Grouped Hydropower Plants in Chongqing, Yunnan,Sichuan and Guizhou Provinces, P.R. China

Audit Analysis

A large grouped small-scale hydropower project (88–98 plants) with VVB-confirmed additionality and a jurisdictional baseline, but undermined by a significant grid emission factor discrepancy between verification reports, a resolved but serious double-counting risk with the Chongqing ETS, numerous calculation errors and corrective actions, and a low extraction confidence rating that limits confidence in the extracted data. The project is inherently low-risk on permanence (hydropower, no reversal risk) and leakage (electricity to grid), but the volume of material findings and contradictions across documents raises meaningful concerns about data reliability and over-crediting risk.

Project Description

Red Flags

• ⚠Grid emission factor contradiction: the 2022 verification report cites 0.5003 tCO2/MWh while the 2017 verification report cites 0.9735 tCO2/MWh, and the baseline methodology section shows weighted averages of 0.8959 (CSPG) and 0.9515 (CCPG) — a factor-of-two discrepancy that directly affects credit quantities
• ⚠Double-counting risk with the Chongqing ETS compliance period (2013–2015) was identified in the verification report; 7 hydro plants in Chongqing had to be excluded and 36,001 tCO2e removed from the 2013–2015 period
• ⚠Project performance achieved only circa 66% of expected results (1,016,115 vs 1,539,874 credits) per the verification report, yet the verified ERR for the 2020–2021 monitoring period (363,333 tCO2e) is roughly 8.5× the pro-rata expectation derived from the 3,696,995 tCO2e lifetime ex-ante estimate — an inconsistency that cannot be reconciled without further data
• ⚠FPIC was not conducted and no grievance mechanism is documented, despite stakeholder consultation being carried out through the EIA process
• ⚠Min extraction confidence is rated low, meaning at least one key document was poorly readable, reducing reliability of all extracted figures

Credit Vintages