CRIOS Methodology v3.3

MCTI Combined Margin — credited factor of record · Hourly AEF evidence layer · Beneficial-ownership-share crediting

The No-Self-Reporting Principle

Conventional carbon credit verification relies on operator-submitted data. Projects file monitoring reports; validation/verification bodies audit what operators claim; registries issue credits based on the audited operator submissions. The operator sits in the middle of the chain of custody for their own credits.

Karbera operates differently. Every Karbera-verified credit is grounded in data already being recorded by parties other than the operator — government-published grid metering (ONS Brazil), regulatory plant registries (ANEEL SIGA), utility-issued documents, and hardware-attested device readings. Karbera reads what's already being recorded; the operator doesn't have to assemble or submit anything. The verification runs on the data, not on the operator.

This is the proof, not the pitch. It is what makes the rest of the engine possible.

This principle is foundational to both Karbera (the verification methodology) and CRIOS (the issuance platform that accepts only methodologies operating under it).

v3.3 · current

Earlier methodology versions remain in effect for operators where v3.2 schema extensions don't apply (e.g., v3.1 for MMGD operators without per-installation ownership data). Each operator surfaces its own active version.

Overview

Karbera computes avoided emissions at hourly resolution using verified ONS dispatch. Verification depth varies by asset class: utility-scale plants are individually grid-verified; MMGD operators are reconciled against EPE PDGD aggregates where possible, modeled where not. Every per-row figure carries its verification tier so reviewers can audit the mechanism, not just the number.

Four-tier verification taxonomy

Tier 1A
Utility-scale · grid-verified per-plant

Every plant's hourly generation is independently verified at the generation-side meter via ONS dispatch (geracao_usina_2_ho / geracao_termica_despacho_2_ho) — the canonical metered values used by ANEEL/CCEE for settlement. The offset is credited at the MCTI Combined Margin (v3.3), net of operator beneficial-ownership share (v3.2). Operators served: Engie Brasil Energia, CEMIG GT.

methodology · CRIOS-v3.3-grid-verified
Tier 1B
MMGD · aggregate-verified, methodology-allocated

Operator's aggregate portfolio matches EPE PDGD cell totals within ±15% tolerance. Per-installation figures are methodology allocations of the verified aggregate — not independently metered per-plant. The honest framing: best-available verification for Class A MMGD operators.

methodology · CRIOS-v3.2-aggregate-verified
Tier 0
MMGD · modeled-only

Capacity known from Sistema GD registry; production modeled from regional capacity factors and hourly profiles. No reconciliation anchor. Default when EPE PDGD fixtures are absent or cell reconciliation falls outside tolerance. Avoided emissions credited at the MCTI Combined Margin of record (v3.3); modeled production is the quantity, not the factor.

methodology · CRIOS-v3.3-modeled
Tier 2 / 3 / 4
Third-party data with consent · hardware-attested

Tier 2 — bill-OCR (utility-issued documents are third-party to the operator). Tier 3 — inverter API direct-read (manufacturer-side telemetry). Tier 4 — hardware-attested signed device readings. All tiers operate under the No-Self-Reporting Principle: the operator authorises access; the data originates outside the operator. Ingestion is Phase 4 work.

methodology · reserved

Methodology integrity rule

Any displayed numeric figure that an external party could independently verify uses the recognizable form (operator's published nameplate, not internal methodological transformations). Derived values are shown alongside, not in place of, canonical values. This governs capacity (DC nameplate primary, AC equivalent alongside), coverage % (basis explicit), emission factors (sources cited), and grid AEF (Karbera-computed value cross-checked against MCTI's official monthly factors).

Production-of-record principle

Every per-row numeric figure is traceable to its verification mechanism, and the mechanism is visible to the user. The four-tier taxonomy above is the buyer-facing form of this principle.

Data sources

ANEEL SIGA

Plant registry — every generation asset connected to the Brazilian grid, with capacity, technology, owner, location.

Updated daily
Source
ONS Geração por Usina em Base Horária

Verified hourly generation by plant, published by the Brazilian grid operator.

Updated daily
Source
ONS Geração de Térmicas por Despacho

Verified thermal dispatch by plant and fuel type, used to compute hourly grid AEF.

Updated daily
Source

Emission factors

Fuel / sourcetCO₂/MWhCitation
Natural gas combined cycle0.40IPCC AR6, 50%-efficient CCGT lifecycle
Natural gas simple cycle0.55IPCC AR6
Coal0.95IPCC AR6, average for Brazilian fleet
Oil / Diesel0.78IPCC AR6
Biomass0.00IPCC standard convention; see limitations
Nuclear0.00IPCC standard convention
Renewable (hydro/wind/solar/ocean)0.00IPCC standard convention

Factor of record — MCTI Combined Margin

The headline avoided-emissions figure (the tonnes an operator can claim) is credited at Brazil's official grid displacement factor: the MCTI dispatch-analysis Combined Margin (CDM Tool 07). CM = 0.75·OM + 0.25·BM, where OM is the Operating Margin (marginal dispatched plant, from MCTI's monthly dispatch analysis) and BM is the annual Build Margin. Base year 2025 (latest complete MCTI annual dispatch publication):

CM = 0.75 × OM(2025) + 0.25 × BM(2025)
= 0.75 × 0.4125 + 0.25 × 0.0711 = 0.3271 tCO₂/MWh
VintageOMBMCM
20210.59850.0271*0.4556
20220.40680.02710.3117
20230.37850.03260.2920
20240.44730.05230.3485
2025 · of record0.41250.07110.3271

The factor refreshes annually — each new MCTI dispatch publication updates the constant, and the vintage is stated with every figure. Disclosure notes: (a) an earlier value of 0.476 was not a published MCTI number — it paired the 2021 OM with a Build Margin (~0.108) that MCTI never published, and overstated CM; it has been corrected. (b) The 2021 vintage CM uses the 2022 BM as a proxy, since no 2021 BM was published. (c) MCTI also publishes an inventory-style average "fator médio" (~0.02–0.03 tCO₂/MWh); this is a different quantity and is never used as an offset factor here.

Submarket emission intensity (informational — national CM is applied)

Informational · not applied

Derived from the ONS 2025 generation fuel mix and anchored to the national Operating Margin (0.4125), so the four submarket figures reconcile exactly to the national factor. Shown so the regional spread is visible in both directions — some regions above the national number, some below.

SubmarketSubmarket CMvs national 0.3271
Sudeste/CO0.3138−4%
Sul0.5348+64%
Nordeste0.1366−58%
Norte0.5061+55%

Karbera credits every asset at the national Combined Margin (0.3271). These submarket figures are shown for transparency only — they are not applied to any credited number. They use each region's average generation mix (a shape anchored to the national factor); a marginal-resolved version is future work.

Hourly AEF — the evidence layer, not an alternative offset

Karbera also computes the hourly Average Emission Factor (AEF) of the grid mix — fossil emissions ÷ total dispatched generation each hour, from ONS metered dispatch. For a hydro-dominated grid the AEF (~0.03–0.04 tCO₂/MWh) is roughly an order of magnitude below the dispatch marginal CM, because they answer different questions: the AEF describes the average intensity of all generation, while the CM describes the marginal fossil plant a new MWh actually displaces. Karbera uses the AEF as the verification / evidence layer — independent, metered proof that the credited MWh were physically delivered to the grid — beneath the official CM offset. The AEF is not presented as an alternative, lower offset value; the two are not interchangeable and are never netted against each other.

Surplus-hour analysis (disclosed, not applied)

In some hours the marginal MWh displaces almost nothing — surplus conditions where price sits at the regulatory floor. Using 2025 CCEE hourly settlement price (PLD) by submarket, the share of hours at the floor (R$58.60/MWh) was: Nordeste 45.6%, Norte 43.4%, Sudeste 23.2%, Sul 22.3%. A physically strict marginal factor would haircut those surplus hours, lowering the credited displacement for renewables-heavy submarkets. Karbera discloses this but does not apply it: the official MCTI Combined Margin ships unmodified as the factor of record. A surplus-hour-adjusted marginal factor is future (MEF-product) work.

Distributed loss-avoidance gross-up (Tier 1)

A distributed MWh delivered at or near the point of use avoids the transmission-and-distribution technical losses a central plant incurs, so it displaces more than one central MWh. For distributed generation only, Karbera applies a per-installation gross-up 1 / (1 − L), where L is the technical loss to the installation's connection voltage — always ≥ 1, a clean positive uplift. L is keyed per installation from its distributor, voltage class, and self-consumed-vs-injected modality (register attributes). The distributor loss factors are Brazil's official ANEEL SAMP declared/measured technical losses (SAMP - Balanço, PRORET Submódulo 2.6; medido variant, latest 12 published months per distributor), cited per figure. On the current distributed portfolio this adds ~10% to credited tonnes.

Real vs regulatory disclosure: SAMP publishes the real declared/measured losses used here. A distinct regulatory tariff-recognized loss % (PRORET-set) is used in tariff reviews and lives only in ANEEL's Perdas report base; the two can differ. Karbera credits at the real (SAMP) figure and discloses this choice. Grid-scale, transmission-connected plants receive no gross-up — they inject at the Rede Básica and avoid none of these losses.

Calculation walkthrough

Worked example for one hour of one plant.

Example: On 2025-06-15 at 19:00 BRT:
· Total grid load: 73.2 GW (from ONS)
· Thermal plants generated: 9.1 GW (from ONS thermal dispatch)
Fuel mix: 6.2 GW gas CCGT, 1.8 GW gas SCGT, 0.7 GW coal, 0.4 GW oil
Total fossil emissions:
(6.2 × 0.40) + (1.8 × 0.55) + (0.7 × 0.95) + (0.4 × 0.78) = 4,461 tCO₂
AEF for hour: 4,461 / 73,200 = 0.061 tCO₂/MWh
Engie Itá generated 980 MWh that hour.
Avoided emissions for Itá that hour: 980 × 0.061 = 59.8 tCO₂

Limitations (honest disclosure)

  • Offset = MCTI Combined Margin; AEF = evidence. The credited offset uses Brazil's official dispatch-analysis Combined Margin (a marginal factor). Karbera's hourly Average Emission Factor is retained as the independent metered evidence layer, not a second offset. A bespoke plant-specific Marginal Emission Factor (surplus-hour-adjusted, per the analysis above) is on the roadmap — scoped, not yet in development.
  • Biomass treatment. Biomass is treated as zero-emission per IPCC convention. This assumes biomass is part of the short-term carbon cycle, which is debated in academic literature. Future versions may apply biomass-specific factors.
  • Coverage. Currently restricted to plants individually tracked in ONS dispatch data. Plants in MMGD (Micro/Minigeração Distribuída) classifications are aggregated and not individually verifiable from public data alone. Operators may provide additional data to extend coverage.
  • Losses. The grid emission factor itself is a busbar figure: it does not yet embed transmission-and-distribution losses or auxiliary consumption at thermal plants. This is a property of the factor, not of the whole method — distributed generation is already credited for the losses it avoids under the Tier-1 loss-avoidance treatment. Embedding loss and auxiliary adjustments into the factor for transmission-connected plants remains on the roadmap.

Scientific references

Karbera methodology is calibrated to first-principles scientific authorities and Brazilian regulatory data — not to commercial registry standards.

Version history

  • v3.3
    current — Adopts the MCTI dispatch-analysis Combined Margin (base year 2025, 0.3271 tCO₂/MWh, refreshed annually) as the offset factor of record, with the hourly AEF retained as the evidence layer. Replaces the prior hardcoded 0.476 (never a published MCTI value). Corrects the "Fator Médio" mislabel; adds the vintage table and surplus-hour disclosure.
  • v3.2
    in service — Adds beneficial-ownership-share crediting (JV-aware netting) on top of v3.1's four-tier taxonomy. Active for utility-scale operators (Engie, CEMIG GT) where ownership data is available.
  • v3.1
    in service for MMGD — Four-tier verification taxonomy. MMGD via Class A operators (aggregate-verified) and Class B/C disclosure framing. Remains current for MMGD operators pending per-installation ownership data.
  • v3.0
    deprecated — Hourly AEF for utility-scale only.
  • v2.0
    deprecated — Annual average emission factor. No longer issued.
  • v1.0
    deprecated — Pilot-only static factor.