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VCS avoidance China Registry: Registered Documentazione completa General Methodology v2.0

65MW Dagushan Hydropower Project In China

VCS-653 ↗

5.8 / 10
Integrity
5.2
Transparency
6.0
Claim Safety
5.4
Documentation
7.2

Score Breakdown

Integrity

verified Additionality is confirmed by the VVB using an investment test (validation/verification documentation in the extracted record).

missing Baseline and key quantification inputs show inconsistencies across monitoring/validation documents (e.g., grid emission factor and ERR figures), weakening confidence in the baseline and ER calculation.

Transparency

verified VVB is identified (TUV SUD South Asia Pvt Ltd) and the monitoring period is clearly stated (2021-01-01 to 2021-12-31) in the monitoring report (2022).

missing A corrective action in the monitoring report (2022) flags inconsistencies between the monitoring report and the ER spreadsheet, reducing MRV clarity.

Claim Safety

verified The project is stated as not CORSIA-eligible, reducing some downstream claim and double-claiming risk.

missing Over-crediting risk is elevated by conflicting ERR totals and a materially different grid emission factor across monitoring reports.

Documentation

verified Multiple core document types are present in the extracted record (PDD, monitoring report, validation report, issuance) with high extraction confidence and 26 documents used.

missing Several cross-document contradictions (safeguards, grievance mechanism, benefit sharing, FPIC, crediting period) indicate documentation inconsistency despite breadth.

Detailed Analysis

Integrity

Additionality appears reasonably supported because the validation documentation indicates an investment test and confirms additionality by the VVB. However, baseline robustness is weakened by conflicting grid emission factors between monitoring reports (2022 monitoring report: 0.5536 vs 2021 monitoring report: 0.8712), which can materially change calculated reductions under ACM0002. Leakage is not treated consistently: the 2022 monitoring report does not address leakage, while an older validation report (2011) deems it negligible; this inconsistency reduces confidence in completeness of the integrity assessment.

Transparency

The monitoring period is clearly specified (2021-01-01—2021-12-31) in the monitoring report dated 2022-08-15, and the VVB is named (TUV SUD South Asia Pvt Ltd). Reported claimed and verified ERs match within the selected record (both 122,100), but contradictions across validation reports (122,100 vs 137,144) reduce transparency on what was ultimately asserted and checked. The monitoring report (2022) includes a corrective action noting inconsistencies between the monitoring report text and the ER calculation spreadsheet, which undermines MRV clarity.

Claim Safety

CORSIA eligibility is explicitly stated as false, which lowers the risk of certain high-profile compliance claims. Nonetheless, over-crediting/greenwashing risk is elevated because key quantification inputs and outcomes vary across documents: the grid emission factor differs substantially across monitoring reports (0.5536 vs 0.8712), and total ERs differ across validation reports (122,100 vs 137,144). With leakage not addressed in the most recent monitoring record, buyers have less assurance that all relevant sources of overstatement were considered.

Documentation

The extracted record indicates a relatively complete documentation set (PDD, monitoring report, validation report, issuance) and a high extraction confidence with 26 documents used. However, the presence of multiple contradictions across monitoring/validation documents (safeguards, FPIC, grievance mechanism, benefit sharing, crediting period, grid emission factor, and ERR totals) suggests version control or reporting quality issues. The monitoring report (2022) also lists a corrective action related to inconsistent ER reporting between the narrative and spreadsheet, further indicating documentation quality concerns despite breadth.

Overall

I privileged the more recent documents where possible: for ER totals and key parameters, I used the 2022-era figures (122,100 ER and grid emission factor 0.5536 from the 2022 monitoring report) over older conflicting values, because they are later in time and more likely to reflect the current crediting/monitoring context. However, the contradictions are substantial and span core eligibility and quantification elements: ER totals conflict between validation reports (2021 vs 2022), leakage treatment shifts from 'deemed negligible' (2011 validation) to 'not addressed' (2022 monitoring), safeguards/FPIC/grievance/benefit sharing flip between older and newer monitoring reports, and even the crediting period conflicts (2009–2019 vs 2019–2029). These inconsistencies reduce confidence in both integrity and claim safety and are the main reason the overall score is mid-range rather than high.

Audit Analysis

This VCS hydropower project has VVB-confirmed additionality and a complete-looking document set, but several internal inconsistencies across reports raise reliability and over-crediting concerns. Leakage treatment is unclear in the more recent monitoring record, and key parameters (grid emission factor and even the crediting period) conflict across documents.

Project Description

Located in Su’nan Yugu Autonomous County, China, the Dagushan Hydropower Plant is a renewable energy project that produces positive environmental and economic benefits. With a total installed capacity of 65MW, the project will displace part of the electricity generated by the Northwest Power Grid, resulting in an estimated annual GHG emission reduction of 170,015 tCO2e.

Red Flags

  • Conflicting verified/claimed emission reductions across validation reports (122,100 vs 137,144), indicating data reliability issues.
  • Grid emission factor differs materially between monitoring reports (0.5536 vs 0.8712), which can significantly change credited reductions.
  • Crediting period is inconsistent across monitoring reports (2019–2029 vs 2009–2019), creating uncertainty about eligibility and period boundaries.
  • Corrective action notes inconsistencies between the monitoring report narrative and the ER calculation spreadsheet.

Credit Vintages

Issued Retired Available
2009
139,394 38,394 101,000
2010
32,621 19,171 13,450
2012
411,092 411,092 0
2013
229,867 229,867 0
2014
223,595 223,595 0
2015
32,375 32,375 0
2016
275,951 274,049 1,902
2017
225,469 0 225,469
2018
211,061 0 211,061
2019
34,244 85 34,159
2020
102,900 0 102,900
2021
15,530 13,981 1,549
Total 1,934,099 1,242,609 691,490

Cosa migliorerebbe questo punteggio

  • Publish a clear version-controlled reconciliation note explaining the correct crediting period, grid emission factor selection, and why earlier documents show different values.
  • Resolve the corrective action by aligning the monitoring report narrative with the ER calculation spreadsheet and providing an auditable ER breakdown for the full crediting period and all schemes.
  • Provide an explicit leakage assessment consistent with ACM0002 requirements (even if negligible) in the latest monitoring/verification package, with justification and any deduction stated.

Questi suggerimenti indicano quali prove pubbliche aggiuntive potrebbero migliorare il livello di confidenza di questa valutazione. Non garantiscono un punteggio futuro più alto.

Risk Indicators

Additionality

VVB-confirmed investment test

Permanence

Avoidance project; no reversals reported

Leakage

Leakage treatment inconsistent/unclear

Baseline

Project-specific baseline; reassessment timing unclear

Safeguards

Safeguards/FPIC reported but inconsistent over time

Double-claim

Not CORSIA-eligible; CCP status not stated

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Analysis Provenance Scored 2026-04-02 General Methodology v2.0 Documentazione completa

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