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Resourceextractionissuers-103.Pdf By E-Mail: Chair Mary Jo White December 3, 2015 Commissioner Luis Aguilar Commissioner Michael Piwowar Commissioner Kara Stein SEC Comment File Securities and Exchange Commission 100 F Street, NE Washington, DC 20459-1090 RE: Rulemaking for Section 1504 of the Dodd-Frank Act Dear Chair and Commissioners: To support rulemaking related to Section 1504 of the Dodd-Frank Act, we wished to share maps that illustrate existing public, company-by-company, project-level disclosure that would align with transparency rules adopted in other markets, such as the European Union1 and Canada2. The maps attached illustrate how oil project status is commonly communicated to the public and investors. 1. Angola Concession Map 2015 Attached please find the oil concession map for Angola. This is provided to the public and investors by Angola’s state oil company, Songangol, on its website to market its oil blocks and disclose block operatorship.3 The map provides the names of the company operator as well as equity partners in the block and their respective stakes. Public disclosures by Statoil, for example, align with the block map.4 2. West Africa 2014 Offshore Oil and Gas Concession Map Attached please find a concession map of West Africa produced by Offshore Magazine, which is publicly available.5 As with the map of Angola, it illustrates that the concession and block allocation system is commonly used throughout the offshore area of West Africa. While less detailed than the Angola map, this map also includes the names of company block operators and license holders. 1 See: http://www.publishwhatyoupay.org/wp-content/uploads/2013/11/PWYP-fact-sheet-on-EU-Accounting- and-Transparency-Directives.pdf 2 See submission from Publish What You Pay Canada on Extractive Sector Transparency Measures Act (ESTMA), 2 Oct 2015: http://www.sec.gov/comments/df-title-xv/resource-extraction- issuers/resourceextractionissuers-88.pdf 3 See: http://www.sonangol.co.ao/English/AreasOfActivity/Concessionary/Pages/Concessions-Map.aspx 4 See Statoil Payments to Governments 2014 report included in submission from PWYP US at P.13: http://www.sec.gov/comments/df-title-xv/resource-extraction-issuers/resourceextractionissuers-73.pdf 5 See also: http://www.offshore-mag.com/content/dam/offshore/print-articles/volume- 74/12/1412OFFWestAfricaMap_1.pdf OXFAM AMERICA 1100 15TH STREET, NW SUITE 600, WASHINGTON, DC 20005 TEL +1 (202) 496 1180 FAX +1 (202) 496 1190 www.oxfamamerica.org We hope these maps are useful in developing a revised draft rule for Section 1504. Please let us know if you have any questions. Sincerely, Isabel Munilla Senior Policy Advisor, Extractive Industries ANGOLA-CONCESSIONS 8º0’0”E 10º0’0”E 12º0’0”E 14º0’0”E 16º0’0”E CONGO ONSHORE AND O FFSHORE PRODUCT ION ACTIVITY R.D.CONGO Cabinda BLOCK-0 AREA (A,B) BLOCK-2 / 85 BLOCK-2 / 05 CHEVRON (OP) 39.20% PETROBRAS 27.50% SONANGOL P&P (OP) 50.00% CN SONANGOL P&P 41.00% SONANGOL P&P (OP) 25.00% SOMOIL 30.00% TOTAL 10.00% CHEVRON 20.00% KOTOIL 10.00% ENI 09.80% SOMOIL 09.30% POLIEDRO OIL CO. S.A. 10.00% POLIEDRO OIL, CO. 09.10% KOTOIL, S.A. 09.10% CC BLOCK - 3 / 05 BLOCK - 3 BLOCK - 3 / 91 0 CANUKU SONANGOL P&P (OP) 25.00% TOTAL (OP) 50.00% CS CHINA SONANGOL 25.00% SONANGOL 06.25% 2500m SONANGOL P&P (OP) 100.00% AJOCO 20.00% ENI 15.00% 3000m 14 ENI 12.00% AJOCO 12.50% SOMOIL 10.00% SVENSKA 06.25% NAFTGAS 04.00% INA-NAFTA 05.00% 6º0’0”S INA-NAFTA 04.00% NAFTAGAS 05.00% 6º0’0”S 15/06 CON2 CON3 46 SOYO BLOCK - 4 / 05 CABINDA SOUTHERN FST ASSOCIATION 1/06 CON4 CON5 SONANGOL P&P (OP) 40.00% 31 CON1 STATOIL 20.00% PLUS PETROL (OP) 55.00% SOMOIL (OP) 15.00% SOMOIL 15.00% SONANGOL P&P 20.00% SONANGOL E.P. 63.67% ACREP S.A 15.00% FORCE PETROLEUM LDTE 20.00% CHEVRON 16.33% CON6 CON7 LOWER CONGO BASIN SONANGOL P&P 05.00% 47 PRODOIL 10.00% CUPET 15.00 % 05.00% CON8 2/05 CON9 FST ASSOCIATION 16 1500m 3/05-A SOMOIL (OP) 15.00% 48 SONANGOL E.P. 80.00% SONANGOL P&P 05.00% 32 20m CON10 17/06 4 ONSHOR E AND OFFSHORE EXPLO RATION ACTIVITY 49 BLOCK-0 AREA (A,B) CABINDA NORTHERN BLOCK- 3/05A SONANGOL P&P (OP) 20.00% 33 % 0 2.9 3 TEIK ) PO OKU ( N O R V E H C 17.00% SONANGOL P&P (OP) 25.00% 8º0’0”S %00.14 S OC O L P&POGNANOS 17.00% CHINA SONANGOL 25.00% 8º0’0”S % 0 0 . 0 1 AC REP S.A .L A T O T 15.00% AJOCO 20.00% 18/6 ENI 12.00% 50 09.80% I NCH E INA SONANGOL 11.00% 5 ENI 10.00% SOMOIL 10.00% PETROPARS 10.00% NAFTGAS 04.00% ANGOLA INA-NAFTA 04.00% 34 KON1 BLOCK - 5 / 06 BLOCK- 6/06 BLOCK - 8 PETROBRAS (OP) 40.00% 19 VAALCO ENERGY (OP) 40.00% KON3 SONANGOL P&P 30.00% MAERSK OIL & GAS (OP) 50.00% KON2 SONANGOL P&P 60.00% CHINA SONANGOL 20.00% SVENSKA 30.00% 35 6 INITIAL OIL & GAS 10.00% SONANGOL P&P 20.00% KON4 KON5 KON6 KON7 BLOCK - 9/09 KON8 KON9 KON10 COBALT (OP) 40.00% KWANZA BASIN SONANGOL P&P 60.00% 36 20 7 KON11 KON12 KON13 KON14 2000m 50m DEEP WATER PRODUCTION ACTIVITY KON15 KON16 KON17 KON18 10º0’0”S 10º0’0”S ULTRA DEEP WATER 37 BLOCK - 14 BLOCK - 15 BLOCK - 17 21 KON19 KON20 CHEVRON (OP) 31.00% ESSO (OP) 40.00% TOTAL (OP) 40.00% 8 SONANGOL P&P 20.00% BP 26.67% STATOIL 23.33% ENI 20.00% ENI 20.00% ESSO 20.00% KON21 TOTAL ANGOLA 20.00% STATOIL 13.33% KON22 GALP ENERGIA OVERSEAS 09.00% BP 16.67% 38 22 BLOCK - 18 KON23 BP (OP) 50.00% SSI 50.00% 9 23 39 DEEP WATER EXPLORATION ACTIVITY BLOCK- 14 BLOCK - 16 CHEVRON (OP) 31.00% BLOCK - 15 / 06 SONANGOL P&P 20.00% 24 ENI (OP) 35.00% MAERSK OIL ANGOLA AS (OP) 65.00% 40 ENI 20.00% SONANGOL P&P 35.00% SONANGOL P&P 20.00% TOTAL ANGOLA 20.00% ODEBRECHT E&P Gmbh(”OE&P”)15.00% GALP ENERGIA OVERSEAS 09.00% SSI 25.00% 10 12º0’0”S 12º0’0”S FALCON OIL 05.00% BENGUELA BASIN BLOCK - 17 / 06 BLOCK - 18 / 06 BLOCK - 19/11 25 TOTAL (OP) 30.00% PETROBRAS (OP) 30.00% SSI 27.50% SSI 40.00% BP (OP) 50.00% 41 SONANGOL P&P 20.00% SONANGOL P&P 25.00% SONANGOL P&P 40.00% SOMOIL 10.00% GEMINAS 05.00% CHINA SONANGOL 10.00% FALCON OIL 05.00% ACREP 17 S.A. 05.00% PARTEX 02.50% 26 BLOCK - 22/11 BLOCK - 20/11 BLOCK - 21/09 REPSOL ANGOLA 22 B.V. (OP) 30.00% COBALT (OP) 40.00% COBALT (OP) 40.00% SONANGOL P&P 60.00% SONANGOL P&P 50.00% SONANGOL P&P 30.00% STATOIL 20.00% 42 BP 30.00% 27 BLOCK - 23 BLOCK - 24/11 BLOCK - 25/11 MAERSK OIL & GAS (OP) 50.00% BP (OP) 50.00% TOTAL (OP) 35.00% SONANGOL P&P 30.00% SVENSKA 30.00% 11 SONANGOL P&P 20.00% SONANGOL P&P 50.00% STATOIL 20.00% 14º0’0”S 14º0’0”S BP 15.00% 43 ULTRA DEEP WATER EXPLORATION ACTIVITY ATLANTIC OCEAN 28 BLOCK - 31 BLOCK - 32 BLOCK - 33 TOTAL (OP) 30.00% BP (OP) 26.67% SONANGOL P&P 30.00% TOTAL (OP) 58.67% SONANGOL E.P 45.00% SSI 32 20.00% SONANGOL P&P 20.00% SSI 31 15.00% ESSO 15.00% FALCON OIL 16.00% STATOIL 13.33% GALP 05.00% GALP 05.33% 29 BLOCK - 34 BLOCK - 35/11 BLOCK - 36/11 44 12 ENI (OP) 30.00% SONANGOL P&P (OP) 20.00% CONOCOPHILLIPS (OP) 50.00% STATOIL HYDRO 50.00% SONANGOL P&P 45.00% BRASPETRO 30.00% REPSOL 25.00% SONANGOL P&P 50.00% NAMIBE BASIN 16º0’0”S 16º0’0”S BLOCK - 37/11 BLOCK - 38/11 BLOCK - 39/11 STATOIL (OP) 45.00% CONOCOPHILLIPS (OP) 30.00% STATOIL (OP) 30.00% SONANGOL P&P 30.00% SONANGOL P&P 30.00% SONANGOL P&P 50.00% WRG Angola Limited 15.00% REPSOL 20.00% TOTAL 15.00% ECOPETROL 10.00% WRG ANGOLA BLOCO 3 9 L IMITED 15.00% ECOPETROL GERMANY GHBH 10.00% 45 30 BLOCK - 40/11 13 TOTAL (OP) 40.00% IV E R SONANGOL P&P 30.00% R LEGEND STATOIL 20.00% E PETRONA 10.00% N CAPITAL C U N E EXPLORATION AREA CITY PRODACTION AREA RIVER BORDER NAMIBIA FREE AREA BATHYMETRIC LINE 6º0’0”E 8º0’0”E 10º0’0”E 12º0’0”E 14º0’0”E 16º0’0”E GAD201509-DMC0003-I Reliable OFFSHORE CONTRACTOR YOUR 100% NIGERIAN PARTNER DISCOVER THE in WEST AFRICA OUR WORLDWIDE SERVICES INCLUDE: DIFFERENCE Rigid and Flexible Pipe Installation | Platform Installation | Accommodation, Hook Up and Commissioning | SURF Installation | Decommissioning | Marine Support www.doris-engineering.com www.waventures.com ST. LOUIS ST. LOUIS DEEP KOSMOS PETROASIA Mauritania CAYAR CAYAR DEEP KOSMOS West Africa Offshore Oil & Gas Map PETROASIA Dakar Senegal Niger Blocks Pipelines Abbreviations ADDAX ADDAX PETROLEUM GAZANIA GAZANIA INVESTMENTS PAN AFRICA PAN AFRICA OIL RUFISQUE RUFISQUE Oil AFRICAN AFRICAN PETROLEUM HARVEST HARVEST NATURAL RESOURSES INC PBS PETROBRAS OFFSHORE CAIRN Blocks ALLIED ALLIED ENERGY RESOURCES HRT HRT OIL & GAS PEAK PEAK OIL AND GAS AFRICAN SANGOMAR CAIRN Exploration Licences Gas AMNI AMNI INTERNATIONAL IMPACT IMPACT AFRICA PETROSA PETROLEUM OIL & GAS SANGOMAR DJIFERE ATLANTIC ATLANTIC ENERGY INC INC NATURAL RESOURCES CORP OF SOUTH AFRICA DEEP TRACE Niamey Oil & Gas BAYFIELD BAYFIELD ENERGY JUPITER JUPITER PETROLEUM REGALIS REGALIS PETROLEUM CAIRN Banjul BLACKWOOD BLACKWOOD GROUP KAYUKO KAYUKO UNIVERSAL SAHARA SAHARA ENERGY FIELDS The Fields BRILLIANT BRILLIANT OIL KNOC KNOC CS NG SERICA SERICA ENERGY A1 CAMAC A3 Other Chad Mali CAIRN CAIRN ENERGY LEKOIL LEKOIL E&P SILVER WAVE SILVER WAVE ENERGY PPL A4 CAMAC A6 Gambia CAVENDISH CAVENDISH PETROLEUM M&P MAUREL & PROM SOCO SOCO INTERNATIONAL Oil Future CHEV CHEVRON MARATHON MARATHON EG STARC STARC LIMITED Bamako CITY CITY PETROLEUM MASTERS MASTERS ENERGY SUNLINK SUNLINK PETROLEUM OFFSHORE OFFSHORE SUD CLIVEDEN CLIVEDEN PETROLEUM CO MEDEA MEDEA ENERGIA TALEVERAS TALEVERAS GROUP SUD PROFOND Ouagadougou Gas Sudan ELENILTO AGC SHALLOW Cities CNPC CHINA NATIONAL PETROLEUM CORP MURPHY MURPHY OIL TOTAL TOTAL E&P AFRICAN ORYX CNR CANADIAN NATURAL RESOURCES NEW AGE NEW AGE ALGOA TRACE TRACE ATLANTIC OIL Terminals Capital City CONSOLIDATEDNdjamenaCONSOLIDATED OIL NIGERIAN NIGERIAN NATIONAL PETROLEUM UNIMAG UNIMAG TRADING SA DOME FLORE Guinea ECO ECO ATLANTIC NOBLE NOBLE ENERGY CAMEROON VAALCO VAALCO ENERGY INC 1 Bissau EXPRESS EXPRESS PETROLEUM NORTH SOUTH NORTH SOUTH PETROLEUM VARADA VARADA PETROLEUM AGC PROFOND TRACE Bissau Terminals Major Town EXXON EXXONMOBIL ORANTO ORANTO PETROLEUM LTD VIOCO VIOCO PETROLEUM LTD OPHIR WESTBRIDGE WESTBRIDGE ENERGY 2 This map is the exclusive copyright of Infeld Systems Ltd and may not be reproduced in whole or in part without the express written permission of Infeld Systems Ltd.
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