ncx-co / ifm_deferred_harvest

Documents, Data, and Code. The NCX Methodology For Improved Forest Management (IFM) Through Short-Term Harvest Deferral.
Apache License 2.0
11 stars 1 forks source link

Public Comment: 253 (Daniel H. Hudnut) #253

Closed ncx-gitbot closed 1 year ago

ncx-gitbot commented 1 year ago

Commenter Organization: Wagner Forest Management, Ltd.

Commenter: Daniel H. Hudnut

2021 Deferred Harvest Methodology Section: No Section Indicated

Comment: In order to demonstrate additionality, the proponent should have to demonstrate that there is no 'adverse selection' within the program, whereby the population of program participants differs systematically from the general population from which data was drawn for estimating probability of and intensity of harvest. As a program participant, I can state that I had no plans to harvest timber from our NY woodlot during the activity period, and the payment we will receive will have caused in no change in behavior. While there may well be people who have deferred harvest becuase of the payments, there certainly are people who have entered into the program and accepted payment for harvest deferral when they had no intention or expectation of harvesting timber.

Proposed Change: The proponent should have to demonstrate either that they have gotten rid of 'freeloaders' like me, or they should discount the purported carbon impact of the project to account for the fact that some payments result in no change in harvest behavior. This discount should be supported by careful research.

ncx-gitbot commented 1 year ago

NCX response: Where the methodology is not explicitly prescriptive, it is expected that project developers will implement appropriate safeguards to avoid adverse selection. NCX signs a legal agreement with landowners that affirms their willingness to harvest the volume they are instead credited with deferring. We look forward to working with other developers and academic researchers to explore methods of measuring adverse selection directly in the future.