GS11677 GS11902 Malawi Biomass Energy Conservation Programme CPA 17

Audit Analysis

A Gold Standard improved-cookstove project in Malawi with a VVB-confirmed investment additionality test and no reported reversal events, but undermined by a massive discrepancy between the ex-ante lifetime estimate (~194 ktCO₂e) and the verified annual figure (~1.53 MtCO₂e), a project-specific baseline with no stated reassessment date, and numerous cross-document contradictions in leakage treatment, FNRB method, and usage rates. The project's safeguards and FPIC documentation are adequate, but the ERR over-delivery of roughly 119× the pro-rata expectation raises serious over-crediting concerns.

Project Description

Red Flags

• ⚠Verified ERR of 1,534,828 tCO₂e for a single monitoring year is approximately 119× the pro-rata expectation of ~12,927 tCO₂e derived from the 193,899 tCO₂e lifetime ex-ante estimate over a 15-year crediting period — an extraordinary over-delivery that warrants independent re-verification.
• ⚠The verification report is dated 23 August 2023 yet the stated monitoring period is 1 January – 31 December 2024, creating a temporal inconsistency that undermines confidence in which period the verified figure actually covers.
• ⚠Leakage treatment is contradictory: the verification report (Aug 2023) describes it as 'quantified' (5% deduction), while a later appendix (Mar 2024) characterises it as 'deemed negligible' — the two positions are mutually inconsistent.
• ⚠FNRB method is contradictory: the verification report (Aug 2023) cites a national default (0.81), while an earlier verification report (Feb 2023) cites a local field measurement — the basis of the 0.81 value is unclear.

Credit Vintages