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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: 207 (Andrea Tuttle) #207

Closed ncx-gitbot closed 1 year ago

ncx-gitbot commented 1 year ago

Commenter Organization: Forest and Climate Policy

Commenter: Andrea Tuttle

2021 Deferred Harvest Methodology Section: No Section Indicated

Comment: I strongly oppose adoption of the proposed NCX methodology based on 1) violations of core offset principles of transparency, additionality, leakage, permanence and financial additionality that are required for a credible forest carbon offset, and 2) erroneous logic in applying discount equations derived from economic analysis to the physics of climate change.

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. 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. Leakage is poorly studied across existing IFM projects, especially short-term harvest deferral projects. We agree that leakage is a possible outcome of purposefully delaying a harvest. Based on comments received, we have updated the methodological approach to include a more conservative deduction. We look forward to working with other developers and academic researchers to explore methods of measuring leakage directly in the future.