Comment Log Display

1.	During ALM project verifications, the farmers are very concerned
about revealing too much information to the general public and
other farmers. These disclosures were not as inclusive and
revealing as the ones required in the rice protocol. A system to
obscure some information from the general public, perhaps by making
OPOs anonymous to all but ARB, the project developer, verifier and
consultant, should be devised.

2.	Waiting for additional information on bailing rice straw residue
as a project activity is wise. What would the destination of the
straw be? What are the repercussions to SOC when crop residues are
gleaned from rice fields? However, we urge active research to
resolve the issue, and include baling as an activity if studies
demonstrate no adverse environmental effects.

3.	It is not clear whether every field must be verified at each
verification. If so, a sampling of fields to be visited by
verifiers, using methods similar to the risk analysis method in the
CAR protocol, should be considered.

4.	During the pilot verification program, please consider studying
the possibilities of holding verifications over several eligible
crop years, rather than each one.

5.	Enacting early drainage activities in preparation for harvest
requires that verification bodies send crop experts into each field
to verify the stage of growth of the rice at the time of field
drainage. Unpredictable growing conditions may require that the
crop expert visit fields two or more times to first document the
stage of crop growth, and then to document the degree of drainage
in the field. The stated purpose for verifying the stage of growth
is to ensure that rice yields do not suffer as a result of the new
management practice. This requirement seems unnecessarily onerous.
It will increase verification costs significantly and potentially
interfere with farming operations if the verification body is
delayed for unforeseen reasons.

The requirement to verify the stage of crop growth during growing
operations puts the verifier in an awkward position of being a crop
consultant instead of an unbiased third party.

Maintaining crop yield should be left entirely to the grower.
Carbon offset credits are unlikely to reach a price that would
tempt a farmer to reduce crop yields in order to develop them.
Since yield must be reported, why not apply a deduction in offset
credits when there is a significant decrease in yield for weather
conditions of that growing season?

In addition, time-stamped photos are already depended upon to
document the timing of drainage operations. Perhaps a method can be
devised to remotely monitor and document the growth stage of the
crop without a series of costly early site visits, if proving the
growth stage at the time of field drainage is indispensable.