5.30 MW Bundled Wind Power Project in India
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Host party(ies) India
Methodology(ies) AMS-I.D. ver. 16
Standardised Baselines N/A
Estimated annual reductions* 9,505
Start date of first crediting period. 30 Jun 11
Length of first crediting period. 10 years
DOE/AE Bureau Veritas India Pvt. Ltd.
Period for comments 21 Jan 11 - 19 Feb 11
PP(s) for which DOE have a contractual obligation Sanghvi Foods Pvt.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 (1315 KB)
Local stakeholder consultation report: N/A
Impact assessment summary: N/A
Submission of comments to the DOE/AE Compilation of submitted inputs:
The PP states that they have considered 80% accelerated depreciation. However the PDD is silent on the tax shielding as a result from accelerated depreciation.
PPs cleverly do not consider the accounting tax offsetting in their companies while calculating the IRR. This is evident from the recently registered projects and those requesting registration.  
The DOE is therefore requested to critically analyze how the accelerated depreciation benefit has been taken into account and confirm the accounting of the cash inflows as a result of the negative tax liability in the initial years. DOE should not be misguided by the financial presented by the PP or consultant which are custom made for CDM purposes and not the actual financial considered at the investment decision.
Note that considering cash inflows results in an increase in the IRR making wind projects a profitable venture.

Please also check the offer from WTG supplier and Purchase Order while validating the PLF. It may be so that the third party report may indicate a lower PLF.

The start date of the project is way back in 2005. This clearly indicates there is no CDM consideration at all by the PP. PP must have created forge documents for proving that the PP had contracted with consultant (Synergy global). DOE should interview and ascertain that indeed there was a contract executed. Also validate why then the project did not go ahead for validation in 2006/2007? Why all of a sudden now the PP wants CDM and is validating in 2011??? 6 years later than investment decision making??

Did the PP really consider such a high benchmark while evaluating the investment decision?? 18% is too high for taking investment decision. PP has constructed a higher benchmark so as to prove additionality. Market returns seems to be high. DOE to evaluate conservativeness.

Power purchase rate for Sanghvi (I) should be compared with the prevailing purchase rate currently as this is the rate which the PP is benefitting now.

Per MW cost should be compared with that indicated in the respective tariff orders for Maharashtra and Rajasthan prevailing at the time of decision making.
Submitted by: Babloo

Comment (24 KB) Submitted by: Decosta


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