7.5 MW Wind Project by ACC limited in Rajasthan
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Host party(ies) India
Methodology(ies) AMS-I.D. ver. 17
Standardised Baselines N/A
Estimated annual reductions* 11,896
Start date of first crediting period. 01 Dec 11
Length of first crediting period. 10 years
DOE/AE SGS-UKL
Period for comments 03 Aug 11 - 01 Sep 11
PP(s) for which DOE have a contractual obligation ACC 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 (1228 KB)
Local stakeholder consultation report: N/A
Impact assessment summary: N/A
Submission of comments to the DOE/AE Compilation of submitted inputs:
Since the entire power is wheeled for captive consumption, the PDD should have given the tariff assumed. It is totally silent on this issue and therefore the global stakeholders cannot comment on the financial indicator. With the given information, it is not possible to reproduce the worksheet and arrive at the same results. How did DOE publish this PDD?  This project should be re webhosted with all relevant information before being taken up for validation. 

Sourcing PLF from RERC tariff order is not conforming to Annex 11, EB 48. Several web hosted wind projects from Rajasthan have assumed higher PLF. Therefore, DOE should check the other projects and also the actual PLF achieved by the project before accepting 20% PLF.

Line loss of 4.5% is not recommended by RERC. It recommends only 4% and that too if it is connected to 132 or 220 kv; otherwise it is only 1%. DOE should check the commissioning certificate and then accept the line losses. In any way, it cannot be more than 4%

Project cost at Rs.6.3 core per MW is very high. The cost is based on offer letter. DOE should check the purchase order and use its sectoral and local expertise. The cost should be based on purchase order and not offer letter.

The project is eligible for 100% depreciation and tax holiday. Depreciation will enable the company to save tax. This should be taken into account as cash inflow. As this project is part of ACC, there cannot be MAT. Providing MAT is not as per Income Tax Act.

Unless the project is financed fully by equity, equity IRR should not be accepted. PP should use only project IRR. If the project is fully financed by equity, then the DOE should take a declaration from PP and also the Chartered Accountant. It should also inspect the annual report of the company and find whether it is correct.

The benchmark is more than RERC recommended return of 16%. EB has recommended much lower return. Therefore the benchmark is high.

The tariff, though not given, is more than Rs.5/kWh in Gujarat. DOE should ensure that the PP takes into account not only the base tariff, but also fuel surcharge, time of usage charges and electricity duty as all these represent saving when the power is wheeled instead of importing from grid.

This project cannot be additional and the consultant has made it additional by overlooking so many input parameters and tax savings.
Submitted by: Karthikeyan


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