PP has deliberately chosen BSE 500 index which will give higher expected returns to raise the benchmark.

Why unlevered beta is right for benchmark calculation and for the equity returns from project??

With such a high benchmark of more than 18% the project will not be viable even without CDM benefits!! Why then the PP is investing in the unviable project even without CDM benefits???

Consultant has not written a clear pdd. No good work done!!

Why Reliance Infrastructure Ltd is considered as a comparable company which is into power distribution and various other services other than power producing.. is the risk profile same???

Such a high beta of more than 1 is unacceptable... Why are you considering BF utilities which gives erratic beta?? Just to rise your benchmark??

All bundles are having different varying benchmakr which shows that one can always play with numbers indices, beta, etc to construct whatever benchmark needed?? Is EB scrutinising such projects in depth???

THe expected generation seems to be very low only to make the project unviable.

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.

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 equity irr?

Stakeholder consultation:
No details provided on which all stakeholders attended the meeting. 

Dear oh! Dear, what is this? How can you re-webhost a rejected project for 2nd time and claim CER’s?
How EB is evaluating this? 1st of all Why the DOE is web hosting such projects for GSCP?  It should not have taken up such a projects. Has the DOE done a study of the past i.e., History of the project? Now, I request the DOE to answer my quires i.e., issues of concern
1.	 Why the project was rejected, when it was web- hosted for the 1st time during 12th June 2009 – 11th July 2009? 

2.	It was web-hosted with a title of “Grid connected renewable electricity generation project by M/s. Premier Mills Pvt Ltd in Tamilnadu, India” with total installed capacity of 47.85MW and why the title (Grid Connected Wind Power Generation in Tamil Nadu, India) and capacity (24.75MW) changed now? 

3.	What happened to the other Premier Mills Pvt Ltd (PML) formerly Premier Fine Yarns Pvt Ltd (PFYL) and Premier Spg & Wvg Mills Pvt Ltd (PSW) formerly Premier Mills Pvt Ltd? 

4.	Why the consultant (earlier CantorCO2e India Pvt. Ltd.) and now (General Carbon Advisory Services Pvt Ltd) is coming up with a new bundle? Point to be noted here is the company name of the consultant has been changed, but not the team.

5.	Applicability of baseline of this project activity absolutely wrong, DOE has to check and verify and give justification regarding this.

6.	The emission factor value (Southern grid) for calculating baseline emission is wrong. Refer B.6.3

7.	Was the project IRR crossing Benchmark during 12th June 2009 – 11th July 2009 webhosting? So the capacity is reduced now? 

8.	Why the capacity, title and DOE changed now, except the consultant?

9.	In the earlier web-hosted PDD, Project IRR is 9.17% against Benchmark of 13.30% (CAPM model) for Premier Cotton Textiles and for Sree Narasimha Textiles Pvt Ltd the Project IRR is 7.77% against Benchmark of 13.30% (CAPM model). But now (i.e., in the latest web hosting) Project IRR is 9.16% against Benchmark of 14.20% (CAPM model) for Premier Cotton Textiles and for Sree Narasimha Textiles Pvt Ltd the Project IRR is 7.41% against Benchmark of 14.29% (CAPM model). Why?

10.	Even with CDM benefits these projects will never cross Benchmark. Then why the PP is investing in such kind of projects (I don’t expect an answer telling environmental friendly, less GHG, pls. give a valid explanation). This is clearly to make Mockery of CDM and Kyoto protocol.

11.	Most important point to note here is, the PP is running these windmills from 2004 till date i.e., exactly 7 years without any shut down. 

•	So then why the HELL he want’s CDM money? 
•	If so many financial barriers were present, first of all why did he invest?
•	Ok, if we agree that the PP saw CDM money and invested, but when the project was rejected by UNFCCC for the 1st time during 2009, they how the Windmills are running till date without PP being Bankrupt?
•	Has PP taken loan from others sources to run the project to get CDM money (which huge compare to other sources)?
•	How as the PP managed to Pay Consultant and DoE for two times (as per my knowledge the Consultation and Validation fee will not be less than 1 Million rupees for a single validation for a project of this scale)? Is the Consultant and DoE working for free?
•	I strongly demand an explanation from the PP/Consultant/DoE for these; they should not answer telling irrelevant to the project activity. As this is a serious issue, which requires a proper explanation. I once again request the EB to check how DoE justified and take further actions regarding this project during RFR.

12.	My last and the final question to the PP and consultant is if the project is rejected now, will they reduce the capacity (small scale), change the title and re-webhost with a new DOE (say SIRIM or PJR)? Because SIRIM and PJR are web-hosting only rejected projects taken up by General Carbon Advisory Services Pvt Ltd. General carbon please stop playing the games in the market. General carbon is an un-ethical company who ever working with GC is also unethical. GC should explain why they are working only on rejected and withdrawn projects. BVQI immediately stop working on these kind of projects.

Dear oh! Dear, what is this? How can you re-webhost a rejected project for 2nd time and claim CER’s?
How EB is evaluating this? 1st of all Why the DOE is web hosting such projects for GSCP?  It should not have taken up such a projects. Has the DOE done a study of the past i.e., History of the project? Now, I request the DOE to answer my quires i.e., issues of concern
1.	 Why the project was rejected, when it was web- hosted for the 1st time during 12th June 2009 – 11th July 2009? 

2.	It was web-hosted with a title of “Grid connected renewable electricity generation project by M/s. Premier Mills Pvt Ltd in Tamilnadu, India” with total installed capacity of 47.85MW and why the title (Grid Connected Wind Power Generation in Tamil Nadu, India) and capacity (24.75MW) changed now? 

3.	What happened to the other Premier Mills Pvt Ltd (PML) formerly Premier Fine Yarns Pvt Ltd (PFYL) and Premier Spg & Wvg Mills Pvt Ltd (PSW) formerly Premier Mills Pvt Ltd? 

4.	Why the consultant (earlier CantorCO2e India Pvt. Ltd.) and now (General Carbon Advisory Services Pvt Ltd) is coming up with a new bundle? Point to be noted here is the company name of the consultant has been changed, but not the team.

5.	Applicability of baseline of this project activity absolutely wrong, its should be diesel,  DOE has to check and verify and give justification regarding this.

6.	The emission factor value (Southern grid) for calculating baseline emission is wrong. Refer B.6.3

7.	Was the project IRR crossing Benchmark during 12th June 2009 – 11th July 2009 webhosting? So the capacity is reduced now? 

8.	Why the capacity, title and DOE changed now, except the consultant?

9.	In the earlier web-hosted PDD, Project IRR is 9.17% against Benchmark of 13.30% (CAPM model) for Premier Cotton Textiles and for Sree Narasimha Textiles Pvt Ltd the Project IRR is 7.77% against Benchmark of 13.30% (CAPM model). But now (i.e., in the latest web hosting) Project IRR is 9.16% against Benchmark of 14.20% (CAPM model) for Premier Cotton Textiles and for Sree Narasimha Textiles Pvt Ltd the Project IRR is 7.41% against Benchmark of 14.29% (CAPM model). Why?

10.	Even with CDM benefits these projects will never cross Benchmark. Then why the PP is investing in such kind of projects (I don’t expect an answer telling environmental friendly, less GHG, pls. give a valid explanation). This is clearly to make Mockery of CDM and Kyoto protocol.

11.	Most important point to note here is, the PP is running these windmills from 2004 till date i.e., exactly 7 years without any shut down. 

•	So then why the HELL he want’s CDM money? 
•	If so many financial barriers were present, first of all why did he invest?
•	Ok, if we agree that the PP saw CDM money and invested, but when the project was rejected by UNFCCC for the 1st time during 2009, they how the Windmills are running till date without PP being Bankrupt?
•	Has PP taken loan from others sources to run the project to get CDM money (which huge compare to other sources)?
•	How as the PP managed to Pay Consultant and DoE for two times (as per my knowledge the Consultation and Validation fee will not be less than 1 Million rupees for a single validation for a project of this scale)? Is the Consultant and DoE working for free?
•	I strongly demand an explanation from the PP/Consultant/DoE for these; they should not answer telling irrelevant to the project activity. As this is a serious issue, which requires a proper explanation. I once again request the EB to check how DoE justified and take further actions regarding this project during RFR.

12.	My last and the final question to the PP and consultant is if the project is rejected now, will they reduce the capacity (small scale), change the title and re-webhost with a new DOE (say SIRIM or PJR)? Because SIRIM and PJR are web-hosting only rejected projects taken up by General Carbon Advisory Services Pvt Ltd. General carbon please stop playing the games in the market. General carbon is an un-ethical company who ever working with GC is also unethical. GC should explain why they are working only on rejected and withdrawn projects. BVQI immediately stop working on these kind of projects.

1.	As per official website the project already implemented, when it was implemented please clarify.
2.	Why PP deleted the two entities from the project list, justify.
3.	Why the total capacity of the project has been reduced. What is the secret behind this, clarify.
4.	DOE has to check the Installation of WTGs between sept 2004 to 2006 is not consistent in both earlier and present webhosted PDD.
5.	PP and consultant has not taken serious CDM consideration and they are not proved adequately.
6.	PP has been failed in identification of baseline itself, DOE has to validate the proposed baseline.
7.	Chronology of events not described the board resolution and investment decision. DOE has to check.
8.	The debt-equity ratio not as per the wind power policy norms.
9.	Debt/Equity ratio should be based on recent investment done by the Project proponent. 
10.	Derating factor, array efficiency of the wind energy system is not depicted in the PDD. Pls. clarify. 
11.	Whether pre-tax or post tax IRR is selected is not demonstrated in the PDD.
12.	The calculation of project IRR is not as per “Guidance on the Assessment of Investment Analysis’ Version 03, EB 51, Annex 58”.
13.	The chronology of events shows that it has been pre-planned scenario between consultants PP.

This project is for captive consumption. PP can also seek REC credits and hence the project is non-additional. How can the DOE ensure that the PP does not seek REC credits in future after project registration?

The project was conceptualised way back in 2004. Why then now the PP is requiring CDM benefits. How did the project sustain all these 6 years without CDM??

How come the PP has considered the beta values of textile industries?? Beta risk should be similar to the project activity i.e. wind power generation. How equity beta has been calculated. A unlevered beta would be appropriate for calculations which is also conservative.

The PLF seems to be very low. Tamil nadu normally has a PLF of more than 30%. Also check the tariff order.

Page 21 mentions a D:E of 70:30 while the projects have used 80:20 for IRR computations??

When the project falls in tamilnadu and is governed by TNERC, how come MERC tariff order is referred for deration?? Did the third party report also mention on the deration?

1.	It is clear from authentic sources and public resources that Premier Mills is an experienced player in the wind power segment and had planned to set up a 47.85 MW wind farm in 2004 itself in Tirunelveli and Coimbatore districts of Tamil nadu.
http://wind-power.industry-focus.net/index.php/tamil-nadu-wind-power-projects/172-premier-mills-to-set-up-4785-mw-wind-power-project-at-tamil-nadu.html
2.	Previously the PP had applied for validation of the entire capacity split in to different PPs. The PDD was rejected at validation stage by the DoE.
3.	The investment board decision is the same for both the entire bundle of 47.85 MW. But this project is for a capacity of 24.75 MW only. For the remaining capacity, the PP has created another CDM project and submitted for validation for 14.85 MW capacity https://cdm.unfccc.int/Projects/Validation/DB/SSPNJ9BYJAJEJV22N2ZX4I4URQ7SXI/view.html
4.	Then what about the remaining 8.25 MW capacity?  Why is the PP not applying for CDM for this capacity? 
5.	What is significant in the PDD for 14.85 MW is that the PP categorically declares that the pre-project scenario used fuel oil and diesel for captive power requirement as early as from 2002 onwards. Before 2002 , the import from grid was done for captive consumption. As Fuel Oil prices increased, the FO was discontinued and PP opted for wind power.
6.	Thus the most conservative baseline scenario for premier mills group would be fuel oil or diesel as a captive power plant was existing before wind farm investment. 
7.	Also the PLF from third party indicates 28 % for the 47.85 project in the older PDD while in this PDD indicates 27.10 % for PCT and 25.70 % for Narasimha textiles? it is a case of cooking up the PLF document to pass CDM. Also this PDD states a transmission loss of 2 %?..the EB is requested to take from the DoE a proper justification as in Tamilnadu state the billing occurs in the Windmill yard itself and there is no loss?. Also the deration of 5 % per year after 10th year is not according to guidelines. It is a clear case of trying to make the generation less and proving additionality.
8.	The project cost is 5547 lakhs and 8610 lakhs for PCR and narasimha textiles based on actuals in the older PDD while the offer letter in the new PDD indicates 5970 lakhs and 9352 lakhs?
9.	Offer letter for the 14.85 MW project indicates a date of 27 th Dec 2004, while for this project it indicates 1 November 2004? If same investment decision is taken for entire bundle then why is the offer letters split up by the same supplier?  It is clearly a case of cooking up offer letters for sake of passing CDM projects. The previous rejection by the DoE was on stringent grounds, and the PP has conveniently packaged his earlier project in two different CDM projects with cooked up documents. The DoE is being made in to a fool and the biggest cheat is the General Carbon team, who collect such garbage from the market and put it as a neat package for validation.
10.	Regarding Benchmark and IRR, the previous PDD has lower benchmark for entire bundle (as investment date is same), while in this PDD two benchmarks on the higher side are calculated?. The DoE is being made in to a fool and their incompetence in validating such projects is the first criteria for the consultant selecting them.
11.	The host government approval letter has been falsified. How can a government issue a HGA for 48.75 MW project and the same reference be used for approval of 24.75MW?. the extent of fooling the DoE has gone beyond normal critera as no other DoE in the market would have taken up this project. The extent of general carbons lies can be seen that even Indian govt is not spared.

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.