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.
Commenter Organization: Forest and Climate Policy
Commenter: Andrea Tuttle
2021 Deferred Harvest Methodology Section: No Section Indicated
Comment: • Verification and Transparency: No standard should be approved if the calculations cannot be independently replicated and verified. The proposed methodology rests on proprietary computer modeling to generate a baseline based on machine learning and AI.
The algorithm claims to predict BAU harvest behavior based on forest type, location, roads, proximity to mills, timber price and other factors. While these attributes may also be useful to other protocols in refining their FIA common practice baselines, the black box nature of the calculations makes it impossible for Verifiers to ascertain whether the baseline is skewed towards over-crediting or not.
Proposed Change: No Proposed Change