CITIZENS CONCERN FOR DAMS AND DEVELOPMENT 
IMPHAL MANIPUR NORTH EAST INDIA 795001
E-ADD: CCDDNE@YAHOO.CO.IN, MANGANGMACHA@GMAIL.COM 

After a careful perusal of the Project Design Document submitted by the Energy Development Company Limited (EDCL)-Tawang Power Private Limted for construction of the 90 MW Tsa Chu II Hydroelectric Project near the confluence of Nykrongchu river and Tsa-chu river in Tawang District of Arunachal Pradesh, the Citizens Concern for Dams and Development, Manipur, North East India, is of the view that that the Tsa Chu II HEP will be ineligible to receive carbon credits from the CDM mechanism of the UNFCCC Convention. The reason for such ineligibility of the project is outlined herewith:  

Rightful Participation of Affected Peoples in Decision Making Process Undermined: 
Violation of Indigenous Peoples rights to Free, Prior and Informed Consent: The communities to be affected by the series of dam projects are indigenous peoples in their own land and territories and has not been consulted widely and their consent not taken with due respect of their rights over their land and resources. The absence of Free, Prior and Informed Consent of affected indigenous peoples is also evident in the series of protest against Hydroelectric Projects in Tawang. Thousands of affected people held a protest rally against the construction of proposed mega hydro projects, including Tsa Chu II in Tawang on 4 April 2012 .  The Save Mon Committee (SMC) which organized the protest expressed strong objections to the proposed mega dam project reasoning that the Tsa chu II dam along with series of other dams, total fifteen (15) in number to be build in Tawang District will completely destroy the beautiful landscape, flora and fauna and cause wide displacement of thousands of people residing along the Tsa Chu River.  Among the total 148 Memorandum of Agreements (MoA) on Dam projects signed by the Arunachal Pradesh Government till July 2011, fifteen (15) Projects with more than 3500 MW are in Tawang District. Moreover, these MoAs has been condemned for its lack of transparency and corruption.  
The efforts of project authorities to pursue the project without peoples’ participation and consent itself constitute a serious violation of the right to Free, Prior and Informed Consent of indigenous peoples (FPIC) affected by mega dams, a key provision of the United Nations Declaration on the Rights of Indigenous Peoples, 2007, endorsed by the Government of India in its adoption at the United Nations in 2007.  The UN Committee on the Elimination of Racial Discrimination had asked the Government of India in 2007 and 2011 to take FPIC of indigenous peoples before construction of mega dams in India’s North East , which is blatantly violated by the project authority of the Tsa Chu Project II.  
No Cumulative Impact Assessment and Flouting World Commission on Dams Recommendations       
Absence of Cumulative Impact Assessment: There is no detailed impact assessment of the Tsa Chu II project on wildlife, biodiversity, social and cultural impacts, human rights impacts both in upstream and downstream of the proposed dam with due participation of affected communities as per the guidelines of the recommendations of the World Commission on Dams. As there is also no detailed and holistic impact assessment of the dam and also cumulative impact due to the planned construction of Tsa Chu II HEP together with other mega dams over major Rivers in Tawang District of Arunachal Pradesh, the project authorities has violated the recommendations and guidelines of the World Commission on Dams.  
Biodiversity and Wild Life Impacts of Tsa Chu II HEP: The efforts to built Tsa Chu II HEP along other series of dams across the rivers in Tawang District again constitute a complete disregard of the environmental impact, loss of rich and diverse flora and fauna of the region. The Tawang Chu II project will pose serious threat to rare species like Red Panda and Macau, Mountain Goat, Snow Leopard which are found in the area. Tawang is also a home to rare Himalayan Wild Plant species like Rhododendron etc. Tawang is indeed the only places on Earth where all different varieties of Rhododendron are grown. As per survey report of Nature Conservation Foundation, Mysore, International Snow Leopard Trust, Seattle, USA and Wildlife Conservation Society, Bangalore, the area of Mago Chu valley harbor the richest mammalian assemblage which are of global conservation importance. Tawang is perhaps the only known region in the world to have all the three (3) Goral species- listed as threatened species. 
The area has also been identified as an important site for the creation of State’s First High Altitude Wildlife Reserve. The area has also been covered under “His Holiness the VIth Dalai Lama Tsangyang Gyatso World Peace Park (Biosphere Reserve)”, dedicated by Shri Gegong Apang, Hon’ble Chief Minister, Arunachal on 19th November 2004.  
Impact of Road construction:  The Government of India takes initiative to widen the original Bhalukpong to Tawang Road through Sela Pass for transporting heavy equipments for the Tsa Chu II and other HEP planned in the region. If heavy equipments for construction of the Tsa Chu II HEP are transported through this particular stretch of road, it will have serious impact on the biodiversity and wildlife of the region . The road to Lumla which links the Tawang Chu II is very fragile and is landslide prone.  Every year during monsoon season rain washes away portions of the road.  
Projection of road building by the project authorities as part of social well being criteria  is completely meaningless as it implies that the Government of India or for that matter the project authorities will never build roads if the area is not conducive for hydropower projects or other similar initiatives. Roads, Schools, health facilities are fundamental rights and needs of communities and has to be mandatorily created in far flung areas irrespective of whether the area has scope for companies to exploit its resources. 
Social and Cultural impacts:  The local indigenous peoples will be decimated due to the influx of migrant workers from other parts of India, which will further have a wide ranging impact on small local indigenous populations on their  subsistence economy. The Tawang District has only 49,950 people as per 2011 census in an area of 2085 sq km.  Each Dam building requires more than 2000 to 3000 workers and with fifteen dams planned in Tawang, dam workers will completely overwhelm the local indigenous populations, which will have a serious health, cultural and social impacts as well due to influx of migrant workers. These dams building will also lead to more militarization of the area which will further add pressures to land rights.  The economic benefits to locals as claimed by the project authority is again irrational as the actual benefits will go to the dam developers and other companies, which provides equipments for the Tsa Chu II HEP, such as construction company and the turbine companies etc. 
Many holy and sacred sites are also situated along the River Basin of Tsa Chu, Tawang Chu and Nyamjangchu like- centuries old 200 feet span iron chain suspension bridge at Chaksam, hot water springs, Hromang/Surbi village pilgrimage site; centuries old Gorsam Chorten Stupa, Zemithang and Gomshing near Bletteng village etc. In Mon Tawang Region, the local people believed that transcendental deities, eminent local deities and spirits make their abodes in mountains, valleys, cliffs, trees etc. There are also many holy Mountain Sites at Rho village. The Tsa Chu II and other Hydro Electric Projects in Tawang will lead to disastrous consequences for the people and ecology of the Region. The PDD submitted by the project authority has failed to highlight these socio-cultural impacts.  
Undermining Emissions from Tsa Chu II HEP   
The project authorities falsely mentioned repeatedly in the PDD that the Tsa Chu II HEP is an emission free project reasoning that it is a renewable project and a fossil fuel free project. Several Studies worldwide have already confirmed that mega dams are one of the worst emitters of Green House Gases (GHGs). Range of emissions, such as the emission from dam reservoir due to submergence of forests, the emissions due to boring of tunnels and the emission from sudden release of water from power houses, emissions due to numerous vehicles to be used in the construction  of reservoirs and boring of tunnels, emission due to felling of trees and destruction of forest by numerous dam workers etc are not taken into consideration and completed omitted deliberately in the PDD submitted by the project proponent.  
Wrong projection of Baseline Scenario: 
In Arunachal Pradesh and in other seven states of India’s North East, there is no fossil fuel based power plant but only generations from hydropower sources.  Interestingly, the  North East region power Grid, dominated by Hydropower has been clubbed with other  Northern Power Grid, Eastern Power Grid and Western Power Grid, which is dominated by Thermal based power generation, to form the NEWNE Grid  so as to facilitate arbitrary claims that the NEWNE is dominated by fossil based generation, when in reality there is not even a single fossil fuel based power plant in the entire North Eastern Grid comprising Eight states of Sikkim, Assam, Manipur, Nagaland, Mizoram, Meghalaya, Arunachal Pradesh, Tripura. The project authority’s statement that generating power from hydropower is a clean technology is false as it failed to highlight range of emissions during construction processes, from the vehicles used in dam construction, creation of reservoirs and tunnels, construction of approach roads and felling of trees etc.  
The Citizens Concern for Dams and Development would like to point out that the Tsa Chu II HEP will not be eligible to receive carbon credits from CDM due to the aforementioned multitude of impacts. 


 
(Dr. RK RANJAN)
Chairperson   

TO WHOM IT MAY CONCERN.
 
We the Save Mon Region Federation upgraded form of Save Mon Committee would like to strongly oppose the Tsachu 1, Tsachu 11 & Tsachu Lower Mega Hydro power Project for the following reason
1         The Projected area is the Habitat of endangered Species of Schedule 1 wildlife such as Clouded Leopard, Snow Leopard, Red Panda  & Musk Deer etc. & home to several locally threatened plant species like Rhododendron, Taxes,  Ponirochis, Saussurea,  Obvallata, Fritillaria cirrhosa and Potentilla etc.
2         There are more than Twenty mini & micro Hydel in Tawang alone which already destroyed so many forest, farming land.
3         There are merely 30000 ( Thirty Thouasand) ethnic  Monpa Trbal population which will be reduced to minority in our own land by population influx of migrant labourers
4         There is pilgrimage site of Dechok Abode, Chumig Gyatsar & many sacred holy places blessed by Guru Padmasambava.
5         These projects will disturb the ecological balance due to massive tunneling of area & damming.
6         The displacement of Local Monpa Scheduled Tribes.
7         Tawang is highly sensitive international border which witnessed 1962 war. So instillation of Mega Dam Project will be full of risk.
8         Tawang is considered as youngest mountain in world which is still evolving. So it is infavourable for Mega Hydro Power projects.
9         There will be cultural Genocide of Monpa by these Mega Hydro Power Projects.
 
Lobsang gyatso
General Secretary

South Asia Network on Dams, Rivers and People 
Delhi INDIA
ht.sandrp@gmail.com, www.sandrp.in 

After a careful perusal of the Project Design Document submitted by the Energy Development Company Limited (EDCL)-Tawang Power Private Limted for the 90 MW Tsa Chu II Hydroelectric Project near the confluence of Nykrongchu river and Tsa-chu river in Tawang District of Arunachal Pradesh, we are of the view that that the Tsa Chu II HEP should be ineligible to receive carbon credits from the CDM mechanism of the UNFCCC Convention. The reasons for such conclusion are given below:  

1. Rightful Participation of Affected Peoples in Decision Making Process Undermined: 
Violation of Indigenous Peoples rights to Free, Prior and Informed Consent: The communities to be affected by the series of dam projects in this basin, including this specific project are indigenous peoples in their own land and territories and has not been consulted properly in an informed way and their consent not taken with due respect of their rights over their land and resources. The absence of Free, Prior and Informed Consent of affected indigenous peoples is also evident in the series of protest against Hydroelectric Projects in Tawang. Thousands of affected people held a protest rally against the construction of proposed mega hydro projects, including Tsa Chu II in Tawang on 4 April 2012 .  The Save Mon Committee (SMC) which organized the protest expressed strong objections to the proposed mega dam project reasoning that the Tsa chu II dam along with series of other dams, total fifteen (15) in number to be build in Tawang District will completely destroy the beautiful landscape, flora and fauna and cause wide displacement of thousands of people residing along the Tsa Chu River.  Among the Memorandum of Agreements (MoA) on Dam projects signed by the Arunachal Pradesh Government till July 2011, fifteen (15) Projects with more than 3500 MW are in Tawang District. Moreover, these MoAs has been condemned for its lack of transparency and corruption.  
The efforts of project authorities to pursue the project without peoples’ participation and consent itself constitute a serious violation of the right to Free, Prior and Informed Consent of indigenous peoples (FPIC) affected by mega dams, a key provision of the United Nations Declaration on the Rights of Indigenous Peoples, 2007, endorsed by the Government of India in its adoption at the United Nations in 2007.  The UN Committee on the Elimination of Racial Discrimination had asked the Government of India in 2007 and 2011 to take FPIC of indigenous peoples before construction of mega dams in India’s North East , which is blatantly violated by the project authority of the Tsa Chu Project II.  

2. Wrong projection of Baseline Scenario The PDD claims on page 3, “The generated power from this project activity is supplied to the Arunachal Pradesh State Electricity Board”. In Arunachal Pradesh and in other seven states of India’s North East, there is no fossil fuel based power plant but only generations from hydropower sources and only a few gas based stations that too none in Arunachal Pradesh.  Interestingly, the  North East region power Grid, dominated by Hydropower has been clubbed with other  Northern Power Grid, Eastern Power Grid and Western Power Grid, which is dominated by Thermal based power generation, to form the NEWNE Grid  so as to facilitate arbitrary claims that the NEWNE is dominated by fossil based generation, when this is not the reality.  

3. Project is non additional Considering the large number of hydro projects being taken up in the area, and large number of agreements signed and even up front payment of millions and sometimes billions of Rupees made, it is clear that the project faces no barriers (the claim to the contrary on page 18 of PDD in alternative 1 is wrong) and is in fact getting incentives from the govt of India and hence it is not an additional project. It is business as usual large hydro projects, of the kind of which very large number are being taken up. 

4. Project is not the least cost option If the objective is to provide electricity to the people nearby the project area, or people of the Tawang district or the people of Arunachal Pradesh, or the people of the North East India or the general development of any of these, than there are better options available in terms of sub MW scale hydro projects, for which there is huge potential, which has not even been assessed, leave aside the question of realised. Such projects would indeed be sustainable with less social and environmental impacts and great chance of community involvement from the planning to operation stages. Without assessment and realization of such options, taking up such big hydro projects would be detrimental to the interests of the people and the region, detrimental to the sustainable development and also to the global climate. 

5. Use of wrong financial indicator The project claim on page 24 of PDD, “Based on the above assumptions, the project IRR works out to be 9.89%. From the above it is evident that the return on equity from the project activity is lower than the established benchmark of 12.75%.” is wrong. As per the norms of India’s electricity Act, and Central Electricity Regulatory Commission, all projects are assured 14% return on equity, the tariff is calculated on that basis. In addition, they are allowed to sell 40% of power as merchant power, through which they can earn additional revenues. Hence the PDD is making misleading claims. 

6 No Project level or Cumulative Impact Assessment and Flouting Indian Law, World Commission on Dams Recommendations       
Absence of Cumulative Impact Assessment: There is no detailed impact assessment of the Tsa Chu II project on wildlife, biodiversity, social, environmental and cultural impacts, human rights impacts both in upstream and downstream of the proposed dam with due participation of affected communities as per the guidelines of the recommendations of the World Commission on Dams. 
The PDD accepts on page 46, “The EIA is being carried out and at an appropriate time, the Environmental Clearance (EC) would be obtained from the Government of India.” This clearly shows that the Environment Impact Assessment has not even been carried out. How can than the project be declared as environment friendly?  The project also thus violates requirement D2 mentioned on page 47. The requirements of section E, is also not possible to fulfill, without and impact assessment and clearance from the statutory environment angle, forests angle and wildlife angles. The description from the section E makes it clear that there has been NO public hearing or consultation has required under Indian law or under WCD guidelines. It is shocking that EDCL has considered their own employees and equipment suppliers for this stakeholders consultations! They are clearly making the UNFCCC process a laughing stock. 
As there is also no detailed and holistic impact assessment of the dam and also cumulative impact due to the planned construction of Tsa Chu II HEP together with other mega dams over major Rivers in Tawang District of Arunachal Pradesh, the project authorities has violated the recommendations and guidelines of the World Commission on Dams.  Moreover, it is not possible to certify the project to be of sustainable development, without the basic project level and cumulative impact assessment would be wrong, and improper. Without such an impact assessment it is not even possible to know if the impacts are quantifiable, acceptable, mitigable or desirable. Nor can the local communities and others know abut the impacts of the projects, without the impact assessment. 

7. Wrong claims about project impacts The PDD claims in section A2, page 2, “The   project   activity   will   be   carried   out   on an existing   river body,   i.e.,   no   water reservoir needs to be constructed for the project activity.” This is clearly a wrong claim. The project will involve building of a dam on the river to divert the water into the tunnel, it will not be able to use only the existing river body. In fact this claim is contradicted on page 7, where it is said that the project will involve a weir of 10-15 m. This statement also shows that the project authorities still do not know even about the basic dimensions of the various components of the project. The difference between impacts of a 10 m and a 15 m weir would be huge indeed. 

8. Biodiversity and Wild Life Impacts of Tsa Chu II HEP: The efforts to built Tsa Chu II HEP along other series of dams across the rivers in Tawang District again constitute a complete disregard of the environmental impact, loss of rich and diverse flora and fauna of the region. The Tawang Chu II project will pose serious threat to rare species like Red Panda and Macau, Mountain Goat, Snow Leopard which are found in the area. Tawang is also a home to rare Himalayan Wild Plant species like Rhododendron etc. Tawang is indeed the only places on Earth where all different varieties of Rhododendron are grown. As per survey report of Nature Conservation Foundation, Mysore, International Snow Leopard Trust, Seattle, USA and Wildlife Conservation Society, Bangalore, the area of Mago Chu valley harbor the richest mammalian assemblage which are of global conservation importance. Tawang is perhaps the only known region in the world to have all the three (3) Goral species- listed as threatened species. 
As mentioned on page 7 of PDD, the project elevation is high at around 4200 m and hence this is a very high altitude, cryosphere area, where the biodiversity is much more vulnerable and rare. Hence this biodiversity needs to be protected and the project will actually destroy it. 
The area has also been identified as an important site for the creation of State’s First High Altitude Wildlife Reserve. The area has also been covered under “His Holiness the VIth Dalai Lama Tsangyang Gyatso World Peace Park (Biosphere Reserve)”, dedicated by Shri Gegong Apang, Hon’ble Chief Minister, Arunachal on 19th November 2004.  

9. Social and Cultural impacts:  The local indigenous peoples will be decimated due to the influx of migrant workers from other parts of India, which will further have a wide ranging impact on small local indigenous populations on their subsistence economy. The Tawang District has only 49,950 people as per 2011 census in an area of 2085 sq km.  Each Dam building requires more than 2000 to 3000 workers and with fifteen dams planned in Tawang, dam workers will completely overwhelm the local indigenous populations, which will have a serious health, cultural and social impacts as well due to influx of migrant workers. These dams building will also lead to more militarization of the area which will further add pressures to land rights.  The economic benefits to locals as claimed by the project authority is again irrational as the actual benefits will go to the dam developers and other companies, which provides equipments for the Tsa Chu II HEP, such as construction company and the turbine companies etc. 
Many holy and sacred sites are also situated along the River Basin of Tsa Chu, Tawang Chu and Nyamjangchu like- centuries old 200 feet span iron chain suspension bridge at Chaksam, hot water springs, Hromang/Surbi village pilgrimage site; centuries old Gorsam Chorten Stupa, Zemithang and Gomshing near Bletteng village etc. In Mon Tawang Region, the local people believed that transcendental deities, eminent local deities and spirits make their abodes in mountains, valleys, cliffs, trees etc. There are also many holy Mountain Sites at Rho village. The Tsa Chu II and other Hydro Electric Projects in Tawang will lead to disastrous consequences for the people, their culture, religion and ecology of the Region. The PDD submitted by the project authority has failed to highlight these socio-cultural impacts.  

10. Undermining Emissions from Tsa Chu II HEP   The project authorities falsely mentioned repeatedly in the PDD that the Tsa Chu II HEP is an emission free project reasoning that it is a renewable project and a fossil fuel free project. Several Studies worldwide have already confirmed that mega dams in tropical situation like the one in project area could be some of the worse emitters of Green House Gases (GHGs). Range of emissions, such as the emissions due to the destruction of forests that are GHG sinks when forests are destroyed for various project components, the emission from dam reservoir due to submergence of forests, the emissions due to boring of tunnels and the emission from sudden release of water from power houses, emissions due to numerous vehicles to be used in the construction  of reservoirs and boring of tunnels, emission due to felling of trees and destruction of forest by numerous dam workers etc are not taken into consideration and completed omitted deliberately in the PDD submitted by the project proponent.  

11. Impact of Road construction:  The Government of India takes initiative to widen the original Bhalukpong to Tawang Road through Sela Pass for transporting heavy equipments for the Tsa Chu II and other HEP planned in the region. If this particular stretch of the road is widened for the transportation of heavy equipments for construction of the Tsa Chu II HEP, it will have serious impact on the biodiversity and wildlife of the region . The road to Lumla which links the Tawang Chu II is very fragile and is landslide prone.  Every year during monsoon season rain washes away portions of the road.  
Projection of road building by the project authorities as part of social well being criteria  is completely misleading and meaningless as the people for their needs do not need this wide road, the widened road is only for the project. It also implies that the Government of India or for that matter the project authorities will never build roads if the area is not conducive for hydropower projects or other similar initiatives. Roads, Schools, health facilities are fundamental rights and needs of communities and has to be mandatorily created in far flung areas irrespective of whether the area has scope for companies to exploit its resources. 

We would like to reiterate that the Tsa Chu II HEP should not be eligible to receive carbon credits from CDM due to the aforementioned reasons. 

Himanshu Thakkar (ht.sandrp@gmail.com)					                 May 4, 2012
South Asia Network on Dams, Rivers & People (www.sandrp.in) 

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.