First of all the project belongs to a public sector, the biggest alumunium producer of the country. And is one of the navratan companies of india, I assume its is a very very prestigious feature for a public entity in India. 
It was surprising to see that a power plant of 960 MW talks about not implementing an energy efficiency measures which will cost only 35 million, however the savings could go as high as 45 GW thermal. Under the section B.5, the PDD mentions technological barrier for the project. This was so startling, the biggest and a navratan company of india considers the project as a technological barrier. How can CDM overcome their technological barriers? CDM can only give them money the barriers would not have any effect what so ever. 
Coming to the investment part, where is the analysis, what are the sources. Has NALCO read the guidelines for general CDM SSC PDD filling? I don’t think they have and neither their consultants seem to have read the guidelines. The PDD is incomplete, let me state the words of the under para 5 of the General information on CDM SSC PDD guidelines “Project participants shall therefore, in accordance with paragraph 45 (b) of CDM M&P describe the choice of approaches, assumptions, methodologies, parameters, data sources, key factors and additionality in a transparent and conservative manner. The scope and detail of the description in the PDD should allow interested parties to reproduce the rationale of the project”.
I now ask the DOE to give me a assessment based only on the information under section B.5, there are no sources how these savings in terms of energy and monetary have come from. Just plain simple values have mentioned, so that the stakeholders are not able to comment on it. 
I know the DOE would not be interested in web-hosting the PDD again, however I ask the DOE if they are able to asses that the PDD is complete, kindly guides us how they are able to assess the completeness. If they ask any other information apart from that is now mentioned in the PDD, I ask the DOE to web-host it again so that the stakeholders are able to comment on it. 
At the present the PDD is incomplete and thus does not provide the stakeholders with an opportunity to comment specifically. I am not very hopeful for the DOE to work, however I hope the CDM EB takes care of such irresponsible PP, consultant and DOEs. I request the CDM EB to allow a reasonable chance to the stakeholders to comment on the project activity. 
Coming to the investment barrier part, God know how they have come to a saving of 3.78 million per year. I have a very very simple calculation (I hope atleast the DOE is able to understand this) 
The savings mentioned in the PDD is 45.05 GW thermal, now as it is a power plant I have converted the thermal part in to electrical savings for the sake of simplicity and conservativeness (the actual savings would be much much higher). 45.05 GW thermal is equivalent to 15 MW electrical, 
Now considering a 80% PLF of the power plant and 330 days of operation; 
15*330*24*80 = 9504000 kwh *1.77 rs . 
Savings = Rs. 16822080
Here it shows how wrong and fraudulent were the intentions of NALCO. For the DOE’s information the cost of electricity is taken as 1.77 is not out of nowhere like the values in PDD, the cost is directly taken from the annual report of NALCO. They have considered the cost of electricity as 1.77 per unit. 
So the savings of 16.8 million comes from this simple calculation, if we go to thermal part is am so sure the savings would be even higher. I hope the DOE is capable enough to assess the same. Now can NALCO carryout the actual payback period? It would be approximately 2 years which is way less than the 4 years mentioned in their PDD. I also know for a fact that the PPs change their whole benchmark, now they might go for a IRR or NPV analysis, again the stakeholder would be left out without being given an opportunity to present the actual facts. Can the DOE take assure the stakeholders comment in case of any change is taken care of???
I also urge the Management of NALCO (Mr. A. K Srivastav to be specific) not to indulge in such irresponsible manner. You are a Navratan of India, such lies portrays a very bad picture.