Public Comment: 11 (William Sonnenfeld)

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Commenter Organization: WillSonn Advisory, LLC

Commenter: William Sonnenfeld

2021 Deferred Harvest Methodology Section: 9

Comment: VVB look at the program forest at time 0 and time 1, the period during which the property is under contract for deferral. This ignores the opportunity to "learn" and refine the likelihood assessments by measuring carbon stocks on non-program properties with similar forests and similar ownership groups.

Proposed Change: If a landowner foregoes harvests during the deferral period, while non-participating landowners with similar forests (same age, same size, same stocking, same species, same markets, same ownership group) continue to harvest, then that provides evidence of additionality. However, if neighboring landowners are also deferring harvests of similar forests during the deferral period (waiting for their forests to grow, or to add value, or to allow more time for prices to increase), this provides evidence of a lack of additionality. This assessment of nearby and similar landowners operating under similar circumstances should be a key component of third-party verification of additionality. It may also be used to provide a more applicable estimate of leakage.

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NCX response: Our baseline model is informed by observed harvesting behavior in forests across the U.S. As the first project cycles close, we will have the capability of fine tuning the baseline model with information from non-enrolled forest properties.