1. It is really a tragedy happened with the PP who has changed DOE and webhosted the PDD in a short span.

2. It seems that PP would like to hide the reality or truth which was addressed by old DOE or Global Stake holder comments received during public consultation which PP wouldn’t have addressed properly.

3.PP has to justify the change of DOE from old DOE and re-webhosting of the PDD, along with
change of information from already webhosted PDD to the PDD under comments, in track
change mode.

4. As PP has mentioned that the Funding is from the GOI (Government of India) and GNCTD
(Government of National Capital Territory of Delhi), how it could be justified that the funding is not from ODA? As per funding details received from the web it seems that DMRC has received fund of Japan Bank.

5. If DMRC has considered CDM revenue since 2001, Than why this project has been webhosted now? Even as per chronology of event he has appointed consultant in 2007, means what he was doint till date on CDM front? Please justify.

6. The consultant has carried out baseline studies but has not provided the information of the data collection and the calculation from base data to data used for preparing the PDD.- PP should include authenticity of the data collection with sample calculations of each data from raw form to the final calculations.

7. The alternatives listed in the PDD are vague, these options are not available to DMRC as
DMRC is not an individual investor who has other alternatives (options) of investments, as
DMRC was only ventured for Delhi Metro and involved for this project.

8.The CDM consideration data used related to meth proposal are not relevant, PP should remove it, as PP hasn't proposed it.

9. As per corporate finance, PP should invest into any of the project if NPV is positive, with
negative NPV how PP has planned to invest into this project. The viability of the project is
questioned at investment decision than why PP has invested?

Dear Sirs,
It seems the project proponent has changed the DOE and webhosted the project with increased coverage of the metro (distance)! I had some concerns regarding the project earlier also, which have still not been answered and hence would request  you to clarify the same.
We understand that Delhi Metro is being implemented in two phases, I & II. 
Red Line	Line No.1- Shahdara-Tri Nagar-Rithala
Yellow line	Line No.2- Vishwa Vidyalaya-Central Secretariat
Blue line	Line No.3- Indraprastha-Barakhamba Road-Dwarka Sub City
Phase II of the Delhi Metro Project consist of the following lines:- 
	Shahdara – Dilshad Garden 
Blue Line	Indraprastha – Noida Sector 32 City Centre 
Green Line 	Yamuna Bank – Anand Vihar ISBT 
Blue line	Vishwavidyalaya – Jahangir Puri 
Green Line 	Inderlok – Kirti Nagar -Mundka 
Yellow line	Central Secretariat – Sushant Lok 
Blue  Line	Dwarka Sector 9 to Dwarka Sector 21
Orange Line	New Delhi – Airport
Blue Line	Anand Vihar – KB Vaishali 
Violet Line	Central Secretariat – Badarpur
Source: http://en.wikipedia.org/wiki/Delhi_Metro, http://www.delhimetrorail.com/corporates/projectupdate/phase1_network.html
As evident from the above tables, many lines of phase II are mere extensions of the lines established in phase I(See red/ blue lines). The project is an environmental friendly project and contributes towards decreasing the emissions. However, we fail to understand why certain sections of the metro network are being projected as a CDM project? Section A.2 states that 
“all corridors of Phase II and Line 3 of Phase I of Metro Delhi managed by DMRC (Delhi Metro Rail Corporation Ltd.). Lines 1 and 2 of Phase I are not included as CDM project…”
We fail to understand that how it is being projected as a CDM project and why the previous phases were not considered under Clean Development Mechanism of the Kyoto Protocol. Why does these specific lines require CDM revenue when the lines under phase I had started their operation in 25th December 2002 and have been earning profits. With the success of the lines opened for public in 2002, why does DMRC require CDM revenue for the already profitable DMRC? 
Further, “Internationally, of the 135 Metros worldwide, only four make an operating profit apart from Delhi, these are Hong Kong, Taipei, Singapore and Tokyo. (Source: http://www.thehindu.com/2007/09/24/stories/2007092457210400.htm). Then why is CDM revenue required for the already profitable DMRC?
“The Delhi Metro Rail Corporation (DMRC) has earned a profit of Rs 398.69 crore during 2006-07, an increase of 15% over the previous year.” (Source: http://www.financialexpress.com/printer/news/220261/)
What is the difference between the metro infrastructure installed in these phases and why the previous phase did not foresee all such requirements?
Out of Rs. 70 lakhs per day, which is its operating revenue, as high as 25% comes from property development and includes activities like leasing out commercial spaces, advertising, construction of shopping arcades, setting up of accommodation units, construction of IT parks etc.(Source: http://www.indianrealtynews.com/real-estate-india/delhi/dmrc-earning-high-from-property-development.html) – is this revenue considered while calculating the Net Present Benefit?  Also, the land that has been given to DMRC by the government is sussidised, why has this not been taken into account.
Revenue earnings of Delhi Metro Rail Corporation (DMRC) are likely to shoot up by about 194% in next 3 years and touch Rs.2100 crore, according to the ASSOCHAM (http://www.assocham.org/prels/shownews.php?id=1607) , then why does such a profitable project need more revenue?
Further, section B.5 of the PDD states that 
“The project could not be entered earlier into validation due to the fact that no approved methodology for this case existed, with the first methodology for MRTS entered by Grütter Consulting in May 2007 (NM0229) subsequently being rejected by the Methodology Panel with a new methodology being submitted March 2008 (NM0266). The approval of this methodology took more than 1½ years thus delaying the entry to validation of the project.”
Then it states that the Contract for project development was being awarded to the consultant  in 19/03/2008. Unfortunately the timelines are not matching!!!! How can DMRC state that it could not enter into validation because it  did not have a methodology for more than 6years!!!!, when it did not make any attempts for new methodology. Also, it should be noted that the methodologies that were rejected by CDM EB in 2007 when the consultant was not even appointed.
The methodology NM105 (transportation sector) was proposed before 09 May 2005 & the methodology AM0031 was valid from 28th July 2006. Why didn’t the DMRC not make any attempts to propose a new methodology ?
DMRC is earning profits from phase I and this can be evaluated by the validators  by conducting a small google search. But, still phase II anticipated loss and considered CDM..!!! now that is contracdictory!
 
EB 39, annex 22 states that , “The project participant must indicate, by means of reliable evidence, that continuing and real actions were taken to secure CDM status for the project in parallel with its implementation. Evidence to support this should include, inter alia, contracts with consultants for CDM/PDD/methodology services, Emission Reduction Purchase Agreements or other documentation related to the sale of the potential CERs (including correspondence with multilateral financial institutions or carbon funds), evidence of agreements or negotiations with a DOE for validation services, submission of a new methodology to the CDM Executive Board, publication in newspaper, interviews with DNA, earlier correspondence on the project with the DNA or the UNFCCC secretariat”
It must be noted that neither of the above mentioned evidences are available. The PDD has mentioned that DMRC discussed the option of CDM with many consultants but as the timeline demonstrates, it did not finalize until 2008. If CDM was an important part of the decision making process than why did DMRC not seriously consider CDM. None of the evidences mentioned by UNFCCC have been met by DMRC.
Also, line 3 of phase 1 started operation in 2005, if CDM revenue was such an integral paart then how is the project operating till date. 
The Japanese Government has financed about 60% of the cost by the way of a soft loan through JBIC. Is there any agreement with them about the project considering carbon credits? If yes, then why have these facts not been disclosed to the general public? If no, then we guess it might pose a question on DMRC that why it did not disclose such crucial information to the investor?  The funds received for the project can be accessed at http://www.mofa.go.jp/POLICY/oda/data/02ap_sa01.html#INDIA. The funds accured from JICA can be accessed at 
Further, as per the statements given by DMRC officials earlier about the climate change initiatives of DMRC, the modal shift project never featured. 
Source: http://timesofindia.indiatimes.com/city/delhi/Carbon-conscious-DMRC-earns/articleshow/1087010.cms, http://www.tribuneindia.com/2008/20080105/nation.htm#2, http://docs.google.com/viewer?a=v&q=cache%3AjzzuYP36yVwJ%3Anidm.gov.in%2FNews%2520in%2520PDF%2F2008%2FJanuary%2F05-01-08.pdf+dmrc+cdm&hl=en&gl=in&sig=AHIEtbRD4rg8X3kdadkCt1BWCFXV3VtbAw&pli=1
However, lately there have been articles on the modal shift CDM project, http://www.indiaenvironmentportal.org.in/files/DMRC.pdf
We would request DMRC to clarify how the modal shift project has started featuring now although the PDD mentions in Section B.5, DMRC indicating that Kyoto Protocol should be used to offset additional costs of Metro Delhi

Delhi Metro is one of the laurels of our country and one of our greatest green initiatives. However, in order to gain carbon revenues, DMRC should not make such futile attempts at turning the events. Delhi Metro has been in news ever since it was conceptualized and not even once did DMRC mention about the need or importance of carbon credit. 
One of the projects of DMRC is also registered under the Kyoto mechanism of CDM.
“Installation of Low Green House Gases (GHG) emitting rolling stock cars in metro system” which is a small scale project activity and has a potential to reduce 41,160 CER/ annum. However in the PDD of the modal shift project DMRC has not mentioned anything about this small scale project activity nor has it subtracted the emissions from the modal shift project. The PDD does not throw any light on how the credits from that project will be accounted and considering the credit from the entire metro system will lead to double counting of credits.

Further, the DRMC project has attained loan subsides, land subsidies (http://web.iitd.ac.in/~tripp/delhibrts/metro/Metro/Metro%20delhi%20BS%20Oct%2008.pdf) – has this been taken into account the NPV calculation?
In section B.5 of the PDD, the it is being stated that identification of the consultant began in 22.10.2003, howver, the consultant was not being appointed till 19.03.2008. it seems very unlikely that in country with the highest number of CDM project registrations (one being their own) DMRC did not find any CDM consultant over a period of Five years  nor did it make any attempts to submit a new methodology!! We would request you to clarify this!
Delhi metro is expected to cover the entire NCR and ridership will be divided accordingly. But the PDD does not state how it has planned to account for the difference in the ridership in the satellite cities o like Noida, Gurgaon.
We understand that the DMRC routes are based on the routes proposed by them in their Delhi Metro Master Plan. They are also, at times based on the basis of commuter demand and population density, based on a transportation demand study conducted by RITES. Then the proposal is being sent to the government for approval.  We would like to know if the proposal to the government included carbon credits , and if the government consider it while giving approval? The approval for the DMRC projects is being given a by a group of ministers (government) & hence documents demonstrating that they had considered CDM while approving the project should be shown to the public.  Further, there is no mention about CDM being assessed as a key factor in the approval that has been given (http://www.delhicapital.com/delhi-metro/news/metro-line-to-noida-gets-go-ahead.html). The DOE should use RTI to check the authenticity of all the documents and claims or our NGO would use RTI and go public with all these documents. If CDM revenue was so very seriously considered than how were some phases of the phase II commissioned? Without  CDM??
The PDD considers 12/03/2003 as the project start date. Howver, many activities have been initiated for the Delhi Metro long before its constructions began (http://civilaviation.nic.in/ccrs/Annual%20report05-06/Activities%20in%20regard%20to%20Delhi%20Metro%20Rail%20Corporation.html)
a.	Delhi Metro Rail (Operation & Maintenance) Act 2002 was enacted by the Parliament and was published in the Gazette of India vide Notificaion No.72 dated 18.12.2002.
b.	In May 1998, as a first step, the DMRC appointed Japan's Pacific Consultants International (PCI) as general consultant to the project. The general consultant's role is vital. It will choose the firm which will finally execute the project.( http://www.india-today.com/itoday/14091998/urban.html). And for the phase II, DMRC awarded the contract for general consultancy for Phase II construction to a consortium of five companies comprising Pacific Consultants International (PCI), Parsons Brinckerhoff International, Japan Railway Technical Services, TONICHI Engineering Consultant and RITES Ltd. These companies had earlier provided consultancy for Phase I of the Delhi Metro Project as well. Hence this was a mere extension of the consultancy contract awarded earlier. Then how is the start date considered beginning of construction.

The PDD states that the total investment of the project activity is 81783 million INR and the CER revenue over a period of 7 years will be 475.5 million INR. We fail to understand how revenue which is about 0.5% of the project cost is going hedge the risk. Further, in which all investments has the Government of India considered Net present value analysis that this project has taken?

 We would seriously acknowledge that this is a CDM project if Mr. E. Sreedharan and the group of ministers give it in writing that this project was conceptualized as a CDM project and without CDM revenue, the project will stop operation. Hence, if the DOE gives a negative validation report, entire metro network of Delhi will come to a standstill!