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A READY RECKONER FOR THOSE WHO WISH TO UNDERSTAND THE OIL AND GAS BUSINESS E&P – an uncertain business
1. Unlike other sectors such as power, steel and construction, the business of oil and gas
exploration and production (E&P) is a high risk business where everything is uncertain
through the entire life cycle of a project – from exploration and appraisal, to development
and production.
2. Not only is the success ratio of exploratory wells as low as one in ten, the quantum of
reserve too can only be estimated in term of probability rather than certainty.
3. With the cost of drilling and exploration well in deep waters being over Rs 700 crore (a
development well costs even more at Rs. 1200 to 1400 crore) returns are never guaranteed.
4. The deep sea environment involving water depths between 3000 to 10,000metre. multiples
risk manifold. Subsea installation & maintenance tasks have to be conducted in an
environment that is beyond human endurance. Even simple tasks such as tightening nuts
and bolts require advanced precision guided deep water robotic vehicles. The entire
installation process has to be remotely guided with heavy equipment being manipulated
under a mile high sea waters to lay down high pressure pipes with hundreds of miles of high
voltage electrical
as
well
as
communication
cables.
The
robotic
vessels
have
to
work
in
an
environment that is far more extreme than that faced by remotely controlled buggies used
to explore the Moon or the Mars.
5. This is a business in which the risk is a part of its intrinsic DNA: the entire risk is carried by
the exploration company and not by the owner of the resource
Evolution of NELP 6. India had tried to bring technology driven companies into its deep water exploration
program since the 80s. Companies like Shell and Chevron had been engaged with little
success. It was finally Chevron, who after expending considerable amount of exploration
finally dubbed India’s East coast as the “failed basin”.
7. Until 1991,
India’s
oil
&
gas
sector
thus
remained
the
exclusive
domain
of
oil
PSUs
operating
under an Administered Pricing Mechanism (“APM”) which guaranteed fixed returns on all
costs. This cost plus regime passed the entire risk of exploration, appraisal and production
on to the taxpayer.
8. By 1990 India found itself in a position where it neither had the technology to venture into
its deep water basins nor the resources to invest. Its mounting oil import bill had brought it
to a balance of payments crisis.
9. It was then that the sector was opened for private investment by encouraging 100% FDI to
bring in new technologies as well as risk capital for increasing exploration in grossly under
explored Indian basins. Even though India possessed as much as 3.14 million sq km of these
basins, barely 15% had been explored. The prospectivity was known to be poor and
Chevron’s failures
on
the
East
Coast
had
only
strengthened
these
doubts.
India
needed
a new regime for exploring basins whose prospectivity was a far cry from the basins found not
only in Saudi Arabia, Kuwait, Qatar but even Myanmar, Pakistan and Bangladesh.
10. After experimenting with various PSC regimes, which sometimes involved auctioning of even
discovered fields to investors, the New Exploration Licensing Policy (NELP) was formulated
by the 3rd Front Government in 1997. Interestingly, the one of the main complainants in the
FIR as well as the PIL against RIL, was a Secretary to the same Cabinet that approved the
terms that are now being implemented. The most important of these terms which
differentiated NELP from all earlier PSC regimes was the grant of marketing freedom to the
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PSC Contractor and allowance of sale of all gas at market determined prices. Is it not strange
that the ex‐Cabinet Secretary, who was part of the approval process, had filed an FIR
challenging the terms of the PSC and demanded that KG D6 prices should be fixed not as per
the market but as per the cost of production?
11. NELP bids were only for unexplored areas having either no data or extremely scanty data.
NELP ended the earlier system of auctioning producing wells or discovered fields in the possession of OIL or ONGC.
It
auctioned
rank
exploration
blocks.
12. In the first of these auctions, done through a transparent & international competitive
bidding process, RIL & NIKO won the KG‐D6 exploration block in 2000 on account of it being
the highest bidder.
13. Out of 254 blocks awarded under NELP policy, even though over 110 discoveries have been
made, only 6 are under production. If the total number of discoveries across all regimes is
counted the figure is over 160. Many of these, including those by ONGC and GSPC, made
before or at the same time as RIL’s D1‐D3 discoveries are yet to be brought into production.
So D1‐D3 fields will always remain India’s first deep water production. It remains an
achievement that a country should be celebrating, not denigrating.
RIL’s investments in Oil & Gas sector 14. RIL remains the largest investor under NELP. More so in difficult off shore blocks
Contents RIL (NELP offshore) NELP offshore^^ RIL % No. of blocks 37 offshore blocks,
currently holds 6
(also holds 1
onshore, total 7)
134 28
2D seismic (lkm) 82,807 3,42,245 24
3D seismic (sq. km) 99,733 2,18,560 46
Total no. of wells 101 (expl+appraisal),
29 development
259 39
Total investments* ($
Bn)
12.6 Do not have the
number for total
investments in NELP
offshore blocks
No. of discoveries 43 80 54
No. of discoveries in
production
3 3 100
Production 2.279 tcf, 24.384
MMbbls
2.279 tcf, 24.384
MMbbls
100
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^ till dec’13 *At JV level in NELP offshore blocks (Gross 100%). Includes only exploration ($4.9 Bn), Development ($7.7 Bn). Does not include OPEX including Royalty paid ($2 Bn) ^^As per DGH web site
15. RIL currently
retains
only
7 blocks
(of
which
6 are
offshore)
of
the
45
blocks
awarded
under
Pre‐NELP and NELP rounds. It has invested $1.92 bln (approx. ~Rs 12000 at current exchange
rate) on the 37 surrendered blocks and is set to surrender another 2. Many blocks with
discoveries had to be relinquished as they were not viable to develop and produce at current price of $4.2 per MMBtu.
16. D1‐D3 is the first & only deep water production in India and remains amongst the most
complex reservoirs in the world. Other discoveries in the same block such as R Series,
Satellites & MJ1 are pending development.
17. D1/D3 production will vary but is not expected to increase substantially. Any increase in
production will not come from D1‐D3 but through development of the new discoveries in KG
D6 block. The earliest this could happen is 2017‐18.
Gas Pricing under NELP 18. NELP as per the approved terms of offer had invited International bids on the promise that
Contractors would be allowed to sell crude oil at international prices and gas at arm’s length
market price. Because of these pricing provisions prices cannot be on the basis of cost of production.
19. In 2003, in response to NTPC tender RIL submitted a bid for supply of gas when imported
LNG was being sold at around $ 3.5/MMBtu. RIL did not renege from this offer. In fact, on
14, Dec 2005, RIL signed and sent a contract to NTPC to supply gas at $ 2.34/MMBtu. NTPC,
however, insisted on the inclusion of open ended uncapped liability conditions and refusing
to accept the offer and chose to go into litigation. The matter is currently sub‐ judice in
Bombay High Court.
20. Meanwhile a proposal
to
sell
gas
to
RNRL
was
sent
to
the
Government
for
approval
which
rejected it on the ground that it was not an arms‐length sale. The decision was challenged by
RNRL but the Supreme Court upheld the Government’s decision stating that national
resources could not be sold as part of a family arrangement. The Government was entitled
to a fair compensation for the same. In the 2G case again the SC again held that natural
resources should be disposed of through a fair and transparent auction process
21. In 2007, RIL discovered the gas price through a price discovery process as mandated under
the PSC and the recommendations of the Sinha Committee. The price of $ 4.2/MMBtu was
approved by an Empowered Group of Ministers (EGOM) which included user ministries
(power, fertilizer & steel). The approval was given for a period of 5 years from the start of
commercial production hence valid up to March 31, 2014.
22. It is
noteworthy
that
the
price
of
$ 4.2/MMBtu
was
discovered
at
a time
when
crude
price
was around $ 30/bbl and imported LNG was being sold in India at around $ 4‐5/MMBtu
23. Subsequently, the administered gas prices (APM prices) of ONGC & OIL were also raised to $
4.2/MMBtu & non‐APM gas of ONGC was priced even higher at $ 5.25/MMBtu.
24. The prices had to be revised now because the prevailing price formula ceases to be valid
w.e.f. 1/4/2014. A number of discoveries (~10 TCF equivalent to ~$ 150 Billion of LNG
imports) were pending review by DGH / MoPNG as they would be uneconomic at $ 4.2 /
MMBtu. Consequently, at the request of the then Petroleum Minister Sh. Jaipal Reddy, PM
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in May 2012 constituted an expert panel under the chairmanship of Dr C. Rangarajan
Chairman, Economic Advisory Council to PM.
25. The expert committee held wide consultations with all stakeholders including consumers
and submitted its report in December 2012. Its recommendations were considered by
various ministries before the proposal was approved by CCEA on 27 Jun 2013.
26. Subsequently,
certain
issues
were
raised
by
Ministry
of
Finance
and
Parliamentary
Standing
Committee on Finance. These were again considered by CCEA in December 2013 and the gas
price formula was approved.
27. The first gas price approved in 2007. The revised prices are effective from 1/4/2014 – a gap
of 7 years. In last 10 years, the price for other commodities, offshore services, consumer
items, etc. have increased disproportionately compared to the revised gas price. Crude Oil
prices have moved from around $ 30/bbl to over $ 100/bbl and imported LNG from around $
4/MMBtu to over $ 14/MMBtu.
28. The revised prices apply to the entire domestic production. KG‐D6 produces a bare 15%
share of this while PSUs who are the major beneficiaries produce 75%. After taking into
account RIL share in KG‐D6, RIL share of production is less than 10% and therefore any
allegation that price increase is for benefiting RIL alone is a huge exaggeration.
29. As per IHS CERA, 27 TCF of discovered gas (equivalent to $ 400 Bn of imported LNG) in the
country is awaiting further investments for development & production. Another, 64 Tcf of
risked recoverable gas resources are Yet to Be Found (YTF) through further exploration.
30. Even after doubling of gas price to $ 8 / MMBTu only 5 TCF of the 27 TCF of discovered gas
resources
can
be
developed.
31. As per CERA, the following gas prices are required for projects to be economically viable:
a. Onshore: $ 6‐8 / MMBTu
b. Shallow water: $ 6‐10 / MMBTu
c. Deepwater: $ 8‐12 / MMBTu
d. Ultra deep water: $ 10‐12 / MMBTu
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54,500) crores, which goes to meeting capital as well as operational costs before it can
be counted as profit. d. BP (British Petroleum) must have seen high returns from a known discovery at the
current price of $ 4.2 / MMBtu and thus, it invested about Rs. 33,000 crore for 30 per cent stake in RIL's KG basin block: Farming in, i.e. taking a participating share in the risks
as well as benefits of a block by other partners is part of the terms of NELP as framed in
1997.
It
is
a
common
industry
practice
under
which
Vedanta
acquired
Cairn
India’s
interests, ONGC brought in BP, BHP and various other companies and farmed into others
in India and abroad (eg. Sakhalin, Imperial, etc). BP invested not in KG‐D6 alone but
because it found the RIL portfolio of Blocks as well as the PSC terms attractive. Investors
naturally assume that any Government would honour the terms of offer as well as the
PSC.
34. NIKO, RIL’s partner is selling same gas in Bangladesh at $ 2.34 / MMBtu: NIKO is not selling any KG D6 gas into Bangladesh. It sells gas produced from its on‐land
fields in that country as per a price formula agreed with the Government of Bangladesh as
per the terms of offer. The terms of offer under NELP (approved in 1997) provided for
market prices. Apples cannot be compared to oranges:
a. KG‐D6 is a deep water not an on‐land block.
b. Commercial operation of Niko onshore block started in 2000 and was developed in low
oil price era i.e. at very low development capex.
c. NELP dispensed with pre‐negotiated pricing formulas and instead provided for market
prices. The gas price for NIKO Bangladesh field was embedded in the Contract i.e. same
as Raava or PMT block in India. There is no provision of market price in Niko Bangladesh
contract.
As an aside, as per Wood Mac report, Bangladesh’s remaining gas reserves are ~10.51 TCF and
current
production
is
only
6.5
mmscmd.
Bangladesh
is
in
a
situation
of
high
reserves
but extremely low production because of its unattractive price regime. Does India want to emulate
Bangladesh?
Impact of gas price on other sectors – Power, fertiliser, CGD
35. Increase in gas price of KG‐D6 gas will not impact consumer price of CNG as the gas is
supplied in accordance with the Gas Utilisation Policy (GUP) under which no gas from KGD6 is being supplied to any City Gas Distribution network including New Delhi.
36. For fertilizer the alternate fuel is mainly imported LNG / naphtha which are priced more than
$ 25
/ MMBtu
which
is
three
times
the
revised
gas
price.
37. Today 5‐8% of the total power capacity is gas based which is contrary to the perception that
the whole power sector will collapse because of increase in gas price. Power sector
consumption of gas is only 24 MMSCMD and gas supply from KG D6 to power sector is Nil.
38. As per Kotak analysis, in case the current increase in gas prices is allowed to pass through to
the end‐customers, the increase in power tariff is expected to be only about 10 paise / unit.
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39. Deregulation of petrol & diesel prices have been absorbed by the market without creating
any havoc in spite of the fact that 97.2% of transportation sector is diesel, petrol or auto LPG
compared to 2.8% natural gas based. Even at the revised price natural gas supplied to
consumer is far cheaper than subsidized domestic LPG.
40. What would $ 8 / MMBtu translate to in a 15 kg cooking gas price
First LPG is mixture of Butane (C4 fraction of Hydrocarbon) and Propane (C3). D6 gas is pure
Methane gas (99% Methane i.e. C1 fraction with no higher fractions like C2, C3 or C4, etc.)
and no LPG can be extracted from D6 gas as it neither has propane or butane. For
reference, $ 8 / MMBtu in energy equivalent terms would be Rs. 24 / kg or Rs. 340 for the
household cylinder (a standard household cylinder has Rs. 14 kgs). Thus the revised well
head price of $ 8.4 per MMBtu implies a cost of Rs. 340 per 14.2 kg LPG cylinder. Even after
transport and overheads the delivered price comes to not more that Rs. 400. It may be
noted that non‐subsidized LPG today is priced at more than Rs. 1100 a cylinder
41. In E&P, on average almost 50 % of price increase flows back to GOI through royalty, profit
petroleum, dividends & taxes (including subsidies). As per Barclays report, based on current
production levels, for every $ 1 / MMBtu increase in price Government will have a net
balance of $ 101 MM after paying fertilizer & north east subsidies. The increased accrual in
government kitty will enable further disbursement towards infrastructure and nation
building. A clear indication of multiplier effect.
42. On the contrary, if domestic gas is not offered market price, it will result in rapid
depreciation of the Indian Rupee
a. There are currently over 110 discoveries but only six are under production as companies
(including ONGC,
GSPC
etc)
do
not
find
it
viable
to
produce
them
at
current
prices.
b. Unable to produce at current domestic price will only increasing import dependency
leading to expensive imports & adverse impact on Balance of Payments (As per CERA
current gas demand‐supply gap of 45% can balloon to more than 80% by 2025)
The price hike will therefore make more gas available as more discoveries can be produced
reducing the need to import gas at $ 14 to $ 19 per MMBtu which is not only causing
inflation but also resulting in such a rapid depreciation of the Indian Rupee.
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43. Idling of gas based power& fertilizer plants Not a single power or fertilizer plant has come up in the country on assurance of gas supply
from KG D6 block. All of these came up on the basis of allocation made from gas to be
produced by ONGC or sourced by GAIL. GSPAs exist to show these supply commitments
which never materialized because of the inability of ONGC or GAIL to meet the
commitments made in these GSPAs. KG D6 gas in fact came as a saviour to these stranded
assets until
the
production
went
into
decline
in
2011.
For
example
a number
of
plants
in
Andhra built on gas allocations from ONGC and GAIL produced their first power using KG D6.
Even Dabhol project was based on LNG and was able to commission 1800 MW using KG D6
gas
44. Cost of production of gas is $ 0.89/MMBtu
45. We are not sure where the $1/MMBtu number has come from. Figure of less than a dollar
being quoted as cost of production of gas from Block KG D6 is factually incorrect. The letter
referred to in the FIR is not about the cost of production but limited to post‐production costs
between the well head and delivery point which at that time (2009‐10) was estimated as $
0.89 per MMBtu for year 2009‐10. The figure was required because royalty was to be paid at
the well head value which value had to be derived by subtracting the post well head cost ($
0.89 per MMBtu) from the approved price of $ 4.2 per MMBtu.
46. Post production cost between the well head and delivery point is only a small component of
the total cost of production. To calculate production cost, in addition to the post production
cost between well head and delivery point (i.e. $ 0.89 per MMBtu), the expenditure incurred
in discovery, appraisal, development production, maintenance will need to be considered;
eg cost of drilling of wells, production expenditure including work‐overs expenditure,
Exploration & Appraisal cost etc.
47. In addition, RIL and its partner has spent around $ 4 Billion on non‐KGD6 blocks; $ 1.9 billion
on relinquished blocks (failed exploration) and expected to spend another $ 1.8 billion on
other NELP blocks till end of FY2014 where there is still no certainty of recovery. In case
prices are
to
be
fixed
on
cost
of
production,
this
additional
cost
of
$ 7.4
billion
will
also
need
to be reimbursed. (Note: Numbers are based on simple interest and for pre‐tax return of 18
%, with compound interest; $ 7.4 billion will increase to $ 10.4 billion)
48. In any case the cost of production cannot be relevant to the determination of prices because
NELP as framed in 1997 promises investors market price for gas & imported prices for oil to
encourage exploration. It does not allow the Government to fix prices on the cost of
production. Doing so is tantamount to violation of the provisions of the PSC and terms of
offer under NELP. Crude oil from the same PSCs is being sold at international prices so how
can the Government not give market price for gas as per the PSC?
Hoarding of gas
49. Hoarding is technically impossible. Any attempt to hold back production in an existing field
immediately shows up in pressure anomalies in the affected wells. Each well is like the
release valve of a huge pressure cooker where the oil and gas has literally been cooking for
cooking for millions of years ‐ hold back gas in one and the pressure difference is
immediately apparent in the next. Simply put if gas is being hoarded pressure in all
producing wells cannot decline uniformly because pressure decline is a sure sign that the
pressure cooker is running out of steam.
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50. Hoarding of gas also does not make any commercial sense. Any delay in production delays
the recovery of costs and subsequent revenues for the contractor. Any prudent operator will
not risk their present cash flows for uncertain future benefits.
51. The decline of production in D1, D3 fields in KGD6 block is due to reservoir complexity &
geological surprises and not due to hoarding. The issue can be easily settled by getting the
existing reserves assessed and certifies through any expert international reserve certification
agency.
52. Reservoir surprises are common in the industry. There are various case examples both in
India & abroad, to name a few ‐ Neelam, Mumbai High redevelopment plans, and Imperial
(in Russia) where reserves and production fell far short of expectation.
Underutilization of facilities 53. Stating that design capacity of 80 mmscmd has been underutilized or RIL has built excess
capacity is a very simplistic statement
a. Any oil and gas development project must be planned and implemented on the basis of
data and information availableat that time. Uncertainty is the hall mark of this business
and
it
is
impossible
to
predict
the
nature
or
behavior
of
a
reservoir
until
well
after
production.
b. For this reason reservoir surprises being common occurrences, a development plan as
per the PSC only gives estimates of production and reserves which are meant to be
revised from time to time. These figures being pure estimates, they cannot be termed a
commitment to produce by any stretch of imagination.
c. Even though reserves and reservoir behavior will be uncertain, oil and gas facilities must
be designed for peak production. That is the financial risk the Contractor takes when he
undertakes development. It must be remembered that as per the designed capacity, KG‐
D6 achieved a production of 63 mmscmd before the nature of the reservoir began to
become apparent. .
d. Today, with decline in production pressure the same system has been efficiently
handling lesser quantity of gas and bringing it to markets with a safety record that is
matched by only the best projects in the world.
e. The design was appropriate considering the estimates of gas reserves & production
profile at that time. In hindsight, people are accusing of overbuilding of capacity. A few
years later similar hindsight will show that the same facilities have been a huge boon in
costs, leading to the development of other discoveries (R Series, Satellite etc.). Had
these facilities not existed, those other discoveries would never have been viable.
f. Notwithstanding the above facts, the Government has chosen to give a notice to the
Contractor for failing to utilize the facilities. The grounds of the above notice being
highly disputable, the matter is now the subject matter of arbitration.
Gold plating
54. The charges of gold plating are far remote from the harsh realities of the business. Unless
the costs incurred are fraudulent, a cost can never be a profit. For any investor, costs are
incurred upfront whereas future revenues are only notional.
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55. In the D1‐D3 field, the investment costs rose because of increase in reserves as well as 200%
to 300% increase in prices of commodities, goods and services internationally between 2003
and 2006. The CAG audit for the years 2006 to 2008 never even once mentions the word
“gold plating”. It also does not quantify any excess expenditure but only comments on the
procurement processes. The PAC has asked the CAG to quantify so called excess expenditure
upon which the CAG has assured that it will do so during the audit of the following years.
The audit
for
the
years
2008
onward
in
still
ongoing.
56. As already explained, costs cannot become windfalls unless the costs themselves are
fraudulent. No such charge has been levied by anyone against RIL to date. On the contrary, a
forensic audit has already confirmed that all expenses were in fact incurred and
corresponding payments made to unrelated third parties.
57. It does not make any sense to deliberately increase costs as it would:
a. impact contractor profit disproportionately– Every $ 1 extra expense reduces $ 0.9 from
contractor profits
b. significantly increase non‐recoverable financing costs due to longer gestation period
c. yield low return on investment and long payback period
58. In
order
to
maximize
value,
the
Contractor
has
to
be
prudent
operator
and
cost
&
time
efficient.
59. In any case all costs are reviewed, approved and the audited by the Government as per the
PSC and costs not found appropriate can always be denied for cost recovery purposes as per
the procedure laid down in the PSC. The audit, which is very much part of the control
processes envisaged in the PSC, is still ongoing as per the laid down procedure.
RIL ran the UPA government for 10 years and if the NDA comes to power, RIL will run the government for another 5 years
60. It is totally absurd and baseless. If RIL had this kind of alleged influence, how would the
Government:
a. impose about $ 1.8 billion cost recovery penalty, delay the sanctions of future
development and seek bank guarantee for allowing increased gas price for natural gas
output from KG‐D6 block during the last three years.
b. Take away the tax holiday promised under PSC, right when KG‐D6 gas came into
production
c. Take away marketing / pricing freedom from the Contractor promised under the PSC.
– Today RIL buys 12 mmscmd of LNG at more than $ 15 / MMBtu while sells its D6
production at $ 4 / MMBtu.
d. Introduced new taxes on exploration despite fiscal stability promised under PSC.
61. RIL has never blown its trumpet in terms of employment it has offered, value created for its
stakeholder, forex saving for the country, creating world class benchmarking in
petrochemicals, contribution in GDP growth and export earningsetc.
RIL contributes extensively to create value for the whole nation 62. RIL’s contribution to upliftment of society and nation building is so enormous and difficult to
quantify.
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63. The basic drive which established RIL as a large empire was driven from the basic principle of
fulfilling the needs of common man ‐ Roti, kapda and makan.
• Employment generation for millions of people – both directly and multi‐fold indirectly
• The culture of equity markets was brought in to nooks and corner of the country by RIL.
Those who had invested in initial years became millionaires. In fact RIL shares helped
them in financing for their children education, marriage etc.
• Kapda –
Polyester
revolution
–
RIL
revolutionised
the
manmade
fibre
sector
and
offered
decent, economical and easy to maintain clothing for Aam Aadmi (Common man)
• PET – Provided cheaper but quality packaging material to preserve food and other goods
to common man
• Mobile – Monsoon Hungama….First to give the power of communication and connected
the common man to his family & community
• Silently contributing for welfare and upliftment of underprivileged, and poor through
various activities of Reliance Foundation's contribution to the society.
• RIL created equity cult which provided new avenue to small retail investors –Today RIL
has lakhs of shareholders, many of whom have created for its shareholders
Reliance is being witch hunted for no fault of theirs. Rather it has contributed immensely to the
development of
the
nation
&
all
its
stakeholders.
You be the Judge…! 1. Should we question the credibility of an expert panel headed by Dr Rangarajan?
2. Should we continue paying exorbitantly high prices for imports and make LNG exporting
countries and Indian importers richer?
a. Does it make sense to promote oil exporting countries to sell more oil & gas in India?
b. Do you know it is oil & gas not gold which has the heaviest forex outflow?
c. Do we want to promote the economy of oil & gas exporting countries at the cost of the
people of
India?
3. Should we not promote India’s E&P sector to encash the benefit of $ 400 billion equivalent
domestic resources, thereby save money, provide employment & overall growth?
4. Given huge chronic demand‐ supply gap, should we discourage E&P investments in India &
drive away investors to other countries, and invariably import the same fuel at a higher
price?
5. Should RIL be blamed for increase in gas price by the Government when its share in
production is less than 10%?
6. Is it not pertinent to move towards energy security?
7. Should we not promote usage of cleaner fuel & save our environment?
8. Is it in interest of the country to compromise energy security by keeping unsustainable low
price for domestic gas?
9. Should India
not
adopt
market
based
prices
for
energy
to
bring
efficiency
in
use
and
help
demand side management?