This is seriously insane. We’ve spent decades trying to get governments and corporations to take climate change and deforestation seriously, now that some are finally beginning to take notice, activities that are actually making a difference are being torn apart by those who claim to care about these issues.
These charges against the Katingan Mentaya Project are false, it’s disinformation. Those pushing them – Greenpeace, ORF, WRM, and Redd Monitor – either haven’t bothered to understand the project properly or have and decided that pesky facts shouldn’t stand in the way of a headline-grabbing story about corporate exploitation and greenwashing.
If anyone is even the least bit interested in what is actually happening on the ground, the publicly available PDD and monitoring reports set out how the project was design and what its achieving https://registry.verra.org/app/projectDetail/VCS/1477 .
The PDD details the consultation process the project held with representatives from ALL surrounding communities prior to launch.
The project was designed and implemented to fully recognise customary rights and community land tenure. It facilitated participatory land-use mapping and demarcated land-use boundaries in project-zone villages based on these customary rights. It establish formal consensus on the project area and helped local communities resolve conflicts within the broader project zone.
Participatory planning fundamentally shaped how the project worked with and supported local communities. It employed two tenure-based methods: participatory community mapping and village planning. Participatory community mapping transparently compiled critical spatial information about project-zone villages. This included village boundaries, the extent of cultivated land owned by community members, other land uses, and relevant thematic data. All data points were collaboratively validated with the communities, recorded using GPS, and integrated into spatial maps. The finalised maps were then presented to the communities for review and approval to ensure transparent and collective agreement.
No one was kicked off their land and no has had land taken away from them. But that’s hardly a story to rile up readers or to petition for more donations.
Instead of repeating Greenpeace’s lines, it might be helpful if journalists questioned why an international organisation that rakes in hundreds of millions of dollars each year might campaign so aggressively against an alternative form of financing conservation and climate action.
And if all that was just far too many words. Then how about this gif https://permianglobal.com/news/katingan-mentaya-project/ which uses publicly available historical Landsat optical satellite constellation data (NASA-Landsat mission). See if you can spot the Katingan Mentaya Project. I'll give you a clue, it's the dark green shape increasingly isolated against the devastation of land clearance around it. But sure, keep shouting about no threat, no additionality.
Of course, there are projects run by bad actors trying to make an easy buck. There are examples of data fudging and inflated baselines and damn right there are more than enough companies that just want to greenwash their quarterly returns as the world goes up in flames. All of that must called out and nailed to the wall.
But the absolute blind determination by some in the media to automatically see failings and corruption in any and all projects like these is not honest reporting, it’s a fiction, an easy narrative to work up some righteous anger. Worse than that, it’s making it harder for conservation to happen. It’s playing right into the hands of those who profit from destroying forests and converting the land.
As for the NGOs that knowingly spread lies about genuine and effective forest conservation because it doesn’t fit their ideological model, well, there’s just not a lot that can be done against such callous cynicism.
Thanks for this comment. I think it's worth pointing out that you are the Head of Communications at the UK incorporated company Permian Global. In 2013, PT Rimba Makmur Utama, the company running the Katingan REDD project, entered into a partnership with Permian Global. Permian's role is to sell carbon credits from the project and to raise finance for the project.
You're paid to promote the project, in other words.
While Permian Global is incorporated in the UK, the Permian Global Fund (the "Master Fund") is based in the tax haven of Luxembourg, where it is managed by Permian Global Management SARL, one of four Permian companies registered in Luxembourg.
You state that the project recognises customary rights and community land tenure and you describe the land-use mapping that took place. You write that, "No one was kicked off their land and no has had land taken away from them."
True, no one was evicted to make way for the Katingan REDD project. However, there are several reports of villagers having lost their farmland because of the conservation project.
The ORF documentary visits farmland inside the project area that villagers can no longer use. You have previously written that, "the project takes community grievances very seriously and works closely with community members to identify and resolve any issues that may arise." Are you now saying that the villagers that ORF spoke to simply made up the story about not being allowed to farm their land?
In 2019, a Dutch journalist and two Indonesian journalists wrote about the Katingan REDD project. They reported a land conflict between the REDD project and local communities. Villagers had cleared plots of land inside the project area and marked the plots with wooden signs with their names on. (https://archive.ph/D16Xj)
In 2016, PRI reported on a conflict over land tenure in the project area: "But some residents in the surrounding towns have long considered portions of it theirs in a traditional land tenure system. The combination of new conservation laws and the presence of the Katingan Project has cut people off from what they consider to be their land." (https://archive.ph/mJlo2)
In order to determine whether any REDD project is additional, the project developers create a counterfactual story about what would have happened in the absence of the project. This story is impossible to verify because the project did go ahead. In the case of the Katingan REDD project, the story involved the forest being cleared for industrial acacia plantations. Greenpeace's argument is that these acacia plantations were extremely unlikely to go ahead.
To calculate the rate of deforestation in the absence of the REDD project, the project used seven reference regions, five of which are in Riau province, Sumatra. Two of the world's largest and most destructive pulp and paper companies operate there: APP and APRIL.
But the underlying problem with the Katingan REDD project is not that it is attempting to protect an area of forest in Central Kalimantan. The problem is that it is a carbon trading project. Shell has bought almost 9 million carbon credits from the project. Shell is one of the world's most polluting companies. It is buying these (and other) carbon credits to greenwash its continued extraction of fossil fuels. By selling carbon credits to Shell and other Big Polluters, Katingan (and Permian Global) is complicit in this greenwashing. That looks like callous cynicism to me.
We cannot address the climate crisis without leaving fossil fuels in the ground. Carbon trading legitimates continued emissions from burning fossil fuels. That's what is seriously insane.
On your last point, Chris, I couldn’t agree with you more, fossil fuels must stay in the ground. I've spent my life sickened, angry and terrified by the sluggishness of climate action and the sheer complacency of those in power, just like you, I'm sure.
Those profiting from their continued extraction and use must be hammered hard with protests, legal action, policy action, disinvestment and good journalism.
Do you really think for a minute though that if we got rid of carbon credits today, that that would have any impact whatsoever on the level of global investment and use of coal, gas and oil? Call out greenwashing wherever it’s used, but do you seriously think a company making billions from fossil fuels would suddenly reverse course if they were prevented from sending out a press release about some green initiatives they’d supported? They would not even blink.
Blaming offsets and saying it legitimises continuing emissions is a convenient bogeyman. You’re as guilty as me at legitimising continuing emissions every time you drive, fly, turn on the gas, use plastic, or vote for politicians who don't make climate change a central tenet of their politics.
Meanwhile, today a carbon credit is a means of putting money into climate action that otherwise wouldn't get it - it's clumsy, has the potential for gaming and needs continual oversight and improvement, but it is a tool available now for preventing environmental destruction.
In a perfect world we wouldn’t need carbon offsets and we wouldn't need to finance conservation, we would just wave a wand. A carbon market is one solution we have in the real world.
I get the feeling you core issue with offsets is not so much the financing of climate action but how the companies buying them make claims afterwards - that's a legitimate concern, but it seems to have become popular in the media to attack the conservation programmes rather than going after those emitters making the claims. And anyway, who should be paying for actions that prevent emissions? Surely those profiting from polluting the planet?
On the additionality point. Yes, absolutely, to prevent deforestation, a project developer must use a counterfactual baseline. Your tone makes it sound like that’s a bad thing. The alternative would be to do nothing, to wait and see if all the evidence did in fact point to land conversion. Of course, by that point the forest would be gone, the species living there eradicated and the emissions wafting around in the atmosphere, doing their thing.
A counterfactual is a model based on best available data. It’s imperfect but an absolutely fundamental and necessary feature of impact analysis. All climate models rely on counterfactuals (hey, why bother lowering emissions at all, climate change is just some counterfactual story those moany scientists have been harping on about). They’re used to predict a negative outcome so we might do everything we can to stop whatever it is from coming true - yes, impossible to verify in the strictest sense unless the project fails.
When the Katingan project started, the forest was both legally eligible for acacia plantation establishment and it had been designated as such by the government. Numerous policy initiatives had been developed to grow the acacia market, which was and still is a major contributor to the country’s economy, not to mention a major cause of deforestation and emissions. The market was and still is dominated by a small number of multinational companies that have operations right across Indonesia. A third of the project area had already had a plantation application, which would have facilitated further exploitation – the project prevented this.
Greenpeace has argued that the threat to the project had been eliminated due to a temporary moratorium on new peatland concessions that was announced in 2011. The very same Greenpeace that said this: Kiki Taufik, Global Head of Greenpeace Southeast Asia forests campaign, “Deforestation and forest fires have continued inside moratorium areas and boundary maps get regularly redrawn to remove forest or peat areas that are of interest to plantation companies. Making it permanent doesn’t fix its fundamental weaknesses and won’t stop forest and peatland degradation in Indonesia”.
Again, please watch this https://permianglobal.com/news/katingan-mentaya-project/ - Greenpeace will say whatever it wants, but had the project not intervene, the forest would face the same fate as the 2 million hectares to the west.
On the ORF documentary, I have no way of knowing. The journalists didn’t contact the project for comment – which to me doesn’t sound fair or balanced. Meanwhile, the project has run consultations with 34 villages around the project to agree the project boundaries and works to address all grievances it receives.
ORF, like the Dutch journalist before, seem intent on telling a story of exploitation and greenwashing, despite evidence to the contrary. It’s far easier to spin a narrative of corporate malpractice to stir up readers’ anger. Evidently, it doesn’t matter that it’s not true, a rousing takedown piece is far more publishable.
And yes, totally right, as head of comms, I do have a professional interest in defending this project - paid to promote it, as you say. But everything I have said about it is back up by publicly available project documentation, all of which has undergone multiple third-party audits and validation.
You write that, "Those profiting from . . . continued extraction [of fossil fuels] and use must be hammered hard with protests, legal action, policy action, disinvestment and good journalism."
How does helping to greenwash the operations of these fossil fuel corporations by selling them carbon credits fit into this? Accepting the money for almost 9 million carbon credits from Shell is immoral and unethical. It's similar to, and just as bad as, museums and art galleries accepting sponsorship from Shell and other fossil fuel companies.
No, stopping carbon credits would not stop the extraction of fossil fuels. Neither would getting oil out of art sponsorship. But selling carbon credits to fossil fuel companies like Shell undermines the campaigns and protests against these companies.
Shell has used carbon credits from Katingan to claim that deliveries of LNG (fossil gas) are carbon neutral. Even Renat Heuberger, ex-CEO of South Pole, has admitted that the idea of carbon neutral fossil fuels is "such obvious nonsense". But I'm still waiting for the press release from Katingan, or Permian, or Verra, or any of the other companies profiting from sales of carbon offsets to Big Polluters, explaining why this is "obvious nonsense".
Since you're accusing me of legitimising emissions from burning fossil fuels, I should point out that I don't drive. I don't fly. I don't have a gas cooker or fossil fuel heating or cooling. I do use some plastic, which I try to limit. I don't vote for politicians that ignore action on climate change. I'm vegan.
And, I would never accept money from a fossil fuel corporation.
There are many other ways of protecting forests that do not involve carbon trading. Was there no forest conservation before carbon offsets were invented? Forest conservation existed long before carbon trading. Unfortunately, there is a dominant narrative that conservation is only possible with billions of dollars of conservation finance. And, in this narrative, carbon offsets and biodiversity offsets (and credits) have become a key way of raising conservation finance.
On your point about counterfactuals, there is an enormous difference between climate models and counterfactual baselines used in REDD projects. There are several climate models. They are rigorously discussed, subjected to peer review, and are based on science. Counterfactual baselines for REDD projects are a single storyline dreamed up by a project developer. This storyline is then approved by an auditor who is paid by the project developer. The auditors' reports are approved by Verra, which makes its money from a commission on the carbon credits it certifies. The whole system is riddled with conflicts of interest.
Yes, the forest in the Katingan REDD project area should be protected. But not by selling carbon credits, and not at the expense of the communities that live there.
I'm astonished that you dismiss the findings of journalists and environmentalists who visit the project and report land conflicts as just spinning a narrative. I don't want to tell you how to do your job, but just from a PR perspective that looks terrible!
Incidentally, you're very quiet about the Permian Global Fund being based in the tax haven of Luxembourg. Why would a UK company run a fund out of a tax haven? I know it's not illegal, but it's certainly not ethical.
Great report, thanks! This is how this "Shell" game works - conflicts of interest, quick profits, funds moving around to quickly to track, no real emissions reductions and lots of displaced people. What's not to like?
This is seriously insane. We’ve spent decades trying to get governments and corporations to take climate change and deforestation seriously, now that some are finally beginning to take notice, activities that are actually making a difference are being torn apart by those who claim to care about these issues.
These charges against the Katingan Mentaya Project are false, it’s disinformation. Those pushing them – Greenpeace, ORF, WRM, and Redd Monitor – either haven’t bothered to understand the project properly or have and decided that pesky facts shouldn’t stand in the way of a headline-grabbing story about corporate exploitation and greenwashing.
If anyone is even the least bit interested in what is actually happening on the ground, the publicly available PDD and monitoring reports set out how the project was design and what its achieving https://registry.verra.org/app/projectDetail/VCS/1477 .
The PDD details the consultation process the project held with representatives from ALL surrounding communities prior to launch.
The project was designed and implemented to fully recognise customary rights and community land tenure. It facilitated participatory land-use mapping and demarcated land-use boundaries in project-zone villages based on these customary rights. It establish formal consensus on the project area and helped local communities resolve conflicts within the broader project zone.
Participatory planning fundamentally shaped how the project worked with and supported local communities. It employed two tenure-based methods: participatory community mapping and village planning. Participatory community mapping transparently compiled critical spatial information about project-zone villages. This included village boundaries, the extent of cultivated land owned by community members, other land uses, and relevant thematic data. All data points were collaboratively validated with the communities, recorded using GPS, and integrated into spatial maps. The finalised maps were then presented to the communities for review and approval to ensure transparent and collective agreement.
No one was kicked off their land and no has had land taken away from them. But that’s hardly a story to rile up readers or to petition for more donations.
As for the Greenpeace accusations: https://permianglobal.com/news/permian-global-analysis-of-greenpeace-report/. Apparently, Greenpeace will happily watch a forest burn if it helps spread misinformation about a successful REDD+ project.
Instead of repeating Greenpeace’s lines, it might be helpful if journalists questioned why an international organisation that rakes in hundreds of millions of dollars each year might campaign so aggressively against an alternative form of financing conservation and climate action.
And if all that was just far too many words. Then how about this gif https://permianglobal.com/news/katingan-mentaya-project/ which uses publicly available historical Landsat optical satellite constellation data (NASA-Landsat mission). See if you can spot the Katingan Mentaya Project. I'll give you a clue, it's the dark green shape increasingly isolated against the devastation of land clearance around it. But sure, keep shouting about no threat, no additionality.
Of course, there are projects run by bad actors trying to make an easy buck. There are examples of data fudging and inflated baselines and damn right there are more than enough companies that just want to greenwash their quarterly returns as the world goes up in flames. All of that must called out and nailed to the wall.
But the absolute blind determination by some in the media to automatically see failings and corruption in any and all projects like these is not honest reporting, it’s a fiction, an easy narrative to work up some righteous anger. Worse than that, it’s making it harder for conservation to happen. It’s playing right into the hands of those who profit from destroying forests and converting the land.
As for the NGOs that knowingly spread lies about genuine and effective forest conservation because it doesn’t fit their ideological model, well, there’s just not a lot that can be done against such callous cynicism.
Thanks for this comment. I think it's worth pointing out that you are the Head of Communications at the UK incorporated company Permian Global. In 2013, PT Rimba Makmur Utama, the company running the Katingan REDD project, entered into a partnership with Permian Global. Permian's role is to sell carbon credits from the project and to raise finance for the project.
You're paid to promote the project, in other words.
While Permian Global is incorporated in the UK, the Permian Global Fund (the "Master Fund") is based in the tax haven of Luxembourg, where it is managed by Permian Global Management SARL, one of four Permian companies registered in Luxembourg.
You state that the project recognises customary rights and community land tenure and you describe the land-use mapping that took place. You write that, "No one was kicked off their land and no has had land taken away from them."
True, no one was evicted to make way for the Katingan REDD project. However, there are several reports of villagers having lost their farmland because of the conservation project.
The ORF documentary visits farmland inside the project area that villagers can no longer use. You have previously written that, "the project takes community grievances very seriously and works closely with community members to identify and resolve any issues that may arise." Are you now saying that the villagers that ORF spoke to simply made up the story about not being allowed to farm their land?
In 2019, a Dutch journalist and two Indonesian journalists wrote about the Katingan REDD project. They reported a land conflict between the REDD project and local communities. Villagers had cleared plots of land inside the project area and marked the plots with wooden signs with their names on. (https://archive.ph/D16Xj)
In 2016, PRI reported on a conflict over land tenure in the project area: "But some residents in the surrounding towns have long considered portions of it theirs in a traditional land tenure system. The combination of new conservation laws and the presence of the Katingan Project has cut people off from what they consider to be their land." (https://archive.ph/mJlo2)
In order to determine whether any REDD project is additional, the project developers create a counterfactual story about what would have happened in the absence of the project. This story is impossible to verify because the project did go ahead. In the case of the Katingan REDD project, the story involved the forest being cleared for industrial acacia plantations. Greenpeace's argument is that these acacia plantations were extremely unlikely to go ahead.
To calculate the rate of deforestation in the absence of the REDD project, the project used seven reference regions, five of which are in Riau province, Sumatra. Two of the world's largest and most destructive pulp and paper companies operate there: APP and APRIL.
But the underlying problem with the Katingan REDD project is not that it is attempting to protect an area of forest in Central Kalimantan. The problem is that it is a carbon trading project. Shell has bought almost 9 million carbon credits from the project. Shell is one of the world's most polluting companies. It is buying these (and other) carbon credits to greenwash its continued extraction of fossil fuels. By selling carbon credits to Shell and other Big Polluters, Katingan (and Permian Global) is complicit in this greenwashing. That looks like callous cynicism to me.
We cannot address the climate crisis without leaving fossil fuels in the ground. Carbon trading legitimates continued emissions from burning fossil fuels. That's what is seriously insane.
On your last point, Chris, I couldn’t agree with you more, fossil fuels must stay in the ground. I've spent my life sickened, angry and terrified by the sluggishness of climate action and the sheer complacency of those in power, just like you, I'm sure.
Those profiting from their continued extraction and use must be hammered hard with protests, legal action, policy action, disinvestment and good journalism.
Do you really think for a minute though that if we got rid of carbon credits today, that that would have any impact whatsoever on the level of global investment and use of coal, gas and oil? Call out greenwashing wherever it’s used, but do you seriously think a company making billions from fossil fuels would suddenly reverse course if they were prevented from sending out a press release about some green initiatives they’d supported? They would not even blink.
Blaming offsets and saying it legitimises continuing emissions is a convenient bogeyman. You’re as guilty as me at legitimising continuing emissions every time you drive, fly, turn on the gas, use plastic, or vote for politicians who don't make climate change a central tenet of their politics.
Meanwhile, today a carbon credit is a means of putting money into climate action that otherwise wouldn't get it - it's clumsy, has the potential for gaming and needs continual oversight and improvement, but it is a tool available now for preventing environmental destruction.
In a perfect world we wouldn’t need carbon offsets and we wouldn't need to finance conservation, we would just wave a wand. A carbon market is one solution we have in the real world.
I get the feeling you core issue with offsets is not so much the financing of climate action but how the companies buying them make claims afterwards - that's a legitimate concern, but it seems to have become popular in the media to attack the conservation programmes rather than going after those emitters making the claims. And anyway, who should be paying for actions that prevent emissions? Surely those profiting from polluting the planet?
On the additionality point. Yes, absolutely, to prevent deforestation, a project developer must use a counterfactual baseline. Your tone makes it sound like that’s a bad thing. The alternative would be to do nothing, to wait and see if all the evidence did in fact point to land conversion. Of course, by that point the forest would be gone, the species living there eradicated and the emissions wafting around in the atmosphere, doing their thing.
A counterfactual is a model based on best available data. It’s imperfect but an absolutely fundamental and necessary feature of impact analysis. All climate models rely on counterfactuals (hey, why bother lowering emissions at all, climate change is just some counterfactual story those moany scientists have been harping on about). They’re used to predict a negative outcome so we might do everything we can to stop whatever it is from coming true - yes, impossible to verify in the strictest sense unless the project fails.
When the Katingan project started, the forest was both legally eligible for acacia plantation establishment and it had been designated as such by the government. Numerous policy initiatives had been developed to grow the acacia market, which was and still is a major contributor to the country’s economy, not to mention a major cause of deforestation and emissions. The market was and still is dominated by a small number of multinational companies that have operations right across Indonesia. A third of the project area had already had a plantation application, which would have facilitated further exploitation – the project prevented this.
Greenpeace has argued that the threat to the project had been eliminated due to a temporary moratorium on new peatland concessions that was announced in 2011. The very same Greenpeace that said this: Kiki Taufik, Global Head of Greenpeace Southeast Asia forests campaign, “Deforestation and forest fires have continued inside moratorium areas and boundary maps get regularly redrawn to remove forest or peat areas that are of interest to plantation companies. Making it permanent doesn’t fix its fundamental weaknesses and won’t stop forest and peatland degradation in Indonesia”.
https://www.greenpeace.org/southeastasia/press/2834/one-million-hectares-of-forest-burned-inside-forests-moratorium-area-greenpeace-analysis-show/
Again, please watch this https://permianglobal.com/news/katingan-mentaya-project/ - Greenpeace will say whatever it wants, but had the project not intervene, the forest would face the same fate as the 2 million hectares to the west.
On the ORF documentary, I have no way of knowing. The journalists didn’t contact the project for comment – which to me doesn’t sound fair or balanced. Meanwhile, the project has run consultations with 34 villages around the project to agree the project boundaries and works to address all grievances it receives.
ORF, like the Dutch journalist before, seem intent on telling a story of exploitation and greenwashing, despite evidence to the contrary. It’s far easier to spin a narrative of corporate malpractice to stir up readers’ anger. Evidently, it doesn’t matter that it’s not true, a rousing takedown piece is far more publishable.
And yes, totally right, as head of comms, I do have a professional interest in defending this project - paid to promote it, as you say. But everything I have said about it is back up by publicly available project documentation, all of which has undergone multiple third-party audits and validation.
You write that, "Those profiting from . . . continued extraction [of fossil fuels] and use must be hammered hard with protests, legal action, policy action, disinvestment and good journalism."
How does helping to greenwash the operations of these fossil fuel corporations by selling them carbon credits fit into this? Accepting the money for almost 9 million carbon credits from Shell is immoral and unethical. It's similar to, and just as bad as, museums and art galleries accepting sponsorship from Shell and other fossil fuel companies.
No, stopping carbon credits would not stop the extraction of fossil fuels. Neither would getting oil out of art sponsorship. But selling carbon credits to fossil fuel companies like Shell undermines the campaigns and protests against these companies.
Shell has used carbon credits from Katingan to claim that deliveries of LNG (fossil gas) are carbon neutral. Even Renat Heuberger, ex-CEO of South Pole, has admitted that the idea of carbon neutral fossil fuels is "such obvious nonsense". But I'm still waiting for the press release from Katingan, or Permian, or Verra, or any of the other companies profiting from sales of carbon offsets to Big Polluters, explaining why this is "obvious nonsense".
Since you're accusing me of legitimising emissions from burning fossil fuels, I should point out that I don't drive. I don't fly. I don't have a gas cooker or fossil fuel heating or cooling. I do use some plastic, which I try to limit. I don't vote for politicians that ignore action on climate change. I'm vegan.
And, I would never accept money from a fossil fuel corporation.
There are many other ways of protecting forests that do not involve carbon trading. Was there no forest conservation before carbon offsets were invented? Forest conservation existed long before carbon trading. Unfortunately, there is a dominant narrative that conservation is only possible with billions of dollars of conservation finance. And, in this narrative, carbon offsets and biodiversity offsets (and credits) have become a key way of raising conservation finance.
On your point about counterfactuals, there is an enormous difference between climate models and counterfactual baselines used in REDD projects. There are several climate models. They are rigorously discussed, subjected to peer review, and are based on science. Counterfactual baselines for REDD projects are a single storyline dreamed up by a project developer. This storyline is then approved by an auditor who is paid by the project developer. The auditors' reports are approved by Verra, which makes its money from a commission on the carbon credits it certifies. The whole system is riddled with conflicts of interest.
Yes, the forest in the Katingan REDD project area should be protected. But not by selling carbon credits, and not at the expense of the communities that live there.
I'm astonished that you dismiss the findings of journalists and environmentalists who visit the project and report land conflicts as just spinning a narrative. I don't want to tell you how to do your job, but just from a PR perspective that looks terrible!
Incidentally, you're very quiet about the Permian Global Fund being based in the tax haven of Luxembourg. Why would a UK company run a fund out of a tax haven? I know it's not illegal, but it's certainly not ethical.
Great report, thanks! This is how this "Shell" game works - conflicts of interest, quick profits, funds moving around to quickly to track, no real emissions reductions and lots of displaced people. What's not to like?