Bundled Wind Project Activity in Tamil Nadu by MMP
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Host party(ies) India
Methodology(ies) AMS-I.D. ver. 16
Standardised Baselines N/A
Estimated annual reductions* 19,891
Start date of first crediting period. 01 Jan 12
Length of first crediting period. 7 years
DOE/AE PJR CDM
Period for comments 20 Jan 11 - 18 Feb 11
PP(s) for which DOE have a contractual obligation Muthoot Fincorp Limited
Muthoot Finance Limited
Parkkot Maritima Agencies 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 (380 KB)
Local stakeholder consultation report: N/A
Impact assessment summary: N/A
Submission of comments to the DOE/AE Compilation of submitted inputs:
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.

There are no details on the construction of the benchmark and its components. How can a DOE webhost such an incomplete PDD for global stakeholder consultation? How can a stakeholder comment on such case?

How has the beta calculated for the CAPM benchmark? A unlevered beta is appropriate for equity based benchmark. PP should clarify this.
DOE must be well versed with the financials for validating the benchmark and financial analysis.

Tariff rate: Check the actual tariff rate from the invoices. A recent tariff order in Tamil Nadu mentions a higher tariff rate for wind projects. Is there any REC benefit claimed by the PP?

PLF of 24.76% seems to be low. Please check the tariff order for the PLF for this region or pass.

When the project was web-hosted earlier why a re-webhosting is done now? It may be that the earlier DOE may have issued a negative validation opinion or there may be open findings which were not closed. This DOE is requested to discuss this aspect with the earlier DOE and also discuss the same in the validation report.

The start date of the project is way back in 2006. This clearly indicates there is no CDM consideration at all by the PP. 

Input values are not presented in the PDD. Again an incomplete PDD for web-hosting.

PP/Consultant may think that this DOE is new and may not have the competence to find out mistakes from the earlier validation. DOE should also check the earlier PDD and the logic for additionality. DOE will agree that the additionality and investment logic should not change. Did the earlier PDD webhosted also have the same logic of CAPM benchmark versus a Equity IRR?? Be careful about this. This PDD (second hosting) may have constructed a higher benchmark for proving additionality. Beware!!!
Submitted by: Babloo

Non de-bundling nature of the project is not justified properly in the section A.4.5. DOE has to validate whether there is no registered project with the PP nor there is an application for registration of any project. PP doesn’t confirm in the PDD that there is no application for registration. 
2.	Operating margin, build margin, combined margin is not as per “Tool for emission factor for an electricity system”. The tool is not used at all. Pls. calculate combined margin as per the tool. Pls. justify that grid emission factor calculated is as per CEA data latest version.
3.	The date of investment decision is not provided transparently. It should be used generously in the PDD for clarity.
4. 	DOE has to check, Page no.16 of the PDD, PP to indicate that continuing and real actions was wrong, two times webhosted details are not provided, dates and title mentioned in the  PDD is not matching  at UNFCCC web site. Whether earlier webhosted project have been conducted by same DOE? 	
5.	The date of board meeting, investment decision meeting, and offer date are not provided in the chronology of events column.
6.	A notification has to be sent to government of India and EB stating the starting of the project. It is not clear from the PDD whether it is done since this aspect is not provided in the PDD. Pls. clarify.
Submitted by: Johan pereira


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