Subject: File No. s7-29-07
From: Geoff Zakaib, P.Eng., MBA
Affiliation: President, Zakaib Strategies inc. (ZSi)

February 15, 2008

Comments on File No. S7-29-07

Concept Release on Possible Revisions to the Disclosure Requirements Relating to Oil and Gas Reserves

I would like to express my strong support for revisions to the disclosure requirements relating to oil and gas reserves. Adoption of the SPE Petroleum Resources Management System (PRMS) would serve to move the SEC and the industry as a whole towards the ultimate goal of being able to utilize a common global reserves and resources classification framework.

In these comments I will address a number of points concerning the use of XBRL (eXtensible Business Reporting Language see www.xbrl.org). XBRL is a data-tagging technology that I believe holds the key to successful implementation of the PRMS for the purpose of disclosure.

1. XBRL data tags have been developed for the US GAAP taxonomy as supported by the SEC (see http://www.sec.gov/news/press/2007/2007-253.htm). The tags used in the Extractive Industries Disclosures (see attached spreadsheet) reflect current SEC reporting requirements.

2. The outcome of the SEC Concept Release on Possible Revisions to the Disclosure Requirements Relating to Oil and Gas Reserves will hopefully be the extension of current reporting requirements through the adoption of a reserves and resources classification framework such as PRMS. It is therefore important that the XBRL data tags and taxonomy architecture used in the US GAAP taxonomy be reviewed to ensure that that these types of extensions could be made in the future without significant difficulty or confusion. The oil and gas industry should collaborate on performing this review and results should be fed into the public comment process on the US GAAP Taxonomy that ends April 4, 2008.

3. Reserve reporting frameworks and jurisdictional requirements are evolving towards a global standard. This holds the promise of international comparability of reserve reports from different companies and countries. But this comparability will only be efficient and effective if the XBRL data tags used by all parties conform to a standard reserves and resources taxonomy (i.e. only one specific tag is used for each category of reserves and resources). With this future in mind, various regulators that are developing taxonomies (i.e. SEC for US GAAP) should cooperate and collaborate with other jurisdictional standard setters (i.e. International Accounting Standards Board for IFRS) and industry groups / initiatives (i.e. SPE Oil and Gas Reserves Committee, Committee for Mineral Reserves International Reporting Standards, United Nations Economic Commission for Europe Framework Classification) to move towards convergence of the various existing frameworks and to establish a standard XBRL reserves and resources taxonomy.

To participate in this compelling future vision, the SEC should take the important first step of revising disclosure requirements for oil and gas reserves to authorize the use of PRMS.

Geoff Zakaib, P.Eng., MBA
President, Zakaib Strategies inc. (ZSi)
Calgary, Alberta, Canada