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: Carbon Direct, Inc.
Commenter: Bodie Cabiyo, Van Butsic, John Dees
2021 Deferred Harvest Methodology Section: No Section Indicated
Comment: Harvested wood products (HWPs) are not included in the project boundary because 1-year deferred harvest “leads only to a shift in the harvested wood products decay curve” (Table 5.1). This is a conservative and appropriate assumption for additional carbon stored in HWPs due to the project. It will, however, create large errors when applied to baseline modeling. The baseline methodology described tacitly assumes immediate combustion of all counterfactual harvested carbon by excluding HWPs from Equation 1. However, immediate carbon release is mostly limited to combusted logging slash, mill waste, and wood used for bioenergy. The proposed methodology should only credit those carbon pools that would be released during the one-year crediting period. HWPs will decay over time periods from multiple years to centuries, as the methodology alludes to in Table 5.1. By excluding HWPs in the baseline, this methodology is claiming to avoid carbon emissions from decay of HWPs that will occur well after the project crediting period. In some cases, this crediting error would account for nearly half of the credits claimed under the proposed methodology.
Proposed Change: The baseline scenario should conservatively estimate the amount of carbon that would not be stored in HWPs during the one-year project period. In most cases, this will be the sum of logging slash, mill waste, and wood used for bioenergy. Existing methodologies like VM0003 and VM00012 do incorporate HWPs into baseline modeling, however, they should not be used verbatim as a template because they assume that carbon in short-lived products (3- and 5-years) is immediately released. The proposed methodology should only credit avoided emissions that are realized during the one-year harvest deferral period.