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ICRAvoidance / ReductionBRACM0002

AES/Embrasca SANTOS Wind Power Project

ICR-131 ↗

#341of 1935 in Renewable energy#5of 154 in Intl. Carbon Registry (ICR)#252of 1287 in ACM0002

6.0/ 10
Integrity
6.5
Transparency
5.5
Claim Safety
5.0
Documentation
7.0

Audit Analysis

The Santos Wind Power Complex is a VVB-verified ICR project with a jurisdictional baseline and confirmed additionality, but it delivered only about 53% of its pro-rata ex-ante expectation for the monitoring period, and the leakage justification is inconsistent between the monitoring and verification reports. All five material findings from the verification were corrected, and the documentation set is reasonably complete with high extraction confidence.

Red Flags

  • Verified ERR of 123,504 tCO₂e is only ~53% of the pro-rata ex-ante expectation (~231,500 tCO₂e) for the 22-month monitoring period, indicating significant under-delivery relative to the lifetime estimate
  • Leakage justification is contradictory: the verification report (Aug 2022) states leakage was 'quantified' while the monitoring report (Jun 2022) records it as 'not addressed', creating ambiguity about whether a 0% deduction is properly justified
  • Five material findings were raised during verification (including a missing environmental assessment for transmission lines and incorrect IRR values in the investment analysis), all corrected but indicating initial documentation gaps

Credit Vintages

IssuedRetiredAvailable
2014
11,673011,673
2015
65,997065,997
2016
69,141069,141
2017
60,299060,299
2018
59,850059,850
2019
56,511056,511
2020
49,801049,801
2021
64,065064,065
2022
42,540042,540
2023
41,692041,692
2024
43,608043,608
Total565,1770565,177

Risk Indicators

Additionality

VVB-confirmed combined test

Permanence

Wind project, no reversals reported

Leakage

0% deduction, justification inconsistent across docs

Baseline

Jurisdictional, reassessment date not stated

Safeguards

FPIC conducted, grievance mechanism present

Double-claim

CORSIA and CCP status not stated

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Analysis ProvenanceScored2026-09-02ACM0002

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