"the PEP -11 project application".... What on Earth are you talking about?
The NOPTA application does not give them permission to drill, it simply extends the permit term and possibly changes the final year from 3D seismic to post drill studies.
The point is, you said: "PEP-11 is located 26 km offshore" (76379450). You were wrong. You confused the whole permit area with the drill site/prospect.
Ann: Close of Entitlement Offer and Notice of Shortfall, page-128
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