1.As per the PDD, the board resolution indicating the CDM consideration is dated 18/03/2010. Also, the purchase order date of the WTG is 04/06/2010. Then, how come the equity IRR benchmark has been calculated considering the inflation rate provided in the RBI report dated 25 May 2011? Does it mean that the project’s financial evaluation for CDM consideration has been done after placing the purchase order of the WTGs?

2.As per the latest guidelines on common practice (EB 63/ annex 12), the stepwise approach for common practice analysis includes calculating the factor F - which is (1- ratio of no. of projects with different technologies to the total no. of projects installed in the region prior to project start date). However, the PDD uses a different route, which is not very clear. Latest guidelines should be applied to assess common practice.

1.As per the PDD, the board resolution indicating the CDM consideration is dated 18/03/2010. Also, the purchase order date of the WTG is 04/06/2010. Then, how come the equity IRR benchmark has been calculated considering the inflation rate provided in the RBI report dated 25 May 2011? Does it mean that the project’s financial evaluation for CDM consideration has been done after placing the purchase order of the WTGs?

2.As per the latest guidelines on common practice (EB 63/ annex 12), the stepwise approach for common practice analysis includes calculating the factor F - which is (1- ratio of no. of projects with different technologies to the total no. of projects installed in the region prior to project start date). However, the PDD uses a different route, which is not very clear. Latest guidelines should be applied to assess common practice.

1.As per the PDD, the board resolution indicating the CDM consideration is dated 18/03/2010. Also, the purchase order date of the WTG is 04/06/2010. Then, how come the equity IRR benchmark has been calculated considering the inflation rate provided in the RBI report dated 25 May 2011? Does it mean that the project’s financial evaluation for CDM consideration has been done after placing the purchase order of the WTGs?

2.As per the latest guidelines on common practice (EB 63/ annex 12), the stepwise approach for common practice analysis includes calculating the factor F - which is (1- ratio of no. of projects with different technologies to the total no. of projects installed in the region prior to project start date). However, the PDD uses a different route, which is not very clear. Latest guidelines should be applied to assess common practice.

1.	Explain the technical details of WTG.
2.	What would be impact of negative environmental conditions of area upon project? What would be alternatives in that case?
3.	What is responsibility of GMDC and Suzlon in case of failure of project?
4.	How many skilled/unskilled people from surrounding area will be employed at this project during commissioning and operation? 
5.	List of stakeholders and minutes of stakeholder meeting is not attached with PDD.

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

Gujarat forum on CDM respectfully submit the following comments on the Project Design Document (PDD) for 40.5 Megawatt, wind power project by GMDC, Gujarat, India. We thank the CDM Executive Board and Designated Operation Entity (DOE) for recognizing the integral role of transparency in CDM Validation process, and for taking this comment into consideration.
The project is not appropriate for the following points

o	No justification has been given regarding the selection of sites for installation of Wind farm turbines and how much land has been acquired for the purpose?

o	No information has been provided about the land type of acquired land and its previous use.

o	No explanation has been given about the investment purpose. The GMDC has no such experience in the sector of wind energy then why it is investing in the project which is not economically viable without the support of CDM CER?

o	No plan has been submitted regarding use of 2% of the net revenue accrued from the sale of CER toward achieving the sustainable development goals
gujaratfourmoncdm@gmail.com