We were deeply disappointed to see SBTi include Rainforest Foundation UK’s 2020 “REDD Minus”, a poorly researched, biased opinion piece, listed as “evidence” that they considered in evaluating the effectiveness of carbon credits. This is one of a growing number of references to this report by those who are generally accepted as reputable organizations who should be doing proper due diligence.
As those philosophically opposed to REDD have expanded their tactics, we never thought their use of untruths would be accepted as truth by those who should know better. But this is the reality we find ourselves now and we are forced to unpack the lies.
Today, we will start to set the record straight, starting with publishing our rebuttal to the Rainforest Foundation UK’s outdated report.
Please note the original rebuttal was prepared in 2020 and did not include updates to PIREDD. Project investments to date have been added in relevant sections.
Original report: REDD Minus: The rhetoric and reality of the Mai Ndombe REDD+ programme
Date: December 2020
Author: Rainforest Foundation UK (RFUK)
Wildlife Works response:
Background :
This RFUK report primarily reproduces content from a 2018 report by RFUK and their local partner, then referred to as APEM, for which we issued a prior rebuttal. This recycled report claims to address four REDD+ initiatives in the Mai Ndombe province of the Democratic Republic of the Congo (DRC):
The Mai Ndombe REDD+ project, a private project run by Wildlife Works Carbon, LLC since 2011 (WWC) in a 300k ha conservation concession located on the western shore of Lac Mai Ndombe, in the Province of Mai Ndombe
The Integrated REDD+ Mai Ndombe Project (PIREDD Mai Ndombe), funded by the World Bank’s Forest Investment Programme (FIP) with funding from the Central African Forest Initiative (CAFI) and implemented by FRM Ingenierie and WWC since 2018
The Integrated REDD+ Plateaux Project (PIREDD Plateau District), funded by the World Bank’s Forest Investment Programme (FIP) and run by WWF (World Wildlife Fund)
The World Bank FCPF Carbon Fund’s jurisdictional Emission Reduction program (ER Program) for the entire Province of Mai Ndombe.
Wildlife Works is involved in the first, second and fourth initiative. However the first initiative is the only one in which Wildlife Works is responsible for reducing emissions within our conservation concession, and generating VERs (carbon credits) from verified performance. This project is also the extent of our participation in the fourth initiative listed above, where the REDD+ Project was the first “nested” project in the World Bank’s ER Program. The second initiative is a traditional World Bank infrastructure investment project aimed at improving communities’ sustainable agroforestry production and their market access by repairing roads and bridges across the entirety of the Mai Ndombe Province. WWC is in an implementing partnership with a French Agroforestry specialist company, FRMi, to deliver this program on behalf of the World Bank. This initiative does not produce carbon credits.
It is also important to note that at no time have RFUK or their local partner, APEM, who are now referred to in this report as Bolukiluki (which translates to “observer”) had any official oversight or monitoring responsibilities of any of the four REDD+ initiatives on behalf of communities. Official civil society observer organizations, MOABI and GTCRR, have been tasked with monitoring the project on behalf of the World Bank. Their reports showed positive progress and did not raise the same findings highlighted in the RFUK report, because the RFUK report and its findings was poorly researched, as detailed below.
It should also be noted that the conclusions reached by RFUK about the WWC project in this report were said to be based on an anonymous interview with 131 individuals in seven villages (Mbale, Ibali, Selenge, Ntand’engongo, Wania, Mbwenzey and Bobolampinga) during 2 unannounced visits between 2018 and 2019. There are at least 50,000 people in the project area across more than 30 villages. This means that RFUK’s study was based on a 0.2% sample size of the project’s actual population. WWC’s commitment to these communities, all of whom signed on to the REDD+ project via their legally authorized representatives, is to provide a transparent share of project revenues to implement social benefits over the 30-year life of the project. The speed at which we can reach any or all communities to deliver social benefits is dependent on our success at selling credits in the voluntary market, and we adhere to a schedule for activity implementation. Neither RFUK nor their Bolukiluki representatives contacted WWC or Mai Ndombe authorities before conducting their work, which could explain why they visited 4 villages (Ntand’engongo, Wania, Mbwenzey and Bobolampinga) in which, according to our implementation schedule, we had not yet begun to deliver social benefits. They did not visit any other villages where we have already built schools(Lobeke, Lokanga, Bokebene, Kesenge, Nsongo, Ikita, Ilee and Mankaba).
*2024 update: Credit sales funded the construction of 2 new hospitals and 18 mobile medical clinics, which routinely deliver life-saving care for tens of thousands of community members, particularly during infectious disease outbreaks, which are common in the region. Communities have commissioned 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.
The credibility of RFUK’s reporting must be questioned due to repeated demonstrably false statements, including: our clinic and school in Bobolampinga are in a state of disrepair, when we haven’t begun construction of either in that particular village; or the claim that our demonstration gardens, which are extremely well received with the communities, are only 2m2 , a claim that is visibly proven false in their own 2018 report that included a photo of one of our 200m gardens. Lastly, we possess evidence demonstrating local customary chiefs' opposition to these RFUK-supported visits. Chiefs have chastised RFUK-supported personnel for coming to their communities to deliberately provoke problems with ERA/WWC when ERA/WWC has built positive relationships to develop the community’s vision for their self-determined sustainable development.
RFUK has a clear historical and deep-rooted opposition to the basic principle of REDD+. To support their ethos, they present unnecessary and unsubstantiated caveats in their report, such as the claim to have had trouble collecting data due to the presence of “agents of the company and agitated elites”, without defining what is meant by agents or elites, or indeed documenting any evidence supporting this claim. Yet, when convenient for them, they refer to the same “elites” as recognized customary authorities within the same report. WWC has Congolese employees in the field, whose job it is to be physically present in the project area, and to be aware of what is going on. Naturally, when expatriates arrive asking questions about the REDD+ project, uninvited by WWC or the community, the community engages WWC to assist in understanding the intent of the strangers. Across the world, such community visits require some form of local communication process, typically provided either by the community elders, or the Government (national or local). WWC welcomes well-intentioned oversight, but we believe RFUK and their Bolukiluki agents did not act with such intentions. It should be noted that at no time did any employee of WWC bar RFUK, or their agents, from carrying out their activities. The community, however, objected to what they perceived as RFUK’s lack of respect for their authority and cultural processes.
There are 9 key allegations in the report related to the WWC REDD+ project, all of which are either false or based on incomplete information.
The report claims that 70% of the 131 interviewees had never heard of REDD+, with women particularly unaware.
WWC Response: Incomplete, small, biased sample size:
In our REDD+ projects, every claim must be supported by evidence and independently audited. In contrast, RFUK makes supposedly data driven claims without proper, audited evidence, making it difficult to verify their statements. The data they do present is based on an inappropriately small and unrepresentative sample of the 50,000 population size (.1% of the population of 50,000). There is documentation of the signed Free, Prior and Informed Consent (FPIC) agreements from the 28 villages that signed FPIC agreements with us after extensive consultations. By their own admission, from their prior report in 2018, RFUK/APEM found that “many” in their sample were aware of the ongoing WWC/ERA project. The great majority of community members in communities where our project activities are ongoing are aware of our project. Since the onset of the FPIC process up until today, WWC has maintained a team of field-based community-engagement specialists who traverse the project area informing the communities about the project, its aims and their role. We follow internationally recognized and independently audited processes. WWC considers FPIC an ongoing obligation, to ensure that the community remains knowledgeable and supportive of the project, even after original consent was given by each of the communities prior to project initiation. This is because it is only once they begin to see the real benefits of the project can they truly informed of their decision to support the project or not.
2. Of the 30% of respondents who have heard of REDD+ only 8 people felt their community had the opportunity to provide their consent to the project.
WWC Response: Incomplete research, small, biased sampling:
WWC enters project communities through the established governance structures, whether customary, political or administrative. From this, we employ an internationally accepted FPIC process that follows international practice, as espoused under the UN-REDD FPIC Guidelines. This process requires that we work within the communities’ cultural and local governance contexts to inform the community on the project propositions, and then determine if the community is in support of the proposal. This support can vary from written to oral (e.g., a show of hands), as well as from actual consent to simple endorsement depending on the recognized tenure system on the proposed project land. Crucially, either way, it is given following the culturally accepted community systems and structures, which can vary from community-wide meetings to elected committees signing on behalf of their communities. In other words, whilst every individual can and should contribute to the process if they so desire, final decisions are made through the governance structures the community has in place for development projects, such as the Customary Chiefs (tribal government) and Local Development Committees (CLDs) in the case of this project (see Fig. 1). As the CLDs were not operating before the project began, (they have been revived by the project), the decision to join the project was made in public community meetings in every village, and then endorsed by the Customary Chief. Once again due to the lack of transparency on process from RFUK it is impossible to verify their claim, as they could have spoken to persons not involved in the formal consent process 10 years ago. Their sample size is too small to capture the majority of community consent. If they had asked us or informed us about their research, we would have gladly introduced them to all 28 community decision making bodies.
Figure 1: Hierarchy of community governance structure in the Mai Ndombe REDD+ Project run by WWC
3. Despite most of the concession being subject to customary claims and usages, there has been little effort to integrate these into the management of the area.
WWC Response: False:
On the contrary, by law as a concession holder from the DRC Government we were required to gain consent from all of the customary users of the forest. FPIC activities have been carried out with the consent and in agreement with customary representatives recognized by all, in the entire project area. Discussions were public and involved most of the villagers in officially recognized meeting areas in the villages. Customary authorities have been signing documents (in Lingala) renewing their commitment to the project in their villages every year except for 2020 due to COVID-19 when for safety reasons we did not visit these remote communities.
There is no detail provided in the report about how these focus groups were carried out, where they were held or who attended and the selection process, making it difficult to provide a direct response to the conclusions drawn.
4. In the villages visited, most of the Local Development Committee members were chosen by WWC agents rather than elected by the communities
WWC Response: False:
Members of Local Development Committees (CLD) have been duly and legally elected by the villagers themselves. None of the CLD members have been nominated by the company. If RFUK had spoken to any of the dozens of CLD committee members, they would have been able to verify this. However, we have not been able to find any CLD member who was interviewed by RFUK. The forest communities of the DRC are mostly patriarchal, and while it is the policy of WWC to honor traditional culture, the international standards the project subscribes to require WWC to demonstrate specific efforts to bring on board any marginalized segments of project communities, especially women and indigenous groups. Membership of CLDs must include both genders (a maximum of four out of seven members should be of one gender) so that any specific needs for any gender are not overlooked. Similarly, the youth should have at least one representative of either gender and indigenous groups like the Batwa must also be represented (both genders).
5. 96 percent of people surveyed either did not know what benefits WWC promised to their village or were not satisfied with them.
WWC Response: Incomplete research, small, biased sampling:
Again, there is no detail provided in the report about how these focus interviews were carried out or how interviewees were selected, but 4 out of the 7 villages they visited were places where we have not begun any work yet (as per our project implementation schedule). RFUK could have avoided this source of bias in their study by visiting and interviewing people in villages where project activities had begun. It is very improbable that in the other 3 villages (Ibali, Mbale and Nselenge) where we have built schools and in Ibali a clinic, (see photos) or in the other villages where we have already constructed schools (Lobeke, Lokanga, Bokebene, Kesenge, Nsongo, Ikita, Ilee and Mankaba) that they could have found anyone unaware of those benefits, as these are by far the most prominent buildings in the community, and a large portion of the community was voluntarily involved in collecting sand and rocks as the communities’ contribution to the school construction. So again, we point to their small and biased sample size.
Ibali Medical Clinic under construction 1
Lokanga School built by WWC 1
*2024 update: the Ibali hospital was completed in 2024 and performed its first surgery in 2024. 30 schools in 30 villages have now been built or renovated.
Watch impact videos here.
6. Agreements between WWC and communities were not available in the village surveyed, community members have minimal understanding of their contents, and in some instances, they were signed on behalf of communities by outsiders.
WWC Response: False:
Again, untrue and we point to their small, biased sample size. Project documents are available in each village and kept at CLDs. The signatories, which are all verifiably community members, are listed on the front of the documents. RFUK and its representatives did not contact the CLDs in the villages, so made this claim without ever having seen the documents. WWC recognizes the CLD as a legally established institution by the Ministry of Environment to represent communities in Forest Governance matters. Outsiders are not allowed to be on the CLD. RFUK has presented no evidence to support this claim, presumably because they didn’t engage with any of the CLDs.
7. The presence of the project has sparked serious inter-communal conflict between certain villages.
WWC Response: Incomplete research: The inter-communal conflict was instigated by the displaced logging company and ambitious politicians in one area called Ngongo, as has been proven by court cases and convictions. Most attacks were aimed at stopping the REDD+ project to allow the logging to return. This activity by the displaced logging company to disrupt our project mostly stopped around 5 years ago, so this is an outdated comment. Our personnel are now welcome in all villages of the project area and plans are underway for construction of schools in all remaining communities over the next 10 years.
8. WWC agents obstructed the work of the teams who were legally surveying communities in its concession.
WWC Response: False:
WWC personnel were not involved in RFUK activities in the villages as RFUK didn’t inform us of their planned arrival. It was community members who accosted them, as they were strangers with no apparent legal right to survey the communities, who were clearly trying to discredit their project. Community members asked them why RFUK has not built schools and clinics in villages instead of attacking WWC who has. This is in fact what the Chief of Kesenge (who is not a WWC employee) asked Mr. Joe Eisen from RFUK who showed up without informing local authorities and wanted to conduct a “workshop” in a school building constructed by WWC. The entire episode was recorded on video by a community member in the village. In the Democratic Republic of the Congo, it is illegal for a foreign national to disembark in villages or concessions belonging to others to carry out activities such as the so-called “workshop”, without informing and agreeing with local authorities and the concession owner. This demonstrates it is RFUK who was disrespectful to local communities and ignored their cultural traditions.
9. Preliminary analysis of forest loss data inside the WWC concession show that deforestation levels increased since the company acquired the concession in 2012.
WWC Response: False:
This is plainly false as we have proven by international independent audit. The concession was acquired in 2011 and was previously owned by the logging company SOFORMA and they had logged 28,000 ha in the decade prior to our acquiring the concession. There has been no logging since we took it over. RFUK cited Hansen et al., which is a free dataset that is globally accurate on larger scales, but locally inaccurate and widely regarded as ineligible for the level of scientific rigor required of a REDD+ project like ours. What we know from the images they provided is that they report forest change in general and most of these changes are related to the rotational use of fallows and secondary forest by the community for cultivation, and results in minimal emissions. Fallows/secondary forest are cut, burned and cultivated then abandoned for 3 to 4 years creating a regrowth before getting cultivated again. These areas were excised from our project accounting area as it is illegal for anyone under the Forest Code to stop local community members from using their traditionally cultivated area. However, inside of the primary forest domain within our concession and in the former logged areas, the forest has been steadily recovering since 2011 and natural regeneration of forest in the protected savannas from 2014 to 2018.
There were many other specific false claims in the RFUK report. We summarize some of them here:
RFUK reuses the old moratorium argument to challenge the additionality of our concession – the moratorium was on new concessions and had no bearing on our concession which was an existing logging concession that we acquired through the Forest Code while the concession, held by a logging company, was temporarily suspended.
RFUK states we could be a beneficiary of $9M USD from the World Bank ER Program in addition to our private sales, but that depends on a decision by the World Bank to buy our verified emission reductions instead of our selling them to private companies. The WB ER Program in Mai Ndombe Province is a $55M program and does have a maximum cap for private sector projects of 17% of the total ERPA. This is where they are getting the $9M figure, but if we sell $9M worth of our emission reductions over the 5 years to the World Bank, they will not be available for us to sell to the voluntary market so it is not additional to our private sales.
They claim that arguments over our “nested” reference level are what is preventing the ER Program from moving ahead – this is simply untrue. We have had an agreed “nested” reference level with the DRC Government for over 5 years, and what has held up the ER Program is internal machinations within the World Bank.
They employ an unattributed quote from a villager in Ibali that dates from the beginning of the project and was reported years ago in one of the reports RFUK took much of their content from that states they (the community members) knew what was going on in the time of the logging company but don’t really understand the work of our engineers. This quote is highly believable as the logging company was destroying their forest, and our engineers are not, and the work of our forest engineers in measuring the forest inventory is quite technical in nature. But this is hardly a condemnation of the project.
They make an egregiously false claim that the villagers of Mbale have decided to destroy the new school we constructed there to avoid conflict over which members of the community get to use it. The new school is not yet big enough to house all the potential students in this village catchment area so they have had to work out a sharing schedule until such time as we are able to create additional classrooms, but there is no indication that there is an intention to destroy the school that so many community members are benefiting from.
They falsely claim that we stated that “communities share two percent of the proceeds”. The benefit sharing plan we have with the communities is transparent and clear. Communities receive 25% of all sales to use towards social programs, such as school building and clinic construction, fees for school children etc. In addition they benefit from jobs and provision of services to the project which is the lion’s share of the project budget. WWC and the Government of the DRC split any surplus from the project after community share and operating costs on an annual basis 50:50.
They criticize the role of CLDs using an example that is nowhere near our project and has nothing to do with our project.
They claim there is no functioning grievance mechanism in place without providing any evidence of that. In fact there is a functioning grievance mechanism through which we and the provincial government receive comments and complaints that must be addressed through a formal documented grievance process. There has never been any request from any village to rescind participation in the project, although there are often questions regarding when benefits will come to villages we haven’t yet begun working in.
They claim we didn’t consult entire villages and give the example of Bobola Mpinga. WWC did not consult in the village of Bobola Mpinga at the start of the project (2011) because it has only recently become a village. It was a former site that people from the Mbale village moved to so we aimed to pay respect to the tradition and the customary authorities and to discuss with all the clan “owners” of the forests headquartered in Mbale. People from Bobola Mpinga are part of these clans and have participated in these discussions. That is the reason why the customary authorities of Mbale requested the construction of a school building in Bobola Mpinga, which is clearly documented in the Cahier de Charge. It seems quite clear for us that the RFUK agents have never been in Bobola Mpinga because they claim to have seen a school building and a clinic built by us, which “are currently in poor condition”. But our company has not yet built any infrastructure in this village. The RFUK agents would have known that had they been in the field. Nevertheless, it is important to point out that forest governance is exercised within the framework of village CLDs. These CLDs decide on activities and benefit distribution, not WWC. Bobola Mpinga therefore now has its own CLD (annexed to the Mbale CLD).
Conclusion and way forward
Conclusion
Wildlife Works was founded on the belief that local communities must come first in the battle to protect forests and biodiversity to the benefit of all. We retain an open-door policy across all our projects and recognize that these are complex undertakings and will never be perfect. As such, we are always happy to discuss ways we can improve project implementation processes, and use lessons learnt to improve future operations and new projects.
All our REDD+ projects are dually validated, subscribing to robust internationally recognized standards for both carbon measurement (VCS) and Community and Biodiversity (CCBA) monitoring elements, to ensure the claims we make remain verifiable and additional for the lifetimes of our various projects. Besides full compliance with the laws of the countries in which we operate and international REDD+ guidelines like the Warsaw Framework, we also adhere to international best practice for project operations, e.g., guided by the IFC Performance Standards, World Bank Safeguards and UN-REDD FPIC Guidelines. In this way, we typically go above and beyond the minimum requirements based on the national laws and regulations as pertains to benefit sharing and inclusiveness.
In these types of projects that include tens of thousands of community members, it is difficult - in fact impossible - to reach every single individual in a community. The mechanics of high integrity FPIC is not to ensure that each and every individual understands the technicalities of the project equally and fully; it is to ensure that the communities, as a whole, represented by democratically voted in leaders who agree themselves that they have sufficient information of project goals and impacts on their livelihoods, to be able to make the decision about whether they would support such a project or not.
Way forward
For the Mai Ndombe REDD+ project, RFUK and similar reports could be useful in emphasizing the important elements that REDD+ projects should strive to adhere to. The purpose of this rebuttal is not to contest or impugn the important oversight role that civil society plays. However, when NGOs, who are not recognized as legitimate civil society watchdogs write reports based on faulty research and inaccurate information, we are compelled to provide facts and full context. We request that RFUK and similar organizations conduct their research in a transparent manner that is constructive to projects and does not threaten the benefits to communities.
Despite a difficult marketplace at the start of the Mai Ndombe REDD+ Project in 2011, WWC has remained committed to the Clause Sociale. Clause Sociale is a social responsibility mechanism that requires concessions to contribute to the development of forest communities. We support the community’s right to form and elect their representatives in their customary ways, and ensure there is top-down and bottom-up accountability in project operations in line with the Clause Sociale. We are deeply committed to having open and transparent processes towards ensuring any benefits from the REDD+ project are equitably spread to have the greatest impact in improving the lives of these communities. Lastly, through our open engagement with government and customary authorities, plus our grievance and feedback processes, we aspire to provide an example of how REDD+ can work for Congo Basin forests, biodiversity and peoples, and provide vital lessons for any future jurisdictional processes to learn from.
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