70 MW Bhadla Solar power plant by Fortum Finnsurya Energy Pvt Ltd (EKIESL-CDM-APRIL-16-01)
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Host party(ies) India
Methodology(ies) ACM0002 ver. 17
Standardised Baselines N/A
Estimated annual reductions* 48,562
Proposed start date of PA 29 Jul 16
Start date of first crediting period. 31 Oct 17
Length of first crediting period. 7 years
DOE/AE LGAI Technological Center, S.A.
Period for comments 17 Dec 16 - 15 Jan 17 (23:59:59 GMT)
PP(s) for which DOE have a contractual obligation Fortum FinnSurya Energy 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 (642 KB)
Local stakeholder consultation report: N/A
Impact assessment summary: N/A
Submission of comments to the DOE/AE Compilation of submitted inputs:
Project title: 70 MW Bhadla Solar power plant by Fortum Finnsurya Energy Pvt Ltd (EKIESL-CDM-APRIL-16-01)
DOE: LGAI
PP: Fortum FinnSurya Energy Private Limited
Fortum Group: Awadhesh.Jha@fortum.com 
Comments on Additionality:
Why has fortum published contradicting information in the CDM PDD. The IRR from the project is mentioned as 8.96% same as that of your other project, whereas on its website they publicly disclose a ROE of 22.7%. Surely in all its solar project this high ROE was never mentioned then how is such a scenario possible. What has been hidden for public comments needs to be checked. 
The benchmark value given in the PDD is ludicrous. In the era of copy paste your consultants have forgotten simple additions. The benchmark presented as 16.06%, does not match up with the 11.06% and inflation forecast of 4.5%. Further the PDD mentions benchmark as 16.61 (5 year) then 13.06% (10years) and the conservative of the two selected has a value of 16.06%. Where did these 3 different values came from. Can Mr. Awadhesh confirm that the project has employed this benchmark? If not, now my question is to the DOE, 
Donít you think if the benchmark value changes, this would mean significant changes from the published PDD? Pls. let me know a valid reason if you think this is not a significant change (I hope the team from Spain looks into it as its Indian counterparts would overrule such things). 
Where are the assumptions? If the assumptions are added in a later stage, again I would ask the DOE to clarify if these changes are not significant? Should the PDD not be re-webhosted so that we can give our comments on the assumptions? 
Common Practice analysis: Total of 60 project of that size in Rajasthan, why have the details not been mentioned. 
What has been mentioned in the PDD just does not make any sense, is it just to confuse the staekholders or Fortum is not able to appoint a good consultant? 
Nsolar: 60
Nall: 70, Ndiff: 69 basically all your projects regardless of which state the project is implemented the same values are mentioned. In case these are change;  
Again I would ask the DOE to clarify if these changes are not significant? Should the PDD not be re-webhosted so that we can give our comments on the correct values? 
Calibration: Why 5 years have been mentioned when the PPA from Rajasthan government has a standard of annual calibration? 
LSC Meeting: Fortum group conducts LSC meeting in such manner? Your website says something totally different. 
Who carried out the LSC Meeting? In case the final PDD provides significant changes in the LSC section I would ask the DOE to web-host this again. 
I canít find a single Local stakeholder from the current PDD. No name, no location, no villages that were invited. Why is all these information not provided. In case these are added in the final PDD, the doe should publish this again so that stakeholders are able to give their views on this. 
One request to Fortum is please donít rely on you previous consultant, its your stake and impression that gets affected. Get a good decent consultant or at least have some sense to look what is being presented in the documents as these go in the name of Fortum. 
DOE please ensure a correct check, with all your previous experiences I doubt you will work ethically, still I am hopefull that the spain office will take action and re publish such shitty PDD with correct data and values for the stakeholder to judge. 
Submitted by: Naveen Dhingra


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