Sub: Comments for biomass based Amreli Power Plant requesting for CDM Registration.

Sir, 

We have reviewed non technical summary of above mentioned project. Following are our comments/suggestions/observations regarding project.

1.	Whether plant is in operation or not? If yes from which date it is in operation?
2.	Whether necessary permission from GEB, Gram Panchayat and GPCB are obtained or applied for?
3.	How biomass supply will be assured for running every day plant? What will be the system of collection and transport of biomass from source?
4.	What is the method of compensation for biomass bought for running power plant?
5.	Whether permission for use of ground water has been obtained from Central Ground Water board? Please attach copy of it.
6.	Please explain distribution system of power generated from the plant.
7.	Whether EIA Notification 2006 applied to this plant or not?
8.	Whether public consultation under CDM project is carried out by company or consultant or government?
9.	Whether state government departments are aware of this public consultation?
10.	How many people will be beneficiated from this plant directly and indirectly?
11.	How many local people will get direct employment in this plant?
12.	Whether revenue earned from carbon trading will be used for socio economic development of the area? 
13.	Which type of commitment would company make for socio economic development of area?
14.	Form a women co-operative society for collection of bio mass. So women get involved in your work and empowered.

Yours truly,


Mahesh Pandya
Paryavaran Mitra
Thaltej, Ahmedabad
 

How does the project proponent justify that it is FIRST OF A KIND? This may be not be true. The project of 10 MW power plant with bio-mass as fuel and TG is a standard configuration by manufacturers like THERMAX and hence can not claim to be first of a kind. DOE must make efforts to understand and then justify if it is so.

DOE need to understand and justify as to why the project proponent has not given a thought to gassification route for power generation which is most efficient and cost effective as compared to thermal route. 

Further, the availability and sustainability of the fuel is a major concern which is not very clearly stated and demonstrated in the PDD. this needs to be further evidenced by PP and to be confirmed by DOE. Otherwise the sustainability of this project may be a question

The project proponent has not very clearly stated if ESP [Electro Static Precipitator] would be part of the equipment right from the beginning. There is a mention that PROVISION FOR ESP would be made in the equipment. This needs to be clarified and mentioned clearly in the PDD and the DOE must ensure that ESP must be part of the equipment. Otherwise the dust emission would be hazardous for the local population.