We are writing to you and the Board to express our deep concern for the CNPC [China National Petroleum Corporation] 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 CNPC-Aktobemunaigas JSC and KMK Munai JSC, which are subsidiaries of the CNPC…

… 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". CNPC-Aktobemunaigas JSC is a subsidiary of CNPC (85.42% of the shares) and is developing the Kenkiyak-Podsolevoye oil and gas field within Kokzhide … CNPC subsidiaries account for almost 60% 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 CNPC-Aktobemunaigas oil exploration activities were in violation of the requirements of the Environmental Code and contractual obligations… In response, representatives of CNPC-Aktobemunaigas assured and continue to assure that they were doing everything possible so as not to pollute groundwater. The company claims that an observation network of wells was set up on Kokzhide to monitor groundwater, and that there had not been any discharge exceeding oil product standards since 2007.  However, contrary to the claims by the company, the results of state monitoring for the period 2010-2017 confirm levels of water contamination as an outcome of earlier oil exploration activities still affects the quality of groundwater in Kokzhide in 2017…

… 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…

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 production…

While PetroChina, the publicly traded arm of CNPC, has stated in its Sustainability Report for Kazakhstan that all projects under the company’s implementation conforms with the “precautionary principle” and meets all environmental protection requirements...However, official Kazakh authorities have identified several violations in connection with CNPC’s activities in the Aktobe region, which raise serious concerns about the company’s fiduciary responsibility, and highlights CNPC - a Chinese state-owned enterprise - and its ability to comply with environmental and social due diligence requirements and the national law in Kazakhstan…

In connection with the foregoing, we ask you to convey to the Board of Directors of the CNPC to:

    1. Conduct, together with representatives of companies, authorized state bodies, the public and specialists of the Republic of Kazakhstan, a verification of the facts of the negative impact of subsidiaries of CNPC-Aktobemunaigas JSC and KMK Munai JSC on the state of the Kokzhide underground water field,   

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

   3. Publish the results of the public consultations and the audit in the media…