Greenhouse Gas Emission Reductions through Super-critical Technology - Coastal Andhra Power Ltd.
Host party(ies) India
Methodology(ies) ACM0013 ver. 3
Standardised Baselines N/A
Estimated annual reductions* 1,219,229
Start date of first crediting period. 30 Sep 14
Length of first crediting period. 10 years
Period for comments 05 May 10 - 03 Jun 10
PP(s) for which DOE have a contractual obligation Coastal Andhra Power 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 (947 KB)
Local stakeholder consultation report: N/A
Impact assessment summary: N/A
Submission of comments to the DOE/AE Compilation of submitted inputs:
Certainly this consultant has done a better job than the one who was working on other Indian super-critical projects. At least data is presented in a clear manner without taxing stakeholderís mind. First thing i checked in this PDD is of project coal calorific value. Half of my professional community, if not more, know you have won this project by taking an unconventional approach on fuel., i.e., considering low calorific value coal mines abroad unlike other companies which generally go for higher calorific value coal mines. I am glad you have not deviated from that and made a right disclosure. Above all, No reference to 14% equity return which i believe is absurd for projects awarded on competitive bidding. 

Here are my comments on this PDD.

1.	Financial indicator for this methodology is levelized energy production cost. You should disclose IRR data. Donít say it is not a methodological requirement. I canít buy that logic which most DOEs seem to make. It is not conservative assessing additionality on production cost basis alone. How could DOE confirm additionality without IRR being known? DOE should compare IRRs of Project and assessed plausible baseline before confirming additionality. Donít make the same mistake which other DOEs have committed.

2.	I am against any merchant plant asking for Carbon funding because short-term trading of power is one of the most lucrative business option in India. Same holds true for a equity return guaranteed plant. I am aware Ultra Mega Power Projects does not allow merchant capacity creation. I want to ensure i am correct. Take a declaration from the PP that there will be no merchant capacity from this project and submit the document to UNFCCC. Make it a monitoring parameter if it is required. If you are establishing any merchant capacity as part of this project then, explain the basis how you have arrived at the merchant tariff and what is the impact of merchant tariff on IRR? 

3.	Check the names of your alternatives (1) and (2) in Page # 29. What you have mentioned in page 29 is not to what was mentioned in Page 32. Your inclusion of sub-bituminous and bituminous in titles is confusion. When you are using common calorific value in both alternatives (1) and (2), why did you classify it under two different names? Is it an error or is it intentional? 

4.	I donít remember reading efficiency of your plant in the PDD. Why was no disclosure of efficiency being made in the PDD? I note net efficiency as 36.06% from energy balance diagram. DOE should cross-check if meth given equation yields same value and verify PP presented correct data to international stakeholder community.

5.	Why was energy balance diagram not presented for sub-critical plant, although you have done it for project? I think this is one of the place where PDD filling guidelines were not followed. You should add energy mass balance for sub-critical technology as well.

I am not able to upload the pdf file because of software problem and I am 5 minutes short of making this submission. Please do send me an email if the pdf version of document is required for this comments. 
Submitted by: GS

Comment (5023 KB) submitted by: eva filzmoser on behalf of Stefan on behalf of CDM Watch

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