Salto Pilão Hydropower Plant Project Activity

Audit Analysis

The Salto Pilão hydropower project has a fundamentally sound design—jurisdictional baseline, VVB-confirmed regulatory-surplus additionality, and no reversal risk as an avoidance activity—but is undermined by an extensive list of material findings (over 30), multiple grid emission-factor inconsistencies, ER calculation errors, and a confirmed absence of FPIC and benefit-sharing documentation in the most recent verification report. The ex-ante lifetime estimate shows a three-fold discrepancy between the PDD and the monitoring report, raising over-crediting concerns that cannot be fully resolved from the available record.

Project Description

Red Flags

• ⚠FPIC was not conducted and benefit sharing is not described, per the 2026 verification report, despite the 2022 report stating both were present — a serious safeguard gap for a project in Brazil
• ⚠Ex-ante lifetime ERR contradicts between the PDD (≈1.87 million tCO₂) and the monitoring report (≈592,000 tCO₂), a three-fold discrepancy that cannot be reconciled from the extracted record
• ⚠Over 30 material findings and 28 corrective actions were raised, including multiple grid emission-factor errors, ER calculations not based on net electricity delivered, and missing net-harm and stakeholder assessments
• ⚠Verified emissions reductions were 44.1% higher than the registered PDD estimate, combined with the ex-ante discrepancy, creating over-crediting risk
• ⚠Grid emission factor values are inconsistent across documents (0.1852 in 2026 report vs 0.3242 in 2022 report), and EFOM values for September–October 2021 did not match Brazilian DNA data

Credit Vintages