in DR Congo

Is Wildlife Work’s Mai Ndombe REDD+ project “additional”?

For a REDD project to generate carbon credits, the project developer has to write a story about what would have happened without the project. This story, or baseline scenario, is crucial to REDD. As long as the actual deforestation is less than the deforestation in the baseline scenario, the REDD project can generate carbon credits.

The project developer’s story allows an exact figure to be put on the number of carbon credits generated by the project.

Obviously, it is the project developer’s interest to write a story about the impending destruction of the forest in the REDD project area. Equally obviously, it is impossible check whether the project developer’s story is accurate or not because it is a story about something that did not happen.

We ought to jettison the whole concept of additionality

A 2016 paper in the International Forestry Review concludes that, “the baseline scenarios in REDD+ projects amount to untestable guesses”.

And as Larry Lohmann of The Corner House points out,

If baselines are unverifiable, there can be no effective criteria for distinguishing between “bogus” and “nonbogus” baselines. And to say that a project is “nonadditional” implies that with some effort, it might be made “additional”, but again this is not the case. If there can be no criteria for distinguishing between “additional” and “nonadditional” projects, we might as well just come out and say frankly that there is no such thing as additionality and we ought to jettison the whole concept.

Unfortunately though, the concept of additionality has yet to be jettisoned.

Last week Jutta Kill and Rainforest Foundation UK submitted a Public Comment about the second verification of Wildlife Works’ Mai Ndombe REDD project in the Democratic Republic of Congo. The Mai Ndombe REDD project provides a good example of how ridiculous the concept of additionality actually is.

Mai Ndombe REDD project: A brief history

The Mai Ndombe REDD+ project started operations on 14 March 2011. It covers an area of 299,645 hectares in Mai Ndombe province. The project was developed by a Canadian carbon trading company called ERA Ecosystem Restoration Associates Inc. In its announcement of the project on 4 April 2011, ERA stated that,

This project will consist of two distinct activity types: Improved Forest Management (IFM) and Reduced Emissions from Deforestation and Degradation (REDD+). The IFM portion of the project will result in the cessation of active commercial logging activity. The reduction of illegal logging and the reduc­tion of unsustainable forest clearing for agriculture and fuel wood will be addressed in the REDD+ portion of the project.

ERA explained that in the first year, the project would generate Verified Carbon Units (VCUs) from the IFM part of the project.

In March 2012, ERA announced a joint venture with Wildlife Works to run the Mai Ndombe REDD+ project. In October 2013, Wildlife Works Carbon bought ERA’s share in the project (by this time ERA was a subsidiary of Offsetters Climate Solutions Inc).

In 2012, Det Norske Veritas Climate Change Services AS (DNV) validated and verified the Mai Ndombe REDD+ Project to the CCB standard, and at the same time to the VCS standard. So far, just over 2.5 million VCUs have been generated in the period between 14 March 2011 and 31 October 2012.

The Mai Ndombe project is currently undergoing a second verification process to the Climate, Community and Biodiversity Alliance Standards. The second Monitoring and Implementation report is available here (English, French and Lingala translations of the summary are also available).

Project developer’s additionality claims

Jutta Kill and Rainforest Foundation UK’s public comment (available here) focusses on the “additionality” claims made in the project documents – claims that were accepted in previous CCB and VCS assessments.

The Mai Ndombe REDD project consists largely of two former logging concessions. A company called BIMPE AGRO had delegated logging operations on the concessions to SOFORMA. In December 2008, these two concessions were cancelled under an Interministerial Commission set up to review the legality of logging concessions in DRC.

Nevertheless, ERA, the project developer when the Mai Ndombe REDD project was first validated and verified, argued that logging was imminent. Kill and Rainforest Foundation UK write in their comment that,

The project developer’s additionality argument in the August 2012 PDD [project design document] rests on the claim that in 2010, the Minister of Environment had agreed to a proposal by SOFORMA to swap a concession the company held elsewhere in the country for the two concessions held by BIMPE AGRO in the Mai Ndombe area, which had been cancelled in 2008.

According to ERA, the Minister of Environment “agreed by written letter” to SOFORMA’s swap offer. But “after further consideration”, in March 2011 he signed a Carbon Rights Agreement with ERA.

ERA stated in its PDD that in 2011, DRC had lifted its moratorium on the issuance of new logging concessions. In fact the moratorium is still in place. Kill and Rainforest Foundation UK argue that swapping concessions would be in breach of the moratorium.

In its 2012 Validation report, DNV accepted ERA’s additionality claim:

DNV is able to certify with a reasonable level of assurance that the emission reductions from the “The Mai Ndombe REDD Project” during the period 14 March, 2011 to 31 October, 2012 amount to 2 548 715 tonnes CO2 equivalent after a 25% buffer pool deduction amounting to 849 572 tonnes CO2 equivalent.

Kill and Rainforest Foundation UK ask what evidence DNV assessed apart from the letter from the Minister of Environment (which has never been made public) to accept ERA’s additionality claim.

A changing story?

Wildlife Works’ second Monitoring report, released on 1 August 2017, changes the additionality story. Instead of the story being about imminent logging due to swapped concessions, Wildlife Works argues that the forests have already been logged, opening them up to “slash and burn agriculture”. Wildlife Works states that,

The Mai-Ndombe REDD+ project area has undergone forest logging three times in the past, with the state-owned company, FORESCOM, first in the 1920’s, then Bimpe Agro in the 1980’s, and most recently by SOFORMA from 2003 to 2008. While logging activities do not usually directly result in total stand destruction, the removal of large trees and forest openings facilitate clearing for cassava and corn cultivation by locals. SOFORMA’s logging intensity is particularly destructive as it leads to a high number of trees being removed. This creates important openings that favor extension of slash and burn agriculture, forest degradation and eventually complete deforestation (cascade of deforestation).

Next to this statement is a photograph of “Unsustainable slash and burn agriculture leading to deforestation in the project area.”

The man sitting on the felled tree with the red cap is Prince Ea, a US rapper, poet and filmmaker. He visited Mai Ndombe in 2015 to promote sales of carbon credits from REDD projects via the USAID-funded website “Stand for Trees”.

From a recently cleared area of forest inside the Mai Ndombe REDD project, Prince Ea asks “Why are forests being destroyed at such an enormous rate?”

He doesn’t mention that the forest was cleared by some of the poorest people on the planet. Or that four years of the Mai Ndombe REDD project doesn’t seem to have improved things much.

Instead, he holds up a US$100 bill. “For this,” he says. “Today we live in a world where destroying trees makes you money.”

“Spurious ‘additionality’ claim”

Of Wildlife Work’s additionality claims, Jutta Kill and Rainforest Foundation UK conclude that,

It is our view that the project proponents of the Mai Ndombe REDD+ project have from the start failed to present a convincing case that continuation of (legal) industrial logging within the two former logging concessions that make up the REDD+ project area, was imminent and could reasonably be considered a credible baseline scenario. It is incomprehensible how such a spurious ‘additionality’ claim could have passed sound assessment of a VCS validation and CCB validation and verification assessment by the auditing company, DNV. . . .

In our view, REDD+ credits issued to the Mai Ndombe REDD+ project must therefore be considered blatantly ‘non-additional’, because the project lacks a convincing baseline.


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