BEFORE THE OIL & GAS
CONSERVATION COMMISSION
OF THE STATE OF COLORADO
|
IN THE MATTER OF THE APPLICATION OF AMOCO PRODUCTION
COMPANY, THE SOUTHERN UTE INDIAN TRIBE, d/b/a RED WILLOW PRODUCTION COMPANY,
ET AL., 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 AND ARCHULETA 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 the Southern
Ute Indian Tribe, d/b/a Red Willow Production Company, J.M. Huber Corporation,
Hallwood Petroleum, Inc., SG Interests I, Ltd., San Juan Basin Consortium, Four
Star Oil & Gas Company, Vastar Resources, Inc., EnerVest San Juan
Operating, LLC, Pablo Operating Company, Petrogulf Corporation, Elm Ridge
Resources, Maralex Resources, Inc., and Don Gosney (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 and Archuleta Counties,
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 and Archuleta County, Colorado, as described on Exhibit A attached
hereto and incorporated by reference.
3.
That insofar as this
Application concerns lands within the jurisdiction of the Southern Ute Indian
Tribe, it is submitted to this Commission in accordance with the terms of the
Memorandum of Understanding dated August 22, 1991 between the Bureau of Land
Management (“BLM”) and this Commission and separate Memorandum of Understanding
dated August 22, 1991 between the Bureau of Indian Affairs, the BLM and the
Southern Ute Indian Tribe. In the lands
described on Exhibit A, the Southern Ute Indian Tribe owns significant surface
interests and significant mineral interests underlying such lands.
4.
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 and, with respect to Tribal lands, the rules and
regulations of the BLM.
6.
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.
7.
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.
8.
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”) which shall apply to non-tribal operations on
lands outside of the jurisdiction of the Southern Ute Indian Tribe. The 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 on such non-tribal lands.
9.
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 5 above subject to the Director approving exceptions
for the permitted well location as provided in paragraph 7, 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 concerning non-tribal
operations on lands outside of the jurisdiction of the Southern Ute Indian
Tribe.
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
SOUTHERN
UTE INDIAN TRIBE, d/b/a RED WILLOW PRODUCTION COMPANY, J.M. HUBER CORPORATION,
HALLWOOD PETROLEUM, INC., SG INTERESTS I LTD., SAN JUAN BASIN CONSORTIUM, FOUR
STAR OIL & GAS COMPANY, VASTAR RESOURCES, INC., ENERVEST SAN JUAN
OPERATING, LLC, PABLO OPERATING COMPANY, PETROGULF CORPORATION, ELM RIDGE
RESOURCES, MARALEX RESOURCES, INC., and DON GOSNEY
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:
|
Southern Ute Indian Tribe,
d/b/a Red Willow Production
Company P.O. Box 737 Ignacio, Colorado 81137 |
Don Gosney P.O. Box 367 6699 C.R. 521 Bayfield, Colorado 81122 |
|
J.M. Huber Corporation 1050 17th Street,
Suite 1850 Denver, Colorado 80202 |
Hallwood Petroleum, Inc. 4610 S. Ulster Street, Suite
200 Denver, Colorado 80237 |
|
SG
Interests I, Ltd. 1331 Lamar, Suite 501 Houston, Texas 77010 |
San Juan Basin Consortium 370 17th Street,
Suite 3210 Denver, Colorado 80202 |
|
Four
Star Oil & Gas Company 4601
DTC Boulevard Denver,
Colorado 80237 |
Vastar
Resources, Inc. 15375
Memorial Drive Houston,
Texas 77079 |
|
EnerVest San Juan Operating,
LLC 3473 Main Avenue, Suite 23 Durango, Colorado 81301 |
Pablo Operating Company 309 West 17th
Street, Suite 1200 Fort Worth, Texas 76102 |
|
Petrogulf Corporation 518 17th Street,
Suite 1455 Denver, Colorado 80202 |
Elm Ridge Resources 12225 Greenville Avenue,
#950 Dallas, Texas 75423-9362 |
|
Maralex Resources, Inc. P.O. Box 338 775 Goddard Avenue Ignacio, Colorado 81137 |
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 Southern Ute
Indian Tribe, d/b/a Red Willow Production Company, J.M. Huber Corporation,
Hallwood Petroleum, Inc., SG Interests I, Ltd., San Juan Basin Consortium, Four
Star Oil & Gas Company, Vastar Resources, Inc., EnerVest San Juan
Operating, LLC, Pablo Operating Company, Petrogulf Corporation, Elm Ridge
Resources, Maralex Resources, Inc., and Don Gosney, 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
TO AMOCO PRODUCTION
COMPANY, ET AL APPLICATION
LIST OF LANDS INCLUDED,
SOUTH OF THE UTE LINE
ARCHULETA & LA PLATA COUNTIES, COLORADO
Township 34 North, Range 6 West, N.M.P.M. (S.U.L.)
Sections 3 thru 10: All
Sections 15 thru 22: All
Sections 27 thru 34: All
Township 34 North, Range 7 West, N.M.P.M. (S.U.L.)
Sections 1 thru 36: All
Township 34 North, Range 8 West, N.M.P.M. (S.U.L.)
Sections 1 thru 15: All
Section 16: S/2
Sections 17: All
Section 18: All
Section 19: W/2
Sections 20 thru 23: All
Section 24: S/2
Sections 25 thru 28: All
Section 29: E/2
Sections 30 thru 36: All
Township 34 North, Range 9 West, N.M.P.M. (S.U.L.)
Section 1: E/2
Sections 2 thru 11: All
Section 12: E/2
Sections 13 thru 35: All
Township 34 North, Range 10 West, N.M.P.M. (S.U.L.)
Section 12: All
Section 13: All
Section 14: S/2
Sections 22 thru 36: All
Township 33 North, Range 6 West, NMPM
Sections 3 thru 10: All
Sections 16 thru 21: All
Section 27: W/2
Sections 28 thru 34: All
Township 33 North, Range 7 West, NMPM
Sections 1 thru 7: All
Section 8: E/2
Sections 9 thru 25: All
Section 26: W/2
Sections 27 thru 34: All
Section 35: W/2
Section 36: N/2
Township 33 North,
Range 8 West, N.M.P.M.
Sections 1 thru 18: All
Section 19: N/2
Section 20: N/2
Sections 21 thru 27: All
Section 35: N/2
Section 36: All
Township 33 North,
Range 9 West, N.M.P.M.
Section 1: All
Section 2: All
Section 3: N/2
Sections 4 thru 24: All
Section 29: W/2
Section 30: All
Section 31: N/2
Section 32: W/2
Township 33 North, Range 10 West, N.M.P.M.
Sections 1 thru 6: All
Section 10: All
Section 11: E/2
Section 12: All
Section 14: W/2
Section 15: All
Section 16: All
Section 20: E/2
Section 21: W/2
Township 33 North, Range 11 West, N.M.P.M.
Section 1: E/2
Section 13: N/2
Section 14: All
Township 32 North, Range 5 West, N.M.P.M.
Sections 5 thru 8: All
Sections 17 thru 20: All
Township 32 North, Range 6 West, N.M.P.M.
Sections 1 thru 4: All
Section 5: N/2
Section 7: E/2
Section 8: E/2
Sections 9 thru 16: All
Section 17: E/2
Section 18: All
Section 23: All
Section 24: All
Township 32 North, Range 7 West, N.M.P.M.
Sections 3 thru 6: All
Section 7: E/2
Sections 8 thru 11: All
Sections 13 thru 17: All
Section 19: E/2E/2
Sections 20 thru 23: All