Huizhou Landfill Gas Power Generation Phase III and IV Project
#88of 189 in Methane#769of 1084 in China#857of 1339 in Verra (VCS)#81of 159 in ACM0001
Audit Analysis
A registered VCS landfill gas project with a reputable VVB and a closed corrective action, but undermined by significant contradictions across documents on additionality (legal capture requirement), leakage treatment, and FPIC status. The verified emissions reductions for the two-year monitoring period are roughly 112% of the pro-rata lifetime expectation, which is reasonable, yet the baseline and additionality foundations carry unresolved questions that limit confidence in the integrity of the claims.
Red Flags
- The PDD states that LFG capture is legally required under GB 50869-2013, while the monitoring report states it is not — a fundamental additionality contradiction that the VVB addressed via a closed CAR but which remains unresolved in the document record.
- Leakage deduction is 0% with the justification recorded as 'not addressed' in the verification report, despite the monitoring report claiming it was 'deemed negligible' — no substantive leakage analysis is documented.
- Reversal events are recorded as 'not addressed' and no buffer pool percentage is stated, leaving permanence risk unquantified.
- Two different grid emission factors (0.8042 and 0.50885) appear in monitoring reports dated 2023-06-30 and 2023-07-26, a 58% discrepancy that affects the magnitude of claimed reductions.
- FPIC status is contradictory: the validation report records it as conducted, while the more recent monitoring report records it as not conducted.
Credit Vintages
| Issued | Retired | Available | ||
|---|---|---|---|---|
| 2020 | 5,523 | 5,522 | 1 | |
| 2021 | 323,056 | 75,255 | 247,801 | |
| 2022 | 251,601 | 46,201 | 205,400 | |
| Total | 580,180 | 126,978 | 453,202 |
Risk Indicators
VVB-confirmed investment test, but PDD asserts legal capture requirement (GB 50869-2013) and CDM-3201 overlap unresolved in record
Reversal events not addressed; LFG avoidance project has lower inherent risk
0% deduction with justification recorded as 'not addressed' in verification report; monitoring report claims 'deemed negligible' but no analysis documented
Project-specific baseline; measured per monitoring report but modeled per PDD; last reassessment date not stated (not yet due under 10-year VCS ALM rule)
Grievance mechanism present and safeguards mentioned, but FPIC status is contradictory across documents (conducted vs not conducted)
CORSIA eligibility and CCP status not stated; CDM-3201 overlap flagged in corrective actions but no explicit dual-registration evidence
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