ncx-gitbot
commented
2 years ago NCX response: We appreciate comments noting that the structure and performance of the baseline model used within this methodology is strongly influential on the predicted and realized climate impact of projects. Our revised methodology increases transparency rather than following an expert review process. This includes both detailed documentation of particular models used, as well as sharing benchmarking and performance information for baseline models. Finally, the revised approach to uncertainty explicitly accounts for imprecision in the baseline model in calculating the final number of credits generated from projects developed under this methodology.
Commenter Organization: International Emissions Trading Association (IETA)
Commenter: Ellen Lourie
2021 Deferred Harvest Methodology Section: 1e. Appendix a: baseline common practice harvest model (addressing transparency)
Comment: In Appendix A, the proposed methodology provides a high level, generalized framework for project implementation. Based on the information provided, projects using this methodology could seemingly take very different implementation approaches, leading to inconsistencies in approaches that affect the quality of one project to the next. Although the NCX generalized methodology in Appendix A was approved by an expert panel, the results of this expert analysis are not available for public review. It states future proposed approaches may also be proposed and must pass expert review. This raises several concerns, including: will there be consistency in who is selected for the panel; against what criteria will the panel be assessing baseline models; will the verification body review the model, or simply rely on the approval of the approach by the expert panel? IETA requests that Verra make the results of the expert analysis available for public review, and implement a transparent process for selecting expert panels, and the expert review process (including the criteria and review). We encourage Verra to make the methodology more thorough, conservative, and replicable, by increasing transparency.
Proposed Change: No Proposed Change