1.	PJR contract review form people & PJR Auditors & management including people sitting in Japan & U.S should explain what kind of due diligence they have undertaken to take up this project. This is totally a non-CDM project proved twice in the past. The DOE must understand that the General Carbon is in the habit of hiring new DOE’s for bad and cooked up CDM projects and pressurizing the DOE’s to give the positive validation report by promising the future business to them. This has been done in the past by General Carbon with RINA & SIRIM. Now it is PJR. 
2.	PJR should understand that General Carbon Director’s especially Ram Babu was the reason for some DOE’s suspension in the past. Now, this will happen to PJR also if they do not do proper due diligence before taking a project.
3.	Why General Carbon is web hosting only bad projects? Why can’t they do business like any other Consultants in the market, this is nothing but cheating the system & blackmailing DOE’s, employees of DOE’s & Project owners.
4.	If any DOE’s working more with Ram Babu means he will corrupt the employees & management and teach all sort of dirty things & finally he will ensure that DOE is screwed up.

1.	The PP (Bhoruka Power Corpn. Ltd.) has already invested in wind project according their web-site http://www.bhorukapower.com/Jaisalmer.htm in feb 2003. Of 2.1 MW in Jaisalmer. The DoE is required to check whether CDM was considered for this project activity and if not why?
2.	The website also informs that in March 2005 a 2 MW wind project was commissioned at Karnataka http://www.bhorukapower.com/chitradurga.htm. The DoE is required to check whether CDM was considered for this project activity and if not why?
3.	The entity BGL is mentioned to issue a PO of 3.2 MW and capacity sharing agreement also. Then why PP name only BPCL is mentioned in PDD section A.3?. this shows the incompetence of the DoE during completenss check.
4.	BGL is a sister company of BPCL and had agreed for joint development of CDM project in September 2006. But board decision is only taken by BPCL earlier in August 2006?. The Board decision for BGL is not provided and hence for 3.2 MW the CDM serious consideration cannot be established.
5.	At conceptualisation stage BGL was owner of 3.2 MW and PO was issued in sep 2006. But was amended in june 22, 2007 to include only BPCL as sole owner? What circumstances have prompted this change, the DoE is requested to verify? Also change mentions change of capacity not of ownership? Also previous web hosted PDD does not mention BGL itself while this has come up in this version of the PDD?
6.	The previous web hosted PDD indicates a high project cost of  Rs. 43.10 crores taken on purchase order while the recent PDD mentions a DPR for a cost of 60. 26 crores ? Where is the date of DPR mentioned?. It is a clear case of cooking up an expensive cost as DPR by the consultant  and DoE for satisfying CDM requirements.
7.	Also IRR of 10.96 has been taken in previous PDD while in this GSCP 9.4 has been taken? 
8.	The tariff rate from 11th Year is uncertain in karnataka and in the previous PDD a sensitivity analysis to an extent of 30 % has been taken?. Why this has been left out in this PDD? Also the previous PDD describes in detail the risks available with the tariff rate structure?
9.	13. 55 % has been taken as benchmark in this PDD while 16 % has been taken in the earlier PDD?
10.	Debt equity ratio is applied as 70 : 30 Based on KERC order. But as per EB guidelines if PP has history of Loan sanctions, then these should be considered appropriate. What is significant is the PP has two previous wind projects in 2003 and 2005 and many hydro projects (refer web-site)…then why these were not considered?
11.	PLF is based on third party report as 28.9% while previous PDD has indicated a PLF of 32.3 % based on both the equipment manufacturer offer letter and external consultant? Offer letter is conservative while external consultant is appropriate?. Then how a new value of 28.9% is assessed?? 

•	I am ASTONISHED!! Is it a CDM project?  Has the DOE, done a due diligence before taking up such project? The project has been web-hosted twice (2007) before web-hosting now. Was the project rejected/with- drawn, if yes then for what reason? Has the DOE checked this, will it be made available now? 
•	When TÜV Rheinland Japan Ltd was not able to register this project with two attempts, there would be some serious issue with the project, I request EB to look in to this and DOE to give reason for it’s rejection/with-drawn twice from EB and for taking up this project again validation.
•	If we see Perry Johnson Registrars Clean Development Mechanism, Inc. (PJR CDM), they are only web-hosting all rejected projects/ web-hosted twice or thrice earlier. Why the new DOE is taking up such projects, that to with General Carbon? What is the agreement between them? Are they taking projects to help the PP with CDM benefits or for their own benefits? Is the CDM EB really looking into such issues or not aware of such things?
•	It is declared in the PDD that “BPCL was incorporated in 1986 with the objective of setting up renewable energy based power stations. BPCL has so far promoted 108MW of renewable power projects such as wind projects, hydro projects in India. BPCL has the reputation of developing renewable power projects and has been recognized as a clean energy developer”, then why do they now require CDM benefits i.e., CDM money? Even when the project can run without CDM benefits for past 3-4years. 
•	The consultants and his team are making MOCKERY of CDM Guidelines. It’s time for EB to look into it and see only true/good projects get the benefits of CDM.
•	For instance, in section A.2 of the PDD, it is mentioned that “BPCL has so far promoted 108MW of renewable power projects such as wind projects, hydro projects in India”. But, i n section A.4.5 for the query “if there is a registered small-scale activity or an application to register another small-scale activity”, for the same “Project Participant confirms that it has not registered any small scale activity or applied for registration of another small scale project activity of same category or technology”. 
•	So, once again request the DOE to check all the values in the PDD are according to CDM latest guidelines and be transparent in the approach. For eg; D/E ratio, Rationale of selecting PLR as Benchmark, etc

1.	PP has to clarify total how many PP are participated in the project activity, only BPCL is mentioned in the PDD, refer section A.3.1.
2.	The project cost of the project should be based on offer and not on purchase order or tariff order.
3.	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. 
4.	The chosen benchmark is not consistent with earlier webhosted PDD and present, DOE has to validate this.
5.	Chronology of events with corresponding emails, letters need to be validated by DOE.
6.	How risk free return, market return and beta is calculated is not documented in the PDD. How many companies included in the calculation of beta. Government bond rates should be taken from the date of inception of BSE. 
7.	The application of MAT which is based on tax holiday while calculating WACC is not appropriate. 
8.	Justification of tariff rate is not provided.
9.	Operating margin, build margin, combined margin is not as per “Tool for emission factor for an electricity system”. The tool is not used at all. Pls. calculate combined margin as per the tool. Pls. justify that grid emission factor calculated is as per CEA data latest version.
10.	Justification of PLF is not provided. There is a huge difference between two webhosted projects. It should be based on guideline as provided by latest EB report. Pls. clarify. DOE has to validate this.
11.	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.

1.	The PP (Bhoruka Power Corpn. Ltd.) has already invested in wind project according their web-site http://www.bhorukapower.com/Jaisalmer.htm in feb 2003. Of 2.1 MW in Jaisalmer. The DoE is required to check whether CDM was considered for this project activity and if not why?
2.	The website also informs that in March 2005 a 2 MW wind project was commissioned at Karnataka http://www.bhorukapower.com/chitradurga.htm. The DoE is required to check whether CDM was considered for this project activity and if not why?
3.	The entity BGL is mentioned to issue a PO of 3.2 MW and capacity sharing agreement also. Then why PP name only BPCL is mentioned in PDD section A.3?. this shows the incompetence of the DoE during completenss check.
4.	BGL is a sister company of BPCL and had agreed for joint development of CDM project in September 2006. But board decision is only taken by BPCL earlier in August 2006?. The Board decision for BGL is not provided and hence for 3.2 MW the CDM serious consideration cannot be established.
5.	At conceptualisation stage BGL was owner of 3.2 MW and PO was issued in sep 2006. But was amended in june 22, 2007 to include only BPCL as sole owner? What circumstances have prompted this change, the DoE is requested to verify? Also change mentions change of capacity not of ownership? Also previous web hosted PDD does not mention BGL itself while this has come up in this version of the PDD?
6.	The previous web hosted PDD indicates a high project cost of  Rs. 43.10 crores taken on purchase order while the recent PDD mentions a DPR for a cost of 60. 26 crores ? Where is the date of DPR mentioned?. It is a clear case of cooking up an expensive cost as DPR by the consultant  and DoE for satisfying CDM requirements.
7.	Also IRR of 10.96 has been taken in previous PDD while in this GSCP 9.4 has been taken? 
8.	The tariff rate from 11th Year is uncertain in karnataka and in the previous PDD a sensitivity analysis to an extent of 30 % has been taken?. Why this has been left out in this PDD? Also the previous PDD describes in detail the risks available with the tariff rate structure?
9.	13. 55 % has been taken as benchmark in this PDD while 16 % has been taken in the earlier PDD?
10.	Debt equity ratio is applied as 70 : 30 Based on KERC order. But as per EB guidelines if PP has history of Loan sanctions, then these should be considered appropriate. What is significant is the PP has two previous wind projects in 2003 and 2005 and many hydro projects (refer web-site)…then why these were not considered?
11.	PLF is based on third party report as 28.9% while previous PDD has indicated a PLF of 32.3 % based on both the equipment manufacturer offer letter and external consultant? Offer letter is conservative while external consultant is appropriate?. Then how a new value of 28.9% is assessed?? 

1. PJR contract review form people & PJR Auditors & management including people sitting in Japan & U.S should explain what kind of due diligence they have undertaken to take up this project. This is totally a non-CDM project proved twice in the past. The DOE must understand that the General Carbon is in the habit of hiring new DOE’s for bad and cooked up CDM projects and pressurizing the DOE’s to give the positive validation report by promising the future business to them. This has been done in the past by General Carbon with RINA & SIRIM. Now it is PJR. 
2. PJR should understand that General Carbon Director’s especially Ram Babu was the reason for some DOE’s suspension in the past. Now, this will happen to PJR also if they do not do proper due diligence before taking a project.
3. Why General Carbon is web hosting only bad projects? Why can’t they do business like any other Consultants in the market, this is nothing but cheating the system & blackmailing DOE’s, employees of DOE’s & Project owners.
4. If any DOE’s working more with Ram Babu means he will corrupt the employees & management and teach all sort of dirty things & finally he will ensure that DOE is screwed up.

This project is for captive consumption. PP can also seek REC credits and hence the project is non-additional. How can the DOE ensure that the PP does not seek REC credits in future after project registration?

The project was conceptualised way back in 2006. Why then now the PP is requiring CDM benefits. How did the project sustain all these 4 years without CDM??

How come the PP has considered the beta values of more than 1.3?? Unlevered beta would be appropriate for calculations which is also conservative. DOE to validate the risk critically!

Why loan processing charges are included as project cost? Guidlines say that any processing fee for acquiring debt should not be considered as expense.

The latest KERC tariff order gives a higher tariff rate? Check whether higher rate is applicable for project.

When PP was aware of CDM through hydro projects taken up as CDM, why did it take so long for getting CDM?? Why is PP not investing in wind energy than hydro??

The PLF seems to be very low. Also check the tariff order.

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.

It is the responsibility of DOE to conduct proper due diligence and contract review before signing any contract. Now DOE to explain what it has done this project case. Why a DOE should work this kind of cooked up and fake CDM projects. How many genuine projects this consultant has done till to date? This consultant is responsible for corrupting and spoiling the whole CDM business in India. Why this consultant is not working like any other consultant in the market? Why he is web hosting only projects which were rejected, with drawn, forged (documents changed and forged) and fully problematic projects? 
The Managing Director/CEO (Rambabu) of this consulting company called General Carbon/General carbon pte Ltd. is fully responsible for spoiling the CDM consulting business in India. He is totally unprofessional and unethical. He never did any work in a professional and ethical manner in his working. He started his own consulting company when he was working with PWC by violating the contract with PWC. Then later on he started CantorCO2e in India. They gave all sorts of wrong promises to clients and finally many of the clients are disappointed and lost money who signed with CantorCO2e. While leaving the CantorCO2e while working in CantorCO2e itself he promoted his own company General Carbon Advisory Services Pvt. Ltd and made the clients sign with General Carbon. 
What is this? After he left CantorCO2e employment he took away most of the projects and clients of CantorCO2e by violating all his contract terms, employment conditions and established business ethics. CantorCO2e is pursuing this person legally and he should not be left free. If he thinks he is intelligent he should develop businesses on his own and not rob like this. It is shame that project owners and DOE’s are working with such illegal, unethical, unprofessional and cheating companies and individuals.
General Carbon/ General carbon pte Ltd. is intentionally quote very low to kill completion and also the CDM business as a whole. Only they wish to be in the market, nobody else should work as a consultant in the market. They should explain why it is so. 
 Every project owner and DOE whoever is working with General Carbon should introspect, understand the implications and stop working with General Carbon. General Carbon/ General carbon pte Ltd. is built on totally wrong foundation with robbed clients, wrong promises, cheating the system, deceiving, corrupting the full CDM business overall. One should be ashamed of working with General Carbon in what so ever manner. He spoiled old DOE’s and the system by bribing the DOE auditors and others in the system.
 Every new and old DOE entered in the market was misused by him somehow. How long he wants to spoil CDM business and earn disrepute permanently? What is he finally going to achieve? Some money and bad name for ever? DOE to seek answers from General Carbon/ General carbon pte Ltd. on these points and take appropriate actions to save the project owners and CDM business fraternity from this evil person and evil company. Never believe the documents given by General Carbon, DOE must cross check all of them. General Carbon is the forgery masters. 
DOE to be careful in undertaking any jobs referred by this kind of consulting companies, instead they should not take up the job at all in the best interest of CDM business and to protect their interests and reputation.