•	Chronology of events mentioned in the page no of 21 &22 is totally wrong. Why is it hiding intentionally the 2nd webhosting of the project by SGS during 10 oct 2008 to 8 Nov 2008.
•	It is totally unprofessional on the part of new DOE to the checking the chronology of events for the projects.
•	What due diligence the new DOE has done before taking for validation. What made them to take the project which was rejected by DOE twice?
•	New DOE has to check the issues of reports and DVR issued in the past by the other DOE before making a decision.
•	By taking these kind of projects for validation DOE are getting into situation where their obelize to close eyes for same major issues in the projects and clarify.
•	The new DOE to be careful in selecting the projects otherwise it will take consequences from CDM EB which happens in the DOE past.
•	Chronology of events to be checked fully by new DOE including reports and DVR.

	It is an old project dating back to 2005 and proper CDM Consideration may be ensured.

	It is understood from the PPD that 4 windmills for 1.25 MW and 2 windmills for 1.65 MW were installed. The PP may confirm whether the decision date for all windmills is the same or different. Different IRR tables for each windmills is requested in case the decision dates are different.

	The PP may confirm that the Profit After Tax has been taken as Inflow while calculating Post Tax Project IRR. This is not ascertainable in the absence of the IRR sheets and the supporting calculations.

	The Debt Equity ratio of 70:30 which taken from MERC was considered for calculation instead of taking the average debt equity ratio of the last 3 years balance sheet as recommended by the EB 51 para 11.
 
	Tithe PLF is adopted as per Regulatory commission. Instead, the CDM guidance should be followed while adopting.

	Since Post Tax Project IRR is calculated, it has to be ensured that comparable WACC is taken for comparison.

	. As per MERC guidance, escalation of tariff cost of 0.15 paise per year is adopted only till 13th year and from 14th year till the life span of the asset the tariff rate of 13th year should be considered. 

As per the earlier webhosted PDD in Oct 2008, the project IRR was 11.32% and the present PDD indicates 8.07 % IRR. How the investment planned in the same period and climate will vary?, it raises question whether it is cooked up to claim the CDM benefit. 
•	 The DOE needs to validate the variation in the IRR, especially when the PDD claims that ‘only due to prolonged delay in the earlier validation process the PP has terminated the contract (not due to any other factors)’.


•	The PDD states that with CDM revenue the project IRR value comes closure to the benchmark value (exact figure is purposely not revealed in the PDD) which means the CDM revenue is not helping to overcome the barrier envisaged by the PP. it needs to be noted that if the CDM revenue does not help to overcome the barrier then the project activity is not additional.
•	The revenue stream (tariff) is not subjected to sensitivity analysis
•	Why the Project cost varies in all the webhosted PDDs

•	DOE has to check the chronology of events.
•	The project feasibility is not adequately demonstrated by comparing the Project IRR with a bench mark. Justify.
•	In all web hosted PDDs the project cost, generation, CERs varies, justify. And new DOE has to check the parameters provided in the webhosted PDD.
•	For beta calculation PP taken the average of beta values of identified companies are not mentioned in the PDD.
•	Proof for PLF is not justified. 
•	Date of offer is not provided  
•	Project cost is not as per TNERC norms. Refer B.5.
•	O&M charges and its escalation is not as per TNERC norms. 
•	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
•	The DOE has to check the emission factor value (NEWNE) for calculating baseline emission is wrong. Refer B.6.3
•	Net electricity should be continuously monitored, hourly measured and at least monthly recorded. Refer B.7.1
•	Metering regulations as per CEA norms is not adequately followed in monitoring plan. Refer B.7.2
•	PDD does not clearly describe the stakeholders involved in Project or the information provided to them. The PDD mentions “identified stakeholders,” but does not detail which of these stakeholders actually participated in the process. The PDD does not describe the information provided to stakeholders with sufficient clarity, such as whether adverse environmental impacts were described along with the benefits that were mentioned.

As per the earlier webhosted PDD in Oct 2008, the project IRR was 11.32% and the present PDD indicates 8.07 % IRR. How the investment planned in the same period and climate will vary?, it raises question whether it is cooked up to claim the CDM benefit. 
•	 The DOE needs to validate the variation in the IRR, especially when the PDD claims that ‘only due to prolonged delay in the earlier validation process the PP has terminated the contract (not due to any other factors)’.


•	The PDD states that with CDM revenue the project IRR value comes closure to the benchmark value (exact figure is purposely not revealed in the PDD) which means the CDM revenue is not helping to overcome the barrier envisaged by the PP. it needs to be noted that if the CDM revenue does not help to overcome the barrier then the project activity is not additional.
•	The revenue stream (tariff) is not subjected to sensitivity analysis
•	Why the Project cost varies in all the webhosted PDDs