7.5 MW wind power project at Jaisalmer, India
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Host party(ies) India
Methodology(ies) AMS-I.D. ver. 16
Standardised Baselines N/A
Estimated annual reductions* 12,740
Start date of first crediting period. 01 Apr 12
Length of first crediting period. 10 years
DOE/AE SGS-UKL
Period for comments 31 Dec 10 - 29 Jan 11
PP(s) for which DOE have a contractual obligation Mangalam Cement Limited
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 (1163 KB)
Local stakeholder consultation report: N/A
Impact assessment summary: N/A
Submission of comments to the DOE/AE Compilation of submitted inputs:
PP has considered Transmission and wheeling losses as 4.4% and also INR 115/kW/Month. Isn't this double accounting??


The PP states that they have considered 80% accelerated depreciation. However the PDD 

is silent on the tax shielding as a result from accelerated depreciation.
PPs cleverly do not consider the accounting tax offsetting in their companies while 

calculating the IRR. This is evident from the recently registered projects and those 

requesting registration.  
The DOE is therefore requested to critically analyze how the accelerated depreciation 

benefit has been taken into account and confirm the accounting of the cash inflows as 

a result of the negative tax liability in the initial years. DOE should not be 

misguided by the financial presented by the PP or consultant which are custom made 

for CDM purposes and not the actual financial considered at the investment decision.
Note that considering cash inflows results in an increase in the IRR making wind 

projects a profitable venture.

Please also check the offer from WTG supplier and Purchase Order while validating the 

PLF. It may be so that the third party report may indicate a lower PLF.

Benchmark: How come a levered beta has been considered for determining the equity benchmark? A unlevered beta is more appropriate.
Leverered beta considers both the risks from equity and debt, however, a unlevered beta is equity specific risk. As the PP is comparing against an equity IRR a unlevered beta is the right beta for calculating the required return on equity. DOE must be well versed with the financials for validating the benchmark and financial analysis.

Stakeholder consultation:
No details provided on which all stakeholders attended the meeting. 


Submitted by: Babloo


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