It is evident from the PDD that the values are consistent and it is definitely forged and cooked up values to show a non CDM project as a CDM project. What is this? DoE to check the Detailed Project Report and Feasibility Report which is submitted to the other agencies and Banks by Project owner and ensure that the values match with the DPR/FR  submitted to DoE also. After careful study of PDD it is found that DPR/FR is in different versions made and submitted with different purposes to different agencies which is totally unacceptable, illegal and unethical. PP/Consultant may show some undertaking letter from bank manager to DoE stating that both DPR’s are same. These kinds of letters should not be accepted and entertained by DoE. While collecting the DPR/FR from banks and other agencies, all DPR/FR pages should be counter signed by Banks and other agencies so that the real DPR/FR given to other parties by the PP/Consultant is same as the one submitted to DOE. In this particular project there is clear cut evidence that DPR/FR values are changed/ fabricated mischievously and intentionally. This must be probed fully. DOE must take a written undertaking from the PP/Consultant about the list of parties to whom this DPR/FR is submitted and for what purposes. Then DOE should cross check with all the parties and confirm that the same DPR/FR is submitted to all the parties correctly without any changes. DOE must not accept any reports and undertakings from PP/Consultant. DOE must make independent evaluation and use totally different parties without informing the PP or Consultant to cross check the facts. DOE to write to the party who prepared the DPR/FR which is submitted to the banks and other agencies and the same is verified against the one submitted to the DOE by PP/Consultant. This project is a fabricated and fake CDM project and must be rejected by the DOE right away. DOE should not support this kind of projects otherwise CDM EB should suspend this DOE for at least one year. 

The PDD is comprehensive and the project is a welcome step towards inclusion of reforestation efforts of degraded areas of Amazon Basin under Clean Development Mechanism. After going through the Project Document, the following points need some clarification:
i) Crediting Period: Why is the crediting period taken as 17 years and not 20 years (renewal crediting period)? Has it been done deliberately to tweek the cumulative net removals by sink? 
ii) Preotected area within project boundary: Almost half of the area in each farm is  declared as a legally protected area to rejuvenate native vegetation. It has not been described how such a legally mandated protected area is in confirmation with the "Combined tool to identify the baseline scenario and demonstrate additionality in A/R CDM project activities". 
iii) Baseline Scenario: The baseline scenario has been identified as continuation of pre-project land-use (extensive cattle-ranching). So the tool for "Estimation of the increase in GHG emissions attributable to displacement of pre-project agricultural activities in A/R CDM project activity” must be applied. To avoid this, the PP states in Section D2: "grazing animals inside the project boundary were sold or slaughtered before project implementation". The PP needs to explain if it is a business-as-usual scenario in this region to slaughter livestock whenever a plantation activity is initiated on pastureland. If so, slaughtering of livestock itself will eliminate the principle reason behind deforestation and continued degradation.   
iii) Technology Barrier: The PP states that the project region "doesn’t have a tradition of planted forests", but lists at least 18 plantation companies operating in the region, which is contradictory
iv) Barriers due to local tradition: The PP mentions that "the project area belongs to the Arc of Deforestation, historically it has a strong “tradition” of illegal predatory loggings that leaves no space for renewable plantations." But it does not specify whether the "tradition" is followed by local populace and the socio-economic reasons behind the same. In Section A.5.4 the PP plans to put up a 24 hrs vigilance system. The PP is silent as to how this will disrupt the "tradition" and how it will address any potential conflict arising out of it.
v) The project proponent has not considered charcoal as a potential revenue source during calculation of Equity IRR although it is a very common end use of timber in Brazil. 
vii) The PP has also not justified the choice of Eucalyptus over pine although Pine has a better NPV than Eucalyptus
vi) The PP has not dwelt with the potential negative effects of large scale monoculture plantations of Eucalyptus. Is Eucayptus plantations common in the project area so as to justify the species choice? If yes,how does the project prove additonality. If not, how does the PP demonstrate credibly that the effects of monoculture do not outweigh the benefits of sequestration.

Regards
ABhirup Sen