ncx-gitbot
commented
1 year ago NCX response: Projects are additional when the carbon stocks in the project scenario are greater than the carbon stocks expected under the baseline scenario–this is the basis for any carbon project verified against any standard. Because additionality, and therefore, creditable carbon is dependent on an accurate baseline, eligibility is limited to forests that are truly at risk of being harvested in the next year. Deferring that harvest results in additional carbon in the landscape.
Commenter Organization: Baker River Forestry, LLC
Commenter: Bob Berti,
2021 Deferred Harvest Methodology Section: No Section Indicated
Comment: NCX’s program of deferring annual harvests categorically will not create carbon additionality. It will simply pay small woodlot clients that I represent, an annual payment that does not change the “business as usual practice” of selective harvests on a 15-20 year re-entry cycle. It is a disingenuous approach that simply pays people to defer harvests they were not planning on, while distributing wealth from penance seeking carbon offset buyers who think this nature backed solution really works when it does nothing to change behavior. Let me share a real-world example. I have managed over 39 acres for one client over the past 60 years. In that time, her property has always had a minimum stocking of 14 cords/acre of merchantable wood. During these 60 years, I have arranged four different harvest operations, with roughly 15 years between harvests. The goal of our management has been to provide periodic income while taking good care of the underlying forest capital. Under NCX’s methodology, my client could sign up and be paid for deferring harvesting for the next 14 years, because the property has additional standing timber that could be harvested, even immediately after harvest. But since harvests are an episodic event spaced roughly 15 years apart, my client will have exactly the same stocking on her land today as she would have if she was paid to defer harvests for 14 years between logging operations. No change in behavior, no change in stocking. NCX would pay my client to do what she was going to do anyways, and NCX would create, in my opinion, a “bogus” carbon offset to sell on the voluntary market to an under-educated offset buyer seeking indulgences. This is not the way to incentivize meaningful climate change action. There is no additionality. Markets for timber cycle up and down, so we might delay a harvest entry during poor markets, waiting for prices to come up. When prices increase, we would implement the same kind of harvest, taking a little more wood, and putting us right back on the same cycle we were on before. NCX’s methodology would pay my client for this delay. But again, there is no enduring change in the carbon sequestered or stored on the forest. There is a divergence from the prior expectation, but a fairly prompt return to the plan. Now imagine a region with many such landowners, each harvesting sustainably on a periodic basis, as described. They harvest about as much timber as they grow and sell it to local markets. How does the addition of NCX payments affect carbon sequestration and storage in this scenario? Not at all! The forest grows the same amount and the mills consume the same amount. Across the landscape, the amount of carbon sequestered and stored does not change. Verra has an obligation to not simply accept NCX’s proposed methodology as prima facia evidence that their algorithms and satellite imagery will magically measure, verify, and generate new carbon offsets. For Verra to be a credible verifier, you must also understand incentives that change behavior. Carbon offsets are incentives to prompt behavior changes. But if the offsets are rewarded without a change in business as usual behavior, they do nothing for the environment. Paying woodlot owners, a one-year harvest deferral does not change behavior, period. There is no additionality, period. In the final analysis, this methodology is flawed and not worthy of VCS’s approval. I fear you might believe it is not your purview to give a thumbs up or down response. If you don’t recognize the flaws in this proposal then you are complicit in helping create a new category of bogus carbon offsets, with out creating any additionality. This would be a travesty.
Proposed Change: No Proposed Change