Greater Lebanon Refuse Authority Landfill Gas Collection and Combustion Project

Audit Analysis

A long-running (since 2008) VCS landfill gas collection project with VVB-confirmed additionality and an avoidance-type design that carries minimal permanence risk. However, the project is burdened by an extensive record of material findings—primarily recurring methane analyzer calibration lapses and data substitutions—along with contradictory safeguards documentation and an unresolved question about whether gas capture is legally mandated, which together weaken confidence in the robustness of the credit claims.

Project Description

Red Flags

• ⚠Over 40 material findings across multiple verification cycles, dominated by repeated failures to perform weekly calibrations of the Siemens Ultramat 23 methane analyzer and substitution of missing data with 95% lower confidence limits
• ⚠Calibration frequency for the methane analyzer was reduced from 2-year to 5-year intervals, a significant deviation from standard QA/QC practice
• ⚠Contradiction on whether LFG capture is legally required: the 2018 verification report states it is, while the 2026 monitoring report states it is not—this directly bears on additionality
• ⚠FPIC was not conducted and the grievance mechanism status is contradictory between the 2020 verification report (absent) and the 2026 monitoring report (present)
• ⚠24 corrective actions remain open, including requests for calibration records, ownership clarifications, and monitoring plan updates
• ⚠Gas capture legally mandated — additionality in doubt

Credit Vintages