Comment Details
| Comment Author: | Scott Morgan |
| Organization: | The Evergreen State College |
| Comment Date: | Thursday, 13 August 2009 |
| Comments: |
Comments specific to Section 6: Permanent: I understand the critical importance of long-term, permanent offsets. However, I think that there should be serious consideration for parity of time scales between the additionality criteria and permanence. IF additionality is addressed is such a way that the baseline criterion moves as our understanding, science, and measurements improve (which I believe is a necessary approach) THEN permanence should be tied to a similar or complementary time-frame. Otherwise, there is a strong likelihood of creating a long-term market containing many low efficiency offsets created during the early years that could not qualify under more mature criteria, yet that retain a value similar if not identical to higher efficiency offsets created under the more mature criteria. Long-term value guarantees independent of actual valuation can significantly skew the market. Of course, we do need long-term offsets, and the producers need some incentive and assurance that their project will retain value without unexpected de-valuations because the 'science' changed. But, we also need effective offsets. I apologize that I don't have any solutions to suggest at this time. I have a great deal of respect for the work that you are doing, good luck. |