BEFORE THE OIL AND GAS
CONSERVATION COMMISSION
OF THE STATE OF
IN
THE MATTER OF THE PROMULGATION )
AND
ESTABLISHMENT OF FIELD RULES TO )
GOVERN
OPERATIONS IN THE RATON AND ) CAUSE
NO. _____
VERMEJO FORMATIONS,
FIELD, LAS
A P P L I
C A T I O N
Petrogulf Corporation (“Petrogulf”),
through its attorney, Charles Carpenter, hereby submits its application for an
order establishing two 80 acre drilling units for oil and gas production
comprised of the Raton and Vermejo Formations within the W/2NW/4 of Section 15
and W/2NW/4 of Section 22, Township 33 South, Range 67 West, 6th
P.M., Las Animas County, Colorado (“Subject Lands”), and an order pooling all
interests therein as follows:
1.
Petrogulf
is a
2. Petrogulf believes that two wells in the proposed 80 acre drilling units comprised of the Subject Lands will most efficiently drain and recover the optimum amount of oil and gas from the Raton and Vermejo Formations and that such area is not smaller than the maximum area that can be efficiently and economically drained by two wells.
3. Petrogulf believes that 80-acre spacing, with the permitted wells to be located in the NW/4NW/4 and the SW/4NW/4 of each drilling unit no closer than 200 feet from the boundaries of the proposed drilling unit or any lease line or 300 feet from any other well producing from the same formation and otherwise in accordance with the requirements of Rule 318 for wells drilled less than 2,500 feet, will provide for the orderly development of the common source of supply which it believes to exist therein, and will most adequately prevent waste, protect correlative rights, prevent the drilling of unnecessary wells and protect the public health safety and welfare.
4. Separate wells are required to produce from the Raton and Vermejo Formation in the Subject Lands because of the risk of water falling into the deeper formation upon fractionation of the shallower formation. Therefore, twin wells to separately produce the Raton and Vermejo formation from a single drilling pad should also be allowed.
5.
Petrogulf believes that the
rules and regulations of the Commission are sufficient to completely and
adequately address any adverse impacts to the environment and public health,
safety, and welfare that might be raised by this Application, or that any such
impacts may be addressed by the inclusion of appropriate field rules in the
order establishing the proposed drilling unit.
6.
By letters dated February
26, 2004, Petrogulf requested that Evergreen participate in the drilling of the
Robinson 15-11V, Robinson 15-11R, Great Plains 22-22V and Great Plains 22-22R
wells proposed by Petrogulf to be drilled on the Subject Lands and provided
Evergreen with a proposed Operating Agreement and an Authorization for
Expenditure and which estimates the fair, reasonable and typical actual costs
for drilling Raton and Vermejo Formation wells in the area. The information provided included the
location, objective depth, estimated drilling and completion costs and
estimated spud dates for the wells in accordance with Rule 530. Evergreen has provided no formal response
electing to participate in the drilling of any of the proposed wells. Petrogulf believes that Evergreen will not so
elect, and will not execute the proposed operating agreement as Evergreen has
refused to participate in other wells Petrogulf has proposed to drill on other
lands covered by the same leases.
7.
It is imperative that Petrogulf receive
Evergreen’s decision within 30 days because Petrogulf must commence operations
to drill these wells on or before
8.
Petrogulf believes that an
order of the Commission pooling all interests in the proposed drilling units
comprised of the Raton and Vermejo Formations within the Subject Lands is
necessary in order to afford each owner of an interest in said drilling units
the opportunity to recover and receive their just and equitable share of the
oil and/or gas from the common source of supply underlying said drilling
units. In the event that Evergreen has
not provided Petrogulf with a written election to participate in the drilling
of the proposed well by the date said pooling order is entered, the pooling
order should provide that Evergreen shall be deemed to have elected to not
participate, to be non-consenting as to the wells proposed by Petrogulf and to
be subject to the penalties as provided for by C.R.S. § 34-60-116 (7).
9.
Petrogulf believes that the
production obtained from said the proposed drilling units comprised of the
Raton and Vermejo Formations within the Subject Lands should be allocated on
the basis of the proportion that the number of net mineral acres in each lease
covering the Subject Lands bears to the total number of net mineral acres
within each drilling unit.
10. Petrogulf
believes that it should be designated as the operator for the drilling units
and the Robinson 15-11V, Robinson 15-11R,
11. Petrogulf intends to submit additional evidence and information prior to or at the hearing on this Application in support hereof.
WHEREFORE, Petrogulf respectfully
requests that this Application be set for hearing before the Oil and Gas
Conservation Commission of the State of Colorado at its regular meeting on
March 15 & 16, 2004, that notice be given as required by law, and that
after such hearing the Commission issue appropriate orders establishing
drilling units comprised of the Subject Lands, pooling all interests therein,
granting all the relief requested herein and granting such other and further relief
as the Commission deems proper.
DATED:
__________________________
Charles
Carpenter, No. 12197
(303)
831-1745
ATTORNEY
FOR APPLICANTS
Address
of Applicant:
Petrogulf
Corporation
Attn.:
Janet Paul
VERIFICATION
I, Charles Carpenter, being first
duly sworn, state that I have been duly authorized to file the foregoing
Application on behalf of Petrogulf Corporation, and that the facts recited
herein are true and correct to the best of my knowledge and belief.
_____________________________________
Charles
Carpenter
STATE
OF
) ss.
CITY
AND
Subscribed and sworn to before me on
WITNESS
my hand and official seal.
My
commission expires: _________________
______________________________
[SEAL] Notary
Public
BEFORE THE OIL AND GAS
CONSERVATION COMMISSION
OF THE STATE OF
IN
THE MATTER OF THE PROMULGATION )
AND
ESTABLISHMENT OF FIELD RULES TO )
GOVERN
OPERATIONS IN THE RATON AND ) CAUSE NO. _____
VERMEJO
FORMATIONS,
FIELD,
LAS
INTERESTED PARTIES
Evergreen Resources Inc.
Albert and Melanie Robinson
12767 CR 31.9
Donald J. Egan
Great Plains Development LLC
P.O. Box 4678
Englewood, CO 80155
David Royer
6837 Highway 12
Albert Jeffreys Griffith
6000
Thomas C. Graves, Individually
and as Trustee for Thomas C. Graves, Marilyn A. Tripp,
Carolyn Graves Landes and Linda L. Graves
17615 w. 16th Avenue
Petrogulf Corporation
I hereby certify that on