ncx-co / ifm_deferred_harvest

Documents, Data, and Code. The NCX Methodology For Improved Forest Management (IFM) Through Short-Term Harvest Deferral.
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Public Comment: 85 (Ellen Lourie) #85

Closed ncx-gitbot closed 2 years ago

ncx-gitbot commented 2 years ago

Commenter Organization: International Emissions Trading Association (IETA)

Commenter: Ellen Lourie

2021 Deferred Harvest Methodology Section: 1b. Project boundary

Comment: In relation to the project boundary, IETA is concerned with the exclusion of harvested wood products (HWPs). The exclusion of HWPs from the baseline is not conservative and doesn’t follow the best practices established in other forestry methodologies. The additionality of the project is based on the premise of avoiding harvest that would otherwise 100% occur in a specific year. Much of the carbon removed in baseline harvests would continue to be stored long-lived wood products. The carbon is these products is not emitted to the atmosphere immediately upon harvest as the methodology currently suggests. It is common and best practice to include HWP’s in their carbon accounting, this is because it is realistic and conservative to compare harvested wood occurring under the baseline and project scenario. Excluding HWP risks resulting in a significant pool of dubious credits being issued.

Proposed Change: No Proposed Change

ncx-gitbot commented 2 years 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.