Shanxi Yangcheng Huanglian CMM Power Generation Project
#69of 189 in Methane#651of 1084 in China#742of 1339 in Verra (VCS)#9of 35 in ACM0008
Audit Analysis
A VCS methane capture and power generation project in China with VVB-confirmed additionality and an avoidance-based design that eliminates reversal risk. However, six inter-document contradictions—including a nearly 9× discrepancy in the ex-ante ERR estimate and conflicting statements on whether capture is legally required—undermine confidence in the project's data integrity and claim robustness.
Red Flags
- The PDD (2025-03-03) reports a lifetime ERR of 1,438,350 tCO2e while the validation report (2026-02-26) states 164,365 tCO2e — an unexplained ~8.7× discrepancy that cannot be reconciled by period length alone
- Capture being legally required is stated as true in the validation report but false in the PDD; if capture is not legally mandated, the additionality case weakens significantly
- Two material findings (stakeholder identification process and waste-heat inconsistency) required corrective actions, indicating gaps in the project design documentation
- Gas capture legally mandated — additionality in doubt
Credit Vintages
No issuances recorded on the registry.
Risk Indicators
VVB-confirmed combined test
Avoidance project, no reversal risk
0% deduction, contradictory justification
Project-specific, measured vs modeled conflict
FPIC, grievance mechanism, safeguards documented
CORSIA and CCP status not stated
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