Improving Energy Efficiency in Railways' Residential Quarters – Southern and North East Region
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Host party(ies) India
Methodology(ies) AMS-II.J. ver. 3
Standardised Baselines N/A
Estimated annual reductions* 26,613
Start date of first crediting period. 31 May 10
Length of first crediting period. 10 years
DOE/AE DNV-CUK
Period for comments 02 Dec 09 - 31 Dec 09
PP(s) for which DOE have a contractual obligation C-Quest Capital Malaysia 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 (558 KB)
Local stakeholder consultation report: N/A
Impact assessment summary: N/A
Submission of comments to the DOE/AE Compilation of submitted inputs:
A) Its understood that the small scale methodology AMS II J is for residential applications. I would like to highlight the following: 

1) These residential quarters are owned by Indian Railways and given to its employees as a perk in lieu of their work at places where they are required to work. That is a subsidized accommodation provided to its employees according to their position in employment. The occupants of these households live there as per their job roles and designations and thus the usage of electricity is not typically of any normal household. 

2) The residents of these accommodations/quarters are not permanent residents or owners of the quarters. They move to other stations or leave their quarters frequently due to the following reasons;
- When transferred to other stations 
-  When they are promoted to the next position, their entitlement of the size of the quarter changes
- When their job is not required in that station
- When they resign or leave their jobs
- When they are on leave and move to their home towns

3) These quarters are used more like hotels for temporary housing purposes.

4) Indian Railways does not generate its own electricity and is the largest industrial customer of various electricity generation, transmission and distribution companies in India. As a policy, it buys electricity in bulk for two basic purposes;
- Electricity for traction purposes – running train services
- Electricity for Non-Traction purposes – running auxiliary and support services like platforms, workshops and employee quarters

All the above electricity is for industrial use and railways earn its revenues only from selling railway services. As a policy, the electricity is sold to Indian Railways at a subsidized price for both the purposes. There is no electricity being supplied to Indian Railways for residential purposes at all by any discom in India.  The accounting of electricity for traction and non traction purposes separately is only for accounting purposes and there is no such record kept separately with the electricity distribution companies. 

5) The electricity purchased for non traction purposes is not prioritised towards any specific non traction purpose and is easily diverted from one non-traction use to another non-traction use. Even the non-traction electricity is diverted at times for traction purposes when required as that is the priority. The primary purpose of Indian railways to buy the electricity is for its services and not residences or quarters.

6) The residential quarters lighting is not the responsibility of the Indian Railways and the temporary resident occupant own the light fixtures including the bulbs. There is no fixed study on the usage in railways quarters as the Indian railways has fixed the amount of usage as per the category and size of the railway quarter and a fixed bill is sent to the occupant by the Indian Railways and not the discom. These bills are invariably highly subsidized by Indian railways is which fully owned by the government of India, hence it’s subsidized by the Indian tax payer. The railway accommodation and electricity bill is subsidized as a perk to the railway employee. It must also be noted that Railway accommodation is not a right of the railway employees; hence it is provided only to facilitate railway services.

7) In some cases, the electricity supply to railway quarters is not even metered and Indian Railway has no house to house record of consumption. Indian Railway is also not bothered about this consumption as it buys the electricity for non traction purposes and only diverts it to railway quarters and takes a token amount as a bill from the occupants.

8) The occupants are temporarily allotted these quarters and they are not the legal owners / tenants of the house as the overriding fact of their job makes them stay there. How is their database managed as they would frequently shift as well? 

9) Due to the nature of work and relation of job of the occupants, their consumption of electricity is different from the behavior of any normal residential household. These quarters are not typically a reflection/ appropriate sample of the pattern of consumption of electricity. Has any survey been done to find out their existing usage patterns first and then maybe calculate the savings potential of the project activity? As they keep shifting frequently, chances of the leakages in terms of CFLs being taken along by them to their new place of stay seems certain thus impacting the reliability of emission reduction.

 10) The Non traction usage is an absolute commercial usage of electricity by Indian Railways and in no way is it a residential usage, hence the methodology AMS IIJ, does not apply to this project. In light of various points stated above, it seems that the methodology which is applicable for “Households” doesn’t fit appropriately as these quarters are not normal households. Please clarify.

B) Primarily, the railways buy electricity from various discoms in India for its operations. It doesn’t keep separate records of the electricity used across its various other activities like for platforms, corridors, repair workshops and quarters. How the savings of electricity would be measured across these different units / activities. The meters for checking the consumption of electricity at Household level is not very clear and seems to be an impediment while monitoring the savings of electricity.

Please suggest as to how is it being addressed by the railways / project developers.

C) Indian Railways is one of the largest buyers of electricity at India. Indian railways don’t generate electricity but buys it from various electricity distribution companies at a SUBSIDISED RATE / DISCOUNTED RATE and uses it for running trains. It also uses electricity for platforms, maintaining other facilities like workshops and factories and also distributes it to its employees who are temporary occupants of its quarters. Railways subsidize the electricity consumption at these quarters heavily. It happens at various stages –

Stage 1 - Railways buys electricity from discoms at a BULK Rate / subsidized rate 
Stage 2- Railways pays a part of the electricity bill for its employees who are occupants of these quarters.

Thus, as such these subsidies form a part of the project activity. Have they been considered during the assumptions and calculation of projections / financials of the project activity?

D) The quarters are spread across the city jurisdictions. Have project developers intimated the respective electricity distribution companies across the complete project area regions about the development of this project, as switching to CFLs would cause some distortion in the existing distribution systems laid out by them. Are they also the stakeholders as their observations and approvals may be mandatory required as per laws at India? Has this been addressed adequately for smooth rollout and successful and timely completion of project? 

E ) Ministry of Power at India is developing a nationwide CFL distribution program, named Bachat Lamp Yojana, based on same methodology, as per Program of Activities of UNFCCC already submitted with UNFCCC and undergoing validation. 

Electricity distribution companies of India are gearing up for implementation of this national drive and are currently at different stages of development for the same.  

How would the respective distribution companies, across these project areas, simultaneously participate and develop along with federal government of India, the Bachat Lamp Yojana as the households covered in this project would cause the overlap and lead to double counting?

Are the state electricity distribution companies or Ministry of Power or any of its bodies/departments supporting these projects? 

Are they supporting the monitoring or development of these projects? 

Does that involve public funding? Do they have the specific budgets and finances to do so? Have they their board approvals to do so as well?

F) Section A.4.5 mentions: “ A proposed small-scale project activity shall be deemed to be a debundled component of a large project activity if there is a registered small-	scale CDM project activity or an application to register another	small-scale CDM project activity:

		(a) With the same project participants;
		(b) In the same project category and technology/measure; and
		(c) Registered within the previous 2 years; and
		(d) Whose project boundary is within 1 km of the project boundary of the proposed 			small scale activity at	the closest point?

The project participants have not registered another project with the same project 	category and technology/measure in the past 2 years and there is no other project of a similar activity proposed within one kilometer of this project boundary6.

The SSC- CPA PDD reflecting on the UNFCCC website as a part of the PoA (Bachat Lamp Yojana) is also being developed by same project developers? Does this not make it a bundled project with same project developers working as a part of PoA as well as independently?

Would the project developers be developing such projects with respective state electricity distribution companies, in whose areas this project falls? Would it not have an overlap / leakage to the incentive of project developer, if it does so?

G) Section 4.2 of PDD says that “In fact, CQC intends to use 14W CFLs to replace 60W ICLs as Philips has confirmed to CQC that it can manufacture 14WCFLs with a rated normal lumen output of 620…..”

If these CFLs are still in design phase, how come that the distribution and energy 	savings would happen in 2010 itself for 36,223 CERs? Would these CFLs be tested for quality and be of long life? 
How would life test be confirmed if CERs accrue in 2010 itself while these CFLs are only in product concept stage and their commercial production has yet to begin and be followed by certifications and testings? Has the DOE verified this aspect of CFL quality testing and their timely procurement? How soon / by which date would the distribution of CFLs be done in to the households by the project developers?

H) TD losses mentioned in B6.3 while calculating NES are assumed to be 31% which is too high? Is it taken arbitrarily? Do the state electricity distribution companies across these areas have these HIGH TD losses or are these taken on higher / average/lower side?  

Please send me your prompt response by return email.  


Thanks & regards 

B.Nath    
Submitted by: B Nath


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