1. Page number 25 of PDD: the cost per MW of WHRB boiler have been taken from other registered PDD. This has not envisaged by Project Proponent to install coal based power plant in absence of project activity which is against EB guidelines.
2. Page number 30 of PDD: Sub step – 4 ( a) Sl.no. 12,13,15,16,17 is not as per EB 41 , annex 46 guidelines , moreover table doesn’t clarify that whether these organisation have applied for CDM applicability project or not .
3. Page number 31 of PDD : referring Time line table , serious CDM consideration is not as per EB 41 , annex 46 guidelines .
4. Page number 31: Point 6 of Timeline table – local stakeholder is a mandatory requirement how it is affecting the serious CDM consideration.
5. Page 31 of PDD : Chronology is not complete and inadequate (a) CDM consideration when , prior knowledge & board note decision basis (b) parallel efforts for availing CDM benefits (c) consultant appointment purchase order and project activity conflict (d) DPR proposed not mentioned in additionality section , however same has not been discussed in Time line serious CDM consideration section.
6. Page 32 of PDD : Emission reduction calculation , parameter BE elec , y = Fcap calculation not done .
7. Page 33 of PDD: method 3 not as per methodology. Also refer page 36, line 5 PDD mentioned exante calculation fcap is fixed as 1, however that needs to be calculated as ACM 12.
8. Refer methodology - Method 3 , case 1 , ACM 12 does not say that exante should be fixed ( not mention in method 3, case 1).
9. Page 39 of PDD , parameter Pey = 0 (have been taken zero ), However page 2 of PDD mentioned that post project scenario – A 1000 KV DG set will be used to provide auxiliary power requirement to operate the WECM based power plant.
10. Page 2 of PDD , post project scenario, paraline 1 , mentioned 10 MW CPP & the surplus electricity will be export to the grid , about power purchase agreement nothing have been mentioned in whole PDD.
11. Refer Baseline , coal based power plant is baseline & emission factor is also taken for (CBPP)there was coal based power plant has been considered in baseline , we want to ask when Project Proponent was exporting and importing from the grid why Coal based power plant has taken as a baseline .
12. Page 6 of PDD mentioned that expected residual lifetime, how it can be expected the residual lifetime when it is proposed activity.
13. Page 29, 30 of PDD refer table common practice source not mentioned.
14. Page 30 of PDD capping baseline emissions –as per methodology method 3 case number 1 no calculation required, however on page 36 refer line 3,4,5 of PDD contradictory.
15. Page 36 of PDD : PE AFy has been consider zero , PEELY – both do not mention about auxiliary power which will be used by 1000 KVA DG set
16. PE EL , import – type 2 project , (it is not specified PP will import power from grid or not )
17. Refer Page 15 of the methodology section (a , ii, Baseline emission from electricity (BE elec, y) for Type -2 activities , the electricity is generated from waste gas(utilized previous to implementation of project activity and vented /flared ) using more energy efficient equipment than that existing in the baseline captive power plant . however this is not the case as per PDD , Page 36 , PE EL import type 2 activity where as in the PDD it is not being mentioned type 2 activity as per methodology ACM 0012 ver 3
18. Section B .7.1 Page 40 of PDD frequency of calibration is not mentioned for
• Gross electricity
• Auxiliary consumption
19. Section B.7.1 – hasn’t mention the apportioning formula
20. B.7.1 – Fcap not mentioned in the monitoring section
21. Refer Page 48 of PDD lines 5 & 6 are contradictory with section B 7.1
22. Refer Page 48 of PDD lines 14 & 15 says that change in project boundary not accepted by UNFCCC, however it is envisaged that there will be change in Project boundary
23. 24 Refer Section D.1 page 50 of PDD that EIA still going on , however PDD has been webhosted without mentioning environmental impacts against the EB guidelines .
24. Annex 3 page 55 is wrong
25. annex 4, page 56 of PDD is referring B6.2 and B.7 which are not properly mentioned all the details
26. Annex 4 mentioned refer section B 6.2 and B7 as a reference however these sections are incomplete and not clarifying the monitoring plan transparently
Submitted by: Pragya Kaushik
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