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. 

It is very clear from the chronology of events mentioned in the PDD that CDM consideration was an after thought. The fact that from board resolution to the   CDM consultant is about 12 Months gap proves this Point. Hence DOE has to validate and verify that CDM consideration is real and pre established.
Environment Public Hearing is integral part of Environment Clearance process in India. What was major concern raised during EPH of this project? Whether minutes of EPH have been available with DOE? What are the major conditions stipulated in Environment Clearance?
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?
The DOE is requested to investigate how the CDM benefits assist the project participant in the overcoming the barriers mentioned under section B.5 in the PDD, in particular:
- any statistics on use of gas engines in Indian industries located in the Gujarat region
- impact of non-availability of gas; if this happens than the project proponent will purchase electricity and burn fossil fuels; the monitoring plan should account for leakage emissions in that case for periods of such occurences.
The DOE is requested to investigate on the following issues.
The project activity (with start date in 26/04/2008) hosted in a manufacturing facility uses trigeneration as a replacement of conventional heat and chillers and grid electricity.
In this context, the technologicals and prevailing practice related barriers mentioned are not reasons enough to justify that the project activity is not business as usual.

The arguments provided on technological barriers do not demonstrate if there is not enough local skills available to undertake the project without needing additional financial support from CDM revenues and how the difficulties described (say, uncertain gas availability) will be alleviated through potential CDM revenue.

The arguments for prevailing practice related barriers do not justify why the project activity is not a common choice for an industrial/manufacturing facility of Schering-Plough Ltd's type. The arguments provided do not actually refer to anything that is called "Barrier due to prevailing practice".
It is not clear why the project start date is in 2008 while validation started in 2011.
It is not clear how with the barriers claimed above which are disruptive to the manufacturing operations at the facility, the project developer agreed to implement the project due to some anticipated CDM revenues.
Why are the maximum demand charges considered for the financial calculations? As they would anyway apply in the baseline case as well. DOE must be aware of this fact. By this way, the PP intends to show a cost outflow in the financials to make it less attractive.
The project activity needs to demonstrate what investment barriers it is likely to face, if any and at all. Otherwise, the project activity appears to be, without any investment cost-benefit related information, to be a clearly business as usual case.
The monitoring plan also requires monitoring of the necessary parameters to demonstrate that the measures implemented by the project activity are limited to activities that results in additional steam/heat generation of no more than 5% of the project situation. This requirement is also applicable to all projects and not just for existing project activities.