Safe Water Programme – Kenya – VPA 38
GS-3317 ↗ · current registry ID: GS11296
#986of 1329 in Industrial#123of 157 in Kenya#1415of 1801 in Gold Standard (GS)
Audit Analysis
The Safe Water Programme in Kenya has a confirmed investment-test additionality and a named VVB, but is undermined by a material finding that actual emission reductions fall below the original PDD estimates, an unaddressed 0% leakage deduction, and 24 outstanding corrective actions spanning sampling methodology, operational-day calculations, and bias risks in chlorine tablet usage. Multiple contradictions between verification reports (2023 vs. 2024) on leakage justification, FNRB method, and ERR figures further erode confidence in the data chain.
Red Flags
- Material finding in the 2024 verification report explicitly states actual emission reductions are lower than ex-ante estimates in the registered PDD, indicating the original credit volume was over-optimistic.
- Leakage deduction is 0% with justification recorded as 'not addressed' in the most recent verification report (2024-09-21), a significant gap for a distributed water-supply project where users may revert to unsafe sources.
- 24 corrective actions remain open, including requirements to fix stratified random sampling to meet CDM Appendix 3, eliminate potential systemic bias in chlorine tablet usage, and justify operational-day assumptions with evidence.
- Contradiction in total ERR figures between the October 2023 verification report (362,022) and the September 2024 verification report (1,023,164) is unexplained in the extracted record, raising questions about whether the higher figure is cumulative or a revised single-period value.
Credit Vintages
| Issued | Retired | Available | ||
|---|---|---|---|---|
| 2021 | 57,350 | 57,350 | 0 | |
| 2022 | 49,128 | 48,147 | 981 | |
| 2023 | 49,734 | 0 | 49,734 | |
| 2024 | 53,930 | 0 | 53,930 | |
| Total | 210,142 | 105,497 | 104,645 |
Risk Indicators
Investment test VVB-confirmed
mixed evidence / unresolved risk
0% deduction, justification not addressed
Project-specific, no reassessment date
Mentioned but FPIC not confirmed; grievance mechanism present
CORSIA and CCP status not stated
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