Lapidoth-Heletz: What Exactly Is Blocking The Permit, And What Already Sits As Environmental Risk
The Heletz bottleneck is no longer generic bureaucracy. The 2025 filing shows a focused planning and environmental dispute around Heletz 3, while legacy contamination and guarantee obligations already sit on the balance sheet and the restart timeline has slipped to 2027.
What This Follow-Up Is Actually Isolating
The main article already framed the core gap at Lapidoth-Heletz: cash is not what restarts the Heletz field. This continuation isolates the other side of the equation, what exactly is stuck in the permit path, and what environmental layer is no longer just a footnote but is already embedded in both the planning process and the financial statements.
The first point is that the field is not waiting for one more signature. Under the terms of the holding right, commercial production can begin only after the plan is approved and the required approvals under planning and construction law are obtained. So the bottleneck was built into the operating path from the start.
The second point is that this friction now has a name and an address. The Ministry of Environmental Protection explicitly flagged Heletz 3 as a drilling site located, in its view, in an area of high ecological sensitivity and therefore one that should not be reactivated. The partnership disputes that position and continues to advance Heletz 3 as part of the field-development plan. From that point on, the permit issue is no longer a vague timetable problem. It becomes a concrete dispute over what the plan can include and what can actually be reactivated.
The third point is that the environmental layer is not only forward-looking. On one hand, the partnership says it cannot assess the economic significance of fixing past environmental hazards or the full scope of those hazards. On the other hand, it also says the financial statements include a sufficient provision for the ministry’s requirements on soil and water contamination and on well sealing. That is not necessarily a contradiction, but it does say something sharp: what has already been identified is inside the accounting, while what is still unresolved at the planning and environmental level remains an open layer above it.
| Junction | What happened | Why it matters |
|---|---|---|
| September 2018 to September 2019 | A detailed plan was filed and later updated | The problem is not lack of a plan, but inability to get that plan approved |
| November 2021 to July 2022 | The environmental-impact statement was filed and then supplemented | The process moved long ago from initiation into substantive environmental review |
| December 2022 | The planning bureau said the number of wells in the plan was expected to be reduced materially | The plan was already not expected to pass in its original form |
| July 23, 2024 | The environmental ministry identified disputed drilling sites and said Heletz 3 should not be reactivated | This is where the bottleneck became specific rather than generic |
| November 2025 | The partnership submitted a legal opinion on the statutory basis for the proposed drilling plan | Even late in 2025, the argument was still about the plan’s legal-planning foundation |
| As of the report date | The plan was still waiting to be scheduled for discussion before the district committee plenary | Without that discussion, there is no transition to the next stage |
The Permit Is Stuck in Two Layers, Not One
A superficial reading says this is simply a planning delay. The more accurate reading is sharper: there is both a planning path that has not closed and an environmental layer that shapes that path from inside.
On the planning side, the filing shows a long sequence. The detailed plan was filed in 2018, updated in 2019, the environmental-impact statement was filed in 2021, supplements were filed in 2022, and in that same year the planning bureau already said the number of wells was expected to be reduced materially. In June 2023, the site-specific review of the wells and their locations was presented, and an in-principle district committee discussion was expected later that year. With the outbreak of the Iron Swords war, that discussion was postponed, and by the report date no new date had been set.
On the environmental side, the delay is no longer abstract. In July 2024, the Ministry of Environmental Protection did not just make generic comments. It sent the planning bureau a specific position on drilling sites included in the development plan that it viewed as disputed. Heletz 3 sits at the center of that dispute. In November 2025, at the planning bureau’s request, the partnership had to submit a legal opinion on the statutory basis for the proposed oil drilling plan, parts of which lie in areas of relatively high environmental sensitivity.
The implication is that the field is not merely waiting for the end of a process. It is waiting for a decision on what remains inside the plan at all, and what a workable development route looks like if one of the key wells in that plan, Heletz 3, is being treated by the ministry as a well that should not be reactivated.
That is also the difference between a routine delay and a real choke point. In a routine delay, the plan is assumed to be fundamentally viable and time is the only issue. Here, the filing shows the plan itself is still under dispute, and that the more environmentally sensitive area is dictating the pace.
Heletz 3 Is Not Just Another Well. It Is Where Planning Meets Accounting
The value of that distinction does not stop in the risk section. It already flows into the asset valuation itself. Note 7 explicitly links the prolonged regulatory process with the planning authorities to the need to update the oil asset’s impairment.
The critical datapoint is that there was no material change in reserves for Heletz 3 and Heletz A41 at the end of 2025, aside from a negligible change in 2P reserves to about 169 thousand barrels. And yet, during 2025 the partnership recorded an impairment loss of about NIS 1.16 million while the estimated return-to-production date moved from 2026 to 2027. In other words, what was impaired here is not a new geological story but the value of time, certainty, and planning feasibility.
The filing also shows that this pain is not distributed evenly across the wells:
Heletz 3 ends 2025 with an impairment reserve of NIS 5.362 million and a net carrying amount of NIS 2.365 million, versus Heletz 41A with an impairment reserve of NIS 2.202 million and a net carrying amount of NIS 3.437 million. The filing does not explicitly say this is a direct result of the dispute around Heletz 3. But it is hard to ignore the proximity between the two facts: in the same period in which the ministry explicitly objects to reactivating Heletz 3, that same well also carries the heavier impairment layer.
This is exactly where planning meets accounting. The partnership can keep advancing a legal position, but the financial statements are already pricing the wait.
Historical Liability Has Not Been Solved. It Has Only Been Narrowed
There is another distinction here, and it may be the most important one in the entire thread: the partnership disputes historical responsibility, but at the same time it still has to move environmental remediation forward if the field is to become operational.
The legacy-contamination layer did not begin in 2025. As far back as January 2012, the partnership received a warning from the environmental ministry following suspected contamination from hazardous-waste residues. In February 2014, additional warnings were issued, including claims of unauthorized evacuation of material from the drainage pond and infiltration into the soil. In 2016, the ministry demanded sampling plans, removal work, updated land surveys, and additional information on pipelines and site infrastructure. In other words, the problematic environmental background at Heletz is not a byproduct of a new permitting dispute. It is an older layer that follows the restart effort.
What matters is that the partnership does not accept a framing of automatic liability. It explicitly says that most of the alleged damage was not caused by it and emphasizes the principle that the polluter pays. In 2017, it also received clarification from the petroleum commissioner that the Heletz holding deed neither adds to nor subtracts from any legal obligation to clean historical environmental damage that already existed under prior law.
But this is exactly the point a reader can miss: even if the legal argument over historical responsibility stays open, it does not remove the need to make the field fit for an approved operating path. That is why, within the environmental-impact process, the partnership submitted a supplemental soil-survey plan that was approved by the environmental ministry. According to the planned-work description, a supplemental land survey will first be carried out in the yards and compounds required to operate the production system before production is renewed, and later, before each drilling site is reactivated, a supplemental land survey and treatment of contaminated soil will be performed before production from that site begins.
So the dispute over who is to blame and the need to show what must be fixed before production are two different tracks. The first matters legally. The second is what determines whether the field can actually restart.
What Is Already Sitting in the Statements, and What Is Still Open
From an accounting perspective, the partnership is trying to draw a clear boundary: the demands that have already been identified were translated into provisions and guarantees, so in its view the known risk layer already carries a number. Note 9 says the financial statements include a sufficient provision for the ministry’s requirements regarding soil and water contamination, including well-sealing costs. During 2025 these provisions were reduced by about NIS 237 thousand, after increasing by about NIS 231 thousand in 2024. At the same time, the board says current and non-current liabilities consist mainly of provisions for soil contamination treatment at the Heletz field and additional well-sealing provisions, totaling NIS 7.194 million at the end of 2025.
In addition, the partnership has an autonomous irrevocable bank guarantee of USD 2 million in favor of the state to secure compliance with the terms of the holding deed. That guarantee has been extended several times, most recently through December 31, 2027. The filing also says that, as of the financial-statement approval date, the partnership had not yet begun the actual well-sealing work.
But anyone who stops there misses the second half of the story. The environmental-risk section states explicitly that the partnership cannot assess the economic significance of correcting past environmental hazards or the overall scope of those hazards. So the correct read is two-layered:
| Layer | What is relatively closed | What is still open |
|---|---|---|
| Accounting | There are provisions, liabilities, and a USD 2 million guarantee | Those numbers relate to what has been identified and recognized, not necessarily to everything the process may still surface |
| Planning | There is a plan, an environmental-impact statement, supplements, and a legal opinion | There is still no district committee plenary discussion and no resolution on Heletz 3 |
| Environment | A supplemental soil-survey plan has been approved and corrective actions are committed | The full scope and economic meaning of past hazards remain unquantified in the partnership’s own disclosure |
That is the core of it. The numbers in the statements do not prove that the risk is closed. They prove only that the risk is no longer theoretical.
Bottom Line
The obstacle at Heletz is no longer "regulation" in the broad sense. It narrows to three concrete tests: a district-level discussion that still has not been scheduled, an explicit environmental dispute around Heletz 3, and the need to complete land surveys and environmental treatment before actual reactivation.
Why this matters is that the filing shows how those three layers connect. When return to production slips to 2027 despite only a negligible change in reserves, that is a sign that Heletz value now depends less on whether oil exists and more on whether there is a development route that can be approved, defended environmentally, and executed in practice.
That is also why the intelligent counter-thesis is not that everything is frozen forever. The dispute could still be resolved through a narrower plan, relocation of drilling points, or proof that the existing provisions really are enough. But as of end-2025, anyone trying to understand Heletz has to read the planning and environmental map before reading the financial one.
Disclosure: Deep TASE analyses are general informational, research, and commentary content only. They do not constitute investment advice, investment marketing, a recommendation, or an offer to buy, sell, or hold any security, and are not tailored to any reader's personal circumstances.
The author, site owner, or related parties may hold, buy, sell, or otherwise trade securities or financial instruments related to the companies discussed, before or after publication, without prior notice and without any obligation to update the analysis. Publication of an analysis should not be read as a statement that any position does or does not exist.
The analysis may contain errors, omissions, or information that changes after publication. Readers should review official filings and primary sources before making decisions.