We are writing to express our deep concern for the Korea National Oil Corporation (KNOC) associated oil production and the threat to one of the largest and most unique underground freshwater desposit Kokzhide in Kazakhstan. This letter addresses impacts, and pollution caused by the oil exploration and production of Ada Oil Firm LLP, which is a subsidiary of the KNOC…

… the Kokzhide massif is currently affected due to the exploration and production of oil. Seven oil producing companies operating within the Kokzhide massif are: Kazakhoil Aktobe LLP, KMK Munai JSC… Ada Oil Firm LLP… CNPC-Aktobemunaigas JSC… LLP "Urikhtau Operating", LLP JV "Fial" and LLP "MGK". Ada Oil Firm LLP is a subsidiary of KNOC (40% of the shares, LG International 35% of the shares) and is developing the Bashenkol oil field within Kokzhidevi. Thus, KNOC subsidiary account for almost 40% of production wells within the Kokzhide underground water field. 

 The main factor in the underground water pollution of Kokzhide is the activity of oil companies…  

… Back in 2012, public authorities found roads, power lines and flow lines to 15 wells of Ada Oil were built without the permission of the Committee of Geology and Subsoil Use of the Ministry of Industry and New Technologiesxiii. According to the Department of Ecology of Aktobe Oblast, currently the largest impact on Kokzhide is exerted by the companies CNPC-Aktobemunaigas JSC, KMK Munai JSC, Kazakhoil Aktobe LLP and Ada Oil Firm LLP, as they produce uninterrupted oil productionxiv. According to local hydrogeologists, the most dangerous companies for Kokzhide are those who use shallow wells, including the Ada Oil…

… Prime Minister Bakytzhan Sagintayev said in May 2018 that the Kokzhide underground water field belongs to specially protected natural areas where any activity that threatens their safety is prohibited…

The pollution of the Kokzhide underground water has already impacts on the residents around Ada Oil Firm…

Despite of the ongoing pollution of the Kokzhide underground water field and the local residents’ suffering, it has been impossible for the local residents to raise issue to Ada Oil Firm due to lack of official communication channel. Since Ada Oil Firm does not have any complaint mechanism accessible for the local residents, they bring their complaints to the local authorities. Furthermore, since there is no website accessible for Ada Oil Firm besides introduction in KNOC’s website in English, the local residents have not been able to get any information regarding the business activities and their impacts to them as well as to the environment. 

As a public agency in Korea, KNOC adopted the Human Rights Management Regulations, and is committed to the implementation of the regulations…

We therefore request that the KNOC holds the Human Rights Management Committee and conduct the following reviews based on the said regulations…

In connection with the foregoing, we would also ask the KNOC to:

1. Conduct an independent investigation by involving third parties and authorized state bodies on the pollution and impacts to the environment and on the Kokzhide underground water field, 

2. Conduct public consultations for concerned citizens and professionals who have appealed on the state of Kokzhide watershed;

3. Make consultation results public and accessible to the Kazakh public and local communities…