<SEC-DOCUMENT>0000314590-16-000038.txt : 20161110
<SEC-HEADER>0000314590-16-000038.hdr.sgml : 20161110
<ACCEPTANCE-DATETIME>20160913120329
<PRIVATE-TO-PUBLIC>
ACCESSION NUMBER:		0000314590-16-000038
CONFORMED SUBMISSION TYPE:	CORRESP
PUBLIC DOCUMENT COUNT:		1
FILED AS OF DATE:		20160913

FILER:

	COMPANY DATA:	
		COMPANY CONFORMED NAME:			SASOL LTD
		CENTRAL INDEX KEY:			0000314590
		STANDARD INDUSTRIAL CLASSIFICATION:	CRUDE PETROLEUM & NATURAL GAS [1311]
		IRS NUMBER:				000000000
		STATE OF INCORPORATION:			T3
		FISCAL YEAR END:			0630

	FILING VALUES:
		FORM TYPE:		CORRESP

	BUSINESS ADDRESS:	
		STREET 1:		1 STURDEE AVE
		STREET 2:		ROSEBANK
		CITY:			JOHANNESBURG
		STATE:			T3
		ZIP:			2196
		BUSINESS PHONE:		01127114413111

	MAIL ADDRESS:	
		STREET 1:		P O BOX 5486
		CITY:			JOHANNESBURG
		STATE:			T3
		ZIP:			99999

	FORMER COMPANY:	
		FORMER CONFORMED NAME:	SASOL LTD/ADR/
		DATE OF NAME CHANGE:	20000101
</SEC-HEADER>
<DOCUMENT>
<TYPE>CORRESP
<SEQUENCE>1
<FILENAME>filename1.txt
<TEXT>
14 September 2016

Mr Brad Skinner
Senior Assistant Chief Accountant
Office of Natural Resources
Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549

Dear Mr. Skinner,


Sasol Limited Annual Report on Form 20-F for the Year Ended 30 June 2015
Filed 9 October 2015
File No. 1-31615

We refer to the further comment letter, dated 30 August 2016, from the
staff of the Office of Natural Resources (the "Staff") continuing
correspondence relating to the Form 20-F (the "Filing") of Sasol Limited
(the "Company") for the year ended 30 June 2015. Set forth below are the
responses to the Staff's further comment letter, which have been provided
in each case following the text of the comment in the Staff's letter.

Standardized Measure of Discounted Future net Cash Flows Relating to
Proved Reserves, page G-9

1. Based on your response to comment one, it appears that the contracted
transportation capacity reservation costs must be incurred in order to
deliver your produced sales gas to market. Given this, it appears that the
portion of those costs incurred over the forecast life of your proved
reserves should be considered in determining the economic producibility of
those reserves. To the extent that the revenue from your proved reserves
does not offset the costs of operation, including applicable
transportation costs, the quantities would not be considered economically
producible and should not be reported as proved reserves.

Response
We agree with the Staff's observation that transportation costs must be
incurred in order to deliver produced sales gas to market.

The Company would like to advise that Canada reserves represent 1,6% of
Sasol's Proved Reserves as at 30 June 2015.

Of the R 1 672,9 million future cost included in the Filing, only
R 166,6 million is actually required to transport the produced sales
gas to market; the remaining cost represents unused capacity which the
Company markets on an ad hoc basis. Although such marketing has been
successful in the past no future revenue from this marketing is included
in the calculation of the standardized measure of discounted future net
cash flows.

The Company has reviewed its calculation of proved reserves for financial
year 2015 by adjusting future net cash flows used to determine economic
producibility to include that portion of the transportation capacity
reservation cost which is actually required to transport the produced
sales gas to market (the "applicable transportation costs"). The effect of
this change is to reduce the period of economic production by a maximum of
one year, with a resulting small reduction in the proved reserves. The 2015
proved reserves are consequently reduced from 116,8 billion cubic feet to
115,1 billion cubic feet. This reduction represent a 0,02% change in Sasol's
Proved Reserves as at 30 June 2015. The impact on the financial statements
would have been R6 million higher depreciation, which represents a 0,04%
change, and lower profit before tax by 0,01%  for the period ending
30 June 2015. The amounts are immaterial to both the reserve information
and the financial statements and therefore no restatement will be made.

Proved reserves for financial year 2013 and 2014 were estimated with
applicable transportation costs included in the calculation to determine
the period of economic production. There is therefore no revision or
impact on the 2013 and 2014 reserves as reported.

In all future filings, beginning with the annual report on Form 20-F for
the year ended 30 June 2016, the Company will ensure reserves are
determined with applicable transportation costs included in the calculation
to determine the period of economic production.

2. Please expand your disclosure to provide an explanation for the negative
undiscounted future net cash flows relating to proved reserves for Canada
and Gabon. Refer to FASB ASC 932-235-50-36.

Response
The Company has referred to the disclosure requirements under
FASB ASC 932-235-50-36 and acknowledges the Staff's comment.

The Company has considered the impact of unutilised transportation cost
on the standardized measure of discounted future net cash flows. The
Company believes that including these costs in the standardized measure
presented in the Filing, combined with a suitable narrative, provides
a fair presentation to the user of the Form 20-F.

In all future filings, beginning with the annual report on Form 20-F
for the year ended 30 June 2016, the Company will revise the disclosure
to provide a narrative explanation for any negative undiscounted future
net cash flows relating to proved reserves.

Illustrative disclosure based on the Filing

The undiscounted future net cash flows for Canada in 2013, 2014 and
2015 and for Gabon in 2015 are negative as a result of future production
and development costs, primarily contractually committed costs and asset
retirement costs which are not directly related to future production or
dependent upon the continuation of production and will be incurred even
in the event of no future production. For both assets these costs are
fully responsible for the negative future cash flow.

In Canada, the cost of unused gas transportation capacity is included
which the Company markets on an ad hoc basis. Although such marketing
has been successful in the past no future revenue from this marketing
is included in the calculation of the standardized measure of discounted
future net cash flows.

We acknowledge that:

* The Company is responsible for the adequacy and accuracy of the
disclosure in the filing;
* Staff comments or changes to disclosure in response to Staff
comments do not foreclose the Commission from taking any action
with respect to the filing; and
* The Company may not assert Staff comments as a defence in any
proceeding initiated by the Commission or any person under the
federal securities laws of the United States.

We appreciate the Staff's review of Filing. Should the Staff have any
questions or require any additional information, please telephone the
undersigned at +27-11-441-3422. My email address is
Bongani.Nqwababa@sasol.com.


Yours faithfully


/s/ Paul Victor
Paul Victor
Chief Financial Officer
</TEXT>
</DOCUMENT>
</SEC-DOCUMENT>
