Kozbuku HEPP

Audit Analysis

Kozbükü HEPP is a small-scale hydro avoidance project in Turkey with VVB-verified additionality and no reversal events, but it carries notable integrity concerns including a 0% buffer pool, a baseline-method contradiction between the validation and verification reports, and a significant gap between claimed and verified emission reductions (the project delivered roughly 71% of the pro-rata expectation for the elapsed monitoring period). Thirty-five corrective action requests were raised and resolved, indicating a thorough but issue-laden verification process.

Project Description

Red Flags

• ⚠Verified ERR of 859,672 tCO₂e is only ~71% of the pro-rata lifetime expectation (~1,213,000 tCO₂e for the 8.6-year monitoring window), while the issuance document claims 1,221,826 tCO₂e — a 42% over-claim relative to verified figures
• ⚠Baseline method is stated as 'project-specific' in the verification report but 'jurisdictional' in the validation report, creating ambiguity about the robustness of the counterfactual
• ⚠Level 5 additionality claim was found to be unsupported and had to be removed during verification, and 35 CARs were raised in total, indicating substantial initial documentation weaknesses
• ⚠Inconsistencies in grid emission factors were found between the ER sheet and the PDD/MR, undermining confidence in the quantification chain

Credit Vintages