BEFORE
THE OIL AND GAS CONSERVATION COMMISSION
OF
THE STATE OF
IN
THE MATTER OF THE PROMULGATION )
AND ESTABLISHMENT OF FIELD RULES ) CAUSE NO. 112
TO GOVERN OPERATIONS IN THE ) DOCKET NO. 0210-UP-07
IGNACIO-BLANCO FIELD,
COUNTY,
VERIFIED APPLICATION
COMES NOW, the Applicant,
Chevron U.S.A. Inc., a
Applicant is the operator
and/or working interest owner of one or more oil and gas leases covering all or
a portion of the following described lands within the Ignacio Blanco Field,
Township 34 North, Range 9 West, N.M.P.M.
Section
8U: N/2
Section
5U: Lots 1, 2, 3, & 4
(hereinafter
"Application Lands")
Under its order in Order No.
112-60, the Commission designated the Application Lands as a 425.80 acre
drilling and spacing unit for the production of gas from the Fruitland coal
seams. Under its Order No. 112-57, the
Commission allowed an optional second well to be drilled upon the Application
Lands for the production of gas from the Fruitland coal seams.
Applicant has plans to drill
the Koshak BA-A well as an optional second well on the Application Lands for
the production of gas from the Fruitland coal seams. In preparation for the drilling of such well,
Applicant made reasonable efforts to allow each owner within the Application
Lands the opportunity to lease or participate in the drilling of this
well. Notwithstanding such efforts, one
unleased owner, James R. Sinton, elected not to so lease or participate in the
drilling of the well.
Applicant requests that such
nonconsenting owner be force pooled under the applicable provisions of C.R.S. §
34-60-116 and the rules of the Commission.
Without prejudice to the generality of the foregoing, Applicant requests
that such unleased owner be deemed leased under the applicable provisions of
C.R.S. § 34‑60‑116(7)(c) and that consenting owners be entitled to
recover costs from the consenting owner's share of production to the maximum
degree provided for under C.R.S. §34-60-116(7)(b)(l)and(ll).
Applicant states to the best
of its information and belief that the "interested party" and the
owner as defined in the Oil and Gas Conservation Act of the State of
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 force pooling James R. Sinton in respect of the
drilling of such well. 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 9th day of
September, 2002.
Respectfully
submitted,
GORSUCH
KIRGIS LLP
By: William A. Keefe
Tower
I, Suite 1000
1515
Arapahoe Street
Denver,
Colorado 802020
303/376-5000
Applicant's
Address
ChevronTexaco
Mid-Continent
Business Unit
Attn:
Matthew D. Hutchison
11111
So. Wilcrest, Rm.S-1219A
Houston,
TX 77009
VERIFICATION
STATE
OF TEXAS )
) ss.
COUNTY
OF HARRIS )
Matthew D. Hutchison, as Landman of Chevron U.S.A.
Inc., upon oath, deposes and says that he has read the foregoing Verified
Application before the Oil and Gas Conservation Commission of the State of
Colorado, and states that the matters contained therein are true to the best of
his knowledge and belief.
Subscribed to and sworn to before me this _____ day of
September, 2002, by Matthew D. Hutchison, as Landman of Chevron U.S.A, Inc.
My commission expires:
Notary
Public
EXHIBIT A
INTERESTED
PARTY
James
R. Sinton
P.O.
Box 1844
Durango,
CO 73069
James
R. Sinton
c/o
Frank Sinton
P.O.
Box 2705
Durango,
CO 81312