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ICRavoidanceSpainVintage 2020, 2021, 2022ACM0017

Substitution of fossil fuels for the use of sustainable biofuels manufactured by Iniciativas Bioenergéticas S.L.

CT-618 ↗

#206of 352 in Biomass#3of 5 in Spain#71of 154 in Intl. Carbon Registry (ICR)

4.2/ 10
Integrity
5.0
Transparency
3.5
Claim Safety
3.5
Documentation
4.5

Audit Analysis

A Spanish biofuel substitution project under the CDM/ICR framework with VVB-confirmed additionality and documented feedstock sustainability, but severely limited by the complete absence of monitoring data, a 12-fold discrepancy in the estimated emission reductions between the PDD and the validation report, and a thin leakage justification. The project's claims cannot currently be substantiated against any verified performance data.

Red Flags

  • The PDD (Sept 2021) reports a total ERR of 95,000 tCO2e while the validation report (Oct 2021) reports 1,128,074 tCO2e — a roughly 12-fold discrepancy that undermines confidence in the project's quantification.
  • No monitoring report or verified ERR figure exists in the available record, making it impossible to confirm that the project is actually delivering the claimed reductions.
  • Leakage is set at 0% with only a 'deemed negligible' justification; the PDD does not address leakage at all, and no quantitative analysis is provided for a project type where displaced fossil-fuel demand could shift to other locations.
  • No buffer pool, permanence mechanism, or reversal-risk mitigation is documented for this avoidance-type project.

Credit Vintages

No issuances recorded on the registry.

Il marketplace dichiara i vintage: 2020, 2021, 2022 (non verificato).

Risk Indicators

Additionality

VVB-confirmed investment test

Permanence

mixed evidence / unresolved risk

Leakage

0% deduction, 'deemed negligible' only; PDD omits leakage

Baseline

Project-specific baseline, no FNRB stated; reassessment not yet due

Safeguards

Safeguards mentioned but no FPIC, grievance mechanism, or benefit sharing documented

Double-claim

CORSIA and CCP status both unstated; dual-channel risk unassessed

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Analysis ProvenanceScored2026-09-03ACM0017

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