Its a fake project...and wondering why SIRIM wanted to validate a project which is not fulfilling the guidelines and known to all the stake holders. Please consider all the valid GSC comments raised during the earlier web hosting period. Please consider all the GSC comments in below link:
http://www.global-warming.de/e/1908/

Regards
Green Energy  

Dear Sirs,
I agree that the start date of the project can be taken up as the Engineering, Procurement & Construction contract but it can be verified from the publically available data that many activities has been taken up related to the same project activity since 1996 and a example of the same can be verified from the following web-link: http://www.processregister.com/Vemagiri_Power/Project/pid16752.htm
Extract of which is as follows: “ Wednesday, July 24, 1996 Letter of Intent (LoI) received Monday, March 31, 1997 PPA (Power purchase agreement) signed Saturday, July 05, 1997 CCFI (Cabinet Committee on Foreign Investment) approval received Thursday, September 24, 1998.Date on which environmental clearance was received Thursday, January 14, 1999 CEA (Central Electricity Authority) approval received Sunday, December 31, 2000 Initial commissioning date “ Also it can be verified from the following links about the activities before 2000.Pre-feasibility report for the proposed station by NTPC
http://www.ntpc.co.in/Services_Offered/ownerengserv_exp.shtml
Therefore I request DOE to check the authenticity of the start date & consideration of CDM as the process appears that it’s been started long back since 1996 & would not qualify under Kyoto protocol. I would take this opportunity to appreciate RIT of UNFCCC for excellent reviewing of CDM projects. If the comments provided by me are addressed by the PP then I would request the DOE to send the clarification on the comments (before finalizing the validation protocol) and the consent of the stakeholder should be taken before it is sent for registration. This would ensure that the apprehension of stakeholder is addressed in very transparent & the purpose of GSP is met. If the above request is not met I would kindly request RIT of UNFCCC to review my comments & clarification on the comments critically before forwarding it for registration.
According to the various documents available the project proponent would be using NG or LNG also hence two types of leakages needs to be considered) Leakage emissions due to fugitive upstream CH4 emissions in the year y, 2) Leakage emissions due to fossil fuel combustion / electricity consumption associated with the liquefaction, transportation, re-gasification and compression of LNG into a natural gas transmission or distribution system during the year” The above stated emissions are mentioned in approved methodology AM0050, which is also a natural gas based methodology. So these emissions need to be accounted for AM0029 methodology also Hence the DOE is requested to raise a clarification to meth panel regarding the same on AM0029 methodology. If the project proponent explains that they would not use
LNG, hence they would not account for the above emissions, then the same should be taken up in writing by DOE and if PP uses LNG during the crediting period then the emissions would be accounted as zero. More-over the emission factor value available in the methodology AM0029 is according to the 1996 IPCC value that needs to be revised according to IPCC values2006 so DOE is again requested to raise a clarification on the methodology More-over the PP has taken value of
160tCH4/PJ instead of 296 tCH4/PJ(values mentioned in PDD to be taken up for projects in countries like INDIA) which according to the methodology is taken up under the following situation “The US/Canada values may be used in cases where it can be shown that the relevant system element (gas production and/or processing/transmission/ distribution) is predominantly of recent vintage and built and operated to international standards.” therefore I request DOE to validate the “gas production and/or processing/transmission/ distribution” is predominantly of recent vintage and built and operated to international standards based on the publically available data.
1) GMR over the past has engaged CDM consultants other than PWC so GMR might have approached other consultants also before approaching PWC so I would request the validator to check the correspondence with the other consultants also.
 2) The methodology AM0029 got approved in May 2006 and the PDD was submitted in July 2008(As per the chronology mentioned in the PDD) so what was project proponent pursing in the mean time of 2 years?? This actually raises question to the consideration of CDM in the project activity.
3) According to the methodology AM0029 applicability’s criteria “Natural gas is sufficiently available in the region or country, e.g. future natural gas based power capacity additions, comparable in size to the project activity, are not constrained by the use of natural gas in the project activity” But various documents are available in public domain(websites) which clearly states that NG is not available in surplus in AP although there has been discovery of NG in KG basin. Please find below the details which are available in public domain which clearly states non-availability of NG: I would like to request the DOE/UNFCCC to kindly review the following documents which clearly states that due to non-availability of NG which is highly contradictory to the applicability conditions of the AM0029.
 a)Although the project got commissioned in 2006 it was not operational for one year because of non-availability Natural Gas in the AP which can be substantiated by the following article from the newspaper (Live Mint) The same has been openly confirmed by the GMR Energy's CEO Raaj Kumar which is available in the public domain (from article in the newspaper) as follows: Links on the public domain:
http://www.livemint.com/2007/11/28144034/AP-govt-directs-gas-supply-to.html?d=1
http://www.equitybulls.com/admin/news2006/news_det.asp?id=21937
Article available in the public domain is as follows: “Languishing for a year for want of fuel, GMR group’s largest power plant at Vemagiri will be back on stream from January 2008, with the Andhra Pradesh government ordering diversion of gas to it from some operational power plants in the state. The 388.5 MW Vemagiri Power Generation Ltd would receive 1.12-1.15 million standard cubic metres of natural gas per day from Gail India. This would be sufficient for meeting up to 70% requirement of the plant in Andhra Pradesh. The gas supply to Rs1,500 crore power project is, however, for a period of four months only according to a communication sent by state authorities to GMR Energy. Commissioned in September 2006, the project was unable to generate even a single unit of electricity due to unavailability of gas, causing the promoters substantial revenue loss. When contacted, GMR Energy CEO Raaj Kumar confirmed the report. “The Andhra Pradesh government has conveyed willingness to supply gas to our Vemagiri project from January 2008. The plant was has not been operational for about a year because of non-availability of the fuel, due to which we incurred financial losses of more than Rs150 crore,” he said. Sources said the state government has directed four projects in the area, including those owned by Lanco Infratech and GVK Power, to generate power using naphtha. The resulting excess gas would be diverted to the
Vemagiri project.”
 b) The same problem of the availability of Natural Gas has also been expressed by the GMR’s senior manager which is again available in the public domain as the following text: Link:
http://www.domain-b.com/companies/companies_g/gmr_group/20071129_vemagiri.html
Article as available in the public domain is as follows: “The Hyderabad-based GMR Infrastructure Ltd has announced that its Vemagiri power plant in Rajahmundry district in the state of Andhra Pradesh will start generating power from January 2008 onwards, initially for a period of four months. This will be possible if the state government acts on its assurance to provide the plant 1.12 - 1.15 million cu. m. of natural gas per day from Gas Authority of India Ltd (GAIL). The 388.5 MW Vemagiri plant, which was commissioned in November 2006, works with combined cycle technology, and uses natural gas as fuel.
Under the power purchase agreement it has signed with APTRANSCO, Vemagiri Power Generation Ltd must supply power to the power distributor for a period of 23 years. According to a GMR senior manager, "The Andhra Pradesh government has conveyed its willingness to supply gas to our Vemagiri project from January, 2008. The plant has not been operational for about a year now, due to the non-availability of fuel. This is a very positive development and a win-win situation for both, the people of Andhra Pradesh as well as our company." The Vemagiri power plant is the largest amongst the three operational plants of GMR Energy. Its other power projects are:
• 200 MW LSHS-fired power plant in Chennai which commenced commercial operations in 1999 
• 220 MW Naphtha - fired power plant in Mangalore which commenced commercial operations in 2001 • 140 MW hydroelectric power plant on the river Alaknanda in Uttaranchal • 1050 MW coal based power plant in the Angul / Dhenkanal districts of Orissa 
• 160 MW hydroelectric power project in Tallong district in Arunachal Pradesh 
•1000 MW coal based thermal power project in Chattisgarh 
• 180 MW project on river Ravi in the Chamba district of Himachal Pradesh” Also it can be clearly verified from the following news in the public domain(from Business Standard article) that the Natural Gas would be diverted from Lanco project, located near Vijayawada, to Vemagiri project & then the Lanco project will operate on Naptha, this will further increase the emissions due to leakage. Link:
http://www.business-standard.com/india/storypage.php?autono=305806
Article: “Gas from Lanco Kondapalli to be diverted to GMR's Vemagiri project. In an extraordinary move, the Andhra Pradesh government has proposed to divert the natural gas being supplied to the 350-MW Lanco Kondapalli Power project to the 370Mw Vemagiri power project of the GMR group for at least three months from January next year. The Kondapalli project during the period will run on the expensive naphtha fuel. The government has decided to approach the ministries of power and natural gas to facilitate this arrangement so that the installed capacity of Vemagiri can be utilised to partly meet the growing energy demand during the ensuing rabi season. The Vemagiri project is lying idle for want of gas. The government has already discussed the issue with both the listed companies, officials told Business Standard. The reason for diverting gas from one plant to the other is: While the Lanco project, located near Vijayawada, has naphtha storage facilities to meet the fuel requirement for at least one week, there is no such storage facility available with the Vemagiri project. Moreover, the GMR group has informed that it was ready to build a storage facility for naphtha provided it was given an assurance that the plant would be run on naphtha for a relatively longer period. The GMR is the only company among the four new independent power producers (IPPs) to have signed a revised power purchase agreement (PPA) with the state power utilities by removing the alternate fuel clause, which entitles the
company to run on expensive alternate fuels in the absence of gas. The
government has proposed to buy 502 million units of power from the
Vemagiri plant during the three-month period. Lanco Kondapalli Power
chief executive officer Panduranga Rao said the project was
technically equipped to switch over to naphtha. Gas Authority of India
Limited (GAIL) currently supplies around 70 per cent of the allocated
gas to the Kondapalli plant as all the existing power plants are
operating at a lower plant load factor (PLF) due to shortage in gas
from the K-G Basin. The energy demand in the state is projected to
touch as much as 204 million units a day in March next year as
compared with around 180 million units in the corresponding period
last year. While the estimated additional costs on additional energy
purchases between November 2007 and March 2008 have been revised to Rs
1,681 crore from Rs 1,482 crore, the government has planned to spend
Rs 1,065 crore only on naphtha-based fuel, which works out at Rs 8.62
per unit. The government has also roped in the existing GVK and
Spectrum power projects to partly utilise their idle capacity by using
naphtha. This would be in addition to the additional power purchases
of 1,913 Mw from the Power Trading Corporation, and 824 mw from NTPC
planned during the November-March period. While about 81 Mw of
consumption was expected from the lift irrigation schemes
operationalised during the current financial year, the same is
expected to go up to 1,059 Mw when 11 more projects are scheduled to
be completed in the next financial year, the irrigation department
said.” So this would lead to increase in huge amount of leakage which
is not accounted for in the project emissions & nor does the
methodology allows for the same. 2) Also when the company can operate
a Naphtha based power plant in karnata with the levelized cost of Rs
10/kWh(as per the data available) than what is the problem with the
plant operating with the levelized cost of Rs 3.65/kWh (as mentioned
in the PDD) 3) Please find below the excerpts of CEO Mr. KVV Rao, CEO
power sector & Director from CNBC TV18 It has been clearly stated by
Mr. Rao that after the extension of the PPA “GMR is structuring in
such a manner that the losses would not be there for the company at
all” so I request DOE to check the financials mentioned in the PDD.
(Link: http://www.moneycontrol.com/india/news/business/jsureshkumarcfo/lancogmrenergyltdallottedcoalblocks/market/stocks/article/313581
) Exact statement available in the public domain is: “Q: At the moment
you are anchoring losses on the Vemagiri power project. By when do you
think GMR Energy itself will be making profits? A: GMR energy is
already profitable and it’s already making profits and it has always
been making profits. GMR Vemagiri project, yes, the PPA has been
extended over a period of 22 years and we are structuring in such a
manner that the losses would not be there for the company at all”. 4)
GMR over the past has engaged CDM consultants other than PWC so GMR
might have approached other consultants also before approaching PWC so
I would request the validator to check the correspondence with the
other consultants also 5) The methodology AM0029 got approved in May
2006 and the PDD was submitted in July 2008(As per the chronology
mentioned in the PDD) so what was project proponent pursing in the
mean time of 2 years?? This raises question to the consideration of
CDM

1. for a power plant of this scale..common practice analysis should
have been carried out for all india level. As there is not much
difference in regional sectoral policies, so i request DOE to get the
common practice done for the entire host country. 2. On page 28, the
efficiency of supercritical power plant should be taken as 43-44% and
not 36%.

1. on page 14 it is stated that one of the options is open cycle
turbine....i think this could be a realistic baseline scenario as
there are a lot of open cycle plants operational in India. This
project activity should only get the incremental benefits of
installing combined cycle as compared with open cycle. 2. PP has
discussed run of the river hydro as non-plausible...but at the same
time..storage based hydro could have been an option. Moreover, PP
itself is implementing a lot of hydro projects under GMR energy...thus
this could be a viable baseline option. 3. in levelized tariff
determination for baseline establishment, supercritical technology has
been considered as one of the viable options. But to my surprise, how
can this be considered "?? supercritial was not available in 2004,
i.e. when PP started the project activity. This technology was simply
not available in India at that time. Please dont try to fool the
stakeholders by giving such foolish arguments. Moreover, supercritical
is only available in the sizes like 660MW or 800 MW, how can this be
compared with the project which is in the range of 300-400MW. Mr.
Sanjay Narayan Barde..please dont try to fool anyone here....you
sincerely tell me and prove it by a credible evidence that you
considered this as an option in 2004. 4. For common practice..use the
recent data of 2007-08 and not 04-05. 5. Why multifuel firing plants
have been excluded from common practice? the plants which are running
on naphtha and NG would have even higher cost of power generation (due
to higher prices of Naphtha) so when they can survive without CDM
funds, then why does GMR requires the CDM funds?? Just to enhance the
profits?

due to enhaced availability of natural gas in very near future (coming
up of KG basing gas) in the project area, all the future capacity
additions would be gas based power generation. Hence there would be no
emission reduction happening due to the project activity.

Regards,

Nishant Tyagi