This briefing looks at those regulatory challenges, the lessons from the US experience, Europe’s position on the matter, and the likely regime for shale gas in Europe, with a particular focus on Poland and Romania
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Shale gas in Europe: Soon in a jurisdiction near you
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OTHER PROFESSIONAL SERVICES BY POSTING SAID MATERIAL. THE INFORMATION AND OPINIONS CONTAINED IN THIS DOCUMENT ARE FOR GENERAL
INFORMATION PURPOSES ONLY, ARE NOT INTENDED TO CONSTITUTE LEGAL OR OTHER PROFESSIONAL ADVICE, AND SHOULD NOT BE RELIED ON OR TREATED AS A
SUBSTITUTE FOR SPECIFIC ADVICE RELEVANT TO PARTICULAR CIRCUMSTANCES. SCHOENHERR DOES NOT ACCEPT ANY RESPONSIBILITY FOR ANY LOSS WHICH MAY
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Shale Gas in Europe - Soon in a jurisdiction near
you?
Shale gas confronts Brussels with the challenge of recognising its potential and
future role in the European energy policy. Any shale gas policy the EU may choose
to follow would not need necessarily to be a start-up, as it could be integrated in the
current policies. The crucial issue with regard to the regulatory process is
recognising the specific geological, technical and environmental aspects of shale
gas, understanding how it varies from conventional oil and gas exploration and
production, and ultimately addressing these issues via regulation. In addition to the
regulatory challenges, public acceptance proves to be an extremely sensitive issue,
especially in Europe.
If these environmental impacts can be contained, shale gas’s potential is too large
for it to be ignored both by Brussels and those member states with considerable
reserves. Some progress has been made since the shale gas discussion in Europe
started in 2011 and the Commission’s 2013 Work Programme proposed delivering a
framework to manage risks, address regulatory shortcomings, and provide
maximum legal clarity and predictability for both market operators and citizens
across the EU.
This briefing looks at those regulatory challenges, the lessons from the US
experience, Europe’s position on the matter, and the likely regime for shale gas in
Europe, with a particular focus on Poland and Romania.
Background
Shale gas is a type of natural gas produced from shale formations that typically
function both as a reservoir and source. Shale gas is a dry gas composed primarily
of methane (90% or more). Shale formations are sedimentary rock formations
consisting predominantly of consolidated clay particles.
The combined processes of horizontal drilling and hydraulic fracturing are the
enabling technologies that have made the recovery of shale gas economically viable.
Hydraulic fracturing involves the injection of large volumes of water, sand and some
chemicals at high pressure down a well. The pressurised fluid mixture causes the
formation to crack open, allowing natural gas or oil to flow up the well. Horizontal
drilling is used to maximise the surface contact with the shale deposit.
Large scale hydraulic fracturing was first developed in Texas in 1950s and was used
to drill the Barnett shale (Texas) in 1986. During the 1980s, production volumes
began to expand rapidly, and the first horizontal well was drilled at the same shale
play in 1992.
In an interview with The Economist in 2012, famed energy researcher and writer
Daniel Yergini
said: “the technological revolution in unconventional gas has been the
single most important energy innovation so far this century. Its tremendous
potential has already transformed North America’s energy landscape and may now
transform the global gas industry”.
Indeed, in the US shale gas production has increased from 1% of overall energy
production in 2000 to 20% in 2009, with an average annual 50% increase in shale
gas and oil production since 2007. A recent McKinsey strategy report identifies shale
gas as one of the five game changers that will revive US economy and ensure
growth. The report estimates that capturing the shale opportunities could add 2-4
percent to the country’s annual GDP and create up to 1.7 million permanent jobsii
.
Contact
Maciej Huzior
T: +48 22 222 42 00
E: m.huzior@schoenherr.eu
Contact
Anca Velicu
T: +40 21 319 67 90
E: a.velicu@schoenherr.eu
Contact
Raluca Dirjan
T: +32 2 743 40 41
E: r.dirjan@schoenherr.eu
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INFORMATION PURPOSES ONLY, ARE NOT INTENDED TO CONSTITUTE LEGAL OR OTHER PROFESSIONAL ADVICE, AND SHOULD NOT BE RELIED ON OR TREATED AS A
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Source: Maximilian Kuhn, Frank Umbach, , “Strategic Perspectives of Unconventional Gas, A Game Changer with
Implication for the EU’s Energy Security”, published by the European Centre for Energy and Resource Security
(EUCERS) in 2011
In spite of this success in North America, it is not yet clear whether the “shale gas
revolution”, as it has been coined, can be replicated in Europe.
Regulatory challenges
The industry and the market have been ahead of the regulators in the shale gas
game. To date, there is no legislation specifically addressing shale gas, neither in
the US nor elsewhere in the world. In spite of this, there are a number of common
regulatory challenges that have been recognised and associated with
unconventional gas exploration and production, regardless of the jurisdiction:
Hydraulic fracturing – in addition to the technical side, there is increasing
public, media and governmental concern regarding potential contamination of
drinking water aquifers as a result of the fracturing fluid chemicals dispersing
beyond the well.
Water management – the key issues associated with water are the extremely
large volumes (ie: 10,000-30,000 tonnes of water per well) needed to fracture
the shale rock with the current technologies and the disposal and safe
management of the waste fluids used for fracturing.
Well spacing requirements – the optimal well spacing and densities are
extremely relevant for the efficient recovery of the gas, as shale gas resources
are characterised by reservoirs that have an extremely low level of permeability
and are laterally extensive. The reservoirs also vary substantially depending on
their location, thickness and number of layers.
Environmental issues – three crucial elements have been identified: surface and
groundwater pollution risk; increased local greenhouse gas emissions; and local
deforestation and natural habitat disturbance.
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SUBSTITUTE FOR SPECIFIC ADVICE RELEVANT TO PARTICULAR CIRCUMSTANCES. SCHOENHERR DOES NOT ACCEPT ANY RESPONSIBILITY FOR ANY LOSS WHICH MAY
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Public acceptance – as shale gas reserves are located mainly on shore,
sometimes in areas with high population density, public acceptance is a main
concern. In addition to fracturing, the heavy truck traffic, the noise, the effects
of emissions on the local air quality, and potential property damage also need
to be dealt with at the regulatory level.
Overcoming the influence of lobbyists and environmental pressure groups.
Information collection and dissemination – the key issue is to appreciate that a
different set of information is needed than for conventional oil and gas drilling.
It should also be noted that the operators have so far been very active in
protecting what they consider to be proprietary information (most importantly,
the composition of the fracturing fluid) in their desire to secure their
competitive advantage.
The US experience
Although specific legislation to cater for shale gas exploration and production has
not been enacted in the United States, the US government has played its part in
supporting unconventional gas through fiscal policies, R&D funding, and non-
stringent exploration and production and environmental regulations – although the
latter set of policies are now subject to substantial criticism. It will be interesting to
follow if this recent criticism will eventually crystallise into a regulatory framework.
Aside from its economic and security of supply benefits, the exploration and
production of shale gas in the US has fuelled debates amongst its stakeholders,
mostly from an environmental perspective. In the words of the gas industry,
hydraulic fracturing is a proven technology that has been used safely for more than
60 years in drilling over one million wells. For those opposing shale gas exploration
and production, the matter represents a substantial threat to the environment and
the health of local communities. A good example of how unsettled the matter is at
the regulatory level: ExxonMobil Corp. (Exxon) inserted an “opt out” provision in its
December 2009 merger agreement with XTO Energy in an attempt to insulate itself
from any regulatory consequences, allowing the deal to be called off by Exxon in
case of a “Company Material Adverse Effect” which included changes to the existing
legislation that would make hydraulic fracturing illegal or “commercially
impracticable.”
According to the US Department of Energy, the exploration and production of shale
gas in the US by and large falls under the same complex set of federal, state and
local laws as for the conventional oil and gas industry at large.
The key legal issues with shale gas are not related to upstream legislation, but
rather arise mainly from environmental legislation.
The Environmental Protection Agency (EPA) is in charge of the administration of the
federal environmental legislation in the United States. In addition to this, there are
one or several regulatory authorities for each state in which oil and gas is produced
that are, collectively or separately, in charge of licensing, including setting the site
for the wells, operation, abandonment, waste and disposal, air emissions,
undergoing injections, wildlife impact, surface disturbance, and health and safety
issues. By statute, the states may adopt their own environmental legislation,
provided they cater for at least the minimum level of protection imposed by the
federal legislation. The complexity of the federal, state and sometimes municipal
legislation has been criticised as being a source of inefficiency and confusion in the
development of this new source of energy for which the stakes are high, and
industry has often taken action at a faster pace than either legislation or the
regulatory authorities.
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Despite the fact that industry and, in previous years, even the US Department of
Energy stated that fracturing is a well-tested and safe technology and that the
current legal framework is well-equipped to tackle the regulatory challenges, there
have been voices from the public, as well as from professional and academic
environments, who have carefully flagged and explained some concerns related to
this new-found bonanza.
Historically, due to an exemption in the Safe Drinking Water Act (SDWA), the EPA
until recently had not regulated gas production wells and had not considered
hydraulic fracturing to fall within the definition of underground injection. Following
Leaf v EPA in 1997 and reflecting an increasing number of public complaints, the
EPA issued a report in 2004 and concluded that the injection of hydraulic fracturing
fluids posed little threat to the underground sources of drinking water and required
no further study. That report was heavily criticised by public opinion and some
members of Congress.
In 2005, following the Energy Policy Act, Congress decided to amend the SDWA to
specifically exclude from the definition of “underground injection” the injection of
fluids or propping agents (other than diesel) used in hydraulic fracturing operations
related to oil and gas. This meant that the EPA’s authority to regulate underground
injection was expressly removed. The New York Times dubbed this legislative action
“the Halliburton Loophole”, as it was inserted at the call of then-Vice President Dick
Cheney, a former chief executive of Halliburton.
Following this exemption, public concern grew stronger and a new bill was
introduced in 2009 (Fracturing Responsibility and Awareness of Chemicals Act –
FRAC Act) that amended the definition in the SDWA of “underground injection” to
expressly include the “underground injection of fluids or propping agents used for
hydraulic fracturing in oil and gas operation and production activities.” The FRAC Bill
requires disclosure of the chemicals used in the fracturing fluids. This Bill was
introduced on 15 March 2011 in the US House of Representatives, but it has not
been enacted yet; in May 2013, the Bill was referred to a congressional committee
that will consider it before possibly sending it on to the House or to the Senate.
In March 2011, President Obama announced a plan for US energy security in which
he also instructed the Secretary of Energy Advisory Board to improve the safety for
shale gas development by working with the gas industry, states, and environmental
experts in this respect.
The Secretary has set up a Subcommittee specifically tasked to work with the EPA
and industry experts on issuing recommendations by examining fracturing issues. A
number of high profile energy experts were appointed as members of the
Subcommittee.
In November 2011, the Subcommittee issued its revised report putting together a
list of twenty recommendations. The bullet point list below flags only those
recommendations that are also relevant for a European discussion on shale gas:
Disclosing the composition of fracturing fluids– the Subcommittee takes the
view that the risk of fracturing fluid leakage into drinking water is remote; nev-
ertheless, there is no economic or technical reason to prevent disclosure of all
chemicals, except for genuinely proprietary information.
Protecting water quality and supply – the regulatory system should be based on
continuous and consistent measurement and public disclosure of the flow and
composition of water at every stage of the production process.
Managing the impact on communities, land use and landscape, and wildlife.
Improving public involvement and information on shale gas operations.
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On a general note, the Secretary of the Energy Advisory Board concluded that if
action is not taken to reduce the environmental impact associated with the already
considerably large-scale drilling and production of shale gas, there is a serious risk
of real environmental consequences causing a loss of public confidence that could in
turn delay or stop those operations.
The European experience
One of the ingredients for the success of shale gas production in the United States,
the title to the hydrocarbons, cannot be replicated in Europe, where gas is the
property of the state. As a consequence, there are no upfront benefits to the local
land owners in Europe and this situation directly impacts the level of public
acceptance.
In addition to this, European voters are perceived as environmentally-aware
electorates with strong and vocal environmental organisations and lobbyists, and a
successful track record of preventing or unwinding large infrastructure projects.
Europe’s energy policy is based on three core principles: the internal energy
market, security of supply, and climate change. Many observers argue that even if
no shale gas is as yet being produced in Europe, US production has nevertheless
radically changed the security of supply and pricing game of gas for Europe.
Under the Lisbon Treaty, EU member states are free to determine the conditions for
the exploitation of their energy resources and their energy mix. They are also free
to adopt environmental legislation that is stricter than the one in place at the EU
level.
The Hydrocarbon Licensing Directive 1994 (HLD 1994) recognises the rights of the
member states over their hydrocarbon resources. As an effect of this Directive, the
upstream oil and gas market in Europe has been opened up for competition
(transparent, objective, non-discriminatory criteria), ensuring that member states
could not restrict exploration and exploitation rights to their own national
companies. Nevertheless, it is up to each member state to decide whether to open
its geographical areas for exploration and production and, if so, which particular
areas to develop.
The implementation of the HLD 1994 by the member states had not been
problematic.
There are no conceptual barriers that would prevent the HLD 1994 from covering
the licensing process for shale gas exploration and production. As is the case with
the US legal framework, the issues with shale gas in Europe will likely revolve
around the environmental impact, land use and planning, and public acceptance,
rather than exploration and production.
It was only in 2011 that shale gas really appeared on Brussels’ radar, and no
overarching, comprehensive EU policy has been articulated so far. Prior to 2011,
there are almost no relevant materials, reports or press statements from Brussels
on this topic.
The crucial issue with the regulatory process is to appreciate the specific geological,
technical, and environmental aspects of shale gas and their variations from
conventional oil and gas activities, and ultimately to address these issues and via
regulation to bridge the gap presently associated with this new commercially viable
sector.
Following a European Council meeting in February 2011 and the European
Parliament’s November 2012 call for the introduction of an EU-wide risk
management framework for unconventional fossil fuels exploration and extraction,
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with a view to ensuring that harmonised provisions for the protection of human
health and the environment apply across all member states, the Commission has
released several studies on shale gasiii
.
A study commissioned in 2011 concluded that the existing EU legislation is
applicable also to shale gas exploration, development, production, and
decommissioning; however, more information was required to determine if the
existing legislation was fit to cover the topic adequately.
An on-line public consultation came to an end in March 2013 and the results are
now freely availableiv
. The context of this public consultation is the preparation of
the impact assessment on the ‘Environmental, Climate and Energy Assessment
Framework to Enable Safe and Secure Unconventional Hydrocarbon Extraction.’ The
questionnaire’s scope is to provide an understanding of the views on the
opportunities and possible solutions to address the challenges associated with the
exploration and production of unconventional fossil fuels. 22,875 respondents
(22,122 individuals, the rest being various public and private organisation and
companies) provided their input. The majority of the respondents agreed on the
absence of adequate legislation, the need for public information, and the lack of
public acceptance. Out of the policy options proposed in the questionnaire, ‘doing
nothing at EU level’ is the least appealing approach, according to the respondents.
The results of this public consultation clearly show that stakeholders and the public
at large expect the EU to develop an official position on shale gas followed by some
type of legislative initiative.
The Commission’s 2013 Work Programme proposed to deliver a framework to
manage risks, address regulatory shortcomings, and provide maximum legal clarity
and predictability for both market operators and citizens across the EU. The Impact
Assessment will look at options to prevent, reduce, and manage surface and
subsurface risks, to adapt monitoring, reporting, and transparency requirements,
and to clarify the EU regulatory framework with regard to both exploration and
extraction activities. Complementary studies were launched by the Commission,
which will provide further socio-economic and legal support in the frame of this
exercise.
Focus on Poland and Romania
Poland is estimated to hold substantial reserves of shale gas, although an
inconsistency between the figures reported by the Polish Geological Institute and
the reality on the ground has become apparent. The US Energy Information
Administration estimates that Poland holds some 4 billion cubic metres, making this
the largest reserve of shale gas in Europe.
Poland imports more than 60% of its domestic gas consumption from Russia, which
in terms of energy security is considered as high exposure.
Poland has given so far 109 concessions for shale gas, covering 88,000 km², with
43 exploration wells.
So far, the Polish government has exhibited the most ‘pro’ shale gas stance of any
other government in Europe. Public acceptance is also very high.
The US Energy Information Administration estimates that Romania holds some 1.4
billion cubic metres of recoverable wet shale gas, making it the third-largest deposit
in Europe after Poland and Francev
. This could potentially turn Romania into the
biggest gas producer in South-East Europe, and provide the country’s domestic
consumption of gas for another 100 years.
Chevron holds a number of concessions in Romania and has announced its intention
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to start exploratory drilling in late 2013. Petrom, Romgaz MOL, Sterling, East-West,
and Zeta Petroleum have also all expressed an interest in further shale gas
opportunities in Romania.
The Romanian government’s position with regard to shale gas appears to be
shifting. After a period of a so-called de facto moratorium, the country’s prime
minister and, more recently, its president have issued public statements in support
of shale gas exploration and production. Some protests against shale gas have been
reported, especially in Romania’s North-Eastern counties.
Title to hydrocarbons
As opposed to the US, in most European jurisdictions (with some exceptions in
Germany) it is the state that holds the title to natural resources. This also holds true
for both Poland and Romania: in Poland, the proprietor is the State Treasury and
the Minister of Environment grants concessions as proxy of the State Treasury,
while in Romania, the state itself is the proprietor and the National Agency for
Mineral Resources is the authority in charge of the licensing process.
In Poland, the title to exploration and/or production consists of two (separate) legal
instruments: a concession (an administrative document issued by the Ministry of
Environment) and a mining usufruct (a commercial contract entered into with the
Ministry of Environment).
In Romania, a petroleum agreement grants a concession right for exploration
and/or production and the right to perform petroleum operations.
Authorities in charge
In Poland, the main public bodies involved in the upstream oil and gas sector are
typically the State Treasury, the Ministry of Environment, the State Mining Authority
and the Polish Geological Institute, whereas in Romania, the central role rests with
the National Agency for Mineral Resources, while it is worth noting that the
petroleum agreement needs to be approved by the Government.
Primary legislation
The Polish Geological and Mining Act 2011 and the Romanian Petroleum Act 2004 by
and large follow the provisions of the HLD 1994.
Also relevant are those provisions of the Polish Energy Act 1997 and the Romanian
Energy Law 2012 that cover downstream issues. The Polish Energy Act 1997 is
currently in the process of being amended to transpose the provisions of the Third
Energy Package, whereas the Romanian Energy Act 2012 arguably transposes most
of the provisions of the Third Gas Directive.
Who can hold a license?
In Poland, only entities duly registered in Poland can apply for an exploration
licence, whereas in Romania any legal entity (foreign or Romanian) can apply for a
licence, with successful bidders (if these are foreign legal entities) needing to
register in Romania within 90 days as of the signing of the petroleum agreement.
Joint Operating Agreement (JOA), Unitisation and Farm-Out
The Polish Geological and Mining Act 2011 is silent on whether an investor has the
option of entering into a JOA or unitisation agreement, or if the investor can farm
out its interest in a block. Arguably, this would be possible, and a bill currently
under public debate clarifies these options (please also see section What’s next
below).
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All of these options are already available to a potential licence holder under the
Romanian Petroleum Act 2004.
Awarding procedure
By and large, the awarding procedure is similar in both jurisdictions, based on the
framework set in place under the HLD 1994.
By way of a brief overview in Poland:
the bidding round is initiated by the Ministry of Environment and the
announcement is published on its website and in the Official Journal of the
European Union
bidders are given at least 3 months to submit their bids
the selection criteria are based on the technical and financial capability, as well
as on the proposed technology for the works programme
the winning bidder is awarded a concession and enters into a mining usufructus
for up to 50 years with the Ministry of Environment.
As well by way of a brief overview for Romania:
the bidding round is initiated by the regulator or at the request of an interested
party and the announcement is published in Official Journals of Romania and
the European Union
the bidders are given 3 to 6 months to submit a bid
a bid must include the works programme, and demonstrate the technical and
financial capability of the bidder
evaluation of the bids is set for 15 to 30 days
the winning bidders enter into negotiations of the petroleum agreement with
the National Agency for Mineral Resources
the petroleum agreement is signed by National Agency for Mineral Resources
and approved by the Government
Liabilities and Indemnities
Under the Polish Geological and Mining Act 2011:
the licensee is liable for any damages incurred by third parties, damages
caused to land and water, unless it can prove that the damages have been
caused by some other entity
the State Treasury can be ultimately liable
there is a statutory joint liability of the licensee and other entities engaged in
the operations
there is no statutory cap on liability
Under the Romanian Petroleum Act 2004, there is no special regime for liabilities
and indemnities resulting out of the petroleum operations; inherently, the provisions
of the Romanian Civil Code on tort and contractual liability become applicable.
Similarly as in Poland, there is no statutory cap on liability.
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INFORMATION PURPOSES ONLY, ARE NOT INTENDED TO CONSTITUTE LEGAL OR OTHER PROFESSIONAL ADVICE, AND SHOULD NOT BE RELIED ON OR TREATED AS A
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Royalties
In Poland, there is no special regime for royalties on shale gas production under the
current legislation. For exploration, there is a one-time concession fee of PLN 218
for each square kilometre of the licensed blocks. For production, the fees are
structured as follows:
high-methane gas: (PLN 6.06 for each1,000 cubic metres) X quantity of fossil
exploited during a six month period
other gas: (PLN 5.04 for each 1,000 cubic metres X quantity of fossil exploited
during a six month period
Romania too has no specific royalties’ regime applicable only to shale gas. The
general royalties’ regime in Romania is linked to the gross value of the production:
3.5% - below 10 million cubic metres
7.5% - between 10 million cubic metres – 50 million cubic metres3
9% - between 50 million cubic metres – 200cubic metres
13% - more than 200 million cubic metres
Decommissioning
In both Poland and in Romania, the decommissioning plan must be approved by the
regulatory authority.
In Poland, the decommissioning fee is set to 3% of the depreciation allowance for
the fixed assets and is deposited into a ring-fenced bank account.
In Romania, there is no statutory level set for the decommissioning fee, but simply
a duty to book a provision throughout the entire term of the concession.
Environment
Both Poland and Romania have by and large transposed the set of directives that
have been identified by the Commission’s report as applicable for shale gas
exploration and production.
What’s next?
In 2013, Poland published a Bill to Amend the Geological and Mining Act (draft of 12
June 2013) and a Bill on Hydrocarbon Taxation (draft of 12 June 2013) that are
meant to address the main issues identified so far as a gap in the existing
legislation to appropriately cater for shale gas exploration and production. Some of
the relevant provisions of these bills, which may be still be subject to further
amendments prior to their adoption by the Polish Parliament, are summarized
below.
Bill to Amend the Geological and Mining Act
no need to obtain a concession for prospecting
proposed new term for the duration of the concession: 10 to 30 years
(currently concessions are granted for a period of 3 to 50 years)
new and more transparent tender procedure consisting of three phases: (i)
qualification, (ii) tender, and (iii) conclusion of a joint operating agreement
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new every week
bidding round tender to be initiated also by the interested party
the joint operating agreement will be concluded with newly established state-
owned joint stock company – Narodowy Operator Kopalin Enrgetycznych Spółka
Akcyjna (National Operator of the Energy Fossils - NOKE S.A.)
investment decision for moving on from the exploration to the production phase
Farm-out is permitted and the bill expressly provides for this option.
The Bill to Amend the Geological and Mining Act has been under public consultation
over the past few months. On 18 June 2013, the bill was submitted for debate and
approval to the Polish Parliament, where it is currently subject to legislative works.
It is difficult to estimate when the final version will be adopted.
Bill on Hydrocarbon Taxation
Production:
o high-methane gas: (PLN 24 per 1,000 cubic metres) X quantity of
fossil exploited during half-year period
o other gas: (PLN 20 per 1,000 cubic metres m3) X quantity of fossil
exploited during half-year period
Additional tax of:
o 0% if ratio of income to qualified expenditures is lower than 1.5 , or
o if ratio of income to qualified expenditures is at least 1.5 but lower
than 2, the tax is calculated according to the following formula:
(25 X ratio of income to qualified expenditures - 25) / 100, or
o 25% if the ratio of income to qualified expenditures is at least 2.
i
Daniel Howard Yergin is a Pulitzer Prize winning American author, speaker, and economic researcher. Yergin is the co-founder and chairman
of Cambridge Energy Research Associates, an energy research consultancy that is now part of IHS Inc. He is best known as author of The Prize:
The Epic Quest for Oil, Money, and Power and The Quest: Energy, Security, and the Remaking of the Modern World.
ii
McKinsey Global Institute, Game Changers: Five opportunities for US growth and renewal
iii
The full content of the studies can be accessed at this link: http://ec.europa.eu/environment/integration/energy/uff_studies_en.htm
iv
The full content of the results of the public consultation and a recording of the stakeholders conference of June 2013 can be accessed by fol-
lowing this link: http://ec.europa.eu/environment/integration/energy/uff_event_7june2013_en.htm
v
According to a United States Energy Information Administration study, carried out without exploratory drilling, it is estimated that France has technically recover-
able reserves of 3.8 trillion cubic metres