This project seems to be a cooked up project. I don’t know why DOE’s are taking risk in webhosting such kind of projects and more over General Carbon’s team is known for creating refurbished documents and cheating DOE’s. However, DOE has to ensure that all the documents submitted by PP/Consultant to be verified with originals.   

1.	This is a meaningless PDD. If you look at the chronology, they are showing the Board resolution for prior CDM knowledge. Any company can show their Board resolution as per their convenience. PP has to show any other evidence apart from Board resolution to DOE. 
2.	Second point is regarding the P.O dated 30/7/2008. One can easily make out that this Purchase Oder is a modified one. As per Annex 46 of EB 41 the projects having the start date from 2nd Aug 2008 PP has to intimate Host DNA or UNFCCC within 6 months from the start date. 
3.	I believe that Ispat was not aware of this and later on they have appointed the Consultant and as per the Consultant’s advice they have modified the P.O letter to escape from the intimation deadline. This clearly shows that Ispat was not at all serious about CDM and this project should not be promoted.  
4. Why there was a gap of 2 years to appoint a DOE.

•	For a plant that generates 42MW of power through its four WHRBs besides the project activity, claiming grid as the baseline does not seem to be a realistic option
•	PDD does not conclusively say the end use of power from the project activity, in one section it says all the power generated will be supplied to grid and in other section it says part power is for captive consumption. It seems the PP is not very clear on the purpose of the CDM project activity
•	Project activity is 20 MW Biomass power plant, but nowhere in the PDD this CDM activity specific turbine information is mentioned viz its capacity, whether it is purchased or is it part of any already planned capacity expansion, if so, was CDM considered then
•	The project follows investment analysis approach to prove additionality so in this context whether the project cost considered include the cost of turbine, other existing common auxiliaries example cost of the common header
•	The important parameter for power plant ‘PLF’ is not subjected to sensitivity analysis  
•	While the project meets the captive requirement, the basis of considering tariff for sensitivity analysis is not justifiable
•	Net calorific value of the biomass is not monitored / measured as per meth requirement

It is learnt that in Chhattisgarh State Coal based captive power plants are banned by the State Government and by Central Government due to very high pollution in the Industrial Area of Raipur District and Raigarh and Korba District. As per CEPI index these are declared severely polluted and critically polluted. Because of this many industries have put up the power plant in the name of biomass based power plant even the biomass is not available at all in Raipur district and only to circumvent the legal ban on putting up coal based captive power plant all these biomass based power plants are put up in industrial area.  Because of this biomass base captive power plant being a legal only option in that area becomes baseline.  Also the acute shortage of biomass would result into sever leakage in already established and operating power plants.  The shortage of biomass in Raipur district has already resulted in closure of the first biomass power plant of Chhattisgarh state thus very detail survey is required to proof that surplus biomass is available to all these biomass based power plants.

 

The captive power plant is going to replace the power likely to be generated by the already registered CDM project activity in the form of WHR boilers due to this the selection of baseline actually is WHRB based power plant. Because the projects which are registered are not yet verified for the generated CER, so the baseline is either the biomass based power plant itself or WHRB based power plant installed in the same premises.

 

The overlapping of the project boundary and apportioning of steam with biomass based power plant are not approved in the methodology under which the already registered WHRB projects are implemented.   

 

Over lapping of project boundary with different methodology project activity and with different time frame of project also require to be revalidated if the projects already registered were also additional or not.  As the project life claimed in the current PDD is 20 years, this shows that the existing registered project activity will also survive for 20 more years.  In the financial additionality the benefit of available infrastructure cost need to be reflected upon. 

 

In India the govt has introduced several subsidy schemes and sales tax exemption benefit as well as captive subsidy and renewable energy certificate mechanism, the financial impact on cost of project and revenue due to these should be considered while working out the financial viability.

How the power generation figures from 7 MW WHRB and 10 MW WHRB registered project is being validated, is is accordance with registered monitoring plan if yes whether this is verified.