1.	How PP is saying 0.81% as compliance rate. This seems to be very low. Further PP is saying 10% as the compliance rate considered on conservative basis. Please justify the same. To calculate the compliance rate, PP should stretch the geographical boundary to the host country as the MSW Rules 2000 are applicable to all the states in India. Based on the latest available data published by CPCB or SPCB only PP should determine the compliance rate for the India and should apply the same. 
2.	For the fresh waste, PP is providing the undertaking. This may not be sufficient to judge that only fresh waste will be treated. In addition, DOE should check the solid waste procurement (or supply) agreement between PP and Municipality and whether that mentions the fresh waste or not. In solid waste treatment project, it happens many times that the waste dumped at the dumping yards of municipality is collected and treated in the solid waste management facility. These dumping yards act as waste holding stations for these projects. Many times the waste brought to the dumping yard (for the purpose of supplying it to the solid waste management project) is mixed with the existing waste. In such cases it becomes difficult to identify the fresh and existing waste. DOE should verify this by visiting the dumping yard (if in case it’s a waste holding station for this project). 
3.	In order to verify whether the project is not treating industrial or hospital waste, DOE should check the waste composition received at the project site. Only DPR as an evidence is not sufficient
4.	Additionality presented in the PDD is not strong. PP claims high capital investment for composting project. While in fact; composting involves few machines (like only sieving machine and loaders for turning), very basic civil work (like platform building) and the land cost. This does not seem to be very high investment. Further PP says high operation cost which is not true. Major operation cost will be only labor cost and fuel cost (For machines). Then how PP is facing investment barrier? Did PP face any loan rejections from banks? Under the investment barrier, PP is saying that the based on past experience, composting facilities were closed in short time. This may be because of interrupted supply of solid waste and not because of investment barrier. Investment barrier shown in the PDD itself is a weak argument and is not in line with EB guidance on investment barrier. PP is requested to explain this. 
5.	Under Market barrier, PP is saying public perception is that compost is dirty material and giving reference of some 2005 document. PP is still living in the era of 19th century where people had this perception. Now the organic products like organic manure etc are in much demand and a good market for organic products have been emerged over the time. Nobody has now “fear psychosis” and people have started using organic manures in their farms. The use of organic manure is not only limited to the small-scale farmers but has also been used widely. PP has written this market argument living in the era which is no more relevant now. DOE should look for the arguments which are in sync with the present time. 
6.	What is the investment decision date for project? PP has only mentioned the PO date as 2010. If this is the PO date; investment decision may be maximum 2 years before, then why PP has used 2003, 2005 dated reports. Please check the decision date  and use the latest report the in the context of decision date.  
7.	As per MSW Rules 2000, the landfill gas captured should be captured and should either be used or destroyed. If not possible, a passive venting system should be adopted. Hence, saying that there are no regulations for capture of landfill gas is wrong. 

 	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.

 	 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.  


 	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 these 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. 

 	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 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. 
 	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 tampered 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. 

Additionality demonstration is very sketchy in this PDD. The consultant only quotes the Waste to Wealth report and all the barriers are general in nature and not unique to this project.

It appears that the Consultant did not give investment analysis so that the input parameters need not be disclosed. In case the PP demonstrates additionality with investment analysis during validation, it is improper and DOE should insist on re-webhosting the PDD and then only take it up for validation. 

There is already one project in Varanasi engaged in compost manufacture and this project has adopted investment analysis to demonstrate additionality. There is no reason for this project to go by barrier analysis only. Qualitative statements – involving high cost and high operating costs- cannot become barriers and should not be accepted