This project is located in a ecologically fragile area and is situated near kanchenjunga national park. The EIAs are done with little ground/site visit.Hence most of these EIAs tend to be cut and past jobs.
The river on which the HEP is going to be built is considered scared by the Bhuddhist community and hence there is protest against it by the monasteries and the monks as well as others. another HEP was stopped previously on the same river due to protests carried out on the same issue. 

There are excess numbers of HEP in the region which are killing the ecology and the environment of the area as well as the rivers. This will have a devastating cumulative impact in the long run.

no mitigating measures will help in the long run. 
the project should not be given any approval.  

Step 2a of Sec. B.5. states, “As defined in Step 1 above, the alternative to the proposed project activity is the baseline scenario, that is the supply of electricity from the Vietnamese national electricity grid”. It is not clear how the Vietnamese national grid is relevant to a power project located in India. 

Again the PDD states, “………average corporate tax rate paid by the project is 28.0% (see financial model for references)”. However, financial model is not enclosed to PDD. How does the PP or consultant expect the reader to comment on this issue

The best part of the PDD is the WACC calculation given. WACC is calculated using the formula - 70% x 7.75% x (1-28%) + 30% x 26.5% - and the WACC has been given as 13.19%. Can solving this equation result in 13.19%. Either the PP / consultant do not know how to solve the equation or the mistake is intentional or fixing the WACC at 13.19%. The equation will result in WACC of 11.85% and DOE should not accept any benchmark more than 11.85%. This is however subject to correction of Return on equity. Return of 26.5% on equity is extremely high. CERC has recommended only 15.5% and many SERCs have recommended return of only 16%. As stated by the PP, even the EB has recommended a much lower return. Therefore, any return of more than 16% on equity should not be accepted. The benchmark is therefore very high and should not be accepted

Tariff has been taken at Rs.2.12/kWh. At this rate all projects will be additional. Has the PP seen other projects from Sikkim web hosted. None of them have assumed such a low tariff. 

How can the life of the project be 20 years? A number of hydro power projects have assumed life period of more than 20 years without any additional refurbishing cost. If DOE goes through other hydro power projects it would realise this fact. Hence, the project life period is incorrect and should not be accepted.    

O&M expenses have been provided at 2%, and again at 5.7% and the O&M cost has been escalated at 1%. CERC provides for only one O&M expenses at 2% subject to 5.72% escalation. Other than this, CERC order does not provide any other costs. Therefore DOE should not permit O&M cost more than 2% of capital expenditure.

The income tax rates given is wrong; depreciation rate does not take additional depreciation into account