The Innovations of the Petroleum Industry Act With Respect to Gas in Nigeria

ABSTRACT

Nigeria has never had any single legislation before the enactment of the Petroleum Industry Act that dealt with gas holistically. What we had were pockets of legislation that addressed gas, but were not far reaching to the point of saddling and giving capability to the gas possibilities of Nigeria. What we needed, considering the gas possibilities of Nigeria was a legislation that tended to gas completely, and that is the very thing the Petroleum Industry Act has endeavored to do. To put things into context, of the multitude economically valuable resources in Nigeria, gas is the most abundant. Nigeria holds 187 trillion cubic feet (Tcf) of proven gas reserves as of 2017, ranking 9th in the world and accounting for about 3% of the world’s total natural gas reserves of 6,923 Tcf.[1]

Introduction

Nigeria has proven gas reserves equivalent to 306.3 times its annual consumption. This means it has about 306 years of gas left (at current consumption levels and excluding unproven reserves). These natural gas resources are uniformly apportioned between associated and non-associated gas, and are incredibly depicted as the absolute best quality on the planet. However, due to the lack of infrastructure to adequately commercialize or re-inject gas, oil companies that produce natural gas in association with crude oil production have resorted to flaring this gas.

Nigeria has proven gas reserves more than three times greater than our oil reserves, and it’s surprising that prior to the Petroleum Industry Act, we’ve never had any comprehensive legislation to harness our gas potential. Several efforts have recently been made to curtail gas flaring, including the establishment of a liquefied natural gas plant, a pipeline to transport gas to some neighbouring countries, and legislative measures to regulate the oil and gas industry.

This article focuses on the innovation of the Petroleum Industry Act (the “PIA”) with respect to gas in Nigeria. This PIA is expected to expand both domestic utilization of gas in Nigeria, and our natural gas market along the West Africa coast.  Laws regulating gas will be analyzed.

This article will dwell on direct and indirect initiatives to harness gas in Nigeria, before the enactment of the Petroleum Industry Act. This section will shed light on past administrative efforts, under previous regimes to utilize gas in Nigeria. The innovations of the Petroleum Industry Act with respect to gas will also be examined. This section presents in details the Petroleum Industry Act put in place by the government of Nigeria, which tries to address the organization of gas infrastructure situated to lay out an energetic gas economy for the country as well as the entire region. The provisions of the Petroleum Industry Act will be in focus. The opportunities missed by the Petroleum Industry Act will also be addressed.

Previous Policy and Legislative Efforts Put in Place to Utilize Gas in Nigeria

The Petroleum Act[2] which was our primary legislation with respect to our oil and gas industry did not have any extant provision on gas in Nigeria. Rather, we had other legislation that had a bearing on gas. Regulation 43 of the Petroleum (Drilling and Production) Regulations[3] provides that Not later than five years after the commencement of production from the relevant area, the licensee or lessee shall submit to the Minister any feasibility study, programme or proposals that he may have for the utilisation of any natural gas, whether associated with oil or not, which has been discovered in the relevant area.

What this regulation attempted to do was curb gas flaring, by mandating licensees or lessees to submit a plan for the utilization of gas during oil exploration activities. This regulation failed to impose penalties for gas flaring. In a bid to improve gas utilization, with the aim of curbing gas flaring in the long run, the Associated Gas Re-injection Act[4] was enacted in 1979.  

The Associated Gas Re-injection Act mandated oil companies to submit to the minister schemes for the viable utilization of all associated gas produced from a field, project or projects to re-inject all gas produced in association with oil but not utilized in an industrial project, and also mandated them to submit detailed programmes and plans for the implementation of programmes relating to the re-injection of all produced associated gas. 

The major innovation of the Associated Gas re-injection Act was that of the Act prohibited flaring of gas without the permission of the Minister.[5] Where the Minister is satisfied after 1 January, 1984 that utilization or re-injection of the produced gas is not appropriate or feasible in a particular field or fields, he may issue a certificate in that respect to a company engaged in the production of oil or gas, specifying such terms and conditions, as he may at his discretion choose to impose, for the continued flaring of gas in the particular field or fields; or permitting the company to continue to flare gas in the particular field or fields if the company pays such sum as the Minister may from time to time prescribe for every 28.317 Standard cubic metre (SCM) of gas flared.

This Act imposes penalties for gas flaring.[6] Where a person flares gas, the person shall forfeit his concessions granted to him, and in addition, the Minister may order the withholding of all or part of any entitlements of any offending person towards the cost of completion or implementation of a desirable re-injection scheme, or the repair or restoration of any reservoir in the field in accordance with good oil-field practice.

In Essence, what the Associated Gas Re-injection Act did was to mandate oil companies to submit detailed plans for the utilization and re-injection of gas, and made gas flaring an offence. The Associated Gas Re-injection (continued flaring of gas) Regulations were introduced in 1985 to prescribe the conditions under which issuance of certificate for continued flaring of gas pursuant to section 3(2) of the Associated Gas Re-Injection Act is required. 

The Regulations permitted gas flaring where more than 75% of the produced gas is effectively utilised or conserved; the produced gas contains more than 15% impurities which render the gas unsuitable for industrial purposes; when gas utilisation equipment suffers a failure, so long as the failure are not too frequent and do not extend beyond three months; the ratio of the volume of gas produced per day to the distance of the field from the nearest gas line or possible utilisation point is less than 50,000 SCF/KM so long as gas is not venting at a level above 3,500 SCF /bbl, and it is not technically advisable to re-inject the gas in that field ; and where any condition set by the Minister is satisfied.[7]

The next administration that took radical steps to utilize the gas prospects of Nigeria was the Ibrahim Babangida administration. Among other things, his administration initiated the Nigeria liquefied natural gas project (NLNG). The NLNG was incorporated as a Limited Liability company on May 17, 1989, to harness Nigeria’s vast natural gas resources and produce Liquefied Natural Gas (LNG) and Natural Gas Liquids (NGLs) for export.

The establishment of NLNG as a company is backed by the Nigeria LNG (Fiscal Incentives, Guarantees and Assurances) Act,[8] which confers pioneer status on the Nigeria LNG, and exempts the company from certain taxes, custom duties, and other levies, and the provisions of the Pre-shipment Inspection of Imports Act, and provides for the guarantees and assurances by the Federal Government of Nigeria to the Company and its Shareholders. S7 of the Act exempts the Company, contractors, and sub-contractors from the payment of custom duties in respect of all necessary imports of plants, machinery, goods, and materials for use in the construction of or incorporation in the plant, jetties, shipping, transmission facilities, and ancillary works used in the company’s business, and in respect of any major spare parts needed in the event of a plant failure, and ordered within two years of commissioning that part of the plant for which the particular spare part is ordered, subject to (2) of this section.

The second schedule to the Act provides for the guarantees and Assurances of the government which amongst others, provides that; the venture shall be subject to the fiscal regime of this Act, and cannot be amended in any way without the prior written agreement of the government and the company; neither the company nor its shareholders in their capacity as shareholders of the company shall in any way be subject to new laws, regulations, taxes, duties, or imposts whatsoever which are not applicable to companies incorporated in Nigeria; shareholders who have purchased shares in the company with funds originating from outside Nigeria, shall enjoy all the benefits of approved status under relevant legislation in respect of their equity shareholding; shares in the company should be freely transferrable, and accordingly the government shall facilitate the grant of all permits and other authorization required for the sale and transfer of shares in the company.

Another laudable achievement towards ending gas flaring was the Escravos gas project. This is a joint venture developed by Nigeria National Petroleum Corporation (NNPC) and Chevron Nigeria Limited (CNL) of which the Nigeria National Petroleum Corporation are the majority partners.[9] The beginning of this project dates as far back as the early 70s when it became clear that the CNL/NNPC fields in the Escravos area contained immense oil and gas reserves, and it became paramount to extract most of the associated gas in the Okan and Mefa oil fields, and the Escravos off-shore wells. This project is an ambitious plan to eliminate gas flaring in Nigeria, and to ensure the utilization of this abundant natural resource, by commercializing gas.

Another significant landmark towards gas utilisation for infrastructural development and environmental preservation is the West Africa Gas Pipeline (the “WAGP”), a regional gas development, which Nigeria became a signatory to, under the Olusegun Obasanjo administration, to transport natural gas produced in Nigeria to commercially viable markets in Benin Republic, Togo and Ghana, and an entryway to the gas market in Equatorial Guinea.[10]

The WAGP is closely associated with the Chevron/Nigerian National Petroleum Corporation (NNPC) joint venture in the Escravos area of the Niger Delta, Nigeria, which is the first large scale project that is zeroing in on improving territorial use of associated gas, by eliminating gas flaring, and ensuring the commercialization of gas across the shores of West Africa.[11] The project history dates back to 1982 when the Economic Community of West Africa States proposed the development of a natural gas pipeline through West Africa.

In a bid to further the commercial exploitation and management of our gas resources, the administration of Late President Yar’adua introduced the Gas master plan. The three key strategies of this plan were to stimulate the multiplier effect of gas in the domestic economy, position Nigeria competitively in high value export markets, and guarantee the long term energy security of Nigeria. In order to achieve the above said objectives, the Nigeria Gas Master Plan was developed into three critical elements:

1. Gas Pricing Policy: the aim of this policy is to ensure natural gas is supplied at affordable prices to all domestic sectors, mainly power and other sectors that have a significant multiplier effect on the nation’s economy.[12]

2. The Domestic Gas Supply Obligation: The whole idea of this obligation is that domestic players in the Nigerian gas market were mandated to supply a certain fragment of gas to the domestic market. Each of these players were mandated to submit a gas production and supply plan, which was in accordance with their domestic gas supply obligation.

3. The Gas infrastructure blueprint: An extensive gas infrastructure blueprint was introduced to stimulate the Gas Master Plan. The blueprint aims to create a commercially viable gas market in Nigeria by bridging the gap between major gas reserves, and the demand centres, in a bid to ensure proper utilization of gas in Nigeria.[13]

These policies had some effect on the utilization of gas in Nigeria. However, gas flaring continued, and the administration of President Muhammadu Buhari also attempted to tackle the issue of gas flaring, by launching the Nigeria Gas flare commercialization programme (NGFCP) on December 13, 2016, and setting an ambitious target of ending gas flaring by 2020.

The objective of the NGFCP is to eliminate gas flaring through technically and commercially sustainable gas utilization projects developed by competent third party investors who will be invited to participate in a competitive and transparent bid process. The whole idea of this programme is that the Federal Government will offer flare gas to competent third party investors, within and outside Nigeria, through a competitive bidding system. This programme gained legislative backing with the enactment of the Flare Gas (Prevention of Waste and Pollution) Regulations of 2018.

Among other things, this Regulation entitled the Federal Government to authorize a qualified applicant to take flare gas on behalf of the Federal Government at any flare site as specified in the Permit, and this authority was exercisable by virtue of Paragraph 35 to the First schedule of the Petroleum Act which entitles the government to take natural gas produced with crude oil free of cost at the flare and without payment of royalty.

The Department of Petroleum Resources may request a producer to provide flare gas data, and where such request is made, the producer must provide the flare gas data within 30 calendar days from the request. Regulation 6 of this regulation provides that no person shall have access to a flare gas data except pursuant to a data access permit issued by the Department of Petroleum Resources, and the application for the data access permit to the Department of Petroleum Resources in respect of a bid process, shall be done in accordance with this Regulation, and the guidelines approved by the minister with respect to such bid process. Regulation 6(3) authorizes the holder of a data access permit to access flare gas data held at any Department of Petroleum Resource with respect to any flare site.

Innovations of the Petroleum Industry Act With Respect to Gas

The Petroleum Industry Act introduced a number of innovations into the Nigerian gas sector. The objective of the Act is to pull together the gas resource of the Country to animate the domestic market, regional development, and the export market. Institutionally, the government was very weak with respect to the gas sector.

The PIA creates new institutions that would be more responsive to investment. The Act grants the Minister Powers of general supervision over the affairs and operations of the Petroleum Industry.

The PIA creates the Nigerian National Petroleum Corporation Limited under Section 53as a successor to the Nigerian National Petroleum Corporation (NNPC), and the company shall be incorporated within six months from the commencement of the Act. The Actvests in the new company rights to natural gas under production sharing contracts which were entered into prior to and after the enactment of the Act.[14]

The Act also introduces new regulators. Matters relating to the upstream are vested in the Nigerian Upstream Regulatory Commission (the “Commission”) while midstream and downstream matters are vested in the Nigerian Midstream and Downstream Petroleum Regulatory Authority (the “Authority”).

The Commission are vested with a number of technical regulatory functions, which include defining and enforcing approved standards and regulations for construction, fabrication, and operation of plants, installations and facilities used in natural gas evaluation and management, upstream natural gas gathering, natural gas treatment, and the elimination of natural gas flaring.

The responsibility of the Authority would be to provide oversight over technical, operational, and commercial midstream and downstream activities, including domestic and export natural gas operations, determining appropriate tariff methods for; processing of natural gas, transmission and transportation of natural gas, and bulk storage of natural gas.

The Act also makes ample provisions for gas flaring. Section 104(1) of the Petroleum Industry Act 2021 makes gas flaring an offence in Nigeria, except; in the case of an emergency; pursuant to an exemption granted by the commission; or as an acceptable safety practice under established regulations. Breach of this provision would lead to the payment of a fine, and this fine shall be for the purpose of environmental remediation and relief of the host communities of the settlors on which the penalties are levied.

The licensee or lessee shall pay a fine pursuant to the flare gas (prevention of waste and pollution regulations). Among other things, a licensee or lessee prior to the commencement of petroleum production, install metering equipment conforming to the specifications conferred on every facility from which gas flaring is permitted as the commission or authority may prescribe, and failure to install such metering equipment would constitute an offence.

The Petroleum Industry Act also mandates a licensee or lessee producing natural gas to submit a natural gas flare elimination and monetization plan to the commission, within 12 months of the effective date, and this plan should be in accordance with the regulations set out by the commission under this Act.  Another innovation of the Act is the domestic gas delivery obligation.

In 2008, the Gas aggregation company of Nigeria (GACN) was established to organize gas supply, in line with the domestic gas supply and pricing regulations 2008. The whole idea was that the GACN acted as an intermediary between gas suppliers and buyers in the domestic gas market, for domestic utilization. Under this arrangement, every producer would have a domestic gas supply obligation. The Domestic gas aggregator was established as a contractor.

The Department of Petroleum Resources (the “DPR”) would look at the asset base, and give each licensee or lessee an allocation. The DPR would inform the domestic gas aggregator on the allocation given to each player, and the GACN was tasked with making sure they supply gas. GACN received applications from domestic players interested in gas, assessed whether they were technically and financially competent to take gas, and matched suppliers with competent buyers. This thinking was incorporated into the Petroleum Industry Act, but this domestic gas supply obligation was changed to a domestic gas delivery obligation.

The Act provides that the Commission shall prescribe and allocate the domestic gas delivery obligation among every lessee based on the domestic gas demand requirement, and ensure compliance by every lessee of the gas delivery obligation. The volume of natural gas to be dedicated by a lessee towards the fulfillment of its gas delivery obligation shall be based on an allocation system among lessees shall be determined by the commission, upon consultation with the authority.

The Act also mandates the lessee to deliver the volume of natural gas prescribes to a wholesale customer, determined by the domestic gas aggregator and at a location prescribed by the domestic gas aggregator.

Failure to comply with the gas delivery obligation would attract an adjustable penalty of $3.50 of MMBtu not delivered, as well as compensation to any customer-client for any loss suffered as a result of default to supply marketable natural gas in accordance with a gas purchase order issued by the domestic aggregator.

The PIA also creates the midstream and downstream gas infrastructure fund (MGIF).[15] The MGIF is a corporate body with perpetual succession, and is vested in the Authority. The MGIF shall have the power to acquire, hold and dispose of property, sue and be sued in its corporate name. The purpose of the fund shall be to make equity investments of Government-owned participating or shareholder interests in infrastructure related to midstream gas operations aimed at; increasing the domestic consumption of natural gas in projects partly financed by private investment, encouraging private investment through risk sharing, and eliminating gas flaring.

The source of the Midstream and downstream infrastructure fund shall be 0.5% of the wholesale price of petroleum products and natural gas sold in Nigeria, funds and grants accruing from multilateral agencies, bilateral agencies, and related sources dedicated to the development of infrastructure for midstream and downstream gas operations in Nigeria, interests, gas flaring penalties, and donations. Another innovation of the Petroleum Industry Act is the Gas network code. This code creates the basis for buyers and suppliers of natural gas to put it through infrastructure facilities on an open access basis, upon payment of the prescribed fees. The Act also creates a domestic gas aggregation license.[16]

The duration of the license shall be for a period of two years effective from the date of the grant of the license, and the license can be renewed for a further period of two years until the attainment of liquidity. The Act also creates six other licenses. The newly created midstream and downstream licensees created under the PIA relating to gas are:

1. Bulk Gas Storage Licence (BGSL) – The PIA provides that upon approval and payment of the prescribed fees, a bulk gas storage license shall be issued to a qualified person, authorizing the holder to undertake the bulk storage of natural gas, either for its own account, or on behalf of others.[17]

2. Gas Transportation Pipeline Licence (GTPL) – The PIA grants a qualified person exclusive right to own, construct, operate and maintain a gas transportation pipeline within a route as defined in the license either for its own account with third party access provisions, or as a common carrier as stipulated in the license.[18]

3. Gas Transportation Network Operator Licence (GNOL) – Section 138 of the PIA grants a qualified person a gas transportation network operator license, which would authorize the licensee to convey natural gas through the gas transportation network on an open access basis, balance the inputs and off takes from the gas transportation network, provide access to shippers, and charge for the use of the gas transportation network based on the tariffs established by the authority.

4. Wholesale Gas Supply Licence (WGSL) – This licence authorizes the licensee to purchase natural gas directly from any lessee or third party, and sell and distribute wholesale gas to wholesale customers and gas distributors at any location in Nigeria.[19]

5. Retail Gas Supply Licence (RGSL) – This license authorizes a licensee to sell or retail compressed or liquified marketable natural gas to customers and establish, construct and operate facilities to deliver compressed natural gas and small-scale facilities for LNG not requiring a gas processing licence, for transportation by truck, railcar or marine vessel to customers in compressed or liquified form.[20]

6. Gas Distribution Licence (GDL) – This license authorizes a licensee to establish, construct, and operate a gas distribution system and to distribute and sell its natural gas to consumers in a local distribution zone including non-wholesale customers.[21]

The PIA also creates a framework for price control. The Act provides that the Authority shall determine the domestic base price each year, for the purpose of determining the prices for the power sector, commercial sector, and gas based industries.[22]

The Authority shall continue to determine the prices for strategic sectors for as long as it is required. The price control and the corresponding role of the price aggregator shall not be required where the entire domestic gas requirement is covered by supply contracts between wholesale customers and lessees or suppliers, or the domestic market for natural gas is largely characterized by free market based contracting for natural gas between willing buyers and willing sellers, based on criteria established by the Authority.

The price of marketable natural gas applicable to the power sector shall be the domestic base price at the marketable natural gas delivery point. The price of marketable natural gas applicable to the commercial sector shall be the domestic base price at the marketable natural gas delivery point plus US $0.50 per MMBtu. The gas price for the gas based industries shall be determined by the pricing principles set out in the fourth schedule to this Act.[23]

The PIA creates a floor and ceiling structure. The floor price for the gas based industries shall be US $0.90 per MMBtu, while the ceiling price shall be the domestic base price applicable for any year. The Authority may additionally regulate prices where it determines that a certain licensed service is a monopoly activity, competition has not yet developed in the market to such an extent that it would protect customers, and that a particular licensee is a dominant provider.  

Another innovation of the Act is commercial gas discovery, a license specifically for gas. Upon the completion of an appraisal programme, a licensee may declare a commercial discovery, or declare a significant gas discovery. Where a significant gas discovery has been declared, the licensee shall be entitled to retain the area of such significant gas discovery, for a retention period of not more than 10 years from the day of the declaration.

The retention area of a significant gas discovery shall continue to subsist pursuant to a petroleum prospecting license until the expiration of the period, or the declaration of a commercial discovery by the licensee.

So what has the PIA Resolved?

• The Petroleum Industry Act has provided a long overdue regulatory framework for gas, including;
• New regulatory institutions
• Ample provisions for gas flaring
• New licensing framework
• Competitive supply and delivery of natural gas
• Framework for price control
• Fiscal regime for gas development

Missed Opportunities

We missed opportunities with the design of the regulatory framework. The dual regulatory framework is a missed opportunity. This structure may have big implications on both domestic and foreign players in the gas sector, because companies in the gas sector would have to navigate from the Commission to the Authority. Approval would have to be sought twice.

Most Investors would want consistent regulation, and the gas sector has to be regulated consistently in order to allow the Country take opportunities that come from the energy transition. The PIA takes steps to compound Nigeria’s abandoned asset risk by directing the operations of pipelines and the establishment of new ones while neglecting to represent the stranding risk.

Instead of getting more capital into ventures and framework that will soon be obsolete, Nigeria ought to advance the stewardship of resources that push the energy transition forward, not those that will be abandoned.[24]

Conclusion

The Petroleum Industry Act has given the evolving gas market of Nigeria the right foundation to thrive on. This Act was developed out of a thoroughly examined process of gas infrastructural development that supported the quick development of the domestic market, and the expansion of our regional markets.

The Petroleum Industry Act is designed to aid the aspiration of the government in building a vibrant economy; the new regulators are vested with a number of technical regulatory functions, the domestic gas delivery obligation will create a competitive framework for the delivery of gas to domestic customers and gas based industries, the gas flaring provisions will prohibit gas flaring, the Midstream and Downstream gas infrastructure fund shall make equity investments of Government-owned participating or shareholder interests in infrastructure related to midstream gas operations, the new licenses will create a framework around the storage, supply, delivery, and distribution of gas.

These policies present a plethora of investment opportunities in the nearest future to both domestic and foreign players in the gas sector. The long term effect of these gas infrastructural developments to the Nigeria economy will be massive.

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* Law Graduate, Faculty of law, Niger Delta University, Wilberforce Island, Bayelsa State, Nigeria. Email: [email protected].

[1] Worldometer “Nigeria Natural Gas” Available at https://www.worldometers.info/gas/nigeria-natural-gas/#:~:text=Nigeria%20holds%20187%20trillion%20cubic,gas%20reserves%20of%206%2C923%20Tcf.&text=This%20means%20it%20has%20about,levels%20and%20excluding%20unproven%20reserves) (accessed 20 February 2022).

[2] Petroleum Act (PACT) CAP. P11, Laws of the Federation of Nigeria, 2004

[3] Petroleum (Drilling and Production) Regulations, (L. N. 69 of 1969)

[4] Associated Gas Re-injection Act (AGRA) CAP. A25, Laws of the Federation of Nigeria, 2004

[5] AGRA, s.3

[6] AGRA, s 4.

[7] Ralph Ibekwe “A critical appraisal of the legal regime for the control of gas flaring in Nigeria” (2018) Available at https://nairametrics.com/2018/04/11/nigeria-gas-flaring/> (accessed 24 February 2022).

[8]  Nigeria LNG (Fiscal Incentives, Guarantees and Assurances) Act Cap. N87, Laws of Federation of Nigeria, 2004                                                                

[9] Francis Idowu Ibitoye ‘Ending Natural Gas Flaring in Nigeria’s Oil Fields’ (2014) Journal of Sustainable Development, Available at https://www.ccsenet.org/journal/index.php/jsd/article/view/33951 (accessed 20 February 2022).

[10] Philip Ejoor Agbonifo ‘Natural Gas Distribution Infrastructure and the Quest for Environmental Sustainability in the Niger Delta: The Prospect of Natural Gas Utilization in Nigeria’ (2016) International Journal of Energy Economics and Policy, Available at https://dergipark.org.tr/en/pub/ijeeep/issue/31918/351100  (accessed 20 February 2022).

[11] Ibid

[12]Ukpohor, Excel Theophilus, ‘Nigerian Gas Master Plan: Strengthening the Nigeria Gas Infrastructure Blueprint as a Base for Expanding Regional Gas Market” available at https://nairametrics.com/wp-content/uploads/2013/03/nigerian-gas-master-plan.pdf (accessed 25 February 2022).

[13] Ibid.

[14] Petroleum Industry Act (PIA), 2021, s 64.

[15]PIA, s. 52

[16] PIA, s. 153.

[17] PIA, s. 132

[18] PIA, s. 135

[19] PIA, s. 142.

[20] PIA, s. 146.

[21] PIA, s. 148

[22] PIA, s. 167

[23] PIA, s. 168

[24] Solina Kennedy, Martin Dietrich Brauch, Perrine Toledano, and Tehtena Mebratu-Tsegaye, “Nigeria’s Petroleum Industry Bill: A Missed Opportunity to Prepare for the Zero-Carbon Future” (2021) Available at file:///C:/Users/PERE%20-%20OWEI/Downloads/SSRN-id3823600%20(2).pdf (accessed 29 March 2022).

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