ncx-gitbot
commented
1 year ago NCX response: We appreciate the detailed comments raised about the absence of HWP accounting in the initial draft of our methodology. The carbon stored in trees is released into the atmosphere when a tree dies, some of it almost instantaneously and sometimes over years to decades. We believe it is important to account for all reasonable pools of emissions related to a harvest, and our revised methodology takes the storage of carbon in, and subsequent release of carbon from, harvest wood products into account.
Commenter Organization: Forest Carbon Works
Commenter: Briana Capra
2021 Deferred Harvest Methodology Section: Section 5 Project Boundary
Comment: The methodology ignores carbon stored in wood products in favor of crediting all baseline harvesting without accounting for the portion that is stored in long-lived wood products. Existing ERA methodologies such as VM0003 conservatively require the accounting of carbon stored in wood products, as do other methodologies approved for use by CAR and CARB. The methodology fails to establish criteria and procedures for the exclusion of the wood products GHG source in the baseline scenario. The requirement is: Specific carbon pools and GHG sources do not have to be accounted for if their exclusion leads to conservative estimates of the total GHG emission reductions or removals generated. The methodology shall establish criteria and procedures by which a project proponent may determine a carbon pool or GHG source to be conservatively excluded. And further that: IFM methodologies applicable to activities that reduce harvested timber shall account for the GHG emissions associated with changes in the wood products pool to avoid overestimating project net GHG benefits. The quantity of live biomass going into wood products shall be quantified where above de minimis (as set out in Section 3.3.6).
Proposed Change: VCS Rerefence: VCS Methodology Requirements Section 3.3.7 and 3.3.15