The PDD only states that the commercial lending rate as published by RBI is taken as discount rate. For reasons not clear, consultant is not interested in disclosing the discount rate. Therefore, the reader cannot reproduce the worksheet with the given input parameters and arrive at the same results. Is it in conformity with the CDM methodological requirements? Then, how did the DOE web host this project?

PDD states, in applying the investment comparison analysis, cost overruns of former investments in MRTS or reduced revenues of former MRTS investments compared to original projections, which make new investments less viable and riskier are considered in the investment analysis. The methodology provides for it. But can the traffic be reduced by 74%? It is not clear whether the organization engaged a reputed consultancy organization or a novice. If it reputed organization, the consultants statement only reveals that the organization knows less than the CDM consultant in estimating the cost and traffic!! In short, this is nothing but a method adopted to make the project additional. It is also surprising that whatever fact is not convenient, the consultant dismisses by stating exceptional as in the case of DMRC. 

On what basis the consultant is ignoring the depreciation, interest etc. and going by pre tax NPV? Is the project exempted from tax?   Will any agency making investment take a decision based on pre tax return when it knows that the project is subject to taxation? How does it conform to the requirement of Additionality tool?

In sum, it appears that a non additional project is being made additional, by deviating from the project report prepared by a reputed consultant