In response to a request for information from the US Department of Agriculture (USDA) to support the preparation of proposed regulations intended to implement the Greenhouse Gas Technical Assistance Provider and Third-Party Verifier Program, Sky Harvest provided the input included below.
RE: Docket No. AMS-LP-24-0012-0001; Greenhouse Gas Technical Assistance Provider and Third-Party Verifier Program
Dear Associate Administrator,
Thank you and the U.S. Department of Agriculture (“USDA”) for the opportunity to provide comments and thank you for proactively demonstrating the initiative to understand and provide regulatory guidance to this emerging, maturing carbon market. Sky Harvest supports the USDA’s interest in regulation to implement the Greenhouse Gas Technical Assistance Provider and Third-Party Verifier Program (the “Program”) and in-turn to improve quality standards across the Voluntary Carbon Market (“VCM”) as a whole.
Today’s market is a product of self-organization and self-regulation. It is rife with conflicts of interest. Recent attempts to self-regulate (IC-VCM, et al.) appear to be largely on-track to affirm the broken status quo. For regulation to successfully advance consistency, reliability, effectiveness, efficiency, and transparency, we need a new framework for regulation, one determined by a body in the absence of current market incentives. Sky Harvest believes the USDA could be such a body. We believe we offer such a framework: Carbon 2.0.
Carbon 2.0 presents a new definition for carbon credits. This new definition (i) quantifies the duration and timing of a credit (in addition to mass) and (ii) ensures a “pay-upon-delivery” model (rather than the payment for future promises of carbon dioxide storage). The success of the carbon market depends on rigorous quantification, and today’s status quo—limited to measuring mass only and “pay-for-promises”—is neither rigorous nor fully quantified.
The Carbon 2.0 framework requires multiple tonnes of carbon dioxide to be combined into each credit issued to ensure the impact of that credit properly and completely offsets the negative impact of greenhouse gas emissions, which remain in the atmosphere forever. This framework is broadly applicable to every type of carbon credit (as demonstrated by the United Nations’s Article 6.4 proposal, Section 5.2) and remains imperative to the successful growth of the VCM.
In the following pages are responses to select questions asked in the Request For
Information (“RFI”), including information about a methodology for improved forestry management developed specifically within the Carbon 2.0 framework. Throughout Sky Harvest’s responses is an overarching theme: that any regulation of the VCM should necessarily consider the Carbon 2.0 framework.
I ask that you duly consider the arguments included in this letter. Then, upon due consideration, I call on the USDA to publicly endorse Carbon 2.0 as an improved framework for carbon accounting. Our team is humbly at your service to help. The implications of perpetuating the status quo will yield grave consequences for the future of carbon markets and the future of global warming.
Sincerely,
Will Clayton
CEO, Sky Harvest
Sky Harvest is a VCM project developer working exclusively with small-acreage[1] and underserved[2] private foresters in the United States to generate carbon credits. More importantly, Sky Harvest is voluntarily issuing credits under the Carbon 2.0 framework, which requires us to issue fewer credits but ensures that each credit we issue properly and completely offsets the negative climate impact of emissions elsewhere. To our knowledge, we are the only developer issuing credits with multiple tons of carbon in each credit.
For additional information and citations on the science behind Carbon 2.0, we incorporate the following resources as part of this letter by reference:
• Attachment A: Carbon 2.0: A Better Yardstick for Carbon Markets
• Attachment B: Carbon 2.0 Calculator
Answers to the RFI’s Specific Questions
Question 1: How should USDA define the terms “consistency,” “reliability,” “effectiveness,” “efficiency,” and “transparency” (see 7 U.S.C. 6712(c)(1)(A)) for use in protocol evaluation?
Consistency: The ability of a protocol to produce repeatable and uniform results
Reliability: The degree to which a protocol consistently produces accurate and dependable outcomes over time and in an evolving market
Effectiveness: The extent to which a protocol achieves its purpose i.e., assessing environmental outcomes of a climate change mitigation activity
Efficiency: The ratio of the beneficial outcomes to the resources expended to generate the beneficial outcomes, under the protocol
Transparency: The clarity with which a protocol and its results are documented, communicated, and made accessible to the public
Question 2: What metrics or standards should USDA use to evaluate a protocol's alignment with each of the five criteria to be defined in Question 1? What should USDA consider as minimum criteria for a protocol to qualify for listing under the Program?
To achieve the five criteria described above, the USDA should consider the Carbon 2.0 framework as a minimum criterion for any protocol to qualify for listing under the program.
Carbon 2.0 is applicable to any and every type of carbon credit protocol
Carbon 2.0 measures mass, duration, and timing of carbon storage (rather than just mass, as is measured in Carbon 1.0 – today’s broken status quo)
Carbon 2.0 eliminates the possibility of so-called “carbon reversals” and thus the need for complicated mechanisms to compensate for reversals (e.g. buffer pools), which are inherently rife with conflicts of interest
Carbon 2.0 ensures that credits are issued upon delivery of verified environmental benefit (rather than speculation of promised environmental benefits for decades to come)
Carbon 2.0 standardizes credit quantification and issuance across projects of varying durations, which is, perhaps, of most importance to the USDA where nature-based solutions are particularly relevant
Carbon 1.0 – today’s broken status quo – only measures tons of carbon dioxide stored.
It assumes that one ton stored for any duration is equal and opposite to carbon emitted from a smokestack forever. Thus, the offset. However, “any duration” ≠ “forever”. The scales don’t balance. And negative impacts outweigh positive impacts, affecting the climate and society, who are left holding the bag.
Carbon 2.0 balances these scales. It requires equivalence between the environmental impact of emissions and offsets: “emissions-equivalence.” Emissions equivalence is an important fundamental principle of any crediting protocol.
At the core of Carbon 2.0 is a simple metric called a ton-year. One ton-year represents one metric ton of carbon dioxide stored for one year. Built into this metric are mass (tons) and duration (years). Using ton-years as the key metric, one can simply measure the number of ton-years associated with the emission of one ton of CO2 into the atmosphere, to understand the required number of ton-years in an “emissions equivalent” carbon credit. Fortunately, IPCC scientists already performed this measurement.[3] All that is needed now, is for a regulatory body, like the USDA, to adopt emissions-equivalence as a principle of its program and Carbon 2.0 as the mechanism through which emissions-equivalence is implemented.
The Carbon 2.0 framework and its key metric, ton-years, will greatly increase the USDA’s alignment with all five criteria listed above:
Consistency: Variability in credit quality due to varying project duration requirements will no longer exist because all credits will be required to demonstrate emissions equivalence.
Reliability: Buyers of credits can rest assured that they are buying emissions-equivalent credits, with outcomes that have already occurred and been verified. This is very different than today’s market where any credit is subject to reversal risk at any point in time and the credit may not be emissions-equivalent in the first place
Effectiveness: Emissions-equivalence ensures that the targeted reductions in greenhouse gas emissions are achieved. Carbon 1.0, today’s broken status quo, is a bad deal for climate for three reasons:
The positive impact of credits is less than the negative impact of emissions (it’s like giving away $1.00 not knowing if you’ll receive $1.00, or $0.00, or anywhere in between in return)
The positive impact of these credits is predicated on multi-decade contracts and promises that may simply go unenforced
The positive impact of these credits is always subject to risk of reversal due to natural disasters, which have historically been under-accounted for by buffer pools
Efficiency: Issuing credits under an emissions-equivalent, ton-year-based framework creates tremendous flexibility and efficiency. Landowners, unwilling to participate in multi-generational contracts are now free to enroll in shorter-term contracts, with confidence that what they cannot commit in years, they can make up for in tons to generate the same number of ton-years and the same high-quality, emissions-equivalent carbon credit. Consequently, this unlocks a tremendous latent potential for climate action that today remains dormant. Private forest landowners, ranchers, and farmers currently on the sidelines of climate change could quickly be brought onto the field to contribute.
Transparency: The adoption of Carbon 2.0 creates a single, clear framework for quantifying carbon credits across projects of varying durations and timing. Auditors can simply run verified measurements through an emission equivalence calculator.
Question 3: In general, after a new protocol is published, how long does it take for a project to use the protocol and be issued credits (i.e., what is the lag time between protocol publication and first credit generation)?
No response.
Question 4: Which protocol(s) for generating voluntary carbon credits from agriculture and forestry projects should USDA evaluate for listing through the Greenhouse Gas Technical Assistance Provider and Third-Party Verifier Program?
Any protocols that utilize Carbon 2.0 as the underlying carbon accounting framework.
One such protocol is the Sky Harvest Carbon 2.0 Methodology for Improved Forest Management, which is discussed in further detail in Question #5 below.
Question 5: For any protocol(s) identified under Question 4:
(a) Has the protocol resulted in the generation and sale of credits? If yes, when was the most recent year and volume of credit generation and retirement? If not, is there evidence that the protocol will generate credits (e.g., projects are under development)?
Since its inception in 2021, Sky Harvest has already contracted with underserved and small-acreage landowners across ~30,000 acres in four Southern states and successfully executed and received payment for the sale of its Carbon 2.0 carbon credits to 25 customers from the energy, tech, and finance sectors. The business model is poised to explode nationwide, and awarded funding from the USDA IRA Forest Landowner Support Program will accelerate that growth. By the end of the decade, Sky Harvest is prepared to enroll millions of acres.
(b) What is the average size (in acres, hectares, or another relevant unit) of projects using the protocol?
The size of a project can vary dramatically because the methodology allows for
“grouped projects,” which means the project can represent a mosaic of noncontiguous parcels owned by separate landowners in the same project.
There is no minimum threshold for landowners to enroll in a grouped project. We have a landowner with as few as 30 acres enrolled. Due to efficiencies gleaned from aggregating parcels into a grouped project and due to efficiencies gained from the use of remote sensing technology, projects are uniquely economical even with small parcels enrolled in a mosaic.
Within Sky Harvest’s existing project, landowners must qualify as either small-acreage (<2,500 acres) or underserved (per the USFS Landowner Support Program’s definition). This is not a requirement of the methodology writ large.
(c) What is the average credit issuance per unit land area (acre or hectare) for projects using the protocol, inclusive of credits that are contributed to a buffer pool?
The average credit issuance per acre can range from 0.5 to 2 credits per acre per year, depending on the type of volume of carbon, growth of the trees, and the maturity of timber. Note: this is after credits have been run through the Carbon 2.0 quantification framework that accounts for the short duration of carbon dioxide storage. For clarity, it is worth noting that stands of trees contain many more tons per acre of carbon at any given moment, but because Carbon 2.0 only issues credits upon delivery of environmental benefits, this number is heavily discounted when considered on an annual basis.
Buffer pools are irrelevant under Carbon 2.0 because Carbon 2.0 credits are issued only for the storage of carbon dioxide that has already occurred: the issue-upon-delivery model. Ipso facto, it cannot be reversed. In this model, if a wildfire burns a forest, the project cannot issue any more credits in future years, but the credits previously issued are still valid.
(d) Does the protocol reduce the cost, paperwork, and/or reporting burden for smaller, diversified, or underserved farmers, ranchers, or private forest landowners, while maintaining the reliability of offsets? If yes, how?
Yes, the entire methodology is designed to be compatible for smaller, diversified, or underserved private forest landowners, while maintaining the reliability of the offsets.
The landowner must simply apply to the program through a user-friendly web interface, and then sign a contract with the developer. Thereafter, the landowner only has to do three things: (i) not harvest their timber, (ii) provide periodic property access to foresters to measure timber, and (iii) cash their check.
The Sky Harvest contract was designed to be beneficial to smaller, diversified, and underserved landowners:
Landowner benefit | Impact |
• No minimum acreage requirement | Broader access to all landowners |
• No upfront payment | Broader access to all landowners |
Flexibility, broader access | |
• Annual payments | Consistent, predictable cash flow |
• Price certainty throughout contract term | Limited downside risk |
• Price renegotiation upon renewal | Available upside benefit |
The last two bullet points create a particularly favorable risk disposition for Sky Harvest landowners because they receive price certainty in a volatile carbon market without sacrificing the potential for significant upside gains as the market matures and prices increase.
Moreover, the contract structure also addresses a number of barriers preventing landowner access to carbon markets not specifically mentioned in the question:
Barrier | Under-served | Small acreage | Strategies for addressing |
Multi-decadal contracts | ✓ | ✓ | Five-year commitment period [6] |
Upfront costs | ✓ | ✓ | No upfront payment |
1-time or delayed payments | ✓ | ✓ | Annual payments |
Price uncertainty | ✓ | ✓ | Price certainty throughout contract term |
No benefit from rising prices | ✓ | ✓ | Price renegotiation upon renewal |
Unaware of programs | ✓ | ✓ | ‘Recruitment’ subproject |
Mistrust of carbon programs | ✓ | ✓ | Work through trusted channel partners |
Mistrust of others generally | ✓ | ✓ | Work through trusted channel partners |
Enrollment is difficult | ✓ | ✓ | Automate user-friendly, web enrollment |
Unequipped to perform | ✓ | ✓ | None required (harvest deferral) |
Cannot afford to perform | ✓ | ✓ | No costs; income covers ownership costs |
Contracts are confusing | ✓ | ✓ | Simple, endorsed contracts with assistance |
Credits do not hold value | ✓ | ✓ | Carbon 2.0 framework ensures value |
Min. acreage requirements |
| ✓ | No minimum acreage requirement |
(e) Does the protocol allow multiple entities to aggregate into a single project? If yes, what are the parameters for aggregation and is there evidence that aggregation has successfully occurred?
Yes, the methodology allows for aggregation or “grouped projects.” The parameters for aggregation are described below in an excerpt from the methodology. Aggregation has successfully occurred in Sky Harvest’s projects.
This methodology allows grouped projects.
A grouped project is a project to which additional instances of the project activity (“project activity instances” or “PAIs”), which meet pre-established eligibility criteria, may be added subsequent to project validation.
Grouped projects shall specify a clearly defined geographic area within which a PAI may be developed.
Grouped projects shall include one or more sets of eligibility criteria for the inclusion of new project activity instances. A set of eligibility criteria shall ensure that new project activity instances:
Meet the applicability conditions set out in the methodology applied to the project.
Use the technologies or measures specified in the project description.
Apply the technologies or measures in the same manner as specified in the project description.
Are subject to the baseline scenario determined in the project description for the specified project activity and geographic area.
Have characteristics with respect to additionality that are consistent with the initial instances for the specified project activity and geographic area. For example, the new project activity instances have financial, technical and/or other parameters (such as the size/scale of the instances) consistent with the initial instances, or face the same investment, technological and/or other barriers as the initial instances.
Grouped projects provide for the inclusion of new project activity instances subsequent to the initial validation of the project. New project activity instances shall:
Occur within the designated geographic area specified for the project
Conform with the eligibility criteria for the inclusion of new project activity instances.
Be included in the monitoring report with sufficient technical, financial, and geographic detail, as well as other relevant information to demonstrate conformance with the applicable set of eligibility criteria and enable evidence gathering by the validation/verification body
Be included in an updated project description, with updated project location information, which shall be validated at the time of verification against the applicable set of eligibility criteria.
Have evidence of project ownership, in respect of each project activity instance, held by the project developer from the respective start date of each project activity instance (i.e., the date upon which the project activity instance began reducing or removing GHG emissions)
Have a start date that is the same as or later than the grouped project start date
Be eligible for crediting from the start date of the project activity instance through to the end of the project activity period
Not be or have been enrolled in another GHG project
The baseline scenario and project scenario shall be determined for each PAI. Additionality shall be demonstrated for each PAI.
A PAI may leave the grouped project at the end of the project activity period. When an instance leaves a grouped project prior to the end of the project activity period, the project shall:
Conservatively assume a loss of all previously verified removals associated with the PAI; or
Continue to monitor the PAI for the remainder of the instance’s project activity period. If a loss is identified, the size of the loss shall be quantified accordingly and subtracted from any subsequent crediting periods. Where the continuation of monitoring is not possible, the project shall conservatively assume a loss of all previously verified removals associated with the PAI.
(f) Does the registry administering the protocol use a fee structure that allows for aggregated entities to pay a single project fee, or does each entity need to pay a project fee?
All registry fees are paid by the developer, not the landowners. A single registration fee is allowed for grouped projects.
(g) What are the verification requirements in the protocol, including recordkeeping requirements?
This question can be answered with excerpts from the methodology.
Validation requirements:
The validator must be ISO accredited and qualified to validate this project type. The validator must validate the project design document (PDD) for its adherence to this methodology. The PDD is not required to be validated prior to the start of the project activity period; however, the PDD is required to be validated prior to verification and issuance of credits for the first credited period. If the project developer decides to validate the PDD after the project start date, the risk of non-compliance and/or project invalidation is on the project developer.
Validation should conform to the principles and requirements of ISO 14064-3.
Verification requirements:
The verifier must be ISO-accredited and qualified to verify this project type. The project shall maintain its PDD. The project shall share the PDD, monitoring report, and relevant supporting documentation with the verifier, which will collectively be used for verification by the verifier. These are designed to be the guidance documents that auditors shall use to develop a project-specific risk assessment and sampling plan.
The verifier must verify the project documentation to ensure that the measurements, assumptions, and calculations adhere to this project methodology and ISO 14064-2 and that the quantified GHG impact described in the monitoring report occurred. The verifier may perform field visits, audit calculations, or use remotely sensed data to perform verification. The verification should yield a conclusive report and confirm the final number of credits to be issued.
Verification should conform to the principles and requirements of ISO 14064-3.
Upon the successful completion of verification, the verifier shall issue a verification statement, prepared in accordance with ISO 14064-3.
Data management requirements:
The project developer must establish and apply quality management procedures to manage data and information, including the assessment of uncertainty, relevant to the project and baseline scenario. The project developer should reduce, as far as is practical, uncertainties related to the quantification of GHG emission reductions or removal enhancements. Note: The project developer may apply the principles of ISO 9001 and ISO 14033 for managing data quality.
Furthermore, the project developer must establish and apply data security procedures to ensure data protection from the threat of manipulation, breach of landowner confidentiality, or loss. The project developer at a minimum must store data in at least one redundant, secure location for 5 years beyond final credit issuance.
(h) Does the protocol require on-site verification? If yes, does the protocol require
100% on-site verification, or does the protocol specify a procedure for determining an on-site verification sample group? What is required as part of the on-site verification? Does the protocol allow remote verification methods/technologies (e.g., remote sensing)?
Yes, the protocol requires on-site verification.
The project requires 100% data coverage using remotely sensed data. This can be 100% verified by the verifier by tracing remotely sensed data back to the third-party data provider’s data source.
The verifier must also perform on-site verification for a sample of the plot data that is used to calibrate remotely sensed data. The plots sampled for verification must be randomly selected. On-site verification must ensure that the data recorded confirms with reality of the trees present within the plot.
(i) Does the protocol include a risk management approach for determining which data inputs or project sites are required for third-party verification? If yes, what does the risk management approach require?
Yes, the protocol includes a risk management approach for determining which data inputs or project sites are required for third-party verification because it requires that all measurements, assumptions, and calculations are verified, with the exception of plot measurements from which a sample must be verified. Because of the use of third-party remotely sensed data, verification of these data, assumptions, and calculations can be performed without extensive effort.
(j) Does the protocol allow for simplified measurement, monitoring, reporting, and verification (MMRV) processes? If yes, are there requirements or restrictions for using the simplified MMRV processes?
No, the protocol does not allow for simplified MMRV. However, the protocol was designed to utilize large data structures so that the MMRV is inherently simplified to begin with. Developers may build their own systems to automate data flows and further reduce the cost of MMRV without reducing the auditability of MMRV.
(k) What quantification methodology(ies) does the protocol require for quantification of emissions reductions and/or removals? What scientific evidence is available to support these methodologies?
The protocol uses the Carbon 2.0 quantification framework, the only high-integrity yardstick for measuring emissions-equivalent carbon credits. Through this framework assessment of stored carbon dioxide is extended beyond mass (tons) to duration (years) and timing (post-issuance). Further, carbon credits are only issued after environmental outcomes have already occurred and been verified.
The body of scientific evidence supporting Carbon 2.0 is vast and dates back to the IPCC in the early 1990s. Citations footnoted in context can be found in the protocol, available upon request.
For convenience, many of those footnotes have been included here:
Forster and Ramaswamy. “Changes in Atmospheric Constituents and in Radiative Forcing.” IPCC. (2007).
Joos, Fortunat & Roth, R. & Fuglestvedt, J. & Peters, G. & Enting, I. & Von Bloh, Werner & Brovkin, V. & Burke, Eleanor & Eby, M. & Edwards, Neil & Friedrich, Tobias & Frölicher, Thomas & Halloran, Paul & Holden, Philip & Jones, Chris & Kleinen, Thomas & Mackenzie, F. & Matsumoto, K. & Meinshausen, Malte & Weaver, Andrew. (2013). Carbon dioxide and climate impulse response functions for the computation of greenhouse gas metrics: A multi-model analysis. ATMOSPHERIC CHEMISTRY AND PHYSICS. 13. 10.5194/acpd-12-19799-2012.
Wigley et al., 1998; Shine et al., 2005; Allen et al., 2016; Edwards et al., 2016
Schmalensee, Richard. 1993. "Symposium on Global Climate Change." Journal of Economic Perspectives, 7 (4): 3-10.
Mallapragada, D.S., Mignone, B.K. A theoretical basis for the equivalence between physical and economic climate metrics and implications for the choice of Global Warming Potential time horizon. Climatic Change 158,107–124 (2020).
EDF, WWF, Oko-Institut, “What makes a high-quality carbon credit?” (2020).
Intergovernmental Panel on Climate, C. Global Warming of 1.5°C: An IPCC Special
(l) For protocols where models are required to quantify emissions, is there a process for model review and approval prior to use by prospective projects? Can approved models be used by any project or are they specific to a project developer?
Yes, the protocol strongly recommends that the simulation of carbon stocks over time is performed with the USDA’s Forest Vegetation Simulator (FVS). Please see the below excerpt from the protocol:
Simulation of carbon stocks over time
The project developer must then reformat the timber inventory for upload into the USDA’s Forest Vegetation Simulator (FVS E).7 FVS is selected as the default vegetation simulator because it is a peer-reviewed forestry model approved by Verra8, American Carbon Registry[7], and Climate Action Reserve[8] for establishing carbon stocks and projecting growth of carbon stocks accordingly.
Note: The project developer may choose to use another forest growth modeling tool other than FVS, provided that such tool is research-based, peer-reviewed, of equivalent standard as FVS, and developed and maintained by a third party over which the project developer has no influence or control and in which the project developer owns no equity.
(m) If models are allowed for quantification of emissions reductions, are models required to have gone through scientific review, parameterization, calibration, and validation to demonstrate performance for the practices on the relevant crops and/or species in the geography of the project? Does the protocol provide clear guidance on where eligible models can be applied?
The protocol discourages models other than USDA’s Forest Vegetation Simulator (FVS). The protocol does require that any alternative models must be “research-based, peer-reviewed, and of equivalent standard as FVS.” The protocol does not provide further specifics on how such models are to be validated. This is a potential area for improvement in future versions of the protocol.
(n) What does the protocol require or allow for determining a project baseline?
To determine the project baseline, the protocol requires the project developer to perform a timber inventory within the project area:
This timber inventory will be used for two purposes: (i) to determine the amount of carbon in the baseline and project scenarios and (ii) to determine the value of the timber in the baseline and project scenarios as a determinant of each individual stand’s additionality….
The project developer must perform the timber inventory for the entire project activity area or, in the case of a grouped project, for each PAI, prior to the first issuance of credits. Stand growth shall be modeled using timber modeling software (i.e. FVS) from the year of the timber inventory to the start and end years of the credited period. The project developer may also optionally elect to perform the timber inventory at both the beginning and end of the credited period, in which case timber growth does not need to be modeled and may be ascertained by the difference in measurements between the two inventories.
In the case of a subsequent crediting period under renewed contracts, a subsequent timber inventory is required for any credited period in which the end date of such credited period is more than ten years from the most recent timber inventory.
In addition to the timber inventory, a comprehensive inspection of the forested project area must be performed both at the beginning and end of the credited period to assess the tree cover ratio to determine if any harvesting occurred during the credited period. The project developer is encouraged to use remotely sensed imagery (e.g., satellite, aerial, lidar) to perform this tree cover inspection. A tree cover inspection is required for every credited period.
The following sections outline the requirements of the timber inventory….
The protocol goes on to describe in detail the process for defining forest stands, on-the-ground plot sampling, remote sensing analysis, the specifications of the final timber inventory, and the simulation of carbon stocks over time. It continues…
The project developer must simulate two scenarios: a Baseline Scenario where the timber is harvested immediately and a Project Scenario where the timber is maintained for the credited period and then harvested. Both scenarios must be modeled for 100 years… All emissions that occur during the 100 years are then modeled in the atmosphere for the subsequent 1,000,000 years, which is effectively equal to infinity.
Using this approach, the project developer can compare the project scenario to the baseline scenario to measure the carbon exchanges between the atmosphere and the biosphere (either in wood in the stand or wood removed from the stand as merchantable timber) over time.
Lastly, the methodology provides the specific equations used to establish the project baseline. For example:
Equation 1
Where ......
The equation tree includes 37 different equations, like the one above, which can be provided to the USDA upon request.
(o) How does the registry administering the protocol restrict the potential double counting of credits?
No response. Registries are better suited to answer this question because it is their area of subject-matter expertise.
(p) Does the protocol require projects to quantify and report uncertainty associated with greenhouse gas calculations?
Yes, uncertainty is quantified and reported. The protocol also requires an uncertainty deduction based on the calculated uncertainty factor. Equations are provided in the methodology for calculating the uncertainty factor.
(q) Has the protocol generated credits which were later canceled due to issues of credit integrity or validity?
No.
(r) For project categories where reversals (i.e., the intentional or unintentional release of sequestered carbon for which credits have been issued) are possible, does the protocol contain procedures to maintain net GHG impact?
As mentioned above, Carbon 2.0 eliminates the possibility of reversals.
(s) Where is information about the protocol made publicly available?
The Sky Harvest Carbon 2.0 Methodology for Improved Forest Management is available upon request and has already been shared with the U.S. Forest Service. It will be publicly available on the registry and the Sky Harvest website, after registry validation is complete.
Question 6: How should USDA evaluate technical assistance providers (TAP)? What should be the minimum qualifications, certifications, and/or expertise for a TAP to qualify for listing under the Program?
USDA should publicly endorse Carbon 2.0 and TAPs should be required to be familiar with Carbon 2.0 to ensure high-quality credits are issued under this framework.
In addition to other requirements not expressed here, we recommend a qualification process for TAPs, requiring them to complete a Carbon 2.0 certification process to ensure well-qualified TAPs. Sky Harvest is willing to make available its network of experts and/or team’s time to assist in such efforts.
Question 7: Should the qualifications and/or registration process be different for entities and individuals that seek to register as a TAP?
We do not believe that the qualification process should differ.
Question 8: What should be the minimum qualifications and expertise for a third-party verifier to qualify for registration under the Program?
The International Standards Organization could serve as the standard under this program. VVBs should be ISO accredited (or ANSI accredited, which is the US version). The relevant accreditation is “ISO 14064-3: 2019”
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Sky Harvest appreciates the opportunity to provide input. We are committed to supporting USDA's efforts in advancing sustainable agricultural and forestry practices through effective carbon credit protocols and technical assistance programs. If we can be of any further assistance in explaining the mechanisms of Carbon 2.0, please do not hesitate to contact us.
[1] Less than 2,500 acres
[2] As defined by the U.S. Forest Service’s Landowner Support Program
[3] Joos, Fortunat & Roth, R. & Fuglestvedt, J. & Peters, G. & Enting, I. & Von Bloh, Werner & Brovkin, V. & Burke, Eleanor & Eby, M. & Edwards, Neil & Friedrich, Tobias & Frölicher, Thomas & Halloran, Paul & Holden, Philip & Jones, Chris & Kleinen, Thomas & Mackenzie, F. & Matsumoto, K. & Meinshausen, Malte & Weaver, Andrew.(2013). Carbon dioxide and climate impulse response functions for the computation of greenhouse gas metrics: A multi model analysis. ATMOSPHERIC CHEMISTRY AND PHYSICS. 13. 10.5194/acpd-12-19799 2012.
[4] The status quo for carbon projects is multi-decadal contracts.
[5] Note: Sky Harvest—alone amongst project developers—compensates for the shorter-term duration of CO2 storage through Carbon 2.0, so that the credits issued are still of high integrity and offset the cost of carbon dioxide emissions elsewhere.
[6] Note: Sky Harvest—alone amongst project developers—compensates for the shorter-term duration of CO2 storage through Carbon 2.0, so that the credits issued are still of high integrity and offset the cost of carbon dioxide emissions elsewhere.
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