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The suspension of the environmental permit entails an indispensable stop of production at Tengiz, Kashagan and Karachaganak fields

On September 14, 2021, the 37th meeting of the Oil and Gas Industry Committee of the Presidium of the National Chamber of Entrepreneurs of the Republic of Kazakhstan "Atameken" was held.

The participants of the meeting debriefed a report on the execution of instructions given at previous meetings of the Committee. The Executive Director of Kazenergy Association Zangar Nogaybay told about the ongoing work on amendments and additions to the Tax Code of the Republic of Kazakhstan, about the progress of work on the exchange trade in petroleum products, as well as about the current status of issues under the Environmental Code.

Deputy Managing Director of NCOC Yermek Marabayev told about the issues of applying the suspension of the environmental permit as a sanction of the Code of Administrative Offences.
From July 1, 2021 entered in the actions of the addition to article 328 of the Code of Administrative Offences of the stricter accountability for the systematic (more than twice) during the year exceeded the emission standards (emissions and discharges of POLLUTANTS), implementation of emissions from sources not specified in the environmental permit, or the excess of the emission standards two times lasting more than three hours straight, through the use of high penalty (20 000% of the appropriate rate in respect exceeded the number of POLLUTANTS) with a simultaneous suspension of an environmental permit for the operation of the respective source of emission or production of the site. Although the specified administrative offense is considered by the court, the issue of suspending the environmental permit is not at the discretion of the court, since the applied sanction is not an alternative.
Yermek Marabayev expressed concern that the suspension of the environmental permit entails an indispensable shutdown of production at Tengiz, Kashagan and Karachaganak fields. Consequently, this will lead to significant socio-economic consequences at any of the enterprise facilities.
The Chairman of the Committee, Daniyar Abulgazin, instructed to organize a meeting with all interested parties on this issue and prepare proposals to the Government of the Republic of Kazakhstan.

Bolat Auetayev, General Director of the Kazakhstan Fuel Association, spoke about equipping oil depots with control devices for accounting and charging a subscription fee for data transmission from the CMD to NIT JSC.
Currently, the State Revenue Committee of the Ministry of Finance of the Republic of Kazakhstan is once again initiating a pilot project to install a CMD at oil depots. The main problem for the owners of oil depots is the purchase of appropriate equipment, due to its high cost. Work on this issue is carried out both within the framework of the NCE RK Atameken and KAZENERGY Association, and within the framework of the activities of the working bodies of the departments.
Daniyar Tiesov, Deputy Chairman of the Oil Refining and Marketing Board of NC KazMunayGas JSC, noted the importance of introducing control metering devices at oil depots to ensure transparency of the functioning of the oil products market. The work will be continued by KAZENERGY Association together with the SRC of the Ministry of Finance of the Republic of Kazakhstan, the Ministry of Finance of the Republic of Kazakhstan and market participants for further appeal to the Government of the Republic of Kazakhstan.

The Deputy Chairman of the Management Board for the Corporate Center of Kazakhstan Petrochemical Industries LLP told about the need to include in the Resolution of the Government of the Republic of Kazakhstan dated 28.12.2015 No. 1095 "On approval of the list of activities..." such activities as production and wholesale of plastics in primary forms.
By section 5 of the Decree of the Government of the Republic of Kazakhstan dated December 28, 2015 No. 1095, these types of activities were not included in the CCЕA. In this regard, a proposal was voiced to contact the authorized state bodies to resolve this issue.
Following the meeting, the participants of the meeting discussed general conclusions and made recommendations for the implementation of the proposals.

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