Hegang Coal Industry (Group) Co., Ltd. Coalmine Methane Utilization Project

Audit Analysis

A CDM coal mine methane utilization project in China with VVB-confirmed additionality (combined test by DNV), but significant data gaps including no monitoring reports, no verified emission reductions, and a ten-fold discrepancy in claimed ERR between the PDD and the validation report. The project lacks a buffer pool and relies on a project-specific modeled baseline, with leakage deemed negligible at 0%. The absence of any post-validation monitoring data and the ERR inconsistency materially weaken confidence in the project's claimed reductions.

Project Description

Red Flags

• ⚠Ten-fold discrepancy in total ERR: the PDD states 2,786,654 tCO2e while the validation report states 278,665 tCO2e — a factor-of-10 difference that is unresolved and undermines data reliability
• ⚠No monitoring reports or verified emission reductions found in the extracted record; the project's actual performance over its 2010–2020 crediting period is entirely unverified
• ⚠Contradiction on whether methane capture is legally required: the PDD states it is, while the validation report (DNV) states it is not — this directly affects the additionality claim

Credit Vintages

No issuances recorded on the registry.