The Regenerative Standard

Regenerative Soil Organic Carbon Methodology
for Rangeland, Grassland, Agricultural, and Conservation Lands

Version 2.0 (UNDER REVIEW)
October 2024

Open-Access

Preface

The Regenerative Standard (TRS) is a family of methods, authored by scientists, focused on regeneration and restoration of ecosystem services (Soil Health, Water, and Biodiversity) including on working lands. This document is focused on the Regenerative Soil Organic Carbon Methodology (TRS SOC), the first method available under TRS. Subsequent methods in development are focused on water resources and biodiversity; ultimately creating a suite of methods meant to quantify full system restoration. Forthcoming methods under TRS will introduce improved quantification tools for measure-to-measure, robust and reliable ecosystem metrics for these focal areas. Each method under TRS is an open access, living document that has been developed from the body of science, from peer reviewed publications, and expertise under each topical area and will be continuously improved as new research and technologies are reviewed.

The core technical foundations of the Soil Organic Carbon Methodology (TRS SOC) are based upon the original The Earth Partners, Soil Carbon Quantification Methodology, which was written, tested, and published over decades by a distinguished team of soil carbon scientists and authors of books, technical papers, and synthesis publications on agricultural soil carbon and the potential role of regenerated agricultural systems as a climate mitigation strategy, including many of the authors found in Kimble et al (2007), Paul et al (1997), Daniel and Hammer (1992) and others. This method was subsequently VCS approved and released as Verra VM0021 Soil Carbon Quantification Methodology. Ownership, authorship, and copyright of VM0021 and the 20 chapters under VM0021 is now held by Applied Ecological Institute and is referenced throughout TRS SOC as these methods are still the best available and used by many other protocols i.e. VM0042 and BCarbon. See Appendix 6.0 for the full history and lineage.

While building upon the earlier methods, TRS SOC is an independent and original method that has been continuously developed and refined over millions of acres of sampling, resampling and carbon quantification. The Verra VM0021 Soil Carbon Quantification Methodology has been strengthened, modernized, reorganized, and streamlined to reduce costs, ensure scalability, and confirm accuracy, precision and robustness to support high quality, trustable carbon credits.

Preface

Introduction

Definitions and Acronyms Used

Project Framework

Project Requirements

Task 1. Project Overview - Identification and Eligibility of Project Activity

Task 1.1. Data confidentiality statement

Task 1.2. Physical Address of the Properties Submitted for Certification

Task 1.3. Description of Land Management Activity

Task 1.4. Project Eligibility

Task 1.5. Project Boundary

Task 1.6. Baseline Scenario

Task 1.7. Additionality

Task 1.8. Permanence

Task 1.9. Credit Release

Task 1.10. Contractual Commitment

Task 2. Measurement and Reporting

Task 2.1. Quantification of Soil Carbon Stocks for Baseline and Project Scenarios

Task 2.2. Ex-ante Projections of Project Emissions from Non-soil Carbon Sources

Task 2.3. Ex-post Quantification of Project Emissions

Task 2.4. Ex-ante Projection of Leakage

Task 2.5. Ex-post Quantification of Project Leakage

Task 2.6. Monitoring

Task 3. Interim Crediting Assessment (Optional)

Task 3.1. Projection of future soil carbon accrual rate for the project scenario

Task 4. Project Application Submission

Task 5. Verification

Task 6. Registration

Appendices

Appendix 1.0 Verification Guidance and Checklists

Appendix 3.0 Guidance on Potential Emerging Technologies Being Tested to Monitor and Measure Grazing Land Use Changes, and SOC Stocks

Appendix 4.0 The Regenerative Standard SOC Methodologies

Appendix 5.0 Verra VM0021

Appendix 6.0 The Regenerative Standard History

Appendix 7.0 Verra Links

Introduction

The Regenerative Standard Soil Organic Carbon Method (TRS SOC), the first release of a family of methods under The Regenerative Standard (TRS), describes how carbon drawdown credits can be generated through nature-based, atmospheric carbon drawdown and soil carbon storage related to conservation, ecosystem restoration, and agricultural projects. It also applies to other projects where the management of soils directly or indirectly through management of hydrology, livestock, soil fertility, and plant diversity and productivity can improve soils, reduce erosion, and promote soil carbon storage.

TRS SOC ensures the delivery of high-quality, carbon removal credits, based on rigorous soil sampling, laboratory analysis, and independent third-party verification. To meet these objectives, TRS SOC combines best practices, rigor, and approaches from published work, and has been informed by several existing standards, including Verra, ISO, Climate Action Reserve, BCarbon, as well as guidelines from the IPCC 2003 Good Practice Guidance for Land Use, Land-Use Change, and Forestry. TRS SOC is focused on delivering proven, technical, and scientific innovation to produce high-quality carbon removal credits based on measurement to measurement improvements in soil carbon stocks over time. TRS SOC V2.0 includes updated guidelines on additionality and permanence with adequate safeguards to ensure results are real, measurable, and verifiable. Version 2.0 does not allow for avoided conversions, defined strictly protecting grasslands, conservation lands or perennial agricultural lands. It does however, should a carbon program developer wish, have allowances for documenting reductions in emissions such as in the conversion of row crop agricultural land to perennial grasslands, where fertilizers, and tillage related emissions are reduced or eliminated. Please see the glossary that differentiates between avoided conversion and reduced emissions of GHG’s. Many standards describe how carbon credits from nature-based soil carbon storage can be generated. However, TRS SOC emphasizes carbon removal credit quality while also making it easier for landowners to participate in nature-based carbon storage opportunities at scale. TRS SOC is designed to make it easier to initiate and participate in soil carbon storage project opportunities by removing typical participation barriers and requiring that crediting be based on bonified measurements of soil carbon stocks over time. TRS SOC is designed to allow future measured soil carbon benefits created by “Early Adopters” (see glossary) starting with the date of their enrollment, in a soil carbon project.

TRS SOC does not focus on any particular or specific activity change and allows land stewards to participate and innovate activities to sequester and store additional soil carbon. These two guideposts simplify who can be involved in carbon programs. To further expand participation and rapid scaling by land stewards, the measurement-to-measurement basis for crediting, requires that imported carbon materials such compost, manure, mulches, lime, or earthmoving that moves carbon (soils) around the landscape, are not allowed unless accounted for in the Project Plan.

TRS SOC is based on technical procedures detailed herein (and those incorporated through supporting references, such as to VM002 through VM0035, and others), in which the farmers, ranchers, or conservationists (“land stewards”) are focused on conservation, restoration, and regeneration on grazing, agricultural, or conservation lands. TRS SOC also offers guidance to allow Project Proponents to address and document additionality and permanence requirements in innovative ways to increase land steward participation.

TRS SOC is focused on carbon removal credits and does not include benefits from “avoided conversion emissions” but does allow for reduced emissions crediting (see glossary). Atmospheric carbon removal and reduced emission crediting storage is determined by conducting repeated measures of soil organic carbon (SOC) stocks. Only measure-to-measure increases, between T0 (Time Zero—the initial sample date at the start of the project) and T1 (Time One—the subsequent sample date often ranges from five to seven years later) produce creditable carbon credits. If a project proponent proposes to include reduced emissions crediting it also is to be based on direct measurement using repeated sampling as with soil organic carbon. Consequently, resampling time increments (See Expected Time Increments—in glossary) are up to the carbon program developer. This flexibility accounts for geographic differences, soil differences, ecological and agricultural cropping differences and growing season deviations from normal, and as such this extends through the life span of a project and Verification Period (see glossary). Flexibility in potentially lengthening the Expected Time Increment, and Project Life Expectance is warranted to assert accountancy, precision, and control over uncertainty through the robust measurement to measurement requirements under TRS SOC. Timing of sampling and the verification align to ensure the process is and representations have robust, rigorous, and transparent quantitative foundations underly crediting on any timeline (see Verification Checklist).

Flexibility comes with annualized assurances of program compliance and incentives by allowing annualized crediting. Crediting can be calculated over any varying time horizons using literature predictions and, due to the measurement to measurement based crediting, and true-up of carbon stocks and thus by comparison of mean carbon stocks against the baseline at T0, during T1, T2 and so on. Using scientific literature on accrual rates, prior to T0 for projections, are trued-up against actual stock changes art T1. Following the collection of T1, conservative linear accrual rate assumptions, again are trued-up at T2.

Accountancy and ledger records of all crediting periods, the assignment of registered uniquely numbered certificates for each credit generated assures no double counting occurs. Regardless if credit is sold to one or multiple buyers, credit issuances of registered certificates safeguards confusion and miscounting or double counting (see Registry Checklist).

One-meter-deep (1m) soil sampling, analysis, and the generation of high-quality data is the foundation of TRS SOC, along with optional methods to estimate the carbon stocks and carbon stock changes over time (e.g., the rate of carbon accrual) that allow for revenue to Land Stewards in the interim years before T1 measurements are completed. This ensures Land Stewards can meet the financial challenges of implementing new management practices and therefore the quality of the credits registered through TRS SOC.

Forward-looking assessments for interim crediting are required to be followed by 1-meter-deep, direct soil sampling to establish the T0 baseline soil organic carbon, with subsequent 1-meter-deep sampling collected within an average of five to seven years to true-up the project soil carbon sequestration between the baseline T0 and final T1 soil sampling. Forward assessments used as the basis for interim crediting are required to be substantiated with actual field sampling results either reported in published and/or peer reviewed literature or measured by the Project Proponent using approved methods and technologies (see glossary for terms).

This document lays out the steps required to fulfill estimation, quantification, and application requirements for projects wishing to register credits under Nature’s Registry. TRS SOC V2.0 incorporates by reference, published modules for specific techniques and options for estimating, projecting, and measuring changes in specific carbon pools and emissions.

Supporting References

** Incorporation by reference of published and available protocols and technical publications (see references) include, for example, VM0021 and other numbered modules from The Earth Partners “Soil Carbon Quantification Method” as published and copyrighted.

Definitions and Acronyms Used

Activity Shifting Leakage: Activities that are moved by local actors from within the project area to outside due to the project, and which result in losses of carbon in pools outside the project area.

Additionality: A criterion to determine whether emission removals and reductions are real, measurable, and in addition to what would have happened in the absence of the project. TRS SOC V2.0 offers four tests of additionality; an ultimate test is measure to measure increases in soil organic carbon stocks.

Agent: A person or organization undertaking actions that impact the management of carbon pools and emissions.

Avoided Conversion GHG Emissions: GHG emissions do not occur, because of a direct decision to protect land and its included carbon stocks.

Avoided Conversion GHG Carbon Credits: Under a baseline scenario, if a perennial agricultural landscape, or a working landscape (e.g. perennial native grassland) is proposed to be protected, rather than plowed up and converted to a corn cropland, TRS SOC currently does not support crediting for the protection of existing carbon stocks in the to be protected or already protected landscape. The rationale currently is that most conservation protection occurs using legal instruments such as conservation easements (or deed restriction). The value of the asset is determined by independent certified conservation appraisal and many assets, including generated ecological services values are more commonly now included as assets with donative value. To avoid conflicts such as double counting on the value of a protected landscape asset, and details of what is or is not included in conservation appraisal, currently we do not allow GHG emissions crediting with protection of land.

Baseline: The total amount of carbon within the project area in absence of the project.

Baseline (Displaced): Baseline may occur under TRS SOC where a baseline activity changes (is displaced) as a part of the planned activity change such as continuous grazing is replaced by Adaptive multi-paddock grazing, or a corn/soybean under a soil tillage rotation is replaced by no-till agriculture or a conversion to a perennialized cropping system requiring no tillage. For purposes of TRS SOC, because of the measurement to measurement carbon estimation and accounting, baseline displacement will be recorded as a change in activity and the actual on the ground changes will be measured and accounted for in carbon crediting. Where a displacement occurs special attention by the proponent and verifier through reassessing any subsequent leakage must also be documented with annual monitoring and reviewed during verification.

Baseline Scenario: The sequence of events and actions which would be expected to occur within the project area in the absence of the project.

Buffer (Pool): A percentage of project carbon credits reserved by the Registry to address shortfalls and reversals, both avoidable and unavoidable, thereby ensuring that atmospheric carbon removal created by a project is secured and guaranteed. TRS SOC V2.0 offers three buffer pool assurance options so that carbon credits always represent actual measured improvements in soil organic carbon stocks on the ground.

Conservative: Tending to err on the side of reduced creditable carbon in cases where uncertainty exists as to the correct value of variables, or relationships among variables.

Coarse Fragments: Pieces of rock or cemented soils > 2mm in diameter, and therefore too large to pass through the screen used in the laboratory prior to laboratory analyses.

Crediting Period: The time period for which GHG emission reductions or removals generated by the project are eligible for issuance as Verified Carbon Credits, not including any potential crediting period renewals. Also referred to as the “Project Crediting Period.”

Credit Year: Each year during which credit is requested by the carbon project developer, and during which, a verification is conducted, and the registry may review certify and issue Verified Carbon Credits.

Credit Yield: The projected or measured carbon credits over the life of a soil carbon project, that can be annualized through projection based on science literature, but must ultimately be based and trued-up against on-the-ground measurements over time. The credit yield is to only be determined by remeasurement of soil carbon stock changes against time zero, baseline measurement.

Constant Baseline: is a baseline that may be constantly declining, increasing or be stable at a rate of change that does not change, where the trajectory does not vary. Compared to a static baseline’s which can fluctuate around a consistent mean rate of change but may not be the same at any point in time.

Directly Attributable: The change or effect occurs because of a chain of causal events linking the change or effect to an event, or to the actions of an agent. Each of the causal events or conditions in the chain must be primarily and directly caused by the previous event in the chain. Analysis of the linkages in the chain should show that for each one, the previous event is at least 75% responsible for the next event. For this reason, the relationship between an event, or the actions of an agent, and the directly attributable effect, typically consists of not more than a few causal linkages.

Early Adopters: Land stewards who adopt a practice change, and culturally often are the leaders in the farming, ranching, and ecological restoration community. Early Adopters are often motivated by outcomes and benefits that may not be recognized or supported by programs, such as the Farm Bill, when they commence a new practice. Additionality in their case is often not financially motivated.

Election of Option: Project Proponent selection of definitional additionality and permanence requirements under TRS SOC V2.0.

Enrolled Property Boundary

Enrolled property is defined to have demonstrated through title and attached plat of survey, and other attachments to the PDD including but not limited to title or deed documenting fee ownership, or bonified lease or other form of legal control of the property, during the carbon contract term, which includes the post-contract term (e.g. 10 yrs.) must be documented in the PDD, reviewed and approved by the verification process.

To meet the enrolled property definition within a defined project, a carbon project developers must document the MLRA of each property and then give each property a unique nomenclature, that can specify the activity and time period of the project. This must be denoted in the PDD.

Ex-ante: Before the fact. Projection of values or conditions in the future.

Ex-post: After the fact. Estimation of values or conditions in the present or past.

Expected Time Increments: Carbon stock resampling timelines are not specified and have been left up to the project carbon developer. This is because the time from activity change initiation until statistically robust signals of change can be detected depends on growing conditions and plant productivity, geography, and meteorological year. In the midwestern USA under normal precipitation/growing conditions, often a 3-5 yr. lapsed time period is required; this extends to 7-10 years in semi-arid to arid rangelands.

Forest: A forest is a complex ecological system in which trees are the dominant life-form. There are many types of forests. And, also different expressions of the same forest. For example, in a forest system that experiences (and one often co-evolved with) wildfire, while live trees may be reduced to re-sprouting roots after fire, where trees are top-killed; or reduced entirely, initiating a recolonization process. Under this common scenario the same forest type, or even its recognition as a forest, may change depending on the classification used to identify the type of ecosystem present.

Healthy Soil’s Co-Benefits: Healthy soil supports healthy food, healthy livestock, and human nutrition, improves infiltration of precipitation to re-grow potable water supplies, can reduce flooding and costly flood damages, and the improvement of soil health may be one of the primary ways any (every) land steward can participate in improvement natural resources.

Idea Note: A document that summarizes a soil carbon project that is typically used to familiarize a registry, verifier, and potential buyers with the project. This is not a substitute for a project design plan.

Land Management Activity Change: Any change in crop, tillage, fertilizer, land drainage/water management, crop litter, livestock use (mass, density, stocking rate, rest-rotation), species or composition, amendment, invasive plant management technique changes (tillage, prescribed burning, herbicide or formulation, application method, flame or thermal management, smother-cropping, etc.), equipment or technical deployment, land-tenure and operations and staffing, are all accepted by definition as contributing to or resulting in a land management activity change.

Long-lived wood products: Products produced from harvested timber which is expected to persist and sequester carbon for an extended period – typically one hundred years unless there is a specific reason for using a different time.

Minimum Soil Disturbance: In TRS, under land management activity plans, as required to be documented in the proponents PDD, a clear description of the activity changes proposed and the level of land/vegetation disruption that may lead to temporary (14-60 days) or longer term (season or multi-season long) soil disruption must be documented. Soil disruption is defined as any activity resulting in bare soil of greater than 1 acre in size that is not cover cropped, mulched or protected from heating and wind and water erosion within 7 days of executing the activity that created the bare soil. Under most erosion control requirements and plans of federal and state governmental agencies any time soil is exposed and bare on greater than one acre, an erosion control plan and permit is required. Temporary soil disturbance on farms and ranches is typically associated with tillage or herbiciding followed by the installation of a cover crop or next crop, including perennial grasses in grazed lands. Typically, the soils are prepared and promptly (often in less than a week) the seed bed is drilled or broadcast with the next crop. Deviation from a prompt turn around, such as bare soil remaining exposed and subject to erosion, and soil organic carbon degradation, must be documented a priori in the PDD and reported annually in the project monitoring program. If the soil disturbance acreage is significantly large, new baseline sampling must be documented in an addendum to the PDD. The Minimum Soil disturbance must be demonstrated via satellite imagery analysis of bare soil annually and included in the monitoring report.

Monitoring event: The time at which monitoring of all the relevant variables is undertaken, to determine the net change in atmospheric carbon attributable to the project.

Monitoring period: The time specified in a monitoring report during which GHG emission removals were generated by the project.

Monitoring plan: Plan in which a monitoring schedule and methods will be documented as a part of the submittal to The Regenerative Standard, Verifier, and Nature’s Registry.

Nature’s Registry: This is a fully functional ledger, record keeping, and accountancy organization that reviews verification reports, certifies and issuances credits for projects that have used The Regenerative Standard, and any of the methods therein for quantification, reporting and verification. Nature’s Registry is a separate operating entity from The Regenerative Standard which is part of Applied Ecological Institute, Inc., a 501c3.

Organic Carbon (stocks): Organic carbon is a large and diverse source of carbon-based compounds found within natural and engineered, terrestrial, aquatic and wetland environments. It is matter composed of organic compounds that have come fromfrom the feces and remains of organisms such as plant and animals. For purposes of Soil Organic Carbon, under the TRS SOC, all non-peat (i.e. hemic and fibric peat types) are eligible for crediting. Sapric peats (commonly referenced as “muck” soils) are eligible for inclusion and can be sampled under this methodology where they comprise a relatively thin layer on a prevalent soil system that is inorganic in nature, including hystic epipedon’s directly over bedrock or sand.

Peatlands: Land with a prevalence of hystic soils (e.g. sapric, hemic and fibric peat types) require different soil carbon measurement methods, that provide a permanently installed vertical reference gage or marker, so that soil strata thickness and Bulk density can be accurately measured over time. This marker is used to calibrate for shrink-swell and paludification dynamics that occurs under varying levels of saturation or inundation, and whether frozen or thawed. Consequently, land with hemic and fibric peat soil carbon is not addressable under TRS SOC at this time.

Permanence: Permanence is the long-term durability of soil organic carbon stocks, and TRS SOC uses a comprehensive permanence framework to establish a reasonable and adequate assurance that the atmospheric carbon removal created by a project is secured and guaranteed for at least 40 years. Regenerative grazing, farming, and restoration and management of conservation projects inherently contribute to the level of mineral associated carbon fractions. Each of these project types we have measured this increase in accrued carbon stocks in general, and specifically mineral associated stocks down to a meter depth. For TRS, we define permanence realistically, from the perspective of how the earth has performed, as a model for what can be accomplished, rather than from a theoretical legal perspective. Paleontological studies and carbon dating of soil organic carbon stocks in unglaciated landscapes (i.e. Palouse agroecosystem in Eastern Washington State) have average carbon ages in the upper 1 dm of 200-300 years. And, from 2 to 10 dm the average age is 200,000 years (Retallack 2007). In glaciated corn belt regions of WI, IL, IA the average age in the upper 1 dm is 200-300 years, and > 5000-7000 years below that to an ~ 1 m depth (Apfelbaum unpublished data using UM Pollen analysis). In New Mexico, near Corona, to 1 dm depth the age was ~1000 years; below 2 dms, the age was 3-5 million years (_Monger 2014). A literature review is beyond the scope of the intent of this Glossary of terms. That said, a central valley CA study found topsoils had an average age of several hundred years and 1500-1800 years below that to 1 m depth.

Achieving permanence is defined under TRS using three criteria learned from measuring Soil Organic Carbon to 1 m depth:

Increased soil organic carbon deeper in the soil
Increased mineral associated carbon fractions
Reduction in relative abundance of shorter-lived particulate carbon fractions

Permanence Period: TRS requires annual monitoring and reporting during each year a parcel is enrolled under the TRS SOC. TRS also requires project end monitoring when the enrollment true-up resampling and measurement of soil organic stocks are measured and compared with the baseline measurements to document accruals that have occurred. After enrollment ends, for a period of forty years, annual monitoring and t0th year monitoring close out documentation is required to be delivered to TRS by the project proponent. The monitoring reports shall be focused exclusively to document compliance with maintaining the activity change that was executed on each the property. Permanence monitoring and documentation can be accomplished using remote sensing with on-the-ground confirmation photography.

Planned: Changes in the value of the variable are under the control of identified agents who are independent of the Project Proponent.

Project Boundary (See Enrolled Property Boundary)

The area or areas of land on which the Project Proponent will undertake the project activities. TRS SOC defines a project as any group of properties, where upon, a similar project activity is proposed, that enroll to participate by use of TRS SOC, that occur in a USDA (or equivalent) defined Major Land Resources Area within the defined period of time around which the project is organized, as submitted in the PDD, and approved through the verification process. Across the USA, there are Major Land Resources Areas (USDA, NRCS 2022) (MLRA’s) defined based on biophysical conditions present, and for each a description of the typical land use history, including land settlement and cropping and soil tillage activities are provided.

One or more projects proposing the same project activity change can be defined within each MLRA by different carbon project aggregators/developers. And, one or more projects can be defined for other activity changes within the same MLRA’s.

Where MLRA’s are not defined (such as outside the USA), ecoregional and agroecoregions, and biome definitions may be offered as biophysical boundaries that can be reviewed by The Regenerative Standard as acceptable congeners to the MLRA definition. Examples of ecoregion definitions occurring outside the USA as defined by Walter 1983 can be considered for use in providing high level understandings of a project’s biophysical setting.

As an example, an improved grazing project found in a single mapped MLRA in central Montana; this single MLRA (like many others) occupies very large acreages of land. Many ranches can be considered part of a single project if they sign up for participation of improved grazing as the activity, within the time period for this improved grazing offering.

To meet the project definition, Carbon project developers must document the MLRA of each ranch and then give each project a unique nomenclature (which should be informed by the biophysical stratification conducted for each participating property), to specify the activity and time period of the project. This must be denoted in the PDD.

Project Design Document (PDD) or “Project Plan”: A carbon project developer creates a PDD for submittal to The Regenerative Standard, a third party Verifier, and Nature’s Registry. The PDD contains all document requirements under the Project Framework. See “Project Registration, Verification and Validation” definition.

Project Proponent: The individual or organization that has overall control and responsibility for the project, or an individual or organization that together with others, each of which is also a Project Proponent, has overall control or responsibility for the project. The entity(s) that can demonstrate project ownership in respect of the project.

Project Life Span: The time over which the soil carbon project generates and accounts for carbon credits. Because of varying time periods for soil carbon change statistical signals (See Expected Time Increments definition), the life span will vary. Overall project life span may last for decades, the time required to regenerate and restore carbons stocks from deteriorated state (see USDA 2014 documentation of 70-90% deterioration on average across the USA).

Project Registration, Verification and Validation: The process of submitting the full required documentation, which may include an “Idea Note” for a pre-application conference with the registry and verifier, or the fully required submittals: “The Project Design Document (PDD) ”, The Measurement and Monitoring Plan”, The Verification Report, The Validation Report, and other required documentation by the carbon project developer to Nature’s Registry. The Verifier/validator is required for registering, and formalizing verification/validation, and all record keeping, credit certification and issuance by the Registry. Requirements for submittals are detailed in TRS SOC V2.0 and in the Verification checklists.

Project Verification Period: The time between project initiation and each crediting event. Under TRS SOC V2.0, carbon project developers can verify annually and credit annually, and under this scenario the Project Verification Period is annual.

Project Scenario: The resulting soil carbon pools over the project time due to the project activity. The soil organic carbon stocks are present at the next scheduled soil measurement date, calculated according to the technical procedures and methods described below. For example, a project that plans to conduct soil measurements every five years, the initial (T0) measurements are taken in year zero and the project scenario measurements are taken in years five (T1), ten (T2), fifteen (T3), and so on.

Project Start Date: The first field sampling date for any Project, also annotated as Time Zero or “T0.”

Reduced GHG Emissions and Crediting: Practice changes (except for land protection-see Avoided Conversion definition) directly resulting in a reduction in GHG emissions, such as by reduced tillage, or reduced or eliminated fertilizer use.

Registry Checklist: Clear, step by step registry procedures to be followed by “Nature’s Registry” (or other) to ensure the Registry follows a standardized, rigorous process for verification reports, in reaching certification and credit issuance decisions.

Removal: Carbon stocks that are comprised of highly recalcitrant fractions of organic and mineralized carbon such as fire pyrolyzed carbon (char), submerged and saturate carbon protected from oxidative and anerobic decomposition because of the chemical environment (e.g. pocosin peat protection by antimicrobial/antifungal phenolic compounds, etc.), mineralized forms of organic carbon (e.g. mineral associated organic carbon fractions) comprise forms of carbon that may be stable for predictable long periods of times, measured on geological time scales of thousands to millions of years.

Significant: A pool or source is significant if it does not meet the criteria for being deemed de minimis. Specific carbon pools and GHG sources, including carbon pools and GHG sources that cause project and leakage emissions, may be deemed de minimis and do not have to be accounted for if together the omitted decrease in carbon stocks (in carbon pools) or increase in GHG emissions (from GHG sources) amounts to less than five percent of the total GHG benefit generated by the project.

Soil: Soils are typically defined as the upper layer of earth in which plants grow, a black or dark brown material typically comprising of a mixture of organic remains, silt, clay and sand in various percentages which define the type of soil. For purposes of the TRS SOC, soils are defined as inorganic, mineral, and organic soils. Inorganic and mineral soil types can contain organic matter. Soils of each type, except hemic and fibric peat soil types are able to be included under this method when measurement to measurement soil sampling documents an increase in soil organic carbon stocks. Soils with a hystic epipedon, may also be included if the hydrology and wildfire/prescribed burning regimes that may be associated with land management activity do not degrade, decompose, erode, of combust the hystic epipedon.

Soil sampling depth of refusal: during soil sampling, this is the depth at which, for example, bedrock, scattered rocks, or tree roots prevent achieving deeper sampling of soils. This depth is recorded if it falls short of the 1-meter sampling depth requirement under TRS SOC.

Stratification: The division of an area into sub-units (strata) which are homogenous for the value of the variable on which the stratification is based, which are repeatable in the landscape, and could be expected to be similarly identified and classified by different people.

Static Baseline: is a base with an unchanging trend that may fluctuate around a mean rate. This is different than a constant baseline which may have a constant declining or increasing trend, a rate of change that does not change and assumes a trajectory that varies from a static baseline’s fluctuate around a consistent mean rate of change.

Statum: An area of land within which the value of a variable, and the processes leading to a change in that variable, are homogenous.

Stratification: Use of spatial data to evaluate and map biophysical conditions, including but not limited to: land-use history, geology, hydrology, cropping and grazing history, depth to bedrock, depth to water table (piezometric surface), land-use and land-cover, historic and existing vegetation, topography, slope, aspect, slope position, presettlement ecosystem mapping, flood prone, floodplain, paddocks or field identification and changes over time, historic cropping, soil types, soil textures, and myriad other data that may be available or procured for property.

Stratified-Random Sampling: Use of the stratification results to randomly allocate “random-stratified” sampling locations to statistically represent the varied conditions (strata) present on property, such as for the measurement of soil carbon on a landscape.

Technologies: New or improved methods, tools, and processes that have well documented benefits for improved accuracy, precision, efficacy, and efficiency in the measurement (including analytical soil laboratory processes), computational needs, or automated documentation preparation, among other examples.

Uncertainty: Uncertainty is a parameter associated with the result of a measurement that characterizes the dispersion of the values that could be attributed to the measured amount.

Validation: The independent assessment of the project by a validation/verification body that determines whether the project conforms with the TRS SOC rules and evaluates the reasonableness of assumptions, limitations, and methods that support a claim about the outcome of future activities

Validation/Verification Body (VVB): An organization qualified to act as a validation/verification body in respect of providing validation and/or verification services in accordance with the TRS SOC rules.

VCC(s): Verified Carbon Credits are the currency of issuance of carbon credits used by Nature’s Registry. One VCC is equal to 1 TCo2e/acre and 1 TCo2e/acre-yr.

Verification Date: A date on which an independent verifier audits the results of monitoring.

Verification: The independent assessment by a validation/verification body of the GHG emission reductions and removals that have occurred because of the project during the monitoring period. The assessment is submitted to a registry that is independent from the Project Proponent and the verifier and is based on historical data and information to determine whether the claim is materially correct, conforms with specified requirements, and is conducted in accordance with TRS SOC rules.

Verification Checklist: Clear, step by step verification procedures to be followed by a prequalified verifier, which starts the verification process by evaluation of project submittal completeness.

Verified Carbon Credits: TRS SOC recognized unit of carbon currency is a Verified Carbon Credit (VCC), equal to 1 (one) Tonne of CO2equivalent.

Woody Biomass: Biomass that exists primarily in the form of lignified tissues, such as that of shrubs and trees. Typically accounting of woody biomass includes the non-woody parts (leaves, etc.) of plants that contain woody biomass.

Wetland: Land that (1) has a predominance of hydric soils; (2) is inundate or saturated by surface or groundwater at a frequency and duration sufficient to support a prevalence of hydrophytic vegetation typically adapted for life in saturated soil conditions; and (3) under normal circumstances do support a prevalence of vegetation typically adapted for life in saturated soil conditions. This definition (US Army Corps of Engineers, 1987) has been developed pursuant to the Clean Water Act, Section 404 Definitions. This same definition is used with some language changes by the USEPA and the USDA, NRCS, with their definition applicable to croplands.

Wetland, Seasonally Inundated: Land that meets the definition of wetland that may occur in floodways, floodplains, shallow poorly drained depressional landscape position and in undrained farmed soils. Seasonally inundated inorganic and non-hystic soil dominated seasonally flooded land can be eligible for soil carbon crediting under TRS SOC.

Wetland, Prior Converted: Land that was historic wetland that have experienced altered hydrology from land drainage (such as the tiling or ditching) and altered vegetation systems, where the drainage alterations restrict a normal growing season prevalence of hydrophytic vegetation. Prior convere inorganic and non-hystic soil dominated seasonally flooded land can be eligible for soil carbon crediting under TRS SOC.

Acronyms Used in TRS SOC V2.0

AFOLU - Agriculture, Forestry and Other Land Use

ARS - Agricultural Research Service

CDM - Clean Development Mechanism

CH4 - Methane

CO2 - Carbon Dioxide

FAO - Food and Agriculture Organization

GHG - Greenhouse Gas

IGM - Improved Grassland Management

ICM - Improved Cropland Management

IPCC - Intergovernmental Panel on Climate Change

ISO - International Organization for Standardization

N2O - Nitrous Oxide

NRCS - Natural Resources Conservation Service

PDD - Project Design Document

SOC - Soil Organic Carbon

T0 - Time Zero (initial sample date)

T1 - Time One (subsequent sample date)

UNFCCC - United Nations Framework Convention on Climate Change

VCS - Verified Carbon Standard

VVB - Validation/Verification Body

Project Framework

Project Proponent and Verifiers interested in working with TRS SOC V2.0 should consult with Nature’s Registry for Project Proponent and Verifier pre-qualification processes and requirements.

The project crediting period is at least five (5) years with a minimum forty-year storage requirement for each credit year and can be renewed an unlimited number of times, as supported by measure-to-measure improvements on the land. This project period minimum aims to incentivize more land regeneration from Land Stewards resistant to traditional 100-year requirements but who want to engage in ecologically valuable projects. Verification period is required to coincide with each credit release, and the crediting timeline is identified by the applicant. Both the verification and crediting timelines can be annualized, but both must proceed on the same timelines. The proponents proposed timeline dictates both, with the true-up timing occurring during the estimate range in years between T-0 and T-1 (e.g. 5-7 yrs.) as described above, from what has been learned about the time required under various regenerative practices in different ecological/geographic settings to be able to accurately measure a statistical signal of changes in soil carbon stocks (See literature references in TRS-Soil Carbon Method modules).

The project start date is defined as the date of commencement of the initial (T0) set of baseline soil measurements. The project start date can be up to five (5) years prior to the project registration date if the T0 sampling measurements are consistent with this TRS SOC V2.0.

Credit yield shall be calculated as the project scenario; the soil carbon measured in the project area after conversion to regenerative practices minus the soil carbon measured at the time of the baseline sampling.

Project registration and validation is required of an approved Project Proponent by the submittal of a Project Idea Note to an approved verifier and Nature’s Registry** for any project proposed under TRS SOC.
**Nature’s Registry is a separately governed and administered organization from The Regenerative Standard, and is addressed outside of this TRS-Soil Carbon Method document.

For project qualification and the issuance of credits, both interim and final, TRS SOC requires the Project Proponent to complete the following tasks (Figure 1) each of which is comprised of a number of sub-tasks:

Task 1: Project Overview - Identification and Eligibility of Project Activity
Task 2: Measurement and Reporting Plan
Task 3: Interim Crediting Assessment (optional)
Task 4: Project Application Submission
Task 5: Verification
Task 6: Registration

Fig 1. Overview of project framework and documentation

Project Requirements

When completing a TRS SOC Project Application, a Project Proponent shall submit responses to the following:

Task 1. Project Overview - Identification and Eligibility of Project Activity

A Project Proponent should summarize the land management activities, the stratification process and stratified-random sampling plan proposed, how data is collected, literature sources that support the project, planned project activities, and any deviations or additions to the methodologies detailed and/or referenced under TRS SOC. The project proponent must also demonstrate proof of contract with the land steward(s) as a submittal requirement, confirmed and affirmed by the verification and registry certification processes.

The longer-term roadmap for The Regenerative Standard is to layer in complexity over time. Phase 1 of the release of TRS is focused on The Soil Carbon Measurement Method (TRS SOC). Phase 2 will add Biodiversity. TRS SOC is focused on cropland, grassland and conservation/restoration project soil carbon. Future phases will integrate carbon stock changes in forests, wetlands, and peatlands. The soon to be introduced Biodiversity Method cuts across all ecosystems and land uses, and crediting is anticipated to be an option for additive credit with TRS SOC V2.0-based credits.

Task 1.1 Data confidentiality statement

A Project Proponent should list any data that is to remain confidential between the Project Proponent, Verifier, and Registry. Such data includes personal data, addresses, data related to the project properties, historical, current, and future land management techniques, livestock information, ecological assessment data, etc.

While data confidentiality is honored and necessary, data sharing under terms of protection and confidentiality is also encouraged to foster the exchange of knowledge essential to accelerate scaling, adoption, and to refine decision making so that time is not wasted experimenting with “what if” strategies for improving carbon drawdown and re-growing soil carbon stocks.

TRS SOC requires that raw data, computations, mapping of project baseline and responses to management to be submitted to the verifier for the verification process and with Nature’s Registry for credit certification, issuance, and warehousing. We are exploring confidential data warehousing for participating carbon project developers so that meta-analyses, such crowd sourced real time national mapping of carbon stocks and accrual rates can benefit all carbon developers. This can help reduce the discounting on credit yields, by providing more accurate early estimates of carbon credit yields, and other benefits. Actual landowner georeferenced data would be anonymized and confidential.

Carbon program/project developers are requested to discuss their willingness to explore participation in this data sharing and meta-analysis and having confidential web-portal access to updated findings created though this partnering. This broader philosophy can benefit all developers and accelerate rapid scaling of solutions to address soil carbon stock improvements, biodiversity, and other benefits of The Regenerative Standard.

Task 1.2 Physical Address of the Properties Submitted for Certification

A Project Proponent should describe the location of the project property with an address, latitude, longitude, total land area (e.g., acres, hectares, etc.), creditable land area, and verification of ownership (e.g., tax assessors’ data and vesting deed(s)).

Task 1.3 Description of Land Management Activity

A Project Proponent should document and describe landowners’ historical, current, and planned future land management practices, as applicable:

type(s) of livestock
stocking rates
number and size of paddocks
average rest and recovery periods
average rotation frequency
forage information
mowing/bush hog
bale grazing.
chemical usage
compost usage
notable wildlife/plants
notable non-native wildlife/plants
crops/crop types
burning
termite and earthworm diversity/density
soil organism’s genomics census
cover crop activities
other relevant and notable agricultural practices

For grazing projects, land management should be assessed semi-qualitatively using multiple factors that govern success in soil restoration using grazing, including:

land management style
number of years of regenerative or holistic management practice
# of paddocks
average paddock size
stocking density
stocking numbers
rotational frequency
livestock and wildlife diversity
grazing plan documentation
specific individual holistic practices impacting soil health
This qualitative assessment may determine how closely the reported grazing practices can correlate to a high, medium, or low impact to the site conservative estimate of soil organic carbon accrual potential.

Task 1.4 Project Eligibility

TRS SOC V2.0 is intended for use by projects on agricultural, grazing, and other regenerative, restorative practices or conservation lands undergoing Land Use Activity Change. Planned and/or implemented land management practices must be incorporated in the project plan to ensure that the project will increase the actual measured storage of soil organic carbon within the boundaries of the project.

A Project Proponent should use this section to describe how a project meets either the mandatory or optional project eligibility criteria outlined below.

Task 1.4.1 Mandatory Eligibility Conditions

All projects using this methodology must meet the following mandatory conditions:

Agricultural Land Management
Activities that increase carbon stocks in soils and non-forest woody biomass and reduce CO2, N2O and/or CH4 emissions to or from soils on croplands and/or grasslands. Avoided conversion projects are not eligible under TRS SOC V2.0 (See Glossary of terms) but projects that generate reduced GHG emissions may be eligible. And activities that

Improved Cropland Management (ICM**)
Improved Grassland Management (IGM)
Cropland and Grassland Land-use Conversions (CGLC)

** See acronyms in the Glossary of Definitions.

Grassland or Cropland
As of the project start date all the project areas consist of grasslands or croplands or non-forest and non-wetland, non-peatland landscapes. Crops may include woody species grown for food products, fuel products, or timber, providing that the densities of these crops do not meet the definition of forest lands. Orchards that integrate improved practices (e.g., a conversion of annually tilled cropped land, such as between the rows of fruit or nut tree crops) to perennial grasses that measurably improve soil organic carbon is an example of a “non-forest, food cropland” a project type under TRS SOC. If improved grassland, cropland, and improved management of protected or restored land is not the primary acreage enrolled by a landowner, these can be “associated enrolled land”, if the eligibility requirements are met (See definition of Soil in glossary of terms).
Non-forest, Non-wetland, Non-peatlands
The project area must exclude and must not have been had forest land cleared or, or wetlands or peatlands dewatered or filled in the past 10 years, with these types defined as:
Forest: Land with woody vegetation that meets an internationally accepted definition (e.g., UNFCCC, FAO, or IPCC) of what constitutes a forest, which includes threshold parameters, such as minimum forest area, tree height, and level of crown cover, and may include mature, secondary, degraded, and wetland forests and may be multi-species or have a simple single species composition. (See definition of Forest in glossary of terms)
Wetlands: Land that is inundated or saturated by water for all or part of the year (e.g., peatland), at such frequency and duration that under natural conditions they support organisms adapted to poorly aerated and/or saturated soil. Wetlands (including peatlands) cut across the different AFOLU categories. Project activities may be specific to wetlands or may be combined with other AFOLU activities. Periodic flooded croplands are only excluded if they are jurisdictional wetlands or farmed wetlands (as determined in the US Army Corp of Engineers 1987). Under this same manual, the USDA, NRCS focused their definition on agricultural lands, and their expanded program definitions include, Prior Converted (historic wetlands) lands, which can be included, if the conversion occurred prior to a decade before the proposed soil carbon project initiation date. They also define “Jurisdictional wetlands” which are excluded from this protocol only because the soil carbon measurement methods required for accurate repeated measurements are different than what is specified under TRS SOC. Wetland substrate carbon is also addressed in other protocols, for example addressing peat system carbon. (See definition of Wetland(s) in Glossary of Terms)
Peatlands: An area with a layer of naturally accumulated organic material (peat) that meets an internationally accepted threshold (e.g., host country, FAO, or IPCC) for the depth of the peat layer and the percentage of organic material composition. Peat originates because of water saturation. Peat soil is either saturated with water for long periods or artificially drained. Common names for peatland include mire, bog, fen, moor, muskeg, pocosin, and peat swamp (forest). Peatlands are only excluded if they are jurisdictional wetlands or farmed wetlands (as determined in the USA by the 1987 US Army Corp of Engineers, Wetland Delineation manual, and regional updates). Peatlands are excluded because the soil carbon measurement methods required for accurate repeated measurements are different than what is specified under TRS SOC and have been specifically addressed in other protocols. (See Peat land definition in the Glossary of Terms).
Displaced
The only baseline activities that could be displaced by the project activities are grazing and fodder production, crop production, and timber production. For example, continuous grazing can be displaced by improved grazing, such as adaptive multi paddock grazing to contribute to significant soil carbon improvements and predicted climate mitigation benefits (Teague et al 2016). Or, fodder production and crop production could be displaced by improved cropping, such as conversion of annual fodder to perennial crops (USDA 2014, Kimble et al 2007), or timber production that emphasizes understory vegetation health and productivity as a part of timber production, such as during oak savanna restoration (Apfelbaum and Haney 2010 and 2012).
Soil Water Regime Changes
Project activities must not include changes in surface and shallow (<1m) soil water regimes through flood irrigation, drainage, or other significant anthropogenic changes in the groundwater table.
Termites
The project activity must not cause a significant change in termite populations, as compared with the baseline scenario. The consideration of termites in a soil carbon project is primarily focused in tropical and subtropical grasslands and savannas. Termites exemplify one of a group of organism types that can contribute to significant improvements in primary productivity on a landscape, such as in subtropical grasslands and savannas (Whittaker R. H. 1979) but a significant increase in their abundance can result in methane emissions that can exceed the soil organic carbon improvements. The measurement (mapping of locations and enumeration the number) of terminaria as a part of baseline sampling and during annual monitoring and reporting, and for the true-up monitoring period, would need to show insignificant increases in the number of terminaria as a requirement to demonstrate eligibility during a project and crediting period.

Task 1.4.2 Optional Eligibility Criteria

The following conditions do not need to be met to utilize the methodology. The consequence of meeting these eligibility requirements for these conditions is that this allows the simplification of the methodology through the elimination of the requirement for the completion of specific tasks. The Optional Eligibility Criteria are available when a “representation or findings” of “No Change” for a baseline measurement(s) can be conservatively used to document no change in GHG emissions are expected even though an unequivocal decrease under the activity change is well documented (under a common activity change) or can be demonstrated. Use of the “no-change” selection, with a focus on measurement to measurement soil carbon stocks may be exercised by the project proponent. A project developer may also choose to formalize in their PDD, and measurements of actual Reduced emissions, and substantiate crediting for this GHG reduction. The following are examples of how this optional eligibility can be opted/opted out with the “no-change” option under TRS SOC.

As an example, a carbon project developer may opt to conservatively assume that actual GHG emissions before and after a conversion from an annually tilled farm field to a perennial native grassland are the same. By opting to use this assumption, they could use scientific literature GHG emissions profiles for any documentation needs, or all together assume no change occurs. The option of not measuring or projecting the changes can only be used where the scientific literature provides clear certainty that GHG emissions decrease with the changed land use or activity. Eliminating specific measurement or documentation tasks can be justified where project/program conservativeness is justifiably enhanced.

Consequence if met: Project Proponent is not required to complete Task 2.3.7 Projection of future emissions of N2O or CH4 from the soils within the project area and Task 2.3.26 Monitoring and estimation of soil emissions of N2O or CH4 from within the project area described herein.

Degrading Baseline Scenario (can be recognized as a type of dynamic baseline)
The activities and agents which have caused the degradation of the croplands, grasslands, rangelands, and conservation lands and their soils are expected to continue to impact the area in the absence of the project activity. On that basis, it can be demonstrated that soil organic (and often inorganic) carbon stocks in the project area are highly unlikely to increase under the baseline scenario during the project crediting period.
Protocols that refer to a Degrading (changing by loss of soil organic carbon stocks) baseline as a Dynamic Baseline (which vary over time with a declining trajectory in mean soil organic stock levels) contrast with a stable baseline (which vary temporally around a “stable” mean soil organic stock level) may or may not account for the dynamics at a landscape scale. Many projects that have used dynamic baselines have been project specific focusing on a narrowly defined type of activity. However, when working with large landscapes with a diversity of land use and changed land use activities, a “common activity baseline” or “weighted baselines” have been used to understand each participating property’s baseline and its likely trajectory within the larger statistical landscape.

For clarification, many existing agricultural, rangeland, and even conservation land conditions are declining. If a carbon program developer chooses to develop a “common activity baseline” for the region over which their improved agricultural soil carbon project is proposed, this could for example represent declining soil organic carbon stocks, using the weighted average loss based on the acreage of moldboard plowing (~2 TCo2e/acre per yr.), & conservation tillage (Loss of ~1.7 TCo2/acre-yr.), and one pass no-till ( + 2 TCo2e/acre-yr.) to mathematically estimate the regional losses as the baseline against which project site future project activities can be judged; this is the process used in Apfelbaum et al (2022). Or, the project proponent may conservatively assume no change would have occurred on the properties included in the project if the improvements under the proposed activity change did not occur.

Consequence if met:

If a project proponent can justify the selection of no-change under Tasks 2.3.2 through Tasks 2.3.10, then this would be so noted in their PDD. This selection would only require that during the project crediting period, during annual reporting and the true-up verification and crediting period, that documentation must be provided to affirm and defend this selection of “no-change”.

A second decision that must be documented is the use of a “stable” vs a “common activity baseline”. Generally, a stable baseline is more conservation, while a common activity baseline can more accurately document overall net changes in carbon accounting over the regional context, it can also be more challenging to measure and calculate in a robust and defensible way.

Given this additional complexity, a proponent in their PDD may also elect to use “a stable baseline”, which for purposes of TRS-Soil Carbon Method would be the equivalent of selecting the “No-Change” option. This is explained below:

Project Proponent may conservatively use a “Stable or Static Baseline Estimate”: by assuming that soil carbon content for all future dates under the baseline scenario shall be accounted as equal to the current soil carbon content, subject to re-assessment at true-up (T1, T2, etc.), as required under TRS SOC V2.0.

Optionally, a proponent may choose to create their property specific/land use history specific baseline measurements and then also create a “common activity baseline” so that accurate carbon accounting can be done to document the net changes/improvements by measurement to measurement changes on the project site, but also embed those changes within a landscape understanding.

Using the above for example, the “Stable baseline” based on Chronoseries analysis and confirmed with repeat sampling and also with flux tower analysis (the difference in carbon stocks between T-one minus T-zero levels, and over the same period of time--total mass balance Flux tower measured Total C sequestered) documented a + 2TCo2e/acre-yr. soil organic carbon accrual. But, the total net improvement using the “Common Activity Baseline” would include the gain under the Stable Baseline + the Reduced Emission losses of an additional ~ 2 Tco2e/acre-yr. based on common activity baseline. Thus the net change over the study region of 7 million acres with the conversion to Low Disturbance Cropping (with other performance details (See Apfelbaum et al 2022) was ~ 4 TCo2e/acre-yr.
No Change in Above and Below-Ground Biomass
Changes in above and below-ground living biomass pools within the project area can be shown to be insignificant under either the baseline or project scenarios.

Consequence if met: Project Proponent is not required to complete Task 2.2.1 Project area stratification for biomass, Task 2.2.2 Estimation of the carbon content of current above-ground woody and non-woody biomass and below-ground living biomass pools, Task 2.2.3 Projection of future biomass pools under the baseline scenario, and Task 2.4.2 Estimation of the carbon content of above-ground woody and non-woody and below-ground living biomass pools described herein.
No Change in Woody Biomass
Woody biomass is found within the project area but amounts of current and projected wood harvest under the baseline and project scenarios are not significant.

Consequence if met: Project Proponent is not required to complete Task 2.4.3 Estimation of the amount of wood harvest from within the project area used for the production of long-lived wood products, and Task 2.4.4 Long-lived wood products described herein.
No Change in Fertilizer, Manure, N-fixing Species. Flooding
No significant change is expected to occur in the amounts or locations of any of the following conditions or activities between the baseline scenario and the project scenario:

Amount or location of application of organic or inorganic fertilizers.
Amount or location of domesticated animal grazing and deposition of manure or urine.
Amount or location of areas subject to flooding, and duration of flooding.
Amount or location of nitrogen-fixing species.

Task 1.5 Project Boundary

A Project Proponent should identify the project boundary using the module TRS-3 Methods to Determine Project Boundary, noting exclusion areas, project start date, and project end date. Providing the project boundary as KML files or other interconvertible formats (e.g., geodetic polygons, additional shape files, maps, .kml files, GPS coordinates, etc.) to support the identification of boundaries accurately and unambiguously is required. The Project Proponent should complete the following task to identify the project boundary:

Task 1.5.1 Identification of project boundary

Requirement: Required for all projects.

Goal: To determine the project boundary for baseline scenario and additionality purposes.

Method: Determine the project boundary using the module TRS-3 Methods to Determine Project Boundary

Task 1.6 Baseline Scenario

This Task furthers the scrutiny in defining your baseline, and subtasks under Task 2 provide a framework for evaluating and documenting how you construct a baseline scenario for a project. Details on stratification, estimation of existing and future soil carbon stocks are detailed in TRS-1 Methods to Determine Stratification, v1.0, TRS-2 Methods to Project Future Conditions, v1.0, TRS-3 Methods to Determine the Project Boundary, v1.0 and VMD0021** Estimation of Stocks in the Soil Carbon Pool, v1.0. Computations for documentation. Details to develop a monitoring plan to measure baseline and the re-measurement of soil carbon stocks (TRS-16 Methods for Developing a Monitoring Plan, v1.0) and computations to document measure to measure changes in stocks (and including net changes if GHG emissions reductions are opted to be addressed by a carbon project developer), are provided (TRS-17 Methods to Determine the Net Change in Atmospheric GHG Resulting from Project Activities, v1.0).

A Project Proponent should follow the Baseline Scenario instructions in accordance with the information in Task 1.4 Project Eligibility and the above detailed technical methods, and for a project that meets the conditions in Task 1.4.2 Optional Eligibility Criteria. A Project Proponent should describe which criteria are met and list any credible references, as applicable.

The baseline scenario, which is what is actually measured, is the quantity of soil organic carbon present in the project area resulting from business-as-usual management practices. For TRS, the measured soil organic carbon stocks across a project site, that have been measured following the stratification, random sample allocation and numbers, and that have achieved defined sampling statistical sufficiently are used by the project proponent to document carbon stocks under an assumed to be static (i.e.. constant) activity during the project period.

TRS requires 1-meter-deep soil sampling (or to refusal, See glossary of terms) to establish a project T0 baseline. Using this actual measurement and assuming a static baseline scenario is more conservative since only atmospheric CO2 removals, (unless a carbon project developer chooses to address both removals and emission reductions), are quantified for additionality and crediting in TRS. Emission reductions might realistically occur, but due to the challenges and uncertainties of characterizing dynamic baselines at a landscape scale, a much more conservative static baseline minimizes the uncertainties by assuming no change in soil carbon stocks resulting as thought existing land uses continued. This assumption thus accepts measured changes over time in Soil organic carbon levels compared to the baseline level measured under the continued land use. And, after remeasurement during Time-one accepts that all changes from the baseline measurement would result from the change in activity during the project period.

While a static baseline (See definition of Static baseline) is possible, it is also a conservative assumption because in most conventionally managed agricultural and continuously grazed rangelands, and conserved lands that are not managed, the baseline measured soil organic carbon stocks often decrease in the absence of a regenerative/restorative project activity (as per Task 1.4.2 Optional Eligibility Criteria described in the previous section). As an example, for conventional continuous and long rotation/short (or no) recovery rotational grazed landscapes, declining carbon stocks have been well documented (Teague et al,2011, 2016; Sanderson et al 2020, etc.). conventional row crop lands. Similar findings for soil organic carbon declines have been documented for conventionally tilled and row cropped farm ground (Kimbal et al 2009). In overgrazed properties, soil degradation stemming from the deleterious consequences of forage consumption exceeding forage production (Sanderson et al. 2020) is particularly well documented as causative. In protected conservation land that are not being managed (e.g. fire suppression of fire-evolved and maintain grassland, savanna, wetland, forests) while aggressive and productive non-native and invasive shallow rooted and often annual plant species may increase above ground biomass, the below ground soil carbon stocks also have been documented to decline (Kimble et al 2007, Follett 2001, Folley et al 2005, Apfelbaum et al 2022).

While baseline is measured first and foremost, in terms of carbon stocks present, the project proponent also must provide fundamental measures of ecosystem integrity. This can be done using some standard simple measures such as for land cover, plant species composition, bare soil, presence/abundance of non-native invasive plants, etc. (See standard procedures and data collection forms in Apfelbaum and Haney 2012, The Restoring Ecological Health to Your Land Workbook, Island Press) which can provide for the measurement and understanding secondary evidence (Soil carbon stock measurements are the primary evidence) of the condition(s) occurring on the land before the activity change (i.e. at the time of baseline sampling) and after activity change (i.e. Time-one, Time-two…) the change in activity occurred.

Depending on project site complexity, there are many other ways to add additional levels of details, such as examination of historic and existing conditions. Additional understandings, besides just having carbon stock levels will not only contribute to the understanding of how the land (and carbon stocks change over time) but also can affirm over time that the baseline selection was defensible.

A conservative approach, a static baseline (See glossary of terms) must still be evidenced through demonstration of minimal water and wind-borne soil erosion (e.g., UNFCCC/CCNUCC - Tool for the identification of degraded or degrading lands for consideration in implementing CDM A/R project activities). Such evidence can be provided by measured percent bare soil, perennial vegetation plant cover, and/or invasive and non-native plant species percent cover using on-ground sampling and/or multi-temporal aerial photography or remote sensing which demonstrate the establishment of persistent vegetation cover for consecutive years, particularly following management conversion in degraded lands where re-establishment of healthy, diverse and productive plant communities can take many years. The baseline is established with a site visit evaluating strata, vegetation, and sampling to 1-meter deep and the results of the sampling event and other data collected during T0 represent the “best estimate” of the actual site baseline.

TRS SOC V2.0 allows static baseline and other scenarios at the option of the carbon project developer. Further details on baseline scenarios, and how to assess and frame the baseline to accomplish the requirements of this methodology; associated required submittals are elaborated under Task 2 and subtasks.

Task 1.7 Additionality

Additionality Testing Requirements

Introduction
The Regenerative Standard (TRS) aims to deliver the highest quality nature-based carbon removal credits. It is important for most carbon credit buyers that the acquired credits meet rigorous additionality criteria. TRS SOC V2.0 has adopted an expanded and transparent framework of rigorous and pragmatic best practices to ensure that TRS credits are considered fully additional.

In short, credits are additional if the GHG removal would not have happened in a “business as usual” situation. Project proponents must demonstrate additionality by passing all 4 rigorous tests:

Legal / Regulatory Requirement Test - The project activity is not required by law or regulation.
Financial Additionality Test - The greenhouse gas (GHG) emission reductions or removals from the mitigation activity would not have occurred in the absence of the incentive created by carbon credit revenues.
Performance Standard Test - The greenhouse gas (GHG) emission reductions or removals from the mitigation activity are resulting from the implementation of additional practices, or changes in practices, and are not resulting from common practice.
Measured Additionality Test - The quantitative greenhouse gas (GHG) removals resulting from the mitigation activity must be determined on basis of rigorous, science-based, field sampling and analysis.

Additionality is important to determining your use of The Regenerative Standard (TRS). The supposition is that if your project fails any one of the four tests, then the reduced carbon drawdown impact, or in this case improvements in measured soil carbon quantities in the ground, are not to be made available for sale in the carbon markets. TRS SOC V2.0 requires four rigorous tests of additionally. All four of the tests must be applied each time carbon credits are generated with expectations that the credits would be for sale in a voluntary or compliance marketplace. However, we recognize that for two of these tests—financial and measured additionality tests—the long-term and reliable answer may not be known for several years. Because of this, we define details for each additionality test as follows:

Legal/Regulatory Requirement Test
Objective:
To determine that the project activity is not required by law or regulation.

Evidence to be provided:
This test has an applicant (with verifier confirmation) documenting if the project activity change (e.g. a grazing change, planting a crop conversion, or converting from one method of tillage to another, etc.) is required by a legal decree, a zoning or regulatory permit or ordinance, law or regulation, agency approved farm/ranch plan or enrolled program. If the answer is NO, then your project has passed this test of additionality.
Financial Additionality Test
Objective:
To determine that the greenhouse gas (GHG) removals from the mitigation activity would not have occurred in the absence of the incentive created by carbon credit revenues.

Evidence to be provided:
This test has an applicant (with verifier confirmation) documenting if the project activity change could only be successfully implemented if the financial remuneration from selling carbon credits was available to the project. The applicant is required to determine if a carbon transaction is required, or is projected to provide the financing required before the applicant can afford to implement the practice change at scale (e.g. a grazing change, planting a crop conversion, or converting from one method of tillage to another, etc.) At scale means the practice change would be implemented at a sufficiently large enough scale over the acreage of land in your plan.

If you happened to already have adopted or experimented with the same practice change, you are considered as an “early adopter” and under most standards this has been used as evidence that the carbon financing was not needed for you to make the change.

What we have learned by working with farmers and ranchers is that even if you are an early adopter, most early adoption involves a steep and many-year learning curve to changing practices and making equipment changes. Because of this, most early adopters remain in the “experimenting or “learning stage” for many years. During this stage the practice change is rarely taken to scale over a farm or ranch. Thus, the traditional definition of early adopter perversely assumes immediate proficiency and assumes that the financial costs to become a true “adopter of a technology early” are a one-time cost. We reject this definition because any investment in a practice change isn’t solely about money. It’s also about building confidence enough to trust the wellbeing of your family’s economic health. And, because the new goal of reducing GHG’s and improving soil carbon is not the “Crop” any early adopter farmer ever focused on “growing”. The shift in knowledge, equipment, new practices, and reading the tea leaves requires long time periods to final settle into a resilient new farming/ranching practice adaptation.

To determine that the greenhouse gas (GHG) removals from the mitigation activity would not have occurred in the absence of the incentive created by carbon credit revenues, we implemented the Financial Additionality Test as defined below.

If the answer is that your activity change would not have occurred at a meaningful economic scale without the addition of new revenues, such as from carbon credit sales, then your project has passed this test of additionality.

Evaluate your project using the Financial Additionality Test
This test asks the two questions below. You can elect to answer these financial test questions for the first year of operations after changing your practices, or if your business plan is a multi-year program plan, you can choose to base your answers on your predicted multi-year plan and “break even analysis”. We also allow you to answer the questions based on your understanding at the time of your application. But we give you the flexibility to report when a credit is to be generated so that the reality of the financial performance for the startup conversion year(s) to the new practice is real and truly understood. Rainfall, materials and commodity costs/pricing changes so rapidly that any practice change usually involves a few years of experience, and thus the questions may only be accurately answered only a few years after you change a practice.

Question 1: Was a majority of the carbon credit revenue re-invested into the farming/ranching operations, management, and/or infrastructure, and labor needed to operate the facility. Infrastructure is defined as improvements in paddocks, fences, fencers, batt-latch gates, herd size, water systems, planting or diversification of pasture forage base including brush reduction; improvements in forage base, including noxious weed control, etc. Management and operations are defined as the labor and technology (record keeping, planning technology, communications technology, etc.) required to ensure success.

If the answer is YES, then you pass the financial additionality test. If the answer is NO, then you must answer Question 2.

Question 2: Did you experience less revenue being available for you to adopt the activity change than your ranch or farm plan suggested was going to be generated? If the answer is YES, then you pass the financial additionality test. If the answer is NO to both Questions 1 and 2, then you do not pass the financial additionality test.

Proof of Meeting the Financial Additionality Test:
Applicants must document that the farmer, rancher, landowner, or their management staff have provided information to answer Question 1 or Question 2 affirmatively. This information may be based on the past or current year’s activity or a multi-year plan as described above. The following are examples of information that can serve as proof:

A farm or ranch plan or multi-year plan showing past or planned costs and investments.
Increases in labor required or technology costs (record-keeping, communications, etc.), or other increased management and operations needs to carry out the project activities and ensure success.
Additional infrastructure, physical improvements or equipment (such as adding or improving paddocks, fences, fencers, batt-latch gates, herd water systems, planting or diversification of pasture forage base, improvements in forage base, including noxious weed control) that are connected with the project activities.
Any other form of documentation that the carbon credit revenue was a substantial contributor to the ability to make practice changes and carry out the project activity or to accelerate the practice changes and project activity.
Any other form of documentation that the carbon credit revenue contributed in a significant way to the financial stability, viability, and fiscal confidence of the farm or ranch so that the project activity can continue.
3. Performance Standard Test
Objective:
To determine that the greenhouse gas (GHG) emission reductions or removals from the mitigation activity are resulting from the implementation of additional practices, or changes in practices, and are not resulting from common practice.

Evidence to be provided:

Question 1
List the key practice changes to be implemented, and document that the practice change is NOT listed on the negative practice lists (maintained by TRS), for specific parts of the country. If the practice change is NOT on the negative lists, then the performance standard test is passed by your project. If the practice change IS on the negative lists, you must answer Question 2.

Question 2
Can the project proponents show project-specific factors to demonstrate that the part(s) of a project on the negative lists should actually be considered additional? Considerations can include specific unique characteristics of this land that render the common practices less relevant. Considerations can also include ongoing incremental adoption of more advanced regenerative practices above and beyond the common practice. The applicant must document this with verifier confirmation to demonstrate that greenhouse gas (GHG) emission reductions or removals from the mitigation activity are resulting from the implementation of additional practices, or changes in practices, and are not resulting from common practice. If the answer is YES, then the performance standard test is passed by your project. If the answer is NO to both Questions 1 and 2, then you do not pass the Performance Standard Test.

4. Measured Additionality Test
Objective:
The quantitative greenhouse gas (GHG) removals resulting from the mitigation activity must be determined on the basis of rigorous, science-based, field sampling and analysis.

Evidence to be provided:

The most relevant additionality test is the rigorous field sampling of improvements in soil organic carbon. If the improvement doesn’t occur, then under The Regenerative Standard there is no carbon crediting and no revenue generated. If there is an improvement between predicted and future measured carbon (for interim crediting) and between the baseline and time-one remeasurement (measure to measure improvements) then carbon credits can be generated and made available for sale.

The balance of The Regenerative Standard documents the standard procedures that must be used to do field soil sampling, laboratory measurements of soil carbon levels, and also the computational procedures to document changes in soil carbon stocks. If there are positive changes these are called accruals and this outcome can generate credits meeting the Measured Additionality Test.

If additional soil organic carbon stocks are measured in your soil from the repeated sampling soil tests and if projections predict improvements for interim releases of credits during years when actual measurements are not conducted, then, YES, you have passed the Measured Additionality Test.

Task 1.8 Permanence

The TRS Permanence measures:

Permanence
Permanence is a reasonable and adequate assurance that the atmospheric carbon removal created by a project is secured and guaranteed for at least 40 years and that reasonable and adequate measures are implemented and secured for this time to monitor and observe any carbon removal reversals. The buffer pool is designed to compensate for carbon removal reversals, regardless of the reason of those reversals.

The biophysical permanence of soil organic carbon is summarized as a preface to TRS requirements for how permanence is monitored, how reversal risk is tested, and how reversals are mitigated:

1. Soil Carbon Durability and main reversal risks
2. TRS Soil Carbon permanence monitoring
3. TRS Soil Carbon reversal risk mitigation measures

1. Soil Carbon Durability and main reversal risks

Although agricultural soil carbon sequestration is sometimes classified as “temporary” or “low permanence”, this is not aligned with the scientific understanding of the actual durability of soil carbon. Soil Organic Carbon [SOC] stocks are one of the most stable and durable and abundant forms of organic carbon in nature. On our planet, there is more organic carbon in the first 1m (39.4 inches) of soil than all biomass and atmospheric carbon combined. The soil has been one of Nature’s primary places (after the Oceans) to store organic (and inorganic) carbon. Nature has been storing carbon in soil for hundreds of millions of years.

the science community well understands the durability of soil organic carbon stocks. Scientific understanding of the durability of soil carbon, especially that of mineral associated fractions, suggests a durability for thousands to tens of thousands to millions of years or more (Cotrufo and Lavalee 2022, and Lavallee, Soong and Cotrufo 2019, Mosier et al 2021). Some projects have documented soil organic and organic carbon stocks that have been measured in the millions of years of age. These documented durability and longevities are many multiples longer than the age of carbon stocks as customarily measured in trees, and even the age of peat substrates on earth which typically range from 10,000 to 100,000 years of age (UN global peat report).

Individual carbon containing molecules in soil are highly dynamic in a living and thriving soil ecosystem. The carbon of an atmospheric CO2 molecule captured today might be released back into the atmosphere via a chain of highly complex biochemical and biological processes in a matter of a few hours. This does not mean a low carbon durability. While individual carbon containing molecules in soil might not be permanent, or durable, viewed through an engineering mindset lens thinking of carbon stored in a vessel, the bulk soil carbon stock is very stable and durable and continues to accrue in a dynamic equilibrium with plant productivity, microbial productivity, and biogeochemical cycles driven by moisture and photosynthesis.

Evaluating Reversal Risks and Buffer Pool Options

TRS and Nature’s Registry have evaluated the multiple ways different soil carbon protocols address permanence and how they mitigate for reversals. TRS has developed a comprehensive and pragmatic risk-based permanence framework that evaluates the primary natural and direct human caused reversals to permanence as our preferred and encouraged option for users of TRS. However, we also recognize several other options used for this same purpose that may be selected by project developers as follows:

Buffer Pool Assurance Options:

TRS is focused on the use of the risk-based buffer pool described below. However, applicants may choose from several different options:

Option 1: Set Permanence Retainage
No less than 10% of the credits issued from the project will be withheld in a buffer account.

Option 2. Risk-based Permanence Retainage

This is TRS’s encouraged and preferred Buffer Pool and reversal risk tool.

Option 3. Statistical Variance Method to Inform Retainage

If variances in estimating the mean carbon stocks across properties is equal to or less than 10%, the statistical results can be used as a basis for estimating and determining the buffer retainage from a project.

Option1: Set Permanence Retainage
TRS requires the project developers to deliver at least 10% of the credits generated to the buffer pool. The Registry will manage the buffer pool.

The Registry has the mandate to increase this buffer to levels higher than 10%, based on general risk assessments for the portfolio of projects, or a specific risks assessment for specific projects. If the Registry determines to increase the buffer above 10%, the registry must document the science-based rationale that an increase above 10% is a reasonable requirement to safeguard the permanence guarantees for the credits. The Registry has the mandate to reduce permanence levels from higher than 10% back to 10%.

Option 2. Risk-Based Permanence Retainage

This is TRS’s encouraged and preferred option, and it requires project developers to apply a pragmatic permanence framework that uses the primary documented risks to the permanence of soil organic carbon [SOC] stocks. This includes six key natural risks, and an additional seven key direct human caused risks, also called avoidable risks. These risks to impact permanence are further divided into impact on shallow (top) soil (<30 cm) and impact on deeper soil layers (30-100 cm). Using this option, no less than 8% of the credits issued from the project will be withheld in a buffer account, and the exact percentage is calculated based on these combined risks.

The scientific literature provides examples of the approximate magnitude of each risk, for SOC decline and the depth of loss in the soil system. Most risks are primarily shallow in nature (<30 cm depth) and affect what is well documented to be present in these shallower depth strata as short-lived particulate carbon fractions. Only a few risks from stochastic events and chronic direct human induced changes (avoidable impacts) affect deeper soil depths (> 30 cm) which typically contain the long lived, mineral associated carbon fractions. These are fractions that are well documented to achieve thousands to hundreds of thousands of years of durability or older age. And these deeper soils are the locations where soil organic carbon conversions to even more stable mineralized carbon, and leaches soil inorganic carbon fractions (which also reside in most soil systems), which can be millions of years in age and durability.

The key nature induced risks to SOC durability are:

wildfires
soil heating
soil wetting and saturation
soil desiccation
drought
soil erosion (often the result from the previous risks, or human induced risks)

The key human induced, or avoidable risks to SOC durability are:

soil dewatering
soil tillage
lack of soil cover by vegetation
synthetic fertilizers
over-use of chemicals
drought
overgrazing
excavating

Generally, it can be stated that natural impacts on SOC stocks mainly impact the shallower soil layer [<30 cm], while human induced risks, or avoidable risk chronically impact shallower (e.g. think about the annual tillage of a farm field) and stochastic events affect deeper SOC stocks (e.g. think about deep gulley erosion events after the dust bowl in North America in the 1930’s). Healthy ecologies and their soil systems are more resilient to most of the key risks that can reduce SOC. Figure 1 provides an indicative summary overview of the 13 key risks and qualitative key impacts on SOC stocks for a shallow soil layer (<30 cm) and a deeper soil layer (>30 cm).

**Figure 2 - An indicative overview of 13 key risks and a simplified qualitative summary of the key impacts on SOC stocks for a shallow (<30 cm) and a deeper soil layer (>30 cm).**

If a project developer decides to apply for Option 2 [Risk Based Permanence Retainage], the project developer must demonstrate, on basis of transparent reasonable scientific based data and assumptions, for a specific project what the risk-based permanence buffer pool contribution percentage should be. The Risk Based Permanence Retainage, proposed by the project developer, must be accepted by the Registry.

The project developer must demonstrate and document (on basis of transparent reasonable scientific based data and assumptions) for each of the six key natural risks, and the additional seven key direct human caused risks, also called avoidable risks, what the likelihood of occurrence is in the permanence period and what the SOC impact can be for each of these risks, with in addition, a reasonable safety factor.

Option 3. Statistical Variance Method to Inform Retainage
If variances in estimating the mean carbon stocks across properties is equal to or less than 10%, the statistical results can be used as a basis for estimating and determining the buffer retainage from a project.

If a project developer decides to apply for Option 3 [Statistical Variance Method to Inform Retainage], the project developer must demonstrate, on basis of transparent reasonable scientific based data and assumptions, for a specific project what the risk-based permanence buffer pool contribution percentage should be. The Risk Based Permanence Retainage, proposed by the project developer, must be accepted by the Registry.

2. TRS Soil Carbon permanence monitoring

To provide a reasonable and adequate assurance that the atmospheric carbon removal created by a project is secured and guaranteed for at least 40 years, preferably 100 years, TRS requires the project developer to implement, maintain and guarantee the deployment of measures to timely monitor and document any carbon removal reversals.

Roles and Responsibilities: TRS Soil Carbon permanence monitoring

The Project developer:
The project developer is responsible and accountable for the implementation, maintenance and quality of the system or set of measures to frequently and timely monitor and observe any carbon removal reversals.
Independent third-party verifier:
The independent third-party project verifier must include an assessment of the quality of the system or set of measures to frequently and timely monitor and observe any carbon removal reversals, operated, and maintained by the project developer.
The Registry:
The Registry used to register and maintain the ledger of carbon credits generated according to TRS, is responsible and accountable to frequently review if the systems’ set of measures, used by the project developer to frequently monitor and timely document any carbon removal reversals, is adequately useful for this purpose.
The Registry - Mitigation plan:
The registry must maintain an active set of standards in the form of a mitigation plan describing in adequate detail what pragmatic actions must be implemented by the project developer/landowner, and affirm the system or set of measures to frequently and timely monitor and observe any carbon removal reversals, in case:

The project developer ceases to exist or is incapable or unwilling to execute its monitoring roles and responsibilities.
The registry ceases to exist or is incapable or unwilling to execute its monitoring roles and responsibilities.

The carbon reversal monitoring system for each project should comprise a portfolio of at least some of the following tools and mechanisms:

A contractual agreement between the project developer and landowners in the project to restrict the use of land management practices that form a risk to SOC stocks for the specified permanence period.
A frequent, for instance annual, formal declaration (affidavit) of the landowner submitted to the project developer, that key land management risks and key natural risks did not occur at the property, or if they did occur to what extent.
A frequent, for instance once every 5 years, use of adequate remote sensing tools and techniques to observe any of the key risks that might lead to carbon removal reversals.
A frequent, for instance once every 5-years, visit of the project site to observe any of the key risks that might lead to carbon removal reversals.
Other adequate methods, tools and techniques that will provide frequent (e.g., yearly) and a timely observation of the occurrence of key risks that might lead to carbon removal reversals.

During the phase in which the project is actively delivering carbon removal credits according to TRS, carbon removal credits are generated frequently (e.g. annually) which requires an assessment of the carbon storage accrual, and a frequent (e.g. every 5-years) measure to measure determination of the SOC. For every credit delivery application, independent third party verification of the lack of occurrence of carbon removal reversals is mandatory.

During the phase in which the project is no longer actively delivering carbon removal credits, but the permanence period has not yet expired, the project developer must report to the registry annually that the carbon reversal monitoring system has been implemented and where/if mitigation was necessary, how that has been, or will be implemented and the ongoing revised monitoring commitments.

In the case that carbon removal reversals are observed by any party, the project developer has the main responsibility to report to the registry a carbon removal reversal report, including: the location of reversals, acreage affected, estimated quantify of the reversals, date of the reversals and likely cause(s) of reversals. In case the project developer is unable or unwilling to report carbon removal reversals, any party can report the reversals, or suspicion of reversals, to the Registry.

3. TRS Soil Carbon reversal risk mitigation measures

Once a carbon removal reversal has been observed or reported the next step is to ensure that the carbon removal reversal is adequately and timely compensated and thus effectively eliminated. The following TRS procedures describe the portfolio of actions and measures to guarantee adequate TRS credit permanence.

TRS Buffer Pool Requirements

The TRS buffer requires a 40-year minimum commitment to monitor, report, and compensate for reversals. TRS requirement details addressed in this section include:

Projects are required to contribute to a pooled buffer operated by Nature’s Registry.
Project credits retained in the buffer pool are not returned to the project developer or landowner at the end of their permanence/storage period. Note: This is a change from projects developed under previous versions of The Regenerative Standard.
Project credits included in the buffer pool can be used for shortfalls and/or reversals, either avoidable and/or unavoidable.

Buffer Program Execution and Participation

TRS has established a buffer pool “insurance program” against avoidable and unavoidable reversals to guarantee permanence and trust that carbon credits always represent actual atmospheric carbon removal, based on measured improvements in soil organic carbon stocks in soil.

Retainage/Contributions to Buffer Pool

Each project must at the time of project registration commit to participating in the buffer pool as an eligibility requirement of TRS.
The verifier reviews the permanence test applied to the project and the results, and the verification report confirms that the project PDD includes an appropriate level of credit retainage proposed by the applicant that would be moved to the buffer pool upon Nature’s Registry approval, certification, and issuance of credits for the project.
The retainage must meet the TRS retainage guidelines to ensure the buffer pool is adequately and appropriately de-risked to address reversals, and any shortfalls of any type over, at least, forty years.

Retainage Guidance

The buffer pool creates the assurance that applicant reversals and shortfalls can be timely mitigated so that the sales of carbon removal credit don’t exceed the improvements in soil carbon stocks that can be credited as carbon removal credits from any project over time.

The buffer pool should be viewed as the equivalent of a bank account that is constructed from credits which can be used to compensate for shortfalls or reversals, by the Registry debiting against the buffer pool to provide the compensation.

Whereas the TRS method is predicated on trusted science as measured from repeat soil sampling and SOC analysis on the ground.

Whereas the voluntary carbon market depends on robust and credible market representations of credit yields from each participating project.

Whereas, on the ground activity changes, meteorological changes, and landowner land management decision making may contribute to deviations from projections during interim crediting periods between the baseline and remeasurement periods for soil organic carbon stocks to determine crediting achieved.

Therefore, the following rules must be followed by each project participant in this program:

Applicants must commit to participating in the buffer pool to be eligible to participate under the TRS program.
Verification report results shall be the applicants direct feedback on the adequacy of the buffer credit retainage required from each project to be deposited in the buffer pool.
Buffer pool retained credits shall be deposited as a requirement for credit certification and issuance to the registry.
The registry retains the decision-making authority over the entire buffer pool, based on reversal records, to increase or decrease the buffer pool contribution required by each project.
The project developer can use the permanence test of risk to estimate and document for the verification process, their proposed project’s contribution to the buffer pool, as described in section 2: option 2 or 3.

Option 2. Risk-based Permanence Retainage
Option 3. Statistical Variance Method to Inform Retainage

Buffer Account Governance

The Registry’s buffer pool account(s) represents an insurance program for each participating project to ensure no oversales occur in the marketplace and each credit sold in the marketplace represents atmospheric carbon removal for the permanence period of at least 40 years.
The Registry establishes, maintains, manages, accounts, and makes available for internal and external audits the buffer pool account performance and records.
Shortfall compensation records and reports are generated by the registry quarterly and used by the registry to make any adjustments in the required retainage from future projects, or future annual tranches of credit generated for sale from the same project over time.
The Registry holds as a part of the ledger records on each project’s contribution to the buffer pool.
The Registry quarterly documents shortfalls or reversals from each project in the ledger. A ledger report is available to each project developer and landowner via the on-line project portal and through automated direct emailing to ensure all parties understand the status of accounts, shortfalls, reversals, and credit status.
If a project is experiencing shortfalls, subsequent tranches from the same project and/or other projects by the same project developer can be used by the project developer to provide annual true-up adjustments in credit retained in the buffer pool.
The Registry retains the authority and right over time to adjust buffer credits in the buffer pool should representations made by the project proponent result in an overstatement of the number of actual measurement-based credits deposited in the buffer pool.
The Registry can only liquidate (trade/sell) a commensurate quantity of credits from the buffer pool should some extenuating circumstances such as market adjustments, or policy changes result in a diminishment of the number of credits generated, number of credits in the buffer pool, or other unpredictable circumstance.

Addressing Reversals

Avoidable reversals – Human induced impacts on SOC stock permanence are to be compensated by the project developer and landowner. If the project developer and landowner fail to timely compensate, the buffer pool will be used.
For avoidable reversals, after written notice, the landowner is the first party responsible, during a two growing season period, to generate other shortfall compensating credits or purchase equivalent credits to compensate for the avoidable reversal. After this two year period, failure to compensate would invoke the Registry to debit the buffer pool account of the project and then necessitate that the buffer pool account be replenished by the project proponent. In this situation the buffer pool is used as a buffer to provide timely compensation of shortfalls, before the landowner and project developer are replenishing the buffer account.
Unavoidable Reversals- Nature induced impacts on SOC stock permanence will be compensated by sharing, as explained below, with the developer, landowner and/or from the buffer pool.
For unavoidable reversals, the registry shall compensate for some or all the shortfall by debiting the buffer pool after written notice is given to the project applicant and landowner.
After written notice, the project applicant and landowner shall have two years to provide an affirmative compensation plan to result in satisfying the reversal prior to Nature’s Registry debiting the buffer pool. In this situation the buffer pool is used as a buffer to provide timely compensation of shortfalls, before the landowner and project developer are replenishing the buffer account.

Process and Timing on addressing reversals and shortfalls

Indications and/or evidence of a reversal shall trigger the requirement of a project developer/landowner to investigate and report to explain the reversal and estimate the losses.
Evidence of shortfall shall trigger the same requirement for a developer/landowner report to explain the shortfall estimate.

The evidentiary project plan shall be created by the project developer/landowner to compensate for the reversal/shortfall with adequate details, and this plan should be submitted to the previous verifier of record, to the Registry, and retained to submit during a future verification the next time the project seeks to generate credits.
The Registry can decisively issue a reversal acceptance order, an order of inconclusive or uncertain findings, or an order rejecting the plan for reversal.
The Project developer and landowner will have 90 days to accept or modify findings to revise the reversal mitigation remedy plan.
The Project developer and landowner will have two growing seasons after acceptance of the plan to create the compensation, or can agree at the time of submitting the reversal mitigation remedy plan to accept the following compensation requirement.
At the project’s next verification event, such as the next time it seeks to generate credits, the verifier should review and verify any reversals that were not previously verified.

Mitigation Procedures for project developer/landowner

Buffer compensation can involve cancelling credits held in the buffer pool so that other credits for sale will still be valid for trade/sale.
A compensation plan must focus on mitigating with valid measurement-based (not projections and modeling) credits that exist or that can be demonstrated through repeated sampling have a 90% probability based on past performance to exist within the two year time window of any plan to accomplish the reconciliation.
A compensation plan can involve a new deposit of certified issued measurement-based unsold credits.
Additional instruments of surety can be used by the project applicant in the compensation plan. These may include insurance instruments that allow the project developer, landowner, or Registry to purchase compensation from other credit sellers with bonified measurement-based credits.

Pooled Buffer cannot be used for a project to cover verifier reviewed and verification report confirmed project-specific shortfalls.

The project plan for a shortfall shall identify how a project developer/landowner plans to address the shortfall.

Strategy #1 is that any new credits that a project may generate over the following two years shall be the primary source of new credits to cover project shortfalls.
Only after a period of two years if the project is unable to generate credits to cover the shortfalls then the Registry may choose to use the Buffer pool to cover those shortfalls.
If the buffer pool is debited to cover a shortfall, the project developer/landowner must replenish the buffer pool using its future years of credits generated before it can resume generating credits that can be sold.

In the event the compensation plan is still not acceptable or not believed to be achievable by the verifier or Registry, the Registry will debit the next tranche, any remaining unsold credits for as much as 100% of the reversal credit mitigation needs prior to debiting from the buffer pool.

Monitoring and Reporting

Annual reporting must be detailed in each reversal/shortfall compensation plan.
If a project lapses in monitoring or reporting, during and/or after the crediting period or storage/permanence period, a formal notification shall be given by the Registry to the project developer/landowner.
If the compensation or mitigation for reversals/shortfalls is not adequately made and if monitoring and reporting lapse continues, the Registry will provide written notice to cease and desist in credit sales. The applicant, project developer, and landowner will respond within 30 days with the required monitoring and Reporting. If said report is not received by the registry, the applicant/project developer and landowner will all be notified their project is a delinquent project and is no longer in good standing for selling or trading carbon credits.
The applicant/developer/landowner will have another 30 days to resolve the delinquency.
If the delinquency is not resolved, either by submittal of a refined, revised mitigation plan, or submittal to the verifier with an accepted updated verification report approving said plan, then the delinquent project shall be put on suspension, formally with a suspension notification delivered by the Registry to the applicant/project developer and landowner.
Suspension notification will mean remaining unsold carbon credits that were issued by the Registry will have their certifications removed, until further notice.

Task 1.9 Credit Release

Credit releases following an annual verification is the expected standard of this methodology. Credit releases can occur annually, or at the timeline scheduled in the PDD, commensurate with sampling, annual activity reporting, and permanence assurances being in place and only after annual verification occurs. The Project Proponent may select a credit release after each sampling event (e.g. after T0) or, if completing the optional Task 3. Interim Crediting Assessment, an annual release based on verified carbon stock estimates and adjusted by the T1 or subsequent-year measurement under Verra’s VMD0021 Estimation of Stocks in the Soil Carbon Pool, v1.0 requirements. Annual releases will be certified with the submittal of the Verification Checklist, as detailed in Task 5. Verification, verifying that the assumptions in the original application continue as represented. It is critical that credit releases occur in a timely manner to ensure cash flow to landowners and Land Stewards, and availability of registry credits to carbon credit purchasers. See Task 6. Registration for more details.

Task 1.10 Contractual Commitment

A Project Proponent must describe the contractual commitment with the Land Steward and/or landowner and enforceable provisions within the contract to address topics such as non-disturbance and permanence terms, land ownership changes, double accounting prevention mechanisms, and how the Project Proponent intends to monitor contractual commitments. A Project Proponent should provide the executed contract with the landowner as proof of meeting contractual eligibility.

Task 2. Measurement and Reporting

A Project Proponent must describe the stratification and sample allocation, methods for quantifying soil carbon pools and GHG emissions for the baseline and project scenarios including laboratory and statistical analysis, and reporting.

TRS SOC is focused on carbon removal credits to be generated associated with increases in soil carbon stocks, provided those stocks are rigorously quantified using the procedures described above. No credit is currently awarded with TRS SOC V2.0 for avoided emissions (See glossary of terms) of GHGs associated with land protection. Crediting is an option to be considered by the project proponent for reduced emissions (see glossary of terms) for reduced agricultural inputs such as fertilizers and pesticides, tillage, reduced usage of powered farm equipment. Currently, no crediting is accepted under TRS SOC V2.0 for reduced emissions from livestock or manure operations. This makes TRS SOC V2.0 inherently conservative in terms of the number of credits issued.

However, TRS SOC requires a monitoring plan for leakage that offers a reasonable and sufficient assurance that the net storage of atmospheric carbon in the soil carbon pool has not been negatively impacted by increases in GHG emissions within the project area or elsewhere outside the project area resulting from the implementation of a proposed project.

Changes in carbon pools and GHG emissions related to both project activities and leakage for the project scenario shall be addressed with a two-step process:

A qualitative evaluation to determine if the Project Proponent can establish with reasonable and sufficient assurance that the carbon pools and GHG emissions are likely to remain unchanged during the project period (i.e., they are not expected to change by 10% on a time-weighted basis) or the potential changes are transient in nature.
If the changes in carbon pools and GHG emissions are not likely to be significant (i.e. less than 10% change expected) and can for all practical purposes be considered de minimis, a Project Proponent does not need to quantify these pools and emissions and their value may be accounted as zero for the purposes of carbon crediting.

Otherwise, the magnitude of the changes in carbon pools and GHG emissions must be quantified within the uncertainty limits following validated protocols described below, with zero reductions to carbon crediting if any change is determined de minimis based on application of the CDM A/R methodological Tool for testing significance of GHG emissions in A/R CDM project activities. A few examples of the many resources that may be helpful in this screening include the following examples from Meta-Analyses (Eagle et al 2011, ICF 2013, Kimble et al 2007 and USDA, 2014).

Use the decision support in Table 1, for reasonable and sufficient assurance that carbon pools and GHG emissions are not changing for the project scenario, the Project Proponent is required to determine, at a minimum, the likelihood of the project activities leading to an increase in GHG emissions either within the project area or outside the project area based on consideration of the most important GHG emissions related to operations in agricultural, grazing, and restoration and conservation lands. Table 1 findings will also be used to inform under Section 3.1 the Interim Crediting Assessment for soil carbon changes from a proposed activity change on a project.

**Table 1: Likelihood of project activities leading to an increase in GHG emissions during the project period**

For example, if a decline in agricultural production or significant wood harvesting is likely to occur that would change the project baseline scenario by more than 10%, Task 2.6.1 Monitoring and estimation of emissions from grazing, fodder and agricultural production displacement need to be completed since a change in carbon stocks or GHG emissions might have occurred as a result of the project. Similarly, Task 2.6.2 Monitoring and estimation of emissions from wood harvest displacement need to be completed only if significant wood harvesting from the project area is likely to occur, etc.

It follows that if the project does not involve a reduction of agricultural production nor a reduction in wood harvesting after the project start date, then leakage related to these factors would be zero and optional tasks related to quantitative accounting of carbon or GHG emissions do not need to be completed.

Conversely, if the magnitude of the changes in carbon pools and GHG emissions as a result of the project activities during the duration of the project are likely to change by more than 10%, optional tasks for estimation of the carbon content of current pools and the projection of carbon pools and emissions must be completed.

Task 2.1 Quantification of Soil Carbon Stocks for Baseline and Project Scenarios

These tasks relate to the quantification of soil carbon stocks and, as the core measurements for TRS SOC, are required for all projects.

Task 2.1.1 Stratification for soil carbon sampling

The stratification process involves assembling Project Boundary, soil, hydrologic setting, and vegetation data and selecting representative and adequate locations in the Project Area for the allocation of random soil sampling points. A stratification process and sampling design, including sample point allocation, should in general follow guidance from Task 1.6 Baseline Scenario and Verra’s modules TRS-1 Methods to Determine Stratification and VMD0021 Estimation of Stocks in the Soil Carbon Pool, to quantify the change in soil carbon stocks over time (e.g. as the difference between carbon stocks in T0 and T1) within the project area and to increase measurement precision in a cost-effective manner. This information gathered both quantifies the existing soil carbon pool and enables projections of future conditions per unit area with statistical rigor.

Requirement: Required for all projects.

Goal: To divide the project area into one or more strata within which the projected soil carbon pools and soil carbon dynamics are expected to be uniform under the project scenario, given the stratification determined in Task 2.1, and the proposed treatment under the project scenario.

Method: Use module TRS-1 Methods to Determine Stratification, with soil carbon as the relevant variable X.

Task 2.1.2 Sampling and analysis for soil carbon per unit area, per stratum

The goal is to install sufficient sample locations to meet the required statistical rigor, as discussed in Task 2.1.3 Uncertainty of soil carbon stocks, below. For example, the Project Proponent may use a number of statistical methods to estimate the expected number of samples required, including those in the CDM A/R Methodological Tool Calculation of the number of sample plots for measurements within A/R CDM project activities (Version 2.0 or later).

Requirement: Required for all projects.

Goal: To sample the organic and inorganic soil carbon content in each stratum with a sampling intensity sufficient to estimate at the required levels of statistical precision and accuracy, the amount of soil carbon per unit area.

Method: Use module VMD0021 Estimation of Stocks in the Soil Carbon Pool.

Task 2.1.3 Uncertainty of soil carbon stocks

Projects that utilize emerging technologies for interim crediting or to augment direct soil sampling to 1-meter depth (or to refusal), for example, satellite data, proximal sensing, chrono sequences, eddy covariance data, shallow core sampling (for example, 30-cm depth) and/or digital soil mapping, must demonstrate that the additional methods of measurement predict SOC with sufficient accuracy to meet or exceed the requirements defined in Verra’s VM0042 Methodology for Improved Agricultural Land Management, v2.0, Section 8.6 Uncertainty or VM0026 Methodology for Sustainable Grasslands Management v1.1, Section 8.2.9 Uncertainty Analysis. Projects may use emerging technologies to track, monitor or measures indicators of SOC content if sufficient scientific progress has been achieved in calibrating and validating measurements, and uncertainty is understood. See Appendix 2.0 for examples of several emerging technologies.

Project Proponents may meet or exceed the Verra Standard confidence and uncertainty factors defined in VM0042 Methodology for Improved Agricultural Land Management, v2.0, Section 8.6 Uncertainty or VM0026 Methodology for Sustainable Grasslands Management v1.1, Section 8.2.9 Uncertainty Analysis and utilize project statistically significant factors for SOC analysis and utilize emerging technologies per Appendix 2.0. Statistical confidence and uncertainty must be demonstrated at the appropriate spatial scale of the measurement method.

If the uncertainty is above the limit defined in Verra’s VM0042 Methodology for Improved Agricultural Land Management, v2.0, Section 8.6 Uncertainty or VM0026 Methodology for Sustainable Grasslands Management v1.1, Section 8.2.9 Uncertainty Analysis, a Project Proponent would reduce the carbon removal assessment by the percentage of uncertainty exceeding the uncertainty determined in the applicable Verra Standard, unless a Project Proponent resolves the uncertainty by:

Utilizing VMD0021 Estimation of Stocks in the Soil Carbon Pool Step 6.5a and TRS-1 Methods to Determine Stratification Step 7 or
Demonstrating statistically that the project falls within the uncertainty percentage for the applicable Verra Standard utilized by the Project Proponent.

As an example, lower cost flux towers have become available to measure annual mass balance of GHG’s over landscapes. Prior to accepting these new towers, a research team did two years of side-by-side testing on multiple ranches to see how the long-established flux tower and the lower cost units compared. These findings affirmed more durable and reliable data collection (less down time for maintenance) with the lower cost units, and comparable accuracy and precision during the concurrent data collection periods. The performance testing did, however, demonstrate the lower down time provided a more accurate estimation annual net change in GHG flux.

Quantification of Baseline Emissions from Non-Soil Carbon Sources

These tasks relate to quantification of emissions from sources other than soil carbon such as biomass carbon pools, CH4, N2O, etc. They are required for all projects where significant changes greater than 10% are expected for the baseline scenario at any time after the project start date; but are optional for other projects.

Task 2.1.4 Project area stratification for biomass

Requirement: Required for all projects where the difference in total above and below-ground biomass carbon between the project scenario and the baseline scenario at any time after the project start date is expected to be significant. Optional for all other projects.

Goal: To divide the project area into one or more strata within which the existing vegetation carbon pools and vegetation dynamics are uniform.

Method: Use module TRS-1 Methods to Determine Stratification, with above and below-ground biomass stocks per unit area as the relevant variable X.

Task 2.1.5 Estimation of the carbon content of current above-ground woody and non-woody biomass and below-ground living biomass pools

Requirement: Required for all projects where the difference in total above- and below-ground biomass carbon between the project scenario and the baseline scenario at any time after the project start date is expected to be significant. Optional for all other projects.

Goal: To sample the above-ground biomass pools and derive the below-ground biomass pool in each stratum with a sampling intensity sufficient to estimate at the required levels of statistical precision and accuracy, the amount of biomass carbon per unit area.

Method: Use module TRS-4 Estimation of Carbon Stocks in Living Plant Biomass.

Task 2.1.6 Projection of future biomass pools under the baseline scenario

Goal: To determine the future changes in total biomass within the project area under the baseline scenario.

Method: Use module TRS-2 Methods to Project Future Conditions, with biomass pools as the relevant variable X.

Task 2.1.7 Estimation of the amount of current wood harvest from within the project area used for production of long-lived wood products

Requirement: Required where the harvest of significant quantities (defined as greater than the amounts of woody biomass that currently die annually, and through natural decomposition release GHG quantities to the atmosphere) that are greater than the amounts of woody biomass currently occurs within the project area, or is expected to be regenerated annually in the future under the baseline scenario, and some or all of that woody biomass is used for the production of long lived wood products. Optional and not recommended in all other cases.

Goal: To estimate the current amount of woody biomass harvesting taking place within the project area.

Method: Use module TRS-7 Estimation of Woody Biomass Harvesting and Utilization.

Task 2.1.8 Projection of future wood harvest outputs

Requirement: Required where the harvest of significant amounts of woody biomass currently occurs within the project area or is expected to occur in the future under the baseline scenario, and some or all that woody biomass is used to produce long-lived wood products. Optional and not recommended in all other cases.

Goal: To project the most probable amount of woody biomass harvesting, and utilization of that harvest to produce long-lived wood products, which is expected to occur under the baseline scenario.

Method: Use module TRS-2 Methods to Project Future Conditions, with wood harvest and utilization for long-lived wood products as the relevant variable X.

Task 2.1.9 Long-lived wood products

Goal: To project the amount of carbon which will be sequestered in long-lived wood products under the baseline scenario.

Method: Use module TRS-8 Estimation of Carbon Stocks in the Long Lived Wood Products Pool, with the outputs from Task 2.2.4. Estimation of the amount of current wood harvest from within the project area used for production of long-lived wood products and Task 2.2.5 Projection of future wood harvest outputs as the inputs.

Task 2.1.10 Estimation of current dead wood pools within the project area

Requirement: Required where there are significant amounts of dead wood in the project area at the project start date, and removals of dead wood through utilization, reduced inputs or accelerated burning as part of a management activity are expected to occur under the project scenario. Optional under all other circumstances.

Goal: To estimate the current amount of biomass contained in dead wood pools.

Method: Use module TRS-6 Estimation of Carbon Stocks in the Dead Wood Pool.

Task 2.1.11 Projection of future dead wood pools within the project area

Goal: To project the amount of biomass which will be contained in dead wood pools under the baseline scenario.

Method: Use module TRS-2 Methods to Project Future Conditions, with dead wood pools as the relevant variable X.

Task 2.1.12 Estimation of current average domesticated animal populations within the project area

Requirement: Required where GHG emissions from domesticated animal populations within the project area are expected to be significantly greater under the project scenario as compared with the baseline scenario at any time during the project crediting period. Optional under all other circumstances.

Goal: To estimate the average current population of domesticated animals within the project area.

Method: Use the module TRS-9 Estimation of Emissions from Domesticated Animals.

Task 2.1.13 Projection of future domesticated animal populations under the baseline scenario

Goal: To project the future populations of domesticated animals under the baseline scenario.

Method: Use module TRS-2 Methods to Project Future Conditions, with domesticated animal populations as the relevant variable X.

Comments: If at any time, within the project crediting period, the populations of domesticated animals under the baseline scenario are projected to be greater than those found at the project start date, populations at that time must be accounted as being equal to current levels. Conservatively, this methodology does not account for projected increases in animal populations and resulting emissions under the baseline scenario.

Task 2.1.14 Estimation of emissions of GHGs from domesticated animals within the project area under the baseline scenario

Goal: To estimate GHG emissions from current and projected future domesticated animal populations under the baseline scenario.

Method: Use module TRS-10 Estimation of Emissions from Domesticated Animals, with the outputs from Task 2.2.9. Estimation of current average domesticated animal populations within the project area and Task 2.2.10. Projection of : future domesticated animal populations under the baseline scenario as the inputs.

Task 2.1.15 Estimation of current soil emissions of N2O or CH4 from within the project area

Requirement: Required where emissions of N2O or CH4 from the soils within the project area are expected to be significantly greater under the project scenario as compared with the baseline scenario at any time within the project crediting period. Optional under all other circumstances.

Goal: To estimate the current emissions of N2O or CH4 from within the project area.

Method: Use module TRS-11 Emissions of Non-CO2 GHGs from Soils.

Task 2.1.16 Projection of future emissions of N2O or CH4 from the soils within the project area

Requirement: Required if, at any time within the project crediting period, the emissions of N2O or CH4 from the soils within the project area under the baseline scenario are projected to be greater than those found under the project scenario. Optional under all other circumstances.

Goal: To project future emissions from soils under the baseline scenario, in the case that these emissions are expected to decline.

Method: Use module TRS-2 Methods to Project Future Conditions, with relevant input variable(s) from the module TRS-11 Estimation of Emissions of Non CO2 GHG from Soils, as the relevant variable(s) X. Then, based on the outputs from this module, use the module TRS-11 Estimation of Emissions of Non-CO2 GHG from Soils to estimate the projected future emissions.

Task 2.1.17 Projected emissions from use of power equipment

Requirement: Required for all projects where emissions from power equipment directly attributable to activities within the project area are expected to be significantly greater under the project scenario as compared with the baseline scenario. Not to be used in all other circumstances. Conservatively, this methodology does not account for emission reductions arising from reductions in the use of power equipment under the project scenario as compared with the baseline scenario.

Goal: To project GHG emissions for the monitoring period from the use of power equipment under the baseline scenario. Note that in this methodology emissions of GHGs due to the use of power equipment directly attributable to activities within the project area are all accounted as baseline or project emissions, whether the actual emissions occur within the project area.

Method: Use module TRS-2 Methods to Project Future Conditions, with fuel uses in power equipment as the relevant variable(s) X. Then, based on the outputs from this module, use the module TRS-12 Estimation of Emissions from Power Equipment to estimate the projected future emissions.

Task 2.1.18 Estimation of current litter pools

Requirement: Required where significant decreases in litter pools within the project area are expected under the project scenario as compared with the baseline scenario at any time within the project crediting period. Optional under all other circumstances.

Goal: To estimate the carbon content of the litter pool within the project area.

Method: Use module TRS-5 Estimation of Carbon Stocks in the Litter Pool.

Task 2.1.19 Projection of future litter pools

Goal: To project emissions from future litter pools under the baseline scenario where these emissions are expected to decline under the baseline scenario.

Method: Use module TRS-2 Methods to Project Future Conditions, with relevant input variable(s) from the module TRS-5 Estimation of Carbon Stocks in the Litter Pool, as the relevant variable(s) X.

Comments: If, at any time in the project crediting period, the litter pools within the project area under the baseline scenario are projected to be less than those at the project start date, litter pools for that time must be accounted as being equal to levels at the project start date. Conservatively, this methodology does not account for projected decreases in litter pools under the baseline scenario.

Task 2.1.20 Summation of estimates and projections under the baseline scenario

Requirement: Required for all projects for which changes greater than 10% are expected in any non-soil carbon pool or other GHG emission, otherwise optional.

Goal: To sum current and future carbon sequestration and emissions under the baseline scenario.

Method: Use module: TRS-17 Methods to Determine the Net Change in Atmospheric GHG Resulting from Project Activities.

Task 2.2 Ex-ante Projections of Project Emissions from Non-soil Carbon Sources

These tasks relate to quantification of projected emissions from sources other than soil carbon during the project periods related to changes in biomass carbon pools, CH4, N2O, etc.

Task 2.2.1 Projection of future above-ground woody and non-woody and below-ground living biomass pools under the project scenario

Requirement: Required for all projects where significant decreases in living biomass pools are expected to occur under the project scenario, as compared with the baseline scenario. Optional in all other circumstances.

Goal: To project for the monitoring period the above-ground woody and non-woody biomass and below-ground living biomass pools in each stratum based on expected treatment regimes, and to estimate the amount of living biomass carbon per unit area based on those projections.

Method: Use module TRS-2 Methods to Project Future Conditions, with live biomass as the relevant variable X and the module TRS-4 Estimation of Carbon Stocks in Living Plant Biomass.

Task 2.2.2 Projection of future wood harvest outputs under the project scenario

Requirement: Required for all projects where the harvest of woody biomass within the project area is expected to be significantly lower under the project scenario as compared with the baseline scenario at any time within the project crediting period and some or all that woody biomass is used to produce long-lived wood products. Optional but recommended in the case that harvests of woody biomass under the project scenario are expected to be significantly greater than those under the baseline scenario. Optional, but not recommended, where no significant wood harvest takes place under either the baseline or project scenario, or where no significant change in levels of wood harvest are expected under the project scenario as compared with the baseline scenario.

Goal: To project for the monitoring period the amount of woody biomass harvesting which is expected to take place within the project area under the project scenario, and the percentage of that harvest which is expected to be used to produce long-lived wood products.

Method: Use module TRS-2 Methods to Project Future Conditions, with wood harvest and wood utilization as the relevant variable X.

Task 2.2.3 Projection of carbon sequestration in long-lived wood products

Requirement: Required for all projects where the harvest of woody biomass within the project area is expected to be significantly lower under the project scenario as compared with the baseline scenario at any time within the project crediting period and some or all that woody biomass is used to produce long lived wood products. Optional but recommended in the case that harvests of woody biomass under the project scenario are expected to be significantly greater than those under the baseline scenario. Optional, but not recommended, where no significant wood harvest takes place under either the baseline or project scenario, or where no significant change in levels of wood harvest are expected under the project scenario as compared with the baseline scenario.

Goal: To estimate the amount of carbon which will be sequestered in long-lived wood products under the project scenario, based on the projections prepared in Task 2.3.4 Projection of future wood harvest outputs under the project scenario.

Method: Use module TRS-8 Estimation of Carbon Stocks in the Long Lived Wood Products Pool, with the outputs from Task 2.3.2 Projection of future wood harvest outputs under the project scenario as the inputs.

Task 2.2.4 Projection of future dead wood pools within the project area under the project scenario

Requirement: Required where significant amounts of dead wood are found on the site at the project start date, and removals of dead wood through utilization, reduced inputs, or accelerated burning as part of management activity, are expected to occur under the project scenario. Optional in all other circumstances.

Goal: To estimate the amount of biomass which will be sequestered in dead wood pools under the project scenario.

Method: Use the module TRS-2 Methods to Project Future Conditions, with dead wood pools as the relevant variable X.

Task 2.2.5 Projection of future domesticated animal populations under the project scenario

Requirement: Required where increases in the emissions of GHGs from domesticated animal populations are expected under the project scenario as compared with the baseline scenario. Not to be used in all other circumstances. Conservatively, this methodology does not account for projected decreases in emissions from domesticated animals under the project scenario as compared with the baseline scenario.

Goal: To project the future populations of domesticated animals for the monitoring period under the project scenario.

Method: Use module TRS-2 Methods to Project Future Conditions, with domesticated animal populations as the relevant variable X.

Task 2.2.5 Estimation of emissions of GHGs from domesticated animals within the project area under the project scenario

Goal: To estimate the emissions of GHGs from the current and projected future populations of domesticated animals under the project scenario the monitoring period based on the projections prepared in Task 2.3.5. Projection of future domesticated animal populations under the project scenario.

Method: Use module TRS-9 Estimation of Emissions From Domesticated Animals, with the outputs from Task 2.3.5. Projection of future domesticated animal populations under the project scenario as the inputs.

Task 2.2.7 Projection of future emissions of N2O or CH4 from the soils within the project area

Requirement: Required where significant increases in the emissions of N2O or CH4 from the soils within the project area are expected under the project scenario as compared with the baseline scenario. Optional under all other circumstances.

Goal: To estimate future emissions from soils under the project scenario, in the case that these emissions are expected to increase.

Method: Use module TRS-2 Methods to Project Future Conditions, with relevant input variable(s) from the module TRS-11 Estimation of Emissions of Non CO2 GHG From Soils, as the relevant variable(s) X. Then, based on the outputs from this module, use the module TRS-11 Estimation of Emissions of Non CO2 GHG From Soils, to estimate the projected future emissions.

Task 2.2.8 Projected emissions from use of power equipment

Requirement: Required for all projects where emissions from power equipment directly attributable to activities within the project area are expected to be significantly greater under the project scenario as compared with the baseline scenario. Not for use in all other circumstances. Conservatively, this methodology does not account for emission reductions arising from reductions in the use of power equipment under the project scenario as compared with the baseline scenario.

Goal: To estimate GHG emissions for the monitoring period from the use of power equipment under the project scenario. Note that in this methodology emissions of GHGs due to the use of power equipment directly attributable to the project are all accounted for as project emissions, whether they occur within the project boundary.

Method: Use module TRS-2 Methods to Project Future Conditions, with fuel use in power equipment as the relevant variable(s) X. Then, based on the outputs from this module, use the module TRS-12 Estimation of Emissions from Power Equipment, to estimate the projected future emissions.

Task 2.2.9 Projection of future litter pools

Requirement: Required where significant decreases in the carbon content of the litter carbon pool are expected under the project scenario as compared with the baseline scenario. Optional under all other circumstances.

Goal: To estimate future litter pools under the project scenario.

Method: Use module TRS-2 Methods to Project Future Conditions, with litter carbon pools as the relevant variable X.

Task 2.2.10 Projection of biomass consumption by fire

Requirement: Required where significant burning is expected to be used for management of the project area under the project scenario. Optional but not recommended otherwise.

Goal: To project the future amounts of biomass consumed by fire during the project crediting period under the project scenario.

Method: Use module TRS-2 Methods to Project Future Conditions, with biomass consumed by fire as the relevant variable X.

Comments: This step shall be done twice if biomass burning is to be done both within the project area, and outside of the project area because of displacement leakage. In that case, the results will be used for separate calculations during Task 2.5.2. Projection of leakage due to displacement of wood harvesting.

Task 2.2.11 Projection of non CO2 emissions from burning

Requirement: Required where significant burning is expected to be used for management of the project area under the project scenario. Optional but not recommended otherwise.

Goal: To estimate emissions of non CO2 GHGs from burning of biomass.

Method: Use module TRS-11 Estimation of Emissions of Non CO2 GHG from Soils.

Comments: This step shall be done twice if biomass burning is done both within the project area, and outside of the project area because of activity shifting leakage. In that case, the results will be reported and accounted for separately during Task 2.3.12 Projection of biomass consumption by fire, above.

Task 2.2.12 Summation of ex-ante project scenario emissions from sources other than soil carbon (e.g., biomass carbon pools, CH4, N2O, etc.)

Requirement: Required for all projects. This will be zero for projects with no projected changes in emissions from sources other than soil carbon (e.g., biomass carbon pools, CH4, N2O, etc.). If non-zero, appropriate adjustment : must be made to interim crediting.

Goal: To sum current and future carbon sequestration and emissions under the project scenario.

Method: Use module TRS-17 Methods to Determine the Net Change in Atmospheric GHG Resulting from Project Activities, setting leakage variables to 0, as these will be accounted for in Task 2.6. Ex-post Quantification of Project Leakage.

Task 2.3 Ex-post Quantification of Project Emissions

Ex-post accounting of GHG pools and emissions must be undertaken prior to each verification event, and at least once every five (5) years during the project crediting period. Note that where leakage mitigation measures include tree planting, agricultural intensification, fertilization, fodder production, and/or other measures to enhance cropland and/or grazing land areas, then any significant increase in GHG emissions associated with these activities must be accounted for using the relevant module, whether or not they occur within the project area, unless they are deemed not significant, or can otherwise be conservatively excluded. To determine the ex-post quantification of GHG pools and emissions in the project area, the Project Proponent should use the following steps, as applicable:

Task 2.3.1 Estimation of the carbon content of current soil carbon pools per unit of area, for each stratum

Requirement: Required for all projects.

Goal: To sample the organic and inorganic soil carbon content in each stratum with a sampling intensity sufficient to allow estimation, at the required levels of statistical precision and accuracy, of the amount of soil carbon per unit area.

Method: Use module VMD0021 Estimation of Stocks in the Soil Carbon Pool.

Task 2.3.2 Estimation of the carbon content of above-ground woody and non-woody and below-ground living biomass pools

Requirement: Required for all projects where the above-ground woody and non-woody biomass and below-ground living biomass carbon under the project scenario is found to be significantly less than that projected under the baseline scenarios at any time after the project start date. Optional under all other circumstances. Typically, completion of this task will be required where the project area before the project start date contains more than scattered woody vegetation, and where the project activities include clearance, site preparation, burning, or other activities likely to eliminate woody vegetation, or alternatively to enhance the recruitment of woody vegetation.

Goal: To sample the above-ground woody and non-woody biomass and below-ground living biomass pools in each stratum to a sampling intensity sufficient to allow estimation to the required levels of statistical precision and accuracy of the amount of living biomass carbon per unit area.

Method: Use module TRS-4 Estimation of Carbon Stocks in Living Plant Biomass.

Task 2.3.3 Estimation of the amount of wood harvest from within the project area used to produce long-lived wood products

Requirement: Required for all projects where the harvest of woody biomass within the project area is expected to be significantly lower under the project scenario as compared with the baseline scenario at any time within the project crediting period, and some or all that woody biomass is used to produce long-lived wood products. Optional but recommended in the case that harvests of woody biomass under the project scenario are expected to be significantly greater than those under the baseline scenario. Optional but not recommended in the case where no significant wood harvest takes place under either the baseline or project scenario, or where no significant change in levels of wood harvest are expected under the project scenario, as compared with the baseline scenario.

Goal: To estimate the amount of woody biomass harvesting taking place within the project area during a monitoring period.

Method: Use module TRS-7 Estimation of Woody Biomass Harvesting and Utilization.

Task 2.3.4 Long-lived wood products

Requirement: Required for all projects where the harvest of woody biomass within the project area is expected to be significantly lower under the project scenario as compared with the baseline scenario at any time within the project crediting period, and some or all that woody biomass is used to produce long-lived wood products. Optional but recommended in the case that harvests of woody biomass under the project scenario are expected to be significantly greater than those under the baseline scenario. Optional but not recommended in the case where no significant wood harvest takes place under either the baseline or project scenario, or where no significant change in levels of wood harvest are expected under the project scenario, as compared with the baseline scenario.

Goal: To project the amount of carbon that will be sequestered in long-lived wood products derived from harvesting from within the project area during the monitoring period.

Method: Use module TRS-8 Estimation of Carbon Stocks in the Long Lived Wood Products Pool, with the outputs from Task 2.4.3. Estimation of the amount of wood harvest from within the project area used for the production of long-lived wood products as the inputs.

Task 2.3.5 Estimation of dead wood pools within the project area

Requirement: Required where dead wood is found on the site at the project start date, and significant removals of dead wood through utilization, reduced inputs, or accelerated burning as part of a management activity, are expected to occur under the project scenario. Optional under all other circumstances.

Goal: To estimate the current amount of biomass contained in dead wood pools.

Method: Use module TRS-6 Estimation of Carbon Stocks in the Dead Wood Pool.

Task 2.3.6 Estimation of average domesticated animal populations within the project area

Requirement: Required where increases in emissions from domesticated animals within the project area could occur in the project scenario as compared with the baseline scenario, due either to increases in populations or changes in feeding practices., Optional under all other circumstances.

Goal: To estimate the average current populations of domesticated animals within the project area during the monitoring period.

Method: Use module TRS-10 Estimation of Emissions from Domesticated Animals.

Task 2.3.7 Estimation of emissions of GHGs from domesticated animals within the project area

Requirement: Required where increases in emissions from domesticated animals within the project area could occur in the project scenario as compared with the baseline’s scenario, due either to increases in populations or changes in feeding practices. Not for use under all other circumstances, to conservatively ensure that crediting for reductions in emissions from domesticated animals does not occur.

Goal: To estimate the emissions of GHGs from the current populations of domesticated animals during the monitoring period.

Method: Use module TRS-10 Estimation of Emissions from Domesticated Animals, with the outputs from Task 2.4.6.Estimation of current average domesticated animal populations within the project area as inputs.

Task 2.3.8 Estimation of emissions from use of power equipment

Requirement: Required for all projects where emissions from power equipment directly attributable to activities within the project area could be significantly greater under the project scenario as compared with the baseline scenario. Not for use in all other circumstances. Conservatively, this methodology does not account for emission reductions arising from reductions in the use of power equipment under the project scenario as compared with the baseline scenario.

Goal: To estimate GHG emissions from the use of power equipment under the project scenario during the monitoring period.

Method: Use module TRS-12 Estimation of Emissions from Power Equipment.

Comments: Under this methodology emissions of GHGs due to the use of power equipment directly attributable to the project are all accounted as a project emission, whether they occur within the project boundary.

Task 2.3.9 Estimation of non CO2 emissions from burning

Requirement: Required where significant burning has been used for management of the project area under the project scenario. Optional but not recommended under all other circumstances.

Goal: To estimate emissions of non CO2 GHGs from burning of biomass.

Method: Use module TRS-13 Estimation of Emissions from Burning.

Comments: This step must be done twice if biomass burning is done both within the project area and outside of the project area because of displacement leakage. In that case, the results will be reported and accounted separately during Task 2.5.2. Projection of leakage due to displacement of wood harvesting and/or Task 2.6.2. Monitoring and estimation of emissions from wood harvest displacement.

Task 2.3.10 Monitoring and estimation of soil emissions of N2O or CH4 from within the project area

Goal: To estimate the emissions of N2O or CH4 from within the project area.

Method: Use module TRS-11 Estimation of Emissions of Non-CO2 GHG from Soils.

Comments: These estimations are expected to be based on the same models as those used during the ex-ante project study unless improvements in models have occurred in the interim. In either case, values of variables used in the models must be updated to reflect actual conditions which have occurred during the monitoring period. If an updated model is used, and if modeling of baseline emissions was done as part of the baseline study, that modeling must be redone using the improved models.

Task 2.3.11 Estimation of litter pools

Requirement: Required where significant decreases in the carbon content of the litter pool are expected under the project scenario as compared with the baseline scenario. Optional under all other circumstances.

Goal: To estimate the carbon content of the litter pool within the project area.

Method: Use module TRS-5 Estimation of Carbon Stocks in the Litter Pool.

Task 2.3.12 Summation of ex-post project emissions from sources other than soil carbon (e.g., biomass carbon pools, CH4, N2O, etc.)

Requirement: Required for all projects.

Goal: To sum carbon sequestration and emission impacts directly attributable to the project activity based on the monitoring undertaken during the monitoring period.

Method: Use module TRS-17 Methods to Determine the Net Change in Atmospheric GHG Resulting from Project Activities, setting leakage variables to 0.

Task 2.4 Ex-ante Projection of Leakage

If it is likely the project activities will lead to an increase in GHG emissions by more than 10% during the project period (see Table 1. Likelihood of project activities leading to an increase in GHG emissions during the project period above), the Project Proponent should use the following steps, as applicable.

Task 2.4.1 Projection of leakage due to displacement of grazing, fodder, and agricultural production

Requirement: Required for projects where domesticated animal grazing or fodder or agricultural production occurred within the project area at the project start date, and where these activities are projected to decline within the project area due to project activities.

Goal: To project future emissions from agricultural production, domesticated animals or fodder production displaced under the project scenario.

Method: Use module TRS-2 Methods to Project Future Conditions, with displacement of domesticated animals or agricultural production as the relevant variable(s) X. Then, based on the outputs from this module, use module TRS-14 Estimation of Emissions from Activity-Shifting Leakage, to estimate the impacts. Depending on the results from the module TRS-14 Estimation of Emissions from Activity-Shifting Leakage, calculations of emissions may require the use of other modules.

Task 2.4.2 Projection of leakage due to displacement of wood harvesting

Requirement: Required for projects where displacement of wood harvest to areas outside of the project boundary is projected to occur.

Goal: To project future emissions from wood harvest displaced under the project scenario. Projection includes the reductions in emissions from these displaced wood harvest activities where they are expected to result in the production of long-lived wood products.

Method: Use module TRS-2 Methods to Project Future Conditions, with displacement of wood harvest as the relevant variable(s) X. Then, based on the outputs from this module, use module TRS-14 Estimation of Emissions from Activity-Shifting Leakage, to estimate the impacts. Depending on the results from module TRS-14 Estimation of Emissions from Activity-Shifting Leakage, calculations of emissions may require the use of other modules.

Comments: Where wood harvesting occurs outside of the project boundary as a result of activity shifting leakage, and where that wood harvesting results in the production of long-lived wood products, module TRS-8 Estimation of Carbon Stocks in the Long Lived Wood Products Pool must be used to estimate the amounts of carbon stored in wood products resulting from the wood harvesting.

Task 2.4.3 Projection of market leakage

Requirement: Required for projects where reductions in the production of wood, animals or agricultural products within the project area are expected under the project scenario as compared with the baseline scenario, and where Task 2.5.1. Projection of leakage due to displacement of grazing, fodder, and agricultural production and Task 2.5.2. Projection of leakage due to displacement of wood harvesting do not find that direct displacement of these activities to identifiable areas outside the project area fully replaces the production lost within the project area.

Goal: To project leakage caused by increases in prices or demand for products resulting from reduced production of these products within the project area under the project scenario

Method: Use module TRS-15 Estimation of Emissions from Market Leakage.

Task 2.5 Ex-post Quantification of Project Leakage

Task 2.5.1 Monitoring and estimation of emissions from grazing, fodder, and agricultural production displacement

Requirement: Required for projects where domesticated animal grazing or fodder or agricultural production occurred within the project area at the project start date, and where these activities have declined within the project area due to project activities.

Goal: Estimation of emissions from domesticated animals or fodder production displaced because of project activities during the crediting period.

Method: Use module TRS-14 Estimation of Emissions from Activity-Shifting Leakage, to estimate the impacts. Depending on the results from the module, calculations of emissions may require the use of other modules.

Task 2.5.2 Monitoring and estimation of emissions from wood harvest displacement

Requirement: Required for projects where wood harvest occurred within the project area at the project start date, and where total wood harvest from the project area over the monitoring period will decline as compared with that projected under the baseline scenario.

Goal: Estimation of emissions from wood harvesting displaced because of project activities during the crediting period.

Method: Use module TRS-14 Estimation of Emissions from Activity-Shifting Leakage, to estimate the impacts. Depending on the results from the calculations of emissions may require the use of other modules. Where displaced wood harvesting results in the production of long-lived wood products, module TRS-8 Estimation of Carbon Stocks in the Long Lived Wood Products Pool, must also be used.

Task 2.5.3 Estimation of market leakage

Requirement: Required for projects where reductions in the production of wood, animals, or agricultural products within the project area have occurred under the project scenario, as compared with the baseline scenario, and where Task 2.6.1. Monitoring and estimation of emissions from grazing, fodder, and agricultural production displacement and Task 2.6.2. Monitoring and estimation of emissions from wood harvest displacement do not find that direct displacement of these activities to identifiable areas outside the project area fully replaces the production lost within the project area.

Goal: To estimate leakage caused by increases in prices or demand for products resulting from reduced production of these products within the project area under the project scenario.

Method: Use module TRS-15 Estimation of Emissions from Market Leakage.

Comments: If market leakage has been projected in Task 2.1 Quantification of Soil Carbon Stocks for Baseline and Project Scenarios and Task 2.2 Quantification of Baseline Emissions from Non-Soil Carbon Sources, and if the input conditions remain the same ex-post as those predicted ex-ante, the projections completed in Task 2.3.12 Summation of ex-ante project scenario emissions from sources other than soil carbon (e.g. biomass carbon pools, CH4, N2O, etc.) may be used to satisfy the requirements of this task.

Task 2.6 Monitoring

The Project Proponent must describe following TRS-16 Methods for Developing a Monitoring Plan under the guidance of the VCS Validation and Verification Manual, v3.2 how “the entire project longevity must be covered by management and financial plans that demonstrate the intention to continue the management practices.” The monitoring plan must also include annual proof of activity. For any Project Proponent executing Task 3 Interim Crediting Assessment (Optional), any sample handling or SOC results that might have been received in the interim period must also be documented.

Task 3 Interim Crediting Assessment (Optional)

The generation of high-quality data is the foundation of TRS SOC. This quality is ensured through soil sampling and analysis to one meter depth (or to refusal) with a measure-remeasure approach, from baseline (T0) to follow-up (T1) timepoints spanning the duration of project. To incentivize rancher, farmer, conservationist, and project developer participation, TRS SOC allows for optional methods to estimate annual SOC accrual between the baseline (T0) and subsequent true-up date (T1) measurements. This forward-looking assessment of interim carbon credits aims to provide pre-T1 revenue for farmers, ranchers, and other Land Stewards to overcome financial challenges to implementing improved agricultural management practices, and to incentivize the adoption of improved agricultural, conservation and restorative land management practices and enhance the quality of the carbon credits generated by TRS SOC.

Forward-looking assessments for interim crediting are not a replacement for direct measurement (and the measure-to-measure quantification) of SOC at the beginning and end of the project period. All forward-looking assessments for interim crediting are required to be substantiated by 1-meter deep (or to refusal), direct soil sampling to establish the baseline (T0) soil organic carbon with subsequent (T1) deep sampling collected within an average of five to seven years to true-up the project soil carbon sequestration.

Task 3.1 Projection of future soil carbon accrual rate for the project scenario

Requirement: Required for all projects applying for interim carbon credits.

Goal: To project the future soil organic carbon sequestration rate (“accrual rate”) per unit area for each projected verification date within the project crediting period under the project scenario.

Method: Use module TRS-2 Methods to Project Future Conditions

Comments: Table 1. Will have been used prior to affirm the key factors that drive change with the proposed activity change(s) by a project. The use of Table 1 (See Task 2) helps determine the prediction of variable change, degree of certainty for this prediction, and interrelations of variables resulting from the proposed activity. This information is further evaluated with a focus on soil carbon changes.

The module TRS-2 provides a step-by-step approach to assess the key factors that drive change in future soil organic carbon accrual rates and provides a suite of methods and approaches for projecting future conditions, as well as decision criteria for choosing the most appropriate method.

The following follows the application of module TRS-2 for the estimation of soil organic carbon accrual rates for the purpose of interim crediting, using as a particular example, a project involving regenerative grazing management practices:

Step 1, the variable to be projected is soil organic carbon sequestration (i.e., the SOC accrual rate) and the geographic area is the ranch project boundary.

Step 2, the accrual rate is to be projected under the project scenario.

Step 3, the accrual rate is location specific, because the rate depends on the variability of the weather conditions throughout the growing season and the underlying soil conditions across the location of the ranch. Additionally, the accrual rate is largely systemic, because changes in its value depend primarily on many factors outside of local control (e.g. weather), although other aspects determining the accrual rate may be considered planned (e.g. adaptive multi paddock grazing, low intensity rotational grazing, etc.) or controlled (e.g. reduce grazing intensity by 25%), depending on the particular project scenario.

Step 4, the accrual rate is considered intended, because it arises because of the project activities under the project scenario (e.g., increasing soil health and soil carbon through regenerative grazing management).

Step 5, the steps, or scenario that contribute to a future SOC accrual rate(s) include:

First – Primary Productivity: Weather conditions, including rainfall (by extension, soil moisture), temperature, solar radiation, and relative humidity, as well as soil nutrient availability, define the upper limit to potential rates of grassland primary productivity (i.e., biomass production) at a given location.

Second – Deposition: Plant organic matter because of primary productivity is deposited on or within the soil, from leaf and stem litter residue deposited on the soil surface to root litter and root exudates deposited as rhizodeposition in the root zone extending near the surface to the deepest rooting depths. Aboveground versus belowground allocation of carbon by plants is influenced by the relative aboveground and belowground environmental limitations to growth (e.g., greater allocation to belowground roots to acquire more water if soil moisture is most limiting).

Third – Decomposition: Plant residues are broken down and decomposed by soil fauna (dung beetles, earthworms, ants, etc.) and microorganisms (e.g. fungi and bacteria), with organic matter on or near the soil surface typically decomposing faster and more completely than organic matter deposited deeper in the soil profile as root litter, as conditions near the soil surface generally have greater oxygen concentrations, higher temperatures and the looser soil structure that provide a more conducive environment for decomposition. The rate of decomposition is primarily driven by temperature and soil moisture and by the chemical composition or decomposability of organic matter. Plant organic matter is broken down into particulate organic matter (plant organic matter at various stages of decomposition) and organic matter of microbial origin (e.g., microbial neuromas). Microbial efficiency for decomposition is determined by the soil environmental conditions during decomposition (e.g., soil temperature and moisture) as well as by the decomposability of the organic matter substrate, itself influenced by the soil environmental conditions during production (e.g., influencing the allocation to different stress-response compounds).

Fourth – Dispersal: Organic matter is physically dispersed throughout the soil profile, both vertically and laterally, from its sources near the soil surface or proximal to the rhizosphere of the roots, with a rate and efficiency of diffusion that is dictated by the availability of water in the soil.

Fifth – Stabilization: Finally, SOC can be stored in the soil as relatively unprotected particulate organic matter (POM) or as chemically-protected mineral associated organic matter (MAOM), as well as physically-protected organic matter within soil aggregates. MAOM increases with soil clay and silt content and is nearly exclusively microbial-derived (necromass) with fungi playing a dominant role, and both physical and chemical protection make the organic matter largely inaccessible to decomposition by microorganisms, with MAOM in a more stable form of soil organic carbon (SOC) that is more resistant to decay even after physical disturbance of the soil such as by tilling.

Step 6, Following the procedures of TRS-2 (see TRS-2 Section 5 - Procedures) for systemic, location specific variables, proceed to Step 7.

Step 7, the SOC accrual rate is not directly accessible through remote sensing.

Step 7a, collation and analysis of existing data indicate there is no historical record of SOC accrual rates in the analysis area, proceed to Step 13.

Step 13, lacking any existing or historical trajectory of change in SOC accrual rates, future values are modeled by considering the integration of multiple drivers, agents and causes on the accrual rate. This approach for forecasting accrual rates is data intensive, with the data necessary to determine casual relationships between accrual rates and the various drivers, agents and causes drawn from the best available peer reviewed scientific literature at the time of the project, with clear documentation of the methods and data, including the risks and uncertainties in the variables used to make the projection, to ensure conservative estimates.

Step 13d.1: Current conditions of driving variables drawn from published and/or reliable data sources (e.g., gridded precipitation and temperature, digital maps of soil clay and silt content, digital elevation models and topographic data, digital maps of soil thickness, pH, cation exchange capacity, etc.)

Step 13d.2: Correlate SOC accrual rates with driving variables based on the findings of published literature (e.g. increasing productivity with precipitation1, increasing microbial efficiency and SOC storage with precipitation2, increasing decomposition and decreasing SOC storage with precipitation3, increasing dispersal and SOC storage with precipitation4, increasing SOC storage with decreasing temperature5, increasing SOC storage with soil clay and silt content6, increasing SOC storage with soil thickness7, decreasing SOC storage with slope, increasing SOC storage with improved grazing management8, etc.).

1Del Grosso et al. 2008: Ecology, 89(8):2117-212; 2Anthony et al. 2020: One Earth, 2:349–360; 3Parton et al. 1993: Global Biogeochem Cycles, 7(4):785-809; 4Heckman et al. 2023: PNAS, 120(7):e2210044120; 5Hartley et al. 2021: Nature, 12:6713; 6Georgiou et al. 2022: Nature, 13:3797; 7Jobbagy and Jackson 2000, Ecol. Appl. 10(2):423–36, 8Conant et al. 2017, Ecological Applications, 27(2): 662–668.

Step 13d.3: Model potential SOC accrual rates based on the aforementioned correlations, e.g. using a pragmatic approach, with the potential SOC accrual rate estimated as the potential net primary productivity (gC/m2/yr) and adjustment factors representing the relative probability (with a value ranging from 0-1) of SOC storage based on the most limiting factor (e.g. Law of the Minimum8) among a multitude of potentially limiting factors (e.g. MAP, MAT, soil clay and silt content, topographic slope, soil thickness, pH, cation exchange capacity, rock fragment content, C3/C4 fraction, tree cover fraction, annual/perennial fraction, fungal/bacteria ratio, etc.). 8Lieth, H. 1972. Modeling the primary productivity of the world, 10 pp., Deciduous Forest Biome Memo Rep. 72-9, March 1972.

Step 13d.4: Review and re-parameterize the model if predictions are improbable or show discrepancies compared to actual conditions (e.g., adjust the maximum SOC accrual rate so estimates are consistent with literature values)

Step 13d.5: Project future SOC accrual rates using conservative estimates for model drivers or model projections (e.g., lower quartile of range for model predictions at a given location)

Step 13d.6: Create a time series to predict SOC accrual rates during the years of the project.

Task 4 Project Application Submission

A Project Proponent interacts with the Nature’s Registry to list pipeline projects, register projects, and issue carbon credits. Prior to these interactions, the Project Proponent must open an account and submit all required credentials to the Nature’s Registry to submit projects for pipeline listing, verification, and registration. The full scope of the required project documentation for each property, for the entire credit origination including Idea note if a preapplication discussion is to be the focus with the registry and verifier, or a Project design plan, measurement and monitoring plan, and the content of each document as required in the verification and registry checklists as needed for a project to submit for crediting considerations (See definitions, project activity, life, project registration, verification and validation, project verification period, etc.). , Once a proponent project registration occurs with the Registry, , the project application process can begin.

Figure 2 - Opening a Nature’s Registry account

Note that all Verifiers must also complete an account application and submit all required credentials to the Nature’s Registry prior to verifying carbon projects (See Verifier Prequalification requirements, in Appendix 2).

Approved Project Proponents must initiate the project application with the pipeline listing process by submitting to the Registry the following:

A Project Idea Note that includes at minimum a cover page and drafts of Task 1 Project Overview - Identification and Eligibility of Project Activity and related sub-tasks.
Proof of contract intent (such as a draft contract) or executed contract with an approved Verifier.

Listing a project on the Nature’s Registry project pipeline

Once the project is listed with the Registry, a Project Proponent can complete the project application by submitting all documentation within a Project Plan to the approved Verifier to execute Task 5. Verification. A complete project application includes the Project Plan with the results from Tasks 1-3 in TRS SOC V2.0 with accompanying documentation within appendices that may include the following:

Site maps
Contracts
Proof of Legal Ownership and County Appraisal District Tax Records
Lessee/Lessor agreements (Control of the Land-Type Contracts)
Stratification and Sampling Maps
Supporting documentation for land management activities (Land Steward Surveys, Communications, etc.)
Chain of custody documentation from soil analytics laboratory
References

Submitting a Project Plan for Verification

Task 5. Verification

Flexibility in crediting periods and the life span of the project is allowed for the reasons described in the introduction to TRS SOC V2.0. A comprehensive verification checklist requires that the verifier confirm that the carbon project developer accurately represents conditions during favorable and unfavorable years (e.g., “normal precipitation and growing conditions as compared to drought years, etc.) with a robust and defensible record of the conditions, the activities during each year and measurement data each year it is collected. The verification process ensures that complete and accurate land use/land management records documentation, data and computations, and representations on credit yields (carbon accounting) are accurate, robust, and defensible. During each crediting event, buffer pool requirements, and the computation of credit yield during each true-up and a discounting adjustment, with verification also requiring conservative approvals, is required so that neither overrepresentation nor selling of credits occurs.

Verification of a Carbon Credit Project under the TRS SOC V2.0 is performed by pre-approved, third-party verifiers utilizing the guidance and checklists in Appendix 1.0 Verification Guidance and Checklists which include technical, management practice, and procedural evaluation of compliance with the TRS SOC V2.0 requirements. Any Verifier with sufficient knowledge and experience to ensure technical review and verification of projects under TRS SOC V2.0 must submit a Verifier Application with Nature’s Registry. See Appendix 2 for qualification requirements.

For Project Proponents executing the optional Task 3, annual recertification (i.e. verification of SOC changes in years between T0 and T1), utilizing the guidance and checklists in Appendix 1.0 Verification Guidance and Checklists, shall include a review of monitoring/proof of activities and any sample handling or SOC results that might have been received in this interim period. Examples of such documentation may include:

Farm records from USDA and NRCS showing acreages and confirming practices. We acknowledge these will only be obtainable to a carbon project developer with a release from the land steward. Consequently, these records will be considered private and confidential, to respect private land stewards’ rights.
Independent on-the-ground practice confirmations.
Independent remote sensing practice confirmations.
Maps, acreages, and written explanations of any deviations from a Project Plan including soil amendments, compost, etc.
Financial, meteorological, marketplace, personal explanation of deviations from a Project Plan.
Land Steward affidavit of continuation in the Project and compliance with Best Practice principles for regenerative land stewardship as defined by literature and agreed upon by the Project Proponent and Land Steward.

Task 6. Registration

After a project has been verified, a Project Proponent may request registration and credit issuance by submitting relevant documents to Nature’s Registry. The Registry will conduct a completeness review of the documents and an assessment of conformance of the program rules checklist. Once compliance is confirmed, the Registry will upload the documents to the public registry and issue Verified Carbon Credits (VCCs *See definition) into the Project Proponent’s account. The public registry will make available to the public a summary of each project generating a credit issuance. Private landowner records, confidential data, contracts, and the reports that include these types of records will not become publicly available through the Registry. These records, however, will be available for internal and external auditors for the explicit purpose of quality assurance and control, and other auditor functions.

Citations

Many technical citations are included in the cited VM0021, and other materials incorporated by reference in The Regenerative Standard in V1.1. Version 1.2 of The Regenerative Standard as added the following additional citations.

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Apfelbaum, S.I, and A. Haney 2010 Restoring ecological health to your land. 240 pps. Island press, Covelo, CA.

Apfelbaum, S.I., F. Wang and R. Thompson, 2022 Soil Organic Carbon Changes under Low Disturbance Cropping in the Upper Columbia Plateau Region of Washington, Idaho, and Oregon, USA. Open Acc J Envi Soi Sci 6(3) - 2022. DOI: 10:32474/OAJESS.2022.06.000239.ISSN: 2641-6794. Pps 823-840.

Apfelbaum, S.I., Thompson, R., Wang, F., Mosier, S., Teague., R., Byck, P. 2022 Vegetation, water infiltration, and soil carbon response to multi-paddock and conventional grazing in Southeastern USA ranches. Journal of Environmental Management. 308:114576 DOI 10.1016/j.jenvman.2022.114576.

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Conant,R. T., C. E. P. Cerri, B. B. Osborne, K. Paustian2017, Grassland management impacts on soil carbon stocks: a new synthesis Ecological Applications, 27(2): 662–668.

https://doi.org/10.1002/eap.1473

Cotrufo, M. F. * and Jocelyn M. Lavallee 2022, Soil organic matter formation, persistence, and functioning: A synthesis of current understanding to inform its conservation and regeneration. Chapter 1. Advances in Agronomy, Volume 172 Copyright # 2022 Elsevier Inc. ISSN 0065-2113 All rights reserved. https://doi.org/10.1016/bs.agron.2021.11.002

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Del Grosso et al. 2008: Global potential net primary production predicted from vegetation class, precipitation, and temperature, Ecology, 89(8):2117-212. DOI:10.1890/07-0850.1

Dobert, T. F., E. D. Bork, S. Apfelbaum, C.N. Carlyle, S. X. chang, U, Khatri-Chhetri, L. S. Sobrinho and R. Thompson, 2021, Adaptive multi-paddock grazing improves water infiltration in Canadian grassland soils. http://doi.org/10.1016.k.geoderma.2021.115314.

Eagle, A.J., L. R Henry, L. Olander, K. Haugen-Kozyra, N. Millar, and G. Philip Robertson 2011, Greenhouse Gas Mitigation Potential of Agricultural Land Management in the United States-A synthesis of the literature. 68 pps. Nicholas Institute, Duke University, Durham, NC. https://lter.kbs.msu.edu/docs/robertson/eagle+et+al.+2011+nicholas+inst.pdf

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Folley, J.A., DeFries, R., Asner, G. P. et al 2005 Global consequences of land use. Science. 309:(5734) 570-574.

Georgiou, K., R. B. Jackson, O. Vindušková, R. Z. Abramoff, A. Ahlström, W. Feng,J. W. Harden, A. F. A. Pellegrini, H. W. Polley,J. L. Soong, W.J. Riley & M. S. Torn 2022: Emergent temperature sensitivity of soil organic carbon driven by mineral associations. Nature, 13:3797

Hartley, I. P., T.C. Hill, S. F. Chadburn, and C. Hugelius 2021 Temperature effects on carbon storage are controlled by soil stabilization capacities. : Nature, 12:6713

Heckman et al. 2023 Moisture-driven divergence in mineral-associated soil carbon persistence

PNAS, 120(7):e2210044120, https://doi.org/10.1073/pnas.2210044120

ICF International, 2013 Greenhouse gas mitigation options and costs for agricultural land and animal production within the United States. For USDA Climate Change Program Office, techguide@oce.usda.gov; https://www.usda.gov/sites/default/files/documents/GHG_Mitigation_Options.pdf

ISO 1406-https://www.iso.org/obp/ui/#iso:std:iso:14064:-2:ed-1:v1:en

Jobbágy, E.G. and Jackson, R.B. (2000) The Vertical Distribution of Soil Organic Carbon and Its Relation to Climate and Vegetation. Ecological Applications, 10, 423-436.
http://dx.doi.org/10.1890/1051-0761(2000)010[0423:TVDOSO]2.0.CO;2

Johnson, DC, Teague, R, Apfelbaum, S, Thompson, R, Byck, P. 2022 Adaptive multi-paddock grazing management’s influence on soil food web structure for: increasing forage production, soil organic carbon, abnd reducing soil respiration rates in southeastern USA ranches. 10:e13750 htt://doi.org/10.7712/peerj.13750

Kimble, J. M., C.W. Rice, D. Reed, S. Mooney, R.F. Follett, R. Lal 2007 Soil Carbon Management-Economic, Environmental and Societal Benefits. 268 pps. CRC press, Boca Raton, FL.

Lavallee JM, Soong JL, Cotrufo MF. 2019 Conceptualizing soil organic matter into particulate and mineral‐associated forms to address global change in the 21stcentury. Glob Change Biol. 2020; 26:261–273. https ://doi.org/10.1111/gcb.14859

Monger, H.C. 2014 Soils as generators and sinks of inorganic carbon in geological time. Chapter 3, pps. 27-38. In Soil Carbon: Progress in Soil Science. (Editors, A.E. Hartemink and K. McSweeny) DOI 10.007/978-3-319-04084-4.3. Springer International, Switzerland.

Mosier, S. S. Apfelbaum, P. Byck, F. Calderon, R. Teague, R. Thompson, M. F. Cotrufo 2021. Adaptive multi-paddock grazing enhances soil carbon and nitrogen stocks and stabilization through mineral association in southeastern U.S. grazing lands, Journal of Environmental Management p. 288 (2021) 112409.

Paul, E.A. K. Paustian, E.T. Elliott, and C.V. Cole 1997, Soil Organic Matter in Temperate Agroecosystems-Long Term experiments in North American. 414 pps. CRC press, Boca Raton, FL.

Parton, W. J., J. M. O. Scurlock, D. S. Ojima, T. G. Gilmanov, R. J. Scholes, D. S. Schimel, T. Kirchner, J-C. Menaut, T. Seastedt, E. G. Moya, A. Kamnalrut, J. I. Kinyamario. 1993 Observations and modeling of biomass and soil organic matter dynamics for the grassland biome worldwide Global Biogeochem Cycles, 7(4):785-809. https://doi.org/10.1029/93GB02042

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Sanderson, J.S., C. Beautler, J.R. Brown, I. Burke, T. Chapman, T.T. Conant, J.D. Derner, M. Easter, S.D. Fuhlendorf, G. Grissom, J.E. Herrick, D. Liptzin, J.A. Morgan, R. Morph, C. Pague, I. Rangwala, D. Ray, R. Rondeau, T. Schulze and T .Sullivan. 2020 Cattle, conservation and carbon in western great plains. Jo of Soil and Water conservation, Vol75(1): 5A-12A. DOI:10.2489/HSWC.75.1.5A.

Teague, W. R., S. Apfelbaum, R. Lal, U.P. Kreuter, J. Rowntree, C.A. Davies, R. Conser, M. Rasmussen, J. Hatfield, T. Wang, F. Wang, and P. Byck. 2016. The role of ruminants in reducing agriculture’s carbon footprint in North America. March/April 2016, Journal of Soil and Water Conservation, 71(2):156-164, www.swcs.org.

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Appendix 1.0 Verification Guidance and Checklists

This guide provides instructions for the verification of carbon projects for Project Proponents and Verifiers to follow. The guide and checklist are to be followed by verifiers to efficiently conduct and document their verification process. In short, verification is intended to be a streamlined, rapid, and defensible process that:

Allows Verifiers, Project Proponents, approving bodies, and credit purchasers to understand projects, representations, and claims by the Project Proponents.
Provides a clear decision pathway for all parties to understand conclusions.
Provides a structure for efficient internal and external auditing of projects, programs, and accounts.

The verification process conclusions can be approvals and concurrence with the claims and representations by a Project Proponent. If the Project Proponent has provided an incomplete application, the verifier may request more information, clarifications, or the recognition of a fundamental problem that would not support a determination about application completeness, or support the claims and representations suggested by the Project Proponent. This verification process is intended to create a clear record to support resubmittal and completion of a review, and to encourage clear, open, and transparent communications by the Verifier, and others involved. Completeness requires proof of contract between the carbon project developer and the land steward(s) in each carbon project.

Fundamental to TRS SOC V2.0 and its verification process, must be the recognition that the proof is always in comparing forward assessments for optional interim crediting with actual baseline (T0) and follow-up measurements (T1, T2, etc.). TRS SOC V2.0 can use modeled or literature review projections early, but only measured performance is used for truing the actual credit yield by a Project. This means that representations in a project plan document only have material value when the baseline and subsequent follow-up measurements document performance.

This verification guidance is focused on using a checklist process. TRS SOC V2.0 Checklist Templates streamline the review process to ensure that all procedures are evaluated, and all TRS SOC requirements are met for each year (T0, T1, etc. and, if applying for interim credits, the years between T0, T1, etc.).

Using TRS SOC V2.0 Verification Report Template, the Verifier is expected to generate a report that summarizes whether the claims and representations suggested by the Project Proponent are certifiable to accompany the TRS SOC V2.0 Checklist Templates. If an application is deemed incomplete or if the checklist items do not meet the test of sufficiency, a Verifier should provide a follow-up attachment of no more than one-page in length that identifies deficiencies, discrepancies, and additional information needs.

It is the intention of The Regenerative Standard to maintain a vigilance to ensure verifiers and verification is completely independent of carbon project developers through execution of conflict of interest affidavits, and by updating disclosures, prequalification submittal applications, and also through external and internal audits. The open access requirements of The Regenerative Standard, data submittal requirements, including laboratory quality assurance and quality control execution programs, and the carbon program developer split samples and blind sampling submittal requirements ensure contribute to ensure quality, authenticity, and accuracy. The independent organization, agency, and standardized checklist of procedures of the Nature’s Registry provides yet another control over quality, accuracy, and robustness over the program.

Appendix 2.0 Validation and Verification Body (VVB) Prequalification

Validation and Verification Bodies (VVB’s) must be prequalified. Only qualified professionals/organizations who meet and demonstrate bonified educational and on-the-job field experience as verification and validation service providers for soil carbon crediting projects will be considered to be a qualified VVB by Nature’s Registry-the only registry currently issuing credits under The Regenerative Standard SOC V1.1, V1.2 and V2.0.

VVB’s are also required to submit proof of liability insurance (min $1M/instance) and, once engaged on a project, provide a copy of the service contract with the carbon project developer registering the project on Nature’s Registry.

VVB Service Provider Requirements

Projects intending to issue credits through Nature’s Registry require independent, third-party validation and verification by a prequalified VVB. This VVB provides independent verification and validation services to project developers confirming that the developer has accurately adhered to one of the registry protocols.

The VVB must represent and warrant the accuracy of the validation and verification process and reporting and provide true, accurate, and complete verification reports that have been independently arrived at by the VVB, as of the date of their signed attestation on a verification report.

There is no reciprocity for VVBs approved by other standards or registries at this time is granted without a service provider have received authorized prequalification to provide services for soil carbon crediting projects registered with The Regenerative Standard and Nature’s Registry.

Verification and validation service providers must sign a conflict of interest attestation guaranteeing there to be no financial interest in the project. A standard COI form must be signed by service providers and carbon project developers that acknowledges that service providers have not helped design, measurement or reporting, or project design document development, and have no influence on a carbon developers project or subsequent involvement and is only providing objective scientific peer review process, and a summary of findings services.

Final Accreditation Requirement for Verification, Validation Service Providers:

Within a period of 1 year of having completed the first verification or validation services under The Regenerative Standard or Nature Registry, a service provider must provide an additional proof of accreditation by: American National Standards Institute (ANSI), or International Accreditation Forum (IAF). This is in addition to the mandatory eligibility requirements of meeting professional, technical educational and experience requirements above, or an equivalent recognized accreditation, certification, and history.

Appendix 3.0 Guidance on Potential Emerging Technologies Being Tested to Monitor and Measure Grazing Land Use Changes, and SOC Stocks

Projects may use emerging technologies to determine SOC content if sufficient scientific progress has been achieved in calibrating and validating measurement, and uncertainty is well-documented. This appendix summarizes a non-exhaustive list of potential emerging technologies (with a focus on remote sensing) to for example, monitor livestock grazing activities, explore the creation of proxy indicators that may be predictive of soil organic carbon changes. Any emerging technologies must be tested against reliable standard practices to ensure their robustness and reliability. This list of technologies may be updated to newer versions of the TRS SOC.

The applicability of a selected technology to measure SOC in a project must be demonstrated in several peer-reviewed scientific articles. Project Proponents should provide evidence of the ability of any emerging technologies to predict SOC content with sufficient accuracy through the development and application of adequate calibration with data obtained from classical laboratory methods, such as dry combustion. The site characteristics for the underlying calibration must match the project site conditions, including a range of SOC stocks, soil types, land use, etc. While projects may use the services of companies measuring SOC, the specificities of the applied measurement technology, including calibration methods, must be made available for review by a VVB. They must not have restricted access to intellectual property rights.

Table A.2 below presents potential emerging proximal sensing technologies that research and publications have deemed promising for streamlining SOC measurement. Although proximal sensing techniques may not be as precise per individual measurement compared to conventional analytical laboratory methods, e.g., dry combustion, proximal sensing may be more cost-efficient and provide a better balance between accuracy and cost. Hence, although each individual measurement may be less accurate, many more measurements can be made across time and space than would be feasible with conventional methods, enabling an overall estimate of carbon stock that is of similar or better accuracy than lower-density sampling that is measured with conventional analytical laboratory methods. Since many more proximal devices may be used in a project than would be used if all samples were sent to a single lab, care must be taken to demonstrate device-to-device calibration and precision.

Project Proponents must provide details to the VVB on the criteria and considerations of the emerging SOC measurement technology as specified in Table A.2. Projects should maintain adherence to these criteria over time to ensure that measurement and re-measurement are conducted under the same conditions and are thus comparable. While the focus is on proximal sensing, the Regenerative Standard is tracking developments related to remote (e.g., satellite) sensing of SOC stocks. Future revisions to this appendix may include guidance on using remote sensing for direct SOC measurement if that technology is demonstrated as scientifically credible.

The following scientific publications provide more details and further guidance on the application of the above-listed technologies to measure SOC:

INS

Izaurralde, R. C. et al. (2013) ‘Evaluation of Three Field-Based Methods for Quantifying Soil Carbon’, PLOS ONE, 8(1), p. e55560. doi: 10.1371/journal.pone.0055560.

Kavetskiy, A. et al. (2017) ‘Neutron-Stimulated Gamma Ray Analysis of Soil’, in New Insights on Gamma Rays. Intech Open. Available at: https://www.intechopen.com/books/new-insights-on-gammarays/neutron-stimulated-gamma-ray-analysis-of-soil.

Yakubova, G. et al. (2019) ‘Application of Neutron-Gamma Analysis for Determining Compost C/N Ratio’, Compost Science & Utilization, 27(3), pp. 146–160. doi: 10.1080/1065657X.2019.1630339.

LIBS

Costa, V. C. et al. (2020) ‘Calibration Strategies Applied to Laser-Induced Breakdown Spectroscopy: A Critical Review of Advances and Challenges’, 31(12). doi: https://doi.org/10.21577/0103-5053.20200175.

Fernandes Andrade, D., Pereira-Filho, E. R. and Amara Siriwardena, D. (2021) ‘Current trends in laser induced breakdown spectroscopy: a tutorial review’, Applied Spectroscopy Reviews, 56(2), pp. 98–114. doi: 10.1080/05704928.2020.1739063.

Senesi, G. S. and Senesi, N. (2016) ‘Laser-induced breakdown spectroscopy (LIBS) to measure quantitatively soil carbon with emphasis on soil organic carbon. A review,’ Analytica Chimica Acta, 938, pp. 7–17. doi: 10.1016/j.aca.2016.07.039.

MIR and (Vis-)NIR, incl. DR and DRIFT spectroscopy

Barthès, B. G. and Chotte, J.-L. (2021) ‘Infrared spectroscopy approaches support soil organic carbon estimations to evaluate land degradation’, Land Degradation & Development, 32(1), pp. 310–322. doi: 10.1002/ldr.3718.

Dangal, Shree R.S., Jonathan Sanderman, Skye Wills, and Leonardo Ramirez-Lopez. 2019. "Accurate and Precise Prediction of Soil Properties from a Large Mid-Infrared Spectral Library" Soil Systems 3, no. 1: 11. https://doi.org/10.3390/soilsystems3010011

England, J. R. and Viscarra Rossel, R. A. (2018) ‘Proximal sensing for soil carbon accounting’, SOIL, 4(2), pp. 101–122. doi: 10.5194/soil-4-101-2018.

Ng, W., Minasny, B., Jones, E. and McBratney, A. (2022) ‘To spike or to localize? Strategies to improve the prediction of local soil properties using regional spectral library,’ Geoderma, 406, https://doi.org/10.1016/j.geoderma.2021.115501

Nocita, M. et al. (2015) ‘Chapter Four - Soil Spectroscopy: An Alternative to Wet Chemistry for Soil Monitoring’, in Sparks, D. L. (ed.) Advances in Agronomy. Academic Press, pp. 139–159. doi: 10.1016/bs.agron.2015.02.002.

Reeves, J. B. (2010) ‘Near- versus mid-infrared diffuse reflectance spectroscopy for soil analysis emphasizing carbon and laboratory versus on-site analysis: Where are we and what needs to be done?’, Geoderma, 158(1), pp. 3–14. doi: 10.1016/j.geoderma.2009.04.005.

Sanderman J, Savage K, Dangal SRS. Mid-infrared spectroscopy for prediction of soil health indicators in the United States. Soil Sci.Soc. Am. J. 2020;84:251–261.https://doi.org/10.1002/saj2.20009

Seybold, C.A., et al., ‘Application of Mid-Infrared Spectroscopy in Soil Survey,’ Soil Sci.Soc. Am. J. 2019; 83: 1746-1759. https://doi.org/10.2136/sssaj2019.06.0205

Stevens, A. et al. (2013) ‘Prediction of Soil Organic Carbon at the European Scale by Visible and Near InfraRed Reflectance Spectroscopy’, PLOS ONE, 8(6), p. e66409. doi: 10.1371/journal.pone.0066409.

Viscarra Rossel, R. A. et al. (2016) ‘A global spectral library to characterize the world’s soil’, EarthScience Reviews, 155, pp. 198–230. doi: 10.1016/j.earscirev.2016.01.012.

Viscarra Rossel, R. A. and Webster, R. (2012) ‘Predicting soil properties from the Australian soil visible– near-infrared spectroscopic database’, European Journal of Soil Science, 63(6), pp. 848–860. doi: 10.1111/j.1365-2389.2012.01495. x.

Appendix 4.0 The Regenerative Standard SOC Methodologies

Appendix 5.0 Verra VM0021

Appendix 6.0 The Regenerative Standard History

Summary and Timeline

2010 – Earth Partners LLC, a wholly owned subsidiary of Applied Ecological Services (AES) was started by Steve Apfelbaum (AES), Will Raap, and Charlie Kireker with a mission to widely educate the public on the benefits of restoring soil health and soil carbon

2011 – Earth Partners LP (partnership between AES and Brinkman & Associates Reforestation) formed to bring further investment to the mission and writing begins on the Soil Carbon Quantification Method

2012 – Earth Partners LLC enter approval process with the Verified Carbon Standard (VCS), now Verra, and method is approved as VM0021 with all copyright / IP remaining with The Earth Partners LP. Here is the Verra page that shows that VM0021 was developed (and is copyrighted) by The Earth Partners.

Dec 2012 - Earth Partners LP and Earth Partners LLC part ways and Earth Partners LLC retains all for Soil Carbon Quantification Method / VM0021

Feb 2021 Resource Environmental Solutions (RES) purchases AES and Steve Apfelbaum retains the IP for VM0021.

March 2022 Verra inactivates VM0021

Sept 2022 Applied Ecological Institute, with science partners, updates VM0021 into a new protocol called ‘The Regenerative Standard SOC Module V1.0’ referring to many of the time-tested modules still available online for reference by project developers and VVBs.

Dec 2022 – The first SOC credits under The Regenerative Standard SOC V1.0 are verified and issued by Nature’s Registry.

May 2023 – The most recent version of The Regenerative Standard SOCV1.1 is released.

May 2024-October 2024 – AEI, in partnership with Regen Network, successfully completed a peer review process. You can see those comments and subsequent revisions (V1.2) here.

October 2024 - AEI submits TRS SOC V2.0 with Nature’s Registry to ICVCM for review.

October 2024 - AEI, in partnership with Regen Network opens V2.0 for public comment.

AEI is committed to continually improving the protocol maintaining the original vision set out by The Earth Partners LLC. The full story follows below.

Background--Origins and Lineage of The Regenerative Standard

Early Realizations

A University of VT Gund Institute five-year, intersession, collaboratively taught course in Costa Rica on entrepreneurism and wetland mitigation brought together Will Raap, Steve Apfelbaum, John Todd and Robert Costanza with several dozen students annually at a remote Guanacaste province coastal community. Among many discussions, the debate was fiercest about whether the focus of climate mitigation should be on planting more trees or rebuilding soil health on earth. Will consistently brought us to the conclusion that focusing on afforestation and reforesting missed a key opportunity on earth, soil health. We decided at that moment that we both wanted to leverage more interest in improving soil health on earth using photosynthesis and soil microbial life to rebuild soil system health worldwide.

Commitments to bring Soil Carbon understandings to the Fore.

The Earth Partners, LLC began with a focus on achieving a wider, more accurate understanding of soil carbon. Steve Apfelbaum led the writing about this need including grant proposals to secure funding to accelerate the conversation. Early efforts started with a meeting with USDA, NRCS and learned of a grant proposal opportunity to fund addressing the key data gaps.

During this time, Will brought other potential investor partners to the table while Steve connected with soil health and soil carbon academics and researchers. On their return to the states, Charley Kireker of Fresh Tracks Capital quickly joined the effort. Word spread and we discovered great interest in helping in the education and increased awareness needed.

The group organized several strategic planning meetings with diverse stakeholders to discuss science gaps, marketplace gaps, and widespread misunderstandings about soil health and soil carbon, and the role they could play in climate mitigation and fostering a regenerative agricultural future. This process revealed a wealth of standardized scientific measurement methods and metrics but the information was siloed and scattered and none focused on how to structure an incentive system that encouraged activity changes and monitoring measure to measure improvements over time. We decided that the modeling was too early, too speculative and would not create a trustable, transparent, robust, and defensible method around which consensus could be achieved among disparate counterparties, environmentalists, industry groups, farmers, and the federal trade commission, among others.

We also learned that there was a fundamental misunderstanding and mythology about soil carbon and soil health. In an effort to bring clarity and scientific rigor, Steve’s company at the time, Applied Ecological Services, Inc. (AES), became involved with a consortium of eighteen research institutions who were working with soil carbon in agricultural (primarily cropped) landscapes. AES and The Earth Partners also became involved with researchers studying soil carbon in peatlands, non-peat wetlands, and in rangelands across the world. Over a year of conversations, site visits, and documenting science conclusions, data gaps and mythology (that lived as an undercurrent with both academics and laypersons) we decided creating a standard method for measurement, referencing the most rigorous science at the time was necessary. Over the course of six months we designed the “Soil Carbon Quantification Method.” Steve focused on the soil carbon and the Robert Seaton of the Brinkman Group focused on forest carbon. A circulated draft of the method was reviewed multiple times by a distinguished team of soil carbon specialists with requisite refinements completed by The Earth Partners.

Evaluating the Soil Carbon Quantification Method

Top soil carbon scientists in the USA, Costa Rica, Chile, and Brazil began testing The Soil Carbon Quantification Method in the highest quality natural areas and working forest and agricultural lands. We collaborated on testing the method with the World Resources Institute and The Nature Conservancy as part of an effort to discover climate mitigation benefits on 6000-acre cropland to prairie restoration in Indiana. All tests affirmed the need for measurements as the existing models were 1-2 orders of magnitude in error of the carbon stocks measured in the field.

With the field assistance of Dr John Kimble (ARS, USDA soil scientist) we worked with Dr Dan Janzen (Dry tropical Savanna Foundation) and Alvaro Ugalde (Director of CR Park Service) to sample soil carbon in several national parks and the dry tropical savanna foundation lands. Working with Doug and Kris Tompkins and Fundacion Patagonica, we sampled reference natural areas in Valle Chaka Buko in Patagonia Chile and Rincon del Socorro (in Northern Argentina). We continued to revise the method after a year of field testing, sampling and findings.

In 2011 AES submitted a USDA NRCS Conservation Innovation Grant proposal focused on landscape scale sampling of soil carbon stocks over the Palouse agro-ecosystem in eastern Washington State, northern Idaho, and southeastern Oregon. The purpose of the study was to evaluate and refine the method for large scale market-making possibilities with the regenerative producers of Sheperd’s Grain. The landscape biophysical stratification process was developed and field tested by soil scientists Dr David Hammer and Dr Thomas Hunt, landscape ecologist S. Apfelbaum and field operation specialists from AES focused on cost effective, safe and accurate measurement of carbon stock improvements. AES, and then with subsequent partner Native Energy, engaged the farmers in carbon improvement contracts and all worked together to value and attempt to monetize the measured improvements. This program robustly measured soil carbon using chrono series analysis and parallel repeated sampling over a decade. Predicted significant and reliable improvements in soil carbon by the chrono series analysis and resampling showed a reliable 2 TCo2e/acre-yr accrual rate over this large landscape on farms using “Low Disturbance Farming” practices which involve >80% crop residue retainage and <20% soil disruption from trash rakes on no-till and one pass no-till. The improvements at a meter depth were significant 1.

While working on the Palouse project, our collaboration with the best soil carbon scientists in the world, revealed the need for a publication to support and inform industry and politicians on potential climate policy; specifically on the role of healthy soils and soil carbon improvements connection to climate mitigation. This collaboration resulted in the book Soil Carbon Management – Economic, Environmental and Societal Benefits, published by CRC press in 2007. While writing the book, we shared data from the projects and received informal and formal technical peer reviews from thirty-five of the top scientists and early evolving climate mitigation market experts. This peer review, which included multiple US academics and recognized experts in the UK and across the world, refined the science and informed the final revision of the method which we submitted to VCS formal review and validation.

Commercializing The Soil Carbon Quantification Method

In 2012, the Earth Partners submitted the method for approved use under the newly developed Verified Carbon Standard (VCS), now Verra. From the original philosophy and subsequent scientific findings, we also wrote the requisite front-end modules, eligibility sections, additionality sections, etc. and successfully navigated the technical and marketplace peer review process. After a year, we emerged from the required double technical peer review/validation process, and the method was approved as VM0021.

Soon after the approval, The Earth Partners LP and Earth Partners LLC parted ways due to a shift in focus by The Earth Partners LP. AES/The Earth Partners LLC retained copyright and all IP and expanded the focus to address quantifying soil carbon and climate health. AES/The Earth Partners LLC worked on tens of millions of acres using VM0021 and learned many things including: sampling costs become de minimus when working at landscape scale and repeated sampling could accurately document statistically significant improvements in Total Carbon and Soil Organic Carbon within a few years in productive landscapes with appropriate practices and slightly more time in arid and less productive lands. We learned that grazing and improved farming practice changes, land restoration, and mined land reclamation could produce reliable improvements.

Working with the Shell Oil GameChanger program, Russ Conser at Shell, grazing specialist Dr Richard Teague at Texas A & M, film producer Peter Byck at ASU and a diverse research team including scientists from AES, deployed Verra VM0021 on a Shell Canada study and a Southeastern US study of soil carbon change under improved grazing practices. The findings of the SE study became the focus of the Carbon Nation Series’: Carbon Cowboys,” and “Roots so Deep” which have gained global attention and catapulted proponents of improved grazing (e.g., Dr Allen Williams, Gabe Brown of Understanding Agriculture) in front of the increasing interest by farmers and ranchers. Our study findings were enlightening, especially the soil carbon findings and this drew attention and allowed us to present our findings to many groups, agencies, and Obama’s Office of Science and Technology Team.

Many publications highlighted the rigor of VM0021: Carbon Management: Quantifying carbon for agricultural soil management, EDF: Agricultural Soil Carbon Credits: Making sense of protocols for carbon sequestration and net greenhouse gas removals., but no credits were generated as many developers gravitated towards less rigorous protocols that did not have the same sampling requirements. In 2019 AES was approached by an organization with aspirations to deliver soil carbon crediting opportunities to the farming community at large scales. In the end, this group chose to focus on modeling with reduced and minimal sampling that would not meet the requirements of Verra VM0021. A new protocol Verra VM0042, which does not require as robust sampling requirements, became Verra’s primary soil carbon quantification protocol and VM0021 was deactivated in March 2022.

Responding to demand signals from offset buyers wanting (and willing to pay more for) more scientifically robust soil organic carbon credits, Applied Ecological Institute, founded by Steve Apfelbaum, updated VM0021 as part of a new suite of open access protocols called The Regenerative Standard (The Standard). The mission is to provide rigorous, straight-forward protocols for nature-based solutions and accelerate nature-positive climate action at scale. Following nature’s example of an integrated systems approach, The Standard contains three separate protocols: Soil Organic Carbon (SOC), Biodiversity and Water that are purpose built to work synergistically to improve degraded ecosystems. SOCV1.1 was the first to be deployed and carbon project developers have, thus far, implemented this protocol to generate carbon credits on roughly 600,000 acres to date. Pricing for the offtakes is not public, but the project developers report higher than average pricing for the high-quality credits.

The Regenerative Standard will be continuously reviewed and improved.

Steven I. Apfelbaum*, Fugui Wang and Ry Thompson, Soil Organic Carbon Changes under Low Disturbance Cropping in the Upper Columbia Plateau Region of Washington, Idaho, and Oregon, USA. Open Acc J Envi Soi Sci 6(3) - 2022. OAJESS.MS.ID.000239. DOI: 10.32474/OAJESS.2022.06.000239

Appendix 7.0 Verra/TRS Links

VM0026 Methodology for Sustainable Grassland Management (SGM), v1.1

VM0042 Methodology for Improved Agricultural Land Management, v2.0

TRS-1 Methods to Determine Stratification, v1.0

TRS-2 Methods to Project Future Conditions, v1.0

TRS-3 Methods to Determine the Project Boundary, v1.0

VMD0021** Estimation of Stocks in the Soil Carbon Pool, v1.0

TRS-4 Estimation of Carbon Stocks in Living Plant Biomass, v1.0

TRS-5 Estimation of Carbon Stocks in the Litter Pool, v1.0

TRS-6 Estimation of Carbon Stocks in the Dead Wood Pool, v1.0

TRS-7 Estimation of Woody Biomass Harvesting and Utilization, v1.0

TRS-9 Estimation of Domesticated Animal Populations, v1.0

TRS-8 Estimation of Carbon Stocks in the Long Lived Wood Products Pool, v1.0

TRS-10 Estimation of Emissions from Domesticated Animals, v1.0

TRS-11 Estimation of Emissions of Non-CO2 GHG from Soils, v1.1

TRS-12 Estimation of Emissions from Power Equipment, v1.0

TRS-13 Estimation of Emissions from Burning, v1.0

TRS-14 Estimation of Emissions from Activity-Shifting Leakage, v1.0

TRS-15 Estimation of Emissions from Market Leakage, v1.0

TRS-16 Methods for Developing a Monitoring Plan, v1.0

TRS-17 Methods to Determine the Net Change in Atmospheric GHG Resulting from Project Activities, v1.0

Preface

Table of Contents

Project Requirements

Appendices

Project Framework

Project Requirements

Task 1. Project Overview - Identification and Eligibility of Project Activity

Task 1.1 Data confidentiality statement

Task 1.2 Physical Address of the Properties Submitted for Certification

Task 1.3 Description of Land Management Activity

Task 1.4 Project Eligibility

Task 1.4.1 Mandatory Eligibility Conditions

Task 1.4.2 Optional Eligibility Criteria

Task 1.5 Project Boundary

Task 1.5.1 Identification of project boundary

Task 1.6 Baseline Scenario

Task 1.7 Additionality

Task 1.8 Permanence

Task 1.9 Credit Release

Task 1.10 Contractual Commitment

Task 2. Measurement and Reporting

Task 2.1 Quantification of Soil Carbon Stocks for Baseline and Project Scenarios

Task 2.1.1 Stratification for soil carbon sampling

Task 2.1.2 Sampling and analysis for soil carbon per unit area, per stratum

Task 2.1.3 Uncertainty of soil carbon stocks

Task 2.1.4 Project area stratification for biomass

Task 2.1.5 Estimation of the carbon content of current above-ground woody and non-woody biomass and below-ground living biomass pools

Task 2.1.6 Projection of future biomass pools under the baseline scenario

Task 2.1.7 Estimation of the amount of current wood harvest from within the project area used for production of long-lived wood products

Task 2.1.8 Projection of future wood harvest outputs

Task 2.1.9 Long-lived wood products

Task 2.1.10 Estimation of current dead wood pools within the project area

Task 2.1.11 Projection of future dead wood pools within the project area

Task 2.1.12 Estimation of current average domesticated animal populations within the project area

Task 2.1.13 Projection of future domesticated animal populations under the baseline scenario

Task 2.1.14 Estimation of emissions of GHGs from domesticated animals within the project area under the baseline scenario

Task 2.1.15 Estimation of current soil emissions of N2O or CH4 from within the project area

Task 2.1.16 Projection of future emissions of N2O or CH4 from the soils within the project area

Task 2.1.17 Projected emissions from use of power equipment

Task 2.1.18 Estimation of current litter pools

Task 2.1.19 Projection of future litter pools

Task 2.1.20 Summation of estimates and projections under the baseline scenario

Task 2.2 Ex-ante Projections of Project Emissions from Non-soil Carbon Sources

Task 2.2.1 Projection of future above-ground woody and non-woody and below-ground living biomass pools under the project scenario

Task 2.2.2 Projection of future wood harvest outputs under the project scenario

Task 2.2.3 Projection of carbon sequestration in long-lived wood products

Task 2.2.4 Projection of future dead wood pools within the project area under the project scenario

Task 2.2.5 Projection of future domesticated animal populations under the project scenario

Task 2.2.5 Estimation of emissions of GHGs from domesticated animals within the project area under the project scenario

Task 2.2.7 Projection of future emissions of N2O or CH4 from the soils within the project area

Task 2.2.8 Projected emissions from use of power equipment

Task 2.2.9 Projection of future litter pools

Task 2.2.10 Projection of biomass consumption by fire

Task 2.2.11 Projection of non CO2 emissions from burning

Task 2.2.12 Summation of ex-ante project scenario emissions from sources other than soil carbon (e.g., biomass carbon pools, CH4, N2O, etc.)

Task 2.3 Ex-post Quantification of Project Emissions

Task 2.3.1 Estimation of the carbon content of current soil carbon pools per unit of area, for each stratum

Task 2.3.2 Estimation of the carbon content of above-ground woody and non-woody and below-ground living biomass pools

Task 2.3.3 Estimation of the amount of wood harvest from within the project area used to produce long-lived wood products

Task 2.3.4 Long-lived wood products

Task 2.3.5 Estimation of dead wood pools within the project area

Task 2.3.6 Estimation of average domesticated animal populations within the project area

Task 2.3.7 Estimation of emissions of GHGs from domesticated animals within the project area

Task 2.3.8 Estimation of emissions from use of power equipment

Task 2.3.9 Estimation of non CO2 emissions from burning

Task 2.3.10 Monitoring and estimation of soil emissions of N2O or CH4 from within the project area

Task 2.3.11 Estimation of litter pools

Task 2.3.12 Summation of ex-post project emissions from sources other than soil carbon (e.g., biomass carbon pools, CH4, N2O, etc.)

Task 2.4 Ex-ante Projection of Leakage

Task 2.4.1 Projection of leakage due to displacement of grazing, fodder, and agricultural production

Task 2.4.2 Projection of leakage due to displacement of wood harvesting

Task 2.4.3 Projection of market leakage

Task 2.5 Ex-post Quantification of Project Leakage

Task 2.5.1 Monitoring and estimation of emissions from grazing, fodder, and agricultural production displacement

Task 2.5.2 Monitoring and estimation of emissions from wood harvest displacement

Task 2.5.3 Estimation of market leakage

Task 2.6 Monitoring

Task 3 Interim Crediting Assessment (Optional)

Task 3.1 Projection of future soil carbon accrual rate for the project scenario

Task 4 Project Application Submission