Submission of comments to the DOE/AE
Compilation of submitted inputs:
Comment (27 KB)
submitted by: Dawa Lepcha
on behalf of Dawa Lepcha, Dzongu, Sikkim, India
The EIA of the project deliberately avoided the anthropological aspect of the assesment though the project is located in the heart of the indigenous Lepcha tribal reserve of Dzongu. Hence there is no mention of the Lepcha tribe in the EIA. This displays utter disregard for the indigenous people of the land. The company wants to make profit at the cost of the indigenous people.
Submitted by: Dawa Lepcha
Comment (53 KB)
submitted by: International Rivers
on behalf of International Rivers
Comment (62 KB)
submitted by: sandrp
on behalf of Himanshu Thakkar, Samantha Agarwal, many others
1. The project is claimed to be run of river hydro project. So the calculation of reservoir is wrong. The criterion 3 is applicable only to pumped storage or accumulation hydro projects. What does reservoir refer to as per PP?
2. The justification of opting out alternative 3 and alternative 4 is not justified adequately. It should be based on latest published data and figures. Refer B.4. Pls. clarify.
3. The bilateral agreements, PPA with India are the documents, DOE to check thoroughly
4. Date of investment decision should be at the time of DPR preparation. So, the basis of the cost escalation factors at a later date for CDM consideration is not valid. Pls. clarify. Refer B5. Step 3a. (Investment barrier).
5. How the CDM benefit will alleviate the technical barriers. As per additionality tool, if the barriers are not alleviated by CDM, then the project is not additional.
6. Emission factor for state is not calculated.it should be made available to DOE to clearly validate this value. Emission factor for India is not as per “Tool for emission factor for the system”.
7. Electricity generated by the project, auxiliary consumption, transmission losses, transformer losses, net electricity exported to India, net electricity exported to the grid. These parameters to be monitored continuously and to be cross checked with sale receipts.
8. The Meth mentions that if investment analysis option is used, apply the following:
a. Apply an investment comparison analysis, as per Step 3 of the .Combined tool to identify the baseline scenario and demonstrate additionality., if more than one alternative is remaining after Step 2 and if the remaining alternatives include scenarios P1 and P3;
b. Apply a benchmark analysis, as per Step 2b of the .Tool for the demonstration and assessment of additionality. If more than one alternative is remaining after Step 2 and if the remaining alternatives include scenarios P1 and P2.
But PP failed to apply like this. Pls. clarify.
PLF should be based on EB48 Annex 11guideline which says The plant load factor provided to banks and/or equity financiers while applying the project activity for project financing, or to the government while applying the project activity for implementation approval; (b) The plant load factor determined by a third party contracted by the project participants (e.g. an engineering company); But PDD doesn’t demonstrate how PLF has been arrived at.
9. Whether PLF includes machine shutdown, machine availability. Whether grid availability is accounted for in the calculation of gross generation. To my surprise, critical parameter like PLF is missing from the PDD. How DOE has allowed this.
10. Common practice analysis should be based on EB 39 Annex 10 (Additionality tool). Each step of common practice analysis should be fulfilled as per tool.
11. Emission reduction calculation should be based on EB 50 Annex 14 “Tool for emission factor for the electricity system.
12. Whether only one set of main meter, check meter set is enough for three projects. The monitoring parameters need to be checked by DOE.
13. The main meter and check meter technical parameters like accuracy level, make, etc. needs to be mentioned in the PDD.
14. Layout of power transmission lines from the generation to the consumer with the metering system is not shown. It should include the distance of transmission lines. DOE has to check the meters are installed to monitor electricity generated, net electricity used in Bhutan, net electricity exported to India. Pls. clarify.
15. The status of the construction & commission of the project is not stated in the PDD.
16. What is the basis of calculation for transmission loss, auxiliary consumption and transformer losses? What is the length of transmission line?
Submitted by: lasith
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