Submission of comments to the DOE/AE
Compilation of submitted inputs:
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 Big 4 firm has done till to date? This Big 4 firm is responsible for corrupting and spoiling the whole CDM business in India. Why this Big 4 firm not working like any other consultant in the market? Why is it web hosting projects which should be rejected, with drawn, forged (documents changed and forged) and fully problematic projects?
The Partner of this Big 4 firm is fully responsible for spoiling the CDM business in India. He is totally unprofessional and unethical. He never did any work in a professional and ethical manner in his working. This Big 4 firm should not work with any PP in the market.
Every project owner and DOE whoever is working with this Partner of Big 4 firm should introspect, understand the implications and stop working with this audit firm. They use the audit practise to force clients to take their CDM services. Their audit team is built on totally wrong foundation with robbed clients allowed wrong doing and cheated the system, deceived the country. One should be ashamed of working with this Audit firm in what so ever manner. He spoiled old DOE’s and recommends clients to bribe the DOE auditors and others in the system.
Every new and old DOE entered in the market was misused by the Partner. 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 the parent auditing company, on these points and take appropriate actions to save the project owners and CDM business fraternity from this Partner and evil company. Never believe the documents given by this audit company, DOE must cross check all of them as they are the forgery masters.
DOE to be careful in undertaking any jobs referred by this kind of Big 4 firm, instead they should not take up the job at all in the best interest of CDM business and to protect their interests and reputation.
Submitted by: Kushwanth Sing
Other alternative technologies viz diesel, FO cannot be ruled out for further consideration just because they are of smaller capacities. Since meth states that ‘number of small units’ can be clubbed together to compare with the project activity capacity.
• Further argument that non availability of natural gas in TN is not acceptable, as no of natural gas based projects have come up much even before this project activity is envisaged. This needs to be checked by the DOE.
• Source of PLF considered for project activity needs to be checked, as the super critical technology bound to have higher PLF. It attains significance as 10% increase in PLF for the project activity almost equals the levelised cost of the baseline plant.
• Financial comparison with the baseline plant also needs to be checked as source of the ‘assumed values’ is not evident in the PDD.
• In India, according to publically available reports of manufacturers of boiler units 660 MW units are only available with supercritical and ultra-supercritical technology, adding up to precisely 1320 MW for 2 units are used. In this context initial plan itself is implementation of supercritical power plant so the selection of sub-critical as baseline is not correct. Pls. clarify.
• Why PP not documented the technical specifications of boiler, turbine and balance of plant which is the requirements of CDM requirements.
• DOE has to validate the tender document and proposal by submitted by the PP for the project which will reveal truth whether subcritical system was proposed initially and later changed to supercritical system due to environmental benefits of the latter.
• Traditionally, for a larger project like this, Government will allow investors 10% of power to sell to private parties (i.e Merchant sale). But PDD does not speak about this aspect. How DOE will ascertain this merchant power in the addtionality argument claimed by PP. What is the contract agreement between the concerned parties? It may be available in the tender document which DOE should validate. PP conveniently suppresses the facts.
• PP fails to demonstrate how sub critical system has been considered as only realistic alternative in the PDD. It seems from the hindsight that PP decided to take subcritical as baseline and arrived at the plausible alternatives thereby leaving conveniently other renewable energy sources. PDD does not speak about whether the project is required for peak load or for base load. Only tender document will tell the fact. It is not clearly stated that why NG based system which is comparable to subcritical or supercritical system left out of the baseline. The reason for leaving NG system is not correct. When Jaypee and its subsidiaries have successfully implemented many hydro projects in larger capacities, why renewable energy sources are left out. PP has to clarify and DOE to check the argument.
• Why the date of investment decision and chronology of events are not 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.
• Supercritical plants are expected to provide long-term economic benefits by reducing variable costs by 10% as per Government body ruling during 2007 even though raising upfront construction costs by 10 to 15 percent. Kindly clarify in the PDD.
• Variation of parameters should be done only for the proposed project and not for baseline project. The sensitivity analysis of the PP is absolutely absurd. If it is done only for proposed project, the Levelised cost of the proposed proejct goes below that of baseline levelised cost. So the project is not additional. DOE has to validate carefully.
• The investment analysis is neither transparent nor reproducible and therefore does not support the selection of subcritical coal-fired power plants as the Project’s baseline. Furthermore, project participants fail to include required elements under ACM0013, such as calculation of the levelized cost of electricity and the tariff rate used to calculate the Project’s internal rate of return.
• Supercritical PP has been proved less attractive than other alternatives. But addtionality is based on whether the proposed project is not viable without CDM revenue. This aspect is not argued at all. How DOE has allowed this. Pls. clarify.
• As per methodology ACM 13, the investment analysis should be presented in a transparent manner and all the relevant assumptions should be provided in the CDM-PDD, so that a reader can reproduce the analysis and obtain the same results. Critical techno-economic parameters and assumptions (such as capital costs, fuel price projections, lifetimes, the load factor of the power plant and discount rate or cost of capital) should be clearly presented. Justify and/or cite assumptions in a manner that can be validated by the DOE. In calculating the financial indicator, the risks of the alternatives can be included through the cash flow pattern, subject to project specific expectations and assumptions (e.g. insurance premiums can be used in the calculation to reflect specific risk equivalents). Where assumptions, input data, and data sources for the investment analysis differ across the project activity and its alternatives, differences should be well substantiated. The CDM-PDD submitted for validation shall present a clear comparison of the financial indicator for all scenario alternatives. The baseline scenario alternative that has the best indicator (e.g. the highest IRR) can be pre-selected as the most plausible baseline scenario”. But PDD does not include this aspect.
• While PP argument that not many supercritical PP available that is operational in India, they seem to hide the fact that the majority of new coalfired power plants are expected to use this technology. News reports suggest that at least 35 supercritical plants, in addition to the proposed Project, are at various stages of planning and implementation in India. The PP may argue at the later stages that based on project information listed on the CDM website to argue that all other supercritical coal plants( may be 4 or 5 ) are in CDM development. DOE has to validate
• . PP fail to include all required information like CO2 emisisons, Coal consumed of similar coal-fired power plants in India. This information is needed to verify the emission reduction calculations claimed by PP.
• Section B.6.2 mentions of IPCC value for sub-bituminous coal. Justification is needed why it is taking this value, when national data is publicly available.
• Method of Monitoring of coal consumed is not explicitly stated. Moisture loss, carpet loss should be monitored
• The PDD fails to fully demonstrate amount of ash that will be generated, utilized, and disposed. Although Indian coal may have fewer heavy metals than coal from other areas, fly ash can still be hazardous and still contain heavy metals. Dry storage of ash would be better than wet storage for utilization purposes.
• 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
Submitted by: thomas
Comment (426 KB)
Submitted by: Ben Pearson
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