African Improved Cooking Stoves Grouped Project

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1 African Improved Cooking Stoves Grouped Project Document Prepared by Rohit Lohia (Envirofit International) Contact Information: Project Title African Improved Cooking Stoves Grouped Project Version 3.0 Report ID 1.0 Date of Issue 14 June 2017 Project ID 983 Monitoring Period Prepared By Contact 01 Jan 2014 to 31 Dec 2015 (both days inclusive) Rohit Lohia (Envirofit International) 1

2 Table of Contents TABLE OF CONTENTS 1 Project Details Summary of the Implementation Status of the Project Sectoral Scope and Project Type Project Proponent Other Entities Involved in the Project Project Start Date Project Crediting Period Project Location Title and Reference of Methodology Other Programs Sustainable Development Implementation Status Implementation Status of the Project Activity Deviations Methodology Deviations Project Deviations Grouped Project Safeguards No Net Harm Local Stakeholder Consultation Data and Parameters Data and Parameters Available at Validation Data and Parameters Monitored Monitoring Plan The Operational and management plan Sampling Plan Quantification of GHG Emission Reductions and Removals Baseline Emissions Project Emissions Leakage Net GHG Emission Reductions and Removals

3 1 PROJECT DETAILS 1.1 Summary of the Implementation Status of the Project The purpose of this grouped project (the project) is dissemination of improved cooking stoves (ICS) in the Republic of Ghana (Ghana). The project will replace traditional cooking stoves using charcoal fuel with more energy efficient charcoal stoves. Stoves disseminated under this project are portable devices serving domestic charcoal users. These ICS are more efficient in transferring heat from the fuel to the pot, thus saving fuel (charcoal) compared to the traditional charcoal stoves currently used by households. Furthermore, the ICSs applied in this project have been designed not only to increase heat transfer to the cooking pot, but also to match the traditional utensils and cooking habits of the people in Ghana. In line with the applied CDM methodology AMS.II.G. Version 04, the baseline scenario is the use of fossil fuels for meeting similar thermal energy needs, in the absence of the project activity. Therefore, by reducing the total amount of fuel (non-renewable biomass) required for cooking, the ICS by replacement of traditional stoves reduce the amount of GHG emitted into the atmosphere. The ICS (model CH2300) covered under the project has been manufactured by Envirofit International. The ICS has a manufacturer s warranty of 5 years. An ICS may be replaced at the end of its operating life with like for like or one with higher efficiency. Otherwise, the credits shall be claimed only till the end of the operational life of the project devices. Currently, there is only one project instance under the grouped project. The commissioning date of the first instance is 06 December 2012 (deemed as one day after the installation of first ICS under the instance). Since commissioning, 9,057 units of CH2300 have been implemented under the instance as follows: Year of Installation Number of ICS , , Grand Total 9,057 The ICS are deemed to be under continued operation since their implementation (corrected for drop off rate determined via ex-post monitoring). The total GHG emission reductions generated in this monitoring period is 41,613 tonnes of CO 2 e with following vintage: Year (y) ER y 18,818 22,795 3

4 1.2 Sectoral Scope and Project Type Sectoral scope: 03 Energy Demand Project type: Type II Energy Efficiency improvement project Grouped project: Yes Number of instances: Project Proponent Organization name Contact person Title Vitol S.A. Amal Halawi-Farag Business Development - Carbon Middle East and Africa Address Boulevard du Pont-d Arve 28, PO Box 384, 1211 Geneva 4, Switzerland Telephone ACH@vitol.com 1.4 Other Entities Involved in the Project Organization name Role in the project Contact person Title AfriKids Distributing organisation, field monitoring surveys, central GHG information system and controls Amy Parker CEO Address Ground Floor, 21 Southampton Row, London, WC1B 5HA, United Kingdom Telephone amyparker@afrikids.org Organization name Role in the project Contact person Title Address Envirofit International Cooking stove supply, central GHG information system and controls, QA/QC of monitoring data, ER calculation and preparation of the monitoring report. Nathan Lorenz Vice President of Engineering & Supply Chain Envirofit International Ltd., 109 N College Ave Suite 200, Fort Collins, Colorado, CO 80524, United States of America Telephone Nathan.Lorenz@EnviroFit.org 1.5 Project Start Date 06 December The first day of operation of the first ICS installed in the project 4

5 1.6 Project Crediting Period Project crediting period: First Start date: (The first operating day of the ICS marks the beginning of the crediting period). End date: Total number of years: 10y 0m 1.7 Project Location The grouped project will be hosted by the Republic of Ghana. The grouped project covers the whole of Ghana. The first phase of ICSs will be distributed in the northern part of the republic of Ghana, specifically in: Area Co-ordinates Tamale Bolgatanga AfriKids Ghana 1, the local implementer for the instance is based in Bolgatanga. Map of Ghana 1 5

6 1.8 Title and Reference of Methodology MONITORING REPORT: VCS Version 3 AMS-II.G.: Energy Efficiency Measures in Thermal Applications of Non-Renewable Biomass (version 4.0) - Approved small scale CDM Methodology, sectoral scope Other Programs None 1.10 Sustainable Development The Project s contribution towards sustainable development is as follows: Environmental Benefits: - Greenhouse gas reductions: The project will result in GHG reductions because it will reduce the consumption of non-renewable biomass in Ghana where the biomass harvested for fuel use is typical non-renewable. - Air quality: Users (especially women and children) will be exposed to fewer air pollutants through reduced emissions of not only CO 2, but also carbon monoxide (CO) and particulate matter (PM). Air pollution from cooking with solid fuel is a key risk factor for childhood pneumonia as well as many other respiratory, cardiovascular and ocular diseases. - Biodiversity: This also will be improved as the project reduces pressure on remaining forest reserves in Ghana. The dependency on wood fuel has contributed to the degradation of Ghana s tropical forests by 25% of the original size which would lead in ecological and biodiversity loss in the long run if everything continues in the same pace. Social and Economic Benefits: - Employment: The project will give rise to employment opportunities for staff to be employed by CME and retailers involved in the sales of the ICS, sales promoters and marketers, technicians and other related jobs in Ghana. - Livelihood of the poor: The circumstances of poor families will be improved since the project stoves reduce the amount of spending on fuel, providing financial savings over the medium long term. Reduction in fuel consumption implies relief from drudgery of fuel collection and offers more opportunities for productive activities, education and family life arising from less time spent collecting fuel. - Access to energy services: The ICS to be distributed require less fuel, which in many areas can be a scarce resource or very expensive to buy. The cooking on ICS is more convenient, due to shortening of the required cooking time. 6

7 2 IMPLEMENTATION STATUS 2.1 Implementation Status of the Project Activity The commissioning date of the only instance, included in this grouped project, is 6 December 2012 which is the start date of operation of first ICS under the project. A total of 9,057 ICS are covered in the monitoring period. The chronological distribution of ICS installed is as follows: Year of Installation Number of ICS , , Grand Total 9,057 During the monitoring period, there has been no changes to the project description as specified in the registered PD, that could impact the scale of the project, the applicability of the methodology, project additionality and emission reduction volumes. 2.2 Deviations Methodology Deviations Not applicable Project Deviations Not applicable 2.3 Grouped Project The project is a grouped project. Therefore, as described in the registered project document, for each new instance (sold ICS) the compliance against the stipulated eligibility criteria in ht eregistered PRR is discussed below. No. Criteria / Condition Proof Summary of confirmation 1 Defined geographic area / Ghana Project database All 9,057 ICS in the database are in Ghana 2 Technology / ICS with a minimum efficiency of 20% Emissions and Performance Report of ICS, project database (sales record) All 9,057 ICS are CH2300 with a rated efficiency of 39.4%. This rated efficiency of CH2300 has already been validated in the registered PD 7

8 3 End users / End users are households/communities/sme s. Project database (sales record) All user listed in the Installation database are household / community / SME. 4 Additionality / In accordance with EB Guidelines 2, automatic additionality applies to project activities solely composed of isolated units where (i) the users of the technology/measure are households or communities or Small and Medium Enterprises (SMEs) and where (ii) the size of each unit is no larger than 5% of the small scale CDM thresholds. (i) Project database (sales record); and (ii) the expected energy savings for each ICS are approximately MWh th /year, which is below the limit. Automatic additionality applies to each ICS, because 1. each end user is household/community/ SME as confirmed above. 2. The energy savings for each ICS is approximately 8.67 MWh th /year and only % of the methodology threshold (refer ER calculator). 5 The SSC capacity limit applies to the methodology used. Therefore, (i) no project activity instance shall exceed the applicable SSC limit, which is 180 GWh th /y, and (ii) no single cluster, determined as per VCS Standard v3.2_0 para 3.4.8, of project activity instances shall exceed the capacity limit. (i) The expected energy savings for each ICS, i.e. each project activity instance, are approximately MWh th /year, which is below the limit, and (ii) the expected energy savings for each ICS are approximately MWh th /year, which is below 1% of the limit, therefore no project activity instance is identified and divided into clusters, and thus the limit does not apply to the proposed grouped project. Refer above. No project activity instance is more thanks 1% of the methodology threshold, hence this is not applicable. 2.4 Safeguards No Net Harm No potential negative environmental and socio-economic impact from the project is envisaged. 2 EB68 Annex 27 para 2(c). 8

9 2.4.2 Local Stakeholder Consultation Local stakeholders were invited to a consultation meeting on 14/11/2011 at Alisa conference Hall, Accra Ghana. Stakeholders were identified as those whose activities directly or indirectly impact the project, and those who were to be impacted by the project activities (full lists of attendance are in the Local Stakeholder Consultation Report). Invitation letters were sent by DHL to the individual stakeholders, and an advert inviting the public was placed in the local newspaper. The invitations were welcoming written comments as well as physical attendance. Over 60 stakeholders attended the consultation meeting. The sales man builds up a direct relationship to the customer and supports whenever problems occur in relation to the cook stove. 3 DATA AND PARAMETERS 3.1 Data and Parameters Available at Validation Q biomass Tonnes/year Annual average biomass consumption per appliance Source of data Registered PD, section 4.1 page 19 Value applied: 4.36 Justification of choice of Fixed ex-ante for the entire crediting period. data or description of and procedures applied Used for calculation of B old as per paragraph 7 (a) of methodology NCV biomass TJ/tonne Net calorific value of the non-renewable woody biomass that is substituted Source of data AMS-II.G. version 04, page 2 Value applied: Justification of choice of data or description of and procedures applied Default value as prescribed in the methodology is adopted IPCC default value for wood fuel f NRB,y Fraction Fraction of woody biomass saved by the project activity in year y that can be established as non-renewable biomass using survey methods 9

10 or government data or default country specific fraction of nonrenewable woody biomass (fnrb) values available on the CDM website Source of data Default value provided by Small Scale Working Group in 37 th meeting Value applied: 0.99 Justification of choice of data or description of and procedures applied As per methodology paragraph 43, option (b) EF projected_fossil fuel tco 2 /TJ Emission factor for the substitution of non-renewable woody biomass by similar consumers Source of data AMS-II.G. version 04, page 2 Value applied: 81.6 Justification of choice of data or description of and procedures applied Default value as prescribed in the methodology adopted η old Fraction Efficiency of the system being replaced Source of data Registered PD, section 4.1 page 19 Value applied: Justification of choice of data or description of and procedures applied Fixed ex-ante for the entire crediting period LAF Fraction Net to gross adjustment factor to account for leakages Source of data AMS-II. G version 04 Value applied: 0.95 Justification of choice of data or description of Default value as prescribed by the methodology is applied 10

11 and procedures applied As the LAF is used, surveys are not required 3.2 Data and Parameters Monitored N y, all Source of data of and procedures to be applied Frequency of monitoring/recording Value monitored: 9,057 Monitoring equipment QA/QC procedures to be applied Calculation method Number Number of stoves installed at the end of the monitoring period Project database (sales records) Sales record of each ICS will include Serial ID number (unique number for each ICS); ICS model; name/identification of end user; geographic location of the stove, which is either a fixed address/location or GPS data; ICS sales date Continuous monitoring using sales record of each ICS. Not applicable The end user data received is checked against the master database Not applicable Source of data of and procedures to be applied Frequency of monitoring/recording η new Value monitored: Monitoring equipment QA/QC procedures to be applied Fraction Efficiency of the system being deployed Test report. The efficiency is determined using an internationally accepted stove testing protocol. The efficiency is determined using EPTP protocol which is an approved protocol by GACC. Three sample runs were carried out on four randomly selected ICSs. The average of the test results is taken as the efficiency of the project ICSs. At least every two years. The monitoring equipment used were basic weighing scale, thermometers and moisture meters. These were newly purchased / calibrated to ensure that the measurements are taken with necessary guarantees. The tests are carried out by local experts, trained by Envirofit. 11

12 Calculation method The average of the test results is taken as the efficiency of the project ICSs. Source of data of and procedures to be applied Frequency of monitoring/recording Value monitored: Monitoring equipment QA/QC procedures to be applied SOF y Fraction Stove operation fraction: share of stoves operating or replaced by equivalent in-service appliance Survey of end user behavior as part of monitoring Sampling surveys were conducted to determine if ICS was operational using a visual inspection / follow up interview with the user. At least once every two years Sample size requirement as per UNFCCC sampling guidelines (using 95/10 confidence/precision) Households sampled 219 ICS found operational 213 Stove Operating Fraction Required precision 10% Actual precision achieved 2.20% Not applicable As the monitoring period exceeds 1 year, the sample size has been determined based on confidence/precision of 95/10 as specified in registered PD. 43 Calculation method Ratio of samples reporting using ICS Vs total number of samples surveyed Source of data of and procedures to be applied Frequency of monitoring/recording f old Fraction The fraction of end users that are still using baseline (replaced) stoves Survey of end user behavior Sampling surveys were conducted to determine if ICS users were continuing with the baseline stoves using a visual inspection / follow up interview with the user. Once every monitoring period (at least every two years) Value monitored: Sample size requirement as per UNFCCC sampling

13 Monitoring equipment QA/QC procedures to be applied guidelines (using 95/10 confidence/precision) Households sampled 213 ICS users found using baseline stoves along with ICS 138 f old Required precision 10% Actual precision achieved 9.78% Not applicable As the monitoring period exceeds 1 year, the sample size has been determined based on confidence/precision of 95/10 as specified in registered PD. Calculation method Ratio of ICS users reporting using baseline stove Vs total number of samples reporting using ICS Source of data of and procedures to be applied Frequency of monitoring/recording Value monitored: Monitoring equipment QA/QC procedures to be applied μ old tonnes/year per stove Amount of woody biomass consumption that is consumed through the continued use of old stoves Survey of end user behavior Sampling surveys were conducted to determine the relative baseline stove usage for those who were also using ICS simultaneously Once every monitoring period (at least every two years) Sample size requirement as per UNFCCC sampling guidelines (using 95/10 confidence/precision) Households sampled 138 μ old 1.67 Required precision 10% Actual precision achieved 16.63% Upper bound value used for ER calculations Not applicable As the monitoring period exceeds 1 year, the sample size has been determined based on confidence/precision of 95/10 as specified in registered PD. 35 Calculation method The value of μ old will be estimated by comparing the number of meals per period (day/week/month) before and after ICS receipt, and multiplying this proportion against the total annual biomass consumption. 13

14 Source of data of and procedures to be applied Frequency of monitoring/recording Stove years,y Years Calculated average year equivalent in the monitoring period Project database (sales records) The stove year is the period for which a stove must be credited, depending upon its date of installation, date of operational lifetime end and stat date and end date of monitoring period. Continuous Value monitored: Monitoring equipment QA/QC procedures to be applied Calculation method 3.3 Monitoring Plan Not applicable The Operational and management plan 1. Vitol executed a contract with Afrikids Ghana to distribute stoves and perform ex-post monitoring activities. 2. Vitol provided instructions to Afrikids to collect the end user information at the time of sales to make the stove eligible under the Project. Vitol S.A. made them aware of requirements of end user data collection. Guidance was provided to them on the correct procedures to be followed during distribution. Vitol S.A. also provided a detailed Monitoring Manual and training to ensure that field measurements are undertaken in line with the standards required of the Sampling Plan. 3. Afrikids maintains a Project Sales Database. This database is a compilation of sales record of each ICS. The database includes instance wise list of stoves sales, based on following information, received from dealers (collected this information at the time of sale): a. Name of customer b. Address / location / contact details of the customer c. Stove unique serial ID number d. Stove Model e. Stove distribution date f. Type of old stove which the ICS replaced, i.e. the fuel type. 14

15 4. Vitol / Afrikids performed cross-checks on the ICS sales information received from the dealers. A unique stove id is punched on each stove and the same serial ID is mentioned on the sales record. Therefore, it is possible to identify each stove in the project with its unique serial ID number. The unique serial number linked to each stove and its association with a unique instance eliminates any risk of double-counting of ICSs. 5. Afrikids (supported by Envirofit) coordinated all ex-post monitoring activities in the Project as follows: a. Implemented the monitoring plan, b. Determined the sample size as per sampling plan and identified the samples to be monitored c. Ensured the quality of monitoring data (QA/QC) d. Used this data for emissions reduction calculations. 6. Afrikids / Envirofit checked and recorded the following key parameters in the Monitoring Records. Key monitored parameters were: a. Efficiency of project stoves (η new ) b. Check if project stoves are operational and in use (SOF) c. Check fraction of end users continuing to use replaced stoves (f old ) d. If replaced stoves are being used, the consumption accounted for by the old stoves (μ old ) Sampling Plan 7. Envirofit calculated emission reductions based on monitoring data collected and prepared the monitoring report. The eligible stoves distributed under the CPAs included in this monitoring report are as follows: Year of Installation Number of ICS , , Grand Total 9,057 a) of implemented single sampling design; Due to the large number of ICS distributed under the PoA it was not economically feasible to monitor each individual ICS unit distributed. Therefore, representative sampling was undertaken as part of a project-wide Sampling Plan. The sampling plan consisted of monitoring the following four parameters: Sl. No. Parameter of parameter 1 η new The thermal efficiency of the ICS distributed (%) 2 SOF The Stove Operating Fraction, i.e. the fraction of users using the ICS 3 f old The fraction of stove users still using baseline (replaced) stoves 4 μ old The amount of woody biomass that continues to be used in the replaced stoves (kg) 15

16 Based on the registered PD, page 30, 95/10 reliability level was selected for sampling, the applied monitoring frequency being biennial. Besides, the ICS population under the project is deemed homogenous due to the following: Variability Possibility Characteristic of Population Status of population Country all units have been distributed homogeneous in the same geographical area, i.e. Ghana Fuel Type charcoal / wood fuel End user domestic / small-medium enterprises / community Stove Type - efficiencies are in a similar range defined as being within +/- 10% of each other and they have other common design features All ICS are CH2300 which is a charcoal fuel improved stove all units are for domestic (household) usage as per their design There is only one model in the instance i.e. CH2300 homogeneous homogeneous homogeneous For the parameter η new, as per page 35 of registered PD, three sample runs were carried out on four randomly selected ICSs. For other parameters (SOF, f old, μ old ), simple Random Sampling approach was applied to monitor the three parameters i.e. stove operation (SOF), fraction of traditional stoves still in operation (f old ) and amount of woody biomass that continues to be used by the replaced stoves (µ old ). The required sample sizes were derived using equation (1) on page 68 and equation (4) on page 70 of the Guideline: Sampling and surveys for CDM project activities and programmes of activities, Version 04.0 for proportion based and mean based parameters respectively as follows:! = # $ & ' &-1 * $ + # $ '! = ( %& '()* ), for mean parameters! = $ (1 $)/$ + for proportion parameters Where:! = sample size! = population size! = Confidence value constant (1.96 for 95%)! = Desired precision (10%)!" = expected standard deviation for mean parameter!"#$ = expected mean for mean parameter! = expected proportion for proportion based parameter The following is the number of samples covered during the monitoring activity. Refer ER calculator worksheet Sample Size Calculations for more details on calculation of sample size for each parameter. The expected parameter values (mean, standard deviation and proportion) have been determined based on project developer s knowledge and experience as per para 12(b) and 16

17 12(c) of the Standard: Sampling and surveys for CDM project activities and programmes of activities, Version 05.0 available at: /meth_stan05.pdf Parameter Total population Expected results Reliability Required (N) Sample Size (n) η new 9, SOF 9, / f old 8, / µ old 5, kg (mean); kg (SD) 95/ Monitored samples The stoves were selected by randomly assigning a number to each stove and sorting in increasing order from lower to higher number. 250 Random numbers were generated using online random number generator and the numbers obtained were used to identify the samples from the population. The approach ensured that the samples picked are random and representative of the population. A higher number of samples were monitored than that required to ensure that the desired precision / confidence is achieved as well as have sufficient number of samples that use both ICS and baseline stove for determining μ old. b) Collected data (electronic spreadsheets may be attached and referenced) Data was collected for SOF, f old and µ old following a specially design survey form. The information collected was introduced into an electronic database. This survey form was designed in a way that would allow the surveyor first to check the validity of the records from the sales database, and secondly to collect the necessary information form field visit for the ER calculations. To achieve the 95/10 reliability level, few additional stoves were sampled from the database than that required (as mentioned in the table above) to cover for non-responses, if any. As for the thermal efficiency of the stoves, water boiling tests were conducted using EPTP as given by GACC. Refer ER calculator worksheet Survey summary and WBT Summary for details on data collected during monitoring. Those involved in field survey monitoring were adequately trained to ensure that the surveys are performed correctly. The WBTs were carried out by experts with prior experience of conducting WBTs. c) Analysis of the collected data Analysis of the data monitored through sampling revealed the following results: Parameter Results Unit η new fraction SOF fraction f old fraction µ old 1,734 kg / year d) Demonstration of whether the required confidence/precision has been met The following tables demonstrate the status of precision/confidence for each of the monitored parameters: SOF Fraction Population Size (SoF) 9057 Number Sample Size (SoF) 219 Number Proportion (SoF) fraction Standard error of proportion (SoF) Precision (SoF) 2.20% % 17

18 Result (SoF) ok, acceptable -- f old fraction Population Size (f old ) 8809 number Sample Size (f old ) 213 number Proportion (f old ) fraction Standard error of proportion (f old ) Precision (f old ) 9.78% % Result (f old ) ok, acceptable -- µ old tonnes/y Population Size (µ old ) 5707 number Sample Size (µ old ) 138 number Mean (µ old ) 1.67 tonnes/y Standard Deviation (µ old ) 0.39 tonnes/y Standard error of mean (µ old ) Precision (µ old ) 16.63% % Result (µ old ) user upper bound value -- η new Fraction Population Size (η new ) 9057 number Sample Size (η new ) 4 number Mean (η new ) fraction Standard Deviation (η new ) fraction Standard error of mean (η new ) Precision (η new ) 6.05% % Result for (η new ) ok, acceptable -- For detailed calculations refer ER calculator, worksheet Survey Summary and WBT Summary. 4 QUANTIFICATION OF GHG EMISSION REDUCTIONS AND REMOVALS 4.1 Baseline Emissions The following equations were used for determination of emission reductions from the project activity.!" # = % #,'()*+,'. / *78(''!9 :;7<=>?=@ A7''*BCDEF! ",$%&'()$ =! +, ,- 1 (23! "#$ = &'( +,## -.( (0 12"3,44-6 "#$ "#$ ) -;<=>?@,A 18

19 Data Fixed Ex Ante Value Unit Source Q biomass 4.36 tonne/year Ex-ante, CPA-DD f NRB 0.99 fraction Ex-ante, CPA-DD NCV biomass TJ/tonne Ex-ante, CPA-DD EF fossil_fuel 81.6 tco2/tj Ex-ante, CPA-DD η old fraction Ex-ante, CPA-DD LAF 0.95 fraction Ex-ante, CPA-DD Data Monitored Ex Post Value Unit Source η new 33.16% % Monitored - "WBT data" SOF fraction Monitored - "Monitoring Survey" f old fraction Monitored - "Monitoring Survey" µ old 1734 kg/year Monitored - "Monitoring Survey" Data Ex Post Unit Source N all stoves Calculated STOVE year fraction Calculated B old t biomass Calculated B y, savings t biomass Calculated Annual Energy savings GWh Calculated Scale? Small Small -scale Calculated Capacity Utilization 43.60% 43.60% Calculated ER y 18,818 22,795 tco2e Calculated 4.2 Project Emissions As explained above, the methodology directly provides equation for emission reductions; without separate baseline, project or leakage emission reduction equations. Calculation of Emission Reductions has already been explained above as per the methodology. Thus, this section is not applicable. 4.3 Leakage As explained above, the methodology directly provides equation for emission reductions; without separate baseline, project or leakage emission reduction equations. Calculation of Emission Reductions has already been explained above as per the methodology by application of Gross to Net Leakage adjustment factor of 0.95 to baseline emissions. Thus, this section is not applicable. 4.4 Net GHG Emission Reductions and Removals Year Baseline emissions or Project emissions or Leakage emissions Net GHG emission 19

20 removals (tco 2 e) MONITORING REPORT: VCS Version 3 removals (tco 2 e) (tco 2 e) reductions or removals (tco 2 e) , , , ,795 Total 41, ,613 20