Eligibility and offset compensation should be based upon whether a project, technique or practice sequesters carbon or otherwise reduces GHG emissions. USDA should establish an activity baseline for each offset project type in effect on January 1, 2001 with standardized methodology. We support the establishment of a static baseline of activity to measure against when determining additionality. The fixed baseline should establish which practices were in effect on a specific piece of land on a specific date; any activity that results in GHG reductions measured against that baseline should be deemed eligible/additional.I'm not sure why they used Jan 1, 2001 as the magic date. Nor do I know if they consulted with anyone from NRCS (or FSA) as to the feasibility of doing this. I know the acreage reports submitted to FSA provide some information on the activity on the land, but I don't know whether it's sufficient to be used for this purpose.
If and when it comes to writing legislation, there are lots of issues to be addressed. For example, there's a maintenance question--if farmer Jones was doing no-till on her acreage in 2000, does she have to have continued no-till in the years since? How about shifts in practices among the fields on the farm? And how do the bureaucrats encapsulate the requirement? (See my earlier mention of "conserving base".) Might it be another layer(s) added to the GIS?
But I'm sure this proposal is causing some bureaucratic hearts in NRCS to beat much faster.