Fuel switch project on the Gluten 20 dryer of Tongaat Hulett Starch Pty (Ltd) Germiston Mill

Audit Analysis

A CDM fossil-fuel-switch project at a South African starch mill with a VVB-confirmed barrier additionality test and a strong 6.3× over-delivery versus the ex-ante estimate. The project is an avoidance type with minimal permanence risk, but the project-specific baseline, inconsistent leakage justification across documents, and removal of the investment barrier during validation introduce moderate integrity concerns. Documentation is reasonably complete with 26 sources and high extraction confidence.

Project Description

Red Flags

• ⚠Leakage justification is inconsistent: the validation report (2010) deems leakage negligible, while the monitoring report (2022) records it as not addressed, leaving the 0% deduction without a clear, consistent rationale.
• ⚠The investment barrier was removed during validation (Corrective Action Request No. 11), leaving additionality resting solely on other barriers, which weakens the robustness of the additionality case.
• ⚠Baseline is project-specific rather than jurisdictional or standardised, and no baseline reassessment date is recorded in the available documents.
• ⚠Several key monitoring parameters (FN-RB method, usage monitoring method, end-use tracking) are not stated in the extracted record, limiting independent verification of the MRV chain.

Credit Vintages

No issuances recorded on the registry.