Safe Water Programme – Kenya – VPA 35

Audit Analysis

The Safe Water Programme in Kenya has a VVB-confirmed investment additionality test and a conservative national-default FNRB, but is undermined by an unaddressed 0% leakage deduction, a project-specific baseline with no reassessment record, and 24 outstanding corrective actions spanning sampling methodology, operational-day calculations, and bias risks in chlorine tablet usage. The material finding that actual emission reductions fall below the registered PDD estimates, combined with multiple inter-document contradictions, raises meaningful over-crediting concerns.

Project Description

Red Flags

• ⚠Leakage deduction of 0% with justification recorded as 'not addressed' in the most recent verification report (Sep 2024), while an earlier report (Apr 2023) claimed it was 'deemed negligible' — the more recent and authoritative document provides no substantive justification.
• ⚠24 corrective actions remain open, including stratified random sampling non-compliance with CDM Appendix 3, potential systemic bias in chlorine tablet usage leading to overestimation of ERs, and missing signed population confirmation letters.
• ⚠Material finding in the Sep 2024 verification report states actual emission reductions are lower than ex-ante estimates in the registered PDD, yet the verified figure equals the claimed figure with no downward adjustment applied.
• ⚠Buffer pool percentage and reversal event history are not stated in any available document, leaving permanence risk unquantified.

Credit Vintages