ANP concludes analysis of the exemption request of the Libra consortium

Updated: Wednesday, October 04, 2017, 12:25 PM

The ANP analysis was completed for the Libra Consortium’s request for exemption from compliance with Local Content for the items and sub-items related to the UEP subsite of the Libra Pilot project.

The request was based on the contractual forecast of excessive price, set forth in Clause 25.8 of the Production Sharing Contract (CPP). It also addressed the lack of a supplier capable of meeting the local content commitments of the CPP, as well as the inability of local suppliers to meet the oil extraction schedule by 2020.

The decision of the ANP board was:

1) Rejection of the exemption request for the commitment items prohibited by the Sharing Agreement: Basic Engineering and Detail Engineering;

2) Maintenance of the minimum local content commitments of the CPP for the following identified items:

     Minimum Commitments – CPP
 Plants  Field instrumentation 40%
 Filters 80%
 Screw Compressors 70%
Installation and Integration of Modules  Business Management 80%
 Marine means 10%
Anchoring  Pre-installation and hook-up of lines  40%
 Anchoring system  85%


3) Approval of the exemption request for the items indicated below:

  Hull  Business Management
 Construction and assembly
 Systems and equipment
 Marine systems
Plants  Tanks
 Turbine and gas


4) Adjustment in the minimum compromise of Local Content for the items in which it was verified that there is no qualification in the justifying cases for granting exemption, indicated below:

     ANP Recommendation
    Plants  Business Management 75%
 Construction and assembly 52%
 Systems and equipment 24%
 Pressure vessel 44%
 Valves (up to 24 “) 35%
Pumps 44%
Automation system 19%
 Fiscal measurement system 57%
 Electrical system 23%
Heat exchanger 35%
Materials 51%
   Installation and integration of modules  Construction and assembly 48%
 Commissioning 48%
 Materials 51%


5) Rejection of the request to extend the effects of the exemption granted in the global local content, according to the prohibition expressed in clause 25.8.1 of the Production Sharing Contract; and

6) Impossibility of extension of the effects of the authorized adjustment in the global local content, according to the prohibition expressed in clause 25.9.2 of the Production Sharing Contract.

The Board’s decision has already been communicated to the Libra Consortium Operator, and must be submitted to judicial review, as determined by the Federal Regional Court of the First Region in the Declaratory Action of Invalidity proposed by Sinaval.

The request was submitted to the public consultation, open 09/02/2017, in order to collect comments and the public hearing was held on 04/18/2017.


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