Forestal Apepu Carbon Project
#157of 261 in Soil carbon#6of 8 in Paraguay#1037of 1339 in Verra (VCS)#63of 97 in AR-ACM0003
Audit Analysis
The Forestal Apepu project is a VCS eucalyptus plantation in Paraguay with VVB-confirmed additionality and a 17% buffer pool, but it is undermined by a weak 0% leakage deduction (contradicted by the PDD's 'quantified' treatment), a project-specific baseline with no stated reassessment date, a reported drought-related reversal of 26 ha, and an extensive list of material findings and corrective actions that reveal significant calculation and reporting inconsistencies across documents. The project delivered roughly 74% of its pro-rata ex-ante expectation for the first monitoring period, indicating moderate under-delivery.
Red Flags
- Leakage deduction of 0% justified as 'deemed negligible' in the 2024 verification report, while the PDD (2024-09-30) describes the treatment as 'quantified' — an unresolved contradiction that weakens confidence in the leakage assessment
- 26 ha of plantation lost to drought in 2023/2024 (91 tCO2e subtracted), confirming real reversal risk in a soil-carbon plantation project
- Extensive material findings (20+ items) including inconsistent baseline and project emission calculations, incomplete leakage assessment from displacement of agricultural activities, and incorrect LTA calculations — all addressed via CARs but indicating systemic MRV quality issues
- Non-native eucalyptus species used without sufficient justification over native species, flagged in both material findings and corrective actions
- Additionality test type changed from 'combined' (2023 VR) to 'investment' (2024 VR) without clear explanation of the methodological shift
Credit Vintages Exhausted
| Issued | Retired | Available | ||
|---|---|---|---|---|
| 2019 | 1,457 | 1,457 | 0 | |
| 2020 | 4,666 | 4,666 | 0 | |
| 2021 | 28,349 | 28,349 | 0 | |
| 2022 | 38,621 | 38,621 | 0 | |
| Total | 73,093 | 73,093 | 0 |
Risk Indicators
VVB-confirmed investment test
17% buffer; 26 ha drought reversal reported
0% deduction; 'negligible' vs 'quantified' contradiction
Project-specific; no reassessment date stated
FPIC, grievance mechanism, safeguards documented
CORSIA and CCP status not stated
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