Replacement of Fossil Fuel by Biomass in a Crude Palm Oil (CPO) Refinery at BIDCO’s Thika facility in Kenya
[]
Host party(ies) Kenya
Methodology(ies) AMS-I.C. ver. 18
Standardised Baselines N/A
Estimated annual reductions* 23,827
Start date of first crediting period. 01 Jan 12
Length of first crediting period. 10 years
DOE/AE Carbon Check (India) Private Ltd.
Period for comments 10 Jun 11 - 09 Jul 11
PP(s) for which DOE have a contractual obligation BIDCO Oil Refineries Ltd. (a Private entity)
The operational/applicant entity working on this project has decided to make the Project Design Document (PDD) publicly available directly on the UNFCCC CDM website.
PDD PDD (1090 KB)
Local stakeholder consultation report: N/A
Impact assessment summary: N/A
Submission of comments to the DOE/AE Compilation of submitted inputs:
It is evident from the PDD that the values are consistent and it is definitely forged and cooked up values to show a non CDM project as a CDM project. What is this? DoE to check the Detailed Project Report and Feasibility Report which is submitted to the other agencies and Banks by Project owner and ensure that the values match with the DPR/FR  submitted to DoE also. After careful study of PDD it is found that DPR/FR is in different versions made and submitted with different purposes to different agencies which is totally unacceptable, illegal and unethical. PP/Consultant may show some undertaking letter from bank manager to DoE stating that both DPR’s are same. These kinds of letters should not be accepted and entertained by DoE. While collecting the DPR/FR from banks and other agencies, all DPR/FR pages should be counter signed by Banks and other agencies so that the real DPR/FR given to other parties by the PP/Consultant is same as the one submitted to DOE. In this particular project there is clear cut evidence that DPR/FR values are changed/ fabricated mischievously and intentionally. This must be probed fully. DOE must take a written undertaking from the PP/Consultant about the list of parties to whom this DPR/FR is submitted and for what purposes. Then DOE should cross check with all the parties and confirm that the same DPR/FR is submitted to all the parties correctly without any changes. DOE must not accept any reports and undertakings from PP/Consultant. DOE must make independent evaluation and use totally different parties without informing the PP or Consultant to cross check the facts. DOE to write to the party who prepared the DPR/FR which is submitted to the banks and other agencies and the same is verified against the one submitted to the DOE by PP/Consultant. This project is a fabricated and fake CDM project and must be rejected by the DOE right away. DOE should not support this kind of projects otherwise CDM EB should suspend this DOE for at least one year. 
Submitted by: zhong zhou li

If you carefully read through the PDD it is confirmed that this is not a genuine CDM project at all. What is the exact project cost? The project cost is covering what? The machinery is second hand purchased or fresh and new from an OEM? In either case DOE to check all the quotations, proposals, purchase orders, invoices, way bills, transport bills, proof of payments like bank statements. 
DOE to check with banks by way of written confirmation the amount transacted, to whom the money is paid, when the money is paid, is the party paid is the correct party as shown in the purchase orders. It is very clear that the values, party names, dates are fabricated and misrepresented in this project. DOE should terminate their contract for this project immediately. This is the only way out to protect the value of CDM process. It looks like PP is purchasing second hand or second quality equipment by inflating the purchase order values and invoices. This must be probed thoroughly and real values to taken for additionality calculation. Then I’m sure the additionality is not there at all in this project. How is the base line defined in this project? Base line is hypothetically defined with no proper evidences and proper justification. 
DOE cannot take the base line as suggested by the PDD.  Please note that there are no emissions beyond the real and factual base line. This project definitely qualifies for zero CER’s, not even one CER. DOE cannot assume values and things as giving by this PP. Whatever values are considered throughout the project in all documents including the real DPR (not the one prepared for CDM, the one given to the banks and others), they must be validated, verified and double checked. Do not ask PP for DPR. Ask the parties who have been given DPR by the PP. Get directly from the bank and others by each page of the DPR and Feasibulity report signed. Such document can be considered as a real DPR or FR. This project is genuinely a fabricated, false and misinterpreted project with no base line and additionality.  
Submitted by: alexander

It looks like from the PDD the start date of the project is tampered for sure. This must be verified and let the truth come out. The culprits of forgery and malpractices must be brought to book. Why DOE has taken up such a bad project? Is there any pressure on DOE or some cake offered to DOE? They DOE must terminate this project immediately. DOE to check the offer letters originals and get the same verified in writing from the OEM’s and submitted parties. Where is the OEM supplier agreement original? DOE to check for the same. Is it prepared later with date and amounts changed to suit the project workings? For sure yes. This is not acceptable. 
DOE to check all purchase orders originals with the receiver of purchase orders i.e. the supplier of equipment. This PO confirmation to the DOE must be in writing from a board level person of the equipment supplier to avoid any malpractices and forgery. Then DOE to check for the invoices dates, payment amounts and date of payments made with all original documents and reconfirm with the parties involved and the banks for the accuracy of amounts, dates and parties involved. Same analysis and due diligence work to be repeated for “Notice to Proceed” as written in the case of Purchase order as above. DOE to check all “Notice to Proceed” originals with the receiver of “Notice to Proceed” i.e. the supplier of equipment or Engineering Procurement & Construction Contractor. This “Notice to proceed” and EPC contract confirmation to the DOE must be in writing from a board level person of the equipment supplier and EPC contractor to avoid any malpractices and forgery. Then DOE to check for the invoices dates, payment amounts and date of payments made with all original documents and reconfirm with the parties involved and the banks for the accuracy of amounts, dates and parties involved.
 DOE to check OEM supplier agreements, EPC contractor agreements, “Notice to proceed” letters, and Invoices raised. I’m sure DOE will catch the malpractices happened in this project. All the parties involved in this matter must be brought to justice. DOE must not support this kind of forgeries and malpractices. DOE cannot afford to close their eyes to this kind of malpractices. 
Submitted by: xiangbo yao

If you carefully read through the PDD it is confirmed that this is not a genuine CDM project at all. What is the exact project cost? The project cost is covering what? The machinery is second hand purchased or fresh and new from an OEM? In either case DOE to check all the quotations, proposals, purchase orders, invoices, way bills, transport bills, proof of payments like bank statements. 
DOE to check with banks by way of written confirmation the amount transacted, to whom the money is paid, when the money is paid, is the party paid is the correct party as shown in the purchase orders. It is very clear that the values, party names, dates are fabricated and misrepresented in this project. DOE should terminate their contract for this project immediately. This is the only way out to protect the value of CDM process. It looks like PP is purchasing second hand or second quality equipment by inflating the purchase order values and invoices. This must be probed thoroughly and real values to taken for additionality calculation. Then I’m sure the additionality is not there at all in this project. How is the base line defined in this project? Base line is hypothetically defined with no proper evidences and proper justification. 
DOE cannot take the base line as suggested by the PDD.  Please note that there are no emissions beyond the real and factual base line. This project definitely qualifies for zero CER’s, not even one CER. DOE cannot assume values and things as giving by this PP. whatever values are considered throughout the project in all documents including the real DPR (not the one prepared for CDM, the one given to the banks and others), they must be validated, verified and double checked. Do not ask PP for DPR. Ask the parties who have been given DPR by the PP. Get directly from the bank and others by each page of the DPR and Feasibility report signed. Such document can be considered as a real DPR or FR. This project is genuinely a fabricated, false and misinterpreted project with no base line and additionality.  
Submitted by: sud

Dear Sir, We respectfully submit as below to the board of Directors and Impartiality
Committee of Carbon Check, the DOE for this project.
1) Who are the persons involved in this project? In what way you have ensured that
there is no conflict of interest to you as a DOE and also with the personnel involved
in the validation process in the light of connections between the consultant and
ERPA signatory of this project and you and your employees and contract auditors?
2) Who are the consultants and ERPA signatories? Don’t you have conflict of
interest with them since such CDM consultants or management of ERPA signatories
were your advisors in the past? Is this acceptable as per accreditation norms and
ethical? Please think it over. You say that you had a successful career in military and
have a professional back ground. Having such back ground, is it fair on your part to
do validation of ones projects where in the same party or person has done
consulting and advisory to you in the past? This is totally unfair. Everybody in the
CDM market including accreditation auditors knows that Rambabu and his persons
were advising you directly and indirectly during your accreditation stage with CDM
board. You must terminate these projects right away and bring back some sanity and
reputation to yourself and your company. You are a start-up DOE. By doing this kind
of projects you are doing great mistake. Just check in the CDM market how many
DOE’s are suspended in the past due to Rambabu’s actions and gimmicks. How
many DOE’s he has used in the past for his misadventures and thrown road side? If
you check these facts you will never work with this forgery master. Morally, ethically,
technically and accreditation rules wise you cannot do any validation or verification
work with respect to General Carbon or Rambabu or Care Sustainability or any other
person or entity connected directly or indirectly with any of the directors of General
Carbon Advisory Services Pvt. Ltd or Care Sustainability or General Carbon Pte
Singapore or any General carbon group companies. You must not sign any CDM or
VCS or any other such agreements with this set of people or group of companies.
This particular project is clearly fabricated and cooked up project.No prior
consideration of CDM. All cooked up documentation and forgery. General Carbon
and its team have screwed up Indian CDM business and now you are teaming up
with them to do the same in Africa! This project is not at all a CDM project. There is
no real and continuous action in this project at all. Any real and continuous action
shown by way of agreements with consultants and ERPA signing is just not
acceptable since these are 100% fabricated? Only acceptable alternative as a real
and continuous action is signing with a DOE and payment to them. What is the use
of signing with a DOE? No commitment. PP must have paid to the DOE the advance
amount and published the project for 30 day international stake holder consultation
process. Unless it was webhosted no commitment.By the way, who is the DOE
involved in this process? Is this documentation again arranged and fabricated by
your staff or Conusltants?
3) Who are the auditors and technical experts for this project? In what way
Ravishankar is involved in this project? Ravishankar cannot be involved in this
project in any manner directly or indirectly since he was the immediate past
employee of General carbon who is the consultant and ERPA signatory. As a DOE
you have to ensure that all personnel deployed on this project do their own job
professionally and in a non-partisan way. You cannot put some body’s name in the
reports and get the work done by somebody else. This is not acceptable. You need
to prove this. Ravishankar has been a mole and spy working for Rambabu and
hopping companies one after another after contaminating the systems, working
methods, offices and minds of people working. He takes salary from one company
and works for somebody else. That’s his story for the last several years. He is doing
spying and undercover operation for Rambabu while being in contract with other
companies and taking salary from other companies. Have you checked Ravishankar
and your employee’s antecedents, credentials and certificate’s? If no, do that
immediately before you use them for any audit or non-audit work. If yes, what have
you done with respect to Ravishankar? Have you collected the experience
certificates from his last DOE’s like TUV Nord, RINA and SIRIM India? As I
understand he has fabricated his experience certificates with DOE’s and got in to job
with Sunrise. After coming to know that he has falsely represented his credentials he
was charge sheeted at Sunrise and asked to leave the company. Has he shown you
that charge sheet? How can you hire such persons as employees or contractors?
Have you not collected, checked and validated his documents with the past
employers? Is it not a requirement of personnel qualification process as per UN
guidelines? How can you use a person with no proper experience records and past
behaviour as an auditor or technical expert? Have you assessed in the first place
that Ravishankar is temperamentally fit to be an auditor? What kind of assessment
you have done on Ravishankar? Was he planted in your company by Rambabu to
use your DOE status to his advantage and spoil the whole system? You need to
explain and prove your personnel qualification process in this FVR and other future
FVR’s to show that you have adopted acceptable personnel qualification processes
as per CDM EB guidelines. Ravishankar cannot be participating in any projects
where General Carbon or associated companies are involved in what so ever
manner either directly or indirectly.Ravishankar cannot be used by you for any CDM
validation and verification work unless you establish his proper verified and
confirmed credentials with respect to his qualifications and experience.
4) The whole PDD is wrongly done and technically incorrect. When you have so
many complex fuels being used why no mass and energy balance is missing? Get
the mass and energy balance done and recheck the same pre project and post
project and today’s scenario.
5) Data of the existing boiler, steam generation data and fuel consumption data to be
analysed for period before the installation of this system till to date. The data
pertaining to all this to be verified with the purchase bills, invoices, and payments
made for such bills along with confirmation from bank to that effect. Unless you
check thoroughly these bills and invoices it is of no value. DOE cannot consider the
data given by PP as correct. All details must be verified independently. It does not
look like the project is genuine and no correlation of data.
6) All technical parameters indicated in PDD and documents submitted by PP
related to boiler and all other items need to be checked, validated. All such data to
be cross verified with OEM data, offer letters, purchase orders, invoices, bills,
payment receipts and bank statements.
7) Where are biomass assessment survey reports? All BAS reports since prior to the
date of purchase orders (till to date) need to be checked, validated and cross
verified with the report generator or BAS report consultant. DOE cannot accept the
any BAS reports being done by the PP because they are simply cooked up and
forger documents. DOE to check independently for sufficient availability of biomass
considering the leakage.From how much distance PP is collecting the biomass in
reality? To check and correlate all facts from the BAS reports. Neither there is any
proper availability of biomass, nor PP used biomass as planned in the boiler, nor the
PP never thought of CDM for this project, nor there any additionality in this project.
8) Levelised costs are fabricated to show additionality. The costs are neither realistic
nor practical. DOE to do independent study and establish the facts and proceed with
validation. The costs are cooked up to prove additionality.
9) Efficiency of new boilers mentioned is wrong and false figures. DOE to investigate
all the factors and figures related to the same with request for quotations, offer
letters, purchase orders, invoices, bills, receipts, gate passes, and communication
with banks. The efficiency of boilers should have been at least 7% more than what
is mentioned.
10) Calorific values mentioned are wrong and fake figures projected without any
basis just to prove project additionality. How did PP arrive at the Calorific value while
using multiple fuels? Where are the data, values and calculations? Where did they
get this data? Is the source acceptable? Is the data reliable as on today in the light of
what happened with CV values in the past duration of boiler operation? CV values
are tampered just to show additionality where as there is no additionality in this
project at all.
11) DOE must re webhost this project PDD since all input parameters and
assumptions are not clear, concealed and unavailable to make further comments by
the genuine stake holders. By not re webhosting this PDD again, if the DOE
continues with the validation work then it can be concluded that DOE is indulging in
malpractices by conniving with the consultants, ERPA buyers and PP.
12) Same group of companies putting projects in various places and at some places
claiming LDC benefits and privileges to claim additionality when there is no
additionality in any of the group projects is just not acceptable. DOE should not
accept this approach. The PDD has to be re webhosted.
13) Cost of biomass mentioned is not realistic. The cost of biomass is inflated to
increase the levelized cost of generation. On what basis PP has decided the cost?
DOE to check, validate, confirm with independent sources and also similar projects
in the vicinity and government sources.
14) Specific energy consumption of biomass value is not realistic. It is a fake figure
without any basis. How did PP arrive at this figure in the light of fuels used? What
has been the historic data in real terms?
15) PDD shows project emissions as zero. On what basis PP has taken zero? What
about auxiliary consumption? What about transport emissions? No calculations?
What has really happened after the boiler started operations? What fuels and what
quantities PP used and other datas?
16) Net calorific values are fake and without any basis. For every fuel and for every
purchase does the PP have all relevant records which correlate to total purchases?
All past records to be checked by DOE. Do the figures tally with what PDD says?
17) Is PP really using biomass? If yes what amount till to date? Is it tallying with the
production and operating figures? DOE to thoroughly check Production data, factory
output, bio mass consumption and co-relate with each other along with other
parameters. DOE to verify with original documents and cross verify. This project
looks to be a 100% fake CDM project.
18) Why even after five years of issuing purchase order host country approval is not
obtained. When was host country approval applied? What is the status now? Why
delay? It is true and remain so that CDM was never considered for this project and
this project was never and ever a CDM project.
Submitted by: shan

Dear Sir, We respectfully submit as below to the board of Directors and Impartiality
Committee of Carbon Check, the DOE for this project.
1) Who are the persons involved in this project? In what way you have ensured that
there is no conflict of interest to you as a DOE and also with the personnel involved
in the validation process in the light of connections between the consultant and
ERPA signatory of this project and you and your employees and contract auditors?
2) Who are the consultants and ERPA signatories? Don’t you have conflict of
interest with them since such CDM consultants or management of ERPA signatories
were your advisors in the past? Is this acceptable as per accreditation norms and
ethical? Please think it over. You say that you had a successful career in military and
have a professional back ground. Having such back ground, is it fair on your part to
do validation of ones projects where in the same party or person has done
consulting and advisory to you in the past? This is totally unfair. Everybody in the
CDM market including accreditation auditors knows that Rambabu and his persons
were advising you directly and indirectly during your accreditation stage with CDM
board. You must terminate these projects right away and bring back some sanity and
reputation to yourself and your company. You are a start-up DOE. By doing this kind
of projects you are doing great mistake. Just check in the CDM market how many
DOE’s are suspended in the past due to Rambabu’s actions and gimmicks. How
many DOE’s he has used in the past for his misadventures and thrown road side? If
you check these facts you will never work with this forgery master. Morally, ethically,
technically and accreditation rules wise you cannot do any validation or verification
work with respect to General Carbon or Rambabu or Care Sustainability or any other
person or entity connected directly or indirectly with any of the directors of General
Carbon Advisory Services Pvt. Ltd or Care Sustainability or General Carbon Pte
Singapore or any General carbon group companies. You must not sign any CDM or
VCS or any other such agreements with this set of people or group of companies.
This particular project is clearly fabricated and cooked up project.No prior
consideration of CDM. All cooked up documentation and forgery. General Carbon
and its team have screwed up Indian CDM business and now you are teaming up
with them to do the same in Africa! This project is not at all a CDM project. There is
no real and continuous action in this project at all. Any real and continuous action
shown by way of agreements with consultants and ERPA signing is just not
acceptable since these are 100% fabricated? Only acceptable alternative as a real
and continuous action is signing with a DOE and payment to them. What is the use
of signing with a DOE? No commitment. PP must have paid to the DOE the advance
amount and published the project for 30 day international stake holder consultation
process. Unless it was webhosted no commitment.By the way, who is the DOE
involved in this process? Is this documentation again arranged and fabricated by
your staff or Conusltants?
3) Who are the auditors and technical experts for this project? In what way
Ravishankar is involved in this project? Ravishankar cannot be involved in this
project in any manner directly or indirectly since he was the immediate past
employee of General carbon who is the consultant and ERPA signatory. As a DOE
you have to ensure that all personnel deployed on this project do their own job
professionally and in a non-partisan way. You cannot put some body’s name in the
reports and get the work done by somebody else. This is not acceptable. You need
to prove this. Ravishankar has been a mole and spy working for Rambabu and
hopping companies one after another after contaminating the systems, working
methods, offices and minds of people working. He takes salary from one company
and works for somebody else. That’s his story for the last several years. He is doing
spying and undercover operation for Rambabu while being in contract with other
companies and taking salary from other companies. Have you checked Ravishankar
and your employee’s antecedents, credentials and certificate’s? If no, do that
immediately before you use them for any audit or non-audit work. If yes, what have
you done with respect to Ravishankar? Have you collected the experience
certificates from his last DOE’s like TUV Nord, RINA and SIRIM India? As I
understand he has fabricated his experience certificates with DOE’s and got in to job
with Sunrise. After coming to know that he has falsely represented his credentials he
was charge sheeted at Sunrise and asked to leave the company. Has he shown you
that charge sheet? How can you hire such persons as employees or contractors?
Have you not collected, checked and validated his documents with the past
employers? Is it not a requirement of personnel qualification process as per UN
guidelines? How can you use a person with no proper experience records and past
behaviour as an auditor or technical expert? Have you assessed in the first place
that Ravishankar is temperamentally fit to be an auditor? What kind of assessment
you have done on Ravishankar? Was he planted in your company by Rambabu to
use your DOE status to his advantage and spoil the whole system? You need to
explain and prove your personnel qualification process in this FVR and other future
FVR’s to show that you have adopted acceptable personnel qualification processes
as per CDM EB guidelines. Ravishankar cannot be participating in any projects
where General Carbon or associated companies are involved in what so ever
manner either directly or indirectly.Ravishankar cannot be used by you for any CDM
validation and verification work unless you establish his proper verified and
confirmed credentials with respect to his qualifications and experience.
4) The whole PDD is wrongly done and technically incorrect. When you have so
many complex fuels being used why no mass and energy balance is missing? Get
the mass and energy balance done and recheck the same pre project and post
project and today’s scenario.
5) Data of the existing boiler, steam generation data and fuel consumption data to be
analysed for period before the installation of this system till to date. The data
pertaining to all this to be verified with the purchase bills, invoices, and payments
made for such bills along with confirmation from bank to that effect. Unless you
check thoroughly these bills and invoices it is of no value. DOE cannot consider the
data given by PP as correct. All details must be verified independently. It does not
look like the project is genuine and no correlation of data.
6) All technical parameters indicated in PDD and documents submitted by PP
related to boiler and all other items need to be checked, validated. All such data to
be cross verified with OEM data, offer letters, purchase orders, invoices, bills,
payment receipts and bank statements.
7) Where are biomass assessment survey reports? All BAS reports since prior to the
date of purchase orders (till to date) need to be checked, validated and cross
verified with the report generator or BAS report consultant. DOE cannot accept the
any BAS reports being done by the PP because they are simply cooked up and
forger documents. DOE to check independently for sufficient availability of biomass
considering the leakage.From how much distance PP is collecting the biomass in
reality? To check and correlate all facts from the BAS reports. Neither there is any
proper availability of biomass, nor PP used biomass as planned in the boiler, nor the
PP never thought of CDM for this project, nor there any additionality in this project.
8) Levelised costs are fabricated to show additionality. The costs are neither realistic
nor practical. DOE to do independent study and establish the facts and proceed with
validation. The costs are cooked up to prove additionality.
9) Efficiency of new boilers mentioned is wrong and false figures. DOE to investigate
all the factors and figures related to the same with request for quotations, offer
letters, purchase orders, invoices, bills, receipts, gate passes, and communication
with banks. The efficiency of boilers should have been at least 7% more than what
is mentioned.
10) Calorific values mentioned are wrong and fake figures projected without any
basis just to prove project additionality. How did PP arrive at the Calorific value while
using multiple fuels? Where are the data, values and calculations? Where did they
get this data? Is the source acceptable? Is the data reliable as on today in the light of
what happened with CV values in the past duration of boiler operation? CV values
are tampered just to show additionality where as there is no additionality in this
project at all.
11) DOE must re webhost this project PDD since all input parameters and
assumptions are not clear, concealed and unavailable to make further comments by
the genuine stake holders. By not re webhosting this PDD again, if the DOE
continues with the validation work then it can be concluded that DOE is indulging in
malpractices by conniving with the consultants, ERPA buyers and PP.
12) Same group of companies putting projects in various places and at some places
claiming LDC benefits and privileges to claim additionality when there is no
additionality in any of the group projects is just not acceptable. DOE should not
accept this approach. The PDD has to be re webhosted.
13) Cost of biomass mentioned is not realistic. The cost of biomass is inflated to
increase the levelized cost of generation. On what basis PP has decided the cost?
DOE to check, validate, confirm with independent sources and also similar projects
in the vicinity and government sources.
14) Specific energy consumption of biomass value is not realistic. It is a fake figure
without any basis. How did PP arrive at this figure in the light of fuels used? What
has been the historic data in real terms?
15) PDD shows project emissions as zero. On what basis PP has taken zero? What
about auxiliary consumption? What about transport emissions? No calculations?
What has really happened after the boiler started operations? What fuels and what
quantities PP used and other datas?
16) Net calorific values are fake and without any basis. For every fuel and for every
purchase does the PP have all relevant records which correlate to total purchases?
All past records to be checked by DOE. Do the figures tally with what PDD says?
17) Is PP really using biomass? If yes what amount till to date? Is it tallying with the
production and operating figures? DOE to thoroughly check Production data, factory
output, bio mass consumption and co-relate with each other along with other
parameters. DOE to verify with original documents and cross verify. This project
looks to be a 100% fake CDM project.
18) Why even after five years of issuing purchase order host country approval is not
obtained. When was host country approval applied? What is the status now? Why
delay? It is true and remain so that CDM was never considered for this project and
this project was never and ever a CDM project.
Submitted by: shan

If you carefully read through the PDD it is confirmed that this is not a genuine CDM project at all. What is the exact project cost? The project cost is covering what? The machinery is second hand purchased or fresh and new from an OEM? In either case DOE to check all the quotations, proposals, purchase orders, invoices, way bills, transport bills, proof of payments like bank statements. 
DOE to check with banks by way of written confirmation the amount transacted, to whom the money is paid, when the money is paid, is the party paid is the correct party as shown in the purchase orders. It is very clear that the values, party names, dates are fabricated and misrepresented in this project. DOE should terminate their contract for this project immediately. This is the only way out to protect the value of CDM process. It looks like PP is purchasing second hand or second quality equipment by inflating the purchase order values and invoices. This must be probed thoroughly and real values to taken for additionality calculation. Then I’m sure the additionality is not there at all in this project. How is the base line defined in this project? Base line is hypothetically defined with no proper evidences and proper justification. 
DOE cannot take the base line as suggested by the PDD.  Please note that there are no emissions beyond the real and factual base line. This project definitely qualifies for zero CER’s, not even one CER. DOE cannot assume values and things as giving by this PP. Whatever values are considered throughout the project in all documents including the real DPR (not the one prepared for CDM, the one given to the banks and others), they must be validated, verified and double checked. Do not ask PP for DPR. Ask the parties who have been given DPR by the PP. Get directly from the bank and others by each page of the DPR and Feasibulity report signed. Such document can be considered as a real DPR or FR. This project is genuinely a fabricated, false and misinterpreted project with no base line and additionality.  
Submitted by: sud

•	Careful study must be done so that the DPR/FR is not in different versions made and submitted with different purposes to different agencies, which is totally unacceptable, illegal and unethical. 
•	Project owner should show some undertaking letter from bank manager to DoE stating that both DPR’s are same. These kinds of letters should not be accepted and entertained by DoE at face value, but must be checked independently. While collecting the DPR/FR from banks and other agencies, all DPR/FR pages should be counter signed by Banks and other agencies so that the real DPR/FR given to other parties by the PP/Consultant is same as the one submitted to DOE. 
•	DPR/FR values must be probed fully. DOE must take a written undertaking from the PP/Consultant about the list of parties to whom this DPR/FR is submitted and for what purposes. Then DOE should cross check with all the parties and confirm that the same DPR/FR is submitted to all the parties correctly without any changes. DOE must not accept any reports and undertakings from PP/Consultant. DOE must make independent evaluation and use totally different parties without informing the PP or Consultant to cross check the facts. 
•	DOE to write to the party who prepared the DPR/FR which is submitted to the banks and other agencies and the same is verified against the one submitted to the DOE by PP/Consultant. 
•	DOE must not entertain this project any more if found the DPR/FR is tamprered with at any point in time. PP can not give different DPR’s and FR’s. They must submit only the one given to Banks and other agencies while obtaining loans and decision making time. 
•	DOE to ensure that the PDD values are consistent and ensure that the CDM project is a genuine project
•	DoE to check the Detailed Project Report and Feasibility Report which is submitted to the other agencies and Banks by Project owner and ensure that the values match with the DPR/FR  submitted to DoE also. 
•	Has the PP considered the CDM revenues while envisaging the project? Without CDM the project was not viable, is it right? This project is having a debt component? Then how bankers or lenders gave the loan? Have the bankers or lenders considered the CDM revenues while agreeing to give loan to this projects? If not this project should be rejected right away by DOE by terminating the contract forthwith. If yes, where is the proof? What is the date of the evidence document from bank? Is this document printed now a days or earlier. DOE to independently check the same. If the document is  available from Bank it must be checked from all angles so that it is genuine and not forged and date changed by putting back dated. This is normally done, DOE to be aware of this please. Please check the communication the PP had during that time with banks, emails and postal receipts and the weights and dates mentioned on the receipts. Do not believe in courier bills and receipts since these can be cooked up easily. Insist on government owned postal service receipts only. If the project is fully equity project then on what basis the PP has invested full equity in to the project while considering the CDM revenue? DOE to check the same in detail and bring out the facts. Is there any past record of this PP to invest or not to invest at returns what he is talking about in this project? Proper evidences must be reviewed and digged out by the DOE and take decision on the project based on established facts. Do not ask documents from PP, DOE to collect the same from different sources to do independent evaluation. 

•	Is the project equipment purchased second hand equipment or sourced from cheap foreign sources? If yes, the issue must be probed by DOE since invoices will invariably be inflated and forged. Total project costs mentioned by PP will not be the same as originals. Hence no additionality. These facts must be probed in full by DOE by checking all documents and money transactions along with bank statements and certified accounts by a legally acceptable financial analyst. 
•	How is the base line defined in this project? Is Base line hypothetically defined with no proper evidences and proper justification? In such case, DOE cannot take the base line as suggested by the PDD.  Please check that there are real emission reductions beyond the real and factual base line. It may so happen that this project qualifies for no CER’s. DOE cannot assume values and things as giving by this PP. Whatever values are considered throughout the project in all documents including the real DPR (not the one prepared for CDM, the one given to the banks and others), they must be validated, verified and double checked. Do not ask PP for DPR. Ask the parties who have been given DPR by the PP. Get directly from the bank and others by each page of the DPR and Feasibility report signed. Such document can be considered as a real DPR or FR. UNFCCC CDM process cannot be degraded by fabricating and misinterpreting the project base line and additionality.  

•	From DOE side which auditor has done marketing and business development for acquiring this business of validating this project? With whom he or she was co-ordinating at PP or CER buyer? The same person who has done the marketing and business development to acquire the business do validation or participate in any manner what so ever in the validation process? One cannot do like that. It is against the accreditation rules and norms followed since ages. DOE should send auditors from different offices or countries to do this validation audit. DOE must take care of impartiality and accreditation rules. Due to the targets set by the DOE managements auditors are doing marketing and meeting clients and giving promises that the project will be taken care. Is it acceptable and fair? This must be stopped. No auditor should do marketing. Only non-auditing staff should do marketing. DOE to ensure the same please. 


•	If applicable only: Is these machines, equipment was a part of any bundle of CDM activity envisaged and developed earlier. DOE to check the same through independent sources also. Once some bundles are non-additional and getting negative validation from a DOE, PP is rolling out the same project as an individual project which is not a CDM project at all. DOE to verify the same from independent sources and also take undertaking in the form of an affidavit from the PP’s that any misrepresentation or false statement with respect this would attract strict legal action from UNFCCC and DOE. Furthermore the registered project must be de-registered in case of any future findings contradicting the submissions made by the project owner.  

•	DOE to be more careful so that this is a genuine CDM project. What is the exact project cost? The project cost is covering what? Each value considered must be validated with proof. The machinery is second hand purchased or fresh and new from an OEM? In either case DOE to check all the quotations, proposals, purchase orders, invoices, way bills, transport bills, proof of payments like bank statements. DOE to check with banks by way of written confirmation the amount transacted, to whom the money is paid, when the money is paid, is the party paid is the correct party as shown in the purchase orders. It may so happen that the values, party names, dates are fabricated and misrepresented in this project. DOE should terminate their contract for this project immediately. This is the only way out to protect the value of CDM process. If the PP is purchasing second hand or second quality equipment and inflating the purchase order values and invoices, this must be probed thoroughly and real values to taken for additionality calculation. Then I’m sure the additionality is not there at all in such a situation.

Submitted by: sud

It is the responsibility of DOE to conduct proper due diligence and contract review before signing any contract. Now DOE to explain what it has done this project case. Why a DOE should work this kind of cooked up and fake CDM projects. How many genuine projects this consultant has done till to date? This consultant is responsible for corrupting and spoiling the whole CDM business in India. Why this consultant is not working like any other consultant in the market? Why he is web hosting only projects which were rejected, with drawn, forged (documents changed and forged) and fully problematic projects? 
The Managing Director/CEO (Rambabu) of this consulting company called General Carbon/General carbon pte Ltd. is fully responsible for spoiling the CDM consulting business in India. He is totally unprofessional and unethical. He never did any work in a professional and ethical manner in his working. He started his own consulting company when he was working with PWC by violating the contract with PWC. Then later on he started CantorCO2e in India. They gave all sorts of wrong promises to clients and finally many of the clients are disappointed and lost money who signed with CantorCO2e. While leaving the CantorCO2e while working in CantorCO2e itself he promoted his own company General Carbon Advisory Services Pvt. Ltd and made the clients sign with General Carbon. 
What is this? After he left CantorCO2e employment he took away most of the projects and clients of CantorCO2e by violating all his contract terms, employment conditions and established business ethics. CantorCO2e is pursuing this person legally and he should not be left free. If he thinks he is intelligent he should develop businesses on his own and not rob like this. It is shame that project owners and DOE’s are working with such illegal, unethical, unprofessional and cheating companies and individuals.
General Carbon/ General carbon pte Ltd. is intentionally quote very low to kill completion and also the CDM business as a whole. Only they wish to be in the market, nobody else should work as a consultant in the market. They should explain why it is so. 
 Every project owner and DOE whoever is working with General Carbon should introspect, understand the implications and stop working with General Carbon. General Carbon/ General carbon pte Ltd. is built on totally wrong foundation with robbed clients, wrong promises, cheating the system, deceiving, corrupting the full CDM business overall. One should be ashamed of working with General Carbon in what so ever manner. He spoiled old DOE’s and the system by bribing the DOE auditors and others in the system.
 Every new and old DOE entered in the market was misused by him somehow. How long he wants to spoil CDM business and earn disrepute permanently? What is he finally going to achieve? Some money and bad name for ever? DOE to seek answers from General Carbon/ General carbon pte Ltd. on these points and take appropriate actions to save the project owners and CDM business fraternity from this evil person and evil company. Never believe the documents given by General Carbon, DOE must cross check all of them. General Carbon is the forgery masters. 
DOE to be careful in undertaking any jobs referred by this kind of consulting companies, instead they should not take up the job at all in the best interest of CDM business and to protect their interests and reputation. 
Submitted by: Kushwanth Sing

It is the responsibility of DOE to conduct proper due diligence and contract review before signing any contract. Now DOE to explain what it has done this project case. Why a DOE should work this kind of cooked up and fake CDM projects. How many genuine projects this consultant has done till to date? This consultant is responsible for corrupting and spoiling the whole CDM business in India. Why this consultant is not working like any other consultant in the market? Why he is web hosting only projects which were rejected, with drawn, forged (documents changed and forged) and fully problematic projects? 
The Managing Director/CEO (Rambabu) of this consulting company called General Carbon/General carbon pte Ltd. is fully responsible for spoiling the CDM consulting business in India. He is totally unprofessional and unethical. He never did any work in a professional and ethical manner in his working. He started his own consulting company when he was working with PWC by violating the contract with PWC. Then later on he started CantorCO2e in India. They gave all sorts of wrong promises to clients and finally many of the clients are disappointed and lost money who signed with CantorCO2e. While leaving the CantorCO2e while working in CantorCO2e itself he promoted his own company General Carbon Advisory Services Pvt. Ltd and made the clients sign with General Carbon. 
What is this? After he left CantorCO2e employment he took away most of the projects and clients of CantorCO2e by violating all his contract terms, employment conditions and established business ethics. CantorCO2e is pursuing this person legally and he should not be left free. If he thinks he is intelligent he should develop businesses on his own and not rob like this. It is shame that project owners and DOE’s are working with such illegal, unethical, unprofessional and cheating companies and individuals.
General Carbon/ General carbon pte Ltd. is intentionally quote very low to kill completion and also the CDM business as a whole. Only they wish to be in the market, nobody else should work as a consultant in the market. They should explain why it is so. 
 Every project owner and DOE whoever is working with General Carbon should introspect, understand the implications and stop working with General Carbon. General Carbon/ General carbon pte Ltd. is built on totally wrong foundation with robbed clients, wrong promises, cheating the system, deceiving, corrupting the full CDM business overall. One should be ashamed of working with General Carbon in what so ever manner. He spoiled old DOE’s and the system by bribing the DOE auditors and others in the system.
 Every new and old DOE entered in the market was misused by him somehow. How long he wants to spoil CDM business and earn disrepute permanently? What is he finally going to achieve? Some money and bad name for ever? DOE to seek answers from General Carbon/ General carbon pte Ltd. on these points and take appropriate actions to save the project owners and CDM business fraternity from this evil person and evil company. Never believe the documents given by General Carbon, DOE must cross check all of them. General Carbon is the forgery masters. 
DOE to be careful in undertaking any jobs referred by this kind of consulting companies, instead they should not take up the job at all in the best interest of CDM business and to protect their interests and reputation. 
Submitted by: Kushwanth Sing

Carbon check contract review form people & Carbon check Auditors & management should explain what kind of due diligence they have undertaken to take up this project. The DOE must understand that the General Carbon is in the habit of hiring new DOE’s for bad and cooked up CDM projects and pressurizing the DOE’s to give the positive validation report by promising the future business to them. This has been done in the past by General Carbon with RINA & SIRIM. Now it is Carbon check. 
2.	Carbon check should understand that General Carbon Director’s especially Ram Babu was the reason for some DOE’s suspension in the past. Now, this will happen to Carbon check also if they do not do proper due diligence before taking a project.
3.	Why General Carbon is web hosting only bad projects? Why can’t they do business like any other Consultants in the market, this is nothing but cheating the system & blackmailing DOE’s, employees of DOE’s & Project owners.
4.	If any DOE’s working more with Ram Babu means he will corrupt the employees & management and teach all sort of dirty things & finally he will ensure that DOE is screwed up.
Submitted by: nancy johan

Carbon check contract review form people & Carbon check Auditors & management should explain what kind of due diligence they have undertaken to take up this project. The DOE must understand that the General Carbon is in the habit of hiring new DOE’s for bad and cooked up CDM projects and pressurizing the DOE’s to give the positive validation report by promising the future business to them. This has been done in the past by General Carbon with RINA & SIRIM. Now it is Carbon check. 
2.	Carbon check should understand that General Carbon Director’s especially Ram Babu was the reason for some DOE’s suspension in the past. Now, this will happen to Carbon check also if they do not do proper due diligence before taking a project.
3.	Why General Carbon is web hosting only bad projects? Why can’t they do business like any other Consultants in the market, this is nothing but cheating the system & blackmailing DOE’s, employees of DOE’s & Project owners.
4.	If any DOE’s working more with Ram Babu means he will corrupt the employees & management and teach all sort of dirty things & finally he will ensure that DOE is screwed up.
Submitted by: nancy johan


The comment period is over.
* Emission reductions in metric tonnes of CO2 equivalent per annum that are based on the estimates provided by the project participants in unvalidated PDDs