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Directive 065: Resources Applications for Oil and Gas Reservoirs ...

Directive 065: Resources Applications for Oil and Gas Reservoirs ...

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Requirements<br />

ii) interpretation of the fluid interfaces<br />

present,<br />

Comments<br />

iii) completions <strong>and</strong> treatments to the<br />

wellbore(s), with dates,<br />

iv) cumulative production,<br />

v) finished drilling date <strong>and</strong> kelly<br />

bushing (KB) elevation, <strong>and</strong><br />

vi) the scale of the log readings, <strong>and</strong><br />

d) a tabulation of the interpreted net pay,<br />

porosity, <strong>and</strong> water saturation <strong>for</strong> each<br />

well in the pool, along with the cutoffs,<br />

methodology, <strong>for</strong>mulas, <strong>and</strong> constants<br />

used.<br />

12) A statement indicating whether you are<br />

proposing that the requested order provide<br />

<strong>for</strong> the equalization of the actual cost of<br />

drilling the well to <strong>and</strong> completing it in the<br />

<strong>for</strong>mation(s) named in the pooling order, in<br />

accordance with Section 80(4)(d) of the<br />

OGCA.<br />

This is a st<strong>and</strong>ard provision of a typical<br />

pooling order. It applies to a situation where<br />

an applicant has itself drilled a well <strong>for</strong> the<br />

purpose of producing the zone to be subject<br />

to the pooling order or is proposing to drill<br />

such a well. If the case is not the st<strong>and</strong>ard<br />

one—<strong>for</strong> example, if a well was drilled <strong>and</strong><br />

produced from a zone other than the one to<br />

be subject to the pooling order—it would<br />

normally be appropriate to modify the<br />

st<strong>and</strong>ard provision such that not all original<br />

drilling <strong>and</strong> completion costs would be<br />

shared.<br />

13) A statement as to whether you are proposing<br />

that the requested order provide <strong>for</strong> a<br />

penalty to be imposed against actual drilling<br />

<strong>and</strong> completion costs in accordance with<br />

Section 80(5) of the OGCA <strong>and</strong>, if so,<br />

a) what penalty should be imposed,<br />

b) the justification <strong>for</strong> the proposed<br />

penalty,<br />

<strong>and</strong><br />

c) confirmation that in accordance with<br />

normal ERCB practice, you would agree<br />

that the proposed penalty would be<br />

applied if the tract owner did not pay its<br />

share of actual drilling <strong>and</strong> completion<br />

A penalty under Section 80(5) of the OGCA<br />

is a st<strong>and</strong>ard provision of pooling orders<br />

involving disputes between industry players.<br />

In these cases, the ERCB has normally<br />

provided <strong>for</strong> the maximum penalty allowed<br />

by Section 80(5). That is, if the maximum<br />

penalty applies <strong>and</strong> a tract owner has chosen<br />

to incur the penalty rather than pay costs “up<br />

front,” the tract owner would owe the well<br />

operator its share costs plus the penalty of<br />

two times the cost. If the tract owner’s share<br />

of costs were $10 000 <strong>and</strong> it chose to incur<br />

the penalty, it would pay costs of $10 000<br />

plus two times the costs, equalling $20 000,<br />

<strong>for</strong> a total of $30 000.<br />

ERCB <strong>Directive</strong> <strong>065</strong>: <strong>Resources</strong> <strong>Applications</strong> / Compulsory Pooling (October 2011) • 1-33

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