Project title: 22 MW Solar Power Project by HZL at Rampura agucha Mine, Rajasthan

The project development has been funny, Vedanta group can so blatantly give lies after lies are visible here. 
In A.1 they say the project is displacing the electricity from Grid. 
The baseline scenario in section A.1 mentions the reference of Tool saying grid is the baseline, however are they supplying the electricity to grid or are they using it for captive consumption? 
At least read the tool properly. What I understand by reading the tool is, Grid is the baseline only in case the project is supplying the electricity to the grid in case of captive consumption the project displaces the captive energy, whatever be the source. That has to be estimated. 

They have very clearly shown in the diagram in section B.3, that the generated electricity is used for captive consumption, it is not fed into the grid. 
In this case the baseline should be the captive emissions rate of the plant. Are they also consuming electricity from the grid, the DOE to check this. 
Additionality is full of contradicting statements. I don’t understand what exactly they are trying to prove, is the DOE so dumb that they accept anything a giant corporate gives? 
Contradictions: 
1.	Electricity used for captive consumption: How can IRR be used here? 
In case of captive they should have carried out the LUCE, I am sure the baseline option would come as grid here as grid is the most expensive case in the baseline, they are consuming grid electricity in the pre project scenario, right? 
So carry out the Levelised unit cost of generation and compare it with all the sources used in baseline including grid, I am sure the solar option is a cheaper option than grid atleast. 
In the recent bids, the tariff is 2.5 to 3 Rs/kWh which is cheaper then grid. Indian Solar market has reached grid parity. So it is feasible for them to put solar power project rather than using grid electricity plus they meet their RPO obligation. Doubly beneficial for Vedanta, plus they get carbon credits.. wow!!!
And they say they have an IRR of 7.78% great. Even then the DOE will accept such justifications, sad state of affairs. 
2.	Why has RPO obligation of Vedanta group not mentioned here. 
Are they not using the solar for their RPO obligation? Can the DOE check their publicly available sustainability reports to confirm that RPO obligation has been met without these solar projects? 
In case they are using for RPO obligation, they it becomes mandatory. Why IRR is used and how can IRR be used in such scenario? LUCE calculation shall be demonstrated here. 

3.	Equity IRR of 7.78%, this is laughable. They don’t show the assumptions so that no one is able to reproduce the results, again circumventing the CDM guideline.
Can the DOE reproduce the IRR value with the inputs mentioned, if not I assume they are suppose to upload the PDD for stakeholders comment again as this amounts to a major change in the PDD description. Though i am sure the DOE will find ways to not do this. 

Can the DOE check with the Vedanta Management as with an IRR of 7.78% why have they even approved such a project. I will write to the Vedanta board for this, lets see what they have to say, and what reason they have for accepting such a low IRR project. 
Again in the next PDD version that is made available for public comments, include the LUCE calculations with assumptions so that we are able to check and reproduce the results in line with the CDM guideline. 

4.	Common practice analysis: What exactly do you want to demonstrate here? 
Start date for project is in 2018, while data has been considered till 2015 and 2016 why, without any justification. 
Rajasthan has so many projects why have those not considered? They are even available on the CDM list, atleast those were to be considered. 

Does HZL not have any other solar project by the group in Rajasthan, that question was not answered anywhere in the PDD. Atleast that was to be referred in the common practice analysis. All the renewable projects by Vedanta should be mentioned here, as it is common practice for them to put renewable energy projects. 

5.	Local Stakeholder consultation: Is this how Vedanta communicates about stakeholder consultation carried out. The date of meeting, date of public notice, date of invitation nothing has been mentioned. Are you still looking for dates. 
How blatantly they mention that these details will be shared to DOE. 
Is this allowed? Can you keep the stakeholders in dark? Why have the stakeholders not been given an opportunity to comment on the LSC process? 

The DOE to answer the above question: How is it justified and in line with CDM requirement that a completed PDD be submitted for Global Stakeholder consultation process. 

Though the DOE here I am sure would be lienent in accepting anything that Vedanta asks them to do. 

Will UNFCCC take into account the above questions asked and republish the PDD for a proper opportunity to stakeholder to assess and comment?