BEFORE THE OIL AND GAS
CONSERVATION COMMISSION
OF
THE STATE OF COLORADO
IN THE MATTER OF THE APPLICATION OF )
UNITED STATES EXPLORATION, INC. TO )
AMEND ORDERS NOS. 232-1, ET SEQ. AND )
499-15 TO SEGREGATE A 320-ACRE DRILLING ) CAUSE NO.
232
AND SPACING UNIT INTO TWO 160-ACRE )
DRILLING AND SPACING UNITS FOR THE ) CAUSE NO. 499
PRODUCTION OF GAS AND ASSOCIATED )
HYDROCARBONS FROM THE
"J" AND DAKOTA )
SAND FORMATIONS, WATTENBERG FIELD, )
WELD COUNTY, COLORADO )
IN THE MATTER OF THE APPLICATION OF )
UNITED STATES EXPLORATION, INC. FOR THE )
ESTABLISHMENT OF AN EXPLORATORY )
DRILLING UNIT FOR THE PRODUCTION OF )
OIL AND/OR GAS FROM THE SHANNON, )
SUSSEX, CODELL, NIOBRARA AND DAKOTA )
FORMATIONS COVERING CERTAIN LANDS )
LOCATED IN WELD COUNTY, COLORADO )
IN THE MATTER OF THE APPLICATION OF )
UNITED STATES EXPLORATION, INC. TO ALLOW )
COMMINGLING OF THE SHANNON, SUSSEX, )
CODELL, NIOBRARA,
"J" SAND AND DAKOTA )
FORMATIONS COVERING THE LANDS )
ENCOMPASSED WITHIN THE EXPLORATORY )
UNIT REQUESTED ABOVE )
VERIFIED
APPLICATION
COMES NOW, the Applicant, United States Exploration, Inc., by and
through its attorneys, Bjork, Lindley, Danielson & Little, P.C., and
respectfully petitions the Oil and Gas Conservation Commission of the State of
Colorado as follows:
I
The Commission, in Cause No. 232 in Order No. 232-3 and subsequent
orders, established 320-acre drilling and spacing units for the production of
gas and associated hydrocarbons from the J Sand Formation underlying certain lands located in Weld County,
Colorado, including the following described lands:
Township 4 North, Range 63 West, 6th P.M.
Section 9: N/2
The Commission, in Cause No. 499 in Order No.499-15 and subsequent
orders, established 320-acre drilling and spacing units for the production of
gas and associated hydrocarbons from the Dakota Formation underlying certain
lands located in Weld County, Colorado, including the following described
lands:
Township 4 North, Range 63 West, 6th P.M.
Section 9: N/2
By Order No. 232-23, the Commission allowed the drilling of a second
well upon each 320-acre unit in the area in and around the lands described
above.
II
Applicant is the owner of oil and gas leasehold interests in lands
described as follows in all formations:
Township 4
North, Range 63 West, 6th
P.M.
Section 9: NE/4
containing 160 acres,
more or less.
Applicant alleges and states that no well has heretofore been drilled
to the Dakota and J Sands Formations
underlying the N/2 of Section 9, Township 4 North, Range West, 6th P.M.
Applicant desires to drill a well for the production of gas and associated
hydrocarbons from the Dakota and J Sand Formation at a location on its leasehold in the N/2 of said
Section 9 and hereby petitions the Commission to issue an order segregating the
above-described 320-acre drilling and spacing unit into two 160-acre drilling
and spacing units for production of gas and associated hydrocarbons from the
Dakota and J Sand Formations,
with the NE/4 of said Section 9 being one such unit and the NW/4 of said
Section 9 being the other unit pursuant to COGCC Special Rule 318A.
III
Potentially productive formations underlying the N/2 of said Section 9 , Township 4 North, Range 63 West, 6th P.M. also include
the Shannon, Sussex, Codell and Niobrara Formations which are not presently
spaced by this Commission. Pursuant to
the provisions of §34-60-116(2), Colorado Revised Statutes, as
amended in 1991, Applicant proposes to establish an exploratory drilling unit
comprising the 160 acres described as the NE/4 of said Section 9 , Township 4
North, Range 63 West, 6th P.M. for the exploration for and production of oil
and/or gas from the formations above enumerated. Applicant further acknowledges that experience
in the area has indicated that it may be necessary to drill more than one well
per 160 acres to adequately and efficiently drain said 160acre drilling and
spacing unit as to the Shannon, Sussex, Codell and Niobrara Formations and
requests that such spacing order allow the drilling of additional wells, not to
exceed a total of four wells, on said unit for the production of oil and gas
from the aforesaid formations. As to the
Dakota Formation, Applicant believes that one well will adequately and efficiently
drain 160 acres and that the permitted location should
be in accordance with spacing established for the Dakota and "J"
Sand. Applicant requests that the location of wells for production from any or
all of the Shannon, Sussex, Codell and Niobrara Formations be located in the
center of the 40-acre quarter-quarter section upon which the same is located
with a tolerance of 200 feet in any direction, with the exception that as to
any well which is completed in and productive of gas and associated
hydrocarbons from the "J" Sand Formation at a location permitted
under Orders Nos. 232-1, et seq. and the Dakota Formation as set forth above
shall be allowed as an exception well for production from the Shannon, Sussex,
Codell and Niobrara Formations, and be the permitted well for those formations
as to the 40-acre tract upon which said J well is located.
IV
Applicant further alleges that in many instances it will be necessary,
in order to economically and efficiently drain said reservoirs, to develop the
Shannon, Sussex, Codell, Niobrara, J Sand and Dakota Formations in the same wellbore and to commingle the
production of oil and/or gas from one or more of said formations in the same
wellbore. Applicant proposes to present
evidence to the Commission to the effect that such commingling is necessary and
desirable, and will not adversely affect any or all of said reservoirs or any
freshwater zones, and Applicant requests that the Commission issue its order
allowing such commingling without hearing, subject to the filing and approval
of the permits and sundry notices as required by the Commission.
V
Applicant believes that the granting of this Application is necessary
for the prevention of waste, for the protection of correlative rights, to
assure the efficient and orderly development of the Shannon, Sussex, Codell,
Niobrara, "J" Sand and Dakota common sources of supply, and to assure
the greatest ultimate recovery of oil and/or gas.
VI
Attached hereto as Exhibit A are the names and addresses of all
interested parties as defined by the statutes and the rules of this Commission
who own interests and are entitled to receive notice within the area affected
by this Application.
WHEREFORE, Applicant respectfully requests that this matter be set for
hearing by the Commission; that notice thereof be given as required by law; and
that upon such hearing this Commission issue its order granting this
Application as requested herein.
Applicant further requests that the Commission in its order grant such
other provisions as the Commission may find to be necessary or desirable in the
cause.
DATED this 6th day of June 2002.
Respectfully submitted,
BJORK, LINDLEY, DANIELSON & LITTLE, P.C.
_______________________________________
Peter A. Bjork
1600 Stout Street, Suite 1400
Denver, Colorado 80203
Applicant's
Address:
United States
Exploration, Inc.
1560
Broadway, Suite 1900
Denver,
CO 80202
EXHIBIT A
Township 4 North, Range 63 West, 6th P.M.
Section 9: N/2
Pamela Brown Sankey
15940 NE Morris
Street
Portland, OR 97230
Carolyn Brown
Hawken
14754 Lexington
Avenue
Anacortes, WA 98221
Pamela Brown Sankey
Carolyn Brown
Hawken
c/o Barbara T. Brown
217 Bellaire Street
Denver, CO 80220
Rex Monahan
P.O. Box 1231
Sterling, CO 80751
RME Land Corp.
(NE/4)
(f/k/a
Union Pacific Land Resources Corporation)
P.O. Box 1330
Houston, TX
77251-1330
RME Petroleum
Company (NW/4)
(f/k/a
Union Pacific Land Resources Corporation)
P.O. Box 1330
Houston, TX
77251-1330