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VCS avoidance Türkiye Registry: Late to verify Documentazione completa General Methodology v2.0

Kargilik 24 MW Hydropower Plant, Turkey

VCS-264 ↗

5.9 / 10
Integrity
5.2
Transparency
6.1
Claim Safety
5.6
Documentation
7.4

Score Breakdown

Integrity

verified Additionality is confirmed by the VVB using a barrier analysis (validation documentation referenced in the extracted record).

missing Baseline is project-specific and the timing of any baseline reassessment is not stated in available documents; leakage treatment is inconsistent across documents.

Transparency

verified Monitoring period is clearly stated (2011-04-01 to 2016-03-27) and the extracted record shows claimed and verified ERs matching at 220,348.

missing Key accounting figures conflict across documents (multiple different ER totals), reducing MRV clarity and comparability.

Claim Safety

verified The project is explicitly not CORSIA-eligible, reducing certain double-claiming/dual-eligibility risks.

missing Contradictory ER totals and inconsistent leakage justification increase perceived over-crediting and greenwashing risk.

Documentation

verified A relatively complete document set is present (PDD, validation, monitoring, issuance) with 15 documents used and high extraction confidence.

missing Safeguards and grievance mechanism reporting is inconsistent between earlier and later monitoring reports, indicating uneven documentation quality over time.

Detailed Analysis

Integrity

Additionality is relatively strong on paper because the validation documentation confirms additionality via a barrier analysis and it is confirmed by the VVB. The baseline is project-specific under ACM0002, and the extracted record does not state when the baseline was last reassessed, which weakens robustness for a long crediting period (2006-03-28 to 2016-03-27). Leakage is applied as a 0% deduction, but the monitoring report (2020) indicates leakage was not addressed while the validation report (2020) indicates leakage was quantified, creating uncertainty about whether leakage was properly treated.

Transparency

The extracted record provides a clear monitoring period (2011-04-01 to 2016-03-27) and a grid emission factor value (0.616), supporting basic MRV traceability. The extracted record also shows claimed and verified ERs both equal to 220,348, suggesting internal consistency within the latest figures. However, multiple documents report different ER totals, which reduces transparency because users cannot easily reconcile which numbers govern issuance without deeper registry cross-checking.

Claim Safety

The project is explicitly not CORSIA-eligible, which lowers the risk of certain aviation-related double-claiming narratives. Still, the presence of materially different ER totals across validation/verification vintages increases over-crediting risk and makes public claims harder to substantiate. Leakage treatment is also a claim-safety concern because a 0% deduction paired with inconsistent justification (quantified vs not addressed) can be perceived as under-accounting.

Documentation

Documentation coverage is fairly strong: the extracted record includes a PDD, validation report(s), monitoring report(s), and issuance evidence, with 15 documents used and high extraction confidence. No material findings or corrective actions are reported in the extracted record, which supports procedural completeness. Nevertheless, safeguards and grievance mechanism information appears in the 2020 monitoring report but is absent in the 2010 monitoring report, indicating that social documentation may not have been consistently maintained across periods.

Overall

Overall scoring is pulled down mainly by contradictions that affect core crediting numbers and leakage treatment. For ER totals, the most recent validation report (2020-06-26) reports 220,348, while earlier documents report 85,249 (validation report, 2009-11-23) and 125,315 (validation/verification documentation, 2011-08-17); the 2020 figure is privileged because it is the most recent and aligns with the extracted record’s claimed vs verified totals, but the spread indicates reliability risk. For leakage justification, the validation report (2020-06-26) stating leakage was quantified is privileged over the monitoring report (2020-06-08) stating it was not addressed because validation typically specifies methodological treatment; the inconsistency still warrants a downward adjustment. For safeguards and grievance mechanism, the later monitoring report (2020-06-08) is privileged over the earlier monitoring report (2010-08-08) as the more recent disclosure, but the change over time suggests uneven reporting rather than a stable, well-evidenced safeguards system.

Audit Analysis

The project has a clear VCS setup with VVB-confirmed additionality and matching claimed vs verified reductions in the extracted record. However, multiple cross-document inconsistencies (especially around verified/claimed ERs and leakage treatment) weaken confidence in the underlying accounting and increase over-crediting risk. Safeguards and grievance information appear in later monitoring but are absent in earlier monitoring, suggesting uneven social documentation over time.

Project Description

The Kargilik 24 MW Hydropower Plant in Turkey generates clean and renewable electricity using the Kesis River's gross water head of 150m. Developed by Tektug Elektrik Uretim Anonim Sirketi, the project has a total installed capacity of 24 MWe and is predicted to supply 71,000 MWh4 of net power to the grid per annum. Although the project's actual performance in 2006-2008 was lower than expected due to recent droughts.

Red Flags

  • Large inconsistencies in reported claimed/verified emission reductions across validation/verification vintages (e.g., 220,348 vs 85,249 and 125,315), raising reliability and over-crediting concerns
  • Leakage is recorded as a 0% deduction while justification is inconsistent across documents (quantified in one report vs not addressed in another)

Credit Vintages

Issued Retired Available
2006
22,827 22,827 0
2007
27,866 27,866 0
2008
34,556 34,556 0
2009
56,011 56,011 0
2010
53,564 53,564 0
2011
33,949 33,781 168
2012
57,590 34,288 23,302
2013
41,254 0 41,254
2014
20,723 0 20,723
2015
50,396 0 50,396
2016
16,436 0 16,436
Total 415,172 262,893 152,279

Cosa migliorerebbe questo punteggio

  • Provide a reconciled ER table (by monitoring period and issuance event) that explains why earlier documents show 85,249 and 125,315 while later documents show 220,348, with registry issuance IDs and dates.
  • Clarify leakage treatment under ACM0002 for this project (whether quantified or negligible) and include the calculation/justification consistently in monitoring and verification documentation.

Questi suggerimenti indicano quali prove pubbliche aggiuntive potrebbero migliorare il livello di confidenza di questa valutazione. Non garantiscono un punteggio futuro più alto.

Risk Indicators

Additionality

VVB-confirmed barrier analysis

Permanence

Avoidance project; no reversals reported

Leakage

0% deduction with inconsistent justification

Baseline

Project-specific baseline; reassessment timing unclear

Safeguards

Safeguards/grievance inconsistently documented over time

Double-claim

Not CORSIA-eligible; CCP status not stated

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Analysis Provenance Scored 2026-04-02 General Methodology v2.0 Documentazione completa

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