Submission of comments to the DOE/AE
Compilation of submitted inputs:
1) DOE to ensure that the PDD values are consistent and ensure that the CDM project is a genuine project.
2) 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.
3) Careful study must be done so that the DPR/FR is not in different versions made and submitted with different purposes to different agencies, which is totally unacceptable, illegal and unethical.
4) Project owner should 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 at face value, but must be checked independently. 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.
5) DPR/FR values 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.
6) 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.
7) DOE must not entertain this project any more if found the DPR/FR is tamprered with at any point in time. PP can not give different DPRís and FRís. They must submit only the one given to Banks and other agencies while obtaining loans and decision making time.
8) Has the PP considered the CDM revenues while envisaging the project? Without CDM the project was not viable, is it right? This project is having a debt component? Then how bankers or lenders gave the loan? Have the bankers or lenders considered the CDM revenues while agreeing to give loan to this projects? If not this project should be rejected right away by DOE by terminating the contract forthwith. If yes, where is the proof? What is the date of the evidence document from bank? Is this document printed now a days or earlier. DOE to independently check the same. If the document is available from Bank it must be checked from all angles so that it is genuine and not forged and date changed by putting back dated. This is normally done, DOE to be aware of this please. Please check the communication the PP had during that time with banks, emails and postal receipts and the weights and dates mentioned on the receipts. Do not believe in courier bills and receipts since these can be cooked up easily. Insist on government owned postal service receipts only. If the project is fully equity project then on what basis the PP has invested full equity in to the project while considering the CDM revenue? DOE to check the same in detail and bring out the facts. Is there any past record of this PP to invest or not to invest at returns what he is talking about in this project? Proper evidences must be reviewed and digged out by the DOE and take decision on the project based on established facts. Do not ask documents from PP, DOE to collect the same from different sources to do independent evaluation.
9) Is the project equipment purchased second hand equipment or sourced from cheap foreign sources? If yes, the issue must be probed by DOE since invoices will invariably be inflated and forged. Total project costs mentioned by PP will not be the same as originals. Hence no additionality. These facts must be probed in full by DOE by checking all documents and money transactions along with bank statements and certified accounts by a legally acceptable financial analyst.
10) From DOE side which auditor has done marketing and business development for acquiring this business of validating this project? With whom he or she was co-ordinating at PP or CER buyer? The same person who has done the marketing and business development to acquire the business do validation or participate in any manner what so ever in the validation process? One cannot do like that. It is against the accreditation rules and norms followed since ages. DOE should send auditors from different offices or countries to do this validation audit. DOE must take care of impartiality and accreditation rules. Due to the targets set by the DOE managements auditors are doing marketing and meeting clients and giving promises that the project will be taken care. Is it acceptable and fair? This must be stopped. No auditor should do marketing. Only non-auditing staff should do marketing. DOE to ensure the same please.
11) If applicable only: Is these machines, equipment was a part of any bundle of CDM activity envisaged and developed earlier. DOE to check the same through independent sources also. Once some bundles are non-additional and getting negative validation from a DOE, PP is rolling out the same project as an individual project which is not a CDM project at all. DOE to verify the same from independent sources and also take undertaking in the form of an affidavit from the PPís that any misrepresentation or false statement with respect this would attract strict legal action from UNFCCC and DOE. Furthermore the registered project must be de-registered in case of any future findings contradicting the submissions made by the project owner.
12) DOE to be more careful so that this is a genuine CDM project. What is the exact project cost? The project cost is covering what? Each value considered must be validated with proof. The machinery is second hand purchased or fresh and new from an OEM? In either case DOE to check all the quotations, proposals, purchase orders, invoices, way bills, transport bills, proof of payments like bank statements. DOE to check with banks by way of written confirmation the amount transacted, to whom the money is paid, when the money is paid, is the party paid is the correct party as shown in the purchase orders. It may so happen that the values, party names, dates are fabricated and misrepresented in this project. DOE should terminate their contract for this project immediately. This is the only way out to protect the value of CDM process. If the PP is purchasing second hand or second quality equipment and inflating the purchase order values and invoices, this must be probed thoroughly and real values to taken for additionality calculation. Then Iím sure the additionality is not there at all in such a situation.
13) How is the base line defined in this project? Is Base line hypothetically defined with no proper evidences and proper justification? In such case, DOE cannot take the base line as suggested by the PDD. Please check that there are real emission reductions beyond the real and factual base line. It may so happen that this project qualifies for no CERís. DOE cannot assume values and things as giving by this PP. Whatever values are considered throughout the project in all documents including the real DPR (not the one prepared for CDM, the one given to the banks and others), they must be validated, verified and double checked. Do not ask PP for DPR. Ask the parties who have been given DPR by the PP. Get directly from the bank and others by each page of the DPR and Feasibility report signed. Such document can be considered as a real DPR or FR. UNFCCC CDM process cannot be degraded by fabricating and misinterpreting the project base line and additionality.
Submitted by: Benjamin franklin
1. Purpose of the project and how the proposed project activity reduces greenhouse gas emissions are not briefed in the PDD. Refer section A.2.
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
3. Non- debundling nature of the project activity is not adequately justified as per EB54 Annex 13 (Debundling tool). Refer A.4.5.
4. Please check the project boundary of the project activity is not based on the guidance of the applicable project category.
5. Why has option A (Combined margin) been chosen for calculating emission factor is not justified. Refer B.6
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.
7. The emission factor for the project electricity system can be calculated either for grid power plants only or, as an option, can include off-grid power plants.
8. Basis of choosing PLR as benchmark is not adequately demonstrated in the PDD
9. All the issues of investment analysis guidelines are not discussed in the PDD. Refer B.5.
10. Justification of parameters including O&M, insurance, loan, derating, escalation, and tariff are not demonstrated with justification. Refer B.5.
11. Please provide a proof for proposed debt to equity taken at the investment decision. Refer B.5
12. Proof for PLF is not justified.
13. Date of offer is not provided
14. Project cost is not as per state norms. Refer B.5.
15. O&M charges and its escalation is not as per norms
16. IT rate assumed is not as per standard practice.
17. The application of MAT which is based on tax holiday while calculating WACC is not appropriate.
18. The PP has not explained and justified the key assumptions and rationale.
19. The PP and consultant has not Illustrate in a transparent manner all data used to determine the baseline emissions.
20. Not demonstrated that the proposed project activity is additional as per options provided under attachment A to Appendix B of the simplified modalities and procedures for small-scale CDM project activities.
21. National policies and circumstances relevant to the baseline of the proposed project activity are not being summarized clarify.
22. Explain and justify all relevant methodological choices for the proposed project activity
23. Data that is calculated with equations provided in the approved category or default values specified in the category should not be included in the compilation.
24. CER revenue assumed is not consistently applied
25. Project cost is not as per norms, DOE has to check and clarify.
26. The project cost of the project should be based on offer and not on purchase order or tariff order.
27. O&M charges considered are on higher side. Pls. clarify.
28. Benchmark calculation is not as per WACC tool (EB53 Annex 8)
29. Whether pre-tax or post tax IRR is selected is not demonstrated in the PDD.
30. The basis of calculation of benchmark is not documented in the section B.5. PLR is not acceptable benchmark for the project. WACC based on Government bonds, risk premiums should be taken.
31. Prior consideration of CDM which is important for the determination of additionality is not documented in the section B.5 of the PDD.
32. Date of PPA is not mentioned in the prior consideration of CDM
33. The selection of simple OM based on low cost/must run resources is not adequately justified. Refer B.6.1
34. PP has not provided for each parameter the chosen value or, where relevant, the qualitative information.
35. Please Provide the actual value applied. Where time series of data is used, where several measurements are undertaken or where surveys have been conducted, provide detailed information.
36. Explain and justify the choice for the source of data.
37. Ex-ante option of calculating OM is not adequately demonstrated. Step 3 of Refer B.6.1
38. 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
39. The selection of option (out of two) for calculating OM is not adequately documented with justification. CEA calculation is based on net electricity generation, the average efficiency of each power unit and the fuel types used in each power unit. Step 4 of B.6.1
40. The argument that CEA data for build margin is calculated as per Emission factor tool is not documented. B.6.1
41. Spread sheet is not provided. The data should be presented in a manner that enables reproducing of the calculation of OM, BM, and CM.
42. The justification of negligible project emissions for wind project is not as per AMS. I. D ver 16.0 EB 54).
43. The emission factor value (Southern grid) for calculating baseline emission is wrong. Refer B.6.3
44. Net electricity should be continuously monitored, hourly measured and at least monthly recorded. Refer B.7.1
45. Metering regulations as per CEA norms is not adequately followed in monitoring plan. Refer B.7.2.
46. Where the values have been measured, include a description of the measurement methods and procedures that comply with the guidance provided under general guidance.
47. Provide a detailed description of the monitoring plan, including an identification of the data to be monitored and the procedures that will be applied during monitoring.
48. The PP should include sources of data that will be actually used for the proposed project activity (e.g. which exact national statistics, actual measurement etc. ).
49. Where the parameters are to be measured in accordance with the guidance of the approved project category or the general guidance to the indicative methodologies, specify the measurement methods and procedures including accepted industry standards or national or international standards which will be applied, which measurement equipment is used, how the measurement is undertaken.
50. Which calibration procedures are applied, what is the accuracy of the measurement method, who is the responsible person / entity that should undertake the measurements and what is the measurement interval?
51. Please provide a detailed description of the monitoring plan. Describe the operational and management structure that the project operator will implement in order to monitor emission reductions.
52. Clearly indicate the responsibilities for and institutional arrangements for data collection and archiving.
53. The monitoring plan should reflect good monitoring practice appropriate to the type of project activity. Provide any relevant further background information.
54. Please describe the process by which comments by local stakeholders have been invited and compiled. An invitation for comments by local stakeholders shall be made in an open and transparent manner, in a way that facilities comments to be received from local stakeholders and allows for a reasonable time for comments to be submitted.
55. Project participants shall describe a project activity in a manner which allows the local stakeholders to understand the project activity.
Hydro projects (ACM0002)
Layout of power transmission lines from the generation to the consumer with the metering system is not shown. It should include the distance of transmission lines. DOE has to check the meters are installed to monitor electricity generated, net electricity used in Bhutan, net electricity exported to India. Pls. clarify.
The status of the construction & commission of the project is not stated in the PDD.
What is the basis of calculation for transmission loss, auxiliary consumption and transformer losses? What is the length of transmission line?
The project is claimed to be run of river hydro project. So the calculation of reservoir is wrong. The criterion 3 is applicable only to pumped storage or accumulation hydro projects. What does reservoir refer to as per PP?
The justification of opting out alternative 3 and alternative 4 is not justified adequately. It should be based on latest published data and figures. Refer B.4. Pls. clarify.
The bilateral agreements, PPA with India are the documents, DOE to check thoroughly
Date of investment decision should be at the time of DPR preparation. So, the basis of the cost escalation factors at a later date for CDM consideration is not valid. Pls. clarify. Refer B5. Step 3a. (Investment barrier).
How the CDM benefit will alleviate the technical barriers. As per additionality tool, if the barriers are not alleviated by CDM, then the project is not additional.
Emission factor for state is not calculated.it should be made available to DOE to clearly validate this value. Emission factor for India is not as per ďTool for emission factor for the systemĒ.
Electricity generated by the project, auxiliary consumption, transmission losses, transformer losses, net electricity exported to India, net electricity exported to the grid. These parameters to be monitored continuously and to be cross checked with sale receipts.
The Meth mentions that if investment analysis option is used, apply the following:
a. Apply an investment comparison analysis, as per Step 3 of the .Combined tool to identify the baseline scenario and demonstrate additionality., if more than one alternative is remaining after Step 2 and if the remaining alternatives include scenarios P1 and P3;
b. Apply a benchmark analysis, as per Step 2b of the .Tool for the demonstration and assessment of additionality. If more than one alternative is remaining after Step 2 and if the remaining alternatives include scenarios P1 and P2.
But PP failed to apply like this. Pls. clarify.
PLF should be based on EB48 Annex 11guideline which says The plant load factor provided to banks and/or equity financiers while applying the project activity for project financing, or to the government while applying the project activity for implementation approval; (b) The plant load factor determined by a third party contracted by the project participants (e.g. an engineering company); But PDD doesnít demonstrate how PLF has been arrived at.
Whether PLF includes machine shutdown, machine availability. Whether grid availability is accounted for in the calculation of gross generation. To my surprise, critical parameter like PLF is missing from the PDD. How DOE has allowed this.
Common practice analysis should be based on EB 39 Annex 10 (Additionality tool). Each step of common practice analysis should be fulfilled as per tool.
Emission reduction calculation should be based on EB 50 Annex 14 ďTool for emission factor for the electricity system.
Whether only one set of main meter, check meter set is enough for three projects. The monitoring parameters need to be checked by DOE.
The main meter and check meter technical parameters like accuracy level, make, etc. needs to be mentioned in the PDD.
Submitted by: Benjamin franklin
Do send some auditors who are not in the business development and marketing with the PP. LR should depute a team for any audit who is not involved in the marketing with the client.
LR has degraded and bought disrepute to CDM process by giving all sorts of promises that they will complete the validation process in very short time. In the process neither they check any documents properly nor they any intention to do proper full scale validation. P.C.Acharya and his teamís only goal are to pass CDM validation for projects of his friendly consultants in the market quickly. Has LR management tracking and verifying what P.C.Acharya is doing? Or LR management is only interested in CDM revenues and do not care what P.C.Acharya is doing? What is the use of writing all sorts of procedures and singing all sorts of forms and undertakings when in the heart you have ulterior motives? How can he connive with consultants and offer certification services for CDM? Is it acceptable? LR says it is an old and reputed company. Is this the reputation you hold? Please answer how many visits P.C.Acharya made to clients places with consultants and gave promises to pass the CDM project before the contract is signed? They must come out with the list since PC Acharya joined LR. LR must answer this question and submit their reply to UNFCCC. To save LR reputation and in the interest of CDM process, PC Acharya must be stopped to involve in any manner what so ever whether off site or on-site, with respect to projects involving Ernst& Young consultants and China Light & Power group projects and other relevant projects
How can the DOE auditors do marketing? In which accreditation rules it is allowed? Does LR management know this? If PC Acharya wants to do marketing he should be totally out of auditing process. LR global management has to decide now proper controls by not sending same individuals to a project work more than one time and in same city. Proper TR to be done by a different person. Not the same person doing TR because you have more work. What kinds of work planning you are doing? Where are your time allocations for Lead auditors, auditors, technical experts and technical reviewers considering the 5 day week, annual leaves etc? Is Audit team member doing TR not a practice in LR? Is it ethical and acceptable as per accreditation norms? You tell you are an old and genuine company. Is it the way to work? You just stop misusing your DOE status.
DOE to check all purchase orders, feasibility reports, DPRís submitted to all parties by the PPís and comprehensively review them. DOE to check the original DPRís, FRís submitted by the PP to Banks and the other government agencies. DOE to obtain the same from the banks and government agencies with each page signed or else PP may fabricate and cook up the evidences. Only original documents to be checked along with payments made. All bank check copies, bank statements and written confirmation from banks must be obtained. Purchase order values are correct in this project? Any lack of doing all this proper and full work will mean LR is in connivance with PP for illegal and unethical validation work. Copy sent to UNFCCC.
Submitted by: Benjamin franklin
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