Page 1, Box 1: “aCLEAN DEVELOPMENT MECHANISM” instead of “CLEAN DEVELOPMENT MECHANISM”. Modifying the PDD template is a crime. Does PP have the right to decide on a template of their own style. Is EB noticing or not ? Such kind of crime committed by Integral Coach Factory (ICF) is a public entity, under the Ministry of Railways, Government of India is totally unpardonable.

The project activity is still not fully operational. How could the project promoter (Integral Coach Factory (ICF) is a public entity, under the Ministry of Railways, Government of India) erroneously estimate a generation of 22747 of emission reduction units for a complete year of generation.

Further more the table under section A.4.3 project 22747, whereas 150229/7 works out to be 21461.29. This substantiates the fact that baseline estimation was properly done and any IRR / Financials / figures with respect to this project activity are faulty and misleading. The project promoter attempts to fool the DOE/EB/learned climate scientists/international audience by way of making such estimates. 

Selection of renewable crediting period of 21 years for a project activity employing machines that have only 20 years of life is a major flaw and by doing this the project promoter (Integral Coach Factory (ICF) is a public entity, under the Ministry of Railways, Government of India) clearly proves that their motive of development of the project activity is sheer greed for money from sale of emission reduction units and not greenhouse gas emission reduction. 

While the facts and figures with respect to the project acitiviyt’s IRR / Financial Analysis are based on a twenty year life time and the claim of emission reduction credits for twenty one years is a misleading attempt of the project promoter (Integral Coach Factory (ICF) is a public entity, under the Ministry of Railways, Government of India). This gives rise to the question that the project promoter has all the guts to indulge in activities that would lead to double counting and the project promoter the project promoter (Integral Coach Factory (ICF) is a public entity, under the Ministry of Railways, Government of India) needs to assure by way of an undertaking (that will be made publically available) that the project promoter has not and will not claim emission reduction credits under any regulatory/voluntary mechanism at any given point in time, other than this project activity under clean development mechanism.

The project promoter has to submit the financials to an external independent party who is free of any influence from the Minsitry of Railways (preferably an independent financial expert, a non Indian national / non person of Indian origin) outside the host country, as all people in India are someway or other affiliated/influenced by the governmental bodies.

If the O&M cost estimates are followed as per TNERC tarrif order from the eleventh year till twenty years, then the same should have been followed for the first ten years. Either the TNERC tariff order or any other guidance should be followed in full and not in bits and pieces. Also clear reference of the TNERC tafiff order, as of which one is followed is not made available and is misleading. This clearly proves that the IRR was NOT made at the time of project conceptualisation and was done after the decision making process was completed. This is the foolproof evidence that CDM was an after thought and the project promoter had not had clear intentions prior to start of the CDM project activity.

If the project propmoters claim on life time and renewable crediting period is correct, then the equipment supplier has to guarantee generation of the WTG’s for a period of atleast five years more than the crediting period (atleast 26 years) to prove/support the project promoters claim.

If Suzlon energy limited is providing one such guarantee for the project promoter (Integral Coach Factory (ICF) is a public entity, under the Ministry of Railways, Government of India) then the manufacturer has to provide similar guarantee to all its customers across the world (through individual letters and their website) who have purchased 1.5MW generators till date.

The project promoter, Integral Coach Factory (ICF) is a public entity, under the Ministry of Railways, Government of India) claims itself to be one of the units of Government of India and how can the governmental organisation prove to be faulty in authorising a project activity of estimated life time of 20 years, for which the project finances have been projected. This is a shame to the way of working of governmental organisation in one of the fastest developing and a large democracy, like India.

CER price of 19 Euros: Needs a substantial documentary evidence to support and just cannot be from the air.

The table under A.4.1.4 is to indicate the unique identification of the project activity. In this case, if the machines are installed then it is acceptable to the DOE/EB. If WTGs are not commissioned as on April 01, 2009 the project promoter needs to assure by an undertaking that the project activity will not be shifted/relocate under any given circumstances (including force majeure) at any point in time during the life time of the project activity. 

Local stakeholder consultation process: If questionnaires are with yes/no type of answers, then the local stakeholder consultation process was not very transparent and new stakeholder consultation in the presence of the DOE.

ALL OF THE ABOVE CONTRIBUTE TO DISQUALIFY THE PROJECT ACTIVITY AND SINCERELY REQUEST THE DOE TO WITHDRAW THE PROJECT ACTIVITY FROM THE CDM RACE AND HELP FUNCTIONING OF THE UNFCCC AND CONTRIBUTE TO ONLY REAL, LONGTERM AND MEASURABLE BENEFITS AND AWARD ONLY WORTHY PROJECTS WHICH ARE REALLY IN NEED OF CARBON REVENUES.