Does “One Size Fit All?” Reflecting on Governance and North Sea Licensing Systems Jerome Davis Canada Research Chair (Oil and Natural Gas Policy) Dalhousie University Background Paper: BC Offshore: Potential and Problems A MASC Workshop for Lawyers Dunsmuir Lodge, Sidney B.C. March 18-21, 2004 PLEASE NOTE: This is a background paper for discussion only. Do not quote or cite without the express permission of the author Does “One Size Fit All?” Reflecting on Governance and North Sea Licensing Systems Jerome Davis Canada Research Chair (Oil and Natural Gas Policy) Dalhousie University 1. Introduction: Auction versus Discretionary Licensing Systems This paper might be characterised as an “outlier” in a panel largely focussed on Canadian governance modalities and objectives. It is to address the “European experience” with regard to offshore governance regimes. In fact, one might better argue that there is a diversity of European experiences which might be discussed in this context. The author is poorly placed to encompass the wealth of European experiences, due not only to constraints of paper length, but also to the depth of knowledge that is required for such an exercise. So rather than focus on the wide diversity of offshore issues and the variety of ways in which European states confront these. I shall focus briefly on one set of offshore governance issues, those of offshore oil and gas licensing (or, in the Danish case, concession) policies offshore Northwestern Europe. Ever since Kenneth Dam’s classic Oil Resources: Who Gets What How (Chicago: University of Chicago Press, 1976), North Sea offshore oil and gas licensing regimes have been lumped together as being the North Sea “model.” Dam’s analysis focussed on license allocation systems which were characterised as being either one of two governance models: “auction systems” (North America) and “discretionary allocation” (North Sea—Norway and the UK). In Canada the debate over the Liberal’s National Energy Policy in which the Federal Government attempted to impose many of the elements of Dam’s “discretionary allocation” on Canadian provinces and oil multinationals has further reinforced characterisation of a North Sea “model” often in unfortunate terms. In this context I will advance these arguments: My first argument is as follows: Lumping all Northwestern European licensing allocation systems into one “discretionary” approach can be misleading in several respects. Firstly, there is an element of discretion in any allocation system, even that of auctions. Secondly, the North Sea “model” should not only comprise the UK and Norway, but also two other hydrocarbon exporting nations: Denmark (oil and natural gas) and the Netherlands (natural gas), both of whom have 2 substantial offshore activities, and represent variations of the “model” theme. Thirdly, realising that discretion figures into any offshore licensing regime and that the North Sea model should also take Danish and Dutch policies into account makes for a richer appreciation of offshore governance issues in Northwest Europe, and how these might enter any Canadian academic or policy-maker discourse. My second argument, and one which is very pertinent for any panel discussion on the legal aspects of governance issues is that European offshore allocation regimes are as much a function of what might be termed the differing national property rights systems as they are of adopting a “Norwegian” or a “British” or (for that matter) an “Iranian” model of license allocation. Such a property rights approach is indeed vital for the study of the creation, adaptation, or abandonment of many North Sea licensing practices. My third argument is that there is a tendency in oil policy/governance circles to assume that “one size fits all,” here the North American royalty auction/bidding systems. Other forms of oil licensing regimes are ascribed somewhat negatively to Third World and Transitional governance systems (predominantly various forms of production sharing regimes). I will argue that in terms of the richness of solutions to various ownership problems, and of political legitimacy, the diverse North Sea experiences might be of relevance in designing specific future Canadian offshore regimes. 2. What are Property Rights? A Theoretical Note Key to an understanding of my arguments is an appreciation of what constitutes a property right. There are many overlapping definitions of the concept. I shall utilise that of the MIT Modern Dictionary of Economics. According to this source, property rights are: Those rights pertaining to the permissible socially sanctioned use of resources, goods and services (Pearce, 1986, p. 364) Note that property rights are not ownership rights, here. Rather ownership comprises various sets of property rights: - Ownership of an asset consists of the following rights: To use the asset To change its [the asset’s ] form and substance To transfer all rights through sale Note ownership of an asset is not unfettered because some restrictions are generally imposed by private contract or law (Ibid). 3 Ownership of oil and natural gas resources throughout the North Sea (indeed in most nations both inside and outside of Europe) is vested in the nation state. Such ownership must necessarily impinge on the rights exercised by the licensee and her partners. Here of particular importance is the “fettered nature” of the state’s ownership rights. These are not only fettered by the nature of the license “contract” but are also impinged upon by other factors. For example in both Canada and Western Europe, state ownership rights have been affected by economic union. But, whereas the issues raised by NAFTA may have created some problems in Canadian exploration, exploitation and sale of hydrocarbons in North America, the problems created by the EU, particularly as regards a common energy policy, have had a major impact with far-reaching implications, even for such non-EU members as Norway. 2. Argument One: Diversity in Unity In that this argument is in fact making several contentious points at one and the same time, I shall for reasons of time and space confine myself to the “discretionary” element of auction and discretionary allocation systems, and to the contentious issue of state “participation” in offshore activities, and then use my points here to argue for a more nuanced position towards Northwestern European offshore licensing regimes. I will be happy to expand on both in any panel discussion. 2.1. Auctions and Discretionary Allocation: Questions of Neutrality and Complexity Auctions, we are told, are not discretionary; they are “neutral.” On the other hand, licensing of hydrocarbon rights on the basis of work programs and the use of consecutive licensing rounds to alter the over-all nature of a licensing system as has happened in Norway, Great Britain, and Denmark is “discretionary.” For the sake of argument we will lay efficiency criteria to one side and focus on the nature of the two systems. I will argue that neither system is “neutral.” A state license auctioneer is a monopolist. But in order to auction exploration, exploitation, processing, and transportation rights to a particular area, the auction must attract bidders. This requires communication between the auctioneer and potential bidders. It is not infrequent that bidders will advance preconditions, auctioneer acceptance of which will determine the degree of bidder interest. The state auctioneer, if she is wise, will take such preconditions into account in the period in which the auction is “designed.” Auction participation might depend on the nature of the potential properties on offer. If the potential is thought to be too small, potential bidders might lobby for other additional properties as a precondition for their auction participation. Similarly, the form of bidding is not neutral; bonus bidding auctions can preclude smaller independent oil firms from participation, as these cannot afford the sums involved for a successful bid. Royalty auctions 4 allow for smaller independent participation but have undesirable consequences for the development of any high cost fields found under such an auction. Astute oil companies are aware of these and other factors and do in fact “lobby” the state auctioneer. Another similar problem is that the definition of a “qualified” bidder as the basis of qualification can be discretionary. This clearly impacts on auction entry and the nature of bidding. The technical design of the auction itself can be a matter of choice. Finally, the “neutrality” argument rests on the allocation of oil prospects alone; in fact, returns on oil company investment depend on a series of variables outside the specific license terms of entry. The state retains discretion with regard to taxation schemes aimed at appropriating company rents. Environmental regulations may change, imposing costs on license operators. Detailed questions of transport charges, tariffs, and pipeline access may have to be resolved. Finally, the knotty problem of hydrocarbon valuation, perhaps the most contentious problem of them all, can lead to conflict with regulatory authorities. A discretionary system differs from an auction system perhaps in two respects: firstly, it uses different licensing rounds to alter the nature of the property rights assigned the successful licensee. Secondly, the value of the property rights is not expressed in terms of a cash bonus or a willingness to pay a specified royalty rate, but in licensee acceptance of a set of legal conditions to which he is expected to conform; these can be very constricting, as in the inclusion of an exacting work programme; but alternatively they may not be as onerous as is commonly thought. Thus, the Netherlands authorities have been very liberal as to their demands of a successful applicant as compared to the Norwegian authorities. (For many years, this could be seen in a free-wheeling Dutch system where successful license applicants could be “mom and pop” organisations working from their “headquarters” in an apartment building). What is important to recognise here is that the greater sensitivity of the discretionary system to environmental and political change does lead to differing terms for differing licensing rounds. It is important to recognise here that such changes are not retroactive. A demand that successful applicants in licensing round five allow for state participation on a non-carried interest basis does not mean that winners of round four applications two years previously are forced into similar terms. Licensing “contracts”, with some notable exceptions, are respected. (For instance, this does not rule out the possibility that to qualify for round five, a round four winner may have to agree to state participation on his licenses should she find commercially exploitable hydrocarbons. Neither does it apply to the imposition of special taxes as rent capture mechanisms, but this latter has also been a characteristic of auction systems). 5 There are several major problems with a discretionary system and a major plus. Firstly, discretionary systems become essentially negotiated systems. (Cases in point here are the stories behind the passage of the U.K. Oil Tax Act of 1975, described as the single most complex piece of legislation to pass the House of Commons, a twenty year U.K. controversy over “marginal fields” and the abolition of royalties, the two “renegotiations” of the Danish concession, the Marathon Heimdal controversy in Norway, and these are but a few of the more significant). This creates a second problem, that of transparency where it is necessary to separate what might be termed the formal discretionary system, as prescribed publicly, and an informal system, a system which reflects the actual (as opposed to public) implementation of licensing policies. The second “system” can be far more lenient than the first. Examples of this are not hard to find. After its Fulmar find, a find which led to a new North Sea “play”, Royal Dutch/Shell (Shell) were reoffered all the blocks in the Fulmar area which they had previously surrendered. The value of these blocks had increased due to the new knowledge, but rather than licensing these to new entrants, British authorities favoured Shell. Similar stories abound elsewhere. The British Gas Moracombe Bay field was reoffered to Gulf who had in error surrendered the area through ignoring evidence of a natural gas find. (Gulf Oil refused. BG developed the field which is now the “swing” field for all British North Sea gas). When the continental natural gas consortium imposed lower contractual prices for Norwegian natural gas, the American Independent, Marathon, was faced with economic losses from its Heimdal field. To alleviate these losses, the Norwegian authorities incorporated Marathon’s Heimdal field into its gas gathering/transmission network, enabling Marathon to recoup its losses. Finally any deeper examination into how royalties and taxes are in fact collected by North Sea governments reveals that North Sea rent capture regimes remain more notorious for their “bark” than for their “bite.” A third problem is that such systems “bind” licensees to their commitments in a manner that bonus or royalty bidding systems do not. This limits operator discretion. A working programme requiring the drilling of a certain number of wells at particular .locations to specific depths commits the operator to drilling that number of wells under the conditions specified. Similarly, there can be additional demands as to licensee delivery of information to the licensing authorities, to finance onshore R&D programmes and the like. In this respect, it is interesting to observe that the UK is moving away from such demands in an attempt to attract interested parties to prospects offshore UK, launching diverse initiatives to this end -PILOT, the Fallow Fields, and Brown Fields programmes, Prospect Licenses, and “Share Fairs”- (Townsend, 2003, p.1). 6 A great advantage with the discretionary licensing system is that it is regarded as politically legitimate by the respective voting publics in Northwest Europe. Given that property rights in these countries are well defined and contract law observed, offshore licensees have been able to extract enormous amount of hydrocarbons on commercial terms with a minimum of political fuss and bother. (This notably does not apply to other property rights regimes such as may exist for example in Russia, or Kazakhstan where the oil companies are currently encountering major property rights problems). 2.2. North Sea Licensing: The Question of Variety A second major point in our argument here is that lumping all licensing practices into one “North Sea governance” model can lead to misunderstandings as to the subtleties of North Sea practices. A closer look at North Sea practices reveals major differences in how this “model” in fact functions. I have already pointed to the differences in block allocation systems between the Norwegian system, where licensees for many years were subject to strict controls and were virtually all major oil companies, and that of the Netherlands where block allocations, drilling programs, and relinquishment provisions were granted on a far more liberal basis. There are many other additional examples which could be added to the list: the nature of special petroleum taxes, royalty systems, transport regimes, pace of offshore developments, and so forth. For the purpose of brevity I shall refer to state participation systems here. This example should not be misconstrued. This is NOT an argument for state participation. All four major European oil and gas provinces have been characterised by government participation in its various forms. What is of interest here is how this participation has evolved. The British first created and then privatised the British National Oil Corporation. The British government also privatised the British Gas Corporation in a move aimed at liberalising the British natural gas market. The Norwegian state first created Statoil, a firm which until now has a dominant position in the Norwegian offshore through its part ownership of producing licenses, and through its control of the Norwegian offshore pipeline network; it additionally created another company, Petoro, which is charged with managing (and in some cases disposing of) the State’s Direct Financial Interest (SDFI). The Dutch rather than create a state company assigned responsibility for state participation to an already existing state firm, the Dutch State Mines. Here, state offshore participatory interests were quietly managed in an offshore division with a staff of around 20 employees. (This is now a division of the Energie Beheer Nederland BV (EBN) recently hived off DSM as a separate company (Netherlands Ministry of Economic Affairs, 2003)). 7 Denmark’s Danish Oil and Natural Gas (DONG), originally created to take responsibility for natural gas transportation, has had its role expanded, an outcome of a round of negotiations with the then sole concessionaire of Danish offshore rights, in 1981. It is now an active North Sea operator in the Danish and Norwegian sectors. Even from this limited sampling, the governance modalities of participation vary immensely. The BNOC followed the classic participation model, providing the state owners with some security of supply, a “window” into oil MNE licensee strategies, a reduction of dependence on oil MNEs, a share of the rents involved in oil exploitation, and promotion of the domestic share of offshore activities (Grayson, 1981, pp. 175-196). Statoil not only performed these classic functions but also through its control of offshore pipelines captured any rent element involved in offshore transport, and (in conjunction with the Norwegian Petroleum Directory) indirectly controlled the rate of resource exploitation. The administration of the Norwegian SDFI properties was also a feature which made Statoil participation different from those of its neighbours, at least until this function was allocated to Petoro. With the increased internationalisation of Statoil and activities (and the prospect of its privatisation), the Norwegian state created another state company Petoro to administer its SDFI, but, as importantly, to serve as a watchdog over Statoil’s disposition of the oil and gas produced by these properties. Petoro controls roughly a third of the total proven reserves in the Norwegian offshore which is its only corporate focus. Statoil is left with about 20 percent. And the third state company, Norsk Hydro retains about 10 percent. This multiplicity of state oil companies makes Norwegian governance unique in terms of state participation on licenses. The Danish DONG existed primarily to control pipeline access to continental markets, as participation until the 1980’s was an impossibility. With a changed Danish licensing system, DONG participation in offshore licenses was characterised by involving other non-oil Danish interests in offshore exploration and development. DONG’s participation in offshore licenses took place through a company, DENERCO, which had among its members some of the leading private firms in Denmark. Thus a major objective of Danish state participation was to give private Danish firms access to the opportunities afforded by offshore Danish licenses. The Dutch EBN participates on all Dutch offshore licenses, although there are exceptions, and participates at rates as high as 40 percent (before 2003, these could be higher). Here the objective apparently is more a rent capture objective than that of a “window” or purveyor of oil and gas interests to private Dutch companies. The Dutch state through the EBN has quietly exercised rights to several trillion cubic feet of offshore natural gas and has done so largely unnoted by the literature on the North Sea offshore. 8 Nor has the existence of state participation dampened oil company interest in these areas. There are roughly 15-25 exploration wells (fifteen in 2002 with nine discoveries) drilled in the Norwegian offshore every year and this average has been maintained for twenty years (Quinlan, 2003, p.1). Some 20 wells are drilled in the Netherlands offshore which now accounts for one third of the 2.75 Tcf produced in that country annually. The success rate for wells was a reported 50 percent last year. Danish exploration drilling has never reached the heights of the other provinces, but it too remains roughly constant, with DONG taking on active operator responsibilities for many holes. Only in the British sector has activity declined. From an average of around 80 –90 exploration holes in the 1990’s, the number of exploration wells has slumped noticeably, falling as low as 44 in 2002 (Quinlan, 2003, p.2). Company interest in these provinces remains more a function of future potential than of whether a country requires state participation or not. The point of these examples is not to declare for or against participation, or any particular one of the variants describe above. The point is purely to indicate that state participation can have widely differing implications, and should be seen in context before one passes judgement. In other words, one size really does not fit all. 3. Argument Two: National Property Rights Systems- Causes of Diversity? State owners of potential oil and natural gas all are confronted with the same problem when approached by an oil firm as to the possibilities of exploring for and developing any potential hydrocarbons in their offshore areas, that of determining the licensing regime under which its ownership rights will be exercised. This, I have argued, is in turn a function of the property rights system characterised by that particular state. Yet I have not operationalised what is meant by this. I argue that in the process of drawing up the basic offshore laws, the establishment of the institutions of governance, and in the process of regulating offshore activities, legislators and regulators are sensitive to external signalling from various domestic and oil company applicant and licensee interests. Noll expresses this thought best in discussing American regulatory agencies in another context. In addition to feedback from the regulated parties, the regulatory agency receives additional signals: From each theatre of external judgement- courts, Congress, constituents, executive branch budget process, and press – the agency receives a flow of success indicators: actions that express approval or disapproval of the agency’s decisions. It is plausible that agencies will view the public interest as being served if the success indicators show approval. ..(1985, p. 41) It is my argument, firstly, that external signal feedbacks are vital in terms of regulatory or governance activities is characteristic of all offshore licensing regimes (i.e. this U.S. character- 9 isation is not the exception, but the rule), and, secondly, that these signals constitute the parameters of what institutions, what uses of oil and gas resources, are socially sanctioned for any given North Sea oil and gas governance regime. What affects social sanctions and external signalling here and why do these differ between national governance systems? Definitive answers to this question are difficult. The following generalities are the best that I can do at present: Firstly, differing societies attach differing degrees of faith in markets as a sole means of allocating user rights to publicly owned assets. Key to the North American auction allocation of license rights is the perception that the winning price bid for a license will accurately reflect every future licensee earnings contingency for the duration of the license. Contract prices are complete in the sense that they account for every future possibility. Other societies are more sceptical as to whether prices bid for licenses in year one will reflect actual values in years two through twentyfive, given the unpredictability of oil markets, technological developments, and world reserves forecasts. This is particularly true of rent capture. It should be emphasized that this characteristic is not confined to oil and gas resource use. (For example, perhaps with the exception of the UK, many European states have been very sceptical of the use of auctions for spectrum allocation, a use of auctions which has been regarded as legitimate in the United States for over a decade). Curiously, experiments with bonus or royalty auctions have been confined to British licenses, and, although virtually all North Sea licensing systems are introducing new forms of license allocation today, none of these is based on auction institutions. . A second relevant property right/governance variable might be the over-all putative value of the licensing rights awarded in terms of their potential contribution to community welfare. The closer this relationship is to a 1:1 relationship, the greater the salience of oil and gas governance issues, and the more sensitive the local community is to governance issues. Here it is particularly notable how much more political Norwegian regulatory effort is when compared to those of the Netherlands, Denmark or the United Kingdom. Up until ten years ago, it was required that each and every oil or gas development plan be reviewed and passed upon by the Norwegian legislature, the Storting. Storting committee reports remain among the most valuable sources of research information on many of these fields. A third variable is what might be termed the insider-outsider variable: Given community ownership of oil and gas rights, should these be awarded on an equal basis to all comers, or should members of the community have preferential treatment? In most European countries, incorporating 10 the demands of local industry or those of a national champion are seen as a legitimate goal of offshore oil and gas governance. Licensing regimes tend to reflect this either formally in terms of licensing law (Norway and Denmark) or informally through licensing practices (the Netherlands and- allegedly- the United Kingdom). In Norway, there has been a practice of giving Norwegian state and private firms (Statoil, Norsk Hydro, and, for a time, Saga Petroleum) privileged access to prime licenses. Danish licensing policy is somewhat schizophrenic. There is one concession for the Danish national champion, A.P. Moeller, which has retained ownership of producing rights to the productive Central Graben, and a more modern licensing system for all other participants in which A.P. Moeller is prominently absent. In the Netherlands, the Royal Dutch/Shell- Esso (now Exxon Mobil) partnership Nederlandse Aardolie Maatschappij (NAM) in fact has exercised a decisive influence, in part through its North Sea activities and dominance of the Schloctern gas fields and, in part, through its 50-50 partnership with the Dutch state in the national transmission and marketing giant Gasunie, a relationship which is currently under revision. Similarly, there have been allegations that BP and Royal Dutch Shell have received preferential treatment in the UK sector, although hard evidence here is difficult to come by. Fourthly, a single comprehensible set of external signals to a set of regulators may not be possible due to regional, ethnic, or administrative fragmentation. In such cases, governance systems are liable to be administratively complex with multiple jurisdictions (as is the case in Canada) or imposed by one group upon one or more other groupings (the Nigerian ruling elite and the Ogoni peoples). While there are regional (Norway, the Netherlands) or national (England and Scotland) differences among North Sea countries, they uniformly have strong unitary governments. It has been implied (Fossum, 1995) that such offshore areas as the Canadian may not be suited to a “North Sea model” due to the shared ownership of Canadian offshore areas and the degree of Federal-provincial conflict involved in their governance. I am less certain about Fossum’s implication. Finally, differing societies may view revisions of contractual obligations differently. Curiously, given much of what is written about them, arbitrary state revision of license terms is rare in North Sea governance regimes. The British Labour Government insistence that producing consortia voluntarily sell the British National Oil Corporation participating shares of their producing licenses (see Corti and Frazer,1982) and the Danish Government’s 1981 negotiated revision of its 1963/64 concession with A.P. Moeller are perhaps two of the more questionable episodes here in what otherwise is a surprisingly good record. A third celebrated case did not deal 11 with license rights, but with Marathon’s Norwegian contract to sell Heimdal natural gas to Continental markets. 4. Conclusion. Argument Three. One Size Fits All: Possible Implications for Canada? What are the possible implications of our arguments for the Canadian offshore? My following observations are more points for debate than thoroughly thought through options for Canadian offshore governance. My training is not a legal training. I am not thoroughly acquainted with the intricacies of the Canadian offshore governance regime, and policy mistakes in this area can last for 25 years and cost many billion dollars. With these caveats in mind several points appear to be of interest. Firstly, I have noted the “one size fits all” approach in informal conversations with Canadian experts. Two examples from Atlantic Canada will suffice. The two Permanent Boards (CNSOPB and CNOPB) have virtually all the vital competencies regarding offshore licensing and regulatory policy. There is (was?) a plan afoot to merge these two regulatory instances, a plan which Newfoundland/Labrador has opposed. To outsiders, the rationale for merging seems overwhelming. Indeed, many of the issues dividing the two federal-provincial regimes seem petty (for example the differing certifications required of offshore drilling rigs). Yet, it must be stressed that many regulatory issues involve incredible precision and are likewise incredibly detailed, and details in offshore governance regimes are very important. Given the differing historical circumstances of the two licensing regimes, the importance of details, and, above all, differences in the nature and size of resources discovered and the salience of these to the respective provincial governments, there could well be advantages in having two boards rather than one. (This does not mean that economies of scale in terms of technical staff support and the like need be foregone). Secondly, I have become aware that developments offshore Newfoundland may have been hampered by the royalties charged by the authorities. These are seen as necessary for the province and federal government to implement the economic provisions of the Atlantic Accord, but at the same time, they are a hindrance to commercial development of offshore discoveries. (Note, as royalties are charged net of transport, but before other development costs are deducted, they are seen as a cost which impacts severely on oil company ROR’s for offshore fields). A solution to this problem in the North Sea has been found. One repeals royalties and substitutes a petroleum revenue tax for the royalty. This has the benefit of being levied on profits net of costs, and is far less 12 regressive. (Such a solution has been found in the UK 10 percent increase in corporate taxes in return for abolition of all royalties for British offshore fields; note that the UK offshore fields are “ring fenced” however). In the Atlantic Accord context, it is unlikely that such a (discretionary?) solution could be found. Thirdly, I have been impressed by the radically different political environments impacting on present and future offshore governance regimes. Thus, the fishing communities of Nova Scotia and Newfoundland have radically different attitudes towards offshore activities. Off the British Columbia coast, issues of fishing rights, environmental protection, and First Nation concerns make the communities’ conflicts in the Atlantic Provinces look like “child’s play.” Similarly, Ottawa is going to have to arrive at offshore agreements with Quebec. In all instances, it is tied to the Atlantic Accords and to the institutional arrangements underpinning these accords. I have no doubt that policy-makers are very much aware of the problems in applying the one size of the Atlantic Accord to BC and Quebec. What I am arguing here is that the nature of the offshore licensing regime be taken into account when one examines the nature of the issues here. For success, both provinces and Ottawa may have to abandon the one size fits all bonus/royalty auction systems used in offshore Atlantic Canada. I have not had time to go into detail regarding the wealth of institutional experience which can be learned from offshore Northwest Europe. Can Canadian learn from these? I believe they can, and implementing some of these lessons can increase the political legitimacy of the governance systems concerned. This is not an unequivocal endorsement of the various governance systems in the North Sea; but one can learn as much from failure as from successes, and North Sea countries have had their fair share of both. Bibliography Corti, G, and F. Frazer (1983). The Nation’s Oil: A Story of Control (London: Graham and Trotman, Ltd.) Dam, Kenneth (1976) Oil Resources: Who Gets What How? (Chicago: University of Chicago Press) Fossum, John E. (1997). Oil, the State and Federalism: The Rise and Demise of Petro-Canada as a Statist Impulse (Toronto: University of Toronto Press) Grayson, Leslie E. (1981). National Oil Companies (New York: John Wiley and Sons) 13 International Energy Agency (2001) The Netherlands 2000 Review (Paris: IEA) Netherlands Ministry of Economic Affairs (2003). Oil and Gas in the Netherlands- Exploration and Production 2002 (The Hague: Ministry for Economic Affairs) Noll, Roger G. (1985). “Governmental Regulatory Behaviour: A Multidisciplinary Survey and Synthesis,” in R.G. Noll, ed., Regulatory Policy and the Social Sciences (Berkeley: University of California Press), pp.9-64. Pearce, D.W. ed. (1986). The MIT Dictionary of Modern Economics (Cambridge, Mass: MIT Press) Quinlan, M. (2003). “A sea of contrasts: Norway,” Petroleum Economist, August, pp;. 1-7. Townsend, P. (2003) “Growing old gracefully,” Petroleum Economist, April, p.1. 14