Dear DOE,
Few points to be considered during validation:

1. PLF considering gross generation amounts to 60% which seems to be low as the rivers in Himachal Pradesh are perennial in nature and there is continuous flow of water available throughout the year. PLF to be critically examined by DOE.

2. 4.5% transmission loss considered is not conservative. This figure is infact the maximum permission loss by the HPERC/HPSEB. Please ascertain the distance from the power station to the substation. Normally for a distance of say 20 kms, the transmission losses would be about 1.5%. Please check the conservativeness.

3. The tariff rate of INR 2.5/KWh is as per the previous tariff order of HPERC. As per the recent order its INR 2.87/kWh which needs to be considered while calculating IRR.

4. The project cost is TOO HIGH. It amounts to INR 7.528 Crores/MW. This is unacceptably high. PP is trying to fool the DOE by assuming such a high cost. Please check similar registered projects for comparing the project cost. In Himachal Pradesh the project cost should not be more than INR 5 Crores/MW.

5. Why has the PP considered outage of 2.5%. Dont understand the reasoning behind this. Normally in Himachal Pradesh the grid is mostly available for electricity supply. This seems to be reasonable.

6. PP has cleverly not considered the subsidy offered by the HIMURJA. The subsidy offered is INR 2.25 Crores + INR 37.5 Lakhs/MW. Hence in this case the total subsidy amounts to INR 3 Crores. The PP has to consider this. If PP argues not to consider this in IRR, DOE is requested to clarify the same from EB whether the same can be considered to be E- policy.

7. The barriers are rubbish and not acceptable. Everyone is aware of the geographic terrain and seismic activity in Himachal Pradesh. PP must have been fully aware of the same. DOE is requested to validate the barriers in accordance with the "Guidelines for objective demonstration and assessment of barriers" (version 01) EB50 Annex 13.

DOE is requested to please forward the response to my comments on my email id: clean.development.mechanism.india@gmail.com.

Author wishes to be anonymous.

Thank you