This is the second project the same PP has webhosted. The comments given here apply equally to the other project also.

How the equity IRR is considered a correct financial indicator for demonstrating additionality when the project is financed by debt and equity? Equity IRR is not appropriate for this project

When RERC has recommended a return of only 16% on equity for wind power project, on what basis the PP is seeking 18.30%? If this is the minimum return expected by the PP to set up the project, then the project activity does not conform to Annex 5, EB 62 and should be rejected straightaway.

Based on the available information Enercon never charged more than 5% escalation for O&M cost; No project has assumed one time bullet escalation of 10% in 11th year, 10% O&M contingency, which is provided at 10% or asset manager’s cost, increase in insurance premium  by 1%,  or for that matter any of the charges which the PP/consultant has claimed to make the project additional. This is not in conformity with Additionality Tool as it is based on subjective profitability expectation of the PP. DOE should  not allow any expense other than O&M cost with 5% escalation throughout, insurance premium and statutory charges if the PP is able to evidence the same with documents.

PP/consultant have provided 7.69% depreciation as per IT Act. Since when the depreciation rate has been changed to 7.69%? Or is it a method to increase the tax outflow and bring down the IRR?

Even with CDM benefits the project is not likely to cross the benchmark. Then why is the PP setting up the project? If the PP is doing charity, then why to claim CDM benefits? Either the benchmark is incorrect or the financial parameters used are undependable. If the financial indicator does not cross the benchmark after considering CDM benefits, the project does not satisfy paragraph 112 of VVM.