Comment: The baseline section allows for use of "written harvest plan" to estimate the proportion of standing carbon expected to be removed at harvest. This would be very easy to abuse, particularly with no written management plan or third party certification requirement as mentioned previously. Anyone, qualified or not, could simply update a harvest plan each year to hypothetically remove 100% of stocks and be credited for it each year.
Proposed Change: Remove section or revise language to close this potential loophole.
Commenter Organization: Green Assets
Commenter: Jonathan Pomp, CF, RPF
2021 Deferred Harvest Methodology Section: 6
Comment: The baseline section allows for use of "written harvest plan" to estimate the proportion of standing carbon expected to be removed at harvest. This would be very easy to abuse, particularly with no written management plan or third party certification requirement as mentioned previously. Anyone, qualified or not, could simply update a harvest plan each year to hypothetically remove 100% of stocks and be credited for it each year.
Proposed Change: Remove section or revise language to close this potential loophole.