PCS CN 005 Evidence Sufficiency_v1.0

Document Control

Document identification

• Document code: PCS-CN-005

• Title: Evidence Sufficiency

• Applies to: All PCS submissions where evidence thresholds and auditability are assessed

• Purpose: Clarifies minimum expectations for evidence quality, traceability, and sufficiency to support validation and verification conclusions

Version history and change log

Table DC-1. Revision history

Version	Date	Status	Summary of changes	Issued by	Approved by
v1.0	TBD	Draft	Release for public consultation	PCS	TBD

Governance note on versioning and archiving

Only the latest approved version of this Clarification Note shall be used. Superseded versions shall be archived and retained for traceability and audit purposes, consistent with PCS governance rules.

Chapter 1 - Purpose and Context

1

1. This Clarification Note defines how evidence sufficiency, data gaps, and conservative defaults are to be interpreted and applied under the Planetary Carbon Standard.

2

1. Its purpose is to ensure consistent, conservative, and predictable treatment of incomplete, uncertain, or variable data across PCS methodologies and tools. It clarifies when evidence is considered sufficient, how missing or weak data must be treated, and when conservative defaults or exclusions are required.

3

1. This clarification does not introduce new monitoring or reporting requirements. It clarifies the correct application of existing evidentiary and conservativeness principles embedded in PCS methodologies and tools.

Chapter 2 - Evidence Sufficiency

1

1. Evidence under the Planetary Carbon Standard is considered sufficient where it is relevant, representative, verifiable, and directly supports the parameter or claim to which it is applied. Evidence must be adequate to allow independent reconstruction of calculations and verification of assumptions without reliance on interpretation beyond the documented material.

2

1. Sufficient evidence must correspond to the monitoring period, project boundary, and operational conditions for which credit issuance is requested. Evidence generated outside the monitoring period may be used only where continued representativeness is demonstrated and no material changes have occurred.

3

1. Evidence that is partial, indirect, or weak may be acceptable only where conservative interpretation is applied and where such evidence does not increase credited quantities. Where sufficiency cannot be demonstrated, affected quantities must be conservatively adjusted or excluded from crediting.

4

1. Evidence sufficiency is assessed per parameter and per monitoring period. Sufficiency for one parameter does not imply sufficiency for others, and sufficiency in one period does not automatically extend to subsequent periods.

Chapter 3 - Conservative Defaults

3.1 Purpose of Conservative Defaults

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1. Conservative defaults are applied under the Planetary Carbon Standard to ensure environmental integrity where project-specific evidence is incomplete, uncertain, or unavailable. Defaults are not a substitute for evidence, but a protective mechanism to prevent over-crediting in the presence of uncertainty.

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1. The application of conservative defaults reflects a precautionary approach and does not imply equivalence to site-specific or measured data.

3.2 Hierarchy of Data Sources

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1. Where parameters are required for quantification or eligibility assessment, data sources must be applied according to a hierarchy that prioritizes specificity and reliability. Project-specific measured data is preferred where it is robust and representative. Where such data is unavailable or insufficient, nationally applicable values may be used if relevant. PCS-defined defaults apply only where higher-tier data cannot be demonstrated to be sufficient.

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1. Projects may not bypass higher-tier data in favor of defaults where suitable project-specific evidence is available.

3.3 Conditions for Use of Defaults

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1. Defaults may be used only where project proponents demonstrate that: the required parameter cannot be reliably determined using project-specific evidence for the monitoring period, and the selected default represents a conservative assumption relative to plausible project conditions.

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1. Defaults must not be used to compensate for avoidable data gaps or to defer evidence generation to future monitoring periods.

3.4 Conservative Direction of Defaults

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1. Where multiple default values are available, the most conservative value must be applied. Conservativeness is defined as the option that results in lower credited quantities or more restrictive eligibility outcomes.

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1. Defaults must never be adjusted upward based on project expectations, operational intent, or unverified assumptions.

3.5 Interaction with Caps and Safeguards

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1. Where PCS methodologies or tools apply caps, thresholds, or automated safeguards, defaults must be applied within those constraints. Defaults do not override caps, nor do caps justify the upward adjustment of defaults.

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1. Where default values exceed applicable caps, the capped value must be applied.

3.6 Documentation and Transparency

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1. The use of conservative defaults must be clearly documented in monitoring reports and tool inputs. Documentation must identify the parameter affected, the default applied, the reason project-specific data was not used, and confirmation that the default represents a conservative assumption.

Failure to disclose the use of defaults constitutes a non-conformance.

3.7 Transition from Defaults to Measured Data

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1. Where projects transition from defaults to measured or project-specific data in subsequent monitoring periods, such transitions must not retroactively affect previously credited quantities.

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1. Measured data replacing defaults must be applied conservatively and must be demonstrably representative of the new monitoring period.

Chapter 4 - Treatment of Data Gaps

4.1 Definition of Data Gaps

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1. A data gap exists where required information for eligibility assessment, quantification, or verification is missing, incomplete, or not demonstrably representative of the monitoring period. Data gaps may arise from absent measurements, insufficient sampling, inconsistent records, or loss of traceability.

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1. The existence of a data gap is assessed with respect to the specific parameter and monitoring period for which credit issuance is requested.

4.2 General Treatment Principle

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1. Where data gaps exist, the Planetary Carbon Standard requires conservative treatment. Data gaps must not result in higher credited quantities, relaxed eligibility conditions, or deferred compliance.

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1. Where a data gap cannot be conservatively resolved, the affected quantities are not eligible for crediting for the monitoring period.

4.3 Material and Non-Material Data Gaps

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1. Data gaps are considered material where they could affect eligibility, credited quantities, or environmental integrity. Non-material data gaps may be accepted where they do not influence quantification outcomes or compliance conclusions.

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1. Materiality must be assessed conservatively. Where doubt exists, the data gap must be treated as material.

4.4 Prohibition of Reconstruction and Backfilling

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1. Missing data must not be reconstructed using assumptions, proxy values, or later-period measurements where such reconstruction would increase credited quantities. Backfilling of missing data using favorable assumptions or extrapolated trends is not permitted.

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1. Where reconstruction is unavoidable for operational continuity, it must be conservative and must not increase credited outcomes relative to exclusion.

4.5 Temporal Mismatch and Carry-Over

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1. Data from outside the monitoring period may not be used to fill data gaps unless continued representativeness is demonstrated and no material changes have occurred. Temporal carry-over of data must be justified and must not result in optimistic assumptions.

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1. Where representativeness cannot be demonstrated, the data gap must be conservatively treated.

4.6 Interaction with Defaults

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1. Where defaults are used to address data gaps, such defaults must be conservative and applied strictly in accordance with Chapter 3. Defaults must not be used where the absence of data reflects non-compliance with monitoring requirements.

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1. Repeated reliance on defaults for the same parameter may trigger findings of non-conformance.

4.7 Documentation of Data Gaps

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1. All data gaps and their treatment must be explicitly documented in monitoring reports and tool inputs. Documentation must identify the parameter affected, the reason for the data gap, and the conservative treatment applied.

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1. Undisclosed data gaps constitute a material non-conformance.

Chapter 5 - Verification Expectations

5.1 Scope of Verification

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1. Validation and verification bodies shall assess evidence sufficiency, use of defaults, and treatment of data gaps as part of the conformity assessment for eligibility, quantification, and issuance. Verification shall focus on whether conservative treatment has been applied wherever evidence is incomplete, uncertain, or variable.

5.2 Assessment of Evidence Sufficiency

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1. Verification bodies shall determine whether submitted evidence is relevant, representative of the monitoring period, and adequate to support the parameter to which it is applied. Evidence that is indirect, partial, or weak shall not be accepted where it increases credited quantities.

2

1. Where evidence sufficiency cannot be demonstrated, verification bodies shall require conservative adjustment or exclusion of affected quantities.

5.3 Review of Default Application

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1. Verification bodies shall confirm that defaults are used only where permitted, are applied in accordance with the prescribed data hierarchy, and represent conservative assumptions. Defaults shall not be accepted where project-specific data could reasonably have been generated.

2

1. Any upward adjustment of defaults or selective use of non-conservative values constitutes a non-conformance.

5.4 Evaluation of Data Gaps

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1. Verification bodies shall identify data gaps and assess their materiality. Material data gaps that cannot be conservatively resolved shall result in exclusion of affected quantities for the monitoring period.

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1. Verification bodies shall not accept reconstruction, backfilling, or extrapolation where such practices increase credited outcomes.

5.5 Consistency and Repeat Use

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1. Repeated reliance on defaults or recurring data gaps for the same parameter across monitoring periods shall be treated as an indication of inadequate monitoring. Verification bodies may require corrective action to restore compliance.

5.6 Documentation of Findings

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1. Verification reports shall clearly document findings related to evidence sufficiency, default use, and data gaps, including any conservative adjustments required. Such documentation must allow independent understanding of how verification conclusions were reached.

Chapter 6 - Final Provisions

1

1. This Clarification Note provides the authoritative interpretation of evidence sufficiency, conservative default application, and treatment of data gaps under the Planetary Carbon Standard. It confirms that crediting outcomes must not increase where evidence is incomplete, uncertain, or non-representative.

2

1. Nothing in this Clarification Note modifies eligibility criteria, quantification equations, monitoring requirements, or governance provisions established under applicable PCS methodologies and tools. It clarifies their correct interpretation and application.

3

1. This Clarification Note enters into force on the date of publication and applies to all relevant projects and verification activities from that date onward, subject to PCS transitional provisions.