SEC Company Response from SASOL LTD (SSL, SASOF) (CIK 0000314590) (SSL) — Jul 30, 2013
SASOL LTD (SSL, SASOF) (CIK 0000314590)
Date: July 30, 2013 · CIK: 0000314590 · Accession: 0000314590-13-000009
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File numbers found in text: 001-31615
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29 July 2013
Mr. Brad Skinner
Senior Assistant Chief Accountant
Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C 20549
Dear Mr. Skinner
Sasol Limited Annual Report on Form 20-F for the
Year Ended June 30, 2012
Filed October 12, 2012
File No. 001-31615
We refer to the Staff's comment letter dated
28 June 2013, relating to the Form 20-F of
Sasol Limited (the Company for the year ended
30 June 2012. Set forth below in detail are the
responses to the Staff's comments, which have
been provided in each case following the text of
the comment in the Staff's letter.
In response to the Staff's comments,
the Company intends to revise the disclosures in all
future filings, beginning with the annual report on
Form 20-F for the year ended 30 June 2013
(which the Company intends to file during October 2013),
as discussed in our responses.
1. Since you disclose synthetic oil as reserves
elsewhere in your filing under supplemental oil and gas information,
please expand your disclosure to include the production,
average sales price and average production cost for each of the
last three years in accordance with the requirements set forth in
Item 1204 of Regulation S-K.
Response
The Company has referred to Regulation S-K, Item 1204 and the
intends to revise the disclosure under the subheading
Synthetic Oil Equivalent Production, Production Prices and
Production Costs in future filings to
present the production, average sales price and
average production cost for each of the last three years.
For illustration purposes, we set out below the disclosures
as it would have appeared in our Form 20-F for the year
ended 30 June 2012:
2012
South Africa
(Rand per
unit)
2011
South Africa
(Rand per
unit)
2010
South Africa
(Rand per
unit)
Average sales price per barrel
865,76
675,76
564,64
Average production cost per barrel
376,65
323,84
278,19
Production (millions of barrels)
42,4
44,1
47,0
2. You disclose under this section that the
June 30, 2012 net quantities of proved condensate reserves
were .22 Mbbl.
However, elsewhere in this section you disclose quantities
in terms of MMbbl. Review your disclosure under this section
and revise as may be necessary to use consistent volume
measurements.
Response
The Company acknowledges the Staff's comment, and in all future
filings, beginning with the annual report on Form 20-F for the
year ended 30 June 2013, the Company will revise the disclosure
to ensure the consistent use of volume measurements.
For illustration purposes, the Company has set forth below a draft
of the modified disclosures regarding the net quantities of proved
condensate reserves relating to the Canada producing assets that the
Company believes are responsive to the Staff's comment.
Illustrative disclosure based on the annual report on Form 20-F
for the year ended 30 June 2012
Canada producing assets
In 2012, production from the Farrell Creek and Cypress A asset
amounted to 17,0 Bscf gas and 0,01 MMbbl condensate; and the net
economic interest proved reserves at 30 June 2012 are estimated
to be 55,21 Bscf gas and 0,22 MMbbl condensate.
3. We note your presentation of the average production cost
as a single value per thousand cubic feet/barrel. Please revise the
disclosure to separately present the cost per unit of gas and the
cost per unit of oil produced or to clarify that the presentation
represents a single aggregated unit cost disclosed on a gas or
oil equivalent basis.
Refer to the requirements set forth in Item 1204(b)(2).
Response
The Company acknowledges the Staff's comment, and in all
future filings, beginning with the annual report on Form 20-F
for the year ended 30 June 2013, the Company intends to revise
the disclosure under the subheading Oil and gas production prices
and costs to present the average production cost per unit of
gas and per unit of liquids as separate table entries.
The average production cost per unit of production is calculated
according to the primary sales product. Where a co-product is sold
(e.g. small liquid volumes associated with primary gas production)
the co-product is not included in the production cost calculation.
The Company confirms capital amortisation is performed on the same
basis.
For illustration purposes, we set out below the disclosures
as it would have appeared in our Form 20-F for the year ended
30 June 2012:
Illustrative disclosure based on the annual report on Form 20-F
for the year ended 30 June 2012
Oil and gas sales prices and production costs:
The table below summarises the average sales prices for natural
gas or oil produced and the average production cost, not including
ad valorem and severance taxes, per unit of production for each of
the last three years.
Average sales prices and production costs for the year
ended 30 June
Mozambique
Gabon
Canada
Other
areas
(Rand per unit)
2010
Average sales prices
Natural gas, per thousand standard cubic feet
11,2
-
-
-
Liquids, per barrel
324,2
455,4
-
-
Average production cost*
Natural gas, per thousand standard cubic feet
2,6
-
-
-
Liquids, per barrel
-
116,2
-
-
2011
Average sales prices
Natural gas, per thousand standard cubic feet
11,9
-
23,9
-
Liquids, per barrel
451,0
558,4
551,8
-
Average production cost*
Natural gas, per thousand standard cubic feet
2,3
-
7,9
-
Liquids, per barrel
-
80,8
-
-
2012
Average sales prices
Natural gas, per thousand standard cubic feet
15,8
-
18,7
-
Liquids, per barrel
636,6
741,7
650,2
-
Average production cost*
Natural gas, per thousand standard cubic feet
3,4
-
9,2
-
Liquids, per barrel
-
124,3
-
-
* Average production costs per unit of production are
calculated according to the primary sales product.
4. Please refer to Item 1205 of Regulation S-K and revise
your disclosure to present the
number of net wells drilled
Response
The Company acknowledges the Staff's comment, and in all
future filings, beginning with the annual report on Form 20-F
for the year ended 30 June 2013, the Company will revise the
disclosure under the subheading Exploratory and development
wells to present the net number of wells drilled as defined.
Additionally the Company will include further disclosure under
the subheading Other exploratory and development drilling
activities to disclose the net number of other well types as
defined in Regulation S-X Part 210.4-10 (a).
For illustration purposes, we set out below the
disclosures as it would have appeared in our Form 20-F
for the year ended 30 June 2012
Illustrative disclosure based on the annual report on
Form 20-F for the year ended 30 June 2012
Exploratory and development wells:
The table below provides the number of net exploratory wells
and development wells completed regardless of when drilling
was initiated, in each of the last three years.
Number of wells drilled for the year ended 30 June
Mozambique
Gabon
Canada
Other
areas
Total
(net number of wells drilled)
2010
Exploratory well-productive
-
-
-
-
-
Exploratory well-dry
-
-
-
-
-
Development well-productive
-
0,3
-
-
0,3
Development well-dry
-
-
-
-
-
2011
Exploratory well-productive
1,0
-
-
-
1,0
Exploratory well-dry
-
-
-
-
-
Development well-productive
2,1
0,6
-
-
2,7
Development well-dry
-
-
-
-
-
2012
Exploratory well-productive
-
-
-
-
-
Exploratory well-dry
-
-
-
-
-
Development well-productive
-
-
26,0
-
26,0
Development well-dry
-
-
-
-
-
- A dry well is an exploratory or development well that
proves to be incapable of producing either oil or natural gas
in sufficient quantities to justify completion.
- A productive well is an exploratory or development well
that is not a dry well.
Other exploratory and development drilling activities:
The table below provides the number of net wells, that are not
exploratory wells or development wells, drilled in each of
the last three years.
Number of wells drilled for the year ended 30 June
Mozambique
Gabon
Canada
Other
areas
Total
(net number of wells drilled)
2010
Stratigraphic test well exploratory type
-
0,9
-
-
0,9
Stratigraphic test well development type
-
-
-
-
-
Service well
-
-
-
-
-
2011
Stratigraphic test well exploratory type
2,0
0,3
-
0,6
2,9
Stratigraphic test well development type
-
-
-
-
-
Service well
-
-
-
-
-
2012
Stratigraphic test well exploratory type
-
-
-
0,4
0,4
Stratigraphic test well development type
-
-
-
-
-
Service well
-
-
0,5
-
0,5
- A stratigraphic test well is drilled to obtain
information pertaining to a specific geological condition
and is customarily drilled without the intent of being
completed.
Stratigraphic test wells are exploratory type if not drilled
in a known area or development type if drilled in known area.
- A service wells is an injection well, water supply
/ disposal well or an observation well.
5. Please refer to the definitions contained in
Item 1208(c) and revise your disclosure to provide the area
in terms of acres.
Alternatively, disclose the factor to convert the area
from km2 to acres as a footnote to the table.
Response
The Company acknowledges the Staff's comment, and in all
future filings, beginning with the annual report on Form 20-F
for the year ended 30 June 2013, the Company will revise the
disclosure under the subheading Productive wells and area to
provide the developed and undeveloped amounts in acres.
For illustration purposes, we set out below the disclosures as
it would have appeared in our Form 20-F for the year ended
30 June 2012:
Illustrative disclosure based on the annual report on
Form 20-F for the year ended 30 June 2012
Productive wells and acreage:
The table below provides details of
the productive wells and the amount of developed and
undeveloped acreage at 30 June 2012.
Number of productive wells and acreage
concentrations at 30 June 2012
Mozambique
Gabon
Canada
Other
Total
Productive oil wells (number)
Gross
1
10
-
-
11
Net
1,0
2,8
-
-
3,8
Productive gas wells (number)
Gross
22
-
88
-
110
Net
15,4
-
44,0
-
59,4
Developed acreage (thousand acres)
Gross
431,7
28,7
27,2
-
487,6
Net
302,2
8,0
13,6
-
323,8
Undeveloped acreage (thousand acres)
Gross
7 708,5
730,9
84,3
17 916,9
26 440,5
Net
5 591,8
219,3
42,2
5 951,6
11 804,8
- A productive well is a producing well or a well that is
mechanically capable of production.
- Certain licenses in Mozambique overlap as they
relate to specific stratigraphic horizons.
6. Item 1208(b) of Regulation S-K requires the disclosure of
material amounts of expiring acreage by geographic area.
Please expand your discussion of the individual concessions and
licenses on pages 129 through 130 to include such disclosure.
Response
The Company acknowledges the Staff's comment, and in all future
filings, beginning with the annual report on Form 20-F for the
year ended 30 June 2013, the Company will expand its disclosure
on licence terms to more clearly identify amounts of expiring
acreage.
For illustration purposes, we set out below the disclosures as it
would have appeared in our Form 20-F for the year ended 30 June 2012:
Illustrative disclosure based on the annual report on Form 20-F
for the year ended 30 June 2012
Licence terms Mozambique: The Petroleum Production Agreement for
the Pande-Temane PPA asset expires in 2034 and carries two possible
five year extensions. There are no remaining licence obligations
and there is no requirement to relinquish any acreage until the
expiry of the Petroleum Production Agreement.
The Pande-Temane PSA licence is in the third and last exploration
period.
Two discovery areas (Pande/Corvo/Tafula and Temane/Temane East
/Inhassoro) are currently being appraised. The appraisal phase
is scheduled to end in December 2012. The decision to develop the
fields and retain the associated acreage is dependent on the appraisal
results (442,8 thousand undeveloped net acres affected).
The Exploration and Production Concession for Blocks 16&19 is in the
third and last exploration period which expires in June 2013.
There are no remaining commitments. The acreage will be relinquished
at the end of the exploration period unless the Njika discovery is
declared commercial (1 157,6 thousand undeveloped net acres affected).
The Exploration and Production Concession M-10 is in the second
exploration period which carries a one well commitment and is due to
expire in January 2013. Approval to drill the commitment well (Mupeji)
has been obtained and preparation is under way to drill the well.
The decision to enter the third exploration period and associated
acreage relinquishment is dependent on the drilling results and ongoing
study work (320,0 thousand undeveloped net acres affected).
The Exploration and Production Concession Sofala is in the second
exploration period which expires in January 2013. The gravity survey and
seismic acquisition commitments have been completed. The decision to
enter the third exploration period and associated acreage relinquishment
is dependent on the seismic interpretation results and ongoing study work
(1 809,3 thousand undeveloped net acres affected).
The Exploration and Production Concession Area A licence is in the first
exploration period which expires in May 2014. The gravity survey
commitment has been completed and the seismic acquisition commitment
has commenced. The decision to enter the second exploration period and
associated acreage relinquishment is dependent on the seismic
interpretation results and ongoing study work
(1 862,1 thousand undeveloped net acres affected).
Licence terms Gabon: The exploration area of the Etame Marin Permit
expires in July 2014. There is 1 well commitment outstanding.
The decision to apply for permission to exploit the area and retain
acreage is dependent on the drilling results and ongoing study work.
The full exploration area will be relinquished if it is decided not to
submit a development plan (219,3 thousand undeveloped net acres affected).
The exploitation area of the Etame Marin Permit is covered by three 10 year
Exclusive Exploitation Authorisations each with two five year extensions
available on request and subject to government decree.
The Etame Exclusive Exploitation Authorisation is in the first extension
period to July 2016. The Exclusive Exploitation Authorisations for Avouma
and Ebouri expire in March 2015 and June 2016, respectively.
The current plan of development is based on granting of the various
extensions to July 2021.
Licence terms Canada: As at 30 June 2012, Farrell Creek comprised of
26 licenses and leases and Cypress A comprised of 27 licenses and leases.
Acreage retention and the conversion of licenses
(which carry no production rights) to leases
(with production rights) is enabled by drilling commitments,
the provincial government's prescribed lease selection and validation
process and license extension applications. The decision to retain
acreage and convert licences
to leases is dependent on the drilling results and ongoing study work.
Drilling and retention activities have been and will be included in the
applicable work programmes in order that licences and leases that are due
to expire before 30 December 2013 are retained (10 licences and leases,
4,4 thousand undeveloped and 9,5 thousand developed net acres).
Licence terms other areas: The Botswana licences PL134/2010, PL135/2010
and PL136/2010 are in the first exploration period which expires in
September 2013. The plan is to obtain government approval by June 2013 to
continue the current work programme into the second exploration period
in order to complete the minimum commitments (367,0 thousand undeveloped
net acres affected).
In the Papua New Guinea PPL285, 286, and 288 licences the plan is to
retain a prospective area in the north of PPL285 and PPL288
(685,9 thousand undeveloped net acres) under a combined new licence.
The remaining areas of PPL285 and PPL288 and all of PPL286
(2 922,9 thousand undeveloped net acres) will be relinquished
or assigned. The PPL287 licence is in its third explo