Nanzhao County MSW Landfill Site LFG Pollution Treatment and Comprehensive Utilization Project
#646of 1084 in China#722of 1339 in Verra (VCS)#65of 159 in ACM0001
Audit Analysis
This VCS landfill gas capture project (ACM0001) in China has a VVB-confirmed additionality assessment and a measured baseline, but is undermined by three material findings (incorrect grid emission factor, incorrect ex-ante reduction values, inconsistent energy meters) and eight cross-document contradictions spanning additionality test type, legal requirement, leakage justification, and ERR figures. The absence of a stated buffer pool, a 0% leakage deduction with inconsistent justification, and missing CORSIA/CCP eligibility data further weaken confidence in the integrity and safety of the claimed credits.
Red Flags
- Three material findings in the verification report: incorrect grid emission factor applied in PEEC calculation, incorrect ex-ante emission reduction value for the crediting period, and inconsistent energy meter usage between monitoring periods — all requiring VVB corrective action.
- Contradiction on whether LFG capture is legally required: the PDD (2022) states it is legally required, while the monitoring report (2025) states it is not. If legally required, the additionality claim is fundamentally weakened.
- Contradiction on additionality test type: the PDD (2022) records a combined test, while the monitoring report (2025) records an investment test only.
- Leakage deduction of 0% with contradictory justification: the 2023 verification report states leakage was 'not addressed,' while the 2025 monitoring report states it was 'deemed negligible' — no quantified analysis is evident.
Credit Vintages
| Issued | Retired | Available | ||
|---|---|---|---|---|
| 2021 | 38,324 | 0 | 38,324 | |
| 2022 | 73,802 | 50,053 | 23,749 | |
| 2023 | 70,075 | 0 | 70,075 | |
| 2024 | 11,811 | 0 | 11,811 | |
| Total | 194,012 | 50,053 | 143,959 |
Risk Indicators
VVB-confirmed but test type and legal requirement contradicted across documents
reversal risk unquantified
0% deduction with contradictory justification; no quantified analysis
Project-specific, measured per monitoring report but contradicted by PDD
Grievance mechanism present; FPIC and benefit-sharing contradicted across documents
CORSIA and CCP status not stated in available documents
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