Iraq

Each of the companies in the following table imported crude oil from Iraq in 1997. In the following table we have listed each company's regional production, ⁽¹⁾ each company's imports of crude oil from Iraq into the region, ⁽²⁾ and the ratio of the company's regional imports from Iraq to its regional production.

Mexico

Each of the companies in the following table imported crude oil from Mexico in 1997. In the following table we have listed each company's regional production, ⁽³⁾ each company's imports of crude oil from Mexico into the region, ⁽⁴⁾ and the ratio of the company's regional imports from Mexico to its regional production.

Saudi Arabia

Each of the companies in the following table imported crude oil from Saudi Arabia in 1997. In the following table we have listed each company's regional production, ⁽⁵⁾ each company's imports of crude oil from Saudi Arabia into the region, ⁽⁶⁾ and the ratio of the company's regional imports from Saudi Arabia to its regional production.

Venezuela

Each of the companies in the following table imported crude oil from Venezuela in 1997. In the following table we have listed each company's regional production, ⁽⁸⁾ each company's imports of crude oil from Venezuela into the region, ⁽⁹⁾ and the ratio of the company's regional imports from Venezuela to its regional production.

ARCO

The following facts regarding ARCO's oil exploration, development and production activities are relevant to its stake in the domestic industry.

• In its July 28, 1999, survey response, ARCO reported that in 1997 it produced [ * * * ] barrels of crude oil in the United States, including [ * * * ] barrels in the region.
• ARCO's 1997 production of crude oil makes it the ninth largest producer in the region, accounting for [ * * * ] percent of total regional production.

• ARCO's 1997 Form 10-K at page 2 shows that at the end of 1997 the company's net proved reserves of crude oil in the United States amounted to 2.131 billion barrels.
• ARCO's 1997 Form 10-K does not isolate regional reserves from U.S. reserves. However, ARCO's 1998 annual report states that ARCO has 492 million barrels in proved reserves in the lower 48 states (i.e., excluding Alaska and Hawaii, but including other PADD V states). ⁽¹¹⁾ We estimated that, in 1997, ARCO's net proved regional reserves were at least 387 million barrels.
• According to page 4 of ARCO's 1997 Form 10-K, as of December 31, 1997, the company had 334,000 proved net undeveloped acres and 331,000 proved net developed acres of oil and gas properties in the lower 48 states (excluding 1,659,000 acres held by Vastar).
• According to pages 3-4 of ARCO's 1997 Form 10-K, as of December 31, 1997, ARCO was in the process of drilling 47 net wells in the United States, had completed 438 net exploratory and development wells in 1997, and had 5,146 net productive oil wells (excludes productive wells held or drilled by Vastar).
• According to page 53 of ARCO's 1997 Form 10-K, in 1997 ARCO incurred $1.212 billion worth of capital expenditures for property acquisition, exploration, and production activities in the United States.
• As an additional measure of ARCO's stake in the regional industry over the long term, we divided its 1997 estimated regional reserves by its regional production. The resulting value indicates that ARCO can produce for [ * * * ] years at its 1997 rate, assuming it does not purchase or find more reserves, before depleting its reserves.

The above data supports that ARCO has a substantial and long-term stake in the regional crude-oil industry.

BP Amoco

The following facts regarding BP Amoco's oil exploration, development and production activities are relevant to its stake in the industry.

• In its July 26, 1999, survey response, BP Amoco reported that in 1997 it produced 316.82 million barrels of crude oil in the United States, including 135.05 million barrels in the region.
• BP Amoco's 1997 production of crude oil makes it the largest producer in the region, accounting for [ * * * ] percent of total regional production.

• BP Amoco's 1998 20-F form at page 12 shows that at the end of 1997 the company's net proven reserves of crude oil in the United States amounted to 3.961 billion barrels, including 1.625 billion barrels of proven reserves in the region.
• According to page F-96 of BP Amoco's 1998 20-F form, as of December 31, 1998 (1997 data was unavailable), the company had 5.216 million proved net undeveloped acres and 3.865 million proved net developed acres of oil and gas properties in the United States.
• According to page F-96 of BP Amoco's 1998 20-F form, BP Amoco had 9,542.30 net wells in the United States producing or capable of producing oil in 1998 (1997 figures were unavailable).
• According to page F-97 of BP Amoco's 1998 20-F form, BP Amoco was in the process of drilling 24.4 net exploratory wells in the United States and had completed 89.8 net development wells in 1998 (1997 figures were unavailable).
• According to page F-97 of BP Amoco's 1998 20-F form, BP Amoco completed 27.2 net productive exploratory oil and gas wells and 258.8 net productive development wells in the United States in 1997.
• According to page F-48 of BP Amoco's 1998 20-F form, BP Amoco had 8,450 employees involved in exploration and production (as opposed to refining and marketing) activities in the United States in 1997.
• According to page 8 of BP Amoco's 1998 20-F form, BP Amoco stated that its "exploration program focuses on areas which have been relatively unexplored for political or technical reasons, and where we believe substantial volumes of low cost, high value reserves remain to be found. We are concentrating our exploration activity in areas of recent success, such as ... the deep waters of the US Gulf of Mexico."
• According to page 16 of BP Amoco's 1998 20-F form, BP Amoco's "development expenditure in the USA (excluding pipelines) during 1998 was $1,670 million, compared with $1,744 million in 1997" and that "production comes from a large number of fields situated principally in the states of Alabama, Colorado, Kansas, Louisiana, New Mexico, Oklahoma, Texas and Wyoming."

• As an additional measure of BP Amoco's stake in the regional industry over the long term, we divided its 1997 regional reserves by its regional production. The resulting value indicates that BP Amoco can produce for [ * * * ] years at its 1997 rate, assuming it does not purchase or find more reserves, before depleting its reserves.

The above data supports that BP Amoco has a substantial and long-term stake in the regional crude-oil industry.

Chevron

The following facts regarding Chevron's oil exploration, development and production activities are relevant to its stake in the domestic industry.

• In its July 16, 1999, survey response, Chevron reported that in 1997 it produced 125.305 million barrels of crude oil in the United States, including 81.87 million barrels in the region.
• Chevron's 1997 production of crude oil makes it the third largest producer in the region, accounting for 5.28 percent of total regional production.

• Chevron's 1998 Form 10-K at page 36 shows that at the end of 1997 the company's net proven reserves of crude oil in the United States amounted to 1.196 billion barrels.
• According to page 4 of Chevron's August 3, 1999, submission, approximately 60 percent, or 717.6 million barrels' worth of Chevron's net proved reserves are located in the region.
• According to page 9 of Chevron's 1997 Form 10-K, as of December 31, 1997, the company had 2.493 million proved net developed acres of oil and gas properties in the United States. ⁽¹²⁾
• At the end of 1997 Chevron was in the process of drilling 228 net wells in the United States and during the year had completed 617 productive net wells (wells that were producing or capable of producing oil). At the end of 1997, Chevron owned 13,085 net wells in the United States that were producing or capable of producing crude oil. ⁽¹³⁾
• In 1997 Chevron completed fifty-six net productive exploratory oil and gas wells in the United States. See page 8 of Chevron's 1997 Form 10-K.
• In 1997 Chevron's capital expenditures for U.S. exploration and production were $1.4 billion, ⁽¹⁴⁾ its U.S. payroll in exploration and production related operations was $235 million, and it had expenditures of $30 million for contractor employees who were engaged entirely in its U.S. exploration and production activity. ⁽¹⁵⁾
• On page 3 of its 1997 Form 10-K, Chevron discusses its plans to add more than 2 billion barrels of reserves from Gulf of Mexico deepwater projects.
• In 1997, Chevron's pretax earnings from U.S. upstream production activities equaled $1.5 billion.  See FS-33 of Chevron's 1998 Form 10-K.

• As an additional measure of Chevron's stake in the regional industry over the long term, we divided its 1997 regional reserves by its regional production. The resulting value indicates that Chevron can produce for 8.77 years at its 1997 rate, assuming it does not purchase or find more reserves, before depleting its reserves.

The above data supports that Chevron has a substantial and long-term stake in the regional crude-oil industry.

Coastal

The following facts regarding Coastal's oil exploration, development and production activities are relevant to its stake in the domestic industry.

• In its July 13, 1999, survey response, Coastal reported that in 1997 it produced [ * * * ] barrels of crude oil in the United States. All of this production took place within the region.
• Coastal's 1997 production accounted for [ * * * ] percent of total regional production.

• In 1997 Coastal held 40.143 million barrels of proven reserves in the United States. See Coastal's 1997 Form 10-K, at F-40.
• According to page 12 of Coastal's 1997 Form 10-K, at the end of 1997 the company had .5 million net undeveloped acres and .524 million net developed acres of oil and gas properties in the United States. The domestic net developed acreage is concentrated principally in Texas (36%), Utah (26%), offshore Gulf of Mexico (19%), Kansas (6%) and Wyoming (6%), all of which are part of the region.
• In 1997 Coastal owned 727 net wells in the United States that were producing or were capable of producing oil. See Coastal's 1997 Form 10-K, at 12.
• In 1997 Coastal did not complete any exploratory oil wells, but it completed 1.7 development oil wells in the United States. See 1997 Form 10-K, at 13.

• At the end of 1997, Coastal held interests in 110 blocks and 49 platforms in the Gulf of Mexico, with net natural gas production of 173 MMcf per day and 4,156 barrels per day of oil and condensate (about 26 percent of its regional crude-oil production). The company operates 36 of the platforms. See Coastal's 1997 Form 10-K, at 13.
• Coastal's 1997 operating profit from its U.S. exploration and production operations was $185.6 million. See Coastal's 1997 Form 10-K, at F-7.

• As an additional measure of Coastal's stake in the regional industry over the long term, we divided its 1997 regional reserves by its regional production. The resulting value indicates that Coastal can produce for 6.92 years at its 1997 rate, assuming it does not purchase or find more reserves, before depleting its reserves.

The above data supports that Coastal has a substantial and long-term stake in the regional crude-oil industry.

Conoco

The following facts regarding Conoco's oil exploration, development and production activities are relevant to its stake in the domestic industry.

• In its August 3, 1999, survey response, Conoco reported that in 1997 it produced 21.231 million barrels of crude oil in the United States, all of which was in the region.
• Conoco's 1997 production of crude oil makes it the tenth largest producer in the region, accounting for 1.4 percent of total regional production.

• Conoco's 1997 10-K form at page 15 shows that at the end of 1997 the company's net proved reserves of crude oil in the United States amounted to 0.277 billion barrels. Because all of Conoco's production was located in the region, we presume that all of Conoco's proven reserves are located in the region.
• According to page 70 of Conoco's 1997 Form 10-K, as of December 31, 1997, the company had 2.103 million proved net undeveloped acres and 1.559 million proved net developed acres of oil and gas properties in the United States.
• According to page 69 of Conoco's 1997 Form 10-K, as of December 31, 1997, Conoco was in the process of drilling nine net wells in the United States, had completed 149.5 net wells in 1997, and had 2,523 net productive oil wells.
• As an additional measure of Conoco's stake in the regional industry over the long term, we divided its 1997 estimated regional reserves by its regional production. The resulting value indicates that Conoco can produce for 13.1 years at its 1997 rate, assuming it does not purchase or find more reserves, before depleting its reserves.

The above data supports that Conoco has a substantial and long-term stake in the regional crude-oil industry.

Exxon

The following facts regarding Exxon's oil exploration, development and production activities are relevant to its stake in the domestic industry.

• In its July 26, 1999, survey response, Exxon reported that in 1997 it produced 204.035 million barrels of crude oil in the United States, including 76.65 million barrels in the region.
• Exxon's 1997 production of crude oil makes it the fourth largest producer in the region, accounting for 5.0 percent of total regional production.

• Exxon's 1997 10-K405 form at page F24 shows that at the end of 1997 the company's net proven reserves of crude oil in the United States amounted to 2.377 billion barrels.
• Because neither Exxon's 1997 10-K405 form nor its 1998 10-K form allows us to isolate regional reserves from U.S. reserves, we estimated Exxon's net proven reserves located in the region. ⁽¹⁶⁾ We estimated that, in 1997, Exxon's net proven regional reserves were at least 820.0 million barrels.
• According to page 3 of Exxon's 1997 Form 10-K405, as of December 31, 1997, the company had 4.534 million proved net undeveloped acres and 3.488 million proved net developed acres of oil and gas properties in the United States.
• According to page 2 of Exxon's 1997 Form 10-K405, Exxon had 5,948 net wells in the United States producing or capable of producing oil in 1997.
• According to pages 5 and 6 of Exxon's 1997 Form 10-K405, Exxon was in the process of drilling 59 net wells in the United States and had completed 228 productive net wells (wells that were producing or capable of producing oil) in 1997.
• According to page 5 of Exxon's 1997 Form 10-K405, Exxon completed nine productive exploratory oil and gas wells in the United States in 1997.
• According to page 4 of Exxon's August 4, 1999, submission, Exxon had 4,000 employees involved in exploration and production (as opposed to refining and marketing) activities in the United States in 1997.
• According to page F24 of Exxon's 1998 Form 10-K, Exxon invested $1.341 billion in additions to property, plant and equipment for exploration and production (not including refining and marketing activities) in 1997 and it had $13.752 billion of exploration and production assets in the United States.
• According to page F24 of Exxon's 1998 Form 10-K, Exxon earned $1,634 million after taxes from exploration and production activities in the United States.

• Exxon's 1998 annual report ⁽¹⁷⁾ demonstrates that it is deeply involved in exploration and production in the region, especially in the Gulf of Mexico. For example, Exxon's 1998 annual report states that "{f}ive deepwater Gulf of Mexico projects are expected to come on stream by 2002, with gross daily production rates targeted at 325,000 barrels of liquids."
• Exxon's 1997 10-K405 form states, at page 6, that "Exxon's net acreage in the Gulf of Mexico at year-end 1997 was 2.0 million acres. A total of 47.2 net exploratory and development wells were completed during the year" in the Gulf of Mexico.

• As an additional measure of Exxon's stake in the regional industry over the long term, we divided its 1997 estimated regional reserves by its regional production. The resulting value indicates that Exxon can produce for 10.7 years at its 1997 rate, assuming it does not purchase or find more reserves, before depleting its reserves.

The above data supports that Exxon has a substantial and long-term stake in the regional crude-oil industry.

Fina

The following facts regarding Fina's oil exploration, development and production activities are relevant to its stake in the domestic industry.

• In its July 19, 1999, survey response, Fina reported that in 1997 it produced [ * * * ] million barrels of crude oil in the United States, all of which was in the region.
• Fina's 1997 production of crude oil makes it the fifty-third largest producer in the region, accounting for [ * * * ] percent of total regional production.

• Fina's 1997 10-K form at page 37 shows that at the end of 1997 the company's net proved reserves of crude oil in the United States amounted to 33.4 million barrels. Because all of Fina's production was located in the region, we presume that all of Fina's proved reserves are located in the region.
• According to page 4 of Fina's 1997 Form 10-K, as of December 31, 1997, the company had 228,062 proved net developed acres of oil and gas properties in the United States.
• According to page 4 of Fina's 1997 Form 10-K, as of December 31, 1997, Fina was in the process of drilling 4.6 net wells in the United States, had completed 59.3 net exploratory and development wells in 1997, and had 430 net productive oil wells.
• According to page 32 of Fina's 1998 Form 10-K, Fina invested $125.4 million in capital expenditures for U.S. exploration and production in 1997.
• As an additional measure of Fina's stake in the regional industry over the long term, we divided its 1997 presumed regional reserves by its regional production. The resulting value indicates that Fina can produce for [ * * * ] years at its 1997 rate, assuming it does not purchase or find more reserves, before depleting its reserves.

The above data supports that Fina has a substantial and long-term stake in the regional crude-oil industry.

Marathon

The following facts regarding Marathon's oil exploration, development and production activities are relevant to its stake in the domestic industry.

• In its July 14, 1999, survey response, Marathon reported that in 1997 it produced 37.376 million barrels of crude oil in the United States, including 37.013 million barrels in the region.
• Marathon's 1997 production of crude oil makes it the seventh largest producer in the region, accounting for 2.4 percent of total regional production.

• According to U-32 of USX Corp.'s 1997 10-K form, at the end of 1997 the company's net proven reserves of crude oil in the United States amounted to 609 million barrels, all of which were in the region.
• According to page 13 of USX Corp.'s 1997 10-K form, as of December 31, 1997, the company had 1.451 million proved net undeveloped acres and 0.995 million proved net developed acres of oil and gas properties in the United States.
• According to page 18 of USX Corp.'s 1997 10-K form, Marathon had 3,755 net wells in the United States producing or capable of producing oil in 1997.
• According to page 7 of USX Corp.'s 1997 10-K form, Marathon completed four net productive exploratory oil and gas wells and 44 net productive development wells in the United States in 1997.

• According to page U-32 of USX Corp.'s 1997 10-K form, Marathon incurred $713 million in costs for property acquisition, exploration, and development in the United States.
• According to page U-31 of USX Corp.'s 1997 10-K form, Marathon earned $339 million as a result of its oil- and gas-producing activities (as opposed to refining and marketing activities) in the United States.
• According to page 15 of USX Corp.'s 1997 10-K form, "the principal domestic producing areas are located in Texas, the U.S. Gulf of Mexico, Wyoming, New Mexico and Oklahoma," all of which are in the region.

• As an additional measure of Marathon's stake in the regional industry over the long term, we divided its 1997 regional reserves by its regional production. The resulting value indicates that Marathon can produce for 16.5 years at its 1997 rate, assuming it does not purchase or find more reserves, before depleting its reserves.

The above data supports that Marathon has a substantial and long-term stake in the regional crude-oil industry.

Mobil

The following facts regarding Mobil's oil exploration, development and production activities are relevant to its stake in the domestic industry.

• In its July 21, 1999, survey response, Mobil reported that in 1997 it produced [ * * * ] barrels of crude oil in the United States, including [ * * * ] barrels in the region.
• Mobil's 1997 production of crude oil makes it the eighth largest producer in the region, accounting for [ * * * ] percent of total regional production.

• Mobil's 1997 10-K form at page 55 shows that at the end of 1997 the company's net proven reserves of crude oil in the United States amounted to 539 million barrels.

• Because neither Mobil's 1997 10-K form nor its 1998 10-K form allow us to isolate regional reserves from U.S. reserves, we estimated Mobil's net proven reserves located in the region. ⁽¹⁸⁾ We estimated that, in 1997, Mobil's net proven regional reserves were at least [ * * * ] barrels.
• According to page 13 of Mobil's 1997 Form 10-K, as of December 31, 1997, the company had 2.016 million proved net undeveloped acres and 2.654 million proved net developed acres of oil and gas properties in the United States.
• According to page 12 of Mobil's 1997 Form 10-K, Mobil had 2,904 net wells in the United States producing or capable of producing oil in 1997.
• According to pages 12 and 13 of Mobil's 1997 Form 10-K, Mobil was in the process of drilling six net wells in the United States, completed 13 productive net exploratory wells, and completed 229 productive net development wells in 1997.
• According to page 5 of Mobil's July 21, 1999, submission, Mobil had 1,800 employees involved in exploration and production (as opposed to refining and marketing) activities in the United States in 1997.
• According to page 22 of Mobil's 1997 Form 10-K, Mobil invested $2.887 billion in additions to property, plant and equipment for exploration and production (not including refining and marketing activities) in 1997 and it had $14.393 billion of exploration and production assets in the United States.
• According to pages 3-4 of Mobil's 1997 Form 10-K, "the Gulf of Mexico continental shelf operation continued to be a significant contributor for Mobil, accounting for approximately 25 percent of total U.S. production. In Mobile Bay, offshore Alabama, activity levels remained high in 1997 with the streaming of the Aloe Bay well, and the successful bidding of four more offshore blocks. Drilling is currently in progress at Mobile 823-A5 and in Block 914, immediately to the south of the Mobile Bay operation. Both wells are expected to be on stream in the spring of 1998. In DEEPWATER Gulf of Mexico, Mobil increased its presence by successfully bidding on over 20 additional blocks in 1997, and now holds working interests in over 240 blocks of deepwater acreage. Mobil signed a contract to secure a deepwater drillship for a three-year period commencing in the fourth quarter of 1998."

• As an additional measure of Mobil's stake in the regional industry over the long term, we divided its 1997 estimated regional reserves by its regional production. The resulting value indicates that Mobil can produce for 6.2 years at its 1997 rate, assuming it does not purchase or find more reserves, before depleting its reserves.

The above data supports that Mobil has a substantial and long-term stake in the regional crude-oil industry.

Murphy

The following facts regarding Murphy's oil exploration, development and production activities are relevant to its stake in the domestic industry.

• In its July 15, 1999, survey response, Murphy reported that in 1997 it produced 3.491 million barrels of crude oil in the United States, all of which was in the region.
• Murphy's 1997 production of crude oil makes it one of the top fifty largest producers in the region, accounting for 0.23 percent of total regional production.

• Murphy's 1997 10-K form at page F-23 shows that at the end of 1997 the company's net proven reserves of crude oil in the United States amounted to 19.1 million barrels. Because all of Murphy's production was located in the region, we presume that all of Murphy's proven reserves are located in the region.
• According to page 2 of Murphy's 1997 Form 10-K, as of December 31, 1997, the company had 501,000 proved net non-producing acres and 136,000 proved net producing acres of oil and gas properties in the United States.
• According to pages 2-3 of Murphy's 1997 Form 10-K, as of December 31, 1997, Murphy was in the process of drilling 1.6 net wells in the United States, had completed 17.3 net exploratory and development wells in 1997, and had 131.6 net productive oil wells.
• According to pages F-20 and F-24 of Murphy's 1998 Form 10-K, Murphy invested $147 million in capital expenditures for U.S. crude-oil exploration and development, and it had $400.7 million of exploration and production assets in the United States as of December 31, 1997.
• In a letter dated August 5, 1999, Murphy asserted that it is not dependent upon imports from any of the targeted countries as a supply source, stating that, although Murphy purchased crude oil from Venezuelan sources, "Murphy is not obligated to purchase crude oil from Venezuela. Murphy's contract with Venezuela is a thirty (30) day spot contract, and there is no long-term commitment. Murphy's refinery operations are not dependent upon crude imports from any of the targeted countries."

• As an additional measure of Murphy's stake in the regional industry over the long term, we divided its 1997 estimated regional reserves by its regional production. The resulting value indicates that Murphy can produce for 5.47 years at its 1997 rate, assuming it does not purchase or find more reserves, before depleting its reserves.

The above data supports that Murphy has a substantial and long-term stake in the regional crude-oil industry.

Phillips

The following facts regarding Phillips' oil exploration, development and production activities are relevant to its stake in the domestic industry.

• In its July 21, 1999, survey response, Phillips reported that in 1997 it produced [ * * * ] barrels of crude oil in the United States, including [ * * * ] barrels in the region.
• Phillips' 1997 production of crude oil makes it the eighteenth largest producer in the region, accounting for [ * * * ] percent of total regional production.

• Phillips' 1997 10-K form at page 55 shows that at the end of 1997 the company's net proven reserves of crude oil in the United States amounted to 0.244 billion barrels.
• Because neither Phillips' 1997 10-K form nor its 1998 10-K form allows us to isolate regional reserves from U.S. reserves, we estimated Phillips' net proven reserves located in the region. ⁽¹⁹⁾ We estimated that, in 1997, Phillips' net proven regional reserves were at least [ * * * ] barrels.
• According to page 118 of Phillips' 1997 Form 10-K, as of December 31, 1997, the company had 1,771,000 proved net undeveloped acres and 1,115,000 proved net developed acres of oil and gas properties in the United States.
• According to page 119 of Phillips' 1997 Form 10-K, as of December 31, 1997, Phillips was in the process of drilling 24 net wells in the United States, had completed 140 net exploratory and development wells in 1997, and had 2,876 net productive oil wells.
• As an additional measure of Phillips' stake in the regional industry over the long term, we divided its 1997 estimated regional reserves by its regional production. The resulting value indicates that Phillips can produce for 8.25 years at its 1997 rate, assuming it does not purchase or find more reserves, before depleting its reserves.

The above data supports that Phillips has a substantial and long-term stake in the regional crude-oil industry.

Shell

The following facts regarding Shell's oil exploration, development and production activities are relevant to its stake in the domestic industry.

• In its July 26, 1999, survey response, Shell reported that in 1997 it produced 149.65 million barrels of crude oil in the United States, including 100.010 million barrels in the region.
• Shell's 1997 production of crude oil makes it the second largest producer of crude oil in the region, accounting for approximately 6.5 percent of total regional production.

• In 1997 Shell, in combination with its equity holdings in other producers of crude oil, held 1,736 million barrels of proven crude-oil reserves in the United States. See Shell's 1998 Form 10-K, at 12.
• Because Shell's 1997 Form 10-K does not distinguish regional reserves from U.S. reserves, we calculated an estimated minimum regional reserve for the company ⁽²⁰⁾. Based on this estimation, for 1997, we determined that Shell had at least 1,065 million barrels of net proven regional reserves.
• According to page 8 of Shell's 1997 Form 10-K, at the end of 1997 the company had 6.809 million net undeveloped acres and 1.199 million net developed acres of oil and gas properties in the United States.

• Shell's regional exploration, development, and production operations employ more than 2,200 workers in the region. ⁽²¹⁾
• In 1997 Shell owned 1,803 net wells in the United States that were producing or were capable of producing oil. In 1997 Shell also held equity interests in over 8,148 net wells in the United States that were producing or were capable of producing oil. See 1998 Form 10-K, at 8.
• In 1997 Shell completed 32 net exploratory and 99 net development oil and gas wells in the United States. See 1998 Form 10-K, at 8.
• Shell's 1997 net income from its U.S. exploration and production operations was $1,060 million. See Shell's 1997 Form 10-K, at 6.
• In 1997 Shell spent $2.229 billion on property acquisition, exploration and production in the United States. See Shell's 1997 Form 10-K, at 7.

• Domestically, Shell produces crude oil in 12 states, the Gulf of Mexico, and offshore California. In 1997, domestic onshore production accounted for 50 percent of Shell's crude-oil production. See Shell's 1997 Form 10-K, at 4.
• At the end of 1997 Shell held interests in 1,023 tracts in the Gulf of Mexico, 696 of which are in water depths exceeding 1,500 feet, comprising more than one- fifth of the industry's deepwater leaseholds. See Shell's 1997 Form 10-K, at 4.
• Shell undertakes substantial initiatives in enhanced and supplemental recovery operations in the region to produce crude oil which could not be recovered by natural reservoir forces. In 1997, its CO₂ injection projects in West Texas accounted for 21,214 barrels per day or almost 8 percent of its regional crude-oil production. See Shell's 1997 Form 10-K, at 5.

• As an additional measure of Shell's stake in the regional industry over the long term, we divided its 1997 regional reserves by its regional production. The resulting value indicates that Shell can produce for 9.66 years at its 1997 rate, assuming it does not purchase or find more reserves, before depleting its reserves.

The above data supports that Shell has a substantial and long-term stake in the regional crude-oil industry.

Texaco

The following facts regarding Texaco's oil exploration, development and production activities are relevant to its stake in the domestic industry.

• In its July 27, 1999, survey response, Texaco reported that in 1997 it produced 144.554 million barrels of crude oil in the United States, including 68.539 million barrels in the region.
• Texaco's 1997 production of crude oil makes it the fifth largest producer in the region, accounting for 4.5 percent of total regional production.

• Texaco's 1997 10-K form at page 64 shows that at the end of 1997 the company's net proven reserves of crude oil in the United States amounted to 1.767 billion barrels.
• Because neither Texaco's 1997 10-K form nor its 1998 10-K form allows us to isolate regional reserves from U.S. reserves, we estimated Texaco's net proven reserves located in the region ⁽²²⁾. We estimated that, in 1997, Texaco's net proven regional reserves were at least 970.9 million barrels.
• According to page 7 of Texaco's 1997 Form 10-K, as of December 31, 1997, the company had 5.529 million proved net undeveloped acres and 1.875 million proved net developed acres of oil and gas properties in the United States.
• According to page 7 of Texaco's 1997 Form 10-K, Texaco had 19,110 net wells in the United States producing or capable of producing oil in 1997.
• According to page 8 of Texaco's 1997 Form 10-K, Texaco was in the process of drilling 87 net wells in the United States and 883 net development wells in 1997.
• According to page 8 of Texaco's 1997 Form 10-K, Texaco completed 32 productive exploratory oil wells in the United States in 1997.
• According to page 34 of Texaco's 1997 Form 10-K, Texaco invested $3.183 billion in exploration and production (not including refining and marketing activities) in 1997.
• According to its July 27, 1999, survey response, Texaco had $7.9 billion of exploration and production assets in the United States.
• According to page 27 of Texaco's 1997 Form 10-K, Texaco earned $957 million after taxes from exploration and production activities in the United States.
• Texaco's 1997 10-K form states at page 65 that, "in the United States, liquid and gas reserves were added from the Monterey Resources acquisition and drilling that extended the productive limits of existing fields, such as the McAllen Ranch field in Texas and Caillou Island field onshore Louisiana. Other drilling-related reserve increases resulted from the new field discovery of Ewing Bank Block 963 and new sand discovery at Mound Point, both offshore Louisiana."
• Texaco's 1997 10-K form states at page 6 that "solid cash flow and earnings are generated by core upstream assets around the world, aided by our advanced technologies and alliance-forming skills. Examples: our aggressive exploration and production activity in the deepwater Gulf of Mexico."
• Texaco's 1997 10-K form states at page 7 that "{i}n 1997, we increased our upstream capital budget by 32 percent (excluding the Monterey Resources acquisition) to add reserves and to develop projects" including projects in the Gulf of Mexico.

• As an additional measure of Texaco's stake in the regional industry over the long term, we divided its 1997 estimated regional reserves by its regional production. The resulting value indicates that Texaco can produce for 14.2 years at its 1997 rate, assuming it does not purchase or find more reserves, before depleting its reserves.

The above data supports that Texaco has a substantial and long-term stake in the regional crude-oil industry.

IRAQ

Coastal

Coastal's 1997 regional reserves exceed its regional imports of crude oil from Iraq by a multiple of 80.3. Based on our examination of the data in Annex I, the data in Annex II, and this figure, we find that Coastal's stake in the regional industry substantially exceeds its dependancy on imports from Iraq. Therefore, we determine that it is appropriate to count Coastal's opposition to the antidumping and countervailing duty petitions against crude oil from Iraq.

Exxon

Exxon's 1997 regional reserves exceed its regional imports of crude oil from Iraq by a multiple of 1,643.4. Based on our examination of the data in Annex I, the data in Annex II, and this figure, we find that Exxon's stake in the regional industry substantially exceeds its dependancy on imports from Iraq. Therefore, we determine that it is appropriate to count Exxon's opposition to the antidumping and countervailing duty petitions against crude oil from Iraq.

Marathon

Marathon's 1997 regional reserves exceed its regional imports of crude oil from Iraq by a multiple of 170.6. Based on our examination of the data in Annex I, the data in Annex II, and this figure, we find that Marathon's stake in the regional industry substantially exceeds its dependancy on imports from Iraq. Therefore, we determine that it is appropriate to count Marathon's opposition to the antidumping and countervailing duty petitions against crude oil from Iraq.

Phillips

Phillips' 1997 regional reserves exceed its regional imports of crude oil from Iraq by a multiple of 90.3. Based on our examination of the data in Annex I, the data in Annex II, and this figure, we find that Phillips' stake in the regional industry substantially exceeds its dependancy on imports from Iraq. Therefore, we determine that it is appropriate to count Phillips' opposition to the antidumping and countervailing duty petitions against crude oil from Iraq.

Texaco

Texaco's 1997 regional reserves exceed its regional imports of crude oil from Iraq by a multiple of 1,079.9. Based on our examination of the data in Annex I, the data in Annex II, and this figure, we find that Texaco's stake in the regional industry substantially exceeds its dependancy on imports from Iraq. Therefore, we determine that it is appropriate to count Texaco's opposition to the antidumping and countervailing duty petitions against crude oil from Iraq.

MEXICO

BP Amoco

BP Amoco's 1997 regional reserves exceed its regional imports of crude oil from Mexico by a multiple of 49.5. Based on our examination of the data in Annex I, the data in Annex II, and this figure, we find that BP Amoco's stake in the regional industry substantially exceeds its dependancy on imports from Mexico. Therefore, we determine that it is appropriate to count BP Amoco's opposition to the antidumping and countervailing duty petitions against crude oil from Mexico.

Chevron

Chevron's 1997 regional reserves exceed its regional imports of crude oil from Mexico by a multiple of 16.0. Based on our examination of the data in Annex I, the data in Annex II, and this figure, we find that Chevron's stake in the regional industry substantially exceeds its dependancy on imports from Mexico. Therefore, we determine that it is appropriate to count Chevron's opposition to the antidumping and countervailing duty petitions against crude oil from Mexico.

Coastal

Coastal's 1997 regional reserves exceed its regional imports of crude oil from Mexico by a multiple of 2.4. Based on our examination of the data in Annex I, the data in Annex II, and this figure, we find that Coastal's dependancy on imports from Mexico exceeds its stake in the regional industry. Therefore, we determine that it is appropriate to disregard Coastal's opposition to the antidumping and countervailing duty petitions against crude oil from Mexico.

Conoco

Conoco's 1997 regional reserves exceed its regional imports of crude oil from Mexico by a multiple of 8.6. Based on our examination of the data in Annex I, the data in Annex II, and this figure, we find that Conoco's dependancy on imports from Mexico exceeds its stake in the regional industry. Therefore, we determine that it is appropriate to disregard Conoco's opposition to the antidumping and countervailing duty petitions against crude oil from Mexico.

Exxon

Exxon's 1997 regional reserves exceed its regional imports of crude oil from Mexico by a multiple of 16.9. Based on our examination of the data in Annex I, the data in Annex II, and this figure, we find that Exxon's stake in the regional industry substantially exceeds its dependancy on imports from Mexico. Therefore, we determine that it is appropriate to count Exxon's opposition to the antidumping and countervailing duty petitions against crude oil from Mexico.

Fina

Fina's 1997 regional reserves exceed its regional imports of crude oil from Mexico by a multiple of 2.0. Based on our examination of the data in Annex I, the data in Annex II, and this figure, we find that Fina's dependancy on imports from Mexico exceeds its stake in the regional industry. Therefore, we determine that it is appropriate to disregard Fina's opposition to the antidumping and countervailing duty petitions against crude oil from Mexico.

Marathon

Marathon's 1997 regional reserves exceed its regional imports of crude oil from Mexico by a multiple of 39.8. Based on our examination of the data in Annex I, the data in Annex II, and this figure, we find that Marathon's stake in the regional industry substantially exceeds its dependancy on imports from Mexico. Therefore, we determine that it is appropriate to count Marathon's opposition to the antidumping and countervailing duty petitions against crude oil from Mexico.

Mobil

Mobil's 1997 regional reserves exceed its regional imports of crude oil from Mexico by a multiple of 2.5. Based on our examination of the data in Annex I, the data in Annex II, and this figure, we find that Mobil's dependancy on imports from Mexico exceeds its stake in the regional industry. Therefore, we determine that it is appropriate to disregard Mobil's opposition to the antidumping and countervailing duty petitions against crude oil from Mexico.

Shell

Shell's 1997 regional reserves exceed its regional imports of crude oil from Mexico by a multiple of 11.3. Based on our examination of the data in Annex I, the data in Annex II, and this figure, we find that Shell's stake in the regional industry substantially exceeds its dependancy on imports from Mexico. Therefore, we determine that it is appropriate to count Shell's opposition to the antidumping and countervailing duty petitions against crude oil from Mexico.

SAUDI ARABIA

BP Amoco

BP Amoco's 1997 regional reserves exceed its regional imports of crude oil from Saudi Arabia by a multiple of 82.7. Based on our examination of the data in Annex I, the data in Annex II, and this figure, we find that BP Amoco's stake in the regional industry substantially exceeds its dependancy on imports from Saudi Arabia. Therefore, we determine that it is appropriate to count BP Amoco's opposition to the antidumping and countervailing duty petitions against crude oil from Saudi Arabia.

Chevron

Chevron's 1997 regional reserves exceed its regional imports of crude oil from Saudi Arabia by a multiple of 12.3. Based on our examination of the data in Annex I, the data in Annex II, and this figure, we find that Chevron's stake in the regional industry substantially exceeds its dependancy on imports from Saudi Arabia. Therefore, we determine that it is appropriate to count Chevron's opposition to the antidumping and countervailing duty petitions against crude oil from Saudi Arabia.

Exxon

Exxon's 1997 regional reserves exceed its regional imports of crude oil from Saudi Arabia by a multiple of 15.3. Based on our examination of the data in Annex I, the data in Annex II, and this figure, we find that Exxon's stake in the regional industry substantially exceeds its dependancy on imports from Saudi Arabia. Therefore, we determine that it is appropriate to count Exxon's opposition to the antidumping and countervailing duty petitions against crude oil from Saudi Arabia.

Marathon

Marathon's 1997 regional reserves exceed its regional imports of crude oil from Saudi Arabia by a multiple of 9.6. Based on our examination of the data in Annex I, the data in Annex II, and this figure, we find that Marathon's dependancy on imports from Saudi Arabia exceeds its stake in the regional industry. Therefore, we determine that it is appropriate to disregard Marathon's opposition to the antidumping and countervailing duty petitions against crude oil from Saudi Arabia.

Mobil

Mobil's 1997 regional reserves exceed its regional imports of crude oil from Saudi Arabia by a multiple of 6.2. Based on our examination of the data in Annex I, the data in Annex II, and this figure, we find that Mobil's dependancy on imports from Saudi Arabia exceeds its stake in the regional industry. Therefore, we determine that it is appropriate to disregard Mobil's opposition to the antidumping and countervailing duty petitions against crude oil from Saudi Arabia.

Phillips

Phillips' 1997 regional reserves exceed its regional imports of crude oil from Saudi Arabia by a multiple of 6.7. Based on our examination of the data in Annex I, the data in Annex II, and this figure, we find that Phillips' dependancy on imports from Saudi Arabia exceeds its stake in the regional industry. Therefore, we determine that it is appropriate to disregard Phillips' opposition to the antidumping and countervailing duty petitions against crude oil from Saudi Arabia.

Shell

Shell's 1997 regional reserves exceed its regional imports of crude oil from Saudi Arabia by a multiple of 119.3. Based on our examination of the data in Annex I, the data in Annex II, and this figure, we find that Shell's stake in the regional industry substantially exceeds its dependancy on imports from Saudi Arabia. Therefore, we determine that it is appropriate to count Shell's opposition to the antidumping and countervailing duty petitions against crude oil from Saudi Arabia.

Texaco

Texaco's 1997 regional reserves exceed its regional imports of crude oil from Saudi Arabia by a multiple of 5.3. Based on our examination of the data in Annex I, the data in Annex II, and this figure, we find that Texaco's dependancy on imports from Saudi Arabia exceeds its stake in the regional industry. Therefore, we determine that it is appropriate to disregard Texaco's opposition to the antidumping and countervailing duty petitions against crude oil from Saudi Arabia.

VENEZUELA

ARCO

ARCO's 1997 regional reserves exceed its regional imports of crude oil from Venezuela by a multiple of 118.6. Based on our examination of the data in Annex I, the data in Annex II, and this figure, we find that ARCO's stake in the regional industry substantially exceeds its dependancy on imports from Venezuela. Therefore, we determine that it is appropriate to count ARCO's opposition to the antidumping and countervailing duty petitions against crude oil from Venezuela.

BP Amoco

BP Amoco's 1997 regional reserves exceed its regional imports of crude oil from Venezuela by a multiple of 146.9. Based on our examination of the data in Annex I, the data in Annex II, and this figure, we find that BP Amoco's stake in the regional industry substantially exceeds its dependancy on imports from Venezuela. Therefore, we determine that it is appropriate to count BP Amoco's opposition to the antidumping and countervailing duty petitions against crude oil from Venezuela.

Chevron

Chevron's 1997 regional reserves exceed its regional imports of crude oil from Venezuela by a multiple of 45.1. Based on our examination of the data in Annex I, the data in Annex II, and this figure, we find that Chevron's stake in the regional industry substantially exceeds its dependancy on imports from Venezuela. Therefore, we determine that it is appropriate to count Chevron's opposition to the antidumping and countervailing duty petitions against crude oil from Venezuela.

Coastal

Coastal's 1997 regional reserves exceed its regional imports of crude oil from Venezuela by a multiple of 2.2. Based on our examination of the data in Annex I, the data in Annex II, and this figure, we find that Coastal's dependancy on imports from Venezuela exceeds its stake in the regional industry. Therefore, we determine that it is appropriate to disregard Coastal's opposition to the antidumping and countervailing duty petitions against crude oil from Venezuela.

Conoco

Conoco's 1997 regional reserves exceed its regional imports of crude oil from Venezuela by a multiple of 17.7. Based on our examination of the data in Annex I, the data in Annex II, and this figure, we find that Conoco's stake in the regional industry substantially exceeds its dependancy on imports from Venezuela. Therefore, we determine that it is appropriate to count Conoco's opposition to the antidumping and countervailing duty petitions against crude oil from Venezuela.

Exxon

Exxon's 1997 regional reserves exceed its regional imports of crude oil from Venezuela by a multiple of 27.9. Based on our examination of the data in Annex I, the data in Annex II, and this figure, we find that Exxon's stake in the regional industry substantially exceeds its dependancy on imports from Venezuela. Therefore, we determine that it is appropriate to count Exxon's opposition to the antidumping and countervailing duty petitions against crude oil from Venezuela.

Fina

Fina's 1997 regional reserves exceed its regional imports of crude oil from Venezuela by a multiple of 3.7. Based on our examination of the data in Annex I, the data in Annex II, and this figure, we find that Fina's dependancy on imports from Venezuela exceeds its stake in the regional industry. Therefore, we determine that it is appropriate to disregard Fina's opposition to the antidumping and countervailing duty petitions against crude oil from Venezuela.

Marathon

Marathon's 1997 regional reserves exceed its regional imports of crude oil from Venezuela by a multiple of 48.1. Based on our examination of the data in Annex I, the data in Annex II, and this figure, we find that Marathon's stake in the regional industry substantially exceeds its dependancy on imports from Venezuela. Therefore, we determine that it is appropriate to count Marathon's opposition to the antidumping and countervailing duty petitions against crude oil from Venezuela.

Mobil

Mobil's 1997 regional reserves exceed its regional imports of crude oil from Venezuela by a multiple of 12.93. Based on our examination of the data in Annex I, the data in Annex II, and this figure, we find that Mobil's stake in the regional industry substantially exceeds its dependancy on imports from Venezuela. Therefore, we determine that it is appropriate to count Mobil's opposition to the antidumping and countervailing duty petitions against crude oil from Venezuela.

Murphy

Murphy's 1997 regional reserves exceed its regional imports of crude oil from Venezuela by a multiple of 0.5. Based on our examination of the data in Annex I, the data in Annex II, and this figure, we find that Murphy's dependancy on imports from Venezuela exceeds its stake in the regional industry. Therefore, we determine that it is appropriate to disregard Murphy's opposition to the antidumping and countervailing duty petitions against crude oil from Venezuela.

Phillips

Phillips' 1997 regional reserves exceed its regional imports of crude oil from Venezuela by a multiple of 312.9. Based on our examination of the data in Annex I, the data in Annex II, and this figure, we find that Phillips' stake in the regional industry substantially exceeds its dependancy on imports from Venezuela. Therefore, we determine that it is appropriate to count Phillips' opposition to the antidumping and countervailing duty petitions against crude oil from Venezuela.

Shell

Shell's 1997 regional reserves exceed its regional imports of crude oil from Venezuela by a multiple of 214.4. Based on our examination of the data in Annex I, the data in Annex II, and this figure, we find that Shell's stake in the regional industry substantially exceeds its dependancy on imports from Venezuela. Therefore, we determine that it is appropriate to count Shell's opposition to the antidumping and countervailing duty petitions against crude oil from Venezuela.

Texaco

Texaco's 1997 regional reserves exceed its regional imports of crude oil from Venezuela by a multiple of 38.9. Based on our examination of the data in Annex I, the data in Annex II, and this figure, we find that Texaco's stake in the regional industry substantially exceeds its dependancy on imports from Venezuela. Therefore, we determine that it is appropriate to count Texaco's opposition to the antidumping and countervailing duty petitions against crude oil from Venezuela.

1. We obtained the regional production figures for this annex from the companies' survey responses.

2. We obtained the regional import figures from the Energy Information Administration webpage. See http://www.eia.doe.gov/oil_gas/petroleum/data_publications/company_level_im ports/cli.html and the memorandum to the file dated August 7, 2001, regarding Import Data.

3. We obtained the regional production figures for this annex from the companies' survey responses.

4. We obtained the regional import figures from the Energy Information Administration webpage. See http://www.eia.doe.gov/oil_gas/petroleum/data_publications/company_level_im ports/cli.html and the memorandum to the file dated August 7, 2001, regarding Import Data.

5. We obtained the regional production figures for this annex from the companies' survey responses.

6. We obtained the regional import figures from the Energy Information Administration webpage. See http://www.eia.doe.gov/oil_gas/petroleum/data_publications/company_level_im ports/cli.html and the memorandum to the file dated August 7, 2001, regarding Import Data.

7. When determining Texaco's imports from the four subject countries, we attributed all of Star Enterprises' imports from Saudi Arabia to Texaco and included them in Texaco's import figures. We did this because Star Enterprise is a joint venture between Texaco and Aramco, the Saudi Arabian state-owned crude-oil company.

8. We obtained the regional production figures for this annex from the companies' survey responses.

9. We obtained the regional import figures from the Energy Information Administration webpage. See http://www.eia.doe.gov/oil_gas/petroleum/data_publications/company_level_im ports/cli.html and the memorandum to the file dated August 7, 2001, regarding Import Data.

10. Unless noted otherwise, all financial data cited in this annex is contained in the memorandum, "Data on Stake as a Producer in the U.S. Crude Oil Industry for Companies that Imported Subject Merchandise," dated August 7, 2001.

11. We estimated ARCO's proven regional reserves using the following steps: 1) we calculated the depletion rate for the region and for the United States for BP-Amoco, Marathon, Chevron, and Fina, the only opposing importers for which we had proven reserves and production for both the region and the United States as a whole; 2) we determined the largest absolute difference between the regional depletion rate and the U.S. depletion rate on both an absolute and percentage basis (in this case, the difference for Chevron was 0.78 years, which was 8.17 percent of Chevron's U.S. depletion rate); 3) we calculated ARCO's depletion rate (reserves divided by production) for the United States as a whole, which was [* * *] years; 4) as a conservative measure, we deducted [* * *] years from ARCO's depletion rate (we chose the percentage amount because 8.17 percent of [* * *] years is [* * *] years, which is larger than 0.78 years), which resulted in an estimated regional depletion rate of [* * *] years; 5) finally, we multiplied the estimated regional depletion rate by ARCO's regional production to calculate the estimated minimum regional reserves.

12. Net acreage is the sum of the company's fractional interests in gross acreage.

13. The figures for net wells produced consists of the number of wells completed during the year regardless of when drilling was initiated. Also, completion refers to the installation of permanent equipment for the production of oil or gas. Net wells are the sum of the company's fractional interests in gross wells. See Chevron's 1997 Form 10-K, at 14-15.

14. Chevron's 1998 Form 10-K, at FS-33, also lists this figure for 1997 costs of exploration, property acquisitions, and development for upstream operations.

15. Page 4 of August 3, 1999, submission from DeKieffer & Horgan, on behalf of Chevron Corporation.

16. We estimated Exxon's proven regional reserves using the following steps: 1) we calculated the depletion rate for the region and for the United States for BP-Amoco, Marathon, Chevron, and Fina, the only opposing importers for which we had proven reserves and production for both the region and the United States as a whole; 2) we determined the largest absolute difference between the regional depletion rate and the U.S. depletion rate on both an absolute and percentage basis (in this case, the difference for Chevron was 0.78 years, which was 8.17 percent of Chevron's U.S. depletion rate); 3) we calculated Exxon's depletion rate (reserves divided by production) for the United States as a whole, which was 11.6 years; 4) as a conservative measure, we deducted 0.95 years from Exxon's depletion rate (we chose the percentage amount because 8.17 percent of 11.6 years is 0.95 years, which is larger than 0.78 years), which resulted in an estimated regional depletion rate of 10.7 years; 5) finally, we multiplied the estimated regional depletion rate by Exxon's regional production to calculate the estimated minimum regional reserves.

17. Available at http://www.exxon.mobil.com/exxon_nrarchive/publications/annual_98/explor2.html

18. We estimated Mobil's proven regional reserves using the following steps: 1) we calculated the depletion rate for the region and for the United States for BP-Amoco, Marathon, Chevron, and Fina, the only opposing importers for which we had proven reserves and production for both the region and the United States as a whole; 2) we determined the largest absolute difference between the regional depletion rate and the U.S. depletion rate on both an absolute and percentage basis (in this case, the difference for Chevron was 0.78 years, which was 8.17 percent of Chevron's U.S. depletion rate); 3) we calculated Mobil's depletion rate (reserves divided by production) for the United States as a whole, which was [* * *] years; 4) as a conservative measure, we deducted the 0.78 year difference we calculated for Chevron from Mobil's depletion rate (we chose the absolute amount because 8.17 percent of [* * *] years is [* * *] years, which is smaller than 0.78 years), which resulted in an estimated regional depletion rate of [* * *] years; 5) finally, we multiplied the estimated regional depletion rate by Mobil's regional production to calculate the estimated minimum regional reserves.

19. We estimated Phillips' proven regional reserves using the following steps: 1) we calculated the depletion rate for the region and for the United States for BP-Amoco, Marathon, Chevron, and Fina, the only opposing importers for which we had proven reserves and production for both the region and the United States as a whole; 2) we determined the largest absolute difference between the regional depletion rate and the U.S. depletion rate on both an absolute and percentage basis (in this case, the difference for Chevron was 0.78 years, which was 8.17 percent of Chevron's U.S. depletion rate); 3) we calculated Phillips' depletion rate (reserves divided by production) for the United States as a whole, which was [* * *] years; 4) as a conservative measure, we deducted [* * *] years from Phillips' depletion rate (we chose the percentage amount because 8.17 percent of [* * *] years is [* * *] years, which is larger than 0.78 years), which resulted in an estimated regional depletion rate of [* * *] years; 5) finally, we multiplied the estimated regional depletion rate by Phillips' regional production to calculate the estimated minimum regional reserves.

20. We estimated Shell's proven regional reserves using the following steps: 1) we calculated the depletion rate for the region and for the United States for BP-Amoco, Marathon, Chevron, and Fina, the only opposing importers for which we had proven reserves and production for both the region and the United States as a whole; 2) we determined the largest absolute difference between the regional depletion rate and the U.S. depletion rate on both an absolute and percentage basis (in this case, the difference for Chevron was 0.78 years, which was 8.17 percent of Chevron's U.S. depletion rate); 3) we calculated Shell's depletion rate (reserves divided by production) for the United States as a whole, which was 11.6 years; 4) as a conservative measure, we deducted 0.95 years from Shell's depletion rate (we chose the percentage amount because 8.17 percent of 11.6 years is 0.95 years, which is larger than 0.78 years), which resulted in an estimated regional depletion rate of 10.7 years; 5) finally, we multiplied the estimated regional depletion rate by Shell's regional production to calculate the estimated minimum regional reserves.

21. July 12, 1999, letter from Shell Oil Company to the Department of Commerce.

22. We estimated Texaco's proven regional reserves using the following steps: 1) we calculated the depletion rate for the region and for the United States for BP-Amoco, Marathon, Chevron, and Fina, the only opposing importers for which we had proven reserves and production for both the region and the United States as a whole; 2) we determined the largest absolute difference between the regional depletion rate and the U.S. depletion rate on both an absolute and percentage basis (in this case, the difference for Chevron was 0.78 years, which was 8.17 percent of Chevron's U.S. depletion rate); 3) we calculated Texaco's depletion rate (reserves divided by production) for the United States as a whole, which was 15.43 years; 4) as a conservative measure, we deducted 1.26 years from Texaco's depletion rate (we chose the percentage amount because 8.17 percent of 15.4 years is 1.26 years, which is larger than 0.78 years), which resulted in an estimated regional depletion rate of 14.17 years; 5) finally, we multiplied the estimated regional depletion rate by Texaco's regional production to calculate the estimated minimum regional reserves.