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VCS avoidance Bulgaria Vintage 2020, 2021 Registry: Registered Documentazione completa General Methodology v2.0

Saint Nikola Wind Farm

VCS-1258 ↗

6.4 / 10
Integrity
6.2
Transparency
6.0
Claim Safety
6.4
Documentation
7.4

Score Breakdown

Integrity

verified The validation/verification record indicates additionality was confirmed by the VVB (validation report).

missing Leakage is applied as a 0% deduction while the latest monitoring report says leakage was not addressed, and earlier monitoring documentation indicates it was quantified.

Transparency

verified Key MRV elements are present (identified VVB, monitoring period 2020-12-01 to 2022-10-31, and a stated grid emission factor of 0.791 in the monitoring report dated 2025-04-30).

missing Contradictory ER and safeguards statements across monitoring reports reduce the credibility and auditability of disclosed information.

Claim Safety

verified The project is explicitly not CORSIA-eligible in the extracted record, lowering aviation-claim and double-claim exposure.

missing Verified ERs exceed claimed ERs in the latest record (562,361 verified vs 527,199 claimed), and claimed ERs also conflict across periods/documents, increasing confusion and misclaiming risk.

Documentation

verified A relatively complete document set is referenced (PDD, validation report, multiple monitoring reports, issuance) with 18 documents used and high extraction confidence.

missing Repeated contradictions between documents suggest document control/versioning issues even if documents exist.

Detailed Analysis

Integrity

The project applies ACM0002 with a project-specific baseline approach, and the monitoring report (2025-04-30) cites a grid emission factor of 0.791 with a baseline last reassessed in 2012. Additionality is stated as confirmed by the VVB (validation report), which supports integrity for a renewable energy project type. However, leakage is weakly handled: the monitoring report (2025-04-30) indicates leakage was not addressed while still applying a 0% leakage deduction, and an earlier monitoring report (2015-02-25) reportedly treated leakage as quantified—this inconsistency undermines robustness.

Transparency

The extracted record includes the VVB name (4K Earth Science Private Limited), a clear monitoring period (2020-12-01 to 2022-10-31), and no material findings or corrective actions in the latest monitoring report (2025-04-30). Transparency is reduced by internal inconsistencies across monitoring reports, including conflicting claimed ER totals and conflicting safeguards disclosures. These contradictions make it harder for third parties to reconcile what was monitored, claimed, and assured over time.

Claim Safety

The project is explicitly marked as not CORSIA-eligible, which reduces the risk of high-profile aviation-related claims and some double-claim concerns. Over-crediting/claim risk remains because the latest extracted figures show verified ERs higher than claimed ERs (monitoring report 2025-04-30: 562,361 verified vs 527,199 claimed), and claimed ERs also conflict with an earlier monitoring report (2021-06-15: 1,151,085 claimed). In addition, leakage justification is inconsistent across monitoring reports, which can affect the defensibility of net ER claims.

Documentation

Documentation coverage appears relatively strong: the evidence list includes a PDD, validation report, monitoring reports, and issuance records, with 18 documents used and high extraction confidence. The latest monitoring report is recent (2025-04-30) and includes key MRV fields such as monitoring period and grid emission factor. Nonetheless, repeated contradictions across documents indicate weaknesses in document consistency and version control, which lowers confidence despite the apparent completeness.

Overall

Overall scoring is pulled down primarily by contradictions across official documents. For the claimed ER total, the more recent monitoring report (2025-04-30) value of 527,199 is privileged over the older monitoring report (2021-06-15) value of 1,151,085 because recency typically reflects the latest reconciled accounting, but the magnitude of the discrepancy materially reduces confidence. For leakage and safeguards (leakage justification; FPIC; grievance mechanism; safeguards mention), the latest monitoring report (2025-04-30) is privileged for the same recency reason, yet the fact that earlier monitoring reports state different positions (including quantified leakage in 2015 and no FPIC/grievance in 2016) signals reliability issues that warrant score penalties. For additionality test type, the validation report (2014-10-22) is privileged over later monitoring narrative because the validation report is the primary source for the additionality demonstration, but the inconsistency still indicates weak cross-document coherence.

Audit Analysis

This is a grid-connected wind project under VCS ACM0002 with VVB-confirmed additionality and no reported reversals, which supports basic credit integrity. However, multiple internal inconsistencies across monitoring reports (including a large discrepancy in claimed ERs and conflicting statements on leakage and safeguards) reduce confidence in the reliability of the record and increase over-crediting/greenwashing risk.

Project Description

The Saint Nikola Wind Farm in Kavarna, Bulgaria, is a 156 MW renewable energy project that has been operational since 2010. The project consists of 52 wind turbines and contributes to Bulgaria's goal of increasing its renewable energy share. The project has been registered under the Verified Carbon Standard (VCS) since 2014, allowing it to generate carbon credits by displacing electricity that would have otherwise been produced from fossil fuels. The project's environmental benefits include a reduction in greenhouse gas emissions, as well as a decrease in other pollutants such as CO2, NOx, SOx, and particulate matter. The project also has social and community benefits, including the creation of jobs, both skilled and unskilled, and contributions to local road upgrades and community needs such as healthcare technologies. The project's commitment to sustainability is further demonstrated by its close relationship with the local community and its ongoing efforts to minimize any negative environmental impacts.

Red Flags

  • Large contradiction in claimed emission reductions between monitoring reports (527,199 vs 1,151,085), indicating potential reporting or boundary/period inconsistencies.
  • Leakage treatment is inconsistent across monitoring reports (one states leakage was quantified; the latest states leakage was not addressed while still applying a 0% deduction).
  • Safeguards-related disclosures (FPIC and grievance mechanism) conflict across monitoring reports, raising stakeholder-risk and transparency concerns.

Credit Vintages

Nessuna emissione registrata sul registro.

Il marketplace dichiara i vintage: 2020, 2021 (non verificato).

Cosa migliorerebbe questo punteggio

  • Publish a reconciled ER accounting note that explains the discrepancy in claimed ER totals across monitoring reports (including periods covered, any restatements, and links to issuance/verification statements).
  • Provide a consistent leakage assessment aligned to ACM0002 (either quantified or justified as negligible) and ensure the same position is carried through all monitoring/verification documentation.
  • Standardize safeguards reporting across monitoring reports (explicit FPIC evidence, grievance mechanism details, and stakeholder engagement outcomes) and correct/annotate prior inconsistent statements.

Questi suggerimenti indicano quali prove pubbliche aggiuntive potrebbero migliorare il livello di confidenza di questa valutazione. Non garantiscono un punteggio futuro più alto.

Risk Indicators

Additionality

VVB-confirmed additionality

Permanence

Avoidance project; no reversals reported

Leakage

0% deduction with inconsistent justification

Baseline

Project-specific baseline; reassessment timing dated

Safeguards

Safeguards/FPIC/grievance inconsistently documented

Double-claim

Not CORSIA-eligible; CCP status not stated

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Analysis Provenance Scored 2026-04-02 General Methodology v2.0 Documentazione completa

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