It is evident from the PDD that the values are consistent and it is definitely forged and cooked up values to show a non CDM project as a CDM project. What is this? 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. After careful study of PDD it is found that DPR/FR is in different versions made and submitted with different purposes to different agencies which is totally unacceptable, illegal and unethical. PP/Consultant may 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. 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. In this particular project there is clear cut evidence that DPR/FR values are changed/ fabricated mischievously and intentionally. This 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. This project is a fabricated and fake CDM project and must be rejected by the DOE right away. DOE should not support this kind of projects otherwise CDM EB should suspend this DOE for at least one year. 

This is one of the very intelligently drafted PDD with no information given so that the PP can change any parameter during validation to make the project additional and get registered. 

Not only that no information has been given, even the conclusions drawn are incorrect. Thermal power generation constituting 69% of total installed capacity of NEWNE region is not an indication of national policy preferring fossil fuel based power plants. The share of thermal power capacity and preference of national policy to fossil fuel based power plants are two different issues. Former is due to historical reason and the latter is current policy. The conclusion drawn is totally incorrect.

PDD does not give the name and date of publication from which the benchmark – PLR- has been sourced. The PDD does not even give the chronology of events and how the project conforms to Annex 22, EB 49. How can the reader know that the PLR is correct? The start date of the project activity is 10/3/2011. Hence, the decision must have been taken not before January or February 2011. The PLR in January 2011 was not 13.25%. This rate was prevailing in 2008. Do you mean to say that a partnership firm took the decision 3 years ago to implement the project? This is misleading and nothing but a blatant attempt on the part of PP to make the project additional. 

Do you think that with whatever information you have given in the PDD, a reader can reproduce the worksheet and arrive at the same result? The PDD does not given even a single input parameter! The PDD has been webhosted only as a formality and not in the true spirit of inviting global stake holder comments. The ultimate objective is to somehow make the project additional. EB should not permit such webhosting and the concerned DOE should be questioned. 

This project must have commenced operation before March 31, 2011. The windpower projects are eligible for 100% depreciation (80% + 20%). So in the first year it is eligible for 50% depreciation, 40% in the 2nd year, 8% in the 3rd year and 1.6% in the 4th year. If the tax savings arising out of the depreciation benefit is taken into account and the cash out flow is deducted from the cash inflow of first year generation (remember India follows April – March financial year and tax computation is based on financial year), the project will become non-additional.

This project should be re-webhosted with all input parameters and DOE should not validate this project until re-webhosting is done. EB should take note of this and reject this proposal if it is submitted without re-webhosting