Crooked Carbon Business: Hawk Mountain Improved Forest Management Project, USA
The Nature Conservancy’s fake carbon offsets.
A new briefing by Simon Counsell and Jutta Kill looks into the Hawk Mountain Improved Forest Management Project, in Pennsylvania, USA.1 The briefing can be downloaded here:
The project was developed by the Hawk Mountain Sanctuary Association and The Nature Conservancy. The project documents were produced by Bluesource LLC in November 2018. In 2022, Bluesource merged with Element Markets under the name Anew™, which describes itself as “one of the largest climate solution companies in North America”.
Incidentally, Anew is embroiled in a legal case with Terra Global Capital over a US$640 million carbon deal that collapsed.
By March 2025, the project had issued 221,089 carbon credits, most of which have been sold and retired. One of the biggest buyers is the US bank, JPMorgan.
Of all the credits to be issued over the project’s 20 year crediting period, 75% were issued in the first four years. As a result, the project received large sums of money at the beginning. For the remainder of the project less than 4,000 credits per year will be issued. The project started in 2017. By March 2022, ten verifications had been carried out — all by SCS Global Services.
For the rest of the project monitoring and verification will take place every five years. None have happened since March 2022.
A fake baseline
Counsell and Kill note that the project document claims that, “By committing to maintain forest CO₂ stocks above the regional baseline level, the project will provide significant climate benefits through carbon sequestration.”
The project’s “improved forest management” represents “a significant improvement in the carbon storage and conservation value than higher return, more aggressive management regimes of industrial private lands in the region”.
The project document includes this illustration of how the number of carbon credits generated by the project are calculated:
The baseline scenario shows an approximately 80% reduction in above ground woody biomass, based on the assumption that in the absence of the carbon project the forest would be logged in the same way as the industrial timber concessions nearby.
The project document states that, “The project action will allow the forest to progress naturally with no commercial harvesting. In tandem with the project, a conservation easement has been put into place to ensure permanence.”
But the forests in the Hawk Mountain Sanctuary were not under any conceivable threat of commercial harvesting. In 1934, Rosalie Edge, a philanthropist, feminist, and bird watcher bought the land and created the “world’s first refuge for birds of prey”. Since 1938, the Hawk Mountain Sanctuary Association has managed the forest.
No additionality
The project is registered with American Carbon Registry, which has so far earned approximately US$50,000 in registration fees from the project’s carbon credits. In 2022, American Carbon Registry stated that,
Prior to developing the carbon project, the Hawk Mountain project area had no restrictions on timber harvesting, and the forest was aging. It is ACR’s understanding that in the absence of carbon revenue, the management activities required for improved forest health would not have been feasible without additional funding such as through timber harvesting.
Counsell and Kill looked up the financial records of the Hawk Mountain Sanctuary Association. In 2012, the Association received more than US$2 million income from contributions, membership and admission fees. It held reserves of almost US$14 million. By 2019, the Association’s annual income had reached US$3.3 million. Its reserves were more than US$17 million.
In 2024, with the income from carbon credits, Hawk Mountain Sanctuary Association’s annual income was US$6.7 million. Its reserves reached more than US$29 million. But the Association’s expenses had only increased by about US$400,000 per year — entirely as a result of salary increases.
Clearly, the Hawk Mountain Sanctuary Association did not need carbon income in order to invest in its already protected woodland.
In 2020, Ben Elgin, a journalist with Bloomberg exposed The Nature Conservancy’s “meaningless carbon offsets” at Hawk Mountain and elsewhere. Hawk Mountain’s director of conservation, Laurie Goodrich, told Bloomberg that without the carbon payments, “We’d still be management the land the same way.”
In a post based on Elgin’s article, I wrote that,
By selling carbon offsets from a forest that wasn’t threatened, The Nature Conservancy is allowing polluting corporations to continue pumping out greenhouse gases, and thus making the climate crisis worse. The only reason that carbon offsets exist is to allow polluting companies to continue polluting for as long as possible.
Following Bloomberg’s exposé, The Nature Conservancy carried out what it calls a “thorough review of our carbon portfolio”. As a result of the review, The Nature Conservancy cancelled its Pennsylvania Ridges project, that had also featured in Ben Elgin’s reporting.
“However, the Hawk Mountain project continued,” Counsell and Kill write, “and carried on issuing credits, despite its similarly dubious basis.”
This is the second in a new collection of posts on REDD-Monitor under the headline “Crooked Carbon Business”. The posts are based on a series of briefings about carbon offset projects written by Simon Counsell and Jutta Kill.
And now TNC is in Brazil, operating in the Amazon region, in the states of Oará and Amazonas, in partnership with local governments to develop jurisdictional REDD.