Heilongjiang Wangkui 50MW Level Biomass Cogeneration Project

Audit Analysis

This CDM biomass cogeneration project carries severe integrity concerns: the verification report documents that the plant was converted from cogeneration to power-only operation, equipment deviated from the registered PDD, and unregistered biomass types were introduced, all requiring a PDD revision. The project delivered approximately 167% of the pro-rata ex-ante expectation for the elapsed monitoring period, a figure that is difficult to reconcile with a project whose fundamental design changed mid-crediting. Combined with a project-specific baseline anchored to a 2004 grid emission factor and a 0% leakage deduction whose justification is inconsistent across documents, the over-crediting risk is material.

Project Description

Red Flags

• ⚠Verification report (2016) records that the project changed from cogeneration to a power-only plant, a fundamental design deviation from the registered PDD that invalidates the original baseline and additionality framework
• ⚠Boiler, turbine, and generator specifications in the monitoring report are inconsistent with the registered PDD, and additional biomass types (wood residue, rice husk) were used beyond what was registered
• ⚠Verified ERR of 198,341 tCO₂e for the 2013–2015 monitoring period represents roughly 167% of the pro-rata expectation (~118,800 tCO₂e) derived from the 377,593 tCO₂e lifetime claim, raising over-crediting concerns especially given the operational changes
• ⚠Grid emission factor of 0.996 tCO₂/MWh is drawn from 2004 data and has not been updated, undermining baseline accuracy for a project operating through 2016
• ⚠No heat supply contract existed at the time of validation, yet the project was registered as a cogeneration project claiming reductions from both heat and power

Credit Vintages