Rebuttal response to Carbon Market Watch report

Summary

Carbon Market Watch (CMW) names Permian Global, Katingan or Kuamut in nine places. Apart from a negative Calyx rating, every negative finding about the two projects rests on one of three things: methodology-level scores that their own publishers say do not apply to individual projects; allegation mostly from 2019 to 2020 that CMW claims it had no realistic way to verify (p. 38); and a pass/fail test that no project using any of the REDD+ methodologies the CCQI has scored could pass.

• Katingan holds AA ratings from both BeZero and Sylvera. CMW records this but overrides it, saying the project failed on “shortcomings that were not captured in the ratings”. It names no shortcoming it found itself.
• The same authors wrote about Katingan 15 months ago in Built to Fail? (June 2025), where they classed Katingan as one of only four of 47 large projects they did not consider problematic. The project has not changed. The test has.
• Kuamut is failed on Katingan’s allegations, which were themselves untrue. CMW cites no source about Kuamut for “Land conflicts and dispossession, baseline lobbying” [sic]. Its own table note says the claims “are not necessarily linked to the project in this table”.
• Carbon Credit Quality Initiative (CCQI) scores are not project scores. The CCQI states that its scores “do not apply to individual projects”.
• The test cannot be passed. CCQI scores VM0048, the REDD+ methodology that the Integrity Council for the Voluntary Carbon Market (ICVCM), an independent multi-stakeholder governance body, approved for the Core Carbon Principles (CCP) label in 2024, at 1 out of 5 on additionality and permanence. Under CMW’s thresholds a new CCP-approved REDD+ project would also fail.
• The accusation of “baseline lobbying” comes from Permian’s response to a 2021 consultation by the Taskforce on Scaling Voluntary Carbon Markets, the ICVCM’s predecessor. CMW lists it as a “claim of harm or wrongdoing” in the same column as abuse and eviction allegations against other developers.
• CMW ignores the CCB standard. Both projects are CCB certified to Triple Gold level status, the highest attainable. CCB covers FPIC and community safeguards and is audited by the same auditors.

 

Point-by-point rebuttal

1. Permian grouped with developers facing serious allegations

CMW says: “Much of the public scrutiny has placed responsibility on … project developers (such as Wildlife Works, Carbon Green Investments or Permian Global)” (p. 8).

Response:

• Wildlife Works faced sexual abuse allegations that CMW itself quotes (p. 38). Carbon Green Investments ran Kariba, where Verra cancelled excess credits. Permian is placed alongside them on the strength of a 2020 Greenpeace Germany campaign report about Volkswagen. Permian published a line-by-line rebuttal of that report in 2020. CMW does not cite it (Permian Global, 2020).

 

2. Katingan and Kuamut “failed” despite high ratings

CMW says: Katingan (BeZero AA, Sylvera AA, Calyx Tier 2) and Kuamut (BeZero A, Sylvera A, Calyx Tier 2) are “somewhat risky” and “ultimately failed to pass our integrity assessment … due to shortcomings that were not captured in the ratings from agencies” (p. 33).

Response:

• The ratings are the only part of CMW’s assessment that looks at individual projects using project data. On that test Katingan is among the best-rated forest projects in the market, but CMW sets the result aside.
• One Calyx Tier 2 makes a project “somewhat risky”; two AA ratings do not make it low risk, even though CMW’s own footnote defines BeZero AA as “a very high likelihood” of delivering 1 tonne per credit (p. 33, n. 13).
• Calyx Tier 2 is a band covering BBB to B. CMW does not report the actual grade.
• The “shortcomings not captured in the ratings” are the methodology-level scores and unverified allegations dealt with below, not findings of CMW’s own.

 

3. CCQI methodology scores used to judge individual projects

CMW says: Table 3 records Katingan as “Very Low on Additionality/Vulnerability, Non-permanence and Quantification” and Kuamut as “Very Low on Quantification and Low on Additionality/Vulnerability and Non-permanence”.

Response:

• The CCQI factsheet states: “CCQI scores therefore do not apply to individual projects”, and that individual projects “might outperform any of our scores” (CCQI, July 2024). On IFM, Oeko-Institut says the scores are “for credit types, not individual projects” (Oeko-Institut).
• CMW’s Digital Annex describes this as an assessment of “the strengths or weaknesses of the seven methodologies associated with the 15-project sample” (Annex), yet the report counts it toward a verdict on each project.
• The same factsheet scores VM0048, approved for the CCP label by the ICVCM (ICVCM, November 2024), at 1 for additionality and 1 for non-permanence. On CMW’s thresholds, no project using any of the REDD+ methodologies the CCQI has scored could pass.

 

4. “Fails on inflated baselines & over-crediting” (independent expert review)

CMW says: Every project “failed the independent expert review of academic and grey literature because the methodologies were shown to lead to a high risk of non-additionality, over-crediting, double-counting or a combination of these” (p. 36).

Response:

• None of the studies cited reports findings on Katingan or Kuamut. West et al. (2023) covered Peru, Colombia, Cambodia, Tanzania, Zambia and the DRC (University of Bonn); West et al. (2020) covered Brazil.
• CMW reports a methodology-wide risk as a project failure.
• The review has no stated inclusion rules. CMW lists one study showing that REDD+ projects reduce deforestation but does not engage with it, and omits another (Guizar-Coutiño et al. 2022; Swinfield et al. 2026).
• Kuamut uses VM0010 (IFM). Most of the deforestation-baseline literature does not apply to it.
• Studies have reported over-crediting across parts of the sector. Sector averages are not project findings. Methodologies also leave out some real emission reductions, such as avoided soil emissions outside peat projects and removals from regrowth in peat projects, so the net position of any project can only be judged on its own evidence.

 

5. CCP status: “did not apply” (Katingan) and “pending” (Kuamut)

CMW says: Table 3 records Katingan’s CCP status as “Did not apply” and Kuamut’s as “Pending”, and both projects fail overall. “The remaining 14 projects had methodologies which have either been rejected or not applied to for CCP approval” (p. 39).

Response:

• Verra excluded its legacy REDD+ methodologies, including VM0007, from ICVCM assessment (ICVCM, November 2024). This was not a project decision. CMW acknowledges this on p. 37.
• VM0010 is still under ICVCM assessment (Calyx tracker). It has not been rejected. CMW itself says on p. 37 that the absence of a CCP label “isn’t a clear red flag”.

 

6. Katingan is “partly on protected land”

CMW says: “Investigations into Katingan found that the project had important additionality risks, as it is partly on protected land” (p. 33, citing a 2021 Unearthed article about Shell).

Response:

• This repeats the 2020 argument about Indonesia’s 2011 moratorium, which Permian answered at the time. The moratorium exempted applications already approved in principle by the Minister of Forestry, and peer-reviewed research found it contributed little (Groom et al. 2022).
• Greenpeace’s own research contradicts the argument. In August 2019, more than a year before Greenpeace Germany’s report, Greenpeace Southeast Asia found that forest loss inside moratorium areas had risen to 137,000 ha a year, from 97,000 ha a year before the moratorium, and said that it “doesn’t deliver real change on the ground” (Greenpeace Southeast Asia, 2019). Before publication, Permian also gave Greenpeace Germany’s researcher evidence that the moratorium had not stopped peatland deforestation. The report ignored the evidence and made the argument anyway.
• The forest is protected today because RMU holds a 60-year restoration concession, granted in 2013 after a competing plantation application was rejected.
• Areas the law protects absolutely (peat-dome peak and river buffers, 11,726 ha), plus 26,836 ha held back as a precaution, are already excluded from the baseline. The regulatory position and an independent legal opinion (Sembiring & Ferdianza, April 2026) are on the Verra registry.

 

7. Katingan “allegedly overestimated” avoided deforestation

CMW says: “The developer has allegedly overestimated the amount of deforestation avoided” (p. 33, citing Unearthed, October 2021).

Response:

• The source is an article about Shell’s marketing that restates the 2020 Greenpeace argument. CMW presents no analysis of its own.
• The Greenpeace comparison set Katingan’s planned-deforestation baseline against historic provincial averages. These measure different things.
• The baseline has been validated, verified over successive monitoring periods, and assessed by two ratings agencies with project data, both at AA.

 

8. Land conflicts at Katingan

CMW says: “The Katingan project has been linked to land conflicts, and locals have reported that the land the project was built on belongs to them and was used for farming” (p. 33, citing Greenpeace Germany, 2020).

Response:

• The Greenpeace passage relies on a 2019 Dutch magazine article and a master’s thesis, not peer reviewed, covering four of 34 villages. Permian set out the thesis’s weaknesses in 2020. The thesis surveyed about 250 households, half of them in control villages, including gold-mining communities, some distance from the project. Its project-village sample was about 1% of families in the 34 villages (the number of villages partnering with the project has since increased to 41).
• The concession is state forest land allocated by the Ministry of Forestry. Customary claims in Central Kalimantan are real, and the project addresses them through agreements, tenure support and its grievance mechanism.
• RMU works with 41 villages through 80 Memoranda of Understanding, with FPIC built into consultation. In 2020 to 2023 the project helped 11 villages secure tenure rights, created over 390 jobs and supported 55 health posts and 21 schools. It holds CCB Triple Gold certification.

 

9. “Baseline lobbying” listed as wrongdoing

CMW says: Table 3 lists “baseline lobbying” under “Claims of harm or wrongdoing” for Permian Global.

Response:

• This refers to Permian’s 2021 response to a public consultation by the Taskforce on Scaling Voluntary Carbon Markets.
• In that response Permian “strongly agree[d] that baselines must be independently audited and endorsed by third party specialist experts” and supported making all baseline data public. It disagreed with one proposal, that forest baselines be built only by parties with no interest in the project, on grounds of cost and practicality.
• CMW places this alongside allegations of eviction, human rights abuse and sexual assault against other developers. Yet CMW responded to both Taskforce consultations. In December 2020 it answered “No” to whether it would endorse the Taskforce’s blueprint and argued that land-based activities should not generate tradeable offsets (CMW, December 2020). In June 2021 it argued on the very question Permian answered, asking that “baseline setting is undertaken by third Parties, rather than project developers” for “at least all LULUCF project types” (CMW, June 2021). By CMW’s own standard, its submissions were lobbying too. Taking part in a public consultation is legitimate for CMW and for Permian alike.
• CMW is itself registered as a lobbying organisation on the EU Transparency Register, with 12 declared staff (LobbyFacts).

 

10. Kuamut failed on Katingan’s allegations

CMW says: Table 3 shows Kuamut with claims of “Land conflicts and dispossesion, baseline lobbying” [sic] and a final assessment of FAIL. The table note says: “These claims can be associated with any project the developer was linked to, and are not necessarily linked to the project in this table.”

Response:

• CMW cites no source about Kuamut. The claims come from Katingan, a different project in a different country.
• Kuamut protects 83,381 ha in Sabah. The project led the Sabah Forestry Department to reclassify the area from Class II production forest to a Class I protected forest reserve, ending commercial logging, as part of an agreement financed through carbon credits.
• It is a partnership between the Sabah Forestry Department, Rakyat Berjaya Sdn Bhd (Yayasan Sabah) and Permian Malaysia, supported on the ground by PACOS Trust and SEARRP.
• The project area is uninhabited. Nearby Orang Sungai communities have been engaged since 2016. The Project Description records that access to traditional resources is a sensitive issue, and that there were no disputes involving arbitration, protest or conflict at the time.

 

11. Audit findings presented as failure

CMW says: “Despite nearly 15 years of auditing, 13 different auditors, 88 reports and over 1,600 findings … nearly all the projects still fail” (p. 28). Katingan: 94 findings over 9 reports. Kuamut: 95 findings over 3 reports.

Response:

• Findings are how audits work: questions are raised, answered and closed. CMW accepts that in most cases findings “were subsequently resolved” (p. 28).
• Many findings are read as a sign of problems, but CMW does not say what number of findings would indicate a sound audit.
• Kuamut’s figure covers validation and first verifications, when findings are normally highest. Katingan’s includes the 2026 revalidation for the crediting-period renewal.

 

12. CMW ignores the CCB standard

CMW says: “It is entirely unclear how auditors are expected to enforce FPIC and social safeguards” (p. 22).

Response:

• Both projects are certified under the Climate, Community & Biodiversity (CCB) Standards, which set requirements on FPIC, community benefits and grievance mechanisms. The same auditors check conformance. Katingan and Kuamut attained Triple Gold.
• CMW reviewed 14 VCS documents and no CCB documents. CCB is not mentioned in the report text, although CMW’s Table 2 records that Katingan’s 2026 audit covered “VCS and CCB”.

 

13. Katingan grouped with Mai Ndombe

CMW says: “These include the two largest projects in the world for this period (Katingan and Mai Ndombe) … All 94.3 million carbon credits stem from projects that lacked integrity” (p. 40).

Response:

• Katingan supplies about 24% of the 94.3 million credits and is the highest-rated project in the sample.
• The sample was chosen by volume. Larger projects attract more scrutiny, so a test that counts allegations will find more of them in larger projects regardless of quality.

 

14. The authors’ 2025 assessment passed Katingan

CMW says: “Neither the authors, experts nor Carbon Market Watch have any conflict of interest to disclose” (p. 53).

Response:

• In Built to Fail? (Corporate Accountability, June 2025), the same two authors ranked Katingan second by volume, listed its BeZero rating as AA, and treated it as one of four non-problematic projects out of 47 (report).
• Since then Katingan’s 2021–2023 monitoring period has been verified, and credits were issued in July 2026 with the approval of Indonesia’s Ministry of Forestry. The method changed, and so did the result.
• Rachel Rose Jackson is Corporate Accountability’s Director of Research and International Policy: Climate (profile). Both Corporate Accountability and CMW campaign against offsetting. CMW attributes “unconscious, self-serving bias” to auditors because of who pays them, but does not apply the same test to itself.