PDD states, “Based on its previous experience with Green Building Delhi project, ONGC Limited identified that the proposed project is not a financially viable proposition”.  If the previous project were to be the basis for deciding whether the project is financially viable or not, then all the projects will be non-additional, if one project set up by the PP is non-additional. This is very surprising to see that an organization like ONGC makes such a statement, without understanding the implication of the statement

There is no explanation on how the savings in the electricity has been calculated. Since the investment is not given, reader cannot comment on electricity saved. 

PP states, “As explained earlier, ONGC is aware of its social responsibility and therefore has a long term vision to attain Carbon Neutrality”. But, surprisingly, ONGC is not aware of the need to be transparent despite being a public sector company.  It is not even aware of the CDM rules. Guidelines for completing PDD requires PDD to “Explain and justify key assumptions and rationales. Provide relevant documentation or references. Illustrate in a transparent manner all data used to assess the additionality of the project activity (variables, parameters, data sources etc.)”. Further, Additionality Tool states “Present the investment analysis in a transparent manner and provide all the relevant assumptions, preferably in the CDM-PDD, or in separate annexes to the CDM-PDD, so that a reader can reproduce the analysis and obtain the same results”. ONGC has not thought it necessary to comply with this regulations. Whatever, information ONGC has chosen to give are least relevant to additionality.  The information has been hidden and the PDD is not transparent.

It is not clear how the DOE web hosted this project without even satisfying itself that the project conforms to CDM rules. DOE should not take up this project for validation unless it is re webhosted again with all information. EB may kindly ensure that this project is not accepted for registration unless it is re-webhosted with all information.