ncx-gitbot
commented
1 year ago NCX response: Contemporary statistical practice has moved beyond trying to derive design unbiased estimators based on blocking the data into homogeneous groups. Our business as usual model is a hierarchical statistical model that predicts one-year harvest risk and intensity based on FIA training data and a suite of covariates that include geographic, biological, economic, and sociological factors. Partial pooling across forest types ensures that the model is able to leverage the similarity and ubiquity of covariate relationships across the forests of the continental U.S. while still allowing for regionally specific differences. Predicting behavior of any type, which is the basis for any forest carbon program, is not straightforward, and depends on models whose performance can be measured.
Commenter Organization: Forest Carbon Works
Commenter: Briana Capra
2021 Deferred Harvest Methodology Section: Section 4 Applicability Conditions, Table 11-1 and 11-2 Appendix A
Comment: The methodology fails to clearly demonstrate similarity across the many sub areas of the geographic scope. It does not specify sub area a parameter to the carbon-at-risk model nor does it require sub area to be considered in the parametrization of the model. The methodology is not in conformance with the requirements for establishing and validating a performance benchmark. The requirement is: In establishing the scope of validity of the methodology or each performance benchmark, the methodology shall clearly demonstrate that there is similarity across the sub areas of the geographic scope in factors such as socioeconomic conditions, climatic conditions, energy prices, raw material availability and electricity grid emission factors, as such factors relate to the baseline scenario and additionality, noting that variation is permitted where correction factors address such variation as set out in Section 2.3.8.
Proposed Change: VCS Rerefence: VCS Methodology Requirements Section 3.2.5