a)	Purpose of the project and how the proposed project activity reduces greenhouse gas emissions are not briefed in the PDD. Refer section A.2.
b)	How environmentally safe and sound technology is used for the project and details of technology transfer is not demonstrated adequately. Refer A.4.2
c)	Non- debundling nature of the project activity is not adequately justified as per EB54 Annex 13 (Debundling tool). Refer A.4.5.
d)	Please check the project boundary of the project activity is not based on the guidance of the applicable project category.
e)	Why has option A (Combined margin) been chosen for calculating emission factor is not justified. Refer B.6
f)	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. 
g)	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.
h)	Basis of choosing PLR as benchmark is not adequately demonstrated in the PDD 
i)	All the issues of investment analysis guidelines are not discussed in the PDD. Refer B.5. 
j)	Justification of parameters including O&M, insurance, loan, derating, escalation, and tariff are not demonstrated with justification. Refer B.5.
k)	Please provide a proof for proposed debt to equity taken at the investment decision. Refer B.5 
l)	Proof for PLF is not justified. 
m)	Date of offer is not provided  
n)	Project cost is not as per state norms. Refer B.5.
o)	O&M charges and its escalation is not as per  norms 
p)	IT rate assumed is not as per standard practice. 
q)	The application of MAT which is based on tax holiday while calculating WACC is not appropriate. 
r)	The PP has not explained and justified the key assumptions and rationale.
s)	The PP and consultant has not Illustrate in a transparent manner all data used to determine the baseline emissions.
t)	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.
u)	National policies and circumstances relevant to the baseline of the proposed project activity are not being summarized clarify.
v)	Explain and justify all relevant methodological choices for the proposed project activity
w)	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.
x)	CER revenue assumed is not consistently applied 
y)	Project cost is not as per  norms, DOE has to check and clarify.
z)	The project cost of the project should be based on offer and not on purchase order or tariff order.
aa)	O&M charges considered are on higher side. Pls. clarify. 
bb)	Benchmark calculation is not as per WACC tool (EB53 Annex 8)
cc)	Whether pre-tax or post tax IRR is selected is not demonstrated in the PDD.
dd)	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.
ee)	Prior consideration of CDM which is important for the determination of additionality is not documented in the section B.5 of the PDD.  
ff)	Date of PPA is not mentioned in the prior consideration of CDM 
gg)	The selection of simple OM based on low cost/must run resources is not adequately justified. Refer B.6.1
hh)	PP has not provided for each parameter the chosen value or, where relevant, the qualitative information.
ii)	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.
jj)	Explain and justify the choice for the source of data.
kk)	Ex-ante option of calculating OM is not adequately demonstrated. Step 3 of Refer B.6.1
ll)	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
mm)	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
nn)	The argument that CEA data for build margin is calculated as per Emission factor tool is not documented.  B.6.1
oo)	Spread sheet is not provided. The data should be presented in a manner that enables reproducing of the calculation of OM, BM, and CM. 
pp)	The justification of negligible project emissions for wind project is not as per AMS. I. D ver 16.0 EB 54). 
qq)	The emission factor value (Southern grid) for calculating baseline emission is wrong. Refer B.6.3
rr)	Net electricity should be continuously monitored, hourly measured and at least monthly recorded. Refer B.7.1
ss)	Metering regulations as per CEA norms is not adequately followed in monitoring plan. Refer B.7.2.
tt)	 Where the values have been measured, include a description of the measurement methods and procedures that comply with the guidance provided under general guidance.
uu)	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.
vv)	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. ).
ww)	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.
xx)	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?
yy)	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.
zz)	Clearly indicate the responsibilities for and institutional arrangements for data collection and archiving.
aaa)	The monitoring plan should reflect good monitoring practice appropriate to the type of project activity. Provide any relevant further background information.
bbb)	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.
ccc)	Project participants shall describe a project activity in a manner which allows the local stakeholders to understand the project activity.
BY Lawrance
















Hydro projects  (ACM0002)
Layout of power transmission lines from the generation to the consumer with the metering system is not shown. It should include the distance of transmission lines. DOE has to check the meters are installed to monitor electricity generated, net electricity used in Bhutan, net electricity exported to India. Pls. clarify.

The status of the construction & commission of the project is not stated in the PDD.
What is the basis of calculation for transmission loss, auxiliary consumption and transformer losses? What is the length of transmission line? 

The project is claimed to be run of river hydro project. So the calculation of reservoir is wrong. The criterion 3 is applicable only to pumped storage or accumulation hydro projects. What does reservoir refer to as per PP? 

The justification of opting out alternative 3 and alternative 4 is not justified adequately. It should be based on latest published data and figures. Refer B.4. Pls. clarify.
The bilateral agreements, PPA with India are the documents, DOE to check thoroughly

Date of investment decision should be at the time of DPR preparation. So, the basis of the cost escalation factors at a later date for CDM consideration is not valid. Pls. clarify. Refer B5. Step 3a. (Investment barrier).

How the CDM benefit will alleviate the technical barriers. As per additionality tool, if the barriers are not alleviated by CDM, then the project is not additional. 

Emission factor for state is not calculated.it should be made available to DOE to clearly validate this value.  Emission factor for India is not as per “Tool for emission factor for the system”. 

Electricity generated by the project, auxiliary consumption, transmission losses, transformer losses, net electricity exported to India, net electricity exported to the  grid. These parameters to be monitored continuously and to be cross checked with sale receipts. 

The Meth mentions that if investment analysis option is used, apply the following: 

a.	Apply an investment comparison analysis, as per Step 3 of the .Combined tool to identify the baseline scenario and demonstrate additionality., if more than one alternative is remaining after Step 2 and if the remaining alternatives include scenarios P1 and P3;

b.	Apply a benchmark analysis, as per Step 2b of the .Tool for the demonstration and assessment of additionality. If more than one alternative is remaining after Step 2 and if the remaining alternatives include scenarios P1 and P2.

But PP failed to apply like this. Pls. clarify.

PLF should be based on EB48 Annex 11guideline which says The plant load factor provided to banks and/or equity financiers while applying the project activity for project financing, or to the government while applying the project activity for implementation approval; (b) The plant load factor determined by a third party contracted by the project participants (e.g. an engineering company); But PDD doesn’t demonstrate how PLF has been arrived at. 

Whether PLF includes machine shutdown, machine availability. Whether grid availability is accounted for in the calculation of gross generation. To my surprise, critical parameter like PLF is missing from the PDD. How DOE has allowed this. 

Common practice analysis should be based on EB 39 Annex 10 (Additionality tool). Each step of common practice analysis should be fulfilled as per tool.

Emission reduction calculation should be based on EB 50 Annex 14 “Tool for emission factor for the electricity system.
Whether only one set of main meter, check meter set is enough for three projects. The monitoring parameters need to be checked by DOE.
The main meter and check meter technical parameters like accuracy level, make, etc. needs to be mentioned in the PDD.