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2 years ago NCX response: We appreciate comments noting that the structure and performance of the baseline model used within this methodology is strongly influential on the predicted and realized climate impact of projects. Our revised methodology increases transparency rather than following an expert review process. This includes both detailed documentation of particular models used, as well as sharing benchmarking and performance information for baseline models. Finally, the revised approach to uncertainty explicitly accounts for imprecision in the baseline model in calculating the final number of credits generated from projects developed under this methodology.
Commenter Organization: Wagner Forest Management, Ltd.
Commenter: Daniel H. Hudnut
2021 Deferred Harvest Methodology Section: 9.2
Comment: The US National Forest Inventory (USFS FIA) data is collected and processed to provide area-based estimates of growth, not the individual tree estimates of growth that the proponent is deriving, making it difficult to 'annualiz(e) appropriately.' Expectations here are under-specified to a fault. What is the source of forest type classifications for the plots and project area? Uncertainty? What is specified - species assemblage? Site index? Stand stocking? How is the relevant geography established? It is not immediately obvious why the most recent pair of remeasurement data should be used. Calculating the annualized individual tree growth rate for aboveground live tree biomass again relies on a series of equations that should properly yield a range of values, rather than a single estimate.
Proposed Change: The FIA data provides area based estimates of growth. Work with those, controlling for (at a minimum) geography, species assemblage and initial stocking levels, rather than % growth from individual tree data.