ncx-gitbot
commented
1 year ago NCX response: We appreciate the detailed comments raised about the absence of HWP accounting in the initial draft of our methodology. The carbon stored in trees is released into the atmosphere when a tree dies, some of it almost instantaneously and sometimes over years to decades. We believe it is important to account for all reasonable pools of emissions related to a harvest, and our revised methodology takes the storage of carbon in, and subsequent release of carbon from, harvest wood products into account.
Commenter Organization: EP Carbon
Commenter: Kyle Holland
2021 Deferred Harvest Methodology Section: No Section Indicated
Comment: The methodology over credits baseline emissions by ignoring carbon stored in long-lived wood products. The methodology fails to account for carbon in harvested wood products and therefore overstates baseline emissions. This is observed in the form of Equation 1 that Δ𝐶𝑂2𝑏𝑠𝑙 = −𝑟𝐶𝑡0 is simply the amount of carbon contained in above ground biomass removed in the baseline scenario and inherently assumes that all carbon removed is immediately emitted into the atmosphere. Regarding wood products, Table 5-1 states that “Not required as harvest deferral leads only to a shift in the harvested wood products decay curve, whose impact differs depending on the number of years harvest is deferred during and after participation” which is simply not true for the baseline. In the baseline scenario, carbon would be stored in long-lived wood products and therefore the baseline emissions should be net of carbon storage in long-lived wood products irrespective of the project scenario. Though section 3.3.4 of the VCS Methodology Requirements states that wood products is an optional pool for Extended Rotation Age in IFM, section 3.3.15 states “IFM methodologies applicable to activities that reduce harvested timber shall account for the GHG emissions associated with changes in the wood products pool to avoid overestimating project net GHG benefits.” By ignoring long-lived wood products in the baseline where the project scenario is to reduce (or eliminate) harvested timber, the methodology is overestimates net GHG benefits and therefore should be revised to account for carbon stored in long-lived wood products. This is especially the case where the methodology may be applied to project activity instances in a grouped project for only a few years and then emissions associated with any deferred harvesting occur after the participation period when there is no requirement for carbon accounting of such emissions that would otherwise be captured as project emissions. The requirement to account for wood products in an IFM project is a benchmark provided by the approved methodology VM0003 where projects must account for wood products unless “wood products are rising faster in the project case than in the baseline or are decreasing faster in the baseline than in the project case” per the requirements of Table 1. In most instances for IFM activities and all instances of the application of VM0003 to projects, wood products are not rising faster in the project case and therefore should be accounted for in the baseline scenario.
Proposed Change: No Proposed Change