Applicability of the methodology: (this is the 3rd project i am commenting, still how can you go for new projects if this meth is not applicable. ask a clarification to UNFCCC first)

Para 4 of the ACM0013 version 4 demands “data on the fuel consumption of recently constructed power plants are available”. Adani and their consultants seem ignorant and least bothered to fulfill the requirements under ACM0013 version 4. However what is surprising is that the DOE has not bothered to even look whether the project is applicable for this methodology or not. 
ACM0013 version 4 page 11 under FCjx and FCnv under the row of “any comment” it clearly states that the “The DOE should verify that the data on fuel consumption is based on first-hand measurements of the actual quantity of fuel consumed by each power plant, and is not based on second-hand calculations or estimations”. Do the PP/consultant or the DOE even understand the implications and requirement of this special addition in version 4? The meaning of this statement is, you cannot arrive/estimate/compute the fuel consumption. It has to be through direct measurement of actual quantity of the respective units and not the entire power plant. Having known the open fact that none of the baseline plants (NTPC, CEA, CERC) measure/monitor the fuel consumption at unit level and the data is not available. that is the reason you are estimating which is not correct and not inline. 
Why has DOE not asked a deviation/clarifications/revision before web-hosting even if the requirements of the methodology are publicly displayed. This displays sheer incompetency of the DOE. Hence I would like to state the project is not applicable under this methodology. Though it is proven now that the project is not applicable under this methodology, I hope DOE does not proceed with the validation; ignoring my comments. But be warned that CDM EB and members are very well aware of the Indian scenario, so Adani you cannot escape here. 

Ramesh Gupta
CC Cell, Gurgaon

1.	In India, according to publically available reports of manufacturers of boiler units 660 MW units are only available with supercritical and ultra-supercritical technology, adding up to precisely 2640 MW for 4 units are used. In this context initial plan itself is implementation of supercritical power plant so the selection of sub-critical as baseline is not correct. Pls. clarify. 
2.	why PP not documented the technical specifications of boiler, turbine and balance of plant which is the requirements of CDM requirements.
3.	DOE has to validate the tender document and proposal by submitted by the PP for the project which will reveal truth whether subcritical system was proposed initially and later changed to supercritical system due to environmental benefits of the latter.   
4.	Traditionally, for a larger project like this, Government will allow investors 10% of power to sell to private parties (i.e Merchant sale). But PDD does not speak about this aspect. How DOE will ascertain this merchant power in the addtionality argument claimed by PP. What is the contract agreement between the concerned parties? It may be available in the tender document which DOE should validate.  PP conveniently suppresses the facts.
5.	PP fails to demonstrate how sub critical system has been considered as only realistic alternative in the PDD. It seems from the hindsight that PP decided to take subcritical as baseline and arrived at the plausible alternatives thereby leaving conveniently other renewable energy sources. PDD does not speak about whether the project is required for peak load or for base load. Only tender document will tell the fact.
6.	. Why the date of investment decision and chronology of events are not documented in the PDD. How DOE has allowed this. It seems that it is deliberate action by PP which is well supported by DOE. It is not expected of a well reputed DOE.  The PDD fails to provide data during investment decision date to reject imported electricity as a project alternative. Since date of investment decision is not stated explicitly, it is difficult to reject the option of import of electricity.  
7.	While calculating levelised tariff all input values should be taken at the investment decision but Project investors have not provided the source and it is not clear that these values were taken at the time of investment decision. DOE has the responsibility to check the authenticity of values and justification.
8.	Variation of parameters should be done only for the proposed project and not for baseline project. The sensitivity analysis of the PP is absolutely absurd. If it is done only for proposed project, the Levelised cost of the proposed proejct goes below that of baseline levelised cost. So the project is not additional. DOE has to validate carefully.
9.	The investment analysis is neither transparent nor reproducible and therefore does not support the selection of subcritical coal-fired power plants as the Project’s baseline. Furthermore, project participants fail to include required elements under ACM0013, such as calculation of the levelized cost of electricity and the tariff rate used to calculate the Project’s internal rate of return.
10.	. Supercritical PP has been proved less attractive than other alternatives. But addtionality is based on whether the proposed project is not viable without CDM revenue. This aspect is not argued at all. How DOE has allowed this. Pls. clarify.  
11.	Common practice analysis: PP fails to establish how many supercritical PP is running in India and then they should argue about their viability. Their argument misleading that the project is of first of this magnitude which is wrong as far as my little knowledge is concerned. The PDD does not fulfill the requirements of the common practice analysis, which compares the proposed Project to similar activities occurring without CDM funds in order to check the credibility of additionality claims. The project participants do not substantiate their claim that construction of supercritical coal plants is not a common practice in India.
12.	While PP argument that not many supercritical PP available that is operational in India, they seem to hide the fact that the majority of new coalfired power plants are expected to use this technology. News reports suggest that at least 35 supercritical plants, in addition to the proposed Project, are at various stages of planning and implementation in India. The PP may argue at the later stages that based on project information listed on the CDM website to argue that all other supercritical coal plants( may be 4 or 5 )  are in CDM development. DOE has to validate
13.	. Moreover, the PDD conveniently suppress the facts of incentives for plant load factor. PP has to explain how these incentives affected the baseline scenarios and technology choice.
14.	PDD does not clearly describe the stakeholders involved in Project or the information provided to them. The PDD mentions “identified stakeholders,” but does not detail which of these stakeholders actually participated in the process. The PDD does not describe the information provided to stakeholders with sufficient clarity, such as whether adverse environmental impacts were described along with the benefits that were mentioned.
15.	The PDD does not explain about identified training, monitoring and maintenance as per the Technology requirements for contractors / engineers by the client. There is no mention of field quality Assurance systems & procedures that are available at site, field quality plans and their approval.

1.Recently, super-critical technology in coal-based energy plants is under the scanner by the UNFCCC for not defining the criteria of ‘additionality’. How does this project differ from the methodologies done prior to review of all such projects?
2.As this is a large-scale project, please specify the number of people who shall be employed as per the parameters of – skilled, unskilled, contractual and daily-wage workers from Dahej (Taluka) and Gujarat (State).The Government of Gujarat (Res.No 1095-644-2(2) of Sachivalay, Gandhinagar of 31st March, 1995) has a notification to provide employment to 85% of people employed of total number of employees from the State of Gujarat. Has this been duly considered?
3.Please elaborate how this project shall “promote capacity building and development of new skills and knowledge base in the thermal power sector” as mentioned in the criteria for achieving technological sustainability. 
4.Who are the CDM consultants for the project? What were the services areas that they covered for this project?
5.When was the public consultation held? Date, time and venue should be specified. Which newspapers (National and Regional) carried out a Public Notice for such consultation?
6.The list of stakeholders present at the consultation has not been provided in the PDD.
7.Did the Public Consultation include a discussion on the EIA Report prepared for the project with the villagers? Were they given a copy of the document in their local language? (Gujarati)
8.Did the Public Consultation include a representative of the State Government (Department of Environment and Forests) or the Gujarat Pollution Control Board?
9.The PDD consists of a table that shall evaluate the money transactions dedicated for 2% of the CERs generated – but does not explain what work shall be undertaken for improving the conditions of the local people. Has there been a plan of CSR activities that shall be undertaken? If yes, please elaborate and justify.
10.Please mention the area, and type of land acquired for the project site. Does it include grazing land and agricultural land that has been diverted for this purpose?
11.Finally, please extend the period for Public comments until the Final EIA and EMP has been approved and the PDD has been revised. This document conceals information therein and we thus unable to analyse upon basic indicators until such information is furnished. 

We would like to add a comment in furtherance of those we have raised earlier:
It is known that this project is coming up in a Notified industrial area (GIDC) where Environment Public Hearings are not required for industrial projects. However, it is approx 64 hectares of Grazing land that has been seized from the Panchayat (Local Government) common grounds, that cause a loss in the livelihoods of people and access to common resources including a water body and easementary rights of way.
Moreover, this project has violated the provisions of the EIA Notification, 2006 through a variety of legal loopholes. 
These concerns must be evaluated before approving that CDM status of such projects, else it shall defeat the purpose of an inclusive and transparent means of attaining Sustainable Development