ncx-gitbot
commented
1 year ago NCX response: We agree that accounting for uncertainty is very important in any forest carbon project. Our revised methodology propagates and accounts for uncertainty and requires a deduction associated with the uncertainty of carbon stocks in the project and baseline scenarios.
Commenter Organization: WWF-US
Commenter: Brad Schallert
2021 Deferred Harvest Methodology Section: No Section Indicated
Comment: Uncertainty requirements: Updating the statistical confidence threshold to 10% at the 90% confidence interval is a reasonable change and in line with norms of the carbon market. However, the proposed requirement 2.4.2 suggests a provision to exclude uncertainty “where it is unlikely” to exceed 10%. Section 2.4.4 (15) also suggests a VB judgement call on “…whether there is significant risk that the….confidence interval could exceed 10%...”. Both random and systematic error can and should be quantified for all projects. Whether uncertainty “could” exceed a certain threshold should not be a judgement call. The only way to be sure is to quantify it. We suggest deleting these section statements and requiring a statistical quantification of uncertainty for all projects. The absence of such measures presents a serious risk of over-crediting. Section 2.4.4 also states “Where the half-width…exceeds 100%....the project is not eligible for crediting”. We strongly agree any carbon claims for project-level crediting with uncertainty ≥ 100% are unfounded and should not be credited (this is essentially the same as complete uncertainty of the GHG assertion). We suggest a more stringent requirement of +/- 20% at 90% CI, aligning with other reputable carbon standards and providing a more realistic and conservative metric by which to judge the validity and accuracy of potential new quantification approaches.
Proposed Change: No Proposed Change