Liyang 15 MW Low-concentration CMM Power Generation Project

Audit Analysis

The Liyang CMM power generation project has VVB-verified additionality and no inherent reversal risk, but the verification report surfaced six corrective action requests including internal inconsistencies in the monitoring data and a lack of independent cross-checks. The project delivered only about 55% of the pro-rata ex-ante expectation for the three-year monitoring period, raising material over-crediting concerns. Multiple contradictions between the validation, monitoring, and verification documents further erode confidence in the data chain.

Project Description

Red Flags

• ⚠Verified ERR of 757,901 tCO2e is only ~55% of the pro-rata expectation (1,368,063 tCO2e) for the 3-year monitoring period against the 4,560,209 tCO2e lifetime ex-ante estimate, indicating significant under-delivery relative to projections
• ⚠Verification report material finding: 'Actual achieved emission reductions of this monitoring period are not consistent within the monitoring report' — internal data inconsistency in the primary monitoring document
• ⚠Six corrective action requests raised during verification, including the requirement for the VVB to independently assess government authorization and provide detailed cross-verification of methane captured
• ⚠Leakage deduction of 0% with justification described as 'quantified' in the verification report but 'deemed negligible' in the monitoring report — the two characterisations are inconsistent and a 0% deduction in a CMM project warrants scrutiny
• ⚠Material finding: 'Lack of independent cross-checks and unreported data gaps' identified by the VVB during verification
• ⚠Gas capture legally mandated — additionality in doubt

Credit Vintages