Greenhouse Gas Emission Reductions Through Thermal Solar Power Technology - Rajasthan Sun Technique Energy Private Limited
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Host party(ies) India
Methodology(ies) ACM0002 ver. 12
Standardised Baselines N/A
Estimated annual reductions* 266,169
Start date of first crediting period. 07 May 13
Length of first crediting period. 10 years
DOE/AE T‹V NORD CERT GmbH
Period for comments 10 May 11 - 08 Jun 11
PP(s) for which DOE have a contractual obligation Rajasthan Sun Technique Energy Private Limited
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 (649 KB)
Local stakeholder consultation report: N/A
Impact assessment summary: N/A
Submission of comments to the DOE/AE Compilation of submitted inputs:
Hello!

Thus you would like to prove anything by any ways.

Have you done prior consideration communication with what name ? Is this the same name? You didn't mentioned capacity in the prior consideration as well as PDD.

If you are carrying out this project for 100 MW as per bid requirement than why are you hiding the capacity? it has not mentioned anything within the specs? If the PLF considered over here is based on 100 MW it is showing higher value than CERC considered PLF.

DOE should validate it properly. As bid condition did not allowed more than 100 MW capacity i.e. each bidder will receive maximum 100 MW only.

On what basis PP considered LCEP as an indicator instead of IRR? LCEP do not represents the viability of the project.

If this project is not viable to PP why PP has not considered other options like wind, biomass, coal based power plant, gas based power plant etc.

In this bidding scheme others have quoted lower tariff however their projects becoming viable while this project not why? 

In case of non-viability of project why PP has not bidded higher tariff insted of CDM benefit.

DOE should validate this project thoroughly.







Submitted by: Javid

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 DPRís 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. 
Submitted by: zhong zhou li

Following are the doubts on additionality:

- this is not the first of its kind project, before this another developer has already planned to undertake a solar thermal project of sizable capacity before this, which is already at a much lower tariff than this, further technology risk cannot be accepted, since all technology are equal considering the risk/cost/benefits.

- are they not taking any performance guarantee from the EPC contractor, in order to mitigate the risks of first of its kind? How this can be explained considering that the company building the plant is already highly qualified for undertaking these jobs?

- the project was won in a competitive bidding along with 6 other projects won by other developers, how a competitive bidding won project can qualify for CDM?

- There is other project developer who even quoted lower than this project, its is worth to note that CDM has already been mentioned in the qualifying criteria for these projects under JNSSM, so no argument can be accepted that the competitive bid included consideration of CDM, its already inbuilt in the system, which considers CDM as incentive rather than a financial support, even the declared tariff considers reasonable returns, therefore when the company has bidded for such low tariff, just to meet some obligation or strategic move cannot be considered as a CDM project.

- not much details on the technology to be used in the project has been explained, how a plant with PLF of around 20-23% can generate CERs counting 266.169

- Can DOE provide a proof that before starting the webhosting of the project they received the final CER as well as Financial Calculation sheet?
Submitted by: Sonika

Dear Sir,

I give below my comments on the project:

1.It should be possible from the information given in the PDD for anybody to compute the financial indicator and arrive at the same results. The information given in the PDD is grossly inadequate to calculate the financial indicator. Even the installed capacity and PLF are not given. How did DOE allow such PDD to be webhosted?

2.The financial indicator given cannot be relied upon. The PDD should be re-webhosted with all relevant information required to calculate the financial indicator. Correcting the mistake during validation is not acceptable

3.Why should this project require 27 months for installation? Are you going to wait for the entire project to be completed before commissioning? 

4.DOE should go through the bid document carefully and see what are the terms of allotment of the project. 

5.Why should the auxiliary consumption be 10%? Why should this project require auxiliary consumption? DOE should examine this aspect carefully

6. Project proponent is very modest! He is projecting O&M cost at  INR 1.37/MW. What is this?

7.DOE should check the award of contract and PPA signed by the project developer to see whether 60 days receivables is required

8.How can you use investment comparison analysis and LCEP as financial indicator for this project? Have you read guidance 19 of Annex 13 of EB 61? 

9.On what basis you are stating that there are no thermal solar power project operational in the country? This is not correct.  

Yours sincerely
Karthikeyan
Submitted by: Karthikeyan


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