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- Gas flaring – the provisions on gas flaring seem excessively punitive
- Domestic Supply Obligations – should not apply to crude oil or gas
- Abandonment Fund – the provisions on abandonment should be flexible to allow different organisations evolve mechanisms appropriate for their organisation.
- Delineation of sectors – existing operations to be grandfathered
- Acreage relinquishment – too aggressive and only 50% of acreage be relinquished
- Powers of the Commission – may prove excessive