Applicability of the methodology: 
Project is not applicable under ACM0013 version 4.
Seem, LRQA must be very happy to take these kind projects irrespective of availability of competency. You could have just gone through the meth once while proceeding.
Para 4 of the ACM0013 version 4 demands “data on the fuel consumption of recently constructed power plants are available”. L&T, LRQA and their consultants seem ignorant and least bothered to fulfill the requirements under ACM0013 version 4. But what is surprising is that the DOE (LRQA) has not bothered to even look whether the project is applicable for this methodology or not. On one hand UNFCCC is breaking their heads to ensure that the standards of DOE are met, and other hand DOEs like you are diluting the complete concept. As a layman I am able to understand what is written in black and white under ACM0013, why can’t LRQA understand this??
ACM0013 version 4 page 11 under FCjx and FCnv under the row of “any comment” it clearly states that the “The DOE should verify that the data on fuel consumption is based on first-hand measurements of the actual quantity of fuel consumed by each power plant, and is not based on second-hand calculations or estimations”. Do the client or the DOE even understand the implications and requirement of this special addition in version 4? The meaning of this statement is that you cannot arrive/estimate/compute the fuel consumption. It has to be through direct measurement of actual quantity of the respective units and not the entire power plant. Having known the fact that none of the baseline plants (NTPC, CEA, CERC) measure/monitor the fuel consumption at unit level. At least the operation station heat rates are also not available publicly.
Why has LRQA not asked a deviation/clarifications/revision before web-hosting even if the requirements of the methodology are publicly displayed. This displays sheer incompetency of the DOE. Hence I would like to state the project is not applicable under this methodology. Though it is proven now that the project is not applicable under this methodology, I hope LQRA does not proceed with the validation; ignoring my comments. But be warned that CDM EB and members are very well aware of the Indian scenario.

Where is the IRR computation of the project. NGOs are shouting on PPs to carry out IRRs, but how can you do LUC for additionality determination. Don’t you know that increase in project cost alone will increase the LUC of super critical when compared to sub critical. In that case definitely project would be additional in LUE computation. But CDM is not meant for that. LRQA should ensure the financial viability of the project by computing IRR. This is only possible if the above condition is in compliance.


Ramesh Gupta
CC Cell, Gurgaon

Link 1:
http://www.cdm-watch.org/wordpress/wp-content/uploads/2010/03/annex1_comments_on_acm0013.pdf   

Link 2:
http://www.google.co.in/url?sa=t&source=web&cd=4&ved=0CCYQFjAD&url=http%3A%2F%2Fwww.cdm-watch.org%2Fwordpress%2Fwp-content%2Fuploads%2F2010%2F03%2Fannex1_comments_on_acm0013.pdf&rct=j&q=EGWBRZLZJPSAY9YSFZSCPR20C19LB9%2F&ei=SCWMTfjeBc7trQfnqJTQDQ&usg=AFQjCNFYHjQf79qlad02tvOYDURycq7_Pg&cad=rja 


If any one of the above links not open, please get in touch with me @ jhonson806@gmail.com