25.3MW WHR Project of Zhejiang Leomax Group

Audit Analysis

A 25.3 MW waste-heat-recovery CDM project in China with VVB-confirmed additionality and a combined test, but undermined by a ten-fold discrepancy in claimed emission reductions between the PDD and the validation report, material findings on equipment parameter inconsistencies, three outstanding corrective actions, and a project-specific baseline. CORSIA eligibility without a stated CCP status raises double-claiming concerns, and the absence of a buffer pool or quantified reversal analysis leaves permanence protection thin for an energy-efficiency project.

Project Description

Red Flags

• ⚠Ten-fold discrepancy in total emission reductions: the PDD reports 1,622,030 tCO₂e while the validation report reports 162,203 tCO₂e — a factor-of-10 gap that cannot be reconciled from the available documents
• ⚠Three corrective actions remain open, including the requirement to justify why project emissions are deemed zero and to update the grid emission factor for coke and refinery gas to IPCC 2006 defaults
• ⚠Material findings confirm that turbine and generator nameplate parameters at both the Tonglu and Guangde sites differ from those registered in PDD Version 03
• ⚠CORSIA eligibility is confirmed while CCP status is not stated, creating an unresolved double-claiming pathway
• ⚠Reversal risk is explicitly not addressed in the monitoring report, and no buffer pool percentage is recorded

Credit Vintages