Comment: The determination and establishment of a baseline scenario shall follow an internationally accepted GHG inventory protocol, such as the IPCC 2006 Guidelines for National GHG Inventories, however no such requirement is presented in the methodology. Rather, the methodology allows for remotely-sensed data that may not conform to the requirements of any internationally accepted GHG inventory protocol.
NCX response: Our model makes high fidelity predictions on the basis of remotely sensed data combined with robust field measurements to create a dynamic and spatially resolved baseline.
Commenter Organization: Forest Carbon Works
Commenter: Briana Capra
2021 Deferred Harvest Methodology Section: Appendix A
Comment: The determination and establishment of a baseline scenario shall follow an internationally accepted GHG inventory protocol, such as the IPCC 2006 Guidelines for National GHG Inventories, however no such requirement is presented in the methodology. Rather, the methodology allows for remotely-sensed data that may not conform to the requirements of any internationally accepted GHG inventory protocol.
Proposed Change: VCS Rerefence: VCS Methodology Requirements Section 3.4.9