# Principles & requirements

Project Developers shall demonstrate that they comply with all principles and requirements outlined in the [Rainbow Standard Rules](/~/changes/229/rainbow-standard-documents/rainbow-standard-rules/principles-and-requirements.md), and described below with a specific focus on BioCCS.

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[Rainbow Standard Rules](/~/changes/229/rainbow-standard-documents/rainbow-standard-rules.md)
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## Additionality

To demonstrate additionality, Project Developers shall perform **regulatory surplus analysis and investment  analysis**, using the [Rainbow Additionality Template](/~/changes/229/rainbow-standard-documents/procedural-templates/additionality-evaluation-template.md).

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{% tab title="Regulatory surplus analysis" %}
**Regulatory surplus analysis** shall demonstrate that there are no regulations that require or mandate project activities. It is acceptable if regulations promote or set targets for these activities, because the resulting increase in activities shall be accounted for in the [baseline scenario](#id-8422amp7fe3k-1).

At the European Union level, projects automatically pass the regulatory surplus analysis, which has been conducted by the Rainbow Team. Project Developers are only required to provide a country-level regulatory surplus analysis.
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{% tab title="Investment analysis" %}
**Investment analysis** shall be used to prove that revenue from carbon finance is necessary to make the project investment a financially viable and interesting option, and that the project would not have been viable through government support or compliance market payments alone. The investment may cover:

* The creation and launching of new **carbon capture** **sites** (i.e. greenfields)
* Expansion of capacity of existing **carbon capture** activities
* Expansion by installing new **carbon capture processes** onto existing CO<sub>2</sub> generating sites (i.e. retrofits)

Business plans shall be provided as initial proof for investment analysis. During subsequent verifications, audited financial statements shall be used to demonstrate that the initial estimates from the business plan were reasonable, and that carbon finance was used as initially described for the expected investment.

It is strongly recommended to use the project’s Internal Rate of Return (IRR) with and without carbon finance as the basis for investment analysis. See the [Rainbow Standard section on additionality](/~/changes/229/rainbow-standard-documents/rainbow-standard-rules/principles-and-requirements.md#additionality) for more detailed IRR calculation instructions.

Note that for investments in expansion, **only the additional carbon removals enabled by the expansion shall be eligible for Rainbow Carbon Credits.**
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## Durability <a href="#lc9eewbyvlyk" id="lc9eewbyvlyk"></a>

### Durability threshold

The durability of carbon removal for projects certified under this methodology is **1000+ years**.&#x20;

### Reversal risk assessment

The major carbon reversal risks from BioCCS is at the CO<sub>2</sub> storage site in geological formations, where fugitive CO<sub>2</sub> leaks may occur due to e.g. natural or induced seismicity, lateral migration of CO<sub>2</sub> plume, deteriorated confining system integrity, faults and fractures at infrastructure.&#x20;

Project design requirements largely reduce reversal risks by restricting the [eligible carbon storage](/~/changes/229/methodologies/biogenic-carbon-capture-and-storage-bioccs/eligibility-and-scope.md#eligible-storage) to countries with established storage regulations.

In addition to storing CO<sub>2</sub> at a regulated storage site, Project Developers shall:

* prove access to storage capacity for the projected amount of CO<sub>2</sub> captured during the facility's operating lifetime through contracts with storage providers,
* prove compliance with national storage regulation (in the [Storage Plan](#lc9eewbyvlyk-1)),
* establish a post-crediting reversal monitoring procedure (in the [Storage Plan](#lc9eewbyvlyk-1)),

Upon meeting the above-mentioned requirements, the risk of reversal for carbon storage in geological formations is considered negligible.There are **no further project requirements to assess reversal risks** for reversals.

All projects certified under this methodology shall contribute the default minimum 2% of their verified removal RCCs to the [Rainbow Buffer Pool](/~/changes/229/rainbow-standard-documents/procedures-manual/rainbow-carbon-credits.md#buffer-pool), as defined in the Rainbow Standard Rules.

### Storage Plan <a href="#lc9eewbyvlyk" id="lc9eewbyvlyk"></a>

The assumption that reversal risk is negligible in geological storage relies on sites being **rigorously selected, characterized, and monitored,** both during operations and after site closure. As part of the validation audit, Project Developers are required to provide a **storage plan**, including but not limited to the following information:

{% hint style="info" %}
Note that all required information must comply with the requirements from relevant **local or national regulations**. If such regulations do not provide specifications, it shall be based on **industry best practices or peer-reviewed scientific literature.**
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<table><thead><tr><th width="198.1973876953125">Section of Storage Plan</th><th>Required content</th></tr></thead><tbody><tr><td><strong>Site suitability</strong></td><td><ul><li>applicable regulations governing the geological storage site </li><li>characterization of the storage site (i.e potential storage complex and surrounding area), </li><li>assessment methods and data used to determine suitability for geological storage,  </li><li>risk assessment for the potential of leakage from the storage site, including risk magnitude, timing and frequency.</li></ul></td></tr><tr><td><strong>Reversal monitoring plan scope</strong></td><td><p>Plans to monitor the injection facility, the storage complex, including the CO<sub>2</sub> plume where possible, and its <a data-footnote-ref href="#user-content-fn-1">surroundings</a>, covering at least the following points:</p><ul><li>changes in the actual and modeled behavior of CO<sub>2</sub>, </li><li>any irregularities, </li><li>migration and leakage of CO<sub>2</sub>, </li><li>negative effects on the surrounding environment, </li><li>structural integrity of the infrastructure,</li><li>location and extent of the area monitored</li></ul></td></tr><tr><td><strong>Monitored parameters and monitoring procedures</strong></td><td><ul><li>technologies used </li><li>frequency of monitoring </li><li><p>The list of monitored parameters shall at least comprise </p><ul><li>the gas flow rate, </li><li>the chemical composition of the injected CO<sub>2</sub> stream</li><li> the  pressure and temperature at the injection wellhead, at the reservoir and/or along the well (where accessible)</li></ul></li><li><strong>Normal, alert and threshold values</strong> for monitored parameters rocedures implemented in case the alert or threshold values are reached;</li></ul></td></tr><tr><td><strong>Response protocol</strong></td><td><p>Outlining actions taken if a reversal event is detected (i.e. timeline for response steps, corrective measures, documentation of any reversal events). This protocol shall be in accordance with the <a href="https://docs.rainbowstandard.io/rainbow-standard-documents/procedures-manual/rainbow-carbon-credits#canceling-removal-credits-due-to-reversals">Rainbow Cancelation Procedure</a> and its <a data-footnote-ref href="#user-content-fn-2">Cancelation Notice</a>. </p><p><br>Project Developers shall establish an agreement with the storage operator to ensure compliance with the above mentioned requirements, if the Project Developer is not the storage provider.</p></td></tr><tr><td><strong>Post-closure procedure</strong></td><td><p>Description of procedures and liability transfer process, in accordance with applicable regulatory frameworks. This shall at least cover </p><ul><li>post-closure monitoring, </li><li>reporting and corrective measures, </li><li>conditions for liability transfer.</li></ul></td></tr><tr><td><strong>Liability</strong></td><td>In the case that the <strong>Project Developer is not the storage operator</strong>, the Project Developer shall provide a clear division of responsibilities and liabilities between the Project Developer and the external storage operator.</td></tr></tbody></table>

## No double counting <a href="#n1iy4xaxuthk" id="n1iy4xaxuthk"></a>

Project Developers shall sign the [Rainbow MRV & Registry Terms & Conditions](/~/changes/229/other/terms-and-contracts/terms-and-conditions-for-project-developers-mrv-+-registry.md), committing to follow the requirements outlined in the [Rainbow Standard Rules](/~/changes/229/rainbow-standard-documents/rainbow-standard-rules.md), including not double using or double issuing carbon credits.

BioCCS projects encompass multiple process steps, with each step potentially operated or managed by parties other than the Project Developer. To avoid double counting, Project Developers shall provide proof, through contracts with all parties involved in the supply chain, that they are the sole owner of the RCCs associated with the storage activity, and ensure that no other party claims carbon removals associated to the activity.

Any allocation applied in the [GHG Quantification](/~/changes/229/methodologies/biogenic-carbon-capture-and-storage-bioccs/ghg-quantification.md) section of this methodology shall be **consistent with any other GHG accounting performed by the operator** for co-products, whether voluntary or required under applicable law. Specifically, this means that emissions assigned to the BioCCS activity shall not also be deducted or claimed as avoided in a product carbon footprint, Environmental Product Declaration, or corporate GHG inventory for the primary product(s). This requirement prevents the same emission reduction from being counted twice, once within the carbon credit and once as a product-level green claims.

## Co-benefits <a href="#id-8f3i2uvmiuhl" id="id-8f3i2uvmiuhl"></a>

Projects should support at least two **quantifiable and verifiable** environmental or social co-benefits, aligned with the [UN Sustainable Development Goals](https://unstats.un.org/sdgs/indicators/Global-Indicator-Framework-after-2024-refinement-English.pdf) (SDGs) framework. Any co-benefits claimed by the Project Developer shall be **quantified, monitored, and audited** for each verification and credit issuance.

Common co-benefits under this methodology are detailed in the table below. Project Developers may suggest and prove other co-benefits not mentioned here.

SDG 13 on Climate Action by default is not considered a co-benefit here, since it is implicitly accounted for in the issuance of carbon credits. If the project delivers climate benefits that are not accounted for in the GHG reduction quantifications, then they may be considered as co-benefits.

*Table 1 Common co-benefits that projects under this methodology may provide are detailed, including types of proof that can be used to justify each co-benefit.*

<table><thead><tr><th width="205.4730224609375">UN SDG</th><th width="345">Example</th><th>Proof</th></tr></thead><tbody><tr><td><strong>SDG 7.2.</strong> Increase the share of renewable energy in the global energy mix.</td><td>BioCCS projects classified as greenfield projects produce renewable bioenergy (heat, electricity, biogas), and contribute to increasing the share of renewable energy.</td><td>energy produced (kWh), injection receipts from electricity/heat/gas network</td></tr><tr><td><strong>SDG 9.4:</strong> Upgrade infrastructure and retrofit industries to make them sustainable.</td><td>Retrofits and additions to existing facilities support sustainable industrialization by operating scalable, innovative carbon-negative solutions. </td><td>project description </td></tr><tr><td><strong>SDG 11.6:</strong> Reduce adverse environmental impact of cities</td><td>By capturing flue gas from municipal solid waste management sites, BioCCS projects may capture harmful pollutants alongside CO<sub>2,</sub> thereby improving urban air quality.</td><td>analysis and quantification of captured flue gas</td></tr><tr><td><strong>SDG 12.2:</strong> Achieve sustainable management and efficient use of natural resources.</td><td>BioCCS project capturing CO<sub>2</sub> from <strong>waste-only</strong> biomass ensures that no additional land or resources are required for feedstock. This approach maximizes resource efficiency, avoids competition with food production and promotes circular economy principles. </td><td>biomass invoices and supplier contracts</td></tr></tbody></table>

## Environmental and social safeguards <a href="#id-82n4j72vjt9v" id="id-82n4j72vjt9v"></a>

Project Developers shall prove that the **project does not contribute to substantial environmental and social harms.**

Projects must follow all national, local and European (if located in Europe) environmental and social regulations for the **capture, transport and storage of CO**<sub>**2**</sub>, and prove such compliance using, for example, permits, certifications, or licenses.

Project Developers must comply with the following biomass sustainability requirements, and complete the [BioCCS risk assessment](#esdnh-risk-assessment) described below.

### Biomass sustainability&#x20;

The following requirements apply to all [biomass fractions](#user-content-fn-3)[^3]:

* Project Developers shall transparently report on the **mass, type and source of biomass** to the level required in national guidance and relevant industrial standards.
* Project Developers shall prove that biomass complies with the requirements for different types of biomass outlined below.

<details>

<summary>Forestry waste</summary>

Eligible sources of [forestry waste](#user-content-fn-4)[^4] and downstream wood processing waste are:

* **Secondary forest:** Natural but not primary old-growth forest, may still be managed for timber
* **Managed forest:** Managed mixed-use forests that may include agroforestry, plantations or rotational logging
* **Necessary tree removal from any forest:** Damaged trees, or trees removed for planned forest management such as preventing disease spread or fires

Forestry waste biomass shall meet all of the following requirements:

* Biomass shall **not be sourced from a primary forest**, unless sourced as part of a of a necessary tree removal activity.
* Biomass shall be proven to be waste, following the [proof of waste status](#proof-of-waste-status) requirements below.
* Biomass shall hold at least one of the following **forestry sustainability certificates** (or equivalent[^5], with a sufficient justification):
  * FSC (Forest Stewardship Council)⁠
  * PEFC (Program for the Endorsement of Forest Certification)⁠
  * RSB (Roundtable on Sustainable Biomaterials)⁠
  * SFI (Sustainable Forestry Initiative)⁠
  * SBP (Sustainable Biomass Program)⁠
* Biomass shall be sourced from an area with **stable or increasing carbon stocks**, unless sourced as part of a necessary tree removal activity. Assessment of forest carbon stocks shall be evidenced by one of the following approaches:

  * **Sourcing area assessment (preferred):** An independent third-party assessment demonstrating that the net change in forest carbon stocks within the [sourcing region ](#user-content-fn-6)[^6]has not decreased over the most recent 10-year [rolling average](#user-content-fn-7)[^7], using the most recently available data. The assessment shall cover, at minimum, above-ground biomass, below-ground biomass and dead matter. Soil carbon shall either be quantified or evidenced as not negatively impacted. Where biomass is sourced from jurisdictional territories exceeding 5 million km<sup>2</sup> this approach is mandatory.
  * **Jurisdictional assessment:** Evidence that the net LULUCF[^8] emissions of the jurisdiction, as reported to the UNFCCC, are zero or negative (i.e. a net carbon sink) over a rolling average not exceeding 10 years, using the most recently available primary data. Net emissions shall include both forest land and harvested wood products as reported within the LULUCF sector.

  Acceptable evidence for the necessary tree removal activity includes official documentation from a competent governmental authority confirming the necessity of tree removal, stating the forest health objective (such as fire risk reduction, pest control, or disease containment), together with chain-of-custody records linking the biomass to the designated intervention area.

</details>

<details>

<summary>Agro-food waste</summary>

Agro-food waste may originate from the field, or from food processing facilities. It shall be proven to be waste, following the [Proof of waste status](#proof-of-waste-status) requirements below.

If agro-food waste originates from the field, it shall be harvested in a way that preserves soil carbon stocks and soil quality. Evidence may include national or regional regulations, policies or local residue harvesting plans, provided these include some form of monitoring and enforcement.

</details>

<details>

<summary>Marginal energy crops</summary>

To avoid competition with food and feed production, marginal energy crops are defined as crops that are:&#x20;

* grown on marginal, degraded or contaminated land, that is not suited for food or feed production; or
* grown as a cover crop or intermediary crop, on agricultural land suited for food and feed production.

Project Developers shall demonstrate compliance with the following sustainability criteria:

* Marginal energy crops shall only be cultivated on land that has been **continuously classified as agricultural land** since January 2008, or for at least 20 years prior to the date of harvest, whichever is the later. Crops cultivated on land that was, at any point within that period, classified instead as [highly biodiverse land](#user-content-fn-9)[^9] or [land with high-carbon stock](#user-content-fn-10)[^10] is not eligible. Land use maps, land register extracts or other official documentation shall be provided as evidence.&#x20;
* Marginal energy crops shall be cultivated under an agronomic **monitoring or management plan** that preserves or improves soil quality and soil carbon. Acceptable proof includes national or regional regulations, policies or local harvesting plans, provided these include some form of monitoring and enforcement.&#x20;
* Cultivation of intermediary or cover crops shall comply with applicable local or regional regulations governing the cultivation of this crop type for bioenergy applications, ensuring that the crop is not the primary driver of land use and does not trigger demand for additional land. Acceptable proof includes feedstock traceability records, identifying each feedstock batch by plot of origin and delivery date. Access to feedstock sourcing history at farm level shall be made available upon request.&#x20;

</details>

<details>

<summary>Primary energy crops</summary>

Primary energy crops are grown as primary crop on agricultural land that is suited for food and feed production.&#x20;

This biomass type is eligible only for BioCCS projects capturing CO<sub>2</sub> from **anaerobic digestion,** and shall not exceed 15% of the total mass of the feedstock mix.

To avoid competition with food and feed production, primary energy crops are only eligible if the land on which they are grown has been in **repeated cultivation for energy crops for at least 20 years** prior to the project start date.

Project Developers shall demonstrate compliance with the following sustainability criteria:&#x20;

* Primary energy crops shall only be cultivated on land that has been **continuously classified as agricultural land** since January 2008, or for at least 20 years prior to the date of harvest, whichever is the later. Crops cultivated on land that was, at any point within that period, classified as [highly biodiverse land](#user-content-fn-9)[^9] or [land with high-carbon stock](#user-content-fn-10)[^10] is not eligible. Land use maps, land register extracts or other official documentation shall be provided as evidence.&#x20;
* Primary energy crops shall be cultivated under an agronomic **monitoring or management plan** that preserves or improves soil quality and soil carbon. Acceptable proof includes national or regional regulations, policies or local harvesting plans, provided these include some form of monitoring and enforcement.&#x20;

</details>

<details>

<summary>Invasive species</summary>

Project Developers shall **provide proof of invasive species status** for any biomass feedstock categorized as invasive species. This may include but is not limited to peer-reviewed scientific literature documenting the species as invasive in the specific region, national or regional government invasive species lists or registers, regional intergovernmental lists (e.g. IUCN Invasive Species Specialist Group database), or local official weed management orders.

Project Developers shall provide an **Ecosystem Restoration Plan**, outlining all of the following:

* the extent of invasive species harvesting, and how much biomass is left in the field after harvesting
* procedures to ensure only targeted invasive species are harvested
* impacts on biodiversity and habitat loss
* impacts on ecosystem carbon loss&#x20;

</details>

<details>

<summary>Municipal solid waste (MSW)</summary>

Municipal solid waste shall not be generated for the purpose of generating CO<sub>2</sub> and for CDR.

MSW sites shall prove sustainable management of any hazardous waste, following the applicable regulations.

The biomass shall also be proven to be waste, following the [proof of waste status](#proof-of-waste-status) requirements below.

</details>

<details>

<summary>Municipal sludge</summary>

Municipal sludge such as sewage sludge and biosolids shall not be generated for the purpose of generating CO<sub>2</sub> and for CDR.

The biomass shall also be proven to be waste, following the [proof of waste status](#proof-of-waste-status) requirements below.

</details>

<details>

<summary>Animal waste </summary>

Animal waste such as manure and slurry shall not be generated for the purpose of generating CO<sub>2</sub> and for CDR.

The biomass shall also be proven to be waste, following the [proof of waste status](#proof-of-waste-status) requirements below.

</details>

#### Proof of waste status

Biomass types categorized above as waste shall be **proven to be waste** using one any one of the following three methods:

1. **Price**: if Project Developers did not pay for the biomass, or if they were paid to handle it, the biomass can be considered waste. Acceptable proof includes invoices, receipts, or contracts.
2. **Contextual analysis**: Project Developers may submit an analysis supported by reputable sources that the biomass 1) could not be used as main material products, and 2) was not grown for the purpose of CDR[^11] or bioenergy generation.
3. **Positive list of wastes**: if the biomass is included in the following list, it can be considered waste. Acceptable proof includes invoices, receipts, contracts, or photographic evidence and is required for validation:

{% columns %}
{% column %}

* sawmill residues
* sawdust
* shavings
* bark
* forestry tops and branches
* wildfire management residues
* straw
* husks
  {% endcolumn %}

{% column %}

* corn cobs
* wood pruning from horticulture
* nut shells
* bagasse
* sugar beet pulp
* municipal solid waste
* municipal sludge and biosolids
* animal manure and slurry
  {% endcolumn %}
  {% endcolumns %}

&#x20;

***

<details>

<summary>🇪🇺 CRCF Requirement: Biomass sustainability</summary>

In addition to meeting all requirements outlined above, Projects seeking certification under the European Commission's [Carbon Removal Certification Framework](#user-content-fn-12)[^12] (CRCF) shall use biomass that is compliant with the EU's [Renewable Energy Directive](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32023L2413\&qid=1699364355105) (RED) III.&#x20;

This shall be proven by demonstrating accreditation of the biomass under voluntary national schemes that are

* approved under RED III by the European Commission or
* recognized by the competent national authority in the state where the BioCCS facility is located.

A list of EU-approved schemes can be found [here](https://energy.ec.europa.eu/topics/renewable-energy/bioenergy/voluntary-schemes_en)​.

Project Developers shall ensure that:

* if biomass is sourced from conservation or protected areas, including national restoration areas, it is harvested in line with conservation and restoration objectives and&#x20;
* biomass is not identified as being produced from a high indirect land use change risk feedstock, as defined in the RED.

If CO<sub>2</sub> is captured from energy production covered by the EU's [Renewable Energy Directive](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32023L2413\&qid=1699364355105) (RED), Project Developers shall demonstrate compliance with the national implementation of that directive, in particular with requirements laid out in Article 3 (3) and (3a) on the use of woody biomass and (3c) on financial support from Member States.&#x20;

</details>

#### **Avoidance of increase in biomass demand**&#x20;

The following requirements are intended to **prevent an increase in biomass demand** resulting from carbon finance incentives. Specifically, Project Developers shall avoid operational changes that increase CO<sub>2</sub> generation per unit of output, meaning more CO<sub>2</sub> produced for the same amount of useful energy or product delivered, where the sole purpose of that change is to produce additional CO<sub>2</sub> for capture.&#x20;

The following requirements apply where CO<sub>2</sub> is captured from a facility that primarily converts **biomass to heat or electricity.**&#x20;

* Where such a facility is [newly constructed](#user-content-fn-13)[^13] or has been [recently converted](#user-content-fn-14)[^14] from fossil fuel to biomass use, Project Developers shall demonstrate that the facility would remain economically viable without the carbon removal activity.&#x20;
* In all other cases, Project Developers shall demonstrate that the facility's [nameplate energy generation capacity](#user-content-fn-15)[^15] has not increased by more than what is needed **to power the capture process.** This shall be assessed relative to the facility's nameplate capacity either at the time it began operating or three years prior to the start of the project's crediting period.

The rules do not apply to the following types of facilities:

* waste-to-energy facilities combusting wastes or residues other than agricultural, aquaculture, fisheries, and forestry residues (e.g. municipal waste incineration);
* facilities using biomass for **non-energy applications** or where heat/electricity are **not the primary outputs** (e.g., biofuel or biogas production);
* facilities using biomass as part of an **industrial chemical process** to produce a product other than heat or electricity, even if energy is also extracted.

{% hint style="info" %}
**Example 1**&#x20;

A bioenergy plant, built in 2015, has a nameplate energy generation capacity of 50 MW, which has remained unchanged since it began operating. In 2022, the facility was retrofitted with a carbon capture unit, which requires 3 MW of energy to operate, and captures **18,000 tCO**<sub>**2**</sub>**/year**. The plant consumes 100,000 tonnes/year of woody biomass.

* **Scenario 1:** The plant’s nameplate capacity increased by 3 MW, from 50 MW (2019, three years prior to the start of the project) to 53 MW, due to an increased consumption of biomass. The capacity increase **exactly matches the energy needed to power the capture process**. No other operational changes were made.
  * ✅ **This scenario is eligible** because the increase only covers the energy demand of the capture unit.
* **Scenario 2:** The plant’s nameplate capacity increased by 6 MW, from 50 MW (2019) to 56 MW, **exceeding the 3 MW required for the capture process**. Since the increase is greater than what is needed to power the capture unit, it suggests that biomass consumption was increased not only to power the capture unit, but also to generate more CO<sub>2</sub> for capture.
  * ❌ **This scenario is ineligible** because the capacity increase goes beyond the needs of the capture process.
    {% endhint %}

### Environmental and social risk assessment <a href="#esdnh-risk-assessment" id="esdnh-risk-assessment"></a>

Project Developers shall fill in the [BioCCS risk assessment template](/~/changes/229/methodologies/biogenic-carbon-capture-and-storage-bioccs/risk-assessment-template.md), to evaluate the identified environmental and social risks of projects. The identified risks include:

For biomass

* Disruption of soil health when collecting and exporting organic matter
* Deforestation from use of forestry products as feedstock
* Distant transport of feedstock inputs (>100 km)

For CCS

* Generation of hazardous liquid and solid wastes and exhaust gases during capture process
* CO<sub>2</sub> stream impurities&#x20;
* CO<sub>2</sub> leakage during transport
* CO<sub>2</sub> migration or leakage to surface or near-surface at storage site&#x20;
* Contamination of groundwater due to leakage of CO<sub>2</sub> from storage reservoir
* Induced seismicity

Project Developers shall assign a likelihood and severity score of each risk, and provide an explanation of their choices. The VVB and Rainbow’s Certification team shall evaluate the assessment and may recommend changes to the assigned scores.

Any identified material risk (defined as issues with a risk score of moderate or higher) shall be subject to a [Risk Mitigation Plan](/~/changes/229/rainbow-standard-documents/rainbow-standard-rules/principles-and-requirements.md#environmental-and-social-risk-assessment), which outlines how Project Developers will mitigate, monitor, report, and if necessary, compensate for any environmental and/or social harms.

Additional proof may be required for certain high risk environmental and social problems.

The Project Developer, the Rainbow Certification Team, or the VVB may suggest additional risks to be considered for a specific project.

{% hint style="info" %}
Note that the **life-cycle GHG reduction calculations account for the climate change impacts of most environmental risks**. Nonetheless, Project Developers shall transparently describe any substantial and sensitive GHG emission risks in the risk evaluation template.
{% endhint %}

{% hint style="info" %}
All risk assessments must also address the [Minimum environmental and social risks ](/~/changes/229/rainbow-standard-documents/rainbow-standard-rules/principles-and-requirements.md#environmental-and-social-risk-assessment)defined in the Rainbow Standard Rules.
{% endhint %}

## Leakage <a href="#lc9eewbyvlyk" id="lc9eewbyvlyk"></a>

According to the [Rainbow Standard Rules](/~/changes/229/rainbow-standard-documents/rainbow-standard-rules/principles-and-requirements.md#leakage), carbon removal projects shall minimize leakage, where carbon-emitting activities are displaced or shifted outside of the project boundary.

Project Developers shall assess and, if identified to be material, quantify the leakage caused by the BioCCS project. This shall be done by first identifying the alternative fate of biomass, and then assessing the leakage risks from the following identified leakage sources:&#x20;

1. Baseline carbon storage
2. Diversion of biomass
3. Diversion of bioenergy and biomaterial
4. Indirect land use change.

Biomass-related leakage requirements (leakage sources 1, 2 and 4) apply to the following [biomass fractions](#user-content-fn-3)[^3]:

* Retrofit projects: additional biomass
* Greenfield projects: biomass allocated to CO<sub>2</sub> generation

Any leakage GHG emissions are calculated according to the [Quantification of leakage emissions](/~/changes/229/methodologies/biogenic-carbon-capture-and-storage-bioccs/ghg-quantification.md#quantification-of-leakage-emissions) section and deducted from the project GHG quantification.&#x20;

The **leakage assessment is valid for 5 years**, provided the biomass type and source[^16] remain unchanged. The Project Developer is responsible for reporting any significant change in biomass type or source in their monitoring report at each verification. Where such a change is identified, a reassessment of leakage impacts is required.

### Alternative fate of biomass&#x20;

Project Developers shall evaluate the most likely alternative use/s of the biomass in order to assess leakage risks associated with **the baseline carbon storage and the diversion of biomass**. The assessment shall be transparent and conservative.

Alternative uses of the biomass include:

{% columns %}
{% column %}

* incineration
* energy combustion
* left on field&#x20;
* animal bedding
  {% endcolumn %}

{% column %}

* mulching
* landfill
* other (specified by Project Developers)
  {% endcolumn %}
  {% endcolumns %}

Proof shall be provided and may include signed statements from the biomass provider, historical records from the biomass provider, regional statistics or reputable reporting.

A short list of likely alternative uses may be provided for descriptive purposes, but for the purpose of further analysis, one single alternative use shall be proposed.

### Baseline carbon storage

BioCCS projects shall only be credited for carbon storage that is genuinely additional. This means that the carbon stored by the project would have been otherwise released into the atmosphere in the absence of the project. If a feedstock's biogenic carbon would have partially remained stored for a meaningful period in the alternative fate scenario, the corresponding fraction is not additional and shall not be credited.

The assessment of the baseline carbon storage is informed by the alternative fate scenario of the biomass.&#x20;

* No baseline carbon storage is considered for feedstock whose alternative fate is to be incinerated or used in energy combustion, fully releasing the carbon in the feedstock.&#x20;
* For all other alternative fate scenarios, baseline carbon storage is assumed to be non-negligible and must be quantified.

Any baseline carbon storage is calculated according to the detailed instructions in the [Quantification of baseline carbon storage](/~/changes/229/methodologies/biogenic-carbon-capture-and-storage-bioccs/ghg-quantification.md#quantification-of-baseline-carbon-storage) section and deducted from the project GHG quantification.&#x20;

### Diversion of biomass

BioCCS projects capture CO<sub>2</sub> from sustainable biomass, a scarce resource, that may otherwise have been used elsewhere. Demand from the project's activity risks displacing biomass from an existing use, forcing other actors to use high-emission alternatives.

Leakage from the diversion of biomass feedstock can assumed **negligible** if Project Developers can demonstrate one of the following cases:

*Table 1 : Cases in which leakage from the diversion of biomass can be considered negligible.*

<table data-full-width="false"><thead><tr><th width="366.44677734375">Description</th><th>Proof</th></tr></thead><tbody><tr><td>The feedstock is agricultural or forestry waste with no value that would have been burnt on the field or elsewhere.</td><td>Historic proof of disposal from feedstock supplier (e.g. contract with disposal or end-use sites) </td></tr><tr><td><p>The project is a retrofit and the biomass feedstock consumed by the project did not change in</p><ul><li>type</li><li><a data-footnote-ref href="#user-content-fn-16">source</a></li><li>quantity</li></ul><p>compared to the business-as-usual scenario over the last 3 years prior to retrofitting. </p></td><td>Calculation of the<a data-footnote-ref href="#user-content-fn-17"> baseline consumption rate</a>, according to the rules set out in the <a href="/pages/eFyO8ZlCqCWYfFKHBFiH#quantification-of-leakage-emissions">Quantification of leakage</a> section</td></tr><tr><td>The feedstock is whole trees from <a data-footnote-ref href="#user-content-fn-18">necessary tree removal</a> and is unsuitable for bioenergy or material production.</td><td><p>Justification and proof of </p><ul><li><a data-footnote-ref href="#user-content-fn-19">necessary tree removal </a> </li><li>unsuitability for bioenergy and material production</li></ul><p>Historic proof of disposal from feedstock supplier (e.g. contract with disposal or end-use sites)</p></td></tr></tbody></table>

**Leakage quantification.** If none of the cases can be demonstrated, leakage from the diversion of biomass shall be quantified for each feedstock type and source according to the rules set out in the  [Quantification of leakage from biomass diversion](/~/changes/229/methodologies/biogenic-carbon-capture-and-storage-bioccs/ghg-quantification.md#quantification-of-leakage-from-biomass-diversion) section and deducted from the total GHG removals of the project.

### Diversion of bioenergy and biomaterial&#x20;

The assessment of leakage from the diversion of bioenergy and biomaterial depends on the chosen baseline scenario and shall be quantified according to the rules set out in [Quantification of leakage from bioenergy and biomaterial](/~/changes/229/methodologies/biogenic-carbon-capture-and-storage-bioccs/ghg-quantification.md#quantification-of-leakage-from-diversion-of-bioenergy-and-biomaterial) section:

* For **greenfield** BioCCS facilities, no leakage due to diversion of bioenergy and biomaterial is considered because there are no such outputs in the BAU.&#x20;
* For **retrofits/ additions on top of existing sites** that:
  * produce an equivalent or increased amount of bioenergy or biomaterial (e.g. through improvement of efficiency), no leakage for the diversion of such is assumed.&#x20;
  * produce and export less energy or material than the BAU (e.g. due to high internal energy consumption of the CCS equipment), leakage shall be quantified for the displaced provisioning of the marginal energy or material.&#x20;

### Indirect land use change

Sites that use any fraction of biomass input that derives from oil palm plantations and soybean cultivation are ineligible due to the [high risk](#user-content-fn-20)[^20] of indirect land-use change (iLUC) associated to this feedstock type.

In addition to proving compliance with the sustainability criteria, and proving that biomass is not associated with high iLUC risk, Project Developers shall conduct the following iLUC leakage assessments for any biomass types used:

* This leakage source is **considered negligible** for biomass from invasive species, municipal solid waste, municipal sludge and animal waste.
* This leakage source is **considered mitigated** for biomass from **marginal energy crops**, because they are marginal by definition and do not compete for land use with food and feed crops.
* **Forestry and agro-food waste:** the project's demand may create a new or significantly expanded market for those residues, incentivizing changes in primary land use or management decisions that generate indirect land use change emissions. This leakage source is considered mitigated and no further requirements apply if Project Developers demonstrate that

  * they did not pay for the biomass, or&#x20;
  * they were paid to handle the biomass, or
  * residue sales do not exceed 50% of the feedstock supplier's revenues. Project Developers shall assess the **relative income of the feedstock supplier from residue sales** to the BioCCS project using farm records or analysis of [secondary data](#user-content-fn-21)[^21].

  If none of these criteria can be demonstrated, the leakage source shall be quantified on a case-by-case basis, and added to the project emissions.
* **Primary energy crops**. Leakage caused by indirect land use change shall be quantified on a case-by-case basis, and added to the project emissions.

Where applicable, iLUC leakage shall be quantified according to the rules set out in the  [Quantification of iLUC emissions](/~/changes/229/methodologies/biogenic-carbon-capture-and-storage-bioccs/ghg-quantification.md#quantification-of-indirect-land-use-change-emissions) section.&#x20;

## Monitoring <a href="#snhouoxhyrzi" id="snhouoxhyrzi"></a>

Monitoring Plans for this module shall include, but are not limited to, tracking of the following information **for each monitoring period**:

{% tabs %}
{% tab title="Segregated CO2 streams" %}
**For** [**segregated streams**](#user-content-fn-22)[^22]:

Biomass assessment evaluating&#x20;

* [Environmental and Social Safeguards: Biomass sustainability](#biomass)

Carbon storage measurements

* fraction of eligible CO<sub>2</sub> in captured stream&#x20;
* mass or volumetric flow, density, pressure and temperature of injected stream
* concentration of CO<sub>2</sub> in injected stream
* fraction of eligible CO<sub>2</sub> sent for permanent carbon storage under this methodology ($$F\_{RCC}$$)

GHG quantification

* economic allocation fraction and emissions associated with CO<sub>2</sub> generation (for greenfield projects, only)
* amount of biomass sourced in addition to the baseline and associated emissions (for retrofit projects, only) &#x20;
* amount and type of fuel, energy, chemicals and other inputs used by capture processes
  * amount of energy used internally by capture process, i.e. parasitic load and associated emissions (if applicable)&#x20;
* for transportation via pipeline networks, per segment:
  * distance CO<sub>2</sub> traveled in pipeline network&#x20;
  * amount and type of fuel or energy used by the pipeline network&#x20;
* for transportation via road, rail or ship, per segment:
  * distance traveled, weight of CO<sub>2</sub> transported and type of vehicle, or
  * amount and type of fuel consumed, type of vehicle and number of trips
* amount and type of fuel or energy used by stationary transport processes
* amount and type of fuel or energy used by storage processes
* embodied emissions from infrastructure

Proof of delivery

* for transport via pipeline: amount of CO<sub>2</sub> fed into pipeline system
* for transport via container (rail, road, ship): amount of CO<sub>2</sub> delivered to storage site&#x20;

Co-benefits
{% endtab %}

{% tab title="Non-segregated CO2 streams" %}
**For** [**non-segregated streams**](#user-content-fn-23)[^23]**:**

Biomass assessment evaluating&#x20;

* [Environmental and Social Safeguards: Biomass sustainability](#biomass)

Carbon storage measurements

* fraction of eligible CO<sub>2</sub> in captured stream
* mass or volumetric flow, density, pressure and temperature of captured stream
* concentration of CO<sub>2</sub> in captured stream
* amount of CO<sub>2</sub> lost during transport stage&#x20;
* amount of CO<sub>2</sub> lost during storage stage
* fraction of eligible CO<sub>2</sub> sent for permanent carbon storage under this methodology ($$F\_{RCC}$$)

GHG quantification

* economic allocation fraction and emissions associated with CO<sub>2</sub> generation (for greenfield projects, only)
* amount of biomass sourced in addition to the baseline and associated emissions (for retrofit projects, only) &#x20;
* amount and type of fuel, energy, chemicals and other inputs used by capture processes
  * amount of energy used internally by capture process, i.e. parasitic load, and associated emissions (if applicable)&#x20;
* allocation fraction for facility emissions, if applicable&#x20;
* amount and type of fuel, energy, chemicals and other inputs used by capture processes
* for transportation via pipeline networks, per segment:
  * distance CO<sub>2</sub> traveled in pipeline network&#x20;
  * amount and type of fuel or energy used by the pipeline network&#x20;
* for transportation via road, rail or ship, per segment:
  * distance traveled, weight of CO<sub>2</sub> transported and type of vehicle, or
  * amount and type of fuel consumed, type of vehicle and number of trips
* amount and type of fuel or energy used by stationary transport processes
* amount and type of fuel or energy used by storage processes

Proof of delivery

* for transport via pipeline: amount of CO<sub>2</sub> fed into pipeline system
* for transport via container (rail, road, ship): amount of CO<sub>2</sub> delivered to storage site

Co-benefits
{% endtab %}
{% endtabs %}

Monitoring Plans for this module shall also include updated leakage assessments at least once every 5 years.

Monitoring Plans shall include the following information for each monitored parameter:

* monitoring frequency
* emission sources and sinks
* data source
* measurement methods/procedures, and their accuracy and calibration
* quality assessment or quality control procedures
* responsible party for collecting and archiving data

[^1]: often defined as *active/maximum monitoring area,* usually upon to 1 km around maximum CO2 plume extension.

[^2]: The Project Developer must submit a **Cancelation Notice** to notify Rainbow within **30 calendar days** of becoming aware of the reversal event.

[^3]: An accounting construct to delineate which fraction of biomass is used for what purpose:

    * baseline vs additional biomass (retrofit)
    * biomass allocated to CO<sub>2</sub> generation vs allocated to bioenergy generation (greenfield)

    Further information in the [Biomass fractions ](https://app.gitbook.com/o/zK7HMMBIcwhOSDhxzqPO/s/E1FUJsBoIj20nqp3CtMf/~/edit/~/changes/229/methodologies/biogenic-carbon-capture-and-storage-bioccs/eligibility-and-scope#biomass-fractions)section.

[^4]: collected from forest land

[^5]: Equivalent certificates shall at least cover

    * Legal and transparent chain of custody
    * Proper forest regeneration
    * Safeguarding biodiversity and soil health
    * Historically stable or increasing forest carbon stocks
    * Sound socio-environmental practices in forestry operations⁠

[^6]: A continuous geographic area from which biomass is harvested, with similar ecological characteristics (e.g. species composition and biodiversity) as defined by the relevant regional authorities. Definition from Carbon Direct's Guide to Sustainable Biomass Sourcing (2025). [URL](https://www.carbon-direct.com/research-and-reports/2025-guide-to-sustainable-biomass-sourcing)

[^7]: An average calculated using the most recently available data over a defined period (here, 10 years).

[^8]: Land-use, land-use change and forestry: A sector of national greenhouse gas inventories, as reported to the UNFCCC, that accounts for carbon stock changes and GHG emissions and removals resulting from land use and land management activities. A net negative LULUCF value indicates that the land sector is functioning as a net carbon sink

[^9]: forests and grasslands as identified by the relevant competent authority

[^10]: wetlands, peatlands, primary forests and forests

[^11]: Carbon dioxide removal

[^12]: The [Carbon Removal Carbon Farming](https://eur-lex.europa.eu/eli/reg/2024/3012/oj/eng) (CRCF) Regulation is a regulatory framework established by the European Union to certify high-quality carbon removals. For projects certified under the CRCF, additional requirements apply.&#x20;

[^13]: The facility has started operating not more than one year before the start of the BioCCS project.

[^14]: Full converion from fossil to biomass use not more than one year before the start of the BioCCS projects.&#x20;

[^15]: The *nameplate energy generation capacity* is the maximum theoretical (power) output of a facility, determined by the operator and registered with authorities. The actual output can be different.&#x20;

[^16]: A change in biomass source is considered e.g. when sourced from a different geographic area, land use or waste management context. A change in supplier alone does not constitute a change in source.

[^17]: biomass feedstock consumed in the 3 years prior to retrofitting.

[^18]: damaged trees, or trees removed for planned forest management such as preventing disease spread or fires

[^19]: See sustainability criteria for forestry waste:\
    \
    Official documentation from a competent governmental authority confirming the necessity of tree removal, stating the forest health objective (such as fire risk reduction, pest control, or disease containment), together with chain-of-custody records linking the biomass to the designated intervention area.

[^20]: This definition is adopted from the EU's Renewable Energy Directive (RED III). [URL](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A02018L2001-20240716)

[^21]: e.g. regional market prices and agricultural statistics

[^22]: A CO2 stream that is at all times separated from CO2 from other sources.

[^23]: A CO2 stream that is mixed with CO2 streams from other sources at any point after leaving the capture site.


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