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Timur Makhmutov

PhD in Political Science, RIAC Deputy Program Director

Darya Polosina

MSc, MGIMO University, field of study International Economic Law

Anastasia Kosivets

Assistant, Department of International Relations, NRNU MEPhI

Since the end of the past century, the definition of the Arctic as the territory of the dialogue and cooperation has firmly consolidated. The logic of the region itself with its severe and hardly predictable weather conditions encourages it. The search for process solutions and compliance with commitments to responsible activity in such conditions obviously requires joint eff orts of the region’s countries. Accumulated experience of regional cooperation increases the significance of the consensus principle in making decisions and reasonably becomes an important condition for new players in the Arctic region. However, it is impossible to imagine an ideal situation of cooperation in a globalizing world not influenced by international processes from other world’s regions external in relation to the Arctic. The deterioration of relations between Russia and West countries after Ukrainian events of 2013–2014 gradually began to influence the Arctic cooperation becoming an additional factor determining the quality of international interaction in the northernmost region of the world. Despite ongoing constructive contacts within the Arctic Council, many of its members and observers maintain sanctions pressure on Russia.

In 2014, the US and the European Union (EU) introduced restrictive measures against the Russian Federation, which are actively associated with a notion of sanctions in the foreign doctrine.

However, it should be noted that the prevailing point of view in the Russian legal doctrine is that the notions of sanctions and unilateral restrictive measures should not be confused.

Thus, sanctions are of mandatory and vertical nature, while unilateral restrictive measures can be imposed by particular countries and are of horizontal nature, in particular, by virtue of the principle par in parem non habet imperium. Their legitimacy is debatable. Therefore, the measures imposed by the US and the EU are unilateral restrictive measures.

The US and the EU unilateral restrictive measures are aimed at the following:

  • Travel ban and freezing of assets.
  • Prohibition of access to capital markets and loans.
  • Double-purpose goods and technologies.
  • Defense sphere and arms trade.
  • Oil and gas industry (the US measures are aimed at the oil and gas industry in general, while the EU measures mainly concern the oil industry since Europe is a big gas importer).

Despite a similarity of application fields of the US and EU restrictive measures regarding Russia, they are based on different reasonings. The US sanctions activity is primarily associated with the aspiration to exercise a wide deterrent effect on a changing role of Russia in international affairs. The EU uses restrictive measures against Russia to manage the Ukrainian crisis and influence the Russian Federation because of the development of the situation in Ukraine. Taking into account the particularities of the above measures and their legal differences from the UN sanctions, we would mention that the real objectives of negative impact of the restrictions imposed on Russia by the US and the EU are particular persons, companies and projects, while the state is only indirectly concerned.

It is needless to expect a fast growth of economic activity associated with the development of hydrocarbons on the sea shelf in the Arctic. However, prerequisites exist for developing international research projects, building regional economic ties and creating an integrated transport/logistic infrastructure. This becomes difficult to implement under the restrictions consciously imposed by the US and the EU, which do not serve national interests and development goals of Arctic states. Nevertheless, the development of Arctic oil and gas resources was and remains to be one of strategic priorities of the Russian Federation. The difficulties arising in the implementation of this task make for searching comprehensive solutions, which sometimes go beyond narrow areas of activity. Thus, the conditions appear for comprehensive cooperation in the region that may receive a significant positive impetus if the Arctic is exempted from the sanctions confrontation between the US, EU and Russia.

Since the end of the past century, the definition of the Arctic as the territory of the dialogue and cooperation has firmly consolidated. The logic of the region itself with its severe and hardly predictable weather conditions encourages it. The search for process solutions and compliance with commitments to responsible activity in such conditions obviously requires joint eff orts of the region’s countries. Accumulated experience of regional cooperation increases the significance of the consensus principle in making decisions and reasonably becomes an important condition for new players in the Arctic region. However, it is impossible to imagine an ideal situation of cooperation in a globalizing world not influenced by international processes from other world’s regions external in relation to the Arctic. The deterioration of relations between Russia and West countries after Ukrainian events of 2013–2014 gradually began to influence the Arctic cooperation becoming an additional factor determining the quality of international interaction in the northernmost region of the world. Despite ongoing constructive contacts within the Arctic Council, many of its members and observers maintain sanctions pressure on Russia.

In 2014, the US and the European Union (EU) introduced restrictive measures against the Russian Federation, which are actively associated with a notion of sanctions in the foreign doctrine [1].

However, it should be noted that the prevailing point of view in the Russian legal doctrine is that the notions of sanctions and unilateral restrictive measures should not be confused. The term sanctions is directly associated with the UN activity, and they can be introduced to maintain international peace and security only by the decision of the UN Security Council. The notion of sanctions itself was not incorporated in the UN Charter. Article 41 contains an open list of enforcement measures, however, the UN Security Council committees dealing with overseeing the implementation of enforcement measures are called sanctionary, and the Security Council itself considers the measures included in Article 41 of the UN Charter as sanctions [1, p. 206].

Thus, sanctions are of mandatory and vertical nature, while unilateral restrictive measures can be imposed by particular countries and are of horizontal nature [1], in particular, by virtue of the principle par in parem non habet imperium. Their legitimacy is debatable [1]. Therefore, the measures imposed by the US and the EU are unilateral restrictive measures.

The US and the EU unilateral restrictive measures are aimed at the following:

  • Travel ban and freezing of assets.
  • Prohibition of access to capital markets and loans.
  • Double-purpose goods and technologies.
  • Defense sphere and arms trade.
  • Oil and gas industry (the US measures are aimed at the oil and gas industry in general, while the EU measures mainly concern the oil industry since Europe is a big gas importer [2]).

Despite a similarity of application fields of the US and EU restrictive measures regarding Russia, they are based on different reasonings [3]. The US sanctions activity is primarily associated with the aspiration to exercise a wide deterrent effect on a changing role of Russia in international affairs. The EU uses restrictive measures against Russia to manage the Ukrainian crisis and influence the Russian Federation because of the development of the situation in Ukraine. Taking into account the particularities of the above measures and their legal differences from the UN sanctions, we would mention that the real objectives of negative impact of the restrictions imposed on Russia by the US and the EU are particular persons, companies and projects, while the state is only indirectly concerned.

Influence of the US Restrictive Measures on Russian Projects in the Arctic

In 2014, the US was the first to impose restrictive measures against Russia. The US leadership was guided by the following regulatory legal acts to justify the legal aspect of imposing such measures:

  • National Emergencies Act of 1976,
  • International Emergency Economic Powers Act of 1977,
  • Based on the above Laws, the US President Barak Obama issued the following Executive Orders: • Executive Order 13660 of March 6, 2014,
  • Executive Order 13661 of March 17, 2014,
  • Executive Order 13662 of March 20, 2014.

The above regulatory legal acts introduced a number of restrictions for persons and entities to use and manage different types of assets.

The persons and entities (to be determined by the Department of the Treasury Secretary pursuant to Executive Order 13662), which are subject to restrictive measures are listed in respective lists published by the Office of Foreign Assets Control:

  • Sectoral Sanctions Identifications List (SSI List);
  • Specially Designated Nationals List (SDN List).

In July [4] and September 2014, the Office of Foreign Assets Control – OFAC adopted four Directives, in which the oil and gas industry in the Arctic is directly concerned in Directive 4 (of September 12, 2014 pursuant to Executive Order 13662) and indirectly in Directive 1 (of September 12, 2014 pursuant to Executive Order 13662) with respect to the financial services sector of the Russian Federation economy.

Directive 4 directly concern the Russian energy sector prohibiting direct or indirect supply, exportation, or reexportation of goods, services or technology in support of exploration or production for deepwater, Arctic offshore, or shale projects.

According to Directive 1, a number of Russian companies including PJSC Rosneft were deprived of the access to the US dollar funding market, which negatively affected the Arctic projects. The same goes for PAO Gazprom and PAO Lukoil, PAO Gazprom Neft and some others, which suffered from Directives 3 and 4 since they were prohibited to place shares on the US stock exchanges, while the US residents were prohibited to carry out direct or indirect supply, exportation, or reexportation of goods, services or technology in support of exploration or production for deepwater, Arctic offshore, as well as shale projects [2, p. 45].

Also on August 2, 2017, the US Federal Law The Countering America’s Adversaries Through Sanctions Act – CAATSA was adopted that imposed restrictive measures on Russia, Iran, and North Korea. If before the restrictive measures were mandatory for American persons and entities, then CAATSA also provides for the measures against foreign persons cooperating with Russian persons and entities subject to the US restrictive measures [5]. Similar measures were provided by the Ukraine Freedom Support Act – UFSA adopted by the US Congress in 2014, but which were not mandatory [5].

Exxon Mobil is striking example of such a company suffered from restrictive measures.

In July 2017, the Office of Foreign Assets Control (OFAC) fined the American ExxonMobil $2 million for violating US sanctions on Russia. As a result, the company fi led suit against the US Government in the Texas State Court [6].

In May 2014, ExxonMobil made a number of deals (related to oil and gas projects) with the Russian Rosneft, which was not under the US restrictive measures at that time. However, Igor Sechin, CEO of the company, who had already been included in one of the US sanctions lists, SDN, since April 2014, signed the documents for Rosneft [7].

OFAC opinion is that in May 2014 ExxonMobil violated the U.S. Department of Treasury’s sanctions imposed on April 28, 2014 based on Executive Order 13661 by having signed eight legal documents with Rosneft [8].

Exxon Mobile is that at the time of signing the documents, Rosneft was not under sanctions prohibiting the activity under the documents signed by the companies (most of them memorialized the extension of pre-existing agreements, for example, on joint projects in the Arctic and related to natural gas development in the Russian Far East). At the same time, the sanctions were applied to Igor Sechin’s assets and activity only in his individual capacity [8, p. 2], so his activity as the CEO of Rosneft, ExxonMobil thinks, is not covered by the sanctions since the inclusion of a person in SDN was intended to target his personal wealth and not his business actions [8].

OFAC determined that Sechin’s actions constituted a service being a violation of the sanctions regime [7], however, did not argue the legality of deals between ExxonMobil and Rosnef.

OFAC cited FAQ 3 (frequently asked questions) that could be found on the Office website. The question was related to the Myanmar sanctions and removed from the website after the sanctions program was terminated. The question states that a contract with a non-prohibited entity that is signed by an SDN may result in a violation [7].

ExxonMobil states that this source cannot be cited since it deals with other restrictive measures and such an interpretation is not acceptable by virtue of Title 31 of the Code of Federal Regulations (C.F.R. par. 598.101) [9].

In particular, ExxonMobil in support of its position cited the White House guidance regarding the Executive Order 13661 [8, p. 3], according to which the sanctions targeted the personal assets of certain individuals designated in their individual capacities, and not the deals with the companies employing them. Also referring Barak Obama’s and senior administration officials’ statements [8, p. 9], who emphasized that the sanctions on Igor Sechin covered his personal capacity and concerned his property, property interests and assets that had been frozen (according to the US President Executive Order 13661), but did not prohibit to do business with Rosneft (because he does not own the company) [8, p. 9].

The above is the main ExxonMobil’s arguments in challenging the Administrative Procedure Act (APA) issued by OFAC and by virtue of which a penalty was imposed on the company. Also ExxonMobil indicated that OFAC sought to retroactively enforce a new interpretation of the US President Executive Order 13661 and stressed that business relationship with Rosneft had begun long before 2014 [8, p. 8]. For example, cooperation on the projects in the Russian Far East began in the 1990s. In 2011, ExxonMobil Development Company and Rosneft concluded a Strategic Cooperation Agreement in the Kara Sea and Black Sea basins, as well as in 2013 an agreement with respect to joint projects in the Arctic was concluded. The 2014 agreements did not create additional obligations or rights of the parties, but extended and added the existing ones [8, p. 7].

Ivan Panichkin:
To Explore and Develop

Thus, ExxonMobil, interpreting the US President Executive Order 13661 provisions actively cites the White House representatives and the Department of the Treasury Secretary officials, The Wall Street Journal articles [8, p. 13] and other sources which are not of regulatory nature.

According to Daniel Pilarski, the ExxonMobil mistake is to cite and be guided by informal rules and guidance not having legal force. According to him, the parties should have agreed on the condition that representatives of the company taking part in the deal were not subject to sanctions and performed due diligence to previously carry out relevant check [7].

As of March 2018, the BBC Russian Service reports that ExxonMobil now pulls out of joint projects with Rosneft [10]. The company was involved in the activity in the Arctic (the Kara, Chukchee and Laptev Seas), as well as the Black Sea that will result in financial losses not only for ExxonMobil, but significantly slow down the development of the Russia’s continental shelf. Among joint projects, only the Sakhalin-1 Project is not subject to sanctions [10].

Arctic Dimension of the EU Restrictive Measures in Relation to Russia

On July 31, 2014, the Council Regulation No. 833/2014 concerning restrictive measures in view of Russia’s actions destabilising the situation in Ukraine was issued by the EU Council decision [11].

Restrictive measures imposed by the EU [12]:

  • the Council imposes EU restrictive measures through a CFSP Council decision. While this decision contains all measures imposed, additional legislation may be needed to give full legal effect to the sanctions in EU member states;
  • valid within EU territory, as well as on board of aircrafts or vessels under the jurisdiction of a member state;
  • binding on EU member states persons and entities including branches irrespective of the country.

The measures imposed can be challenged in Court.

The EU recommends third countries to impose similar sanctions on Russia [2, p. 57].

The activity in the Arctic is directly concerned with Article 3 of the above Regulation: prohibition was imposed for any sale, supply, transfer or export of technologies for use in deep water oil production, Arctic oil exploration and production, or shale oil projects. The list of technologies is given in Annex II. Also Article 3 item 3 states that the technologies listed in Annex II cannot be sold, transferred and supplied if there is a reason to suppose that they will be used in projects associated with Arctic oil production, deep water oil production and projects associated with shale oil production.

Also according to Article 5 Gazprombank, Sberbank and some others (listed in Annex II to the Regulation are subject to restrictions: the EU residents are prohibited to carry out operation with securities issued by the above entities, as well as entities acting on behalf or owning over 50 percent of the above organizations (if the entities were established inside the EU). Also Gazprombank and other ones listed in Annex III are prohibited to provide investment services.

Such restrictions negatively impact Russian oil and gas industry since it significantly depends on foreign know-how and technologies despite import substitution programs.

Threats and Challenges for Russia’s Arctic Activity under Sanctions

Currently, the success of developing Arctic hydrocarbon deposits depends to a great extent on international cooperation effectiveness. At the same time, the combinations of project participants can be quite different in terms of their involvement in a project. The most in-demand are attracting technologies and attracting investment. It is in these areas that the US and the EU seek to maximally restrict reference projects in the Arctic with Russia participation. Moreover, such projects as Prirazlomnoe [13] and Shtokman [14] obtained international significance due to the interest in them from large international players. This allowed to attract attention to international economic cooperation prospects in the region, show the possibility and interest of business in developing large-scale projects and complementarity of participants in using technologies.

In determining technological efficiency, it should be noted the importance of such underwater facilities as underwater pipelines, drilling installations, pumping systems and hydrocarbon treatment systems [15]. Their attractiveness is to a great extent provided by the possibility of year-round use irrespective of ice conditions in the Arctic.

The world leaders in developing and manufacturing equipment for offshore hydrocarbon deposits are American FMC Technologies, Cameron, GE Vetco, and Aker Solutions (Subsea) (Norway). The German Siemens и MAN also develop underwater equipment and technologies. Russia also has its technological solutions, for example, Lazurit CDB [16]. The Norwegian Statoil occupies leading positions in using underwater hydrocarbon production technologies. The development of the Ormen Lange field located in the Barents Sea and developed by this company since 2007 has become a good illustration. As B. Vasiliev notes, in the beginning of its development “at the stage of drilling production wells, a sea floor template with well slots was installed at each wellhead of cluster, onto which an underwater production unit (UPU) was placed. It includes a manifold and all the necessary set of wellhead equipment to safely extract hydrocarbons [15].” Then the hydrocarbon flow consisting of a mixture of oil, gas and condensate, sand and water is transported via a 160-km long underwater pipeline to a processing plant located near Hammerfest where hydrocarbons are separated and treated. Next, gas is liquefied and prepared for loading into tankers, while separated carbon dioxide gas is pumped back into wells [15].

According to Law On Subsurface Resources of February 21, 1992 (as amended in 2008), the range of companies in Russia, which can be provided with licenses to use the Russian Federation continental shelf sites of subsurface resources, is limited. Currently, only PAO NK Rosneft and PAO Gazprom, which are permitted to operate on the shelf, fully comply with the applicable legislation. Rosneft has 7 licensed sites in the Barents Sea; 8 – in the Pechora; 4 – in the Kara; 5 – in the Laptev; 1 – in the East Siberian, and 3 – in the Chukchee Sea [17]. Gazprom has 7 licensed sites in the Barents Sea; 3 – in the Pechora; 13 – in the Kara Sea; 8 – in the Gulf of Ob, and 1 – in the East Siberian Sea [18].

Positive results of production on the Prirazlomnoe field discovered in 1989 in the Pechora Sea allowed to ship and deliver 300 thousand tons of oil to the port of Rotterdam in 2014 (about 2.2 million barrels) [19]. The oil produced was called Arctic Oil (ARCO) [20]. Currently, this is the only project on the Russian Arctic shelf, where oil is commercially produced. This gives additional advantages for Gazprom, which owns the project. In this context, Rosneft, which also develops the shelf, has no active underwater production projects, which is very important for operations on the deep water Arctic shelf, nor has active projects on the Arctic shelf.

The situation also worsens due to the fact that Rosneft and Gazprom cannot involve foreign partners with their technologies in exploration and production. Other Russian companies, as previously noted, have no access to the shelf due to legislation requirements [21]. Russia technologically depends on Western partners in oil and gas production, mainly on offshore drilling rigs, pump-and-compressor and downhole equipment, power generation equipment and software [22]. As Gazprom Neft notes on its website, there are difficulties [23] in searching for a drilling rig, primarily self-elevating floating drilling rigs (SEFDR) designed or able to operate in severe Arctic conditions. Referring to Fearnley Offshore brokerage fi rm Gazprom Neft notes that about 50 of existing SEFDRs are fi t for operation in northern seas [23]. Taking into account a high demand, most of them have already been freighted by foreign companies.

The use of equipment and services from third countries, primarily China, increases risk of accidents due to a lower quality of the products. At the same time, the replacement of a number of goods by domestic analogs is possible approximately not until 2020–2025 [24]. Several projects of developing domestic technologies for exploration on the shelf have been selected by the Ministry of Industry and Trade of Russia [25] for funding, however, there is still a long way to go to create real products and their use in production, and the final result is not clear. Much will depend on the development of efficient research, experimental, production/testing, and planning/budgeting infrastructure [15].

In addition, import substitution projects depend on different external factors: economic, politico-economic, environmental and technological ones.

Economic reasons explicitly refer to the level of profitability of hydrocarbon production in the Arctic. By some estimates, Arctic fields would be profitable at the average price of 110 dollars per oil barrel [26]. However, the high volatility of oil prices with the average prices significantly lower than the above ones challenges the active development of Arctic fields. Moreover, the level of development of transport infrastructure remains the key factor for any projects in the Arctic.

Restrictive measures imposed by the US and the EU against Russia occupy not last place in this list. In this context, the development of new projects in the Russian Arctic is extremely difficult. However, the damage infringed to real economic contacts and projects can have much more far-reaching consequences than deterioration of relations between the US, EU and Russia.

Despite noticeable climate warming in the Arctic, the region remains to be complex from the climatic point of view. It is this aspect that puts into the forefront the environmental component and need for the most thorough approach to environmental protection and use of the most perfect and protected technologies. Currently, in fact, no effective methods exist to deal with oil spills in harsh conditions of the Far North involving a specific alternation of day and night and considerable remoteness, thousands of kilometers, from industrial urban centers. Consequences of oil spills and other unfavorable human-induced events for vulnerable Arctic nature can be disastrous since it is extremely difficult to organize prompt mitigation of such consequences. In view of the above restrictions, the Ministry of Natural Resources and Environment of Russia is in favor of extending the moratorium on issuing production licenses for the Arctic shelf [27] introduced in 2016 [28]. These conditions create good prerequisites for extensive scientific work involving foreign researchers to search for effective methods of combating oil spills in Arctic conditions.

In terms of technologies, the Arctic requires the use of new types of equipment for development and exploratory drilling designed for year-round and long-term autonomous operation in the Arctic shelf conditions. The innovation component is of huge importance here. This may refer to the use of artificial intelligence in managing drilling rigs and introducing new types of equipment to monitor the state of pipelines, pumping stations, and power generation and supply systems.

The above reasons quite clearly show it is needless to expect a fast growth of economic activity associated with the development of hydrocarbons on the sea shelf in the Arctic. However, prerequisites exist for developing international research projects, building regional economic ties and creating an integrated transport/logistic infrastructure. This becomes difficult to implement under the restrictions consciously imposed by the US and the EU, which do not serve national interests and development goals of Arctic states. Nevertheless, the development of Arctic oil and gas resources was and remains to be one of strategic priorities of the Russian Federation. The difficulties arising in the implementation of this task make for searching comprehensive solutions, which sometimes go beyond narrow areas of activity. Thus, the conditions appear for comprehensive cooperation in the region that may receive a significant positive impetus if the Arctic is exempted from the sanctions confrontation between the US, EU and Russia.

List of References

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2. Клишас А.А. Политико-правовой анализ ограничительных мер, введенных в отношении Российской Федерации, ее граждан и юридических лиц некоторыми интеграционными объединениями и зарубежными государствами // Вестник РУДН. 2016. № 1. С. 53.

3. Тимофеев И.Н. Санкции против России: направления эскалации и политика противодействия. Доклад РСМД № 37/2018. М.: НП РСМД, 2018. – [Электронный ресурс]: URL: http://russiancouncil.ru/papers/Sanctions-Report37ru.pdf

4. Директивы № 2 и 3 от 16 июля 2014 г. и от 12 сентября 2014 г. соответственно — во исполнение Указа Президента 13662.

5. РБК: США начнут по всему миру преследовать за помощь россиянам под санкциями // Сайт РБК. 01.11.2017. URL: https://www.rbc.ru/economics/01/11/2017/59f995d19a79477abe151714?from=materials_on_subject

6. Exxon оспорит в суде штраф Минфина США за сделки с Сечиным // Сайт Reuters. 21.07.2017. URL: https://ru.reuters.com/article/topNews/idRUKBN1A60TF-ORUTP

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8. ExxonMobil vs. US. Complaint Civ. No. 3:17-cv-1930. P. 1.

9. US GPO 31 CFR 598.101 - Relation of this part to other laws and regulations. URL: https://www.gpo.gov/fdsys/search/pagedetails.action?collectionCode=CFR&browsePath=Title+31%2FSubtitle+B%2FCha pter+V%2FPart+598%2FSubpart+A%2FSection+598.101&granuleId=CFR-2014-title31-vol3-sec598101&packageId=CFR-2014-title31-vol3&collapse=true&fromBrowse=true

10. «Дело к этому шло»: Exxon выходит из совместных проектов с Роснефтью // BBC Русская служба. 01.03.2018. URL: http://www.bbc.com/russian/news-43237775

11. EUR-Lex. Council Regulation (EU) No 833/2014 of 31 July 2014 concerning restrictive measures in view of Russia’s actions destabilising the situation in Ukraine. URL: https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32014R0833

12. Информационный листок об ограничительных мерах ЕС от 29 апреля 2014 г. (EU restrictive measures factsheet). URL: https://www.consilium.europa.eu/media/24503/135804.pdf

13. Проект «Приразломное» // Сайт «Газпромнефть». URK: http://www.gazprom-neft.ru/company/business/exploration-and-production/new-projects/prirazlomnoe/

14. Штокмановский проект // Сайт компании «Штокман Девелопмент АГ». URL: http://www.shtokman.ru/project/

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16. Подводные буровые комплексы // Cайт АО Центрального конструкторского бюро «Лазурит». URL: http://www.cdb-lazurit.ru/burovie_kompleksi.html

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19. Разработка морских нефтегазовых ресурсов Арктики: ридер РСМД // Сайт Российского совета по международным делам. URL: http://russiancouncil.ru/arcticoil

20. Подробнее см. Приразломное месторождение // Сайт ПАО «Газпром». URL: http://www.gazprom.ru/about/production/projects/deposits/pnm/

21. Бузовский В.В. Факторный анализ условий освоения арктического шельфа РФ. Различия стратегий ПАО «НК «Роснефть» и ПАО «Газпром» // Сайт Pro-Arctic. URL: http://pro-arctic.ru/01/11/2016/ resources/23925

22. Ампилов Ю.П. Сейсморазведка на российском шельфе в условиях санкций и низких цен на нефть // Технологии сейсморазведки. 2015. № 4. С. 5–14.

23. Разведка морем // Сайт «Газпром нефть». URL: http://www.gazprom-neft.ru/press-center/sibneft-online/archive/2014-july-august/1104872/

24. Макова Е. Перспективы и проблемы освоения запасов углеводородов Арктического шельфа // Сайт Центра информационного и правового обеспечения развития Арктики. 26.03.2017. URL: http://arctic-centre.com/ru/analitika/item/250-perspektivy-i-problemy-osvoeniya-zapasov-uglevodorodov-arkticheskogoshelfa

25. Минпромторг занялся арктической инженерией // Сайт газеты «Коммерсант». 25.01.2017. URL: https://www.kommersant.ru/doc/3200888

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27. Правительство ввело временный мораторий на выдачу лицензий на шельфе // РБК. 07.09.2016. URL: https://www.rbc.ru/business/07/09/2016/57cff64b9a794724e40ebb7d

28. Минприроды считает преждевременным снятие моратория на выдачу лицензий на шельфе в Арктике // ТАСС. 17.08.2018. URL: https://tass.ru/ekonomika/5465882


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