9.9 MW Wind power Project by Texmo Industries at A.P. and Gujarat, India
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Host party(ies) India
Methodology(ies) AMS-I.D. ver. 16
Standardised Baselines N/A
Estimated annual reductions* 17,590
Start date of first crediting period. 11 Aug 11
Length of first crediting period. 10 years
DOE/AE Bureau Veritas India Pvt. Ltd.
Period for comments 18 May 11 - 16 Jun 11
PP(s) for which DOE have a contractual obligation Texmo Industries
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 (950 KB)
Local stakeholder consultation report: N/A
Impact assessment summary: N/A
Submission of comments to the DOE/AE Compilation of submitted inputs:
It is evident from the PDD that the values are consistent and it is definitely forged and cooked up values to show a non CDM project as a CDM project. What is this? DoE to check the Detailed Project Report and Feasibility Report which is submitted to the other agencies and Banks by Project owner and ensure that the values match with the DPR/FR  submitted to DoE also. After careful study of PDD it is found that DPR/FR is in different versions made and submitted with different purposes to different agencies which is totally unacceptable, illegal and unethical. PP/Consultant may show some undertaking letter from bank manager to DoE stating that both DPR’s are same. These kinds of letters should not be accepted and entertained by DoE. While collecting the DPR/FR from banks and other agencies, all DPR/FR pages should be counter signed by Banks and other agencies so that the real DPR/FR given to other parties by the PP/Consultant is same as the one submitted to DOE. In this particular project there is clear cut evidence that DPR/FR values are changed/ fabricated mischievously and intentionally. This must be probed fully. DOE must take a written undertaking from the PP/Consultant about the list of parties to whom this DPR/FR is submitted and for what purposes. Then DOE should cross check with all the parties and confirm that the same DPR/FR is submitted to all the parties correctly without any changes. DOE must not accept any reports and undertakings from PP/Consultant. DOE must make independent evaluation and use totally different parties without informing the PP or Consultant to cross check the facts. DOE to write to the party who prepared the DPR/FR which is submitted to the banks and other agencies and the same is verified against the one submitted to the DOE by PP/Consultant. This project is a fabricated and fake CDM project and must be rejected by the DOE right away. DOE should not support this kind of projects otherwise CDM EB should suspend this DOE for at least one year. 
Submitted by: zhong zhou li

The input parameters presented does not contain the project cost or financing pattern. How can a reader use the financial parameters and arrive at the same results? It has become common nowadays to webhost the PDD with as little information as possible so that the input parameters can be changed later to make the project additional. EB should take note of this and direct DOEs not to webhost such PDDs. This PDD should not be accepted and re-web hosted to enable the global stake holders to comment 

The tariff for wind power projects in Gujarat is 3.56/kWh and not Rs.3.55/kWh

It is presumed that the O&M cost includes service tax as it is quite high

AP windmills were commissioned in 2009-10; Gujarat windmills in 2010-11. Wind projects are set up only for tax benefits. AP windmills are eligible to get 50% depreciation benefit and Gujarat windmills are entitled to 100% depreciation.  

DOE should ensure that the tax savings on account of depreciation (the project is eligible for 100% depreciation - 80% +20% of additional depreciation) has been taken into account in cash flow.
  
AP windmills commenced generation in 2009-10 and investment had also taken place in the very same year. Similarly, Gujarat purchase orders for Gujarat windmills were issued in 2010-11 and they commenced in the very same year. Therefore, the cash outflow for AP windmills should be accounted in 2009-10 and Gujarat windmills in 2010-11 and should be deducted from cash inflow of respective years. DOE should ensure that this is done.  If it is not done, it is incorrect and IRR is artificially brought down

DOE should not allow any other expenditure other than O&M cost and insurance in financial indicator calculation 

There seems to be no uniformity in PLF at all. Projects located in same district assume PLF which makes the project additional. GERC has recommended PLF of 23%. It does not provide for any losses. APERC has recommended PLF of 
24.5%.  This order also does not provide for any transmission loss and auxiliary consumption. Here the project developer in his wisdom considers not only 22% PLF as against 23% and 24.5% recommended by ERCs, but also provides for 2% transmission loss and auxiliary consumption over and above that! DOE should check the actual generation achieved by the project since commencement of generation till June 2011 and see whether on year to year basis the PLF is as low as 21%. There is no justification for taking 22% PLF. 

EB has recommended return on equity of 11.75% for energy project. The calculation reveals benchmark of 14.58%. This is very high.

With all these corrections, IRR cannot be less than 11-12%. DOE should check this

Is the organization a company? How can there be Board resolution?

Karthikeyan
Submitted by: Karthikeyan


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