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 BEECHER ISLAND FIELD, YUMA COUNTY, COLORADO |
CAUSE NO. 300 DOCKET NO. ___________ |
VERIFIED APPLICATION
COMES NOW, the Applicant, Petroleum Development 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:
I.
Applicant is the operator and/or working interest owner of one or more oil and gas leases covering all or a portion of the Application Lands (as described below) within the Beecher Island Field.
II.
By Order Nos. 300-5 and 300-6 dated August 22, 1978 and September 9, 1981 respectively, the Commission established 160‑acre drilling and spacing units for the production of gas from the Niobrara Formation underlying certain lands including the following described lands located in the Beecher Island Field, Yuma County, Colorado:
Section 6: E/2
Section 7: All
Section 8: All
Section 9: All
Section 10: All
Section 15: All
Section 17: All
Section 18: All
Section 22: All
Section 27: All
Section 32: All
Section 33: All
(hereinafter "Application Lands")
The Orders provide that each said drilling unit shall consist of 160 acres, that each such drilling unit shall consist of a quarter section, according to the governmental survey thereof, and that the permitted well in each unit shall be located no closer than 900 feet from the boundaries of the quarter section in which the well is located.
III.
By Order No. 300-7 dated March 25, 1997, the Commission ordered that an additional well would be allowed to be drilled on each 160-acre drilling and spacing unit on lands in the Beecher Island Field (including the Application Lands), at the option of the operator for production of gasfrom the Niobrara Formation, with the subsequent permitted well to be no closer than 560 feet from the outer boundaries of the drilling and spacing unit and further allowing the Director to grant exceptions to the permitted well locations wihout prior notice or hearing upon an adequate showing by the operator that topography make it unreasonable to drill a second well within the 560 feet setback, but no closer than 380 feet from the boundary of the drilling and spacing unit and requests for any other exception location may be granted in accordance with Rule 318.
IV
Subsequent drilling and production operations in the area of the Application Lands have yielded geological and engineering evidence indicating that two wells will not adequately drain an area of 160 acres, and that an option to drill up to a total of four (4) wells within each drilling unit of the Application Lands should be permitted in order to allow economic and efficient drainage of the gas and associated hydrocarbons from the Niobrara Formation underlying each such 160‑acre drilling and spacing unit of the Application Lands.
V
In order to allow maximum flexibility in the drilling of wells upon the Application Lands and consistent with protection of correlative rights, it is appropriate that each additional well drilled upon the Application Lands be allowed to be located anywhere within the drilling unit upon which it is drilled provided it is located no closer than 560 feet to the outer boundaries of the drilling unit. In addition, the Director should be allowed to grant an exception to the permitted well location without prior notice or hearing upon an adequate showing by the operator that topography makes it unreasonable to drill the second well within a 560-feet setback, but no closer than 380 feet from the boundary of the drilling and spacing unit, and requests for any other exception location may be granted in accordance with Rule 318.
VI
Therefore, to prevent waste, to protect correlative rights, to ensure proper and efficient development of the Beecher Island Field, and to assure the greatest ultimate recovery of gas and associated hydrocarbons from the Niobrara Formation, Applicant requests that after notice and hearing, as provided by law, the Commission issue its Order providing that a total of four (4) wells shall be allowed to be drilled on each drilling unit of the Application Lands at the option of the operator; that the permitted location be anywhere within the 160‑acre drilling and spacing unit provided it is no closer than 560 feet from the outer boundaries of said 160‑acre drilling and spacing unit; and that the Director be allowed to grant an exception to the permitted well location without prior notice or hearing upon an adequate showing by the operator that topography makes it unreasonable to drill the second well within a 560-feet setback, but no closer than 380 feet from the boundary of the drilling and spacing unit, and requests for any other exception location may be granted in accordance with Rule 318.
VII
Applicant states to the best of its information and belief that the "interested parties" and the owners as defined in the Oil and Gas Conservation Act of the State of Colorado and the Rules and Regulations of this Commission are 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 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 _____ day of December, 2003.
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:
Petroleum Development Corporation
Attn: Eric R. Stearns, Executive Vice President
2970 29th Street
Greeley, CO 80631
VERIFICATION
STATE OF COLORADO )
) ss.
County of Weld )
Eric R. Stearns, as Executive Vice President of Petroleum Development Corporation, 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.
Eric R. Stearns
Subscribed to and sworn to before me this _____ day of December, 2003, by Eric R. Stearns as Executive Vice President of Petroleum Development Corporation.
My commission expires:
Notary Public
Exhibit A
BEECHER ISLAND
Billy G. Mansfield and Ellen
Mansfield
938 W. 11th Street
Wray, CO 80758-2034
Rosewood Resources, Inc.
2711 N. Haskell Avenue
Suite 2800, LB #22
Dallas, TX 75204
Samedan Oil Corporation
12600 Northborough, Suite 250
Houston, TX 77067
FMP Operating Company, a
Limited Partnership
3421 N. Causeway Boulevard
Metairie, LA 70002
James T. Rutherford, Jr.
11 Hillside Drive
Denver, CO 80215
Harold S. Wood
217 E. 24th Street
Tulsa, OK 74105
Stephen G. Bolyard
6071 S. Aberdeen
Littleton, CO 80120
H. Robert Wood
3101 E. 45th Street
Tulsa, OK 74105
Donald G. McLean, D.V.M.
8080 Meade Street
Westminster, CO 80020
J.W. Chandler
2910 S. Tejon Street
Englewood, CO 80110
Jose M. Calhoun, Trustee u/a
Joseph D. Sargent dated December 11, 1973
c/o Conning & Company
41 Lewis Street
Hartford, CT 06103
Alexander & Ambrose Oil
Corporation
1020 15th Street, Suite 20-C
Denver, CO 80202
SGT Oil & Gas Ltd.
1615 California St, Suite 407
Denver, CO 80202
Lonetree Oil & Gas
Company
c/o LoneTree Energy, Inc.
621 17th Street, Suite 2501
Denver, CO 80293
John P. Lockridge
1801 Broadway, Suite 1250
Denver, CO 80202
Thompson Brothers Ventures,
LLC
c/o Clyde E. Thompson
59 Golden Eagle Road
Greenwood Village, CO
80121-2120
Heartland Oil and Gas Company
Heartland 1989 Oil & Gas
Partnership
Heartland 1990 Oil & Gas
Partnership
5390 Manhattan Circle, Suite
100
Boulder, CO 80303
Blair Oil Interests, LLC, a
Colorado Limited Liability Company
885 S. Colorado Boulevard
Denver, CO 80246
OXY USA Inc.
10889 Wilshire Boulevard,
Suite 1500
Los Angeles, CA 90048
Mountain Petroleum
Corporation
1801 Broadway, Suite 1250
Denver, CO 80202
WBI Production, Inc.
200 N. Third Street, Suite
300
Bismark, ND 58501
Thompson Gas Corporation
7951 E. Maplewood Avenue,
Suite 324
Englewood, CO 80111
American Production
Partnership-V, Ltd
2100 RepublicBank Center
700 Louisiana
Houston, TX 77002
Ninian Oil Finance Corp.
2100 RepublicBank Center
700 Louisiana
Houston, TX 77002
Chester F. Whomble and
Doris J. Whomble, h/w
433 Adams
Wray, CO 80758-2034
Press Oil Investments
1645 Court Place, Suite 402
Denver, CO 80202
Cogeneration Holdings, LLC.
370 Van Gordon Street
Lakewood, CO 80228
State of Colorado
State Board of Land
Commissioners
1313 Sherman Street, Room 621
Denver, CO 80203
Alice Crossland
824 Olive Street
Denver, CO 80220
Robert W. Crossland
Eckley, CO 80727
Victor H. Crossland
Haxton, CO 80731
Annabell Sharpe
2909 Swing Station Way
Fort Collins, CO 80521
Baylor Van Meter, Jr
1600 Broadway, Suite 1470
Denver, CO 80202
Frank W. Winegar Trust
5460 Ward Road, Suite 200
Arvada, CO 80002
Joseph Sargent Trust
25 Cream Hill Road
Mendon, VT 05701
J-Chan Inc
357 N. Broadway
Denver, CO 80203
Martin Living Trust
400 West Illinois
Suite 1120, Midland, TX 79701
Marshall & Winston, Inc
P.O. Box 50880
Midland, TX 79710-0880
Judson Operations Ltd.
P.O. Box 3340
Midland, TX 79702-3340
LAJ Corporation
P.O. Box 10626
Midland, TX 79702-0626
The Skeeters Company
410 SW Brielle Lane
Lees Summit, MO 64082
Bobbie Jean Wood Trust
C/O Stephen A. Milligan
Trustee
4815 S Harvard, #128
Tulsa, OK 74135-3052
Richard D. Lammers
2615 Oak Driver, #33
Lakewood, CO 80215
Robert E. Kavli and Judith K.
Kavli
34743 County Road 22
Wray, CO 80758
Britoil Ventures, Inc.
P.O. Box 42833
Houston, TX 77242-2833
Kansas-Nebraska Natural Gas
Company, LLC
300 North St. Joseph Ave
Hastings, NE 68901
Baseline Minerals, Inc
1645 Court Place, Suite 422
Denver, CO 80202
Press Oil Investments
P.O. Box 464
Wray, CO 80758
Fidelity Exploration &
Production Company
1700 Lincoln, Street, Suite
4600
Denver, CO 80203
FM Properties Operating Company
1615 Poydras Street
P.O. Box 60004
New Orleans, LA 70160
High Plains Energy Company
1600 Broadway, Suite 1565
Denver, CO 80202
Ninian Oil Company
2100 Republic Bank Center
700 Louisiana
Houston, TX 77002
The Richard W. Smith Trust
dtd 7/2/03
The Helen E. Smith Trust dtd
7/2/03
1038 West 9th
Wray, CO 80758
Mountain Petroleum Ltd
712 Denver Center Bldg
Denver, CO 80203
Joe Gray
1445 Ross Ave, Ste 3200
Dallas, TX 75202-2711
XTO, Inc
Hickory Timbers Limited
Partnership
810 Houston Street, Suite
2000
Ft. Worth, TX 76102
Doris J. Whomble
Arthur Rowe Shively
29520 County Road 13
Idalia, CO 80735
Ellen A. Mansfield
938 West 11th
Wray, CO 80758
Robert J. Gutru, LP
307 Farmers and Bankers Bldg
Wichita, KS 67202
Heyliger Oil and Gas Corporation
885 S. Colorado Blvd
Denver, CO 80246
Stelbar Oil Corporation, Inc
200 West Douglas, Suite 950
Wichita, KS 67202
Glenn R. Wudtke
7551 County Road CC
Idalia, CO 80735
JG-Kansas No. 2 Venture
1445 Ross Ave, Ste 3200
Dallas, TX 75202-2711
Sarah H. Potter
451 Northcentral Expressway
Dallas, TX 75206-6401
Meredith Mallory, Jr.
8700 Crownhill, Suite 601
San Antonio, TX 78209
Laura Jane Westerman,
Individually
and as Personal
Representative of the Estate of
Howard G. Westerman aka H.G.
Westerman
c/o Cohort Energy Company
P.O. Box 226406
Dallas, TX 75222-6406
Cohort Energy Company
P.O. Box 226406
Dallas, TX 75222-6406
Thomas J. Jeffery
1750 N. Collins Blvd., Ste
122
Richardson, TX 75080
Richard L. Wudtke
9567 County Road CC
Idalia, CO 80735
Linda Briggs
Yuma County
310 Ash Street, Suite A
Wray, CO 80758