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HomeMy WebLinkAboutCO 477 B INDEX CONSERVATION ORDER NO. 477B Milne Point Field Milne Point Unit Nikaitchuq Field Nikaitchuq Unit Schrader Bluff Oil Pool 1. February 4, 2025 Hilcorp application for expansion of CO 477A 2. February 4, 2025 Hilcorp revised application for expansion of CO 477A 3. February 24, 2025 AOGCC notice of public hearing 4. March 3, 2025 Hilcorp Application for Spacing Exception for well MPU H-21 (CO 477B.001) 5. March 3, 2025 Hilcorp Application for Spacing Exception for well MPU H-31 (CO 477B.002) 6. March 3, 2025 Hilcorp Application for Spacing Exception for wells MPU H-41 and H-43 (CO 477B.003) 7. March 10, 2025 AOGCC notice of public hearing (CO 477B.001) 8. March 10, 2025 AOGCC notice of public hearing (CO 477B.002) 9. March 10, 2025 AOGCC notice of public hearing (CO 477B.003) 10. June 23, 2025 Hilcorp Application for Spacing Exception for well MPU M-65 (CO 477B.004) 11. June 26, 2025 AOGCC notice of public hearing (CO 477B.004) 12. July 15, 2025 CPAI request for hearing (CO 477B.004) 13. July 17, 2025 Question for spacing exception (CO 477B.003) 14. July 30, 2025 Agreement between Hilcorp and CPAI (CO 477B.004) 15. December 1, 2025 DNR case file abstract 16. December 1, 2025 AOGCC spacing exception question. (Confidential documents held in secure storage) STATE OF ALASKA ALASKA OIL AND GAS CONSERVATION COMMISSION 333 W. 7th Avenue Anchorage Alaska 99501 Re: THE APPLICATION OF Hilcorp Alaska, LLC to amend Conservation Order No. 477A to expand the areal extent of the Milne Point Unit Schrader Bluff Oil Pool into the Nikaitchuq Field, Nikaitchuq Unit ) ) ) ) ) ) ) ) ) Conservation Order 477B Milne Point Field Milne Point Unit Nikaitchuq Field Nikaitchuq Unit Schrader Bluff Oil Pool September 18, 2025 ERRATA NOTICE The Alaska Oil and Gas Conservation Commission (AOGCC) notes that Conservation Order 477B (CO 477B) had two sections of the original affected area of Conservation Order 477A (CO 477A) omitted from the Affected Area table and that CO 477A did not reflect an Amendment originally made to Conservation Order 477. Namely, sections 30 and 31 of Township/Range 14N-10E were omitted from “Table 1: Legal Description of the Expanded SBOP” of CO 477B, and the sustained casing pressure rules defined by Conservation Order 496 (CO 496) were absent from the Rules of CO 477A and hence those of CO 477B. These corrections will be reflected in a Conservation Order 477B Errata to be issued by the AOGCC. DONE at Anchorage, Alaska and dated September 18, 2025. Jessie L. Chmielowski Gregory C. Wilson Commissioner Commissioner Jessie L. Chmielowski Digitally signed by Jessie L. Chmielowski Date: 2025.09.18 11:41:46 -08'00' Gregory C Wilson Digitally signed by Gregory C Wilson Date: 2025.09.18 12:58:11 -08'00' STATE OF ALASKA ALASKA OIL AND GAS CONSERVATION COMMISSION 333 West 7th Avenue Anchorage, Alaska 99501 Re: THE APPLICATION OF Hilcorp Alaska, LLC to amend Conservation Order No. 477A to expand the areal extent of the Milne Point Unit Schrader Bluff Oil Pool into the Nikaitchuq Field, Nikaitchuq Unit ) ) ) ) ) ) ) ) ) ) ) Docket Number: CO-25-004 Conservation Order 477B Errata Milne Point Field Milne Point Unit Nikaitchuq Field Nikaitchuq Unit Schrader Bluff Oil Pool September 18, 2025 Nunc pro tunc May 6, 2025 IT APPEARING THAT: 1.By application dated February 4, 2025, Hilcorp Alaska, LLC (Hilcorp), as operator of the Milne Point Unit (MPU) and operator of the Nikaitchuq Unit (NU), requested an order from the Alaska Oil and Gas Conservation Commission (AOGCC) to expand the affected area of Conservation Order No. 477A (CO 477A), which established pool rules for the MPU Schrader Bluff Oil Pool (SBOP), and to supersede Conservation Order No. 639 (CO 639), which established pool rules for the NU Nikaitchuq Schrader Bluff Oil Pool (NSBOP). 2.Pursuant to 20 AAC 25.540, the AOGCC tentatively scheduled a public hearing for April 3, 2025, at 10:00 AM. On February 24, 2025, the AOGCC published notice of that hearing on the State of Alaska’s Online Public Notice website and on the AOGCC’s website and electronically transmitted the notice to all persons on the AOGCC’s email distribution list. On February 26, 2025, the notice was also published in the Anchorage Daily News. 3.The AOGCC received no comments or requests to hold the proposed hearing. The tentatively scheduled hearing was vacated. 4.Hilcorp’s application, AOGCC’s records, and publicly available information provide sufficient information upon which to make an informed decision. FINDINGS: 1.Order History x CO 255, issued July 2, 1990, defined the SBOP and established Pool Rules to govern its operations. x CO 477, issued August 23, 2002, expanded the extent of the SBOP and consolidated several older conservation orders into one comprehensive set of Pool Rules for the SBOP in the MPU. x CO 496, issued September 8, 2003, defined sustained casing pressure rules for development wells in all pools within the Milne Point Field. Conservation Order 477B Errata September 18, 2025 Page 2 of 9 x CO 639, issued November 19, 2010, defined a new oil pool, the NSBOP, and prescribed comprehensive Pool Pules governing operation of that pool. x CO 806, issued July 11, 2023, granted an exception to well spacing requirements for well MPU M-61in the SBOP. 2. CO 477A, issued May 29, 2024, expanded the aerial extent of the SBOP within the MPU. Operatorship History of SBOP and NSBOP The SBOP was defined in 1990 and operated initially by Conoco Inc. In 1994, BP Exploration Alaska became sole owner and operator of the MPU and the SBOP. In 2020, Hilcorp North Slope, LLC became sole owner and operator of the MPU and the SBOP. The NSBOP was defined in 2010 and initially operated by Eni US Operating Company, Inc. In 2024, Hilcorp Alaska, LLC acquired the Nikaitchuq assets from Eni and became sole owner and operator for the NU and the NSBOP. 3. Owners and Landowners The affected landowner of the MPU and the NU is the State of Alaska, Department of Natural Resources (DNR). All lands within the Affected Area are leased from the State of Alaska. Hilcorp, Herbaly Exploration LLC, and George Alan Joyce are the lease holders of the MPU. Hilcorp is the sole lease holder of the NU. 4. Expansion of the SBOP Hilcorp proposes combining the SBOP and the NSBOP into one contiguous oil pool that underlies part of the MPU and all the NU. This expanded SBOP will incorporate about 21,228.6 acres currently assigned to the NSBOP. Figure 1, below, presents a map depicting the current and proposed Affected Areas. A legal description for the expanded Affected Area is presented in Table 1, below. 5. Expansion Justification To support this proposed pool expansion, Hilcorp provided confidential data to the AOGCC consisting of a seismic cross-section, annotated with well logs, that passes through the NU (west to east) and the MPU (northwest to southeast), and a structure map of the Schrader Bluff OA Sand showing a continuous oil-water contact that crosses the MPU and NU boundary. These data give Hilcorp high confidence that the Schrader Bluff forms a common reservoir within both units. Hilcorp’s initial plan is to further develop the SBOP by drilling wells from the Milne Point Raven Pad that cross the NU-MPU boundary. Figure 1 also depicts the locations of several currently proposed wells to be drilled from the Milne Point Raven Pad. CONCLUSIONS: 1. AOGCC accepts Hilcorp’s request to keep the seismic data and OA Sand structure map confidential because they are based on interpreted data. 2. Information provided by Hilcorp demonstrates that the SBOP is continuous across the MPU and NU boundary and that combining the NSBOP and the MPU SBOP into one single, contiguous pool is appropriate. Conservation Order 477B Errata September 18, 2025 Page 3 of 9 3. Having an administrative action rule in the SBOP pool rules is no longer necessary due to AOGCC regulations now allowing administrative action to be taken on any order issued by the AOGCC. NOW, THEREFORE, IT IS ORDERED: 1. This conservation order hereby supersedes CO 477A, dated May 29, 2024, and all associated administrative approvals to CO 477A (CO 477A.001, CO 477A.002, and CO 477A.003). The record, findings, and conclusions of CO 477A and its associated administrative approvals are incorporated by reference into the record for this order. 2. This conservation order hereby supersedes CO 806. The record, findings, and conclusions of CO 806 are incorporated by reference into the record for this order. 3. This conservation order hereby supersedes CO 639, dated November 19, 2010, that defined the NSBOP. 4. This conservation order hereby supersedes Administrative Approval CO 639.001 and 639.002. 5. The development and operation of the SBOP within the affected area is subject to the following rules and the statewide requirements under 20 AAC 25 (to the extent not superseded by these rules). Affected Area (Revised this order): Umiat Meridian Township/Range Sections 12N-10E 1, 2, 11, 12 12N-11E 2, 3, 4, 5, 6, 7, 8, 9, 10, 11 13N-9E 1, N ½ of 2, SE ¼ of 2, NE ¼ of 11, 12, 13, 14, 23, 24 13N-10E W ½ of 2, SE ¼ of 2, 3-11, S ½ of 12, 13-36 13N-11E 18, 19, W ½ of 20, SW ¼ of 27, 28-33, W ½ of 34 14N-10E 30, 31 14N-9E 5-8, 11-36 14N-8E 1, 2 (protracted), 3(protracted), 4(protracted), 9-15, 22-26, 35, 36 15N-8E 33(protracted), 35(protracted), 36(protracted) Table 1. Legal Description of the Expanded SBOP Conservation Order 477B Errata September 18, 2025 Page 4 of 9 Figure 1. Existing Extent and Proposed Expansion of SBOP Affected Area (Source: Hilcorp North Slope, LLC) Rule 1: Designation and Definition (Restated from CO 477 and CO 639) The fields are the Milne Point Field and the Nikaitchuq Field. Hydrocarbons underlying the Affected Area and within the interval of the Schrader Bluff Formation identified below constitute the Schrader Bluff Oil Pool (SBOP). The SBOP is defined as the accumulation of hydrocarbons that are common to and correlate with the stratigraphic interval in the Milne Point A-1 well (API No. 50-029-20376-00-00) between the measured depths of 4,174 and 4,800 feet, and the stratigraphic interval in well Kigun No. 1 (API No. 50-629-23239-01-00) between the measured depths of 3,530 and 3,867 feet. Rule 2: Well Spacing (Revised by CO 477.005, CO 477A.001, CO 477A.002, CO 477A.003, CO 477.009, CO 806) From CO 477.005: There are no restrictions as to well spacing except that no pay shall be opened in a well closer than 500 feet from the exterior boundary of the affected area. Conservation Order 477B Errata September 18, 2025 Page 5 of 9 From CO 477A.001, CO 477A.002, CO 477A.003 An exception to the above well spacing provision is granted for wells MPU R-101, MPU R-102, and MPU R-103 to allow drilling, completion, testing, pre-production and injection for R-101 and R-103 and drilling, completion, testing, and production for MPU R-102. From CO 477.009: An exception to the above well spacing provision is granted for well MPU H-31 to allow drilling, completion, testing, pre-production and injection within 500 feet of the external boundary of the SBOP. The following constraints apply to well MPU H-31: 1. Constraints requested to apply until December 31, 2030: a. Injection pressure gradients not to exceed 0.65 psi/feet; b.No gas injection; c. Pre-production of MPU H-31 not to exceed 60 days; and d.Downhole pressure gauge data from MPU H-31 provided to CPAI upon written request. 2. Constraint that will apply for the life of MPU H-31: a. Injection only (MPU H-31 cannot be converted to a producer). From CO 806: An exception to the above well spacing provision is granted for well MPU M-61 to allow drilling, pre-production (for no more than 30 days), and injection within 500 feet of the external boundary of the SBOP, near the Kuparuk River Unit (KRU). Rule 3: Horizontal/High Angle Completions (Repealed by CO 477.005) Rule 4: Casing and Cementing Requirements (Restated from CO 477 and revised by CO 639.002) From CO 477: To provide proper anchorage for the blowout prevention equipment, surface casing shall be set at least 500 feet below the base of the permafrost, and the annulus shall be filled with cement. To withstand anticipated internal pressure and the potential forces generated by thaw subsidence and freeze back, the casing shall meet normal design criteria and have minimum axial strain properties of 0.5 percent in tension and 0.7 percent in compression. From CO 639.002: The surface casing in water supply well OP21-WW01 is allowed to be set approximately 260 feet below permafrost, a depth less than the otherwise required depth of 500 feet below permafrost. Rule 5: Automatic Shut-in Equipment (Rescinded by Other Order 66 and replaced by 20 AAC 25.265) Conservation Order 477B Errata September 18, 2025 Page 6 of 9 Rule 6: Common Production Facilities and Surface Commingling (Revised by CO 477.008) a. Production from the SBOP may be commingled on the surface with production from the Kuparuk River Oil Pool (KROP) and the Sag River Oil Pool (SROP), MPU, prior to custody transfer. b. SBOP wells will use the allocation factor for oil, gas, and water derived from the Milne Point Central Facility Pad (CFP) and the allocation factor for oil, gas, and water derived from the Oliktok Production Plant (OPP). c. Each producing well shall be tested at least once per month for a minimum of 6 hours per test. d. The AOGCC may require more frequent or longer duration well tests if the summation of the calculated monthly production volume for both pools is not within 10 percent of the actual LACT metered volume. e. The operator shall provide the AOGCC with a Well Test and Allocation Report of commingled regular production from all MPU wells on April 1, 2003, and annually thereafter. The report will consist of a thorough analysis of all surveillance data relative to the well test system and the resulting allocation factors. Rule 7: Reservoir Pressure Monitoring (Restated from CO 477) a. Prior to regular production, a pressure survey shall be taken on each well to determine reservoir pressure. b. A minimum of one bottom-hole pressure survey per producing governmental section shall be run annually. The surveys in Part “a” of this rule may be used to fulfill the minimum requirements. c. The datum for all surveys is 4000 feet subsea. d. Pressure surveys may be stabilized static pressure measurements at bottom-hole or extrapolated from surface (single phase fluid conditions), pressure fall-off, pressure buildup, multi-rate tests, drill stem tests, and open-hole formation tests. e. Data and results from pressure surveys shall be submitted with the annual reservoir surveillance report. All data necessary for analysis of each survey need not be submitted with the report but must be available to the AOGCC upon request. f. Results and data from any special reservoir pressure monitoring techniques, tests, or surveys shall also be submitted in accordance with part (e) of this rule. Rule 8: Pool-wide Waterflood Project (Restated from CO 477 and CO 639) MPU A waterflood project to maintain reservoir pressure must be implemented within eighteen months after regular production from the Schrader Bluff Oil Pool has started. Water injection must be implemented within the expanded S-Pad area within eighteen months of initial production. Conservation Order 477B Errata September 18, 2025 Page 7 of 9 Nikaitchuq Unit Production and injection must ensure the average reservoir pressure in any isolated compartment is maintained at, or above, the bubble point for that respective reservoir compartment. Rule 9: Gas-Oil Ratio Exemption (Restated from CO 477) Wells producing from the Schrader Bluff Oil Pool are exempt from the gas-oil-ratio limits of 20 AAC 25.240(a) so long as requirements of 20 AAC 25.240(b) are met. Rule 10: SBOP Annual Reservoir Surveillance Report (Restated from CO 477) An annual Schrader Bluff Oil Pool surveillance report is required by April 1 of each year. The report shall include, but is not limited to, the following: a. Progress of enhanced recovery project implementation and reservoir management summary including results of reservoir studies. b. Voidage balance by month of produced fluids and injected fluids and cumulative status for each producing interval. c. Summary and analysis of reservoir pressure surveys within the pool. d. Results and, where appropriate, analysis of production and injection log surveys, tracer surveys, observation well surveys, and any other special monitoring. e. Review of pool production allocation factors and issues over the prior year. f. Future development plans. g. Review of Annual Plan of Operations and Development. Rule 11: Administrative Action (Superseded by regulation 20 AAC 25.556 (d)) Rule 12: Production Facilities (Restated from CO 639.001) a. Schlumberger VX multi-phase meters will be used to measure produced oil, gas and water volumes during well testing operations. The metering system must be operated and maintained in accordance with the procedures described in the “Application for the Qualification of a Multiphase Metering System for Well Testing at the Nikaitchuq Field” dated October 24, 2010. i. Any changes to the operation and maintenance procedures must be approved by the AOGCC prior to being implemented. b. Production shall be allocated to wells within the Nikaitchuq Schrader Bluff Oil Pool based on well tests. The production allocation methodology shall be performed as described in the “Application for the Qualification of a Multiphase Metering System for Well Testing at the Nikaitchuq Field” dated October 24, 2010. i. Any changes to the production allocation methodology must be approved by the AOGCC prior to being implemented. c. The AOGCC may require more frequent or longer testing if the summation of the calculated monthly production volume for the pool is not within 10 percent of the actual LACT metered volume. Conservation Order 477B Errata September 18, 2025 Page 8 of 9 d. The operator shall submit a monthly report and electronic file(s) containing daily allocation data and daily test data for agency surveillance and evaluation. e. The operator shall provide the AOGCC an annual well test and allocation review report in conjunction with the annual reservoir surveillance report required under Rule 10, above. Rule 13: Sustained Casing Pressure Rules (Restated from CO 496) a. The operator shall conduct and document a pressure test of tubulars and completion equipment in each development well at the time of installation or replacement that is sufficient to demonstrate that planned well operations will not result in failure of well integrity, uncontrolled release of fluid or pressure, or threat to human safety. b. The operator shall monitor each development well daily to check for sustained pressure, except if prevented by extreme weather conditions, emergency situations, or similar unavoidable circumstances. Monitoring results shall be made available for AOGCC inspection. c. The operator shall notify the AOGCC within three working days after the operator identifies a well as having (1) sustained inner annulus pressure that exceeds 2000 psig or (2) sustained outer annulus pressure that exceeds 1000 psig. d. The AOGCC may require the operator to submit in an Application for Sundry Approvals (Form 10-403) a proposal for corrective action or increased surveillance for any development well having sustained pressure that exceeds a limit set out in paragraph “c” of this rule. The AOGCC may approve the operator’s proposal or may require other corrective action or surveillance. The AOGCC may require that corrective action be verified by mechanical integrity testing or other AOGCC approved diagnostic tests. The operator shall give AOGCC sufficient notice of the testing schedule to allow AOGCC to witness the tests. e. If the operator identifies sustained pressure in the inner annulus of a development well that exceeds 45% of the burst pressure rating of the well’s production casing for inner annulus pressure, or sustained pressure in the outer annulus that exceeds 45% of the burst pressure rating of the well’s surface casing for outer annulus pressure, the operator shall notify the AOGCC within three working days and take corrective action. Unless well conditions require the operator to take emergency corrective action before AOGCC approval can be obtained, the operator shall submit in an Application for Sundry Approvals (Form 10-403) a proposal for corrective action. The AOGCC may approve the operator’s proposal or may require other corrective action. The AOGCC may also require that corrective action be verified by mechanical integrity testing or other AOGCC approved diagnostic tests. The operator shall give AOGCC sufficient notice of the testing schedule to allow AOGCC to witness the tests. f. Except as otherwise approved by the AOGCC under paragraph “d” or “e” of these rules, before a shut-in well is placed in service, any annulus pressure must be relieved to a sufficient degree (1) that the inner annulus pressure at operating temperature will be below 2000 psig and (2) that the outer annulus pressure at operating temperature will be below 1000 psig. However, a well that is subject to paragraph “c” but not paragraph “e” Conservation Order 477B Errata September 18, 2025 Page 9 of 9 of these rules may reach an annulus pressure at operating temperature that is described in the operator’s notification to the AOGCC under paragraph “c,” unless the AOGCC prescribes a different limit. g. For purposes of these rules, “inner annulus” means the space in a well between tubing and production casing; “outer annulus” means the space in a well between production casing and surface casing; “sustained pressure” means pressure that (1) is measurable at the casing head of an annulus, (2) is not caused solely by temperature fluctuations, and (3) is not pressure that has been applied intentionally. DONE at Anchorage, Alaska September 18, 2025. Nunc pro tunc May 6, 2025. Jessie L. Chmielowski Gregory C. Wilson Commissioner Commissioner RECONSIDERATION AND APPEAL NOTICE As provided in AS 31.05.080(a), within 20 days after written notice of the entry of this order or decision, or such further time as the AOGCC grants for good cause shown, a person affected by it may file with the AOGCC an application for reconsideration of the matter determined by it. If the notice was mailed, then the period of time shall be 23 days. An application for reconsideration must set out the respect in which the order or decision is believed to be erroneous. The AOGCC shall grant or refuse the application for reconsideration in whole or in part within 10 days after it is filed. Failure to act on it within 10-days is a denial of reconsideration. If the AOGCC denies reconsideration, upon denial, this order or decision and the denial of reconsideration are FINAL and may be appealed to superior court. The appeal MUST be filed within 33 days after the date on which the AOGCC mails, OR 30 days if the AOGCC otherwise distributes, the order or decision denying reconsideration, UNLESS the denial is by inaction, in which case the appeal MUST be filed within 40 days after the date on which the application for reconsideration was filed. If the AOGCC grants an application for reconsideration, this order or decision does not become final. Rather, the order or decision on reconsideration will be the FINAL order or decision of the AOGCC, and it may be appealed to superior court. That appeal MUST be filed within 33 days after the date on which the AOGCC mails, OR 30 days if the AOGCC otherwise distributes, the order or decision on reconsideration. In computing a period of time above, the date of the event or default after which the designated period begins to run is not included in the period; the last day of the period is included, unless it falls on a weekend or state holiday, in which event the period runs until 5:00 p.m. on the next day that does not fall on a weekend or state holiday. Jessie L. Chmielowski Digitally signed by Jessie L. Chmielowski Date: 2025.09.18 11:44:07 -08'00' Gregory C Wilson Digitally signed by Gregory C Wilson Date: 2025.09.18 12:54:49 -08'00' STATE OF ALASKA ALASKA OIL AND GAS CONSERVATION COMMISSION 333 West 7th Avenue Anchorage, Alaska 99501 Re: THE APPLICATION OF Hilcorp Alaska, LLC to amend Conservation Order No. 477A to expand the areal extent of the Milne Point Unit Schrader Bluff Oil Pool into the Nikaitchuq Field, Nikaitchuq Unit ) ) ) ) ) ) ) ) ) ) Docket Number: CO-25-004 Conservation Order 477B Milne Point Field Milne Point Unit Nikaitchuq Field Nikaitchuq Unit Schrader Bluff Oil Pool May 6, 2025 IT APPEARING THAT: 1.By application dated February 4, 2025, Hilcorp Alaska, LLC (Hilcorp), as operator of the Milne Point Unit (MPU) and operator of the Nikaitchuq Unit (NU), requested an order from the Alaska Oil and Gas Conservation Commission (AOGCC) to expand the affected area of Conservation Order No. 477A (CO 477A), which established pool rules for the MPU Schrader Bluff Oil Pool (SBOP), and to supersede Conservation Order No. 639 (CO 639), which established pool rules for the NU Nikaitchuq Schrader Bluff Oil Pool (NSBOP). 2.Pursuant to 20 AAC 25.540, the AOGCC tentatively scheduled a public hearing for April 3, 2025, at 10:00 AM. On February 24, 2025, the AOGCC published notice of that hearing on the State of Alaska’s Online Public Notice website and on the AOGCC’s website, electronically transmitted the notice to all persons on the AOGCC’s email distribution list. On February 26, 2025, the notice was also published in the Anchorage Daily News. 3.The AOGCC received no comments or requests to hold the proposed hearing. The tentatively scheduled hearing was vacated. 4.Hilcorp’s application, AOGCC’s records, and publicly available information provide sufficient information upon which to make an informed decision. FINDINGS: 1. Order History x CO 255, issued July 2, 1990, defined the SBOP and established Pool Rules to govern its operations. x CO 477, issued August 23, 2002, expanded the extent of the SBOP and consolidated several older conservation orders into one comprehensive set of Pool Rules for the SBOP in the MPU. x CO 639, issued November 19, 2010, defined a new oil pool, the NSBOP, and prescribed comprehensive Pool Pules governing operation of that pool. x CO 477A, issued May 29, 2024, expanded the aerial extent of the SBOP within the MPU. Conservation Order 477B May 6, 2025 Page 2 of 8 x CO 806, issued July 11, 2023, granted an exception to well spacing requirements for well MPU M-61in the SBOP. 2. Operatorship History of SBOP and NSBOP The SBOP was defined in 1990 and operated initially by Conoco Inc. In 1994, BP Exploration Alaska became sole owner and operator of the MPU and the SBOP. In 2020, Hilcorp North Slope, LLC became sole owner and operator of the MPU and the SBOP. The NSBOP was defined in 2010 and initially operated by Eni US Operating Company, Inc. In 2024, Hilcorp Alaska, LLC acquired the Nikaitchuq assests from Eni and became sole owner and operator for the NU and the NSBOP. 3. Owners and Landowners The affected landowner of the MPU and the NU is the State of Alaska, Department of Natural Resources (DNR). All lands within the Affected Area are leased from the State of Alaska. Hilcorp, Herbaly Exploration LLC, and George Alan Joyce are the lease holders of the MPU. Hilcorp is the sole lease holder of the NU. 4. Expansion of the SBOP Hilcorp proposes combining the SBOP and the NSBOP into one contiguous oil pool that underlies part of the MPU and all the NU. This expanded SBOP will incorporate about 21,228.6 acres currently assigned to the NSBOP. Figure 1, below, presents a map depicting the current and proposed Affected Areas. A legal description for the expanded Affected Area is presented in Table 1, below. 5. Expansion Justification To support this proposed pool expansion, Hilcorp provided confidential data to the AOGCC consisting of a seismic cross-section, annotated with well logs, that passes through the NU (west to east) and the MPU (northwest to southeast), and a structure map of the Schrader Bluff OA Sand showing a continuous oil-water contact that crosses the MPU and NU boundary. Hilcorp has high confidence that this data suggests that the Schrader Bluff forms a common reservoir that lies within both units. Hilcorp requested that the seismic data and OA Sand map be held confidential. Hilcorp’s initial plan is to further develop the SBOP by drilling wells from the Milne Point Raven Pad that cross into the NU. Figure 1 also depicts the locations of several currently proposed wells to be drilled from the Milne Point Raven Pad. CONCLUSIONS: 1. AOGCC accepts Hilcorp’s request to keep the seismic data and OA Sand structure map confidential because they are based on interpreted data. 2. Information provided by Hilcorp demonstrates that the SBOP is continuous across the MPU and NU boundary and that combining the NSBOP and the MPU SBOP into one single, contiguous pool is appropriate. 3. Having an administrative action rule in the SBOP pool rules is no longer necessary due to AOGCC regulations now allowing administrative action to be taken on any order issued by the AOGCC. Conservation Order 477B May 6, 2025 Page 3 of 8 NOW, THEREFORE, IT IS ORDERED: 1. This conservation order hereby supersedes CO 477A, dated May 29, 2024, and all associated administrative approvals to CO 477A (CO 477A.001, CO 477A.002, and CO 477A.003). The record, findings, and conclusions of CO 477A and its associated administrative approvals are incorporated by reference into the record for this order. 2. This conservation order hereby supersedes CO 806. The record, findings, and conclusions of CO 806 are incorporated by reference into the record for this order. 3. This conservation order hereby supersedes CO 639, dated November 19, 2010, that defined the NSBOP. 4. This conservation order hereby supersedes Administrative Approval CO 639.001 and 639.002. 5. The development and operation of the SBOP within the affected area is subject to the following rules and the statewide requirements under 20 AAC 25 (to the extent not superseded by these rules). Conservation Order 477B May 6, 2025 Page 4 of 8 Affected Area (Revised this order): Umiat Meridian Township/Range Sections 12N-10E 1, 2, 11, 12 12N-11E 2, 3, 4, 5, 6, 7, 8, 9, 10, 11 13N-9E 1, N ½ of 2, SE ¼ of 2, NE ¼ of 11, 12, 13, 14, 23, 24 13N-10E W ½ of 2, SE ¼ of 2, 3-11, S ½ of 12, 13-36 13N-11E 18, 19, W ½ of 20, SW ¼ of 27, 28-33, W ½ of 34 14N-9E 5-8, 11-36 14N-8E 1, 2 (protracted), 3(protracted), 4(protracted), 9-15, 22-26, 35, 36 15N-8E 33(protracted), 35(protracted), 36(protracted) Table 1. Legal Description of the Expanded SBOP Figure 1. Existing Extent and Proposed Expansion of SBOP Affected Area (Source: Hilcorp North Slope, LLC) Conservation Order 477B May 6, 2025 Page 5 of 8 Rule 1: Designation and Definition (Restated from CO 477 and CO 639) The fields are the Milne Point Field and the Nikaitchuq Field. Hydrocarbons underlying the Affected Area and within the interval of the Schrader Bluff Formation identified below constitute the Schrader Bluff Oil Pool (SBOP). The SBOP is defined at the accumulation of hydrocarbons that are common to and correlate with the stratigraphic interval in the Milne Point A-1 well (API No. 50-029-20376-00-00) between the measured depths of 4,174 and 4,800 feet, and the stratigraphic interval in well Kigun No. 1 (API No. 50-629-23239-01-00) between the measured depths of 3,530 and 3,867 feet. Rule 2: Well Spacing (Revised by CO 477.005, CO 477A.001, CO 477A.002, CO 477A.003, CO 477.009, CO 806) From CO 477.005: There are no restrictions as to well spacing except that no pay shall be opened in a well closer than 500 feet from the exterior boundary of the affected area. From CO 477A.001, CO 477A.002, CO 477A.003 An exception to the above well spacing provision is granted for wells MPU R-101, MPU R-102, and MPU R-103 to allow drilling, completion, testing, pre-production and injection for R-101 and R-103 and drilling, completion, testing, and production for MPU R-102. From CO 477.009: An exception to the above well spacing provision is granted for well MPU H-31 to allow drilling, completion, testing, pre-production and injection within 500 feet of the external boundary of the SBOP. The following constraints apply to well MPU H-31: 1. Constraints requested to apply until December 31, 2030: a. Injection pressure gradients not to exceed 0.65 psi/feet; b.No gas injection; c. Pre-production of MPU H-31 not to exceed 60 days; and d.Downhole pressure gauge data from MPU H-31 provided to CPAI upon written request. 2. Constraint that will apply for the life of MPU H-31: a. Injection only (MPU H-31 cannot be converted to a producer). From CO 806: An exception to the above well spacing provision is granted for well MPU M-61 to allow drilling, pre-production (for no more than 30 days), and injection within 500 feet of the external boundary of the SBOP, near the Kuparuk River Unit (KRU). Rule 3: Horizontal/High Angle Completions (Repealed by CO 477.005) Rule 4: Casing and Cementing Requirements (Restated from CO 477 and revised by CO 639.002) From CO 477: To provide proper anchorage for the blowout prevention equipment, surface casing shall be set at least 500 feet below the base of the permafrost, and the annulus shall be filled with cement. To Conservation Order 477B May 6, 2025 Page 6 of 8 withstand anticipated internal pressure and the potential forces generated by thaw subsidence and freeze back, the casing shall meet normal design criteria and have minimum axial strain properties of 0.5 percent in tension and 0.7 percent in compression. From CO 639.002: The surface casing in water supply well OP21-WW01 is allowed to be set approximately 260 feet below permafrost, a depth less than the otherwise required depth of 500 feet below permafrost. Rule 5: Automatic Shut-in Equipment (Rescinded by Other Order 66 and replaced by 20 AAC 25.265) Rule 6: Common Production Facilities and Surface Commingling (Revised by CO 477.008) a. Production from the SBOP may be commingled on the surface with production from the Kuparuk River Oil Pool (KROP) and the Sag River Oil Pool (SROP), MPU, prior to custody transfer. b. SBOP wells will use the allocation factor for oil, gas, and water derived from the Milne Point Central Facility Pad (CFP) and the allocation factor for oil, gas, and water derived from the Oliktok Production Plant (OPP). c. Each producing well shall be tested at least once per month for a minimum of 6 hours per test. d. The AOGCC may require more frequent or longer duration well tests if the summation of the calculated monthly production volume for both pools is not within 10 percent of the actual LACT metered volume. e. The operator shall provide the AOGCC with a Well Test and Allocation Report of commingled regular production from all MPU wells on April 1, 2003, and annually thereafter. The report will consist of a thorough analysis of all surveillance data relative to the well test system and the resulting allocation factors. Rule 7: Reservoir Pressure Monitoring (Restated from CO 477) a. Prior to regular production, a pressure survey shall be taken on each well to determine reservoir pressure. b. A minimum of one bottom-hole pressure survey per producing governmental section shall be run annually. The surveys in Part “a” of this rule may be used to fulfill the minimum requirements. c. The datum for all surveys is 4000 feet subsea. d. Pressure surveys may be stabilized static pressure measurements at bottom-hole or extrapolated from surface (single phase fluid conditions), pressure fall-off, pressure buildup, multi-rate tests, drill stem tests, and open-hole formation tests. e. Data and results from pressure surveys shall be submitted with the annual reservoir surveillance report. All data necessary for analysis of each survey need not be submitted Conservation Order 477B May 6, 2025 Page 7 of 8 with the report but must be available to the AOGCC upon request. f. Results and data from any special reservoir pressure monitoring techniques, tests, or surveys shall also be submitted in accordance with part (e) of this rule. Rule 8: Pool-wide Waterflood Project (Restated from CO 477 and CO 639) MPU A waterflood project to maintain reservoir pressure must be implemented within eighteen months after regular production from the Schrader Bluff Oil Pool has started. Water injection must be implemented within the expanded S-Pad area within eighteen months of initial production. Nikaitchuq Unit Production and injection must ensure the average reservoir pressure in any isolated compartment is maintained at, or above, the bubble point for that respective reservoir compartment. Rule 9: Gas-Oil Ratio Exemption (Restated from CO 477) Wells producing from the Schrader Bluff Oil Pool are exempt from the gas-oil-ratio limits of 20 AAC 25.240(a) so long as requirements of 20 AAC 25.240(b) are met. Rule 10: SBOP Annual Reservoir Surveillance Report (Restated from CO 477) An annual Schrader Bluff Oil Pool surveillance report is required by April 1 of each year. The report shall include, but is not limited to, the following: a. Progress of enhanced recovery project implementation and reservoir management summary including results of reservoir studies. b. Voidage balance by month of produced fluids and injected fluids and cumulative status for each producing interval. c. Summary and analysis of reservoir pressure surveys within the pool. d. Results and, where appropriate, analysis of production and injection log surveys, tracer surveys, observation well surveys, and any other special monitoring. e. Review of pool production allocation factors and issues over the prior year. f. Future development plans. g. Review of Annual Plan of Operations and Development. Rule 11: Administrative Action (Superseded by regulation 20 AAC 25.556 (d)) Rule 12: Production Facilities (Restated from CO 639.001) a. Schlumberger VX multi-phase meters will be used to measure produced oil, gas and water volumes during well testing operations. The metering system must be operated and maintained in accordance with the procedures described in the “Application for the Qualification of a Multiphase Metering System for Well Testing at the Nikaitchuq Field” dated October 24, 2010. Conservation Order 477B May 6, 2025 Page 8 of 8 i. Any changes to the operation and maintenance procedures must be approved by the AOGCC prior to being implemented. b. Production shall be allocated to wells within the Nikaitchuq Schrader Bluff Oil Pool based on well tests. The production allocation methodology shall be performed as described in the “Application for the Qualification of a Multiphase Metering System for Well Testing at the Nikaitchuq Field” dated October 24, 2010. i. Any changes to the production allocation methodology must be approved by the AOGCC prior to being implemented. c. The AOGCC may require more frequent or longer testing if the summation of the calculated monthly production volume for the pool is not within 10 percent of the actual LACT metered volume. d. The operator shall submit a monthly report and electronic file(s) containing daily allocation data and daily test data for agency surveillance and evaluation. e. The operator shall provide the AOGCC an annual well test and allocation review report in conjunction with the annual reservoir surveillance report required under Rule 10, above. DONE at Anchorage, Alaska May 6, 2025. Jessie L. Chmielowski Gregory C. Wilson Commissioner Commissioner RECONSIDERATION AND APPEAL NOTICE As provided in AS 31.05.080(a), within 20 days after written notice of the entry of this order or decision, or such further time as the AOGCC grants for good cause shown, a person affected by it may file with the AOGCC an application for reconsideration of the matter determined by it. If the notice was mailed, then the period of time shall be 23 days. An application for reconsideration must set out the respect in which the order or decision is believed to be erroneous. The AOGCC shall grant or refuse the application for reconsideration in whole or in part within 10 days after it is filed. Failure to act on it within 10-days is a denial of reconsideration. If the AOGCC denies reconsideration, upon denial, this order or decision and the denial of reconsideration are FINAL and may be appealed to superior court. The appeal MUST be filed within 33 days after the date on which the AOGCC mails, OR 30 days if the AOGCC otherwise distributes, the order or decision denying reconsideration, UNLESS the denial is by inaction, in which case the appeal MUST be filed within 40 days after the date on which the application for reconsideration was filed. If the AOGCC grants an application for reconsideration, this order or decision does not become final. Rather, the order or decision on reconsideration will be the FINAL order or decision of the AOGCC, and it may be appealed to superior court. That appeal MUST be filed within 33 days after the date on which the AOGCC mails, OR 30 days if the AOGCC otherwise distributes, the order or decision on reconsideration. In computing a period of time above, the date of the event or default after which the designated period begins to run is not included in the period; the last day of the period is included, unless it falls on a weekend or state holiday, in which event the period runs until 5:00 p.m. on the next day that does not fall on a weekend or state holiday. Jessie L. Chmielowski Digitally signed by Jessie L. Chmielowski Date: 2025.05.06 14:25:57 -08'00' Gregory C. Wilson Digitally signed by Gregory C. Wilson Date: 2025.05.06 14:51:06 -08'00' From:Coldiron, Samantha J (OGC) To:AOGCC_Public_Notices Subject:[AOGCC_Public_Notices] Conservation Order 477B and Area Injection Order 10D (Hilcorp) Date:Tuesday, May 6, 2025 3:53:10 PM Attachments:CO477B.pdf AIO10D.pdf THE APPLICATION OF HILCORP ALASKA, LLC. To expand the Affected Area of Area Injection Order Number 10C to include the newly expanded Schrader Bluff Oil Pool into the Nikaitchuq Unit. THE APPLICATION OF Hilcorp North Slope, LLC to amend Conservation Order No. 477A to expand the areal extent of the Milne Point Unit Schrader Bluff Oil Pool into the Nikaitchuq Field, Nikaitchuq Unit Samantha Coldiron AOGCC Special Assistant Alaska Oil and Gas Conservation Commission 333 West 7th Avenue Anchorage, AK 99501 (907) 793-1223 __________________________________ List Name: AOGCC_Public_Notices@list.state.ak.us You subscribed as: samantha.coldiron@alaska.gov Unsubscribe at: https://list.state.ak.us/mailman/options/aogcc_public_notices/samantha.coldiron%40alaska.go v Alaska Oil and Gas Conservation Commission 333 West Seventh Avenue Anchorage, Alaska 99501-3572 Main: 907.279.1433 Fax: 907.276.7542 www.aogcc.alaska.gov ADMINISTRATIVE APPROVAL CONSERVATION ORDER NO. 477B.001 Jamie Wilson Sr. Landman Hilcorp Alaska, LLC 3800 Centerpoint Drive, Suite 1400 Anchorage, AK 99503 Re: Docket Number: CO-25-005 Spacing Exception Milne Point Unit H-21 Injector Well Milne Point Unit Schrader Bluff Oil Pool Dear Ms. Wilson: By letter dated March 3, 2025, Hilcorp Alaska, LLC (Hilcorp) requested the Alaska Oil and Gas Conservation Commission (AOGCC) issue an order approving an exception to the spacing requirements of Conservation Order 477A1 (CO 477A) to drill, complete, short-term pre-produce (flow back for up to 60 days), and operate as a service injection well the proposed Milne Point Unit (MPU) H-21 well (MPU H-21) within 500 feet of the external boundary of the Schrader Bluff Oil Pool (SBOP) affected area, MPU, North Slope Borough, Alaska. Pursuant to 20 AAC 25.540, AOGCC tentatively scheduled a public hearing for May 13, 2025. On March 10, 2025, AOGCC published notice of the opportunity for that hearing on the State of Alaska’s Online Public Notice website and on AOGCC’s website, electronically transmitted the notice to all persons on AOGCC’s email distribution list. On March 12, 2025, AOGCC published the notice in the Anchorage Daily News. Hilcorp sent, by certified mail, notice of the application to all owners, landowners, and operators of all properties within 1,000 feet of the MPU H-21 well trajectory and provided the notice, addresses to which the notices were delivered, and certified mail receipts to AOGCC. The AOGCC received no comments or requests to hold the proposed hearing. The scheduled hearing was vacated. Hilcorp’s application, the hearing record, AOGCC’s records, and publicly available information provide sufficient information upon which to make an informed decision. 1 As discussed below, since Hilcorp submitted this application, CO 477A has been superseded by CO 477B. Accordingly, the AOGCC is treating Hilcorp’s application as a request for an exception to CO 477B. CO 477B.001 July 28, 2025 Page 2 of 5 PURPOSE AND NEED FOR THIS ORDER Well spacing regulations protect the oil and oil rights of adjacent landowners and maximize resource recovery by establishing default limits on how close, under the land's surface, oil and gas wells can be to each other and to property lines where ownership changes hands. These limits are set forth in a regulation 20 AAC 25.055 or in pool rules like CO 477B. Operators must abide by the default well spacing limits (referred to as statewide spacing requirements) unless they apply for, and obtain, an exception to those limits. Although exceptions to the default well spacing requirements are not unusual, AOGCC carefully evaluates each application, and typically grants them only when actual geologic conditions demonstrate that the proposed subsurface location of a well is necessary to reach otherwise unreachable oil or gas, the rights of both adjacent landowners are upheld, and underground drinking water can be protected. As a general matter, AOGCC does not have extensive authority over surface impacts such as noise, emissions, or construction. FINDINGS Hilcorp is operator for the MPU and the planned MPU H-21, an onshore, horizontal, extended- reach injection well that targets the informally named OBa reservoir sandstone within the SBOP. Surface Location: 2529' FNL, 1212’ FWL, Section 34, T13N, R10E, U.M. Top Productive Horizon: 70’ FSL, 1320’ FWL, Section 34, T13N, R10E, U.M. Bottom Hole Location: 70’ FSL, 1440’ FEL, Section 31, T13N, R10E, U.M. MPU H-21 will be located on State of Alaska leases ADL 025906 and ADL 025517 that are operated by Hilcorp. Adjacent immediately to the south are State of Alaska leases ADL 025627 and ADL 025628 that lie within the Kuparuk River Unit (KRU), which is operated by CPAI. Since Hilcorp submitted this application, the AOGCC has issued CO 477B, which expands the areal extent of the SBOP and restates the rules governing that pool. CO 477B supersedes CO 477A and all administrative approvals associated with CO 477A. Accordingly, Rule 2 of CO 477B now governs well spacing in the SBOP within the MPU. That Rule states: “There are no restrictions as to well spacing except that no pay shall be opened in a well closer than 500 feet from the exterior boundary of the affected area.” At Milne Point, the SBOP development comprises three high permeability reservoir sandstones (informally designated as OBa, OA, and NB, in ascending stratigraphic order). These sandstones were deposited in shallow marine and fluvial-deltaic environments, are relatively uniform in thickness, and are widespread throughout the MPU and adjacent acreage within the KRU. MPU H-21 will be drilled to the west from a surface location on H-Pad. This well will open reservoir along a course that lies parallel to, and 70 feet from, the external boundary of the SBOP, which coincides with the boundary line separating the MPU from adjacent leases within the CPAI- operated KRU. This horizontal, extended-reach well will open a two-and-one-half-mile long section of Schrader Bluff OBa reservoir to injection. MPU H-21 will be the peripheral well of a line-drive injection pattern. Fluid injected into this well will push a uniform, linear bank of oil toward the planned, parallel, horizontal MPU H-22 CO 477B.001 July 28, 2025 Page 3 of 5 production well that will be located about 1,000 feet to the north. Similarly, injection into MPU H-21 will also push a uniform, linear bank of oil toward the south into the KRU. Figure 1. Map of Planned Hilcorp MPU H-21 Wellbore Displaying the Proposed Well Path (Source: Modified from Hilcorp Alaska, LLC) The courses of MPU H-21 and MPU H-22 are situated at the most prospective locations on the subsurface structure and within the reservoir. Polymer-injection pilot projects within the MPU SBOPconducted below reservoir parting pressure greatly improved pattern sweep efficiency and increased ultimate recovery. Polymer injection also significantly reduces direct channeling of injected water from injectors to producers, a problem CO 477B.001 July 28, 2025 Page 4 of 5 that has adversely impacted past waterflood projects in Schrader Bluff reservoirs.2 Injection at pressures less than reservoir fracturing pressure will safely maintain reservoir pressure and should not adversely impact CPAI’s future development of adjacent Schrader Bluff reservoirs within the KRU. Polymer injection into MPU H-21 will impact oil reserves that lie within 500 feet of the external boundary of the MPU SBOP. These reserves would not be swept by an injection well conforming to the spacing requirements of CO 477B Rule 2. A horizontal production well located 500 feet from the external boundary would recover only a small portion of these reserves. Limited-duration pre-production of MPU H-21 (60 days or less) prior to injection operations will clean out the well bore, improve injectivity, and recover a portion of the oil reserves from those portions of Hilcorp’s leases that lie within 70’ of the MPU-KRU boundary. Such limited-duration pre-production will not significantly impact oil reserves on adjacent CPAI acreage. CONCLUSIONS An exception to the well spacing provisions of CO 477B is necessary to allow drilling, completion, limited-duration pre-production, and regular injection into the SBOP in MPU H-21 well to maximize ultimate resource recovery. It is not possible to recover a significant portion the targeted reserves from a well location that conforms to the spacing requirements CO 477B. Recent polymer-injection pilot projects within viscous-oil-bearing Schrader Bluff reservoirs at MPU have demonstrated the effectiveness of polymer injection to improve pattern sweep efficiency, increase expected ultimate recovery, and significantly reduce water channeling. Injection of polymer at pressures no greater reservoir fracturing pressure will safely maintain reservoir pressure and should not adversely impact CPAI’s future development of adjacent Schrader Bluff reservoirs within the KRU. Limiting pre-production of MPU H-21 to 60 days will increase injectivity and will not adversely affect reserves located within the KRU. If constructed and operated as required, granting an exception to the well spacing provisions of CO 477B for MPU H-21 will not result in waste or jeopardize correlative rights of adjoining or nearby owners, is based on sound engineering and geoscience principles, and will not result in an increased risk of fluid movement into freshwater. 2 Edwards, R., Aitulov, A., Redwine, C., and Cunha, K., 2022, Viscous Oil Polymer Flood Milne Point Field Case History Concept to Full Field Implementation, Society of Petroleum Engineers, Paper 209372-MS. CO 477B.001 July 28, 2025 Page 5 of 5 NOW THEREFORE IT IS ORDERED The AOGCC grants Hilcorp’s March 3, 2025 application for an exception to the well spacing provisions of CO 477B to allow drilling, completion, limited-duration pre-production, and injection into well MPU H-21 within the SBOP. Hilcorp may proceed and must comply with the constraints stated below, all applicable laws, and all other legal requirements. 1. Constraints requested to apply until December 31, 2030: a. Injection pressure gradients not to exceed 0.65 psi/ft; b. No gas injection; c. Pre-production of MPU H-31 not to exceed 60 days; and d. Downhole pressure gauge data for the Well provided to CPAI upon written request, or as reasonably necessary. 2. Constraint requested to apply for the life of the well: a. Injection only (cannot be converted to a producer). DONE at Anchorage, Alaska and dated July 28, 2025. Jessie L. Chmielowski Gregory C. Wilson Commissioner Commissioner RECONSIDERATION AND APPEAL NOTICE As provided in AS 31.05.080(a), within 20 days after written notice of the entry of this order or decision, or such further time as the AOGCC grants for good cause shown, a person affected by it may file with the AOGCC an application for reconsideration of the matter determined by it. If the notice was mailed, then the period of time shall be 23 days. An application for reconsideration must set out the respect in which the order or decision is believed to be erroneous. The AOGCC shall grant or refuse the application for reconsideration in whole or in part within 10 days after it is filed. Failure to act on it within 10-days is a denial of reconsideration. If the AOGCC denies reconsideration, upon denial, this order or decision and the denial of reconsideration are FINAL and may be appealed to superior court. The appeal MUST be filed within 33 days after the date on which the AOGCC mails, OR 30 days if the AOGCC otherwise distributes, the order or decision denying reconsideration, UNLESS the denial is by inaction, in which case the appeal MUST be filed within 40 days after the date on which the application for reconsideration was filed. If the AOGCC grants an application for reconsideration, this order or decision does not become final. Rather, the order or decision on reconsideration will be the FINAL order or decision of the AOGCC, and it may be appealed to superior court. That appeal MUST be filed within 33 days after the date on which the AOGCC mails, OR 30 days if the AOGCC otherwise distributes, the order or decision on reconsideration. In computing a period of time above, the date of the event or default after which the designated period begins to run is not included in the period; the last day of the period is included, unless it falls on a weekend or state holiday, in which event the period runs until 5:00 p.m. on the next day that does not fall on a weekend or state holiday. Gregory C. Wilson Digitally signed by Gregory C. Wilson Date: 2025.07.28 12:26:00 -08'00' Jessie L. Chmielowski Digitally signed by Jessie L. Chmielowski Date: 2025.07.28 12:57:32 -08'00' From:Coldiron, Samantha J (OGC) To:AOGCC_Public_Notices Subject:[AOGCC_Public_Notices] Conservation Order 477B.001, 477B.002 and 477B.003 Date:Monday, July 28, 2025 1:15:30 PM Attachments:CO477B.001.pdf CO477B.002.pdf CO477B.003.pdf Docket Number: CO-25-005 Spacing Exception Milne Point Unit H-21 Injector Well Milne Point Unit Schrader Bluff Oil Pool Docket Number: CO-25-006 Application for Spacing Exception Milne Point Unit H-31 Extended Well (Injector) Amendment to CO 477.009 Milne Point Unit Schrader Bluff Oil Pool Docket Number: CO-25-007 Application for Spacing Exception Milne Point Unit H-41 and MPU H-43 Injector Wells Milne Point Unit Schrader Bluff Oil Pool Samantha Coldiron AOGCC Special Assistant Alaska Oil and Gas Conservation Commission 333 West 7th Avenue Anchorage, AK 99501 (907) 793-1223 __________________________________ List Name: AOGCC_Public_Notices@list.state.ak.us You subscribed as: samantha.coldiron@alaska.gov Unsubscribe at: https://list.state.ak.us/mailman/options/aogcc_public_notices/samantha.coldiron%40alaska.go v Alaska Oil and Gas Conservation Commission 333 West Seventh Avenue Anchorage, Alaska 99501-3572 Main: 907.279.1433 Fax: 907.276.7542 www.aogcc.alaska.gov ADMINISTRATIVE APPROVAL CONSERVATION ORDER NO. 477B.002 Jamie Wilson Sr. Landman Hilcorp Alaska, LLC 3800 Centerpoint Drive, Suite 1400 Anchorage, AK 99503 Re: Docket Number: CO-25-006 Application for Spacing Exception Milne Point Unit H-31 Extended Well (Injector) Amendment to CO 477.009 Milne Point Unit Schrader Bluff Oil Pool Dear Ms. Wilson: By letter dated March 3, 2025, Hilcorp Alaska, LLC (Hilcorp) requested the Alaska Oil and Gas Conservation Commission (AOGCC) amend an existing spacing exception order (CO 477.009) that approved an exception to the spacing requirements of Conservation Order 477 (CO 477) to drill, complete, test, pre-produce for a limited period (up to 60 days), and operate as a service injection well the proposed Milne Point Unit (MPU) H-31 well (MPU H-31) within 500 feet of the external boundary of the Schrader Bluff Oil Pool (SBOP) affected area, MPU, North Slope Borough, Alaska. Hilcorp seeks to amend the spacing exception approved in CO 477.009 as the planned well course for MPU H-31 has since changed. Pursuant to 20 AAC 25.540, AOGCC tentatively scheduled a public hearing for May 13, 2025. On March 10, 2025, AOGCC published notice of the opportunity for that hearing on the State of Alaska’s Online Public Notice website and on AOGCC’s website, electronically transmitted the notice to all persons on AOGCC’s email distribution list. On March 12, 2025, AOGCC published the notice in the Anchorage Daily News. Hilcorp sent, by certified mail, notice of the application to all owners, landowners, and operators of all properties within 1,000 feet of the MPU H-31 well trajectory and provided the notice, addresses to which the notices were delivered, and certified mail receipts to AOGCC. The AOGCC received no comments or requests to hold the proposed hearing. The scheduled hearing was vacated. Hilcorp’s application, the hearing record, AOGCC’s records, and publicly available information provide sufficient information upon which to make an informed decision. CO 477B.002 July 28, 2025 Page 2 of 5 PURPOSE AND NEED FOR THIS ORDER Well spacing regulations protect the oil and oil rights of adjacent landowners and maximize resource recovery by establishing default limits on how close, under the land's surface, oil and gas wells can be to each other and to property lines where ownership changes hands. These limits are set forth in a regulation 20 AAC 25.055 or in pool rules like CO 477B. Operators must abide by the default well spacing limits (referred to as statewide spacing requirements) unless they apply for, and obtain, an exception to those limits. Although exceptions to the default well spacing requirements are not unusual, AOGCC carefully evaluates each application, and typically grants them only when actual geologic conditions demonstrate that the proposed subsurface location of a well is necessary to reach otherwise unreachable oil or gas, the rights of both adjacent landowners are upheld, and underground drinking water can be protected. As a general matter, AOGCC does not have extensive authority over surface impacts such as noise, emissions, or construction. FINDINGS Hilcorp is operator for the MPU and the planned MPU H-31, an onshore, horizontal, extended- reach injection well that targets the informally named OBa reservoir sandstone within the SBOP. Surface Location: 2223' FNL, 1293’ FWL, Section 34, T13N, R10E, U.M. Top Productive Horizon: 70’ FSL, 682’ FEL, Section 34, T13N, R10E, U.M. Bottom Hole Location: 70’ FSL, 570’ FWL, Section 31, T13N, R10E, U.M. Hilcorp’s amended application extends the course of proposed well MPU H-31 within the OA reservoir, and it adds a final three-quarters of a mile section through the underlying OBa reservoir. MPU H-31 will be located on State of Alaska leases ADL 025906 and ADL 025517 that are operated by Hilcorp. Adjacent immediately to the south are State of Alaska leases ADL 025627 and ADL 025628 that lie within the Kuparuk River Unit (KRU), which is operated by CPAI. Since Hilcorp submitted this application, the AOGCC has issued CO 477B, which expands the areal extent of the SBOP and restates the rules governing that pool. CO 477B supersedes CO 477A and all administrative approvals associated with CO 477A. Accordingly, Rule 2 of CO 477B now governs well spacing in the SBOP within the MPU. That Rule states: “There are no restrictions as to well spacing except that no pay shall be opened in a well closer than 500 feet from the exterior boundary of the affected area.” At Milne Point, the SBOP development comprises three high permeability reservoir sandstones (informally designated as OBa, OA, and NB, in ascending stratigraphic order). These sandstones were deposited in shallow marine and fluvial-deltaic environments, are relatively uniform in thickness, and are widespread throughout the MPU and adjacent acreage within the KRU. MPU H-31 will be drilled to the west from a surface location on H-Pad. This well will open reservoir along a course that lies parallel to, and 70 feet from, the external boundary of the SBOP, which coincides with the boundary line separating the MPU from adjacent leases within the CPAI- operated KRU. The initial portion of this horizontal, extended-reach well will open a two-and-one- CO 477B.002 July 28, 2025 Page 3 of 5 half-mile long section of Schrader Bluff OA reservoir to injection.The final portion of this well will open about three-quarters of a mile of the underlying OBa reservoir to injection. Figure 1. Map of Planned Hilcorp MPU H-31 Wellbore Displaying the Proposed Well Path (Source: Modified from Hilcorp Alaska, LLC) MPU H-31 will be the peripheral well of a line-drive injection pattern. Fluid injected into this well will push a uniform, linear bank of oil toward the planned, parallel, horizontal MPU H-32 production well that will be located about 1,000 feet to the north. Similarly, injection into MPU H-31 will also push a uniform, linear bank of oil toward the south into the KRU. The courses of MPU H-31 and MPU H-32 are situated at the most prospective locations on the subsurface structure and within the reservoirs. CO 477B.002 July 28, 2025 Page 4 of 5 Polymer-injection pilot projects within the MPU SBOP conducted below reservoir parting pressure greatly improved pattern sweep efficiency and increased ultimate recovery. Polymer injection also significantly reduces direct channeling of injected water from injectors to producers, a problem that has adversely impacted past waterflood projects in Schrader Bluff reservoirs.1 Injection at pressures less than reservoir fracturing pressure will safely maintain reservoir pressure and should not adversely impact CPAI’s future development of adjacent Schrader Bluff reservoirs within the KRU. Polymer injection into MPU H-31 will impact oil reserves that lie within 500 feet of the external boundary of the MPU SBOP. These reserves would not be swept by an injection well conforming to the spacing requirements of CO 477B Rule 2. A horizontal production well located 500 feet from the external boundary would recover only a small portion of these reserves. Limited-duration pre-production of MPU H-31 (60 days or less) prior to injection operations will clean out the well bore, improve injectivity, and recover a portion of the oil reserves from those portions of Hilcorp’s leases that lie within 70’ of the MPU-KRU boundary. Such limited-duration pre-production will not significantly impact oil reserves on adjacent CPAI acreage. CONCLUSIONS An exception to the well spacing provisions of CO 477B is necessary to allow drilling, completion, limited-duration pre-production, and regular injection into the SBOP in MPU H-31 well to maximize ultimate resource recovery. It is not possible to recover a significant portion the targeted reserves from a well location that conforms to the spacing requirements CO 477B. Recent polymer-injection pilot projects within viscous-oil-bearing Schrader Bluff reservoirs at MPU have demonstrated the effectiveness of polymer injection to improve pattern sweep efficiency, increase expected ultimate recovery, and significantly reduce water channeling. Injection of polymer at pressures no greater reservoir fracturing pressure will safely maintain reservoir pressure and should not adversely impact CPAI’s future development of adjacent Schrader Bluff reservoirs within the KRU. Limiting pre-production of MPU H-31 to 60 days will increase injectivity and will not adversely affect reserves located within the KRU. If constructed and operated as required, granting an exception to the well spacing provisions of CO 477B for MPU H-31 will not result in waste or jeopardize correlative rights of adjoining or nearby owners, is based on sound engineering and geoscience principles, and will not result in an increased risk of fluid movement into freshwater. 1 Edwards, R., Aitulov, A., Redwine, C., and Cunha, K., 2022, Viscous Oil Polymer Flood Milne Point Field Case History Concept to Full Field Implementation, Society of Petroleum Engineers, Paper 209372-MS. CO 477B.002 July 28, 2025 Page 5 of 5 NOW THEREFORE IT IS ORDERED The AOGCC grants Hilcorp’s March 3, 2025 application for an exception to the well spacing provisions of CO 477B to allow drilling, completion, limited-duration pre-production, and injection into extended well MPU H-31 within the SBOP. Hilcorp may proceed and must comply with the constraints stated below, all applicable laws, and all other legal requirements. 1. Constraints requested to apply until December 31, 2030: a. Injection pressure gradients not to exceed 0.65 psi/ft; b. No gas injection; c. Pre-production of MPU H-31 not to exceed 60 days; and d. Downhole pressure gauge data for the Well provided to CPAI upon written request, or as reasonably necessary. 2. Constraint requested to apply for the life of the well: a. Injection only (cannot be converted to a producer). DONE at Anchorage, Alaska and dated July 28, 2025. Jessie L. Chmielowski Gregory C. Wilson Commissioner Commissioner RECONSIDERATION AND APPEAL NOTICE As provided in AS 31.05.080(a), within 20 days after written notice of the entry of this order or decision, or such further time as the AOGCC grants for good cause shown, a person affected by it may file with the AOGCC an application for reconsideration of the matter determined by it. If the notice was mailed, then the period of time shall be 23 days. An application for reconsideration must set out the respect in which the order or decision is believed to be erroneous. The AOGCC shall grant or refuse the application for reconsideration in whole or in part within 10 days after it is filed. Failure to act on it within 10-days is a denial of reconsideration. If the AOGCC denies reconsideration, upon denial, this order or decision and the denial of reconsideration are FINAL and may be appealed to superior court. The appeal MUST be filed within 33 days after the date on which the AOGCC mails, OR 30 days if the AOGCC otherwise distributes, the order or decision denying reconsideration, UNLESS the denial is by inaction, in which case the appeal MUST be filed within 40 days after the date on which the application for reconsideration was filed. If the AOGCC grants an application for reconsideration, this order or decision does not become final. Rather, the order or decision on reconsideration will be the FINAL order or decision of the AOGCC, and it may be appealed to superior court. That appeal MUST be filed within 33 days after the date on which the AOGCC mails, OR 30 days if the AOGCC otherwise distributes, the order or decision on reconsideration. In computing a period of time above, the date of the event or default after which the designated period begins to run is not included in the period; the last day of the period is included, unless it falls on a weekend or state holiday, in which event the period runs until 5:00 p.m. on the next day that does not fall on a weekend or state holiday. Gregory C. Wilson Digitally signed by Gregory C. Wilson Date: 2025.07.28 12:36:44 -08'00' Jessie L. Chmielowski Digitally signed by Jessie L. Chmielowski Date: 2025.07.28 12:59:01 -08'00' From:Coldiron, Samantha J (OGC) To:AOGCC_Public_Notices Subject:[AOGCC_Public_Notices] Conservation Order 477B.001, 477B.002 and 477B.003 Date:Monday, July 28, 2025 1:15:30 PM Attachments:CO477B.001.pdf CO477B.002.pdf CO477B.003.pdf Docket Number: CO-25-005 Spacing Exception Milne Point Unit H-21 Injector Well Milne Point Unit Schrader Bluff Oil Pool Docket Number: CO-25-006 Application for Spacing Exception Milne Point Unit H-31 Extended Well (Injector) Amendment to CO 477.009 Milne Point Unit Schrader Bluff Oil Pool Docket Number: CO-25-007 Application for Spacing Exception Milne Point Unit H-41 and MPU H-43 Injector Wells Milne Point Unit Schrader Bluff Oil Pool Samantha Coldiron AOGCC Special Assistant Alaska Oil and Gas Conservation Commission 333 West 7th Avenue Anchorage, AK 99501 (907) 793-1223 __________________________________ List Name: AOGCC_Public_Notices@list.state.ak.us You subscribed as: samantha.coldiron@alaska.gov Unsubscribe at: https://list.state.ak.us/mailman/options/aogcc_public_notices/samantha.coldiron%40alaska.go v Alaska Oil and Gas Conservation Commission 333 West Seventh Avenue Anchorage, Alaska 99501-3572 Main: 907.279.1433 Fax: 907.276.7542 www.aogcc.alaska.gov ADMINISTRATIVE APPROVAL CONSERVATION ORDER NO. 477B.003 Jamie Wilson Sr. Landman Hilcorp Alaska, LLC 3800 Centerpoint Drive, Suite 1400 Anchorage, AK 99503 Re: Docket Number: CO-25-007 Application for Spacing Exception Milne Point Unit H-41 and MPU H-43 Injector Wells Milne Point Unit Schrader Bluff Oil Pool Dear Ms. Wilson: By letter dated March 3, 2025, Hilcorp Alaska, LLC (Hilcorp) requested the Alaska Oil and Gas Conservation Commission (AOGCC) issue an order approving an exception to the spacing requirements of Conservation Order 477A1 (CO 477A) to drill, complete, short-term pre-produce (flow back for up to 60 days), and operate as service injection wells the proposed Milne Point Unit (MPU) H-41 and H-43 wells (MPU H-41 and MPU H-43) within 500 feet of the external boundary of the Schrader Bluff Oil Pool (SBOP) affected area, MPU, North Slope Borough, Alaska. Pursuant to 20 AAC 25.540, AOGCC tentatively scheduled a public hearing for May 13, 2025. On March 10, 2025, AOGCC published notice of the opportunity for that hearing on the State of Alaska’s Online Public Notice website and on AOGCC’s website, electronically transmitted the notice to all persons on AOGCC’s email distribution list. On March 12, 2025, AOGCC published the notice in the Anchorage Daily News. Hilcorp sent, by certified mail, notice of the application to all owners, landowners, and operators of all properties within 1,000 feet of the MPU H-41 and MPU H-43 well trajectories and provided copies of the notice, addresses to which the notices were delivered, and certified mail tracking numbers to AOGCC. The AOGCC received no comments or requests to hold the proposed hearing. The scheduled hearing was vacated. Hilcorp’s application, the hearing record, AOGCC’s records, and publicly available information provide sufficient information upon which to make an informed decision. 1 As discussed below, since Hilcorp submitted this application, CO 477A has been superseded by CO 477B. Accordingly, the AOGCC is treating Hilcorp’s application as a request for an exception to CO 477B. CO 477B.003 July 28, 2025 Page 2 of 6 PURPOSE AND NEED FOR THIS ORDER Well spacing regulations protect the oil and oil rights of adjacent landowners and maximize resource recovery by establishing default limits on how close, under the land's surface, oil and gas wells can be to each other and to property lines where ownership changes hands. These limits are set forth in a regulation 20 AAC 25.055 or in pool rules like CO 477B. Operators must abide by the default well spacing limits (referred to as statewide spacing requirements) unless they apply for, and obtain, an exception to those limits. Although exceptions to the default well spacing requirements are not unusual, AOGCC carefully evaluates each application, and typically grants them only when actual geologic conditions demonstrate that the proposed subsurface location of a well is necessary to reach otherwise unreachable oil or gas, the rights of both adjacent landowners are upheld, and underground drinking water can be protected. As a general matter, AOGCC does not have extensive authority over surface impacts such as noise, emissions, or construction. FINDINGS Hilcorp is operator for the MPU and the planned MPU H-41 and MPU H-43, onshore, horizontal, extended-reach injection wells. MPU H-41 targets the informally named NB and OA reservoir sandstones within the SBOP. Surface Location: 2435' FNL, 1105’ FWL, Section 34, T13N, R10E, U.M. Top Productive Horizon: 70’ FSL, 2535’ FWL, Section 33, T13N, R10E, U.M. Bottom Hole Location: 70’ FSL, 70’ FWL, Section 31, T13N, R10E, U.M. MPU H-43 targets the NB and OA reservoir sandstones within the SBOP. Surface Location: 2291' FNL, 1158’ FWL, Section 34, T13N, R10E, U.M. Top Productive Horizon: 1497’ FSL, 612’ FWL, Section 33, T13N, R10E, U.M. Bottom Hole Location: 2004’ FSL, 70’ FWL, Section 31, T13N, R10E, U.M. MPU H-41 and MPU H-43 will be located on State of Alaska leases ADL 025906 and ADL 025517 that are operated by Hilcorp. Adjacent immediately to the south are State of Alaska leases ADL 025627 and ADL 025628 that lie within the Kuparuk River Unit (KRU), which is operated by ConocoPhillips Alaska Inc. (CPAI). Immediately adjacent to the west is State of Alaska lease ADL 025519 that also lies within the KRU. Since Hilcorp submitted this application, the AOGCC has issued CO 477B, which expands the areal extent of the SBOP and restates the rules governing that pool. CO 477B supersedes CO 477A and all administrative approvals associated with CO 477A. Accordingly, Rule 2 of CO 477B now governs well spacing in the SBOP within the MPU. That Rule states: “There are no restrictions as to well spacing except that no pay shall be opened in a well closer than 500 feet from the exterior boundary of the affected area.” At Milne Point, the SBOP development comprises three high permeability reservoir sandstones (informally designated as OBa, OA, and NB, in ascending stratigraphic order). These sandstones CO 477B.003 July 28, 2025 Page 3 of 6 were deposited in shallow marine and fluvial-deltaic environments, are relatively uniform in thickness, and are widespread throughout the MPU and adjacent acreage within the KRU. Figure 1. Map of Planned Hilcorp MPU H-41 and MPU H-43 Wellbores Displaying the Proposed Well Paths (Source: Modified from Hilcorp Alaska, LLC) MPU H-41 will be drilled to the west from a surface location on H-Pad. This well will open reservoir along a course that lies parallel to, and 70 feet from, the external boundary of the SBOP, which coincides with the boundary line separating the MPU from adjacent leases within the CPAI- operated KRU. The initial portion of this horizontal, extended-reach well will open a one-and- ADL 025519 CO 477B.003 July 28, 2025 Page 4 of 6 three-quarters-mile long section of Schrader Bluff NB reservoir to injection. The final portion of the well will open a nearly one-mile long section of Schrader Bluff OA reservoir to injection. MPU H-41 will be the peripheral well of a line-drive injection pattern. Fluid injected into this well will push a uniform, linear bank of oil toward the planned, parallel, horizontal MPU H-42 production well that will be located about 800’ to 1,000 feet to the north. Similarly, injection into MPU H-41 will also push a uniform, linear bank of oil toward the south into the KRU. MPU H-43 will be drilled to the west from a surface location on H-Pad. This well will open about one-and-one-half miles of NB reservoir along a west-trending course that mainly lies approximately parallel to, and about 1,500’ and 2,000’ feet north of, MPU H-41. The final portion of the well will open about three-quarters of a mile long section of Schrader Bluff OA reservoir to injection. MPU H-43 will lie about 800’ to 1,000’ north of the planned parallel, MPU H-42 producer that will lie in between, and approximately equidistant from, MPU H-41 and MPU H-43. An exception to the spacing requirements is needed for MPU H-43 because the proposed bottom- hole location lies 70’ from State of Alaska Lease ADL 025519, which lies to the west within the CPAI-operated KRU. MPU H-43 will push a linear bank of oil toward the H-42 producer. The lowermost portion of MPU H-43 will also push oil west into the KRU. The courses of MPU H-41 and MPU H-43 and MPU H-42 are situated at the most prospective locations on the subsurface structure and within the reservoirs. Polymer-injection pilot projects within the MPU SBOP conducted below reservoir parting pressure greatly improved pattern sweep efficiency and increased ultimate recovery. Polymer injection also significantly reduces direct channeling of injected water from injectors to producers, a problem that has adversely impacted past waterflood projects in Schrader Bluff reservoirs.2 Injection at pressures less than reservoir fracturing pressure will safely maintain reservoir pressure and should not adversely impact CPAI’s future development of adjacent Schrader Bluff reservoirs within the KRU. Polymer injection into MPU H-41 and MPU H-43 will impact oil reserves that lie within 500 feet of the external boundary of the MPU SBOP. These reserves would not be swept by an injection well conforming to the spacing requirements of CO 477B Rule 2. Limited-duration pre-production of MPU H-41 and MPU H-43 (60 days or less) prior to injection operations will clean out the well bore, improve injectivity, and recover a portion of the oil reserves from those portions of Hilcorp’s leases that lie within 70’ of the MPU-KRU boundary. Such limited-duration pre-production will not significantly impact oil reserves on adjacent CPAI acreage. 2 Edwards, R., Aitulov, A., Redwine, C., and Cunha, K., 2022, Viscous Oil Polymer Flood Milne Point Field Case History Concept to Full Field Implementation, Society of Petroleum Engineers, Paper 209372-MS. CO 477B.003 July 28, 2025 Page 5 of 6 CONCLUSIONS An exception to the well spacing provisions of CO 477B is necessary to allow drilling, completion, limited-duration pre-production, and regular injection into the SBOP in MPU H-41 and MPU H- 43 wells to maximize ultimate resource recovery. It is not possible to recover a significant portion the targeted reserves from well locations that conform to the spacing requirements CO 477B. Recent polymer-injection pilot projects within viscous-oil-bearing Schrader Bluff reservoirs at MPU have demonstrated the effectiveness of polymer injection to improve pattern sweep efficiency, increase expected ultimate recovery, and significantly reduce water channeling. Injection of polymer at pressures no greater reservoir fracturing pressure will safely maintain reservoir pressure and should not adversely impact CPAI’s future development of adjacent Schrader Bluff reservoirs within the KRU. Limiting pre-production of MPU H-41 and MPU H-43 to 60 days will increase injectivity and will not adversely affect reserves located within the KRU. If constructed and operated as required, granting an exception to the well spacing provisions of CO 477B for MPU H-41 and MPU H-43 will not result in waste or jeopardize correlative rights of adjoining or nearby owners, is based on sound engineering and geoscience principles, and will not result in an increased risk of fluid movement into freshwater. NOW THEREFORE IT IS ORDERED The AOGCC grants Hilcorp’s March 3, 2025 application for an exception to the well spacing provisions of CO 477B to allow drilling, completion, limited-duration pre-production, and injection into wells MPU H-41 and MPU H-43 within the SBOP. Hilcorp may proceed and must comply with the constraints stated below, all applicable laws, and all other legal requirements. 1. Constraints requested to apply until December 31, 2030: a. Injection pressure gradients not to exceed 0.65 psi/ft; b. No gas injection; c. Pre-production of MPU H-31 not to exceed 60 days; and d. Downhole pressure gauge data for the Well provided to CPAI upon written request, or as reasonably necessary. 2. Constraint requested to apply for the life of the well: a. Injection only (cannot be converted to a producer). CO 477B.003 July 28, 2025 Page 6 of 6 DONE at Anchorage, Alaska and dated July 28, 2025. Jessie L. Chmielowski Gregory C. Wilson Commissioner Commissioner RECONSIDERATION AND APPEAL NOTICE As provided in AS 31.05.080(a), within 20 days after written notice of the entry of this order or decision, or such further time as the AOGCC grants for good cause shown, a person affected by it may file with the AOGCC an application for reconsideration of the matter determined by it. If the notice was mailed, then the period of time shall be 23 days. An application for reconsideration must set out the respect in which the order or decision is believed to be erroneous. The AOGCC shall grant or refuse the application for reconsideration in whole or in part within 10 days after it is filed. Failure to act on it within 10-days is a denial of reconsideration. If the AOGCC denies reconsideration, upon denial, this order or decision and the denial of reconsideration are FINAL and may be appealed to superior court. The appeal MUST be filed within 33 days after the date on which the AOGCC mails, OR 30 days if the AOGCC otherwise distributes, the order or decision denying reconsideration, UNLESS the denial is by inaction, in which case the appeal MUST be filed within 40 days after the date on which the application for reconsideration was filed. If the AOGCC grants an application for reconsideration, this order or decision does not become final. Rather, the order or decision on reconsideration will be the FINAL order or decision of the AOGCC, and it may be appealed to superior court. That appeal MUST be filed within 33 days after the date on which the AOGCC mails, OR 30 days if the AOGCC otherwise distributes, the order or decision on reconsideration. In computing a period of time above, the date of the event or default after which the designated period begins to run is not included in the period; the last day of the period is included, unless it falls on a weekend or state holiday, in which event the period runs until 5:00 p.m. on the next day that does not fall on a weekend or state holiday. Gregory C. Wilson Digitally signed by Gregory C. Wilson Date: 2025.07.28 12:41:12 -08'00' Jessie L. Chmielowski Digitally signed by Jessie L. Chmielowski Date: 2025.07.28 12:59:52 -08'00' From:Coldiron, Samantha J (OGC) To:AOGCC_Public_Notices Subject:[AOGCC_Public_Notices] Conservation Order 477B.001, 477B.002 and 477B.003 Date:Monday, July 28, 2025 1:15:30 PM Attachments:CO477B.001.pdf CO477B.002.pdf CO477B.003.pdf Docket Number: CO-25-005 Spacing Exception Milne Point Unit H-21 Injector Well Milne Point Unit Schrader Bluff Oil Pool Docket Number: CO-25-006 Application for Spacing Exception Milne Point Unit H-31 Extended Well (Injector) Amendment to CO 477.009 Milne Point Unit Schrader Bluff Oil Pool Docket Number: CO-25-007 Application for Spacing Exception Milne Point Unit H-41 and MPU H-43 Injector Wells Milne Point Unit Schrader Bluff Oil Pool Samantha Coldiron AOGCC Special Assistant Alaska Oil and Gas Conservation Commission 333 West 7th Avenue Anchorage, AK 99501 (907) 793-1223 __________________________________ List Name: AOGCC_Public_Notices@list.state.ak.us You subscribed as: samantha.coldiron@alaska.gov Unsubscribe at: https://list.state.ak.us/mailman/options/aogcc_public_notices/samantha.coldiron%40alaska.go v Alaska Oil and Gas Conservation Commission 333 West Seventh Avenue Anchorage, Alaska 99501-3572 Main: 907.279.1433 Fax: 907.276.7542 www.aogcc.alaska.gov ADMINISTRATIVE APPROVAL CONSERVATION ORDER NO. 477B.004 Jamie Wilson Sr. Landman Hilcorp Alaska, LLC 3800 Centerpoint Drive, Suite 1400 Anchorage, AK 99503 Re: Docket Number: CO-25-013 Application for Spacing Exception Milne Point Unit M-65 Injector Well Schrader Bluff Oil Pool Milne Point Unit North Slope Borough, Alaska Dear Ms. Wilson: By letter received June 23, 2025, Hilcorp Alaska, LLC (Hilcorp) requested the Alaska Oil and Gas Conservation Commission (AOGCC) issue an order approving an exception to the spacing requirements of Conservation Order 477B (CO 477B) to drill, complete, short-term pre-produce (flow back for up to 30 days1), and operate as service injection well the proposed Milne Point Unit (MPU) M-65 well (MPU M-65) within 500 feet of the external boundary of the Schrader Bluff Oil Pool (SBOP) affected area, MPU, North Slope Borough, Alaska. Pursuant to 20 AAC 25.540, AOGCC tentatively scheduled a public hearing for August 7, 2025. On June 26, 2025, AOGCC published notice of the opportunity for that hearing on the State of Alaska’s Online Public Notice website and on AOGCC’s website and electronically transmitted the notice to all persons on AOGCC’s email distribution list. On June 29, 2025, AOGCC published the notice in the ANCHORAGE DAILY NEWS. In accordance with 20 AAC 25.055(d), Hilcorp sent, by certified mail, notice of the application to all owners, landowners, and operators of all properties within 1,000 feet of the MPU M-65 well and provided to AOGCC copies of the notices and addresses to which the notices were delivered. 1 Hilcorp’s application states on page 2: “Hilcorp intends to flow back this well for up to 30 days to fully clean out the wellbore to reduce the effect of near-wellbore damage caused by drilling fluid invasion which will ensure maximum injectivity”, and “Associated oil will only be “produced” for 30 days to ensure the wellbore is as clean as possible before commencing injection operations.” In combination, these statements are a bit unclear; however, adjacent lease owner/operator ConocoPhillips Alaska, Inc. subsequently proposed, and Hilcorp concurred with, pre-production not to exceed 60 days. See emails referenced in footnotes 3 and 4, below. Pre-production for up to 60 days also conforms to durations approved in similar SBOP spacing exception orders CO 477B.001, CO 477B.002, and CO 477B.003. CO 477B.004 December 9, 2025 Page 2 of 6 The AOGCC received one comment from an adjacent owner / operator requesting the proposed hearing be held if Hilcorp and that operator were unable to reach an acceptable agreement. Subsequently, that requestor reported an acceptable agreement had been reached, Hilcorp concurred that an agreement had been reached, and the scheduled hearing was vacated. Hilcorp’s application, additional information submitted by Hilcorp and the adjacent operator, AOGCC’s records, and publicly available information are sufficient to make an informed decision. PURPOSE AND NEED FOR THIS ORDER Well spacing regulations protect the oil and oil rights of adjacent landowners and maximize resource recovery by establishing default limits on how close, under the land's surface, oil and gas wells can be to each other and to property lines where ownership changes hands. These limits are set forth in a regulation 20 AAC 25.055 or in pool rules like CO 477B. Operators must abide by the default well spacing limits (referred to as spacing requirements) unless they apply for, and obtain, an exception to those limits. Although exceptions to the default well spacing requirements are not unusual, AOGCC carefully evaluates each application, and typically grants them only when actual geologic conditions demonstrate that the proposed subsurface location of a well is necessary to reach otherwise unreachable oil or gas, the rights of both adjacent landowners are upheld, and underground drinking water can be protected. As a general matter, AOGCC does not have extensive authority over surface impacts such as noise, emissions, or construction. FINDINGS MPU M-65 will be located as follows. Surface: 363' FNL, 741' FEL, Section 14, T13N, R9E, Umiat Meridian (UM) Target (Estimated): 558' FNL, 137’ FWL, Section 14, T13N, R9E, UM Bottom Hole: 116' FSL, 94’ FWL, Section 23, T13N, R9E, UM Hilcorp is operator for the MPU and for this proposed onshore, extended-reach, horizontal injection well that will lie parallel to, and within 500 feet of, the external boundary of the SBOP, which in this area also separates the MPU from the Kuparuk River Unit (KRU). (See Figure 1, below.) CPAI is operator for adjacent KRU leases ADL 355023, ADL 25513, ADL 25519, and ADL 25520. The affected landowner is the State of Alaska (SOA). Hilcorp is 100% working interest owner for lease ADL 025514, which contains the proposed surface, target, and bottom-hole locations for MPU-65. On Figure 1, the horizontal portion of MPU M-65 that will be open to the SBOP is depicted by the north-south oriented red line. A portion of the MPU-65 wellbore that is shallower than the target reservoir interval will traverse part of adjacent lease ADL 355023 that lies within the KRU and is owned by ConocoPhillips Alaska, Inc. (CPAI) and ExxonMobil Alaska Production Inc. (ExxonMobil). Authorization to drill this portion of the well has been granted by the Alaska Department of Natural Resources (DNR) through a subsurface easement that is described in DNR’s Land Administration System Case File CO 477B.004 December 9, 2025 Page 3 of 6 No. 421155, and is extended until June 12, 2029 by letter dated June 11, 2024. 2 The three additional adjacent leases ADL 25513, ADL 25519, and ADL 25520 lie within the KRU and are owned by CPAI and ExxonMobil. Figure 1. Map of Planned Hilcorp MPU M-65 Well Displaying the Proposed Well Path and 500-Foot Buffer Inside of the Milne Point Unit and the Affected Area of CO 477B. (The portion of MPU M-65 open within the reservoir is depicted by the vertical red line. The dark blue line represents the MPU – KRU boundary. The dashed purple line depicts the 500-foot buffer.) (Source: Modified from Hilcorp Alaska, LLC) Rule 2 of CO 477B governs well spacing for the SBOP within the MPU. An exception is required for MPU M-65 because the proposed injection interval will lie within 500 feet of property lines where ownership changes. 2 Smith, G., 2024, DNR Letter to J. Wilson, Hilcorp, titled “Re: ADL 421155 Extension of Moose Pad Wellbore Easement Pursuant to AS 38.05.850”, dated June 11, 2024. ADL 025519 ADL 355023 CO 477B.004 December 9, 2025 Page 4 of 6 At Milne Point, the SBOP development comprises several high-permeability reservoir sandstones. These sandstones were deposited in shallow marine and fluvial-deltaic environments, are relatively uniform in thickness, and are widespread throughout the MPU and adjacent acreage in the KRU. MPU M-65 will be drilled to the west-northwest from a surface location on M-Pad and then turned directly south. This well will open to injection a nearly two-mile long section of reservoir along a course that lies parallel to, and about 100 to 200 feet from, the external boundary of the SBOP, which in this area coincides with the boundary line separating the MPU from adjacent leases within the CPAI-operated KRU. The course of MPU M-65 is situated at the most prospective location on the subsurface structure and within the Schrader Bluff reservoirs. MPU M-65 will be the peripheral well of a line-drive injection pattern. Fluid and polymer injected into this well will push a uniform, linear bank of oil toward a parallel, horizontal MPU production well that will be located about 500 to 1,000 feet to the east. Similarly, injection into MPU M-65 will also push a uniform, linear bank of oil toward the west into the KRU. These reserves would not be swept by an injection well conforming to the spacing requirements of CO 477B Rule 2. Limited-duration pre-production of MPU M-65 (60 days or less) prior to injection operations will clean out the well bore, improve injectivity, and recover a portion of the oil reserves from those portions of Hilcorp’s leases that lie near the MPU-KRU boundary. Such limited-duration pre- production will not significantly impact oil reserves on adjacent CPAI acreage. CPAI, owner and operator of the four adjacent leases, has agreed to drilling and operation of MPU M-65 as an injection well contingent upon the conditions listed below.3 By email dated July 30, 2025, Hilcorp concurred with these conditions.4 x Injection pressure gradients not to exceed 0.65 psi/ft; x No gas injection; x Pre-production of the well not to exceed 60 days; x Downhole pressure gauge data for the well will be provided to CPAI upon written request, or as reasonably necessary; x Injection only (cannot be converted to a producer); and x Hilcorp will not penetrate the N-sand interval, as seen at 3,552’ MD in the West Sak No. 1 well, on ADL 355023. If conducted as required, drilling, completion, pre-production, and operation of MPU M-65 as an injection well will not cause waste or result in an increased risk of fluid movement into freshwater. 3 King, R., 2025, CPAI email to S. Coldiron, AOGCC, titled “[EXTERNAL] RE: [EXTERNAL]RE: Request for Hearing on Docket No. CO-25-013”, dated July 29, 2025. 4 O’Quinn, A., 2025, Hilcorp Email to R. King, Hilcorp, and S. Coldiron, AOGCC, titled “Re: [EXTERNAL] RE: [EXTERNAL]RE: Request for Hearing on Docket No. CO-25-013”, dated July 30, 2025. CO 477B.004 December 9, 2025 Page 5 of 6 CONCLUSIONS An exception to the well spacing provisions of CO 477B is necessary to allow drilling, completion, limited-duration pre-production, and regular injection into the SBOP in MPU M-65 well to maximize ultimate resource recovery. It is not possible to recover a significant portion of the targeted reserves from well locations that conform to the spacing requirements CO 477B. Limiting pre-production of MPU M-65 to 60 days will increase injectivity and will not adversely affect reserves located within the KRU. Correlative rights of landowners of leases adjacent to MPU M-65 will be protected by the constraints specified below. If constructed and operated as required, granting an exception to the well spacing provisions of CO 477B for MPU M-65 will not result in waste or jeopardize correlative rights of adjoining or nearby owners, is based on sound engineering and geoscience principles, and will not result in an increased risk of fluid movement into freshwater. NOW THEREFORE IT IS ORDERED The AOGCC grants Hilcorp’s June 23, 2025, application for an exception to the well spacing provisions of CO 477B to allow drilling, completion, limited-duration pre-production, and injection into well MPU M-65 within the SBOP. Hilcorp may proceed and must comply with the constraints stated below, all applicable laws, and all other legal requirements. x Injection pressure gradients not to exceed 0.65 psi/ft; x No gas injection; x Pre-production of MPU M-65 not to exceed 60 days; x Downhole pressure gauge data for the well will be provided to CPAI upon written request, or as reasonably necessary; x MPU M-65 is restricted to injection only and cannot be converted to a producer; and x MPU M-65 will not penetrate the Schrader Bluff N-sand interval, as seen at 3,552’ MD in the West Sak No. 1 well, on lease ADL 355023. DONE at Anchorage, Alaska and dated December 9, 2025. Jessie L. Chmielowski Gregory C. Wilson Commissioner Commissioner Jessie L. Chmielowski Digitally signed by Jessie L. Chmielowski Date: 2025.12.09 13:45:21 -09'00' Gregory C Wilson Digitally signed by Gregory C Wilson Date: 2025.12.10 08:48:07 -09'00' CO 477B.004 December 9, 2025 Page 6 of 6 RECONSIDERATION AND APPEAL NOTICE As provided in AS 31.05.080(a), within 20 days after written notice of the entry of this order or decision, or such further time as the AOGCC grants for good cause shown, a person affected by it may file with the AOGCC an application for reconsideration of the matter determined by it. If the notice was mailed, then the period of time shall be 23 days. An application for reconsideration must set out the respect in which the order or decision is believed to be erroneous. The AOGCC shall grant or refuse the application for reconsideration in whole or in part within 10 days after it is filed. Failure to act on it within 10-days is a denial of reconsideration. If the AOGCC denies reconsideration, upon denial, this order or decision and the denial of reconsideration are FINAL and may be appealed to superior court. The appeal MUST be filed within 33 days after the date on which the AOGCC mails, OR 30 days if the AOGCC otherwise distributes, the order or decision denying reconsideration, UNLESS the denial is by inaction, in which case the appeal MUST be filed within 40 days after the date on which the application for reconsideration was filed. If the AOGCC grants an application for reconsideration, this order or decision does not become final. Rather, the order or decision on reconsideration will be the FINAL order or decision of the AOGCC, and it may be appealed to superior court. That appeal MUST be filed within 33 days after the date on which the AOGCC mails, OR 30 days if the AOGCC otherwise distributes, the order or decision on reconsideration. In computing a period of time above, the date of the event or default after which the designated period begins to run is not included in the period; the last day of the period is included, unless it falls on a weekend or state holiday, in which event the period runs until 5:00 p.m. on the next day that does not fall on a weekend or state holiday. From:Coldiron, Samantha J (OGC) To:AOGCC_Public_Notices Subject:[AOGCC_Public_Notices] Area injection Order 477B.004 (Hilcorp) Date:Wednesday, December 10, 2025 10:16:53 AM Docket Number: CO-25-013 Application for Spacing Exception Milne Point Unit M-65 Injector Well Schrader Bluff Oil Pool Milne Point Unit North Slope Borough, Alaska Samantha Coldiron AOGCC Special Assistant Alaska Oil and Gas Conservation Commission 333 West 7th Avenue Anchorage, AK 99501 (907) 793-1223 __________________________________ List Name: AOGCC_Public_Notices@list.state.ak.us You subscribed as: samantha.coldiron@alaska.gov Unsubscribe at: https://list.state.ak.us/mailman/options/aogcc_public_notices/samantha.coldiron%40alaska.go v 16 CAUTION: External sender. DO NOT open links or attachments from UNKNOWN senders. CAUTION: This email originated from outside the State of Alaska mail system. Do not click links or open attachments unless you recognize the sender and know the content is safe. From:Jamie Wilson To:Davies, Stephen F (OGC) Cc:Dewhurst, Andrew D (OGC); Starns, Ted C (OGC); Coldiron, Samantha J (OGC) Subject:RE: [EXTERNAL] MPU M-65 Spacing Exception - Question Date:Monday, December 1, 2025 10:06:48 AM Attachments:image001.png image002.png ADL 421155 Moose Pad Wellbore EA Extension_Expire 6.12.29.pdf Steve, Attached please find the extension of ADL 421155 through June 12, 2029. Let me know if you need anything else! Thanks, Jamie From: Davies, Stephen F (OGC) <steve.davies@alaska.gov> Sent: Monday, December 1, 2025 9:59 AM To: Jamie Wilson <jamie.wilson@hilcorp.com> Cc: Dewhurst, Andrew D (OGC) <andrew.dewhurst@alaska.gov>; Starns, Ted C (OGC) <ted.starns@alaska.gov>; Coldiron, Samantha J (OGC) <samantha.coldiron@alaska.gov> Subject: [EXTERNAL] MPU M-65 Spacing Exception - Question Hello Jamie, I'm working on Hilcorp's requested spacing exception for the MPU M-65 well. A shallow portion of this well will be drilled outside of the MPU, crossing a lease within the Kuparuk River Unit. Hilcorp's application states in part: DNR's LAS Case File ADL 421155 contains the following: According to this Case File, the DNR's interim authorization for Hilcorp's subsurface easement expired in June 2024. Is this correct? If not, could Hilcorp please provide me with evidence of current authorization? Thanks and Be Well, Steve Davies Senior Petroleum Geologist AOGCC CONFIDENTIALITY NOTICE: This e-mail message, including any attachments, contains information from the Alaska Oil and Gas Conservation Commission (AOGCC), State of Alaska and is for the sole use of the intended recipient(s). It may contain confidential and/or privileged information. The unauthorized review, use or disclosure of such information may violate state or federal law. If you are an unintended recipient of this e-mail, please delete it, without first saving or forwarding it, and, so that the AOGCC is aware of the mistake in sending it to you, contact Steve Davies at 907-793-1224 or steve.davies@alaska.gov The information contained in this email message is confidential and may be legally privileged and is intended only for the use of the individual or entity named above. Ifyou are not an intended recipient or if you have received this message in error, you are hereby notified that any dissemination, distribution, or copy of this email is strictly prohibited. If you have received this email in error, please immediately notify us by return email or telephone if the sender's phone number is listed above, then promptlyand permanently delete this message. While all reasonable care has been taken to avoid the transmission of viruses, it is the responsibility of the recipient to ensure that the onward transmission, opening, oruse of this message and any attachments will not adversely affect its systems or data. No responsibility is accepted by the company in this regard and the recipientshould carry out such virus and other checks as it considers appropriate. Department of Natural Resources DIVISION OF OIL AND GAS 550 West 7“' Avenue, Suite 1100 Anchorage, AK 99501-3560 Main: 907-269-8800 Fax: 907-269-8939 THE STATE ^ "'ALASKAm Governor Mike Dunleavy June 11,2024 Jamie Wilson Senior Landman Hilcorp Alaska, LLC 3800 Centerpoint Dr. Ste 1400 Anchorage, Alaska 99503 Re: ADL 421155 Extension of Moose Pad Wellbore Easement Pursuant to AS 38.05.850 Dear Ms. Wilson: On Tuesday May 28, 2024, Hilcorp Alaska, LLC (HAK) submitted a request to the State of Alaska, Department of Natural Resources (DNR), Division of Oil and Gas (Division) to extend the entry authorization for ADL 421155 in the North Slope region. The easement covers wellbores that originate in the Milne Point Unit (MPU), pass through land located outside of the MPU, and return to lands located within the MPU. The term of the easement is June 11, 2019, to June 11, 2054, conditioned upon meeting the terms of the entry authorization. The entry authorization was issued on June 12, 2019, and expires June 12, 2024. The total area of the easement is 240 acres. The Division finds that an extension of the existing entry authorization is necessary, to allow time for completion of the wellbores and a final survey to be provided to the Division. This extension will ensure the authorization remains effective until the Division has all the information required to evaluate the survey, and to complete the necessary administrative actions and process associated with a final easement. This extension constitutes a minor change to the existing entry authorization and does not expand the scope, nor does it constitute a new or expanded interest in state land. The entry authorization for this project is hereby extended until the issuance of a final easement, or for a period of up to five (5) years expiring June 12, 2029, whichever occurs first. The easement remains subject to the terms and conditions defined in the entry authorization granted on June 12, 2019. A final easement agreement for the wellbores will be issued upon completion of the necessary administrative and public processes for easement authorizations pmsuant to AS 38.05.850. If you have questions regarding this authorization, please contact Alexander Zinck at (907) 269-8804 or alexander.zinck@alaska.gov. Sincerel' Cf(l( DateGrajaam Smith / Petroleum Land Manager, Division of Oil and Gas 15 We are now accepting payments online for case agreements and mining claims bills! To make a payment by credit card or from your bank account, click here. Online Public Notices Results - Case File Abstract Summary Customer: 000053766 HILCORP ALASKA, LLC 3800 CENTERPOINT DRIVE SUITE 1400 ANCHORAGE AK 99503 Case Type: 582 PRIVATE EASEMENT DNR Unit: 780 OIL AND GAS File Location: DOG DIV OIL AND GAS Case Status: 21 INTERIM AUTHORIZATON Status Date: 06/12/2019 Total Acres: 240.000 Date Initiated: 04/10/2019 Office of Primary Responsibility: DOG DIV OIL AND GAS Last Transaction Date: 12/19/2022 Case Subtype: 8707 EXCLUSIVE ROW Last Transaction: FILE SEE OTHER ASSOCIATED FILE Land Records Meridian: U Township: 013N Range: 009E Section: 11 Section Acres: 240 Case Actions Legal Description File: ADL 421155 04-10-2019 APPLICATION RECEIVED FEE PD?:Y YES FEE AMOUNT:1200 APPLICATION RECEIVED FOR SUBSURFACE EASEMENT TO ALLOW WELLBORES DRILLED FROM MOOSE PAD IN MPU TO CROSS IN TO KRU. 04-19-2019 PUBLIC NOTICE SENT COMMENTS DUE:05-19-2019 NO COMMENTS WERE RECEIVED 06-11-2019 DIRECTOR'S DECISION DATE OF DECISION:06-11-2019 06-12-2019 AWARD/NON-OBJECTION/INTERIM AUTHORIZATION EXPIRATION DATE 06-12-2024 STATUS 21 21 INTERIM AUTHORIZATON AWARD TYPE EA ENTRY AUTHORIZATION 12-19-2022 SEE OTHER ASSOCIATED FILE ASSOC FILE TYPE EPF ENGINEERNG PLAT FILE ASSOC FILE NUMBER 20210036 MOOSE PAD BORE LINES 12/1/25, 8:34 AM LAS - Alaska Department of Natural Resources Land Administration System https://dnr.alaska.gov/projects/las/#filetype/ADL/filenumber/421155/landflag/y/searchtype/casefile/reporttype/abstract 1/2 LEGAL DESCRIPTION HAS BEEN ADDED TO XML DATABASE TO ACCESS THIS LEGAL DESCRIPTION, GO TO HTTP://WWW.DNR.STATE.AK.US/INT/LAS 12/1/25, 8:34 AM LAS - Alaska Department of Natural Resources Land Administration System https://dnr.alaska.gov/projects/las/#filetype/ADL/filenumber/421155/landflag/y/searchtype/casefile/reporttype/abstract 2/2 14 CAUTION: External sender. DO NOT open links or attachments from UNKNOWN senders. From:Aaron O"Quinn To:King, Ryan C; Coldiron, Samantha J (OGC) Cc:Parker, Jason C; Evans, John R (LDZX); Jamie Wilson; Nottingham, Derek W (DNR); William Neely; Hobie Temple Subject:Re: [EXTERNAL] RE: [EXTERNAL]RE: Request for Hearing on Docket No. CO-25-013 Date:Wednesday, July 30, 2025 9:11:39 AM Attachments:image001.png Outlook-0kxbbx2p.png Samantha, Am confirming Hilcorp's concurrence with these conditions. Thank you, Aaron Aaron O’Quinn · Land Manager · Hilcorp Alaska, LLC O: 907.564.4388 · C: 907.615.9866 aaron.oquinn@hilcorp.com 3800 Centerpoint Drive · Suite 1400 · Anchorage · Alaska · 99503 From: King, Ryan C <Ryan.C.King@conocophillips.com> Sent: Tuesday, July 29, 2025 3:48 PM To: Coldiron, Samantha J (OGC) <samantha.coldiron@alaska.gov> Cc: Parker, Jason C <Jason.C.Parker@conocophillips.com>; Evans, John R (LDZX) <John.R.Evans@conocophillips.com>; Aaron O'Quinn <aaron.oquinn@hilcorp.com>; Jamie Wilson <jamie.wilson@hilcorp.com>; derek.nottingham@alaska.gov <derek.nottingham@alaska.gov> Subject: [EXTERNAL] RE: [EXTERNAL]RE: Request for Hearing on Docket No. CO-25-013 Good afternoon, Samantha, We have agreed to the following conditions with Hilcorp that we would like the AOGCC to include in the order: Injection pressure gradients not to exceed 0.65 psi/ft; No gas injection; Pre-production of the Well not to exceed 60 days; and Downhole pressure gauge data for the Well provided to CPAI upon written request, or as reasonably necessary. Injection only (cannot be converted to a producer). Hilcorp will not penetrate the N-sand interval, as seen at 3,552’ MD in the West Sak No. 1 well, on ADL 355023. Hilcorp’s plans to backbuild its MPU M-65 into CPAI’s ADL 355023 under their Wellbore Easement with the DNR will impair CPAI’s ability to fully develop its leasehold unless Hilcorp stays out of the N-sand as laid out above. Respectfully, Ryan O: 907-265-6106 C: 281-813-6847 ryan.c.king@conocophillips.com From: Coldiron, Samantha J (OGC) <samantha.coldiron@alaska.gov> Sent: Monday, July 28, 2025 1:48 PM To: King, Ryan C <Ryan.C.King@conocophillips.com> Cc: Parker, Jason C <Jason.C.Parker@conocophillips.com>; Evans, John R (LDZX) <John.R.Evans@conocophillips.com>; aaron.oquinn@hilcorp.com; jamie.wilson@hilcorp.com Subject: [EXTERNAL]RE: Request for Hearing on Docket No. CO-25-013 CAUTION:This email originated from outside of the organization. Do not click links or open attachments unless you recognize the sender and know the content is safe. Hi Ryan, Has an agreement between Hilcorp and CPAI been reached? Regards, Samantha Coldiron AOGCC Special Assistant (907) 793-1223 From: King, Ryan C <Ryan.C.King@conocophillips.com> Sent: Tuesday, July 15, 2025 2:51 PM To: Coldiron, Samantha J (OGC) <samantha.coldiron@alaska.gov> Cc: Coldiron, Samantha J (OGC) <samantha.coldiron@alaska.gov>; Nottingham, Derek W (DNR) <derek.nottingham@alaska.gov>; Parker, Jason C <Jason.C.Parker@conocophillips.com>; Evans, John R (LDZX) <John.R.Evans@conocophillips.com>; aaron.oquinn@hilcorp.com; jamie.wilson@hilcorp.com Subject: Request for Hearing on Docket No. CO-25-013 CAUTION: This email originated from outside the State of Alaska mail system. Do not click links or open attachments unless you recognize the sender and know the content is safe. Good afternoon, Samantha, On behalf of ConocoPhillips Alaska, Inc., I hereby submit this Request for Hearing regarding Docket Number CO-25-013. We are in discussions with Hilcorp and hope to come to an agreement in a timely manner that allows us to withdraw this request. However, in the event we are unable to come to an agreement timely, we wish for AOGCC to hold this scheduled hearing. Should you have any questions, please do not hesitate to contact me. Respectfully, Ryan C. King, CPL | Land & Business Development | ConocoPhillips Alaska, Inc. O: 907-265-6106| C: 281-813-6847 | 700 G Street, Anchorage, AK 99501 The information contained in this email message is confidential and may be legally privileged and is intended only for the use of the individual or entity named above. If you are not an intended recipient or if you have received this message in error, you are hereby notified that any dissemination, distribution, or copy of this email is strictly prohibited. If you have received this email in error, please immediately notify us by return email or telephone if the sender's phone number is listed above, then promptly and permanently deletethis message. While all reasonable care has been taken to avoid the transmission of viruses, it is the responsibility of the recipient to ensure that theonward transmission, opening, or use of this message and any attachments will not adversely affect its systems or data. No responsibilityis accepted by the company in this regard and the recipient should carry out such virus and other checks as it considers appropriate. 13 CAUTION: This email originated from outside the State of Alaska mail system. Do not click links or open attachments unless you recognize the sender and know the content is safe. From:Jamie Wilson To:Davies, Stephen F (OGC); Katharine Cunha; Taylor Wellman Cc:Aaron O"Quinn; Roby, David S (OGC) Subject:RE: [EXTERNAL] Spacing Exception Application for MPU H-41 and MPU H-43 - Question Date:Thursday, July 17, 2025 1:14:20 PM Attachments:image001.png Milne Point H-41 and H-43 Spacing Exception_3.3.25_eSIG.pdf Steve, I think I misunderstood what you were asking. The Exhibit A-1 on our application includes details to the sands we are targeting in the Schrader Bluff for each well (application re-attached for reference). However, we just realized that the H-43 is missing language stating the “Toe of the well will be completed in the Schrader Oa”. The H-43 is planned to be drilled similarly to H-41 with the first 2/3 in the Schrader Nb and the last 1/3 in the Schrader Oa. Would we be able to set up a call to discuss how to handle this clarification on our application? We don’t have plans to drill either of these wells until Q1-2026. Here is what it should say on Exhibit A-1 for the H-41 and H-43: Thanks, Jamie From: Jamie Wilson jamie.wilson@hilcorp.com Sent: Thursday, July 17, 2025 12:28 PM To: Davies, Stephen F (OGC) steve.davies@alaska.gov; Katharine Cunha Katharine.Cunha@hilcorp.com; Taylor Wellman twellman@hilcorp.com CAUTION: External sender. DO NOT open links or attachments from UNKNOWN senders. Cc: Aaron O'Quinn Aaron.Oquinn@hilcorp.com Subject: RE: [EXTERNAL] Spacing Exception Application for MPU H-41 and MPU H-43 - Question Steve, We are only seeking Spacing Exception approval on the MPU H-41 and 43 injectors which will be flowing back from the Schrader Bluff formation for up to 60 days. We made reference to the MPU H- 42 producer on the application just so you are aware we will be drilling a producer in between both injectors. However, the MPU H-42 producer is not part of our application requesting spacing exception approval since it is greater than 500’ from the unit boundary. Let me know if this answers your question. I do want to note that the first well in this batch of spacing exception requests to be drilled is the MPU H-21 beginning as soon as the end of this month (Taylor – please correct me if this timeline has moved up), so we ask that this well take precedent over the other applications. The next well to be drilled is the H-31 which we are requesting an extension to the previously approved spacing exception. Thanks, Jamie From: Davies, Stephen F (OGC) <steve.davies@alaska.gov> Sent: Thursday, July 17, 2025 11:24 AM To: Katie.cunha@hilcorp.com; Jamie Wilson <jamie.wilson@hilcorp.com> Subject: [EXTERNAL] Spacing Exception Application for MPU H-41 and MPU H-43 - Question Katie, Jamie: I’m reviewing Hilcorp’s spacing exception application for these wells. To make certain my understanding is correct, which Schrader Bluff reservoir sands will be opened by the planned MPU H-43 injector and the associated MPU H-42 producer? Thanks and Be Well, Steve Davies Senior Petroleum Geologist AOGCC CONFIDENTIALITY NOTICE: This e-mail message, including any attachments, contains information from the Alaska Oil and Gas Conservation Commission (AOGCC), State of Alaska and is for the sole use of the intended recipient(s). It may contain confidential and/or privileged information. The unauthorized review, use or disclosure of such information may violate state or federal law. If you are an unintended recipient of this e-mail, please delete it, without first saving or forwarding it, and, so that the AOGCC is aware of the mistake in sending it to you, contact Steve Davies at 907-793-1224 or steve.davies@alaska.gov The information contained in this email message is confidential and may be legally privileged and is intended only for the use of theindividual or entity named above. If you are not an intended recipient or if you have received this message in error, you are herebynotified that any dissemination, distribution, or copy of this email is strictly prohibited. If you have received this email in error, pleaseimmediately notify us by return email or telephone if the sender's phone number is listed above, then promptly and permanently deletethis message. While all reasonable care has been taken to avoid the transmission of viruses, it is the responsibility of the recipient to ensure that theonward transmission, opening, or use of this message and any attachments will not adversely affect its systems or data. No responsibilityis accepted by the company in this regard and the recipient should carry out such virus and other checks as it considers appropriate. 12 CAUTION: This email originated from outside the State of Alaska mail system. Do not click links or open attachments unless you recognize the sender and know the content is safe. From:King, Ryan C To:Coldiron, Samantha J (OGC) Cc:Coldiron, Samantha J (OGC); Nottingham, Derek W (DNR); Parker, Jason C; Evans, John R (LDZX); aaron.oquinn@hilcorp.com; jamie.wilson@hilcorp.com Subject:Request for Hearing on Docket No. CO-25-013 Date:Tuesday, July 15, 2025 2:51:19 PM Attachments:image001.png Good afternoon, Samantha, On behalf of ConocoPhillips Alaska, Inc., I hereby submit this Request for Hearing regarding Docket Number CO-25-013. We are in discussions with Hilcorp and hope to come to an agreement in a timely manner that allows us to withdraw this request. However, in the event we are unable to come to an agreement timely, we wish for AOGCC to hold this scheduled hearing. Should you have any questions, please do not hesitate to contact me. Respectfully, Ryan C. King, CPL | Land & Business Development | ConocoPhillips Alaska, Inc. O: 907-265-6106| C: 281-813-6847 | 700 G Street, Anchorage, AK 99501 11 Notice of Public Hearing STATE OF ALASKA ALASKA OIL AND GAS CONSERVATION COMMISSION RE: Docket Number: CO-25-013 Hilcorp Alaska, LLC’s Spacing Exception Application for Well MPU M-65 Milne Point Unit, North Slope Borough, Alaska Hilcorp Alaska, LLC (Hilcorp), by letter dated June 23, 2025, filed an application with the Alaska Oil and Gas Conservation Commission (AOGCC) for an exception to the spacing requirements of 20 AAC 25.055 and Rule 2 of Conservation Order No. 477B to drill, complete, short-term pre- produce (flow back for up to 30 days), and inject into the Milne Point Unit M-65 service well in the Schrader Bluff Oil Pool within 500 feet of the exterior boundary of the Schrader Bluff Oil Pool Affected Area, pursuant to 20 AAC 25.055(d). Surface Location: 363' FNL, 741' FEL, Section 14, T13N, R9E, Umiat Meridian (UM) Target Location (Estimated): 558' FNL, 137’ FWL, Section 14, T13N, R9E, UM Bottom Hole Location: 116' FSL, 94’ FWL, Section 23, T13N, R9E, UM Well spacing regulations protect the oil and gas rights of adjacent leaseholders and landowners and maximize resource recovery by establishing default limits on how close, under the land's surface, oil and gas wells can be to property lines where ownership changes hands. These limits are set forth in a regulation, 20 AAC 25.055. Operators must abide by the default limits unless they apply for, and obtain, an order approving an exception to those limits. Although exceptions to the default limits are not unusual, AOGCC carefully evaluates each application, and typically grants them only when actual geologic conditions demonstrate that the proposed subsurface location of a well is necessary to reach otherwise unreachable oil or gas and that both the rights of adjacent leaseholders and landowners and underground drinking water can be protected. As a general matter, AOGCC does not have extensive authority over surface impacts such as noise, emissions, or construction. This notice does not contain all the information filed by Hilcorp. To obtain more information, contact the AOGCC’s Special Assistant, Samantha Coldiron, at (907) 793-1223 or samantha.coldiron@alaska.gov. The AOGCC has tentatively scheduled a public hearing on this matter for August 7, 2025, at 10:00 a.m. via Microsoft Teams. The hearing, which may be changed to full virtual, if necessary, will be held in the AOGCC hearing room located at 333 West 7th Avenue, Anchorage, AK 99501. The audio call in information is (907) 202 7104 Conference ID: 876 411 274#. Anyone who wishes to participate remotely using MS Teams video conference should contact Ms. Samantha Coldiron at least two business days before the scheduled public hearing to request an invitation for the MS Teams. To request that the tentatively scheduled hearing be held, a written request must be filed with the AOGCC no later than 4:30 p.m. on July 15, 2025. If a request for a hearing is not timely filed, the AOGCC may issue an order without a hearing. To learn if the AOGCC will hold the hearing, call (907) 793-1223 after July 17, 2025. In addition, written comments regarding this application may be submitted to the AOGCC, at 333 West 7th Avenue, Anchorage, AK 99501 or samantha.coldiron@alaska.gov. Comments must be received no later than 4:30 p.m. on August 1, 2025, except that, if a hearing is held, comments must be received no later than the conclusion of the August 7, 2025, hearing. If, because of a disability, special accommodations may be needed to comment or attend the hearing, contact Samantha Coldiron, at (907) 793-1223, no later than July 31, 2025. Jessie L. Chmielowski Gregory C. Wilson Commissioner Commissioner Jessie L. Chmielowski Digitally signed by Jessie L. Chmielowski Date: 2025.06.26 08:33:32 -08'00' Samantha Coldiron Digitally signed by Samantha Coldiron Date: 2025.06.26 08:40:39 -08'00' FOR GCW From:Coldiron, Samantha J (OGC) To:AOGCC_Public_Notices Subject:[AOGCC_Public_Notices] Public Hearing Notice (Hilcorp) Date:Thursday, June 26, 2025 8:52:12 AM Attachments:CO-25-013 Public Hearing Notice Hilcorp MPU M-65 Spacing Exception.pdf Docket Number: CO-25-013 Hilcorp Alaska, LLC’s Spacing Exception Application for Well MPU M-65 Milne Point Unit, North Slope Borough, Alaska Samantha Coldiron AOGCC Special Assistant Alaska Oil and Gas Conservation Commission 333 West 7th Avenue Anchorage, AK 99501 (907) 793-1223 __________________________________ List Name: AOGCC_Public_Notices@list.state.ak.us You subscribed as: samantha.coldiron@alaska.gov Unsubscribe at: https://list.state.ak.us/mailman/options/aogcc_public_notices/samantha.coldiron%40alaska.go v Lisi Misa being first duly sworn on oath deposes and says that she is a representative of the An- chorage Daily News, a daily newspaper. That said newspaper has been approved by the Third Judicial Court, Anchorage, Alaska, and it now and has been published in the English language continually as a daily newspaper in Anchorage, Alaska, and it is now and during all said time was printed in an office maintained at the afore- said place of publication of said newspaper. That the annexed is a copy of an advertisement as it was published in regular issues (and not in supplemental form) of said newspaper on AFFIDAVIT OF PUBLICATION ______________________________________ Notary Public in and for The State of Alaska. Third Division Anchorage, Alaska MY COMMISSION EXPIRES ______________________________________ 06/29/2025 and that such newspaper was regularly distrib- uted to its subscribers during all of said period. That the full amount of the fee charged for the foregoing publication is not in excess of the rate charged private individuals. Signed________________________________ Subscribed and sworn to before me Account #: 100869 ST OF AK/AK OIL AND GAS CONSERVATION COMMISSION333 W. 7TH AVE STE 100, ANCHORAGE, AK 99501 Order #: W0053549 Cost: $435.49 Notice of Public HearingSTATE OF ALASKAALASKA OIL AND GAS CONSERVATION COMMISSION RE: Docket Number: CO-25-013 Hilcorp Alaska, LLC’s Spacing Exception Application for Well MPU M-65Milne Point Unit, North Slope Borough, Alaska Hilcorp Alaska, LLC (Hilcorp), by letter dated June 23, 2025, filed an application with the Alaska Oil and Gas Conservation Commission (AOGCC) for an exception to the spacing requirements of 20 AAC 25.055 and Rule 2 of Conservation Order No. 477B to drill, complete, short-term pre-produce (flow back for up to 30 days), and inject into the Milne Point Unit M-65 service well in the Schrader Bluff Oil Pool within 500 feet of the exterior boundary of the Schrader Bluff Oil Pool Affected Area, pursuant to 20 AAC 25.055(d). Surface Location: 363’ FNL, 741’ FEL, Section 14, T13N, R9E, Umiat Meridian (UM)Target Location (Estimated): 558’ FNL, 137’ FWL, Section 14, T13N, R9E, UMBottom Hole Location: 116’ FSL, 94’ FWL, Section 23, T13N, R9E, UM Well spacing regulations protect the oil and gas rights of adjacent leaseholders and landowners and maximize resource recovery by establishing default limits on how close, under the land’s surface, oil and gas wells can be to property lines where ownership changes hands. These limits are set forth in a regulation, 20 AAC 25.055. Operators must abide by the default limits unless they apply for, and obtain, an order approving an exception to those limits. Although exceptions to the default limits are not unusual, AOGCC carefully evaluates each application, and typically grants them only when actual geologic conditions demonstrate that the proposed subsurface location of a well is necessary to reach otherwise unreachable oil or gas and that both the rights of adjacent leaseholders and landowners and underground drinking water can be protected. As a general matter, AOGCC does not have extensive authority over surface impacts such as noise, emissions, or construction. This notice does not contain all the information filed by Hilcorp. To obtain more information, contact the AOGCC’s Special Assistant, Samantha Coldiron, at (907) 793-1223 or samantha.coldiron@alaska.gov. The AOGCC has tentatively scheduled a public hearing on this matter for August 7, 2025, at 10:00 a.m. via Microsoft Teams. The hearing, which may be changed to full virtual, if necessary, will be held in the AOGCC hearing room located at 333 West 7th Avenue, Anchorage, AK 99501. The audio call in information is (907) 202 7104 Conference ID: 876 411 274#. Anyone who wishes to participate remotely using MS Teams video conference should contact Ms. Samantha Coldiron at least two business days before the scheduled public hearing to request an invitation for the MS Teams. To request that the tentatively scheduled hearing be held, a written request must be filed with the AOGCC no later than 4:30 p.m. on July 15, 2025. If a request for a hearing is not timely filed, the AOGCC may issue an order without a hearing. To learn if the AOGCC will hold the hearing, call (907) 793-1223 after July 17, 2025. In addition, written comments regarding this application may be submitted to the AOGCC, at 333 West 7th Avenue, Anchorage, AK 99501 or samantha.coldiron@alaska.gov. Comments must be received no later than 4:30 p.m. on August 1, 2025, except that, if a hearing is held, comments must be received no later than the conclusion of the August 7, 2025, hearing. If, because of a disability, special accommodations may be needed to comment or attend the hearing, contact Samantha Coldiron, at (907) 793-1223, no later than July 31, 2025. Jessie L. Chmielowski Gregory C. WilsonCommissioner Commissioner Pub: June 29, 2025 STATE OF ALASKA THIRD JUDICIAL DISTRICT ______________________________________2025-07-02 2029-01-23 Document Ref: EHC6J-BUCEX-CT4UZ-EEWJR Page 8 of 42 10 June 18, 2025 Jessie Chmielowski, Commissioner Alaska Oil and Gas Conservation Commission 333 West 7th Avenue, Suite 100 Anchorage, Alaska 99501 RE: Application for Spacing Exception Milne Point Unit M-65 Injector Well Commissioner Chmielowski: Hilcorp Alaska, LLC (“Hilcorp”), as Operator of the Milne Point Unit, hereby submits this application for spacing exception to drill the Milne Point Unit M-65 injection well (“M-65 Well”)in the Schrader Bluff Oil Pool. The proposed productive interval and location for the proposed drill operations are listed below and further depicted on the attached Exhibit “A” Surface Location: x State Lease ADL 25514 x 363’ FNL, 741’ FEL x Section 14, T13N-R9E, UM Top of the Producing Interval: x State Lease ADL 25514 x 558’ FNL, 137’ FWL x Section 14, T13N-R9E, UM Bottom Hole Location: x State Lease ADL 25514 x 116’ FSL, 94’ FWL x Section 23, T13N-R9E, UM Hilcorp submits this application to ensure compliance with 20 AAC 25.055(a)(1), which states “for a well drilling for oil, a wellbore may be open to test or regular production1 within 500 feet of a property line only if the owner is the same and the landowner is the same on both sides of the line.” 1 AS 31.05.170(14) “regular production” means continuing production of oil or gas from a well into production facilities and transportation to market, but does not include short term testing, evaluation, or experimental pilot production activities that have been approved by permit or order of the commission.” PO Box 244027 Anchorage, AK 99524-4027 3800 Centerpoint Drive, STE 1400 Anchorage, AK 99503 Phone: (907) 777-8341 Fax: (907) 777-8301 Email: jamie.wilson@hilcorp.com By Samantha Coldiron at 7:14 am, Jun 23, 2025 Hilcorp Alaska, LLC Spacing Exception Milne Point Unit M-65 Well June 18, 2025 Page 2 of 6 The M-65 Well will be an injection well. In order to achieve maximum injectivity of the wellbore, Hilcorp intends to flow back this well for up to 30 days to fully clean out the wellbore to reduce the effect of near-wellbore damage caused by drilling fluid invasion which will ensure maximum injectivity. The initial flowback will consist mostly of drilling and completion fluids, including cuttings and other fine materials that will be flowed to tanks, transported offsite and disposed of in accordance with State regulations. Once the flowback has less than 0.5% solids, the flow stream will be sent to the Milne Point production facility to continue cleaning up. In order to prevent waste, Hilcorp intends to sell any oil processed and separated at the production facility. Hilcorp is not proposing to drill and complete this well as a producing oil well. Associated oil will only be “produced” for 30 days to ensure the wellbore is as clean as possible before commencing injection operations. The intent of this application is to allow Hilcorp to prevent waste that may occur as a result of its cleanup process by: 1. Ensuring a clean wellbore to achieve maximum injectivity. 2. Enhancing recovery of the offset production well which will be spaced between each injection well. 3. Avoid disposal of sales quality oil. Additionally, well spacing within the Schrader Bluff Oil Pool is governed by Rule 2 of Conservation Order 477b: Rule 2. Well Spacing (Revised by CO 477.005, CO 477A.001, CO 477A.002, CO 477A.003, CO 477A.009, CO 806) There are no restrictions as to well spacing except that no pay shall be opened in a well closer than 500 feet from the exterior boundary of the affected area. The proposed M-65 Well operations target undrained reserves that cannot be reached by wells conforming to applicable spacing restrictions. Approval of short-term pre-production of the proposed M-65 Well allows for protection of its correlative rights by recovering the otherwise stranded reserves and ensures future maximum injectivity of the wellbore. Additionally, the correlative rights of all affected owners, landowners and operators will be protected and enhanced by the long-term support provided by the polymer injection. Hilcorp anticipates drilling operations of the M-65 Well to commence as soon as January 2026. This well is subject to Wellbore Easement ADL 421155 whereby the Alaska Department of Natural Resources, Division of Oil and Gas, granted Hilcorp approval to traverse through the Kuparuk River Unit. There will be no open casing from within the Kuparuk River Unit. Hilcorp Alaska, LLC Spacing Exception Milne Point Unit M-65 Well June 18, 2025 Page 3 of 6 As of the date of delivery of this application, and in accordance with 20 AAC 25.055(d)(1), notice of Hilcorp’s intent to drill the M-65 Well has been sent by certified mail to those certain owners, landowners, and operators of property within 1,000 feet of the well listed in Exhibit “B”. A copy of the notice and corresponding certified mailing receipts have been attached to this application. Pursuant to 20 AAC 25.055(d)(3), and attached as Exhibit “C”, is an affidavit executed by a person acquainted with all pertinent facts of this application and verifying that all facts set forth herein are true. It is requested that the Commission approve, by Administrative Approval, pursuant to 20 AAC 25.556(d), an exception to the well spacing for drilling the M-65 Well. If you require additional information or would like to have a technical meeting regarding this application, please contact Will Neely, Geologist, at (907) 564-5082, or me at (907) 777-8341 or by email at jamie.wilson@hilcorp.com. Sincerely, Jamie Wilson Sr. Landman Hilcorp Alaska, LLC cc: Ashley Ethridge, Unit Manager, Division of Oil and Gas (via email) Derek Nottingham, Director, Division of Oil and Gas (via email) Samantha Coldiron, Assistant, AOGCC (via email) Attachments: Exhibit “A”Map of Spacing Exception Well Exhibit “B”Notice List Exhibit “C”Affidavit Digitally signed by Jamie Wilson (2170) DN: cn=Jamie Wilson (2170) Date: 2025.06.18 13:35:22 - 08'00' Jamie Wilson (2170) Hilcorp Alaska, LLC Spacing Exception Milne Point Unit M-65 Well June 18, 2025 Page 4 of 6 EXHIBIT “A” APPLICATION FOR SPACING EXCEPTION Milne Point Unit M-65 Well (Injector) Hilcorp Alaska, LLC Spacing Exception Milne Point Unit M-65 Well June 18, 2025 Page 5 of 6 EXHIBIT “B” APPLICATION FOR SPACING EXCEPTION Milne Point Unit M-65 Well (Injector) Notice List Unit/Lease Landowner Owner Operator Kuparuk River Unit - ADL 355023 - ADL 025513 - ADL 025520 - ADL 025519 Department of Natural Resources Division of Oil & Gas 550 W. 7th Avenue, Ste. 1100 Anchorage, AK 99501-3560 Attn: Derek Nottingham, Director ConocoPhillips Alaska, Inc ATTN: Ryan King 700 G Street Anchorage, Alaska 99501 ConocoPhillips Alaska II, Inc ATTN: Ryan King 700 G Street Anchorage, Alaska 99501 ExxonMobil Alaska Production Inc. Attn: Justin Shuff 22777 Springwoods Village Pkwy Spring, Texas 77389 ConocoPhillips Alaska, Inc ATTN: Ryan King 700 G Street Anchorage, Alaska 99501 1 Jamie Wilson From:AnchorageMail Sent:Wednesday, June 18, 2025 3:47 PM To:Jamie Wilson Subject:Certified Tracking Hello Jamie, Here is your certified tracking #9489 0178 9820 3021 0094 91 #9489 0178 9820 3021 0825 31#9489 0178 9820 3021 0825 24 #9489 0178 9820 3021 0825 17. Please click the link below and enter your email to receive your E- Return Receipt, once package has been delivered. https://tools.usps.com/go/TrackConfirmAction_input Thank you. June 18, 2025 ConocoPhillips Alaska, Inc ATTN: Ryan King 700 G Street Anchorage, Alaska 99501 RE: Notice of Applications for Spacing Exception Milne Point Unit M-65 Injector Well Mr. King: Hilcorp Alaska, LLC (“Hilcorp”), as Operator of the Milne Point Unit, will be submitting to the Alaska Oil and Gas Conservation Commission (“AOGCC”) the enclosed Application for Spacing Exception to drill the above referenced well in the Schrader Bluff Oil Pool. Please note this well is subject to Wellbore Easement ADL 421155 whereby Hilcorp has approval to traverse through the Kuparuk River Unit. There will be no open casing from within the Kuparuk River Unit. Pursuant to 20 AAC 25.055(d)(1), all owners, landowners, and operators of all properties within 1,000 feet of a well drilling for oil for which an exception is sought must receive notice of such exception application. As an owner of certain property located within 1,000 feet of Hilcorp’s proposed well depicted on Exhibit “A”, please allow for this letter to serve as notice of Hilcorp’s intent to submit an Application for a Spacing Exception for the proposed operation, and its request for Administrative Approval from AOGCC. Should you require additional information regarding this application, please contact me by phone at (907) 777-8341 or by email at jamie.wilson@hilcorp.com. Sincerely, Jamie Wilson Sr. Landman Hilcorp Alaska, LLC PO Box 244027 Anchorage, AK 99524-4027 3800 Centerpoint Drive, STE 1400 Anchorage, AK 99503 Phone: (907) 777-8341 Fax: (907) 777-8301 Email: jamie.wilson@hilcorp.com June 18, 2025 ConocoPhillips Alaska II, Inc ATTN: Ryan King 700 G Street Anchorage, Alaska 99501 RE: Notice of Applications for Spacing Exception Milne Point Unit M-65 Injector Well Mr. King: Hilcorp Alaska, LLC (“Hilcorp”), as Operator of the Milne Point Unit, will be submitting to the Alaska Oil and Gas Conservation Commission (“AOGCC”) the enclosed Application for Spacing Exception to drill the above referenced well in the Schrader Bluff Oil Pool. Please note this well is subject to Wellbore Easement ADL 421155 whereby Hilcorp has approval to traverse through the Kuparuk River Unit. There will be no open casing from within the Kuparuk River Unit. Pursuant to 20 AAC 25.055(d)(1), all owners, landowners, and operators of all properties within 1,000 feet of a well drilling for oil for which an exception is sought must receive notice of such exception application. As an owner of certain property located within 1,000 feet of Hilcorp’s proposed well depicted on Exhibit “A”, please allow for this letter to serve as notice of Hilcorp’s intent to submit an Application for a Spacing Exception for the proposed operation, and its request for Administrative Approval from AOGCC. Should you require additional information regarding this application, please contact me by phone at (907) 777-8341 or by email at jamie.wilson@hilcorp.com. Sincerely, Jamie Wilson Sr. Landman Hilcorp Alaska, LLC PO Box 244027 Anchorage, AK 99524-4027 3800 Centerpoint Drive, STE 1400 Anchorage, AK 99503 Phone: (907) 777-8341 Fax: (907) 777-8301 Email: jamie.wilson@hilcorp.com June 18, 2025 ExxonMobil Alaska Production Inc. Attn: Justin Shuff 22777 Springwoods Village Pkwy Spring, Texas 77389 RE: Notice of Applications for Spacing Exception Milne Point Unit M-65 Injector Well Mr. Shuff: Hilcorp Alaska, LLC (“Hilcorp”), as Operator of the Milne Point Unit, will be submitting to the Alaska Oil and Gas Conservation Commission (“AOGCC”) the enclosed Application for Spacing Exception to drill the above referenced well in the Schrader Bluff Oil Pool. Please note this well is subject to Wellbore Easement ADL 421155 whereby Hilcorp has approval to traverse through the Kuparuk River Unit. There will be no open casing from within the Kuparuk River Unit. Pursuant to 20 AAC 25.055(d)(1), all owners, landowners, and operators of all properties within 1,000 feet of a well drilling for oil for which an exception is sought must receive notice of such exception application. As an owner of certain property located within 1,000 feet of Hilcorp’s proposed well depicted on Exhibit “A”, please allow for this letter to serve as notice of Hilcorp’s intent to submit an Application for a Spacing Exception for the proposed operation, and its request for Administrative Approval from AOGCC. Should you require additional information regarding this application, please contact me by phone at (907) 777-8341 or by email at jamie.wilson@hilcorp.com. Sincerely, Jamie Wilson Sr. Landman Hilcorp Alaska, LLC PO Box 244027 Anchorage, AK 99524-4027 3800 Centerpoint Drive, STE 1400 Anchorage, AK 99503 Phone: (907) 777-8341 Fax: (907) 777-8301 Email: jamie.wilson@hilcorp.com June 18, 2025 Department of Natural Resources Division of Oil & Gas 550 W. 7th Avenue, Ste. 1100 Anchorage, AK 99501-3560 Attn: Derek Nottingham, Director RE: Notice of Applications for Spacing Exception Milne Point Unit M-65 Injector Well Dear Mr. Nottingham: Hilcorp Alaska, LLC (Hilcorp), as Operator of the Milne Point Unit, will be submitting to the Alaska Oil and Gas Conservation Commission (AOGCC) the enclosed Application for Spacing Exception to drill the above referenced well in the Schrader Bluff Oil Pool. Please note this well is subject to Wellbore Easement ADL 421155 whereby Hilcorp has approval to traverse through the Kuparuk River Unit. There will be no open casing from within the Kuparuk River Unit. Pursuant to 20 AAC 25.055(d)(1), all owners, landowners, and operators of all properties within 1,000 feet of a well drilling for oil for which an exception is sought must receive notice of such exception application. As an owner of certain property located within 1,000 feet of Hilcorp’s proposed well depicted on Exhibit “A”, please allow for this letter to serve as notice of Hilcorp’s intent to submit an Application for a Spacing Exception for the proposed operation, and its request for Administrative Approval from AOGCC. Should you require additional information regarding this application, please contact me by phone at (907) 777-8341 or by email at jamie.wilson@hilcorp.com. Sincerely, Jamie Wilson Sr. Landman Hilcorp Alaska, LLC PO Box 244027 Anchorage, AK 99524-4027 3800 Centerpoint Drive, STE 1400 Anchorage, AK 99503 Phone: (907) 777-8341 Fax: (907) 777-8301 Email: jamie.wilson@hilcorp.com 9 Notice of Public Hearing STATE OF ALASKA ALASKA OIL AND GAS CONSERVATION COMMISSION RE: Docket Number: CO-25-007 Hilcorp Alaska, LLC’s Spacing Exception Application for Wells MPU H-41 and H-43 Milne Point Unit, North Slope Borough, Alaska Hilcorp Alaska, LLC (Hilcorp), by letter dated March 3, 2025, filed an application with the Alaska Oil and Gas Conservation Commission (AOGCC) for an exception to the spacing requirements of 20 AAC 25.055 and Rule 2 of Conservation Order No. 477A to drill, complete, short-term pre- produce (flow back for up to 60 days), and inject into the Milne Point Unit H-41 and H-43 service wells in the Schrader Bluff Oil Pool within 500 feet of the exterior boundary of the Schrader Bluff Oil Pool Affected Area, pursuant to 20 AAC 25.055(d). MPU H-41 Surface Location: 2,435' FNL, 1,105' FWL, Section 34, T13N, R10E, Umiat Meridian (UM) Target Location: 70' FSL, 2,535’ FWL, Section 33, T13N, R10E, UM Bottom Hole Location: 70' FSL, 70’ FWL, Section 31, T13N, R10E, UM MPU H-43 Surface Location: 2,291' FNL, 1,158' FWL, Section 34, T13N, R10E, UM Target Location: 1,497' FSL, 612’ FWL, Section 33, T13N, R10E, UM Bottom Hole Location: 2,004' FSL, 70’ FWL, Section 31, T13N, R10E, UM Well spacing regulations protect the oil and gas rights of adjacent leaseholders and landowners and maximize resource recovery by establishing default limits on how close, under the land's surface, oil and gas wells can be to property lines where ownership changes hands. These limits are set forth in a regulation, 20 AAC 25.055. Operators must abide by the default limits unless they apply for, and obtain, an order approving an exception to those limits. Although exceptions to the default limits are not unusual, AOGCC carefully evaluates each application, and typically grants them only when actual geologic conditions demonstrate that the proposed subsurface location of a well is necessary to reach otherwise unreachable oil or gas and that both the rights of adjacent leaseholders and landowners and underground drinking water can be protected. As a general matter, AOGCC does not have extensive authority over surface impacts such as noise, emissions, or construction. This notice does not contain all the information filed by Hilcorp. To obtain more information, contact the AOGCC’s Special Assistant, Samantha Coldiron, at (907) 793-1223 or samantha.coldiron@alaska.gov. The AOGCC has tentatively scheduled a public hearing on this matter for May 13, 2025, at 10:00 a.m. via Microsoft Teams. The hearing, which may be changed to full virtual, if necessary, will be held in the AOGCC hearing room located at 333 West 7th Avenue, Anchorage, AK 99501. The audio call in information is (907) 202 7104 Conference ID: 595 741 512# #. Anyone who wishes to participate remotely using MS Teams video conference should contact Ms. Samantha Coldiron at least two business days before the scheduled public hearing to request an invitation for the MS Teams. To request that the tentatively scheduled hearing be held, a written request must be filed with the AOGCC no later than 4:30 p.m. on March 28, 2025. If a request for a hearing is not timely filed, the AOGCC may issue an order without a hearing. To learn if the AOGCC will hold the hearing, call (907) 793-1223 after April 1, 2025. In addition, written comments regarding this application may be submitted to the AOGCC, at 333 West 7th Avenue, Anchorage, AK 99501 or samantha.coldiron@alaska.gov. Comments must be received no later than 4:30 p.m. on April 16, 2025, except that, if a hearing is held, comments must be received no later than the conclusion of the May 13, 2025, hearing. If, because of a disability, special accommodations may be needed to comment or attend the hearing, contact Samantha Coldiron, at (907) 793-1223, no later than May 8, 2025. Jessie L. Chmielowski Gregory C. Wilson Commissioner Commissioner Gregory C. Wilson Digitally signed by Gregory C. Wilson Date: 2025.03.10 12:38:15 -08'00' Jessie L. Chmielowski Digitally signed by Jessie L. Chmielowski Date: 2025.03.10 13:05:45 -08'00' From:Coldiron, Samantha J (OGC) To:AOGCC_Public_Notices Subject:[AOGCC_Public_Notices] Public Hearing Notices (Hilcorp) Date:Monday, March 10, 2025 2:00:21 PM Attachments:CO-25-005 Public Hearing Notice Hilcorp MPU H-21 Spacing Exception.pdf CO-25-006 Public Hearing Notice Hilcorp MPU H-31 Spacing Exception.pdf CO-25-007 Public Hearing Notice Hilcorp MPU H-41 and H-43 Spacing Exception.pdf Docket Number: CO-25-005 Hilcorp Alaska, LLC’s Spacing Exception Application for Well MPU H-21 Milne Point Unit, North Slope Borough, Alaska Docket Number: CO-25-006 Hilcorp Alaska, LLC’s Amended Spacing Exception Application for Well MPU H-31 Milne Point Unit, North Slope Borough, Alaska Docket Number: CO-25-007 Hilcorp Alaska, LLC’s Spacing Exception Application for Wells MPU H-41 and H-43 Milne Point Unit, North Slope Borough, Alaska Samantha Coldiron AOGCC Special Assistant Alaska Oil and Gas Conservation Commission 333 West 7th Avenue Anchorage, AK 99501 (907) 793-1223 __________________________________ List Name: AOGCC_Public_Notices@list.state.ak.us You subscribed as: samantha.coldiron@alaska.gov Unsubscribe at: https://list.state.ak.us/mailman/options/aogcc_public_notices/samantha.coldiron%40alaska.go v Lisi Misa being first duly sworn on oath deposes and says that she is a representative of the An- chorage Daily News, a daily newspaper. That said newspaper has been approved by the Third Judicial Court, Anchorage, Alaska, and it now and has been published in the English language continually as a daily newspaper in Anchorage, Alaska, and it is now and during all said time was printed in an office maintained at the afore- said place of publication of said newspaper. That the annexed is a copy of an advertisement as it was published in regular issues (and not in supplemental form) of said newspaper on AFFIDAVIT OF PUBLICATION ______________________________________ Notary Public in and for The State of Alaska. Third Division Anchorage, Alaska MY COMMISSION EXPIRES ______________________________________ 03/12/2025 and that such newspaper was regularly distrib- uted to its subscribers during all of said period. That the full amount of the fee charged for the foregoing publication is not in excess of the rate charged private individuals. Signed________________________________ Subscribed and sworn to before me Account #: 100869 ST OF AK/AK OIL AND GAS CONSERVATION COMMISSION333 W. 7TH AVE STE 100, ANCHORAGE, AK 99501 Order #: W0051332 Cost: $472.52 Notice of Public HearingSTATE OF ALASKAALASKA OIL AND GAS CONSERVATION COMMISSION RE: Docket Number: CO-25-007Hilcorp Alaska, LLC’s Spacing Exception Application for Wells MPU H-41 and H-43Milne Point Unit, North Slope Borough, Alaska Hilcorp Alaska, LLC (Hilcorp), by letter dated March 3, 2025, filed an application with the Alaska Oil and Gas Conservation Commission (AOGCC) for an exception to the spacing requirements of 20 AAC 25.055 and Rule 2 of Conservation Order No. 477A to drill, complete, short-term pre-produce (flow back for up to 60 days), and inject into the Milne Point Unit H-41 and H-43 service wells in the Schrader Bluff Oil Pool within 500 feet of the exterior boundary of the Schrader Bluff Oil Pool Affected Area, pursuant to 20 AAC 25.055(d). MPU H-41Surface Location: 2,435’ FNL, 1,105’ FWL, Section 34, T13N, R10E, Umiat Meridian (UM)Target Location: 70’ FSL, 2,535’ FWL, Section 33, T13N, R10E, UMBottom Hole Location: 70’ FSL, 70’ FWL, Section 31, T13N, R10E, UM MPU H-43Surface Location: 2,291’ FNL, 1,158’ FWL, Section 34, T13N, R10E, UMTarget Location: 1,497’ FSL, 612’ FWL, Section 33, T13N, R10E, UMBottom Hole Location: 2,004’ FSL, 70’ FWL, Section 31, T13N, R10E, UM Well spacing regulations protect the oil and gas rights of adjacent leaseholders and landowners and maximize resource recovery by establishing default limits on how close, under the land’s surface, oil and gas wells can be to property lines where ownership changes hands. These limits are set forth in a regulation, 20 AAC 25.055. Operators must abide by the default limits unless they apply for, and obtain, an order approving an exception to those limits. Although exceptions to the default limits are not unusual, AOGCC carefully evaluates each application, and typically grants them only when actual geologic conditions demonstrate that the proposed subsurface location of a well is necessary to reach otherwise unreachable oil or gas and that both the rights of adjacent leaseholders and landowners and underground drinking water can be protected. As a general matter, AOGCC does not have extensive authority over surface impacts such as noise, emissions, or construction. This notice does not contain all the information filed by Hilcorp. To obtain more information, contact the AOGCC’s Special Assistant, Samantha Coldiron, at (907) 793-1223 or samantha.coldiron@alaska.gov. The AOGCC has tentatively scheduled a public hearing on this matter for May 13, 2025, at 10:00 a.m. via Microsoft Teams. The hearing, which may be changed to full virtual, if necessary, will be held in the AOGCC hearing room located at 333 West 7th Avenue, Anchorage, AK 99501. The audio call in information is (907) 202 7104 Conference ID: 595 741 512# #. Anyone who wishes to participate remotely using MS Teams video conference should contact Ms. Samantha Coldiron at least two business days before the scheduled public hearing to request an invitation for the MS Teams. To request that the tentatively scheduled hearing be held, a written request must be filed with the AOGCC no later than 4:30 p.m. on March 28, 2025. If a request for a hearing is not timely filed, the AOGCC may issue an order without a hearing. To learn if the AOGCC will hold the hearing, call (907) 793-1223 after April 1, 2025. In addition, written comments regarding this application may be submitted to the AOGCC, at 333 West 7th Avenue, Anchorage, AK 99501 or samantha.coldiron@alaska.gov. Comments must be received no later than 4:30 p.m. on April 16, 2025, except that, if a hearing is held, comments must be received no later than the conclusion of the May 13, 2025, hearing. If, because of a disability, special accommodations may be needed to comment or attend the hearing, contact Samantha Coldiron, at (907) 793-1223, no later than May 8, 2025. Jessie L. Chmielowski Gregory C. WilsonCommissioner Commissioner Pub: Mar. 12, 2025 STATE OF ALASKA THIRD JUDICIAL DISTRICT ______________________________________2025-03-13 2028-07-14 Document Ref: ITNUX-TDPV5-TLRHK-GXTIJ Page 7 of 12 8 Notice of Public Hearing STATE OF ALASKA ALASKA OIL AND GAS CONSERVATION COMMISSION RE: Docket Number: CO-25-006 Hilcorp Alaska, LLC’s Amended Spacing Exception Application for Well MPU H-31 Milne Point Unit, North Slope Borough, Alaska Hilcorp Alaska, LLC (Hilcorp), by letter dated March 3, 2025, filed an amended application with the Alaska Oil and Gas Conservation Commission (AOGCC) for an exception to the spacing requirements of 20 AAC 25.055 and Rule 2 of Conservation Order No. 477A to drill, complete, short-term pre-produce (flow back for up to 60 days), and inject into the Milne Point Unit H-31 service well in the Schrader Bluff Oil Pool within 500 feet of the exterior boundary of the Schrader Bluff Oil Pool Affected Area, pursuant to 20 AAC 25.055(d). Surface Location: 2,223' FNL, 1,293' FWL, Section 34, T13N, R10E, Umiat Meridian (UM) Target Location (Revised): 70' FSL, 682’ FEL, Section 34, T13N, R10E, UM Bottom Hole Location (Revised): 70' FSL, 570’ FWL, Section 31, T13N, R10E, UM Well spacing regulations protect the oil and gas rights of adjacent leaseholders and landowners and maximize resource recovery by establishing default limits on how close, under the land's surface, oil and gas wells can be to property lines where ownership changes hands. These limits are set forth in a regulation, 20 AAC 25.055. Operators must abide by the default limits unless they apply for, and obtain, an order approving an exception to those limits. Although exceptions to the default limits are not unusual, AOGCC carefully evaluates each application, and typically grants them only when actual geologic conditions demonstrate that the proposed subsurface location of a well is necessary to reach otherwise unreachable oil or gas and that both the rights of adjacent leaseholders and landowners and underground drinking water can be protected. As a general matter, AOGCC does not have extensive authority over surface impacts such as noise, emissions, or construction. This notice does not contain all the information filed by Hilcorp. To obtain more information, contact the AOGCC’s Special Assistant, Samantha Coldiron, at (907) 793-1223 or samantha.coldiron@alaska.gov. The AOGCC has tentatively scheduled a public hearing on this matter for May 13, 2025, at 10:00 a.m. via Microsoft Teams. The hearing, which may be changed to full virtual, if necessary, will be held in the AOGCC hearing room located at 333 West 7th Avenue, Anchorage, AK 99501. The audio call in information is (907) 202 7104 Conference ID: 595 741 512# #. Anyone who wishes to participate remotely using MS Teams video conference should contact Ms. Samantha Coldiron at least two business days before the scheduled public hearing to request an invitation for the MS Teams. To request that the tentatively scheduled hearing be held, a written request must be filed with the AOGCC no later than 4:30 p.m. on March 28, 2025. If a request for a hearing is not timely filed, the AOGCC may issue an order without a hearing. To learn if the AOGCC will hold the hearing, call (907) 793-1223 after April 1, 2025. In addition, written comments regarding this application may be submitted to the AOGCC, at 333 West 7th Avenue, Anchorage, AK 99501 or samantha.coldiron@alaska.gov. Comments must be received no later than 4:30 p.m. on April 16, 2025, except that, if a hearing is held, comments must be received no later than the conclusion of the May 13, 2025, hearing. If, because of a disability, special accommodations may be needed to comment or attend the hearing, contact Samantha Coldiron, at (907) 793-1223, no later than May 8, 2025. Jessie L. Chmielowski Gregory C. Wilson Commissioner Commissioner Gregory C. Wilson Digitally signed by Gregory C. Wilson Date: 2025.03.10 12:39:40 -08'00' Jessie L. Chmielowski Digitally signed by Jessie L. Chmielowski Date: 2025.03.10 13:06:00 -08'00' From:Coldiron, Samantha J (OGC) To:AOGCC_Public_Notices Subject:[AOGCC_Public_Notices] Public Hearing Notices (Hilcorp) Date:Monday, March 10, 2025 2:00:21 PM Attachments:CO-25-005 Public Hearing Notice Hilcorp MPU H-21 Spacing Exception.pdf CO-25-006 Public Hearing Notice Hilcorp MPU H-31 Spacing Exception.pdf CO-25-007 Public Hearing Notice Hilcorp MPU H-41 and H-43 Spacing Exception.pdf Docket Number: CO-25-005 Hilcorp Alaska, LLC’s Spacing Exception Application for Well MPU H-21 Milne Point Unit, North Slope Borough, Alaska Docket Number: CO-25-006 Hilcorp Alaska, LLC’s Amended Spacing Exception Application for Well MPU H-31 Milne Point Unit, North Slope Borough, Alaska Docket Number: CO-25-007 Hilcorp Alaska, LLC’s Spacing Exception Application for Wells MPU H-41 and H-43 Milne Point Unit, North Slope Borough, Alaska Samantha Coldiron AOGCC Special Assistant Alaska Oil and Gas Conservation Commission 333 West 7th Avenue Anchorage, AK 99501 (907) 793-1223 __________________________________ List Name: AOGCC_Public_Notices@list.state.ak.us You subscribed as: samantha.coldiron@alaska.gov Unsubscribe at: https://list.state.ak.us/mailman/options/aogcc_public_notices/samantha.coldiron%40alaska.go v Lisi Misa being first duly sworn on oath deposes and says that she is a representative of the An- chorage Daily News, a daily newspaper. That said newspaper has been approved by the Third Judicial Court, Anchorage, Alaska, and it now and has been published in the English language continually as a daily newspaper in Anchorage, Alaska, and it is now and during all said time was printed in an office maintained at the afore- said place of publication of said newspaper. That the annexed is a copy of an advertisement as it was published in regular issues (and not in supplemental form) of said newspaper on AFFIDAVIT OF PUBLICATION ______________________________________ Notary Public in and for The State of Alaska. Third Division Anchorage, Alaska MY COMMISSION EXPIRES ______________________________________ 03/12/2025 and that such newspaper was regularly distrib- uted to its subscribers during all of said period. That the full amount of the fee charged for the foregoing publication is not in excess of the rate charged private individuals. Signed________________________________ Subscribed and sworn to before me Account #: 100869 ST OF AK/AK OIL AND GAS CONSERVATION COMMISSION333 W. 7TH AVE STE 100, ANCHORAGE, AK 99501 Order #: W0051330 Cost: $435.75 Notice of Public HearingSTATE OF ALASKAALASKA OIL AND GAS CONSERVATION COMMISSION RE: Docket Number: CO-25-006Hilcorp Alaska, LLC’s Amended Spacing Exception Application for Well MPU H-31Milne Point Unit, North Slope Borough, Alaska Hilcorp Alaska, LLC (Hilcorp), by letter dated March 3, 2025, filed an amended application with the Alaska Oil and Gas Conservation Commission (AOGCC) for an exception to the spacing requirements of 20 AAC 25.055 and Rule 2 of Conservation Order No. 477A to drill, complete, short-term pre-produce (flow back for up to 60 days), and inject into the Milne Point Unit H-31 service well in the Schrader Bluff Oil Pool within 500 feet of the exterior boundary of the Schrader Bluff Oil Pool Affected Area, pursuant to 20 AAC 25.055(d). Surface Location: 2,223’ FNL, 1,293’ FWL, Section 34, T13N, R10E, Umiat Meridian (UM)Target Location (Revised): 70’ FSL, 682’ FEL, Section 34, T13N, R10E, UM Bottom Hole Location (Revised): 70’ FSL, 570’ FWL, Section 31, T13N, R10E, UM Well spacing regulations protect the oil and gas rights of adjacent leaseholders and landowners and maximize resource recovery by establishing default limits on how close, under the land’s surface, oil and gas wells can be to property lines where ownership changes hands. These limits are set forth in a regulation, 20 AAC 25.055. Operators must abide by the default limits unless they apply for, and obtain, an order approving an exception to those limits. Although exceptions to the default limits are not unusual, AOGCC carefully evaluates each application, and typically grants them only when actual geologic conditions demonstrate that the proposed subsurface location of a well is necessary to reach otherwise unreachable oil or gas and that both the rights of adjacent leaseholders and landowners and underground drinking water can be protected. As a general matter, AOGCC does not have extensive authority over surface impacts such as noise, emissions, or construction. This notice does not contain all the information filed by Hilcorp. To obtain more information, contact the AOGCC’s Special Assistant, Samantha Coldiron, at (907) 793-1223 or samantha.coldiron@alaska.gov. The AOGCC has tentatively scheduled a public hearing on this matter for May 13, 2025, at 10:00 a.m. via Microsoft Teams. The hearing, which may be changed to full virtual, if necessary, will be held in the AOGCC hearing room located at 333 West 7th Avenue, Anchorage, AK 99501. The audio call in information is (907) 202 7104 Conference ID: 595 741 512# #. Anyone who wishes to participate remotely using MS Teams video conference should contact Ms. Samantha Coldiron at least two business days before the scheduled public hearing to request an invitation for the MS Teams. To request that the tentatively scheduled hearing be held, a written request must be filed with the AOGCC no later than 4:30 p.m. on March 28, 2025. If a request for a hearing is not timely filed, the AOGCC may issue an order without a hearing. To learn if the AOGCC will hold the hearing, call (907) 793-1223 after April 1, 2025. In addition, written comments regarding this application may be submitted to the AOGCC, at 333 West 7th Avenue, Anchorage, AK 99501 or samantha.coldiron@alaska.gov. Comments must be received no later than 4:30 p.m. on April 16, 2025, except that, if a hearing is held, comments must be received no later than the conclusion of the May 13, 2025, hearing. If, because of a disability, special accommodations may be needed to comment or attend the hearing, contact Samantha Coldiron, at (907) 793-1223, no later than May 8, 2025. Jessie L. Chmielowski Gregory C. Wilson Commissioner Commissioner Pub: Mar. 12, 2025 STATE OF ALASKA THIRD JUDICIAL DISTRICT ______________________________________2025-03-13 2028-07-14 Document Ref: ITNUX-TDPV5-TLRHK-GXTIJ Page 6 of 12 7 Notice of Public Hearing STATE OF ALASKA ALASKA OIL AND GAS CONSERVATION COMMISSION RE: Docket Number: CO-25-005 Hilcorp Alaska, LLC’s Spacing Exception Application for Well MPU H-21 Milne Point Unit, North Slope Borough, Alaska Hilcorp Alaska, LLC (Hilcorp), by letter dated March 3, 2025, filed an application with the Alaska Oil and Gas Conservation Commission (AOGCC) for an exception to the spacing requirements of 20 AAC 25.055 and Rule 2 of Conservation Order No. 477A to drill, complete, short-term pre- produce (flow back for up to 60 days), and inject into the Milne Point Unit H-21 service well in the Schrader Bluff Oil Pool within 500 feet of the exterior boundary of the Schrader Bluff Oil Pool Affected Area, pursuant to 20 AAC 25.055(d). Surface Location: 2,529' FNL, 1,212' FWL, Section 34, T13N, R10E, Umiat Meridian (UM) Target Location (Estimated): 70' FSL, 1,320’ FWL, Section 34, T13N, R10E, UM Bottom Hole Location: 70' FSL, 1,440’ FEL, Section 31, T13N, R10E, UM Well spacing regulations protect the oil and gas rights of adjacent leaseholders and landowners and maximize resource recovery by establishing default limits on how close, under the land's surface, oil and gas wells can be to property lines where ownership changes hands. These limits are set forth in a regulation, 20 AAC 25.055. Operators must abide by the default limits unless they apply for, and obtain, an order approving an exception to those limits. Although exceptions to the default limits are not unusual, AOGCC carefully evaluates each application, and typically grants them only when actual geologic conditions demonstrate that the proposed subsurface location of a well is necessary to reach otherwise unreachable oil or gas and that both the rights of adjacent leaseholders and landowners and underground drinking water can be protected. As a general matter, AOGCC does not have extensive authority over surface impacts such as noise, emissions, or construction. This notice does not contain all the information filed by Hilcorp. To obtain more information, contact the AOGCC’s Special Assistant, Samantha Coldiron, at (907) 793-1223 or samantha.coldiron@alaska.gov. The AOGCC has tentatively scheduled a public hearing on this matter for May 13, 2025, at 10:00 a.m. via Microsoft Teams. The hearing, which may be changed to full virtual, if necessary, will be held in the AOGCC hearing room located at 333 West 7th Avenue, Anchorage, AK 99501. The audio call in information is (907) 202 7104 Conference ID: 595 741 512# #. Anyone who wishes to participate remotely using MS Teams video conference should contact Ms. Samantha Coldiron at least two business days before the scheduled public hearing to request an invitation for the MS Teams. To request that the tentatively scheduled hearing be held, a written request must be filed with the AOGCC no later than 4:30 p.m. on March 28, 2025. If a request for a hearing is not timely filed, the AOGCC may issue an order without a hearing. To learn if the AOGCC will hold the hearing, call (907) 793-1223 after April 1, 2025. In addition, written comments regarding this application may be submitted to the AOGCC, at 333 West 7th Avenue, Anchorage, AK 99501 or samantha.coldiron@alaska.gov. Comments must be received no later than 4:30 p.m. on April 16, 2025, except that, if a hearing is held, comments must be received no later than the conclusion of the May 13, 2025, hearing. If, because of a disability, special accommodations may be needed to comment or attend the hearing, contact Samantha Coldiron, at (907) 793-1223, no later than May 8, 2025. Jessie L. Chmielowski Gregory C. Wilson Commissioner Commissioner Gregory C. Wilson Digitally signed by Gregory C. Wilson Date: 2025.03.10 12:40:38 -08'00' Jessie L. Chmielowski Digitally signed by Jessie L. Chmielowski Date: 2025.03.10 13:06:16 -08'00' From:Coldiron, Samantha J (OGC) To:AOGCC_Public_Notices Subject:[AOGCC_Public_Notices] Public Hearing Notices (Hilcorp) Date:Monday, March 10, 2025 2:00:21 PM Attachments:CO-25-005 Public Hearing Notice Hilcorp MPU H-21 Spacing Exception.pdf CO-25-006 Public Hearing Notice Hilcorp MPU H-31 Spacing Exception.pdf CO-25-007 Public Hearing Notice Hilcorp MPU H-41 and H-43 Spacing Exception.pdf Docket Number: CO-25-005 Hilcorp Alaska, LLC’s Spacing Exception Application for Well MPU H-21 Milne Point Unit, North Slope Borough, Alaska Docket Number: CO-25-006 Hilcorp Alaska, LLC’s Amended Spacing Exception Application for Well MPU H-31 Milne Point Unit, North Slope Borough, Alaska Docket Number: CO-25-007 Hilcorp Alaska, LLC’s Spacing Exception Application for Wells MPU H-41 and H-43 Milne Point Unit, North Slope Borough, Alaska Samantha Coldiron AOGCC Special Assistant Alaska Oil and Gas Conservation Commission 333 West 7th Avenue Anchorage, AK 99501 (907) 793-1223 __________________________________ List Name: AOGCC_Public_Notices@list.state.ak.us You subscribed as: samantha.coldiron@alaska.gov Unsubscribe at: https://list.state.ak.us/mailman/options/aogcc_public_notices/samantha.coldiron%40alaska.go v Lisi Misa being first duly sworn on oath deposes and says that she is a representative of the An- chorage Daily News, a daily newspaper. That said newspaper has been approved by the Third Judicial Court, Anchorage, Alaska, and it now and has been published in the English language continually as a daily newspaper in Anchorage, Alaska, and it is now and during all said time was printed in an office maintained at the afore- said place of publication of said newspaper. That the annexed is a copy of an advertisement as it was published in regular issues (and not in supplemental form) of said newspaper on AFFIDAVIT OF PUBLICATION ______________________________________ Notary Public in and for The State of Alaska. Third Division Anchorage, Alaska MY COMMISSION EXPIRES ______________________________________ 03/12/2025 and that such newspaper was regularly distrib- uted to its subscribers during all of said period. That the full amount of the fee charged for the foregoing publication is not in excess of the rate charged private individuals. Signed________________________________ Subscribed and sworn to before me Account #: 100869 ST OF AK/AK OIL AND GAS CONSERVATION COMMISSION333 W. 7TH AVE STE 100, ANCHORAGE, AK 99501 Order #: W0051328 Cost: $430.49 Notice of Public HearingSTATE OF ALASKAALASKA OIL AND GAS CONSERVATION COMMISSION RE: Docket Number: CO-25-005 Hilcorp Alaska, LLC’s Spacing Exception Application for Well MPU H-21Milne Point Unit, North Slope Borough, Alaska Hilcorp Alaska, LLC (Hilcorp), by letter dated March 3, 2025, filed an application with the Alaska Oil and Gas Conservation Commission (AOGCC) for an exception to the spacing requirements of 20 AAC 25.055 and Rule 2 of Conservation Order No. 477A to drill, complete, short-term pre-produce (flow back for up to 60 days), and inject into the Milne Point Unit H-21 service well in the Schrader Bluff Oil Pool within 500 feet of the exterior boundary of the Schrader Bluff Oil Pool Affected Area, pursuant to 20 AAC 25.055(d). Surface Location: 2,529’ FNL, 1,212’ FWL, Section 34, T13N, R10E, Umiat Meridian (UM)Target Location (Estimated): 70’ FSL, 1,320’ FWL, Section 34, T13N, R10E, UMBottom Hole Location: 70’ FSL, 1,440’ FEL, Section 31, T13N, R10E, UM Well spacing regulations protect the oil and gas rights of adjacent leaseholders and landowners and maximize resource recovery by establishing default limits on how close, under the land’s surface, oil and gas wells can be to property lines where ownership changes hands. These limits are set forth in a regulation, 20 AAC 25.055. Operators must abide by the default limits unless they apply for, and obtain, an order approving an exception to those limits. Although exceptions to the default limits are not unusual, AOGCC carefully evaluates each application, and typically grants them only when actual geologic conditions demonstrate that the proposed subsurface location of a well is necessary to reach otherwise unreachable oil or gas and that both the rights of adjacent leaseholders and landowners and underground drinking water can be protected. As a general matter, AOGCC does not have extensive authority over surface impacts such as noise, emissions, or construction. This notice does not contain all the information filed by Hilcorp. To obtain more information, contact the AOGCC’s Special Assistant, Samantha Coldiron, at (907) 793-1223 or samantha.coldiron@alaska.gov. The AOGCC has tentatively scheduled a public hearing on this matter for May 13, 2025, at 10:00 a.m. via Microsoft Teams. The hearing, which may be changed to full virtual, if necessary, will be held in the AOGCC hearing room located at 333 West 7th Avenue, Anchorage, AK 99501. The audio call in information is (907) 202 7104 Conference ID: 595 741 512# #. Anyone who wishes to participate remotely using MS Teams video conference should contact Ms. Samantha Coldiron at least two business days before the scheduled public hearing to request an invitation for the MS Teams. To request that the tentatively scheduled hearing be held, a written request must be filed with the AOGCC no later than 4:30 p.m. on March 28, 2025. If a request for a hearing is not timely filed, the AOGCC may issue an order without a hearing. To learn if the AOGCC will hold the hearing, call (907) 793-1223 after April 1, 2025. In addition, written comments regarding this application may be submitted to the AOGCC, at 333 West 7th Avenue, Anchorage, AK 99501 or samantha.coldiron@alaska.gov. Comments must be received no later than 4:30 p.m. on April 16, 2025, except that, if a hearing is held, comments must be received no later than the conclusion of the May 13, 2025, hearing. If, because of a disability, special accommodations may be needed to comment or attend the hearing, contact Samantha Coldiron, at (907) 793-1223, no later than May 8, 2025. Jessie L. Chmielowski Gregory C. WilsonCommissioner Commissioner Pub: Mar. 12, 2025 STATE OF ALASKA THIRD JUDICIAL DISTRICT ______________________________________2025-03-13 2028-07-14 Document Ref: ITNUX-TDPV5-TLRHK-GXTIJ Page 5 of 12 6 March 3, 2025 Jessie Chmielowski, Commissioner Alaska Oil and Gas Conservation Commission 333 West 7th Avenue, Suite 100 Anchorage, Alaska 99501 RE: Application for Spacing Exception Milne Point Unit H-41 and H-43 Injector Wells Commissioner Chmielowski: Hilcorp Alaska, LLC (“Hilcorp”), as Operator of the Milne Point Unit, hereby submits this application for spacing exception to drill two (2) injection wells, the Milne Point Unit H- 41 and H-43, collectively referred to as (“H-Pad Injection Wells”)in the Shrader Bluff Oil Pool. The proposed productive interval and location for the proposed drill operations are listed below and further depicted on the attached Exhibit “A” and “A-1”: H-41: Surface Location: x State Lease ADL 25906 x 2435’ FNL, 1105’ FWL x Section 34, T13N-R10E, UM Top of the Producing Interval: x State Lease ADL 25906 x 70’ FSL, 2535’ FWL x Section 33, T13N-R10E, UM Bottom Hole Location: x State Lease ADL 25517 x 70’ FSL, 70’ FWL x Section 31, T13N-R10E, UM H-43: Surface Location: x State Lease ADL 25906 x 2291’ FNL, 1158’ FWL x Section 34, T13N-R10E, UM PO Box 244027 Anchorage, AK 99524-4027 3800 Centerpoint Drive, STE 1400 Anchorage, AK 99503 Phone: (907) 777-8341 Fax: (907) 777-8301 Email: jamie.wilson@hilcorp.com By Samantha Coldiron at 3:44 pm, Mar 04, 2025 Hilcorp Alaska, LLC Spacing Exception Application Milne Point Unit H-41 & H-43 Injection Wells March 3, 2025 Page 2 of 8 Top of the Producing Interval: x State Lease ADL 25906 x 1497’ FSL, 612’ FWL x Section 33, T13N-R10E, UM Bottom Hole Location: x State Lease ADL 25517 x 2004’ FSL, 70’ FWL x Section 31, T13N-R10E, UM Hilcorp submits this application to ensure compliance with 20 AAC 25.055(a)(1), which states “for a well drilling for oil, a wellbore may be open to test or regular production1 within 500 feet of a property line only if the owner is the same and the landowner is the same on both sides of the line.” The H-41 and H-43 wells will be injection wells. In order to achieve maximum injectivity of the wellbore, Hilcorp intends to flow back each well for up to 60 days to fully clean out the wellbore to reduce the effect of near-wellbore damage caused by drilling fluid invasion which will ensure maximum injectivity. The initial flowback will consist mostly of drilling and completion fluids, including cuttings and other fine materials that will be flowed to tanks, transported offsite and disposed of in accordance with State regulations. Once the flowback has less than 0.5% solids, the flow stream will be sent to the Milne Point production facility to continue cleaning up. In order to prevent waste, Hilcorp intends to sell any oil processed and separated at the production facility. Hilcorp is not proposing to drill and complete any of these wells as a producing oil well. Associated oil will only be “produced” for 60 days to ensure the wellbore is as clean as possible before commencing injection operations. The intent of this application is to allow Hilcorp to prevent waste that may occur as a result of its cleanup process by: 1. Ensuring a clean wellbore to achieve maximum injectivity. 2. Enhancing recovery of the offset production well which will be spaced between each injection well. 3. Avoid disposal of sales quality oil. Additionally, well spacing within the Schrader Bluff Oil Pool is governed by Rule 2 of Conservation Order 477a: 1 AS 31.05.170(14) “regular production” means continuing production of oil or gas from a well into production facilities and transportation to market, but does not include short term testing, evaluation, or experimental pilot production activities that have been approved by permit or order of the commission.” Hilcorp Alaska, LLC Spacing Exception Application Milne Point Unit H-41 & H-43 Injection Wells March 3, 2025 Page 3 of 8 Rule 2. Spacing (Revised by CO 477.005) There are no restrictions as to well spacing except that no pay shall be opened in a well closer than 500 feet from the exterior boundary of the affected area. The proposed H-Pad Injection Wells operations target undrained reserves that cannot be reached by wells conforming to applicable spacing restrictions. Approval of short-term pre- production of the proposed H-Pad Injection Wells allows for protection of its correlative rights by recovering the otherwise stranded reserves and ensures future maximum injectivity of each wellbore. Additionally, the correlative rights of all affected owners, landowners and operators will be protected and enhanced by the long-term support provided by the polymer injection. The proposed production well which will be drilled between each of the H-Pad Injector Wells, as shown on Exhibit “A-1”, will be further than 500 feet from the exterior boundary of the affected area and does not require a spacing exception approval. Hilcorp anticipates drilling operations of the H-Pad Injection Wells to commence as soon as June 2025. As of the date of delivery of this application, and in accordance with 20 AAC 25.055(d)(1), notice of Hilcorp’s intent to drill the H-Pad Injection Wells has been sent by certified mail to those certain owners, landowners, and operators of property within 1,000 feet of the well listed in Exhibit “B”. A copy of the notice and corresponding certified mailing receipts have been attached to this application. Pursuant to 20 AAC 25.055(d)(3), and attached as Exhibit “C”, is an affidavit executed by a person acquainted with all pertinent facts of this application and verifying that all facts set forth herein are true. It is requested that the Commission approve, by Administrative Approval, pursuant to 20 AAC 25.556(d), an exception to the well spacing for drilling the H-Pad Injection Wells. If you require additional information or would like to have a technical meeting regarding this application, please contact Katie Cunha, Geologist, at (907) 564-4786, or me at (907) 777-8341 or by email at jamie.wilson@hilcorp.com. Sincerely, Jamie Wilson Sr. Landman Hilcorp Alaska, LLC cc: Heather Beat, Unit Manager, Division of Oil and Gas (via email) Ashley Ethridge, Unit Manager, Division of Oil and Gas (via email) Digitally signed by Jamie Wilson (2170) DN: cn=Jamie Wilson (2170) Date: 2025.03.03 14:40:38 - 09'00' Jamie Wilson (2170) Hilcorp Alaska, LLC Spacing Exception Application Milne Point Unit H-41 & H-43 Injection Wells March 3, 2025 Page 4 of 8 Derek Nottingham, Director, Division of Oil and Gas (via email) Samantha Coldiron, Assistant, AOGCC (via email) Attachments: Exhibit “A” Map of Overview of Well Locations Exhibit “A-1” Map of Spacing Exception Wells Exhibit “B” Notice List Exhibit “C” Affidavit Hilcorp Alaska, LLC Spacing Exception Application Milne Point Unit H-41 & H-43 Injection Wells March 3, 2025 Page 5 of 8 EXHIBIT “A” APPLICATION FOR SPACING EXCEPTION Milne Point Unit H-41 and H-43 Injection Wells Overview Map Hilcorp Alaska, LLC Spacing Exception Application Milne Point Unit H-41 & H-43 Injection Wells March 3, 2025 Page 6 of 8 EXHIBIT “A-1” APPLICATION FOR SPACING EXCEPTION Milne Point Unit H-41 and H-43 Injection Wells Map of Spacing Exception Wells Hilcorp Alaska, LLC Spacing Exception Application Milne Point Unit H-41 & H-43 Injection Wells March 3, 2025 Page 7 of 8 EXHIBIT “B” APPLICATION FOR SPACING EXCEPTION Milne Point Unit H-41 & H-43 Injection Wells Notice List Unit/Lease Landowner Owner Operator Kuparuk River Unit - ADL 025627 - ADL 025628 - ADL 025519 Department of Natural Resources Division of Oil & Gas 550 W. 7th Avenue, Ste. 1100 Anchorage, AK 99501-3560 Attn: Derek Nottingham, Director ConocoPhillips Alaska, Inc ATTN: Ryan King 700 G Street Anchorage, Alaska 99501 ConocoPhillips Alaska II, Inc ATTN: Ryan King 700 G Street Anchorage, Alaska 99501 ExxonMobil Alaska Production Inc. Attn: Justin Shuff 22777 Springwoods Village Pkwy Spring, TX 77389 ConocoPhillips Alaska, Inc ATTN: Ryan King 700 G Street Anchorage, Alaska 99501 March 3, 2025 ConocoPhillips Alaska, Inc ATTN: Ryan King 700 G Street Anchorage, Alaska 99501 RE: Notice of Applications for Spacing Exception Milne Point Unit H-41 and H-43 Injector Wells Mr. King: Hilcorp Alaska, LLC (“Hilcorp”), as Operator of the Milne Point Unit, will be submitting to the Alaska Oil and Gas Conservation Commission (“AOGCC”) the enclosed Application for Spacing Exception to drill the above referenced wells in the Schrader Bluff Oil Pool. Pursuant to 20 AAC 25.055(d)(1), all owners, landowners, and operators of all properties within 1,000 feet of a well drilling for oil for which an exception is sought must receive notice of such exception application. As an owner of certain property located within 1,000 feet of Hilcorp’s proposed wells depicted on Exhibit “A”, please allow for this letter to serve as notice of Hilcorp’s intent to submit an Application for a Spacing Exception for the proposed operation, and its request for Administrative Approval from AOGCC. Should you require additional information regarding this application, please contact me by phone at (907) 777-8341 or by email at jamie.wilson@hilcorp.com. Sincerely, Jamie Wilson Sr. Landman Hilcorp Alaska, LLC PO Box 244027 Anchorage, AK 99524-4027 3800 Centerpoint Drive, STE 1400 Anchorage, AK 99503 Phone: (907) 777-8341 Fax: (907) 777-8301 Email: jamie.wilson@hilcorp.com March 3, 2025 ConocoPhillips Alaska II, Inc ATTN: Ryan King 700 G Street Anchorage, Alaska 99501 RE: Notice of Applications for Spacing Exception Milne Point Unit H-41 and H-43 Injector Wells Mr. King: Hilcorp Alaska, LLC (“Hilcorp”), as Operator of the Milne Point Unit, will be submitting to the Alaska Oil and Gas Conservation Commission (“AOGCC”) the enclosed Application for Spacing Exception to drill the above referenced wells in the Schrader Bluff Oil Pool. Pursuant to 20 AAC 25.055(d)(1), all owners, landowners, and operators of all properties within 1,000 feet of a well drilling for oil for which an exception is sought must receive notice of such exception application. As an owner of certain property located within 1,000 feet of Hilcorp’s proposed wells depicted on Exhibit “A”, please allow for this letter to serve as notice of Hilcorp’s intent to submit an Application for a Spacing Exception for the proposed operation, and its request for Administrative Approval from AOGCC. Should you require additional information regarding this application, please contact me by phone at (907) 777-8341 or by email at jamie.wilson@hilcorp.com. Sincerely, Jamie Wilson Sr. Landman Hilcorp Alaska, LLC PO Box 244027 Anchorage, AK 99524-4027 3800 Centerpoint Drive, STE 1400 Anchorage, AK 99503 Phone: (907) 777-8341 Fax: (907) 777-8301 Email: jamie.wilson@hilcorp.com March 3, 2025 ExxonMobil Alaska Production Inc. Attn: Justin Shuff 22777 Springwoods Village Pkwy Spring, Texas 77389 RE: Notice of Applications for Spacing Exception Milne Point Unit H-41 and H-43 Injector Wells Mr. Shuff: Hilcorp Alaska, LLC (“Hilcorp”), as Operator of the Milne Point Unit, will be submitting to the Alaska Oil and Gas Conservation Commission (“AOGCC”) the enclosed Application for Spacing Exception to drill the above referenced wells in the Schrader Bluff Oil Pool. Pursuant to 20 AAC 25.055(d)(1), all owners, landowners, and operators of all properties within 1,000 feet of a well drilling for oil for which an exception is sought must receive notice of such exception application. As an owner of certain property located within 1,000 feet of Hilcorp’s proposed wells depicted on Exhibit “A”, please allow for this letter to serve as notice of Hilcorp’s intent to submit an Application for a Spacing Exception for the proposed operation, and its request for Administrative Approval from AOGCC. Should you require additional information regarding this application, please contact me by phone at (907) 777-8341 or by email at jamie.wilson@hilcorp.com. Sincerely, Jamie Wilson Sr. Landman Hilcorp Alaska, LLC PO Box 244027 Anchorage, AK 99524-4027 3800 Centerpoint Drive, STE 1400 Anchorage, AK 99503 Phone: (907) 777-8341 Fax: (907) 777-8301 Email: jamie.wilson@hilcorp.com March 3, 2025 Department of Natural Resources Division of Oil & Gas 550 W. 7th Avenue, Ste. 1100 Anchorage, AK 99501-3560 Attn: Derek Nottingham, Director RE: Notice of Applications for Spacing Exception Milne Point Unit H-41 and H-43 Injector Wells Dear Mr. Nottingham: Hilcorp Alaska, LLC (Hilcorp), as Operator of the Milne Point Unit, will be submitting to the Alaska Oil and Gas Conservation Commission (AOGCC) the enclosed Application for Spacing Exception to drill the above referenced wells in the Schrader Bluff Oil Pool. Pursuant to 20 AAC 25.055(d)(1), all owners, landowners, and operators of all properties within 1,000 feet of a well drilling for oil for which an exception is sought must receive notice of such exception application. As an owner of certain property located within 1,000 feet of Hilcorp’s proposed wells depicted on Exhibit “A”, please allow for this letter to serve as notice of Hilcorp’s intent to submit an Application for a Spacing Exception for the proposed operation, and its request for Administrative Approval from AOGCC. Should you require additional information regarding this application, please contact me by phone at (907) 777-8341 or by email at jamie.wilson@hilcorp.com. Sincerely, Jamie Wilson Sr. Landman Hilcorp Alaska, LLC PO Box 244027 Anchorage, AK 99524-4027 3800 Centerpoint Drive, STE 1400 Anchorage, AK 99503 Phone: (907) 777-8341 Fax: (907) 777-8301 Email: jamie.wilson@hilcorp.com Certified Mail Tracking Spacing Exception Application Milne Point Unit H-21, H-31, H-41 and H-43 Large Envelope #1 # 9489017898203021009101 (ConocoPhillips Alaska, Inc and Conocophillips Alaska II, Inc Attn: Ryan King) Large Envelope #2 # 9489017898203021009118 (Department of Natural Resources Division of Oil & Gas Attn: Derek Nottingham) Large Envelope #3 # 9489017898203021009125 (ExxonMobil Alaska Production Inc. Attn: Justin Shuff) Large Envelope #4 # 9489017898203021009132 (Jessie Chmielowski, Commissioner Alaska Oil and Gas Conservation Commission) WSAK 17 -3,458 N-01 -3,679 N-01A -3,664 N-01B -3,663 M-01 -3,707 M-01A -3,620 3K-09 -3,377 3K-09A -3,334 G-02 -4,166 G-01 -4,079 J-05 -4,039 J-07 -4,057 1R-23 1R-22 J-06 -3,957 J-09 -3,979 J-09A -3,973 J-08 -3,995 J-08A -3,976 J-10 -4,039 J-11 -3,992 J-12 -3,956 J-13 -4,036 H-05 -4,112 H-06 -4,118 I-05 -3,951 H-07 -4,115 H-07A -4,101 H-07AL1 -4,106 L-34 -4,009 L-35 -3,921 G-09 -4,143 G-11 -4,261 G-15 -4,117L-20 -3,885 L-36 -3,896 H-10 -3,979 H-14 -4,040 H-11 -3,990 H-09 -3,947 H-12 -4,164 H-08 -4,085 H-08A -4,087 H-08B -4,087 H-08BL1 H-13 -4,055 I-08 -3,859 I-06 -3,775 J-21 -3,873 J-17 -3,914 J-20 -3,868 J-20A -3,723 J-18 -3,993 L-37 -3,984 L-37A -3,984 C-40 -4,235 J-22 -3,934 L-45 -4,011 J-15 -4,021 I-09 -3,879 I-10 -3,778 J-23 -3,703 J-24 -3,786 J-24L1 -3,786 I-13 -3,563 3K-20 -3,435 3K-19 -3,393 G-14 -4,071 G-14L1 -4,071 I-11 -3,543 I-11L1 -3,541 I-12 -3,591 I-12L1 -3,591 S-21 -4,115 S-31 -3,970 S-27 -3,984 S-27L1 -3,984 S-25 -4,044 S-25L1 -4,043 I-15 -3,905 I-15L1 -3,904 S-29 -4,065 S-29L1 -4,065 S-33 -4,055 S-33A -4,035 S-30 -4,004 S-20 -4,052 S-26 -4,033 S-14 -3,979 S-34 -4,126 S-34L1 -4,126 G-16 -4,224 G-16L1 -4,224 G-17 -4,045 -4,099 G-18L1 -4,097 J-26L1 -3,899 J-26L2 -3,900 I-17 -3,824 I-17L1 -3,823 I-17L2 -3,824 I-14 -3,862 I-14L1 -3,862 I-19 -3,941 I-19L1 -3,942 I-16 -3,842 H-18L1 -4,034 H-16 -3,938 H-16L1 -3,938 H-15 -3,967 1H-NORTH -3,847 1R-EAST -3,660 LIVIANO 1 -3,762LIVIANO 1A -3,765 PESADO 1 -3,951 PESADO 1A -3,949 H-17 -4,103 H-19 -4,081 H-19L1 -4,079 3K-102 -3,373 3K-103 -3,379 3K-108 -3,410 I-18 -3,831 3K-105 -3,354 WSAK 25 -3,884 3K-01 -3,306 3K-05 -3,305 3K-06 -3,304 3K-07 -3,348 3K-16 -3,388 3K-18 -3,403 O-18 334 O-15 ,301 O-14 359 O-12 ,375 O-11 ,365 3O-06 -3,365 3O-04 -3,401 -08 372 3O-01 -3,425 3O-05 -3,391 H-01 -4,083 H-02 -4,041 H-03 -4,084 H-04 -4,019 I-01 -3,942 I-02 -3,973 I-03 -3,889 I-04 -3,948 I-04A -3,946 I-04AL1 -3,949 J-01 -3,945 J-01A -3,960 J-01AL1 -3,953 J-03 -3,882 J-04 -4,044 -4,119 G-06 -4,218 I-07 -3,848 J-19 -3,943 J-19A -3,949 J-16 -3,992 J-23L1 -3,703 H-07APB1 -4,107 H-08APB1 -4,092 J-24L1PB1 -3,786 I-12PB1 -3,561 I-15PB1 -3,904 G-18PB1 -4,099 J-25PB1 -3,949 I-04PB1 -3,955 H-07AL1PB1 -4,106 H-08BPB1 -4,087 J-24L1PB2 -3,787 G-16PB2 -4,224 I-04APB1 -3,948 H-07AL1PB2 -4,106 G-17LS -4,044 G-17SS -4,043 3K-102L1 -3,374 3K-103L1 -3,380 3K-108L1 -3,409 3K-105L1 -3,354 L-50 -4,003 L-47 -4,042 L-46PB1 -4,133M-03 -3,628 M-14 -3,795 M-15 -3,789 M-13 -3,831 M-12PB2 -3,947 M-16 -3,751 M-17 -3,689 M-18 -3,658 M-19 -3,642 M-23 -3,753 M-25 -3,546 M-26 -3,526 M-18PB1 -3,657 M-18PB2 -3,655 M-20PB1 -3,598 M-22PB1 -3,562 M-35 -3,809M-34 -3,754 M-15PB1 -3,797 M-23PB1 -3,753 M-35PB1 -3,808 M-44 M-45 M-43 I-20 -3,860 I-38 I-28 -3,880 I-07A -3,879 I-07APB1 -3,880 I-27 -3,889 I-30 -3,785 I-29 -3,797 I-32 -3,801 I-31 -3,873 I-33 -3,849 I-23 -3,796 J-43 J-42 J-44 J-32 -3,979 1 L -0 1 6 41-3 2120192423 2829302526 343332313635 234561 I J H G DRILLSITE 3K ADL025519 ADL025517 A ADL025906 ADL025628 ADL025627 HILCORP ALASKA LLC MILNE POINT FIELD H-Pad Future Drill Wells H-41 and H-43 FEET 0 1,000 2,000 3,000 POSTED WELL DATA Well NumberFMTOPS - MP_SB_OA[KMC] (SS) (FEET) SYMBOL HIGHLIGHT SBF OA LWR INJ - ACTIVE_SI SBF OA LWR INJ - P&A SBF OA LWR PRODUCED - P&A'D SBF OA LWR PRODUCING SI SBF OA LWR WET SBF OA LWR SHOW WELL SYMBOLS Oil D&A Location Shut In Oil INJ Well (Water Flood) P&A Oil P&A Oil/Gas Abandoned Injector SWD J&A Plug Back Pilot Well Shut In INJ WATER SOURCE Drilling By: K. Cunha February 13, 2025 PETRA 2/13/2025 1:02:42 PM Oa1 Oa2 Oa3 Oa4/out of Zone Schrader Bluff Oa Subzones: KUPARUK RIVER UNIT MILNE POINT UNIT Deepest open interval of 3K-105L1 (West Sak D = Schrader Oa)3K-105L1 Toe H-41 BHL located 70' from northern and western lease line H-43 BHL located 70' from lease line CO 477a Affected Area (500' buffer) shown in purple dashed line Proposed H-42 Producer -Not requesting spacing exception H-41 TPH H-41 Proposed Injector: x Located approx. 70' north of lease line. x First 2/3 of well will be completed in the Schrader Nb (KRU equivalent = Ugnu A), and last 1/3 of well will be completed in the Schrader Oa (KRU equivalent = West Sak D). x BHL is 2,650' away from the closest open interval of KRU producer in the Schrader Oa, the 3K-105L1. H-43 Proposed Injector: x Located approx. 70' east of lease line. x Well will be completed in the Schrader Oa. x BHL is 1,360' away from the closest open interval of KRU producer in the Schrader Oa, the 3K-105L1. H-43 TPH H-41 Proposed Injector H-43 Proposed Injector Milne Point Unit Boundary Schrader Bluff Oa Map = West Sak DExhibit "A-1" Spacing Exception Milne Point Unit H-41 and H-43 Injectors First 2/3 in Shrader NB = KRU Equiv Ugnu A Last 1/3 in Schrader Oa = KRU Equiv West Sak D 5 March 3, 2025 Jessie Chmielowski, Commissioner Alaska Oil and Gas Conservation Commission 333 West 7th Avenue, Suite 100 Anchorage, Alaska 99501 RE: Application for Spacing Exception Milne Point Unit H-31 Extended Well (Injector) Amendment to CO477.009 Commissioner Chmielowski: On January 12, 2024, Hilcorp Alaska, LLC (“Hilcorp”) submitted an application to drill the Milne Point Unit H-31 well which was approved under CO477.009. After further review, Hilcorp would like to extend the well a total of 5,440’. The new, proposed top productive horizon (TPH) has been shifted eastward by 1,460’ and the bottom hole location (“BHL”) of the well has been shifted an additional 3,980’ west to access additional resources within the same lease as previously approved in order to protect the correlative rights of the State, and prevent waste of resources that otherwise might not be captured. There will be no change to the location of the BHL as to the exterior boundary of the lease line. Now therefore, Hilcorp, as Operator of the Milne Point Unit, hereby submits this amended application for spacing exception to drill the Milne Point Unit H-31 Well (“H-31 Well”) with an adjusted TPH and extended BHL in the Shrader Bluff Oil Pool. The proposed productive interval and location for the proposed drill operations are listed below and further depicted on the attached Exhibit “A”: Surface Location (Same as CO477.009): x State Lease ADL 25906 x 2,223’ FNL, 1,293’ FWL x Section 34, T13N-R10E, UM Top of the Producing Interval (Revised from CO477.009): x State Lease ADL 25906 x 70’ FSL, 682’ FEL x Section 34, T13N-R10E, UM Bottom Hole Location (Revised from CO477.009): x State Lease ADL 25517 x 70’FSL, 570’ FWL x Section 31, T13N-R10E, UM PO Box 244027 Anchorage, AK 99524-4027 3800 Centerpoint Drive, STE 1400 Anchorage, AK 99503 Phone: (907) 777-8341 Fax: (907) 777-8301 Email: jamie.wilson@hilcorp.com By Samantha Coldiron at 3:44 pm, Mar 04, 2025 Hilcorp Alaska, LLC Spacing Exception Milne Point Unit H-31 Well Extended BHL March 3, 2025 Page 2 of 6 Compliance with CO477.009: Should this amended application be approved, Hilcorp will abide by all terms and conditions outlined in CO477.009 for the Milne Point Unit H-31 Well. Hilcorp submits this application to ensure compliance with 20 AAC 25.055(a)(1), which states “for a well drilling for oil, a wellbore may be open to test or regular production1 within 500 feet of a property line only if the owner is the same and the landowner is the same on both sides of the line.” The H-31 Well will be an injection well. As previously approved in CO477.009, Hilcorp is requesting to flow back the well for up to 60 days to fully clean out the wellbore to reduce the effect of near-wellbore damage caused by drilling fluid invasion which will ensure maximum injectivity. The initial flowback will consist mostly of drilling and completion fluids, including cuttings and other fine materials that will be flowed to tanks, transported offsite and disposed of in accordance with State regulations. Once the flowback has less than 0.5% solids, the flow stream will be sent to the Milne Point production facility to continue cleaning up. In order to prevent waste, Hilcorp intends to sell any oil processed and separated at the production facility. Hilcorp is not proposing to drill and complete a producing oil well. Associated oil will only be “produced” for 60 days to ensure the wellbore is as clean as possible before commencing injection operations. The intent of this application is to allow Hilcorp to prevent waste that may occur as a result of its cleanup process by: 1. Ensuring a clean wellbore to achieve maximum injectivity. 2. Enhancing recovery of the offset H-32 production well. 3. Avoid disposal of sales quality oil. Additionally, well spacing within the Schrader Bluff Oil Pool is governed by Rule 2 of Conservation Order 477a: Rule 2. Spacing. There are no restrictions as to well spacing except that no pay shall be opened in a well closer than 500 feet from the exterior boundary of the affected area. The proposed H-31 Well operations target undrained reserves that cannot be reached by wells conforming to applicable spacing restrictions. Approval of short-term pre-production 1 AS 31.05.170(14) “regular production” means continuing production of oil or gas from a well into production facilities and transportation to market, but does not include short term testing, evaluation, or experimental pilot production activities that have been approved by permit or order of the commission.” Hilcorp Alaska, LLC Spacing Exception Milne Point Unit H-31 Well Extended BHL March 3, 2025 Page 3 of 6 of the proposed H-31 Well allows for the recovery of otherwise stranded reserves and ensures future maximum injectivity of the wellbore. Additionally, the correlative rights of all affected owners, landowners and operators will be protected and enhanced by the long- term support provided by the proposed H-31 injection. As of the date of delivery of this application, and in accordance with 20 AAC 25.055(d)(1), notice of Hilcorp’s intent to drill the H-31 Well has been sent by certified mail to those certain owners, landowners, and operators of property within 1,000 feet of the well listed in Exhibit “B”. A copy of the notice and corresponding certified mailing receipts have been attached to this application. Pursuant to 20 AAC 25.055(d)(3), and attached as Exhibit “C”, is an affidavit executed by a person acquainted with all pertinent facts of this application and verifying that all facts set forth herein are true. It is requested that the Commission approve, by Administrative Approval, pursuant to 20 AAC 25.556(d), an exception to the well spacing for drilling the extended BHL of the H- 31 Well, amending CO477.009. If you require additional information or would like to have a technical meeting regarding this application, please contact Katie Cunha, Geologist, at (907) 564-4786, or me at (907) 777-8341 or by email at jamie.wilson@hilcorp.com. Sincerely, Jamie Wilson Sr. Landman Hilcorp Alaska, LLC cc: Heather Beat, Unit Manager, Division of Oil and Gas (via email) Ashley Ethridge, Unit Manager, Division of Oil and Gas (via email) Derek Nottingham, Director, Division of Oil and Gas (via email) Samantha Coldiron, Assistant, AOGCC (via email) Digitally signed by Jamie Wilson (2170) DN: cn=Jamie Wilson (2170) Date: 2025.03.03 14:32:02 - 09'00' Jamie Wilson (2170) Hilcorp Alaska, LLC Spacing Exception Milne Point Unit H-31 Well Extended BHL March 3, 2025 Page 4 of 6 EXHIBIT “A” APPLICATION FOR SPACING EXCEPTION MILNE POINT UNIT H-31 WEL Hilcorp Alaska, LLC Spacing Exception Milne Point Unit H-31 Well Extended BHL March 3, 2025 Page 5 of 6 EXHIBIT “B” APPLICATION FOR SPACING EXCEPTION Milne Point Unit H-31 Well Unit/Lease Landowner Owner Operator Kuparuk River Unit - ADL 025627 - ADL 025628 Department of Natural Resources Division of Oil & Gas 550 W. 7th Avenue, Ste. 1100 Anchorage, AK 99501-3560 Attn: Derek Nottingham, Director ConocoPhillips Alaska, Inc ATTN: Ryan King 700 G Street Anchorage, Alaska 99501 ConocoPhillips Alaska II, Inc ATTN: Ryan King 700 G Street Anchorage, Alaska 99501 ExxonMobil Alaska Production Inc. Attn: Justin Shuff 22777 Springwoods Village Pkwy Spring, Texas 77389 ConocoPhillips Alaska, Inc ATTN: Ryan King 700 G Street Anchorage, Alaska 99501 March 3, 2025 ConocoPhillips Alaska, Inc ATTN: Ryan King 700 G Street Anchorage, Alaska 99501 RE: Notice of Applications for Spacing Exception Milne Point Unit H-31 Extended Well (Injector) Amendment to CO477.009 Mr. King: Hilcorp Alaska, LLC (“Hilcorp”), as Operator of the Milne Point Unit, will be submitting to the Alaska Oil and Gas Conservation Commission (“AOGCC”) the enclosed Application for Spacing Exception to drill the above referenced well in the Schrader Bluff Oil Pool. Pursuant to 20 AAC 25.055(d)(1), all owners, landowners, and operators of all properties within 1,000 feet of a well drilling for oil for which an exception is sought must receive notice of such exception application. As an owner of certain property located within 1,000 feet of Hilcorp’s proposed well depicted on Exhibit “A”, please allow for this letter to serve as notice of Hilcorp’s intent to submit an Application for a Spacing Exception for the proposed operation, and its request for Administrative Approval from AOGCC. Should you require additional information regarding this application, please contact me by phone at (907) 777-8341 or by email at jamie.wilson@hilcorp.com. Sincerely, Jamie Wilson Sr. Landman Hilcorp Alaska, LLC PO Box 244027 Anchorage, AK 99524-4027 3800 Centerpoint Drive, STE 1400 Anchorage, AK 99503 Phone: (907) 777-8341 Fax: (907) 777-8301 Email: jamie.wilson@hilcorp.com March 3, 2025 ConocoPhillips Alaska II, Inc ATTN: Ryan King 700 G Street Anchorage, Alaska 99501 RE: Notice of Applications for Spacing Exception Milne Point Unit H-31 Extended Well (Injector) Amendment to CO477.009 Mr. King: Hilcorp Alaska, LLC (“Hilcorp”), as Operator of the Milne Point Unit, will be submitting to the Alaska Oil and Gas Conservation Commission (“AOGCC”) the enclosed Application for Spacing Exception to drill the above referenced well in the Schrader Bluff Oil Pool. Pursuant to 20 AAC 25.055(d)(1), all owners, landowners, and operators of all properties within 1,000 feet of a well drilling for oil for which an exception is sought must receive notice of such exception application. As an owner of certain property located within 1,000 feet of Hilcorp’s proposed well depicted on Exhibit “A”, please allow for this letter to serve as notice of Hilcorp’s intent to submit an Application for a Spacing Exception for the proposed operation, and its request for Administrative Approval from AOGCC. Should you require additional information regarding this application, please contact me by phone at (907) 777-8341 or by email at jamie.wilson@hilcorp.com. Sincerely, Jamie Wilson Sr. Landman Hilcorp Alaska, LLC PO Box 244027 Anchorage, AK 99524-4027 3800 Centerpoint Drive, STE 1400 Anchorage, AK 99503 Phone: (907) 777-8341 Fax: (907) 777-8301 Email: jamie.wilson@hilcorp.com March 3, 2025 ExxonMobil Alaska Production Inc. Attn: Justin Shuff 22777 Springwoods Village Pkwy Spring, Texas 77389 RE: Notice of Applications for Spacing Exception Milne Point Unit H-31 Extended Well (Injector) Amendment to CO477.009 Mr. Shuff: Hilcorp Alaska, LLC (“Hilcorp”), as Operator of the Milne Point Unit, will be submitting to the Alaska Oil and Gas Conservation Commission (“AOGCC”) the enclosed Application for Spacing Exception to drill the above referenced well in the Schrader Bluff Oil Pool. Pursuant to 20 AAC 25.055(d)(1), all owners, landowners, and operators of all properties within 1,000 feet of a well drilling for oil for which an exception is sought must receive notice of such exception application. As an owner of certain property located within 1,000 feet of Hilcorp’s proposed well depicted on Exhibit “A”, please allow for this letter to serve as notice of Hilcorp’s intent to submit an Application for a Spacing Exception for the proposed operation, and its request for Administrative Approval from AOGCC. Should you require additional information regarding this application, please contact me by phone at (907) 777-8341 or by email at jamie.wilson@hilcorp.com. Sincerely, Jamie Wilson Sr. Landman Hilcorp Alaska, LLC PO Box 244027 Anchorage, AK 99524-4027 3800 Centerpoint Drive, STE 1400 Anchorage, AK 99503 Phone: (907) 777-8341 Fax: (907) 777-8301 Email: jamie.wilson@hilcorp.com March 3, 2025 Department of Natural Resources Division of Oil & Gas 550 W. 7th Avenue, Ste. 1100 Anchorage, AK 99501-3560 Attn: Derek Nottingham, Director RE: Notice of Application for Spacing Exception Milne Point Unit H-31 Extended Well (Injector) Amendment to CO477.009 Dear Mr. Nottingham: Hilcorp Alaska, LLC (Hilcorp), as Operator of the Milne Point Unit, will be submitting to the Alaska Oil and Gas Conservation Commission (AOGCC) the enclosed Application for Spacing Exception to drill the above referenced well in the Schrader Bluff Oil Pool. Pursuant to 20 AAC 25.055(d)(1), all owners, landowners, and operators of all properties within 1,000 feet of a well drilling for oil for which an exception is sought must receive notice of such exception application. As an owner of certain property located within 1,000 feet of Hilcorp’s proposed well depicted on Exhibit “A”, please allow for this letter to serve as notice of Hilcorp’s intent to submit an Application for a Spacing Exception for the proposed operation, and its request for Administrative Approval from AOGCC. Should you require additional information regarding this application, please contact me by phone at (907) 777-8341 or by email at jamie.wilson@hilcorp.com. Sincerely, Jamie Wilson Sr. Landman Hilcorp Alaska, LLC PO Box 244027 Anchorage, AK 99524-4027 3800 Centerpoint Drive, STE 1400 Anchorage, AK 99503 Phone: (907) 777-8341 Fax: (907) 777-8301 Email: jamie.wilson@hilcorp.com 4 March 3, 2025 Jessie Chmielowski, Commissioner Alaska Oil and Gas Conservation Commission 333 West 7th Avenue, Suite 100 Anchorage, Alaska 99501 RE: Application for Spacing Exception Milne Point Unit H-21 Injector Well Commissioner Chmielowski: Hilcorp Alaska, LLC (“Hilcorp”), as Operator of the Milne Point Unit, hereby submits this application for spacing exception to drill the Milne Point Unit H-21 injection well (“H-21 Well”)in the Shrader Bluff Oil Pool. The proposed productive interval and location for the proposed drill operations are listed below and further depicted on the attached Exhibit “A” Surface Location: x State Lease ADL 25906 x 2,529’ FNL, 1,212’ FWL x Section 34, T13N-R10E, UM Top of the Producing Interval: x State Lease ADL 25906 x 70’ FSL, 1,320’ FWL x Section 34, T13N-R10E, UM Bottom Hole Location: x State Lease ADL 25517 x 70’ FSL, 1,440 FEL x Section 31, T13N-R10E, UM Hilcorp submits this application to ensure compliance with 20 AAC 25.055(a)(1), which states “for a well drilling for oil, a wellbore may be open to test or regular production1 within 500 feet of a property line only if the owner is the same and the landowner is the same on both sides of the line.” 1 AS 31.05.170(14) “regular production” means continuing production of oil or gas from a well into production facilities and transportation to market, but does not include short term testing, evaluation, or experimental pilot production activities that have been approved by permit or order of the commission.” PO Box 244027 Anchorage, AK 99524-4027 3800 Centerpoint Drive, STE 1400 Anchorage, AK 99503 Phone: (907) 777-8341 Fax: (907) 777-8301 Email: jamie.wilson@hilcorp.com By Samantha Coldiron at 3:44 pm, Mar 04, 2025 Hilcorp Alaska, LLC Spacing Exception Milne Point Unit H-21 Well March 3, 2025 Page 2 of 6 The H-21 Well will be an injection well. In order to achieve maximum injectivity of the wellbore, Hilcorp intends to flow back this well for up to 60 days to fully clean out the wellbore to reduce the effect of near-wellbore damage caused by drilling fluid invasion which will ensure maximum injectivity. The initial flowback will consist mostly of drilling and completion fluids, including cuttings and other fine materials that will be flowed to tanks, transported offsite and disposed of in accordance with State regulations. Once the flowback has less than 0.5% solids, the flow stream will be sent to the Milne Point production facility to continue cleaning up. In order to prevent waste, Hilcorp intends to sell any oil processed and separated at the production facility. Hilcorp is not proposing to drill and complete this well as a producing oil well. Associated oil will only be “produced” for 60 days to ensure the wellbore is as clean as possible before commencing injection operations. The intent of this application is to allow Hilcorp to prevent waste that may occur as a result of its cleanup process by: 1. Ensuring a clean wellbore to achieve maximum injectivity. 2. Enhancing recovery of the offset production well which will be spaced between each injection well. 3. Avoid disposal of sales quality oil. Additionally, well spacing within the Schrader Bluff Oil Pool is governed by Rule 2 of Conservation Order 477a: Rule 2. Spacing (Revised by CO 477.005) There are no restrictions as to well spacing except that no pay shall be opened in a well closer than 500 feet from the exterior boundary of the affected area. The proposed H-21 Well operations target undrained reserves that cannot be reached by wells conforming to applicable spacing restrictions. Approval of short-term pre-production of the proposed H-21 Well allows for protection of its correlative rights by recovering the otherwise stranded reserves and ensures future maximum injectivity of the wellbore. Additionally, the correlative rights of all affected owners, landowners and operators will be protected and enhanced by the long-term support provided by the polymer injection. The proposed production well which will be drilled north of the H-21 Well, as shown on Exhibit “A”, will be further than 500 feet from the exterior boundary of the affected area and do not require a spacing exception approval. Hilcorp anticipates drilling operations of the H-21 Well to commence as soon as June 2025. As of the date of delivery of this application, and in accordance with 20 AAC 25.055(d)(1), notice of Hilcorp’s intent to drill the H-21 Well has been sent by certified mail to those certain owners, landowners, and operators of property within 1,000 feet of the well listed Hilcorp Alaska, LLC Spacing Exception Milne Point Unit H-21 Well March 3, 2025 Page 3 of 6 in Exhibit “B”. A copy of the notice and corresponding certified mailing receipts have been attached to this application. Pursuant to 20 AAC 25.055(d)(3), and attached as Exhibit “C”, is an affidavit executed by a person acquainted with all pertinent facts of this application and verifying that all facts set forth herein are true. It is requested that the Commission approve, by Administrative Approval, pursuant to 20 AAC 25.556(d), an exception to the well spacing for drilling the H-21 Well. If you require additional information or would like to have a technical meeting regarding this application, please contact Katie Cunha, Geologist, at (907) 564-4786, or me at (907) 777-8341 or by email at jamie.wilson@hilcorp.com. Sincerely, Jamie Wilson Sr. Landman Hilcorp Alaska, LLC cc: Heather Beat, Unit Manager, Division of Oil and Gas (via email) Ashley Ethridge, Unit Manager, Division of Oil and Gas (via email) Derek Nottingham, Director, Division of Oil and Gas (via email) Samantha Coldiron, Assistant, AOGCC (via email) Attachments: Exhibit “A”Map of Spacing Exception Well Exhibit “B”Notice List Exhibit “C”Affidavit Digitally signed by Jamie Wilson (2170) DN: cn=Jamie Wilson (2170) Date: 2025.03.03 14:37:56 - 09'00' Jamie Wilson (2170) Hilcorp Alaska, LLC Spacing Exception Milne Point Unit H-21 Well March 3, 2025 Page 4 of 6 EXHIBIT “A” APPLICATION FOR SPACING EXCEPTION Milne Point Unit H-21 Well Hilcorp Alaska, LLC Spacing Exception Milne Point Unit H-21 Well March 3, 2025 Page 5 of 6 EXHIBIT “B” APPLICATION FOR SPACING EXCEPTION Milne Point Unit H-21 Well Notice List Unit/Lease Landowner Owner Operator Kuparuk River Unit - ADL 025627 - ADL 025628 Department of Natural Resources Division of Oil & Gas 550 W. 7th Avenue, Ste. 1100 Anchorage, AK 99501-3560 Attn: Derek Nottingham, Director ConocoPhillips Alaska, Inc ATTN: Ryan King 700 G Street Anchorage, Alaska 99501 ConocoPhillips Alaska II, Inc ATTN: Ryan King 700 G Street Anchorage, Alaska 99501 ExxonMobil Alaska Production Inc. Attn: Justin Shuff 22777 Springwoods Village Pkwy Spring, Texas 77389 ConocoPhillips Alaska, Inc ATTN: Ryan King 700 G Street Anchorage, Alaska 99501 March 3, 2025 ConocoPhillips Alaska, Inc ATTN: Ryan King 700 G Street Anchorage, Alaska 99501 RE: Notice of Applications for Spacing Exception Milne Point Unit H-21 Injector Well Mr. King: Hilcorp Alaska, LLC (“Hilcorp”), as Operator of the Milne Point Unit, will be submitting to the Alaska Oil and Gas Conservation Commission (“AOGCC”) the enclosed Application for Spacing Exception to drill the above referenced well in the Schrader Bluff Oil Pool. Pursuant to 20 AAC 25.055(d)(1), all owners, landowners, and operators of all properties within 1,000 feet of a well drilling for oil for which an exception is sought must receive notice of such exception application. As an owner of certain property located within 1,000 feet of Hilcorp’s proposed well depicted on Exhibit “A”, please allow for this letter to serve as notice of Hilcorp’s intent to submit an Application for a Spacing Exception for the proposed operation, and its request for Administrative Approval from AOGCC. Should you require additional information regarding this application, please contact me by phone at (907) 777-8341 or by email at jamie.wilson@hilcorp.com. Sincerely, Jamie Wilson Sr. Landman Hilcorp Alaska, LLC PO Box 244027 Anchorage, AK 99524-4027 3800 Centerpoint Drive, STE 1400 Anchorage, AK 99503 Phone: (907) 777-8341 Fax: (907) 777-8301 Email: jamie.wilson@hilcorp.com March 3, 2025 ConocoPhillips Alaska II, Inc ATTN: Ryan King 700 G Street Anchorage, Alaska 99501 RE: Notice of Applications for Spacing Exception Milne Point Unit H-21 Injector Well Mr. King: Hilcorp Alaska, LLC (“Hilcorp”), as Operator of the Milne Point Unit, will be submitting to the Alaska Oil and Gas Conservation Commission (“AOGCC”) the enclosed Application for Spacing Exception to drill the above referenced well in the Schrader Bluff Oil Pool. Pursuant to 20 AAC 25.055(d)(1), all owners, landowners, and operators of all properties within 1,000 feet of a well drilling for oil for which an exception is sought must receive notice of such exception application. As an owner of certain property located within 1,000 feet of Hilcorp’s proposed well depicted on Exhibit “A”, please allow for this letter to serve as notice of Hilcorp’s intent to submit an Application for a Spacing Exception for the proposed operation, and its request for Administrative Approval from AOGCC. Should you require additional information regarding this application, please contact me by phone at (907) 777-8341 or by email at jamie.wilson@hilcorp.com. Sincerely, Jamie Wilson Sr. Landman Hilcorp Alaska, LLC PO Box 244027 Anchorage, AK 99524-4027 3800 Centerpoint Drive, STE 1400 Anchorage, AK 99503 Phone: (907) 777-8341 Fax: (907) 777-8301 Email: jamie.wilson@hilcorp.com March 3, 2025 ExxonMobil Alaska Production Inc. Attn: Justin Shuff 22777 Springwoods Village Pkwy Spring, Texas 77389 RE: Notice of Applications for Spacing Exception Milne Point Unit H-21 Injector Well Mr. Shuff: Hilcorp Alaska, LLC (“Hilcorp”), as Operator of the Milne Point Unit, will be submitting to the Alaska Oil and Gas Conservation Commission (“AOGCC”) the enclosed Application for Spacing Exception to drill the above referenced well in the Schrader Bluff Oil Pool. Pursuant to 20 AAC 25.055(d)(1), all owners, landowners, and operators of all properties within 1,000 feet of a well drilling for oil for which an exception is sought must receive notice of such exception application. As an owner of certain property located within 1,000 feet of Hilcorp’s proposed well depicted on Exhibit “A”, please allow for this letter to serve as notice of Hilcorp’s intent to submit an Application for a Spacing Exception for the proposed operation, and its request for Administrative Approval from AOGCC. Should you require additional information regarding this application, please contact me by phone at (907) 777-8341 or by email at jamie.wilson@hilcorp.com. Sincerely, Jamie Wilson Sr. Landman Hilcorp Alaska, LLC PO Box 244027 Anchorage, AK 99524-4027 3800 Centerpoint Drive, STE 1400 Anchorage, AK 99503 Phone: (907) 777-8341 Fax: (907) 777-8301 Email: jamie.wilson@hilcorp.com March 3, 2025 Department of Natural Resources Division of Oil & Gas 550 W. 7th Avenue, Ste. 1100 Anchorage, AK 99501-3560 Attn: Derek Nottingham, Director RE: Notice of Applications for Spacing Exception Milne Point Unit H-21 Injector Well Dear Mr. Nottingham: Hilcorp Alaska, LLC (Hilcorp), as Operator of the Milne Point Unit, will be submitting to the Alaska Oil and Gas Conservation Commission (AOGCC) the enclosed Application for Spacing Exception to drill the above referenced well in the Schrader Bluff Oil Pool. Pursuant to 20 AAC 25.055(d)(1), all owners, landowners, and operators of all properties within 1,000 feet of a well drilling for oil for which an exception is sought must receive notice of such exception application. As an owner of certain property located within 1,000 feet of Hilcorp’s proposed well depicted on Exhibit “A”, please allow for this letter to serve as notice of Hilcorp’s intent to submit an Application for a Spacing Exception for the proposed operation, and its request for Administrative Approval from AOGCC. Should you require additional information regarding this application, please contact me by phone at (907) 777-8341 or by email at jamie.wilson@hilcorp.com. Sincerely, Jamie Wilson Sr. Landman Hilcorp Alaska, LLC PO Box 244027 Anchorage, AK 99524-4027 3800 Centerpoint Drive, STE 1400 Anchorage, AK 99503 Phone: (907) 777-8341 Fax: (907) 777-8301 Email: jamie.wilson@hilcorp.com Certified Mail Tracking Spacing Exception Application Milne Point Unit H-21, H-31, H-41 and H-43 Large Envelope #1 # 9489017898203021009101 (ConocoPhillips Alaska, Inc and Conocophillips Alaska II, Inc Attn: Ryan King) Large Envelope #2 # 9489017898203021009118 (Department of Natural Resources Division of Oil & Gas Attn: Derek Nottingham) Large Envelope #3 # 9489017898203021009125 (ExxonMobil Alaska Production Inc. Attn: Justin Shuff) Large Envelope #4 # 9489017898203021009132 (Jessie Chmielowski, Commissioner Alaska Oil and Gas Conservation Commission) 3 Notice of Public Hearing STATE OF ALASKA ALASKA OIL AND GAS CONSERVATION COMMISSION RE: Docket Numbers: AIO-25-004 and CO-25-004 By applications dated February 4, 2025, Hilcorp Alaska, LLC (Hilcorp) requests that the Alaska Oil and Gas Conservation Commission (AOGCC) expand the map extent of the Schrader Bluff Oil Pool (SBOP), and its associated Area Injection Order, in and around the Milne Point Unit. Conservation Order No. 477A defines the SBOP and prescribes rules for its development. Area Injection Order (AIO) No. 10C prescribes rules for injecting fluids for enhanced recovery purposes into the SBOP. Hilcorp proposes to amend these orders to incorporate include the area covered by the Schrader Bluff Oil Pool, and its associated AIO, in the Nikaitchuq Unit to allow for unified operations of the SBOP. This notice does not contain all the information filed by Hilcorp. To obtain more information, contact the AOGCC’s Special Assistant, Samantha Coldiron, at (907) 793-1223 or samantha.coldiron@alaska.gov. A public hearing on the matter has been tentatively scheduled for April 3, 2025, at 10:00 a.m. The hearing, which may be changed to full virtual, if necessary, will be held in the AOGCC hearing room located at 333 West 7th Avenue, Anchorage, AK 99501. The audio call-in information is (907) 202-7104 Conference ID: 239 074 590#. Anyone who wishes to participate remotely using MS Teams video conference should contact Ms. Coldiron at least two business days before the scheduled public hearing to request an invitation for the MS Teams. To request that the tentatively scheduled hearing be held, a written request must be filed with the AOGCC no later than 4:30 p.m. on March 13, 2025. If a request for a hearing is not timely filed, the AOGCC may issue an order without a hearing. To learn if the AOGCC will hold the hearing, call (907) 793-1223 after March 14, 2025. In addition, written comments regarding this application may be submitted to the AOGCC, at 333 west 7th Avenue, Anchorage, AK 99501 or samantha.coldiron@alaska.gov. Comments must be received no later than 4:30 p.m. on March 28, 2025, except that, if a hearing is held, comments must be received no later than the conclusion of the April 3, 2025, hearing. If, because of a disability, special accommodations may be needed to comment or attend the hearing, contact Samantha Coldiron, at (907) 793-1223, no later than March 27, 2025. Jessie L. Chmielowski Gregory C. Wilson Commissioner Commissioner Jessie L. Chmielowski Digitally signed by Jessie L. Chmielowski Date: 2025.02.24 09:35:55 -09'00' Gregory C. Wilson Digitally signed by Gregory C. Wilson Date: 2025.02.24 11:04:10 -09'00' From:Coldiron, Samantha J (OGC) To:AOGCC_Public_Notices Subject:[AOGCC_Public_Notices] Public Hearing Notice (Hilcorp) Date:Monday, February 24, 2025 11:40:18 AM Attachments:AIO-25-004 and CO-25-004 Public Hearing Notice MPU SBOP Expansion.pdf Docket Numbers: AIO-25-004 and CO-25-004 By applications dated February 4, 2025, Hilcorp Alaska, LLC (Hilcorp) requests that the Alaska Oil and Gas Conservation Commission (AOGCC) expand the map extent of the Schrader Bluff Oil Pool (SBOP), and its associated Area Injection Order, in and around the Milne Point Unit. Samantha Coldiron AOGCC Special Assistant Alaska Oil and Gas Conservation Commission 333 West 7th Avenue Anchorage, AK 99501 (907) 793-1223 __________________________________ List Name: AOGCC_Public_Notices@list.state.ak.us You subscribed as: samantha.coldiron@alaska.gov Unsubscribe at: https://list.state.ak.us/mailman/options/aogcc_public_notices/samantha.coldiron%40alaska.go v Lisi Misa being first duly sworn on oath deposes and says that she is a representative of the An- chorage Daily News, a daily newspaper. That said newspaper has been approved by the Third Judicial Court, Anchorage, Alaska, and it now and has been published in the English language continually as a daily newspaper in Anchorage, Alaska, and it is now and during all said time was printed in an office maintained at the afore- said place of publication of said newspaper. That the annexed is a copy of an advertisement as it was published in regular issues (and not in supplemental form) of said newspaper on AFFIDAVIT OF PUBLICATION ______________________________________ Notary Public in and for The State of Alaska. Third Division Anchorage, Alaska MY COMMISSION EXPIRES ______________________________________ 02/26/2025 and that such newspaper was regularly distrib- uted to its subscribers during all of said period. That the full amount of the fee charged for the foregoing publication is not in excess of the rate charged private individuals. Signed________________________________ Subscribed and sworn to before me Account #: 100869 ST OF AK/AK OIL AND GAS CONSERVATION COMMISSION333 W. 7TH AVE STE 100, ANCHORAGE, AK 99501 Order #: W0051017 Cost: $319.93 Notice of Public HearingSTATE OF ALASKAALASKA OIL AND GAS CONSERVATION COMMISSION RE: Docket Numbers: AIO-25-004 and CO-25-004 By applications dated February 4, 2025, Hilcorp Alaska, LLC (Hilcorp) requests that the Alaska Oil and Gas Conservation Commission (AOGCC) expand the map extent of the Schrader Bluff Oil Pool (SBOP), and its associated Area Injection Order, in and around the Milne Point Unit. Conservation Order No. 477A defines the SBOP and prescribes rules for its development. Area Injection Order (AIO) No. 10C prescribes rules for injecting fluids for enhanced recovery purposes into the SBOP. Hilcorp proposes to amend these orders to incorporate include the area covered by the Schrader Bluff Oil Pool, and its associated AIO, in the Nikaitchuq Unit to allow for unified operations of the SBOP. This notice does not contain all the information filed by Hilcorp. To obtain more information, contact the AOGCC’s Special Assistant, Samantha Coldiron, at (907) 793-1223 or samantha.coldiron@ alaska.gov. A public hearing on the matter has been tentatively scheduled for April 3, 2025, at 10:00 a.m. The hearing, which may be changed to full virtual, if necessary, will be held in the AOGCC hearing room located at 333 West 7th Avenue, Anchorage, AK 99501. The audio call-in information is (907) 202-7104 Conference ID: 239 074 590#. Anyone who wishes to participate remotely using MS Teams video conference should contact Ms. Coldiron at least two business days before the scheduled public hearing to request an invitation for the MS Teams. To request that the tentatively scheduled hearing be held, a written request must be filed with the AOGCC no later than 4:30 p.m. on March 13, 2025. If a request for a hearing is not timely filed, the AOGCC may issue an order without a hearing. To learn if the AOGCC will hold the hearing, call (907) 793-1223 after March 14, 2025. In addition, written comments regarding this application may be submitted to the AOGCC, at 333 west 7th Avenue, Anchorage, AK 99501 or samantha.coldiron@alaska.gov. Comments must be received no later than 4:30 p.m. on March 28, 2025, except that, if a hearing is held, comments must be received no later than the conclusion of the April 3, 2025, hearing. If, because of a disability, special accommodations may be needed to comment or attend the hearing, contact Samantha Coldiron, at (907) 793-1223, no later than March 27, 2025. Jessie L. Chmielowski Gregory C. Wilson Commissioner Commissioner Pub: Fab. 26, 2025 STATE OF ALASKA THIRD JUDICIAL DISTRICT ______________________________________2025-04-04 2029-01-23 Document Ref: 9OCHJ-CFDK6-5F6LY-YVS5G Page 19 of 25 2 February 4, 2025 Jessie Chmielowski, Commissioner Alaska Oil and Gas Conservation Commission 333 West 7th Avenue, Suite 100 Anchorage, Alaska 99501 RE: Application for Expansion of Conservation Order 477a Schrader Bluff Oil Pool Milne Point Field Nikaitchuq Field Commissioner Chmielowski: Hilcorp Alaska, LLC (“Hilcorp”), as Operator of the Milne Point Unit, hereby submits this application to expand the Affected Area of the Milne Point Schrader Bluff Oil Pool (“SBOP”) as described in Conservation Order 477a (“CO 477a”) to include the Nikaitchuq Field. Proposed Affected Area Expansion Hilcorp requests to expand the Affected Area of CO 477a to include 21,228.6 acres, more or less, of additional lands within the Nikaitchuq Unit (“Expansion Area”) as depicted on Figure 1. The Nikaitchuq Schrader Bluff Oil Pool is currently governed by Conservation Order No. 639 (“CO 639”). This application requests that CO 639 be superseded in its entirety and CO 477a be amended to include the following Expansion Area. Additionally, we request to keep the following orders active: CO 639.001 and 639.002. CO 477a proposed Expansion Area: Lease Number Description Township 14N., Range 9 E., Umiat Meridian, Alaska. ADL 388581 Section 5, Protracted, All tide and submerged lands; (Nikaitchuq Unit, Tract 4) Section 6, Protracted, All tide and submerged lands; Section 7, Protracted, All tide and submerged lands; Section 8, Protracted, All tide and submerged lands; Township 14N., Range 9 E., Umiat Meridian, Alaska. ADL 388583 Section 17, Unsurveyed, All tide and submerged lands; (Nikaitchuq Unit, Tract 7) Section 18, Unsurveyed, All tide and submerged lands; Section 20, Protracted, All tide and submerged lands; Post Office Box 244027 Anchorage, AK 99524-4027 3800 Centerpoint Drive Suite 1400 Anchorage, AK 99503 Phone: (907) 777-8341 Fax: (907) 777-8301 Email: jamie.wilson@hilcorp.com Hilcorp Alaska, LLC Application for Expansion of CO 477a Schrader Bluff Oil Pool February 4, 2025 Page 2 of 9 Township 14N., Range 9 E., Umiat Meridian, Alaska, Tract A Section 17, Unsurveyed, All Uplands; Section 18, Unsurveyed, All Uplands; Township 14N., Range 9 E., Umiat Meridian, Alaska. ADL 388582 Section 16, Unsurveyed, All tide and submerged lands; (Nikaitchuq Unit, Tract 8) Section 21, Unsurveyed, All tide and submerged lands; Township 14N., Range 9 E., Umiat Meridian, Alaska, Tract A Section 16, Unsurveyed, All Uplands; Section 21, Unsurveyed, All Uplands; Township 14N., Range 9 E., Umiat Meridian, Alaska. ADL 390615 Section 28, Protracted, All; (Nikaitchuq Unit, Tract 9) Section 33, Protracted, All; Township 14N., Range 9 E., Umiat Meridian, Alaska. ADL 390616 Section 29, Protracted, All; (Nikaitchuq Unit, Tract 10) Section 32, Protracted, All; Township 14N., Range 8 E., Umiat Meridian, Alaska. ADL 388571 Section 1, Protracted, All tide and submerged lands; (Nikaitchuq Unit, Tract 11) Section 2, Protracted, All tide and submerged lands within the computed territorial sea, listed as "State Acreage" on Alaska's seaward boundary diagram approved by the State on April 15, 1996; Section 11, Protracted, All tide and submerged lands; Section 12, Protracted, All tide and submerged lands; Township 15N., Range 8 E., Umiat Meridian, Alaska. Section 35, Protracted, All tide and submerged lands within the computed territorial sea, listed as "State Acreage" on Alaska's seaward boundary diagram approved by the State on April 15, 1996; Section 36, Protracted, All tide and submerged lands within the computed territorial sea, listed as "State Acreage" on Alaska's seaward boundary diagram approved by the State on April 15, 1996; Hilcorp Alaska, LLC Application for Expansion of CO 477a Schrader Bluff Oil Pool February 4, 2025 Page 3 of 9 Township 14N., Range 8 E., Umiat Meridian, Alaska. ADL 388572 Section 3, Protracted, All tide and submerged lands within the computed territorial sea, listed as "State Acreage" on Alaska's seaward boundary diagram approved by the State on April 15, 1996; Section 4, Protracted, All tide and submerged lands within the computed territorial sea, listed as "State Acreage" on Alaska's seaward boundary diagram approved by the State on April 15, 1996; (Nikaitchuq Unit, Tract 12) Section 9, Protracted, All tide and submerged lands; Section 10, Protracted, All tide and submerged lands; Township 15N., Range 8 E., Umiat Meridian, Alaska. Section 33, Protracted, All tide and submerged lands within the computed territorial sea, listed as "State Acreage" on Alaska's seaward boundary diagram approved by the State on April 15, 1996; Township 14N., Range 8 E., Umiat Meridian, Alaska. ADL 388574 Section 13, Protracted, All tide and submerged lands; (Nikaitchuq Unit, Tract 14) Section 14, Protracted, All tide and submerged lands; Section 23, Protracted, All tide and submerged lands; Township 14N., Range 8 E., Umiat Meridian, Alaska. ADL 388575 Section 15, Protracted, All tide and submerged lands; (Nikaitchuq Unit, Tract 15) Section 22, Protracted, All tide and submerged lands; Township 14N., Range 8 E., Umiat Meridian, Alaska. ADL 388577 Section 26, Protracted, All tide and submerged lands; (Nikaitchuq Unit, Tract 16) Section 35, Protracted, All tide and submerged lands; Township 14N., Range 8 E., Umiat Meridian, Alaska. ADL 391283 Section 24, Protracted All (Nikaitchuq Unit, Tract 18A & 18B) Section 25, Protracted, All; Section 36, Protracted, All; Township 14N., Range 9 E., Umiat Meridian, Alaska. Section 19, Protracted All Section 30, Protracted, All; Section 31, Protracted, All; Hilcorp Alaska, LLC Application for Expansion of CO 477a Schrader Bluff Oil Pool February 4, 2025 Page 4 of 9 Development Drilling Plans and Geology The proposed expansion of the SBOP to cover the Nikaitchuq Unit, operated by Hilcorp, would allow for further development of the Schrader Bluff reservoir from the Milne Point Raven-Pad into the Nikaitchuq Unit, beginning as soon as April 2025. Figure 2 depicts the location of the proposed Schrader Bluff Oa Drill Wells from the Milne Point Raven Pad. Blue lines indicate injectors, while green lines are producers. Well data within the proposed Expansion Area shows that the Schrader Bluff is structurally continuous across the Nikaitchuq and Milne Point Units. Hilcorp has submitted confidential seismic data to the Commission (Figure 3) depicting a seismic cross section and Type Wells through the Nikaitchuq Unit (West to East) and the Milne Point Unit (Northwest to Southeast). Reviewing this internal seismic data gives Hilcorp high confidence that the Schrader Bluff formation is a continuously mappable seismic horizon. Figure 3.1, marked as confidential, depicts the shared lease line between the Nikaitchuq Unit, Milne Point Unit, and the known Schrader Bluff OA Sand Well Tops. The well control and mappable fluid contact also indicate that the Schrader Bluff is structurally continuous across the units. As of the date of delivery of this application, and in accordance with 20 AAC 25.055(d)(1), notice of Hilcorp’s proposal to expand the Affected Area of CO 477a has been sent by certified mail to those certain owners, landowners, and operators of property within 1,000 feet of the proposed Expansion Area listed in Exhibit “A”. A copy of the notice and corresponding certified mailing receipts have been attached to this application. Pursuant to 20 AAC 25.055(d)(3), and attached as Exhibit “B”, is an affidavit executed by a person acquainted with all pertinent facts of this application and verifying that all facts set forth herein are true. It is requested that the Commission schedule a public hearing to review Hilcorp’s application for expansion of the SBOP in accordance with 20 AAC 25.540. Should you require additional information regarding this application, please contact me by phone at (907) 777-8341 or by email at jamie.wilson@hilcorp.com. Hilcorp Alaska, LLC Application for Expansion of CO 477a Schrader Bluff Oil Pool February 4, 2025 Page 5 of 9 Sincerely, Jamie Wilson Sr. Landman Hilcorp Alaska, LLC cc: Samantha Carlisle, Assistant, AOGCC (via email) Heather Beat, Unit Manager, State of Alaska, DNR (via email) Ashley Ethridge, Unit Manager, State of Alaska, DNR (via email) Derek Nottingham, Director, Division of Oil and Gas (via email) Hilcorp Alaska, LLC Application for Expansion of CO 477a Schrader Bluff Oil Pool February 4, 2025 Page 6 of 9 FIGURE 1. Affected Area defined in CO 477a with proposed Expansion Area lands. Hilcorp Alaska, LLC Application for Expansion of CO 477a Schrader Bluff Oil Pool February 4, 2025 Page 7 of 9 FIGURE 2. Proposed future Schrader Bluff drill wells from Raven Pad to the Nikaitchuq Unit. Hilcorp Alaska, LLC Application for Expansion of CO 477a Schrader Bluff Oil Pool February 4, 2025 Page 8 of 9 EXHIBIT “A” APPLICATION FOR EXPANSION OF CO 477a SCHRADER BLUFF OIL POOL Unit/Lease Landowner Owner Operator Kuparuk River Unit - ADL 355030 - ADL 355024 - ADL 355023 Department of Natural Resources Division of Oil & Gas 550 W. 7th Avenue, Ste. 1100 Anchorage, AK 99501-3560 Attn: Derek Nottingham, Director ConocoPhillips Alaska, Inc ATTN: Ryan King 700 G Street Anchorage, Alaska 99501 ConocoPhillips Alaska II, Inc ATTN: Ryan King 700 G Street Anchorage, Alaska 99501 ExxonMobil Alaska Production Inc. Attn: Melonnie Amundson P.O. Box 196601 Anchorage, AK 99519 ConocoPhillips Alaska, Inc 700 G Street Anchorage, Alaska 99501 1 February 4, 2025 Jessie Chmielowski, Commissioner Alaska Oil and Gas Conservation Commission 333 West 7th Avenue, Suite 100 Anchorage, Alaska 99501 RE: Application for Expansion of Conservation Order 477a Schrader Bluff Oil Pool Milne Point Field Nikaitchuq Field Commissioner Chmielowski: Hilcorp Alaska, LLC (“Hilcorp”), as Operator of the Milne Point Unit, hereby submits this application to expand the Affected Area of the Milne Point Schrader Bluff Oil Pool (“SBOP”) as described in Conservation Order 477a (“CO 477a”) to include the Nikaitchuq Field. Proposed Affected Area Expansion Hilcorp requests to expand the Affected Area of CO 477a to include 21,228.6 acres, more or less, of additional lands within the Nikaitchuq Unit (“Expansion Area”) as depicted on Figure 1. The Nikaitchuq Schrader Bluff Oil Pool is currently governed by Conservation Order No. 639 (“CO 639”). This application requests that CO 639 be superseded in its entirety and CO 477a be amended to include the following Expansion Area. Additionally, we request to keep the following orders active: CO 639.001 and 639.002. CO 477a proposed Expansion Area: Lease Number Description Township 14N., Range 9 E., Umiat Meridian, Alaska. ADL 388581 Section 5, Protracted, All tide and submerged lands; (Nikaitchuq Unit, Tract 4) Section 6, Protracted, All tide and submerged lands; Section 7, Protracted, All tide and submerged lands; Section 8, Protracted, All tide and submerged lands; Township 14N., Range 9 E., Umiat Meridian, Alaska. ADL 388583 Section 17, Unsurveyed, All tide and submerged lands; (Nikaitchuq Unit, Tract 7) Section 18, Unsurveyed, All tide and submerged lands; Section 20, Protracted, All tide and submerged lands; Post Office Box 244027 Anchorage, AK 99524-4027 3800 Centerpoint Drive Suite 1400 Anchorage, AK 99503 Phone: (907) 777-8341 Fax: (907) 777-8301 Email: jamie.wilson@hilcorp.com Hilcorp Alaska, LLC Application for Expansion of CO 477a Schrader Bluff Oil Pool February 4, 2025 Page 2 of 9 Township 14N., Range 9 E., Umiat Meridian, Alaska, Tract A Section 17, Unsurveyed, All Uplands; Section 18, Unsurveyed, All Uplands; Township 14N., Range 9 E., Umiat Meridian, Alaska. ADL 388582 Section 16, Unsurveyed, All tide and submerged lands; (Nikaitchuq Unit, Tract 8) Section 21, Unsurveyed, All tide and submerged lands; Township 14N., Range 9 E., Umiat Meridian, Alaska, Tract A Section 16, Unsurveyed, All Uplands; Section 21, Unsurveyed, All Uplands; Township 14N., Range 9 E., Umiat Meridian, Alaska. ADL 390615 Section 28, Protracted, All; (Nikaitchuq Unit, Tract 9) Section 33, Protracted, All; Township 14N., Range 9 E., Umiat Meridian, Alaska. ADL 390616 Section 29, Protracted, All; (Nikaitchuq Unit, Tract 10) Section 32, Protracted, All; Township 14N., Range 8 E., Umiat Meridian, Alaska. ADL 388571 Section 1, Protracted, All tide and submerged lands; (Nikaitchuq Unit, Tract 11) Section 2, Protracted, All tide and submerged lands within the computed territorial sea, listed as "State Acreage" on Alaska's seaward boundary diagram approved by the State on April 15, 1996; Section 11, Protracted, All tide and submerged lands; Section 12, Protracted, All tide and submerged lands; Township 15N., Range 8 E., Umiat Meridian, Alaska. Section 35, Protracted, All tide and submerged lands within the computed territorial sea, listed as "State Acreage" on Alaska's seaward boundary diagram approved by the State on April 15, 1996; Section 36, Protracted, All tide and submerged lands within the computed territorial sea, listed as "State Acreage" on Alaska's seaward boundary diagram approved by the State on April 15, 1996; Hilcorp Alaska, LLC Application for Expansion of CO 477a Schrader Bluff Oil Pool February 4, 2025 Page 3 of 9 Township 14N., Range 8 E., Umiat Meridian, Alaska. ADL 388572 Section 3, Protracted, All tide and submerged lands within the computed territorial sea, listed as "State Acreage" on Alaska's seaward boundary diagram approved by the State on April 15, 1996; Section 4, Protracted, All tide and submerged lands within the computed territorial sea, listed as "State Acreage" on Alaska's seaward boundary diagram approved by the State on April 15, 1996; (Nikaitchuq Unit, Tract 12) Section 9, Protracted, All tide and submerged lands; Section 10, Protracted, All tide and submerged lands; Township 15N., Range 8 E., Umiat Meridian, Alaska. Section 33, Protracted, All tide and submerged lands within the computed territorial sea, listed as "State Acreage" on Alaska's seaward boundary diagram approved by the State on April 15, 1996; Township 14N., Range 8 E., Umiat Meridian, Alaska. ADL 388574 Section 13, Protracted, All tide and submerged lands; (Nikaitchuq Unit, Tract 14) Section 14, Protracted, All tide and submerged lands; Section 23, Protracted, All tide and submerged lands; Township 14N., Range 8 E., Umiat Meridian, Alaska. ADL 388575 Section 15, Protracted, All tide and submerged lands; (Nikaitchuq Unit, Tract 15) Section 16, Protracted, All tied and submerged lands; Section 21, Protracted, All tide and submerged lands; Section 22, Protracted, All tide and submerged lands; Township 14N., Range 8 E., Umiat Meridian, Alaska. ADL 388577 Section 26, Protracted, All tide and submerged lands; (Nikaitchuq Unit, Tract 16) Section 35, Protracted, All tide and submerged lands; Township 14N., Range 8 E., Umiat Meridian, Alaska. ADL 391283 Section 24, Protracted All (Nikaitchuq Unit, Tract 18A & 18B) Section 25, Protracted, All; Section 36, Protracted, All; Township 14N., Range 9 E., Umiat Meridian, Alaska. Section 19, Protracted All Section 30, Protracted, All; Hilcorp Alaska, LLC Application for Expansion of CO 477a Schrader Bluff Oil Pool February 4, 2025 Page 4 of 9 Section 31, Protracted, All; Development Drilling Plans and Geology The proposed expansion of the SBOP to cover the Nikaitchuq Unit, operated by Hilcorp, would allow for further development of the Schrader Bluff reservoir from the Milne Point Raven-Pad into the Nikaitchuq Unit, beginning as soon as April 2025. Figure 2 depicts the location of the proposed Schrader Bluff Oa Drill Wells from the Milne Point Raven Pad. Blue lines indicate injectors, while green lines are producers. Well data within the proposed Expansion Area shows that the Schrader Bluff is structurally continuous across the Nikaitchuq and Milne Point Units. Hilcorp has submitted confidential seismic data to the Commission (Figure 3) depicting a seismic cross section and Type Wells through the Nikaitchuq Unit (West to East) and the Milne Point Unit (Northwest to Southeast). Reviewing this internal seismic data gives Hilcorp high confidence that the Schrader Bluff formation is a continuously mappable seismic horizon. Figure 3.1, marked as confidential, depicts the shared lease line between the Nikaitchuq Unit, Milne Point Unit, and the known Schrader Bluff OA Sand Well Tops. The well control and mappable fluid contact also indicate that the Schrader Bluff is structurally continuous across the units. As of the date of delivery of this application, and in accordance with 20 AAC 25.055(d)(1), notice of Hilcorp’s proposal to expand the Affected Area of CO 477a has been sent by certified mail to those certain owners, landowners, and operators of property within 1,000 feet of the proposed Expansion Area listed in Exhibit “A”. A copy of the notice and corresponding certified mailing receipts have been attached to this application. Pursuant to 20 AAC 25.055(d)(3), and attached as Exhibit “B”, is an affidavit executed by a person acquainted with all pertinent facts of this application and verifying that all facts set forth herein are true. It is requested that the Commission schedule a public hearing to review Hilcorp’s application for expansion of the SBOP in accordance with 20 AAC 25.540. Should you require additional information regarding this application, please contact me by phone at (907) 777-8341 or by email at jamie.wilson@hilcorp.com. Hilcorp Alaska, LLC Application for Expansion of CO 477a Schrader Bluff Oil Pool February 4, 2025 Page 5 of 9 Sincerely, Jamie Wilson Sr. Landman Hilcorp Alaska, LLC cc: Samantha Carlisle, Assistant, AOGCC (via email) Heather Beat, Unit Manager, State of Alaska, DNR (via email) Ashley Ethridge, Unit Manager, State of Alaska, DNR (via email) Derek Nottingham, Director, Division of Oil and Gas (via email) Digitally signed by Jamie Wilson (2170) DN: cn=Jamie Wilson (2170) Date: 2025.02.11 11:48:49 - 09'00' Jamie Wilson (2170) Hilcorp Alaska, LLC Application for Expansion of CO 477a Schrader Bluff Oil Pool February 4, 2025 Page 6 of 9 FIGURE 1. Affected Area defined in CO 477a with proposed Expansion Area lands. Hilcorp Alaska, LLC Application for Expansion of CO 477a Schrader Bluff Oil Pool February 4, 2025 Page 7 of 9 FIGURE 2. Proposed future Schrader Bluff drill wells from Raven Pad to the Nikaitchuq Unit. Hilcorp Alaska, LLC Application for Expansion of CO 477a Schrader Bluff Oil Pool February 4, 2025 Page 8 of 9 EXHIBIT “A” APPLICATION FOR EXPANSION OF CO 477a SCHRADER BLUFF OIL POOL Unit/Lease Landowner Owner Operator Kuparuk River Unit - ADL 355030 - ADL 355024 - ADL 355023 Department of Natural Resources Division of Oil & Gas 550 W. 7th Avenue, Ste. 1100 Anchorage, AK 99501-3560 Attn: Derek Nottingham, Director ConocoPhillips Alaska, Inc ATTN: Ryan King 700 G Street Anchorage, Alaska 99501 ConocoPhillips Alaska II, Inc ATTN: Ryan King 700 G Street Anchorage, Alaska 99501 ExxonMobil Alaska Production Inc. Attn: Melonnie Amundson P.O. Box 196601 Anchorage, AK 99519 ConocoPhillips Alaska, Inc 700 G Street Anchorage, Alaska 99501 Digitally signed by Jamie Wilson (2170) DN: cn=Jamie Wilson (2170) Date: 2025.02.11 11:49:06 - 09'00' Jamie Wilson (2170)