local government unit (lgu) of palawan, page-10

I'll put this up so people can have a think about it.

SC55:

January 2010: BHPP and OEL sign SC55 Farmin Option Agreement (+ seismic)

February 2010: BHPP funded SC55 seismic begins.

May 2011: BHPP exercise SC55 Farmin Option.

December 2011: OEL and BHPP execute final farmin agreement for SC55.

February 2012: DOE Approve BHPP Farmin to SC55. (completes the last of the conditions precedent).

April 2012: BHPP requests DOE for 18 mth ext.

May 2012: DOE grant 12 mth ext.

BY COMPARISON

SC54B:

October 2010: Shell farmin to SC54B.

January 2011: DOE Approves Shell farmin to SC54B (the last in a number of conditions precedent).

March 2011: Atwood Falcon (rig) contracted to drill Gindara.

May 2011: Atwood Falcon Mobilises for Gindara.

May 2011: Atwood Falcon Spuds Gindara-1.


Surely the DOE would be charged with arranging/getting local government approvals for any expected drilling activities in a fixed SC tenement as part of their farmin approval assessment.

Moreover, I would expect this to be a part of marking out blocks for energy contracting rounds. You can't tell me the DOE is telling the winners of the block, OK, here are the phases you must comply with, a number of which will be drilling phases. They are hardly likely to be telling the winners of a bid, "OK, but before you drill you'll need to get LGU approval...hey, don't look at us, we only issue the blocks and work phases!"

It is a little hard for me to imagine that the DOE can approve a farmin where the express intent is to drill a well/s, but the last say goes to local government! What if local gov says, "no, bugger off, we don't want it."

If indeed it is a lack of LGU approval/s, I cannot imagine it being anymore than an immediate rubber stamp.

Note that in both cases above, the DOE approval of both farmins contains a phrase stating .."the last in a number of conditions precedent.."