BEFORE THE OIL & GAS
CONSERVATION COMMISSION
OF THE STATE OF COLORADO
|
IN THE MATTER OF THE APPLICATION OF AMOCO PRODUCTION
COMPANY, HALLWOOD PETROLEUM, INC., J. M. HUBER CORPORATION, FOUR STAR
OIL & GAS COMPANY AND ENERVEST SAN JUAN OPERATING, LLC, FOR AN ORDER
ALLOWING AN OPTIONAL SECOND WELL IN THE DRILLING AND SPACING UNITS COVERING
THE FRUITLAND COAL SEAM FORMATION, IGNACIO-BLANCO FIELD, LA PLATA COUNTY,
COLORADO |
) ) ) ) ) ) ) ) ) ) |
CAUSE NO. 112 Docket No. __________ |
APPLICATION
COMES NOW Amoco Production Company, by and through its
attorney Bradley S. McKim of McKim Law Offices, LLC, together with J.M. Huber
Corporation, Hallwood Petroleum, Inc., Four Star Oil & Gas Company,
EnerVest San Juan Operating, LLC (collectively referred to herein as
“Applicants”), by and through their attorneys Clanahan, Tanner, Downing and
Knowlton, P.C., make application to the Oil and Gas Conservation Commission of
the State of Colorado, for an order to permit an optional second well in the
drilling and spacing units for the Fruitland Coal Seam formation. In support thereof, the Applicants state and
allege as follows:
1.
That the Applicants are the
owners of numerous leasehold interests in La Plata County, Colorado, located
within the area requested for spacing.
2.
That the Applicants are
requesting that two (2) wells be permitted in the existing drilling and spacing
units of 320 acres for the Fruitland Coal Seam formation covering the lands in
La Plata County, Colorado, as described on Exhibit A attached hereto and
incorporated by reference.
3.
In support of the requested
order, Applicants assert that one well will not efficiently and economically
drain each of the 320-acre drilling and spacing units contained in Exhibit A,
and that additional wells are necessary to prevent waste, protect correlative
rights and to recover gas and associated hydrocarbons from the Fruitland coal
formation all in accordance with the Colorado statutes, the rules and
regulations of this Commission.
5.
That dual completion of the
Mesaverde, Dakota or Pictured Cliffs formations with the Fruitland Coal Seam
formation and downhole commingling with such other productive formation be
authorized in accordance with Commission Rule 322.
6.
That the Director may without
further notice and hearing approve exceptions to the permitted well locations
due to topography or surface hazards or the recompletion of wells previously
drilled at permitted locations, provided that the Director is satisfied that
appropriate notice of such exception location is afforded to offset owners as
required by Commission rules.
7.
Applicants further state that
the requested additional wells can be developed in a manner consistent with
protection of public health, safety and welfare. To this end, Applicants shall propose a Health, Safety and
Welfare Plan (“HS&W Plan”) and request that it be incorporated and made
part of the requested order. Applicants
request a finding by the Commission that the HS&W Plan adequately addresses
concerns related to the environment and public health, safety and welfare not
otherwise addressed by Commission rule.
8.
Exhibit B attached hereto and
made part hereof is the list of the names of "Owners" required to be
notified in accord with Commission Rule 508(a), including within the areas
covered by this Application. To the
best of Applicant's knowledge and belief, Exhibit B contains the names of all
such owners.
WHEREFORE, Applicants respectfully request that this
matter be set for hearing, that notice thereof be given as required by law and
that upon such hearing this Commission enter its order:
A. Establishing that two (2) Fruitland
Coal wells may be completed in the 320-acre drilling and spacing units for gas
and associated hydrocarbons from the Fruitland Coal Seam formation underlying
the lands set forth on Exhibit A with the second well being an optional well in
the discretion of the operator. The
permitted wells shall be located as described in paragraph 4 above subject to
the Director approving exceptions for the permitted well location as provided in
paragraph 6, above.
B. That commingling of the Fruitland
Coal Seam and the Mesaverde, Dakota or Pictured Cliffs formations be allowed
per Commission Rule 322.
C. That Applicants’ HS&W Plan shall
be incorporated as part of the Commission Order.
D. For such other findings and orders
as the Commission may deem proper or advisable in the premises.
DATED
this 6th day of March, 2000.
Respectfully submitted,
AMOCO PRODUCTION COMPANY
By:
Bradley S. McKim
McKim Law Offices, LLC
1019 8th Street,
Suite 301
Golden, Colorado 80401
(303)
216-0761
J.M.
HUBER CORPORATION, HALLWOOD PETROLEUM, INC., FOUR STAR OIL & GAS COMPANY,
ENERVEST SAN JUAN OPERATING, LLC
By:
Michael
J. Wozniak
Clanahan,
Tanner, Downing and Knowlton, P.C.
Attorneys
for Applicants
730
17th Street, Suite 500
Denver,
Colorado 80202-3580
(720)
359-9500
Applicants' Addresses:
|
J.M. Huber Corporation 1050 17th Street,
Suite 1850 Denver, Colorado 80202 |
|
|
Hallwood Petroleum, Inc. 4610 S. Ulster Street, Suite
200 Denver, Colorado 80237 |
|
|
Four
Star Oil & Gas Company 4601
DTC Boulevard Denver,
Colorado 80237 |
|
|
EnerVest San Juan Operating,
LLC 3473 Main Avenue, Suite 23 Durango, Colorado 81301 |
|
|
Amoco Production Company P. O. Box 3092 Houston, Texas 77253 |
|
STATE
OF COLORADO )
)
ss.
CITY
AND COUNTY OF DENVER )
Michael J. Wozniak, of lawful age, being first duly
sworn upon oath, deposes and says that he is the attorney for Hallwood
Petroleum, Inc., J.M. Huber Corporation, Four Star Oil & Gas Company and
EnerVest San Juan Operating, LLC, and that he has read the foregoing
Application and that the matters therein contained are true to the best of his
knowledge, information and belief.
Subscribed and sworn to before this 6th day
of March, 2000.
Witness my hand and official seal.
My commission expires:
Notary Public
STATE OF COLORADO )
)
ss.
___________ COUNTY OF
______________ )
Bradley S. McKim, of
lawful age, being first duly sworn upon oath, deposes and says that he is the
attorney for Amoco Production Company and that he has read the foregoing
Application and that the matters therein contained are true to the best of his
knowledge, information and belief.
Subscribed and sworn to
before this _____th day of March, 2000.
Witness my hand and
official seal.
My
commission expires:
Notary Public
EXHIBIT A
TO AMOCO PRODUCTION COMPANY, ET AL
APPLICATION
LIST OF LANDS INCLUDED, NORTH OF THE UTE LINE
LA PLATA COUNTY,
COLORADO
Township 35 North, Range 6 West, N.M.P.M.
Section 19: All
Section 20: All
Section 21: S/2
Section 22: W/2
Sections 27 thru 34: All
Township 35 North, Range 7 West, N.M.P.M.
Section 16: S/2
Section 17: S/2
Sections 18 thru 22: All
Section 23: S/2
Section 24: S/2
Sections 25 thru 33: All
Section 34: E/2
Section 35: All
Section 36: All
Township 35 North, Range 8 West, N.M.P.M.
Sections 13, 14: All
Section 15: S/2
Section 19: S/2
Sections 20 thru 23: All
Section 25: W/2
Section 27: W/2
Sections 28 thru 30: All
Section 34: S/2
Section 35: N/2
Section 36: S/2
Township 35 North, Range 9 West, N.M.P.M.
Section 25: All
Section 35: S/2
Section 36: All
Township 34 North, Range 6 West, N.M.P.M. (N.U.L.)
Sections 3-10: All
Sections 15-17: All
Township 34 North, Range 7 West, N.M.P.M. (N.U.L.)
Sections 1 thru 8: All
Section 9: E/2
Section 10: All
Section 11: W/2
Section 12: W/2
Section 13: All
Section 14: All
Sections 16 thru 18: All
Township 34 North, Range 8 West, N.M.P.M. (N.U.L.)
Section 1: All
Section 2: All
Section 5: W/2
Section 7: All
Section 8: All
Section 10: E/2
Sections 11 thru 16: All
Section 18: All
Township 34 ½ North,
Range 9 West, N.M.P.M. (N.U.L.)
Section 35: All
Section 36: All
Township 34 North,
Range 9 West, N.M.P.M. (N.U.L.)
Section 1:
All
Section 2: All
Section 3: E/2
Section 9 thru 12: All