CEMEL HYDRO BUNDLE

Audit Analysis

The Cemel Hydro Bundle is a small hydro avoidance project in Turkey verified by RINA, with a confirmed investment-test additionality and reasonable leakage treatment. However, a project-specific baseline built on a 2010 grid emission factor, a significant discrepancy between the PDD ex-ante estimate (36,451 tCO₂) and the monitoring-report claim (54,101 tCO₂) despite actual generation running 26 % below the ex-ante figure, and a low extraction-confidence rating across 31 documents collectively limit confidence in the credit quantity and baseline robustness.

Project Description

Red Flags

• ⚠The monitoring report claims 54,101 tCO₂ while the PDD ex-ante estimate is 36,451 tCO₂, yet the verification report notes actual generation (109,763 MWh) is 26 % below the ex-ante estimate (148,103 MWh) — the higher credit claim is not supported by the generation data.
• ⚠The grid emission factor used in the baseline is from 2010 (0.4929 tCO₂/MWh); Turkey's grid mix has likely changed substantially over 15 years, potentially inflating the avoided-emissions baseline.
• ⚠Nine contradictions were identified across documents, including conflicting FPIC status (conducted per the 2021 verification report vs. not conducted per the 2024 PDD) and conflicting baseline methodology (project-specific per the verification report vs. jurisdictional per the monitoring report).
• ⚠The verification report was conducted remotely (no onsite visit), and the VVB itself flagged the need for an onsite verification in the next cycle.
• ⚠Min extraction confidence is rated low, indicating at least one key document was poorly readable, reducing reliability of the extracted data.

Credit Vintages