1. Project participant use national emission factor 0.8 for emission reduction, but use transmission and distribution loss of some other grid. This is wrong. Transmission and distribution losses of grid should be of same grid as grid of emission factor. even if not transmission and distribution loss of more than 65% is a lie. Simple Web - Research show that commercial losses also added in the more than 65% loss of grid by project participants. Transmission and distribution losses in grid of state Orissa is less than 35% . transmission and distribution loss of india is less than 35%. Project proponents should not lie in PDD to inflate emission reductions unethically.

http://www.wescoorissa.com/cinfo/a33.htm

http://www.thehindubusinessline.com/2005/12/03/stories/2005120303300900.htm

http://in.biz.yahoo.com/090121/203/6zcgg.html

2. Project participant should write in PDD how result of survey would be responsible for reduction of broken CFL in the crediting year. How to ensure that selection of sample households were random is not describe in PDD. How the survey result calculate smaller emission reduction in crediting year is not describe in PDD. It is also possible that project participants would give good CFL in the household for survey and replace their CFL immediately after breaking and show that in a small sample no or less CFL breaks, when in reality a lot of CFL breaks in the rest of the project range. This will be a lie and inflate emission reductions unethically.

3. 7-8 PDD of Orissa on the same methodology and same project participants. this is debundling. Even if the project participants say that the distance between two projects in more than 1 km - it is debundling. DNV Validator should review their thinking to verify that the. 1 km option is for standing project, such as wind, hdyro, biomass. Project, which move like transport and distribution CFL can be designed to be away by 1 km from another project – so dnv should review this and say if this is debundling or not carefully. Participants of the project should apply am46 methodology for this large project - which is divided into many small projects

4. CFL-hour operation per year data. is not clear whether 3.5 hours is fixed or estimated. How will the project participants to ensure that they will not influence the households in the survey to use CFL for the more number of hours and then inflate emission reductions unethical. This should be set at only 3.5 hours and fix it for the credting year.

5. How to ensure that higher value CFL 100W not be distributed only to inflate emission reductions unethically. Project participant to describe in the PDD