1) PP has used the PLF of 24.16% which is lesser than the TNERC recommended PLF (27.15%), this shows that PP has used 3% lesser PLF than the recommended PLF. DOE shall ask the PP to use 27.15% PLF in the project activity and use the same PLF in the sensitivity analysis. Nowadays Tirpur district is generating PLF of around 30%. Hence DOE has to ask the PP to use 27.15 % recommended PLF in the project activity and use the same in the sensitivity analysis to prove 30% PLF.
2) As per the version 17, the grid is also a part of project boundary.
3) CEA database version 6 has been used in the project activity and the link used in the PDD is version 05.
4) How the local stakeholders were invited for the stakeholders meeting and how it was compiled
5) PP has stated that "local stakeholders were invited by distributing printed invitation well in advance" well in advance means state the exact date and proof for the date and also DOE has to ask the PP, how the printed invitation was distributed
6) In the section B.4 of the PDD, no need to incorporate the formulae, PP has to describe about the baseline activities
7) PP has not provided any information related to the WACC for the global stakeholders process. DOE has to cross check the calculation thoroughly like how the companies were chosen in the BETA calculation, PP has to use the even duration in the beta calculation. PP has to use the minimum beta in the WACC calculation
8) Why BSE 500 was used? PP may answer for this question like most of the companies has covered under BSE 500 but PP has to use BSE 200 or 100. These are the most appropriate stock exchanges. If possible DOE can ask the PP to use NSE data’s
9) PP has used pre tax Benchmark and IRR. here i would like to say something to DOE that the most of the PP investment in the wind power project is for TAX deduction, TAX Holiday and TAX shield benefits, etc., Hence DOE has to cross check the additionality with Post TAX benchmark and Post TAX IRR. PP can use Pre TAX but they have to prove their additionality with Post TAX also.
10) There is no information provided in the PDD related to Investment analysis and the source for that. This is not a complete PDD as per the CDM glossary. Consultant has purposely done the same. DOE has to re-webhost the PDD contains all the information related to WACC and the investment analysis. 

There is no mention about the compliance of this project activity to Annex 13 of EB 62. Though the PP /consultant cite the latest guidelines on investment analysis (Annex 5, EB 62), they are still using the wordings of earlier version. Annex 5, EB 62 does not seem to contain the sentence, ““In the cases of projects which could be developed by an entity other than the project participant, the benchmark should be based on publicly available data sources which can be clearly validated by the DOE. Such data sources may include local lending and borrowing rates, equity indices, or benchmarks determined by relevant national authorities”.

PDD gives only theoretical background of CAPM, as the PP/consultants understands and not the data based on which the WACC has been arrived at. Not even a single data – market return, companies selected for beta computation, duration and return interval used, cost of debt, expected return on equity or risk free return- has been given in the PDD. Will the DOE please explain whether the global stakeholders are required to comment on theory as the PP/consultant understands it, or the input parameters used.  

Leave alone benchmark, the PDD does not give any information on the input parameters used for calculating financial indicator also. Guidelines for completing the PDD states that all the input parameters and assumptions should be given transparently in the PDD. Additionality Tool requires the PP to present the investment analysis in a transparent manner and provide all the relevant assumptions, preferably in the CDM-PDD, or in separate annexes to the CDM-PDD, so that a reader can reproduce the analysis and obtain the same results. This PDD does not give any information. 

Hiding information only proves that the project is not additional and has been made additional. Otherwise there is no reason why the PP should hide information from global stakeholders.  The project is made additional. This can be seen from the PLF assumed by the consultant. For a project located in Tirunelveli Dist., PP/consultant gives PLF of 24.16%! TUV Nord itself has webhosted and registered projects from Tirunelveli District with 30% PLF!! Consultant would have avoided giving this information also if Sec. B.6 and B.7 permitted giving vague information. This project, located in Tamil Nadu, cannot give an IRR of as low as 6.75% unless the input parameters are all over stated, tax saving is not considered and revenue is grossly underestimated. 

Therefore, this project should not be taken up for validation by DOE unless the PP re webhosts the PDD with all information. If the DOE goes ahead with validation without re webhosting, it will prove that it is also not aware of the rules. EB may kindly note this proposal and do not accept it for registration unless it is re web hosted.

EB should note this project and this trend and ensure that this project is not accepted for registration without being re-webhosted with all information.