Public Comment: 215 (Andrea Tuttle)

[ncx-gitbot]

Commenter Organization: Forest and Climate Policy

Commenter: Andrea Tuttle

2021 Deferred Harvest Methodology Section: No Section Indicated

Comment: • Permanence: The debatable logic of the tonne-year methodology eliminates the requirements for both permanence and buffer pools, e.g. “...The tonne-year accounting approach allows for equivalence to permanent tonnes on an annual basis and therefore permanence risk assessment and buffer pool contributions are not required” (NCX p.6).

Even if we accept the notion that one-year of deferred harvest is marginally meaningful to the climate, the fact that the carbon can immediately be re-emitted next year -- and in even larger quantities -- hardly meets a laugh test of a meaningful climate contribution, especially in the eyes of a highly skeptical public audience.

Proposed Change: No Proposed Change

[ncx-gitbot]

NCX response: 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.