ncx-gitbot
commented
2 years ago NCX response: Where the methodology is not explicitly prescriptive, it is expected that project developers will implement appropriate safeguards to prevent gaming in this manner. NCX signs a legal agreement with landowners that affirms their control over harvesting decisions of all land under their ownership.
Commenter Organization: Finite Carbon
Commenter: Sarah Wescott
2021 Deferred Harvest Methodology Section: 4; 8.3
Comment: The internal or activity shifting leakage factor is assessed in the methodology as zero due to the required “whole entity” reporting approach. If comprehensive, whole entity reporting or inclusion in the project would adequately protect against negative outcomes from activity shifting decisions. With such an approach, it would be clear if an entity shifted harvesting activities to another portion of their ownership. However, we noted that Page 9, Item 7 of the methodology leaves the door open to potential gaming. This bullet requirement is written such that an owner that has designated their forest to be managed by two or more dedicated managers would not be required to report or include all lands, but rather just the lands covered by the relevant manager. Many timberland portfolios in the United States have multiple managers, so this rule seems to leave the door open for activity-shifting leakage by the owner from one manager to another.
Proposed Change: We suggest that the language require enrollment of all owned lands in the United States or, at a minimum, disclosure of any harvesting within the entire ownership, disclosure of lands transferred between managers, and a calculation of any associated activity-shifting leakage disclosed during that reporting for discounting purposes.