I think you should read your post again.
(1) The holder of a licence shall -
As you said - WDS is not the holder.
The reports etc etc are not prepared by or on behalf of PCL, they are prepared etc by WDS for the purpose of WDS determining whether or not they wish to exercise their option.
I am certain WDS wrote the agreement so that it is their property and PCL have no rights to it.
Therefore, PCL cannot submit something they do not have.
If WDS exercises their option, then, yes they would be bound by the Namibian Petro Act but at the moment they have no such interest.
I think you should read your post again.(1) The holder of a...
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