Q1: What types of licences can be applied for regulated activities related to Natural Gas, RLNG, Flared Gas, and LNG? A: Licences for these regulated activities are specified in Schedule-I of the Natural Gas Regulatory Authority (Licensing) Rules, 2002, the LNG Rules, 2007, and the Flared Gas Guidelines, 2016.

Q2: What laws or rules govern the process of obtaining these licences? A: The relevant regulations include the OGRA Ordinance, 2002, the Natural Gas Regulatory Authority (Licensing) Rules, 2002, the Oil & Gas Regulatory Authority (Liquefied Natural Gas) Rules, 2007 (LNG Rules), the LNG Policy, 2016, and the Flared Gas Guidelines, 2016.

Q3: Who is eligible to apply for a licence, and where should the application be submitted? A: Any company, whether incorporated inside or outside Pakistan, can apply for a licence by submitting the application to the Authority through the Registrar, OGRA.

Q4: Can applications be filed online on the OGRA website? A: No, applications must be filed in the specific format provided in Schedule-I of the relevant rules.

Q5: What initial documents are required when filing these applications? A: Applicants must submit documents/information as stipulated in Rule 4 of the Natural Gas Regulatory Authority (Licensing) Rules, 2002, and the LNG Rules, 2007.

Q6: Which departments within OGRA are involved in processing these applications? A: The relevant departments include the Gas, Finance, Registrar, and LNG Departments.

Q7: Are interested or affected parties, including the general public, involved in the licence granting process? A: Yes, all interested or affected persons, parties, and the general public are invited through a Public Notice to file comments, objections, and interventions. These notices are published in leading national and local newspapers in both Urdu and English, as per Rule 6(c) of the Natural Gas Regulatory Authority (Licensing) Rules, 2002.

Q8: What is an intervention request, and how is it processed under the relevant rules? A: The mechanism for processing intervention requests is detailed in Rule 7 of the Natural Gas Regulatory Authority (Licensing) Rules, 2002, and the LNG Rules, 2007.

Q9: Is there an opportunity for a hearing before a licence is issued? A: Yes, after examining the application, the Authority may hold a Pre-Admission hearing if deemed appropriate. Subsequently, a Public Hearing is conducted in compliance with Rule 10 of the Natural Gas Tariff Rules, 2002. a) The hearing is conducted by the Authority if the quorum is complete (Chairman and two Members as per Section 4(1) of the OGRA Ordinance, 2002). b) Hearings are usually held in the four provincial capitals for Revenue Requirement cases. For Natural Gas and RLNG cases, hearings are held in the relevant city of Pakistan.

Q10: How long does it take to process and finalise such applications? A: If all documentation and the quorum of the Authority are complete, the case is typically finalised within 180 days.

Q11: Who is the final authority that grants these licences after the entire process is completed? A: The Authority, comprising the Chairman and two Members under Section 4(1) of the OGRA Ordinance, 2002, grants the licences. However, under Section 10(2) of the OGRA Ordinance, 2002, the power to grant licences for the transportation, filling, or marketing of LPG, LNG, or CNG may be delegated to a Member of the Authority. If not delegated, the full Authority grants these licences.

Q12: Is there a fee associated with the application for a licence, and is it refundable? A: Yes, the fees for each category of licence are specified in Schedule-II of the relevant Rules and are payable to OGRA when the application is filed. The fee is refundable if the application is withdrawn before it is admitted by the Authority.

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Q13: How can the application fee be paid? A: The fee must be paid via Demand Draft made payable to the Oil and Gas Regulatory Authority.

Q14: What is the validity period for these licences? A: The validity of the licences is stipulated in Rule 3 of the relevant rules.

Q15: Can a licence be transferred to another person or party? A: No, a licence can only be transferred to another party with the written approval of the Authority.

Q16: Is there any other fee required to be paid by the licensee besides the application fee? A: Yes, additional fees are required as specified in Rule 29 of the LNG Rules, 2007, and the NGRA (Licensing) Rules, 2002, as outlined in Schedule-II of these rules.

Q17: What remedy is available against a decision made by OGRA? A: A review can be filed under Section 13 of the OGRA Ordinance, 2002, Rule 15(4) of the NGRA (Licensing) Rules, 2002, and the LNG Rules, 2007.

Q18: Is the applicant given an opportunity to present their case before OGRA finalises the application? A: Yes, if the applicant desires, an opportunity for a presentation is provided upon written request to facilitate the applicant.

Q19: Who will take the presentation from the applicant? A: The concerned department or a member of the Authority will take the presentation from the applicant.

Q20: Can the Authority reject a licence application without providing an opportunity for a hearing? A: No, according to Rule 5(3) of the OGRA (Licensing) Rules, 2002, and the LNG Rules, 2007, the Authority cannot refuse admission without giving the applicant an opportunity to be heard or to make a written representation.

Q and A’s on LPG

1. What is Liquefied Petroleum Gas (LPG)? Liquefied Petroleum Gas (LPG) is a clean, environmentally friendly, portable, and economical fuel. Legally defined, “LPG” refers to any material with a vapour pressure not exceeding the limits allowed for commercial propane, comprising predominantly the hydrocarbons propane, propylene, butane (normal butane or isobutene), and butylenes, either individually or as mixtures.

2. What is the Role of OGRA in Licensing of LPG? The Oil & Gas Regulatory Authority (OGRA) is vested with the authority to regulate the LPG sector under the OGRA Ordinance, 2002, and the LPG (Production & Distribution) Rules, 2001. OGRA issues licences for various categories of LPG facilities in accordance with these provisions.

3. Are LPG (Production & Distribution) Rules 2001 available on OGRA’s website? Yes, the LPG Rules are available on OGRA’s website for public access.

4. Who can apply for an LPG licence? Any company that is authorised by its memorandum of association or other appropriate legal instrument may apply for a licence to operate various categories of LPG facilities as per the LPG Rules, 2001.

5. What are the requirements for obtaining a licence for various categories of LPG facilities? OGRA issues licences for LPG production/extraction and air mix facilities, LPG storage and filling plants, and LPG auto refueling stations. The specific requirements for each category are detailed on OGRA’s website.

6. How much LPG is produced on a monthly basis? Monthly LPG production data is publicly available on OGRA’s website.

7. How much LPG is imported on a monthly basis? Monthly LPG import data is also available on OGRA’s website.

8. Where can details of OGRA’s LPG Third Party Inspectors be found? The details of OGRA’s authorised Third Party Inspectors are listed on OGRA’s website.

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9. What is the duration of licences for various categories of LPG facilities? A construction licence for LPG facilities is initially granted for a period of one year, which can be extended up to 15 years, subject to compliance with the relevant regulations.

10. Who is eligible to import LPG? According to the LPG Policy, any entity holding a valid OGRA licence may import LPG, provided they comply with all applicable government duties and taxes.

11. Is there a restriction on the storage capacity of LPG refueling stations? Yes, the storage capacity for LPG at auto refueling stations is restricted to a maximum of 10 metric tons.

12. Where can one find details of LPG licences issued by OGRA? Details of the various LPG licences issued by OGRA are available on OGRA’s website.

13. What standards are followed in the LPG sector? The LPG sector adheres to the standards outlined in the LPG Rules, 2001, which are detailed in Appendix I of these Rules.

14. What is Liquefied Natural Gas (LNG)? Liquefied Natural Gas (LNG) is natural gas that has been cooled to a liquid state for ease of storage and transport.

15. What is OGRA’s role regarding the licensing of LNG? The licensing process for LNG-related activities is governed by the OGRA (LNG) Rules, 2007, which are available on OGRA’s website.

16. Are the LNG Rules, 2007, available on OGRA’s website? Yes, the LNG Rules are available on OGRA’s website for public reference.

17. Who can apply for an LNG licence? Any company, whether incorporated within Pakistan or internationally, may apply to OGRA for a licence to undertake regulated LNG activities. Applications must be filed with the Registrar, OGRA, along with the requisite documents as per the LNG Rules, 2007.

18. What is the duration of a Provisional Licence for an LNG facility? A Provisional Licence for an LNG facility is granted for one year. During this period, the licensee must apply for a construction licence and fulfill all formalities under Rule 4(3) of the LNG Rules, 2007.

19. What is the duration of a Construction Licence for an LNG facility? A Construction Licence for an LNG facility is granted for a period of two years.

FAQs on CNG

1. What are the applicable rules for the CNG sector? The CNG sector in Pakistan is regulated by the Pakistan CNG (Production & Marketing) Rules, 1992.

2. What are the relevant rules for the renewal of a CNG marketing licence? The renewal of a CNG marketing licence is governed by Rule 7(ii) and Rule 7(iii) of the Pakistan CNG (Production & Marketing) Rules, 1992.

3. What is the exact time period defined in the CNG Rules, 1992 for applying for a renewal of a CNG marketing licence? Applications for the renewal of a CNG marketing licence must be submitted at least ninety (90) days before the licence’s expiry.

4. If a licensee applies for renewal before the expiry of their marketing licence but not within the 90-day period, do they qualify for renewal? Yes, they qualify for renewal but must pay a penalty of Rs. 50,000/- and complete other applicable formalities.

5. If a licensee applies for renewal after the expiry of their marketing licence, do they qualify for renewal? Yes, they qualify for renewal but must pay a penalty of Rs. 100,000/- and complete other applicable formalities.

6. What is the fee for renewing a CNG marketing licence? The fee for renewing a CNG marketing licence is Rs. 25,000/-.

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7. What is the mode of payment for submission of penalties or fees to OGRA? Penalties and fees must be paid via Demand Draft or Pay Order in favour of OGRA, payable at Islamabad.

8. Is a valid Form-B required for the renewal of a marketing licence? Yes, a valid/renewed Form-B is required for the renewal of a CNG marketing licence, along with other applicable formalities.

9. Do the documents submitted to OGRA for licence renewal need to be attested? Yes, documents must be attested by a Class-1 Gazetted Officer or a Notary Public.

10. Do the annual inspection fees of a CNG station need to be cleared before renewing its marketing licence? Yes, there should be no pending inspection fees or dues against the CNG station intending to renew its marketing licence.

11. Does a CNG station need to comply with the provisions of the CNG Rules, 1992 to acquire a renewal of its marketing licence? Yes, compliance must be verified through a third-party inspection report of the concerned CNG station.

12. Is an NOC from the concerned Oil Marketing Company required for the renewal of a CNG marketing licence? Yes, an NOC is required if a petrol pump is established on the premises of the concerned CNG station.

13. Do licensees need to submit an affidavit confirming there is no change in the physical location of the CNG station for licence renewal? Yes, an affidavit in the prescribed format confirming no change in the physical location of the CNG station must be submitted.

14. Should there be no pending court cases that restrict OGRA from renewing a CNG marketing licence? Yes, this must be confirmed through a prescribed affidavit submitted by the licensee.

15. Is a confirmation letter required from the Explosives Department for the renewal of a CNG marketing licence? Yes, a confirmation letter from the Explosives Department indicating that Form-B is granted after completing applicable formalities/safety rules is required.

16. Why is the renewal of every CNG marketing licence mandatory? Operating any CNG station without a valid CNG marketing licence is a violation of Rule-3 of the CNG Rules, 1992. Therefore, a valid licence is mandatory for the operation of any CNG station.

17. Should a request for the renewal of a CNG marketing licence be submitted on the official letterhead of the concerned CNG station? Yes, the renewal request must be submitted on the letterhead of the concerned CNG station.

18. Must a formal request for the renewal of a CNG marketing licence be signed by an authorized signatory? Yes, the formal request for renewal must be signed by an authorized signatory of the concerned CNG station.

19. Does the renewal of a CNG marketing licence require permission from the competent authority? Yes, every CNG marketing licence renewal requires the approval of the Authority, subject to the completion of applicable formalities.

20. What is the estimated time required for the renewal of a CNG marketing licence after all applicable formalities are completed? The renewal process typically takes 10-15 days, subject to the completion of the Authority’s quorum.

21. For how long can a CNG marketing licence be renewed after its expiry, as per the requirements of the CNG Rules, 1992? A CNG marketing licence can be renewed for a period of five (05) years from the date of its expiry.

22. Can the CNG marketing licence of a CNG station be extended multiple times? Yes, a CNG marketing licence can be renewed multiple times but for a maximum period of five years from its expiry each time.

By The Josh and Mak Team

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