1) Applicability of methodology
The so called ‘Greenfield plant’ was operating from 2001 on naphtha in Mangalore under GMR Energy Limited. This is evident from GMR group website http://www.gmrgroup.co.in/Energy/GMR_Energy_Limited.html

CEA CO2 Baseline Database for the Indian Power Sector, Ver. 05 also has the entry for this plant as operating on NG + napthta from 8 June 2001. 

http://www.abb.co.in/cawp/seitp202/aab2262a522aeca5c1257790002ca8be.aspx
‘The floating power plant named Tanir Bavi, was earlier located at Mangalore in the state of Karnataka on India’s West coast and has been recently shifted to Kakinada in Andhra Pradesh, on India’s East coast. As the power plant is barge mounted it was easily transported by sea. Tanvir Bavi was earlier using naphtha as fuel and has now converted to gas to make use of the abundant gas resources recently discovered in the East Godavari region of Andhra Pradesh.’

Thus,
1)	methodology selection is wrong – applicability condition 1 of AM0029 requires ‘The project activity is the construction and operation of a new natural gas fired grid-connected electricity generation plant.’ This project plant is only a modification of an existing plant that operated for nine+ years now.

2)	If the plant is just a retrofit, how baseline can be a coal based plant? Was it possible to retrofit this GTs to use coal? This is a ridiculous claim by behalf of PP and consultants

Even continuation of existing scenario is debatable considering the PPA of old naptha based plant had expired and PP had no option but to switch to NG use. None of the power buyers allow naphtha use in present situation. 

http://www.moneycontrol.com/news/business/gmr%92s-gmr-energygmr-power-corporation-fully-operational_368743.html
’GEL, the 220 MW power plant situated at Tanir Bavi, Mangalore, Karnataka, commenced generation of power on 7th June 2001 and supplied power to Govt. of Karnataka till 6th June 2008 as per the Power Purchase Agreement (PPA). The Power plant was non-operational after the expiry of PPA.’

Similarly, there were many other barriers to continue the existing plant on naphtha.
http://www.accessmylibrary.com/article-1G1-61477313/india-escrow-account-judge.html

2) Project cost:  is escalated by multiple times. Following link shows that total project cost (announced as latest as June 2009) was $83.54 million i.e. 4,000 million INR.
http://www.industrialinfo.com/showAbstract.jsp?newsitemID=147789
Whereas PDD has used total project cost of 14,000 million Rs.

http://timesofindia.indiatimes.com/city/bangalore/Tanir-Bavi-generates-power-despite-problems-/articleshow/557139.cms


3) The plant will operate on merchant basis – thus, how cost of generation and comparison is a suitable financial indicator? This revenue is not considered in the investment analysis.