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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: 200 (Danny Cullenward) #200

Closed ncx-gitbot closed 1 year ago

ncx-gitbot commented 1 year ago

Commenter Organization: CarbonPlan

Commenter: Danny Cullenward

2021 Deferred Harvest Methodology Section: 8.3

Comment: The Proposed Methodology's assumption that there is no activity-shifting leakage rests on a loose definition of the term "project area" that is defined by project proponents and subject to potential maniupulation. See attached comment letter submitted in response to Methodology for Improved Forest Management through Targeted, Short-Term Harvest Deferral (March 2022).

Proposed Change: Set clear, objective guidance to define "project area" or assign a non-zero activity-shifting leakage factor. See comment letter.

ncx-gitbot commented 1 year ago

NCX response: Where the methodology is not explicitly prescriptive, it is expected that project developers will implement appropriate safeguards. For example, NCX signs a legal agreement with landowners that affirms their control over harvesting decisions of all land under their ownership.