1.Please elaborate how “The installation of wind power project will result in rural and infrastructural development in the surrounding rural areas” on page 3 at Para 2 under ‘Economical well-being’

2.Please elaborate how “The project will provide encouragement to other entrepreneurs to invest into renewable energy sources,” on page 2 at Para 3 under ‘Social well-being.’ 

3.How many people shall this project employ? Please elaborate on the basis of skilled, unskilled, contractual and daily-wage labourers. Will local people be employed as per directives issued by the State Government?

4.“If the activity undertaken involves capital expenditure exceeding the minimum requirement of 2%, the additional expenditure made would be set-off against the requirements for the subsequent years. Such expenditure would be made within one year after the realization of revenues from the sale of the CERs.” Please explain this statement under ‘Community Development’ on Page 3 If the additional expenditure is set-off, would it amount to the discontinuance of the welfare activity in a region?

5.Please specify the time and venue of the Public consultation that was held.

6.The List of stakeholders (with the names and signatures) has not been included in the PDD. Was a member of the Gujarat Pollution Control Board/State Government also present at the Public consultation?

7.What will be the impact of an earthquake or natural calamity on the said project? As it is located in an earthquake-prone zone has a feasibility study in this regard been done?

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. The third party report can be forge just to indicate 

a lower PLF. Also cross check with tariff order.

PP has registered two wind projects earlier ref 3327 and 3632. In that it has compared benchmark with 

project IRR. Benchmark was 14.40% in tamil nadu project and 14.76% in gujarat project. How all of sudden 

the benchmark / discount factor rises to 22.79%???
Beta in earlier 2 projects was 0.5969. And now the beta in this project is 1.3189?? This clearly indicates 

that the PP is playing with CDM and this proves how developers are cheating the EB on the CDM 

requirements. DOEs are not able to validate the benchmarks and are easily cheated...

DOEs should critically evaluate such projects by such developers and see that only genuine projects get 

through!

Beta calculation is not clearly documented in the PDD. Clarify the type of beta used - asset or equity? 

How Reliance Infrastructure is considered as having similar risk when they are involved in many activities 

apart from power generation (transmission etc)

Is the project availing REC credits? PDD does not mention details. What if the REC credits are claimed 

during project operation?? How can DOE ensure on this?

Why NPV has been calculated instead of IRR for comparision against ROE?? This is not as per guidelines 

which says for benchmark a suitable indicator such as IRR to be used. Why NPV is calculated instead of 

IRR. See the guidance on investment analysis.

How can a NPV calculated only on the equity portion and not on total project cost?? This is not correct! 

NPV can never be on equity component rather on the total project investment!

Why did the PP change its evaluation for additionality from registered projects which calculated IRR?

Why the PP has considered a particular vintage for calculation of market returns. Everyone knows that 

selecting a particular vintage can lead to a drastic change in the market returns. How the market returns 

can be calculated only on the basis of two values - start and end indice value?? The index can have a 

great fall or great jump in a single day? How this calculation is appropriate and conservative?

DOE to check whether the companies considered for beta are true representative companies for the wind 

project. 

How quotes can be basis for PLF? How guidance is followed?

Why all different types of errors are considered for generation? DOE to validate them critically!

DOE to compare the project cost with that indicated in recent tariff order.

Project capacity is 9.9MW. Then how ACM002 is applied?? 

How PP ensured stakeholder meeting is done in a fair manner? 

How 4 to 5 days are sufficient for stakeholders to respond and comment on the project?

Why only three types of stakeholders were invited? One of then ie Vestas is an interested party?

What about local NGOs, farmers, nearby residents, electricity board officials, contract workers, laborers??

PP has only chosen particular stakeholders and given invitation by hand. This clearly indicates the local stakeholder consultation is not done properly!

PP should conduct the meeting again and re-webhost the PDD.

Even if CDM benefits are considered, still the project remains below the benchmark / not financially attractive by a big margin. Then why the PP decided to invest in the project????

This raises a question mark on the decision making process. Clearly indicates that the benchmarks are only made for CDM purposes and not really considered by the PP to make investment decisions!