4/16/2018 https://mail.gov.in/iwc_static/layout!shell.html?lang=en&3.0.1.2.0_15121607

Subject: Registration for establishing & operating Liquefied Natural Gas (LNG)terminals, Regulations, 2018

To: secretary@pngrb.gov.in

Date: 16/04/1811:15AM

From: Mayank Garg <mayank@vlng.in>

VLNG _PNGRB _ LNG _160420 18.pdf (242kB)

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VLNG/PNGRB/2018/01Dear Sir

We, Venerable LNG Pvt. Ltd. is an energy infrastructure development company, which is currently developing small scale LNG

terminal in India, with targeted volume utilization between 0.1 MMTPA to 1.5 MIYITPA.

PNGRB had recently published the draft of the regulation requiring registration for establishing & operating LNG terminals, andinvited public comments.

In our opinion it is a positive step towards opening up Gas markets in India and will enable small consumers of gas to have more

control over the gas supply chain, promote competition, and eventually result in optimization of landed price of gas to endconsumer.

However we would like to bring to your notice the complexities and challenges it will pose for the small to mid scale LNG

terminals with targeted volume utilization of less than 2.5 MMTPA, which are planned to be developed in the country. Small

scale LNG terminals have very limited or captive targeted demand, and distribution of gas may also be carried in liquid form as

LNG itself using Trucks and river barges with cryogenic storages.Given the above facts we would like to submit that bringing small scale terminals also under the cover of the proposed

regulation will make the development and operations of these terminals unviable. The clause 3. (l).a technically cannot even be

imposed on small scale LNG terminals, as some of the terminals will have total capacity of less than 0.5 MMTPA.

In light of this, we would request that terminal with targeted volume utilization of 2.5 MMTPA or above only be brought under

the coverage of this regulation.As a small scale LNG infrastructure developer we are already struggling with technical standards also 194 which were designed

for large LNG terminals,!ut without any clarity given on its applicability are used by PESO even for risk assessment of small

scale LNG terminals, where OISD 194 can not even be technically applied.

Regards

Mayank GargManaging Director, Venerable LNG Pvt. Ltd.

M : +91 8826167772 1 Email : mayank@vlng.in 1 www.vlng.in

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VLNG/PNG RB/2018/01Date 13/04/2018

ToSeci etaryPNGRBNew Deihl

Sub Registration fOI estilbilshlllg & opera ling Liquelied Natur;iI Gel, (LNG) terminals, Regulations.2018

We, Venerable LNG Pvt. Ud is an energy infrastructure development comp.inv. which I, currentlydeveloping >111<111scale LNG tcrrrun.i: in India, with targeted volume utiliz ation between 0.1 MMTPA \0

1.5 MMTPA.

PNGRB had recently published the draft of the regulation requiring registration for establishing &ope: ating LNG terminals, and invited public comments.

In our opinion It is a posrtive step towards open lilt up Gas markets ill India and will enable ,l11illlconsumers of cas to have more conu ol OVt.!1 the gds supply chain. promote cornpeuuon. and

eventually result in optirnrzauon of landed price of gas to end consumer.

However ,lie would like to bring to your notice the complex.ur-s and challenges it will POSl' 101 the'small to mid scale LNG ter mmals with tnrgeted volume utilization of less than 2.5 MMTPA, which aroplanned to be developed in the country. Small scale LNG termmals have very limited or captivelargeted demand. and distribution of gas may also be (cHlll'0 111 liqUid lor m as LNG Itself usrng TI uck>

and rive I barges With uyogenic storages.

Given the above facts we would like to submit that bringing small scale ieruunats also under the coverof the p.oposed I cgutation will make the development and operation'> of thl'se tcun.nats unv.abh .'1he cl.iusc 3. (l).a t cchnicallv cannot even be Imposed on small scale LNG tel mind!>, a, SOI11eof the

terminals will have t ot al capac.tv of less than 0.5 rvlMTPA

In light of this, we would request ihat t ermin al with \,lrEeled volume utilization of 2.5 MMTPI\ 01

above only be brought under the coverage of this regulation

/I.,:>" ~!l1dll >(dlc L G inlrd~tluctult' developer \'Jl dIe dllL:'ddy ,trugl:11I1[; with t or hnrc.rl stand.ud; OISI)194 which were designed for large LNG t errrun.ils. but without anv ciJflty given on 1[:; applit abiluv .I/('

used by PESO even lor risk assessment of 1'1JII SCJlc LNG rermmals. whe: e OISD 19,1 can not evvn bt~

techn IcailY;d pphed.

Mayank GargManaging Director

Venerable LNG PvL Ltd.E 258, Shastri agar, Delhi 110052

contactesvenergysolutions.com, www. ving. in