ncx-gitbot
commented
1 year ago NCX response: No buffer pool would be required regardless of the number of properties within a project. Under this methodology credits are not generated or sold until after the performance period, which avoids the scenario where credits are purchased and retired before the climate impact has occurred. If a landowner decides to harvest while not enrolled, then re-enroll, the baseline model would likely calculate little to no carbon at risk. Credit is only granted during the years that, compared to the baseline, carbon is held out of the atmosphere.
Commenter Organization: American Forest Foundation
Commenter: Lynn Riley
2021 Deferred Harvest Methodology Section: No Section Indicated
Comment: Losses during validation/verification; Safeguards Against Emissions Events Going Unaccounted For: If an instance is enrolled, and it is discovered during verification that there was a net loss during the activity for some reason, how is that handled without a buffer pool? (This may be more of a question for VERRA than this methodology, how is this handled for tonne-year accounting.) We also recommend adding in safeguards for projects using this methodology to prevent any incentive for either the project proponent or participating properties to participate in years in which a harvest was not already planned, stop reporting/participating in years of harvest/loss, and then participate once again. This scenario leaves room for emissions events to go unaccounted for, and opens up significant questionability of the additionality of any participation at all (in other words, was the harvesting schedule on that property really deferred due to the incentive of the carbon market, or would it have happened that way all along, with the harvest losses conveniently unreported?). The methodology should create safeguards for preventing this from occurring, perhaps in the form of restrictions on participating properties around having “gap years” of enrollment in a tonne-year project.
Proposed Change: Incorporate safeguards against "gap years" of participation in project under this methodology, to increase credibility of additionality.