Reduction in Greenhouse Gas emissions through replacement of Fuel Oil with Natural Gas in refinery furnace operations at Essar Oil Ltd.
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Host party(ies) India
Methodology(ies) AMS-III.AH.
Standardised Baselines N/A
Estimated annual reductions* 51,186
Start date of first crediting period. 01 Mar 12
Length of first crediting period. 10 years
DOE/AE TÜV NORD CERT GmbH
Period for comments 10 Nov 11 - 09 Dec 11
PP(s) for which DOE have a contractual obligation Essar Oil Limited
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 (1272 KB)
Local stakeholder consultation report: N/A
Impact assessment summary: N/A
Submission of comments to the DOE/AE Compilation of submitted inputs: 
PP has conducted NPV and shows a negative NPV for project. DOE to analyse whether the pre-project scenarios NPV is also negative. It may be so that all options have a negative NPV and still the PP wants to show the project as additional.

No comparison of NPV with the baseline scenario.

The O&M expenses for NG based system will be far more lesser as compared to FO based system.

How will the PP ensure the availability of NG for the operational lifetime of project.

The project is not clear as to how much NG will be consumed and whether the fossil fuels will still be fired along with the NG. Is it a complete replacement or partial replacement.

If the NG is being imported the cost of import and the escalation based on international prices should be considered rather than the domestic price trend.
Submitted by: Babloo 
Gujarat fourm on CDM respectfully submit the following comments on the Project Design Documnt (PDD) Reduction in Greenhouse Gas emissions through replacement of Fuel Oil with Natural Gas in refinery furnace operations at Essar Oil Ltd. We thank the CDM Executive Board and Designated Operation Entity (DOE) for recognizing the integral role of transparency in CDM Validation process, and for taking this comment into consideration.
The project is not appropriate for the following points



o	The investment analysis is incomplete and fails to provide the data and assumptions necessary for reader to reproduce the result.

o	No information has been provided regarding the cost of fuel switch, and the distance of the source is and mode of transportation.

o	No information has been provided regarding the cost of fuel switch in the PDD?


o	Descriptions of the stakeholder meeting are not provided adequately. No information has been provided regarding the Number of persons attended the meeting, issues raised during the consultation and where the stakeholder consultation was conducted etc.


o	In India there is huge shortage of Natural Gas especially the irregular and interrupted supply of the Gas. At the same time the project proposed to use Natural gas which would further aggravated the problem. In that case the present user of the natural gas would be forced to switch to the alternative such as fossil fuel and ultimately the GHG would be released. 


o	No commitment has been shown towards achieving the sustainable development goals.

Gujarat Fourm on CDM
Email: gujartfourmoncdm@gmail.com
Submitted by: Gujarat Forum on CDM

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