Rockingham County Landfill Gas Combustion Project

Audit Analysis

The Rockingham County Landfill Gas Combustion Project uses a well-established methodology (ACM0001) with VVB-confirmed additionality and inherently low permanence risk, but is undermined by an extensive list of material findings (40+ items) including incorrect GWP values, a missing flaring equation, an incorrect project boundary, and outdated emission factors. Internal contradictions in the monitoring report (44,952 vs 21,148 tCO2e) and between documents (grid EF, additionality test type, grievance mechanism) raise concerns about data reliability. The project is not CORSIA-eligible and has no CCP approval, limiting double-claiming risk.

Project Description

Red Flags

• ⚠The monitoring report (2024-12-11) contains an internal contradiction: total ERR appears as both 44,952 and 21,148 tCO2e, with no explanation for the discrepancy
• ⚠40+ material findings identified across the PDD, MR, and VR, including incorrect GWP values (25 vs 28), a missing flaring emissions equation, an incorrect project boundary (Phase 5 exclusion), and outdated grid and propane emission factors
• ⚠The verification period was 16 months instead of the required annual cycle, and NMOC assessment was performed every 5 years instead of annually
• ⚠The County received a Notice of Violation for late Title V permit report submissions (though all monitoring was ultimately completed on time)
• ⚠The crediting period end date is missing (null) in the verification report, while the monitoring report states 2030-04-18 — an unresolved discrepancy

Credit Vintages