The PP states that they have considered 80% accelerated depreciation. However the PDD is silent on the tax shielding as a result from accelerated depreciation.
PPs cleverly do not consider the accounting tax offsetting in their companies while calculating the IRR. This is evident from the recently registered projects and those requesting registration.  

The DOE is therefore requested to critically analyze how the accelerated depreciation benefit has been taken into account and confirm the accounting of the cash inflows as a result of the negative tax liability in the initial years. DOE should not be misguided by the financial presented by the PP or consultant which are custom made for CDM purposes and not the actual financial considered at the investment decision.
Note that considering cash inflows results in an increase in the IRR making wind projects a profitable venture.

Please also check the offer from WTG supplier and Purchase Order while validating the PLF. It may be so that the third party report which is made after investment decision making - indicates a lower PLF.
The PLF seems to be very low. Also check the tariff order.


Benchmark: 
No details are provided on the beta estimation. Is the beta levered or unlevered and what is the reason?? How is the beta appropriate for irr chosen?

Stakeholder consultation:
No details provided on which all stakeholders attended the meeting. 

Benchmark:
The benchmark is too high. Even after considering CDM benefits the IRR will not cross the benchmark. Then WHY did the PP go ahead with this non-profitable venture??
This clearly indicates the benchmark is made high just to prove additionality and is not the real benchmark expected by the PP.

Why has the PP considered Reliance Infrastructure Ltd for beta determination when Reliance Infrastructure Ltd. has many other businesses other than pure power generation? How come the risk profile of Reliance Infrastructure Ltd match with the project activity which involves wind electricity generation?

What is the vintage considered for beta determination? Is considering only one year appropriate?
Why tax computations for beta are only considered for one year?? What is the basis for considering a particular vintage for the market returns, beta estimation and risk free returns?

Why the particular index is considered for calculating the market returns? DOE to evaluate whether the PP has made any other investments considering the same index. Only because a particular index results in a higher benchmark??

Project cost seems to be very high. Are the quotations real or fabricated?

Are REC benefits being claimed? How will the DOE ensure that the PP does not claim REC benefits during project operation?

DOE to submit a negative opinion in case the IRR does not cross the benchmark even after considering CDM benefits as it clearly indicates the projects unviability in any case. Why would any one invest in a loss making venture? 

And if the PP can still go ahead with the project - it indicates that the benchmark is fabricated and is not considered by the PP while making the investment decision!! DOE to validate this critically!! How are the investment decisions really made???

DOE to check if the financials correctly apply the 10 year tax holiday - i.e. not liable for taxes for 10 years from the initial 15 years. 

	As per official website of the company http://www.moneycontrol.com/news/press-release/reliance-infra-bags-epc-contract-for-samalkot-power-project_530274.html, the total project cost of the project activity is not matching with the PDD, please clarify.

	DOE has to check, according to PDD Starting date of the project activity is 11/10/2010, but web site showing 26/08/2010(http://eco2data.com/project/57849), clarify.

	Why the entire background of the project with chronology of events with date is not documented in the PDD. DOE has to validate the events with proof.

	DOE to check the DPR, tender documents inviting proposals, tender correspondence, proposals etc. to clearly validate. 

	PP tries to hide many perils the project faced. The article appeared in Frontline is given below for better clarity. PP has to give sufficient explanation for the problems and why it is shifted. DOE has to validate. 

	Project proponent conveniently hides the past history of the project and presents it as if it is a new project. DOE to check the prehistory of the project.

	DOE to check the surplus availability of natural gas in the region  

	When the investment decision took place it is not stated very clearly. 

	The reason for excluding the power generation using natural gas with different technologies is not clear. It is mentioned in the PDD that the project activity is a combined cycle power plant with the modern state of art technology and significant efficiency improvement is not possible with current technology status to reduce GHG intensity any further. As CCPP is very efficient technology there are no higher efficient technologies available to the project proponent for power generation utilizing natural gas.

	 The argument for opting out of other energy sources from the baseline is not adequately demonstrated in the PDD. Where is the proof for each of the argument? PP has duty to provide to all the points it raised to opting out of renewable and other sources. 

	The input values taken for calculation of levelised cost of generation are not provided. Pls. clarify. 

	What is the basis for arriving discount factor since it has more bearing on the levelised cost. 

	The leakage calculation is not correct as per applied meth AM29.

	Chronology of events with corresponding emails, letters need to be validated by DOE.

	The PDD does not explain about identified training, monitoring and maintenance as per the Technology requirements for contractors / engineers by the client. There is no mention of field quality Assurance systems & procedures that are available at site, field quality plans and their approval

Dear All

What the HELL is going on? What are you guy’s up to? What are you writing in the pre-project scenario? Has the consultant and DOE ever read CDM PDD guidelines? 
I want to know how and why the DOE has taken up such a project. What due diligence has been done before taking up such a project? Is the DOE technically competent? 
1.	Is this project applied/registered under VCS or any other GHG programme?  How many CDM/VCS projects does the PP have? Is the DOE aware of this?

2.	If the Technology used in the project activity is imported from Annex-I country (United States of America), why you need CDM? It the PP is capable of this, how can he claim that he is financially weak? 

3.	“The Gazette of India, Extraordinary”, [Part II-Sec. 3(ii)], Ministry of Power, Notification, Dated. 29/03/1994 has specified the fair life of both gas and diesel based power plants as 15 years. Then how and why PP has taken the life to be as 25year? What the DOE doing?

4.	Why after every 4 years there are 5,275 increase in CERs in the table provided in section A.4.4 of the PDD?

5.	For Plausible Alternative 6: Power generation using Naphtha, the justification by the PP is not clear and acceptable. How did the DOE evaluate this? Is the DOE aware of Government of Andhra Pradesh -2000 order “Deciding to convert all short gestation period power plants to be natural gas”. Then how is Naphtha a realistic and credible and fulfils all the criteria?

6.	For Plausible Alternative 7: Power generation using Diesel / other fuel oils, the justification by the PP is not clear and acceptable. How did the DOE evaluate this? The justification by the PP for not considering the option is not acceptable. Pls. refer the other registered PDD.

7.	The justification provided for Wind, Hydro and especially Solar is FUNNY.  For Solar, the explanation is not acceptable “Although clustering of Solar PV plants equalling the capacity of project activity is technically possible, it is not realistic to generate the electricity proposed to be generated by the project activity”. Without proving financially analysis, how can you conclude? What the DOE is doing?

8.	Why PP has not considered SUPER CRITICAL technology as another alternative to this project activity?

9.	Common practice analysis, done in 1 sentence, my goodness! Look’s very funny; can anyone tell what’s really going on? What is the EB and DOE doing? Wake up guy’s, I strongly believe that this is a FAKE project, with COOKED stuff! Is the EB fool to believe? What does the PP/consultant and DOE think? Is the DOE technically competent? On what basis DOE has evaluated this project before web hosting? This is 100% a fake CDM project, the consultant and DOE are making MOCKERY of CDM and UNFCCC guidelines. They are telling all FARIY TALE stories. Please, EB wake up, open your eyes and look into this, this is a serious issue. Don’t approve such FAKE projects. 

10.	Why SHR (Station Heat Rate) is not considered for sensitivity analysis? Again I have a doubt, is the financial part of the project looked up by an expert or the DOE just believes the consultant/PP? Has the DOE checked all the financial parameters as per the latest investment analysis guidance?

11.	Is the PP getting TAX Exemption in India by investing in this project? Is the Consultant and DOE really aware of this? Is this reflected in the financial calculation sheets? As the financial calculation sheets are not available, I request the DOE and EB members to look in to this.

12.	The PP/DOE has not proved the availability of gas is abundant in the region (AP) as per meth in the PDD, instead he is taking INDIA as a region, why? The possible leakage is also not addressed. Is the DOE aware of this?

13.	 As the life of WTG is 25 years, he is getting tax benefits and for the rest 10 years he wants CDM money. For the entire 25 years he is getting money from the state electricity board as per the PPA. With so many benefits how can you still claim that the project is financially not attractive? I request the EB members to look into it.

14.	PP has already has many electricity generating project, the core business is energy production. Then why do you need CDM money to implement this project? Has the DOE checked the annual reports/red prospect hearing and other press release related to the company? Please mention the same in the PDD for more clarity.

15.	The calculation of levelised cost is also not transparent. Are all the assumptions in parameters used for the project activity and the baseline are as EB guidelines on investment analysis? Pls justify on their conservativeness transparently in the PDD.

16.	The funniest part of all is the CER, the value’s given in section A.4.4 and B.6.4 are not the same i.e., consistent, why is it like that? What the DOE is doing, he is really not aware of the issues? Do the DOE doing a completeness check of the PDD, before web hosting? Has he is comparing with meth and PDD guidelines published by UNFCCC? What due diligence has been done before taking up such a project? Is the DOE technically competent?

17.	Life time of the project in section A.4.3 mentioned as 25 years, but in section C.1.2 it is mentioned as 23 years? Why in the same PDD like this? What is the PP and DOE up to?

18.	In section A.4.4 the crediting period date is mentioned as 30/09/2012 - 29/09/2013 and in section B.6.4 it is mentioned as 30/03/2012 - 29/03/2013. But in section C.2.2.1 it is mentioned as 31/03/2012. Oh! God, what’s happening? I am reviewing the PDD? What the DOE has done? Is the DOE really fit to do this job? How did he get accredited by UNFCCC? Are there some procedural mistakes/loop holes in the UNFCCC accreditation itself? How can UNFCCC give accreditation to such companies/organisations? I am really feel sorry to the Public/NGO and other persons interested in CDM, that they have to see such WORST PDD; this PDD is the best example of what not to do and reflects the STANDARD of the DOE and puts a BIG QUESTION MARK on its TECHNICAL COMPETENCE and capacity in not able to handle large scale projects of such nature/complexity.

19.	Coming to EIA part, it is clearly evident from this section that the PP and DOE are not having any knowledge on EIA of the host country and its procedures. As per this section there are 3 types/kinds of EIA, so let us know what exactly was done? Please clarify on what is
	Indian Environmental (Protection) Act 1986 and its further amendments
	Rapid / Comprehensive EIA
	Summary EIA

20.	Why there is no mention of natural gas in the EMP? Is natural gas a safe substance to use and no hazardous are associated with its extraction/transport/storage/use?

21.	I request the PP/DOE to give the “Clean Development Mechanism (CDM) compliance procedure for local stakeholder consultation meeting” as indicated in section E.1 of the PDD. Why the PP has identified people involved with implementation and operation as the local stakeholder (these are the employee of the PP, and definitely will a positive response)? It’s funny! And a serious issue to look, now it’s clear that the local stakeholder consultation meeting was held without the people who are opposing/harmed by this project activity were not consulted. The process and procedure of stakeholders meeting mentioned in section E of the PDD is not adequate and transparent, as a 3rd party I am not able to know what exactly happened? Has the DOE aware of VVM? Has he seen/heard or read this anywhere? 

What the DOE is doing, he is really not aware of the above issues? If yes, then how and why did the DOE webhost this project? I strongly feel that the project should not have been web hosted, however the consultant and DOE have succeeded in achieving this.  Therefore, now I request the EB members to look into this project as a special case. 
After going through project PDD, I strongly believe that this is a FAKE project, with COOKED stuff! I think that DOE in not technically competent. I want to know on what basis the DOE has evaluated this project before web hosting. The PP/consultant and DOE are making MOCKERY of CDM and UNFCCC guidelines. They are telling all FARIY TALE stories. And think the EB and others are fools to believe this? What does the PP/consultant and DOE think? 

This is 100% a fake CDM project. Please, EB wake up, open your eyes and look into this, this is a serious issue. Don’t approve such FAKE projects. 

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.