1.	As per official website of the company http://www.moneycontrol.com/news/press-release/reliance-infra-bags-epc-contract-for-samalkot-power-project_530274.html, the total project cost of the project activity is not matching with the PDD, please clarify.

2.	DOE has to check, according to PDD Starting date of the project activity is 11/10/2010, but web site showing 26/08/2010(http://eco2data.com/project/57849), clarify.

3.	Why the entire background of the project with chronology of events with date is not documented in the PDD. DOE has to validate the events with proof.

4.	DOE to check the DPR, tender documents inviting proposals, tender correspondence, proposals etc. to clearly validate. 

5.	PP tries to hide many perils the project faced. The article appeared in Frontline is given below for better clarity. PP has to give sufficient explanation for the problems and why it is shifted. DOE has to validate. 

6.	Project proponent conveniently hides the past history of the project and presents it as if it is a new project. DOE to check the prehistory of the project.

7.	DOE to check the surplus availability of natural gas in the region  

8.	When the investment decision took place it is not stated very clearly. 

9.	The reason for excluding the power generation using natural gas with different technologies is not clear. It is mentioned in the PDD that the project activity is a combined cycle power plant with the modern state of art technology and significant efficiency improvement is not possible with current technology status to reduce GHG intensity any further. As CCPP is very efficient technology there are no higher efficient technologies available to the project proponent for power generation utilizing natural gas.

10.	 The argument for opting out of other energy sources from the baseline is not adequately demonstrated in the PDD. Where is the proof for each of the argument? PP has duty to provide to all the points it raised to opting out of renewable and other sources. 

11.	The input values taken for calculation of levelised cost of generation are not provided. Pls. clarify. 

12.	What is the basis for arriving discount factor since it has more bearing on the levelised cost. 

13.	The leakage calculation is not correct as per applied meth AM29.

14.	Chronology of events with corresponding emails, letters need to be validated by DOE.

15.	The PDD does not explain about identified training, monitoring and maintenance as per the Technology requirements for contractors / engineers by the client. There is no mention of field quality Assurance systems & procedures that are available at site, field quality plans and their approval

1.	As per official website of the company http://www.moneycontrol.com/news/press-release/reliance-infra-bags-epc-contract-for-samalkot-power-project_530274.html, the total project cost of the project activity is not matching with the PDD, please clarify.

2.	DOE has to check, according to PDD Starting date of the project activity is 11/10/2010, but web site showing 26/08/2010(http://eco2data.com/project/57849), clarify.

3.	Why the entire background of the project with chronology of events with date is not documented in the PDD. DOE has to validate the events with proof.

4.	DOE to check the DPR, tender documents inviting proposals, tender correspondence, proposals etc. to clearly validate. 

5.	PP tries to hide many perils the project faced. The article appeared in Frontline is given below for better clarity. PP has to give sufficient explanation for the problems and why it is shifted. DOE has to validate. 

6.	Project proponent conveniently hides the past history of the project and presents it as if it is a new project. DOE to check the prehistory of the project.

7.	DOE to check the surplus availability of natural gas in the region  

8.	When the investment decision took place it is not stated very clearly. 

9.	The reason for excluding the power generation using natural gas with different technologies is not clear. It is mentioned in the PDD that the project activity is a combined cycle power plant with the modern state of art technology and significant efficiency improvement is not possible with current technology status to reduce GHG intensity any further. As CCPP is very efficient technology there are no higher efficient technologies available to the project proponent for power generation utilizing natural gas.

10.	 The argument for opting out of other energy sources from the baseline is not adequately demonstrated in the PDD. Where is the proof for each of the argument? PP has duty to provide to all the points it raised to opting out of renewable and other sources. 

11.	The input values taken for calculation of levelised cost of generation are not provided. Pls. clarify. 

12.	What is the basis for arriving discount factor since it has more bearing on the levelised cost. 

13.	The leakage calculation is not correct as per applied meth AM29.

14.	Chronology of events with corresponding emails, letters need to be validated by DOE.

15.	The PDD does not explain about identified training, monitoring and maintenance as per the Technology requirements for contractors / engineers by the client. There is no mention of field quality Assurance systems & procedures that are available at site, field quality plans and their approval

Dear All
What the HELL is going on? What are you guy’s up to? What are you writing in the pre-project scenario? Has the consultant and DOE ever read CDM PDD guidelines? 
I want to know how and why the DOE has taken up such a project. What due diligence has been done before taking up such a project? Is the DOE technically competent? 
1.	Is this project applied/registered under VCS or any other GHG programme?  How many CDM/VCS projects does the PP have? Is the DOE aware of this?

2.	If the Technology used in the project activity is imported from Annex-I country (United States of America), why you need CDM? It the PP is capable of this, how can he claim that he is financially weak? 

3.	“The Gazette of India, Extraordinary”, [Part II-Sec. 3(ii)], Ministry of Power, Notification, Dated. 29/03/1994 has specified the fair life of both gas and diesel based power plants as 15 years. Then how and why PP has taken the life to be as 25year? What the DOE doing?

4.	Why after every 4 years there are 5,275 increase in CERs in the table provided in section A.4.4 of the PDD?

5.	For Plausible Alternative 6: Power generation using Naphtha, the justification by the PP is not clear and acceptable. How did the DOE evaluate this? Is the DOE aware of Government of Andhra Pradesh -2000 order “Deciding to convert all short gestation period power plants to be natural gas”. Then how is Naphtha a realistic and credible and fulfils all the criteria?

6.	For Plausible Alternative 7: Power generation using Diesel / other fuel oils, the justification by the PP is not clear and acceptable. How did the DOE evaluate this? The justification by the PP for not considering the option is not acceptable. Pls. refer the other registered PDD.

7.	The justification provided for Wind, Hydro and especially Solar is FUNNY.  For Solar, the explanation is not acceptable “Although clustering of Solar PV plants equalling the capacity of project activity is technically possible, it is not realistic to generate the electricity proposed to be generated by the project activity”. Without proving financially analysis, how can you conclude? What the DOE is doing?

8.	Why PP has not considered SUPER CRITICAL technology as another alternative to this project activity?

9.	Common practice analysis, done in 1 sentence, my goodness! Look’s very funny; can anyone tell what’s really going on? What is the EB and DOE doing? Wake up guy’s, I strongly believe that this is a FAKE project, with COOKED stuff! Is the EB fool to believe? What does the PP/consultant and DOE think? Is the DOE technically competent? On what basis DOE has evaluated this project before web hosting? This is 100% a fake CDM project, the consultant and DOE are making MOCKERY of CDM and UNFCCC guidelines. They are telling all FARIY TALE stories. Please, EB wake up, open your eyes and look into this, this is a serious issue. Don’t approve such FAKE projects. 

10.	Why SHR (Station Heat Rate) is not considered for sensitivity analysis? Again I have a doubt, is the financial part of the project looked up by an expert or the DOE just believes the consultant/PP? Has the DOE checked all the financial parameters as per the latest investment analysis guidance?

11.	Is the PP getting TAX Exemption in India by investing in this project? Is the Consultant and DOE really aware of this? Is this reflected in the financial calculation sheets? As the financial calculation sheets are not available, I request the DOE and EB members to look in to this.

12.	The PP/DOE has not proved the availability of gas is abundant in the region (AP) as per meth in the PDD, instead he is taking INDIA as a region, why? The possible leakage is also not addressed. Is the DOE aware of this?

13.	 As the life of WTG is 25 years, he is getting tax benefits and for the rest 10 years he wants CDM money. For the entire 25 years he is getting money from the state electricity board as per the PPA. With so many benefits how can you still claim that the project is financially not attractive? I request the EB members to look into it.

14.	PP has already has many electricity generating project, the core business is energy production. Then why do you need CDM money to implement this project? Has the DOE checked the annual reports/red prospect hearing and other press release related to the company? Please mention the same in the PDD for more clarity.

15.	The calculation of levelised cost is also not transparent. Are all the assumptions in parameters used for the project activity and the baseline are as EB guidelines on investment analysis? Pls justify on their conservativeness transparently in the PDD.

16.	The funniest part of all is the CER, the value’s given in section A.4.4 and B.6.4 are not the same i.e., consistent, why is it like that? What the DOE is doing, he is really not aware of the issues? Do the DOE doing a completeness check of the PDD, before web hosting? Has he is comparing with meth and PDD guidelines published by UNFCCC? What due diligence has been done before taking up such a project? Is the DOE technically competent?

17.	Life time of the project in section A.4.3 mentioned as 25 years, but in section C.1.2 it is mentioned as 23 years? Why in the same PDD like this? What is the PP and DOE up to?

18.	In section A.4.4 the crediting period date is mentioned as 30/09/2012 - 29/09/2013 and in section B.6.4 it is mentioned as 30/03/2012 - 29/03/2013. But in section C.2.2.1 it is mentioned as 31/03/2012. Oh! God, what’s happening? I am reviewing the PDD? What the DOE has done? Is the DOE really fit to do this job? How did he get accredited by UNFCCC? Are there some procedural mistakes/loop holes in the UNFCCC accreditation itself? How can UNFCCC give accreditation to such companies/organisations? I am really feel sorry to the Public/NGO and other persons interested in CDM, that they have to see such WORST PDD; this PDD is the best example of what not to do and reflects the STANDARD of the DOE and puts a BIG QUESTION MARK on its TECHNICAL COMPETENCE and capacity in not able to handle large scale projects of such nature/complexity.

19.	Coming to EIA part, it is clearly evident from this section that the PP and DOE are not having any knowledge on EIA of the host country and its procedures. As per this section there are 3 types/kinds of EIA, so let us know what exactly was done? Please clarify on what is
	Indian Environmental (Protection) Act 1986 and its further amendments
	Rapid / Comprehensive EIA
	Summary EIA

20.	Why there is no mention of natural gas in the EMP? Is natural gas a safe substance to use and no hazardous are associated with its extraction/transport/storage/use?

21.	I request the PP/DOE to give the “Clean Development Mechanism (CDM) compliance procedure for local stakeholder consultation meeting” as indicated in section E.1 of the PDD. Why the PP has identified people involved with implementation and operation as the local stakeholder (these are the employee of the PP, and definitely will a positive response)? It’s funny! And a serious issue to look, now it’s clear that the local stakeholder consultation meeting was held without the people who are opposing/harmed by this project activity were not consulted. The process and procedure of stakeholders meeting mentioned in section E of the PDD is not adequate and transparent, as a 3rd party I am not able to know what exactly happened? Has the DOE aware of VVM? Has he seen/heard or read this anywhere? 

What the DOE is doing, he is really not aware of the above issues? If yes, then how and why did the DOE webhost this project? I strongly feel that the project should not have been web hosted, however the consultant and DOE have succeeded in achieving this.  Therefore, now I request the EB members to look into this project as a special case. 
After going through project PDD, I strongly believe that this is a FAKE project, with COOKED stuff! I think that DOE in not technically competent. I want to know on what basis the DOE has evaluated this project before web hosting. The PP/consultant and DOE are making MOCKERY of CDM and UNFCCC guidelines. They are telling all FARIY TALE stories. And think the EB and others are fools to believe this? What does the PP/consultant and DOE think? 

This is 100% a fake CDM project. Please, EB wake up, open your eyes and look into this, this is a serious issue. Don’t approve such FAKE projects. 

Dear all,
Please see how Reliance is trying to make us fools. Entire Globe knows that Reliance is expanding the NG power plant in Samlkot and GE bagged 2000 MW order also(http://prosperingindianpowersector.blogspot.com/2010/11/reliance-power-ge-sign-750-mn-deal-for.html). Then Why Reliance is webhosting Pahse-1, Pahse-11 and may come Pahse -111 in future and that too with different DOEs. You are spoiling entire CDM mechanism. I simply ask you one question! You have registered the Sasan Project (Ref:3960) considering 6X600 MW with different commissioning periods; then why didn’t you go for 6 validation with different DOEs? And Why are you going ahead with 754 MW I phase wise? Meaning- you are trying to check your fate three times instead of one time. Have reliance prepared one DPR or Three DPR? If it is one DPR why three webhosting?Everybody knows that you can prepare three DPRs for phase wise; Have Ministry provided clearance for phase wise or as a total? Ceratinly, it cannot be for phase wise; If this is the case I request DOE not to consider this for validation and request PP to recall all the earlier webhosting PDD and combine as one and go ahead.

Baseline Development and Additionality
It is quite interesting and making yourself fools by projecting such kind of alternatives as the most plausible baseline alternatives. Can any Indian Investor invested in Lignite based power plant with a capacity of 2000 MW  in recent times? Secondly, what is Reliance past record? Have you ever implemented any Lignite based power plant? You have 4000 MW Sasan, 4000 MW Thaliya (Jarkahnd), 4000 MW Krishnapatnam (Andhra), 4000 MW Chitrangi Power plant, Rosa-1. Rosa-11, Butibori Power Project and all are coal based and mostly super Critical technologies (http://www.reliancepower.co.in/business_areas/power_projects/coal_based_projects.htm ). Ohh, you got LUCE of Lignite is higher that is the reason on a Hypothetical basis you have considered Lignite based subcritical as alternative. 

This project is not additional as the Lignite based Su-critical cannot and should not be an alternative. I also highlight the issues w.r.t Sasan Project (UNFCCC 3690) which is registered. You have projected in the project of UNFCCC ref 3690-(Sasan project) the LUCEs of Natural Gas advanced class, Supercritical, sub-critical pit head and Lignite as 2.98, 1.139,1.073 and 2.224. Surprisingly, within short span of time period, your LUCEs have gone like mad i.e. 2.74, 2.12, 2.06 and 2.94. Is there any Logic my dear bluff master. This itself clear demonstrate that the project is not additional. You should feel shame on your part for trying dilute the CDM mechanism;  trying to make CDM EB, DOE, and stake holder as fools; Meaning, you want to make the things to turn whichever the way you want to make the project additional. I request DOE to check the most plausible baseline scenario and ensure that the plausible scenario is “Super Critical Technology”

Interestingly, ACM0013 and AM029 mention that the additionality determination should follow the Additionality tool. You have considered IRR in UNFCCC 3690 buy, why didn’t you compute the IRR in present project. Methodology did not say to compute the LUCE for additionality request DOE to ensure the Re-webhosting of PDD for stakeholder consultation process on IRR basis.

Though the project does not go forward, a stake holder I need to comment on Emission reduction!. DOE is requested not to give any hypothetical emission reduction as per VVM considering the Sub-critical Lignite as the baseline. Most plausible baseline scenario should Supercritical-Pithead. The differential efficiency of supercritical efficiency to Natural gas power plant efficiency would only the emission reductions. 

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. 

1.	PDD hasn’t discussed adequately pre-project and baseline scenario and taken baseline is absolutely wrong and unprofessional, Doe needs to check regarding this.
2.	When reference plant is chosen as baseline (which is anyway wrong), then benchmark should be based on reference plant. Calculate LUCE for both the proposed project activity and reference plant and prove that proposed activity is less financially attractive than reference plant. They have chosen (I don’t know what approach) something different and arguing.How it is calculated and PP has to prove during the global stake holder consultation itself and later stages. How DOE allowed this. PP to choose levelised unit cost of generation to argue the additionality.

3.	PP fails to demonstrate how sub critical (Coal based) have been considered as only realistic alternative in the PDD. It seems from the hindsight that PP decided to take subcritical system as baseline and arrived at the plausible alternatives. PP has not demonstrated why it is not considering renewable energy sources.


4.	The investment analysis is neither transparent nor reproducible and therefore does not support the selection of subcritical coal-fired power plants as the Project’s baseline. Furthermore, project participants fail to include required elements under AM0029.

5.	Moreover, the PDD conveniently suppress the facts of incentives for plant load factor. PP has to explain how these incentives affected the baseline scenarios and technology choice. 


6.	Capacity of the baseline scenarios was not given transparently in the relevant sections. To make the supercritical PP less financially attractive, From hindsight, it seems that PP has decided and concluded it is taking sub critical coal based PP as baseline and then making other alternatives less attractive to argue the additonality. Pls. clarify.

7.	Critical techno-economic parameters and assumptions (such as capital costs, fuel price projections, lifetimes, the load factor of the power plant and discount rate or cost of capital) should be clearly presented. Justify and/or cite assumptions in a manner that can be validated by the DOE. In calculating the financial indicator, the risks of the alternatives can be included through the cash flow pattern, subject to projectspecific expectations and assumptions (e.g. insurance premiums can be used in the calculation to reflect specific risk equivalents). Where assumptions, input data, and data sources for the investment analysis differ across the project activity and its alternatives, differences should be well substantiated. The CDM-PDD submitted for validation shall present a clear comparison of the financial indicator for all scenario alternatives. The baseline scenario alternative that has the best indicator can be pre-selected as the most plausible baseline scenario”. But PDD does not include this aspect.


8.	Common practice analysis: PP fails to establish how many  PP is running in India and then they should argue about their viability. Their argument misleading that the project is of first of this magnitude which is wrong as far as my little knowledge is concerned. The PDD does not fulfill the requirements of the common practice analysis, which compares the proposed Project to similar activities occurring without CDM funds in order to check the credibility of additionality claims. The project participants do not substantiate their claim that construction of supercritical coal plants is not a common practice in India.

9.	While PP argument that not many PP available that is operational in India, they seem to hide the fact that the majority of new coalfired power plants are expected to use this technology. News reports suggest that at least 35 supercritical plants, in addition to the proposed Project, are at various stages of planning and implementation in India. The PP may argue at the later stages that based on project information listed on the CDM website to argue that all other supercritical coal plants( may be 4 or 5 )  are in CDM development. DOE has to validate


10.	Date of EPC contract- 11/10/2010. This needs to be checke by DOE.  And confirmation from the contract copy whether it is genuine one or not.

11.	Supercritical PP has been proved less atteactive than other alternatives. But addtioanlity is based on project is not viable without CDM revenue. This aspect is not argued at all. How DOE has allowed this. Pls clrify.  


12.	While calculating levelised unit cost of electricity generation tariff all input values should be taken at the investment decision but Project investors have not provided the source and it is not clear that these values were taken at the time of investment decision. DOE has the responsibility to check the authenticity of values and justification.

13.	PP does not state the investment decision date explicitly and DOE has to validate. 
14.	The PDD does not explain about identified training, monitoring and maintenance as per the Technology requirements for contractors / engineers by the client. There is no mention of field quality Assurance systems & procedures that are available at site, field quality plans and their approval.

15.	Host country is already encouraging sustainable development on basis of clean technology and cleaner fuel, in this case how this project meet additionality criteria of CDM process?


16.	Who is consultant for the PDD preparation? 
17.	Whether uninterrupted supply of Natural Gas has been ensured from suppliers for continuous operation? Whether gas will be provided from existing network of pipeline or modification is needed?

18.	Whether project has got Environment Clearance from Ministry of Environment & Forest? What are major conditions stipulated in Clearance?
19.	PP should clarify what is the actual capacity of the project activity; in section A.2 the total capacity is not consistent throughout the PDD.

20.	PDD does not clearly describe the stakeholders involved in Project or the information provided to them. The PDD mentions selected stakeholders, but does not detail which of these stakeholders actually participated in the process. The PDD does not describe the information provided to stakeholders with sufficient clarity, such as whether adverse environmental impacts were described along with the benefits that were mentioned.