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: 181 (Bodie Cabiyo, Van Butsic, John Dees) #181

Closed ncx-gitbot closed 1 year ago

ncx-gitbot commented 1 year ago

Commenter Organization: Carbon Direct, Inc.

Commenter: Bodie Cabiyo, Van Butsic, John Dees

2021 Deferred Harvest Methodology Section: 8.4

Comment: Uncertainty is based solely on uncertainty around carbon accounting. However, because the baseline is a model, there is uncertainty in the baseline model that goes beyond simply carbon accounting. Section 6: Baseline scenario broadly describes a type of probabilistic model which can predict the amount of harvest that would take place under the project scenario. However, from the requirements of Section 6, there is no way for an independent verifier to interrogate the quality of the model. While we believe the generalized model presented is a good starting place to assure the model accurately predicts forest harvest we suggest some changes.

Proposed Change: The developers using this methodology must present in their documentation: (1) a statistical measure of goodness-of-fit appropriate for the model type used and (2) estimated coefficients for each variable in the model such that an independent verifier can confirm the model results are logical. A conservative suggestion is that the uncertainty should be propagated in the baseline estimate by estimating the baseline likelihood one standard deviation below the mean, instead of the mean itself. This would encourage developers to select landowners with higher certainty and improve models.

ncx-gitbot commented 1 year ago

NCX response: We agree that accounting for uncertainty is very important in any forest carbon project. Our revised methodology accounts for and requires a deduction associated with the uncertainty of carbon stocks in the project and baseline scenarios.