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Krombacher

06/30/19 12:33 PM

#18186 RE: manuel06 #18174

So I'm reading through the PSC and other contracts found on the web.

ERHC is listed as Contractor and not as licensee.

This suggests to me that to have a license you must be the operator.

When you click on blocks 11A and 11AA it says Operator open and the licensing status are open. That means there's no operator and no license for an operator. It does not say that the Contract or the Contractor is open.

I ascertain that this means that CEPSA left the block, and that's why the operator is open and there's no license issued for any new operator and that's why the licensing status is open. But ERHC is still (or could still) be there.

For a sanity check, I looked up all the listed licenses in the Ministry of Kenya's presentation of 2016. We know back then that ERHC still had Kenya as a CONTRACTOR. And even had CEPSA as an operator.

http://documents.worldbank.org/curated/en/186991495657679496/pdf/SFG2851-V2-EA-P145234-Box402910B-PUBLIC-Disclosed-5-24-2017.pdf

Sure enough if you go to page 17 in Table 6, you see all of the Licensed Petroleum Companies as of June 2016. Block 11A is listed and it is LICENSED to CEPSA (not ERHC), even though ERHC is mentioned in other places in the document. And while you can find CEPSA in that table, you find it only for Block 11A. (Actually, it says Block L11A, but I think the "L" is a typo)

Hence, while one cannot definitively conclude that ERHC is in Kenya, one cannot definitively conclude that ERHC is NOT in Kenya. The only conclusion we can come to is that CEPSA is NOT in Block 11A any more.

Hope this helps,

Krombacher