1. The methodology is not even applicable as there are multiple fuel being used in the baseline. 
2. The baseline cannot be coal as it cannot be established by structuring alone, it has to be established for individual captive consumers. I am sure that more use diesel and the emission factor of diesel is less than coal and this proves the non-conservativeness of baseline.

3. The PDD mentions that "This project  displaces the use of coal by natural gas in a cogeneration system thereby displacing more GHG intensive fossil fuel by a less intensive fossil fuel. Therefore, this applicability condition is met". This is not true as baseline cannot be based on assumption that PP would have invested in coal and not any other fuel. The DOE should validate the usage of NG with respect to availability as well. Is coal being used in the geographic area?

3. This project is not even additional as IRR route should be adopted to assess the additionality. Merchant sale of power attracts attractive returns and thus levelized cost of generation cannot be used alone to prove additionality. Further, IRR is also a suitable indicator as the project proponent has the option of not investing into the project. The PP is not bound to supply electricity and thus tariff alone cannot be used to substantiate additionality. Further, the fuel escalation is pass through to the consumers. This implies that the project IRR will be very high. The IRR should be calculated for the sale of power and steam.

4. The PPA between the PP and the consumers should be analyzed very closely by the DOE and this should be validated that it was not created to just prove the project additional. The tariff should have a business logic. Also, the assumed value of coal price is very low, it should be approx 4500 (consider the landed cost of coal)

5. The PLF of natural gas based generation is 85% as CERC guidelines. It should be used.

6. What is the structuring of the new company (Malanpur Captive Power)? Does it not affect additionality?

•	As per A.2 of the PDD, power is supplied to grid as well as to other facilities and hot water is also generated whereas these systems are not indicated in the project boundary 
•	Important parameter heat rate is not subjected to sensitivity analysis
•	Coal based cogeneration plant as the baseline plant needs introspection, as per meth requirement baseline reference plant approach has to be followed to strengthen the baseline cause. But the PDD is weak in establishing the baseline (as coal based cogeneration that supplies ‘power to grid’ and ‘steam to other facilities’ is a rare phenomenon in the Indian context) 
•	CER estimation seems to be wrong
•	The purpose of not considering CERs due to steam/ hotwater raises a question mark, since if considered it crosses the prescribed limit of 60 ktCO2 per annum which means the project does not qualify as a CDM project activity
•	The DOE is requested to check the actual technical parameters such as heat rate, aux consumption – to cross verify the CER estimation. (as the values provided here are completely different to that of previously webhosted PDD)
•	Since the plant is in operation, the actual power generation can be verified to estimate the CERs, which in any case is bound to cross the small scale threshold limit