PROYECTO ASOCIATIVO PROGRAMÁTICO ZONA ANDINA Y COSTA ATLÁNTICA - FCG

Audit Analysis

A mature Colombian forestry project (7th verification, 171 participants, ~6,800 ha) with VVB-confirmed additionality and a 15% buffer pool, but undermined by three open corrective actions on land tenure and legal registration, a project-specific baseline, no FPIC or grievance mechanism, and a 15.6% discrepancy in verified ERR figures across documents. The project over-delivers relative to its pro-rata ex-ante expectation (~161%), which is a positive signal, but the unresolved land-title and ICA-registration issues create material integrity risk.

Project Description

Red Flags

• ⚠Three open corrective actions (SAF 1, 3, 4) concern land-tenure continuity after a July 2025 harvest, missing ICA (Ventanilla Única Forestal) registrations for plantations established 2008–2023, and an unresolved legal embargo on two parcels in Necoclí — all pending as of the November 2025 verification report.
• ⚠Verified ERR of 321,054 tCO2e in the verification report contradicts 272,899 tCO2e in the validation report and issuance document (a 15.6% gap) without a documented reconciliation.
• ⚠No Free, Prior and Informed Consent (FPIC) was conducted and no grievance mechanism is documented, despite 171 smallholder participants across four departments.
• ⚠Field-audit observations reveal multiple data-quality problems: plot displacement (Parcela 343 moved ~7 m), digitization errors (99 vs 9.9 DAP), trees outside plot boundaries included in measurements, and a harvested parcel (232) with no standing trees.

Credit Vintages