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EPA Shuts Down Carbon Deal Over DayLight’s Investigation


The headquarters of the Environmental Protection Agency of Liberia in Sinkor. The DayLight/Mark B. Newa

By Esau J. Farr

MONROVIA – The Environment Protection Agency (EPA) has disapproved of carbon credit negotiations between an American-owned company  BlueEarth Capital and rural communities following an investigation by The DayLight that exposed irregularities with the deal.  

“[The EPA] has thus issued an immediate resolute call to all communities involved in discussions with the company (BlueEarth) to cease all engagements without delay or risk drastic actions,” said the agency in a statement over the weekend.

“EPA’s involvement and approval are non-negotiable pre-requisites in carbon credit deals in Liberia,” it added. 

The agency further expressed “profound dismay” over the ongoing illegal carbon negotiations between BlueEarth Capital and residents of Ziadue Clan, River Cess County.

The release came on the back of a DayLight story on  BlueEarth’s proposed MoU with Ziadue to save carbon credits on more than 55,000 hectares of forestland.  

The DayLight reported a number of illegalities associated with the proposed deal.

The investigation showed BlueEarth induced community leaders to consent to the deal by underwriting their transportation and food costs.

It proved that ordinary townspeople and some community leaders were still unaware of the deal despite emerging in March, a violation of locals’ right to free, prior and informed consent (FPIC).  (FPIC is guaranteed in the Community Rights Law, the Land Rights Act, and the United Nations Declaration on the Rights of Indigenous Peoples)

The deal sought over 55,000 hectares, more than 8,000 hectares of the uncontracted area Ziadue has.

It was illegally intended to last for 25 years, 10 more than the legal duration of a community forest contract, based on the Community Rights Law. 

EPA, one of the agencies responsible for regulating the carbon industry, said it was caught unaware by The DayLight’s investigation.

BlueEarth Capital intended to capture carbon credits in more than 55,000 hectares of forestland in Ziadue Clan, Central River Cess District in River Cess County. The DayLight/Carlucci Cooper

“Their intent is to exploit these forests for carbon harvesting and subsequent trading of carbon credits on the international market,” it said. BlueEarth has also engaged communities in Nimba, Grand Cape Mount and Gbarpolu.

Ziadue Clan’s land leadership said they would now focus on getting its ancestral land deed, a process it has almost completed.

“We are customary people. What we are running after now is our confirmatory survey to get a deed from the Liberia Land Authority (LLA),” said Emmanuel Roberts, the chairman of the Ziadue’s community land development management committee (CLDMC).

“If we have anything to do with BlueEarth Capital, it will not be hidden from the national government, civil society organizations and our consultant.”

Augustine Jarrett, BlueEarth’s American owner and former presidential adviser, did not answer questions for comments on the matter. However, he defended his institution in a statement on Monday evening.

“We are deeply committed to the principles of transparency, integrity, and community engagement,” Jarrett said.  

Inside A Problematic Carbon Deal in River Cess


Top: A graphic depicting BlueEarth Capital’s CEO Augustine Jarrett and townsmen of Ziadue Clan.  The DayLight /Rebazar Forte

By Esau J. Farr        

  • BlueEarth Capital, a company seeking a carbon contract with Ziadue Clan, River Cess, gave locals money ahead of an agreement, undermining villagers’ right to free, prior and informed consent.  
  • The proposed agreement targets over 55,000 hectares of forest, more than Ziadue’s uncontracted forest area
  • Liberia has no laws or policies for carbon trading, and the duration of the proposed deal is not backed by existing laws
  • Many townspeople The DayLight interviewed said they were not aware of a proposed contract with the company, another red flag.
  • Locals expressed concern over BlueEarth’s lack of expertise in the emerging carbon credit market and are uncertain about their fair share of benefits

ZIADUE CLAN – The ongoing negotiation between the Liberian government and the UAE-based Blue Carbon would affect parts of River Cess. But a community in the southcentral county is negotiating its own carbon agreement with another company—and under similar controversial circumstances.

Ziadue, located in the Central River Cess District, is negotiating a carbon credit memorandum of understanding (MoU) with BlueEarth Capital, an American-owned company. The parties had earlier signed a letter of intent. The company wants to harvest carbon from over 52,000 hectares of forest and trade the carbon credits it obtains on the international carbon market.

But BlueEarth Capital has been providing food and transportation fares for community leaders reviewing the agreement, according to the company itself and townspeople. Recently, the company gave the community cash for the same purpose.

“We hosted a meeting to view this thing (draft agreement) that they brought here… So, they sponsored the meeting that time,” said Emmanuel Roberts, the chairman of the Ziadue’s community land development and management committee. Under the Land Rights Act, the CLDMC, which comprises locals from towns and villages, represents customary communities in land matters.

Roberts claimed that BlueEarth provided about L$25,000 for a recent meeting in a town called Gbardiah he used to buy food and reimbursed attendees’ transportation fares.  

Friday Wesseh, the treasurer of the CLDMC, told The DayLight Roberts informed him that BlueEarth had sent him US$10 but had yet to receive it. Roberts denied that claim, saying he had only promised Wesseh on his own accord.

“Even though Wesseh did not attend the meeting in Gbardiah, being a CLDMC leader, I decided to give him something from my pocket,” Roberts told The DayLight in a phone interview.

BlueEarth’s payments to local has undermined the principle of free, prior and informed consent (FPIC), a right granted to rural people in the Land Rights Act and the Community Rights Law… The word “free” in FPIC means void of intimidation, coercion or manipulation.

Augustine Jarrett, BlueEarth’s sole owner said the payments were not meant to influence villagers. Jarrett said the payments were part of a tradition for people seeking to work with communities.

“We did facilitate bringing people to areas… We don’t expect them to come with their lunches…,” Jarrett told The DayLight in an interview at his Tweh Farm office outside Monrovia. “We are not attempting to induce anybody to do anything they are unwilling to do.”

Emmanuel M. Roberts, Ziadue’s CLDMC Chairperson. The DayLight/Esau J. Farr

But Jarrett’s claims are not backed by facts. Companies underwrite expenses for communities’ meetings It is true in forestry. However, that happens in cases where such payments are captured in an existing agreement, and not an FPIC engagement.  

BlueEarth’s proposed MoU also flouts the FPIC standards in other ways. Ziadue and BlueEarth have been negotiating the deal since February but many townspeople said they were unaware of it. Only three out of 40 CLDMC members had signed the letter of intent, the document shows.

“That’s my first time hearing about it,” said Patience Smith a member of the CLDMC.

“The one I know about is… [the logging company],” added Betty Gaywea, a women leader. She was referencing EJ&J Logging Company which works in Ziadue.

In order for a community to give its consent, all of its representatives must have their say through a transparent process. That is according to the UN’s Declaration on the Rights of Indigenous Peoples, which Liberia has ratified, and Liberia’s own FPIC Policy.  

Jarrett claimed his company respected FPIC and would get the community’s general consent in time. He wrongly claimed that FPIC “continues over the entire life of the project.” Actually, FPIC must occur prior to the approval or commencement of a project, according to the United Nations. 

‘Not a forestry company’

BlueEarth eyes a 25-year contract with Ziadue, subject to a 10-year review. Those timeframes go against the Community Rights Law of 2009 with Respect to Forest Lands. The law sets a 15-year ceiling for community forest-related contracts, with a five-year review period.

BlueEarth seeks over 55,000 hectares of forest in Ziadue, River Cess, which the clan does not have. The DayLight/Carlucci Cooper

Jarrett said BlueEarth’s proposed MoU was not a forestry contract, so, 15 years was not attractive enough for investors.

“How can I ask a person to invest in Liberia’s forest conservation if we can’t guarantee that we are going to conserve the forest over the next… 30 years?” Jarrett said. 

“We are not regulated under the forestry law, we are not a forest company and we are not going to extract forestry assets,” he added.

Those points are largely misleading. While Liberia does not have any specific legal framework on carbon credits, the emerging industry is more related to forestry than other sectors. The Forestry Development Authority (FDA) is playing a key role in the negotiation between Liberia and the UAE-based Blue Carbon. The FDA has also added carbon credits to its communities, conservation and commercial pillars.  Liberia’s first-known carbon negotiation about 15 years ago targeted 400,000 hectares, the maximum under the National Forestry Reform Law.

The size of the forest is another issue. BlueEarth’s MoU targets 55,123 hectares of forestland but Ziadue does not have such land area to lease. Ziadue’s uncontracted forest covers only 47,000 hectares, according to BlueEarth. That is 8,000 hectares less than BlueEarth’s target.

Moreover, that 47,000 hectares is questionable. Blatoe, a town arguably in Ziadue across the Cestos River, has a boundary issue with a town in the neighboring Beaworn Clan. That problem has stalled Ziadue’s quest to acquire its ancestral deed, a journey the clan started in 2020.  (Under the Land Rights Act, a community must resolve its border issues before the government surveys its lands and gives its deed)

A collage of BlueEarth’s map (left) and the Sustainable Development Institute’s map of Ziadue  

Early last month, monitors of the Liberia Land Authority (LLA) found Ziadue was unready for an official survey, a requirement for the issuance of the document. This week, the Sustainable Development Institute (SDI), which is assisting with Ziadue in getting its deed, told The DayLight that the Blatoe issue had been resolved. However, LLA did not confirm the information.

Jarrett declined to comment on that matter.

‘Think carefully’

Locals have consulted SDI on the proposed MoU.

“We are waiting on our consultants for advice before we accept or reject BlueEarth,” said Samuel Morris, a member of Ziadue’s CLDMC. “For me, I am not yet encouraged whether BlueEarth is a good company or not because I do not know anything about carbon.”

Elijah Garsuah, the acting clan chief of Ziadue, even feared BlueEarth Capital would end up like EJ&J Logging Company. The firm contracted a portion of the forest Ziadue shares with its neighbor, the Ziadue and Teekpeh Community Forest in 2018 and did not live up to the agreement. In fact, the leadership of the community forest has resolved to cancel its agreement.

Under the MoU, BlueEarth will pay land rental fees of US$82,684 for a one-year feasibility study at US$1.50 per hectare.

After that period, the company will pay Ziadue 10 percent of the total sales of carbon credits on the voluntary carbon market, according to the document. Companies trade carbon credits to other companies that want to offset their carbon emissions on the voluntary carbon market.  

Critics say Liberia does not have the expertise and laws to regulate such a complex industry.

Elijah Garsuah, Acting Clan Chief of Ziadue. The DayLight/Esau J. Farr

BlueEarth was founded in February last year, with Jarrett as its sole American owner, according to the company’s article of incorporation. Jarrett was the chief finance officer of Liberia Wood Industry, a parent company of International Consultant Capital (ICC), which holds a logging contract for forest in River Cess and Nimba. However, he does not have any experience in carbon trading.

SDI said it was analyzing the proposed MoU and had observed that the proposed 10 percent share for Ziadue from potentially generated revenue from the carbon project in the agreement is not fair to the community.

“We advise the community to think carefully before signing this deal,” said Nora Bowier, the coordinator of SDI’s land rights program.

“We know that development opportunities are crucial for these communities but proper due diligence is necessary to ensure that communities do not make the same mistakes of the past by signing agreements with companies that had no capacity to deliver.”

[Aaron Geezay contributed to this report]


Alleged Bribery, Fraud and Arrest: Liberia’s First Carbon Deal 

created by dji camera

Top: Carbon Harvesting Corporation (CHC) proposed a carbon credit deal for 400,000 hectares of forest in River Cess that would have left Liberia US$2.2 billion poorer. The DayLight/Derick Snyder

By James Harding Giahyue

MONROVIA – Many would believe that the current negotiation between the Liberian government and Blue Carbon of the United Arab Emirates is Liberia’s first attempt at a carbon credit deal.

Well, that is not true. Liberia’s first carbon trading discussions occurred more than one-and-a-half decades ago with a Carbon Harvesting Corporation (CHC), based in the United Kingdom, and worth US$2.2 billion.

The CHC deal went on to become one the biggest scandals of the administration of then President Ellen Johnson Sirleaf. It sparked cross-border investigations, with Monrovia requesting London to extradite a British businessman involved.

Liberian investigators found officials connived to grant CHC the carbon concession without any bidding. Evidence showed that Liberia would have lost millions of dollars, the Forestry Development Authority (FDA) board of directors and violated Liberian procurement law.

The CHC cross-border scandal had all the ingredients of a crime story: fraud, bribery, other violations of Liberia’s concession-related laws, and even plagiarism of an American study.

The four-year criminal activities ended with the arrest of the British businessman, a presidential pronouncement for the prosecution, reprimand and dismissal of the officials involved, and the impeachment of the senator.

From a carwash to the Office of the President

In 2007 about this time of the year, George Antwi, a Ghanaian, approached then River Cess senator Jonathan Banney about a carbon trading investment in the county. Antwi had been hired by Michael Foster, the owner of Carbon Harvesting Corporation (CHC), a firm based in Liverpool.

The deal appeared simple to Banney: CHC wanted to sequester carbon on 400,000 hectares of forestland in the southcentral county, obtain carbon credits and then sell them on carbon markets to companies wanting to offset their own carbon emissions. It would take eight years for the world to adopt carbon offsetting as a way to combat climate change at the Paris Climate Summit. However, experts, some in Liberia, were setting the pace for the global carbon trading market, a process still being done today.

Banney bought Antwi’s proposal right away.

“[Antwi] informed Mr. Foster about my eagerness of wanting investment to go to River Cess,” Banney would later tell investigators.

“Thereafter, I got an email. I informed the President about this investment proposal and that I wanted to extend [an] invitation to the investors. She agreed,” Banney would add.

In December of that year, Banney arranged a meeting between President Sirleaf and CHC represented by Foster, Antwi and other members of the company.

Things moved with lightning speed thereafter. By July 2008, there were meetings with the President and John Woods, the Managing Director of the Forestry Development Authority (FDA) at the time. A memorandum of understanding (MoU) with the chiefs and elders of Yarnee District, River Cess had been signed and Banney paid the FDA approximately US$15,000 for a biomass study.

Then in July 2008, CHC presented its proposal to the Liberian government to sell carbon credits on the unregulated and unverified carbon market at the rate of US$4 per tonne. It claimed that it had to trade below the international estimate of up to US$15 per tonne because Liberia’s rainforest was not recognized by the Kyoto Protocol, the UN operational mechanism for reducing carbon emissions.

That was followed by an analysis cost and benefits of its investment CHC claimed to have done, which found Liberia would benefit more from carbon credits than from commercial logging.

UK Police Arrests Foster

Then in February 2009, Woods informed the board of directors of the FDA and asked for the Public Procurement Concession and Commission (PPCC) for the CHC contract to be single-sourced, which was granted in December that year.

It was Woods’ efforts to get the green light from the Inter-ministerial Concession Committee (IMCC) that coincided with the demise of the CHC deal.

The Chairman of the National Investment Commission Dr. Richard Tolbert question the legality of the FDA negotiating the CHC instead of the IMCC. Tolbert suggested that the CHC proposals be sent to all members of the IMCC, including the Ministry of Justice and Finance. “I assume that the IMCC, constituted by the President for forest management contracts is the same body to act on this matter,” Tolbert said in a letter to Woods in early 2010.  

Michael Foster faced extradition from the United Kingdom to Liberia between 2010 and 2015 for alleged bribery, fraud and criminal conspiracy over a carbon credit deal. Picture credit: Liverpool Echo

Tolbert’s communications on the CHC deal continued until President Sirleaf requested him to constitute an IMCC negotiation of the CHC deal.

But it did not happen. In June that year, police in London arrested Foster for allegedly paying a bribe to seal the deal. The U.K.-based Global Witness, investigating the deal for two years, had told police Foster referenced an alleged US$2.5 million payment when they interviewed him.

It emerged that the company had calculated that Liberia would save 423 tonnes of carbon emissions in each hectare of the River Cess 400,000 hectares of forest. That meant 162 million carbon credits to Liberia, the Guardian of the U.K. reported.

But it emerged Liberia risked losing over US$2 billion if the CHC deal had gone on.  Thomas Downing, an expert with the Governance and Economic Management Assistance Programme (GEMAP), told the Guardian he had advised the FDA against it. 

Downing said the carbon credit figures were “unreasonably high” and had “no commercial value” for Liberia. GEMAP was created by Liberia and the international community to help combat corruption after the country’s civil wars.

“I had understood that the Carbon Harvesting proposal had been definitively rejected. Thus, I was surprised to hear that it still enjoyed some support,” Downing said.

“The proposal, if adopted, would be quite damaging to the FDA. Indeed, it could cost [Liberia] hundreds of millions of dollars,” he added.

Liberia investigates the CHC deal

Back in Liberia, hell broke loose. President Sirleaf set up an official inquest into the CHC scandal. The head of the CHC Investigation Committee was Cllr. Negbalee Warner, the future dean of the Louis Arthur Grimes School of Law at the University of Liberia. Future deputy police chief Rose Stryker and one William Massaquoi completed the team.

“The President’s communication to the committee suggested that certain procedural requirements relative to the granting of such [a] concession might not have been followed,” Warner told the Guardian at the time. “For example, the proposal was recommended to the inter-ministerial committee without any open competitive bidding process.” 

In roughly four months, Warner’s committee was back with its findings. It interviewed 19 people and institutions, including forest watchdog Global Witness and the United Nations Panel of Experts.

The committee recommended Banney be impeached as senator for abusing his legislative functions and bribery. CHC paid Banney over US$20,000 for arranging a meeting with President Sirleaf, getting River Cess communities’ consent for the project, running errands and pressuring the FDA and other entities to grant the concession.

Minister of Internal Affairs Ambulai Johnson was recommended to face prosecution for allegedly soliciting a US$2 million bribe from CHC. The committee heard the company asked him for help when it faced “obstacles” from other officials.

The committee recommended the dismissal of the Executive Director of the PPCC Peggy Meres. She allegedly influenced the procurement process through which CHC, a gaming company until now, single-sourced the concession.

The committee asked that Augustine Johnson, the agency’s geoinformation service manager, and Joseph Neufville, an adviser at the PPCC, be dismissed immediately. It found the duo allegedly solicited and accepted bribes and committed a procurement offense.

Woods, who was now replaced at the FDA over his poor health, was asked to be reprimanded over his alleged role in the scandal. “The MD has been paid and is on our side as he is dependent on us in the future,” the investigation found CHC officials bragged among themselves.

The committee also found that Woods had allegedly ignored the pieces of advice from Downing and Silas Siakor, the executive director of the Sustainable Development Institute (SDI), and others.

The Carbon Harvesting Corporation deal plagiarized a study from the United States Forest Service estimating that it would capture 423 carbon credits in one hectare of tropical rainforest in Liberia. It was exposed following an investigation by a special presidential committee headed by Cllr. Negbalee Warner. The DayLight/James Harding Giahyue

Downing’s case was more startling. The committee found that he had informed Woods that CHC’s so-called cost and benefit analysis was plagiarized from the United States Forest Service’s study on a California rainforest. Downing shared copies of the plagiarized study with Woods severally and both men even viewed the two documents.

Minister of Planning and Economic Affairs Amara Konneh was reprimanded for issuing CHC a concession certificate in breach of the procurement law. Konneh denied any wrongdoing, saying the report was politically motivated.

The committee recommended Foster and Antwi face the law in Liberia for alleged fraud, bribery and criminal conspiracy. Both men denied the allegations.

President Sirleaf agreed with the committee’s recommendation and took the actions it had suggested. She called on the Ministry of Foreign Affairs to request the extradition of Foster and announced additional restrictions on presidential visits.

But President Sirleaf later rescinded her decision against the Liberian officials. About a month later, she dismissed her entire cabinet, except for one minister.

Foster extradition case lingered until 2015 when police dropped all charges against him. U.K. police said they could not obtain evidence in key areas of their investigation.

The story was a production of the Community of Forest and Environmental Journalists of Liberia (CoFEJ).

International NGOs Call for Halt to Blue Carbon Deal


Top: Liberia’s proposed deal with Blue Carbon of the United Arab Emirates is expected to cover over a million hectares of rainforests. Graphic by Rebazar Forte

By James Harding Giahyue

  • Liberia and Blue Carbon should halt carbon credit negotiation, as the deal violates Liberian laws, according to a group of international NGOs  
  • The deal must comply with procurement, forestry and land laws, and seek the consent of local communities to continue
  • The NGOs say the United Arab Emirates wants to use the agreement to “greenwash,” its own carbon emissions
  • NGOs say the “vague” and “secret” deal is not good for the Liberian government and indigenous communities and undermines Liberia’s own climate targets

MONROVIA – A group of 16 international NGOs has called for a halt to an ongoing carbon credit deal between Liberia and Blue Carbon of the United Arab Emirates until it complies with Liberian laws and is clear on how the country and local communities would benefit.  

The Liberian government and Blue Carbon negotiating the terms of the agreement. The government wants to give the company over 1 million hectares of land over 30 years for US$50 billion, according to a draft memorandum of understanding (MoU).

But the deal would be a violation of Liberia’s procurement forestry and land laws, the statement said. 

“We, therefore, call upon the Government of Liberia and Blue Carbon to halt these negotiations until there is clear evidence that the contract is in line with Liberian law,” the NGO said in a statement released last week. 

“This risks the livelihoods of up to a million people. It would also extinguish community land ownership in the selected areas while violating peoples’ legal right to provide free, prior and informed consent for any developments on their land,” it added.

In March, Liberia and Blue Carbon penned the agreement, in which Liberia is expected to lease Blue Carbon a number of protected areas and proposed protected areas to solely manage. Blue Carbon’s mission is to use bilateral agreements to help reduce carbon emissions globally, according to its website.

“This bilateral association marks another milestone for Blue Carbon to enable government entities to define their sustainable frameworks and help transition to a low-carbon economical system…,” Sheikh Ahmed Dalmook Al Maktoum, Blue Carbon’s chairman and senior member of UAE’s Royal Ruling Family.  

Minister of Finance and Development Planning Samuel Tweah, Jr. said the deal marked an “era of sustainability.”  

But local communities that would be affected by the deal have not had a say in it, a violation of the National Forestry Reform Law, the Land Rights Act and the United Nations Declaration on the Rights of Indigenous Peoples, an instrument Liberia has signed into law.  All three legal instruments require villagers’ free, prior and informed consent in concessions negotiations.

Furthermore, more than 1 million hectares of rainforests render the MoU illegal. Liberia’s forestry law limits forest concessions to 400,000 hectares.

The NGOs call on the parties to consult communities and incorporate their benefits into the deal. They include Fern, Friends of Earth Netherlands and the Environmental Investigation Agency.

“It should also prove that the financial support provided protects threatened forests and restores degraded forests with strict monitoring and control mechanisms in place,” the statement said.

The proposed deal would also break the Public Procurement and Concession Act because there was no bidding.

A forest in Sinoe County is one of the places that would be affected by the proposed Blue Carbon deal. The DayLight/James Harding Giahyue

The Liberian cabinet endorsed Blue Carbon as a sole source on June 3, based on a letter from the Managing Director of the Forestry Development Authority (FDA) Mike Doryen to the Public Procurement and Concession Commission (PPCC).

In the letter, Doryen asked PPCC’s Officer-in-Charge Stevenson Yond to approve Blue Carbon as a sole bidder for the concession.

Section 55 of the procurement law allows for “sole sourcing,” except in an “extreme urgency,” and other instances, none of which the deal qualifies for.  

Section 101 of the act also provides for a sole source but limits it to a bidder with specialized expertise only that bidder can provide. It also requires the concession to involve research only the bidder can undertake or it would be against national security for a competitive bidding process. However, none of those instances fits Blue Carbon, established only about a year ago and had not traded in the carbon market before.

Doryen did not immediately respond to The DayLight’s queries for comments.


The international NGOs accused the UAE, a country that has one of the highest emission rates in the world, of using the Blue Carbon deal to offset its own greenhouse gas emissions. In other words, the Arab nation, which hosts the United Nations climate change conference later this year, allegedly wants to invest in Liberia’s rainforest and continue its energy, oil/gas and infrastructure projects.

“The revenue model described in this contract generously allows for that,” the statement said. “This contract seems to give Blue Carbon, a private UAE company, the authority to act on Liberia’s behalf to negotiate [United Nations Framework Convention on Climate Change] Article 6 rules.” Article 6 of the Paris Climate Agreement talks about carbon credits and trading.

The NGOs critique the draft document’s intent to award Blue Carbon the exclusive right to use carbon credits. Blue Carbon would exclusively manage the forest resources, including reforestation, conservation and ecotourism, according to the MoU.

“If they are sold, Liberia will not be able to use the carbon credits to meet its own climate targets,” the statement said. Liberia committed at the Paris Summit to reduce deforestation by 50 percent by 2030.  

“It is unclear what the benefits for Liberia and its communities will be. The contract is confidential and extremely vague, and a [MoU]… signed in March this year has not been widely discussed,” it added.

The statement followed criticisms from national NGOs and the Liberian People’s Party.  

The DayLight has reached out to Blue Carbon for comments.