Public Comment: 226 (Kyle Holland)

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Commenter Organization: EP Carbon

Commenter: Kyle Holland

2021 Deferred Harvest Methodology Section: No Section Indicated

Comment: By setting the upper bound of the internal of 𝑟 ∈ [0,1] the total baseline emissions are over credited by a factor of 𝑚. For example, in a thirty-year crediting period the total emissions are overstated by as much as a factor of 30. Assuming zero growth and 𝑟 = 1 one can easily see how emissions are over credited: ∑Δ𝐶𝑂2𝑏𝑠𝑙,𝑡 30 𝑡=1 = ∑[𝐶𝑡0(1+ 𝐺𝑏𝑠𝑙,𝑡)(1 − 𝑟) −𝐶𝑡0 ] 30 𝑡=1 ∑Δ𝐶𝑂2𝑏𝑠𝑙,𝑡 30 𝑡=1 = ∑[ 𝐶𝑡0 (1 + 0)(1 − 1)− 𝐶𝑡0 ] 30 𝑡=1 ∑Δ𝐶𝑂2𝑏𝑠𝑙,𝑡 30 𝑡=1 = ∑−𝐶𝑡0 30 𝑡=1 ∑Δ𝐶𝑂2𝑏𝑠𝑙,𝑡 30 𝑡=1 = −30 ∗ 𝐶𝑡0 This fundamental flaw in accounting occurs is irrespective of whether absolute tonnes of carbon or tonne-years are used the conversion from units of absolute tonnes of carbon to tonne-years as a final step in Equation 12. In converting to tonne-years in Equation 12, the final result is still overstated by a factor of 𝑚.

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.