The statement “In the absence of the project activity, equivalent amount of power and steam would have been sourced from more carbon intensive sources” is incorrect. In the absence of the project activity steam would have been generated using rice husk fired boiler and the power would have been imported from grid. Let DOE check the common practice among rice milling industry and find out what is the practice. 

As per project boundary diagram given in the PDD, the steam is used for generation of electricity and the steam is extracted from the turbine. Therefore, electricity generation is the prime purpose. 

Keeping the above in view, using investment comparison analysis is not correct. PP should use benchmark analysis to demonstrate additionality.

The project is setting up a rice mill. Rice husk will be generated by the project. How can there be cost attached to the by-product? If the PP contends that it would sell the rice husk then there is no justification to include transportation cost in costing the rice husk. The cost cannot be more than Rs.400/ton ex-factory. The capacity of rice mill is not given in PDD. DOE should ascertain the rice husk generated by the project and only the excess requirement, if any, should be taken at the invoice value. The difference between the levelized cost of baseline and project activity is very high and is not correct. 

The project is eligible for 100% depreciation, MNRE subsidy and tax holiday. Tax savings due to depreciation should be taken into account while calculating the financial indicator 

DOE should also check the power requirement of the project. It is most probable that the generated electricity will be more than the power needed by the project. Therefore, the additional power will be exported to grid. This income should also be accounted