NRT's response fails to address most of the key concerns raised in Survivals' report. In particular, it does not address our view that the project lacks a basis of 'additionality' and has no empirical baselines, as fundamentally required by carbon offset projects. The NRT response further fails to address the issue that the project is demonstrably non-compliant with the Verra-approved methodology under which the project was developed - especially in terms of its inability to control the project's borders - and should never have been validated and allowed to generate carbon credits on each of these grounds.

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