in Cambodia, DR Congo, USA

Responses from Terra Global Capital, VCS, and Wildlife Works to Fern’s report, “Unearned credit: Why aviation industry forest offsets are doomed to fail”

In November 2017, Fern published a report titled, “Unearned credit: Why aviation industry forest offsets are doomed to fail”. The report takes aim at the aviation industry’s planned carbon trading mechanism, the Carbon Offsetting and Reduction Scheme for International Aviation.

CORSIA is a cap-and-trade scheme without the cap. Aviation emission will increase alarmingly. Emissions above 2020 levels will be offset. CORSIA utterly fails to address the aviation industry’s impact on the climate.

Currently, aviation emissions account for about 5% of greenhouse gas emissions. According to a 2015 report by the German environmental research organisation Öko-Institut produced for the European Parliament, that figure could reach 22% by 2050.

After Fern’s report was published, Virgin Atlantic stopped buying carbon credits from the Oddar Meanchey REDD project in Cambodia. The project was one of two case studies in the report. The other was the Mai Ndombe REDD project in the Democratic Republic of Congo.

Terra Global Capital, VCS, and Wildlife Works have each put out statements in response to Fern’s report. The statements are posted here in full and unedited.

Response: How FERN actively uses forest communities as a political tool depriving them of much needed resources

Terra Global Capital, January 2018

A response to FERN’s paper “Unearned Credit”

  • Communities working on the literal frontier of deforestation are being used as a political tool by FERN in their recent report – (“Unearned Credits – Why aviation industry forest offsets are doomed to fail”) – a group who emphatically opposes the use of market based solutions without regard to the negative impact it has on forest dependent communities.
  • FERN’s actual target is the ICAO CORSIA mechanism, a much needed and landmark initiative which uniquely brings together government, airlines and NGO’s to develop rules for use of offsets for aviation carbon neutrality.
  • Accountability of the social and environmental outcomes from forest projects are a much needed and industry has gone to great pains to continually iterate and improve practices – however this does not justify the mistruths perpetuated by FERN, which cannot go unanswered.

What is clear from the recent Fern report “Unearned Credits – Why aviation industry forest offsets are doomed to fail” is that Fern has a negligent misunderstanding of how forest offsets work, but more deplorable is its mission-driven goal to drive away desperately needed financial resources from rural, impoverished communities who protect their forests. This report has been widely publicized and reported on as a “truth”, further driving away those few organizations willing to reward communities for results and again throwing cold water on a sizable opportunity that the airlines could provide to finance reduced deforestation and degradation around the world.

Shame on you Fern and others who seek to limit opportunities for communities that desperately need financial resources to protect forests and make a decent living without offering any viable alternatives. Before Fern and others who have never designed or managed a REDD+ program start to criticize the hard work of communities and the partners that support them, they should 1) get their facts straight as the Fern report has numerous completely false statements and gross misunderstandings of the actualities on the ground and how forest offsets work, and 2) they should not misinterpret cause and effect. The Fern reports attempts to claim that carbon offsets are not an effective or legitimate way to reduce deforestation, and that in some way the purchase of offsets funds deforestation. However, in truth, it is the lack of funding to communities that leads to deforestation, which could be addressed through sale of offsets.

The negative impact of the world’s unwillingness to provide finance for audited results of reducing deforestation on communities, exacerbated by Fern and others, can be viewed through the Oddar Meanchey project that was falsely maligned in the Fern report. The ongoing and long term success of reducing deforestation and degradation depends on a number of key factors for the Oddar Meanchey project: 1) communities’ secured land tenure and on-going interest in protecting their forests as part of their community forestry plans, 2) financial resources to implement the activities needed on-the-ground to address drivers of deforestation and degradation, build livelihoods and provide technical support for communities (where needed), and 3) government/local enforcement support for communities protecting their forests. Without these three components, it is difficult for the communities to protect their forests from the pressure of deforestation.

For the Oddar Meanchey project, the 13 communities groups led by the Monks Forest, continue to have legal tenure over their forests and work to protect it. However, trees do not protect themselves, and resources are needed to fund the activities the communities need to undertake to address the drivers of deforestation. For the Oddar Meanchey communities, this has been difficult because carbon revenue was to be the main source of funding for ongoing implementation of on-the-ground activities, which would have provided the necessary income to protect forests and build community’s incomes. But carbon sales have been very limited over the last four years due to lack of global demand that Fern and others continue to negatively impact. And with very few funds available to the project from the Cambodian Government’s limited budgets and the lack of interest from international donors to support the project, it is left underfunded and unable to finance the communities’ implementation of activities. This is not a failure of the project, communities, project proponents, carbon developer, or market standard. It is a failure of the market for carbon and the shift that international donors have made away from supporting on-the-ground REDD+ activities to paying millions of dollars to governments for national level REDD+ readiness and results-based payment programs which will not likely trickle down to Oddar Meanchey in the near future.

As it relates to the government/local enforcement support, while resources are limited and some areas of enforcement may still be difficult, the project has made some progress recently. The project is near the border with Thailand which has had some unrest, and one driver of deforestation is encroachment of Cambodia Military camps being setup in the communities’ project area. Over the last couple years with the support of the Forestry Administration, communities, military and local police, the number of camps within the project areas has been greatly reduced.

For the Oddar Meanchey REDD+ Project, the development of carbon offsets provided a structure and method for independent accounting for social and environment benefits and produced an environment asset/service that could be monetized to provide long-term funding for communities’ sustainability in managing their forests. It is the world’s first Climate, Community and Biodiversity triple gold verified project for its added community, biodiversity and adaptation benefits. The problem was not with creating the offsets, it was with the fact that globally there was limited value placed on the credit credits that were generated by the communities for reducing deforestation. Had the communities of Oddar Meanchey been able to sell the first set of one million verified emission reductions, they would have had the funding required to support their on-the ground activities for up to seven years, empowering them with the required resources needed to reduce deforestation and improve their livelihoods. Without finance, there is no question that deforestation risks have increased since the end of the last monitoring period. Since the project has received virtually no funds to implement activities from sale of its environmental assets, from the government or donors, they lack the resources to address the deforestation drivers impacting their forest areas.

Shame on you Fern and others who criticize and impede a system (while not 100% perfect) that places value on independently audited results of communities reducing deforestation and degradation. You state your mission is “to achieve greater environmental and social justice, focusing on forests and forest peoples’ rights”. Your position on forest credits does exactly the opposite as you work to rip away the most important stream of finance from the airline industry that communities desperately need to protect their forest and make a decent living.


Well Earned Credits: How Aviation Industry Forest Offsets Can Effectively Reduce Global Emissions


This document is intended to address claims made in the recent Fern publication, “Unearned credit: Why aviation industry forest offsets are doomed to fail”. The purpose of this response is to correct the inaccurate and misleading arguments made by Fern in respect of both how the Verified Carbon Standard (VCS) Program functions and how forest carbon projects using the VCS Program (and greenhouse gas accounting standards more broadly) are designed, implemented and verified.

While the Fern paper authors are entitled to oppose offsetting from an ideological position, the ‘facts’ and sources used to support their analysis are flawed. Fern makes an emotional appeal but does not back this up with credible evidence. Rather, they point to old arguments about risks that made forest offsets unattractive to the EU Emissions Trading System (ETS) and the UN Clean Development Mechanism (CDM) a decade ago, without acknowledging the significant progress made since then by pioneering standards such as the VCS or by REDD+ projects that are today shining examples of how to stop deforestation and reduce emissions. Indeed, over the last decade the REDD+ sector has matured considerably, establishing itself as a well-accepted and credible approach to reducing GHG emissions while ensuring environmental integrity. Robust methods for the accounting, monitoring, reporting and independent verification of REDD+ activities have been transparently developed and effectively demonstrated around the world, and REDD+ is now a highly sought after offset type by both the public and private sectors. In fact, over recent years, forest carbon projects have become the most demanded offset type by informed corporates looking to robustly achieve their voluntary climate leadership goals.

By adhering to a standard such as the VCS, forest carbon credits are well-positioned to meet all of the UN International Civil Aviation Organization’s (ICAO’s) offset quality criteria and guiding principles. Looking to the future, VCS is also working to facilitate the integration of projects into emerging subnational and national REDD+ programs, incentivizing the continued engagement of local communities, indigenous land-managers, and other forest conservation stewards, along with much-needed private sector investment in REDD+.

This document first provides background on the VCS Program and then directly addresses each of the misleading claims made in the Fern paper as they relate to our program. The document then provides a summary conclusion.


The VCS Program allows verified projects to turn their GHG emissions reductions into tradable carbon credits. The VCS Program brings a high level of quality assurance to global carbon markets by ensuring all issued Verified Carbon Units (VCUs) represent GHG emission reductions that are real, measurable, additional, permanent and independently verified. The diagram below illustrates the various requirements VCUs have to meet.

VCS cares deeply about the integrity of its program. As a non-profit standard-setting body, VCS has strong incentives to maintain the integrity of its standards for the sake of the market and the projects it vets, both of which rely on VCS Program certification as a badge of quality. Projects developed under the VCS Program must apply an approved, technically-sound GHG accounting methodology and follow a transparent and rigorous assessment process in order to be certified. All VCS projects are subject to desk and field audits by both qualified independent third-parties and VCS staff to ensure that standards are met and methodologies properly applied. The VCS registry system, the central storehouse of data on all registered projects, transparently tracks the generation, retirement and cancellation of all VCUs. VCS maintains an impartial position in the carbon market and does not hold, transact or solicit trades of VCUs.

Because of the focus on integrity and credibility the VCS Program is the world’s most widely used voluntary GHG standard, both in the broader voluntary carbon market as well as the forest carbon market.


1. Additionality through Rigorous and Conservative Baselines

  • Claim: Any methods used to calculate baselines (or reference levels) will always be “highly imprecise” and “improbable”.
  • Reality: Well-established and sophisticated methods have been developed and demonstrated to ensure realistic and credible baselines for calculating forest carbon emission reductions and removals.

VCS addresses possible baseline inflation by outlining strict criteria for baseline setting using approved methodologies and a high level of rigor in validation and verification through third-party auditing. These best-in-class methodologies are carefully developed, typically over 12-24 months, through a robust multi-stakeholder process, including expert input, public comments and vetting by two independent auditing bodies. Reference areas chosen must be demonstrably similar to the project area, including having similar drivers of deforestation and degradation and socio-economic factors, among others. The requirements also mandate that the baseline be periodically revised (every ten years) to account for changing conditions and that all data and methods be transparent and publicly available – a fundamental principle of GHG accounting.

The Fern paper also overlooks another key rule of any credible GHG standard – the use of conservative estimates. All VCS projects are required to use conservative assumptions, values and procedures to ensure emission reductions are not overstated, and furthermore to discount reductions where uncertainty remains, including when that uncertainty relates to the selection of the baseline. Due to this conservativism, it is likely that each VCU actually generates more than 1 ton CO 2 e benefit to the atmosphere, rather than the opposite being true.

In addition, recent studies have shown that REDD+ project activities have been highly effective at reducing emissions compared to surrounding areas. A recent peer-reviewed study showed investments to reduce local communities’ dependence on forests had a statistically significant correlation with reduced deforestation rates and conservation outcomes.[1] This supports the conclusion that project baselines are credible, and that project activities result in real changes to the drivers of deforestation.

2. Ensuring Permanence by Pooling Risk

  • Claim: No forest carbon project can guarantee permanent emissions reductions.
  • Reality: While projects may include a physical “buffer” zone to promote sustainable livelihoods around project areas, they also mitigate permanence risk through the use of a non-physical “pooled buffer account.”

Fern demonstrates how little they understand about how the VCS Program works by conflating the term “buffer” and making the outlandish claim that the inclusion of physical “buffer zones” are the way the VCS Program ensures emission reductions are permanent. VCS utilizes the pooled buffer account for Agriculture, Forestry and Land Use (AFOLU) projects including REDD+ projects, to address the risk of non-permanent emission reductions. The buffer account is a single account that holds non-tradable buffer credits to cover the non-permanence risk associated with all AFOLU projects globally. A portion of all reductions achieved by an AFOLU project must be deposited into the buffer account based on the risk profile of the project. In order to quantify that risk, each VCS AFOLU project (including REDD+ projects) undertakes a risk analysis to assess internal, external and natural risks to then determine the portion of credits to be deposited into the pooled buffer account. The buffer account is managed to ensure any losses from individual project failures are covered. As opposed to claims made in the paper that use of a buffer is “hardly ever checked by auditors”, the process of calculating and depositing buffer credits is rigorously checked by third-party auditors at each verification. Since being pioneered by VCS, use of a pooled buffer to address non-permanence risk has now been accepted by many carbon markets, including California’s cap-and-trade system.

It should be noted that if there is a loss of forest in the project area, this deforestation is detected in the subsequent monitoring report and there is no issuance of VCUs for this loss. REDD+ is a payment-for-results system; therefore, if there has been no reduction in emissions nor increase in sequestration, no credits will be issued. In addition, buffer credits are cancelled from the pooled account to cover any losses – meaning all issued VCUs remain permanent and atmospheric integrity is maintained. The VCS pooled buffer account currently holds more than 22 million credits to cover such potential losses and ensure atmospheric integrity across the portfolio of projects.

The Ecuadorian project cited in the paper is not a valid example as it was never certified to any credible standard, let alone to the VCS. Poorly designed and implemented forest carbon projects using self-certification or standards with a low level of rigor unfortunately do exist. However, the fact that these low-quality projects exist is not a reason to exclude high-quality REDD+ projects from CORSIA and miss the enormous associated opportunity to drive finance to forest protection.

3. Effectively Managing Leakage

  • Claim: Preventing emissions from being displaced is beyond the scope of any carbon offset project, as projects have no power beyond their own geographical area.
  • Reality: This is a simplified argument and ignores what projects set out to do, which is to transform the forest economy to sustainable models, thereby removing the risk that destructive practices are simply shifted to another area. Furthermore, robust tools and methods are used for identifying, mitigating and accounting for leakage to ensure that credited forest emission reductions are real and not nullified by potential increases in emissions elsewhere.

Well-designed REDD+ projects may have very little to no leakage because they are effective at addressing the drivers of deforestation and transforming the forest economy. Indeed, there is ample evidence that VCS REDD+ projects often result in positive leakage where areas outside of the project boundaries adopt the practices being implemented by REDD+ projects, such as the implementation of sustainable agricultural practices to grow food without the need for shifting agriculture, which contributes to deforestation. Projects use rigorous methods to estimate any leakage, and to the extent that there is negative leakage, this must be conservatively estimated and always subtracted from the total number of GHG emission reductions eligible to be issued as VCUs.

For projects with localized drivers, the potential for leakage must be identified and the project must address the socio-economic factors that drive deforestation or forest degradation, often by providing economic opportunities for communities that transform the local economy and encourage forest protection. Leakage is calculated by monitoring forested areas surrounding the project and other forested areas within the country susceptible to leakage from project activities. VCS strongly encourages projects to include leakage management zones in the overall project design, which can help to maintain livelihood activities inside the project area, such as agroforestry on degraded land and sustainable production of non-timber forest products.

The Fern paper also claims that addressing leakage from large-scale agricultural/timber drivers is impossible for REDD+ projects. This is not the case and illustrates yet another example where Fern has misunderstood or willfully chosen to ignore VCS Program rules, which require projects to quantify leakage by directly monitoring the activities of the deforestation agent. Where such agents are driven by the demand for market commodities such as agricultural products or timber, the project must directly account for market leakage associated with the specific project activity. This is done by taking into account the supply and demand elasticities for the commodity and must be based on methods for quantifying leakage from scientific peer-reviewed sources.

4. Beyond No Net Harm – Engaged Communities at the Heart of REDD+

  • Claim: Forest offset projects cause real harm through conflict and criminalization of forest peoples, who often receive no benefits at all. Furthermore, the concept of “net harm” is problematic because if harm is net, this implies that harm to one person or community can be justified by compensating a different person or community.
  • Reality: VCS requires projects to identify any potential negative environmental and socio-economic impacts and mitigate them. The project must also establish mechanisms for communication with local stakeholders during project design and implementation, so concerns can be raised about any potential negative impacts, and must demonstrate to the auditor at validation and every verification that it has taken due account of all and any input received.

Positively engaged communities are the foundation of successful REDD+ projects. The vast majority of VCS AFOLU projects go above and beyond VCS requirements by also applying the Climate, Community and Biodiversity (CCB) Standards. In fact, 92% of VCS REDD projects by volume of issued VCUs apply the CCB Standards in some way. The CCB Standards, developed by leading NGOs, including CARE International, Conservation International, The Nature Conservancy, Wildlife Conservation Society and Rainforest Alliance, were designed to deliver credible, significant and net positive benefits for local communities (in addition to CCB’s climate and biodiversity benefits). Relevant requirements align closely with UNFCCC safeguard requirements and include the application of Free, Prior and Informed Consent (FPIC) to guide community engagement, equitable community benefit sharing and the appropriate resolution of land tenure issues.

Multiple studies have shown that REDD+ has created a drive to promote clarity on land tenure among other community rights. A study[2] by the Rights and Resources Institute (RRI) and the World Resources Institute (WRI) found that carbon finance saves forests by promoting indigenous rights. Research[3] by the Center for Global Development also shows a strong correlation between REDD+ and rights. In the same vein, a recent book “Forest Preservation in a Changing Climate: REDD+ Indigenous and Community Rights in Indonesia and Tanzania”[4] shows the positive impact of REDD+ projects on indigenous rights, stating that:

    “Project developers have indeed accorded significant attention to the participatory and substantive rights of local communities. This is consistent with emerging evidence on the ways in which REDD+ projects have sought to engage and empower communities around the world… It is striking that the overwhelming majority of the thirty-eight [studied] REDD+ projects have had some positive impacts on the rights of local communities and that very few appear to have engendered the sort of human rights violations that were feared by scholars and practitioners in the earlier stages of the global emergence of REDD+.”

5. Independent, Objective Third-Party Auditors

  • Claim: “Auditors have their own vested interest in exaggerated baseline scenarios” and “third-party auditors usually charge for their services depending on the volume of carbon credits a project generates.”
  • Reality: These statements are gross misrepresentations of the fact that auditors may charge more for large AFOLU projects due to needing to spend longer in the field to conduct rigorous audit work on a larger area. There is no incentive for auditors to see projects issue higher volumes of carbon credits.

Projects must contract an approved validation/verification body (VVB) to confirm that the project design meets VCS criteria and that all GHG emission reductions are quantified according to VCS requirements. Both VCS and accreditation bodies (i.e., members of the International Accreditation Forum and UNFCCC Designated Operational Entities, DOEs) oversee the work of auditing firms to assess their performance, which often requires corrective action on the part of the auditor. Obviously auditors have a strong incentive not to lose their accreditation and subsequently all of their business. VCS-approved auditing firms must understand the underlying requirements of the program they are auditing against and adhere to strict conflict of interest requirements in order to maintain their accreditation. These requirements work to ensure the integrity of the system.

6. Unique and Transparent VCUs

  • Claim: Credits from REDD+ projects have not been deducted from host country national GHG inventories; therefore they undermine environmental integrity and should not be accepted by CORSIA.
  • Reality: This misleading claim is based on a misunderstanding of how double counting will be prevented in the context of the Paris Agreement. While the Fern paper correctly points out that double counting needs to be addressed, the authors conveniently ignore the fact that comprehensive rules to prevent double counting under the Paris Agreement have not yet been developed by the UNFCCC, which makes it impossible for any credit from any GHG crediting program, VCS or otherwise, to comply with these rules.

The UNFCCC is currently in the process of developing rules to address double counting as part of Articles 6.2 and 6.4 of the Paris Agreement. Their goal is to have draft rules this spring and final rules by COP 24 in December of 2018. If the UNFCCC is successful in developing such rules, then countries will need to put in place procedures to enable compliance with the rules. At the same time, GHG programs (like VCS) who are interested in issuing credits that can be used for international compliance in schemes such as CORSIA will need to develop requirements that projects can follow to meet these rules. It should be noted as well that these rules will need to apply to all project types, not just REDD+. VCS is closely following the UNFCCC discussions and plans to update its rules when any new requirements are issued internationally to prevent double counting and thus ensure the integrity of carbon trading.

The broader point raised by the Fern paper relates to the need for having a transparent registry to track all units issued by a GHG crediting program, particularly if those units will be used across borders to meet compliance obligations, such as those created under CORSIA. To address this requirement, VCS projects must register with a VCS registry operator to ensure each issued VCU is assigned a unique serial number and is transparently listed on the VCS Project Database. Any time VCUs are verified, issued or retired, the information is publicly available. Further, key safeguards are in place to prevent the double counting of emissions reductions across different GHG programs.


REDD+ is a proven, efficient and effective way to achieve emission reductions as well as to provide additional benefits for local communities and the environment. It is in line with all of the goals and principles of CORSIA, and a supply of robust and cost-effective REDD+ offsets can play a key role in filling the emissions gap and supporting the aviation sector to meet its climate goals, while supporting developing countries, indigenous peoples and other land stewards in conserving their native forests.

Fern has a clear ideological stance against offsetting. Sources listed in its paper, such as REDD Monitor, have a well-established anti-REDD+ agenda and therefore should not be used as legitimate, independent, objective and peer-reviewed sources of information. Fern states upfront that the only purpose of carbon credits is to enable corporates to continue to pollute as they have in the past, ignoring the fact that the purpose of carbon crediting is to enable greater ambition while reducing compliance costs and providing a tool to companies with a carbon footprint to transition to low-carbon technologies. Such transitions can be costly and disruptive, particularly when investments in technology are long lived, such as the case with airplanes which last for 20+ years. Carbon credits can help smooth that transition while driving finance to sectors and project activities that can reduce emissions, such as REDD+. Beyond that, offsetting can bring critical funding to “non-productive” activities, including tropical forest conservation and restoration, that otherwise would find few incentives to be undertaken.

For the last two decades, REDD+ projects have targeted high-threat areas preventing millions of hectares from being deforested. These projects are delivering emission reductions while working successfully with local communities to protect forests, and increasingly with governments to ensure project alignment and integration with emerging subnational and national REDD+ programs. REDD+ is the best available tool to attract urgently needed private sector finance to reduce global deforestation. The aviation sector’s commitment to curb its emissions is an enormous opportunity to slow climate change, and to the extent it accepts REDD+ credits, help maintain the world’s remaining intact ecosystems and improve the livelihoods of forest-dependent people.






Rebuttal of Jutta Kill’s anti Mai Ndombe REDD+ Case Study
In the Paper entitled “Unearned credit – why aviation offsets are doomed to fail”


We feel it is important for context that we point out that Jutta Kill is a self-proclaimed enemy of REDD+ who has a history of being a hired gun for anti-REDD foundations who seek to discredit our work. This is not our first dealing with her. In fact this paper mostly references other prior papers written by Ms. Kill which we have previously discredited. FERN, the organization that published this report written by Ms. Kill is an NGO that has a clear anti carbon market position, because they believe that allowing any offsets to be sold in the market is delaying activity in reducing emissions in the industrial north. This is a philosophical position not specific to REDD+ offsets. We believe that there is no evidence to support this position, and in fact to the contrary studies have shown that companies that use offsets to achieve carbon neutrality are doing far more than the average company in their sector to reduce their own source emissions as well. Therefore both Ms. Kill and FERN have a longstanding record of looking for ways to discredit forest carbon offsets to support their view that they shouldn’t be allowed to exist.

Many of the arguments Ms. Kill uses in this FERN paper are actually just her opinion based on her opposition to the concept of market based REDD+ and offsets. It is clear that the REDD+ industry has addressed all the criteria needed to support ICAO, and that REDD+ is in fact a great option to require the airlines to use their financial growth to support reductions in deforestation, while they simultaneously invest in new fuel technologies that will reduce their own emissions. Opposition from these ideologue NGOs based on an idea that markets are bad and forests should just be left alone, are at best naive and at worst completely counterproductive arguments that will prolong the real world status quo of forests disappearing rapidly everywhere.

Detailed rebuttal of 8 assessments in the Mai Ndombe Case Study

Criteria 1: Additionality – PASS

Ms. Kill references her own prior reports as the basis for her assessment here, and her argument contains the following fatal flaws:

  1. The forest concession we took over in 2010 was not a new concession, it was an existing concession, that had been suspended pending settlement of tax issues and it was going to be reissued had we not intervened. We provided concrete evidence of this to two separate independent auditors of the project during the validation and verification audits. Ms. Kill in her prior attempts to discredit our work chose to make a wild speculation that the evidence did not exist, simply because she had not bothered to ask us to see it. The evidence contains sensitive documents which is why they are not part of the public record, but we at Wildlife Works have shared them with the auditors, our customers and anyone with a genuine interest in understanding the truth. Ms. Kill’s claim that our concession wouldn’t have been re-awarded due to the moratorium is absolutely false. In point of fact two other suspended concessions in the Mai Ndombe were re-awarded. Therefore our REDD+ project is clearly additional.
  2. All avoided deforestation REDD+ carbon offset projects are based on an avoided deforestation premise, or they wouldn’t exist, as clearly the forests we are protecting are still there, so to compare performance in protecting remaining forests you need to have a reference scenario or baseline to compare to of similar forests under similar threat that were recently deforested. Our Mai Ndombe project followed this common approach of finding the most relevant reference area to demonstrate the most likely business as usual case for the forest we are protecting. See below for more details.

Criteria 2: Based on a realistic and credible baseline – PASS

Ms. Kill clearly chooses to present false statements as facts to support her argument ignoring how REDD+ actually works. The Mayombe reference area for the Mai Ndombe project is not supposed to look like the Mai Ndombe forest now. The point is that it should have been the most similar to the Mai Ndombe project area at the beginning of the historical baseline period, so that what happened to Mayombe can in fact be the most realistic and credible evidence of what would happen to Mai Ndombe in the absence of the REDD+ project. The fact is that Mayombe is almost the exact same distance from Kinshasa as Mai Ndombe, and two decades ago at the beginning of the historical baseline period, the reference area in Mayombe was not a mosaic of farmland and forest, it was an intact forest the same size and type[1] as the Mai Ndombe project forest (See White, 1983), and was a logging concession operated by the same logging company that was operating the Mai Ndombe project area concession prior to Wildlife Works taking it over.

The fact that the Mayombe forest became aggressively deforested over the past twenty years under the management of the exact same logging company is precisely what provides the most credible baseline for the Mai Ndombe project. The argument that the company’s past behavior is the most likely predictor of future behavior is further supported by the fact that they owned two concessions in the Mai Ndombe, the one we took over and another immediately to the south of our concession that is now almost completely deforested.

Now that the Mayombe area has been completely deforested, the next frontier for forests is the Mai Ndombe. Our Mai Ndombe project is more than 50% of the frontier of the Congo Basin Forest closest to Kinshasa, and the population in our area is not at all sparse.

These actual facts were presented to the two independent audit reviews the project has undergone, and the auditors visited the reference area in Mayombe and reviewed all of the documentation and both came to the conclusion that our baseline was the most realistic and credible scenario.

Criteria 3: Quantified, Monitored Reported and verified – PASS

Ms. Kill’s only argument here is to suggest that because the auditors didn’t reach the same conclusion she did they must not be credible. In fact the auditors who are tropical forest experts did perform an exhaustive review of the additionality and the baseline scenario including visiting the reference area and the project area and examining all the factual evidence Ms. Kill chooses to overlook. Both of the independent audits were conducted by international firms that are accredited under international environmental auditing standards, including being qualified under the United Nations to audit climate projects. Furthermore, Wildlife Works is a conservation company that is making a 30-50 year commitment to these project communities where our goal is to mitigate climate change, create green economic development and enhance biodiversity. Our team of over 100 people in the Mai Ndombe are all Congolese working hard to support these rural forest communities of over 50,000 people. For Ms. Kill to suggest we would collude with the auditors to cheat is offensive.

Criteria 4: A clear and transparent chain of custody – PASS

Ms. Kill again presents an untruth as a fact and then draws an invalid conclusion to support her argument.

The project does in fact make publicly available the information to allow public monitoring of the carbon credits chain of custody. The Markit registry for the Mai Ndombe project does in fact track every single credit issued to the project by unique serial number from issuance to retirement, and double selling is impossible under this system.

Criteria 5: Represent permanent emission reductions – PASS

Once again Ms. Kill presents a fact and then draws her own flawed conclusion to support her desire to discredit REDD+. It is certainly true that REDD+ projects have to deal uniquely with the concept of permanence, because of course protecting a forest for one year and then seeing it destroyed means you just delayed emissions. That is why REDD+ projects must run for at least 30 years and must have a system in place to deal with reversals during that time period. That system for VCS REDD+ projects is an insurance buffer pool into which every project has to place a significant number of credits that cannot be sold, based on the independently assessed risk of each project so that if one project suffers a subsequent loss of forest that would negate emission reductions previously issued, those credits can be canceled and replaced by still valid credits from another project, maintaining the environmental integrity of any credits bought under the VCS system as a whole.

To quote EDF, an international NGO highly respected for their work at the UN climate level:

“Producing an equivalent output with less emissions than in a prior baseline scenario constitutes a permanent reduction in any economic sector. The UNIPCC Special report on Land Use, Land Use Change and Forestry, in discussing permanence of REDD+ results, notes that permanent emission reductions – whether they are from fossil or biological carbon – do not mean that a particular carbon stock is left underground or sequestered in a forest forever. The IPCC report states “…suppose that a homeowner replaces an incandescent bulb with a compact fluorescent, avoiding one ton of emissions over the life of the compact fluorescent. The benefit is not reversed even if an incandescent bulb is installed at the end of the compact fluorescent’s useful life.” Similarly, REDD+ programs that reduce the flow of carbon dioxide emissions to the atmosphere from the forest sector achieve benefits even if emissions increase later.

To address the possibility that emission reductions might be later reversed, REDD+ programs take additional steps, such as the establishment of diversified buffer reserves (i.e. reserves of reductions which are not transferred but which can be accessed to compensate for any reversals). Consequently REDD+ programs achieve greater CO2 benefits than other programs which do not establish such buffers.”

Ms. Kill presents a graph of deforestation in the Mai Ndombe project area as evidence that we have not been able to control deforestation, but there are a few problems with her presentation:

    1) She doesn’t show the project’s historical emissions baseline as a comparison of whether these emissions still represent a dramatic reduction against the baseline (they do)

    2) That the process of deforestation in a commercial logging concession begins slowly with roads and selective harvest of the merchantable timber, and then increases rapidly through a well understood process called the cascade of deforestation with illegal logging, fire and farming following the loggers into the concession, and this was an early stage concession with only 28,000 hectares having been logged before we took over

    3) Most importantly, that the two spikes in deforestation in 2010 and 2013 are the result of fires that spread into the concession and the whole Mai Ndombe province as a result of a massive cyclical drought that happened during these years. Such an event is difficult to predict. However, recovery is more likely to happen in protected forests as shown in recent deforestation analysis results that were not presented by Ms. Kill. In fact recent land use and land cover change from the same source shows net regrowth in the project area. Nonetheless, we are working with the communities to find ways to stop fire damage to the forest as well as to address all other drivers of deforestation in the project area and its surroundings.

    4) That we reported all emissions from fire in our concession and deducted those emissions from our performance against the baseline during our verifications, and the net benefit of our activities against the baseline were still dramatic.

Criteria 6: Safeguard against a potential increase in emissions elsewhere – PASS

Ms. Kill suggests that we don’t define how we will ensure deforestation is not displaced. This is simply untrue. We do define it, and it was supported by the independent auditors. There was at the time we began our project and there still is in fact a moratorium on NEW logging concessions. This is why the logging company was so aggressively trying to get this concession back. Without the logging company activity opening up the forest, the cascade described above cannot happen, therefore the moratorium was the basis for the fact that our emission reductions would not move elsewhere.

Criteria 7: Only counted once towards a mitigation obligation – PASS

Ms. Kill uses the same untruth that was used in her argument to Criteria 4 to make the argument that our emission reductions could be counted more than once against a mitigation obligation. They are tracked for their lifetime in an independent registry and cannot be double counted or double sold. Of course we all support an increase in scale to sub-national, national and global REDD+ to allow for an aggregation of site specific activity like our Mai Ndombe REDD+ project into the international climate accounting. In fact our project is at the heart of the world’s first sub-national program for the province of Mai Ndombe that Ms. Kill has also tried to stop as part of her ongoing war against REDD+.

Criteria 8: Do no net harm – PASS

Ms. Kill is again selectively reporting to suit her arguments. It is true that a majority of the forest concession overlaps customary forest ownership, but the REDD project does not deny the communities any access to forest for any reason. They are just told the benefits they can receive from the project if they avoid further deforestation, they are taught how to make more productive use of the land they have already cleared and they make their own decisions. Wildlife Works has no enforcement in the Mai Ndombe whatsoever. As a result of this approach we received legal written approval from all of those customary chiefdoms to operate our REDD+ project in their forest. This is not at all what led to conflict. In fact there was some opposition and even violence directed toward our REDD+ project in the early stages of the project from some elements in the communities Ms. Kill cites, but we have repeatedly demonstrated that this violence was financed by the logging company who had lost the concession to us, in an attempt to destabilize our project and see us fail so they could get the concession back. As time has passed and the communities throughout the project area have seen the benefits of the REDD+ project such as schools being built in other villages and the benefits being shared as promised, the logging company has stopped their efforts and the tensions have disappeared. It is important to note that to the best of our knowledge Ms. Kill has never set foot in our project area. On the other hand, contrary to her claim, the audit teams did in fact go to Kesenge (Ntomb’e Nzale), Mbale (Bolia) and Mpili (Basengele). They have heard community members expressing their initial concerns, based on the many false rumors they were told by representatives of the logging company, including our favorite, that we were stealing the oxygen from the forest to send to Canada, and that realizing they were being misled they now fully embrace the project. All communities in the Mai Ndombe REDD+ Project Area are in grave need of economic development. Their first priority is always to have a school built in their village.

The Mai Ndombe REDD+ project is a decades long project, so clearly we cannot build a school in every village all at once, but we have enacted a schedule that fits with our financial ability. This inevitably causes some minor discontent in some communities that the Project has not yet been more active in their area.


Wildlife Works Mai Ndombe REDD+ project represents the best of the potential of REDD+ to solve a very difficult problem of stopping deforestation while providing real sustainable economic development alternatives to one of the most impoverished communities in the world. We have been independently audited on multiple occasions over the past 7 years by highly respected international audit firms, and we are held accountable to extremely high scientific standards. We and other REDD+ programs around the world could benefit enormously from the sort of larger scale stable market for forest carbon offsets that access to ICAO’s CORSIA program might provide. Reports like this that use pseudoscience and opinion to thinly disguise an ideological opposition to any form of carbon offsets care nothing for the collateral damage they do to the very forest communities they pretend to represent, and are in our opinion disgraceful.

Mike Korchinsky
Founder and President, Wildlife Works
On behalf of the Wildlife Works Mai Ndombe REDD+ project team

[1] According to the DRC’s forest classification at the end of the 20 century, the Mayombe forest is categorized as a moist lowland forest, the same class as the Mai Ndombe forest. The Luki Man and Biosphere reserve in Mayombe features a remnant of this forest that shows the same physiognomic characteristics as the Mai Ndombe forest.


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