Rice Husk Based Cogeneration project in Haryana, India by Goel International Pvt. Ltd
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Host party(ies) India
Methodology(ies) AMS-I.C. ver. 18
Standardised Baselines N/A
Estimated annual reductions* 63,672
Start date of first crediting period. 01 Oct 11
Length of first crediting period. 10 years
DOE/AE SGS-UKL
Period for comments 13 Nov 10 - 12 Dec 10
PP(s) for which DOE have a contractual obligation Goel International 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 (398 KB)
Local stakeholder consultation report: N/A
Impact assessment summary: N/A
Submission of comments to the DOE/AE Compilation of submitted inputs:
Comment (26 KB) submitted by: Justin on behalf of 
In section  B -4  of  the PDD   cleary  explain that in the  pre  project  scenario pp had  dependent  on the  grid  power, more  over  that PDD is  not  transparent on which  fuel the pp was using in the preproject  scenario for  Steam requirement , AMS IC  ver -18 require  historic  data  to  be  used  for  arriving   at  the base line . DOE  to  verify  the rationale  of  coal based  cogen  as  base line  which  is  hypothetical  in nature .

DOE  to  confirm  whether coal  is  prelavent  practice in the  region  where the project  is installed  to assume  coal base  cogen as  baseline .

Investment  comparsion analysis for unit cost  is  used   for  demonstrating  additionality ,It  is  highly in approprite  to  used  Investement  comparision  when  grid  power  is  one  of the  alternative  ( In this  case  pre project  scenario) 
If  so  how  the cash outflow  on account  of the saving  from the grid  electricity is accounted .

The project need  to  demonstrate additionality  using  benchmark analysis  since  the alternative  is  grid  ( pre project also grid)

In a  sense the project  is  to  save  cost  for  the  operation   to  put  in cdm  frame  work  an  hypothetical  base line  scenario of  coal cogen is  implated   with  an  wrong  additionality  model , request  the DOE to  verify  the  applicability  of  base  line  coal  cogen and  the  additionality  claimed through  investement  comparision .
Submitted by: Sree

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