March 21, 2013
VIA EDGAR CORRESPONDENCE
Mr. Brad Skinner
Senior Assistant Chief Accountant
United States Securities and Exchange Commission
Division of Corporation Finance
101 F Street N.E.
Washington, D.C. 20549
Re: CAMAC Energy, Inc.
Form 10-K for Fiscal Year Ended December 31, 2011
Filed March 15, 2012
Definitive Proxy Statement on Schedule 14A
Filed April 30, 2012
Response dated February 15, 2013
File No. 1-34525
Dear Mr. Skinner:
We refer to a telephonic conversation of March 12, 2013 between Mr. Michael Faye, Staff Accountant of the Securities and Exchange Commission (“SEC”), and the undersigned of CAMAC Energy Inc. (the “Company”). Further to such conversation, we are providing supplemental information to the Staff in connection with our response in our February 15, 2013 letter to the Staff’s prior comment number 3.
Table 1 below illustrates the approach we took to risk adjust the Company’s future net cash flows as of December 31, 2011. Table 2 represents the summary projection of reserves and revenue contained in the Company’s 2011 reserve report from Netherland, Sewell & Associates, Inc. and supports the Undiscounted Future Net Revenues Less Costs shown in Table 1 for each reserve category. Table 2 also shows how capital costs and operating expense have been taken into account in the calculation of the future net cash flows. Please note that for probable reserves no additional development wells are required, but rather, the incremental reserves would result from improved well performance from existing wells (Oyo-7, 8 & 9) and therefore no additional capital expenditures would be required. Additional operating expenditures would be required, however, due to longer field life for the probable reserves. For the possible reserves, new wells (Oyo -10, 11 and 12) will be required in the eastern part of the field and therefore both additional capital expenditures and operating expenditures would be incurred.
In connection with its response, CAMAC Energy Inc. acknowledges that:
● | CAMAC Energy Inc. is responsible for the adequacy and accuracy of the disclosures in the filings; |
● | Staff comments or changes to disclosure in response to Staff comments do not foreclose the Commission from taking any action with respect to the filings; and |
● | CAMAC Energy Inc. may not assert Staff comments as a defense in any proceeding initiated by the SEC or any person under the federal securities laws of the United States. |
If you have any questions or comments regarding this letter, please contact the undersigned at 713-797-2961.
Very truly yours
CAMAC Energy Inc.
By:
Nicolas J. Evanoff
Senior Vice President & General Counsel
Table 1
Future Net Cash Flows from Proved (P1), Probable (P2), and Possible (P3) Reserves - December 31, 2011 |
CAMAC Energy Inc. Share of Oyo Field |
| | | | 12/31/2011 | | Risked |
| | | | Productive | | Undiscounted |
| | | | Carrying | | Basis |
| | Undiscounted Future Revenues Less Costs | | Amount | | Excess/(Def). |
| | Unadjusted | | | Risk | | | Risk | | | | |
| | for Risk | | | Factor | | | Adjusted | | | | |
Net proved reserves 12/31/11 | | | 80,311,900 | | | | 1.00 | | | | 80,311,900 | | | | |
Net probable - incremental | | | 210,090,200 | | | | 0.50 | | | | 105,045,100 | | | | |
Net possible - incremental | | | 675,046,600 | | | | 0.10 | | | | 67,504,660 | | | | |
Total 12/31/11 | | | 965,448,700 | | | | | | | | 252,861,660 | | 190,979,000 | | 61,882,660 |
Table 2
![](https://capedge.com/proxy/CORRESP/0001529290-13-000006/nsa_logo.jpg)
SUMMARY PROJECTION OF RESERVES AND REVENUE
CAMAC ENERGY INC. INTEREST
OYO FIELD, OIL MINING LEASE 120, OFFSHORE NIGERIA AS OF DECEMBER 31, 2011
PROVED(1P)RESERVES
| | | | | | | | | | | | | | | | | | | | | | | | | |
| | | Oil Reserves | | | Future Gross | | | | | | Net Capital | | | Net Operating | | | Future Net | | | Cumulative PWat | |
Period | | | Gross | | | Net | | | Revenue | | | Taxes | | | Costs | | | Expense | | | Revenue | | | 10.0% | |
Ending | | | (MBBL) | | | (MBBL) | | | $(M) | | | $(M) | | | $(M) | | | $(M) | | | $(M) | | | $(M) | |
| | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | |
| 12-31-2012 | | | | 978.2 | | | | 82.6 | | | | 9,276.1 | | | | 0.0 | | | | 0.0 | | | | 0.0 | | | | 9,276.1 | | | | 8,844.4 | |
| 12-31-2013 | | | | 4,165.9 | | | | 842.6 | | | | 94,593.4 | | | | 2,192.8 | | | | 62,008.4 | | | | 38,693.7 | | | | (8,301.5 | ) | | | 1,648.8 | |
| 12-31-2014 | | | | 4,691.0 | | | | 870.9 | | | | 97,772.3 | | | | 9,370.8 | | | | 0.0 | | | | 37,002.4 | | | | 51,399.1 | | | | 42,150.5 | |
| 12-31-2015 | | | | 2,591.4 | | | | 519.5 | | | | 58,317.4 | | | | 4,064.0 | | | | 0.0 | | | | 33,642.0 | | | | 20,611.5 | | | | 56,915.5 | |
| 12-31-2016 | | | | 1,253.3 | | | | 347.2 | | | | 38,976.6 | | | | 584.1 | | | | 300.0 | | | | 30,765.8 | | | | 7,326.8 | | | | 61,686.9 | |
| 12-31-2017 | | | | 0.0 | | | | 0.0 | | | | 0.0 | | | | 0.0 | | | | 0.0 | | | | 0.0 | | | | 0.0 | | | | 61,686.9 | |
| 12-31-2018 | | | | 0.0 | | | | 0.0 | | | | 0.0 | | | | 0.0 | | | | 0.0 | | | | 0.0 | | | | 0.0 | | | | 61,686.9 | |
| 12-31-2019 | | | | 0.0 | | | | 0.0 | | | | 0.0 | | | | 0.0 | | | | 0.0 | | | | 0.0 | | | | 0.0 | | | | 61,686.9 | |
| 12-31-2020 | | | | 0.0 | | | | 0.0 | | | | 0.0 | | | | 0.0 | | | | 0.0 | | | | 0.0 | | | | 0.0 | | | | 61,686.9 | |
| 12-31-2021 | | | | 0.0 | | | | 0.0 | | | | 0.0 | | | | 0.0 | | | | 0.0 | | | | 0.0 | | | | 0.0 | | | | 61,686.9 | |
Total | | | | 13,680 | | | | 2,663 | | | | 298,936 | | | | 16,212 | | | | 62,308 | | | | 140,104 | | | | 80,312 | | | | 61,687 | |
| | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | |
PROBABLE(2P)UNDEVELOPED RESERVES
| | | | | | | | | | | | | | | | | | | | | | | | | |
| | | Oil Reserves | | | Future Gross | | | | | | Net Capital | | | Net Operating | | | Future Net | | | Cumulative PWat | |
Period | | | Gross | | | Net | | | Revenue | | | Taxes | | | Costs | | | Expense | | | Revenue | | | 10.0% | |
Ending | | | (MBBL) | | | (MBBL) | | | $(M) | | | $(M) | | | $(M) | | | $(M) | | | $(M) | | | $(M) | |
| | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | |
| 12-31-2012 | | | | 0.0 | | | | (3.0 | ) | | | (337.1 | ) | | | 0.0 | | | | 0.0 | | | | 0.0 | | | | (337.1 | ) | | | (321.4 | ) |
| 12-31-2013 | | | | 3,141.6 | | | | 413.9 | | | | 46,469.6 | | | | 7,602.1 | | | | 0.0 | | | | (744.6 | ) | | | 39,612.0 | | | | 34,013.6 | |
| 12-31-2014 | | | | 3,939.5 | | | | 280.2 | | | | 31,457.0 | | | | 10,724.3 | | | | 0.0 | | | | (733.6 | ) | | | 21,466.3 | | | | 50,928.8 | |
| 12-31-2015 | | | | 3,540.7 | | | | 368.9 | | | | 41,411.2 | | | | 9,838.9 | | | | 0.0 | | | | ( 49.6 | ) | | | 31,621.9 | | | | 73,581.2 | |
| 12-31-2016 | | | | 2,941.9 | | | | 543.7 | | | | 61,030.2 | | | | 8,320.2 | | | | 0.0 | | | | 296.5 | | | | 52,413.5 | | | | 107,714.3 | |
| 12-31-2017 | | | | 2,852.6 | | | | 865.1 | | | | 97,113.4 | | | | 21,612.3 | | | | 0.0 | | | | 34,762.7 | | | | 40,738.4 | | | | 131,832.4 | |
| 12-31-2018 | | | | 2,028.9 | | | | 609.8 | | | | 68,451.0 | | | | 20,262.3 | | | | 0.0 | | | | 29,485.0 | | | | 18,703.7 | | | | 141,898.8 | |
| 12-31-2019 | | | | 1,250.3 | | | | 359.5 | | | | 40,362.8 | | | | 5,209.2 | | | | 0.0 | | | | 29,282.0 | | | | 5,871.6 | | | | 144,771.7 | |
| 12-31-2020 | | | | 0.0 | | | | 0.0 | | | | 0.0 | | | | 0.0 | | | | 0.0 | | | | 0.0 | | | | 0.0 | | | | 144,771.7 | |
| 12-31-2021 | | | | 0.0 | | | | 0.0 | | | | 0.0 | | | | 0.0 | | | | 0.0 | | | | 0.0 | | | | 0.0 | | | | 144,771.7 | |
Total | | | | 19,696 | | | | 3,438 | | | | 385,958 | | | | 83,569 | | | | 0 | | | | 92,298 | | | | 210,090 | | | | 144,772 | |
POSSIBLE(3P)UNDEVELOPED RESERVES
| | | Oil Reserves | | | Future Gross | | | | | | Net Capital | | | Net Operating | | | Future Net | | | Cumulative PWat | |
Period | | | Gross | | | Net | | | Revenue | | | Taxes | | | Costs | | | Expense | | | Revenue | | | 10.0% | |
Ending | | | (MBBL) | | | (MBBL) | | | $(M) | | | $(M) | | | $(M) | | | $(M) | | | $(M) | | | $(M) | |
| | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | |
| 12-31-2012 | | | | 0.0 | | | | 0.0 | | | | 5.3 | | | | 0.0 | | | | 0.0 | | | | 0.0 | | | | 5.3 | | | | 5.0 | |
| 12-31-2013 | | | | 1,757.9 | | | | 168.5 | | | | 18,918.6 | | | | 4,699.8 | | | | 0.0 | | | | (850.8 | ) | | | 15,069.5 | | | | 13,067.0 | |
| 12-31-2014 | | | | 6,947.7 | | | | 1409.4 | | | | 158,214.6 | | | | 15,610.3 | | | | 90,773.3 | | | | (438.4 | ) | | | 52,269.3 | | | | 54,254.5 | |
| 12-31-2015 | | | | 10,078.4 | | | | 3986.1 | | | | 447,484.6 | | | | 244,676.0 | | | | 0.0 | | | | 286.4 | | | | 202,522.2 | | | | 199,331.4 | |
| 12-31-2016 | | | | 7,457.1 | | | | 2916.1 | | | | 327,364.8 | | | | 185,992.4 | | | | 0.0 | | | | 261.3 | | | | 141,111.1 | | | | 291,226.8 | |
| 12-31-2017 | | | | 5,308.5 | | | | 1811.0 | | | | 203,301.6 | | | | 107,119.6 | | | | 0.0 | | | | 205.3 | | | | 95,976.6 | | | | 348,047.4 | |
| 12-31-2018 | | | | 3,782.4 | | | | 1305.0 | | | | 146,497.3 | | | | 70,454.5 | | | | 0.0 | | | | 146.8 | | | | 75,896.0 | | | | 388,895.0 | |
| 12-31-2019 | | | | 2,894.6 | | | | 996.7 | | | | 111,888.4 | | | | 58,653.7 | | | | 0.0 | | | | 156.0 | | | | 53,078.8 | | | | 414.865.2 | |
| 12-31-2020 | | | | 2839.5 | | | | 910.4 | | | | 102202.0 | | | | 37,916.2 | | | | 0.0 | | | | 29,286.3 | | | | 34,999.6 | | | | 430.432.9 | |
| 12-31-2021 | | | | 381.8 | | | | 119.8 | | | | 13450.2 | | | | 4,461.5 | | | | 0.0 | | | | 4,870.4 | | | | 4 118.3 | | | | 432,098.2 | |
Total | | | | 41,448 | | | | 13,623.0 | | | | 1,529,327.4 | | | | 729,584.0 | | | | 90,773.3 | | | | 33,923.3 | | | | 675,046.6 | | | | 432,098.2 | |
Totals may not add because of rounding.
BASED ON SEC PRICE AND COST PARAMETERS
All estimates and exhibits herein are part of this NSAI report and are subject to its parameters and conditions.