Guizhou Xintian CMM Power Generation Project

Audit Analysis

The Guizhou Xintian CMM Power Generation Project is a VCS-registered coal mine methane capture and power generation project with VVB-verified additionality and legally mandated capture, but it carries significant integrity concerns from eight material findings, a major discrepancy between the ex-ante ERR estimate and the verified figure, and a mid-period capacity upgrade that was not reflected in the original project design. The project's avoidance-type nature limits permanence risk, and leakage treatment is reasonable, but the over-crediting signal and documentation gaps warrant caution.

Project Description

Red Flags

• ⚠Verified ERR of 1,058,186 tCO2e for a 3-year monitoring period is roughly 10× the pro-rata expectation derived from the PDD ex-ante estimate of 350,473 tCO2e over the full 10-year crediting period, even after adjusting for the 7.6 MW to 14 MW capacity upgrade
• ⚠Eight material findings in the verification report, including missing additionality demonstration for the 7.6 MW scenario, use of outdated 2006 IPCC Guidelines instead of the 2019 Refinement, and ERR estimates that did not reflect the gradual capacity increase
• ⚠Generator capacity was upgraded from 7.6 MW to 14 MW during the monitoring period, a deviation from the PDD that required corrective action
• ⚠Monitoring equipment calibration delays necessitated conservative adjustments to methane and electricity data, introducing measurement uncertainty
• ⚠Gas capture legally mandated — additionality in doubt

Credit Vintages