Surprisingly, Vedanta has moved forward to select an incompetent DOE. This is an open fact to global stake holders. I would like to point out several issues that would prove that the project is not applicable and definitely not additional. 
Applicability of the methodology: 
Para 4 of the ACM0013 version 4 demands “data on the fuel consumption of recently constructed power plants are available”. Vedanta and their consultants seem ignorant and least bothered to fulfill the requirements under aCM0013 version 4. However what is surprising is that the DOE (BVC) has not bothered to even look whether the project is applicable for this methodology or not. On one hand UNFCCC is breaking their heads to ensure that the standards of DOE are met, and other hand DOEs like you are diluting the complete concept. As a layman I am able to understand what is written in black and white under ACM0013, why can’t BVC understand this??
ACM0013 version 4 page 11 under FCjx and FCnv under the row of “any comment” it clearly states that the “The DOE should verify that the data on fuel consumption is based on first-hand measurements of the actual quantity of fuel consumed by each power plant, and is not based on second-hand calculations or estimations”. Do the PP/consultant or the DOE even understand the implications and requirement of this special addition in version 4? The meaning of this statement is, you cannot arrive/estimate/compute the fuel consumption. It has to be through direct measurement of actual quantity of the respective units and not the entire power plant. Having known the open fact that none of the baseline plants (NTPC, CEA, CERC) measure/monitor the fuel consumption at unit level and the data is not available. that is the reason you are estimating which is not correct and not inline. 
Why has BVC not asked a deviation/clarifications/revision before web-hosting even if the requirements of the methodology are publicly displayed. This displays sheer incompetency of the DOE. Hence I would like to state the project is not applicable under this methodology. Though it is proven now that the project is not applicable under this methodology, I hope BVC does not proceed with the validation; ignoring my comments. But be warned that CDM EB and members are very well aware of the Indian scenario, so Vedanta you cannot escape here.  
Financial calculations: 
This part is rather funny. Is the PP doing the financial analysis of such a huge project for the first time? Are they not aware of the Indian market scenario or they think CDM EB and Secretariat member and Stakeholders are fools who would agree to whatever crap they write in their PDDs. 
Will any Indian investor, invest in a project which gives a return of 6.14% IRR. For such a huge project even after CDM consideration the IRR would not be more than around 7.3%. In such a case they even do not cross the interest rate/benchmark (11.75%). Why are they going ahead with the project activity. Who will put in the debt part for a project whose returns do not even reach the interest rate?  
Secondly again a straight forward question to Vedanta, as the project is being funded 75% by consortium of banks, will any Indian Bank associate itself with a project with such a low returns. Vedanta whom are you trying to cheat? Do you that if this figure of 6.14% IRR value is known to shareholders of Vedanta, can you even imagine what would be the implications? The company will sunk down. Anyway I am forwarding the same to SEBI, and will request them to publish the same in the next annual reports. Further I will also request of the banks to consider this value of IRR for the project. 
Looks like after reading these comments, either Vedanta would remove the IRR values or use a different method for investment analysis. But I hope BVC makes it a point to ensure that the IRR values are mentioned in the revised or final version of PDD and any change in the Values are justified. 

I was just comparing the project cost of 1980 MW TSPL and the present 660 MW TSPL project. Interestingly the project cost of 1980 MW is 5.5 Mn INR/MW while for the small unit of 660 MW the project cost is only 3.7 Mn INR/MW even though the supplier is the same. Where is the whole concept of economies of large scale projects?? 
Here I just wanted to ask a straight forward question to Vedanta, in both the cases there is a change of 2 Mn INR/MW still you require CDM revenues. Or I think after my questions raised all the input parameters will change. Here I would like the CDM EB and specially BVC, not to let them change any assumption or parameter as it will render the complete exercise as farce. Vedanta is treating CDM mechanism as a fun activity and they are expecting to get money by cheating the stakeholders/shareholder/DOE and CDM EB. I hope BVC acts in a responsible and sensible way to the above questions raised. 
Further, Pls. check the project cost of recent NTPC sub-critical plants (baseline cost plus plant) which is almost equal to your project cost (3.7 Mn INR/MW) with approximately similar kind of tariff. If NTPC being a public sector and able to achieve 16% returns what is the problem with the financial calculations of Vedanta, they have an IRR of 6.14% only. Is Vedanta is not even half the efficient in working as compared to NTPC? 
 I have described a comparison below; from one of the Validation reports of a supercritical project and validated by a DOE, the source are;
http://www.cea.nic.in/thermal/project_monitoring/BS%20NTPC.pdf
http://www.cea.nic.in/thermal/project_monitoring/index_Thermal_Project_Monitoring.htm  






The project cost is detailed below: 
No. 	Plant unit			Size		Cost (Mn INR/MW)
1.	Kahalgaon STPS St.IIUnit-5,6,7 	500		39.1
2.	Korba STPP St-III, Unit-7         	500		49
3.	Dadri-st.			500		52.4
4.	Indira Gandi STPP		500		55.3	
5.	Bilai				250		49.6		
6.	Anpara – C TPS			1200		34.29	
7.	Rajiv Gandhi TPP		1200		35.82
8.	Raghunathpur TPP		1200		34.35		
9.	Mundra TPP-Phase I-1and2	660		34.35	
From the above list, Vedanta needs to understand that if other project participants go ahead with a sub-critical technology based project at a project cost of as high as 49 Mn INR/MW and still able to operate as profitable, they how is Vedanta not being profitable. The simple reasons is that the financial projection in the PDD is wrong and Vedanta wants to cheat the stakeholders. 	

Emission reduction calculations: 
Your project is only eligible for 3 Million CERs but your projections are double to that. If BVC and your consultants are competent enough to arrive the correct CERs, then you are safe or else CDM EB will off course take care of it, as such they have undergone a deep investigation of this methodology.  But I expect the DOE to look into this. Off course the stage of Emission reduction calculations should not be reached as the project is clearly non-additional. 

Finally I would like to summarize the main points:
1.	The IRR of 6.14% is not correct, and should not be allowed to change after my comments. I want a letter from the debt supplier/bank consortium to provide a approval at this low returns (6.14%) that too the document from shall be made publicly available on either Vedanta’s website or as an attachment in the PDD. 
2.	The project cost varies at the TSPL 4 units at Talwandi itself, any justification for this ?	
3.	Also the details in the PDD are not as per the DRHP released to SEBI, this is a legal violation, BVC should take of this and inform the SEBI. 
4.	Applicability of the methodology ACM0013 version 4 – data on fuel consumption is not based on first hand measurement for the baseline plants. 
I am marking a copy of this mail to BVC, Vedanta CEO, PP in the PDD, CDM EB other Stakeholders and SEBI. 



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gupta.rameshh@gmail.com