•	Why has option A (Combined margin) been chosen for calculating emission factor is not justified. Refer B.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. 
•	Basis of choosing PLR as benchmark is not adequately demonstrated in the PDD 
•	All the issues of investment analysis guidelines are not discussed in the PDD. Refer B.5. 
•	Justification of parameters including O&M, insurance, loan, derating, escalation, and tariff are not demonstrated with justification. Refer B.5.
•	Please provide a proof for proposed debt to equity taken at the investment decision. Refer B.5 
•	Proof for PLF is not justified. 
•	Date of offer is not provided  
•	Project cost is not as per RERC norms. Refer B.5.
•	O&M charges and its escalation is not as per RERC norms 
•	IT rate assumed is not as per standard practice. 
•	CER revenue assumed is not consistently applied 
•	Benchmark calculation is not as per WACC tool (EB53 Annex 8)
•	Date of PPA is not mentioned in the prior consideration of CDM.
•	The selection of simple OM based on low cost/must run resources is not adequately justified. Refer B.6.1
•	Ex-ante option of calculating OM is not adequately demonstrated. Step 3 of Refer B.6.1
•	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
•	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
•	The argument that CEA data for build margin is calculated as per Emission factor tool is not documented.  B.6.1
•	The emission factor value (NEWNE) for calculating baseline emission is wrong. Refer B.6.3
•	Net electricity should be continuously monitored, hourly measured and at least monthly recorded. Refer B.7.1
•	Metering regulations as per CEA norms is not adequately followed in monitoring plan. Refer B.7.2.

I.	My query is regarding the “Applicability criteria of the methodology”, 

1.	The project activity involves installation of a wind power project. The project activity does not displace electricity from a distribution system. Thus, AMS IF is not applicable to this project activity. 

The consultant/PP has mentioned the above for the 1st Applicability criteria of the methodology. I want to know how the DOE has validated this. 

When you’re selling/wheeling the generated electricity to Grid? What will happen, naturally you are displacing the grid, correct?

In the PDD you are telling that GRID is dominated by FOSSIL fuel fired power plants and you are also using Grid emission factor to calculate the CER’s, then how the DOE is validating this? I am confused!!!

If you declare/claim that “The project activity does not displace electricity from a distribution system” Then what the HELL it is doing? How can you claim CER’s?

Come on Guy’s answer me; don’t just write it as an irrelevant question and close the issue, EB member’s please look in to this.

2.	The project activity is a new power plant installed at a site where there was no existing renewable energy power plant. Thus, the project activity complies with clause (a) of the applicability criteria. 

How can you declare that?  Are you guy’s JOKING n think EB and others as FOOLs to believe whatever you write? 

Mokla, Sonu and Serava villages of Jaisalmer, Rajasthan is having good PLF, that’s why there are many WTG in these sites and even PP has put up this WTG’s here. Then how can you tell this? What the DOE is doing? How are you validating this? What’s happening? 

I request the EB to look into these meth issues; it’s of a serious nature.

II.	post tax project IRR 

•	The project IRR is 7.10% against a benchmark of 13.90%. 

•	My Goodness! Then why did the PP take up this project? Or the consultant is doing a MOCKERY of EB guidelines?

•	Why? Even with CDM benefits these projects will never cross Benchmark. Then why the PP is investing in such kind of projects. 

III.	Stake holder meeting is conducted by OEM personnel’s, what about the PP and consultant? Why they did not attend the meeting? Was a meeting really happened or not?

Then what is the need of a stake holder meeting? How the DOE is validating, is he really following the EB guidelines or blindly following the Consultant?

IV.	How can you take D/E ration “Based on investment decision made by management of MWP”. Are you aware of EB guidelines? What the DOE is doing? How did you validate this? 

V.	When PP is capable of pumping in so much money for this project, why do you need CDM revenue?  Even when with CDM benefits the project will never cross Benchmark!

The point to be noted is that the wind projects are mainly installed considering CDM revenues and offsetting of tax liability of the company as a result of accelerated depreciation of 80%.

PPs cleverly do not consider the accounting tax offsetting in their companies while calculating the IRR. This is evident from the recently registered projects and those requesting registration.

The DOE is therefore requested to critically analyze how the accelerated depreciation benefit has been taken into account and confirm the accounting of the cash inflows as a result of the negative tax liability in the initial years. DOE should not be misguided by the financial presented by the PP or consultant which are custom made for CDM purposes and not the actual financial considered at the investment decision.

Note that considering cash inflows results in an increase in the IRR making wind projects a        
          Profitable venture.

It is the responsibility of DOE to conduct proper due diligence and contract review before signing any contract. Now DOE to explain what it has done this project case. Why a DOE should work this kind of cooked up and fake CDM projects. How many genuine projects this consultant has done till to date? This consultant is responsible for corrupting and spoiling the whole CDM business in India. Why this consultant is not working like any other consultant in the market? Why he is web hosting only projects which were rejected, with drawn, forged (documents changed and forged) and fully problematic projects? 
The Managing Director/CEO (Rambabu) of this consulting company called General Carbon/General carbon pte Ltd. is fully responsible for spoiling the CDM consulting business in India. He is totally unprofessional and unethical. He never did any work in a professional and ethical manner in his working. He started his own consulting company when he was working with PWC by violating the contract with PWC. Then later on he started CantorCO2e in India. They gave all sorts of wrong promises to clients and finally many of the clients are disappointed and lost money who signed with CantorCO2e. While leaving the CantorCO2e while working in CantorCO2e itself he promoted his own company General Carbon Advisory Services Pvt. Ltd and made the clients sign with General Carbon. 
What is this? After he left CantorCO2e employment he took away most of the projects and clients of CantorCO2e by violating all his contract terms, employment conditions and established business ethics. CantorCO2e is pursuing this person legally and he should not be left free. If he thinks he is intelligent he should develop businesses on his own and not rob like this. It is shame that project owners and DOE’s are working with such illegal, unethical, unprofessional and cheating companies and individuals.
General Carbon/ General carbon pte Ltd. is intentionally quote very low to kill completion and also the CDM business as a whole. Only they wish to be in the market, nobody else should work as a consultant in the market. They should explain why it is so. 
 Every project owner and DOE whoever is working with General Carbon should introspect, understand the implications and stop working with General Carbon. General Carbon/ General carbon pte Ltd. is built on totally wrong foundation with robbed clients, wrong promises, cheating the system, deceiving, corrupting the full CDM business overall. One should be ashamed of working with General Carbon in what so ever manner. He spoiled old DOE’s and the system by bribing the DOE auditors and others in the system.
 Every new and old DOE entered in the market was misused by him somehow. How long he wants to spoil CDM business and earn disrepute permanently? What is he finally going to achieve? Some money and bad name for ever? DOE to seek answers from General Carbon/ General carbon pte Ltd. on these points and take appropriate actions to save the project owners and CDM business fraternity from this evil person and evil company. Never believe the documents given by General Carbon, DOE must cross check all of them. General Carbon is the forgery masters. 
DOE to be careful in undertaking any jobs referred by this kind of consulting companies, instead they should not take up the job at all in the best interest of CDM business and to protect their interests and reputation. 

Is the PP claiming REC credits? How can the DOE confirm that in future the PP will not apply for REC benefits??

How is the 80% accelerated depreciation accounted?
Is the project coming up only to save on the tax liability of the entity? DOE to ensure that the tax deferment arising from 80% accelerated depreciaition should be accounted in IRR sheet.

DOE to confirm that the PP has used the WACC benchmark in other projects or is the WACC benchmark specific for CDM project?