3 MW bundled wind Power Project in Tamil Nadu
Host party(ies) India
Methodology(ies) AMS-I.D. ver. 17
Standardised Baselines N/A
Estimated annual reductions* 6,085
Start date of first crediting period. 01 Jan 12
Length of first crediting period. 10 years
Period for comments 11 Aug 11 - 09 Sep 11
PP(s) for which DOE have a contractual obligation Mangalam Fashions Ltd
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 (429 KB)
Local stakeholder consultation report: N/A
Impact assessment summary: N/A
Submission of comments to the DOE/AE Compilation of submitted inputs:
Please clarify the location of the windmill, because the unique identification of the project activity(map) is not clear.

The India map indicates the Andra State instead of Tamilnadu. The district map shows the Dharmapuri district instead of Tirupur district.
Don't cut paste from other PDD.
Submitted by: dwarakaa

* Why PP has considered very less PLF recommended by TNERC (27.15%). 
* How PP has calculated the Post TAX Return on Equity? PP has to take out the tax rate from the market risk premium and risk free rate. then only its a post tax return on equity or its pre tax return on equity.
* Use the latest version of the tools and the guidelines in the PDD.
Why NSE 500 has been used in the project activity
* What are the criteria applied in the Project activity for the selection of companies used in the calculation of Beta.
* DOE has to check the financials, whether TAX shield and TAX Holiday has been considered in the project activity.
* How the stakeholders has been invited and the comments were combiled. need a brief description
* How the beta values of BF utilities comes to 0.66, DOE has to check the calculation thoroughly?
* BF utilities has the more beta values
* why PP has not considered the tariff rate in the sensitivity analysis
* Average of 5 years low cost/ must resources has to use in the project activity
*More clarity is required in the emission factor calculations. CM might be 0.944 if Weighted OM is used.
*even duration is required in the companies used in the beta calculations.
* Corporate TAX rate used in the project activity is wrong
* Combined Margin & Operating Margin has to calculate  from the wieghted average not from single year. refer section b.6.2 in the PDD.
* Description of measurement methods in the section B.7.1 has to be elaborate
Submitted by: CDM Developer

PDD reports that UNFCCC has been informed. As per EB 62, Annex 13, both UNFCCC and DNA have to be informed. There is no mention about intimation to DNA in the PDD

Using weighted average interest rate of Central Government Securities (as per web site address given in PDD, which provides information upto 2006-07 and not 2010-11 as claimed) means that the Government securities can be purchased at par. PP/consultant should know how the govt. securities market functions before attempting to use CAPM. 

PP/consultant has used in S&P 500 for market return calculation. But, the PDD does not explain why the index has been selected and how it is representative of market return and fulfills the requirement of CAPM.

Power Grid has been included in the beta calculation, which does not appear to be engaged in power generation. Other power generating companies are not included. PDD does not state what is the period selected and whether weekly or monthly return has been selected for computing beta and the reason for the selection. 

PP/consultant has selected equity beta which is not correct. Beta should be unlevered and only asset beta should be used. Use of equity beta, principal-wise, is incorrect for the given context.

PDD states that return on equity represents deposit rates increased by market risk premium which proves that PP/consultant do not understand what they are doing. It is unfortunate that without understanding the subject in full and the logic, CAPM is used. 

When TNERC has recommended PLF of 27.15%, projecting 25.4% is not correct and should not be accepted.

Suzlon charges only Rs.15 lakhs per 1.5 MW WTG as O&M cost. The given cost yields Rs.16.5 lakhs, which is very high, DOE should check what is the O&M cost the company is actually paying. 

Only recently a few projects have webhosted their PDD with the same 1.5 MW Suzlon make windmills but at a cost of Rs.60 mn./MW. In this case the cost is Rs.62.54 mn./MW. DOE should check what the PP ultimately paid. DOE should not omit any evidence that is likely to affect validation opinion. That is what VVM states.

Besides getting a declaration from PP on the financing, DOE should ask for a CA certificate and also examine the Balance sheet of the company for 2009-10 and 2010-11 to find out any loan has been taken. 
Submitted by: Karthikeyan

Comment (190 KB) Submitted by: E-0010 SGS official account

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