Hydro power project by Sneha Kinetic Power Projects Private Limited
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Host party(ies) India
Methodology(ies) ACM0002 ver. 12
Standardised Baselines N/A
Estimated annual reductions* 482,783
Start date of first crediting period. 01 Apr 14
Length of first crediting period. 7 years
DOE/AE DNV-CUK
Period for comments 02 Feb 12 - 02 Mar 12
PP(s) for which DOE have a contractual obligation Sneha Kinetic Power Projects Private Limited.
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 (506 KB)
Local stakeholder consultation report: N/A
Impact assessment summary: N/A
Submission of comments to the DOE/AE Compilation of submitted inputs:
----Project is not additional, as the chronology followed is not right.
----recheck Power density calculation
----sustainability issues are not addressed properly.
----Local people are severly effected by the project
-----There are various competitive bidders for the project as the project is highly viable.
-----We lost in bidding as the Sneha project Developers are good in Convincing the government and get license
-----Project was allotted long back with a different capacity, later it was enhanced because of the financial viability
----PPA should be reviewed, PTC never does PPA for such a low cost. I will try to get it from my own sources before RFR stage.
----Annual generation values are estimated wrongly.
---overload capacity of turbines, generators are not clear
----There is a saying in Sikkim "Raju gari Modda" which means Project is full viable and project is non additional as the project cost is not written correctly.
 
Submitted by: Dhenge Laje

Comment (8956 bytes) submitted by: Obama the Hero on behalf of Kundeu

1.	Sustainability issues not clear
2.	MAT value is wrong
3.	Who prepared the DPR?
4.	Tariff is not correct
5.	Fake project –actual PPA executed to be verified by DOE (DNV)
6.	DNV is very good name – DNV shall verify documents strictly
7.	PPA is with third party as Sikkim govt is not doing PPA.
8.	Average selling price for third party is more than Rs 6.00/unit in last 2 years in India
9.	Is Sneha kinetic project applying for REC?
10.	IS the power sold to/through third party?
11.	If the power is sold at Rs 2.72/ kWh, then sneha kinetic team is eligible for REC (Less than preferential tariff) – DOE shall check the actual PPA.
12.	During Verification should also check all the parameters
13.	 If the power is sold @ Rs 2.72/kWh to third party then sneha kinetic team is eligible for REC
14.	Sell Power through Manikaran Pwer (Leading power trading company in North India
Submitted by: Obama the Hero

17.	Re webhost the PDD
18.	2 % CERs sharing to be in monitoring plan.
19.	I can see the name of Mr Raju Tirumala (Managing Director) in PDD, Mr Raju is requested to openly discuss with DOE and save the Sikkim state.
a.	We, Sikkim people life is in your hands, stop corruption and fake projects.
20.	Project was an allotted on competitive bidding 
21.	EIA report not discussed 
22.	Effect to floura and fauna not discussed
23.	Tariff is not clear (PPA is never on levilised tariff arrived by DPR consultant)
24.	Escalation in tariff is not clear
25.	Fisheries losing – species loss is not clear
26.	Stake holders meeting not conducted
27.	Stake holders comments are not clear
28.	Sustainability is not addressed properly
29.	GO allotment date is not there
30.	We, Sikkim People are not get any employment
31.	Local employment not clear
32.	Technology is not clear
33.	Commissioning date not clear
34.	Incentive received from MNRE per MW is not discussed (for hydro projects nearly 1.2 Cr/MW and Rs 20 Lakhs/MW as subsidy) – Values may be rechecked again
35.	O&M not discussed /clear
36.	CDM start date not clear
Submitted by: Obama the Hero

1.	Sustainability issues not clear
2.	MAT value is wrong
3.	Who prepared the DPR?
4.	Tariff is not correct
5.	Fake project –actual PPA executed to be verified by DOE (DNV)
6.	DNV is very good name – DNV shall verify documents strictly
7.	PPA is with third party as Sikkim govt is not doing PPA.
8.	Average selling price for third party is more than Rs 6.00/unit in last 2 years in India
9.	Is Sneha kinetic project applying for REC?
10.	IS the power sold to/through third party?
11.	If the power is sold at Rs 2.72/ kWh, then sneha kinetic team is eligible for REC (Less than preferential tariff) – DOE shall check the actual PPA.
12.	During Verification should also check all the parameters
13.	 If the power is sold @ Rs 2.72/kWh to third party then sneha kinetic team is eligible for REC
14.	Sell Power through Manikaran Pwer (Leading power trading company in North India)
Submitted by: Obama the Hero

1.	The project is claimed to be run of river hydro project. So the calculation of reservoir is wrong. The criterion 3 is applicable only to pumped storage or accumulation hydro projects. What does reservoir refer to as per PP? 

2.	The justification of opting out alternative 3 and alternative 4 is not justified adequately. It should be based on latest published data and figures. Refer B.4. Pls. clarify.
3.	The bilateral agreements, PPA with India are the documents, DOE to check thoroughly

4.	Date of investment decision should be at the time of DPR preparation. So, the basis of the cost escalation factors at a later date for CDM consideration is not valid. Pls. clarify. Refer B5. Step 3a. (Investment barrier).

5.	How the CDM benefit will alleviate the technical barriers. As per additionality tool, if the barriers are not alleviated by CDM, then the project is not additional. 

6.	Emission factor for state is not calculated.it should be made available to DOE to clearly validate this value.  Emission factor for India is not as per “Tool for emission factor for the system”. 

7.	Electricity generated by the project, auxiliary consumption, transmission losses, transformer losses, net electricity exported to India, net electricity exported to the  grid. These parameters to be monitored continuously and to be cross checked with sale receipts. 

8.	The Meth mentions that if investment analysis option is used, apply the following: 

a.	Apply an investment comparison analysis, as per Step 3 of the .Combined tool to identify the baseline scenario and demonstrate additionality., if more than one alternative is remaining after Step 2 and if the remaining alternatives include scenarios P1 and P3;

b.	Apply a benchmark analysis, as per Step 2b of the .Tool for the demonstration and assessment of additionality. If more than one alternative is remaining after Step 2 and if the remaining alternatives include scenarios P1 and P2.

But PP failed to apply like this. Pls. clarify.

PLF should be based on EB48 Annex 11guideline which says The plant load factor provided to banks and/or equity financiers while applying the project activity for project financing, or to the government while applying the project activity for implementation approval; (b) The plant load factor determined by a third party contracted by the project participants (e.g. an engineering company); But PDD doesn’t demonstrate how PLF has been arrived at. 

9.	Whether PLF includes machine shutdown, machine availability. Whether grid availability is accounted for in the calculation of gross generation. To my surprise, critical parameter like PLF is missing from the PDD. How DOE has allowed this. 

10.	Common practice analysis should be based on EB 39 Annex 10 (Additionality tool). Each step of common practice analysis should be fulfilled as per tool.

11.	Emission reduction calculation should be based on EB 50 Annex 14 “Tool for emission factor for the electricity system.
12.	Whether only one set of main meter, check meter set is enough for three projects. The monitoring parameters need to be checked by DOE.
13.	The main meter and check meter technical parameters like accuracy level, make, etc. needs to be mentioned in the PDD. 
14.	Layout of power transmission lines from the generation to the consumer with the metering system is not shown. It should include the distance of transmission lines. DOE has to check the meters are installed to monitor electricity generated, net electricity used in Bhutan, net electricity exported to India. Pls. clarify.

15.	The status of the construction & commission of the project is not stated in the PDD.
16.	What is the basis of calculation for transmission loss, auxiliary consumption and transformer losses? What is the length of transmission line? 


Submitted by: M.Brutus


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