/ha/year) is applied unless transparent and verifiable information can be provided to justify a different value.


6: The PoA-DD (page 49) mentions that the project area lands have no prior history of agriculture or used for grazing. However, the PoA-DD (page 3) indicates that a study indicated that mangrove loss between 1975 and 2005 was due to agricultural expansion (including infrastructure, aquaculture, rice and salt production). The CME/DOE shall provide information to support the estimation of leakage emissions as zero whereas there is displacement of agricultural activities in the project area (please refer to the AR Tool 14: Estimation of the increase in GHG emissions attributable to displacement of pre-project agricultural activities in A/R CDM project activity).


7: The PoA-DD (page 46) mentions that the pre-project trees will be monitored for continued existence throughout the project duration. However, the monitoring plan does not provide information on monitoring of the pre-project trees. In doing so, please demonstrate how the area under the pre-project trees will be accounted in the “Area planted in year t, Aplant,t (PoA-DD, equation (4)).


8: The PoA-DD (barrier analysis, page 20) has identified that afforestation of mangroves on the lands within the project boundary without being registered as a CDM programme is prevented by investment barrier hence the remaining land-use scenario (i.e. continuation of pre-programme land use) was considered the baseline scenario. The PoA-DD (page 22) has further conducted investment analysis (simple cost analysis). The CME/DOE shall provide information to justify applicability of conducting investment analysis considering that only one scenario, i.e. continuation of pre-programme land use, is identified as the baseline scenario ((please refer to Figure 1 of the A/R combined Tool).


9: The local stakeholder consultations were conducted on 11/02/2019 which is after the indicated start date of the first CPA (01/02/2019, PoA-DD page 17). The GSC comments were conducted from 29/03/2019. The DOE shall provide information on how the conducted local stakeholder consultation process timing complies with paragraph 64 of PS-PoA ver. 02, which requires the timing should be before either the start date CPA or submission of the PoA-DD for validation, whichever is earlier.