By separating out the credits that represent growth and selling those credits as removals, would carbon offset project developers and landowners be stranded with avoided emission credits that could not be sold if there is a preference for only removals? This would be detrimental to the creation of new IFM and REDD projects in general, and the emphasis on removals-only completely ignores the incredible co-benefits of the protection of the standing carbon in the forest that include protection of forest diversity through existence of uneven aged stands, soil health, watersheds, habitat, opportunities for recreation, and nutrient cycling. Also, from an efficiency standpoint, protecting standing forests takes immediate action to keep the long-lived pollutant of carbon out of the atmosphere immediately, and among the forestry sequestration options of afforestation, reforestation, and forest restoration, restoring natural forests is by far the most effective way to sequester carbon on a per acre basis.
A preference for removals from forestry projects can have some unintended consequences as crediting only removals through growth can incentivize landowners to cut stands of trees in order to have high-growth opportunities for removals. This perverse incentive could lead to an immediate threat to standing carbon. In contrast, the additionality argument for protecting mature stands of trees grows as the trees age since landowners have an increasing incentive to cut mature stands of trees that will yield large amounts of valuable timber.
The simple preference for removals is a bit too myopic when it comes to the complex challenge of reducing ubiquitous greenhouse gases. Restrictions on qualifying activities will not only increase the cost of compliance as neutralization action become limited, but it will also neglect the many co-benefits of avoided emission projects and create some perverse incentives that could lead to immediate increases in carbon emissions. Creating greenhouse gas reduction guidance for companies that does not allow avoided emissions to qualify will likely lead to the abandonment of important avoided emission mitigation activities.
 “Planting Trees is Good. Saving Forests is Better. Protecting People and Nature is best,” Martha Stevenson and Linda Walker, World Wildlife Fund, April 28, 2020, https://www.worldwildlife.org/blogs/sustainability-works/posts/planting-trees-is-good-saving-existing-forests-is-better-protecting-people-and-nature-is-best
 “Restoring Natural Forests is the Best Way to Remove Atmospheric Carbon,” Simon Lewis, Charlotte Wheeler, Edward Mitchard, and Alexander Koch, Nature, April 2, 2019, https://www.nature.com/articles/d41586-019-01026-8