Submission of comments to the DOE/AE
Compilation of submitted inputs:
It is evident from the PDD that the values are consistent and it is definitely forged and cooked up values to show a non CDM project as a CDM project. What is this? 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. After careful study of PDD it is found that DPR/FR is in different versions made and submitted with different purposes to different agencies which is totally unacceptable, illegal and unethical. PP/Consultant may 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. 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. In this particular project there is clear cut evidence that DPR/FR values are changed/ fabricated mischievously and intentionally. This 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. 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. This project is a fabricated and fake CDM project and must be rejected by the DOE right away. DOE should not support this kind of projects otherwise CDM EB should suspend this DOE for at least one year.
Submitted by: zhong zhou li
For the comment itself, we consider it is without any evidences and references.
At the moment we are performing the desk review and we can not make reply to this comment. When we are performing the validation we will ask to PP or consultancy, after the reply from PP or consultancy, we can raise a CAR or CL for this comment or we put this comment in our VR.
Submitted by: E-0032 LGAI official account
1) Layout of power transmission lines from the generation to the consumer with the metering system is not shown. It should include the distance of transmission lines. DOE has to check the meters are installed to monitor electricity generated, net electricity used in Bhutan, net electricity exported to India. Pls. clarify.
2) The status of the construction & commission of the project is not stated in the PDD.
3) What is the basis of calculation for transmission loss, auxiliary consumption and transformer losses? What is the length of transmission line?
4) The project is claimed to be run of river hydro project. So the calculation of reservoir is wrong. The criterion 3 is applicable only to pumped storage or accumulation hydro projects. What does reservoir refer to as per PP?
5) The justification of opting out alternative 3 and alternative 4 is not justified adequately. It should be based on latest published data and figures. Refer B.4. Pls. clarify.
6) The bilateral agreements, PPA with India are the documents, DOE to check thoroughly.
7) Date of investment decision should be at the time of DPR preparation. So, the basis of the cost escalation factors at a later date for CDM consideration is not valid. Pls. clarify. Refer B5. Step 3a. (Investment barrier).
8) How the CDM benefit will alleviate the technical barriers. As per additionality tool, if the barriers are not alleviated by CDM, then the project is not additional.
9) Emission factor for state is not calculated.it should be made available to DOE to clearly validate this value. Emission factor for India is not as per “Tool for emission factor for the system”.
10) Electricity generated by the project, auxiliary consumption, transmission losses, transformer losses, net electricity exported to India, net electricity exported to the grid. These parameters to be monitored continuously and to be cross checked with sale receipts.
11) The Meth mentions that if investment analysis option is used, apply the following:
a) Apply an investment comparison analysis, as per Step 3 of the .Combined tool to identify the baseline scenario and demonstrate additionality., if more than one alternative is remaining after Step 2 and if the remaining alternatives include scenarios P1 and P3;
b) Apply a benchmark analysis, as per Step 2b of the .Tool for the demonstration and assessment of additionality. If more than one alternative is remaining after Step 2 and if the remaining alternatives include scenarios P1 and P2.
But PP failed to apply like this. Pls. clarify.
12) PLF should be based on EB48 Annex 11guideline which says The plant load factor provided to banks and/or equity financiers while applying the project activity for project financing, or to the government while applying the project activity for implementation approval; (b) The plant load factor determined by a third party contracted by the project participants (e.g. an engineering company); But PDD doesn’t demonstrate how PLF has been arrived at.
13) Whether PLF includes machine shutdown, machine availability. Whether grid availability is accounted for in the calculation of gross generation. To my surprise, critical parameter like PLF is missing from the PDD. How DOE has allowed this.
14) Common practice analysis should be based on EB 39 Annex 10 (Additionality tool). Each step of common practice analysis should be fulfilled as per tool.
15) Emission reduction calculation should be based on EB 50 Annex 14 “Tool for emission factor for the electricity system.
16) Whether only one set of main meter, check meter set is enough for three projects. The monitoring parameters need to be checked by DOE.
17) The main meter and check meter technical parameters like accuracy level, make, etc. needs to be mentioned in the PDD.
Submitted by: lawrance
Some of the comments have been mentioned in PDD and some of them are not corresponding for this project and for projects in China.
Despite of this, during the validation we will take care of its.
CDM Technical Manager
LGAI Technological Center, S.A. - Applus+
Submitted by: E-0032 LGAI official account
The comment period is over.