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Submission of comments to the DOE/AE
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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 DPR’s 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 DPR’s and FR’s. 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 PP’s 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 I’m 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 CER’s. 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: zhong zhou li
In the interest of CDM future sustainability the global CDM project developers should stop doing CDM business in China. Enough has been done in China and CDM is dying in the present form because of this exploitation in China. How come HFC and N2O projects in China are CDM registered? This is nothing but a big scandal. This very big scandal is the main reason for today’s poor CDM situation. When it comes to wind and small hydro CDM EB talks not very positive but same CDM EB has approved HFC and N2O projects in China. DOE’s work in China to be cross verified by CDM EB or else without a wind turbine in place Chinese developers can claim CER revenues. They are masters in this kind of manipulation. CDM EB to be careful and while issuing CER’s, double checks to be done by CDM EB and also the lat long details to be verified in a more detailed manner . Simply giving some lat long of a hilly terrain is not good enough evidence. The equipment should be in place and generating the power. The nexus between Chinese developers and CDM consultants from Europe is the main reason for CDM failure and this must be contained and controlled. How come Chinese projects are getting CDM registered very fast whereas in other countries it takes much much longer time. How come proving CDM additionality is so easy in China? What is that magic stick? What does it mean? Is it not because in China CDM is forged, coked, fabricated and stage managed? Who is involved in this? How long some unethical European CDM developers wish to support China CER’s? Now, in the interest of CDM, CDM should be overhauled in China and some discipline is brought in place. CDM is manipulated in China and all European CDM developers are doing business in China. This is a shame! This bunch of European CDM developers will be remembered in the history for all bad reasons, this is for sure. CDM market had enough of this China scandal for years now, Stop this non-sense immediately. It is high time that the international community and international companies must stop buying VER’s and VCU’s from China due their poor record of …… which is well known from decades of actual happenings and real ground situation. This is an absolute shame! It is high time Chinese CER’s and VER’s must be banned from use for any task for various reasons which are obvious and whole World and off-set market knows very well. Now it is up to global corporates to bring in some sanity with respect to China’s emission reduction units. Are global corporates not aware of these facts why? It is so sad.
Submitted by: zhong zhou li
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