The Oil and Gas Regulatory Authority (OGRA) is the primary body responsible for regulating the Liquefied Petroleum Gas (LPG) sector in Pakistan. Established under the OGRA Ordinance, 2002, and the LPG (Production & Distribution) Rules, 2001, OGRA oversees the issuance of licences for constructing and operating LPG facilities. This article provides a detailed guide for clients seeking to obtain a licence for LPG Storage and Filling Plants facilities.

Understanding LPG and Its Regulation

Liquefied Petroleum Gas (LPG) is a versatile and economical fuel composed primarily of hydrocarbons such as propane, propylene, butane, and butylenes. The regulation of LPG storage and filling facilities ensures safety, environmental compliance, and market stability. OGRA enforces these regulations to uphold industry standards and protect public safety.

Types of Licences Issued by OGRA

OGRA issues various categories of licences in the LPG sector, including:

  • Licence for Production/Extraction and LPG Air-Mix Facilities
  • Licence for LPG Storage and Filling Plants Facilities
  • Licence for LPG Auto Refueling Stations
  • Licence for LNG Terminals

This article focuses specifically on the requirements and processes for obtaining a licence for LPG Storage and Filling Plants facilities.

Requirements for LPG Storage and Filling Plants Facilities

The process for obtaining a licence involves several critical steps and the submission of various documents. Here are the detailed requirements:

  1. Application Form:
    • The application must be submitted in triplicate using the prescribed proforma as set out in Appendix II & III of the LPG Rules, 2001.
  2. Licence Fee:
    • A Pay Order/Bank Draft of Rs. 500,000/- in favour of the Oil & Gas Regulatory Authority, payable at Islamabad.
  3. Company Registration:
    • Attested copy of the company’s incorporation certificate.
    • Attested copy of the Memorandum and Articles of Association.
    • Attested copies of ID cards of all directors/partners.
  4. Financial Competence:
    • Proof of financial competence issued by a bank. The format should certify that the company or its chief executive maintains an account with the bank and has sufficient financial resources equivalent to US $0.5 million for setting up the requisite LPG infrastructure.
  5. Company Organogram:
    • A detailed organogram of the company indicating the management and operational structure.
  6. Location Details:
    • Exact location of the plant site.
  7. Audited Reports:
    • Last three years’ audited financial reports (if applicable).
  8. Marketing Plan:
    • A comprehensive marketing plan specifying the current and future locations and capacities of the plant, area of operation, number of cylinders, and details of distributors (province/city-wise).
  9. Minimum Work Program:
    • Number and capacity of storage tanks.
    • Bottling facility capacity.
    • Quantity of LPG to be distributed per day or per month.
    • Identification of areas where distribution/marketing of LPG is planned.
  10. Site Verification Fee:
    • A Bank Draft/Pay Order of Rs. 25,000/- in favour of the Oil & Gas Regulatory Authority for site verification.

Application and Review Process

  1. Submission and Initial Review:
    • Submit the complete application along with the requisite documents and fees. OGRA will review the application to ensure it meets all regulatory requirements.
  2. Communication of Shortcomings:
    • If there are any deficiencies in the application, OGRA will communicate these to the project proponent for rectification.
  3. Appointment of Third-Party Inspectors:
    • Once the application is complete, OGRA will appoint third-party inspectors to conduct a site inspection. The applicant must offer the site for pre-commissioning inspection within the stipulated timeframe.
  4. Inspection and NOCs:
    • After the third-party inspection, the applicant must provide No Objection Certificates (NOCs) from the District Coordination Officer (DCO), Environmental Protection Agency (EPA), and the Explosives Department.
  5. Authority’s Decision:
    • Upon receipt of the inspection report and NOCs, the complete case is submitted to OGRA for consideration. The Authority will decide on the grant of the licence within ninety days of receiving a complete application.

Issuance of Licence

If the application meets all the requirements and passes the inspections, OGRA will issue a construction licence for a period of one year. During this period, the applicant must complete the construction and request a final inspection for the operational licence.

Conclusion

Navigating the regulatory landscape for obtaining a licence for LPG Storage and Filling Plants facilities can be complex. However, with meticulous preparation and adherence to OGRA’s guidelines, the process can be smooth and efficient. Josh and Mak International offers expert legal assistance to guide clients through each step, ensuring compliance and successful licensing.

For further information and assistance, please contact Josh and Mak International. Our team of legal experts is dedicated to providing tailored solutions to meet your business needs in the LPG sector.

By The Josh and Mak Team

Josh and Mak International is a distinguished law firm with a rich legacy that sets us apart in the legal profession. With years of experience and expertise, we have earned a reputation as a trusted and reputable name in the field. Our firm is built on the pillars of professionalism, integrity, and an unwavering commitment to providing excellent legal services. We have a profound understanding of the law and its complexities, enabling us to deliver tailored legal solutions to meet the unique needs of each client. As a virtual law firm, we offer affordable, high-quality legal advice delivered with the same dedication and work ethic as traditional firms. Choose Josh and Mak International as your legal partner and gain an unfair strategic advantage over your competitors.

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