I have some concerns with the proposed approach to 'Tree Equity' for international projects. There are a number of components of the credit language that lack the detail that would give project teams a clear understanding of what is required. For example, how is the 'surrounding community' defined for the tree cover site assessment? How is 'lower tree canopy presence' defined (what is the benchmark)? It is also uncertain what happens for projects that do not identify underserved populations in the viscinity - are they exempt from this requirement?

I feel that we should consider removing the direct connection to equity and simplifying the focus of this portion of the credit to increasing tree canopy (which would appear to better mirror the requirements for US projects). The ability for a project to provide meaningful shade to neighboring properties will be limited in many cases. For projects that are able to accomplish that, it feels like grounds for an exemplary performance or innovation credit.