Dear DOE,
Salam. Please do not try to make these kinds of projects as CDM projects. If foreign CDM investors and local consultants try to bring bad projects in to CDM cycle, then genuine CDM projects will suffer as it happened in some countries already. Let us make CDM projects in Pakistan genuine, additional and qualify for CER issuance. We must not take the project to CDM cycle as an afterthought and just because we are likely to get some extra cash. This is not acceptable and hurts other projects in the pipeline.  In the interest of CDM business in Pakistan this project is withdrawn from the CDM process as it has no proper additionality, no proper base line established, no real & continuous action.  Start dates and project costs are also in doubt and DOE must not proceed further unless these things are clarified with the project owner. PDD is insufficient to comment anything for a genuine stake holder. PDD lacks full details and the validation cannot continue just by web hosting this kind of PDD.

It looks like from the PDD the start date of the project is tampered for sure. This must be verified and let the truth come out. The culprits of forgery and malpractices must be brought to book. Why DOE has taken up such a bad project? Is there any pressure on DOE or some cake offered to DOE? They DOE must terminate this project immediately. DOE to check the offer letters originals and get the same verified in writing from the OEM’s and submitted parties. Where is the OEM supplier agreement original? DOE to check for the same. Is it prepared later with date and amounts changed to suit the project workings? For sure yes. This is not acceptable. DOE to check all purchase orders originals with the receiver of purchase orders i.e. the supplier of equipment. This PO confirmation to the DOE must be in writing from a board level person of the equipment supplier to avoid any malpractices and forgery. Then DOE to check for the invoices dates, payment amounts and date of payments made with all original documents and reconfirm with the parties involved and the banks for the accuracy of amounts, dates and parties involved. Same analysis and due diligence work to be repeated for “Notice to Proceed” as written in the case of Purchase order as above. DOE to check all “Notice to Proceed” originals with the receiver of “Notice to Proceed” i.e. the supplier of equipment or Engineering Procurement & Construction Contractor. This “Notice to proceed” and EPC contract confirmation to the DOE must be in writing from a board level person of the equipment supplier and EPC contractor to avoid any malpractices and forgery. Then DOE to check for the invoices dates, payment amounts and date of payments made with all original documents and reconfirm with the parties involved and the banks for the accuracy of amounts, dates and parties involved. DOE to check OEM supplier agreements, EPC contractor agreements, “Notice to proceed” letters, and Invoices raised. I’m sure DOE will catch the malpractices happened in this project. All the parties involved in this matter must be brought to justice. DOE must not support this kind of forgeries and malpractices. DOE cannot afford to close their eyes to this kind of malpractices. 

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.