Please consider the following comments relevant to the Agriculture and
Forestry sections of the Draft\
Technical Guidelines for Voluntary GHG reporting. While generally
commending the DOE and USDA on a\
pragmatic and thoughtful approach to designing a system that is likely
to become a national standard, we\
offer the following suggestions and critiques, tagged by Chapter,
section and page number:\
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Agricultural Emissions and Sequestration\
1.H.4.2.2: Crop production sources\
\
p. 191:\
Allowing an \"A\" rating for N2O estimates derived from generalized
emission\
factors, with no adjustment for specific site conditions, seems
inconsistent\
with other DOE reporting standards. There is abundant research evidence
that\
these factors grossly overestimate emissions in some agricultural
environments,\
such as Montana wheatfields, while underestimating them in wetter
environments.\
While acknowledging that practical alternatives to the use of
generalized\
emission factors may not yet exist, we believe that according full
weight to\
reported reductions based on such general emission factors will
undermine the\
credibility of the entire agricultural program. Therefore, we would
advocate that\
the DOE recognize the uncertainty inherent in this practice by awarding
a \"C\" (at best)\
rating to its results, reserving the \"A\" rating for reports resulting
from extra efforts,\
such as empirical observations or modeling (e.g. using DAYCENT).\
\
\
1.H.4.3.2: CO2 fluxes on Mineral Soils\
\
p. 198: Assuming emissions only in 1st year of cultivation lets\
all long-term convenitonally-tilled fields off the hook for emissions,\
even if they are still being molboard-plowed. CENTURY shows that plowing
can\
still result in emissions even if field has been cultivated for a\
long time. Model results are supported by experiments in Minnesota by\
D.C. Reicosky, who demonstrated large short-term CO2\
fluxes following MB plowing in fields that have been cultivated for\
many years. So this assumption seems a GROSS oversimplification that
will\
result in biased reporting.\
\
p. 199-200: Similarly, assuming an immediate loss of \>=40% of C stocks
in\
first year of cultivation would over-penalize a farmer who reverts\
to conv cultivation for one or a few years following years of
conservation\
tillage. See above: conventional tillage as currently practiced may\
not necessarily deplete C stocks if there is a high rate of residue\
return.\
\
p. 201: COMET\'s uncertainty estimation procedure is not documented
anywhere.\
How does it account for both bias and random error?\
\
p. 205. Assuming that re-establishing water table in cultivated
histosols\
will result in net C gain ignores the issue of CH4 \-- which could be\
higher if the soils are/have been fertilized. Further research is
urgently\
needed to document these fluxes.\
\
1.I.2.6. Forest Carbon.\
\
p. 228: Natural disturbance is an excludable emission source (for an
entity,\
any emissions \<3% of total gross are excludable). However, presumably
if\
natural disturbance affects C accumulation on a site you also couldn\'t
get\
credit for it.  Model-based evaluation of forest C increments could
help\
factor out the effects of natural disturbance (see above comments on\
baseline values).\
\
p. 230: Sustainable management. SFI has been widely discredited by
forest\
advocates as a weak certification system, although FSC gets good marks.\
\
2.3: Base periods and base values\
\
With reference to Gen. Guidelines (S. 300.8) on Base periods etc:\
\
Limiting registration to post-2002 reductions (2002 baseline):\
We join the majority opinion in preferring that pre-2002 reduction,
going\
back, for example, to 1995, be permitted for consistency with the
original\
stated goal of the enabling legislation, which was to provide a
mechanism\
to credit early action. The mere reporting of early actions does not
constitute\
a crediting mechanism.  Further, we believe that the implementation of a
fixed\
2002 baseline, if applied to agricultural and forest offset projects,
will\
seriously undermine efforts to develop a credible market\
for offset credits derived from these sectors.  This is because\
many agricultural and forest conservation projects were undertaken by\
pro-active individuals and organization during the 1990s, at least\
partly in anticipation of an eventual market for offset credits.\
\
If the 1605(b) program is to serve as the ultimate national reporting\
standard it must take into account the unique opportunities and
constraints\
that exist in the agricultural and forest sectors. These include the
long-term\
and multi-purpose nature of carbon-sequestering activities such as
forest\
planting, land set-asides, and altered tillage systems. They also
include\
the possibility of perverse incentives in the event of late baseliness
that,\
for example, encourage farmers to temporarily implement intensive
tillage\
in order to set a high baseline flux rate and benefit from a later
shift\
to conservation tillage. Additionally, early adopters and good land\
managers are punished by not being able to benefit from their early
shifts\
to conservation tillage or their participation in land restoration
programs.\
\
p. 247. The use of the \"prior year\'s carbon stock\" as a base value
fails\
to account for non-anthropogenic influences on carbon fluxes from
terrrestrial\
ecosystems. Some accounting for climate and other natural impacts on
rates\
of carbon stock change, such as the inclusion of a \"without-project\"\
scenario in the accounting procedure, must be incorporated into the
reporting\
guidelines for credible reporting in this sector.\
 Further, we do not believe that treating annual net fluxes as
reportable\
reductions effectively addresses the business-as-usual issue because it\
fails to distinguish between management and natural influences.\
\
As a general comment, we strongly advocate the development of a reward\
structure for early adopters that permits programmatic recognition, as
in\
the Conservation Security Program, of good stewardship practices that
maintain\
carbon stocks in soils and biomass.\
\
\
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Patrick Zimmerman, Director\
and\
Karen Updegraff, Research Scientist\
South Dakota School of Mines and Technology\
Institute of Atmospheric Sciences\
501 East Saint Joseph St\
Rapid City, SD 57701\
605-394-2294