Zenith Energy – End of 2021 Assessment

As we are now coming to the end of the year, I have been reviewing Zenith’s position as an investment opportunity. I have looked at the progress that Zenith have made in 2021 and the progress that I am hoping for in 2022 and I have spent a large part of the weekend and yesterday writing it up.

I have tried to be as rational and conservative as possible but I have to say that it makes very positive reading – especially in the ability for the company to both borrow and service the $20 million that would be required for OML141 if Zenith were to go ahead with that purchase. I have read a number of opinions on both the UK and Norwegian forums that have suggested that doing this deal would be a stretch too far for Zenith, but having looked at the numbers I am inclined to disagree.

Anyway, here are my thought. It is a very long document so my apologies for that but I hope that some of you find it useful. It has certainly clarified my position that 2022 looks like it could be a very good year for Zenith and this is all thanks to production in Tunisia.

I am happy to discuss my thoughts here with everyone and look forward to the disagreements!


When you take a step back an look at Zenith with a bit of perspective I think that we are seeing a company at a real turning-point in it’s development process.

Going back to its original listing dates in London when the focus of the company was on Azerbaijan the business aim was always to develop production in a quick and cheap way and use the funds developed through doing this as a method to fund more expensive but potentially much more profitable exploration work.

Although things didn’t work out well in Azerbaijan, Andrea seems to have stuck solidly to the principle of building up a production base in order to fund exploration upside. Now after the pivot to Africa it looks like this is on the cusp of working and coming together to deliver the potential for a very serious company financial performance.

The company’s production hub is Tunisia and this is currently delivering 542 bopd

a) 113 bopd from the 22.5% share of SLK
b) 120 bopd from Robanna post workover.
c) 209 bopd from the 45% share of Ezzaouia
d) 100 bopd from EBB-5 at El Bibane

Working on the assumption that opex costs are approx. $25 per barrel then at today’s oi price of $75 per barrel this is worth $27,100 per day to Zenith or $10 million per annum in net revenue. Assuming that we complete the other half of the SLK deal (for which we already have the money raised) then this will further increase to 655 bopd and a net revenue of $12 million per annum.

We also know that Zenith have every intention of also increasing production in Tunisia. They have spelled out their plans there as follows:

a) Drilling of the ROB-3 – which is due to be drilled in January or February and target total Robbana production of 500bopd. This will come at a cost of £600,000 which is already fully funded out of the £3 million raised on November 2nd 2021.
b) Drilling of 2 sidetracks and 3 workovers in Ezzaouia which are also to be drilled in Jan/Feb and are targeting an increase in production of approximately 800bopd. This will come at a cost of £1.3 million and is also fully funded from the £3 million raising.

Supposing that both these drill targets and the acquisition of SLK are successfully carried out then we would be looking at production in Tunisia of:

a) 226 bopd from the 45% share of SLK
b) 500 bopd from Robanna post ROB-3
c) 500 bopd from the 45% share of Ezzaouia
d) 100 bopd from EBB-5 at El Bibane

This would give us a total production of 1,326 bopd and a net revenue of approx. $24 million per annum.

But we also know that Zenith intend to make further acquisitions in Tunisia, both because Andrea has mentioned this in a number of the investor conference calls and also from the comments made by Luca Benedetto at the beginning of last week when the company announced that they have set up a €3 million debt facility with Winance for the specific purpose of making acquisitions in Tunisia.

It has been suggested by AGEOS that the potential acquisition could be the Bir Ben Tartar (BBT) field which is currently owned by Anglo Tunisian Oil & Gas. This field currently produces 500bopd but ATOG had plans to potentially quadruple production there up to 2,000 bopd. Obviously, there is nothing definite about this acquisition yet but if it was successful then the 500bopd would deliver a revenue of an additional $ 9 million per annum.

So in short –

a) Currently Tunisia produces $10 million per annum revenue net to Zenith from 542 bopd production.
b) After the acquisition of the second SLK share this would increase to $12 million per annum from 655bopd.
c) After the fully funded ROB-3 infill well this would increase to $19 million per annum from 1,035 bopd
d) After the fully funded Ezzaouia sidetracks and workovers this would increase to $24 million per annum from 1,326 bopd
e) If we were to acquire Bir Ben Tartar this would increase to $33 million per annum from 1,826 bopd.

Andrea specifically mentioned in the November conference call that Zenith were targeting production of between 2,000-3,000 bopd by the end of 2022 and this seemed like quite a lot to me. However, given that the company has now taken out the Winance loan for the new acquisitions (SLK and potentially BBT) and is already fully funded for the additional work at Ezzaouia and Robbana (from the £3 million raising) then it is entirely possible that Zenith can hit almost 2,000bopd production by the end of Q1 2022. Importantly this is all budgeted for and fully funded already.

Financing Exploration

From the very earliest days the Zenith business model was to try and use the revenue generated from oil production to fund exploration and Andrea has consistently repeated that this is still the case in various investor calls over the last year.

Two years ago, given the fact that the whole Azerbaijan adventure went very wrong Zenith were in fairly big trouble because a model of using production revenue to pay for exploration only works if you actually have production revenue. If production is terrible or too expensive (as it was in Azerbaijan) then the company ends up with pretty much nothing.

One thing that I think Andrea deserves great credit for is for turning around the company when it seemed to be in extreme dire straits. The acquisition of Tilapia was a good bit of opportunity-seizing, but it has actually been the slightly less sexy acquisition of the Tunisian assets that has really confirmed my feeling that Zenith Energy will ultimately be a great success.

By acquiring the Tunisian assets, Andrea returned to the original plan of using production revenue to pay for exploration works as was originally planned in Azerbaijan – only this time it looks like it will actually work. The production revenue is already significant enough to represent a game-changing moment for how Zenith can actually operate. Even the current production rates of 542bopd and $10 million per annum in net revenue will allow the company to service a significant amount of debt for exploration in other areas.

We have already seen this on a small scale how production revenue can enable the establishment of debt facilities via the establishment of the Winance credit line but where I think that we are going to really see the capability of the production revenue is in connection with the OML141 license and, to a lesser extent, Tilapia.

The value of the OML141 deal is very significant to Zenith with there being an initial target of 4,000bopd but a longer term target of approx. 25,000 bopd. However, the acquisition costs of the asset reflect this enormous potential that it presents with the company being required to come up with $20 million to pay for the drilling, testing and completing of the Barracuda well “B-5” between January 15th 2022 and October 12th 2022.

There is no way that the company will be able to come up with $20 million (£15 million) raised by equity as it is the same as the entire current market cap and even if they were willing to dilute all existing shareholders by 50% (and I doubt that they would be because Andrea is still a significant shareholder himself) then there is no chance that they would be able to find a broker to fund it.

However, despite the fact that they cannot fund the OML141 acquisition by the issue of equity we do know that the company do believe that they can fund it or they would not have announced the deal. In fact, in the RNS they were specific about how they were going to fund it and this was vial “pan-African financial institutions”. This is not the first time these had been mentioned either as in the November investor call when he was asked about alternatives to equity financing Andrea mentioned that local (regional) banking is becoming a very effective way to raise money and he said that Zenith are already in negotiations with 5-6 development banks in Africa about raising money in this way. He specifically said “with oil creating cash flow then we can service this”.

So the value of the Tunisian oil revenue is as much about the doors it opens to other financing as it is about the revenue that it brings in directly. The £10 million revenue is more than enough to fund a substantial debt facility. If Zenith were to take a $20,000,000 loan facility at a coupon of 12% repayable over 4 years then they would look at paying back $500,000 per month over 48 months.

At the current rate of revenue generation this would t be just too much for Zenith to manage as, according to the last annual accounts the company has administrative expenses of USD$5.5 million ($7 million CAD). Considering Zenith generates revenue of $10 million per annum from their Tunisian assets then this would be a wholly manageable amount of money to service at today’s revenues.

If Zenith were able to conclude the SLK purchase and also complete the ROB-3 infill well and the Ezzaouia sidetracks and workovers then this would mean that the company generated a net revenue of $24 million per annum. $24 million would allow them to service a loan of up to $50 million over the same 4 year term at 12% interest. And $50 million would allow a lot of acquisitions and exploration work to be completed.

The point behind this is not to say that the company would want to receive a $20 million or $50 million loan, but that with the revenue that they are generating from the Tunisian assets they could now service this money should they need to. This means that the business model that was originally put together for Azerbaijan can now be fully activated due to the Tunisian production.

Tilapia Asset

It is a source of some considerable frustration to me that the Tilapia license is taking so long to be granted but it feels like things must be coming to a successful conclusion now. Andrea has said in the investor conference calls that the company is getting on well with the relevant officials in Congo but that there is simply no way to speed them up. Officialdom in Africa simply goes at the speed that officialdom in Africa wants to go.

Assuming that the new license is granted for Tilapia 2 then Zenith will have acquired for £200,000 a 25 year license on an asset that AAOG originally paid almost £7 million for when it only had 5 years left. The license also contains a well (TLP-103C) that has already been drilled at a cost of £9.6 million (£5.4 million net to AAOG with the rest owed by SNPC) and has discovered oil across 56 meters.

This money spent by AAOG Congo but owed by the SNPC is very important to Zenith as when they bought AAOG Congo this debt became due to them. At the last count I have seen, the amount of money owed now stands at $5.7 million owned by SNPC to AAOG Congo. Although it is highly likely that much of this money will go back to the government when it comes to finalising the signing on bonus it is still means that a 25 year oil license where oil is known to be present was acquired in it’s entirety for a mere £200,000. If for any reason the license is refused then the company is still owed $5.7 million from the Congolese government and this will be a strong reason for then to grant the license approval in the first place.

Although the drill itself was not commercially viable, the fact that it did discover oil is important and the information that was gathered during the failed drill is going to be extremely important to making sure that any new drill is successful.

Other things that we know from the release of information by AAOG is that they thought that the original well (targeting the Djeno layer) would deliver at least 1,000 bopd and that it could deliver up to 2,500 bopd (see page 19 of the AAOG AIM Admission document). They also thought that by drilling down to the Mengo layer with a second well then they could increase this production up to 5,300 bopd and they stated that opex costs (at the 5,300 per day production level) were less than $5 per barrel.

TLP-103C is a nearly completed well that was drilled to 80% of the depth and, according to Andrea’s interview with Financial Fox in February this year there only remains a few hundred meters to drill as a sidetrack/completion before it can be taken into production. It is important to note that this Djeno structure that it is targeting is extremely promising and has produced at least 1,000bopd everywhere it has been drilled in Pointe Noire. What Zenith now know (having had access to all of the AAOG data) is that there were a series of technical mistakes that were made by AAOG in the original drilling of well 103 and so they are confident that they can succeed in this well by doing the right things.

So, in conclusion we have a drill that simply needs a sidetrack to be completed and after this will have high expectations of delivering 1,000 bopd production. It is hard to tell how much the drill will cost to complete but considering it is 80% complete and it only requires a sidetrack being drilled an estimate of between £2.3 - £3.6 million (between 50% and 25% of the £9.6 million spent on the original drill does not seem to wide of the mark). This money could easily be raised by debt as it would not be difficult to service a loan of £3.6 million with a cash flow of $10 million (which is the current net revenue delivered from the Tunisian assets).

Revenue from a successful drill would be pretty significant at today’s prices and considering the opex costs that were originally put out by AAOG. 1,000 bopd production would be split 50%-50% between Zenith and the SNPC (presumably with drilling costs to be covered first) and this would give Zenith an initial production of 500bopd. With oil prices at $75 and doubling up on the $5 opex listed by AAOG to call it a more conservative $10 this would give Zenith a net revenue of $65 per barrel which would work out at $32,500 per day or $12 million per annum. Essentially a successful sidetrack at Tilapia would pay for itself in under 3 months and then the revenue produced from the well would allow the company to fund a comprehensive drilling program on an ongoing basis. This could either target the full 5,300bopd that AAOG talked about as being potentially available in Tlilapia or it could fund exploration work in the new Congolese license that Andrea has said that we are in discussions about. The financial benefits to Zenith from Tilapia alone could clearly be company-making but obviously the license renewal needs to be granted first. Here’s hoping for another Christmas surprise like last year…

OML141 NW – Nigerian Asset

While Zenith have not yet acquired any share of OML141 there is an option agreement that has been released publicly which shows the details of what the asset purchase would cost and there have also been a significant amount of information that has been put up by ADM Energy which gives us more information about what the value of the asset could be in the long term.

However, the first element to deal with about OML141 NW is exactly who owns it as ADM Energy appear to be embroiled in an argument with Noble-Hill Network Limited as to who has the rights to what. I do not plan to rehash all of the details and background to this in this post but my conclusion is that there is no chance that ADM Energy can have any claim on the asset. Whether they were duped into buying a share of KONH UK Ltd or they were knowingly misleading their shareholders is not for me to say but the fact that Noble Hill have published their share registry showing that neither KONH nor ADM Energy own any of their shares is enough evidence for me to believe that there are no issues of ownership. As far as I am concerned Noble Hill appear to be completely free to sell 42% of their company to Zenith.

The fee for acquiring 42% of Noble Hill Network Limited has been set as being valued at $20 million and all of this money is going directly towards funding the drilling, testing and completion of the well Barracuda 5 (B-5).

Because the license in Nigeria appears to operate under slightly different conditions to the licenses that Zenith own in other areas (ie Zenith will be an equity holder in the company that owns the Risk Service Contract rather than the company that holds the ownership of the license) it is hard from the currently available data to work out exactly what this means, so in order to allocate any value to this asset I am going to have to make some (conservative) assumptions:

1) Noble Hill as an entity will have to share 50% of the oil that they recover with the government and the license holders (ie Zenith’s share will be 42% of half of the actual production). I hope that this is wrong and Zenith’s share is greater than this, but I cannot see it being any smaller.
2) Opex costs will remain at $20 per barrel for the near future (as per ADM Energy’s announcement) and the reduction to $12 per barrel will only happen at some time in the future.
3) The first drill will commence in Q1 2022 and will successfully produce 4,000 bopd.

Based on these assumptions we can start putting some numbers on what the B-5 drill could be worth to Zenith.

Production of 4,000 bopd with the oil price at $75 and opex costs of $20 per barrel would mean that Barracuda would be generating a revenue of $220,000 per day or $80 million per year. On the assumption of point 1 above that 50% of this would be going to the license holders and the Nigerian government that this would mean a net revenue to Noble Hill of $40 million per annum and Zenith’s share of this would be $34 million.

From what the company has suggested in their Nov 29th RNS we would expect production to commence in Q2 2022 and so (assuming the well is successful) we can expect a minimum cash flow of $17 million from this in 2022.

Obviously, before the company can generate any revenue from the asset then they have to successfully drill it and in order to do this they have to be able to come up with the $20 million. The company has made it clear in their RNS that this would be funded by loans from pan-African financial institutions and, as I pointed out in the other thread there would be no problem with Zenith covering this loan from their existing Tunisian revenue assuming that they complete the other SLK deal.

To fund a loan of $20 million at an interest rate of 12% repayable over four years then Zenith would need to repay at $500,000 per month over 48 months (giving a total interest payment of $4 million). This would total $6 million per annum and on top of this they would also need to cover the company administrative expenses of $5.5 million per annum. This totals $11.5 million and the annual income from Tunisia once the second SLK deal is completed would be $12 million.

This is why the Tunisian production is so crucial to the development of the company as a whole as it is this money that will allow the borrowing (and servicing of debt on) much larger amounts of money to develop other opportunities.

With a relatively low risk drill such as B-5 (bearing in mind that hydrocarbons have already been found on the site by CNOOC) debt seems like an ideal way of funding it, especially since the Tunisian revenue can fund the loan even if the drill is unsuccessful. Obviously, if it is successful then the production from B-5 would pay for itself.

Overall Future for Zenith

The future for Zenith at the end of 2021 looks brighter for the company than it has ever been before and the revenue that is now coming into the company from the Tunisian operations is crucial to this. It is this Tunisian cash flow that will enable the company to fund the acquisitions and development on high potential exploration/production assets and do this without having to issue even more equity.

The cash-flow from Tunisia currently stands at $10 million per annum and with the addition of the second 22.5% of SLK it will increase to $12 million. This figure is crucial as it will enable the company to then service a debt of $20 million which will enable the funding of the purchase of 42% of Noble Hill Network Limited and therefore giving the company access to the potential of the ONL141 NW license.

If the company can deliver the ROB-3 infill well (which is fully funded and targeted to commence in Jan/Feb 2022) then this would increase production in Tunisia to 1,035 bopd and deliver a revenue of $19 million per annum then this would allow them to service up to $40 million worth of debt (at 12% interests and repayable over four years) The successful completion of the Ezzaouia sidetracks (which are also fully funded) would increase production to 1,326 bopd and revenue to $24 million. This would allow the company to borrow up to $50 million and repay it over only 40 months by making $1.5 million per month in repayments.

The use of this debt as a financing instrument would allow Zenith to AT A MINIMUM, fully fund the acquisition and drilling of OML141 and also the drilling of Tilapia 2 (which between them should come to no more that $26 million).

So the key factors going forwards for Zenith should be to get the second SLK deal done, and to complete the ROB-3 and Ezzaouia drills (which are already both fully funded) in order to deliver the cash-flow which will unlock access to up to $50 million.

If the company is successfully able to deliver this cash flow from Tunisia and is also able to complete the suggested purchase of Bir Ben Tartar (500 bopd) then it would be generating $33 million per annum from Tunisa alone.

The successful completion of the TLP-103C would deliver another $12 million per annum in net revenue (500 bopd) and my (very conservative) estimate on the B-5 drill in Nigeria suggests that it could deliver a net revenue to Zenith of $34 million (840bopd) per annum if it is successful .

So in total, if everything came in as we all wish then it is possible that by the middle of 2022 that Zenith could be producing 3,166 bopd and generating a net revenue of $79 million per annum on a pro-rata basis. This would give a share price value at a minimum of ten times today’s price.

Obviously, to reach this revenue figure would require everything to go completely smoothly and it will not (even since I started writing this document at the weekend ADM Energy have released an RNS saying that they intend to take NHNL to court in Nigeria over their stake in it). But what is really important to realise is that with the branching out of the company into many different wells in many different jurisdictions then there is the ability to build the company in a sensible way without risking everything on a single throw of the dice. If the company borrowed $20 million to drill OML141 and the drill was a failure it is not the end of the world as the debt is just serviced as normal and the focus ends up in being on Tilapia and doing more there.

Even if Tilapia AND OML141 fail then as long as the Tunisian assets keep delivering as I have suggested there will be another $24 million in debt sitting there that can be sent on acquiring more assets.

The key point is that by delivering oil in Tunisia Zenith have opened up access to capital via debt and this, in turn, opens up a huge amount of possibilities for the company to do more and bigger developments on their existing assets and to acquire more and bigger assets for the portfolio. There is now a path to a bright future that allows us to raise more money via debt and would ever be possible via equity and for an oil company that has cash in its pockets there are always going to be plenty of opportunities. We just have to trust that the company will make the right acquisitions – and judging by what has gone on in the last year we are doing all right at this so far. Zenith is going places, and the market will catch up sooner rather than later.

Here's to a bright 2022 for all of us Zenith investors. I’ve got a feeling its going to be a good one…
14.12.2021 kl 11:06 2883

Takk for god info!
14.12.2021 kl 11:21 2822

Fin redegjørelse - fremtiden er umulig å spå, men den ser uten tvil, lys ut for Zenith om ting klaffer!
14.12.2021 kl 12:14 2681

Great post MG! I hope everyone reads it at least two times, because there is so much good information here. I am also confident that 2022 is going to be a good year for Zenith investors, but based on the latest investor call I am also pretty sure we will have some good news before christmas!
14.12.2021 kl 13:29 2538

Alltid godt å få ting oppsummert med fornuftige gode kommentarer som her. Dette blir et dokument for å ta beslutninger på eget aksjeinnhav i selskapet. Det er mange muligheter og no er de samlet og satt i system for en snarlig gjennomgang når en selv trenger det. Tror det er en reell fremtidig kursdriver for Zenit når borringer begynner og en ser fremskritt i gjennomføringen av div. oppkjøp.
14.12.2021 kl 15:33 2326

Good work MG. My only reservation to your analysis is that I think AC can and should use the Nigeria drama to our advantage. ADM Energy is broke and Noble only has this asset if I am not wrong. A long court battle could destroy both companies, and in from the sideline comes AC who could save both their «asses». Having said that, I agree that Zenith under no circumstances should put up hard cash before they have some guarantee that Noble is in a position to legally sell these shares.
14.12.2021 kl 15:53 2254

Nigeria valuations is like a joke USD$0.5/barrels (when oil price is $75) $49million to zenith. You can make it yourself by $3.5 to $9/barrels. Note it is not considered in valuation.
Redigert 14.12.2021 kl 15:54 Du må logge inn for å svare
14.12.2021 kl 16:04 2218

So who should we listen to: You or the analyst…:-) I think they have to start producing before the analysts increases the valuation of the (Nigerian) asset. For now Nigeria seems to be temporarily off the table, so lets get Tilapia signed. AC claims they just need a pen, Allenby assumes they are still negotiating. I am not sure AC has given us the full picture.

100% enig med MG, men uansett hvor god analysen er så kommer nok ikke denne før noe konkret er i orden. Det vi vet nå er Nigeria er utsatt på ubestemt tid, han skulle vel til Kongo for en stund siden men har ikke hørt noe ang. Tilapia så tror nok dette også får vente til over nyttår. Spennende at de allerede trekte 1 mill dollar fra Winance kan tyde på at det kommer noe snart. Men å forvente at det helt store skjer før nyttår tror jeg er uklokt, ting tar somregel lengre tid en forespeilet.
14.12.2021 kl 16:14 2176

Enig. Alle er tjent med nøktern optimisme.
14.12.2021 kl 16:19 2150

AC har nylig uttalt at han ikke kan trade noen aksjer nå pga Tilapia. Den kan komme i morgen, større hint kjenner jeg ikke til 😀
Redigert 14.12.2021 kl 16:20 Du må logge inn for å svare


Akkurat det er vel en rimelig stor indikator på at noe er på gang ihht TLPA II er i komminga😊😊😊

Ha ellers en trivelig aften alle sammen!

Enig i det, men selv ikke AC vet akk. når det kommer. Er ikke urealistisk at dette drar ut noe lengre, å tro alt skal komme før juleaften er ønsketenkning.
14.12.2021 kl 16:31 2102

Det synes jeg er unyansert. Hørte han si det, og dette gjelder alle kursdrivende prosesser som f eks at de forhandler om oppkjøp i Tunisia. Tilapia kan komme før jul eller til påske-AC later i hvert fall som han ikke kan påvirke prosessen.

Once again an excellent piece of work! Thank you for sharing. I just have one question. Has AC mentioned sometime earlier this year that Zenith was considering more than one licence in Nigeria? I have a vague memory which tells me he was speaking about two or three…
Redigert 14.12.2021 kl 16:39 Du må logge inn for å svare
14.12.2021 kl 16:53 2016

I think he was speaking about 12 (?) deals under review/consideration.

Det er riktig Herman! Han snakket om dette fra IC han hadde i sommer at de hadde 12 under lupen og at minst 1 av de ville gå i orden. Så få vi se hva som skjer videre når det gjelder Nigeria. Nigeria tar jeg som en bonus om det kommer noe derifra. Jeg er mer opptatt å få stemplene på TLPA II og i Tunis i orden sånn at selskapet kan utvikle disse feltene videre😊😊😊
14.12.2021 kl 19:39 1758

Nigeria still on paper, second thing it's 2P reserve so valuation based on it, always before production. After production start and if break-even price around USD20 to 30USD/ barrels (max as it is not offshore). Zenith will earn $30/barrels after tax with oil price around $75. Here valuation done with $0.5 /barrels. Standard range as per same report is $2.5 to $18. In Tunisia break-even is less than $20. In Norway deep offshore field ranging break-even between $30 to $40/ barrels with subsea Installation, platform and their maintenance. For Pnor offshore Congo break-even is $20. Here we are talking more than $70/barrel.
14.12.2021 kl 20:19 1667

ADM Energy PLC: Requisition to Convene a General Meeting
12/14/2021 | 02:02am

The Requisition proposes that shareholders be asked to consider the following resolutions:

1. that Osamede Okhomina be removed as a director of the Company with immediate effect;
2. that Richard Carter be removed as a director of the Company with immediate effect;
3. the Oliver Andrews be removed as a director of the Company with immediate effect; and
4. that Richard Jennings be appointed as a Director of the Company with immediate effect.

The Board considers that the documentation received is valid and, accordingly, pursuant to the Act, the Company will within 21 days of receipt of the requisition post a circular to shareholders to convene the GM.

14.12.2021 kl 21:52 1466

You dont need a lot of evidence to be granted a temporary injunction, but you have to prove that you have something that looks like a case. I am not sure what AC has been thinking getting involved in this mess. Either he did not do his homework or he will try to use this drama to get in the drivers seat for the control of the license.