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1 year ago NCX response: A tonne-year is simply a unit of carbon account like a kilowatt hour is to a kilowatt for electricity, a unit of volume over time. While tonne-year accounting may not be used widely today in the voluntary carbon market, it has been supported as an alternative to traditional carbon accounting in the scientific literature for many years. One cannot adequately know the full benefit of a solution without adding in the time or duration term. Fundamentally, tonne-year accounting allows for the delivery of realized impact, not presumed future impact on timescales incongruent with the variability of natural systems. Furthermore, tonne-year accounting allows the direct comparison of benefits of different carbon offsets approaches over many different time scales and technologies. The goal of climate mitigation is more about mitigating the damage caused by climate change, rather than the actual quantity of carbon in the atmosphere. The carbon in the atmosphere causes increased temperatures through climate forcing, which in turn lead to costly economic and social damages to our water, homes, businesses, and livelihoods. The long-standing research and implementation of the Social Cost of Carbon approximates the net present value of the perpetual stream of future costs and damages caused by climate change. For our methodology, we apply a similar economic framing and a net discount rate of 3.0% to identify the equivalence ratio between the benefits of delaying emissions for 1 year compared with 100 years. See Parisa et al. 2022 for a full explanation of how this economic model yields an economic equivalence between credits of different durations. In order to incentivize action today to avoid those future damages, it is appropriate to use a similar economic framework to calculate the benefits of near-term climate action. While a ratio does not signify a physical equivalence, it does appropriately value the future economic benefits of physical action today.
Commenter Organization: CarbonPlan
Commenter: Danny Cullenward
2021 Deferred Harvest Methodology Section: No Section Indicated
Comment: Earlier this month, we submitted comments on Verra’s Proposed Updates to the VCS Program that specifically addressed the implications of issuing offset credits based on ton-year accounting. 2 We incorporate our earlier comments here by reference and write separately to reiterate our concerns with the use of ton-year accounting to issue offset credits to projects that, as proposed here, could store carbon for as little as one year. These approaches are inconsistent with net-zero climate goals and global temperature stabilization. They should be labeled accordingly. We also urge Verra and NCX to directly and transparently address the novel additionality risks posed by ton-year accounting, which the Proposed Methodology fails to do. Ton-year accounting effectively gives projects an open option to exit from carbon storage commitments, which enables strategic, non-additional enrollment behaviors. We do not see adequate protections in the Proposed Methodology that foreclose these risks, as the only meaningful constraints are imposed through a proprietary baseline scenario model that cannot be evaluated in this public consultation. We also discuss a significant loophole that illustrates these additionality problems in concrete terms. Finally, we express concerns with the Proposed Methodology’s treatment of emissions leakage from short-term harvest deferrals.As detailed below, we encourage Verra and NCX to make public any baseline scenario models used to ensure additionality under the Proposed Methodology and to close obvious loopholes that would lead to non-additional crediting. We also suggest ways Verra and NCX should improve their treatment of emissions leakage
Proposed Change: No Proposed Change