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Sigurd Heiberg, Petronavit a.s.

Subject: Comments to the Draft Specifications for Application of UNFC-2009 to Injection Projects for the Purpose of Geological Storage: Sigurd Heiberg, Petronavit a.s.
15 September 2015

First of all, many thanks for issuing these quality draft specifications for public comment.

I have taken the liberty to convert the PDF file to Word and have included the comments in the form of track changes for easy readability. In this way, also minor comments have been included.

The ones of more principal importance concern figures 1 and 2, where it is vital to translate table 2 and 3 of UNFC 2009 fully, including a class of lost quantities that in the text have been well defined to replace non-sales production, and the footnotes. In particular, it is important to preserve the ability of the UNFC to distinguish between E and F contingencies, meaning that projects may be E1 but not technically ready for implementation (F2) or E2 and F2 as noted in the figures. The former will naturally occur if there is a sweeping change of frameworks affect more projects than industry has the capability to follow up immediately.

A second principal concern is the definition of the basis of the estimate, whether it is the project quantities or the quantities corresponding to the economic interests of the reporter. The project quantities are always defined and must be estimated. Appropriation of those quantities to project participants may or may not be directly related to the project. They often are, but the participants are generally free to agree or legislate otherwise, and sometimes do. In order not the loose the project definition, it is important to insist that project quantities are estimated. Reporters will generally be free to disclose or not information they own including project estimates and appropriations, unless required to do otherwise. This is not an issue of classification, but of management.

A third principal concern is the evaluator qualifications. The basic principle here must be that numbers be correct. When they depend on other than geological conditions, the evaluator must be qualified to assess also those.

Comment from Sigurd Heiberg, Petronavit a.s., to the Draft Specifications for Application of UNFC-2009 to Injection Projects for the Purpose of Geological Storage.
Attachment MS WordPDF