Generation of Electricity in Gujarat from Bundled Wind Energy Project Activity – Bundle 9
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Host party(ies) India
Methodology(ies) ACM0002 ver. 11
Standardised Baselines N/A
Estimated annual reductions* 24,530
Start date of first crediting period. 01 Dec 10
Length of first crediting period. 7 years
DOE/AE PJR CDM
Period for comments 18 Aug 10 - 16 Sep 10
PP(s) for which DOE have a contractual obligation Resurge 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 (1476 KB)
Local stakeholder consultation report: N/A
Impact assessment summary: N/A
Submission of comments to the DOE/AE Compilation of submitted inputs:
a)	How come Equity IRR has been determined by using the CAPM model for arriving at the Benchmark rate, instead of WACC, as the project is funded both by Debt and Equity. Also as per the various EB decisions, WACC can be considered as the appropriate benchmark for project IRR.
Also, in Annexure-5 the PO talks about Benchmark IRR to be the cost of Equity, but in Page 20, above the Table presented for Individual Equity IRR, the same has been mentioned as the WACC, could the PO explain this anomaly. 
b)	Similarly while calculating the Project IRR, instead of WACC of the projects, cost of equity has been considered. Based on the fact that both debt and equity have been used, would this be the appropriate measure.
c)	 While calculating the Market Returns, the BSE 100 has been considered as the base.
How could BSE 100 be considered as a correct indicator for representation of the Market returns? (It has been often observed that BSE 100 has differed the market trends, an instance on 15th September could be an evidence of the same)
The project owners should have considered the BSE 500 or the BSE Power sector indices which would give a better representation of the market returns
d)	Has tax holiday been considered while computing the IRR, as nothing is mentioned the Assumptions table?
e)	Is there no increment to the wind tariff? If so, whether the same has been considered while calculating the Cash flows as this would have an impact on the IRR. There has been no mention in the Assumption table
f)	Have all Indirect Tax subsidies been considered while calculating the IRR as this is not mentioned in the Assumption table
g)	In Page 20- Section B.5- where the PO wise after tax Equity IRRs have been provided, in certain cases the Equity IRR is zero (Jayshree Impex, Nisan Exports etc). 
a)	Could the PO explain how the Equity IRR could be zero? 
b)	Also as mentioned in Annexure-5, in case of Renewable energy projects the risk involved is higher and hence the returns expected would be higher. But, there are instances where Equity IRR is ranging between 0% to 6%, which is not even at par with the at par with bank prime lending rate/Risk free rates (where the returns are assured). How did the project owners decide to invest in renewable energy projects, where the return on equity was as low as 0%?
c)	Will the revenue from sale of CERs provide enough returns for a PO to match the benchmark IRR, or enough to bring down the difference between the actual project IRR and the Benchmark IRR?
d)	How come is that when the Debt has been taken for the project, the IRR be zero. In such situations, WACC should have been definitely considered. 
e)	Also, it is very difficult to understand, how come the Investor invested in projects where the return in Zero. 
h)	Also, the average Equity IRR ranges from 0.44% to 6%. Such huge variations and the logic of the PO in investing in such projects where the IRR is so low, is not understandable. I would really like to understand the logic of investing in these projects.
Submitted by: Sandy


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