BEFORE THE OIL AND GAS CONSERVATION COMMISSION
OF THE STATE OF COLORADO
IN THE MATTER OF THE PROMULGATION AND ESTABLISHMENT OF FIELD RULES TO GOVERN OPERATIONS IN THE IGNACIO-BLANCO FIELD, LA PLATA COUNTY, COLORADO |
CAUSE NO.__________ DOCKET NO._________ |
VERIFIED APPLICATION
COMES NOW, the Applicant, Chevron U.S.A. Inc., a Pennsylvania corporation, by and through its attorneys, Gorsuch Kirgis LLP, and respectfully petitions the Oil and Gas Conservation Commission of the State of Colorado as follows:
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, LaPlata County, Colorado:
Township 34 North, Range 9 West, N.M.P.M.
Section 8U: S/2
(hereinafter "Application Lands")
Under its order in Order No. 112-60, the Commission designated the Application Lands as a 320 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 A-3 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, Union Pacific Railroad Company, 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 Colorado and the Rules and Regulations of this Commission is listed on Exhibit A attached hereto by name and address.
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 Union Pacific Railroad Company 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 _____ day of August, 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: William P. Marquis
11111 So. Wilcrest, Rm.S-1033
Houston, TX 77009
VERIFICATION
STATE OF TEXAS )
) ss.
COUNTY OF HARRIS )
William P. Marquis, 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.
William P. Marquis
Subscribed to and sworn to before me this _____ day of August, 2002, by William P. Marquis, as Landman of Chevron U.S.A, Inc.
My commission expires:
Notary Public
EXHIBIT A
INTERESTED PARTY
Union Pacific Railroad Company
C/O McLendon Management Company, LLC
Agent for Union Pacific Railroad Company
2420 Springer Drive, Suite 210
Norman, Oklahoma 73069