GS1354 Vietnam Small Hydro PoA - Ea Sup 3 Hydropower Project (CPA2)

Audit Analysis

The Ea Sup 3 small hydro project in Vietnam demonstrates solid additionality (investment test with IRR below benchmark, VVB-confirmed) and reasonable safeguards, but is held back by a project-specific baseline rather than a jurisdictional one, the absence of a verified ERR figure for the 2024 monitoring period, and a high volume of corrective actions (34 CARs) during validation. The project is a well-understood avoidance technology with low reversal risk, but the lack of verified monitoring data and multiple cross-document contradictions limit confidence in the claimed credit volume.

Project Description

Red Flags

• ⚠No verified ERR figure was extracted from the 2024 monitoring report, making it impossible to confirm whether the project is delivering on its ex-ante estimate of 93,814 tCO₂e
• ⚠Baseline is project-specific rather than jurisdictional, which is a weaker basis for a hydro project and increases over-crediting risk relative to a grid-average approach
• ⚠34 Corrective Action Requests and 9 Clarification Requests were raised during validation, including inconsistencies in the grid emission factor and missing monitoring parameters — all closed but indicative of initial documentation gaps
• ⚠Six cross-document contradictions identified (leakage justification, baseline method, ERR figures, additionality test type, grid EF, crediting period), most attributable to different vintages but still a data-reliability concern

Credit Vintages