POTENTIAL PETROLEUM

REVENUES FOR THE

GOVERNMENT OF KENYA

Implications Of The Proposed 2015 Model

Production Sharing Contract

Don Hubert, PhD!!

Resources!for!Development!Consulting!
March 2016

www.oxfam.org
Oxfam Research Reports are written to share research results, to contribute to public
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For more information on this report, email the Tax Justice Programme Manager on
[email protected],uk

Oxfam International May 2016.

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TABLE OF CONTENTS

SUMMARY ............................................................................................................. 4

CONTEXT ............................................................................................................... 5

ALLOCATING PROFIT OIL......................................................................................... 6

ASSESSING CORPORATE INCOME TAX ...................................................................... 8

FINANCING COSTS.................................................................................................. 9

COMPARATIVE ECONOMIC ANALYSIS ..................................................................... 10

CONCLUSION ....................................................................................................... 13

NOTES ................................................................................................................ 15

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SUMMARY!!
The Petroleum (Exploration, Development and Production) Bill, 2015 and associated
model production sharing contract (PSC) are currently in the final stages of
Parliamentary review. The development of a new regulatory framework for the petroleum
sector was driven by the need to modernize a regime that was first established in 1986
and to take into account recent discoveries of both oil and natural gas.
Of the changes proposed in the 2015 Bill and model PSC, the focus of this analysis is on
the fiscal terms; that is the sources of Government revenue and the specific terms
applicable to them. The new fiscal system that would apply to PSCs negotiated in the
future will be significantly different than the one that applies to all existing PSCs,
including those for the promising blocks in the Turkana region.
Attention is given to the three main differences between the existing and future fiscal
terms. First, the 2015 model PSC proposes to replace the existing approach to the
sharing of profit petroleum from one based on the daily rate of production (DROP)
combined with a windfall profits tax imposed when oil prices are higher, to one based on
a measure of profitability (r-factor). Second, under the 2015 model PSC, corporate
income tax would become tax paid by the company rather than paid out of the
governments share of profit oil. Third, the 2015 model PSC changes a significant
investment incentive by replacing the cost recoverability of interest on debt incurred for
development costs with a 15% uplift on development spending.
As it is difficult to comprehend the significance of the proposed changes in the abstract,
both sets of terms are applied to a potential oil project based on public domain data for
Blocks 10BB and 13T in the South Lokichar region. It is important to note that past PSCs
contain stabilization clauses and as such there is no suggestion that the 2015 terms
would be applicable to the Turkana project. The objective of applying the 2008 and 2015
terms to this hypothetical oil project is to allow for a direct comparison of project
economics and potential government revenue under varying scenarios of production,
price and costs.
Two clear conclusions emerge. The adoption of the R-factor and the development cost
uplift are both consistent with best practice and provide modest economic benefits for
the government. The adoption of an R-factor profit split as set out in the 2015 model
contract generates some additional revenue for the government and is economically
more efficient than the combination of the DROP profit split combined with the windfall
tax. Similarly, the development cost uplift generates some additional revenue and closes
significant potential loopholes.
In contrast, the shift from a deemed corporate income tax to one actually paid by the
company has a profound effect on project economics and the proportion of revenue that
would flow to the government. The inclusion of a paid income tax increases the
government by roughly 10%. It could add billions of dollars to government coffers over
the lifecycle of a project. The additional revenue however also constitutes a significant
extra burden on the contractor.
Following successful oil discoveries, countries often tighten fiscal terms for future
contracts. The change from a deemed to a paid corporate income tax may be appropriate
in light of the Turkana oil finds. But it is a choice that should be made deliberately, with
full awareness of the significant change that it represents to the Kenyas petroleum
fiscal regime.

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CONTEXT! !

Traditional analyses of petroleum regimes draw a sharp distinction between three

different fiscal systems: royalty and tax (concession), production sharing and service
agreements.1 In a royalty and tax system, the company takes ownership of the
petroleum as it reaches the surface with the government securing its revenue through
royalty payments and the assessment of various taxes. In the production sharing
system, the company takes ownership of petroleum only at the delivery point with the
government being allocated a share of after-cost petroleum production. Under a
service contract, the contractor never acquires the title to the resource and is simply
paid a fixed or variable fee for oil production services. Table 1 shows the regional
distribution of these three main systems.2
Over time the
distinctions between Table&1:&Overview&of&Fiscal&Systems&
these types of
agreements have
blurred and so-called
hybrid models
(adding royalties and
income tax to a
production-sharing
system) are now also
common, having
been adopted in
neighbouring
countries including
Uganda, Tanzania
and Mozambique. !
Governments can
ensure that they secure a fair share of the overall revenues independent of the model
chosen. It is the combination of fiscal terms within the system, rather than the system
itself, which determine whether the government has negotiated a good deal.3 The
challenge facing governments, of course, is to offer terms that encourage companies to
explore for oil while at the same time seeking to maximize government revenues should
those exploration efforts be successful.
The Petroleum Exploration and Production Act of 1986 (Chapter 308, Revised Edition
2012) currently governs exploration and production in Kenyas petroleum sector. As is
the case in many developing countries, Kenya has selected to operate a production
sharing system where a private oil company is responsible for oil exploration and
production and the government receives a proportion of oil produced after costs have
been paid.
The specific fiscal terms are set out in a production sharing contract or PSC. The PSC
governs the full lifecycle of the oil project. It gives the company the right to explore for
oil within a specific area, and, if exploration efforts are successful, it also sets the terms
for 25 years of production.
As is common, model production sharing contracts were published in 1986, 1999 and
2008. These template documents provide standardized language for the majority of the
contract while leaving only a few key provisions open for negotiation. The basis for this

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analysis then is a comparison of the fiscal terms set out in the 2008 model PSC and the
proposed 2015 model PSC.
In keeping with good practice in the sector, Kenya is moving towards establishing most
of the terms governing petroleum operations in the law and the model contract, leaving
only a few key elements for project-by-project negotiations. The 2015 model PSC
therefore describes not only the fiscal instruments that generate government revenue;
it also contains the specific terms necessary for an economic analysis.
The 2008 model contract also sets out the fiscal instruments that generate government
revenue but important negotiable elements were left blank. Unfortunately, most Kenyan
production sharing contracts contain confidentiality clauses and the government has
yet to put them in the public domain. Fortunately, international oil companies have
disclosed a number of full PSCs to their investors (Blocks 1, 2B, 11A, L1B, L16, L27, and
L28), while others have disclosed a summary of the core fiscal terms (Blocks 9, 10A,
10BA, 11A, and 12B). A review of these published terms suggest that there is relatively
little variation between them. The analysis below is based on the terms applicable for
Block 10A.
Three main differences between the 2008 and 2015 fiscal regimes are analyzed below,
including:4
1. The replacement of a daily rate of production allocation of profit oil combined
with a windfall tax with a r-factor allocation of profit oil in the 2015 fiscal regime;
2. The replacement of a deemed corporate income tax paid out of the
governments share of profit oil with a corporate income tax paid by the
company; and,
3. The replacement of the investment incentive allowing for the cost-recoverability
of interests on company borrowing, to a 15% capital investment uplift for five
years following an approved development plan.

ALLOCATING PROFIT OIL

The fiscal system set out in the 2008 model PSC would be considered, in most respects,
a classic production sharing system. The regime does not include either a royalty or
corporate income tax. The principal source of government revenue is the share of
petroleum production allocated to the government after costs have been paid. One
additional feature is the inclusion of a windfall tax imposed when oil prices exceed a
specified threshold.
The first significant difference between the 2008 and 2015 fiscal terms is the way in
which petroleum production is shared. As is the case in all production sharing systems,
oil is first allocated to allow the operator to recover its costs.5 Once this cost oil has
been allocated, the remaining profit oil is split on a sliding scale between the company
and the government.

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Under the terms of the 2008 model contract, profit oil is allocated based on the volume
of production. This traditional approach for allocating profit oil is commonly referred to
as daily-rate-of-production (DROP). The terms for Block 10A, for example, are set out in
Table!2. In this case, the
government would receive Table&2:&Profit&Oil&Split&&Block&10A!
55% of production for the
first 10,000 barrels of oil per
day (bopd), while the
company receives 45%. For
production exceeding
10,000 bopd up to 40,000
bopd, the split changes to
60% for the government and !
40% for the company.
One important objective of fiscal regime design is securing a higher proportion of after-
cost revenues for the government as profitability increases. While easy to administer,
this traditional sliding scale is based on volume of production has begun to fall out of
favour, as there is no necessary relationship between production volumes and
profitability. Small projects with low costs can generate high profits, while large projects
with high costs may not generate much profit at all.
The 2008 model contract however includes
a windfall tax specifically designed to Figure&1:&Windfall&Tax&at&$75/bbl!
capture additional revenue when the price
of oil rises. The windfall tax is assessed
against the company share of profit oil that
is generated from oil prices that exceed the
threshold price. There is some variation
among existing PSCs with the threshold
price ranging from $50 (as shown in Figure!
1) to $65 per barrel and the tax rate applied
on contractor profit oil above that threshold
ranging from 20% to 26%. Basing the
windfall tax on the price of oil gets closer to
targeting profitability, though once again
high cost projects may still not be highly !
profitable even when oil prices are high. The
Block 10A PSC sets the threshold price at $50 (inflated from the contract signing date)
and a tax rate of 20%.
Following advice from both the IMF and World Bank-funded consultants,6 the daily-rate-
of-production allocation of profit oil combined with the windfall tax are replaced in the
2015 model PSC with an allocation of profit oil based on a direct measure of profitability,
an R-factor. An R-factor is simply the ratio of total project revenues to total project
costs. As such, it can be considered a measure of payback. When the R-factor is less
than 1, total project costs exceed total project revenues. When the R-factor is greater
than 2, total project revenues would be more than double total project costs.

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 Figure&2:&2015&Profit&Oil&Allocation!

Profit oil under the 2015 model PSC would be allocated according to the terms set out in
Figure 2. Until total project revenues are greater than total project costs, the
government and contractor would each receive 50%. When total project revenues
exceed total project costs, 65% of profit oil would go to the government. Note that the
third tranche is indicative only and would be subject to contract-by-contract
negotiation.
By design, the R-factor system would allocate a higher proportion of profit oil to the
government as the project becomes more profitable. In this way, the r-factor approach
can replace both the DROP profit split and the windfall tax. It has also been suggested
that the R-factor approach would more easily accommodate higher-cost natural gas
projects.

ASSESSING CORPORATE INCOME TAX

The second main change between the 2008 and 2015 fiscal regimes relates to the
applicability of corporate income tax.
Some analyses of Kenyas petroleum fiscal system mistakenly identify corporate income
tax as an independent revenue stream for the government. If this were accurate, the
impact would be a 30% tax on company net income. However, the 2008 model PSC, as
well as the signed PSC in the public domain, are clear that corporate income tax is paid
on behalf of the company from the Governments share of profit oil.
According to Article 27(5) The portion of the Profit Oil or Profit Gas which the Government
is entitled to [] shall be inclusive of all taxes, present or future, based on income or
profits of the Contractor, including specifically tax payable under the Income Tax Act,
and dividend tax imposed by Kenya on any distribution of income or profits by the
Contractor (emphasis added). This means that the provisions of the Finance Act, and
specifically the Ninth Schedule on Taxation of Petroleum Companies, were relevant for
accounting procedures. Each year, companies are required to complete income tax
returns. But they do not actually pay the income tax as reported on these returns.
Instead, the tax is actually paid by the government from its share of profit oil.
While it might seem strange for the contractor not to actually pay its share of corporate
income tax, the provision is not uncommon and exists in order to allow international
companies to secure a tax credit in their home jurisdictions. In a production sharing
system, the profit oil share paid to the Government is not understood as a tax from the
perspective of other countries and is therefore not eligible for a tax credit. In order to
provide the company with an acceptable tax receipt, the Government pays corporate
income tax on behalf of the company out of its share of profit oil. The result is known as
a deemed tax that has no impact on company cash flow and generates no additional
government revenue.

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The approach to corporate income tax changes completely according to the terms of the
2015 model contract. In future PSCs, corporate income tax would be paid rather than
deemed. According to Article 39(3) It is understood and agreed that the portion of
each category of the Profit Petroleum which the Government is entitled to take and
receive for a given fiscal year, and which is calculated under clause 37 shall be
exclusive of all taxes payable by the contractor (emphasis added).
Under the terms of the 2015 model contract, the Finance Act, 2014 and the new Ninth
Schedule on Taxation of Extractive Industries would now be directly applicable to
upstream oil companies. The impact can be expected to be significant, as it will add a
30% tax on the contractors net income to be paid from the contractors share of profit
oil. In addition, companies would be subject to a dividend withholding tax of 10%.

FINANCING COSTS
It is common for oil companies to finance at least part of their operations through debt.
Interest on that debt is commonly accepted as an income tax deduction. There is
however significant potential for abuse (so-called thin capitalization), particularly for
intra-firm lending where one subsidiary of the company lends to another. In order to
avoid profit shifting where high levels the bulk of costs are financed through debt at
high interest rates, countries often put in place limits on both the ratio of company debt
to company equity in combination with limits on the rate of interest or withholding taxes.
In Kenya, for example, under the terms of the 2014 Ninth Schedule, the debt to equity
ratio cannot exceed 2:1 and a 15% withholding tax is imposed.
Within production sharing systems, it is relatively unusual for interest on contractor
debt to be allowed as a cost recoverable expense. This is a significant investment
incentive as it means the contractor would be repaid through cost oil for the interest
that they incur in borrowing for pay capital costs.
Both the 2008 model contract and the existing PSCs in the public domain provide for this
investment incentive. Specifically, the Accounting Procedures (Appendix B) state
Interest incurred on loans raised by the contractor for capital expenditure in petroleum
operations under the contract at rate not exceeding prevailing commercial rates may be
recoverable as petroleum costs. (Section 2.12.2)
As mentioned above, in order to avoid abuse, restrictions are needed on both the ratio of
debt (borrowed money) that can be used in comparison to equity (company cash) as well
as the rate of interest on the debt that can be claimed. In the case of the existing
Kenyan PSCs, there is no limit on the ratio of debt to equity, only the general restriction
that the interest cannot exceed prevailing commercial rates.
The 2015 model PSC changes the investment incentive for companies by removing the
cost recoverability of interest on borrowing and replacing it with a development cost
uplift. The idea of an uplift is that the government encourages investment by
allowing the company to recover an additional percentage of their capital expenditures.
Specifically, the 2015 model PSC states that An amount equal to fifteen percent (15%)
of the development costs shall be cost recoverable for five years following the approval
of a development plan. This means that the company recovers 115% of their
development costs over the first five years. For example, if capital costs in the first year
of the development plan were $200 million, the company would be allowed to recover not
only the $200 million that was spent but also an additional $30 million due to the uplift.
The provision then functions as an investment incentive, though in this case it is much

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less vulnerable to manipulation by the contractor that the recoverability of interest
costs

COMPARATIVE ECONOMIC ANALYSIS

The description above of the main fiscal changes proposed in the 2015 model PSC
provides only a very general sense of the actual implications for project economics and
potential government revenue. Applying the existing and proposed terms to a
hypothetical oil project can provide a more comprehensive understanding of the impact
of the proposed changes.
An economic model has been developed for Cordaid and the Kenya Civil Society Platform
on Oil and Gas (KCSPOG) in order to assess the potential government revenue from
Turkana oil under the terms disclosed for Block 10A . That model has been adapted in
order to compare the Block 10A terms as described above with those contained in the
2015 model contract.
It is important to note that there is no indication that the 2015 terms would ever be
applied to the Turkana projects. The contracts for Blocks 10BB and 13T contain
stabilizations clauses that provide for sanctity of the original fiscal terms in the signed
production sharing contracts.
The comparative analysis below is based on the following base case assumptions:
o 600 million barrels of recoverable oil;
o First oil production in 2021, production life of 20+ years;
o First phase peaks at 75,000 bopd; second phase peaks at 150,000 bopd;
o Brent crude oil price - $65 low price and $85 high price (with $10 discount);
o Costs are: exploration ($1.8b), development ($6/bbl), operating (6% of
development); pipeline tariff ($15.20);
o Existing fiscal terms based on Block 10A (60% cost recovery, interest costs
recoverable, DROP profit oil split starting at 55% for government; windfall tax
threshold of $50/bbl and tax rate of 20%; state participation at 20%); and,
o 2015 fiscal terms based on model PSC (60% cost recovery limit, 15%
development cost uplift, R-factor profit oil split starting at 50% for government,
paid corporate income tax; state participation at 20%).
The analysis below will first seek to assess the independent effects of the three main
fiscal changes outlined above. It will then combine the three changes to provide an
overall comparison of the 2008 and 2015 fiscal regimes.

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DROP v R-factor
The first change to assess is the difference between the DROP and R-factor allocation of
profit oil.7
For the base case as set out above, the revenue impact of this change is modest. For
the government, the 2015 R-factor generates marginally better results than the 2008
DROP. In terms of overall government take, the difference is about 2%, amounting to an
extra $500 million on total government revenues of about $13.5 billion over the lifecycle
of the project (See Figure!3).
At the higher price of
$85/bbl, the differences are Figure!3:!Comparing!DROP!and!R5Factor!
even smaller with the
government take differing by
less than 1%. The 2015
terms would generate an
additional $500 million for
the government over the
lifecycle of the project, but
in this case on total
revenues of about $24.5
billion.
There is a modest difference
in the timing of revenues
between the 2008 and 2015
terms. At both prices, the
DROP generates additional
government revenue in the !
first 5-6 years before
cumulative project costs are recovered and the R-factor moves into the second tranche.
The Turkana project used in this analysis can be considered a higher cost oil project due
to the substantial per barrel costs of the anticipated heated pipeline. Under lower-cost
high-price assumptions, the benefits to the government of the 2015 terms would
increase significantly as the split of profit gas would enter the third tranche.
The modest differences in
government revenue from the
Table&3:&Comparing&Tranche&Proportions&
change between the
combination of the DROP and
windfall tax to the R-factor are
reflected in the company
position as well. While the
overall revenues to the
government grow under the r-
factor, the timing changes help !
company economics and make
the difference between the two sets of terms even smaller.
The shift from the DROP to the R-factor as the mechanism for determining the sliding
scale share of profit oil to be split between the company and the government generates
the anticipated results. The company benefits from a larger portion of revenues in the
very early years of the project while the government share of divisible revenues grows as
the project becomes more profitable. The overall impact on the size of government

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revenues however is modest. The reason is that while the mechanisms for determining
movement through the sliding scale tranches has changed, the proportions allocated to
the company and the government within those tranches remains largely unchanged.
Under both the 2008 and 2015 model contracts, the percentage share allocated to the
government ranges from around 50% at the low end to around 75% at the high end.
Deemed v Paid Corporate Income Tax
While, the differences between the DROP combined with the windfall tax and the R-
factor are very modest, the differences between a paid rather than deemed income
tax are significant.
Under the base case assumptions, with an oil price of $65/bbl, the imposition of a 30%
corporate income tax results in a total government take of around 80%, an increase of
about 10% compared with the 2008 terms. Over the lifetime of the project, a paid
corporate income tax could be expected to generate roughly at least $2.5 billion dollars
in additional government revenue.
At higher prices, the imposition of corporate income tax continues to generate an
additional 10% in overall government take. As the project would generate greater profit
with higher prices, government revenues would increase by more than $3.5 billion over
the lifecycle of the project.
From the company perspective the difference between a deemed and a paid corporate
income tax is very significant. As there is relatively little difference in impact of the
production sharing splits between the 2008 and 2015 terms, the addition of a new
source of government revenue in the form of a paid corporate income tax results in a
significant reallocation of after-cost revenues.
Development Cost Uplift
Allowing interest to be cost recoverable under the terms of the 2008 model PSC is a
significant investment incentive. The provision allows for the company to recover the
costs in interest that it incurs in borrowing for capital expenditures. How significant
depends on the proportion of capital costs financed through debt as well as the interest
rate that would be applied.
Under the base case assumptions listed above, including a debt to equity ratio of 2:1
(66.6% of capital costs financed through debt) and a 10% rate of interest, the company
would be allowed to recover roughly $1.5 billion in interest costs. In terms of the impact
on government revenue, allowing interest to be cost recoverable would result in a
decrease over the lifecycle of the project of about $800 million.
Replacing cost recoverable interest with a 15% uplift on capital costs significantly
reduces the cost to government of this investment incentive. The 15% uplift adds only
about $600 million to cost recovery, less than half the amount that would be allowed
under the 2008 terms. The impact on government revenue is also much less. Adding the
15% uplift only costs the government about $250 million over the lifecycle of the project.
Clearly the 2015 terms are more favourable for the government. The amount of money at
stake is not particularly large, only about 0.5% of additional government take. But it is
important to note that this comparison almost certainly under-estimates the potential
benefits of restricting the recoverability of interest. Under the terms of the 2008 model
PSC, no limit was placed on the ratio of debt to equity. It is conceivable then that the
company could use debt to finance 80%, or even more, of their capital costs.
Furthermore, the rate of interest could well exceed 10%, with 12% being commonly used
in intra-firm financing in the extractive sector.8 In contrast, the uplift clearly defines the
economic benefit to the company and significantly limits the potential for abuse.

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CONCLUSION
The combined impact of the three main changes contained in the 2015 model PSC is a
significant increase in the percentage take flowing to the government. Under the base
case scenario government take climbs from just under 70% to more than 80%. The
difference in overall government revenue is shown below.

Potential!Government!Revenues!under!2008!/!2015!Fiscal!Terms!

The challenge in fiscal regime design is to find the appropriate balance between
attracting oil companies to undertake risky exploration while at the same time
maximizing the benefits that would accrue to government if the exploration were to be
successful.
The terms contained in the 2008 model PSC were based on a fiscal regime first designed
in 1980s. Those terms do not reflect existing best practice, particularly in linking the
profit split to production rather than profitability. When offered to international oil
companies, the terms contained in the existing PSCs were sufficiently attractive to
encourage significant, and in some cases successful, exploration. Africa Oil CEO Keith
Hill is reported to have said of Kenya: There are not many places left on earth where you
can put together an acreage portfolio like this ... Good contract terms, good support from
the government there are not that many happy hunting grounds left.9
It is widely accepted that frontier countries those without existing oil production or
any commercially viable discoveries must offer generous terms in order to attract
high-risk exploration. The question facing Kenya as it establishes new terms for future
production sharing contracts is whether, in the face of the discoveries in Turkana, the
government should be asking for a significantly larger share in future contracts.
Two of the main changes in the 2015 model contract the R-factor for splitting profit oil
and the development cost uplift are consistent with best practice and will contribute
to modest improvements in potential government oil revenue. The third change the

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shift from a deemed to a paid income tax is of a different order. It adds an entirely new
source of government revenue and has a major impact on project economics and
potential government revenue. The change from a deemed to a paid corporate income
tax may be appropriate in the current Kenyan context. But it is a choice that should be
made deliberately, with full awareness of the significant change that it represents to the
Kenyas petroleum fiscal regime.

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NOTES !
!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!
1
!See!Silvana!Tordo,!Fiscal!Systems!for!Hydrocarbons,!World!Bank,!2006.!!
2
!Daniel!Johnston,!reproduced!in!Marie!Wagner,!The!Law,!Science!and!Finance!of!
International!Energy!Projects,!Anadarko,!2013.!!
3
!Different!systems!do!expose!the!company!and!Government!differently!to!the!upsides!and!
downsides!of!a!project!in!terms!of!timing,!capital!cost,!production!rate!and!reserves.!
4
!As!there!are!no!significant!changes!in!the!right!of!the!state!either!directly!of!through!the!
National!Oil!Corporation!of!Kenya!(NOCK)!to!an!equity!stake!in!all!oil!projects,!this!additional!
source!of!government!revenue!is!not!included!in!this!analysis.!
5
!A!limit!is!often!imposed!on!the!total!proportion!of!oil!that!can!be!allocated!to!recover!costs.!
For!existing!Kenyan!PSCs,!this!limit!has!commonly!been!set!at!60%.!A!60%!cost!recovery!limit!
is!also!included!in!the!2015!model!PSC.!!
6
!See!Kenya!Oil!and!Gas!Sector!Development:!Final!Report!on!Contractual!and!Fiscal!
Guidance,!2013!p.!3_4;!and!Philip!Daniel,!Generating!Extractive!Industry!Revenues,!Nairobi,!
2013,!p.!12_13.!!!!!
7
!Note!that!the!base!case!assumptions,!with!an!oil!price!of!$65/bbl,!does!not!engage!the!
windfall!tax!because!of!the!discount!of!$10/bbl!for!oil!quality!and!the!inflation!index!applied!
to!the!threshold!price!from!the!contract!date.!!
8
!See!for!example:!Is!a!12%!interest!rate!by!Glencore!to!itself!in!Mauritania!normal?!
OpenOil,!2015.!!
9
!See!Luke!Patey,!Kenya:!An!Africa!oil!upstart!in!transition,!Oxford!Institute!for!Energy!
Studies,!2014,!p.!10.!!
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