The project is not satisfying methodology. Natural Gas is not available in the country. If the DOE Google the non-availability of gas for power projects in India, it will  come across a number of websites which will prove that whatever the PP says is not correct. The Ministry of Power in its letter dated March 14th states, “As per the information made available by MOP&NG regarding NELP gas the production is likely to go down by 15.03 mmscmd in 2012-13 and additional 3.42 mmscmd in 2013-14 against the availability of 42.67 mmscmd of gas in 2011-12. MOP&NG has not given any projections for the years 2014-14 and 2015-16. It is evident from above that no additional domestic gas is likely to be available till 2015-16. Hence, developers are advised not to plan projects based on domestic gas till 2015-16.” 

The PP has accepted the non availability of gas and the report available in the web says, “Hyderabad-based Lanco Group has been unable to commission its 740MW power plant at Vijaywada in Andhra Pradesh because of the non-availability of gas. “We have invested close to Rs. 2,600 crore and the plant is ready for commissioning from the last two months,” a company official said, requesting anonymity. “We have not been able to sign a power purchase agreement as there is no assured fuel supply from the government despite several representations.” (http://www.livemint.com/2011/11/17233943/Decline-in-gas-supplies-makes.html). 

Annual Report of the company reveals that the project achieved capacity utilization of only 66%. When the PP has projected 85% PLF, why should the plant achieve only 66% PLF? The entire explanation given in sec. B.3 is unreliable and the project is not fulfilling the requirement of methodology.

PDD states it is a merchant power plant. Hence, the tariff and the cost of generation are mutually exclusive. Then, how can levelised cost be considered as financial indicator for selecting the baseline?  Ministry of power uses levelised cost for its project is not a valid reason for applying the levelised cost as Government projects are not merchant power plants. IRR should be the basis for selecting baseline.

The logic given arguing the use of levelised cost as financial indicator in sec. B5 is not correct. If this argument is correct then all renewable energy power projects can use investment comparison analysis using levelised cost as the financial indicator. This is becasue PPs can set up any other renewable energy based power project or fossil fuel based power projects. The argument is wrong.  Step 1 of the methodology clearly states that the benchmark analysis should be used for additionality demonstration. Additionality tool gives benchmark only for NPV and IRR and not for levelised unit cost. Therefore, the argument given for levelised unit cost shows that the PP is misleading. 

PP has realized that the argument is not correct.  It is for this reason that he has also given project IRR (calling it as equity IRR!) with WACC as benchmark. With the given input parameters, it is not possible to reproduce the analysis and arrive at the same results as required by the methodology. But one thing is certain that the PP has used levelised cost as tariff, which is not correct, as it is a merchant power plant and the tariff will be higher than the levelised cost. If the prevailing merchant power tariff is taken into account the project cannot be additional.    

1.	In India there is huge shortage of Natural Gas especially the irregular and interrupted supply of the Gas. At the same time the project proposed to use Natural gas which would further aggravated the problem. In that case the present user of the natural gas would be forced to switch to the alternative such as fossil fuel and ultimately the GHG would be released.

2.	No plan has been submitted regarding use of 2% of the net revenue accrued from the sale of CER toward achieving the sustainable development goals.

3.	The investment analysis is incomplete and fails to provide the data and assumptions necessary for reader to reproduce the result.

4.	No information has been provided regarding the cost of fuel switch in the PDD.


5.	As per the EIA report the noise level recorded in the individual process units exceeded the stipulated standards of Central Pollution Control Board (CPCB).

6.	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.


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

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


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

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


11.	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. 

12.	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.


13.	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.

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


15.	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.  

16.	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.


17.	Please also check the offer from WTG supplier and Purchase Order while validating the PLF. It may be so that the third party report which is made after investment decision making - indicates a lower PLF. The PLF seems to be very low. Also check the tariff order.

18.	methodology selection is wrong – applicability condition 1 of AM0029 requires ‘The project activity is the construction and operation of a new natural gas fired grid-connected electricity generation plant.’ This project plant is only a modification of an existing plant that operated for many years now.


19.	If the plant is just a retrofit, how baseline can be a coal based plant? Was it possible to retrofit this GTs to use coal? This is a ridiculous claim by behalf of PP and consultants.

20.	Whether project has got Environment Clearance from Ministry of Environment & Forest, New Delhi? What are major conditions stipulated in Clearance?


21.	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?

22.	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?


23.	Whether Environment Public Hearing as process of Environment Clearance was arranged for this gas based power plant? If yes, what were major discussion and decisions of Environment Public Hearing?
24.	Additionality

The methodology considers a project additional under the following circumstances

a)	There is a more economically attractive and GHG intensive alternative available to the project activity (lower levelized cost when compared to the project activity); and
b)	The project on a standalone basis is not financially attractive (low IRR as compared to standard industry benchmark)

While the PP has demonstrated that there is a more economically attractive option available as compared to the project activity, it has not demonstrated that the project on a standalone basis is not financially viable . As the project activity involves displacement of power on the grid and the alternative can be set up by any other entity as well, it needs to undertake a benchmark analysis. In order to perform benchmark analysis, the PP needs to take into account the tariff that it receives from the sale of power. 

The plant is being setup as a Merchant Power Plant (MPP) and hence may not enter into a long term PPA. It is a well known fact that merchant power plants are very attractive, because they get higher tariff than PPA based power plants. An article in Powernomics is quoted here.

1)	DOE to ensure that the PDD values are consistent and ensure that the CDM project is a genuine project.
2)	DoE to check the Detailed Project Report and Feasibility Report which is submitted to the other agencies and Banks by Project owner and ensure that the values match with the DPR/FR  submitted to DoE also. 
3)	Careful study must be done so that the DPR/FR is not in different versions made and submitted with different purposes to different agencies, which is totally unacceptable, illegal and unethical. 
4)	Project owner should show some undertaking letter from bank manager to DoE stating that both DPR’s are same. These kinds of letters should not be accepted and entertained by DoE at face value, but must be checked independently. While collecting the DPR/FR from banks and other agencies, all DPR/FR pages should be counter signed by Banks and other agencies so that the real DPR/FR given to other parties by the PP/Consultant is same as the one submitted to DOE. 
5)	DPR/FR values must be probed fully. DOE must take a written undertaking from the PP/Consultant about the list of parties to whom this DPR/FR is submitted and for what purposes. Then DOE should cross check with all the parties and confirm that the same DPR/FR is submitted to all the parties correctly without any changes. DOE must not accept any reports and undertakings from PP/Consultant. DOE must make independent evaluation and use totally different parties without informing the PP or Consultant to cross check the facts. 
6)	DOE to write to the party who prepared the DPR/FR which is submitted to the banks and other agencies and the same is verified against the one submitted to the DOE by PP/Consultant. 
7)	DOE must not entertain this project any more if found the DPR/FR is tamprered with at any point in time. PP can not give different DPR’s and FR’s. They must submit only the one given to Banks and other agencies while obtaining loans and decision making time. 

8)	Has the PP considered the CDM revenues while envisaging the project? Without CDM the project was not viable, is it right? This project is having a debt component? Then how bankers or lenders gave the loan? Have the bankers or lenders considered the CDM revenues while agreeing to give loan to this projects? If not this project should be rejected right away by DOE by terminating the contract forthwith. If yes, where is the proof? What is the date of the evidence document from bank? Is this document printed now a days or earlier. DOE to independently check the same. If the document is  available from Bank it must be checked from all angles so that it is genuine and not forged and date changed by putting back dated. This is normally done, DOE to be aware of this please. Please check the communication the PP had during that time with banks, emails and postal receipts and the weights and dates mentioned on the receipts. Do not believe in courier bills and receipts since these can be cooked up easily. Insist on government owned postal service receipts only. If the project is fully equity project then on what basis the PP has invested full equity in to the project while considering the CDM revenue? DOE to check the same in detail and bring out the facts. Is there any past record of this PP to invest or not to invest at returns what he is talking about in this project? Proper evidences must be reviewed and digged out by the DOE and take decision on the project based on established facts. Do not ask documents from PP, DOE to collect the same from different sources to do independent evaluation. 

9)	Is the project equipment purchased second hand equipment or sourced from cheap foreign sources? If yes, the issue must be probed by DOE since invoices will invariably be inflated and forged. Total project costs mentioned by PP will not be the same as originals. Hence no additionality. These facts must be probed in full by DOE by checking all documents and money transactions along with bank statements and certified accounts by a legally acceptable financial analyst. 

10)	From DOE side which auditor has done marketing and business development for acquiring this business of validating this project? With whom he or she was co-ordinating at PP or CER buyer? The same person who has done the marketing and business development to acquire the business do validation or participate in any manner what so ever in the validation process? One cannot do like that. It is against the accreditation rules and norms followed since ages. DOE should send auditors from different offices or countries to do this validation audit. DOE must take care of impartiality and accreditation rules. Due to the targets set by the DOE managements auditors are doing marketing and meeting clients and giving promises that the project will be taken care. Is it acceptable and fair? This must be stopped. No auditor should do marketing. Only non-auditing staff should do marketing. DOE to ensure the same please. 


11)	If applicable only: Is these machines, equipment was a part of any bundle of CDM activity envisaged and developed earlier. DOE to check the same through independent sources also. Once some bundles are non-additional and getting negative validation from a DOE, PP is rolling out the same project as an individual project which is not a CDM project at all. DOE to verify the same from independent sources and also take undertaking in the form of an affidavit from the PP’s that any misrepresentation or false statement with respect this would attract strict legal action from UNFCCC and DOE. Furthermore the registered project must be de-registered in case of any future findings contradicting the submissions made by the project owner.  

12)	DOE to be more careful so that this is a genuine CDM project. What is the exact project cost? The project cost is covering what? Each value considered must be validated with proof. The machinery is second hand purchased or fresh and new from an OEM? In either case DOE to check all the quotations, proposals, purchase orders, invoices, way bills, transport bills, proof of payments like bank statements. DOE to check with banks by way of written confirmation the amount transacted, to whom the money is paid, when the money is paid, is the party paid is the correct party as shown in the purchase orders. It may so happen that the values, party names, dates are fabricated and misrepresented in this project. DOE should terminate their contract for this project immediately. This is the only way out to protect the value of CDM process. If the PP is purchasing second hand or second quality equipment and inflating the purchase order values and invoices, this must be probed thoroughly and real values to taken for additionality calculation. Then I’m sure the additionality is not there at all in such a situation.

13)	 How is the base line defined in this project? Is Base line hypothetically defined with no proper evidences and proper justification? In such case, DOE cannot take the base line as suggested by the PDD.  Please check that there are real emission reductions beyond the real and factual base line. It may so happen that this project qualifies for no CER’s. DOE cannot assume values and things as giving by this PP. Whatever values are considered throughout the project in all documents including the real DPR (not the one prepared for CDM, the one given to the banks and others), they must be validated, verified and double checked. Do not ask PP for DPR. Ask the parties who have been given DPR by the PP. Get directly from the bank and others by each page of the DPR and Feasibility report signed. Such document can be considered as a real DPR or FR. UNFCCC CDM process cannot be degraded by fabricating and misinterpreting the project base line and additionality.  

Do send some auditors who are not in the business development and marketing with the PP. Bureau Veritas should depute a team for any audit who is not involved in the marketing with the client. Bureau Veritasnow a days is doing CDM audits in very short time and giving reports. Why and how? What has changed? Overnight have they become very knowledgeable? Same people, same systems and their attitude towards CDM validation has changed and BV auditors are giving request for registration without checking the full particulars of the project. Why the sudden change in attitude? Auditors want to milk CDM and spoil CDM system and then go for their regular inspection and ISO certification stuff when CDM dies? Because of DOE’s like this only CDM is going to dogs. Auditors like HB Muralidhara, Sanjay Patankarand other likeminded auditors in BV are going very fast on CDM projects of their choice and certifying in a great hurry. Why? Bureau Veritas management should probe this? If BV management does not take real interest and keep the house in order, UNFCCC should check this issue. Why BV’s all old projects which are publishedfor comments in 2007 and 2008 are getting request for registration all of a sudden? What clients have shown and given off late which they have not done in the last 3 years or so? What is this? What is happening? What kind of TR is being done? Is TR done just for the sake of doing or is TR raising any true and genuine issues? HB Muralidhara and Sanjay Patankar should not be used for any large scale projects as LA as their independence is definitely questionable. 
They should be used only for TR and some “independent and new to consultants and large group companies”auditors to be used as LA’s. At least both of them should be sent to Inspection to save BV’s reputation on CDM business. BV auditors relationship with some of the big group of companies in India & other countries and some consultants is questionable and brings disrepute to CDM process. Names need not be written, everyone knows including BV’s management. If no credible corrective actions are initiated immediately by BV’s management then we have no other option except to come out openly with names of companies and consultants with whom BV is involved in wrong activities. 
How come HB Muralidhara and Sanjay Patankar do audits for clients and consultants when both are doing marketing and seeking business from market? Is this allowed in any third party certification business? Why BV is flouting rules, for disgrace? Why BV’s auditors themselves are giving suggestions how to close CAR’s and CL’s for CDM projects? Why they are advising corrective actions? Is it acceptable? BV’s management and UNFCCC should look into this matter and correct the things immediately in the interest of CDM process. Flavio Gomes is fit for counting revenues and does not have a proper oversight on his own business operations area, which is proven effectively now. It’s time to set the business in order. Copy marked to UNFCCC. 

1.	Is the project equipment purchased second hand equipment or sourced from cheap foreign sources? If yes, the issue must be probed by DOE since invoices will invariably be inflated and forged. Total project costs mentioned by PP will not be the same as originals. Hence no additionality. These facts must be probed in full by DOE by checking all documents and money transactions along with bank statements and certified accounts by a legally acceptable financial analyst. 

2.	From DOE side which auditor has done marketing and business development for acquiring this business of validating this project? With whom he or she was co-ordinating at PP or CER buyer? The same person who has done the marketing and business development to acquire the business do validation or participate in any manner what so ever in the validation process? One cannot do like that. It is against the accreditation rules and norms followed since ages. DOE should send auditors from different offices or countries to do this validation audit. DOE must take care of impartiality and accreditation rules. Due to the targets set by the DOE managements auditors are doing marketing and meeting clients and giving promises that the project will be taken care. Is it acceptable and fair? This must be stopped. No auditor should do marketing. Only non-auditing staff should do marketing. DOE to ensure the same please. 


3.	If applicable only: Is these machines, equipment was a part of any bundle of CDM activity envisaged and developed earlier. DOE to check the same through independent sources also. Once some bundles are non-additional and getting negative validation from a DOE, PP is rolling out the same project as an individual project which is not a CDM project at all. DOE to verify the same from independent sources and also take undertaking in the form of an affidavit from the PP’s that any misrepresentation or false statement with respect this would attract strict legal action from UNFCCC and DOE. Furthermore the registered project must be de-registered in case of any future findings contradicting the submissions made by the project owner.  



4.	DOE to ensure that the PDD values are consistent and ensure that the CDM project is a genuine project
5.	DoE to check the Detailed Project Report and Feasibility Report which is submitted to the other agencies and Banks by Project owner and ensure that the values match with the DPR/FR  submitted to DoE also. 
6.	Careful study must be done so that the DPR/FR is not in different versions made and submitted with different purposes to different agencies, which is totally unacceptable, illegal and unethical. 
7.	DPR/FR values must be probed fully. DOE must take a written undertaking from the PP/Consultant about the list of parties to whom this DPR/FR is submitted and for what purposes. Then DOE should cross check with all the parties and confirm that the same DPR/FR is submitted to all the parties correctly without any changes. DOE must not accept any reports and undertakings from PP/Consultant. DOE must make independent evaluation and use totally different parties without informing the PP or Consultant to cross check the facts. 
8.	DOE to write to the party who prepared the DPR/FR which is submitted to the banks and other agencies and the same is verified against the one submitted to the DOE by PP/Consultant. 
9.	DOE must not entertain this project any more if found the DPR/FR is tamprered with at any point in time. PP can not give different DPR’s and FR’s. They must submit only the one given to Banks and other agencies while obtaining loans and decision making time. 



10.	 How is the base line defined in this project? Is Base line hypothetically defined with no proper evidences and proper justification? In such case, DOE cannot take the base line as suggested by the PDD.  Please check that there are real emission reductions beyond the real and factual base line. It may so happen that this project qualifies for no CER’s. DOE cannot assume values and things as giving by this PP. Whatever values are considered throughout the project in all documents including the real DPR (not the one prepared for CDM, the one given to the banks and others), they must be validated, verified and double checked. Do not ask PP for DPR. Ask the parties who have been given DPR by the PP. Get directly from the bank and others by each page of the DPR and Feasibility report signed. Such document can be considered as a real DPR or FR. UNFCCC CDM process cannot be degraded by fabricating and misinterpreting the project base line and additionality.  

11.	DOE to be more careful so that this is a genuine CDM project. What is the exact project cost? The project cost is covering what? Each value considered must be validated with proof. The machinery is second hand purchased or fresh and new from an OEM? In either case DOE to check all the quotations, proposals, purchase orders, invoices, way bills, transport bills, proof of payments like bank statements. DOE to check with banks by way of written confirmation the amount transacted, to whom the money is paid, when the money is paid, is the party paid is the correct party as shown in the purchase orders. It may so happen that the values, party names, dates are fabricated and misrepresented in this project. DOE should terminate their contract for this project immediately. This is the only way out to protect the value of CDM process. If the PP is purchasing second hand or second quality equipment and inflating the purchase order values and invoices, this must be probed thoroughly and real values to taken for additionality calculation. Then I’m sure the additionality is not there at all in such a situation.
12.	Project owner should show some undertaking letter from bank manager to DoE stating that both DPR’s are same. These kinds of letters should not be accepted and entertained by DoE at face value, but must be checked independently. While collecting the DPR/FR from banks and other agencies, all DPR/FR pages should be counter signed by Banks and other agencies so that the real DPR/FR given to other parties by the PP/Consultant is same as the one submitted to DOE. 
13.	Has the PP considered the CDM revenues while envisaging the project? Without CDM the project was not viable, is it right? This project is having a debt component? Then how bankers or lenders gave the loan? Have the bankers or lenders considered the CDM revenues while agreeing to give loan to this projects? If not this project should be rejected right away by DOE by terminating the contract forthwith. If yes, where is the proof? What is the date of the evidence document from bank? Is this document printed now a days or earlier. DOE to independently check the same. If the document is  available from Bank it must be checked from all angles so that it is genuine and not forged and date changed by putting back dated. This is normally done, DOE to be aware of this please. Please check the communication the PP had during that time with banks, emails and postal receipts and the weights and dates mentioned on the receipts. Do not believe in courier bills and receipts since these can be cooked up easily. Insist on government owned postal service receipts only. If the project is fully equity project then on what basis the PP has invested full equity in to the project while considering the CDM revenue? DOE to check the same in detail and bring out the facts. Is there any past record of this PP to invest or not to invest at returns what he is talking about in this project? Proper evidences must be reviewed and digged out by the DOE and take decision on the project based on established facts. Do not ask documents from PP, DOE to collect the same from different sources to do independent evaluation. 

Lanco is fundamentally a cheating company. Just one example is the about their dishonest and illegal working in solar business. Read the link:
http://www.rechargenews.com/energy/solar/article312295.ece
Unless the DOE does a thorough investigation of Lanco’s behaviour it cannot process this validation. How come a DOE is doing this CDM validation? DOE to check all payments done by Lanco and DOE to be very careful of any documents given by Lanco since it is an unethical company with only profits in mind. Lanco’s CDM documentation is cooked up and totally false. How come this DOE is undertaking validation of this project without the CDM registration of the first two phases of this project? What is this? DOE to immediately suspend this validation work. Is the DOE sold out to Lanco? DOE (BVQI) management must investigate and submit a report to CDM AT and CDM EB regarding this validation project. What values Lanco is showing in PDD is all cooked up and not genuine. All assumptions are not shown and there is no way that this project will complete a genuine GSCP process with this webhosting. Hence the PDD need to be rewebhosted. DOE to personally investigate the values and ask Lanco to rewebhost the PDD for GSCP again if at all DOE wish to proceed with CDM validation. Without rewebhosting the PDD if DOE is continuing with the validation that means the DOE is sold out to Lanco. This project is a fake CDM project and because of this kind of projects only the CDM business has gone bad and genuine projects are suffering. 

India says developer Lanco 'flouted' NSM rules, but 'no scam'

The Indian government has indicated it will treat Lanco Infratech leniently, despite acknowledging that the developer “flouted” some rules in pursuing projects under the National Solar Mission (NSM).
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The admission may deepen scepticism about the strength of the regulatory regime in one of the world’s fastest-growing solar markets.

In February the Centre for Science and the Environment (CSE), a Delhi-based green group, alleged that Lanco had broken the rules governing the NSM’s first batch of projects by winning at least seven PV arrays – in addition to a 100MW solar-thermal project.

Developers were only allowed to win one project of 5MW in the first 140MW batch, with the government intending to bring as many new players into the sector as possible.

The CSE claims Lanco gained a controlling interest in numerous developers through its employees and their children, and alleges that state-run agencies have since attempted to hush-up the situation.

Lanco has denied the allegations, saying its stakes in the various developers fall within “permissible levels”.

In its first public statements about the case, the government says Lanco did break some rules – though not in an egregious manner.

“Our investigation concludes that the company did flout some guidelines, but there is no scam as such,” says Tarun Kapoor, joint secretary at the Ministry of New and Renewable Energy (MNRE).

Kapoor says the results of a formal investigation into Lanco’s behaviour will be published in “a week or two”.

Delhi is being forced to walk a fine line between cracking down on developers who break the rules or miss their commissioning deadlines, while at the same time avoiding being so draconian that it scares off potential investors.

Kapoor adds that 125MW of the 140MW awarded in the first batch of NSM projects in late 2010 is now operational.

All 140MW was supposed to be commissioned by 9 January, but the government was forced to admit earlier this year that almost none of the capacity would be completed on time.

Many outside observers believe the government has been too lenient with developers to date, and must become more transparent on issues like how far along projects have come, and how they are performing.

Kapoor says the government learned lessons from the first batch of projects and is being “more cautious” with the second 340MW batch, which are due for commissioning early next year.

India’s installed PV base grew from 17.8MW at the end of 2010 to nearly 510MW in March 2012, with more than $2.5bn invested into the sector last year.

Lanco, This is a fake CDM project. How come this project which is a phase 3 of the same site be validated now? How? What is the status of CDM for the last two phases?  If both phases are not CDM registered and how come PP wants CDM for third phase? Why? PP’s this project and this site is already viable without CDM benefits and CDM cannot be given to this phase also. It’s proven. The validation of this project must stop and DOE must investigate why the PP wants CDM for this phase while PP is running both earlier phases for many years without CDM. They wish to make more losses? The fact is they are already making profits and wish to make more projects by CDM windfall benefits. This cannot happen in the interest of CDM process itself. CDM EB must notice this. This DOE is not professional. Why the approach of PDD, deciding of base line, and additionality argument is different in different phases of this Lanco project? Phase 2 PDD and Phase 3 PDD? Why? Has meth changed or what changed? It clearly shows that the project is cooked up. DOE to check this thoroughly and only after CDM registration of both earlier phases this phase site visit can be conducted. If BV is doing the site visit audit before that means it is conniving with PP and indulging in unethical activities. Why TUV Nord is not hired for this project validation? Is it because of some reasons? BV has given any assurances to Lanco? BV’s management must investigate this. Looks like BV’s management is interested in signing contracts left and right without any proper due diligence. What is the basis of marketing CDM services in BV. Why are you doing unethical practices? No validation can happen on this project unless both the earlier phases of the project are CDM registered. If the DOE continue to proceed with the CDM validation that means the DOE is misbehaving and violating the rules. 
This PDD must be re webhosted with all proper calculations and assumptions. Fuel costs assumed are wrong and no proper verifiable links are provided. Heat rate as per EPC mentioned is wrong and cooked up to earn more CER’s. How did PP and Consultant arrived at levilised cost is not clear. What is the point in cooking up the PDD and cheating the CDM system. DOE must check this and reject this project since it is a cooked up project to earn CER’s. No proper local stake holder consultation process is done for this project. It’s a stage managed, cooked up and closely held affair. The same must be conducted again by giving newspaper notice and the PDD to be re webhosted again for GSCP. The DOE cannot continue the validation using this PDD. The PDD must be updated with all full & proper information. This is a totally unfit project for CDM registration. What is this? DOE’s accepting this kind of useless PPD must be suspended. This DOE has done enough damage to CDM. They should now concentrate on their old inspection and ISO stuff rather than spoiling CDM anymore. They any way made ISO 9001 and inspection non-value adding and worth less activities. Now they want to make CDM also the same. Is DOE playing with the system to get CDM status for undeserved projects? DOE must not use the local office employees and must use the totally independent auditors, financial expert and technical reviewer. 

Lanco, This is a fake CDM project. How come this project which is a phase 3 of the same site be validated now? How? What is the status of CDM for the last two phases?  If both phases are not CDM registered and how come PP wants CDM for third phase? Why? PP’s this project and this site is already viable without CDM benefits and CDM cannot be given to this phase also. It’s proven. The validation of this project must stop and DOE must investigate why the PP wants CDM for this phase while PP is running both earlier phases for many years without CDM. They wish to make more losses? The fact is they are already making profits and wish to make more projects by CDM windfall benefits. This cannot happen in the interest of CDM process itself. CDM EB must notice this. This DOE is not professional. Why the approach of PDD, deciding of base line, and additionality argument is different in different phases of this Lanco project? Phase 2 PDD and Phase 3 PDD? Why? Has meth changed or what changed? It clearly shows that the project is cooked up. DOE to check this thoroughly and only after CDM registration of both earlier phases this phase site visit can be conducted. If BV is doing the site visit audit before that means it is conniving with PP and indulging in unethical activities. Why TUV Nord is not hired for this project validation? Is it because of some reasons? BV has given any assurances to Lanco? BV’s management must investigate this. Looks like BV’s management is interested in signing contracts left and right without any proper due diligence. What is the basis of marketing CDM services in BV. Why are you doing unethical practices? No validation can happen on this project unless both the earlier phases of the project are CDM registered. If the DOE continue to proceed with the CDM validation that means the DOE is misbehaving and violating the rules. 
This PDD must be re webhosted with all proper calculations and assumptions. Fuel costs assumed are wrong and no proper verifiable links are provided. Heat rate as per EPC mentioned is wrong and cooked up to earn more CER’s. How did PP and Consultant arrived at levilised cost is not clear. What is the point in cooking up the PDD and cheating the CDM system. DOE must check this and reject this project since it is a cooked up project to earn CER’s. No proper local stake holder consultation process is done for this project. It’s a stage managed, cooked up and closely held affair. The same must be conducted again by giving newspaper notice and the PDD to be re webhosted again for GSCP. The DOE cannot continue the validation using this PDD. The PDD must be updated with all full & proper information. This is a totally unfit project for CDM registration. What is this? DOE’s accepting this kind of useless PPD must be suspended. This DOE has done enough damage to CDM. They should now concentrate on their old inspection and ISO stuff rather than spoiling CDM anymore. They any way made ISO 9001 and inspection non-value adding and worth less activities. Now they want to make CDM also the same. Is DOE playing with the system to get CDM status for undeserved projects? DOE must not use the local office employees and must use the totally independent auditors, financial expert and technical reviewer. 

The website of Lanco mentions that Lanco has a power trading unit called Lanco Power Trading Limited which has been awarded the National Power Trading Licence of CERC. It also says that on 21st May 2008, LPTL transacted 19.81 MUs, the highest for any single day transaction since its inception (http://www.lancogroup.com/power/powertrading/powertrading.html). The DOE should strictly verify the documentary evidence behind the statement made by the PP that the “project activity is quite susceptible to issues like nature of its sale contracts, pricing of merchant power and regulatory risk, development of adequate transmission corridor for evacuation of merchant power…”
Debt Equity

The project is apparently, 100% debt funded as is the case with most MPPs (www.lancogroup.com/Lanco_News_Is27.pdf). This is contrary to the debt equity ratio of 75:25 assumed in the PDD. Apparently, the PP has used standard parameters rather than project specific value. Additionality has to be project specific and each and every parameter should be project specific. The DOE should verify

a)	The assumptions used by the banks for project appraisal in particular the tariff and the PLF for the plant. Since the loan has already been sanctioned, the plant load factor should be taken from the project report submitted to the banks based on which the term loan has been sanctioned. (The PLF should essentially be verified as there is a chance that the PP would reduce the PLF claiming uncertainty in sales on a short term basis). 
b)	Was the debt funding approved after taking into account CDM and if so, is there an explicit mention of it in the loan agreement signed with the 21 banks. It would be a little difficult to believe that the bank sanctioned the loan assuming CDM funds and then fails to incorporate anything related to CDM in the loan agreement)


Gas Availability

At the time when Lanco was conceptualizing the project activity, it was running its existing project on Naphtha. The cost of Naphtha is multiple times that of Natural Gas. Still Lanco chose to run its power on Naptha rather than on Natural Gas. The reason for this most likely should be non availability of Natural Gas. There are multiple other power plants which could not be operational for want of gas. In such an event, the applicability of the methodology itself would need to be questioned.