Wind based power project in Maharashtra by Siddhayu Ayurvedic Research Foundation Pvt. Ltd.
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Host party(ies) India
Methodology(ies) AMS-I.D. ver. 16
Standardised Baselines N/A
Estimated annual reductions* 21,807
Start date of first crediting period. 01 Jan 12
Length of first crediting period. 10 years
DOE/AE SGS-UKL
Period for comments 17 Feb 11 - 18 Mar 11
PP(s) for which DOE have a contractual obligation Siddhayu Ayurvedic Research Foundation Pvt. Ltd.
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 (621 KB)
Local stakeholder consultation report: N/A
Impact assessment summary: N/A
Submission of comments to the DOE/AE Compilation of submitted inputs:
Plz see the link below:
http://www.mahaurja.com/PDF/Windy%20sites%20in%20MAH.PDF
A report Published by Mahaurja mentions that the Wind power density at Chakala @ hub height 50 m is 323w/m2. As per MERC tariff order 2010, PG.29, If wind power density at 50m falls in between 300-400w/m2, a PLF of 27% to be used. 
In the above context Plz explain the PLF chosen as only 21%. The source of PLF mentioned in the PDD is DPR. DOE to check whether the same DPR was submitted to the bank/financial institute/government approval or not. 
PP to should circulate same DPR to banks and for Govt. approvals (like approval from MEDA)
DOE to verify this by conducting a meeting with loan provider institutions and MEDA officials.
Many wind PDDs are providing wrong PLF information and are justifying the PLF with the help of fake third party reports/fake DPRs (which are not actually submitted to banks/government).
I request DOE to consider my suggestion and provide me with the reply in detail on how this comment was closed. 
Mahaurja report should not be overlooked as its the most authentic data provider (over the PP's DPR also which may be submitted to bank).

 
Submitted by: Stacy Johnson

Purpose of the project and how the proposed project activity reduces greenhouse gas emissions are not briefed in the PDD. Refer section A.2.
•	How environmentally safe and sound technology is used for the project and details of technology transfer is not demonstrated adequately. Refer A.4.2
•	Non- debundling nature of the project activity is not adequately justified as per EB54 Annex 13 (Debundling tool). Refer A.4.5
•	Why has option A (Combined margin) been chosen for calculating emission factor is not justified. Refer B.6
•	The justification of choosing IRR as financial indicator is not adequately justified. Whether it is equity or project IRR, pre-tax or post tax is not mentioned in the PDD.  
•	All the issues of investment analysis guidelines are not discussed in the PDD. Refer B.5. 
•	Justification of parameters including O&M, insurance, loan, derating, escalation, and tariff are not demonstrated with justification. Refer B.5.
•	Please provide a proof for proposed debt to equity taken at the investment decision. Refer B.5
•	Interest rate of 11..5% assumed is not adequately justified. 
•	Proof for PLF is not justified. 
•	Date of offer is not provided  
•	Ex-ante option of calculating OM is not adequately demonstrated. Step 3 of Refer B.6.1
•	Power plants registered as CDM project activities should be included in the sample group that is used to calculate the operating margin if the criteria for including the power source in the sample group apply. This argument is not demonstrated. B.6.1
Submitted by: jindal

Why did the ayurvedic research organisation invest in wind power? 

Is this project is for captive consumption. PP can also seek REC credits and hence the project is non-additional. How can the DOE ensure that the PP does not seek REC credits in future after project registration?

Why loan processing charges are included as project cost? Guidlines say that any processing fee for acquiring debt should not be considered as expense.

The benchmark of more than 18% is too high. With such a high benchmark the project will also not be feasible even with CDM revenue. Then why the hell the PP is investing in such a loss making project?? PP to tell this! DOE to submit a negative validation opinion if the CDM revenues does not make project viable financially i.e. crosses the benchmark.

The PLF seems to be very low. Also check the tariff order.

The PP states that they have considered 80% accelerated depreciation. However the PDD is silent on the tax shielding as a result from accelerated depreciation.
PPs cleverly do not consider the accounting tax offsetting in their companies while calculating the IRR. This is evident from the recently registered projects and those requesting registration.  
The DOE is therefore requested to critically analyze how the accelerated depreciation benefit has been taken into account and confirm the accounting of the cash inflows as a result of the negative tax liability in the initial years. DOE should not be misguided by the financial presented by the PP or consultant which are custom made for CDM purposes and not the actual financial considered at the investment decision.
Note that considering cash inflows results in an increase in the IRR making wind projects a profitable venture.
Submitted by: Babloo


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