Ann: PEP 11 Update, page-75

I have a few comments to make about what you wrote:
1) "The heart of their concerns seem to be the prospective resource figure (derived from the Pangean report)", the problem is the derivation, who made this derivative? Was it in compliance with the Listing Rules and the Society of Petroleum Engineers Petroleum Resources Management System (‘SPE-PRMS’)? The ASX said the following: "please provide a detailed explanation for the reasonable basis for disclosing the Resource Statement, commenting specifically on how BPH has a reasonable basis for disclosing the Resource Statement given BPH has not released an announcement in compliance with Listing Rules 5.25, 5.28, 5.35 and 5.36 in relation to the Resource Statement." source: 29 Dec 2022, BPH ENERGY LTD, Response to ASX Aware Query https://cdn-api.markitdigital.com/apiman-gateway/ASX/asx-research/1.0/file/2924-02617432-6A1130453?access_token=83ff96335c2d45a094df02a206a39ff4

And to be very clear, even after BPH said they were referring to the 2010 report, the ASX said "BPH has not released an announcement in compliance with listing rules 5.25, 5.28, 5.35, and 5.36 in relation to the Resource statement". source: 29 Dec 2022, BPH ENERGY LTD, Response to ASX Aware Query

2) "I have no doubt about the bona fides of the Pangean Report" I agree, however, the report does not detail any of the following total prospective resource figures which have been touted for years ever since the renewal, so what you should be concerned about is the "bona fides" of these figures and if they had a basis and complied with the listing rules:

“A report completed by Pangean Resources in 2010 following a review of prior seismic concluded “Undiscovered gross prospective recoverable gas resources for structural targets within the PEP11 offshore permit have been estimated at 5.7 Tcf (as the Best Estimate level).” “ Source: 30/06/2020, ASX:BPH, “PEP 11 Update” https://cdn-api.markitdigital.com/apiman-gateway/ASX/asx-research/1.0/file/2924-02250030-6A984549?access_token=83ff96335c2d45a094df02a206a39ff4

“The offshore Sydney basin offers a solution to the gas supply issues that have impacted the east coast gas market for the last five years with estimates of up to 5.7 TCF” source: 8 Sep 2020, ASX:BPH, PEP11 Update Carbon Capture Storage (CCS), https://cdn-api.markitdigital.com/apiman-gateway/ASX/asx-research/1.0/file/2924-02278372_PS-6A994903?access_token=83ff96335c2d45a094df02a206a39ff4

“The total P50 Prospective Resource calculated for the PEP11 prospect inventory is 5.9 Tcf with a net 5 Tcf to Advent Energy..” source: 4 Nov 2020, ASX:BPH, Annual Report to shareholders https://cdn-api.markitdigital.com/apiman-gateway/ASX/asx-research/1.0/file/2924-02304870-6A1005760?access_token=83ff96335c2d45a094df02a206a39ff4

“Analogues to major discoveries -the offshore Sydney Basin contains all the elements seen in other producing world class petroleum basins, including Prospective Resources of 5.7 Tcf (P50) in structural targets.” 20 May 2021, ASX:BPH, Company presentation https://cdn-api.markitdigital.com/apiman-gateway/ASX/asx-research/1.0/file/2924-02376548-6A1033712?access_token=83ff96335c2d45a094df02a206a39ff4

“The total P50 Prospective Resource calculated for the PEP11 prospect inventory is 5.9 Tcf with a net 5 Tcf to Advent..” source: 1 Sep 2021, ASX:BPH, Appendix 4E / Financial Report https://cdn-api.markitdigital.com/apiman-gateway/ASX/asx-research/1.0/file/2924-02415984-6A1048298?access_token=83ff96335c2d45a094df02a206a39ff4

“The total P50 Prospective Resource calculated for the PEP11 prospect inventory is 5.9 Tcf with a net 5 Tcf to Advent…” source: 1 Nov 2021, ASX:BPH, Annual report https://cdn-api.markitdigital.com/apiman-gateway/ASX/asx-research/1.0/file/2924-02445739-6A1060364?access_token=83ff96335c2d45a094df02a206a39ff4

“Analogues to major discoveries -the offshore Sydney Basin contains all the elements seen in other producing world class petroleum basins, including Prospective Resources of 5.7 Tcf (P50) in structural targets.” Source: 14 Dec 2021, ASX:BPH, Investor Webinar https://cdn-api.markitdigital.com/apiman-gateway/ASX/asx-research/1.0/file/2924-02466478-6A1068543?access_token=83ff96335c2d45a094df02a206a39ff4

“The total P50 Prospective Resource calculated for the PEP11 prospect inventory is 5.9 Tcf with a net 5 Tcf to Advent..” source: 5 Sep 2022, ASX: BPH, Advent Energy Limited June 2022 Annual Financial Statements https://cdn-api.markitdigital.com/apiman-gateway/ASX/asx-research/1.0/file/2924-02564252-6A1108057?access_token=83ff96335c2d45a094df02a206a39ff4

“Analogues to major discoveries -the offshore Sydney Basin contains all the elements seen in other producing world class petroleum basins, including Prospective Resources of 5.7 Tcf (P50) in structural targets.” 6 Oct 2022, ASX:BPH, BPH Company Presentation including Hydrogen update https://cdn-api.markitdigital.com/apiman-gateway/ASX/asx-research/1.0/file/2924-02578968-6A1114137?access_token=83ff96335c2d45a094df02a206a39ff4

“PEP-11 is reported to contain prospective resources up to 5.5 trillion cubic feet of gas, potentially similar in size to the Bass Strait, and enough to supply the East Coast with approx.. 20 years of gas.” Source: 21 Dec 2022, ASX:BPH, Response to ASX Aware Query https://cdn-api.markitdigital.com/apiman-gateway/ASX/asx-research/1.0/file/2924-02615567-6A1129639?access_token=83ff96335c2d45a094df02a206a39ff4

“Progress Report released on 22 December 2010 with MEC Resources Limited (ASX:MMR) on BPH ASX Platform which releases an independent expert report prepared by Mr Tim Berge of Pangean Resources LLC concluding that PEP11 has all the working components of a gas-charged hydrocarbon system, and is a potential giant gas province with a mean estimate of the portfolio aggregate prospective resource calculated to be 15.9Tcf recoverable.” Source: 21 Dec 2022, ASX:BPH, Response to ASX Aware Query https://cdn-api.markitdigital.com/apiman-gateway/ASX/asx-research/1.0/file/2924-02615567-6A1129639?access_token=83ff96335c2d45a094df02a206a39ff4

Just throwing numbers around with wild abandon probably won't help their case with the ASX. I would like to know why 5.5tcf, 5.7tcf, and 5.9tcf were used, instead of just the one? It seems terribly inconsistent. (65456491)

3) "the idea of querying a report released in 2010 is bizarre IMO" but they are not querying the report... they are querying the total prospective resource figures which seemingly do not have a compliant report basis and the ASX said it is not compliant with Listing Rules 5.25, 5.28, 5.35 and 5.36 in relation to the Resource Statement source: 29 Dec 2022, BPH ENERGY LTD, Response to ASX Aware Query https://cdn-api.markitdigital.com/apiman-gateway/ASX/asx-research/1.0/file/2924-02617432-6A1130453?access_token=83ff96335c2d45a094df02a206a39ff4

4) "I suspect ASX:BUY argued that they weren't involved" I don't think the ASX knows about ASX:BUY's previous potentially non-compliant claims of the total prospective resources for PEP-11. Otherwise we would most likely know, for example the ASX said the following:
"Note: ASX does not generally release to the market correspondence between it and an entity except for the following.
• A price query issued by ASX and the entity’s response.
• A query issued by ASX in respect of compliance with a listing rule, and the entity’s response, if the response includes information not previously released to the market." source: ASX listing rule 18.7A https://www.asx.com.au/documents/rules/Chapter18.pdf

So, therefore, I think we would know if the ASX was querying potential non-compliance with ASX:BUY.

5) The ASX most likely believes the following: "if ASX does not consider your response to be satisfactory, ASX is likely to continue to suspend trading in BPH’s securities under Listing Rule 17.3." source: https://cdn-api.markitdigital.com/apiman-gateway/ASX/asx-research/1.0/file/2924-02617432-6A1130453?access_token=83ff96335c2d45a094df02a206a39ff4

For those watching at home, here is a pretty good take of the BPH suspension: 65480399 and here: 65479816, and here: 65456491, and here: 65479433