Chongqing Tongliang LFG Power Generation Project
#51of 204 in China#160of 629 in Verra (VCS)#10of 53 in ACM0001
Audit Analysis
A VCS landfill-gas power-generation project in China with a VVB-confirmed combined additionality test and no material findings, but weakened by a 0% leakage deduction that the verification report describes as 'not addressed,' a project-specific baseline with no recorded reassessment, and a verified emission-reduction figure that is roughly four times the pro-rata expectation derived from the PDD's lifetime estimate. Multiple contradictions between the 2023 and 2025 verification reports on safeguards, FPIC, and grievance mechanisms suggest the project's social-compliance documentation was substantially strengthened only recently.
Red Flags
- Leakage deduction is 0% and the 2025 verification report records the justification as 'not addressed,' while the monitoring report calls it 'deemed negligible' — the higher-authority verification report does not support the zero deduction.
- The verified emission reduction of 105,752 tCO₂e for the two-year monitoring period (Aug 2022 – Jul 2024) is approximately 4.2× the pro-rata expectation of ~24,989 tCO₂e derived from the PDD's 10-year lifetime estimate of 124,945 tCO₂e, raising over-crediting questions even accounting for front-loaded LFG generation.
- Eight contradictions were identified across documents, including FPIC, grievance mechanism, benefit-sharing, and safeguards all flipping from 'not present' in the 2023 verification report to 'present' in the 2025 report, indicating the project's social-compliance record was retroactively strengthened.
- Buffer-pool percentage, reversal-event history, FNRB method, and usage-monitoring method are all absent from the extracted record, leaving key MRV and permanence parameters unverified.
Credit Vintages
| Issued | Retired | Available | ||
|---|---|---|---|---|
| 2021 | 82,273 | 0 | 82,273 | |
| 2022 | 42,672 | 0 | 42,672 | |
| Total | 124,945 | 0 | 124,945 |
Risk Indicators
Combined test, VVB-verified, capture not legally required
LFG power generation – no carbon storage, inherent permanenc
0% deduction, justification 'not addressed' per verification
Project-specific, measured per monitoring report, reassessme
FPIC, grievance, benefit-sharing confirmed in 2025 but absen
CORSIA explicitly not eligible; CCP status not stated
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