Camlica-3 HPP, Run-of-River Hydro Project, Turkey
#171of 770 in Renewable energy#36of 121 in Turkey#199of 629 in Verra (VCS)#128of 383 in ACM0002
Audit Analysis
The Camlica-3 run-of-river hydro project has a VVB-confirmed investment additionality test and no material findings, but is significantly undermined by 22 corrective actions, contradictory leakage justifications across verification reports, and conflicting ERR figures (68,781 vs 147,287 tCO₂) that raise data-reliability concerns. The project is not CORSIA-eligible and uses a reasonable 2020 Turkish grid emission factor, but the absence of a stated buffer pool and the project-specific baseline (contradicted by a 'jurisdictional' label in the monitoring report) leave moderate integrity and claim-safety risk.
Red Flags
- 22 corrective actions (CAR-1 through CAR-22) were required in the 2023 verification report, indicating a substantial number of unresolved or recurring issues
- Leakage justification is contradictory: the 2023 verification report states leakage was 'not addressed' while the 2022 verification report described it as 'quantified', with a 0% deduction in both cases
- Total ERR figures conflict between documents: 68,781 tCO₂ (2023 verification report) vs 147,287 tCO₂ (earlier monitoring/verification reports), a 2.1× discrepancy that undermines confidence in the credit quantity
- Baseline method is labelled 'project' in the 2023 verification report but 'jurisdictional' in the 2022 monitoring report, creating ambiguity about the baseline construction
- Buffer pool percentage is not stated in any available document, leaving the permanence risk mitigation mechanism unverified
Credit Vintages
| Issued | Retired | Available | ||
|---|---|---|---|---|
| 2011 | 32,175 | 32,175 | 0 | |
| 2012 | 39,410 | 0 | 39,410 | |
| 2013 | 34,703 | 5,994 | 28,709 | |
| 2014 | 14,652 | 7,656 | 6,996 | |
| 2015 | 44,236 | 0 | 44,236 | |
| 2016 | 28,370 | 3,239 | 25,131 | |
| 2017 | 14,058 | 0 | 14,058 | |
| 2018 | 13,661 | 0 | 13,661 | |
| 2019 | 35,668 | 19,000 | 16,668 | |
| 2020 | 35,383 | 35,383 | 0 | |
| 2021 | 14,418 | 11,718 | 2,700 | |
| 2022 | 9,626 | 1,254 | 8,372 | |
| Total | 316,360 | 116,419 | 199,941 |
Risk Indicators
VVB-confirmed investment test
No buffer pool stated; no reversal events but no explicit pe
0% deduction with contradictory justification across reports
Project-specific baseline; method label contradicts monitori
FPIC, grievance mechanism, and benefit sharing confirmed in
CORSIA not eligible; no CCP status indicated
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