Sirma Run-Of-River Hydro Project

Audit Analysis

The Sirma Run-of-River Hydro Project is a structurally sound VCS avoidance project with a jurisdictional baseline and VVB-confirmed investment additionality test, but its credibility is undermined by significant data-quality issues, a large discrepancy between the 2021 validation and 2025 verification ERR figures, and a long list of corrective actions. The project delivered only about 44% of its pro-rata ex-ante expectation for the elapsed monitoring period, which is conservative but raises questions about the accuracy of the original estimate. Low extraction confidence and several unquantified parameters limit the overall reliability of the available evidence.

Project Description

Red Flags

• ⚠The 2025 verification report records verified ERR of 25,064 tCO₂e for the full 2019–2023 monitoring period, while the 2021 validation report recorded 58,070 tCO₂e — a 57% discrepancy that the material findings attribute to an incorrect net electricity generation value and calculation errors, but which has not been fully reconciled in the extracted record.
• ⚠Twelve corrective actions were required in the 2025 verification cycle, including errors in net electricity generation, missing methodology applicability assessment, absent regulatory-surplus analysis, and incorrect crediting-period calculations, indicating substantial initial documentation deficiencies.
• ⚠The project delivered only ~44% of the pro-rata ex-ante expectation (25,064 vs. ~57,358 tCO₂e expected for 4.57 of 10 crediting years), suggesting the lifetime ex-ante estimate of 125,510 tCO₂e may have been overly optimistic or that generation has been significantly below design capacity.
• ⚠Minimum extraction confidence is rated 'low', meaning at least one key document was poorly readable, reducing confidence in the completeness of the evidence base.

Credit Vintages