Bethlehem Authority Improved Forest Management Project

Audit Analysis

The Bethlehem Authority IFM project is a long-running VCS ALM project (100-year crediting period) with VVB-confirmed additionality and a 10% buffer pool, but it carries a project-specific baseline with a documented calculation error in the original project design, 11 corrective actions, and no FPIC or grievance mechanism. Multiple contradictions across verification and monitoring reports—particularly a 14% discrepancy in verified emissions and conflicting leakage figures—undermine confidence in the data. The project is not CORSIA-eligible, which limits double-claiming risk, but the absence of a lifetime ex-ante estimate prevents a meaningful pro-rata delivery check.

Project Description

Red Flags

• ⚠Baseline emissions for 2013 were corrected from −15,897 to −10,821 tCO₂e due to a calculation error in the original project design, indicating the baseline was not robust at inception.
• ⚠Eleven corrective actions (CAR 1–11) were required in the 2023 verification report, suggesting persistent data-quality or compliance issues.
• ⚠Verified emissions of 35,959 tCO₂e in the 2023 verification report differ by ~14% from the 31,464 tCO₂e reported in the 2022 monitoring report for the same period.
• ⚠Leakage deduction figures are contradictory: 8,224 (tCO₂e, 2021 verification) versus 0.2 (2022 monitoring report), with unclear units and no reconciliation.
• ⚠No Free, Prior, and Informed Consent (FPIC) was conducted and no grievance mechanism is in place, despite the project operating on public forest land in the United States.

Credit Vintages