PDD states, “The Difference between the manufacturing cost of fly ash bricks and selling price of clay bricks lies in the range of INR 0.16 to INR 0.67 per bricks and blocks”. How is this figure arrived at? Why the input parameters and assumptions supporting the calculations are not given? 

PDD also states, “The CDM revenue for the bricks estimated in the in the range of 0.13 to 1.25INR depending upon the technology used in the baseline be used for market development and the meeting the price competition with the clay bricks, thus alleviating the barrier”. How is this magic figure of 0.13 to 1.25 arrived at? 

Can the reader reproduce the input parameter and assumptions and arrive at the same result as required by CDM methodology? How did the DOE web host this project without even looking at whether it conforms to CDM requirements or not?

Moreover, PP/Consultant should be aware of the financial indicators recommended by Additionality Tool. Whether the ‘Difference between the manufacturing cost of fly ash bricks and selling price of clay bricks” conform to any of the financial indicators accepted by EB? It is neither benchmark analysis nor investment comparison analysis. If the PP/consultant is attempting to prove additionality through investment comparison analysis it is incorrect as per guidance 19 of Annex 5, EB 62 as there is no compulsion for PP to produce fly ash bricks. Hence only benchmark analysis should be used. Is the PP/Consultant aware of the return on fly ash bricks? It is very high. How is the PP/consultant trying to prove the project is additional? 

How are the barriers given under technological barrier is in line with the barriers given in Attachment A to Appendix B and Annex 13, EB 50? 

This PDD hides information and the project will become non- additional, if benchmark analysis is adopted. It is for this reason that the PDD hides information. DOE should not take up this project for validation unless it is re-web hosted conforming to the requirements of disclosing all input parameters and assumptions and choosing the appropriate investment analysis as per Guidance.