I-DEV0417: Request for Deviation from the Monitoring Plan of the Registered PDD for the Monitoring Period under consideration

The Monitoring Plan of the registered CDM PDD (dated February 23, 2006) has defined a monthly monitoring frequency for the parameter “Average Calorific value of Biomass used (calculated based on weighted average of each type of fuel consumed and NCV of each type of biomass residue on monthly basis)”, in Section D.3, point D.3.4.

However, during the site visit, of the current monitoring period (01st October 2007 to 31st July 2008), it was observed that, the project proponent had monitored the NCV of each kind of biomass residues from independent party on annual basis.

Hence, the ex-post annual monitoring of the NCV of biomass for the verification period under consideration represents a deviation from the Monitoring Plan as stated in the registered PDD. As stated below, the deviation in the monitoring frequency does not have any impact on the calculation of the emission reductions.

The Monitoring Period under consideration from 1st October 2007 to 31st July 2008 represents the last Monitoring Period for the first renewable crediting period of the project activity under consideration. In line with the appropriate guidance for renewal of crediting period, the CDM PDD has already been revised (dated 24 April 2008) for the second renewal crediting period in line with the latest version of the applicable baseline and monitoring methodology. The revised document is compliant with the actual monitoring practice at the site and has also been approved by the CDM EB on 05 January 2011.
Hence this request for deviation from the Monitoring Plan of the registered PDD is applicable only for the monitoring period under consideration and will not affect the subsequent monitoring periods of the project activity. Thus there is no requirement for any revision in the monitoring plan or changes in the project activity from the registered PDD, as the subsequent verification exercises will refer to the revised PDD (for senond renewal crediting period).
The deviation in the frequency of the monitoring is also within the CDM Executive Board guidance (EB 59 Annexure 09, Para 17 (b) which states that "Data elements that are generally constant and indirectly related to the emission reductions (E.g. Emission factors, Calorific Value, System Efficiencies) should be measured or calculated at least once in a year, unless detailed specifications are provided as part of the indicated methodology”. The monitoring methodology of AMS-I.D., version 07 does not require this parameter to be monitored ex-post. The parameter also does not figure in the emission reduction calculations. Hence the actual monitoring practice prevalent on site of NCV measurement once a year is also compliant with the relevant rules and guidelines under CDM. As explained further in the next section, the deviation also does not have any impact on the ex-post GHG emission reduction calculations for the monitoring period under consideration.
Hence the deviation does not require a revision of monitoring plan or the changes from the project activity as described in the registered project design document for the first renewal crediting period.

The deviation sought does not have any impact on the emission reduction calculations.
The GHG emission reductions from the project activity are calculated as the product of the net electricity exported to the grid by the project and the CO2 emission factor of the grid to which the project activity exports the electricity generated, as also evident in the section E.1.2.4. of the registered CDM PDD (dated February 23, 2006). The following formula also describes the same:
• Baseline Emissions (tCO2/year) = Electricity Export (tCO2/year) X Grid Emission Factor (tCO2/MWh)
• Project Emissions (tCO2/year) = 0
• Emission Reductions (tCO2/year) = Baseline Emissions (tCO2/year) – Project Emissions (tCO2/year)

Since the parameter of NCV is not used in the calculations, the deviation does not impact emission reductions anyway.