Combio Renewable Biomass Project - Três Marias

Audit Analysis

The Combio biomass energy project in Brazil has a VVB-confirmed investment additionality test and is over-delivering relative to its pro-rata expectation, but suffers from significant baseline calculation errors flagged by the VVB, absence of a buffer pool, and shifting ERR figures across reporting periods that undermine data reliability. The project is registered and CORSIA-ineligible, but the 12 corrective actions and unresolved FPIC gap leave meaningful integrity and safeguards concerns.

Project Description

Red Flags

• ⚠Baseline emissions calculations were not performed in accordance with methodology paragraph 25, and an incorrect efficiency factor was used in baseline calculations (2025 verification report corrective actions)
• ⚠No buffer pool percentage or reversal event data found in any available document, leaving permanence risk unaddressed
• ⚠FPIC was not conducted per the 2025 verification report, contradicting the 2019 monitoring report which stated it was done
• ⚠Total ERR figures shifted substantially between reporting periods (claimed dropped from 184,142 to 111,964; verified rose from 63,740 to 111,964), raising data reliability concerns
• ⚠Biomass accounting deviated from the method described in the PDD (purchase invoices vs. other method), requiring a methodology deviation correction

Credit Vintages