exact kind of publication is not given in the report Give the xerox of the advertisement that was published for the stake holders information. Give the copy of any kind of material that was circulated during the stake holder presentation. list of participants needs to be given. There is no mention about the details of the persons raising query. 

•	Please explain location selection criteria
•	Does project owner had any kind of wind based energy business experience?
•	How many skilled/unskilled people from surrounding area were employed at this project during commissioning and operation as mentioned in social well being section? 
•	What is Complaint redress mechanism of a company, in case of villagers want to complain about wind mills?
From
Mahesh Pandya
Environmental Engineer
Paryavaran mitra
502, Raj Avenue, Bhaikakanagar road
Thaltej, Ahmedabad – 380059 India
Telefax - 079-26851321/1801

Gujarat forum on CDM respectfully submit the following comments on the Project Design Document (PDD) for 2.1 MW Wind Power Project by Kaizen Switchgear Products at village Khandvawadi, taluka Jasdan, Rajkot District of Gujarat.

	Project Activity’s contribution to sustainable developments – clearly indicate the activities of project which will be leading to sustainable development.
	Social well-being – What is project proponent’s role in improving infrastructural facility in surrounding area?
	Economic well-being - How many skilled/unskilled people from surrounding area were employed at this project during commissioning and operation as mentioned in social well being section? 
	Environment well-being – What will be the possible impact on water, air and land use in surrounding area due to project activity? Is there any impact on biodiversity of an area?
	Technological well-being - Does project owner had any kind of wind based energy business experience? And what about the sustainability of the technology used for power generation?
	Structure to solve complaints – In case the villagers have complain about windmills – do the company have any redress mechanism at ground level?
	Local stakeholder consultation – List of participants of meeting is not mentioned in PDD. There is no mention in which newspaper a public notice was published.  
	Host country Approval -  has not been obtained.

In light of the above mentioned observation, we like to give few suggestions 
•	The host country approval letter is to be obtained as a first priority.
•	The public notice is to be widely published so more stakeholders can present their view.
•	List of attendees must be enclosed in the local stakeholder consultation section to ensure transparency of the process.
•	While preparing monitoring report, local people’s view should be taken.
•	Although EIA is not necessary for windmills – SIA (Social Impact Assessment) must be done. Possible impact on bio-diversity should also be studied.


Falguni Joshi 
Gujarat forum On CDM (Email – gujaratforumoncdm@gmail.com) 
(Gujarat Forum on CDM – is a network of Individuals & Organisations working on Environmental issue & Monitoring of CDM projects in Gujarat, India.)

1.	The Sustainability parameters are not clearly stated:


Social well-being and economic well-being:
•	The participant has mentioned that it will contribute towards poverty alleviation through employment of local manpower during erection and operation of the power plant. It hasn't mentioned whom they will employ or how many locals they are going to employ. 
•	The PDD also states that the project has also resulted in improving in the infrastructure of the surrounding region. It would be pertinent to ask: What kind of infrastructure development are they talking about? Whom does it benefit? What are the parameters used to measure this improvement?

Economic well-being: 
•	From the PDD this aspect spells out clearly that the project intervention would benefit most the local contractors along with skilled technical personnel. 

Environmental well-being: 
•	Just putting in numbers of GHG emissions does not qualify the project to address environmental well-being. What about the ‘environmental pollution’ due to the project and the loss of local biodiversity?

Technological well-being:
•	The PDD states that wind energy based power generation is not a commercially viable technology in our country. (This is not quite true. About 50% of the CDM projects and other non-CDM projects are wind based).
•	The PDD also states that the incorporation of the project activity would act as the cornerstone towards promotion of such technology and help in enhancing the technical know-how about the project activity. However, the PDD needs to mention an estimate of the ‘land footprint’ for transporting and erecting each wind turbine.

 
2.	 Stakeholders and the Meeting:
           The PDD does not mention the list of stakeholders or a list of the attendees.
           It states that various stakeholders ‘identified’ by the participant attended the meeting. What are the criteria to be ‘identified’ as a stakeholder? The stakeholder consultation has to be a public platform where the local community is present and is given a complete understanding regarding CDM projects as well as a complete detail regarding CER’s.   

1.	Purpose of the project and how the proposed project activity reduces greenhouse gas emissions are not briefed in the PDD. Refer section A.2.
2.	How environmentally safe and sound technology is used for the project and details of technology transfer is not demonstrated adequately. Refer A.4.2
3.	Non- debundling nature of the project activity is not adequately justified as per EB54 Annex 13 (Debundling tool). Refer A.4.5.
4.	Please check the project boundary of the project activity is not based on the guidance of the applicable project category.
5.	Why has option A (Combined margin) been chosen for calculating emission factor is not justified. Refer B.6
6.	The justification of choosing IRR as financial indicator is not adequately justified. Whether it is equity or project IRR, pre-tax or post tax is not mentioned in the PDD. 
7.	The emission factor for the project electricity system can be calculated either for grid power plants only or, as an option, can include off-grid power plants.
8.	Basis of choosing PLR as benchmark is not adequately demonstrated in the PDD 
9.	All the issues of investment analysis guidelines are not discussed in the PDD. Refer B.5. 
10.	Justification of parameters including O&M, insurance, loan, derating, escalation, and tariff are not demonstrated with justification. Refer B.5.
11.	Please provide a proof for proposed debt to equity taken at the investment decision. Refer B.5 
12.	Proof for PLF is not justified. 
13.	Date of offer is not provided  
14.	Project cost is not as per state norms. Refer B.5.
15.	O&M charges and its escalation is not as per  norms 
16.	IT rate assumed is not as per standard practice. 
17.	The application of MAT which is based on tax holiday while calculating WACC is not appropriate. 
18.	The PP has not explained and justified the key assumptions and rationale.
19.	The PP and consultant has not Illustrate in a transparent manner all data used to determine the baseline emissions.
20.	Not demonstrated that the proposed project activity is additional as per options provided under attachment A to Appendix B of the simplified modalities and procedures for small-scale CDM project activities.
21.	National policies and circumstances relevant to the baseline of the proposed project activity are not being summarized clarify.
22.	Explain and justify all relevant methodological choices for the proposed project activity
23.	Data that is calculated with equations provided in the approved category or default values specified in the category should not be included in the compilation.
24.	CER revenue assumed is not consistently applied 
25.	Project cost is not as per  norms, DOE has to check and clarify.
26.	The project cost of the project should be based on offer and not on purchase order or tariff order.
27.	O&M charges considered are on higher side. Pls. clarify. 
28.	Benchmark calculation is not as per WACC tool (EB53 Annex 8)
29.	Whether pre-tax or post tax IRR is selected is not demonstrated in the PDD.
30.	The basis of calculation of benchmark is not documented in the section B.5. PLR is not acceptable benchmark for the project. WACC based on Government bonds, risk premiums should be taken.
31.	Prior consideration of CDM which is important for the determination of additionality is not documented in the section B.5 of the PDD.  
32.	Date of PPA is not mentioned in the prior consideration of CDM 
33.	The selection of simple OM based on low cost/must run resources is not adequately justified. Refer B.6.1
34.	PP has not provided for each parameter the chosen value or, where relevant, the qualitative information.
35.	Please Provide the actual value applied. Where time series of data is used, where several measurements are undertaken or where surveys have been conducted, provide detailed information.
36.	Explain and justify the choice for the source of data.
37.	Ex-ante option of calculating OM is not adequately demonstrated. Step 3 of Refer B.6.1
38.	Power plants registered as CDM project activities should be included in the sample group that is used to calculate the operating margin if the criteria for including the power source in the sample group apply. This argument is not demonstrated. B.6.1
39.	The selection of option (out of two) for calculating OM is not adequately documented with justification. CEA calculation is based on net electricity generation, the average efficiency of each power unit and the fuel types used in each power unit. Step 4 of B.6.1
40.	The argument that CEA data for build margin is calculated as per Emission factor tool is not documented.  B.6.1
41.	Spread sheet is not provided. The data should be presented in a manner that enables reproducing of the calculation of OM, BM, and CM. 
42.	The justification of negligible project emissions for wind project is not as per AMS. I. D ver 16.0 EB 54). 
43.	The emission factor value (Southern grid) for calculating baseline emission is wrong. Refer B.6.3
44.	Net electricity should be continuously monitored, hourly measured and at least monthly recorded. Refer B.7.1
45.	Metering regulations as per CEA norms is not adequately followed in monitoring plan. Refer B.7.2.
46.	 Where the values have been measured, include a description of the measurement methods and procedures that comply with the guidance provided under general guidance.
47.	Provide a detailed description of the monitoring plan, including an identification of the data to be monitored and the procedures that will be applied during monitoring.
48.	The PP should include sources of data that will be actually used for the proposed project activity (e.g. which exact national statistics, actual measurement etc. ).
49.	Where the parameters are to be measured in accordance with the guidance of the approved project category or the general guidance to the indicative methodologies, specify the measurement methods and procedures including accepted industry standards or national or international standards which will be applied, which measurement equipment is used, how the measurement is undertaken.
50.	Which calibration procedures are applied, what is the accuracy of the measurement method, who is the responsible person / entity that should undertake the measurements and what is the measurement interval?
51.	Please provide a detailed description of the monitoring plan. Describe the operational and management structure that the project operator will implement in order to monitor emission reductions.
52.	Clearly indicate the responsibilities for and institutional arrangements for data collection and archiving.
53.	The monitoring plan should reflect good monitoring practice appropriate to the type of project activity. Provide any relevant further background information.
54.	Please describe the process by which comments by local stakeholders have been invited and compiled. An invitation for comments by local stakeholders shall be made in an open and transparent manner, in a way that facilities comments to be received from local stakeholders and allows for a reasonable time for comments to be submitted.
55.	Project participants shall describe a project activity in a manner which allows the local stakeholders to understand the project activity.