Biomass Based Power Project at Raipur
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Host party(ies) India
Methodology(ies) AMS-I.D. ver. 17
Standardised Baselines N/A
Estimated annual reductions* 63,475
Start date of first crediting period. 01 Sep 12
Length of first crediting period. 10 years
DOE/AE TÜV NORD CERT GmbH
Period for comments 08 Nov 11 - 07 Dec 11
PP(s) for which DOE have a contractual obligation Shanti G.D. Ispat & Power 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 (635 KB)
Local stakeholder consultation report: N/A
Impact assessment summary: N/A
Submission of comments to the DOE/AE Compilation of submitted inputs:
DOE to consider below points during validation:
Is there sufficient biomass available to cater to yet another biomass based project in Raipur area? There are already many biomass projects operating in the region.

It is well known that the PPs operating biomass projects (as CDM) fire coal throughout the year and only during verification, show fraud biomass invoices to the DOE and claim ERs falsely. How will the DOE ensure this does not happen? Does the PP maintain a seperate inventory for the coal being consumed in their primary operation (kiln) and in the biomass plant?

Total capital cost seems to be very high. DOE to compare with the tariff orders in the state.

How come the power sale rate is determined? Is the PP selling to third party? PP can always claim REC benefits in addition to the PPA rate, which will make the project a profitable venture. How is this accounted in financial additionality calculations?

Else, PP can give a declaration of not seeking REC benefits, which can be checked during verification.

Cost of coal and biomass are shown very high. DOE can compare the cost with all registered projects in the State. Coal cost will normally be not more than INR 1500/ton, while biomass will be INR 1800 to 2000/ton.

Annual salaries and wages seems to be very high for a 15 MW biomass project. DOE to consult sector expert to determine the no. of staff required for such projects. Are salaries escalated at 10% per annum?

Why is the need for administration expenses? Isnt it a part of O&M expenses? See relevant tariff orders.

Biomass projects are eligible for accelerated depreciation benefits (80%). How these are accounted for in the calculations? PP can also avail tax shield in initial years. DOE to critically check this.
Submitted by: Babloo

Dear DOE 
 Do you aware of this below mentioned link, please clarify whether this project comes under this category.

http://www.theweekendleader.com/Causes/841/Green-fraud.html
Submitted by: sud

If you carefully read through the PDD it is confirmed that this is not a genuine CDM project at all. What is the exact project cost? The project cost is covering what? 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 is very clear 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. It looks like PP is purchasing second hand or second quality equipment by inflating the purchase order values and invoices. This must be probed thoroughly and real values to taken for additionality calculation. Then I’m sure the additionality is not there at all in this project. How is the base line defined in this project? Base line is hypothetically defined with no proper evidences and proper justification. 
DOE cannot take the base line as suggested by the PDD.  Please note that there are no emissions beyond the real and factual base line. This project definitely qualifies for zero CER’s, not even one CER. 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 Feasibulity report signed. Such document can be considered as a real DPR or FR. This project is genuinely a fabricated, false and misinterpreted project with no base line and additionality.  
Submitted by: alexander


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