This project seems to be a cooked up project. I don’t know why DOE’s are taking risk in webhosting such kind of projects and more over General Carbon’s team is known for creating refurbished documents and cheating DOE’s. However, DOE has to ensure that all the documents submitted by PP/Consultant to be verified with originals.   

First of all I would like to CONGRATULATE the consultant for preparing a good PDD; especially section B.5 is very good! 
Is this the same GC team? Because they were and are handling only REJECTED projects. How come they have taken a new project?

I.	My query is regarding the “Applicability criteria of the methodology”, I want a reply/answer the consultant and DOE; 

1.	The project activity involves installation of a wind power project. The project activity does not displace electricity from a distribution system. Thus, AMS IF is not applicable to this project activity. 

	The consultant/PP has mentioned the above for the 1st Applicability criteria of the methodology. I want to know how the DOE has validated this. 

	When you’re selling/wheeling the generated electricity to Grid? What are you doing there?

	In the PDD you are telling the GRID  is dominated by FOSSIL fuel fired power plants and you are using Grid emission factor to calculate the CER’s, Then how the DOE is validating this? I am confused!!!

	If you declare/claim that “The project activity does not displace electricity from a distribution system” Then what the HELL it is doing? How can you claim CER’s?

	My language might be a bit harsh, cos your writing such Bl……y things, what to do?  But come on Guy’s answer me, don’t just write it a irrelevant question and close the issue, EB member’s please, please look in to this.

2.	The project activity is a new power plant installed at a site where there was no existing renewable energy power plant. Thus, the project activity complies with clause (a) of the applicability criteria. 

	How can you declare that?  Are you guy’s JOKING n think EB and others as FOOLs to believe whatever you write? 

	Mokla, Sonu and Serava villages of Jaisalmer, Rajasthan is having good PLF, that’s why there are many WTG in these sites and even PP has put up his WTG’s here. Then how can you tell this? Pls. come out of this, otherwise I have to take back my word’s that it’s a Good PDD? So, GC guy’s wake up! What the Hell the DOE is doing? How are you validating this? What’s happening? 

	I request the EB to look into this meth issues; it’s of a serious nature.

II.	Next coming to the post tax project IRR 

i.	It is 7.10% without considering revenues from CDM against a benchmark of 13.90%. 
ii.	My Goodness! Then why did the PP take up this project? Or the consultant is doing a MOCKERY of EB guidelines?
iii.	Why? Even with CDM benefits these projects will never cross Benchmark. Then why the PP is investing in such kind of projects (I don’t expect an answer telling environmental friendly, less GHG, pls. give a valid explanation). 

III.	Stake holder meeting is conducted by OEM personnel’s, what about the PP and consultant? Why they did not attend the meeting? Was a meeting really happened or it’s a again a story?

	Then what is the need of a stake holder meeting? How the DOE is validating, is he really following the EB guidelines or blindly following the Consultant?

	I feel this is a cooked up stuff, like the offer letter. 

	So, if you purchase WTG’s Offer letter, Stake holder meeting notice, Attendance sheet and Minutes of meeting are free, Am I right?

IV.	How can you take D/E ration “Based on investment decision made by management of MWP”. Are you aware of EB guidelines? What the DOE is doing? How did you validate this? 

V.	When PP is capable of pumping in so much money for this project, why do you need CDM revenue?  Even when with CDM benefits the project will never cross Benchmark!

The point to be noted is that the wind projects are mainly installed considering CDM revenues and offsetting of tax liability of the company as a result of accelerated depreciation of 80%.

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.

CDM project registration itself has become a joke.  This is not the first wind project of Bannari. If EB/DOE had noticed about  Bannari and it’s group of companies they have many other installation of  wind mills which are not yet registered.  Till now none of their projects has been registered because they were unable to prove the financial additionality. When a company or its group of companies investing every year on wind mill, why do they need CDM revenue.  As it is evident that they have not considered CDM seriously and if their project gets registered under CDM it will be extra revenue to Bannari.  

GC may play some games by using their relationship with DOE’s because that is their strategy of doing business which is proven in the past.
Everybody knows that in a country like India, windmills are installed by big players to avoid income tax. I strongly object on additionally part of this project because they are showing investment barrier. 

When Bannari has invested in wind projects previously, how can they take coal as baseline for calculating CERs. This kind of proving Baseline and Additionality has no meaning and the project should be rejected in the DOE stage itself.
Consultant may show some useless Charted Accountant’s certificate or letter to prove investment barrier. But, DOE is required to check any other authentic document other that CA report. Anybody can get the CA certificate or bank letter by bribing. 

It is not a genuine project. If request for registration is given, EB should reject this project without any review or clarification requests. 

Why this project is not following the CDM guidelines? 
I want to know how and why the DOE has taken up such a project. What due diligence has been done before taking up such a project? Is the DOE technically competent? 
The Baseline is not correct, because
1.	The PP (Bannari Amman Spinning Mill Pvt Ltd) already have many WTG’s in Tamil Nadu itself, is the DOE aware of this? What does the PP and consultant say for this?
2.	Has the DOE checked the web-site, annual reports and other documents of the PP, if yes? Then what does the report say and what is the final conclusion of the DOE? Kindly provide all the reference documents/link in response to this query.
3.	Is this project registered under VCS?  How many VCS projects do the PP has? Is the DOE aware of this? 
4.	I had seen a Bannari Amman Spinning Mill Pvt Ltd managed by Enercon project last year on the UNFCCC site which is 11.2MW capacity, so I request the DOE to look into the link and proceed forward. (http://cdm.unfccc.int/Projects/Validation/DB/FYPAQ52NJB35JZRDUIC0GVD36E6S33/view.html). 
The additionality is totally wrong and misleading, 
1.	Again I have a doubt, is the financial part of the project looked up by an expert or the DOE just believes the consultant?
2.	Has the DOE checked all the financial parameters as per the latest investment analysis guidance?
3.	The PP is really strong in Finance; this is proved by his annual reports and from the investment made on WTG’s by the PP. So why do you need CDM revenue? When you are financially so strong. 
4.	By investing in WTG’s the PP is already getting TAX Exemption in India as per section 80 IA of Income Tax Act for 10 years. Is the Consultant and DOE really aware of this? Is this reflected in the financial calculation sheets? As the financial calculation sheets are not available, I request the DOE and EB members to look in to this.
5.	As the life of WTG is 20 years, he is getting tax benefits for 10 years and for the rest 10 years he wants CDM money. For the entire 20 years he is getting money from the state electricity board as per the PPA. With so many benefits how can you still claim that the project is financially not attractive? I request the EB members to look into it.
6.	PP has already run the machines for 2 years without CDM revenue, so why he wants it now?

And the de-bundling proven is very funny, when the PP is having a project under validation in the last year itself, so how can the PP claim that he is not having any project within 2 years? Pls. refer the below link 
http://cdm.unfccc.int/Projects/Validation/DB/FYPAQ52NJB35JZRDUIC0GVD36E6S33/view.html

What the DOE is doing, he is really not aware of it? If yes, then how and why did the DOE webhost this project?

I strongly feel that the project should not have been web hosted, however the consultant and DOE have succeeded in achieving this.  
Therefore, now I request the EB members to look into this project as a special case. 

Why This project is not following the CDM guidelines. 
I want to know how and why the DOE has taken up such a project. What due diligence has been done before taking up such a project? Is the DOE technically competent? 
The Baseline is not correct, because
1.	The PP (Bannari Amman Spinning Mill Pvt Ltd) already have many WTG’s in Tamil Nadu itself, is the DOE aware of this? What does the PP and consultant say for this?
2.	Has the DOE checked the web-site, annual reports and other documents of the PP, if yes? Then what does the report say and what is the final conclusion of the DOE? Kindly provide all the reference documents/link in response to this query.
3.	Is this project registered under VCS?  How many VCS projects do the PP has? Is the DOE aware of this? 
4.	I had seen a Bannari Amman Spinning Mill Pvt Ltd managed by Enercon project last year on the UNFCCC site which is 11.2MW capacity, so I request the DOE to look into the link and proceed forward. (http://cdm.unfccc.int/Projects/Validation/DB/FYPAQ52NJB35JZRDUIC0GVD36E6S33/view.html). 
The additionality is totally wrong and misleading, 
1.	Again I have a doubt, is the financial part of the project looked up by an expert or the DOE just believes the consultant?
2.	Has the DOE checked all the financial parameters as per the latest investment analysis guidance?
3.	The PP is really strong in Finance; this is proved by his annual reports and from the investment made on WTG’s by the PP. So why do you need CDM revenue? When you are financially so strong. 
4.	By investing in WTG’s the PP is already getting TAX Exemption in India as per section 80 IA of Income Tax Act for 10 years. Is the Consultant and DOE really aware of this? Is this reflected in the financial calculation sheets? As the financial calculation sheets are not available, I request the DOE and EB members to look in to this.
5.	As the life of WTG is 20 years, he is getting tax benefits for 10 years and for the rest 10 years he wants CDM money. For the entire 20 years he is getting money from the state electricity board as per the PPA. With so many benefits how can you still claim that the project is financially not attractive? I request the EB members to look into it.
6.	PP has already run the machines for 2 years without CDM revenue, so why he wants it now?

And the de-bundling proven is very funny, when the PP is having a project under validation in the last year itself, so how can the PP claim that he is not having any project within 2 years? Pls. refer the below link 
http://cdm.unfccc.int/Projects/Validation/DB/FYPAQ52NJB35JZRDUIC0GVD36E6S33/view.html

What the DOE is doing, he is really not aware of it? If yes, then how and why did the DOE webhost this project?

I strongly feel that the project should not have been web hosted, however the consultant and DOE have succeeded in achieving this.  
Therefore, now I request the EB members to look into this project as a special case.