Applicability of the methodology: Project is not applicable under ACM0013 version 4.
Para 4 of the ACM0013 version 4 demands “data on the fuel consumption of recently constructed power plants are available”. Adani and their consultants seem ignorant and least bothered to fulfill the requirements under ACM0013 version 4. But what is surprising is that the DOE (SGS) has not bothered to even look whether the project is applicable for this methodology or not. On one hand UNFCCC is breaking their heads to ensure that the standards of DOE are met, and other hand DOEs like you are diluting the complete concept. As a layman I am able to understand what is written in black and white under ACM0013, why can’t SGS understand this??
ACM0013 version 4 page 11 under FCjx and FCnv under the row of “any comment” it clearly states that the “The DOE should verify that the data on fuel consumption is based on first-hand measurements of the actual quantity of fuel consumed by each power plant, and is not based on second-hand calculations or estimations”. Do the PP/consultant or the DOE even understand the implications and requirement of this special addition in version 4? The meaning of this statement is, you cannot arrive/estimate/compute the fuel consumption. It has to be through direct measurement of actual quantity of the respective units and not the entire power plant. Having known the fact that none of the baseline plants (NTPC, CEA, CERC) measure/monitor the fuel consumption at unit level. At least the operation station heat rates are also not available publicly.
Why has SGS not asked a deviation/clarifications/revision before web-hosting even if the requirements of the methodology are publicly displayed. This displays sheer incompetency of the DOE. Hence I would like to state the project is not applicable under this methodology. Though it is proven now that the project is not applicable under this methodology, I hope SGS does not proceed with the validation; ignoring my comments. But be warned that CDM EB and members are very well aware of the Indian scenario, so Adani Group you cannot escape this time.  

Title: Energy efficient power generation at Kawai in Rajasthan, India
	Why the PP taking 92 years to commissioning the project activity. Refer section A.2
	In India, according to publically available reports of manufacturers of boiler units 660 MW units are only available with supercritical and ultra-supercritical technology, adding up to precisely 1320 MW for 2 units are used. In this context the section of sub-critical as baseline for similar capacity becomes not feasible.
	Why PP not documented the technical specifications of boiler, turbine and balance of plant which is the requirements of CDM processes. 
	From the official website of APRL, it is found that 1.1 million of CERs by 2012 but in PDD the expected commissioning of plant is August 2013, clarify. 
	PP clinched the project quoting a levelized tariff of 2.93 per KWh, getting the better of other contenders like Lanco Infratech (Rs 2.995) and India bulls Power Services (Rs 3.15). But PDD mentions levelized cost of generation for sub critical PP as Rs. 2.93 per KWh and supercritical Rs. 3.05per KWh. What is the difference between levelized tariff and levelized generation cost? Why tariff bid and proposal is not briefly documented in the PDD which will tell many the truth. DOE has to validate the tender document and proposal submitted by PP.
	Usual procedure for larger projects like this, Government will allow investors 10% of power to sell to private parties (Merchant sale). But PDD does not described about this aspect. How DOE will ascertain this merchant power in the addtionality argument claimed by PP. What is the contract agreement between the concerned parties? It may be available in the tender document which DOE should validate.  
	PP fails to demonstrate how sub critical and NG based PP have been considered as only realistic alternative in the PDD. It seems from the hindsight that PP decided to take subcritical and NG PP as baseline and arrived at the plausible alternatives thereby leaving conveniently other renewable energy sources. The project participants’ selection of alternatives for comparison to the Project is not based on evidence but instead relies on unsubstantiated claims about the infeasibility of potentially attractive project alternatives.
	PDD does not mention about coal allocation from the Government LoA for supply of coal from Central Coalfields Ltd. If at all any, PP has to demonstrate the allocation of coal is for subcritical plant and can avail sufficiently to run subcritical power plant. Pls clarify.
	The PDD fails to provide data during investment decision date to reject imported electricity as a project alternative.
	PP does not state the investment decision date explicitly and DOE has to validate when the supercritical PP option was considered.
	The PDD does not explain about identified training, monitoring and maintenance as per the Technology requirements for contractors / engineers by the client. There is no mention of field quality Assurance systems & procedures that are available at site, field quality plans and their approval.
	The investment analysis is neither transparent nor reproducible and therefore does not support the selection of subcritical coal-fired power plants as the Project’s baseline. Furthermore, project participants fail to include required elements under ACM0013, such as calculation of the levelized cost of electricity and the tariff rate used to calculate the Project’s internal rate of return.
	Supercritical PP has been proved less attractive than other alternatives. But additionality is based on project is not viable without CDM revenue. This aspect is not argued at all. How DOE has allowed this. Pls clarify.  
	As per methodology ACM 13, the investment analysis should be presented in a transparent manner and all the relevant assumptions should be provided in the CDM-PDD, so that a reader can reproduce the analysis and obtain the same results. Critical techno-economic parameters and assumptions (such as capital costs, fuel price projections, and lifetimes, the load factor of the power plant and discount rate or cost of capital) should be clearly presented. Justify and/or cite assumptions in a manner that can be validated by the DOE. In calculating the financial indicator, the risks of the alternatives can be included through the cash flow pattern, subject to project specific expectations and assumptions (e.g. insurance premiums can be used in the calculation to reflect specific risk equivalents). Where assumptions, input data, and data sources for the investment analysis differ across the project activity and its alternatives, differences should be well substantiated. The CDM-PDD submitted for validation shall present a clear comparison of the financial indicator for all scenario alternatives. The baseline scenario alternative that has the best indicator (e.g. the highest IRR) can be pre-selected as the most plausible baseline scenario”. But PDD does not include this aspect. 
	PP fail to include all required information like CO2 emissions, Coal consumed of similar coal-fired power plants in India. This information is needed to verify the emission reduction calculations claimed by PP.
	Section B.6.2 mentions of IPCC value for sub-bituminous coal. Justification is needed why it is taking this value, when national data is publicly available.
	Method of Monitoring of coal consumed is not explicitly stated. Moisture loss, carpet loss should be monitored. 
	DOE has to check, measurement methods and procedures to be applied for the proposed project activity. Monitoring by weigh bridge method, it gives total quantity of coal stock but not the actual consumption of the boiler and energy balance also varies.
	Based on the purchased quantities and stock changes not gives the fuel consumption of the project activity, verify.
	The PDD fails to fully demonstrate amount of ash that will be generated, utilized, and disposed. Although Indian coal may have fewer heavy metals than coal from other areas, fly ash can still be hazardous and still contain heavy metals. Dry storage of ash would be better than wet storage for utilization purposes.
	PDD does not clearly describe the stakeholders involved in Project or the information provided to them. The PDD mentions “identified stakeholders,” but no details which of these stakeholders actually participated in the process. The PDD does not describe the information provided to stakeholders with sufficient clarity, such as whether adverse environmental impacts were described along with the benefits that were mentioned.