Coke Dry Quenching waste energy recovery project by JSW Projects Limited.
[]
Host party(ies) India
Methodology(ies) ACM0012 ver. 4
Standardised Baselines N/A
Estimated annual reductions* 342,171
Start date of first crediting period. 01 Jan 13
Length of first crediting period. 10 years
DOE/AE Bureau Veritas India Pvt. Ltd.
Period for comments 06 Jan 12 - 04 Feb 12
PP(s) for which DOE have a contractual obligation JSW Projects Limited
The operational/applicant entity working on this project has decided to make the Project Design Document (PDD) publicly available directly on the UNFCCC CDM website.
PDD PDD (695 KB)
Local stakeholder consultation report: N/A
Impact assessment summary: N/A
Submission of comments to the DOE/AE Compilation of submitted inputs:
1)	A.4.2 – sectoral scopes are 2 as per meth, but only one reported for project activity
2)	A.4.4 – Table format is changed – PP & consultants probably do not know PDD completion guidance
3)	The choice under applicability conditions and baseline is done as per Greenfield capacity. The Coke oven plants in JSW have been operating from 4 years as per earlier announcements by JSW. Thus, DOE is requested to kindly check the complete history of the project development and mass-energy balance in the pre-project scenario.
4)	There is supplementary fuel use as per project boundary diagram. What fuel is that? If it is waste gases diverted from other projects? Interestingly no projects emissions as consultant doesn’t know what supplementary fuel or don’t wasn’t to discuss with CDM process?
5)	Baseline alternatives identification – project activity w/o CDM is excluded in B.4. Shows expertise of JSW and consultants
6)	Baseline identification does not account all existing energy generation sources at JSW – which included many waste heat and gas based power plants. If these are identified as baseline – no emission reduction can be claimed. In elimination of alternative P.8 – now JSW claims existing captive power plants exist. In another PDDs hosted by same plant for TRTs – it says existing plants have exhausted capacity and electricity is purchased from another company. DOE should check the complete energy balance before the project activity and existing energy demand. Alternative P.9 – consultant probably knows only biomass and wind as only renewable power generation sources. There are other alternatives my friend and there is something called wheeling of electricity. Alternative P.10 – PP says he can import from grid – other PDDs from same plant they said plant is not grid connected. It does not look ethical on part of a public company like JSW to blatantly lie in public forum. Alternative P.11 – more lies – no captive WHR based captive power plant. Did you forget same plant has two registered and some in validation projects based on waste heat and gasses? Lies on captive power capacity is elaborated on pg. 29 to show excess capacity available in power whereas other two projects on TRT from same plant have tried to establish otherwise. Probably this is the reason they have gone to a new DOE who has not dealt with any existing dirty projects and all power capacity manipulations.
And finally, the project activity levelised cost is not shown as if that without CDM is not even an alternative. Levelised cost computation for project activity should also be discussed (taking 80IA and tax benefits discussed further) to show it is financially not most attractive than chosen baseline scenario.
7)	The additionality is again contradiction to all the earlier PDDs hosted by group. There is no limit to what PP has put into risk (if it mattered any to JSW reputation). The captive power plants power cost is more than double that quoted in TRT PDDs. So which information put in public domain is true sir? So when IRR was computed in other projects using power replacement cost – tariff was lower. Now it is comparison of levelised costs – tariff becomes higher. This is ridiculous claim to bring further shame to CDM team of PP and consultants E&Y.
8)	Benchmark analysis is not to be done if PP has option not to invest in project. So consultant took time of more than a year after appointment to calculate benchmark. And why no details of which companies’ beta, what index, how many year data for both these parameters is discussed?
9)	Efficient power projects like these are allowed accelerated depreciation at 80% - refer IT Depreciation rates notification – waste heat recovery equipments (http://mof.gov.in/the_ministry/dept_revenue/revenue_headquarters/cbdt/miscell/newappen1.pdf)
10)	For captive power plant tariff was taken from power trading company – is it copied from other PDDs? Interest rate taken from bank’s letter- contradictory to actual interest rate required by investment analysis guidance for post tax IRR calculation.
11)	So finally who is selling power to whom among JSW – SL, Projects and JSWPTC? Interestingly, Annex 1 shows same contact person for both PPs/ companies.
12)	Project life was said 25 years in applicability conditions and in investment analysis life became 20 years. Sir only 5 pages have changed and life reduced by 5 years? Again C.1.2 goes on to accept 25 year project life – so 20 years was for financial analysis alone. This is height of ignorance on part of consultant.
13)	So 12.94% with CDM is sufficient? Then why was benchmark written 15.89%. What was considered by Board or still minutes are to be written?
14)	Baseline in completed in Dec 2011 and PDD version was written on Nov. 2010 as per Section A.1
15)	Sir – now after so much confusion for baseline in sections B.4 and B.5 – in emission factor – which one is used exactly for baseline emissions? Probably consultant is yet to decide what is replaced by project as baseline.
Submitted by: Sasi Yadav

Do send some auditors who are not in the business development and marketing with the PP. Bureau Veritas should depute a team for any audit who is not involved in the marketing with the client. Bureau Veritasnow a days is doing CDM audits in very short time and giving reports. Why and how? What has changed? Overnight have they become very knowledgeable? Same people, same systems and their attitude towards CDM validation has changed and BV auditors are giving request for registration without checking the full particulars of the project. Why the sudden change in attitude? Auditors want to milk CDM and spoil CDM system and then go for their regular inspection and ISO certification stuff when CDM dies? Because of DOE’s like this only CDM is going to dogs. Auditors like HB Muralidhara, Sanjay Patankarand other likeminded auditors in BV are going very fast on CDM projects of their choice and certifying in a great hurry. Why? Bureau Veritas management should probe this? If BV management does not take real interest and keep the house in order, UNFCCC should check this issue. Why BV’s all old projects which are publishedfor comments in 2007 and 2008 are getting request for registration all of a sudden? What clients have shown and given off late which they have not done in the last 3 years or so? What is this? What is happening? What kind of TR is being done? Is TR done just for the sake of doing or is TR raising any true and genuine issues? HB Muralidhara and Sanjay Patankar should not be used for any large scale projects as LA as their independence is definitely questionable. 
They should be used only for TR and some “independent and new to consultants and large group companies”auditors to be used as LA’s. At least both of them should be sent to Inspection to save BV’s reputation on CDM business. BV auditors relationship with some of the big group of companies in India & other countries and some consultants is questionable and brings disrepute to CDM process. Names need not be written, everyone knows including BV’s management. If no credible corrective actions are initiated immediately by BV’s management then we have no other option except to come out openly with names of companies and consultants with whom BV is involved in wrong activities. 
How come HB Muralidhara and Sanjay Patankar do audits for clients and consultants when both are doing marketing and seeking business from market? Is this allowed in any third party certification business? Why BV is flouting rules, for disgrace? Why BV’s auditors themselves are giving suggestions how to close CAR’s and CL’s for CDM projects? Why they are advising corrective actions? Is it acceptable? BV’s management and UNFCCC should look into this matter and correct the things immediately in the interest of CDM process. Flavio Gomes is fit for counting revenues and does not have a proper oversight on his own business operations area, which is proven effectively now. It’s time to set the business in order. Copy marked to UNFCCC. 
Submitted by: Benjamin franklin

Do send some auditors who are not in the business development and marketing with the PP. Bureau Veritas should depute a team for any audit who is not involved in the marketing with the client. Bureau Veritasnow a days is doing CDM audits in very short time and giving reports. Why and how? What has changed? Overnight have they become very knowledgeable? Same people, same systems and their attitude towards CDM validation has changed and BV auditors are giving request for registration without checking the full particulars of the project. Why the sudden change in attitude? Auditors want to milk CDM and spoil CDM system and then go for their regular inspection and ISO certification stuff when CDM dies? Because of DOE’s like this only CDM is going to dogs. Auditors like HB Muralidhara, Sanjay Patankarand other likeminded auditors in BV are going very fast on CDM projects of their choice and certifying in a great hurry. Why? Bureau Veritas management should probe this? If BV management does not take real interest and keep the house in order, UNFCCC should check this issue. Why BV’s all old projects which are publishedfor comments in 2007 and 2008 are getting request for registration all of a sudden? What clients have shown and given off late which they have not done in the last 3 years or so? What is this? What is happening? What kind of TR is being done? Is TR done just for the sake of doing or is TR raising any true and genuine issues? HB Muralidhara and Sanjay Patankar should not be used for any large scale projects as LA as their independence is definitely questionable. 
They should be used only for TR and some “independent and new to consultants and large group companies”auditors to be used as LA’s. At least both of them should be sent to Inspection to save BV’s reputation on CDM business. BV auditors relationship with some of the big group of companies in India & other countries and some consultants is questionable and brings disrepute to CDM process. Names need not be written, everyone knows including BV’s management. If no credible corrective actions are initiated immediately by BV’s management then we have no other option except to come out openly with names of companies and consultants with whom BV is involved in wrong activities. 
How come HB Muralidhara and Sanjay Patankar do audits for clients and consultants when both are doing marketing and seeking business from market? Is this allowed in any third party certification business? Why BV is flouting rules, for disgrace? Why BV’s auditors themselves are giving suggestions how to close CAR’s and CL’s for CDM projects? Why they are advising corrective actions? Is it acceptable? BV’s management and UNFCCC should look into this matter and correct the things immediately in the interest of CDM process. Flavio Gomes is fit for counting revenues and does not have a proper oversight on his own business operations area, which is proven effectively now. It’s time to set the business in order. Copy marked to UNFCCC. 
Submitted by: Benjamin franklin

1.	Is the project equipment purchased second hand equipment or sourced from cheap foreign sources? If yes, the issue must be probed by DOE since invoices will invariably be inflated and forged. Total project costs mentioned by PP will not be the same as originals. Hence no additionality. These facts must be probed in full by DOE by checking all documents and money transactions along with bank statements and certified accounts by a legally acceptable financial analyst. 

2.	From DOE side which auditor has done marketing and business development for acquiring this business of validating this project? With whom he or she was co-ordinating at PP or CER buyer? The same person who has done the marketing and business development to acquire the business do validation or participate in any manner what so ever in the validation process? One cannot do like that. It is against the accreditation rules and norms followed since ages. DOE should send auditors from different offices or countries to do this validation audit. DOE must take care of impartiality and accreditation rules. Due to the targets set by the DOE managements auditors are doing marketing and meeting clients and giving promises that the project will be taken care. Is it acceptable and fair? This must be stopped. No auditor should do marketing. Only non-auditing staff should do marketing. DOE to ensure the same please. 


3.	If applicable only: Is these machines, equipment was a part of any bundle of CDM activity envisaged and developed earlier. DOE to check the same through independent sources also. Once some bundles are non-additional and getting negative validation from a DOE, PP is rolling out the same project as an individual project which is not a CDM project at all. DOE to verify the same from independent sources and also take undertaking in the form of an affidavit from the PP’s that any misrepresentation or false statement with respect this would attract strict legal action from UNFCCC and DOE. Furthermore the registered project must be de-registered in case of any future findings contradicting the submissions made by the project owner.  



4.	DOE to ensure that the PDD values are consistent and ensure that the CDM project is a genuine project
5.	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. 
6.	Careful study must be done so that the DPR/FR is not in different versions made and submitted with different purposes to different agencies, which is totally unacceptable, illegal and unethical. 
7.	DPR/FR values 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. 
8.	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. 
9.	DOE must not entertain this project any more if found the DPR/FR is tamprered with at any point in time. PP can not give different DPR’s and FR’s. They must submit only the one given to Banks and other agencies while obtaining loans and decision making time. 



10.	 How is the base line defined in this project? Is Base line hypothetically defined with no proper evidences and proper justification? In such case, DOE cannot take the base line as suggested by the PDD.  Please check that there are real emission reductions beyond the real and factual base line. It may so happen that this project qualifies for no CER’s. DOE cannot assume values and things as giving by this PP. Whatever values are considered throughout the project in all documents including the real DPR (not the one prepared for CDM, the one given to the banks and others), they must be validated, verified and double checked. Do not ask PP for DPR. Ask the parties who have been given DPR by the PP. Get directly from the bank and others by each page of the DPR and Feasibility report signed. Such document can be considered as a real DPR or FR. UNFCCC CDM process cannot be degraded by fabricating and misinterpreting the project base line and additionality.  

11.	DOE to be more careful so that this is a genuine CDM project. What is the exact project cost? The project cost is covering what? Each value considered must be validated with proof. The machinery is second hand purchased or fresh and new from an OEM? In either case DOE to check all the quotations, proposals, purchase orders, invoices, way bills, transport bills, proof of payments like bank statements. DOE to check with banks by way of written confirmation the amount transacted, to whom the money is paid, when the money is paid, is the party paid is the correct party as shown in the purchase orders. It may so happen that the values, party names, dates are fabricated and misrepresented in this project. DOE should terminate their contract for this project immediately. This is the only way out to protect the value of CDM process. If the PP is purchasing second hand or second quality equipment and inflating the purchase order values and invoices, this must be probed thoroughly and real values to taken for additionality calculation. Then I’m sure the additionality is not there at all in such a situation.
12.	Project owner should show some undertaking letter from bank manager to DoE stating that both DPR’s are same. These kinds of letters should not be accepted and entertained by DoE at face value, but must be checked independently. 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. 
13.	Has the PP considered the CDM revenues while envisaging the project? Without CDM the project was not viable, is it right? This project is having a debt component? Then how bankers or lenders gave the loan? Have the bankers or lenders considered the CDM revenues while agreeing to give loan to this projects? If not this project should be rejected right away by DOE by terminating the contract forthwith. If yes, where is the proof? What is the date of the evidence document from bank? Is this document printed now a days or earlier. DOE to independently check the same. If the document is  available from Bank it must be checked from all angles so that it is genuine and not forged and date changed by putting back dated. This is normally done, DOE to be aware of this please. Please check the communication the PP had during that time with banks, emails and postal receipts and the weights and dates mentioned on the receipts. Do not believe in courier bills and receipts since these can be cooked up easily. Insist on government owned postal service receipts only. If the project is fully equity project then on what basis the PP has invested full equity in to the project while considering the CDM revenue? DOE to check the same in detail and bring out the facts. Is there any past record of this PP to invest or not to invest at returns what he is talking about in this project? Proper evidences must be reviewed and digged out by the DOE and take decision on the project based on established facts. Do not ask documents from PP, DOE to collect the same from different sources to do independent evaluation. 


Submitted by: Benjamin franklin

1.	Is the project equipment purchased second hand equipment or sourced from cheap foreign sources? If yes, the issue must be probed by DOE since invoices will invariably be inflated and forged. Total project costs mentioned by PP will not be the same as originals. Hence no additionality. These facts must be probed in full by DOE by checking all documents and money transactions along with bank statements and certified accounts by a legally acceptable financial analyst. 

2.	From DOE side which auditor has done marketing and business development for acquiring this business of validating this project? With whom he or she was co-ordinating at PP or CER buyer? The same person who has done the marketing and business development to acquire the business do validation or participate in any manner what so ever in the validation process? One cannot do like that. It is against the accreditation rules and norms followed since ages. DOE should send auditors from different offices or countries to do this validation audit. DOE must take care of impartiality and accreditation rules. Due to the targets set by the DOE managements auditors are doing marketing and meeting clients and giving promises that the project will be taken care. Is it acceptable and fair? This must be stopped. No auditor should do marketing. Only non-auditing staff should do marketing. DOE to ensure the same please. 


3.	If applicable only: Is these machines, equipment was a part of any bundle of CDM activity envisaged and developed earlier. DOE to check the same through independent sources also. Once some bundles are non-additional and getting negative validation from a DOE, PP is rolling out the same project as an individual project which is not a CDM project at all. DOE to verify the same from independent sources and also take undertaking in the form of an affidavit from the PP’s that any misrepresentation or false statement with respect this would attract strict legal action from UNFCCC and DOE. Furthermore the registered project must be de-registered in case of any future findings contradicting the submissions made by the project owner.  



4.	DOE to ensure that the PDD values are consistent and ensure that the CDM project is a genuine project
5.	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. 
6.	Careful study must be done so that the DPR/FR is not in different versions made and submitted with different purposes to different agencies, which is totally unacceptable, illegal and unethical. 
7.	DPR/FR values 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. 
8.	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. 
9.	DOE must not entertain this project any more if found the DPR/FR is tamprered with at any point in time. PP can not give different DPR’s and FR’s. They must submit only the one given to Banks and other agencies while obtaining loans and decision making time. 



10.	 How is the base line defined in this project? Is Base line hypothetically defined with no proper evidences and proper justification? In such case, DOE cannot take the base line as suggested by the PDD.  Please check that there are real emission reductions beyond the real and factual base line. It may so happen that this project qualifies for no CER’s. DOE cannot assume values and things as giving by this PP. Whatever values are considered throughout the project in all documents including the real DPR (not the one prepared for CDM, the one given to the banks and others), they must be validated, verified and double checked. Do not ask PP for DPR. Ask the parties who have been given DPR by the PP. Get directly from the bank and others by each page of the DPR and Feasibility report signed. Such document can be considered as a real DPR or FR. UNFCCC CDM process cannot be degraded by fabricating and misinterpreting the project base line and additionality.  

11.	DOE to be more careful so that this is a genuine CDM project. What is the exact project cost? The project cost is covering what? Each value considered must be validated with proof. The machinery is second hand purchased or fresh and new from an OEM? In either case DOE to check all the quotations, proposals, purchase orders, invoices, way bills, transport bills, proof of payments like bank statements. DOE to check with banks by way of written confirmation the amount transacted, to whom the money is paid, when the money is paid, is the party paid is the correct party as shown in the purchase orders. It may so happen that the values, party names, dates are fabricated and misrepresented in this project. DOE should terminate their contract for this project immediately. This is the only way out to protect the value of CDM process. If the PP is purchasing second hand or second quality equipment and inflating the purchase order values and invoices, this must be probed thoroughly and real values to taken for additionality calculation. Then I’m sure the additionality is not there at all in such a situation.
12.	Project owner should show some undertaking letter from bank manager to DoE stating that both DPR’s are same. These kinds of letters should not be accepted and entertained by DoE at face value, but must be checked independently. 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. 
13.	Has the PP considered the CDM revenues while envisaging the project? Without CDM the project was not viable, is it right? This project is having a debt component? Then how bankers or lenders gave the loan? Have the bankers or lenders considered the CDM revenues while agreeing to give loan to this projects? If not this project should be rejected right away by DOE by terminating the contract forthwith. If yes, where is the proof? What is the date of the evidence document from bank? Is this document printed now a days or earlier. DOE to independently check the same. If the document is  available from Bank it must be checked from all angles so that it is genuine and not forged and date changed by putting back dated. This is normally done, DOE to be aware of this please. Please check the communication the PP had during that time with banks, emails and postal receipts and the weights and dates mentioned on the receipts. Do not believe in courier bills and receipts since these can be cooked up easily. Insist on government owned postal service receipts only. If the project is fully equity project then on what basis the PP has invested full equity in to the project while considering the CDM revenue? DOE to check the same in detail and bring out the facts. Is there any past record of this PP to invest or not to invest at returns what he is talking about in this project? Proper evidences must be reviewed and digged out by the DOE and take decision on the project based on established facts. Do not ask documents from PP, DOE to collect the same from different sources to do independent evaluation. 


Submitted by: Benjamin franklin

1.	Is the project equipment purchased second hand equipment or sourced from cheap foreign sources? If yes, the issue must be probed by DOE since invoices will invariably be inflated and forged. Total project costs mentioned by PP will not be the same as originals. Hence no additionality. These facts must be probed in full by DOE by checking all documents and money transactions along with bank statements and certified accounts by a legally acceptable financial analyst. 

2.	From DOE side which auditor has done marketing and business development for acquiring this business of validating this project? With whom he or she was co-ordinating at PP or CER buyer? The same person who has done the marketing and business development to acquire the business do validation or participate in any manner what so ever in the validation process? One cannot do like that. It is against the accreditation rules and norms followed since ages. DOE should send auditors from different offices or countries to do this validation audit. DOE must take care of impartiality and accreditation rules. Due to the targets set by the DOE managements auditors are doing marketing and meeting clients and giving promises that the project will be taken care. Is it acceptable and fair? This must be stopped. No auditor should do marketing. Only non-auditing staff should do marketing. DOE to ensure the same please. 


3.	If applicable only: Is these machines, equipment was a part of any bundle of CDM activity envisaged and developed earlier. DOE to check the same through independent sources also. Once some bundles are non-additional and getting negative validation from a DOE, PP is rolling out the same project as an individual project which is not a CDM project at all. DOE to verify the same from independent sources and also take undertaking in the form of an affidavit from the PP’s that any misrepresentation or false statement with respect this would attract strict legal action from UNFCCC and DOE. Furthermore the registered project must be de-registered in case of any future findings contradicting the submissions made by the project owner.  



4.	DOE to ensure that the PDD values are consistent and ensure that the CDM project is a genuine project
5.	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. 
6.	Careful study must be done so that the DPR/FR is not in different versions made and submitted with different purposes to different agencies, which is totally unacceptable, illegal and unethical. 
7.	DPR/FR values 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. 
8.	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. 
9.	DOE must not entertain this project any more if found the DPR/FR is tamprered with at any point in time. PP can not give different DPR’s and FR’s. They must submit only the one given to Banks and other agencies while obtaining loans and decision making time. 



10.	 How is the base line defined in this project? Is Base line hypothetically defined with no proper evidences and proper justification? In such case, DOE cannot take the base line as suggested by the PDD.  Please check that there are real emission reductions beyond the real and factual base line. It may so happen that this project qualifies for no CER’s. DOE cannot assume values and things as giving by this PP. Whatever values are considered throughout the project in all documents including the real DPR (not the one prepared for CDM, the one given to the banks and others), they must be validated, verified and double checked. Do not ask PP for DPR. Ask the parties who have been given DPR by the PP. Get directly from the bank and others by each page of the DPR and Feasibility report signed. Such document can be considered as a real DPR or FR. UNFCCC CDM process cannot be degraded by fabricating and misinterpreting the project base line and additionality.  

11.	DOE to be more careful so that this is a genuine CDM project. What is the exact project cost? The project cost is covering what? Each value considered must be validated with proof. The machinery is second hand purchased or fresh and new from an OEM? In either case DOE to check all the quotations, proposals, purchase orders, invoices, way bills, transport bills, proof of payments like bank statements. DOE to check with banks by way of written confirmation the amount transacted, to whom the money is paid, when the money is paid, is the party paid is the correct party as shown in the purchase orders. It may so happen that the values, party names, dates are fabricated and misrepresented in this project. DOE should terminate their contract for this project immediately. This is the only way out to protect the value of CDM process. If the PP is purchasing second hand or second quality equipment and inflating the purchase order values and invoices, this must be probed thoroughly and real values to taken for additionality calculation. Then I’m sure the additionality is not there at all in such a situation.
12.	Project owner should show some undertaking letter from bank manager to DoE stating that both DPR’s are same. These kinds of letters should not be accepted and entertained by DoE at face value, but must be checked independently. 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. 
13.	Has the PP considered the CDM revenues while envisaging the project? Without CDM the project was not viable, is it right? This project is having a debt component? Then how bankers or lenders gave the loan? Have the bankers or lenders considered the CDM revenues while agreeing to give loan to this projects? If not this project should be rejected right away by DOE by terminating the contract forthwith. If yes, where is the proof? What is the date of the evidence document from bank? Is this document printed now a days or earlier. DOE to independently check the same. If the document is  available from Bank it must be checked from all angles so that it is genuine and not forged and date changed by putting back dated. This is normally done, DOE to be aware of this please. Please check the communication the PP had during that time with banks, emails and postal receipts and the weights and dates mentioned on the receipts. Do not believe in courier bills and receipts since these can be cooked up easily. Insist on government owned postal service receipts only. If the project is fully equity project then on what basis the PP has invested full equity in to the project while considering the CDM revenue? DOE to check the same in detail and bring out the facts. Is there any past record of this PP to invest or not to invest at returns what he is talking about in this project? Proper evidences must be reviewed and digged out by the DOE and take decision on the project based on established facts. Do not ask documents from PP, DOE to collect the same from different sources to do independent evaluation. 


Submitted by: Benjamin franklin


The comment period is over.
* Emission reductions in metric tonnes of CO2 equivalent per annum that are based on the estimates provided by the project participants in unvalidated PDDs