Originally posted on Quora June 26, 2023
In 2022, USAID said that its US $32 million in funding for the Northern Rangeland Trust had led to the development of “43 independent and sustainable community-conservancies” which were “driving development in conservation, economic empowerment, and peace and security”. I would not relay this report, <href="https://assets.survivalinternational.org/documents/2466/Blood_Carbon_Report.pdf?_gl=1*1s1y01z*_ga_VBQT0CYZ12*MTY4Nzc4NzM4OC4xLjAuMTY4Nzc4NzM5OC4wLjAuMA..">Blood Carbon, from Survival International if it only implicated consenting private parties, but because it implicates three international aid organizations and at least 3 national governments in supporting a fraudulent carbon offset project it discredits the entire “net zero” Agenda 2030 movement. The NGO in charge of the project, the Northern Rangeland Trust (NRT), has received $32 million in grants from USAID since 2004 as well as millions more in grant money from France, Denmark and the European Union. The European Commission has described their Northern Kenya Grassland Carbon Project, the subject of this post, as the model on which they intend to base their NaturAfrica: a large funding programme for conservation projects across Africa. This Northern Kenya Grassland Carbon Project even received the lighthouse award at COP27 last year.
Baseless Assumptions of a Purely Speculative Asset
Carbon offsets are the new tulip futures: "an imaginary commodity created by deducting what you hope happens from what you guess would have happened. (1) NRT in this particular project issues carbon credits on the presumption that replacing the old "unplanned" grazing patterns, of the pastoral tribes in Northern Kenya, which they assumed was depleting the soil, with their prescribed rotational grazing patterns, based on commercial ranching practices, will restore carbon to the soil. (2) Within the 2 million hectare area the project assumes its borders can be accurately monitored and therefore carbon leakage (i.e. cattle grazing outside the project area) accurately calculated and minimized. (3) The project assumes compliance by the 112,000 odd inhabitants of the area will be near unanimous and that the additional soil carbon stored, if it actually occurs, (4) will be permanent. (5) The project also assumes that they have free, prior and informed consent from the 112,000 or so inhabitants and a legal basis to sell carbon credits on land they don’t own. (6) The project assumes their measurement of additional carbon in the soil, satellite images of project area vegetation, is accurate enough to sell carbon credits.
Post Hoc Approval
NRT's project was not validated by Verra (2020) until 7 years after it was started (2013) and sold over 3 million carbon credits. The five largest buyers were Netflix with 180,000 credits, NatWest Group with 120,000 credits, Meta (Facebook) with 90,000 credits, Kering South Africa with 75,000 credits and Salesforce with 48,000 credits. VCS did not approve the methodology of the project until 2 years after the project started (2015).
Conflicts of Interest
Project review, validation, first monitoring, revision and verification process were all conducted by the same parties simultaneously.
The Carbon Calculation Problem
In Hayekian terms the Northern Kenya Grassland Carbon Project replaces a grazing pattern based on thousands of years of tradition and local knowledge with a top down centrally planned, by NRT, rotational grazing pattern based on commercial ranching, under the assumption that the former is depleting resources faster and thus must be managed by the NRT bureaucrats through their 13 conservancies. However, The evidence suggests that the old grazing pattern is not correlated with changes in soil carbon levels. The project claims to measure carbon leakage, defined as grazing outside the project area, by assessing the number of livestock days spent outside the project area, supposedly based on grazing reports submitted by grazing assistants following pastoralists and reporting herd movements to project coordinators, but most of the grazing reports have no information about where the livestock are at any given point in time or where most livestock moved to leading to discrepancies in cattle influx reports between the conservancies and outside the project area. Instead, the project bases their grazing reports mostly on satellite maps of vegetation changes with low quality data of animal movements from the 13 conservancies. Yet, despite making the unsubstantiated claim to being able to monitor the project border, which NRT admits is not defined, and track livestock movement off the project area, a problem which Aster Global found to be unresolved, it was still validated by VERRA because instead of rejecting validation of the project they simply put in a ‘forward action request’ for future verifiers to examine whether the project meets the applicable methodology, kicking the can down the road again.
Fabrication of Data
NRT’s sub methodology neglects the burden of proof because they are not required to demonstrate that different land uses would yield different quantifiable carbon emissions; instead, non-project land uses are assumed to be worse by default and instead of actually demonstrating quantifiable differences in carbon storage they claim additionality through difficulty of implementing the project. Worse, the project was validated despite the fact that NRT had no field reports to correlate with an Excel spreadsheet which purported to show carbon soil calculations. The validators signed off on the project despite the fact that the Excel sheet supposedly showed soil carbon calculations, inadmissible equations and livestock counts and other values different from the 2014 and 2013 versions of the file.
Failure to Launch
The planned rotational grazing, the project's sole claim to additionality, was never actually implemented because the livestock maps used by the project show the traditional grazing pattern. The project admits to relying on traditional grazing patterns and customs thus claims of additional carbon storage in the soil dubious and there is still no evidence of project proposal differing from customary migration patterns.
Soil Carbon (VCS) Actually Declined
The project uses as its baseline measurement and hypothesis that the decline in vegetation quality, based on satellite images, prior to the project is a result of the old grazing pattern, but not only did the project not start with an accurate baseline measurement of soil carbon the soil carbon has continued to decline over the past decade since the project started in 2013 (supposedly). In their 2021 ‘State of the Conservancies’ report the trust reported that vegetation quality had declined across 57.6% of all conservancy areas and 48.5% of project areas including 8 of the 13 project conservancies. In the early years of the project NRT also recorded carbon leakage and found it to be up to nearly 30%; however, they have since changed the parameters of carbon leakage to not count livestock 2 km or less outside the project area (i.e. they do not have a defined boundary).
No Informed Consent
NRT did not solicit participation by the designated conservancies until 2015: a full 2 years after they supposedly started the project. NRT did not even hold meetings with participants until they had verified and sold their first carbon credits for the 2013-2016 verification cycle. NRT claims to have a website where they post announcements and the front pages of each conservancy linked to a blog site with a comments section. The website in question has no content. NRT also did not provide documented evidence that anyone within the 13 conservancies had actually received project documents and project implementation reports in their local language. Despite providing no documentation of free, prior, and informed consent the project was still rubber stamped by validators.
No Legal Claim to Sell Carbon Credits
NRT falsely claims Kenya's Wildlife Conservation and Management Act of 2013 gives them the right to use wildlife conservancies for carbon trading. They cite a law establishing group ranch systems that was repealed in Kenya's 2010 constitution and replaced by public, private and community land. 1 million of the 2 million hectares of the project area are Trust lands subject to Kenya's 2016 community lands act and are legally supposed to be managed by the counties until they are properly registered. Thus the 13 project conservancies have no legal basis. For this reason, some tribal elders, who have no role in the conservancy boards, have challenged NRT’s establishment of conservancies in Kenya’s Isiolo High Court.
The wildlife conservation law they cite does not establish grounds for carbon trading as it is not mentioned and NRT did not sign an agreement with the conservancies to trade carbon until 2021 after the first two verifications (2013-2016 and 2017-2020). NRT claims to have letters of intent from the 13 conservancies to participate in the project, but did not produce letters of intent from the conservancies until 2017, four years after the project start date, and did not demonstrate contractual agreements to trade in emissions reductions with the conservancies. During their validations, Aster Global never asked to see any contracts between NRT and the conservancies. And despite claiming to be a wildlife conservation organization, almost none of the project revenue goes to the pastoralists tribes involved. The lion’s share of revenue goes to just three US based companies: Native Energy, Soils for the Future and NRT.