Baotou Iron & Steel Coke Dry Quenching #3 and Waste Heat Utilization for Electricity Generation Project

Audit Analysis

A CDM industrial electricity-generation project (coke dry quenching waste heat recovery) validated and verified by TÜV SÜD with a confirmed combined additionality test, but undermined by a project-specific baseline, a thin 0% leakage justification, an outdated 2005 grid emission factor, and a very large list of 28 corrective actions that had to be resolved before issuance. The project delivered roughly 69% of its pro-rata ex-ante expectation over the monitored period, indicating moderate under-delivery.

Project Description

Red Flags

• ⚠28 corrective actions were required before issuance, including fundamental issues with the IRR benchmark, baseline scenario identification (captive power plant alternative), and boiler efficiency justification — suggesting the initial PDD was substantially deficient
• ⚠Grid emission factor of 1.03 tCO2/MWh is based on 2005 data, which is over a decade old at the time of the 2016 monitoring report and may overstate the baseline
• ⚠Leakage deduction of 0% is justified only as 'deemed negligible' with no quantified analysis, which is thin for an electricity-generation project where displaced grid electricity could represent a leakage pathway
• ⚠The project delivered only ~69% of the pro-rata ex-ante expectation for the elapsed monitoring period (65,518 tCO2 verified vs ~95,400 tCO2 expected), indicating the ex-ante estimate was optimistic

Credit Vintages