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. PP may show taxation with the logic of cumulative losses - which is totally incorrect!!

So the guideline on continuous action implies that you have one event every 2 years and the project is additional?
Why would anyone sign an ERPA with the PP considering the fact that a substantial time had already elapsed since commissioning and nothing happened on CDM front?

The DOE should validate the authenticity of the ERPA and raise a FAR in the validation report that it should be verified in the monitoring that the CERs are being sold to the same buyer as mentioned in the ERPA. Please also elaborate-

1. What are the conditions in the ERPA? Can it be terminated with a penalty? if so, the FAR should also mention that this penalty should be monitored. if there is no financier implication of terminate then clearly this ERPA was created to fill the time gap and is a farce.

2. What is the authenticity of the buyer? Has he ever bought CERs?


EMCO also has a total capacity of 10.5 MW, indicated in many news articles. This PDD is only for 9 MW. So this implies that 1.5 MW is operating without CDM? The DOE should also validate this.

WACC of 15.06% is very high. DOE should validate the conservativeness of this benchmark

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 consultant has done till to date? This consultant is responsible for corrupting and spoiling the whole CDM business in India. Why this consultant is not working like any other consultant in the market? Why he is web hosting only projects which were rejected, with drawn, forged (documents changed and forged) and fully problematic projects? 
The Managing Director/CEO (Rambabu) of this consulting company called General Carbon/General carbon pte Ltd. is fully responsible for spoiling the CDM consulting business in India. He is totally unprofessional and unethical. He never did any work in a professional and ethical manner in his working. He started his own consulting company when he was working with PWC by violating the contract with PWC. Then later on he started CantorCO2e in India. They gave all sorts of wrong promises to clients and finally many of the clients are disappointed and lost money who signed with CantorCO2e. While leaving the CantorCO2e while working in CantorCO2e itself he promoted his own company General Carbon Advisory Services Pvt. Ltd and made the clients sign with General Carbon. 
What is this? After he left CantorCO2e employment he took away most of the projects and clients of CantorCO2e by violating all his contract terms, employment conditions and established business ethics. CantorCO2e is pursuing this person legally and he should not be left free. If he thinks he is intelligent he should develop businesses on his own and not rob like this. It is shame that project owners and DOE’s are working with such illegal, unethical, unprofessional and cheating companies and individuals.
General Carbon/ General carbon pte Ltd. is intentionally quote very low to kill completion and also the CDM business as a whole. Only they wish to be in the market, nobody else should work as a consultant in the market. They should explain why it is so. 
 Every project owner and DOE whoever is working with General Carbon should introspect, understand the implications and stop working with General Carbon. General Carbon/ General carbon pte Ltd. is built on totally wrong foundation with robbed clients, wrong promises, cheating the system, deceiving, corrupting the full CDM business overall. One should be ashamed of working with General Carbon in what so ever manner. He spoiled old DOE’s and the system by bribing the DOE auditors and others in the system.
 Every new and old DOE entered in the market was misused by him somehow. 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 General Carbon/ General carbon pte Ltd. on these points and take appropriate actions to save the project owners and CDM business fraternity from this evil person and evil company. Never believe the documents given by General Carbon, DOE must cross check all of them. General Carbon is the forgery masters. 
DOE to be careful in undertaking any jobs referred by this kind of consulting companies, instead they should not take up the job at all in the best interest of CDM business and to protect their interests and reputation. 

This project is not following the CDM 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 registered under VCS or any other GHG programme?  How many VCS projects do the PP has? Is the DOE aware of this?

2.	As per section B.5, the POs of the 6 WTGs are issued on 02/07/2007, then why only 3 WTG’s commissioned in Nov-Dec 2007 and 3 WTG’s in 31/03/2008? 

3.	As per section B.5, CDM Consultancy agreement with PWC on 10/03/2008 and Local stakeholders’ meeting at the WTGs site on 25/07/2008. But why did it take such a long time i.e., almost 17 months to sign ERPA for sale of CERs on 25/02/2010. This is clear indication that, the PP was not interested in CDM as the project itself was doing well, i.e., financial viable. Only the consultant (with the help of DOE) to get financial benefits from the PP, have created fake documents. I request the EB has to look into this. The consultant and DOE are making a MOCKERY of CDM and UNFCCC guidelines.

4.	It is mentioned in section B.5, that CDM Consultancy agreement with other consultant on 18/11/2010. But in section it is mentioned “EMCO Limited is the responsible entity for applying baseline study and the monitoring methodology to the project activity and its contact information with completion date as 10/12/2010”. What does it mean? Who is the other CDM consultant? Is the EB fool to believe? What does the PP/consultant and DOE think? Is the DOE technically competent? On what basis has he evaluated the project before web hosting? This is 100% a fake CDM project, the consultant and DOE are making a MOCKERY of CDM and UNFCCC guidelines to fill their pockets. They are telling all FARIY TALE stories. The consultant and DOE are making a MOCKERY of CDM and UNFCCC guidelines. Please, EB wake up, open your eyes and look into this, this is a serious issue. Don’t approve such FAKE projects. 

5.	Again I have a doubt, is the financial part of the project looked up by an expert or the DOE just believes the consultant? Has the DOE checked all the financial parameters as per the latest investment analysis guidance?

6.	By investing in WTG’s the PP is already getting TAX Exemption in India as per section 80 IA of Income Tax Act for 10 years. 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.

7.	As the life of WTG is 20 years, he is getting tax benefits for 10 years and for the rest 10 years he wants CDM money. For the entire 20 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.

8.	PP has already run the machines for 4 years without CDM revenue, so why he wants it now?

9.	The project IRR is 6.36% against a benchmark of 15.06%, My Goodness! Then why did the PP take up this project? Or the consultant is doing a MOCKERY of EB guidelines? Why? Even with CDM benefits these projects will never cross Benchmark. Then why the PP is investing in such kind of project? 

10.	Why PLF is not considered for sensitivity analysis?

11.	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 what exactly happened? How many stakeholders where present? What did they ask? What did the PP/Consultant answer?  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 it? 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. 

This is thoroughly cooked up CDM project. Does not deserve even validation. How come the PP is showing an ERPA and telling that there is real and continuous action? The ERPA what is mentioned is 200% fake and forged. This consultant is the trend setter and record holder in fabricating, forging illegally any documents in CDM process. This ERPA is dated what? Are there any emails exchanged during those ERPA signing days between PP and CER Buyer? Let PP show the real evidence that this particular ERPA was really signed on that date by showing the exchange of emails during those days. Sure none will be there. Any way EPRA has no meaning even if they prove that ERPA was signed those days. Why the party has not signed any validation agreement with a DOE? Do they have a signed CDM validation agreement with any DOE? If yes, have they paid money to DOE so that we can conclusively prove that PP has considered CDM and serious real and continuous action was there. If the PP has not paid to the DOE then we can conclusively say that no real and continuous action at all. This project does not merit any further validation, DOE must tell the PP to with draw the project from CDM. Alternatively DOE should issue a negative validation report and protect their reputation and future. Why did PP not apply for more than three years for host country approval? The fact is PP has never considered CDM revenue to establish the project. In fact that is evident from the actions. After that some fraud consultant must have given this fraud idea of applying for CDM revenues when the PP has almost forgot the project activity itself since it is a done project. DOE must not take this kind of projects at all. This will take the DOE more and closer to suspension and disgrace. Why DOE is taking up this kind of projects? What due diligence and checks the DOE has done prior to accepting this job? Why not take some fresh projects and try to do good work. 

•	Who is the consultant and CER buyer of this project? Is it General Carbon Advisory Services P. Ltd or General Carbon Pte Ltd or Care Sustainability or any of General Carbon’s related companies or related companies of members of General Carbon management? DOE to examine and reject this project right away. This project does not merit even a look at it any more. General Carbon should canvas about their real achievements not their some useless and meaning less awards. There is no point in getting any awards by paying money and influencing. What results this bunch of cheaters in General Carbon has shown till today? How many projects they have registered? For how many projects CER’s are issued? General Carbon achievements include A) Cooking up, forging and manipulating CDM projects and there by bringing disrepute to the whole CDM process. B)  Cheating foreign business partners C) Spoiling the CDM projects indirectly and approaching thereafter to the PP saying that they will register the project. There by taking more money from the PP in an illegal fashion. D) Misguiding DOE’s staff and management so that General Carbon can use each DOE for their own selfish and illegal needs. Telling one DOE about other DOE and influencing the DOE to do some things and eventually DOE’s gets screwed. E) Real driver and main root cause of some of the DOE suspensions in the past. Now General Carbon is maintaining their revered status in this regard and definitely one or two more DOE’s will be suspended soon due their misadventures with General Carbon. Now in the interest of whole CDM market, General Carbon should come out with a report of their achievements on the lines mentioned above. That will help the market understand the real colour of General Carbon. 
•	It is very sad that poor PP’s are getting carried away by the wrong promises being doled out by this bunch of cheaters and hiring General Carbon. They tell many lies and deliver very less results on the ground. Any entity or person working with General Carbon in whatever role is risking heavily their character, future, market image, money, opportunity and time. 

1.	As per chronology of events PP has mentioned the appointment of first consultant with PWC but in 18/11/2010 with other consultant name has not been mentioned intentionally, who is the other secret consultant of this project? This shows PP hiding some information’s form UNFCCC and DOE; this has to be check thoroughly by DOE.

2.	DOE has to check, ERPA was signed within two years from contract with which consultant, new other consultant or PWC, please give us full detail.


3.	Prior consideration of CDM which is important for the determination of additionality is not documented in the section B.5 of the PDD.  

4.	Why PP has not included PLF in sensitivity analysis, please clarify.


5.	Why PP has not taken host country approval so long years, DOE has to check.

6.	The calculation of project IRR is not as per “Guidance on the Assessment of Investment Analysis’ Version 03, EB 51, Annex 58”.


7.	Why the date of investment decision and chronology of events are not properly documented in the PDD. How DOE has allowed this. It seems that it is deliberate action by PP which is well supported by DOE. It is not expected of a well reputed DOE.  The PDD fails to provide data during investment decision date to reject imported electricity as a project alternative. Since date of investment decision is not stated explicitly, it is difficult to reject the option of import of electricity.  

8.	Moreover, the PDD conveniently suppress the facts of incentives for plant load factor. PP has to explain how these incentives affected the baseline scenarios and technology choice.


9.	. PDD does not clearly describe the stakeholders involved in Project or the information provided to them. The PDD mentions “identified stakeholders,” but does not detail which of these stakeholders actually participated in the process. The PDD does not describe the information provided to stakeholders with sufficient clarity, such as whether adverse environmental impacts were described along with the benefits that were mentioned.

10.	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.


11.	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

12.	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


13.	Metering regulations as per CEA norms is not adequately followed in monitoring plan. Refer B.7.2.

Non de-bundling nature of the project is not justified properly in the section A.4.5. DOE has to validate whether there is no registered project with the PP nor there is an application for registration of any project. PP doesn’t confirm in the PDD that there is no application for registration. 
2.	Operating margin, build margin, combined margin is not as per “Tool for emission factor for an electricity system”. The tool is not used at all. Pls. calculate combined margin as per the tool. Pls. justify that grid emission factor calculated is as per CEA data latest version.
3.	The date of investment decision is not provided transparently. It should be used generously in the PDD for clarity. 
4.	How risk free return, market return and beta is calculated is not documented in the PDD. How many companies included in the calculation of beta.
5.	The application of MAT which is based on tax holiday while calculating WACC is not appropriate. 
6.	The project cost of the project should be based on offer and not on purchase order or tariff order.
7.	O&M charges considered are on higher side. Pls. clarify. 
8.	Justification of tariff rate is not provided.
9.	Justification of PLF is not provided. There is a huge difference in project. It should be based on guideline as provided by latest EB report. Pls. clarify. DOE has to validate this.
10.	A notification has to be sent to government of India and EB stating the starting of the project. It is not clear from the PDD whether it is done since this aspect is not provided in the PDD. Pls. clarify.
11. 	The most responsible work of DOE needs to check the ERPA between them. It’s a fake and cocked up project.
12.	UNFCCC has to personally check the project thoroughly. Because more loopholes are there in the proposed project.
13. 	The project proponent and consultants are playing a game with UNFCCC, please take more care of this project, this is my sincere request to DOE.  
14.	DOE has more responsibility to take-up this type of project, if DOE continues this project they will face more problem in future.

	Under CDM consideration section, the  board takes decision in 18th Jan 2007 without any offer from the supplier and issued the PO on July 2, 2007?..then purely it’s a commercial decision…also the gap between the two events is 7 months…what is reason for delay?...when in normal practice, the PO is issued in two months based on previous offer letter?...this implies that offer was received after the board decision , which makes this a non-CDM project. Also CDM consultancy agreement was signed only after commissioning of 3 WTGs..then how serious CDM consideration is shown?
	In project IRR….the tariff rate after 13 years is not evident?...also the tariff is based on MERC wind order 2003-04?....when escalation is also proposed how can tariff of 2003-04 be taken for investment decision of 2007?...the tariff rate also has not taken in to account the new tariff rate by MERC which is higher from 2008?...what basis the IRR was calculated is not transparent...also project cost is taken as 585 million for  9 MW capacity??..at 6.5 crore / MW .while MERC order indicates Rs. 5 crore / MW?...how is the cost inflation justified?....for convenience sake PP has taken project cost from offer while ignoring the MERC order while for other parameters MERC has been taken…
	MERC order on wind power 2003-04, page 12 states that benefits of the CDM has  to be shared with MSEB by the PP….this is not evident in the financials described??....also it states that up to 13th year a RoE of 16 % is guaranteed??...then why PP requires CDM??...How was PLF validated??...PP says based on third party?...but compared to actuals is it conservative??...a study of Maharashtra wind projects actual generation would confirm that these are not conservative…also is salvage value included in the cash returns??
	EMCOs annual financial reports for 2006-07 in its website indicate that 882.76 lakhs ( 8.8 crores) have been spent on WTGs…as on 31st March 2007…..while 2007-08 reports indicate that 7 WTGs of 1.5 MW have been installed…while project activity indicates 6 WTGs only??...How can a purchase order of July 2007 be incorporated as expenses towards WTGs in April 2007 itself ??..this shows that the POs are faked to justify CDM….also as previous WTG was existing in 2006-07 itself it needs to be applied to calculate the debt: equity ratio as per EB guidelines…
	As per annual report 2008…Due to amalgamation of other companies with EMCO…the wind capacity has increased and the PP has included these WTGs also in this activity…..then how is serious CDM consideration validated for the entire project capacity?
	The generation in the annual report of 2007 as per actuals is reported to be 8237 kwh for 1.5 MW capacity and report of 2008 indicates 3,54,1496 MW for the entire capacity of 7 WTGs of 1.5 MW….then how is a generation of only 15,768 MW validated for 9 MW in the PDD??...that too as per third party and being in line with actual generation…this shows that the PLF values are fake and taking the actual generations of the entire project capacity the project can never pass additioanlity…it is a pity that such fake projects are being web-hosted by cheating consultants and incompetent DoEs and spoiling the CDM spirit….