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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: 185 (Ben Parkhurst) #185

Closed ncx-gitbot closed 1 year ago

ncx-gitbot commented 1 year ago

Commenter Organization: Bluesource LLC

Commenter: Ben Parkhurst

2021 Deferred Harvest Methodology Section: 11

Comment: The crediting from this methodology is almost entirely driven by a relatively opaque and complex model to predict the risk of harvesting for any given property in the baseline. However, we believe that this harvest model has not been sufficiently vetted by the peer review process at this point. The methodology notes that the common practice harvest model was fully reviewed by an expert panel, but no details of issues brought up by this panel or responses from NCX have been posted to the VCS website along with this methodology. This model is the fundamental quantification tool for estimating emissions reductions from deferred harvest, but due to the lack of transparency behind the panel review or precedent in the academic community for use of such a model for carbon quantification, we believe that this methodology should be delayed until further details on the review process can be publicly provided. The baseline model is far too complex and unprecedented for use in the carbon market without thorough review by qualified stakeholders and deserves more transparency regarding the review process. The uncertainties in this model are not adequately addressed or acknowledged in the methodology, and there should be more elements of conservativeness applied throughout the quantification to account for model uncertainties.

Proposed Change: No Proposed Change

ncx-gitbot commented 1 year ago

NCX response: We appreciate comments noting that the structure and performance of the baseline model used within this methodology is strongly influential on the predicted and realized climate impact of projects. Our revised methodology increases transparency rather than following an expert review process. This includes both detailed documentation of particular models used, as well as sharing benchmarking and performance information for baseline models. Finally, the revised approach to uncertainty explicitly accounts for imprecision in the baseline model in calculating the final number of credits generated from projects developed under this methodology.