Safe Water Programme – Kenya – VPA 44

Audit Analysis

The Safe Water Programme in Kenya has a VVB-confirmed investment additionality test and a named verification body, but is undermined by a material finding that verified emission reductions fall below ex-ante estimates, a 0% leakage deduction with no documented justification, and 23 outstanding corrective actions. Multiple contradictions across verification reports raise data-reliability concerns, and the absence of a buffer pool or documented permanence mechanism leaves the project exposed to reversal risk.

Project Description

Red Flags

• ⚠Material finding in the 2024 verification report states actual emission reductions are lower than ex-ante estimates in the registered PDD, indicating potential over-crediting in earlier periods.
• ⚠Leakage deduction is 0% with justification recorded as 'not addressed' in the most recent (2024) verification report, contradicting an earlier 'deemed negligible' statement — no quantitative or qualitative leakage analysis is documented.
• ⚠23 corrective actions remain open, including errors in monitoring report dates, sampling design non-compliance with CDM Appendix 3, and missing evidence for operational-day calculations.
• ⚠No buffer pool percentage or permanence mechanism is stated in any available document, leaving reversal risk unmitigated.
• ⚠FPIC (Free, Prior and Informed Consent) is not documented in the extracted record despite the project serving schools and communities in Kenya.

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