Clinton Landfill Gas Collection and Combustion Project

Audit Analysis

The Clinton Landfill Gas project is a mature waste-sector project (operating since 2009) with confirmed additionality and no inherent permanence risk, but it carries a heavy burden of monitoring and calculation deficiencies documented across multiple verification cycles. The 2025 verification report lists 19 material findings and over 30 corrective actions, revealing persistent MRV quality issues including confidence-interval errors, analyzer drift, and calibration gaps. Safeguards documentation is essentially absent, and the leakage treatment has regressed from a quantified justification in 2022 to 'not addressed' in the latest report.

Project Description

Red Flags

• ⚠19 material findings in the 2025 verification report, including use of 90% instead of the required 95% confidence interval, analyzer drift outside 5% threshold, and inconsistent application of flare destruction efficiencies relative to the validated PD
• ⚠Over 30 corrective actions required, spanning calibration failures, data substitution methodology gaps, flow meter errors, and electricity tracking via bills rather than direct meters
• ⚠Leakage justification regressed from 'quantified' (2022 verification report) to 'not addressed' (2025 verification report) while the deduction remains at 0%
• ⚠No FPIC conducted, no grievance mechanism in place, and safeguards not mentioned in the most recent verification report
• ⚠Contradiction on grievance mechanism: the 2025-07-29 verification report states one exists, while the 2025-07-31 report states it does not

Credit Vintages