Comment: Cited reference Thompson et al. (2017) concludes that FIA data provide "little predictive information" about "reactive harvest behavior" of private woodland landowners. This provides evidence of the need for additional disclosure in order to evaluate if a proposed baseline model accurately characterizes these documented, real-world, forest management dynamics, which are critical for ensuring additionality. See attached comment letter submitted in response to Methodology for Improved Forest Management through Targeted, Short-Term Harvest Deferral (March 2022).
Proposed Change: Require full public disclosure of all baseline scenario models and validation benchmarks approved for use with this methodology. See comment letter.
Commenter Organization: CarbonPlan
Commenter: Danny Cullenward
2021 Deferred Harvest Methodology Section: 11.3
Comment: Cited reference Thompson et al. (2017) concludes that FIA data provide "little predictive information" about "reactive harvest behavior" of private woodland landowners. This provides evidence of the need for additional disclosure in order to evaluate if a proposed baseline model accurately characterizes these documented, real-world, forest management dynamics, which are critical for ensuring additionality. See attached comment letter submitted in response to Methodology for Improved Forest Management through Targeted, Short-Term Harvest Deferral (March 2022).
Proposed Change: Require full public disclosure of all baseline scenario models and validation benchmarks approved for use with this methodology. See comment letter.