ncx-gitbot
commented
1 year ago NCX response: Projects are additional when the carbon stocks in the project scenario are greater than the carbon stocks expected under the baseline scenario–this is the basis for any carbon project verified against any standard. Because additionality, and therefore, creditable carbon is dependent on an accurate baseline, eligibility is limited to forests that are truly at risk of being harvested in the next year. Deferring that harvest results in additional carbon in the landscape. We agree that accounting for uncertainty is very important in any forest carbon project. Our revised methodology accounts for and requires a deduction associated with the uncertainty of carbon stocks in the project and baseline scenarios. 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. Leakage is poorly studied across existing IFM projects, especially short-term harvest deferral projects. We agree that leakage is a possible outcome of purposefully delaying a harvest. Based on comments received, we have updated the methodological approach to include a more conservative deduction. We look forward to working with other developers and academic researchers to explore methods of measuring leakage directly in the future.
Commenter Organization: Finite Carbon
Commenter: Sarah Wescott
2021 Deferred Harvest Methodology Section: No Section Indicated
Comment: Credible high quality offsets from LULUCF projects are seeing rapidly growing demand in the marketplace. Of particular interest to consumers are offsets from forestry projects which dominate the voluntary market. Forests are benefiting from this position and perception in the market, and for good reason - no other offset comes with the ancillary benefits that forest-based credits do. However, with this increased demand has come increased scrutiny. The reality is that while strong now, the position that forestry projects have earned is not guaranteed to persist if we cannot continue to improve the integrity of what we produce as an industry. That commitment starts with registries such as Verra and the methodologies they approve for use. We are very concerned about the optics of a methodology such as the one proposed and how it may ultimately erode consumer confidence in forest offsets. Tonne year accounting has not seen wide deployment in other offset programs, and for good reason: in order to do so correctly and defensibly, TYA yields sub-feasible levels of real carbon benefit. We are very concerned that, as written, this methodology has addressed the feasibility issue with TYA through a lack of conservativeness in several areas, and does not reflect industry best practices for forest carbon projects in the areas of leakage, baselines, and harvested wood product accounting. The substance of our concerns is provided above, and we respectfully request that Verra staff and the methodology authors modify the approaches taken on those discrete topics. Finite Carbon is strongly supportive of innovation for carbon projects, so long as quality and integrity are maintained. The voluntary carbon market has become more important now than ever before. It is imperative that our industry anticipate and adapt to the scrutiny that comes with this growth. Verra has a long history of leadership in the market, and we hope this will be an opportunity to demonstrate the robust, rigorous nature of the VCM, as well as the important role played by registries. Taking less conservative approaches on leakage, additionality, and GHG accounting in a single methodology has the potential to reflect poorly on the industry as a whole. It is with that perspective in mind, and in the spirit of improving transparency and integrity across the market as a whole, that we offer this feedback.
Proposed Change: N/A - summary comment. See proposed changes throughout.