I-DEV0316: Deviation for installation of backup meter with lower accuracy than that described in the monitoring plan of the registered PDD

SGS is performing the periodic verification of the registered CDM project, Danian 14MW Hydropower Project in Gansu Province, UNFCCC ref. no. 1808. During the assessment process, we identified that the implementation of the project deviated from the registered PDD, therefore we are submitting this request for deviation to the UN for approval before we can further proceed with the verification of the project.
The project includes two hydropower stations (Danian I and II) that supplies electricity to Northwest Power Grid (NWPG) through Gansu Provincial Grid.
The deviation is about reporting the installation of backup meter with accuracy class of 1.0 at Danian II project site and used for the period from 18/12/2008 to 20/03/2010, which is lower than the requirement prescribed in the registered PDD (i.e.0.5S).
The monitoring plan states that Electricity delivered to the grid by the project in year y (EGy) is directly measured by the electricity meter installed at the Dingzihekou 110 kV substation. Two backup meters are installed at the project site of Danian I and Danian II respectively and used in case the main meter is out of order. Both backup meters should have accuracy level of 0.5S as PDD section B.7.2.3 specifies. It was found during onsite visit that backup meter with accuracy class of 1.0 had been installed at Danian II project site and it had been used from 18/12/2008 until a new backup meter with accuracy class of 0.5S was installed on 20/03/2010. The detailed information of meter replaced and installed are as following:

- Type Accuracy Class S/N Position
Meter replaced on 20/03/2010 DSSD331 1.0S 20061005030167 Control Room of Danian II station
Meter installed on 20/03/2010 DSSD331 0.5S 09090166570104 Control Room of Danian II station

On 20/03/2010, a new meter with accuracy level of 0.5S was installed to replace the old backup meter with lower accuracy class in the witness of representative from the grid company and the project owner at Danian II project site. Meter replacement record signed by both sides has been validated by SGS. The accuracy class of the backup meter newly installed is in compliance with the registered PDD since 20/03/2010.
The non-compliance is not a permanent deviation from the registered monitoring plan, therefore a deviation other than revision of monitoring plan is proposed. The deviation is covering the period from 18/12/2008 to 20/03/2010.

The deviation is about reporting a meter used for backup purpose with lower meter accuracy than what is required in registered PDD in the period from 18/12/2008 to 20/03/2010 because the project participant did not implement the monitoring properly according to the registered PDD. Thus the deviation does not require an amendment to the approved methodology AMS-I.D. ver. 11. Furthermore, this non-compliance is not a permanent deviation from the registered monitoring plan, therefore a deviation other than revision of monitoring plan is proposed. Lastly, this non-compliance does not impact the implementation of the project activity, hence request for change of the registered project design document is not proposed.

As per registered monitoring plan, backup meter of Danian II is only used when the main meter fails to determine baseline emissions. By checking against the daily reading records saved in the computer system of Dingzihekou 110kV substation and the sales receipts during the site visit for the project, it has been confirmed by SGS assessors that the main meter worked properly during the period from 18/12/2008 to 20/03/2010 without any malfunction, and the EGy reported and used for ERs calculation were based on the readings of the main meter. The interview of staff of Dingzihekou 110kV substation also confirmed the aforementioned information. Therefore, the lower accuracy class of backup meter did not impact the calculation of the emission reductions for the period from 18/12/2008 to 20/03/2010.