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: CarbonPlan
Commenter: Danny Cullenward
2021 Deferred Harvest Methodology Section: No Section Indicated
Comment: The Proposed Methodology fails to ensure additionality because it relies on unspecified, proprietary methods to account for the unique additionality risks associated with short-duration harvest deferrals. As we addressed in our earlier comments to Verra, ton-year accounting allows for 1-year crediting periods and creates the ongoing option for landowners to exit from their carbon storage commitment. These characteristics enable new opportunities for landowners to strategically enroll and un-enroll in forest offset projects to earn credits around business-as-usual harvest cycles. Ton-year’s novel additionality risks must be addressed and mitigated within each methodology, but the Proposed Methodology punts management of this critical problem to unspecified, proprietary methods. Accurately crediting harvest deferrals hinges on predicting the baseline scenario — how forests would have been harvested in the absence of carbon finance. The Proposed Methodology credits harvest deferrals by comparing observed on-site carbon to predicted at-risk carbon. All carbon savings above the modeled baseline scenario are considered additional. 3 Thus, evaluating additionality outcomes requires understanding the details of the baseline model because the accuracy of the baseline model determines what the Proposed Methodology considers additional. 4 Despite the fact that the choice and use of baseline models determines the Proposed Methodology’s definition of additionality, the Proposed Methodology does not prescribe specific methods or models that can be used. 5 Instead, the Methodology describes high-level characteristics that a baseline model must consider, but outsources model development and application to financially interested project proponents like NCX. 6
Proposed Change: No Proposed Change