6 MW Wind Power Project (WPP) at Davangere, Karnataka, India.
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Host party(ies) India
Methodology(ies) AMS-I.D. ver. 16
Standardised Baselines N/A
Estimated annual reductions* 13,091
Start date of first crediting period. 01 Oct 11
Length of first crediting period. 10 years
DOE/AE LRQA Ltd
Period for comments 11 Feb 11 - 12 Mar 11
PP(s) for which DOE have a contractual obligation PTC India Financial Services Ltd.
The operational/applicant entity working on this project has decided to make the Project Design Document (PDD) publicly available directly on the UNFCCC CDM website.
PDD PDD (566 KB)
Local stakeholder consultation report: N/A
Impact assessment summary: N/A
Submission of comments to the DOE/AE Compilation of submitted inputs:
Purpose of the project and how the proposed project activity reduces greenhouse gas emissions are not briefed in the PDD. Refer section A.1.
•	How environmentally safe and sound technology is used for the project and details of technology transfer is not demonstrated adequately. Refer A.4.2
•	Non- debundling nature of the project activity is not adequately justified as per EB54 Annex 13 (Debundling tool). Refer A.4.5
•	Why has option A (Combined margin) been chosen for calculating emission factor is not justified. Refer B.6
•	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.
•	All the issues of investment analysis guidelines are not discussed in the PDD. Refer B.5. 
•	Justification of parameters including O&M, insurance, loan, derating, escalation, and tariff are not demonstrated with justification. Refer B.5.
•	Please provide a proof for proposed debt to equity taken at the investment decision. Refer B.5 
•	Proof for PLF is not justified. 
•	Date of offer is not provided  
•	IT rate assumed is not as per standard practice. 
•	CER revenue assumed is not consistently applied 
•	The selection of simple OM based on low cost/must run resources is not adequately justified. Refer B.6.1
•	Ex-ante option of calculating OM is not adequately demonstrated. Step 3 of Refer B.6.1
•	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
•	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
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Submitted by: mathew

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.

Check the offer from WTG supplier and Purchase Order while validating the 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 choseen irr? 

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


The comment period is over.
* Emission reductions in metric tonnes of CO2 equivalent per annum that are based on the estimates provided by the project participants in unvalidated PDDs