Fuel switch from fossil fuel to biomass residues for cogeneration in integrated pulp and paper unit of ITC PSPD at Bhadrachalam

Audit Analysis

A CDM fuel-switch project (coal to biomass residues) at an Indian pulp and paper mill with VVB-confirmed additionality, but significant concerns around a project-specific baseline, unquantified leakage, a 10× discrepancy between the PDD and validation report on emission figures, and the absence of any monitoring-period data. The low extraction confidence and reliance solely on validation-stage documents limit the depth of assessment.

Project Description

Red Flags

• ⚠PDD states 746,500 tCO2e while the validation report (more recent, 2011-06-06) states 74,650 tCO2e — a 10× discrepancy that, while resolved in favour of the lower figure, indicates a significant error in the original project documentation.
• ⚠Leakage deduction of 0% is justified as 'deemed negligible' in the validation report, yet an appendix appears to reference a quantified leakage estimate — an unresolved inconsistency in the treatment of displaced biomass.
• ⚠Five corrective actions were required by the DOE, including substantiation of the CDM-as-decisive-factor claim, levelized cost calculation, biomass price justification, steam demand validation, and transparent ex-ante emission calculation.
• ⚠No monitoring reports, no FNRB method, no usage monitoring method, and no feedstock sustainability data are present in the extracted record, leaving the operational phase entirely unverified.

Credit Vintages

No issuances recorded on the registry.