Zonguldak Landfill Gas to Electricity Project
#133of 189 in Methane#270of 295 in Turkey#1089of 1339 in Verra (VCS)#115of 159 in ACM0001
Audit Analysis
The Zonguldak Landfill Gas to Electricity project has a verified additionality assessment and a named VVB, but the verification report surfaced 13 material findings including a 37%+ gap between estimated and actual emission reductions, an initial exclusion of project emissions, and multiple baseline and calculation inconsistencies. The 0% leakage deduction is justified only as 'deemed negligible,' which is a weak basis for a landfill gas project. Seven contradictions across documents and a low extraction confidence further erode confidence in the data underpinning the credit claims.
Red Flags
- Actual emission reductions were 48.9% (2022) and 47.5% (2023 partial) lower than the project's own estimates, a discrepancy the VVB flagged as excessive
- Project emissions from electricity consumption were initially excluded from the calculation and only added after a site-visit finding, indicating a material under-reporting risk in the original monitoring
- Leakage deduction is 0% with a justification of 'deemed negligible' — a weak basis for a landfill gas project where uncollected methane is a well-known pathway
- Baseline scenario classification is inconsistent between the PDD (Case 1) and the verification report (Case 3), and the VVB required clarification on government policy validation
- The PDD ex-ante lifetime estimate (186,998 tCO2e) is 50% higher than the verified figure (124,559 tCO2e) reported in the verification report, raising questions about the robustness of the original estimates
Credit Vintages
| Issued | Retired | Available | ||
|---|---|---|---|---|
| 2022 | 74,938 | 38,077 | 36,861 | |
| 2023 | 88,096 | 38,303 | 49,793 | |
| 2024 | 86,352 | 0 | 86,352 | |
| Total | 249,386 | 76,380 | 173,006 |
Risk Indicators
VVB-confirmed combined test
mixed evidence / unresolved risk
0% deduction, 'deemed negligible' — weak for landfill gas
Project-specific, measured; last reassessment not stated
FPIC and grievance mechanism present but FPIC status contrad
CORSIA and CCP status not stated in available documents
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