San Matías Gas Pipeline (San Matías Pipeline S.A.) - evacuation of Vaca Muerta gas to the Atlantic

The gazette notice convenes the hearing and the Environmental Impact Study is the document filed: neither of the two is the Declaration. The only lead, Resolución 672/2026 of Neuquén's environmental agency, appears in social media mentions and could not be opened. Golar LNG states to the market that environmental approval was obtained in both provinces, but that is a corporate document, not an act of the State.

The Environmental Impact Study —the document it was expected from— expressly says it does not exist at this stage: the headcount needed will depend directly on the work fronts opened. The project was at Basic Engineering when the study was made.

The Environmental Impact Study commits to the tender documents carrying it, but does not publish the number. Without that figure the RIGI's 20% cannot be reconciled with the 60% of Río Negro's Ley 5805.

The amounts per hectare or per kilometer and the number of properties agreed remain unpublished. What was settled on 20 Aug is the MECHANISM, through art. Three of the Acta Acuerdo ratified by Ley 5849: the Province grants the easements required where the land falls under provincial jurisdiction and guarantees access to existing municipal, provincial and national roads; the cost of obtaining any easement is borne by the companies; and if no agreement is reached with a landholder or occupier, the companies report it to the competent bodies and to the Province for its intervention. The Environmental Impact Study only provided the national framework (Ley 21.449).

The Environmental Impact Study states that it is not defined and that the contractor sets it at Detailed Engineering. Reusing those of YPF's VMOC-VMOS oil pipeline will be assessed.

The law is known only through what its enforcement agency (Centro PyME-ADENEU) publishes: that it requires covered parties to file a sworn statement and an annual supplier development plan with a minimum of three certified companies to develop. The text was not opened, and so it is not known who is covered as an obligated party nor at what threshold.

Capacity: the Environmental Impact Study filed with Neuquén's environmental agency says 28 MMSMCD; the Acta Acuerdo ratified by Ley 5849 declares 26,500 thousand m³/d as the environmental fee's tax base; and article 1 of Resolución 873/2026 —the national act of State approving the RIGI accession— says «veintisiete millones de metros cúbicos diarios (27.000.000 m³/d)». Length: 472.5 km in the Environmental Impact Study (29 in Neuquén plus 443.5 in Río Negro), 444.35 km in the Acta for the Río Negro stretch, and «aproximadamente cuatrocientos ochenta kilómetros (480 km)» in Resolución 873/2026. They are three different acts with different purposes —technical, tax and regime classification— and they are neither averaged nor is the largest picked.

The Acta Acuerdo sets the environmental fee's formulas and coefficients (Ley M N 3.266, Resolución SEEA 170/25) but does not publish what a Unit of Value is worth. Without that value the formulas cannot be converted into pesos and it is not possible to estimate how much the project leaves under that heading.

The Acta's figure is the declared tax base of the provincial environmental fee and covers only the Río Negro stretch; the Study's comes from the technical design. The difference is 0.85 km and is not settled by averaging.

Art. 6 of the law only INVITES the municipalities in whose jurisdiction the works take place to join, and the Acta binds the Province only to «realizar sus mejores esfuerzos» and to «instar» the municipalities. It is a best-efforts obligation, not one of result: without an ordinance joining it, municipal fees and stability are not covered.

Ley 5849 orders it created by regulation and makes the approval a condition for transferring the funds. The implementing decree was not found.

Both factors are in the Acta (6,220,900 m² of pipeline area and $215 per square meter), but the inspection cost is adjusted by INDEC's CPI every 31 January and the Acta does not say from what base or from what date the first adjustment runs. Multiplying them today would be our own calculation presented as a fact.

The RIGI was created by Ley 27.742. The Acta Acuerdo itself, in its articles Four, Eleven and Twelve, cites it correctly as 27.742. The discrepancy is in the recitals of the provincial Executive's ratifying decree, not in the text of the law or the agreement.

Two figures circulate that do NOT measure the same thing and are quoted together. The 1,900 people belong to Southern Energy's complete FLNG PROJECT —that is what its own website says, opened on 20 Aug 2026— and cover vessels, interconnection, two compressor stations, SESA's onshore pipeline and the logistics base: they are not the Dedicated Pipeline's. The pipeline's 1,500 (broken down by the company into 1,100 for laying plus 400 for the compressor plant) come from the hearing and the press, with no act or corporate document backing them.

Sweep of Neuquén's Boletín Oficial: gazettes 4540 to 4604 were read, covering continuously from 30 Jan 2026 to 18 Aug 2026 (the latest published), searching the text for file 00239697 and the names «San Matías Pipeline» and «Tratayén». A SINGLE gazette matches: 4544 of 13 Feb 2026, which is the hearing notice already known. ⇒ The Environmental Impact Declaration is NOT published in the province's Boletín Oficial, and the project is not mentioned there again after the notice. THE METHOD IS CONTROLLED: the same sweep does find all four terms in gazette 4544, so a zero is not a false negative of the search. ⚠️ WHAT THIS ZERO DOES NOT PROVE: (a) that the Declaration does not exist — a resolution can be notified to the applicant without being published; (b) that there are no editions outside the numeric range — the numbering has measured anomalies, gazette 4546 is dated 16 Jun 2026 and sits between two from February; (c) anything about Río Negro, which is another jurisdiction with another procedure. ⚠️ The consequence is that Golar LNG's claim to the market —«Environmental approval obtained from the provinces of Neuquén and Río Negro»— has NO backing in Neuquén's Boletín Oficial. It may be true and unpublished; what cannot be done is cite it as an act of the State. The lead in circulation was also ruled out: Neuquén's Decreto 672/2026 exists but is a hospital security services contract, and the infoleg search engine does not index secretariat resolutions (TipoNorma=4 returns zero rows).