CCIL - Waste Gas based Electricity Generation Project
Audit Analysis
A CDM waste-gas-to-electricity project in India with a confirmed investment-test additionality and a reputable VVB (Bureau Veritas), but undermined by 18 corrective actions at validation, a baseline-method contradiction between the PDD and monitoring report, and a 0% leakage deduction whose 'quantified' justification lacks detail. The project delivered roughly 640% of the pro-rata lifetime expectation for its first monitoring period, suggesting a very conservative initial estimate rather than over-crediting, yet the absence of a buffer pool, verified ERR figure, and safeguards documentation leaves material gaps.
Red Flags
- 18 corrective actions were required at validation, including clarifying turbine capacity, correcting baseline data period, and adding missing monitoring parameters — indicating a weak initial PDD
- Baseline method is stated as 'project-specific' in the monitoring report but 'jurisdictional' in the PDD, creating ambiguity about which baseline was actually applied
- Leakage deduction is 0% with only a one-word 'quantified' justification; the material findings note steam-export leakage provisions were added, yet no quantified figure is provided
- No buffer pool percentage is stated in any available document, leaving permanence risk unaddressed for a 10-year crediting period
- No verified ERR figure is available — only the claimed 34,280 tCO2 for the first monitoring period, with no independent verification report to confirm actual generation
Credit Vintages
| Issued | Retired | Available | ||
|---|---|---|---|---|
| 2013 | 34,325 | 0 | 34,325 | |
| Total | 34,325 | 0 | 34,325 |
Risk Indicators
VVB-confirmed investment test, IRR below WACC
No buffer pool stated; EE project has lower reversal risk
0% deduction, 'quantified' justification lacks detail
Method contradictory across docs; grid EF from 2007
Safeguards mentioned but no FPIC or grievance mechanism
CDM project; CORSIA and CCP status not stated
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