Comment: These concerns are amplified by the suggestion to allow tonne-year accounting across the entire Verra AFOLU portfolio. At this broad level, we are concerned it will be difficult to impossible to provide adequate public disclosure, expert analysis, and public comment. If tonne-year accounting is to be considered, it should only be at the methodology level.
Commenter Organization: International Emissions Trading Association (IETA)
Commenter: Ellen Lourie
2021 Deferred Harvest Methodology Section: No Section Indicated
Comment: These concerns are amplified by the suggestion to allow tonne-year accounting across the entire Verra AFOLU portfolio. At this broad level, we are concerned it will be difficult to impossible to provide adequate public disclosure, expert analysis, and public comment. If tonne-year accounting is to be considered, it should only be at the methodology level.
Proposed Change: No Proposed Change