DOE to check whether tax holiday is corrected applied in the financial calculations i.e. 10 years strict tax holiday and not payment of any type of tax whatsoever. 

DOE to check whether the tax benefits (tax shielding) is correctly applied. Also, for tax shielding the corporate tax should be applied.

In case MAT is also applied, DOE to check the correctness of MAT calculations. Also, check whether MAT credit is considered correctly.

The project cost should be compared with that indicated in the applicable tariff order available at the time of investment decision making. 

The technology supplier can charge a premium price for the WTGs so that the project becomes additional for CDM benefits.

DOE to validate whether a unlevered beta or levered beta would be applicable with proper justification and appropriate reference. An unlevered beta is most appropriate as it leads to a conservative benchmark and hence should be used.

Do the validators used by DOE have the competency to validate the financial sheets presented by the PP or are they taking help from external financial experts.

Please explain location selection criteria.

Does project owner had any kind of wind based energy business experience?

How many skilled/unskilled people from surrounding area were employed at this project during commissioning and operation as mentioned in social well being section? 

List of stakeholders is not attached with PDD.

What would be impact of negative environmental conditions of area upon project? What would be alternatives in that case?


From
Mahesh Pandya
Environmental Engineer
Paryavaran mitra
502, Raj Avenue, Bhaikakanagar road
Thaltej, Ahmedabad – 380059 India
Telefax - 079-26851321/1801
 

Gujarat fourm on CDM respectfully submit the following comments on the Project Design Document (PDD) for Grid connected clean energy project in Jamnagar, Gujarat, India. We thank the CDM Executive Board and Designated Operation Entity (DOE) for recognizing the integral role of transparency in CDM Validation process, and for taking this comment into consideration.
The project is not appropriate for the following points

o	The direct and indirect employments have been considered as  the indicators for the Social and economical well being, but no data has been given regarding the no. of additional direct and indirect  employments will be created and no of person days will be created during the project period. 


o	No justification has been given regarding the selection of sites for installation of Wind Power Turbine and how much land has been acquired for the purpose?


o	No information has been provided about the acquired land and its previous use.

o	No commitment has been shown by the company regarding sustainable development as well as additionality as per CDM requirement.


o	How many live stocks in the nearby villages and how much grasslands are available for the animals.

o	In the stakeholder comments, adequate information has not been provided such as how many people have participated and how many people from near by villages have participated.
o	

.

Gujarat fourm on CDM
Email: gujaratfourmoncdm@gmail.com