Renewable Energy Wind Power Project in Karnataka
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Host party(ies) India
Methodology(ies) AMS-I.D. ver. 16
Standardised Baselines N/A
Estimated annual reductions* 12,335
Start date of first crediting period. 01 May 11
Length of first crediting period. 10 years
DOE/AE SGS-UKL
Period for comments 31 Dec 10 - 29 Jan 11
PP(s) for which DOE have a contractual obligation Vish Wind Infrastructure LLP
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 (668 KB)
Local stakeholder consultation report: N/A
Impact assessment summary: N/A
Submission of comments to the DOE/AE Compilation of submitted inputs:
There are no details on the construction of the benchmark and its components. How can a DOE webhost such an incomplete PDD for global stakeholder consultation? How can a stakeholder comment on such case?

The logic of considering a tariff rate of INR 2/kWh after 10 years is absurd. Everyone is well aware that there cannot be a decrease in the tariff rate rather an increase year on year even after the defined tariff period in the tariff order. Can you support with past cases where one has got a tariff rate of INR 2/kWh or near to this figure??

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.

Please also check the offer from WTG supplier and Purchase Order while validating the PLF. It may be so that the third party report may indicate a lower PLF.

Stakeholder consultation:
The project WTGs are located at the Village: Kalasapur, District: Gadag, State: Karnataka. However the Stakeholder consultation was conducted at Hubli city which is more than 70 kms from the WTG site. 
The most important stakeholders are the farmers and the nearby residents. How did the PP ensure that these low income people (farmer, villager and nearby residents) also participated in the meeting?? Though the panchayat members were present they can afford to travel to Hubli to attend. As such they are regular travellers to Hubli for administrative purposes. However, the low income farmers and villagers and nearby residents cannot travel so far. Was the meeting deliberately conducted at a far off place so that presence of these stakeholders could have been avoided??

How could a nearby farmer leave his daily work and travel for more than 5 hours to attend the meeting?
Interestingly the PP was not present at the meeting. How did the PP ensure that right message was given to the stakeholders in PPs absence?
PP is requested to re schedule the stakeholder meeting nearby the project site and re-webhost the PDD.


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