Safe Water Programme – Kenya – VPA 42
GS-3321 ↗ · current registry ID: GS11300
#922of 1329 in Industrial#114of 157 in Kenya#1346of 1801 in Gold Standard (GS)
Audit Analysis
The Safe Water Programme in Kenya has a VVB-confirmed investment additionality test and no material findings, but is undermined by a 0% leakage deduction with no justification, a project-specific baseline with no reassessment date, and 17 corrective actions flagged by the verifier. The exact match between claimed and verified ERR (1,023,164 tCO₂e) for an 11-month monitoring window within a 60-month crediting period raises serious over-crediting concerns.
Red Flags
- Claimed and verified ERR are identical (1,023,164 tCO₂e) despite the monitoring period covering only 11 of 60 crediting months, implying the project delivered ~545% of the pro-rata expectation — a strong indicator of over-crediting or a data error
- Leakage deduction is 0% and the 2024 verification report records the justification as 'not addressed', while the earlier 2023 report called it 'deemed negligible' — the more recent and authoritative document is the less favourable one
- 17 corrective actions were required by the VVB, including sampling-design non-compliance with CDM Appendix 3, missing deviation documentation, and incomplete safeguard reporting
- No buffer pool percentage, no baseline reassessment date, and no FPIC record were found in any available document
Credit Vintages
| Issued | Retired | Available | ||
|---|---|---|---|---|
| 2021 | 55,058 | 55,058 | 0 | |
| 2022 | 48,497 | 0 | 48,497 | |
| 2023 | 49,287 | 0 | 49,287 | |
| 2024 | 58,371 | 0 | 58,371 | |
| Total | 211,213 | 55,058 | 156,155 |
Risk Indicators
VVB-confirmed investment test
no reversal events recorded
0% deduction, justification 'not addressed'
Project-specific, no reassessment date
Grievance mechanism and benefit sharing present; FPIC not stated; 17 corrective actions
CORSIA and CCP status not stated
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