Cogeneration in India, being a tropical country with power shortfall, means often something else than in Germany. Here cogeneration in particular in the context of sugar mills means the generation of excess power to be sold to an external customer and wheeled through the public grid. All what you have to do, is to junk the old boiler and low pressure steam turbine and replace it by a high temperature and pressure system. I call this a simple energy efficiency measure and not introducing cogeneration. Cogeneration as understood elsewhere means “Combined Heat and Power” generation. In other words it generates with one integrated system  both,  power and process heat. Such plants achieve system efficiencies of 80% - 85%. This means at least 80% of fuel energy supplied to the plant is utilized (i.e. useful energy output). Compare this with conventional power plant efficiencies of at most 40%. Presently the MoP has issued guidelines for the States  concerning cogeneration. Some States give preferential tariffs for such “cogeneration = combined heat and power plants”. As always investors find loopholes in such rules and regulations, meaning they gladly take the special tariffs, but may not really operate a “combined heat and power” plant. We have picked the directives of a State Electricity Regulatory Commission (SERC) for our 2,700 odd subscribers and like to discuss on this example, the difficulties to define and monitor “cogeneration”. All readers are encouraged to read, understand and  analyse this directive, and appreciate the complexity or simplicity. It is not an easy task.  We are looking for comments about the best way  to define a cogeneration system, not only for sugar mills, and suggest ways to verify in the field its operational efficiency.