Safe Water Programme – Kenya – VPA 33

Audit Analysis

The Safe Water Programme (VPA 33, Kenya) has a VVB-confirmed investment additionality test and a functioning grievance mechanism, but is undermined by a verified emission reduction figure that is roughly 25 times the pro-rata ex-ante expectation for the monitoring period, a project-specific baseline with no documented reassessment, no buffer pool or permanence data, and 22 corrective actions flagged by the VVB. Multiple contradictions between the 2024 and 2025 verification reports on ERR figures, FNRB method, and safeguards further erode confidence in the data reliability.

Project Description

Red Flags

• ⚠Verified ERR of 1,462,277 tCO₂e for a single 12-month monitoring period is approximately 24.7× the pro-rata ex-ante expectation of ~59,312 tCO₂e (296,560 lifetime ÷ 5-year crediting period), raising serious over-crediting concerns
• ⚠22 corrective actions required by the VVB, including fundamental sampling methodology deficiencies (stratified random sampling not meeting CDM Appendix 3 requirements) and a discrepancy in reported employee count (44 vs 47)
• ⚠No buffer pool percentage or permanence period stated in any available document, leaving reversal risk unaddressed
• ⚠Contradiction in FNRB method: the 2025 verification report states 'national_default' while the 2024 monitoring report states 'local_field', creating uncertainty about which emission factors were actually applied
• ⚠Leakage deduction of 0% justified only as 'deemed negligible' without quantitative analysis, in a project where households could revert to open-flame cooking or unsafe water sources

Credit Vintages