Notes from Multiple Entities Regarding Amendments to Natural Gas Pipeline Tariff Regulations, 2025

Adani Total Gas Ltd.

Supports efforts to promote natural gas affordability for consumers.
Concerns exist about excluding commercial and industrial segments of CGD networks due to operational, certification, billing, and tax reconciliation issues.
Excluding these segments will impact small and medium-scale commercial and industrial customers who may face constraints in switching fuels.
Suggests a single zonal tariff for all CGD customers to create a level playing field.
Foresees changes in UFT affecting zonal tariffs, potentially impacting the CGD sector's growth.
Proposes a fixed tariff for CGD networks for a suitable period (3-5 years) to ensure stability.
Recommends a tariff of around Rs. 50/mmBtu for the CGD network.
Suggests revisions to the definitions in Regulation 2 (1) (bb) for "applicable unified zonal tariff" to include all quantities transported to CGD networks to be considered in Zone 1.
Seeks clarity on the calculation of "Balance Available for setoff" and "Volume after adjustment" in Schedule A Clause 11, Case 4.

AG&P-Think Gas Distribution Pvt. Ltd.

Welcomes the proposed amendments to the Tariff Regulations.
Believes the amendment has the potential to substantially benefit the growth of the natural gas sector in India, in general, and the CGD sector, in particular.
Advocates for a unified tariff for all CGD customers, including CNG, PNG Domestic, Commercial, and Industrial.
- This would simplify billing and operational processes, eliminate customer-wise tariff discrimination, improve affordability, encourage cleaner fuel adoption, and support fair access to natural gas.
Recommends pricing stability for new CGD projects for the initial five-year period.
Urges rationalization of imbalance charges and their applicability, suggesting:
- Monthly imbalance calculation.
- Revision of threshold limits for imbalance charges.
  - Positive imbalance: No charges for up to 50% of the booked capacity.
  - Negative imbalance: No charges for up to 50% of the booked capacity.
  - Unauthorized overrun: No charges for up to 150% of the allocated capacity.
- Aggregate capacity-based charge calculation.
Suggests expedited interconnectivity of trunk pipelines into the National Gas Grid.
Requests clarification on the inclusion of the 'Isolated Natural Gas Pipeline' definition.
- Recommends a clear and unambiguous definition of Isolated Natural Gas Pipeline in the regulations, excluding CGD pipelines laid within an authorized GA for retail supply to end-consumers.
- Suggests reiterating the functional and regulatory distinctions between CGD networks and Natural Gas pipelines.

Ambit Capital Private Limited

Expresses views/comments on the draft 'Public Consultation Document (PCD) for Tariff Review of unit natural gas pipeline tariff of GAIL (India) Limited'.
Notes that India's gas consumption history is challenged, with muted natural gas consumption growth attributed to supply constraints and LNG import volatility.
Highlights multiple initiatives underway to increase gas proliferation, including expansion of the National Gas Grid Pipeline and CGD networks.
Suggests that these measures need to be supplemented by favorable government action encouraging segments like power, refineries, petrochemical facilities, and industrial units to consume more natural gas.
Points to successful government policies, such as the Air Quality Commission's diktat and the National Green Tribunal's order, as examples of driving increased gas usage.
Notes that GAIL’s natural gas transmission business struggles with sub-par returns and that sub-par volume growth has weighed on GAIL’s pre-tax RoCE for the transmission business, which is consistently below the regulatory threshold.
Believes the government has taken several steps recently to incentivize asset-heavy businesses undertaking capex to improve India’s energy security and facilitate affordable access of clean fuel.
Wishes to submit that the regulator take a balanced view of GAIL’s returns from its transmission business and imperatives to further enhance India’s gas demand.

ArcelorMittal Nippon Steel India Private Limited (AMNS)

Expresses concerns about proposed amendments to Natural Gas Pipeline Tariff Regulations.
Highlights that Natural gas is a crucial element for producing greener steel compared to other production methods, but there are currently no incentives or premiums available in the domestic market for this type of production and manufacturing steel using natural gas is significantly more expensive than coal-based methods.
Notes that the APM gas that was previously allocated to AMNS's Hazira plant has long since been withdrawn and AMNS finds itself at the lowest priority level for the allocation of domestic gas from HPHT fields, leading the company to rely solely on costly imported LNG for its operations.
Suggests that the levelized unified tariff is likely to increase significantly, which would lead to a corresponding rise in the first zone tariff.
Argues that the ratio of the first zone tariff to the second zone tariff, which stands at 66.17%, seems skewed heavily against consumers in the first zone and lacks a clear basis.
Notes that the unified tariff has caused costs to increase nearly tenfold, rising from approximately Rs. 4/MMBtu to the current rate of about Rs. 42.04/MMBtu.
Requests that the proposed merging of the second and third zones be reconsidered and ultimately not pursued.
Advocates for a more equitable solution: capping the ratio of the first zone tariff to the second zone tariff at a significantly lower level - ideally no higher than 25%.

Assam Gas Company Ltd

Requests consideration of their submission on the proposed amendment in the Tariff Regulations.
ANGPL Network is an isolated network directly connected with Producer/ Source. It depends on the end consumers' needs and producers' availability.
Supports the proposed amendment, including AGCL's ANGPL Network in Schedule E of the Regulation and amending the Volume Divisor clause.

Bharat Petroleum Corporation Ltd.

Broadly supports the draft regulation as it will reduce the tariff burden on gas consumers, mainly those located far from the gas source.
Proposes that the tariff for the first zone of the unified tariff should be applicable for all gas consumers connected with the CGD network.
Stresses the importance of cost optimization in the cases of cost-plus pipelines.
Suggests that cost-benefit analysis of using Gas as fuel or using electricity for compression should be done, and operating cost should be benchmarked.

BP Exploration (Alpha) Ltd.

Advocates for a single zone tariff to align with the Government of India’s mission of “One Nation, One Grid and One tariff”.
Believes it would especially benefit all the consumer segments, facilitate the development of a competitive gas market, enhance gas utilization, and thereby enhance the share of gas in India’s energy mix.
PNGRB’s endeavor should be to make the customer source agnostic and provide access to competitive molecules from various suppliers.

Enertech Energy Resources Pvt. Ltd.

Highlights a situation where a customer temporarily stops taking supplies due to unforeseen circumstances, and the gas is diverted to an alternate customer.
Notes that the pipeline operator is opting to levy transportation tariff twice, penalizing the shipper/marketer.
Requests clarification that as long as the contract carrier capacity is utilized, even though for a new UFT path, the pipeline operator ought not to charge double tariff.

GAIL (India) Limited

Encloses views on the draft Petroleum and Natural Gas Regulatory Board (Determination of Natural Gas Pipeline Tariff) Amendment Regulations, 2025.
Deliberated on various other issues related to tariff determination also, which are being faced by transporters.
Recommendations were submitted, in the form of a report after thorough deliberations, in order to provide a fair opportunity to gas transporters to earn the regulated returns on its investments.
GAIL requests PNGRB to consider the following issues: Consideration of reduced levels of Normative volumes for Tariff Determination of Cost-Plus Pipelines, Consideration of Stores and Spares for working Capital, Premium for short-term capacity bookings, Allowance for Management fees after completion of economic life of NG Pipeline, Salvage value of assets and line pack after end of economic life.
Provides specific comments on the proposed amendments in Petroleum and Natural Gas Regulatory Board (Determination of Natural Gas Pipeline Tariff) Regulations, including details of certification ofconsumption volumes for CNG/DPNG, definition of pipeline, isolated methodology for determining tariff after integration.
Suggests to dynamcially align with the prevailing Levelized Unified Tariff

Gujarat Gas Limited

Highlights the importance of equitable mix of customers for the CGD sector, for which the Commercial and Industrial customer base also needs to be protected.
Requests that the proposed proviso in Regulation 2(1)(bb) should not be limited to CNG and PNG-Domestic customers and should include all customer segments.
Requests clarification on whether the “isolated natural gas pipeline” forms part of a CGD network/STPL or Natural Gas pipeline network.
Notes, in point no. 4A(ii), the volume divisor has been replaced with actual volume flow, leading to higher tariff over the remaining economic life of the pipeline.
Suggests uniform transportation tariff for all customer segments to improve affordability and promote use of cleaner fuel.

Gujarat State Petronet Ltd.

Thanks PNGRB Board for proposing another set of reforms in the Natural Gas Pipeline Sector.
Comments that proposed amendment will increase contractual complexity in relation to CGD entity.
Suggests that instead of two separate tariffs, only Zone 1 tariff should be applied to the CGD entity for entire volume of gas transported for them for CNG, PNG-D, Industrial and Commercial.
Has concerns about Linking the tariff of Isolated fields to UFT directly and a multifold increase in tariff should be avoided.
GSPL submits that other amendments like those at Sl#11 [i.e. in case where the actual volume exceeds normative volume be also implemented in a similar manner so that all entities are treated at par and a level playing field is created.
Requests identifying all the pipelines which donot earn 12% post tax return and work out a formula wherein irrespective of the nature of the pipeline - bid out or cost plus, the approved tariff / entitled tariff should be revised to facilitate earning 12% post tax returns.
There is a need to rationalise the distances such that both the zone 1 and zone 2 are of equal length, and retain existing lengths.
Requests to consider and safeguard the interest of the consumers near the source by ensuring that they have a reasonable Zone 1 tariff.
Opposes penalising pipeline entities by setting off Security deposit against Capital expenditure.
The SUG consumption is low and entering into a long term contract may not be technically feasible. Further, GSPL is not engaged in trading of gas and hence it does not have any portfolio. So such provision may please not be applied to pure transmission entities like GSPL.

HCG (KCE) Private Limited

Welcomes and supports the steps taken by PNGRB for the development/growth of natural gas sector.
The Hon'ble Board may please to consider that the Unified Zonal Tariff for the first zone shall be made applicable not only to "CNG and PNG Domestic", but also to Commercial and Industrial Customers located in a specific GA, as it will encourage the industries to opt for cleaner green fuel.

Indian Gas Exchange Ltd.

The move from three unified tariff zones to two zones is a progressive and timely step towards achieving a single-grid tariff or transitioning to an entry-exit tariff model.
A simplified tariff structure will be more gas market-friendly and will help deepen liquidity and improve price discovery.
Offers specific suggestions regarding revenue entitlement/requirement and revenue collection.

India Gas Solutions Private Limited

Highlights its position regarding additive unified zonal tariffs in the case where the same unified path is used more than once.
Requests regulations that change of unified exit point be allowed under regulation and that delta between the unified tariffs between the said two exit points be netted-off and the balance be debited/ credited to the shippers’ account.Incorporating these suggestions will mark a positive step toward building a more efficient, competitive, equitable, and customer-centric natural gas market.

IndianOil-Adani Gas Pvt. Ltd.

Welcomes the amendment aimed at maximizing the benefits for the end consumers of the CGD segments. Please find below our views/ suggestions enclosed as Annexure 1 for the kind consideration of the Board.
The Board is requested to appropriately factor the same and it may be waived off for the CGD entities while being considered under determination of tariff.
** requests to kindly review the ceiling @ 2% based on the actual SUG average of the last 5years and the same shall be benchmarked as per the international standards.
To encourage use of gas across the industrial segment, customers having requirement upto 50,000 SCMD may be included under Zone 1 tariff methodology for pipeline wise invoicing and reconciliation may also be included under the proposed amendment.

Indian Oil Corporation Ltd

With respect to the referred Public notice from PNGRB, please find enclosed comments from IOCL on the proposed draft Petroleum and Natura! Gas Regulatory Board (Determination of Natural Gas Pipeline Tariff) Amendment Regulations, 2025.

Indraprastha Gas Limited

Welcomes the amendment aimed at maximizing the benefits for the end consumers of the CGD segments.
In order to promote these two priority segments (i.e. CNG & PNG-Domestic), we understand that the first Zone tariff shall be applicable for the entire volume (APM/NAPM, NWG, HPHT, RLNG/LNG, etc.) of gas used in these two priority segments.
respectfully request the inclusion of the entire CGD sector - encompassing both priority segments and the Industrial-Commercial Segment - under the first Zone tariff.

Mahanagar Gas Limited

MGL welcomes PNGRB proposal for applicability of first zone unified tariff in CNG transportation and PNG-Domestic segment. In this regard, please find MGL views / comments enclosed at Annexure-I on the subject for kind consideration of the PNGRB.
Clarification is required whether zone 1 tariff for CNG (Transportation) and PNG-Domestic customers will only be applicable on the allocated quantity of APM NAPM/NWG gas being supplied by GAIL to CGD entities or it will also be applicable on shortfall quantity being arranged by CGD entities from non-GAIL suppliers.
It is suggested that the full quantity of gas, including gas being purchased by CGD entities to meet shortfall in priority segment, may also be considered for zone 1 tariff.
requests that hookup charges paid by CGD entities to pipeline entities be made part of pipeline tariff calculation

Natural Gas Society

Summarizes feedback from member companies regarding proposed amendments to Natural Gas Tariff determination regulations.
Suggests broadening the applicability of Zone 1 tariff to all gas supplied through CGD networks, irrespective of distance, to increase gas penetration among small and mid-sized industrial customers.

Nayara Energy Limited

Discusses concerns about steadily increasing unified zone prices, which have significantly increased the costs of transporting R LNG to the Vadinar refinery.
requests that a single Unified Tariff (irrespective of any zone), be alignment with the mission of "One Nation, One Grid, One tariff", so that there is a fair and level playing field for all gas Users in our country.

Pipeline Infrastructure Limited

PIL welcomes the proposed amendments to Petroleum and Natural Gas Regulatory Board (Determination of Natural Gas Pipeline Tariff) Regulations
currently, normative volumes at 75% of pipeline capacity are used as the volume denominator for tariff computations, it is requested to device a mechanism to reduce the normative volume to minimize the gap between normative and actual.
To enhance revenues, a premium should be applicable for for short-term (1 to 30 days) capacity bookings, on top of the existing tariffs, which will promote long-term engagements.
request to clarify that, once the interest-free security deposit is refunded or adjusted by the transporter to the shipper, it will be added back to the capital expenditure in the year of refund.
To provide a transparent SUG procurement , it is requested that either biding process or predefined mechanism be ensured.

Reliance Industries Limited

Suggests that a single-zone tariff model be implemented to fully realise the intended benefits of Unified Tariff.
Highlights that a single-zone tariff will lower the transportation costs for remote regions and enhance overall competitiveness of gas markets.
Additionally It will benefit buyers across sectors and nation-wide by making gas procurement truly supply source agnostic.

Shell Energy India Private Limited

Set out in a roadmap for the sector including a proposed timeline for the reform
with this would cause considerable operational difficulties for shippers, such as requiring separate capacity booking for these volumes and managing the resulting ship or pay/imbalance charges, reconciliation, etc
The same principles of benchmarking should be extended to capital and operating expenditure which would encourage efficiency in the system

Torrent Gas Limited

At the outset, we at Torrent Gas sincerely welcome this progressive initiative, which holds significant potential to enhance the natural gas sector. The proposed amendments are expected to enable CGD entities to plan their gas sourcing more effectively and competitively. We firmly believe that the proposed amendments will substantially support the overall growth of the natural gas sector in India and particularly benefit the CGD sector.To fully operationalise the National Gas Grid system, thereby enabling efficient and reliable gas access across all regions.
the Zone 1 transportation tariff will apply to the entire demand for CNG and PNG-Domestic volumes, irrespective of the gas source if it is clarified. the Board may kindly consider extending the applicability of the Zone 1 transportation tariff to the entire volume sold by CGD entities to end consumers, including the commercial and industrial segments.
the figures for Year 12 to Year 15 under Point 4 Table may needs to addressed as there is inconcistency to the data
o maintain price stability and support sustainable growth, a fixed tariff regime to be applicable for at least five years.

Torrent Power Limited

TPL advocates that GBPP should be kept in separate category.