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ncx-co / ifm_deferred_harvest

Documents, Data, and Code. The NCX Methodology For Improved Forest Management (IFM) Through Short-Term Harvest Deferral.
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Public Comment: 164 (Briana Capra) #164

Closed ncx-gitbot closed 1 year ago

ncx-gitbot commented 1 year ago

Commenter Organization: Forest Carbon Works

Commenter: Briana Capra

2021 Deferred Harvest Methodology Section: Section 4 Applicability Conditions

Comment: The methodology does not provide an applicability condition to prevent lands from being credited where the activity of harvest deferral has already been implemented. Project lands where harvests that have been deferred in the past are eligible for crediting and therefore there is no new measure implemented that reduces emissions. In these cases, the methodology is simply crediting harvest deferrals that happened in prior years and not as a result of implementation of any new technology or measure. The requirement is: Activities that have not implemented any such technologies and/or measures, or that have implemented them on a date that is earlier than that permitted under the VCS rules on project start date, shall be excluded from the methodology.

Proposed Change: VCS Rerefence: VCS Methodology Requirements Section 3.2.4

ncx-gitbot commented 1 year ago

NCX response: This methodology allows any forestland that is at risk of harvest and is not currently generating credits for any other forest carbon project to participate. Even if a landowner previously deferred harvest on their property, there could still be a risk of harvest. The baseline model used calculates risk of harvest on a yearly basis and would exclude any property not at risk.