Please consider below comments in validation:

It is a well known fact that the wind projects are mainly installed considering CDM revenues and offsetting of tax liability of the company as a result of accelerated depreciation of 80%.

PPs cleverly do not consider the accounting tax offsetting in their companies while calculating the IRR. This is evident from the recently registered projects and those requesting registration. It is seen from the projects in pipeline that wind projects do not present the actual financials while proving additionality and hence abusing the Clean Development Mechanism.

The DOE is therefore requested to critically analyze how the accelerated depreciation benefit has been taken into account and confirm the accounting of the cash inflows as a result of the negative tax liability in the initial years. DOE should not be misguided by the financial presented by the PP or consultant which are custom made for CDM purposes and not the actual financial considered at the investment decision.

Note that considering cash inflows results in an increase in the IRR making wind projects a profitable venture.

Let me know if you have any queries/clarification.

Yours,
Babloo Singh

1.What is the specific sustainable development contribution achieved exclusively through this project activity after implementation of this project. Section A.2 of the PDD has not been clearly explained 
2.In the Interest calculation ,the rate of interest is shown as 10%-10.5 % .which value is taken for calculation
3.In page 20 of the PDD it has been mentioned that purchase order placed on 23 Dec2010,where as the machine already commissioned ,and the PDD submitted during Sep 2010
4.The calibration frequency has not been clearly mentioned in the PDD. Also in section B.7.2 the LCS meter reading is used for cross reference .whether it is accepted by TNEB and if so what is the calibration norms for the LCS meter

1.	None of the assumptions to evaluate the benchmark is shown in the PDD. As per additionality guidelines, all the parameters/assumptions must be included in the PDD. 
2.	Whether beta value evaluated for the power sector script is levered or unlevered? 
3.	The CUF of 30% has considered on the basis of a DPR submitted to Bank. But after that the assumed PLF has been reduced by considering the site factors which is not permissible as per Guidance on PLF. Whether these factors have also been considered in DPR in arriving site specific PLF. Requesting DOE to check the credibility of the assumption as per DPR. 
4.	The IRR evaluated for the CDM project including CDM revenue is 12.22%, however the benchmark considered for the project is 14.07%. We want to ask PP that even with CDM revenue the project is not financially viable, then why PP has invested in to the project with significant loss of 1.85% in the return which is very significant to setup the project. 
5.	The guidance considered in the section B.5 of the PDD is of older version. Request PDD consultants to apply latest version of Guidance. 
6.	It seems from the chronology the HCA application has been done to NCDMA on 7th June 2010 by registering with NCDMA, however the stakeholder meeting has been conducted in July 2010 i.e. after HCA application. How the HCA application is managed by submission of PDD without stakeholder concerns/comments.

1.	In section B.2 applicability condition it is mentioned that the project is connected to southern grid of India. But the methodology selected specifies about connectivity to mini grid. Under these circumstances whether the chosen methodology is correct or not.DOE may analyze in detail 
2.	 It has been mentioned that any time the captive consumption might be changed to selling to TNEB grid without any formal approval from UNFCCC. As the financial analysis would differ from captive use to sale to TNEB grid, IRR workings need to be checked whether it suits both. 
3.	The PP has declared 30% PLF/CUF (in page no 17 under section B.5 –Investment barrier table), whereas the annual expected generation stated as 27 million KWH .The PLF declared is not correct.
4.	Is there test/approval issued certificate issued y MNRE on the wind turbine technology as mentioned in section A.4.2 ?
5.	In section A 4.2 its stated that the plant load factor for all the WTGS estimated based on the manufacturer /industry standard software   WAsP,WindPro, whereas in page 17 it is stated that CUF is arrived based on DPR and software of windpro .This is contradictory. DOE may do a detailed analysis  Also it is not known whether the DPR given to Bank WAsP and WindPro PLF certificate, would meet out  as per Annexure 11 of EB 48  -II 3.b
6.	The PP states under section A 4.2 as follows “Prior to the project the users had been drawing electrical energy from southern regional grid and post project the users will be wheeling the electricity generated by WTGs.
 The baseline of the project is discussed in section B.4” .In section B.2 Applicability Condition of AMS 1F Ver. 1 in the table it is stated “This project activity is a capacity addition as the project proponent already has renewable energy unit    supplying electricity to the user”.
This is confusing .If user is already supplying renewable energy then why this project is chosen for captive use and how comes the question of replacing with predominantly fossil fuel plants.DOE may do a thorough analysis.

7.	The estimated emission reductions is incorrect as per the admitted PLF

8.	Whether all power generated through this project will be used for the entire crediting period?

9.	Normally PLF adopted by the PP is subject to include all the factors like grid availability, line loss, and import. In this project again these factors are excluded. DOE may check the issue more critically. 
10.	Section B.7.1 EGY has not included the line losses, whereas in the declared PLF line loss is found excluded.

11.	The tariff for the grid power has been increased recently up to INR 4.80 .The PP has considered the old tariff (INR 3.68) in page 17 of PDD  for all the 20 years and therefore, IRR calculation needs to be arrived based on the increased tariff as it has come in to effect from 1st August 2010 onwards. 

1.	Which index has been selected like BSE NSE and whether all companies have been considered for considered for arriving Bench Mark 
2.	what is the basis of the companies selected for beta value and whether it is levered or not 
3.	whether the PP has considered the incentives on account of indirect taxes ,excise tax customs duty and low VAT 
4.	O&M has been contracted .Hence other expenses like operational charges and admin should not be included while arriving IRR. DOE may critically analyze.
5.	Is the DPR  prepared by an expert and what is the basis it has been prepared and how far it is authenticated for PLF bench mark
6.	The revenue shown in PDD is INR 3.68,but actually it more than INR 4.5 and the new rate to be taken for calculation DOE may do analysis 
7.	DOE may please ensure the values used are as per the approved norms
8.	PP says that they have already supplying renewable energy .In this case whether all the Energy producing sources are getting CDM revenue.
9.	There  are 7 participants in this project ,whether 7 DPR have been provided  .DOE may verify with the concerned bank