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Created January 24, 2023 18:41
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Peter Tittmann Review Comments on Chapter 13

  1. Land Sector and Removals Guidance | Greenhouse Gas Protocol [Internet]. [cited 2023 Jan 20]. Available from: https://ghgprotocol.org/land-sector-and-removals-guidance

(1/24/2023, 9:35:56 AM)

“If relevant, companies shall separately report GHG credits based on whether they are emission reduction 28 credits, removal credits, or a combination.”

(“Land Sector and Removals Guidance | Greenhouse Gas Protocol”, p. 244)(pdf) Why do they need to be reported separately?

Credits used against compensation targets vs. contribution or financing targets”

(“Land Sectorand Removals Guidance | Greenhouse Gas Protocol”, p. 244)(pdf) This distinction is really difficult to understand. An example would help. The explanation is insufficient.

Inset credits vs. offset credits”

(“Land Sector and Removals Guidance | Greenhouse Gas Protocol”, p. 245) (pdf) The distinction between insets and offsets is not meaningful and should not be used. “inset” is jargon in this context and a misuse of the word. An offset can be use to offset emissions internally or externally. there is no need for the word “inset”

purchasing or”

(“Land Sector and Removals Guidance | Greenhouse Gas Protocol”, p. 246)(pdf) By definition, insets would not be purchased. It would simplify the explanation if the use of the term inset was eliminated.

improvement”

(“Land Sector and Removals Guidance | Greenhouse Gas Protocol”, p. 246)(pdf) normative terms are not helpful. I believe ‘emissions reduction’ would be more accurate.

Additionality The intervention (e.g., project or activity) reduces emissions or increases removals relative to the amount of emissions or removals that would have occurred without the incentives provided by the credit. Credible baseline GHG reductions or removals are quantified relative to a realistic, defensible and conservative estimate of GHG reductions or removals occurring in the baseline scenario or performance standard. With respect to removals, a credible baseline may be zero if no removals were likely to occur in the absence of the intervention.”

(“Land Sector and Removals Guidance | Greenhouse Gas Protocol”, p. 247)(pdf) These items may be redundant. “Additionality” is based on establishment of a credible counterfactual baseline. Suggest combining these two would simplify and clarify.

No net harm Interventions reflected within the GHG reduction or removal credits adhere to social, economic, ecological and environmental safeguards to avoid unintended harm. Projects should comply with applicable legal requirements, be free of human rights violations and be gender sensitive. Some programs require that projects proactively advance social and environmental co-benefits, as well as monitor and report on these benefits. Companies should strive to maximize co-benefits associated with GHG projects to meet a variety of social, economic and environmental objectives (such as health, climate resilience, biodiversity, etc.) and contribute to the United Nations Sustainable Development Goals, and to monitor, report and verify these impacts to the extent possible.”

(“Land Sector and Removals Guidance | Greenhouse Gas Protocol”, p. 248) (pdf) While the intent here is noble, the definition and criteria to measure are so nebulous as to be meaningless.

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