Response to Renoster’s “Pro Review” of the Mai Ndombe REDD+ Project
Jeremy Freund
Chief Technology Officer, Wildlife Works
April, 2024
Renoster is a for-profit company that conducts ratings for nature-based carbon projects. They recently conducted a “Pro Review” for the Mai Ndombe REDD+ Project which contains a number of factual inaccuracies, incorrect assumptions and obvious overstatements. Renoster’s reviews rate projects on a number of categories:
1. Additionality
2. Baseline
3. Leakage
4. Verification
5. Permanence
6. Co-benefits
The following are Wildlife Works’ responses to Renoster’s LinkedIn post containing a “Project Spotlight” outlining their more detailed review, according to each category. The more complete review is available on Renoster’s website:
Renoster “Baseline and Accounting”: “The project's baseline is marked by an aggressive forecast of near-total deforestation, relying on a distant reference region and modeling that predicts an unrealistic surge in deforestation rates.”
WWC Response
Project activity category and baseline scenario:
The Mai Ndombe REDD+ Project is defined under VCS activity categories as "Avoiding Planned Deforestation" (APD). This category is applicable because the project intervention is focused on reducing greenhouse gas emissions by preventing deforestation in areas that were legally authorized and documented for conversion to non-forest land, specifically through commercial timber harvest. The baseline (without-project) scenario is described by the “cascade of degradation”, which refers to the sequence of environmental degradation that would likely occur if the project activities were not implemented. This scenario anticipates the following sequence:
Commercial Logging: Legal logging by the primary agents opens up the forest, removing valuable timber and creating access for further exploitation.
Infrastructure Development: Roads and other infrastructure built for logging increase forest fragmentation and accessibility.
Increased Access and Illegal Activities: Easier access leads to illegal logging and encroachment, exacerbating forest degradation.
Agricultural Expansion: Cleared and accessible areas are then converted to agriculture by secondary agents, completing the process of conversion to non-forest.
Reference Area Selection:
Given the project activity category (APD) and the baseline scenario (cascade of degradation), the reference area for the Mai Ndombe REDD+ Project was selected based on key attributes that ensure it accurately reflects the potential deforestation and environmental impacts the project area would face without intervention:
1. Same Logging Company: The reference area was managed by the same company responsible for logging in the project area, ensuring consistent forestry practices in both locations.
2. Planned Deforestation: Both areas were slated for planned commercial logging by the primary agent, providing a direct comparison for assessing the impact of the project's conservation efforts.
3. Ecological Similarity: The reference area shares similar ecological characteristics with the project area, which is crucial for making accurate counter-factual inference.
4. Impact Evaluation: Serving as a control site, the reference area allows for effective measurement of the project's success in reducing deforestation and carbon emissions.
WWC Conclusions:
Renoster’s critique misses these important facts about the nature of the project category and baseline scenario, rendering their baseline critique inapplicable.
Renoster “Leakage and Carbon Estimation”: “A failure to address leakage and to apply deductions accordingly, combined with a gerrymandered proxy area, appears to overestimate the potential carbon savings dramatically.”
WWC Response
Leakage:
Despite the Renoster assertion that there was a failure to address activity-shifting and market leakage, this is not the case. The applicability of both were evaluated by the VVB at project validation, per the VCS accreditation process. Approval that leakage does not apply to the Mai Ndombe REDD+ Project is confirmed in the validation report:
1. Activity-Shifting Leakage: It is not applicable because secondary agents (those indirectly affected by project activities) do not have the mobility or access to migrate their activities to other forested areas. The areas around the project have already been converted to agriculture up to the limits of these agents' reach, thus making further deforestation unlikely.
2. Market-Effects Leakage: This type of leakage is also considered inapplicable. The primary agent, SOFORMA, could not be granted a new concession within the national boundary because there was a moratorium on NEW concessions that is still in place 15 years later, and they were already logging their other concessions to the maximum allowable extent. Therefore, there is no potential for this agent to increase logging activities elsewhere to compensate for reductions within the project area.
These justifications emphasize that under the current conditions and constraints, both activity-shifting and market-effects leakages were deemed inapplicable during the project’s design validation.
Proxy Area:
Renoster also asserts that the project’s proxy area is gerrymandered. This is patently false. The proxy area location was closely evaluated at project validation by the VVB and determined to be not only in compliance with methodological and standards criteria, but conservatively selected:
Definition Compliance: The proxy area complies with the project's definition of “non-forest,” which aligns with a refined definition that includes specific land use types like "forêt secondaire" (secondary forest). This secondary forest consists mainly of agricultural fields interspersed with residual tree cover, which are not considered forested under the project's criteria.
Methodological Requirements: The selection adheres to the methodology VM0009, which specifies that the proxy area should represent an area not forested as of the project start date and is used to estimate residual carbon stocks in the baseline scenario.
Conservative Approach: By including secondary forest in the proxy area and excising those areas from the project accounting area, the proxy area provides a conservative estimate of the baseline carbon stocks, ensuring that the project does not overclaim carbon credits.
Renoster further asserts that the selection of the proxy was made to purposely exclude swamp forest. This is incorrect. The reason the proxy area appears fragmented is because the selection criteria stipulates that the proxy area only contain non-forest, and has nothing to do with different forest types.
WWC Conclusions:
The alleged failure to address leakage represents a misrepresentation, misunderstanding or refusal to acknowledge the official VCS accreditation process. Wildlife Works addressed both activity shifting and market leakage at project validation, and it was determined by an experienced accredited VVB that both were inapplicable to the Mai Ndombe REDD+ Project. As such, neither were calculated ex-post throughout the current baseline validity period. Renoster has made it abundantly clear that they disagree with the VVB’s opinion, stating “While not measuring leakage at all might have been acceptable ten years ago, it’s hard to imagine a REDD+ project ‘getting away with it’ today.” In this light, we further assert that projects cannot predict which conservative deductions that extend above and beyond the requirements of the VCS standard will be selected for analysis by ratings companies 10 years later. Renoster also asserts that “It’s also hard to understand why the project hasn’t been forced to consider leakage in its more recent monitoring reports.” It should be noted that in reaction to market criticism, Verra has in fact required the project to calculate and discount for activity-shifting leakage since 2021, which Renoster has failed to account for in their reviews.
Additionally, Renoster’s misrepresentation of the impetus behind selection of the proxy area is baseless and careless. Renoster’s main assertion that the selection of the proxy area “can only be thought of as a deliberate way to increase the project’s claimed risk”is an entirely false allegation. In fact, the selection of the proxy area was determined to be conservative at validation.
Renoster “Deforestation Realities”: “Despite the project's intentions, deforestation has been on the rise, reaching peak levels in 2022. The underreporting of these figures, compared to Renoster and Global Forest Watch estimates, raises doubts about the project's effectiveness.”
WWC Response
We share Renoster’s concern that deforestation continues to occur within the project accounting area, but we disagree that this metric should factor negatively into a ratings company’s rating algorithm. REDD+ Projects are “pay per performance”, which means that emissions from deforestation in the project accounting area (crediting area) are subtracted from the baseline as part of the GHG accounting process. In short, the more deforestation, the less credits the project receives. It is highly inappropriate for a ratings company to further punish a project with a low rating if despite its best effort to completely halt deforestation, it has not yet been able to. The project is already penalized through the GHG accounting process (discounting) for any emissions reported in the crediting area.
That said, it is Renoster’s second assertion, that deforestation in the crediting area was purposely underreported, and that we “were subject to public pressure and whim rather than scientific findings”, that is of greater concern. We have continued to calculate emissions from deforestation in the project accounting area in good faith throughout the project’s crediting period. Renoster asserts that the initial submission of the monitoring report, which is the version subject to public comment, “was met with public backlash, and public complaints were submitted to Verra by third parties saying that this was not a reasonable number.” We are unaware of any public complaints or backlash and invite Renoster to cite their sources. In reality, we revised our deforestation estimates inside the crediting area due to a finding from the VVB concerning pixel size. We had made an inadvertent calculation error in our model that the VVB identified, and we subsequently updated our calculations. Details can be viewed in the verification report for the m4 monitoring period (2017-2020) for NIR 3 (pg. 45). This process involved no public complaints or backlash that we know of.
WWC Conclusions:
Despite Renoster’s inaccurate characterization of our intent, we assert that we have always, and will continue to conduct GHG accounting in good faith and using the best scientific tools available to us. We have and will always respond to allegations with transparency and objectivity.
Find more information on the Mai Ndombe REDD+ Project FAQs.
Renoster “Community Impact and Transparency Issues”: Perhaps most troubling are reports indicating a lack of meaningful engagement and benefit to local communities. Investigations reveal a disconnection between the project's operations and the community's awareness and tangible benefits, highlighting discrepancies in the distribution of the project's financial gains amidst continuing local poverty.
WWC Response
Renoster’s claims to review what they refer to as “co-benefits”, and what we refer to as “core benefits” using three sources:
1. Project documentation
2. Verification from sources on the ground
3. External news articles
The nature of the main accusation focuses on the third category, external news articles. They cite articles to which we have thorough rebuttals. Despite each of these reports recycling one original report, our public responses to each article have been well documented. We are happy to provide them to any inquiring party.
Below summarizes the points in our response stating that the criticisms were unfounded and based on inaccurate information.
1. Transparency and Verification: We emphasized our commitment to transparency, highlighting their projects are routinely audited by independent firms, and have undergone extensive due diligence by major corporations and institutions.
2. Criticism of Research Methodology: The principal author of the report never visited the project site and relied on secondary sources with anti-REDD agendas that conducted similarly biased, incomplete research and did not accurately represent the project's impact or processes.
3. Misrepresentation of Benefits and Community Rights: Contrary to the claims in the report, the Mai Ndombe REDD+ Project has achieved considerable community benefits. The project's well-documented community resource-sharing system aligns with the DRC’s official homologation process, and is transparently shared with all local communities within the project’s sphere of influence yearly.
The project has made significant strides channeling carbon finance into transformative project activities: The project has created and sustained over 300 local jobs managing the project, engaging with communities to deploy project activities chosen by committee's elected by the local communities. As of 2022, carbon funds have built 2 new hospitals, funded 18 mobile clinics which routinely deliver life saving care for tens of thousands of community members, especially during infectious disease outbreaks. Communities have elected the project to purchase medicine, pay healthcare workers, perform vaccinations, HIV screenings and education programs. They have chosen to build and repair 30 solar-powered wells in 30 different villages, providing safe drinking water to tens of thousands of people. 30 schools have been built or renovated, which has increased the access to quality education for thousands of children. Food security has also been strengthened by 25 new fish ponds and conservation agriculture techniques.
4. Response to Specific Recommendations: We noted that the report’s recommendations are already incorporated into our project plans and challenged the report for suggesting otherwise based on outdated or incorrect details.
5. Support from Local Communities and Authorities: We noted that local Congolese civil society networks have publicly condemned the report and its claims. We also detailed our extensive community engagement and the support they have from local stakeholders.
6. Clarification of Misunderstood Aspects: Our response pointed out errors and misunderstandings in the report about the operational aspects of REDD+ in Mai Ndombe, such as the mischaracterization of logging activities and the roles of various stakeholders.
Despite the inaccuracies and faulty research, these reports have been recently recycled in a new ideological attack on the carbon market in the form of a Verra complaint, which was addressed in Verra’s Project Review during the verification for the 2021 monitoring period.
WWC Conclusions:
Wildlife Works stands in solidarity with the communities that live in and around the Mai Ndombe REDD+ Project. We assert that the project provides significant, verifiable benefits to local communities and contributes positively to conservation efforts, contrary to the claims made in the RRI report. Renoster’s pro-review is not based on facts, but rather on misrepresentation and misunderstanding of the methodology and makes unsubstantiated claims about our intentions. This kind of biased discourse inevitably harms the very communities it claims to defend.
Renoster’s approach risks undermining the credibility of genuinely impactful initiatives like the Mai Ndombe REDD+ Project. Such actions not only detract from the collaboration needed to address critical climate, biodiversity and social issues, but also compromise the integrity of the discourse.
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