Public Comment: 225 (Kyle Holland)

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Commenter Organization: EP Carbon

Commenter: Kyle Holland

2021 Deferred Harvest Methodology Section: No Section Indicated

Comment: The methodology over-credits baseline emissions by repeatedly counting the same avoided emissions year over year. The methodology is flawed because it models 𝑟 ∈ [0,1] where it should be modeled in 𝑟 ∈ [0,1/𝑚] where 𝑚 is the number of years in accounting. It is easy to show that the methodology over-credits baseline emissions by taking the sum of baseline emissions over 𝑚, that mathematically −∑ Δ𝐶𝑂2𝑏𝑠𝑙,𝑡 𝑚 𝑡=1 > 𝐶𝑡0 + 𝐶𝑡0 ∑ 𝐺𝑏𝑠𝑙,𝑡 𝑚 𝑡=1 when 𝑟 > 1/𝑚; that the sum of baseline emissions exceeds the total carbon stock including growth when 𝑟 is greater than 1/𝑚. This follows from simply writing the equation for a single landowner as the sum over time as follows: ∑Δ𝐶𝑂2𝑏𝑠𝑙,𝑡 𝑚 𝑡=1 = ∑[𝐶𝑡0(1+ 𝐺𝑏𝑠𝑙,𝑡)(1 − 𝑟) −𝐶𝑡0 ] 𝑚 𝑡=1 ∑Δ𝐶𝑂2𝑏𝑠𝑙,𝑡 𝑚 𝑡=1 = 𝐶𝑡0 (1 − 𝑟)∑(1 +𝐺𝑏𝑠𝑙,𝑡) 𝑚 𝑡=1 − 𝑚𝐶𝑡0 And then substituting the upper limit on baseline emissions expressed as the opposite of reductions −∑ Δ𝐶𝑂2𝑏𝑠𝑙,𝑡 𝑚 𝑡=1 < 𝐶𝑡0 + 𝐶𝑡0 ∑ 𝐺𝑏𝑠𝑙,𝑡 𝑚 𝑡=1 which cannot physically exceed the total carbon stock over time and solving for 𝑟 yields −[𝐶𝑡0 (1 − 𝑟)∑(1 + 𝐺𝑏𝑠𝑙,𝑡) 𝑚 𝑡=1 − 𝑚𝐶𝑡0 ] ≤ 𝐶𝑡0 + 𝐶𝑡0∑𝐺𝑏𝑠𝑙,𝑡 𝑚 𝑡=1 𝑚𝐶𝑡0 − 𝐶𝑡0 (1 − 𝑟)∑(1 + 𝐺𝑏𝑠𝑙,𝑡) 𝑚 𝑡=1 ≤ 𝐶𝑡0 + 𝐶𝑡0∑𝐺𝑏𝑠𝑙,𝑡 𝑚 𝑡=1 𝑚 − (1 − 𝑟)∑(1 + 𝐺𝑏𝑠𝑙,𝑡) 𝑚 𝑡=1 ≤ 1+ ∑𝐺𝑏𝑠𝑙,𝑡 𝑚 𝑡=1 −(1 − 𝑟)∑(1 + 𝐺𝑏𝑠𝑙,𝑡) 𝑚 𝑡=1 ≤ 1 + ∑𝐺𝑏𝑠𝑙,𝑡 𝑚 𝑡=1 − 𝑚 𝑟 − 1 ≤ 1 +∑ 𝐺𝑏𝑠𝑙,𝑡 𝑚 𝑡=1 − 𝑚 ∑ (1 + 𝐺𝑏𝑠𝑙,𝑡) 𝑚 𝑡=1 𝑟 ≤ 1 + ∑ 𝐺𝑏𝑠𝑙,𝑡 𝑚 𝑡=1 − 𝑚 ∑ (1 + 𝐺𝑏𝑠𝑙,𝑡) 𝑚 𝑡=1 + 1 And then conservatively assuming zero growth rate 𝐺𝑏𝑠𝑙,𝑡 = 0 𝑟 ≤ 1 − 𝑚 𝑚 +1 𝑟 ≤ 1 �

Proposed Change: No Proposed Change

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NCX response: The business as usual model is a hierarchical statistical model that predicts one-year harvest risk and intensity based on FIA training data and a suite of covariates that include geographic, biological, economic, and sociological factors. Partial pooling across forest types ensures that the model is able to leverage the similarity and ubiquity of covariate relationships across the forests of the continental U.S. while still allowing for regionally specific differences.