12 MW Wind Mill Project of GSFC Ltd
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Host party(ies) India
Methodology(ies) AMS-I.D. ver. 16
Standardised Baselines N/A
Estimated annual reductions* 21,160
Start date of first crediting period. 01 Apr 11
Length of first crediting period. 10 years
DOE/AE Bureau Veritas India Pvt. Ltd.
Period for comments 03 Feb 11 - 04 Mar 11
PP(s) for which DOE have a contractual obligation Gujarat State Fertilizers and Chemicals 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 (1112 KB)
Local stakeholder consultation report: N/A
Impact assessment summary: N/A
Submission of comments to the DOE/AE Compilation of submitted inputs:
1.	If Suzlon is going to operate WEG on behalf of proponents, any agreement has been done for that?
2.	Please give break up of 743 millions INR to be invested in the region.
3.	In case of failure of project or any other accident, who would be responsible for it? Suzlon or proponents?
4.	What would be impact of negative environmental conditions of area upon project? What would be alternatives in that case?
5.	How many skilled/unskilled people from surrounding area were employed at this project during commissioning and operation as mentioned in social well being section? 
6.	List of stakeholders and minutes of stakeholder meeting is not attached with PDD.
7.	Stakeholder meeting was held in February 2009 so why it took so long for project to process for registration?

From
Hiral Mehta/Mahesh Pandya
Environmental Engineers
Paryavaran mitra
502, Raj Avenue, Bhaikakanagar road
Thaltej, Ahmedabad – 380059 India
Telefax - 079-26851321/1801
 
Submitted by: paryavaranmitra

•	Purpose of the project and how the proposed project activity reduces greenhouse gas emissions are not briefed in the PDD. Refer section A.2.
•	How environmentally safe and sound technology is used for the project and details of technology transfer is not demonstrated adequately. Refer A.4.2
•	Non- debundling nature of the project activity is not adequately justified as per EB54 Annex 13 (Debundling tool). Refer A.4.5
•	Why has option A (Combined margin) been chosen for calculating emission factor is not justified. Refer B.6
•	The justification of choosing IRR as financial indicator is not adequately justified. Whether it is equity or project IRR, pre-tax or post tax is not mentioned in the PDD. 
•	All the issues of investment analysis guidelines are not discussed in the PDD. Refer B.5. 
•	Justification of parameters including O&M, insurance, loan, derating, escalation, and tariff are not demonstrated with justification. Refer B.5.
•	Please provide a proof for proposed debt to equity taken at the investment decision. Refer B.5 
•	Proof for PLF is not justified. 
•	Date of offer is not provided  
•	Benchmark calculation is not as per WACC tool (EB53 Annex 8)
•	Date of PPA is not mentioned in the prior consideration of CDM 
•	The selection of simple OM based on low cost/must run resources is not adequately justified. Refer B.6.1
•	Ex-ante option of calculating OM is not adequately demonstrated. Step 3 of Refer B.6.1
•	Power plants registered as CDM project activities should be included in the sample group that is used to calculate the operating margin if the criteria for including the power source in the sample group apply. This argument is not demonstrated. B.6.1
•	The selection of option (out of two) for calculating OM is not adequately documented with justification. CEA calculation is based on net electricity generation, the average efficiency of each power unit and the fuel types used in each power unit. Step 4 of B.6.1
•	The argument that CEA data for build margin is calculated as per Emission factor tool is not documented.  B.6.1

Submitted by: Fleming


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