124065 O5 Attachment B - QAPP.docx

QAPP Short Title:

NDEE CPRG IMPLEMENT. QAPP

A. Project Management and Information/Data Quality ObjectivesRequest for Proposal Number 124065 O5 - Attachment B Note: As the measure has developed, several terms and structural elements originally described below have changed. A few include: "Data Bank" replaces "Registry," "NDWEE" replaces "NDEE," and the Governor's Water Quality and Quantity Task force replaces the Governing Council.

A1. Title Page

NEBRASKA DEPARTMENT OF ENVIRONMENT AND ENERGY

Quality Assurance Project Plan for the

CLIMATE POLLUTION REDUCTION IMPLEMENTATION GRANT PROGRAM

Grant # 96718301 Revision 1.0

Prepared by:

Nebraska Department of Environment and Energy 245 Fallbrook Blvd.

P.O. Box 98922 Lincoln, NE 68509-8922 Prepared for:

US EPA Region 7 11201 Renner Blvd.

Lenexa, KS 66219

Period of Applicability: October 1, 2024 through September 30, 2029 April 29, 2025

A2. Approval Page

APPROVALS:

QAPP Revision History

A3. Table of Contents

D. Environmental Information Review and Usability ………………………………………………………………………….. 16

Addendum 8 – Anaerobic Digester/Biogas Hub Program …….……………………………………………………………. 82

List of Figures and Tables

A4. Program Purpose, Problem Definition, and Background This EPA Climate Pollution Reduction Implementation Grant provides the Nebraska Department of Environment and Energy (NDEE) with funding to implement voluntary, incentive-based priority measures designed to reduce greenhouse gases and other air pollutant emissions and/or to sequester carbon. The program covered by this Quality Assurance Project Plan will implement the eight incentive programs listed below:

1. Irrigation Engine Program

2. Residential Pre-Weatherization Program

3. Biochar Program

4. Non-Residential Energy Efficiency Program

5. Rural Community Solar Program

6. Non-Residential Solar Program

7. Ag Registry and Grants Program

8. Anaerobic Digester/Biogas Hub Program These programs are to be implemented and completed by September 30, 2029.

The primary purpose for each of these programs is to reduce emissions of greenhouse gases and/or to sequester carbon. Ancillary objectives are to reduce emissions of other air pollutants. The primary performance metric is thus the accurate determination of emissions reductions for each project and program. Accurate determinations will depend upon valid input data and defensible methodology for calculating emissions reductions. In addition, each program will need sound management practices and documentation to insure proper use of the grant funds.

Each of the incentive programs will fund a different type of voluntary project to reduce greenhouse gases. Some programs will include subawards to third parties to administer program funds. As a result, each program will have a unique project structure, set of tasks, information, and calculation methodologies specific to that type of activity. Therefore, this Quality Assurance Project Plan includes a separate addendum for each program to describe the specific tasks, decisions, and quality assurance measures for that program. Any project outside the scope of this document and its addenda would require a separate, stand-alone Quality Assurance Project Plan.

A5. Project Task Description The project tasks covered by this plan will take place between October 1, 2024 and September 30, 2029, with schedules varying for each program. The project tasks and schedule for each program are described in the specific program addendum. All projects will include semiannual grant reporting to EPA in April and October.

NDEE will review this Quality Assurance Project Plan annually as programs are implemented and make any changes needed as program circumstances dictate.

A6. Information/Data Quality Objectives and Performance/Acceptance Criteria The programs funded through this grant offer financial incentives to outside entities to undertake specific projects or activities to reduce emissions of greenhouse gases and other pollutants and/or to sequester carbon. Data and information collected from applicants and participants will be used:

· to determine applicant eligibility

· to verify financial transactions and proper completion of projects

· as input to calculations or models to determine emissions reductions.

Specific quality objectives and criteria for each program in this grant will be detailed in the appropriate addendum. General principles that apply to all programs are summarized below.

· NDEE will ensure that data and information collected from applicants and participants are submitted via signed forms and substantiated by documentation to the extent possible.

· NDEE will ensure that project expenses are substantiated via invoices and financial documents demonstrating proof of project completion and payment.

· NDEE will ensure that information used as inputs to emission reduction calculations are substantiated by EPA-approved data and emission factors or widely-accepted industry standards, equipment manufacturer specifications, or EPA, DOE, or USDA energy modeling.

· NDEE will ensure that emissions reduction determinations are made using tools or models approved by EPA, DOE, or USDA, or calculations that follow other widely-accepted national or international standards.

· NDEE will ensure that environmental measurements and data gathered by program participants are representative, complete, comparable, and accurate, as demonstrated by documentation of data sources and methods. These programs will not include repeated measurements under identical conditions, so precision and sensitivity will not apply in most cases.

A7. Distribution List This section presents the primary supervisory staff who will oversee the program and will be serving to implement the Quality Assurance Project Plan. The listing in Table 1 includes staff responsible for implementing independent internal quality management steps and EPA staff serving in external oversight roles.

Measure-specific distribution lists will be presented in the addendum for each specific measure program to be carried out under this grant program.

This QAPP will be distributed to the staff listed in Table 1. Additionally, this QAPP will be provided to any unlisted staff and subawardees who are assigned to perform work under this program. A secured copy of this QAPP will be maintained in the project files under the directory N:Grants Section/CPRG_Implementation/Quality_Management.

Table 1. QAPP Distribution List

A8. Project Organization

The primary personnel responsible for implementation of this project are the NDEE Project Manager (PM), Task Leaders (TLs), and the Quality Assurance Manager (QAM). Their duties are outlined briefly in this section. This Quality Assurance Project Plan will be maintained by Randy Smith, Environmental Specialist II in the Planning and Aid Division.

The NDEE PM is responsible for NDEE’s technical and financial performance as well as maintaining communications with the EPA to ensure mutual understanding of grant requirements, EPA expectations, and conformity with EPA quality procedures; managing oversight and conduct of project activities including allocation of resources to specific tasks; ensuring that quality procedures are incorporated into all aspects of the project; developing, conducting, and/or overseeing QA plans as necessary; ensuring that any corrective actions are implemented; operating project activities within the documented and approved Quality Assurance Project Plan; and ensuring that all products delivered to the EPA are of specified type, quantity, and quality.

The ONE RED Section Supervisor will be designated as the PM when that position is created and filled. The Section Supervisor will report to Sarah Starostka, Planning and Aid Division Administrator, who is currently serving as the PM. The Division Administrator reports to Kara Valentine, the Environmental Deputy Director with oversight of the Planning and Aid Division and the Inspection and Compliance Division. The Deputy Director reports to the Department Director.

NDEE will designate a Task Leader (TL) for each of the eight programs funded by this grant. Each TL will work with the PM to develop administrative and quality assurance procedures. After programs are in operation, the TL will be responsible for day-to-day activities, including planning, reporting, and controlling technical and financial resources associated with the task by the PM. Accordingly, each TL is primarily responsible for implementing the Quality Program and this Quality Assurance Project Plan on task-level assignments.

The agency QA Manager, Mark Lohnes, is responsible for overseeing the program quality system, monitoring, and facilitating QA activities on tasks, and generally helping the NDEE PM and TLs understand and comply with EPA QA requirements. At the request of the NDEE PM, Mr. Lohnes is responsible for conducting periodic independent audits of this project’s QA program, and he will produce written documentation of the audit results and recommendations. He has authority to discuss these results and recommendations with the Deputy Director and Director as necessary. He will work closely with the PM and Task Leaders to improve any deficiencies noted during these audits.

A9. Project Quality Assurance Manager Independence The QA Manager is employed by NDEE’s Emergency Response section, which is in a separate division (Management Services) from NDEE’s Planning and Aid Division. The QA Manager is independent of the environmental information operations of these grant activities.

A10. Project Organization and Communications Chart The overall organization of the grant activities is shown in Figure 1. Each of the eight programs funded through this grant will have its own internal organization. The addendum for each program will include a description of the program organization and an organization schematic if necessary.

Figure 1. Project Organization Chart

NDEE

Department Director Jesse Bradley (Interim)

NDEE

Deputy Director of Administration Kevin Stoner

NDEE

Deputy Director Kara Valentine

U.S. EPA

Project Officer or Project Officer’s Representative Ashley Eichman

U.S. EPA

Quality Assurance Officer Diane E. Harris

Planning and Aid Division Administrator Sarah Starostka (Current Project Manager)

Quality Assurance Manager Mark Lohnes

ONE RED Section Supervisor Future Position (Future Project Manager)

NDEE Staff Programs 1, 4, & 8

NDEE

Program Task Leaders Programs 1 - 8

Subawardees Programs 2, 3, 4, 5, 6, & 7

Legend Line of reporting Communication

A11. Personnel Training/Certification All NDEE staff assigned to these programs will have appropriate technical and QA training to properly perform their assignments. The Department Quality Assurance Manager and the staff member assigned to maintain this QAPP have completed the EPA Region 7 training program in Quality Project and Program Management.

The NDEE Quality Assurance Manager will be responsible for ensuring personnel conducting environmental information operations are qualified, trained, and experienced. All task leaders will be required to complete the EPA Region 7 training program in Quality Project and Program Management. The Quality Assurance Manager will be responsible for documenting completion of QA training.

If technical training is required for staff, the PM in coordination with the associated TL will identify available training resources for that program and incorporate the required training into the project schedule. Details of appropriate technical training for each task is outlined in each program addendum.

A12. Documents and Records All environmental information submitted by program participants (via project applications, reports, and reimbursement requests) will be maintained in the program files and databases. Grant documents (applications, agreements, and reimbursement requests) are archived in the State of Nebraska Electronic Content Management System. Grant-related information is retained by NDEE for 10 years after the completion of the project.

B. Implementing Environmental Information Operations This Quality Assurance Project Plan was developed using the following guidance documents:

· EPA IT/IM Directive No. CIO 2105-S-02.1, Quality Assurance Project Plan Standard (2024)

· EPA Guidance on Technical Audits and Related Assessments for Environmental Data Operations (EPA QA/G-7 Final)

· EPA template TD13_Implement_CPRG_QAPP_Outline_EPA_11-12-24_FINAL

B1. Identification of Project Environmental Information Operations The programs covered by this Quality Assurance Project Plan will carry out projects to reduce emissions of greenhouse gases and other pollutants and/or to sequester carbon. Each program will gather information from program participants on relevant physical parameters or processes and use that information as the basis for determining the magnitude of emissions reductions using approved or widely-accepted data, emission factors, calculations, or models. The addendum for each program describes the specific information and methods relevant to the projects in that program.

B2. Methods for Environmental Information Acquisition Most of the programs in this grant activity will not include sampling or direct measurement of environmental parameters and processes. The addendum for each program describes the specific information and methods relevant to the projects in that program.

B3. Integrity of Environmental Information Most of the programs in this grant activity will not include field sampling or laboratory analyses. Measures to ensure the integrity of environmental information provided by program participants are described in the addendum for each program.

B4. Quality Control NDEE will ensure that data and information collected from applicants and participants are submitted via signed forms and substantiated by documentation to the extent possible. Information regarding physical parameters or processes will be substantiated via EPA-approved data, equipment manufacturer specifications, usage records, or EPA and/or DOE modeling methods. NDEE will periodically review submitted data for consistency. Quality control measures specific to each program are described in the addendum for each program.

B5. Instrument/Equipment Calibration, Testing, Inspection, and Maintenance NDEE staff conducting direct collection or measurement of environmental information are required to follow manufacturer guidelines for calibration, regular inspection, and maintenance of any instruments and equipment. The Department’s agreements with subawardees will include the same requirement.

B6. Inspection/Acceptance of Supplies and Services NDEE staff using instruments for direct collection of environmental information are required to ensure that all replacement parts and supplies meet or exceed manufacturer’s specifications. The Department’s agreements with subawardees will include the same requirement.

B7. Environmental Information Management The Department will contract with an enterprise grant management system provider (StreamLink Software Inc. DBA AmpliFund) to develop and implement a grant application portal and document management system for each of the programs covered by this Quality Assurance Project Plan. NDEE will work with the vendor in the design of application interfaces, user training, and reporting requirements for each program. The design phase will be followed by configuration and testing of all program portals by AmpliFund and NDEE staff to ensure compliance with program requirements, detect and correct errors, and prevent information loss in data input, storage, or reporting. Prior to deployment, AmpliFund will conduct user training and provide relevant training assets, including user guides, pre-recorded standard trainings available through the portal, and recordings of live trainings provided to Department staff. The Department will own all data, information, and materials submitted to the portal.

The grant management system will be hosted in the State of Nebraska Single Tenant Microsoft Azure cloud environment. Microsoft Azure provides a cloud environment specifically designed to meet strict security and compliance requirements. Hosting on the Microsoft Azure cloud provides AmpliFund with high availability, scalability, and compliance, as well as a secure platform-as-a-service environment.

AmpliFund maintains an organization-wide information security program and has policies and procedures in place to ensure the availability, security, confidentiality, and privacy of AmpliFund systems and client data stored and managed within AmpliFund. AmpliFund is compliant with the Service Organization Controls (SOC) 2 audit standards governed by the American Institute of Certified Public Accountants (AICPA) that examine an organization’s controls that protect and secure its system or service used by customers or partners.

Key AmpliFund security policies include:

· Network Security Measures through Azure services (Application Gateways, Web Application Firewalls, and SQL Server Advanced Data Security and Advanced Threat Protection)

· Annual external security audits by external security firms

· Information, system, and software Backup

· Disaster recovery

· Access Control

· Encryption of all data in transit and at rest

· Change management

· Privacy

NDEE will develop (or have a contractor develop) a central database to serve as the final data storage/repository for the projects. This database will allow entry of and access to the information and factors used in emissions reduction calculations, the calculation methodology, and to the results of those calculations. NDEE will work with the vendor in the design, configuration, and testing of the database to ensure that it meets program requirements. NDEE will work with Amplifund to develop a system to securely migrate environmental information from the grant portal to the central database.

NDEE will establish procedures to detect and correct errors in data migration, calculations, and reporting to prevent loss of environmental information. Staff members in different subprograms of this grant program will have access to the database to cross-check data and calculations in other subprograms. This central database will be required to incorporate security policies and procedures equivalent to those described above for the Amplifund platform.

C. Assessment, Response Actions, and Oversight C1. Assessments and Response Actions C1.a. Annual Assessments NDEE staff will conduct an annual Audit of Data Quality of all greenhouse gas reduction programs funded by this grant. These audits will be carried out by qualified technical staff members in the Permitting and Engineering Division or in the State Energy Program. The auditors will be staff members not involved in or in close association with the environmental information operations. The audits will determine whether environmental information was accumulated, transferred, calculated, and reported correctly. The questions to be answered by the Audit of Data Quality include:

· Is there sufficient documentation of all procedures used in the data collection effort to allow for repetition of the effort by a person or team with technical qualifications similar to those of the original data collector?

· Is there sufficient documentation to verify that the data have been collected and reported according to these procedures?

· Is enough information provided to allow a potential user to determine the quality and limitations of the data and whether the intended use of the data is appropriate?

· Are the data of sufficient quality with respect to data quality goals and other performance criteria for their intended use?

In conjunction with the Audit of Data Quality, administrative staff in other grant programs in the Planning and Aid Division will review program procedures and project documentation to ensure that proper management measures are in place and have been followed in administration of funds.

The results and findings from both annual assessments will be presented in memos or reports to the Planning and Aid Division Administrator, the Deputy Director overseeing the Planning and Aid Division, the Quality Assurance Manager, and the Deputy Director for Administration.

C1.b. Response Actions If the assessments described above identify deficiencies in any of the greenhouse gas reduction programs, the relevant Task Leader(s) will work with the ONE RED Section Supervisor to update program standard operating procedures and communicate required changes to program staff. The relevant Task Leader(s) will track and document response actions and prepare memos or reports to the Planning and Aid Division Administrator, the Deputy Director overseeing the Planning and Aid Division, the Quality Assurance Manager, and the Deputy Director for Administration.

C2. Oversight and Reports to Management The ONE RED Section Supervisor and Planning and Aid Division Administrator will compile the results and findings from annual assessments and the resulting response actions in a memo or report to the Deputy Director overseeing the Planning and Aid Division, the Quality Assurance Manager, the NDEE Director, and the EPA Region 7 Program Officer. This memo or report will be attached to emails and stored in the Department Quality Assurance archive available to all staff.

D. Environmental Information Review and Usability The quality assurance and assessment activities described above will provide ongoing review of the quality of the indirect information provided by program participants and the data analysis and generation of greenhouse gas reduction estimates by NDEE. At the conclusion of the grant NDEE staff will review all data and calculations undertaken throughout the programs to ensure that all meet the program objectives and are useable for the purpose of the program. This review will evaluate the completeness and correctness of the data and calculations and their compliance with methodological requirements (data verification) and the validity of the data within the framework of the greenhouse gas reduction objectives.

The ONE RED Section Supervisor will prepare a summary of this review, including any noted limitations on useability. This summary will be attached to the Grant Final Report submitted to the EPA Region 7 Project Officer following the conclusion of the grant.

*** ADDENDUMS 1-6 & 8 WERE REMOVED FROM THIS DOCUMENT AS THEY

WERE NOT PERTINENT TO THE AG REGISTRY AND GRANTS PROGRAM. ***

ADDENDUM 7: Ag Registry and Grants Program 7-A. Project Management and Information/Data Quality Objectives 7-A3. Table of Contents 7-A. Project Management and Information/Data Quality Objectives

7-B2.a. Collection of environmental information needed to

7-B2.c. Collection of environmental information to determine emissions reductions

7-A4. Program Purpose, Problem Definition, and Background NDEE will use funds from this grant to establish the Nebraska Ag Registry and Grants Program. This program will provide incentives for a carbon intensity (CI) score registry to foster the widespread adoption of CI scores as a key performance metric for crops and land usage. In parallel, it will initiate community-based programs to encourage adoption of regenerative agriculture practices and provide incentives to farmers to acquire precision agriculture and crop management technology to facilitate adoption of these practices. The increased availability of CI scores in agribusiness, coupled with these programs and incentives, will lead producers towards regenerative agriculture and precision agricultural technologies that minimize nitrous oxide and nitrate emissions, restore soil fertility and moisture levels, and increase carbon dioxide sequestration.

The first component of this three-pronged approach—CI Registry incentives—increases the rate at which growers accept the emergence and management of carbon intensity as a crop performance metric. The second element—regenerative agriculture—provides the framework and principles by which farmers can decarbonize crop production. The third part—precision agriculture technology—enables producers to monitor and verify field and plant performance across the growing season in order to successfully maintain viable yields while reducing emissions, water usage and, at the same time, improving the productive capacity of soil.

As a general principle, “carbon intensity” typically refers to carbon dioxide emissions per joule of energy generated during the production of a raw material within the lifecycle assessment of a finished product. The estimation of CI scores for corn and soybeans has steadily moved towards standardization as a result of the alternative fuels industry. Companies that optimize crop production through precision and regenerative agriculture track and account for the values critical to CI estimates.

The measure proposed here is intended to engage growers and support their understanding and acceptance of carbon intensity as a performance metric and encourage more aggressive adoption of regenerative ag practices using precision technologies and information. This measure acknowledges that there are multiple technical, structural, and economic challenges to effectuating this change and, therefore, empowers every producer to improve their operation within their unique context and circumstances.

The Inflation Reduction Act creates a number of incentives to reduce the carbon intensity of corn and soybeans as feedstocks for alternative fuels. The ability to produce valid CI estimates is converging with the clear evidence that regenerative and precision agriculture directly reduce carbon intensity in row crops while simultaneously improving soil health and reducing co-pollutants.

7-A4.a. Carbon Intensity Score Registry NDEE will engage an outside party (commercial company or non-profit organization) to establish and administer the day-to-day operations of the Nebraska Carbon Intensity Score Registry under the guidance of a governing council consisting of representatives of state government agencies and agricultural organizations and trade groups. The Registry will be designed specifically to serve farmers and will be under Nebraska control, which will allow it to be responsive to local feedback and needs, build trust with farmers, and ensure data privacy.

Farmers will engage third-party service and tech providers to analyze conditions and practices to provide verifiable CI scores. Vendors will apply to the administrative body of the Registry for approval to submit scores on behalf of farmers, with approval contingent on conformance with required data, quality control, and assessment standards. Farmers for whom a CI score is registered will be paid an average of $0.03 per bushel, or the equivalent of $6.00 per acre to provide an initial financial incentive for participation. CI score vendors will also receive an enrollment fee of no more than $500 for the first time they enroll a farming operation in the Registry.

7-A4.b. Regenerative Agriculture Grants Program The Regenerative Agriculture Grants program will award full or cost-share funds to individual producers at the initial stage of implementing practices such as cover crops, no-till, reduced chemical fertilizer, and grazing strategies. The grants will also include the costs of soil benchmarking to assess initial soil conditions and monitor soil health progress. This program will provide financial assistance to reduce the fiscal risk a farmer faces when implementing a change that requires additional equipment, technical support, or documentation. Grant recipients will be required to obtain and register CI Scores for the duration of this program.

The Governing Council of the Nebraska Carbon Intensity Score Registry will designate regenerative practices to be funded that fit the progress of an individual farmer as well as eliminate the barriers to wide-spread implementation. Special care will be taken to ensure that small and medium operations are eligible for funding that reflects the smaller margins and, by extension, the greater challenges they face in any change.

In addition to the grants for individual producers across the state, this award will also fund a community-based Soil Health Education pilot project in south-central Nebraska, followed by expansion to other areas in Nebraska. The innovative pilot project, administered by the nonprofit Nebraska Soil Health Coalition, covers a multi-county area including several low-income disadvantaged community areas. The pilot is based on a three-prong integrated approach that involves the establishment of connections between a stakeholder visioning group, producer-to-producer learning groups, and local educational and demonstration sites relevant to regional producers. This cohesive community-based collaboration will focus on producers, landowners, financial lenders, water providers, health care, urban-rural consumers, policymakers, K-12 education, and other key influencers of sustainability. This group will foster a landscape in which the more typical producer-to-producer learning groups and educational sites will be successful.

7-A4.c. Precision Agriculture Grants Program “Precision Agriculture” refers to the application of water, nutrients, and pest control according to the specific needs of a plant given its genetics, growth stage, and the environment in which it is being cultivated. In practical terms, precision agriculture utilizes soil sampling, satellite imagery, and real-time sensors to track growing conditions. From these data, growers deploy an arsenal of GPS-programmed technologies, advanced equipment designs, and chemically engineered interventions that meet the individualized needs of particular crops and their specific conditions. Computerized crop management systems enable farmers to manage the resulting data streams and schedule irrigation, fertilizer applications, and other interventions.

The Precision Agriculture Grants Program will be administered by the Governing Council of the Nebraska Carbon Intensity Score Registry in a similar manner to the Regenerative Agriculture Grants Program. The Governing Council, in consultation with state agricultural experts, will identify and prioritize suitable technology and systems for advancing sustainable production. The objective of these grants will focus on driving measurable improvements in environmental sustainability, farm profitability, and resilience to climate change. The program will empower farmers to adopt technologies and practices that optimize resource use, reduce emissions, and promote long-term soil health and ecosystem balance. Grant recipients will be required to obtain and register CI Scores for the duration of this program.

7-A5. Project Task Description The tasks addressed for this measure are:

a. Collection of environmental information needed to determine carbon intensity scores for annual crops.

b. Calculation of carbon intensity scores for annual crops.

c. Collection of environmental information to determine emissions reductions from adoption of regenerative agriculture and precision agriculture practices.

d. Calculation of annual and projected emissions reductions for each project.

Project Schedule

· Issue a subaward to the Nebraska Soil Health Coalition for Regenerative Agriculture Educational Hub staffing and work.

· Issue a Request for Proposals to select a commercial or nonprofit organization to administer the Carbon Intensity Score Registry.

· Recruit and convene the Governing Council for the program.

July – September

· Subaward agreement or contract finalized for Registry administrator.

· Registry administrator institutes open bidding process to subcontract for CI Score Registry development: database design, web platform, cyber-security, and marketing.

· Governing Council and NDEE ratify Registry policies and procedures and develop guidelines for grant programs.

October-December

· CI Score Registry and Grant Program marketing and education program begins.

· CI Score Registry development continues.

· Registry administrator opens vetting of third-party vendors to be approved for submission of CI Scores.

· CI Score Registry testing begins.

· Applications for Regenerative and Precision Ag grants received, reviewed, and funded on a rolling basis or annually until funds spent.

· NDEE conducts annual data quality audits on registry data

7-A6. Information/Data Quality Objectives and Performance/Acceptance Criteria The data quality objectives of this program are:

a. Ensure that environmental information collected for the purpose of determining emissions reductions are valid and documented to the extent possible.

b. Ensure that environmental measurements and data gathered by program participants are representative, complete, comparable, and accurate, as demonstrated by documentation of data sources and methods.

c. Ensure that calculations of emissions reductions utilize EPA-approved data and emission factors, or industry-accepted standards.

7-A7. Distribution List See Table 1, QAPP Distribution List in section A7.

7-A8. Project Organization

Day to day operations of this program will be carried out by the Task Leader.

7-A9. Project Quality Assurance Manager Independence The QA Manager is employed by NDEE’s Emergency Response section, which is in a separate division (Management Services) from NDEE’s Planning and Aid Division. The QA Manager is independent of the environmental information operations of these grant activities.

7-A10. Project Organization and Communications Chart The organization of the Ag Registry and Grants Program personnel is shown in Figure 7-1. The organization above the levels of the NDEE Planning and Aid Division Administrator and NDEE Quality Assurance Manager are diagramed in Figure 1.

Figure 7-1. Ag Registry and Grants Program Organization ChartNDEE Planning and Aid Division Administrator Sarah Starostka (Current Project Manager)

NDEE

ONE RED Section Supervisor New Position (Future Project Manager)

NDEE

Quality Assurance Manager Mark Lohnes

Ag Registry and Grants Program Task Leader (To be Determined)

Subawardees/Contractors Nebraska Soil Health Coalition Registry Administrator (TBD) CI Score Providers

Legend Line of reporting Communication

7-A11. Personnel Training/Certification All NDEE staff assigned to this program will have appropriate technical and QA training to properly perform their assignments.

7-A12. Documents and Records

See Section A12.

pg. 1

7-B. Implementing Environmental Information Operations

7-B1. Identification of Project Environmental Information Operations The environmental information operations addressed here are:

a. Collection of environmental information needed to determine carbon intensity scores for annual crops.

b. Calculation of carbon intensity scores for annual crops.

c. Collection of environmental information to determine emissions reductions from adoption of regenerative agriculture and precision agriculture practices.

d. Calculation of annual and projected emissions reductions for each project.

7-B2. Methods for Environmental Information Acquisition 7-B2.a. Collection of environmental information needed to determine carbon intensity scores for annual crops.

Producers will contract with third-party vendors (agronomists/crop consultants that have been approved by the administrative body of the Carbon Intensity Score Registry as outlined in item 7-A4.a) to collect environmental data needed to determine carbon intensity scores. These input data include field size, crop yield, energy/fuel usage, fertilizer/chemical types and application rates, management practices (e.g. cover crop, tillage, and manure application), and soil organic carbon. Vendors will follow standard industry and Natural Resource Conservation Service practices to collect these data for individual producers.

7-B2.b. Calculation of carbon intensity scores for annual crops.

To calculate CI scores for annual crops, approved vendors must agree to use the most recent version of the Feedstock Carbon Intensity Calculator (FD-CIC) created by the U.S. Department of Energy’s Argonne National Laboratory. The FC-CIC is an extract of the Greenhouse gases, Regulated Emissions, and Energy Use in Technologies (GREET) life-cycle assessment model for renewable fuel production, which is a standard model adopted in the United States for calculating carbon intensity. The FC-CIC is a federally-approved, transparent, easy-to-use tool (available in Microsoft Excel) to calculate crop-specific farm level carbon intensity scores. The calculator accounts for emissions from farming inputs and on-farm energy consumption, nitrous oxide emissions from nitrogen inputs, and soil organic carbon sequestration. Using these inputs, FC-CIC calculates greenhouse gas emissions as grams of carbon dioxide equivalents per bushel of crop yield. Use of the FC-CIC will standardize calculation of CI scores across all projects in this program.

The current version of the FC-CIC is documented in ANL/ESD-21/12 Rev. 2, Feedstock Carbon Intensity Calculator (FD-CIC) Users’ Manual and Technical Documentation, November 2023, available online at https://www.osti.gov/biblio/2205308.

7-B2.c. Collection of environmental information to determine emissions reductions from adoption of regenerative agriculture and precision agriculture practices.

Applicants for Regenerative and Precision Agriculture grants will be required to provide baseline data on their farming inputs and practices that can be used in the FD-CIC model to calculate a baseline carbon intensity. Grant recipients will be required to have vendors employ industry-standard practices to gather the data and information needed determine to determine GHG emissions and carbon intensity.

7-B2.d Calculation of annual and projected emissions reductions for each project.

All participants in the CI Score Registry, including recipients of Regenerative and Precision Agriculture grants, will register carbon intensity scores and GHG emissions data with the Registry. It is expected that the combination of these strategies will lead to millions of acres being repeatedly registered with baseline and updated CI scores over the five-year period. The supporting date supplied with each CI score will ensure that emission reductions for particular fields and crops can be tracked over time along with impacts from shifts in production management practices.

7-B3. Integrity of Environmental Information Sampling and handling of soils to determine nutrient status and organic carbon content will use procedures and methods described in the University of Nebraska-Lincoln Extension, Institute of Agriculture and Natural Resources NebGuide G1740, Guidelines for Soil Sampling, which is available online at https://extensionpubs.unl.edu/publication/g1740/2007/pdf/view/g1740-2007.pdf. Testing and analysis of soil samples must be carried out by a reputable laboratory using credible standard procedures and methods.

Contractors providing CI scores to farmers will be required to assure the security and privacy of the producer data prior to and during submission to the Registry. The administrator of the CI Score Registry will be required to ensure data privacy compliance with relevant regulations (e.g., GDPR, CCPA, or applicable federal/state regulations) to protect farmers’ confidential information and to implement robust cybersecurity measures to protect sensitive data, including encryption of both in-transit and at-rest data.

7-B4. Quality Control The Carbon Intensity Score Registry will promote standardized data collection methods for farm input data for calculation of carbon intensity, ensuring consistency and accuracy across Nebraska's farms. The Registry will require CI score vendors to apply for approval to log scores. To obtain approval, vendors must confirm that they follow industry standard data collection practices, will assure the security and privacy of the producer data, have a process for obtaining and preserving producer consent to register a CI score, and have the ability to load CI scores and supporting data via an approved software platform. The Registry’s data security functions will include authentication check of third-party vendors to ensure only approved, verified entities can upload CI scores, minimizing the risk of fraudulent or erroneous data entries.

Vendors must also agree to use the most recent version of the Feedstock Carbon Intensity Calculator (FD-CIC) created by the U.S. Department of Energy’s Argonne National Laboratory, and to participate in efforts by the Registry and producers to assess and reduce variability in data collection and estimation methods during the course of the grant period.

The CI Score Registry will serve as a centralized data platform for carbon intensity scores and environmental performance data from farms across Nebraska. Validation and analysis of the Registry data by Registry staff and NDEE facilitate the standardized reporting and verification of carbon intensity and sustainability outcomes, creating the foundation for more advanced measurement, reporting, and verification (MRV) processes.