SANTOS LANDFILL GAS PROJECT
#91of 189 in Methane#117of 211 in Brazil#879of 1339 in Verra (VCS)#84of 159 in ACM0001
Audit Analysis
The Santos Landfill Gas Project is a VCS-registered LFG destruction project at the validation stage, with VVB-confirmed investment additionality and inherent permanence from methane destruction. However, the validation report (November 2025) identified 22 material findings and 16 corrective actions, the grid emission factor shows a five-fold discrepancy between the PDD and validation report, and several key parameters (buffer pool, FNRB, monitoring details) remain unaddressed. The project is not yet in monitoring, so no over-crediting has occurred, but the documentation quality and unresolved technical ambiguities warrant caution.
Red Flags
- 22 material findings in the validation report, including incorrect project scale, wrong flare model, and ambiguous baseline boundary for pre-2020 landfill cells
- Grid emission factor discrepancy: 0.25 in the validation report versus 1.3 in the PDD — a five-fold difference that materially affects the baseline
- FPIC not conducted, and stakeholder consultation was performed after project implementation without adequate justification
- 16 corrective actions remain open, including delineation of project boundary to exclude pre-2020 landfill sections
Credit Vintages
No issuances recorded on the registry.
Risk Indicators
VVB-confirmed investment test
mixed evidence / unresolved risk
0% deduction, thin 'negligible' justification
Project-specific, modeled; grid EF discrepancy
Grievance mechanism present; FPIC not conducted
CORSIA and CCP status not stated
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