Submission of comments to the DOE/AE
Compilation of submitted inputs:
The PP states that they have considered 80% accelerated depreciation. However the PDD is silent on the tax shielding as a result from accelerated depreciation.
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.
Please also check the offer from WTG supplier and Purchase Order while validating the PLF. It may be so that the third party report which is made after investment decision making - indicates a lower PLF.
The PLF seems to be very low. Also check the tariff order.
No details are provided on the beta estimation. Is the beta levered or unlevered and what is the reason?? How is the beta appropriate for irr chosen?
No details provided on which all stakeholders attended the meeting.
The benchmark is too high. Even after considering CDM benefits the IRR will not cross the benchmark. Then WHY did the PP go ahead with this non-profitable venture??
This clearly indicates the benchmark is made high just to prove additionality and is not the real benchmark expected by the PP.
Why has the PP considered Reliance Infrastructure Ltd for beta determination when Reliance Infrastructure Ltd. has many other businesses other than pure power generation? How come the risk profile of Reliance Infrastructure Ltd match with the project activity which involves wind electricity generation?
What is the vintage considered for beta determination? Is considering only one year appropriate?
Why tax computations for beta are only considered for one year?? What is the basis for considering a particular vintage for the market returns, beta estimation and risk free returns?
Why the particular index is considered for calculating the market returns? DOE to evaluate whether the PP has made any other investments considering the same index. Only because a particular index results in a higher benchmark??
Project cost seems to be very high. Are the quotations real or fabricated?
Are REC benefits being claimed? How will the DOE ensure that the PP does not claim REC benefits during project operation?
DOE to submit a negative opinion in case the IRR does not cross the benchmark even after considering CDM benefits as it clearly indicates the projects unviability in any case. Why would any one invest in a loss making venture?
And if the PP can still go ahead with the project - it indicates that the benchmark is fabricated and is not considered by the PP while making the investment decision!! DOE to validate this critically!! How are the investment decisions really made???
DOE to check if the financials correctly apply the 10 year tax holiday - i.e. not liable for taxes for 10 years from the initial 15 years.
Submitted by: Babloo
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 DPRís 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.
Submitted by: zhong zhou li
1) Purpose of the project and how the proposed project activity reduces greenhouse gas emissions are not briefed in the PDD. Refer section A.2.
2) How environmentally safe and sound technology is used for the project and details of technology transfer is not demonstrated adequately. Refer A.4.2
3) Non- debundling nature of the project activity is not adequately justified as per EB54 Annex 13 (Debundling tool). Refer A.4.5.
4) Please check the project boundary of the project activity is not based on the guidance of the applicable project category.
5) Why has option A (Combined margin) been chosen for calculating emission factor is not justified. Refer B.6
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.
7) The emission factor for the project electricity system can be calculated either for grid power plants only or, as an option, can include off-grid power plants.
8) Basis of choosing PLR as benchmark is not adequately demonstrated in the PDD
9) All the issues of investment analysis guidelines are not discussed in the PDD. Refer B.5.
10) Justification of parameters including O&M, insurance, loan, derating, escalation, and tariff are not demonstrated with justification. Refer B.5.
11) Please provide a proof for proposed debt to equity taken at the investment decision. Refer B.5
12) Proof for PLF is not justified.
13) Date of offer is not provided
14) Project cost is not as per state norms. Refer B.5.
15) O&M charges and its escalation is not as per norms
16) IT rate assumed is not as per standard practice.
17) The application of MAT which is based on tax holiday while calculating WACC is not appropriate.
18) The PP has not explained and justified the key assumptions and rationale.
19) The PP and consultant has not Illustrate in a transparent manner all data used to determine the baseline emissions.
20) Not demonstrated that the proposed project activity is additional as per options provided under attachment A to Appendix B of the simplified modalities and procedures for small-scale CDM project activities.
21) National policies and circumstances relevant to the baseline of the proposed project activity are not being summarized clarify.
22) Explain and justify all relevant methodological choices for the proposed project activity
23) Data that is calculated with equations provided in the approved category or default values specified in the category should not be included in the compilation.
24) CER revenue assumed is not consistently applied
25) Project cost is not as per norms, DOE has to check and clarify.
26) The project cost of the project should be based on offer and not on purchase order or tariff order.
27) O&M charges considered are on higher side. Pls. clarify.
28) Benchmark calculation is not as per WACC tool (EB53 Annex 8)
29) Whether pre-tax or post tax IRR is selected is not demonstrated in the PDD.
30) The basis of calculation of benchmark is not documented in the section B.5. PLR is not acceptable benchmark for the project. WACC based on Government bonds, risk premiums should be taken.
31) Prior consideration of CDM which is important for the determination of additionality is not documented in the section B.5 of the PDD.
32) Date of PPA is not mentioned in the prior consideration of CDM
33) The selection of simple OM based on low cost/must run resources is not adequately justified. Refer B.6.1
34) PP has not provided for each parameter the chosen value or, where relevant, the qualitative information.
35) Please Provide the actual value applied. Where time series of data is used, where several measurements are undertaken or where surveys have been conducted, provide detailed information.
36) Explain and justify the choice for the source of data.
37) Ex-ante option of calculating OM is not adequately demonstrated. Step 3 of Refer B.6.1
38) 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
39) 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
40) The argument that CEA data for build margin is calculated as per Emission factor tool is not documented. B.6.1
41) Spread sheet is not provided. The data should be presented in a manner that enables reproducing of the calculation of OM, BM, and CM.
42) The justification of negligible project emissions for wind project is not as per AMS. I. D ver 16.0 EB 54).
43) The emission factor value (Southern grid) for calculating baseline emission is wrong. Refer B.6.3
44) Net electricity should be continuously monitored, hourly measured and at least monthly recorded. Refer B.7.1
45) Metering regulations as per CEA norms is not adequately followed in monitoring plan. Refer B.7.2.
46) Where the values have been measured, include a description of the measurement methods and procedures that comply with the guidance provided under general guidance.
47) Provide a detailed description of the monitoring plan, including an identification of the data to be monitored and the procedures that will be applied during monitoring.
48) The PP should include sources of data that will be actually used for the proposed project activity (e.g. which exact national statistics, actual measurement etc. ).
49) Where the parameters are to be measured in accordance with the guidance of the approved project category or the general guidance to the indicative methodologies, specify the measurement methods and procedures including accepted industry standards or national or international standards which will be applied, which measurement equipment is used, how the measurement is undertaken.
50) Which calibration procedures are applied, what is the accuracy of the measurement method, who is the responsible person / entity that should undertake the measurements and what is the measurement interval?
51) Please provide a detailed description of the monitoring plan. Describe the operational and management structure that the project operator will implement in order to monitor emission reductions.
52) Clearly indicate the responsibilities for and institutional arrangements for data collection and archiving.
53) The monitoring plan should reflect good monitoring practice appropriate to the type of project activity. Provide any relevant further background information.
54) Please describe the process by which comments by local stakeholders have been invited and compiled. An invitation for comments by local stakeholders shall be made in an open and transparent manner, in a way that facilities comments to be received from local stakeholders and allows for a reasonable time for comments to be submitted.
Submitted by: lawrance
The comment period is over.