The quality of the PDD uploaded for webhosting is of very poor quality and certain sections seem to be copied from the PDD prepared for the Delhi Metro project. It is disappointing that absolutely no thought has gone in to develop the PDD for the project of such nature and scale. The quality of the PDD in itself should be an indicator for the DOE as to how seriously has the PP considered CDM funds. 

Detailed below are some of my specific observations regarding the project. 

Additionality
The Mumbai Metro project was awarded to the project proponent based on the bid that had been submitted by them along with their consortium partners. There were four other parties who had also submitted a bid for the project. We would like to know whether the PP had considered CDM funds at the time of submission of the bid itself. If not then the project cannot be considered as a CDM project. Even if it is determined that the PP had considered CDM funds at the time of bidding, it needs to demonstrate if the other bidders too had considered CDM funds or not. If not, then even if the PP were not to be provided with CDM funds, the project would have either ways been set up. The DOE should also thoroughly assess all the publicly available documents concerning the project prior to arriving at a conclusion. Have the ministries involved in the project been notified about the CDM consideration?

The PP has stated in the PDD that the overestimation of ridership in DMRC was taken into account at the time of financial analysis for Mumbai Metro. The PP and/or its consultant also apparently seems to ‘know all’ about all the metros word wide. Considering the verbose argument provided in the PDD regarding overestimation of the ridership, I guess this is the parameter that the PP has manipulated to ‘fit in’ the IRR for CDM purposes. But has the PP assumed the same figures at the time when it was conceptualizing the project. Were these the very same numbers considered in the bid document? Were these numbers in line with the expectation of the other bidders as well? Or was the PP the only  ‘knowledgeable’ bidder who knew that everything in the project is going to go wrong. Has the PP submitted the same set of numbers to all the financial institutions/ lenders and investors who have invested in this project? Interestingly, no sensitivity analysis seems to be undertaken for ridership? Why? The DOE should make sure that the PP does not do a standard +/- 10% variation in the ridership but assume a higher variation considering the very very very high degeree of uncertainty in estimating the number, as acknowledged by the PP himself

Baseline
The baseline alternatives considered by the project proponent, amongst others include, continuation of the existing practice, establishment of a BRT, establishment of LRT. Considering the stated vision of the Government of Maharashtra to ‘convert Mumbai into Shanghai’, how has the PP concluded that no investment would have happened in the baseline scenario? Can such a conclusion be arrived at the basis of one paper prepared by the MMRDA. Has the PP bothered to check the basis and the accuracy of the said paper? As MMRDA is an interested party in the project, the DOE is also required to assess possibilities for conflict of interest. 
Local Trains are considered the life line of Mumbai. If nothing it can be assumed that the Government would have implemented at least a suburban rail network connecting Versova, Andheri and Ghatkopar. Why is such a possibility not considered?

Sweety Singh

The quality of the PDD uploaded for webhosting is of very poor quality and certain sections seem to be copied from the PDD prepared for the Delhi Metro project. It is disappointing that absolutely no thought has gone in to develop the PDD for the project of such nature and scale. The quality of the PDD in itself should be an indicator for the DOE as to how seriously has the PP considered CDM funds. 

Detailed below are some of my specific observations regarding the project. 

Additionality
The Mumbai Metro project was awarded to the project proponent based on the bid that had been submitted by them along with their consortium partners. There were four other parties who had also submitted a bid for the project. We would like to know whether the PP had considered CDM funds at the time of submission of the bid itself. If not then the project cannot be considered as a CDM project. Even if it is determined that the PP had considered CDM funds at the time of bidding, it needs to demonstrate if the other bidders too had considered CDM funds or not. If not, then even if the PP were not to be provided with CDM funds, the project would have either ways been set up. The DOE should also thoroughly assess all the publicly available documents concerning the project prior to arriving at a conclusion. Have the ministries involved in the project been notified about the CDM consideration?

The PP has stated in the PDD that the overestimation of ridership in DMRC was taken into account at the time of financial analysis for Mumbai Metro. The PP and/or its consultant also apparently seems to ‘know all’ about all the metros word wide. Considering the verbose argument provided in the PDD regarding overestimation of the ridership, I guess this is the parameter that the PP has manipulated to ‘fit in’ the IRR for CDM purposes. But has the PP assumed the same figures at the time when it was conceptualizing the project. Were these the very same numbers considered in the bid document? Were these numbers in line with the expectation of the other bidders as well? Or was the PP the only  ‘knowledgeable’ bidder who knew that everything in the project is going to go wrong. Has the PP submitted the same set of numbers to all the financial institutions/ lenders and investors who have invested in this project? Interestingly, no sensitivity analysis seems to be undertaken for ridership? Why? The DOE should make sure that the PP does not do a standard +/- 10% variation in the ridership but assume a higher variation considering the very very very high degeree of uncertainty in estimating the number, as acknowledged by the PP himself

Baseline
The baseline alternatives considered by the project proponent, amongst others include, continuation of the existing practice, establishment of a BRT, establishment of LRT. Considering the stated vision of the Government of Maharashtra to ‘convert Mumbai into Shanghai’, how has the PP concluded that no investment would have happened in the baseline scenario? Can such a conclusion be arrived at the basis of one paper prepared by the MMRDA. Has the PP bothered to check the basis and the accuracy of the said paper? As MMRDA is an interested party in the project, the DOE is also required to assess possibilities for conflict of interest. 
Local Trains are considered the life line of Mumbai. If nothing it can be assumed that the Government would have implemented at least a suburban rail network connecting Versova, Andheri and Ghatkopar. Why is such a possibility not considered?


Funding mechanism
The project activity has been setup on the basis of viability gap funding model in which the PP assess the viability of the project and gaps if any are funded by the Government. The Central Government for Phase I of the Mumbai Metro has made available INR 2356 Crores. The estimated CDM funds from the project could be in the range of INR 125-135 Crores which is likely 5% of the viability gap funding provided by the project. Is the PP saying that the Government of India, while willing to shell out INR 2356 crores for the project would not have paid an additional 125-135 Crores and the project would have been shelved? Does the PP really expects us to believe it? Does the PP believe that the webhosted PDDs are read by school-going kids who would not be able to understand that you are trying to mislead people? There are too many details regarding the project in the public domain and the PP should know that it is going to be difficult to fudge facts or mislead people. 

Also, all companies involved in developing metros get permission to real estate development and recover their capital expenditure. Has the PP taken these into account at the time of investment analysis? There is no mention of that in the PDD. If it has not been considered by the PP, why could not that be a possible option for the PP when similar considerations have been made in case of other proposed Metros like the Hyderabad one? Has the PP considered any other funding options as well? With the PP and its consultants having know how of all the metros across the globe, they should also be aware of how those projects have been funded? Why haven’t they conducted an analysis for that as a part of the baseline analysis

Impact of CDM

As a total part of the project cost, the CDM funding is going to be negligible. The PP should explain that what it would be able to achieve with the additional funding of INR 125 Crores from CDM that it could not with the viability funding of INR 2356 Crores from the Government of India

Sweety Singh

Resubmitting for confirmation


The quality of the PDD uploaded for webhosting is of very poor quality and certain sections seem to be copied from the PDD prepared for the Delhi Metro project. It is disappointing that absolutely no thought has gone in to develop the PDD for the project of such nature and scale. The quality of the PDD in itself should be an indicator for the DOE as to how seriously has the PP considered CDM funds. 

Detailed below are some of my specific observations regarding the project. 

Additionality
The Mumbai Metro project was awarded to the project proponent based on the bid that had been submitted by them along with their consortium partners. There were four other parties who had also submitted a bid for the project. We would like to know whether the PP had considered CDM funds at the time of submission of the bid itself. If not then the project cannot be considered as a CDM project. Even if it is determined that the PP had considered CDM funds at the time of bidding, it needs to demonstrate if the other bidders too had considered CDM funds or not. If not, then even if the PP were not to be provided with CDM funds, the project would have either ways been set up. The DOE should also thoroughly assess all the publicly available documents concerning the project prior to arriving at a conclusion. Have the ministries involved in the project been notified about the CDM consideration?

The PP has stated in the PDD that the overestimation of ridership in DMRC was taken into account at the time of financial analysis for Mumbai Metro. The PP and/or its consultant also apparently seems to ‘know all’ about all the metros word wide. Considering the verbose argument provided in the PDD regarding overestimation of the ridership, I guess this is the parameter that the PP has manipulated to ‘fit in’ the IRR for CDM purposes. But has the PP assumed the same figures at the time when it was conceptualizing the project. Were these the very same numbers considered in the bid document? Were these numbers in line with the expectation of the other bidders as well? Or was the PP the only  ‘knowledgeable’ bidder who knew that everything in the project is going to go wrong. Has the PP submitted the same set of numbers to all the financial institutions/ lenders and investors who have invested in this project? Interestingly, no sensitivity analysis seems to be undertaken for ridership? Why? The DOE should make sure that the PP does not do a standard +/- 10% variation in the ridership but assume a higher variation considering the very very very high degeree of uncertainty in estimating the number, as acknowledged by the PP himself

Baseline
The baseline alternatives considered by the project proponent, amongst others include, continuation of the existing practice, establishment of a BRT, establishment of LRT. Considering the stated vision of the Government of Maharashtra to ‘convert Mumbai into Shanghai’, how has the PP concluded that no investment would have happened in the baseline scenario? Can such a conclusion be arrived at the basis of one paper prepared by the MMRDA. Has the PP bothered to check the basis and the accuracy of the said paper? As MMRDA is an interested party in the project, the DOE is also required to assess possibilities for conflict of interest. 
Local Trains are considered the life line of Mumbai. If nothing it can be assumed that the Government would have implemented at least a suburban rail network connecting Versova, Andheri and Ghatkopar. Why is such a possibility not considered?


Funding mechanism
The project activity has been setup on the basis of viability gap funding model in which the PP assess the viability of the project and gaps if any are funded by the Government. The Central Government for Phase I of the Mumbai Metro has made available INR 2356 Crores. The estimated CDM funds from the project could be in the range of INR 125-135 Crores which is likely 5% of the viability gap funding provided by the project. Is the PP saying that the Government of India, while willing to shell out INR 2356 crores for the project would not have paid an additional 125-135 Crores and the project would have been shelved? Does the PP really expects us to believe it? Does the PP believe that the webhosted PDDs are read by school-going kids who would not be able to understand that you are trying to mislead people? There are too many details regarding the project in the public domain and the PP should know that it is going to be difficult to fudge facts or mislead people. 

Also, all companies involved in developing metros get permission to real estate development and recover their capital expenditure. Has the PP taken these into account at the time of investment analysis? There is no mention of that in the PDD. If it has not been considered by the PP, why could not that be a possible option for the PP when similar considerations have been made in case of other proposed Metros like the Hyderabad one? Has the PP considered any other funding options as well? With the PP and its consultants having know how of all the metros across the globe, they should also be aware of how those projects have been funded? Why haven’t they conducted an analysis for that as a part of the baseline analysis

Impact of CDM

As a total part of the project cost, the CDM funding is going to be negligible. The PP should explain that what it would be able to achieve with the additional funding of INR 125 Crores from CDM that it could not with the viability funding of INR 2356 Crores from the Government of India

Sweety Singh