	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. 

	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. 


	DOE to ensure that the PDD values are consistent and ensure that the CDM project is a genuine project

	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. 


	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. 

	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. 


	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. 


	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. 

	 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.  



	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. 


	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.  



	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.

	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. 

	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. 

	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. 

	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. 


	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.  



	DOE to ensure that the PDD values are consistent and ensure that the CDM project is a genuine project
	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. 
	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. 
	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. 
	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. 
	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. 



	 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.  

	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.
	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. 

PDD states, “The statutory obligations in Chhattisgarh and India do not require sponge iron plants to utilize the heat content of the waste flue gases from the respective processes, in generation of electricity for captive consumption”. DOE is requested to check the PCB clearance carefully as to what undertaking the company has given for letting out the flue gas in the atmosphere. If it has given an undertaking that the flue gas will be used for electricity generation, then this project is not additional as there is no ‘alternative’. If not whatever cost required to be incurred by the company for letting out the flue gas as per standards prescribed by PCB should be deducted from the total investment as the company would have invested this amount any way.

One of the items in the “chronological history date wise” states, ‘Letter of E & Y informing that Validator reluctance in project start date before 2004’. On what basis the consultant and PP has chosen to resubmit the PDD when the validator has refused to accept the project start date before 2004? Is it because the present DOE was willing to take up the project rejected by others on valid grounds? How does this project  conform to guidance to Annex 13, EB 62?

Is it possible to set up a coal based power plant at a cost of Rs.35 mn./MW? The Expert Committee on Fuels has recommended a cost of Rs.40 mn./MW for large power plants. The PP appears to be more efficient. The cost has been lowered only to make the project additional. 

PDD considers only capital cost, auxiliary consumption and book depreciation. As for project scenario, the waste heat is the fuel and for alternative coal is the alternative. While coal has to be purchased, no cost is attached to waste heat. When there is no cost for the fuel in the case of project scenario, how can the levelised cost for project cost be more than that of alternative? This calculation is totally incorrect and misleading and DOE should not accept the calculation. 

The fact is that the PP and consultant have not disclosed full information in the PDD. Even the financing pattern is not disclosed. PP and consultant want to submit the costs only to DOE so that it can be changed with the assistance of DOE to make the project additional. Please tell us how does the presentation conform to paragraph 8 of sub-step 2(c) of Additionality Tool? With the given information, is it possible to construct the worksheet and calculate the financial indicator and arrive at the same results? DOE should not take up this project for validation, in case PP and consultant introduce new costs other than what is given in the web hosted PDD, unless it is re-webhosted with all information so that the reader is able to reproduce the figures and arrive at the same results. 

All the barriers are either already considered in the investment analysis (which is badly presented) or cannot be considered as barriers. PP and consultant seem to be interested in filling the pages without reading and understanding the VVM and Additionality Tool and Annex 13, EB 50. Similarly whether the common practice analysis is as per Additionality Tool requirement? 

The PDD is not transparent and the DOE should check the actual cost and the reweb host the project before taking up for validation.

Since steam is collected in common header, how can power produced from waste heat be established? Only steam produced from waste heat can be measured. Pls. clarify. A mass, heat and energy balance should be documented in the PDD to transparently reveal the fact. The balance sheet should include waste gas generated, all boilers, steam header, turbine(inter alia)

Quantity of end product from the DRI kiln, Quantity of fuel fired in the kiln, Quantity of flue gas generated, Specific quantity of waste gas generated/end product, Specific quantity of waste gas produced/ fuel fired, Specific quantity of fuel fired in the kiln/end product.  These aspects should be documented with justification in the PDD. These parameters should be monitored so as to cross check the actual quantity of waste gas generated.  
Fuel consumed in the fossil fuel boiler should be monitored. Quantity of steam produced from each fossil fuel boiler/fuel fired should be clearly validated. Mass flow of steam monitored is not enough, the totalizer of steam from each boiler (Both fossil based and WHRB) is required. DOE has to check this aspect during validation. The pressure and temperature will be fluctuating, and then power that would be produced from waste heat will be established.

What is the guarantee that all waste gas/heat that is generated is utilised for steam generation in the WHRB. I am raising this question, because baseline calculation is based on quantity of waste gas generated. Quantity of waste heat can be established based on steam entered in the common header. 

Electricity import during turbine failure /tripping and boiler shutdown (those 15 days) is not considered in the PDD. The project emission should include this. 

The project activity could be developed only be the PP and nobody else. Then how can publicly available external benchmark be compared with local project IRR. The low risk project cannot be compared with high risk project and vice versa. Why the basis of calculation of WACC is not documented in the PDD. How the responsible DOE has allowed this.
Since the Fossil fuel based power plant also included in the project boundary, CO2 emission should be treated as project emission.
 
Total power requirement of the plant, in-plant consumption, auxiliary consumption in each section should be available in the energy balance sheet. 

The calculation of energy content of the steam generated in waste heat recovery boiler fed to turbine via common steam header and energy content of steam generated in other boilers fed to turbine via common steam header is not demonstrated in the PDD. 

Why the parameters mentioned to be monitored are not used in the calculation of emission reduction. The emission reduction should be based on these parameters.