It looks like from the PDD the start date of the project is tampered for sure. This must be verified and let the truth come out. The culprits of forgery and malpractices must be brought to book. Why DOE has taken up such a bad project? Is there any pressure on DOE or some cake offered to DOE? They DOE must terminate this project immediately. DOE to check the offer letters originals and get the same verified in writing from the OEM’s and submitted parties. Where is the OEM supplier agreement original? DOE to check for the same. Is it prepared later with date and amounts changed to suit the project workings? For sure yes. This is not acceptable. 
DOE to check all purchase orders originals with the receiver of purchase orders i.e. the supplier of equipment. This PO confirmation to the DOE must be in writing from a board level person of the equipment supplier to avoid any malpractices and forgery. Then DOE to check for the invoices dates, payment amounts and date of payments made with all original documents and reconfirm with the parties involved and the banks for the accuracy of amounts, dates and parties involved. Same analysis and due diligence work to be repeated for “Notice to Proceed” as written in the case of Purchase order as above. DOE to check all “Notice to Proceed” originals with the receiver of “Notice to Proceed” i.e. the supplier of equipment or Engineering Procurement & Construction Contractor. This “Notice to proceed” and EPC contract confirmation to the DOE must be in writing from a board level person of the equipment supplier and EPC contractor to avoid any malpractices and forgery. Then DOE to check for the invoices dates, payment amounts and date of payments made with all original documents and reconfirm with the parties involved and the banks for the accuracy of amounts, dates and parties involved.
 DOE to check OEM supplier agreements, EPC contractor agreements, “Notice to proceed” letters, and Invoices raised. I’m sure DOE will catch the malpractices happened in this project. All the parties involved in this matter must be brought to justice. DOE must not support this kind of forgeries and malpractices. DOE cannot afford to close their eyes to this kind of malpractices. 

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. 

It looks like from the PDD the start date of the project is tampered for sure. This must be verified and let the truth come out. The culprits of forgery and malpractices must be brought to book. Why DOE has taken up such a bad project? Is there any pressure on DOE or some cake offered to DOE? They DOE must terminate this project immediately. DOE to check the offer letters originals and get the same verified in writing from the OEM’s and submitted parties. Where is the OEM supplier agreement original? DOE to check for the same. Is it prepared later with date and amounts changed to suit the project workings? For sure yes. This is not acceptable. 
DOE to check all purchase orders originals with the receiver of purchase orders i.e. the supplier of equipment. This PO confirmation to the DOE must be in writing from a board level person of the equipment supplier to avoid any malpractices and forgery. Then DOE to check for the invoices dates, payment amounts and date of payments made with all original documents and reconfirm with the parties involved and the banks for the accuracy of amounts, dates and parties involved. Same analysis and due diligence work to be repeated for “Notice to Proceed” as written in the case of Purchase order as above. DOE to check all “Notice to Proceed” originals with the receiver of “Notice to Proceed” i.e. the supplier of equipment or Engineering Procurement & Construction Contractor. This “Notice to proceed” and EPC contract confirmation to the DOE must be in writing from a board level person of the equipment supplier and EPC contractor to avoid any malpractices and forgery. Then DOE to check for the invoices dates, payment amounts and date of payments made with all original documents and reconfirm with the parties involved and the banks for the accuracy of amounts, dates and parties involved.
 DOE to check OEM supplier agreements, EPC contractor agreements, “Notice to proceed” letters, and Invoices raised. I’m sure DOE will catch the malpractices happened in this project. All the parties involved in this matter must be brought to justice. DOE must not support this kind of forgeries and malpractices. DOE cannot afford to close their eyes to this kind of malpractices. 

1.	Please explain technological well being eligibility in detail.
2.	How this project can be considered as bundled project when area and project proponent are different?
3.	Does project owner had any kind of wind based energy business experience?
4.	How many skilled/unskilled people from surrounding area were employed at this project during commissioning and operation as mentioned in social well being section? 
5.	List of stakeholders and minutes of stakeholder meeting is not attached with PDD.
6.	Why for same region separate stakeholder meetings were scheduled?

From
Mahesh Pandya
Environmental Engineer
Paryavaran mitra
502, Raj Avenue, Bhaikakanagar road
Thaltej, Ahmedabad – 380059 India
Telefax - 079-26851321/1801
 

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. 

1.	Non de-bundling nature of the project is not justified properly in the section A.4.5. DOE has to validate whether there is no registered project with the PP nor there is an application for registration of any project. PP doesn’t confirm in the PDD that there is no application for registration. 
2.	Operating margin, build margin, combined margin is not as per “Tool for emission factor for an electricity system”. The tool is not used at all. Pls. calculate combined margin as per the tool. Pls. justify that grid emission factor calculated is as per CEA data latest version.
3.	The date of investment decision is not provided transparently. It should be used generously in the PDD for clarity. 
4.	How risk free return, market return and beta is calculated is not documented in the PDD. How many companies included in the calculation of beta. Government bond rates should be taken from the date of inception of BSE 500. 
5.	The application of MAT which is based on tax holiday while calculating WACC is not appropriate. 
6.	The project cost of the project should be based on offer and not on purchase order or tariff order.
7.	O&M charges considered are on higher side. Pls. clarify. 
8.	Justification of tariff rate is not provided.
9.	Justification of PLF is not provided. There is a huge difference between two projects. It should be based on guideline as provided by latest EB report. Pls. clarify. DOE has to validate this.
10.	A notification has to be sent to government of India and EB stating the starting of the project. It is not clear from the PDD whether it is done since this aspect is not provided in the PDD. Pls. clarify. 
11.	The date of board meeting, investment decision meeting, and offer date are not provided in the chronology of events column. 

 There can not be more than  months gap between the proven mile stones of action? Has the PP discussed this CDM project issue in the relevant board meetings? If yes, where are the certified evidences? The validation process must stop immediately for this project. What kind of due diligence the DOE has conducted before taking up this validation? Its shame on DOE! This DOE should be suspended for this kind of activities. Why to sign this kind of projects and then get sold to some bad CDM consultants and investors? Is this a proper DOE business? 

This is not a CDM project. This is  a cooked up, fabricated and fake CDM project. The start dates are not correct. DOE to check with the equipment supplier and get a written confirmation of the purchase orders. Same way to check for “notice to proceed” and work contracts. No real and continuous action. 

•	The IRR does not explain the basis taken for project cost?. 
•	Also the chronology of events do not mention any offer letter?.. Then how DoE has made due diligence that the project confirms to UNFCCC guidelines?. 
•	There are neither links nor documents mentioned for proof of the parameters assumed for the IRR? 
•	How is PLF estimated to be in accordance to UNFCCC guidelines. 
•	Also the tariff rate has been assumed based on rate existing at investment decision..but does it account for the escalation and why it has been assumed at a flat rate?..