Puyang County Rural MSW Landfill Site LFG Pollution Treatment and Comprehensive Utilization Project
#915of 1084 in China#1047of 1339 in Verra (VCS)#26of 34 in AMS-III.G
Audit Analysis
This VCS landfill gas recovery project in China has a VVB-verified additionality assessment and low permanence risk, but is undermined by a serious contradiction over whether LFG capture is legally required, 13 material findings in the verification report, and a grid emission factor discrepancy between the monitoring and verification reports. The project delivered roughly 63% of its pro-rata ex-ante expectation for the elapsed monitoring period, which is conservative, but the documentation quality and data consistency issues limit confidence in the overall credit claims.
Red Flags
- Contradiction on whether LFG capture is legally required: the verification report (Jan 2024) states it is, while the validation report (Jan 2023) states it is not — if legally mandated, the additionality claim is fundamentally weakened
- Grid emission factor discrepancy: the verification report uses 0.8587 tCO₂e/MWh while the monitoring report uses 0.57205 tCO₂e/MWh, a 50% difference that directly affects credit quantities
- 13 material findings and 9 corrective actions identified in the verification report, including missing baseline data sources, missing calculation equations, and inconsistent parameter descriptions
- FPIC status contradicted between the PDD (not conducted) and the validation report (conducted), raising questions about the reliability of social safeguards documentation
- Leakage justification is inconsistent: the verification report describes it as 'quantified' while the monitoring report calls it 'deemed negligible', both resulting in a 0% deduction
Credit Vintages
| Issued | Retired | Available | ||
|---|---|---|---|---|
| 2021 | 898 | 0 | 898 | |
| 2022 | 18,825 | 0 | 18,825 | |
| 2023 | 16,038 | 0 | 16,038 | |
| Total | 35,761 | 0 | 35,761 |
Risk Indicators
VVB-verified but legally-required capture contradiction
LFG recovery – no reversal risk
0% deduction with contradictory justifications
Project-specific, modeled, no reassessment date
FPIC contradicted; grievance mechanism present
CORSIA and CCP status not stated
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