Annex 8, EB 66 states additionality related information cannot be treated as confidential, whereas the opening page of PDD states that the investment analysis calculation spread sheet be confidential!! 

How 300 MW, 330 MW, 660 MW and 135 MW power plants can be compared to the project with a capacity of 1196.85 MW. Methodology only says that the alternatives need not consist solely of power plants of the same capacity; it does not say that the alternatives of one third or one eighth of the capacity can be considered. The methodology should be studied carefully. 

All the explanations given in the PDD on the availability of natural gas are selective and it is does not give the true picture. If the DOE google the non-availability of gas for power projects in India, it will come across a number of websites which prove that natural gas is not available. The Ministry of Power in its letter dated March 14th states, “As per the information made available by MOP&NG regarding NELP gas the production is likely to go down by 15.03 mmscmd in 2012-13 and additional 3.42 mmscmd in 2013-14 against the availability of 42.67 mmscmd of gas in 2011-12. MOP&NG has not given any projections for the years 2014-14 and 2015-16. It is evident from above that no additional domestic gas is likely to be available till 2015-16. Hence, developers are advised not to plan projects based on domestic gas till 2015-16.” Why should the Government issue this notification if natural gas is available in plenty as PP says?

Another web site says, “Hyderabad-based Lanco Group has been unable to commission its 740MW power plant at Vijayawada in Andhra Pradesh because of the non-availability of gas. “We have invested close to Rs. 2,600 crore and the plant is ready for commissioning from the last two months,” a company official said, requesting anonymity. “We have not been able to sign a power purchase agreement as there is no assured fuel supply from the government despite several representations.” (http://www.livemint.com/2011/11/17233943/Decline-in-gas-supplies-makes.html).” Yet another website says, “Plant load factor—a key measure of efficiency at electricity generating units—of gas-fired projects declined to 57.93% in September compared with 67.16% in April” (http://www.eai.in/club/users/Nikoli/blogs/12122). There is an ICRA report on the NG availability in the website which contradicts the PP’s claim. Therefore, the PP’s argument on gas availability is not correct. Power generation is not the priority for gas allocation in the country now. 

Parent company’s Annual Report both 2009-10 and 2010-11 state that the natural gas is in short supply. DOE may refer to page 14 of 2009-10 Annual Report and page 31 – item G of 2010-11Annual Report. The statements made in the PDD are opposite to what is given in the Annual Report!
 
PP has selected the input paramters in such a way that the project becomes additional. There are reports available in the Published literature state that the cost differs only by 5-10% (see http://www.scribd.com/doc/3019711/Comparative-study-on-Subcritical-and-Super-Critical-Power-Cycles and also Mott Macdonald’s report available in the web). If the super critical project cost is Rs.52.18 mn., then the sub critical project cost cannot be less than  Rs.45 mn. PP has taken Rs.31.36 mn. and Rs.38.75 mn. for sub critical projects using imported coal and domestic coal. There is no reason why the project cost should differ so much between domestic coal and imported coal based sub-critical plants. On the other hand the cost of project is Rs.44.4 mn. Lanco Kondapalli project which is webhosted has taken the cost at Rs.35.18 mn for the project activity and Rs.40 mn. for sub-critical plant and Rs.49 mn. for super critical plant. Natural gas cost is taken at Rs.12/SCM whereas Lanco KOndapalli has taken 9.12/SCM. 

The logic given arguing the use of levelised cost as financial indicator in sec. B5 is strange. If this argument is correct, then all energy power projects – renewable and fossil fuel based - can adopt investment comparison analysis with levelised cost as the financial indicator. PPs can set up any other renewable energy based power project or fossil fuel based power projects. Hence, PP’s argument is wrong.  Step 1 of the methodology clearly states that the benchmark analysis should be used for additionality demonstration. Additionality tool gives benchmark only for NPV and IRR and not for levelised unit cost. Therefore, the argument given for levelised unit cost shows that the PP is misleading. DOE should insist on the benchmark analysis as explained in the additionality tool and not as interpreted by the PP. When Lanco Kondapalli has used benchmark analysis (using project IRR as financial indicator), and recently registered project 4419 has used project IRR and benchmark analysis, the argument given by the PP should be rejected. 

This company is a DISCOM in Dahej SEZ. Hence, the levelised cost is not the applicable tariff for the power sold. It should be the power tariff applicable to industries, as the project will sell power to industries in Dahej SEZ. If the benchmark analysis is adopted, with corrections in the project cost, alternatives, fuel cost and the tariff, this project cannot be additional