Mandatory Blending As Legal Obligation: Assessing The Regulatory Architecture Of India's Compressed Biogas Blending Obligation Under The SATAT Framework
- IJLLR Journal
- Jun 30
- 1 min read
Jishan Singh Padda, Bharatiya Vidyapeeth Deemed University, Pune Institute of Management and Research, Dept. of Law, New Delhi
ABSTRACT
India's Compressed Biogas Blending Obligation (CBO) marks a significant transition in the legal treatment of renewable gas within the country's city gas economy. What began under the SATAT framework as a policy led attempt to stimulate compressed biogas (CBG) production through offtake assurance, industry coordination, and market creation has now moved into a mandatory phase through the Ministry of Petroleum and Natural Gas Office Memorandum dated 27 February 2024 directing City Gas Distribution (CGD) entities to blend prescribed percentages of CBG in the CNG (transport) and PNG (domestic) segments. This article argues that the CBO has evolved beyond a mere policy aspiration, but it has not yet matured into a fully self-contained statutory or regulatory code with an expressly articulated sanction architecture of its own. Instead, the present regime is best understood as a hybrid legal structure, it rests on a biofuels policy decision taken through the National Biofuel Coordination Committee (NBCC), is operationalised through an executive mandate issued by MoPNG, and relies for practical implementation on the pre-existing regulatory ecosystem governing CGD authorisations, pipeline access, technical standards, and network monitoring. That hybrid structure gives the obligation real normative force, but it also leaves important ambiguities around delegated authority, compliance measurement, enforceability, market access, certification, and fiscal neutrality.
Keywords: Compressed Biogas; CBO; SATAT; City Gas Distribution; Renewable Gas Regulation.
