It is the responsibility of DOE to conduct proper due diligence and contract review before signing any contract. Now DOE to explain what it has done this project case. Why a DOE should work this kind of cooked up and fake CDM projects. How many genuine projects this Big 4 firm has done till to date? This Big 4 firm is responsible for corrupting and spoiling the whole CDM business in India. Why this Big 4 firm not working like any other consultant in the market? Why is it web hosting projects which should be rejected, with drawn, forged (documents changed and forged) and fully problematic projects? 

The Partner of this Big 4 firm is fully responsible for spoiling the CDM business in India. He is totally unprofessional and unethical. He never did any work in a professional and ethical manner in his working. This Big 4 firm should not work with any PP in the market. 

Every project owner and DOE whoever is working with this Partner of Big 4 firm should introspect, understand the implications and stop working with this audit firm. They use the audit practise to force clients to take their CDM services. Their audit team is built on totally wrong foundation with robbed clients allowed wrong doing and cheated the system, deceived the country. One should be ashamed of working with this Audit firm in what so ever manner. He spoiled old DOE’s and recommends clients to bribe the DOE auditors and others in the system.

Every new and old DOE entered in the market was misused by the Partner. How long he wants to spoil CDM business and earn disrepute permanently? What is he finally going to achieve? Some money and bad name for ever? DOE to seek answers from the parent auditing company, on these points and take appropriate actions to save the project owners and CDM business fraternity from this Partner and evil company. Never believe the documents given by this audit company, DOE must cross check all of them as they are the forgery masters. 

DOE to be careful in undertaking any jobs referred by this kind of Big 4 firm, instead they should not take up the job at all in the best interest of CDM business and to protect their interests and reputation. 

How GHG emissions will be reduced on account of the proposed project activity is not provided in the PDD.

2.	What is the power demand of the plant? What is the source of power prior to project activity? It is not clear whether only grid was the source before implementation of the proposed project activity. 

3.	It is clear from the PDD that the generated electricity is used for captive purposes, then why the generated electricity (at 11 KV) is stepped up to 33 KV and connected to 33 KV CSEB grid line. What is the need of this kind of design? The electrical layout comprises of generation, step up and step down transformers need to be demonstrated in the PDD.

4.	The value of quantity of flue gas generated mentioned in section A.2 and Section A.4.2 is not consistent. Waste energy and WECM stream is not adequately defined in the PDD. How is it proved that waste gas is termed as waste energy? It is not properly defined as per Methodology AMS III Q in the PDD. Pls. clarify.
5. 	When was the  plant commissioned? What is the status of the proposed project activity? How long flue gas is being wasted without utilised?

6.	As per EB51 Annex 59 Para9, for projects in which the electricity was being produced for captive consumption the benchmark of the core business was considered to be appropriate, as the project was considered to be an investment in the operation of the core business. PP has taken grid connectivity as benchmark which is wrong. The low risk projects cannot be compared with high risk projects. Because the proposed project activity could be developed only by the project developer and nobody else. So WACC could not be taken as benchmark. Pls. take internal benchmark as benchmark for determination of additonality. 
7.	When was DPR for captive power plant prepared? Since the project is existing one, the amount of waste heat utilized in the project activity that was released into the atmosphere prior to implementation of proposed project can be measured by direct measurements of energy content and amount of the waste gas from the date of commissioning of kiln prior to the start of the project activity. But why PP has chosen energy bills and process plant data to prove this. Pls. clarify.

8.	During emergency shutdown of kiln and turbine tripping, what is the source of power generation? It is not demonstrated with evidences that during the abnormal condition i. e emergency shutdown of the plant; waste gas shall be accounted for. What are the precautions and provision taken to ensure that waste gas /energy are not accounted for the calculation of emission reduction? Pls. clarify. Refer B.2
9.	Power tariff is not appropriate parameter to be included in the sensitivity analysis. PLF, no of hours operating and O&M charges are to be included in the sensitivity analysis. Refer B.5.

10.	The following are to be calculated indirectly and recorded on daily basis. Specific quantity of flue gas generated/end product of kiln (qwcm/product), Specific quantity of flue gas produced/ fuel fired in kiln), Specific quantity of fuel fired in kiln/end product of kiln.  These aspects are not documented with justification in the PDD. These parameters should be monitored so as to cross check the actual quantity of waste gas generated.  Quantity of end product in the kiln, quantity of fuel fired should be cross checked with sales and purchase department respectively.
11.	When the PP did not mention other barriers like technical, Infrastructure barrier etc. for the additionality, Common practice is not strong enough to prove that the project activity is business as usual.