PDD is not at all transparent for a stakeholder to comment! How can DOE web-host such a PDD which is not at all transparent. EB to make note of such web-hostings for global stakeholder consultation. This defeats the purpose of transparency of CDM! Is this deliberately done?? DOE to answer this.

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 may indicate a lower PLF. The third party report can be forge just to indicate a lower PLF. Also cross check with tariff order.

Excuse me. Earlier comment was not meant for this project.

1)	Purpose of the project and how the proposed project activity reduces greenhouse gas emissions are not briefed in the PDD. Refer section A.2.
2)	How environmentally safe and sound technology is used for the project and details of technology transfer is not demonstrated adequately. Refer A.4.2
3)	Non- debundling nature of the project activity is not adequately justified as per EB54 Annex 13 (Debundling tool). Refer A.4.5
4)	Why has option A (Combined margin) been chosen for calculating emission factor is not justified. Refer B.6
5)	The justification of choosing IRR as financial indicator is not adequately justified. Whether it is equity or project IRR, pre-tax or post tax is not mentioned in the PDD. 
6)	Basis of choosing PLR as benchmark is not adequately demonstrated in the PDD 
7)	All the issues of investment analysis guidelines are not discussed in the PDD. Refer B.5. 
8)	Justification of parameters including O&M, insurance, loan, derating, escalation, and tariff are not demonstrated with justification. Refer B.5.
9)	Please provide a proof for proposed debt to equity taken at the investment decision. Refer B.5 
10)	Proof for PLF is not justified. 
11)	Date of offer is not provided  
12)	Project cost is not as per state norms. Refer B.5.
13)	O&M charges and its escalation is not as per  norms 
14)	IT rate assumed is not as per standard practice. 
15)	CER revenue assumed is not consistently applied 
16)	Project cost is not as per  norms
17)	Benchmark calculation is not as per WACC tool (EB53 Annex 8)
18)	Date of PPA is not mentioned in the prior consideration of CDM 
19)	The selection of simple OM based on low cost/must run resources is not adequately justified. Refer B.6.1
20)	Ex-ante option of calculating OM is not adequately demonstrated. Step 3 of Refer B.6.1
21)	Power plants registered as CDM project activities should be included in the sample group that is used to calculate the operating margin if the criteria for including the power source in the sample group apply. This argument is not demonstrated. B.6.1
22)	The selection of option (out of two) for calculating OM is not adequately documented with justification. CEA calculation is based on net electricity generation, the average efficiency of each power unit and the fuel types used in each power unit. Step 4 of B.6.1
23)	The argument that CEA data for build margin is calculated as per Emission factor tool is not documented.  B.6.1
24)	Spread sheet is not provided. The data should be presented in a manner that enables reproducing of the calculation of OM, BM, and CM. 
25)	The justification of negligible project emissions for wind project is not as per AMS. I. D ver 16.0 EB 54). 
26)	The emission factor value (Southern grid) for calculating baseline emission is wrong. Refer B.6.3
27)	Net electricity should be continuously monitored, hourly measured and at least monthly recorded. Refer B.7.1
28)	Metering regulations as per CEA norms is not adequately followed in monitoring plan. Refer B.7.2.