Comments on this project are similar to what i have made for Coastal Andhra Power, although  consultant has added detailed information supporting his case. I intend to reproduce my comments for this PDD.

1.	Financial indicator for this methodology is levelized energy production cost. You should disclose IRR data. Don’t say it is not a methodological requirement. I can’t buy that logic which most DOEs seem to make. It is not conservative assessing additionality on production cost basis alone. How could DOE confirm additionality without IRR being known? DOE should compare IRRs of Project and assessed plausible baseline before confirming additionality. Don’t make the same mistake which other DOEs have committed.

2.	I am against any merchant plant asking for Carbon funding because short-term trading of power is one of the most lucrative business option in India. Same holds true for a equity return guaranteed plant. I am aware Ultra Mega Power Projects does not allow merchant capacity creation. I want a declaration from the PP that there will be no merchant capacity from this project and submit the declaration to UNFCCC as part of the docket. Make it a monitoring parameter if it is required. 

3.        If you are establishing any merchant capacity as part of this project then, explain the basis how you have arrived at the merchant tariff and what is the impact of merchant tariff on IRR? 

4.	DOE should cross-check if meth given equation yields same value and verify PP presented correct data to international stakeholder community.

5.	Why was energy balance diagram not presented? I think this is one of the place where PDD filling guidelines were not followed. 

I am not able to upload the pdf file because of software problem is not sorted out yet. Please do send me an email if the pdf version of document is required for this comments. 

Comments on this project are similar to what i have made for Coastal Andhra Power, although  consultant has added detailed information supporting his case. I intend to reproduce my comments for this PDD.

1.	Financial indicator for this methodology is levelized energy production cost. You should disclose IRR data. Don’t say it is not a methodological requirement. I can’t buy that logic which most DOEs seem to make. It is not conservative assessing additionality on production cost basis alone. How could DOE confirm additionality without IRR being known? DOE should compare IRRs of Project and assessed plausible baseline before confirming additionality. Don’t make the same mistake which other DOEs have committed.

2.	I am against any merchant plant asking for Carbon funding because short-term trading of power is one of the most lucrative business option in India. Same holds true for a equity return guaranteed plant. I am aware Ultra Mega Power Projects does not allow merchant capacity creation. I want a declaration from the PP that there will be no merchant capacity from this project and submit the declaration to UNFCCC as part of the docket. Make it a monitoring parameter if it is required. 

3.        If you are establishing any merchant capacity as part of this project then, explain the basis how you have arrived at the merchant tariff and what is the impact of merchant tariff on IRR? 

4.	DOE should cross-check if meth given equation yields same value and verify PP presented correct data to international stakeholder community.

5.	Why was energy balance diagram not presented? I think this is one of the place where PDD filling guidelines were not followed. 

I am not able to upload the pdf file because of software problem is not sorted out yet. Please do send me an email if the pdf version of document is required for this comments.