The explanation and dismissal of alternatives are not in compliance with the Methodology. As per the Methodology alternatives can be excluded only if they are not in compliant with all applicable legal and regulatory requirements. Alternatives which are compliant with applicable legal and regulatory requirements, The CDM-PDD should submit for validation a clear comparison of the financial indicator for all scenario alternatives. Therefore removal of alternatives citing reasons such as uncertainty about the availability, period of availability is not conforming to methodological requirements, though it helps the consultant from providing calculation. The presentation does not satisfy ACM 0013
Uncertainty about the availability, period of availability and comparatively higher cost are not given as acceptable reasons for dismissing the alternative in the methodology. The explanation given for dismissing Naphtha, Fuel Oil and Diesel certainly do not fulfil methodological requirements. Reason given for not considering nuclear option is not correct.
Therefore, restricting the alternatives to sub critical (probably linkage plant as nowhere it is stated whether it is pit head, linkage or imported coal based plant) is not correct.
Publications, which are available in web indicate the difference in the capital cost between sub critical and super critical projects is not more than 15%. In this case, the difference is 30% more. Moreover, Expert Committee on Fuels has given a cost of Rs.4 core per MW in 2004. How is it possible for the company to set up the sub critical project at Rs.4 crore per MW 7 years after the publication of the report?
When the sub critical plants even in public sector are achieving capacity utilisation of more than 90%, why is the PLF restricted to 85% in the PDD?
In Sec. B.5 and LCEP is used to demonstrate additionality. Is LECP is considered appropriate financial indicator for the project type and decision making context? This does not satisfy additionality tool or the methodology.
This is not a bid based project. The tariff will be determined by either APERC or CERC on cost plus basis. Why should the company require CDM benefits?