Dear Sir,
When temperature profile of Gurgaon is considered, the maximum  temperature is above 66 deg F or 18 deg C for 11 months , hence building requires cooling for (12-1)/12= 91% of the year, than how will the Combined Cooling Heating and Power (CCHP) technology with the PLF of 60 % meet the requisite demands?
Further, as per CEA database version 5, the efficiency of Indian grid ranges between 30 %- 35% & DLF should take the lower value while calculating energy savings, then why has it taken a medieval value? The auxiliary consumption of the gas engines is also considered to be 10% which is higher than the industrial standards of 3% for gas engines, than why has DLF considered it more in their calculations?
In august 2008, DLF had webhosted a similar project activity of almost similar capacity, ( http://cdm.unfccc.int/Projects/Validation/DB/HNSU8FVRELYK3C7B6A79DYR36IMR53/view.html) which the project cost was 365 million & this project is also of almost the same capacity then why has the project cost escalated to 667 million which is about 100 % increase?
In Appendix 1, Mr. Kaushik Bhattacharya has thanked everyone for sparing their precious time to know about this new CCHP technology, however DLF has not demonstrated that how the  project is  first of its kind when other players have implemented it. Is this a new technology, which has not been used in India till date? The DOE should check whether others have taken CDM revenue into consideration or not while implementing such technologies. If not, then why does DLF need CDM revenue?

Natural Gas based cogeneration is very old technology many installations are in Gujarat and HBJ pipeline. In cogeneration,  power is produced and the waste heat is used for VAM operation and cooling is used in air-conditioning. Many Indian industries have been using this process for meeting their cooling requirements since early 1990’s then why is DLF claiming CERs for implementing this well established common practice technology of industries, in buildings? Does the technology become new only because it is implemented in buildings? Will the technology supplier say that is new technology since it is implemented in buildings?
Since this technology is a natural gas based cogeneration system with VAM, then why is cogeneration efficiency not used in the calculations of page 10 of the PDD.
The users of DLF will be the real consumers in this case. Will DLF submit ownership of CER certificate from each of the current user? 

DLF has rented out office space to various clients, who bear the cost of electricity generation & cooling cost.Hence the DOE should independently check all the bills and interview all the tenants to check their cooling & electricity bills and then check if it matches with the IRR of the project.

Many Indian manufacturers like Thermax, Voltas, Blue star are pioneers in VAM. The DOE should independently investigate client list of these companies to ascertain whether they have taken CDM or not for their NG based Cogeneration project which has VAM? 

We appreciate that DLF has developed the methodology and got it approved. However, we would like to bring few things to the kind notice of the DOE. As per the methodology NM0288, proposed by DLF,  no leakage associated with natural gas usage was considered inspite of this kind leakage being considered in many Natural gas based methodologies like AM0029. Please refer page no. 40 of the proposed methodology NM0288.

However, UNFCCC had approved the methodology AM0084 (Based on NM0288 submitted by DLF) considering leakage associated with natural gas leakage. This came as a bolt from the sky for DLF, to which they have smartly used AMS II H.

“Leakage may result from fuel extraction, processing, liquefaction, transportation, re-gasification and distribution of fossil fuels outside of the project boundary. This includes mainly fugitive CH4 emissions and CO2 emissions from associated fuel combustion and flaring. The leakage is determined by applying the calculations provided in the Leakage section of AM0029” 

The small scale methodology AMS II H does not take into account the leakage. Hence, it very clear that DLF has split the project into numerous small scale projects to avoid leakage emissions. 


It may be in the first time in the CDM history that the project proponent who has taken pains & efforts in developing the methodology because he is aware that if the approved methodology is used, then leakage due to NG usage is to be considered and emissions reductions would be reduced drastically.

In spite of implementing the same technology/project  in many of its buildings (please refer to various PDDs webhosted by DLF), DLF is not using a large scale methodology or PoA based on AMS-II H, which would have been the most preferred route, because of leakage issue due to NG usage. This fact should be investigated by the DOE to learn the truth about the project.

In section B.5, assumptions provided in the PDD are insufficient to reproduce the IRR calculations. Based on the limited set of assumptions disclosed, we have made a few observations which the DOE is requested to address:
a)	Whether the project revenues are computed based on the calculations tariff applicable for commercial buildings and if suitable escalations during the entire life of the project has been considered. Grid tariff historically has not remained constant and the same needs to be escalated on an annual basis for the entire life of the project. 
b)	The basis for assuming the Chiller PLF equal to 35%. In the National Capital Region, summer sets in during the month of March and the demand for cooling would continue till the month of October. The building set up is likely to house offices which will have cooling demand for 24 hours a day during this period. Based on the above set of assumptions, the PLF works out to be 75%. Also, how is the DOE planning to confirm that the DLF has not indicated a low PLF for the purpose of demonstrating additionality and that the actual operating load would not be higher than that assumed. Has this PLF been certified by a credible and authentic Third Party?
c)	The reason for not conducting a sensitivity analysis for the Chiller PLF. The DOE is also requested to confirm whether a 10% variation in the parameter would be considered reasonable for sensitivity analysis or if a higher percentage is required. 
d)	The DLF has considered O&M Cost at 4% of the Capital Cost. Is this cost comparable to those recommended by the CERC in the tariff order for thermal power generating stations (Order dated 26th March 2004)
e)	DLF has indicated that the identified baseline scenario for the project activity is import of power from the grid.  To meet the chilling requirements, in the baseline, DLF would have been required to invest in Compression Chillers. The implementation of the project has obviated the need for the investment in Compression chillers. Hence, the project cost should be the difference between the cost of VAM & compression chillers, not the total cost of the VAM. What would have been the cost of those Compression Chillers which DLF was not required to invest in? The PDD does not make any mention of these costs. The DOE is requested to confirm if the expenditure on the VAM has been offset with the expenditure on Compression chillers for IRR computation
f)	Similarly, building installations that draw power from the grid are known to have Diesel Generating Sets as backup which is a widely followed practice. The implementation of the project has resulted in avoiding usage of DG set, hence differential investment cost of DG set and NG based engine needs to be considered not the total cost of NG based engine. 
g)	The basis for assuming an auxiliary consumption equal to 10%. Gas based power projects are known to have auxiliary consumption in the range of 2 to 3%. This can be confirmed through the CERC order referred to above and also through the CEA database that the DLF has referred to for sourcing the Grid Emission Factor. 

The other PDD (http://cdm.unfccc.int/Projects/Validation/DB/HNSU8FVRELYK3C7B6A79DYR36IMR53/view.html) which was webhosted states that the start date is of 2005 if DLF had such big plans  of implementing  the projects in many locations then why did they take 3 years to develop a methodology of their own as mentioned in the chronology shown in Appendix 2. Was DLF not serious about CDM revenues? It is also mentioned that a new methodology has been submitted by DLF to the DOE on 21/04/2008. We would like to know what is this methodology and where was it submitted. The DOE was appointed on 29 /07/2009. The applied methodology AMS II H was valid from14th March 2008. This demonstrates that DLF was serious only when there as some scope to attain free CDM revenue
DLF has developed a large scale methodology for the project activity then why is the small scale methodology being applied for the project activity. DLF is using AMS II H to avoid common practice test. Hence, the DOE should ask DLF to prove common practice in all the project activities.

Methodology Applicability: The DOE is requested to clarify as to how it has webhosted the project without even checking if the meth is applicable for the project. 

The applied Meth AMS II H indicates that it is applicable only for project activities a) that displace existing facilities, b) or displace facilities that would have otherwise been built. The PP has erroneously assumed that the project is applicable for Greenfield facility. A facility that would have otherwise been built means that, at an existing facility, if the life of existing equipment has expired and the project activity involves deployment of an energy efficient system as compared to the facility that otherwise would have been built in the baseline scenario. 

This is also amply clear from the following procedures outlined in the methodology:

a)	Point 7 (a) of the methodology requires the PP to assess the remaining life for “EACH” identified equipment that would be displaced by the project activity. 
b)	Point 7 (b) of the meth requires the determination of the historical relative contribution of the equipment to the total annual output of energy type concerned based on relative contribution over the last three years

How has the PP sufficed this condition when there are no existing equipment at the facility. Do note that the meth does not state that this condition is applicable only for existing facilities but is applicable for all identified equipments. 

The monitoring plan also requires monitoring of the necessary parameters to demonstrate that the measures implemented by the project activity are limited to activities that results in additional steam/heat generation of no more than 5% of the project situation. This requirement is also applicable to all projects and not just for existing project activities. 

If there is even an iota of doubt in the DOE’s mind regarding the meth applicability, it should seek a clarification from the Small Scale Working Group before proceeding ahead with the project. 

Small Scale methodologies such as AMS III B require the PP to follow the General Guidance for Small Scale Project Activities which in turn require the PP to undertake a common practice analysis. Such a requirement is not specified in AMS II H as it is not applicable for Greenfield Activities. However, the DOE is still requested to ensure that a common practice analysis is undertaken by the PP. 
	
We would request DLF to reply to all our queries.

We would request the DOE to consider these queries for the other similar projects of DLF as well.