Rebuilding Iraq: Serious Challenges Impair Efforts to Restore Iraq's Oil Sector and Enact Hydrocarbon Legislation
Published: 2007-07-18T00:00:00

Fast Facts:

Highlights:
section_title: Why GAO Did This Study
paragraphs: Rebuilding Iraq's oil sector is crucial to rebuilding Iraq's economy. For example, oil export revenues account for over half of Iraq's gross domestic product and over 90 percent of government revenues. This testimony addresses (1) the U.S. goals for Iraq's oil sector and progress in achieving these goals, (2) key challenges the U.S. government faces in helping Iraq restore its oil sector, and (3) efforts to enact and implement hydrocarbon legislation. This statement is based on our May 2007 report and updated data, where appropriate.
section_title: What GAO Found
paragraphs: Despite 4 years of effort and $2.7 billion in U.S. reconstruction funds, Iraqi oil output has consistently fallen below U.S. program goals. In addition, the State Department's data on Iraq's oil production may be overstated since data from the U.S. Department of Energy show lower production levels--between 100,000 and 300,000 barrels less per day. Inadequate metering, re-injection, corruption, theft, and sabotage account for the discrepancy, which amounts to about $1.8 to $5.5 billion per year. Comprehensive metering of Iraq's oil production has been a long-standing problem and continuing need. Poor security, corruption, and funding constraints continue to impede reconstruction of Iraq's oil sector. The deteriorating security environment places workers and infrastructure at risk while protection efforts have been insufficient. Widespread corruption and smuggling reduce oil revenues. Moreover, Iraq's needs are significant and future funding for the oil sector is uncertain as nearly 80 percent of U.S. funds for the oil sector have been spent. Iraq's contribution has been minimal with the government spending less than 3 percent of the $3.5 billion it approved for oil reconstruction projects in 2006. Iraq has yet to enact and implement hydrocarbon legislation that defines the distribution of oil revenues and the rights of foreign investors. Until this legislation is enacted and implemented, it will be difficult for Iraq to attract the billions of dollars in foreign investment it needs to modernize the sector. As of July 13, 2007, Iraq's cabinet has approved only one of four separate but interrelated pieces of legislation--a framework that establishes the structure, management, and oversight. Another part is in draft and two others are not yet drafted. Poor security, corruption, and the lack of national unity will likely impede the implementation of this legislation.

section_title: Letter
paragraphs: I am pleased to be here today to discuss U.S. efforts to rebuild Iraq’s oil  sector and Iraq’s efforts to enact hydrocarbon legislation.
The oil sector is critical to Iraq’s economy, accounting for over half of  Iraq’s gross domestic product and over 90 percent of its revenues. The  timely and equitable distribution of these revenues is essential to Iraq’s  ability to provide for its needs, including the reconstruction of a unified  Iraq.
The Iraqi government inherited oil infrastructure that was greatly  deteriorated due to the previous regime’s neglect; international sanctions;  and years of conflict, looting, and vandalism. For fiscal years 2003 through  2006, the U.S. government made available about $2.7 billion in  reconstruction funds to help restore Iraq’s crude oil production and  exports. The United States spent an additional $2.8 billion in Iraqi funds on  the oil sector through the end of 2005; however, these funds were used  primarily to purchase petroleum products because Iraq does not have  adequate domestic refining capability.
My testimony discusses (1) U.S. goals for Iraq’s oil sector and progress in  achieving these goals, (2) key challenges the U.S. government faces in  helping Iraq restore its oil sector, and (3) efforts to enact and implement  hydrocarbon legislation.
This statement is based on our May 2007 report and updated data, where  appropriate. To accomplish our report objectives, we reviewed and  analyzed U.S., Iraqi, donor government, United Nations (UN), International  Monetary Fund (IMF), and World Bank reports and data. During two trips  to Iraq and Jordan, we met with Iraqi, UN, IMF, World Bank, donor  country (Japan and European Union), private sector, and U.S. officials. We  also analyzed data on Iraqi oil production from the Department of State  and the Department of Energy’s Energy Information Administration (EIA).  This work was conducted in accordance with generally accepted  government auditing standards.
subsections: section_title: Background
paragraphs: Iraq’s oil infrastructure is an integrated network that includes crude oil  fields and wells, pipelines, pump stations, refineries, gas oil separation  plants, gas processing plants, export terminals, and ports (see fig. 1). This  infrastructure has deteriorated significantly over several decades due to  war damage; inadequate maintenance; and the limited availability of spare  parts, equipment, new technology, and financing. Considerable looting  after Operation Iraqi Freedom and continued attacks on crude and refined  product pipelines have contributed to Iraq’s reduced crude oil production  and export capacities.
Function is to refine crude  oil/gas mixture into usable  consumer products (fuel  oil, diesel, kerosene,  benzene, gasoline, LPG,  natural gas, etc.) metering stations and  transshipment facilities from  pipeline to ship for export   2 export terminals, both in    3 major refineries (Bayji in  south–Al Basrah Oil Terminal  and Khor al Amaya Oil  Terminal  plants of various sizes  and capacities (18 in  north and 34 in south) north, Daura in Baghdad,  and Basrah in south) and  14 smaller refineries      2 export pipelines, both in  north, to Turkey and Syria (gasoline, kerosene,  and other petroleum  products)
Iraq’s crude oil reserves, estimated at a total of 115 billion barrels, are the  third largest in the world. However, Iraq’s ability to extract these reserves  has varied widely over time and has been significantly affected by war.  Figure 2 shows Iraq’s daily average crude oil production levels annually  from 1970 through 2006.
Iraq’s crude oil production reached 3.5 mbpd, its highest annual average,  in 1979. In September 1980, Iraq invaded Iran and production levels  plummeted. Although the Iran-Iraq War continued until 1988, production  levels grew steadily after 1983, peaking at 2.9 million barrels per day in  1989. The Gulf War began the following year when Iraq invaded Kuwait. In  January 1991, the United States and coalition partners began a counter- offensive (Operation Desert Storm). Crude oil production once again  dropped precipitously and remained relatively low from 1990 to 1996,  while Iraq was under UN sanctions. Under the UN Oil for Food program,  Iraqi crude oil production began to rebound, peaking at an annual average  of 2.6 mbpd in 2000. In the 5 years preceding the 2003 U.S. invasion of Iraq,  crude oil production averaged 2.3 mbpd. In 2003, crude oil production  dropped again to a low of about 1.3 million barrels per day (annual  average) but then rebounded.
section_title: Iraq’s Oil Production Goals Have Not Been Met and Oil Production Figures May Be Overstated
paragraphs: Despite U.S. and Iraqi government efforts to reconstruct Iraq’s key  economic sector, oil production has consistently fallen below U.S.  program goals. In addition, production levels may be overstated and  measuring them precisely is challenging due to limited metering and poor  security. Comprehensive metering has been an outstanding goal of the  United States, the international community, and the Iraqi government.
subsections: section_title: U.S. Oil Goals Have Not Been Met
paragraphs: Key reconstruction goals for Iraq’s oil sector, including those for crude oil  production and exports, and refined fuel production capacity and stock  levels, have not been met. U.S. goals for the oil sector include reaching an  average crude oil production capacity of 3 million barrels per day (mbpd)  and crude oil export levels of 2.2 mbpd. However, in 2006, actual crude oil  production and exports averaged, respectively, about 2.1 mbpd and 1.5  mbpd. Figure 3 compares Iraq’s oil production and exports with U.S. goals  (the data for this figure are presented in appendix I). As the figure shows,  production and exports for the first five months of 2007 were still below  U.S. goals. In August 2003, the CPA established a U.S. program goal to  increase crude oil production to about 1.3 mbpd. The CPA increased this  goal every 2 to 3 months until July 2004, when the goal became to increase  crude oil production capacity to 3.0 mbpd.
Besides production and export of crude oil, the CPA also established goals  for the production of natural gas and liquefied petroleum gas (LPG), as  well as the national stocks of refined petroleum products (such as  gasoline) that are used to generate energy by consumers and businesses.  These CPA goals were to increase production capacity of natural gas to  800 million standard cubic feet per day (mscfd); increase production  capacity of LPG to 3,000 tons per day (tpd); and meet demand for benzene  (gasoline), diesel, kerosene, and LPG by building and maintaining their  stock levels at a 15-day supply.
However, the 2006 averages did not meet these goals. To increase the  stocks of petroleum products and their availability to consumers, Iraq  legalized the importation of petroleum products by private companies to  supplement its own production and state-owned company imports. For  2006, the IMF estimated that Iraq’s state-owned companies imported about  $2.6 billion of petroleum products. At the recommendation of the IMF, the  Iraqi government has been reducing subsidies for refined oil products,  which raises the prices consumers pay. In the past, refined oil products in  Iraq had been highly subsidized, which led to increased demand.  Reduction in domestic demand for refined oil products would allow  additional crude oil to be exported for revenue rather than refined in Iraq.
section_title: Iraq’s Crude Oil Production May Be Overstated
paragraphs: Iraq’s crude oil production statistics may be overstated. We compared the  State Department’s statistics to those published by the EIA, which are  based on alternate sources. Part of EIA’s mission is to produce and  disseminate statistics on worldwide energy production and use. While  these two data sets follow similar trend lines, EIA reports that Iraqi oil  production was about 100,000 to 300,000 barrels per day lower than the  amounts the State Department reported. At an average price of $50 per  barrel, this is a discrepancy of $5 million to $15 million per day, or $1.8  billion to $5.5 billion per year. Figure 4 shows these two data sets over the  time period (June 2003 to March 2007) for which data from both State and  EIA were available. The data for this figure are presented in appendix I.
According to EIA, several factors may account for the discrepancy. One  factor is the lack of storage facilities for crude oil in Iraq. Crude oil that  cannot be processed by refineries or exported is reinjected into the  ground. Another factor affecting the discrepancy may be differences in  the frequency and timing of the data. The State Department’s data are  reported daily in real time, while EIA produces monthly data that have  been reviewed and corroborated from several sources. This lag in  reporting and longer time period may allow analysts to address  inconsistencies such a double counting and reinjection. In addition, the  State Department regularly reports on sabotage and interdictions to crude  oil pipelines and other disruptions in the crude oil production process.  Also, under Saddam Hussein, Iraq had a history of diverting crude oil  production to circumvent UN sanctions. Therefore, it is possible that  corruption, theft, and sabotage may also be factors in the discrepancy.
section_title: Metering of Oil Production and Distribution Network Has Been a Long-standing but Unmet Goal
paragraphs: Reliable information on Iraqi’s oil production is further complicated by the  lack of metering. According to a State Department oil advisor, meters are  in place at many locations but are not usable in many instances due to the  difficulties in obtaining needed replacements and spare parts. Without  comprehensive metering, crude oil production must be estimated using  less precise means, such as estimating the flow through pipelines and  relying on reports from onsite personnel rather than an automated system  that could be verified.
An improved metering system has been a U.S. and international donor  priority since early 2004, but implementation has been delayed. In 1996,  the UN first cited the lack of oil metering when Iraq was under UN  sanctions. In 2004, the International Advisory and Monitoring Board  (IAMB) for the Development Fund for Iraq recommended the expeditious  installation of metering equipment. According to IAMB, in June 2004, the  CPA had approved a budget to replace, repair, and calibrate the metering  system on Iraq’s oil pipeline network. However, the oil metering contract  was not completed due to security and technical issues. In June 2006,  IAMB reported that the Iraqi government had entered into an agreement  with Shell Oil Company to serve as a consultant for the Ministry of Oil.  Shell would advise the ministry on the establishment of a system to  measure the flow of oil, gas, and related products within Iraq and in export  and import operations. The U.S. government is assisting in this effort by  rebuilding one component of the metering system in the Al-Basrah oil  port—Iraq’s major export terminal—and expects the project to be  complete in July 2007.
section_title: Security, Corruption, and Funding Challenges Hinder Reconstruction Efforts
paragraphs: The U.S. government and Iraq face several key challenges in improving  Iraq’s oil sector. First, the U.S. reconstruction program assumed a  permissive security environment that never materialized; the ensuing lack  of security resulted in project delays and increased costs. Second,  corruption and smuggling have diverted government revenues potentially  available for rebuilding efforts. Third, future funding needs for  reconstruction of Iraq’s oil sector are significant, but the source of these  funds is uncertain.
subsections: section_title: Poor Security Conditions Have Slowed Reconstruction and Increased Costs
paragraphs: The U.S. reconstruction effort was predicated on the assumption that a  permissive security environment would exist. However, since May 2003,  overall security conditions in Iraq have deteriorated and grown more  complex, as evidenced by the increased numbers of attacks (see fig. 5).  The average number of daily attacks in June 2007 was about the same level  as the prior high of about 180 attacks per day that occurred in October  2006 around the time of Ramadan. Overall, the average number of daily  attacks was about 50 percent higher in June 2007 than in June 2006.
The deteriorating security environment has led to project delays and  increased costs. Insurgents have destroyed key oil infrastructure,  threatened workers, compromised the transport of materials, and  hindered project completion and repairs by preventing access to work  sites. Moreover, looting and vandalism have continued since 2003. U.S.  officials reported that major oil pipelines in the north continue to be  sabotaged, shutting down oil exports and resulting in lost revenues. For  example, according to the Army Corps of Engineers, although eight gas oil  separation plants in northern Iraq have been refurbished, many are not  running due to interdictions on the Iraq-Turkey pipeline and new  stabilization plant. The Corps noted that if the lines and plant were in  operation today, an additional 500,000 barrels per day could be produced  in northern Iraq.
The U.S. government has developed a number of initiatives to protect the  oil infrastructure and transfer this responsibility to the Iraqi government.  Such efforts include fortifying the infrastructure and improving the  capabilities of rapid repair teams and protection security forces such as  the Oil Protection Force and the Strategic Infrastructure Battalions (SIB).  The U.S. government has paired these security forces with coalition  partners and has trained and equipped the SIBs. However, U.S. officials  stated that the capability and loyalty of some of these units are  questionable. According to Department of Defense (DOD) and Center for  Strategic and International Studies reports, these security forces have  been underpaid, underequipped, and poorly led, and are sometimes  suspected of being complicit in interdiction and smuggling. Additional  information on the nature and status of these efforts and the SIBs is  classified.
section_title: Corruption and Smuggling Reduce Oil Revenues
paragraphs: U.S. and international officials have noted that corruption in Iraq’s oil  sector is pervasive. In 2006, the World Bank and the Ministry of Oil’s  Inspector General estimated that millions of dollars of government  revenue are lost each year to oil smuggling or diversion of refined  products. According to State Department officials and reports, about 10  percent to 30 percent of refined fuels are diverted to the black market or  are smuggled out of Iraq and sold for a profit. According to State  Department reporting, Iraqi government officials may have profited from  these activities. The insurgency has been partly funded by corrupt  activities within Iraq and by skimming profits from black marketers,  according to U.S. embassy documents. According to a June 2007 DOD  report, a variety of criminal, insurgent, and militia groups engage in the  theft and illicit sale of oil to fund their activities. For example, DOD  reported that as much as 70 percent of the fuel processed at Bayji was lost  to the black market—possibly as much as $2 billion a year. As a result, the  Iraqi Army assumed control of the entire Bayji refinery, and equipment is  being installed to prevent siphoning.
One factor that had stimulated black market activities and fuel smuggling  to neighboring countries was Iraq’s low domestic fuel prices, which were  subsidized by the government. However, under the IMF’s Stand-by  Arrangement with Iraq, the government has already increased domestic  fuel prices several times, significantly reducing the subsidy for many fuel  products. The Iraqi government intends to continue the price increases  during 2007 and encourage private importation of fuels, which was  liberalized in 2006. The purpose is to decrease the incentive for black  market smuggling and to increase the availability of fuel products.
section_title: Future Funding Needs Are Significant but Funding Sources Are Uncertain
paragraphs: While billions have been provided to rebuild Iraq’s oil sector, Iraq’s future  needs are significant and sources of funding are uncertain. For fiscal years  2003 through 2006, the United States made available about $2.7 billion,  obligated about $2.6 billion, and spent about $2.1 billion to rebuild Iraq’s  oil sector. According to various estimates and officials, Iraq will need  billions of additional dollars to rebuild, maintain, and secure its oil sector.  Since the majority of U.S. funds have been spent, the Iraqi government and  international community represent important sources of potential future  funding.
However, the Iraqi government has not fully spent the capital project funds  already allocated to the oil sector in Iraq’s 2006 budget. In 2006, Iraq  planned to spend more than $3.5 billion for capital projects in the oil  sector. This amount accounted for about 98 percent of the Ministry of Oil’s  total budget ($3.6 billion) that year. As of December 2006, the end of Iraq’s  fiscal year, only 3 percent of oil sector capital project funds had been  spent. While Iraq’s inability to spend its capital budget may not directly  affect U.S.-funded projects, U.S. investment alone is not adequate for the  full reconstruction and expansion of the oil sector. Therefore, Iraq’s  continued difficulties in spending its capital budget could hamper efforts  to attain its current reconstruction goals.
According to U.S. officials, Iraq lacks the clearly defined and consistently  applied budget and procurement rules needed to effectively implement  capital projects. For example, the Iraqi ministries are guided by complex  laws and regulations, including those implemented under Saddam  Hussein, the CPA, and the current government. According to State  Department officials, the lack of agreed-upon procurement and budgeting  rules causes confusion among ministry officials and creates opportunities  for corruption and mismanagement. Additionally, according to the State  Department and DOD, personnel turnover within the ministries, fear of  corruption charges, and an onerous contract approval process have  caused delays in contract approval and capital improvement expenditures.
Furthermore, the Iraqi government has not made full use of potential  international loans, and future donor funding for the oil sector remains  uncertain. Donors other than the United States have not provided any  grants to develop the oil sector, and the Iraqi government had not taken  advantage of $467 million in loans from Japan to develop a crude oil  export facility and upgrade a refinery. According to U.S. and international  officials, donor funding has been limited because of an expectation that  sufficient funds would be provided through Iraq’s oil revenues and private  investors.
Moreover, it is unclear to what extent the International Compact with Iraq  will serve as a viable mechanism to obtain additional donor support for  Iraq, particularly for the oil sector. Launched in May 2007, the compact  was intended to secure additional funding for Iraq’s oil, electricity, and  other sectors. However, the extent to which the compact will stimulate  international assistance for the oil sector remains uncertain.
section_title: Challenges Impede Efforts to Enact and Implement Comprehensive Hydrocarbon Legislation
paragraphs: The World Bank reports that additional incentives are needed to stimulate  oil production and investment, including a clear legal and regulatory  framework; clearly assigned roles for Iraq’s ministries, state agencies, and  the private sector; and a predictable negotiating environment for  contracts. Iraq has yet to enact and implement comprehensive  hydrocarbon legislation that would define the distribution of future oil  revenues and the rights of foreign investors. According to U.S. officials,  until such legislation is passed and implemented, it will be difficult for Iraq  to attract the billions of dollars in foreign investment it needs to modernize  the oil sector.
As of July 13, 2007, the Iraqi government was in various stages of drafting  and enacting four separate, yet interrelated, pieces of legislation:  hydrocarbon framework legislation that establishes the structure,  management, and oversight for the sector; revenue-sharing legislation (the  draft “Law of Financial Resources”); legislation restructuring the Ministry  of Oil; and legislation establishing the Iraq National Oil Company (INOC).  According to the State Department, to be enacted as law, the four pieces  of legislation must be approved by Iraq’s cabinet (Council of Ministers),  vetted through the Shura council, and then submitted by the cabinet to a  vote by Iraq’s parliament (Council of Representatives). If the laws are  passed, they are then made publicly available in the Iraqi government’s  official publication, known as the Official Gazette. Figure 6 shows the  status of the four proposed pieces of legislation as of July 1, 2007.
The draft hydrocarbon framework is the furthest along in the legislative  process and is currently before Iraq’s parliament, according to a State  Department and a KRG official. According to these officials, it provides an  overall framework but lacks key details that will be addressed in the  financial resources and other legislation. The UN reported in early June  2007 that there had been no decision on whether the hydrocarbon  framework legislation would be voted on as a part of a larger energy  package with annexes and supporting legislation or voted on separately.  The KRG has published the negotiated “agreed-to” text for the revenue- sharing legislation, which has not yet been approved by the cabinet.  Negotiated text of the draft legislation for restructuring the Ministry of Oil  and establishing INOC have yet to be developed and published. According  to a State Department and KRG officials, the passage and implementation  of all four pieces of legislation is essential to achieve increased  transparency, accountability, and revenue management.
Moreover, enacting and implementing hydrocarbon legislation and  subsequent regulations and procedures will likely be impeded by some of  the same challenges, such as poor security and corruption, that affect  achieving program goals and reconstruction of the oil sector. According to  U.S. officials, sectarian attacks and the lack of national unity and trust  have resulted in competing sectarian interests and wariness of foreign  investment. Also, according to U.S. officials, opportunities to profit from  corruption and smuggling reduce the incentive for greater transparency  and accountability in oil resource management. U.S. officials recognize  that significant implementation challenges will remain once the draft  legislation is enacted into law.
section_title: Conclusion
paragraphs: As we recently reported, the United States has spent billions of dollars to  rebuild Iraq’s oil sector, but billions more will be needed to surmount the  challenges facing Iraq’s oil sector. Iraq’s oil sector lacks an effective  metering system to measure output, determine revenue trends, and  identify illicit diversions. Opaque laws governing investment have also  limited foreign investment in this critical sector. The passage of  comprehensive Iraqi hydrocarbon legislation could serve as an important  impetus for stimulating additional investment if and when security  conditions improve. The development of the sector is also hindered by  weak government budgeting, procurement, and financial management  systems and limited donor spending. The absence of an integrated  strategic plan that coordinates efforts across the oil and electricity sectors  is essential given their highly interdependent nature. Such a plan would  help identify the most pressing needs for the entire energy sector and help  overcome the daunting challenges affecting future development prospects.
section_title: Recommendations for Executive Action
paragraphs: In our May 2007 report, we recommended that the Secretary of State, in  conjunction with relevant U.S. agencies and in coordination with the  donor community, work with the Iraqi government and particularly the  Ministry of Oil to:  1.  Develop an integrated energy strategy for the oil and electricity sectors  that identifies and integrates key short-term and long-term goals and  priorities for rebuilding, maintaining, and securing the infrastructure;  funding needs and sources; stakeholder roles and responsibilities,  including steps to ensure coordination of ministerial and donor efforts;  environmental risks and threats; and performance measures and  milestones to monitor and gauge progress.  2.  Set milestones and assign resources to expedite efforts to establish an  effective metering system for the oil sector that will enable the  Ministry of Oil to more effectively manage its network and finance  improvements through improved measures of production,  consumption, revenues, and costs.  3.  Improve the existing legal and regulatory framework, for example, by  setting milestones and assigning resources to expedite development of  viable and equitable hydrocarbon legislation, regulations, and  implementing guidelines that will enable effective management and  development of the oil sector and result in increased revenues to fund  future development and essential services.  4.  Set milestones and assign resources to expedite efforts to develop  adequate ministry budgeting, procurement, and financial management  systems.  5.  Implement a viable donor mechanism to secure funding for Iraq’s  future oil and electricity rebuilding needs and for sustaining current  energy sector infrastructure improvement initiatives once an  integrated energy strategic plan has been developed.
section_title: Agency Comments
paragraphs: In commenting on a draft of our May 2007 report, the State Department  agreed that all the steps we included in our recommendations are  necessary to improve Iraq’s energy sector but stated that these actions are  the direct responsibility of the Government of Iraq, not of the Department  of State, any U.S. agency, or the international donor community. The State  Department also commented that U.S. agencies are already taking several  actions consistent with our recommendations. We recognize that these  actions are ultimately the responsibility of the Iraqi government. However,  it remains clear that the U.S. government wields considerable influence in  overseeing Iraq stabilization and rebuilding efforts. We also believe  additional actions are warranted given the lack of progress that has been  made over the last 4 years in achieving Iraq reconstruction goals.
Mr. Chairmen, this concludes my statement. I would be pleased to answer  any questions that you or other Members may have at this time.
section_title: GAO Contacts and Acknowledgments
paragraphs: For questions regarding this testimony, please call Joseph A. Christoff at  (202) 512-8979 or christoffj@gao.gov. Other key contributors to this  statement were Stephen Lord, Assistant Director; Lynn Cothern; Kathleen  Monahan; and Timothy Wedding.
section_title: Appendix I: Data on Iraq’s Crude Oil Production and Exports
paragraphs: Table 1 provides the data used in figures 3 and 4 of this testimony.  Department of State data on Iraq’s crude oil production and exports are  collected by State Department officials in Iraq through Iraq’s Ministry of  Oil. We calculated Iraq’s production for domestic consumption (the  amount of oil produced that remains in the country) as the remainder of  Iraq’s production of crude oil after exports, based on State Department’s  data. Data from the Department of Energy’s Energy Information  Administration (EIA) are based on EIA’s own analysis and a variety of  sources, including Dow Jones, the Middle East Economic Survey, the  Petroleum Intelligence Weekly, the International Energy Agency, OPEC’s  Monthly Oil Market Report, the Oil & Gas Journal, Platts, and Reuters.