0000314590-16-000039.txt : 20161110
0000314590-16-000039.hdr.sgml : 20161110
20160927113249
ACCESSION NUMBER: 0000314590-16-000039
CONFORMED SUBMISSION TYPE: CORRESP
PUBLIC DOCUMENT COUNT: 2
FILED AS OF DATE: 20160927
FILER:
COMPANY DATA:
COMPANY CONFORMED NAME: SASOL LTD
CENTRAL INDEX KEY: 0000314590
STANDARD INDUSTRIAL CLASSIFICATION: CRUDE PETROLEUM & NATURAL GAS [1311]
IRS NUMBER: 000000000
STATE OF INCORPORATION: T3
FISCAL YEAR END: 0630
FILING VALUES:
FORM TYPE: CORRESP
BUSINESS ADDRESS:
STREET 1: 1 STURDEE AVE
STREET 2: ROSEBANK
CITY: JOHANNESBURG
STATE: T3
ZIP: 2196
BUSINESS PHONE: 01127114413111
MAIL ADDRESS:
STREET 1: P O BOX 5486
CITY: JOHANNESBURG
STATE: T3
ZIP: 99999
FORMER COMPANY:
FORMER CONFORMED NAME: SASOL LTD/ADR/
DATE OF NAME CHANGE: 20000101
CORRESP
1
filename1.txt
8 September 2016
Mr Brad Skinner
Senior Assistant Chief Accountant
Office of Natural Resources
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 30 June 2015
Filed 9 October 2015
File No. 1-31615
We refer to the further comment letter, dated 30 August 2016, from the
staff of the Office of Natural Resources (the "Staff") continuing
correspondence relating to the Form 20-F (the "Filing") of
Sasol Limited (the "Company") for the year ended 30 June 2015. Set forth
below are the responses to the Staff's further comment letter, which have
been provided in each case following the text of the comment in the
Staff's letter.
Standardized Measure of Discounted Future net Cash Flows Relating to Proved
Reserves, page G-9
1. Based on your response to comment one, it appears that the contracted
transportation capacity reservation costs must be incurred in order to
deliver your produced sales gas to market. Given this, it appears that the
portion of those costs incurred over the forecast life of your proved
reserves should be considered in determining the economic producibility of
those reserves. To the extent that the revenue from your proved reserves
does not offset the costs of operation, including applicable transportation
costs, the quantities would not be considered economically producible and
should not be reported as proved reserves.
Response
We agree with the Staff's observation that transportation costs must be
incurred in order to deliver produced sales gas to market.
The Company would like to advise that Canada reserves represent 1,6% of
Sasol's Proved Reserves as at 30 June 2015.
Of the R 1 672,9 million future cost included in the Filing, only
R 166,6 million is actually required to transport the produced sales
gas to market; the remaining cost represents unused capacity which the
Company markets on an ad hoc basis. Although such marketing has been
successful in the past no future revenue from this marketing is included
in the calculation of the standardized measure of discounted future
net cash flows.
The Company has reviewed its calculation of proved reserves for financial
year 2015 by adjusting future net cash flows used to determine economic
producibility to include that portion of the transportation capacity
reservation cost which is actually required to transport the produced sales
gas to market (the "applicable transportation costs"). The effect of this
change is to reduce the period of economic production by a maximum of one
year, with a resulting small reduction in the proved reserves. The 2015
proved reserves are consequently reduced from 116,8 billion cubic feet to
115,1 billion cubic feet. This reduction represent a 0,02% change in
Sasol's Proved Reserves as at 30 June 2015. The impact on the financial
results of the Company is also considered immaterial (depreciation would
have been R6 million higher which represents a 0,04% change in Sasol's
total depreciation for the period ending 30 June 2015).
Proved reserves for financial year 2013 and 2014 were estimated with
applicable transportation costs included in the calculation to determine
the period of economic production. There is therefore no revision or impact
on the 2013 and 2014 reserves as reported.
In all future filings, beginning with the annual report on Form 20-F for
the year ended 30 June 2016, the Company will ensure reserves are determined
with applicable transportation costs included in the calculation to determine
the period of economic production.
2. Please expand your disclosure to provide an explanation for the negative
undiscounted future net cash flows relating to proved reserves for Canada
and Gabon. Refer to FASB ASC 932-235-50-36.
Response
The Company has referred to the disclosure requirements under FASB ASC
932-235-50-36 and acknowledges the Staff's comment.
The Company has considered the impact of unutilised transportation cost on
the standardized measure of discounted future net cash flows. The Company
believes that including these costs in the standardized measure presented
in the Filing, combined with a suitable narrative, provides a fair
presentation to the user of the Form 20-F.
In all future filings, beginning with the annual report on Form 20-F for
the year ended 30 June 2016, the Company will revise the disclosure to
provide a narrative explanation for any negative undiscounted future net
cash flows relating to proved reserves.
Illustrative disclosure based on the Filing
The undiscounted future net cash flows for Canada in 2013, 2014 and 2015
and for Gabon in 2015 are negative as a result of future production and
development costs, primarily contractually committed costs and asset
retirement costs which are not directly related to future production or
dependent upon the continuation of production and will be incurred even in
the event of no future production. For both assets these costs are fully
responsible for the negative future cash flow.
In Canada, the cost of unused gas transportation capacity is included which
the Company markets on an ad hoc basis. Although such marketing has been
successful in the past no future revenue from this marketing is included
in the calculation of the standardized measure of discounted future
net cash flows.
We acknowledge that:
* The Company is responsible for the adequacy and accuracy of the
disclosure in the filing;
* Staff comments or changes to disclosure in response to Staff comments do
not foreclose the Commission from taking any action with respect to the filing;
and
* The Company may not assert Staff comments as a defence in any proceeding
initiated by the Commission or any person under the federal securities laws of
the United States.
We appreciate the Staff's review of Filing. Should the Staff have any
questions or require any additional information, please telephone the
undersigned at +27-11-441-3422. My email address is
Bongani.Nqwababa@sasol.com.
Yours faithfully
/s/ Bongani Nqwababa
Bongani Nqwababa
Chief Financial Officer
DRAFT 8 September 2016
CORRESP
2
filename2.txt
6 September 2016
Mr Brad Skinner
Senior Assistant Chief Accountant
Office of Natural Resources
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 30 June 2015
Filed 9 October 2015
File No. 1-31615
We refer to the further comment letter, dated 30 August 2016, from the
staff of the Office of Natural Resources (the "Staff") continuing
correspondence relating to the Form 20-F (the "Filing") of Sasol Limited
(the "Company") for the year ended 30 June 2015. Set forth below are the
responses to the Staff's further comment letter, which have been provided
in each case following the text of the comment in the Staff's letter.
Standardized Measure of Discounted Future net Cash Flows Relating to
Proved Reserves, page G-9
1. Based on your response to comment one, it appears that the contracted
transportation capacity reservation costs must be incurred in order to
deliver your produced sales gas to market. Given this, it appears that
the portion of those costs incurred over the forecast life of your proved
reserves should be considered in determining the economic producibility of
those reserves. To the extent that the revenue from your proved reserves
does not offset the costs of operation, including applicable transportation
costs, the quantities would not be considered economically producible and
should not be reported as proved reserves.
Response
We agree with the Staff's observation that transportation costs must be
incurred in order to deliver produced sales gas to market. Of the
R 1 672,9 million future cost included in the Filing, only R 166,6 million
is actually required to transport the produced sales gas to market; the
remaining cost represents unused capacity which the Company markets on an
ad hoc basis. Although such marketing has been successful in the past no
future revenue from this marketing is included in the calculation of the
standardized measure of discounted future net cash flows.
The Company has reviewed its calculation of the standardized measure of
discounted future net cash flows to include that portion of the
transportation capacity reservation cost which is actually required to
transport the produced sales gas to market (the "applicable
transportation costs"). As mentioned above, this represents only some 10%
of the total reservation cost with the result that the limit of economic
producibility is reached in 2031 (rather than 2032 as incorporated in the
Filing); the proved reserves are thereby reduced from 116,8 billion cubic
feet to 115,1 billion cubic feet.
2. Please expand your disclosure to provide an explanation for the negative
undiscounted future net cash flows relating to proved reserves for Canada
and Gabon. Refer to FASB ASC 932-235-50-36.
Response
The Company has referred to the disclosure requirements under FASB ASC
932-235-50-36 and acknowledges the Staff's comment.
The table below compares the standardized measure of discounted future net
cash flows for 2015 from the Filing, with additional cost detail, with
alternative presentations.
Millions of Rand The Filing Alternatives
Exclude ARC +Exclude UTC
Future cash inflows 3 908.1 3 908.1 3 908.1
Future production costs
Transportation capacity
reservation cost - utilised -166.6 -166.6 -166.6
Transportation capacity
reservation cost - not utilised -1 506.3 -1506.3
Other -1 449.7 -1449.7 -1 449.7
Future development costs
Asset retirement costs -1 199.6
Other -630.8 -630.8 -630.8
Future income taxes 0.0 0.0 0.0
Undiscounted future net
cash flows -1 044.9 154.7 1 661.0
The first alternative presentation excludes the asset retirement costs and
the second additionally excludes the reservation costs associated with the
unutilised transportation capacity. The Company submits that the standardized
measure of discounted future net cash flows presented in the Filing gives a
more complete picture than either of the alternatives which exclude various
costs which will be incurred in future but which are not included in
assessing economic producibility, as discussed above.
In all future filings, beginning with the annual report on Form 20-F for the
year ended 30 June 2016, the Company will revise the disclosure to provide a
narrative explanation for any negative undiscounted future net cash flows
relating to proved reserves.
Illustrative disclosure based on the Filing
The undiscounted future net cash flows for Canada in 2013, 2014 and 2015 and
for Gabon in 2015 are negative as a result of future production and development
costs, including asset retirement costs, which are not dependent upon the
continuation of production and will be incurred even in the event of no future
production. For both assets these costs are fully responsible for the negative
future cash flow.
We acknowledge that:
* The Company is responsible for the adequacy and accuracy of the disclosure in
the filing;
* Staff comments or changes to disclosure in response to Staff comments do not
foreclose the Commission from taking any action with respect to the filing; and
* The Company may not assert Staff comments as a defence in any proceeding
initiated by the Commission or any person under the federal securities laws of
the United States.
We appreciate the Staff's review of Filing. Should the Staff have any questions
or require any additional information, please telephone the undersigned at
+27-11-441-3422. My email address is Bongani.Nqwababa@sasol.com.
Yours faithfully
/s/ Bongani Nqwababa
Bongani Nqwababa
Chief Financial Officer
DRAFT 6 September 2016