The project does not address properly the social and environmental well being, the without social sustainable project is highly questionable.  And the project needs to be reevaluated and PDD to be web hosted with all relevant data again. Section B.2 applicability condition as per meth is not properly considered, the justification provided is not acceptable, since there is no proper justification with evidences. Section B.4 base line scenario needs to more elaborate presently is highly confusing. Section B.5 to be reading since does not considered all the possibilities and options. DOE must investigate why the PP terminated prior DOE, LRQA must investigate all the corresponding DNV to UNFCCC. What due diligence and contract review LRQA done these projects. LRQA is taking up this project and cheated the whole system. In the interest of CDM community the great Eastern Energy should withdraw the projects from CDM project, since this is not suitable for CDM projects. If at all the PP wants to pursue this project as CDM as project there should update all the relevant details and webhosted it again. This project does not have real and continuous action, which must be pointed out DNV. May be this is one of this reason to terminated the DNV. The EIA report must be investigated and re-evaluated. The EIA report must be cross checked from a qualified and approved quality agency Delhi. The local stakeholder consultation process does not identify the people who have come for the meeting that mean the people who had attended and meeting has arranged by the PP and consultation process  is stage managed. The PDD must be re-webhosted with all the detail s of name and addresses. It is written section E, 41 participants attended from near by locality which is false and new PDD indicated must address. The DOE to check all those points before re-webhosting. It is very sad that no proper due diligence done by LRAQ before webhosting the PDD. 

The project does not address properly the social and environmental well being, the without social sustainable project is highly questionable.  And the project needs to be reevaluated and PDD to be web hosted with all relevant data again. Section B.2 applicability condition as per meth is not properly considered, the justification provided is not acceptable, since there is no proper justification with evidences. Section B.4 base line scenario needs to more elaborate presently is highly confusing. Section B.5 to be reading since does not considered all the possibilities and options. DOE must investigate why the PP terminated prior DOE, LRQA must investigate all the corresponding DNV to UNFCCC. What due diligence and contract review LRQA done these projects. LRQA is taking up this project and cheated the whole system. In the interest of CDM community the great Eastern Energy should withdraw the projects from CDM project, since this is not suitable for CDM projects. If at all the PP wants to pursue this project as CDM as project there should update all the relevant details and webhosted it again. This project does not have real and continuous action, which must be pointed out DNV. May be this is one of this reason to terminated the DNV. The EIA report must be investigated and re-evaluated. The EIA report must be cross checked from a qualified and approved quality agency Delhi. The local stakeholder consultation process does not identify the people who have come for the meeting that mean the people who had attended and meeting has arranged by the PP and consultation process  is stage managed. The PDD must be re-webhosted with all the detail s of name and addresses. It is written section E, 41 participants attended from near by locality which is false and new PDD indicated must address. The DOE to check all those points before re-webhosting. It is very sad that no proper due diligence done by LRAQ before webhosting the PDD. 

1)	DOE to ensure that the PDD values are consistent and ensure that the CDM project is a genuine project.
2)	DoE to check the Detailed Project Report and Feasibility Report which is submitted to the other agencies and Banks by Project owner and ensure that the values match with the DPR/FR  submitted to DoE also. 
3)	Careful study must be done so that the DPR/FR is not in different versions made and submitted with different purposes to different agencies, which is totally unacceptable, illegal and unethical. 
4)	Project owner should show some undertaking letter from bank manager to DoE stating that both DPR’s are same. These kinds of letters should not be accepted and entertained by DoE at face value, but must be checked independently. While collecting the DPR/FR from banks and other agencies, all DPR/FR pages should be counter signed by Banks and other agencies so that the real DPR/FR given to other parties by the PP/Consultant is same as the one submitted to DOE. 
5)	DPR/FR values must be probed fully. DOE must take a written undertaking from the PP/Consultant about the list of parties to whom this DPR/FR is submitted and for what purposes. Then DOE should cross check with all the parties and confirm that the same DPR/FR is submitted to all the parties correctly without any changes. DOE must not accept any reports and undertakings from PP/Consultant. DOE must make independent evaluation and use totally different parties without informing the PP or Consultant to cross check the facts. 
6)	DOE to write to the party who prepared the DPR/FR which is submitted to the banks and other agencies and the same is verified against the one submitted to the DOE by PP/Consultant. 
7)	DOE must not entertain this project any more if found the DPR/FR is tamprered with at any point in time. PP can not give different DPR’s and FR’s. They must submit only the one given to Banks and other agencies while obtaining loans and decision making time. 

8)	Has the PP considered the CDM revenues while envisaging the project? Without CDM the project was not viable, is it right? This project is having a debt component? Then how bankers or lenders gave the loan? Have the bankers or lenders considered the CDM revenues while agreeing to give loan to this projects? If not this project should be rejected right away by DOE by terminating the contract forthwith. If yes, where is the proof? What is the date of the evidence document from bank? Is this document printed now a days or earlier. DOE to independently check the same. If the document is  available from Bank it must be checked from all angles so that it is genuine and not forged and date changed by putting back dated. This is normally done, DOE to be aware of this please. Please check the communication the PP had during that time with banks, emails and postal receipts and the weights and dates mentioned on the receipts. Do not believe in courier bills and receipts since these can be cooked up easily. Insist on government owned postal service receipts only. If the project is fully equity project then on what basis the PP has invested full equity in to the project while considering the CDM revenue? DOE to check the same in detail and bring out the facts. Is there any past record of this PP to invest or not to invest at returns what he is talking about in this project? Proper evidences must be reviewed and digged out by the DOE and take decision on the project based on established facts. Do not ask documents from PP, DOE to collect the same from different sources to do independent evaluation. 

9)	Is the project equipment purchased second hand equipment or sourced from cheap foreign sources? If yes, the issue must be probed by DOE since invoices will invariably be inflated and forged. Total project costs mentioned by PP will not be the same as originals. Hence no additionality. These facts must be probed in full by DOE by checking all documents and money transactions along with bank statements and certified accounts by a legally acceptable financial analyst. 

10)	From DOE side which auditor has done marketing and business development for acquiring this business of validating this project? With whom he or she was co-ordinating at PP or CER buyer? The same person who has done the marketing and business development to acquire the business do validation or participate in any manner what so ever in the validation process? One cannot do like that. It is against the accreditation rules and norms followed since ages. DOE should send auditors from different offices or countries to do this validation audit. DOE must take care of impartiality and accreditation rules. Due to the targets set by the DOE managements auditors are doing marketing and meeting clients and giving promises that the project will be taken care. Is it acceptable and fair? This must be stopped. No auditor should do marketing. Only non-auditing staff should do marketing. DOE to ensure the same please. 


11)	If applicable only: Is these machines, equipment was a part of any bundle of CDM activity envisaged and developed earlier. DOE to check the same through independent sources also. Once some bundles are non-additional and getting negative validation from a DOE, PP is rolling out the same project as an individual project which is not a CDM project at all. DOE to verify the same from independent sources and also take undertaking in the form of an affidavit from the PP’s that any misrepresentation or false statement with respect this would attract strict legal action from UNFCCC and DOE. Furthermore the registered project must be de-registered in case of any future findings contradicting the submissions made by the project owner.  

12)	DOE to be more careful so that this is a genuine CDM project. What is the exact project cost? The project cost is covering what? Each value considered must be validated with proof. The machinery is second hand purchased or fresh and new from an OEM? In either case DOE to check all the quotations, proposals, purchase orders, invoices, way bills, transport bills, proof of payments like bank statements. DOE to check with banks by way of written confirmation the amount transacted, to whom the money is paid, when the money is paid, is the party paid is the correct party as shown in the purchase orders. It may so happen that the values, party names, dates are fabricated and misrepresented in this project. DOE should terminate their contract for this project immediately. This is the only way out to protect the value of CDM process. If the PP is purchasing second hand or second quality equipment and inflating the purchase order values and invoices, this must be probed thoroughly and real values to taken for additionality calculation. Then I’m sure the additionality is not there at all in such a situation.

13)	 How is the base line defined in this project? Is Base line hypothetically defined with no proper evidences and proper justification? In such case, DOE cannot take the base line as suggested by the PDD.  Please check that there are real emission reductions beyond the real and factual base line. It may so happen that this project qualifies for no CER’s. DOE cannot assume values and things as giving by this PP. Whatever values are considered throughout the project in all documents including the real DPR (not the one prepared for CDM, the one given to the banks and others), they must be validated, verified and double checked. Do not ask PP for DPR. Ask the parties who have been given DPR by the PP. Get directly from the bank and others by each page of the DPR and Feasibility report signed. Such document can be considered as a real DPR or FR. UNFCCC CDM process cannot be degraded by fabricating and misinterpreting the project base line and additionality.  

 	DOE to be more careful so that this is a genuine CDM project. What is the exact project cost? The project cost is covering what? Each value considered must be validated with proof. The machinery is second hand purchased or fresh and new from an OEM? In either case DOE to check all the quotations, proposals, purchase orders, invoices, way bills, transport bills, proof of payments like bank statements. DOE to check with banks by way of written confirmation the amount transacted, to whom the money is paid, when the money is paid, is the party paid is the correct party as shown in the purchase orders. It may so happen that the values, party names, dates are fabricated and misrepresented in this project. DOE should terminate their contract for this project immediately. This is the only way out to protect the value of CDM process. If the PP is purchasing second hand or second quality equipment and inflating the purchase order values and invoices, this must be probed thoroughly and real values to taken for additionality calculation. Then I’m sure the additionality is not there at all in such a situation.

 	 How is the base line defined in this project? Is Base line hypothetically defined with no proper evidences and proper justification? In such case, DOE cannot take the base line as suggested by the PDD.  Please check that there are real emission reductions beyond the real and factual base line. It may so happen that this project qualifies for no CER’s. DOE cannot assume values and things as giving by this PP. Whatever values are considered throughout the project in all documents including the real DPR (not the one prepared for CDM, the one given to the banks and others), they must be validated, verified and double checked. Do not ask PP for DPR. Ask the parties who have been given DPR by the PP. Get directly from the bank and others by each page of the DPR and Feasibility report signed. Such document can be considered as a real DPR or FR. UNFCCC CDM process cannot be degraded by fabricating and misinterpreting the project base line and additionality.  


 	Has the PP considered the CDM revenues while envisaging the project? Without CDM the project was not viable, is it right? This project is having a debt component? Then how bankers or lenders gave the loan? Have the bankers or lenders considered the CDM revenues while agreeing to give loan to this projects? If not this project should be rejected right away by DOE by terminating the contract forthwith. If yes, where is the proof? What is the date of the evidence document from bank? Is this document printed now a days or earlier. DOE to independently check the same. If the document is  available from Bank it must be checked from all angles so that it is genuine and not forged and date changed by putting back dated. This is normally done, DOE to be aware of this please. Please check the communication the PP had during that time with banks, emails and postal receipts and the weights and dates mentioned on the receipts. Do not believe in courier bills and receipts since these can be cooked up easily. Insist on government owned postal service receipts only. If the project is fully equity project then on what basis the PP has invested full equity in to the project while considering the CDM revenue? DOE to check the same in detail and bring out the facts. Is there any past record of this PP to invest or not to invest at returns what he is talking about in this project? Proper evidences must be reviewed and digged out by the DOE and take decision on the project based on established facts. Do not ask documents from PP, DOE to collect the same from different sources to do independent evaluation. 

 	Is the project equipment purchased second hand equipment or sourced from cheap foreign sources? If yes, the issue must be probed by DOE since invoices will invariably be inflated and forged. Total project costs mentioned by PP will not be the same as originals. Hence no additionality. These facts must be probed in full by DOE by checking all documents and money transactions along with bank statements and certified accounts by a legally acceptable financial analyst. 

 	From DOE side which auditor has done marketing and business development for acquiring this business of validating this project? With whom he or she was co-ordinating at PP or CER buyer? The same person who has done the marketing and business development to acquire the business do validation or participate in any manner what so ever in the validation process? One cannot do like that. It is against the accreditation rules and norms followed since ages. DOE should send auditors from different offices or countries to do this validation audit. DOE must take care of impartiality and accreditation rules. Due to the targets set by the DOE managements auditors are doing marketing and meeting clients and giving promises that the project will be taken care. Is it acceptable and fair? This must be stopped. No auditor should do marketing. Only non-auditing staff should do marketing. DOE to ensure the same please. 


 	If applicable only: Is these machines, equipment was a part of any bundle of CDM activity envisaged and developed earlier. DOE to check the same through independent sources also. Once some bundles are non-additional and getting negative validation from a DOE, PP is rolling out the same project as an individual project which is not a CDM project at all. DOE to verify the same from independent sources and also take undertaking in the form of an affidavit from the PP’s that any misrepresentation or false statement with respect this would attract strict legal action from UNFCCC and DOE. Furthermore the registered project must be de-registered in case of any future findings contradicting the submissions made by the project owner.  

 	DOE to ensure that the PDD values are consistent and ensure that the CDM project is a genuine project
 	DoE to check the Detailed Project Report and Feasibility Report which is submitted to the other agencies and Banks by Project owner and ensure that the values match with the DPR/FR  submitted to DoE also. 
 	Careful study must be done so that the DPR/FR is not in different versions made and submitted with different purposes to different agencies, which is totally unacceptable, illegal and unethical. 
 	Project owner should show some undertaking letter from bank manager to DoE stating that both DPR’s are same. These kinds of letters should not be accepted and entertained by DoE at face value, but must be checked independently. While collecting the DPR/FR from banks and other agencies, all DPR/FR pages should be counter signed by Banks and other agencies so that the real DPR/FR given to other parties by the PP/Consultant is same as the one submitted to DOE. 
 	DPR/FR values must be probed fully. DOE must take a written undertaking from the PP/Consultant about the list of parties to whom this DPR/FR is submitted and for what purposes. Then DOE should cross check with all the parties and confirm that the same DPR/FR is submitted to all the parties correctly without any changes. DOE must not accept any reports and undertakings from PP/Consultant. DOE must make independent evaluation and use totally different parties without informing the PP or Consultant to cross check the facts. 
 	DOE to write to the party who prepared the DPR/FR which is submitted to the banks and other agencies and the same is verified against the one submitted to the DOE by PP/Consultant. 
 	DOE must not entertain this project any more if found the DPR/FR is tamprered with at any point in time. PP can not give different DPR’s and FR’s. They must submit only the one given to Banks and other agencies while obtaining loans and decision making time. 

Through India china LRQA giving promises to the consultant and PP that the project will be handled in very quick time with positive out come. This is totally unprofessional and un acceptable to DOE. Further LRQA management is putting lot of pressure on the auditor to complete the validation and verification of the CDM project in very quick time with positive outcomes, how can auditor do that by LRQA management doing like this? One of the reason for LRQA management approach like this,  LRQA  is hiring auditors at more than the market salary’s and putting pressure on the auditors. This is totally unfair and unethical and violation of labour practices. CDM AP and EB must investigate the LR operation in detail to check the loading of auditors with respect their projects, handling CDM, VCS, ISO14064, ISO 14001, WECD, PoA, trading and other audits and services, CDM AP and CDM EB should not consider what LRQA gives the statement.  They must verify properly because LRQA is doing non CDM work, that means the auditors not only doing CDM audits and they doing lot of audits and works. Why should LRQA pay more money and spoil their personal life and CDM business and CDM projects. They should stop this practice immediately.

Do send some auditors who are not in the business development and marketing with the PP. LR should depute a team for any audit who is not involved in the marketing with the client. 
LR has degraded and bought disrepute to CDM process by giving all sorts of promises that they will complete the validation process in very short time. In the process neither they check any documents properly nor they any intention to do proper full scale validation. P.C.Acharya and his team’s only goal are to pass CDM validation for projects of his friendly consultants in the market quickly. Has LR management tracking and verifying what P.C.Acharya is doing? Or LR management is only interested in CDM revenues and do not care what P.C.Acharya is doing? What is the use of writing all sorts of procedures and singing all sorts of forms and undertakings when in the heart you have ulterior motives? How can he connive with consultants and offer certification services for CDM? Is it acceptable? LR says it is an old and reputed company. Is this the reputation you hold? Please answer how many visits P.C.Acharya made to clients places with consultants and gave promises to pass the CDM project before the contract is signed? They must come out with the list since PC Acharya joined LR. LR must answer this question and submit their reply to UNFCCC. To save LR reputation and in the interest of CDM process, PC Acharya must be stopped to involve in any manner what so ever whether off site or on-site, with respect to projects involving Ernst& Young consultants and China Light & Power group projects and other relevant projects  
How can the DOE auditors do marketing? In which accreditation rules it is allowed? Does LR management know this? If PC Acharya wants to do marketing he should be totally out of auditing process. LR global management has to decide now proper controls by not sending same individuals to a project work more than one time and in same city. Proper TR to be done by a different person. Not the same person doing TR because you have more work. What kinds of work planning you are doing? Where are your time allocations for Lead auditors, auditors, technical experts and technical reviewers considering the 5 day week, annual leaves etc? Is Audit team member doing TR not a practice in LR?  Is it ethical and acceptable as per accreditation norms? You tell you are an old and genuine company. Is it the way to work? You just stop misusing your DOE status.
DOE to check all purchase orders, feasibility reports, DPR’s submitted to all parties by the PP’s and comprehensively review them. DOE to check the original DPR’s, FR’s submitted by the PP to Banks and the other government agencies. DOE to obtain the same from the banks and government agencies with each page signed or else PP may fabricate and cook up the evidences. Only original documents to be checked along with payments made. All bank check copies, bank statements and written confirmation from banks must be obtained. Purchase order values are correct in this project? Any lack of doing all this proper and full work will mean LR is in connivance with PP for illegal and unethical validation work. Copy sent to UNFCCC. 

Do send some auditors who are not in the business development and marketing with the PP. LR should depute a team for any audit who is not involved in the marketing with the client. 
LR has degraded and bought disrepute to CDM process by giving all sorts of promises that they will complete the validation process in very short time. In the process neither they check any documents properly nor they any intention to do proper full scale validation. P.C.Acharya and his team’s only goal are to pass CDM validation for projects of his friendly consultants in the market quickly. Has LR management tracking and verifying what P.C.Acharya is doing? Or LR management is only interested in CDM revenues and do not care what P.C.Acharya is doing? What is the use of writing all sorts of procedures and singing all sorts of forms and undertakings when in the heart you have ulterior motives? How can he connive with consultants and offer certification services for CDM? Is it acceptable? LR says it is an old and reputed company. Is this the reputation you hold? Please answer how many visits P.C.Acharya made to clients places with consultants and gave promises to pass the CDM project before the contract is signed? They must come out with the list since PC Acharya joined LR. LR must answer this question and submit their reply to UNFCCC. To save LR reputation and in the interest of CDM process, PC Acharya must be stopped to involve in any manner what so ever whether off site or on-site, with respect to projects involving Ernst& Young consultants and China Light & Power group projects and other relevant projects  
How can the DOE auditors do marketing? In which accreditation rules it is allowed? Does LR management know this? If PC Acharya wants to do marketing he should be totally out of auditing process. LR global management has to decide now proper controls by not sending same individuals to a project work more than one time and in same city. Proper TR to be done by a different person. Not the same person doing TR because you have more work. What kinds of work planning you are doing? Where are your time allocations for Lead auditors, auditors, technical experts and technical reviewers considering the 5 day week, annual leaves etc? Is Audit team member doing TR not a practice in LR?  Is it ethical and acceptable as per accreditation norms? You tell you are an old and genuine company. Is it the way to work? You just stop misusing your DOE status.
DOE to check all purchase orders, feasibility reports, DPR’s submitted to all parties by the PP’s and comprehensively review them. DOE to check the original DPR’s, FR’s submitted by the PP to Banks and the other government agencies. DOE to obtain the same from the banks and government agencies with each page signed or else PP may fabricate and cook up the evidences. Only original documents to be checked along with payments made. All bank check copies, bank statements and written confirmation from banks must be obtained. Purchase order values are correct in this project? Any lack of doing all this proper and full work will mean LR is in connivance with PP for illegal and unethical validation work. Copy sent to UNFCCC. 

Through India china LRQA giving promises to the consultant and PP that the project will be handled in very quick time with positive out come. This is totally unprofessional and un acceptable to DOE. Further LRQA management is putting lot of pressure on the auditor to complete the validation and verification of the CDM project in very quick time with positive outcomes, how can auditor do that by LRQA management doing like this? One of the reason for LRQA management approach like this,  LRQA  is hiring auditors at more than the market salary’s and putting pressure on the auditors. This is totally unfair and unethical and violation of labour practices. CDM AP and EB must investigate the LR operation in detail to check the loading of auditors with respect their projects, handling CDM, VCS, ISO14064, ISO 14001, WECD, PoA, trading and other audits and services, CDM AP and CDM EB should not consider what LRQA gives the statement.  They must verify properly because LRQA is doing non CDM work, that means the auditors not only doing CDM audits and they doing lot of audits and works. Why should LRQA pay more money and spoil their personal life and CDM business and CDM projects. They should stop this practice immediately.