Crooked Carbon Business: Northern Kenya Grassland Carbon Project, Kenya

This week’s briefing by Simon Counsell and Jutta Kill looks at the Northern Kenya Grasslands Carbon Project in Kenya.1 The briefing can be downloaded here:
The Northern Kenya Grassland Carbon Project covers an area of almost 2 million hectares. The project is run by the Northern Rangelands Trust which has a total area of 4 million hectares in its “conservancies,” which are areas that NRT claims are managed for the benefit of wildlife and people.
More than 100,000 people live inside the project area, including Indigenous Samburu, Maasai, Borana, and Rendille peoples. They are pastoralists whose livelihoods depends on their livestock of cattle, camels, sheep, and goats.
The project aims to replace traditional grazing practices with “planned rotational grazing” which according to NRT, allows more vegetation to grow and store more carbon in the soil.
And NRT claims that without the project, the grasslands would become degraded.
Counsell and Kill write that,
Data was falsely presented as showing that the condition of the grazing lands had declined in the previous decade, with the implication that this would continue. The further implication – also not demonstrated with any empirical evidence – was that this had resulted in declines in stores of soil carbon, which the project would reverse.
The project’s grazing reports show that the project has been unable to monitor the movements of livestock, do not show planned rotational grazing, and cannot be used to monitor carbon leakage. In 2021, NRT produced a report that shows that eight years into the project, rangeland vegetation health is declining across almost half the area of eight conservancies in the carbon project.
By 2022, US$324,000 had been transferred to each of the conservancies. By then 3.2 million carbon credits had been sold. The amount of money raised from sales of carbon credits is unknown and NRT has never published any audited financial accounts. Counsell and Kill estimate that it could be somewhere between US$21 million and US$45 million. The percentage going to communities is tiny.
“As of May 2024, most of the conservancies are reported to have challenged NRT over the distribution of benefits,” Counsell and Kill write.
Verra suspended the project — twice
In 2020, Aster Global Environmental Solutions validated and verified the project under the Verra system. The project started in January 2013. Between 2013 and 2016, the first crediting period, the project generated 3.2 million carbon credits, all of which had been sold by January 2022, according to Verra’s registry.
In the second crediting period, 2017 to 2020, 3.5 million carbon credits were generated. This time the auditor was Ruby Canyon Environmental.
Buyers of the project’s carbon credits include Meta, Netflix, Kering, Beiersdorf, and British Airways. By August 2024, more than 6 million carbon credits from the project had been retired.
In March 2023, Survival International published a detailed critique of the project. Verra suspended sales of carbon credits from the project and carried out a “review”. In November 2023, Verra published the findings of its review. Verra failed to address most of the concerns raised. Survival International described the review as a “shocking whitewash”.
In January 2025, the Environmental and Land Court in Isolo County ruled that two of NRT’s largest conservancies were established unconstitutionally. The ruling followed a 2021 petition by 164 members of the Borana Indigenous community.
One of the conservancies is part of the carbon project and accounts for about 20% of the carbon credits generated.
In May 2025, Verra suspended the project for the second time to carry out another review.
Counsell and Kill summarise the problems with the project as follows:
Non-additionality: The project presents an implausible case that it is creating any genuinely new storage of carbon that would otherwise remain in the atmosphere. It is based on a presumption that the traditional forms of grazing were causing degradation of soils and that only the carbon project could remedy this. But the case that the area was being degraded through “unplanned grazing” is not supported with any empirical evidence.
Baselines: As with additionality claims, offset project baselines are by definition hypothetical and can therefore ultimately not be verified. The baseline for the NRT carbon project (i.e. what is claimed would have happened in the project’s absence) is merely drawn from a presumption that the traditional forms of grazing are causing degradation of soils, and would continue to do so, without this being based on any empirical evidence.
Carbon leakage: The project purports to be able to quantify how many ‘livestock days’ are spent out of the project area, but analysis of the monitoring data on which these claims are based show that these are for the most part wholly inadequate for such a purpose. The quantification of how these animal movements affect carbon storage outside the project area is in fact little more than guesswork. The inability to control the projects borders is in clear contravention of the Verra-approved methodology under which the project was developed.
The basis of NRT’s rights to “own” and trade carbon from the respective lands: There are serious doubts about the basis on which NRT has obtained the rights to trade the carbon putatively stored in the soils of the Conservancies. A formal agreement to this effect was not signed between NRT and the Conservancies until June 2021 – eight and half year after the project started, and after the period covered by first and second verifications. In other words, even setting aside (non-) compliance with the CLA 2016, NRT did not have a clear contractual right to sell the carbon during this period.
Verra’s review process is fundamentally flawed: Taking all these together, it is clear that there have been major failings both by the Verra-accredited validators and verifiers, which have been able to validate and verify with impunity a project that is clearly not in compliance with the respective methodology or Verra’s overall requirements. Verra’s Section 6 review process provided the opportunity to deeply assess what had gone wrong in the case of this project. Instead, a policy of deliberately not investigating the matter properly, and simply ignoring the documented problems, was adopted. This shows that there is, in fact, no functional “ultimate backstop” in the Verra process where projects can be halted when found to be faulty. This all points to wider governance failures, and the extreme danger of entrusting such important aspects of climate mitigation policy to a private and unaccountable body with a vested interest in the outcomes.
This is the sixth 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.





What is absurd, some might use the word scandalous, is that this assumption of pastoralist degradation of the rangelands in east Africa, the Horn, and Sahel, has been fueling rangeland management projects and then conservation and more recently carbon offset projects, since the 1970s. I was the socioeconomic on the Central Rangelands Development Projwct in So Alia that ballooned from a $39million USAID/WorldBank/GYZ project in Tre early 1980s to $100million (1980s dollars). The assumption was Somalis were degrading the rangelands. The premise AFTER years of range ecologist data collection showed it was quite the opposite - the pastoralists’ movement with embedded inter-clan agreements was fundamental to rangeland productivity. The fact over 40 years on despite a robust academic literature proving th e assumption to be dubious at best or baseless at worst, is what is really disappointing. The dominant logic wins over data and analysis to the detriment of people and planet.