Layout of power transmission lines from the generation to the consumer with the metering system is not shown. It should include the distance of transmission lines. DOE has to check the meters are installed to monitor electricity generated, net electricity used in Bhutan, net electricity exported to India. Pls. clarify.

The status of the construction & commission of the project is not stated in the PDD.
What is the basis of calculation for transmission loss, auxiliary consumption and transformer losses? What is the length of transmission line? 

The project is claimed to be run of river hydro project. So the calculation of reservoir is wrong. The criterion 3 is applicable only to pumped storage or accumulation hydro projects. What does reservoir refer to as per PP? 

The justification of opting out alternative 3 and alternative 4 is not justified adequately. It should be based on latest published data and figures. Refer B.4. Pls. clarify.
The bilateral agreements, PPA with India are the documents, DOE to check thoroughly

Date of investment decision should be at the time of DPR preparation. So, the basis of the cost escalation factors at a later date for CDM consideration is not valid. Pls. clarify. Refer B5. Step 3a. (Investment barrier).

How the CDM benefit will alleviate the technical barriers. As per additionality tool, if the barriers are not alleviated by CDM, then the project is not additional. 

Emission factor for state is not calculated.it should be made available to DOE to clearly validate this value.  Emission factor for India is not as per “Tool for emission factor for the system”. 

Electricity generated by the project, auxiliary consumption, transmission losses, transformer losses, net electricity exported to India, net electricity exported to the  grid. These parameters to be monitored continuously and to be cross checked with sale receipts. 

The Meth mentions that if investment analysis option is used, apply the following: 

a.	Apply an investment comparison analysis, as per Step 3 of the .Combined tool to identify the baseline scenario and demonstrate additionality., if more than one alternative is remaining after Step 2 and if the remaining alternatives include scenarios P1 and P3;

b.	Apply a benchmark analysis, as per Step 2b of the .Tool for the demonstration and assessment of additionality. If more than one alternative is remaining after Step 2 and if the remaining alternatives include scenarios P1 and P2.

But PP failed to apply like this. Pls. clarify.

PLF should be based on EB48 Annex 11guideline which says The plant load factor provided to banks and/or equity financiers while applying the project activity for project financing, or to the government while applying the project activity for implementation approval; (b) The plant load factor determined by a third party contracted by the project participants (e.g. an engineering company); But PDD doesn’t demonstrate how PLF has been arrived at. 

Whether PLF includes machine shutdown, machine availability. Whether grid availability is accounted for in the calculation of gross generation. To my surprise, critical parameter like PLF is missing from the PDD. How DOE has allowed this. 

Common practice analysis should be based on EB 39 Annex 10 (Additionality tool). Each step of common practice analysis should be fulfilled as per tool.

Emission reduction calculation should be based on EB 50 Annex 14 “Tool for emission factor for the electricity system.

Whether only one set of main meter, check meter set is enough for three projects. The monitoring parameters need to be checked by DOE.

The main meter and check meter technical parameters like accuracy level, make, etc. needs to be mentioned in the PDD. 

It looks like from the PDD the start date of the project is tampered for sure. This must be verified and let the truth come out. The culprits of forgery and malpractices must be brought to book. Why DOE has taken up such a bad project? Is there any pressure on DOE or some cake offered to DOE? They DOE must terminate this project immediately. DOE to check the offer letters originals and get the same verified in writing from the OEM’s and submitted parties. Where is the OEM supplier agreement original? DOE to check for the same. Is it prepared later with date and amounts changed to suit the project workings? For sure yes. This is not acceptable. 
DOE to check all purchase orders originals with the receiver of purchase orders i.e. the supplier of equipment. This PO confirmation to the DOE must be in writing from a board level person of the equipment supplier to avoid any malpractices and forgery. Then DOE to check for the invoices dates, payment amounts and date of payments made with all original documents and reconfirm with the parties involved and the banks for the accuracy of amounts, dates and parties involved. Same analysis and due diligence work to be repeated for “Notice to Proceed” as written in the case of Purchase order as above. DOE to check all “Notice to Proceed” originals with the receiver of “Notice to Proceed” i.e. the supplier of equipment or Engineering Procurement & Construction Contractor. This “Notice to proceed” and EPC contract confirmation to the DOE must be in writing from a board level person of the equipment supplier and EPC contractor to avoid any malpractices and forgery. Then DOE to check for the invoices dates, payment amounts and date of payments made with all original documents and reconfirm with the parties involved and the banks for the accuracy of amounts, dates and parties involved.
 DOE to check OEM supplier agreements, EPC contractor agreements, “Notice to proceed” letters, and Invoices raised. I’m sure DOE will catch the malpractices happened in this project. All the parties involved in this matter must be brought to justice. DOE must not support this kind of forgeries and malpractices. DOE cannot afford to close their eyes to this kind of malpractices. 

The Proposed project activity with a start date before 2 August 2008, for which the start date is prior to the date of publication of the PDD for global stakeholder consultation, are required to demonstrate that the CDM was seriously considered in the decision to implement the project activity. If your project does not comes under this category please ignore the relevant comments as given below:
1)	It looks like from the PDD the start date of the project is tampered. This must be verified and let the truth come out. The culprits of forgery and malpractices must be brought to book if it happened. If found the dates are tampered, the DOE must terminate this project immediately. DOE to check the offer letters originals and get the same verified in writing from the OEM’s and submitted parties. Where is the OEM supplier agreement original? DOE to check for the same. Is it prepared later with date and amounts changed to suit the project workings? If yes, this is not acceptable. DOE to check all purchase orders originals with the receiver of purchase orders i.e. the supplier of equipment. This PO confirmation to the DOE must be in writing from a board level person of the equipment supplier to avoid any malpractices and forgery. Then DOE to check for the invoices dates, payment amounts and date of payments made with all original documents and reconfirm with the parties involved and the banks for the accuracy of amounts, dates and parties involved. 
2)	Same analysis and due diligence work to be repeated for “Notice to Proceed” as written in the case of Purchase order as above. DOE to check all “Notice to Proceed” originals with the receiver of “Notice to Proceed” i.e. the supplier of equipment or Engineering Procurement & Construction Contractor. This “Notice to proceed” and EPC contract confirmation to the DOE must be in writing from a board level person of the equipment supplier and EPC contractor to avoid any malpractices and forgery. Then DOE to check for the invoices dates, payment amounts and date of payments made with all original documents and reconfirm with the parties involved and the banks for the accuracy of amounts, dates and parties involved. DOE to check OEM supplier agreements, EPC contractor agreements, “Notice to proceed” letters, and Invoices raised. I’m sure DOE will unearth the real story of what happened in this project. All the parties involved in this matter must be brought to justice if found guilty. DOE cannot afford to simply keep validating these kind of old projects just like that. 
3)	Is PP showing ERPA as a part of real and continuous action? If yes, How come the PP is showing an ERPA and telling that there is real and continuous action? In what way PP can prove that the ERPA what is mentioned is genuine? This ERPA is dated what? Are there any emails exchanged during those ERPA signing days between PP and CER Buyer? Let PP show the real evidence that this particular ERPA was really signed on that date by showing the exchange of emails during those days. Any government owned postal receipt copies to prove the transmission of documents?  Any way EPRA has no meaning even if they prove that ERPA was signed those days. ERPA is not a concluding evidence to show real and continuous action. Why the party has not signed any validation agreement with a DOE? Do they have a signed CDM validation agreement with any DOE? If yes, have they paid money to DOE so that we can conclusively prove that PP has considered CDM and serious real and continuous action was there. If the PP has not paid to the DOE the advance amount towards CDM validation, then we can conclusively say that no real and continuous action in this project at all. In such case, this project does not merit any further validation, DOE must tell the PP to with draw the project from CDM. Alternatively DOE should issue a negative validation report and protect their reputation and future. When did PP apply for host country approval? Why delay? DOE to probe fully. Is it a case where PP has never considered CDM revenue to establish the project? Is it case, where one consultant must have given this fraud idea of applying for CDM revenues when the PP has almost forgot the project activity itself since it is a done project without envisaging any CDM revenues? DOE must be careful in taking up this kind of projects. What due diligence and checks the DOE has done prior to accepting this job?