Sea of Change
#9of 11 in Blue carbon#1262of 1339 in Verra (VCS)#9of 14 in AR-AM0014
Audit Analysis
The Sea of Change mangrove restoration project in Myanmar is registered and VVB-verified, but the verification report (August 2025) identifies over 30 material findings that raise serious concerns about the accuracy of carbon stock estimates, including a significantly overestimated soil carbon rate, an allometric equation used outside its valid range, and failure to discount pre-existing trees. The 0% leakage deduction is inconsistent with identified displacement pathways, and the non-permanence risk report dates from 2017. While a 17% buffer pool and VVB-confirmed additionality provide some structural safeguards, the volume and severity of unresolved issues substantially undermine confidence in the integrity of the claimed removals.
Red Flags
- Soil carbon accumulation rate of 13.23 tC/ha/year flagged as significantly overestimated compared to defaults and literature (verification report, 2025)
- Allometric equation used outside its valid diametric range (3.9–7.8 cm) and not meeting CDM Tool 14 requirements for ex-post estimation
- Pre-existing trees in the baseline were not differentiated or discounted, leading to overestimation of removals
- 0% leakage deduction despite material finding that charcoal production displacement leakage is not included in the monitoring plan
- Non-permanence risk report dated 15 November 2017 — nearly 8 years old at time of verification
Credit Vintages
| Issued | Retired | Available | ||
|---|---|---|---|---|
| 2015 | 31,744 | 31,587 | 157 | |
| 2018 | 26,615 | 25,215 | 1,400 | |
| 2019 | 53,369 | 51,441 | 1,928 | |
| 2020 | 54,137 | 50,546 | 3,591 | |
| 2021 | 25,080 | 24,890 | 190 | |
| 2022 | 48,439 | 20,830 | 27,609 | |
| 2023 | 50,641 | 10,000 | 40,641 | |
| Total | 290,025 | 214,509 | 75,516 |
Risk Indicators
VVB-confirmed barrier test
Buffer 17% but NPRR outdated (2017); reversal contradiction
0% deduction; charcoal displacement unaddressed
Project-specific; 10-yr reassessment due ~2025, not yet done
FPIC and grievance per 2025 VR; contradicted by 2023 appendix
CORSIA and CCP status not stated
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