1. How can this project be first of its kind when Delhi metro has already implemented a similar project?
 
2. Can you elaborate how this project is additional?

Dear Sir,
The applied methodology AMS III C is for the category that comprises low-greenhouse gas emitting vehicles and the project activity comprises of regenerative braking system which is an energy efficiency measure not a low GHG emitting technology. Hence, the project activity should use AMS II D not AMS III C. 
In section B.5, Mumbai Metro One Private Limited has stated that they had proposed the methodology NM 266 which has been subsequently converted into ACM.  If Mumbai Metro One Private Limited is planning to take up entire metro project as a CDM project than why are they taking the regenerative pat as a different project? Will this not lead to double counting when the entire metro rail is taken up as CDM project? How does Mumbai Metro One Private Limited plan to take into account the double counting issue?
The common practice analysis states that 
       “ Provide an analysis of any other activities that are operational and that are similar to the proposed project activity. Projects are considered similar if they are in the same country/region and/or rely on a broadly similar technology, are of a similar scale, and take place in a comparable environment with respect to regulatory framework, investment climate, access to technology, access to financing, etc. Other CDM project activities (registered project activities and project activities which have been published on the UNFCCC website for global stakeholder consultation as part of the validation process) are not to be included in this analysis”

  It should be noted by the DOE that the there are only two metros in operational in India, in Delhi & Kolkatta. The Delhi metro has already taken the regenerative braking as CDM project activity under the first of kind barrier. Hence, how can the Mumbai metro claim to be first of its kind when both of them are in the same country and implemented under similar policies. The penetration of Metro Rail in India very so low and only few cities have implemented it. Then why is Mumbai Metro considering state boundaries for common practice analysis?

In the “Installation of Low Green House Gases (GHG) emitting rolling stock cars in metro system” registered project activity of Delhi Metro, the same technological  barriers had been stated and the DOE had considered them as non significant barrier. Then, why is the Mumbai Metro one stating these barriers? The DOE should check the credibility of these barriers. 
Also, Mumbai Metro One has mentioned that in page 9 of the PDD that regenerative braking reduces maintenance cost and increases train availability. Then, how are the technological barriers prohibitive in nature?
Mumbai Metro One has made considerable efforts in copying the PDD of the Delhi metro registered project. However, unfortunately they have not seen the validation report where the validator has concluded these barriers as non prohibitive in nature in page 19 of the validation report.
Regenerative braking is quite economical as the electricity generated during braking becomes available to power other rolling stock. Besides energy saving (7.04 kWh/km for each train having 4 cars and 10.56 kWh/km for each train for 6 car rolling stocks regenerative braking has other benefits in terms of reduction in maintenance, increase in train availability and reduced heat generation.
In page no 9 of the PDD in section A.4.2. the Mumbai Metro One has accepted that regeneration braking is very economical so no financial additionality and also other benefits like reduction in maintenance, increase in train availability etc.,
In page 9 of the PDD, it is mentioned that in Regenerative braking, the electrical energy generated by traction motor is fed back to the overhead line. This energy is then used by other rolling stock. The flow of electricity is controlled by converter-inverter.DOE needs to investigate more on this aspect as  it seems the rolling stock which regenerates electrical energy does not use it and this energy is being used by other rolling stock so how it is energy efficiency project ?
 Also, since the rolling stock which regenerates electrical energy does not use the regenerated electrical energy. This seems to be fictious energy efficiency to get more clarity the trains should be operated without regenerative braking for atleast 1 year so that would be baseline and after setting the baseline the project can be operated and difference can be claimed as emission reductions otherwise its looks that baseline energy figures would be fictious.
Please see the below link: www.rdso.gov.in/projects/projects/emu_ps.doc
This document says that regenerative braking is installed in Mumbai suburban EMUs did these project has taken CDM or how it is operating without CDM? 
The Mumbai metro meth NM266 does not mention not a single word about regenerative braking this itself shows that regenerative braking is not a salient feature. Mumbai Metro one have themselves accepted this fact by not adding it in the proposed methodology or do they want double benefits of CDM. 
We would request the DOE to reply to all our queries/concerns.