BEFORE THE
OIL AND GAS CONSERVATION COMMISSION
OF THE STATE OF COLORADO
IN THE MATTER OF THE APPLICATION OF TOM BROWN, INC FOR AN
ORDER ESTABLISHING SPACING AND WELL LOCATION RULES FOR THE WILLIAMS FORK
FORMATION OF THE MESAVERDE GROUP FOR CERTAIN DESCRIBED LANDS IN THE PARACHUTE
AND RULISON FIELD AREAS, GARFIELD COUNTY, COLORADO
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CAUSE NO. ____
DOCKET NO. ___
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APPLICATION
COMES NOW Tom Brown, Inc. ("Applicant"), a Delaware
corporation, by its attorneys, Gorsuch Kirgis LLP, and makes application to the Oil and Gas
Conservation Commission of the State of Colorado for an order establishing
spacing rules applicable to the drilling and producing of wells from the
Williams Fork Formation of the Mesaverde Group covering certain described lands
in the Parachute and Rulison Field areas, Garfield
County, Colorado and in support of its application states and alleges as
follows:
1.
That Applicant is a corporation duly authorized
to conduct business in the State of Colorado.
2.
That Applicant owns a leasehold interest in all
or a portion of the following described lands (hereinafter “Application
Lands”):
Township 7
South, Range 94 West, 6th P.M.
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3.
That the Application Lands are subject to the
Commission's Order No.440-14, 479-3 and 139-26 which allowed an increase
in the number of wells that could be optionally drilled into and produced from
the Williams Fork Formation of the Mesaverde
Group. For the 640-acre drilling and
spacing units established for the Application Lands, eight (8) wells were
allowed to be optionally drilled into and produced from the Williams Fork
Formation, with the permitted well to be located no closer than 400 feet from
the lease line nor 800 feet from any other producible or drilling oil and gas
well in the Williams Fork Formation.
4.
That the Application Lands are subject to the
Commission’s Order No. 440-16, 479-5 and 139-28 which allowed an increase in
the number of wells that could be optionally drilled into and produced from the
William Fork Formation of the Mesaverde Group in each
640 acre drilling and spacing unit of the Application Lands to sixteen (16)
wells with the permitted well to be located no closer than 400 feet from the
boundaries of the unit and no closer than 800 feet from any existing Williams
Fork Formation well or wells.
5.
That Applicant has drilled, tested and completed
multiple wells in the Williams Fork Formation of the Mesaverde Group upon the Application
Lands and other nearby lands.
6.
That to promote efficient drainage within the
Williams Fork Formation of the Mesaverde Group of the Application Lands, the
Commission should increase the number of wells which can be drilled into and
produced from the Williams Fork Formation of the Application Lands to the
equivalent of one Williams Fork well per 20 acres.
7.
That the permitted downhole
location for each Williams Fork well drilled upon the Application Lands should
be located no closer than 200 feet from the boundaries of the drilling unit and
no closer downhole than 400 feet from any existing
Williams Fork well or wells without exception being granted by the Director of
the Oil and Gas Conservation Commission.
8.
That no more than one pad shall be used for the
drilling of Williams Fork wells per governmental quarter quarter
section and that no more than two Williams Fork wells shall be drilled per
governmental quarter quarter section without
exception being granted by the Director of the Oil and Gas Conservation
Commission.
9.
That the above-proposed spacing and downhole well location rules will allow more efficient drainage
of the Williams Fork Formation of the Mesaverde Group; will not promote waste;
will not violate correlative rights and will assure the greatest ultimate
recovery of gas and associated hydrocarbon substances from the reservoir.
10.
That the names and addresses of the interested
parties according to the information and belief of the Applicant are set forth
in Exhibit A attached hereto and made a part hereof.
WHEREFORE, Applicant respectfully requests that this matter be
set for hearing in August, 2003, that notice be given as required by law and
that upon such hearing this Commission enter its order consistent with
Applicant's proposals as set forth above.
Dated this
___day of June, 2003.
GORSUCH
KIRGIS LLP
By:
William
A. Keefe
Tower 1, Suite
1000
1515
Arapahoe Street
Denver,
Colorado 80202
STATE OF COLORADO )
) ss.
CITY AND COUNTY
OF DENVER )
Dave Davenport,
of lawful age, being first duly sworn upon oath, deposes and says that he is
the Division Land Manager for Tom Brown, Inc. 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.
Dave Davenport
Subscribed and sworn to before me
this ____day of June, 2003.
Witness my hand and official seal.
My commission
expires:
Notary Public
( S E A L )
EXHIBIT A
Mark Bean,
County Planner
109 8th Street
Glenwood Springs, Colorado 81601
Bureau of Land Management
Attention: Duane
Spencer
2850 Youngfield
Street
Lakewood, Colorado 80215
Williams Production RMT Company
Attn: Mark Rothenberg
1515 Arapahoe
Tower 3, Ste 1000
Denver, CO
80202
EnCana Oil & Gas (USA),
Inc.
950 17th Street, Suite
2600
Denver, CO
80202
Petrogulf Corporation
518 17th Street, Suite
1455
Denver, CO
80202
Benson Mineral Group, Inc.
1560 Broadway, Suite
1900
Denver, CO
80202
Ms. Joan
L. Savage
5953 County Road #320
Rifle, CO
81650
BEFORE THE
OIL AND GAS CONSERVATION COMMISSION
OF THE STATE OF COLORADO
IN THE MATTER OF THE APPLICATION OF TOM BROWN, INC FOR AN
ORDER ESTABLISHING SPACING AND WELL LOCATION RULES FOR THE WILLIAMS FORK
FORMATION OF THE MESAVERDE GROUP FOR CERTAIN DESCRIBED LANDS IN THE PARACHUTE
AND RULISON FIELD AREAS, GARFIELD COUNTY, COLORADO
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CAUSE NO. ____
DOCKET NO. ___
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AFFIDAVIT OF MAILING
STATE OF COLORADO )
) ss.
CITY AND COUNTY
OF DENVER )
William A.
Keefe of lawful age, and being first duly
sworn upon his oath, states and declares:
That he is the attorney for Tom Brown, Inc., that on July 3, 2003, he caused a copy of
the attached Application in the subject docket to be deposited in the United
States Mail, postage prepaid, addressed to the parties listed on Exhibit A
to the Application.
William
A. Keefe
Subscribed and sworn to before me July 7, 2003.
Witness my hand and official seal.
My commission expires: January
24, 2005
Notary Public