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HomeMy WebLinkAboutO 041 ) ) Image Project Order File Cover Page XHVZE This page identifies those items that were not scanned during the initial production scanning phase. They are available in the original file, rnay be scanned during a special rescan activity or are viewable by direct inspection of the file. o 0 41 Order File Identifier Organizing (done) o Two-sided 1I111III11111111111 o Rescan Needed 1111111111111111111 RESCAN DIGITAL DATA OVERSIZED (Scannable) o Maps: o Other Items Scannable by a Large Scanner o Color Items: o Greyscale Items: o Diskettes, No. D Other, No/Type: o Poor Quality Originals: OVERSIZED (Non-Scannable) o Other: o Logs of various kinds: NOTES: . BY: ~ Date tr, 7 lob o Other:: Isl ynp Project Proofing BY: G Maria. J II BY: r; Mari~ ) Date: Lf 7 Db , X 30 = Date: Lt.' 7 / ó (-; + ynp = TOTAL PAGES 0 q (Count does not include cover sr eet) M,P Isl II r /s/ Scanning Preparation Production Scanning 1111111111111111111 Stage 1 Page Count from Scanned File: 00 (Count does include cover sheet) " I V YES NO Page Count Matches Number in Scanning Preparation: BY ~ Date: 4-, 7 jtJ& Stage 1 If NO in stage 1 page(s) discrepancies were found: YES /s/ VV\p NO BY: Maria Date: Isl 1111111111111111111 Scanning is complete at this point unless rescanning is required. ReScanned 111111111111111111 BY: Maria Date: /s/ Comments about this file: Quality Checked I111I11111111111111 10/6/2005 Orders File Cover Page.doc e e Index Other 41 Regulation Package Redrilling, well branches and plugging 1. June 7, 2005 2. August 5, 2005 mailing list 3. August 5, 2005 Request file opening 4. August 12,2005 AGO's filing opening 5. August 23,2005 Public members request for accommodation for hearing 6. August 31, 2005 AOGCC response to public members request 7. September 6, 2005 Sign in Sheet 8. September 6,2005 Transcript 9. September 13,2005 AOGA's comments of regulation change 10. September 21,2005 Letter from Pubic Member 11. November 8, 2005 Regulation package submitted to AGO 12. December 6,2005 Memo from AGO to AOGCC re: submission of regulation package to the Lt. Governor's office for signature 13. December 13,2005 Post Notice and Final, Final regulation AGO's review of regulation Notice of Hearing, Affidavit of Publication, bulk/e-mail Other 41 9/1;)' 13 ANCHORAGE '-- Commission updates drilling permit terms The Alaska Oil and Gas Conservation Commission is amending its regulations to recognize the existence of multi-lateral wells: wells with concurrent production from more than one well branch. The change includes amending the defmition of well branch to include drilling below the conductor casing to access more than one objective, or when an initial bottomhole location is changed by plugging back and rcdrilling. Pennit to d~iII requirements are also being amend- ed to distinguish between a plug-back-and-redrill well branch and concurrent multiple well branches. At a Sept. 6 hearing Winton Aubert, a petroleum engineer on the commission's staff, said the staff has been identifYing poten- tial gaps in the agency's regulations and ambiguities in some tenns. Aubert said in a case where one well path has been plugged and another well path drilled from the same bore, but they are not active at the same time, the second well path is commonly called a sidetrack. In the case where "there are two or more well paths away from a given well bore· which are active concurrently, those well paths are commonly called laterals. "" u '" >- « 0- >- C> => Judy Brady, execu- tive director of the Alaska Oil and Gas Association Tenninology standardized What the commission is proposing, Aubert said, is to standardize the terminology: every well path would be called a well branch. Assistant Attorney General Rob Mintz said there is also another issue: a plug back has been referred to as an abandonment, which is not consistent with the commission's regulations because it implies that the entire well has been plugged and abandoned. Under the proposed changes, he said, this is clarified to specifY that it is a well branch which will be plugged. Judy Brady, executive director of the Alaska Oil and Gas Association, said AOGA's task group for AOGCC reviewed the proposed regulations. The amendments "provide clarity in pennitting proposed drilling locations and provide a clear definition of a 'well branch'." Brady also said the amendments do not change the current process for drilling pennits and do not additionally burden operators. Commission Chainnan John Noonan asked if changes in tcchnology were a factor in these amendments, and Aubert said that when the commission last revised its regu- lations industry was not drilling multi-lateral wells. Five well branches are active in one North Slope well, Aubert said, the maximum for Alaska and also for the industry worldwide. -KRISTEN NELSON -------- #13 · ., Oil and Gas Conservation Changes have been adopted to the regulations dealing with well branches, applications for a permit to drill, changes in a drilling program, and redrilling a well. The affected regulations are 20 AAC 25.005(e), 20 AAC 25.015(a)(I) and (b)(1), and 20 AAC 25.990(74). The Lieutenant Governor filed the regulation changes on December 6, 2005, with an effective date of January 5, 2006. For further information or to obtain a copy ofthe amended regulations, contact Jody Colombie, Alaska Oil and Gas Conservation Commission, at (907) 793-1221, fax (907) 276-7542, or e-mail JodyColombie(a).admin.state.ak.us. Register _, '0 MISCELLANEOUS lARDS 20 AAC 25.005(e) is amended to read: (e) EACH [IF A] WELL [HAS MULTIPLE WELL BRANCHES, EACH] branch requires a separate Permit to Drill. If a previouslv drilled well is proposed to be redrilled below the structural or conductor casin!! to a new bottom-hole location, the application for a Permit to Drill must be accompanied bv all items required under (c) ofthis section. If concurrent multiple well branches are proposed from a single conductor, surface, or production casing, ill the applicant shall designate one well branch as the primary wellbore and include all items [INFORMATION] required under (c) of this section with the application for a Permit to Drill for that well branch: and [.] (2) for [FOR] each other [SUBSEQUENT] well branch, the application for a Permit to Drill need only include information under (c) of this section that is unique to that well branch and need not be accompanied bv [INCLUDE] the $100 fee. (Eff. 4/13/80, Register 74; am 4/2/86, Register 97; am 11/7/99, Register 152; am 6/4/2000, Register 154; am / / -- , Register _) Authority: AS 31.05.030 AS 31.05.090 20 AAC 25.0l5(a)(l) is amended to read: (1) submit and obtain the commission's approval of a new application for a Permit to Drill if the proposed surface location is changed, if the proposed bottom-hole location or the proposed location of an objective formation is changed by more than 500 feet laterally or vertically, or if the change requires a spacing exception under 20 AAC 25.055; however, no additional fee is required; or 20 AAC 25.0l5(b)(l) is amended to read: (1) submit and obtain the commission's approval of a new application for a Permit to Drill, accompanied by a fee of $1 00, if the proposed bottom-hole location or the proposed location of an 1 Register _, '0 MISCELLANEOUS.ARDS objective formation is changed by more than 500 feet laterally or vertically, or if the change requires a spacing exception under 20 AAC 25.055; or (Eff. 4/13/80, Register 74; am 4/2/86, Register 97; am 11/7/99, Register 152; am ---.!---.! Register -> Authority: AS 31.05.030 AS 31.05.090 20 AAC 25.990(74) is amended to read: (74) "well branch" means that portion of a well drilled below the structural or conductor casing to access a e:iven [SEP ARA TE] objective in a well with more than one bottom-hole location or whose bottom-hole location is beine: or has been chane:ed bv plue:e:ine: back and redrillin2; (Eff. 11/7/99, Register 152; am, ---.!---.! Authority: AS 31.05.030 , Register -> 2 #12 . . MEMORANDUM State of Alaska Department of Law TO: John K. Nonnan, Chair Alaska Oil and Gas Conservation Commission DATE: December 6, 2005 RECEIVED DEC n 2005 FILE NO.: 993-06-0055 TELEPHONE NO.: 465-3600 FROM: ,{ C r~"i Steven C. W eaver--=><l,-~/>{"''''''' Assistant Attorney General Legislation!Regulations Section--Juneau SUBJECT: Regulations re: pennits to and well branches (20 AAC 25.005(e); 20 AAC 25.015(a)(1), (b)(l); 20 AAC 25.990(74)) Under AS 44.62.060, we have reviewed the attached amendment of these regulations by the Alaska Oil and Gas Conservation Commission, and approve the changes for filing by the lieutenant governor. I have reviewed this project under a specific delegation dated December 5, 2005 from the Regulations Attorney. A duplicate original of this memorandum is being furnished to the lieutenant governor, along with the two pages of regulations and the related documents. You might wish to contact the lieutenant governor's office to confinn the filing date and effective date of the attached regulation changes. The August 5, 2005 public notice and the November 8, 2005 certification order both state that this action is not expected to require an increased appropriation. Therefore, a fiscal note under AS 44.62.195 is not required. In accordance with AS 44.62. 125(b)(6), some corrections have been made III the regulations, as shown on the attached copy. SCW cc w/enc: Mike Tibbles, Deputy Commissioner & Regulations Contact Department of Administration Robert E. Mintz Assistant Attorney General Oil, Gas & Mining Section--Anchorage . . MEMORANDUM State of Alaska Department of Law TO: Hon. Loren Leman Lieutenant Governor DATE: December 6, 2005 FILE NO.: 993-06-0055 TELEPHONE NO.: 465-3600 FROM: -.......... V r ("}''', 'r"' Steven C. Weaver _,X\ ~ Assistant Attorney General LegislationlRegulations Section--Juneau SUBJECT: Regulations re: permits to drill and well branches (20 AAC 25.005(e); 20 AAC 25.015(a)(1), (b)(1); 20 AAC 25.990(74)) We have reviewed the attached regulations from the Alaska Oil and Gas Conservation Commission. I have reviewed this project under a specific delegation dated November 5, 2005 from the Regulations Attorney. A duplicate of this memorandum is being furnished to John K. Norton, the commission chair, along with a copy of the regulations. The Department of Law has reviewed the attached regulations against the statutory standards of the Administrative Procedure Act. Based upon our review, we find no legal problems. This memorandum and the attached duplicate memorandum dated December 6, 2005 constitute the written statement of approval under AS 44.62.060(b) and (c) that authorizes your office to file the attached regulations. The regulation changes were adopted by the Alaska Oil and Gas Conservation Commission after the close of the public comment period. The regulations refine provisions pertaining to permits to drill and well branches. The certification order for the regulations states that this action is not expected to require an increased appropriation. Therefore, a fiscal note under AS 44.62.195 is not required. We have made a few technical corrections to confoffil the regulations with the drafting manual under AS 44.62.060 and 44.62.125. The corrections are shown on the attached copy of the regulations. SCW cc w/enc: John K. Norman, Chair Alaska Oil and Gas Conservation Commission Register _, 200. MISCELLANEOUS BoAs 20 AAC 25.005(e) is amended to read: C ~ [IF AJ well Ç"UAS MUcrlf'f...E. (.ùELL B!<ANCHES) £ACH J) (e) [If A WeLL lIAS MULTIPLE WELL BRANCIIES,] Each [EACH] wcÎÌbranch requires a separate Permit to Drill. If a previously drilled well is proposed to be redrilled below the structural or conductor casine to a new bottom-hole location. the application for a Permit to Drill must be accompanied by all items required under (c) of this section..:. Ifconcurrent multiple well branches are proposed from a single conductor, surface, or production casing, ill the applicant shall designate one well branch as the p~imal{ welIbore and include all - LWith,.)-u. t."\.I'f\ìC'~:·IQ"J f"~ items [INFORMATION] required under (c) of this sectionlfor a Permit to Drill for that well branch.i[.] \:::::) II (2) for [FOR] each other [SUBSEQUENT] well branch, the application for a Pennit to i'\. . .. 0 . ,--,.-.-' iJO 1Mt ~~u.{o-u.... J"'_ .A..wl~ J-. Drill need only include information under (c) of this section that is unique to that well branch and need not be accompanied by [INCLUDE] the $100 fee. (Eff. 4/13/80, Register 74; am 4/2/86, Register 97; am 11/7/99, Register 152; am 6/4/2000, Register 154; am / I -- , Register ~ Authority: AS 31.05.030 AS 31.05.090 20 AAC 25.015(a)(l) is amended to read: (1) submit and obtain the commission's approval of a new application for a Penn it to Drill if the proposed surface location is changed, if the proposed bottom-hole location or the proposed location of an objective fonnation is changed by more than 500 feet laterally or vertically, or if the change ~ requires a spacing exception under 20 AAC 25.055; however, no additional fee is requiredY 20 AAC 25.015(b)(1) is amended to rea~,. CD (1) submit and obtain the commission's approval of a new application for a Permit to Drill, accompanied by a fee of $1 00, if the proposed bottom-hole location or the proposed location of an ¡; \ Register _, 200. MISCELLANEOUS BOaS objective formation is changed by more than 500 feet laterally or vertically, or if the change requires a spacing exception under 20 AAC 25.055;<)D (Eff. 4/13/80, Register 74; am 412/86, Register 97; am 11/7/99, Register 152; am ---1~ Register --'> Authority: AS 31.05.030 AS 31.05.090 20 AAC 25.990(74) is amended to read: (74) "well branch" means that portion of a well drilled below the structural or conductor casing to access a eiven [SEP ARA TE] objective in a well with more than one bottom-hole location Q! whose bottom-hole location is beine or has been chaneed by plueeine back and redrilline; (Eff. 11/7/99, Register 152; am, ---1---1 , Register --'> Authority: AS 31.05.030 2 #11 e MEMORANDUM e STATE OF ALASKA ALASKA OIL AND GAS CONSERVATION COMMISSION TO: DATE: November 8,2005 SUBJECT: Request for Legal Review Of Regulations Project on well branches, 20 AAC 25.005 - .900 Weare requesting legal review and approval of the attached final regulations on changes to well branches, applications for a permit to drill, changes in a drilling program, redrilling, and plugging, which were adopted by Alaska Oil and Gas Conservation Commission. Enclosed are the following documents: 1. the original and one copy of the final regulations for the Department of Law's use; 2. the original of the signed and dated certification order; 3. the original of the public notice; 4. the original of the additional regulations notice infonnation fonn distributed with the notice; 5. the original of the publishers' affidavit of publication; 6. the original of the affidavit of notice; 7. affidavit of commission action; 8. excerpt from unapproved minutes from the October 26,2005 meeting; We have worked with Assistant Attorney General Robert E. Mintz on this project. Register _, 1°- MISCELLANEOUS lARDS 20 AAC 25.005(e) is amended to read: (e) [IF A WELL HAS MULTIPLE WELL BRANCHES,] Each [EACH] well branch requires a separate Pennit to Drill. If a previously drilled well is proposed to be redrilled below the structural or conductor casine: to a new bottom-hole location, the application for a Permit to Drill must be accompanied by all items required under (c) of this section. If concurrent multiple well branches are proposed from a single conductor, surface, or production casing, ill the applicant shall designate one well branch as the primary wellbore and include all items [INFORMATION] required under (c) of this section for a Penn it to Drill for that well branch¡[.] (2) for [FOR] each other [SUBSEQUENT] well branch, the application for a Pennit to Drill need only include infonnation under (c) of this section that is unique to that well branch and need not be accompanied by [INCLUDE] the $100 fee. (Eff. 4/13/80, Register 74; am 4/2/86, Register 97; am 11/7/99, Register 152; am 6/4/2000, Register 154; am / / -- , Register ~ Authority: AS 31.05.030 AS 31.05.090 20 AAC 25.015(a)(1) is amended to read: (1) submit and obtain the commission's approval of a new application for a Penn it to Drill if the proposed surface location is changed, if the proposed bottom-hole location or the proposed location of an objective fonnation is changed by more than 500 feet laterally or vertically, or if the change requires a spacing exception under 20 AAC 25.055; however, no additional fee is required; 20 AAC 25.015(b)(1) is amended to read (1) submit and obtain the commission's approval of a new application for a Pennit to Drill, accompanied by a fee of $1 00, if the proposed bottom-hole location or the proposed location of an 1 Register -' tf- MISCELLANEOUS lARDS objective formation is changed by more than 500 feet laterally or vertically, or if the change requires a spacing exception under 20 AAC 25.055; (Eff. 4/13/80, Register 74; am 4/2/86, Register 97; am 11/7/99, Register 152; am ~~ Register -> Authority: AS 31.05.030 AS 31.05.090 20 AAC 25.990(74) is amended to read: (74) "well branch" means that portion of a well drilled below the structural or conductor casing to access a e:iven [SEP ARA TE] objective in a well with more than one bottom-hole location !!! whose bottom-hole location is beinp" or has been chane:ed bv plu2"e:ine: back and redrilline; (Eff. 11/7/99, Register 152; am, ~~ , Register -> Authority: AS 31.05.030 2 Register _, ¡o- MISCELLANEOUS lARDS 20 AAC 25.005(e) is amended to read: (e) [IF A WELL HAS MULTIPLE WELL BRANCHES,] Each [EACH] well branch requires a separate Permit to Drill. If a previouslv drilled well is proposed to be redrilled below the structural or conductor casin!! to a new bottom-hole location. the application for a Permit to Drill must be accompanied bv all items required under (c) of this section. If concurrent multiple well branches are proposed from a single conductor, surface, or production casing, ill the applicant shall designate one well branch as the primary wellbore and include all items [INFORMATION] required under (c) of this section for a Permit to Drill for that well branchi[.] (2) for [FOR] each other [SUBSEQUENT] well branch, the application for a Permit to Drill need only include information under (c) of this section that is unique to that well branch and need not be accompanied bv [INCLUDE] the $100 fee. (Eff. 4/13/80, Register 74; am 4/2/86, Register 97; am 11/7/99, Register 152; am 6/4/2000, Register 154; am / / -- , Register ~ Authority: AS 31.05.030 AS 31.05.090 20 AAC 25.015(a)(I) is amended to read: (1) submit and obtain the commission's approval of a new application for a Permit to Drill if the proposed surface location is changed, if the proposed bottom-hole location or the proposed location of an objective formation is changed by more than 500 feet laterally or vertically, or if the change requires a spacing exception under 20 AAC 25.055; however, no additional fee is required; 20 AAC 25.015(b)(1) is amended to read (1) submit and obtain the commission's approval of a new application for a Permit to Drill, accompanied by a fee of $1 00, if the proposed bottom-hole location or the proposed location of an 1 Register _, 1°- MISCELLANEOUS BOARDS e objective fonnation is changed by more than 500 feet laterally or vertically, or if the change requires a spacing exception under 20 AAC 25.055; (Eff. 4/13/80, Register 74; am 4/2/86, Register 97; am 11/7/99, Register 152; am -.-1_/ Register ~ Authority: AS 31.05.030 AS 31.05.090 20 AAC 25.990(74) is amended to read: (74) "well branch" means that portion of a well drilled below the structural or conductor casing to access a eiven [SEP ARA TE] objective in a well with more than one bottom-hole location !!I whose bottom-hole location is beine or has been chan2ed bv pluepine back and redrillinv; (Eff. 11/7/99, Register 152; am, -.-1-.-1 , Register ~ Authority: AS 31.05.030 2 e e ORDER CERTIFYING THE CHANGES TO REGULATIONS OF ALASKA OIL AND GAS CONSERVATION COMMISSION The attached two pages of regulations, dealing with well branches, applications for a Permit to Drill, changes in a drilling program, redrilling, and plugging under 20 AAC 25 are hereby certified to be a correct copy of the regulation changes that the Alaska Oil and Gas Conservation Commission adopted at its October 26,2005 meeting, under the authority of AS 31.05.030 and 31.05.040 and after compliance with the Administrative Procedure Act (AS 44.62), specifically including notice under AS 44.62.190 and 44.62.200 and opportunity for public comment under AS 44.62.210. This action is not expected to require an increased appropriation. On the record, in considering public comments, the Alaska Oil and Gas Conservation Commission paid special attention to the cost to private persons of the regulatory action being taken. The regulation changes described in this order take effect on the 30th da after they have been filed by the lieutenant governor, as provided in AS 44.62.180. DATE: November 8, 2005 Anchorage ~~'NOnnM Chairman FILING CERTIFICATION I, Loren Leman, Lieutenant Governor for the State of Alaska, certify that on ,2005 at .m., I filed the attached regulations according to the provisions of AS 44.62.040 - 44.62.120. Lieutenant Governor Effective: Register: ADVERTISING ORDER SEE BOTTOM FOR INVOICE ADDRESS INVOIrA.<;T BE IN TRIPLICATE SHOWING ADVERTISING ORDER N6RTIFIED AO-02614004 AFFID~-F PUBLICATION (PART 2 OF THIS FORM) WITH ATTAC~OPY OF ADVERTISEMENT MUST BE SUBMITTED WITH INVOICE F AOGCC R 333 W 7th Ave, Ste 100 o Anchorage, AK 99501 M AGENCY CONTACT DATE OF A.O. lody Colombie PHONE August 4, 2005 PCN (907) 793 -1 ??1 DATES ADVERTISEMENT REQUIRED: ¿ Anchorage Daily News PO Box 149001 Anchorage, AK 99514 August 5, 2005 THE MATERIAL BETWEEN THE DOUBLE LINES MUST BE PRINTED IN ITS ENTIRETY ON THE DATES SHOWN. SPECIAL INSTRUCTIONS: Type of Advertisement X Legal o Display Advertisement to be published was e-mailed o Classified DOther (Specify) SEE ATTACHED SENDINVOICEINTRIPLICATE AOGCC, 333 W. 7th Ave., Suite 100 . TO·· A nchorage. A K 99:"i0 1 REF TYPE NUMBER AMOUNT DATE 1 VEN I TOTALOF I PAGE 1 OF ALL PAGES$ 2 PAGES COMMENTS 2 ARD 3 4 02910 ¡:IN 4MnllNT ~v f"':.f"':. ProM If"':. 4f"':.f"':.T ¡:y NMR DlST LlQ 1 05 02140100 2 3 4 / REQUlsr~f~_ 7}~ V 73451 DIVISION APPROVAL: e e STATE OF ALASKA NOTICE OF PROPOSED CHANGES IN THE REGULATIONS OF THE ALASKA OIL AND GAS CONSERVATION COMMISSION The Alaska Oil and Gas Conservation Commission ("AOGCC") proposes to adopt regulation changes in Title 20, Chapter 25, of the Alaska Administrative Code, dealing with well branches, applications for a Permit to Drill, changes in a drilling program, redrilling, and plugging, including the following: the definition of "well branch" is proposed to be amended in 20 AAC 25.990(74) to make clear that it applies where an initial bottom-hole location is changed by plugging back and redrilling; 20 AAC 25.005(e) is proposed to be amended to clarify the Permit to Drill requirements for well branches; and 20 AAC 25.015 is proposed to be amended to make clear that it applies to prospective-only changes in drilling locations. You may comment on the proposed regulation changes, including the potential costs to private persons of complying with the proposed changes, by submitting written comments to the AOGCC, 333 W. ih Avenue, Suite 100, Anchorage, AK 99501. The comments must be received no later than 4:30 p.m. on September 13,2005. Additionally, oral or written comments may be submitted at a hearing to be held on September 6, 2005, at 333 W. ih Avenue, Suite 100, Anchorage, AK 99501. The hearing will begin at 9:00 a.m. and may be extended from day to day if necessary to accommodate those present before 9:30 a.m. who did not have an opportunity to comment. If you are a person with a disability who may need special accommodations, auxiliary aid or service, or an alternative communication format in order to participate in the process on the proposed regulation changes, please contact, the Commission's Special Staff Assistant, lody Colombie at 793-1221 by 4:00 p.m., September 1,2005 to ensure that any necessary accommodations can be provided. Copies of the proposed regulation changes may be obtained from the AOGCC office, 333 W. ih Avenue, Anchorage, Alaska 99501, or by telephoning the AOGCC at 907-793- 1221, or on the AOGCC web site at: http://www.aogcc.alaska.gov. After the public comment period ends, the AOGCC will either adopt this or another proposal dealing with the same subject, without further notice, or decide to take no action on it. The language of the final regulations may be different from that of the proposed regulations. YOU SHOULD COMMENT DURING THE TIME ALLOWED IF YOUR e e INTERESTS COULD BE AFFECTED. Written comments received are public records and are subject to public inspection. Statutory Authority: AS 31.05.030; AS 31.05.040. Statutes Being Implemented, Interpreted, or Ma Fiscal Information: The proposed regulation c increased appropriation. /? Date: August 4, 2005 (I i' Jo. .~n aIrman p cific: AS 31.05.030. e not expected to require an Published: August 5, 2005 AO: 02614004 e e ADDITIONAL REGULATIONS NOTICE INFORMATION (AS 44.62. 190(d)) 1. Adopting agency: Alaska Oil and Gas Conservation Commission. 2. General subject of regulations: wells drilled in search of oil or gas 3. Citation of regulations: 20 AAC 25.005; 20 AAC 25.015; and 20 AAC 25.990. 4. Reason for the proposed action: updating and clarifying regulatory provisions in light of experience and information. 5. Program category and BRU affected: Alaska Oil and Gas Conservation Commission. 6. Cost of implementation to the state agency: zero. 7. The name of the contact person for the regulations John K. Norman, Alaska Oil and Gas Conservation Commission, 333 W. ih Avenue, Suite 100, Anchorage, AK 99501, (907) 279-1433. 8. The origin of the proposed actL I ncy staff. 9. Date: Augu 4,2 5 7--~ 10. Prepared by. Anchorage Daily News Tffidavit of Publication e 1001 Northway Drive, Anchorage, AK 99508 PRICE OTHER OTHER OTHER OTHER OTHER GRAND AD# DATE PO ACCOUNT PER DAY CHARGES CHARGES #2 CHARGES #3 CHARGES #4 CHARGES #5 TOTAL 567271 08/05/2005 02614004 STOF0330 $300.96 $300.96 $0.00 $0.00 $0.00 $0.00 $0.00 $300.96 STATE OF ALASKA THIRD JUDICIAL DISTRICT Kimberly Kirby, being first duly sworn on oath deposes and says that she is an advertising representative of the Anchorage Daily News, a daily newspaper. That said newspaper has been approved by the Third Judicial Court, Anchorage, Alaska, and it now and has been published in the English language continually as a daily newspaper in Anchorage, Alaska, and it is now and during all said time was printed in an office maintained at the aforesaid place of publication of said newspaper. That the annexed is a copy of an advertisement as it was published in regular issues (and not in supplemental form) of said newspaper on the above dates and that such newspaper was regularly distributed to its subscribers during all of said period. That the full amount of the fee charged for the foregoing publication is not in excess of the rate charged private individuals. ::::f:~j!!iz 5~~5 Notary Public in and for the State of Alaska. Third Division. Anchorage, Alaska MY COMMISSION EXPIRES: t.c ~ DCa Pð~· AulÜVr J / - -0 \\\{(((((ff" \.\.\\~~ ~'.~~I/I'"~.... ~ø-..' --- "~~~ ~ ~:~OTA~~·.Q '-? .:::. -... .;....... := ' ÞUSUC : =: -:;:~ '. ~ --- _&:æ!$ -::. <ci' ."P'À ,!:>T. ft¡_..... ~~::';-OF þ.~.' fo'~ //;~. '. .' ~'4,-:"\ :.-'.1; i'()n ExpireS- \\\ )})}jJJ1¡))\ - ---------, - - -e----- _'oJr--_..... - -r-- ..------.. - -....---, - -r-- ..-...---...., -...----. ---e STATE OF ALASKA ADVERTISING ORDER SEE BOTTOM FOR INVOICE ADDRESS e NOTICE TO PUBLISHER e INVOICE MUST BE IN TRIPLICATE SHOWING ADVERTISING ORDER NO., CERTIFIED AFFIDAVIT OF PUBLICATION (PART 2 OF THIS FORM) WITH AlTACHED COPY OF ADVERTISEMENT MUST BE SUBMllTED WITH INVOICE ADVERTISING ORDER NO. AO-02614004 F R o M AOGCC 333 West ih Avenue. Suite 100 A n('hnr~O"P A K QQ'iO 1 907-793-1221 AGENCY CONTACT DATE OF A.a. Joclv Colombie AUQust 4. 1005 PHONE PCN (907) 793 -1 ?? 1 DATES ADVERTISEMENT REQUIRED: T o Anchorage Daily News PO Box 149001 Anchorage, AK 99514 August 5, 2005 THE MATERIAL BETWEEN THE DOUBLE LINES MUST BE PRINTED IN ITS ENTIRETY ON THE DATES SHOWN. SPECIAL INSTRUCTIONS: United states of America AFFIDAVIT OF PUBLICATION REMINDER State of ss INVOICE MUST BE IN TRIPLICATE AND MUST REFERENCE THE ADVERTISING ORDER NUMBER. A CERTIFIED COPY OF THIS AFFIDAVIT OF PUBLICATION MUST BE SUBMITTED WITH THE INVOICE. ATTACH PROOF OF PUBLICATION HERE. division. Before me, the undersigned, a notary public this day personally appeared who, being first duly sworn, according to law, says that . he/she is the of Published at in said division and state of and that the advertisement, of which the annexed is a true copy, was published in said publication on the day of 2005, and thereafter for _ consecutive days, the last publication appearing on the _ day of , 2005, and that the rate charged thereon is not in excess of the rate charged private individuals. Subscribed and sworn to before me This _ day of 2005, Notary public for state of My commission expires 02-901 (Rev. 3/94) AO.FRM e e STATE OF ALASKA ) ) ss. ) THIRD JUDICIAL DISTRICT AFFIDA VIT OF NOTICE OF PROPOSED ADOPTION OF REGULATIONS AND FURNISHING OF ADDITIONAL INFORMATION I, Jody J. Colombie, Special Staff Assistant, of Alaska Oil and Gas Conservation Commission, being sworn, state the following: As required by AS 44.62.190, notice of the proposed adoption of changes to Title 20, Chapter 25 of the Alaska Administrative Code, dealing with well branches, applications for a Permit to Drill, changes in a drilling program, redrilling, and plugging, has been given by being (1) published in a newspaper or trade publication; (2) furnished to interested persons [as shown on the attached list]; (3) furnished to appropriate state officials; (4) furnished to the Department of Law, along with a copy of the proposed regulations; (5) electronically transmitted to incumbent State of Alaska legislators; (6) furnished to the Legislative Affairs Agency, Legislative Library; (7) posted on the Alaska Online Public Notice System as required by AS 44.62.175(a)(1) and (b) and 44.62.190(a)(I); (8) furnished electronically, along with a copy of the proposed regulations, to the Legislative Affairs Agency, the chair of the Resources and House Special Committee of Oil and Gas Committee of the Alaska Senate and House of Representatives, the Administrative Regulation Review Committee, and the legislative council. As required by AS 44.62.190(d), additional regulations notice information regarding the proposed adoption of the regulation changes described above has been furnished to interested persons [as shown on the attached list] and those in (5) and (6) of the list above. The additional regulations notice information also has been posted on the Alaska Online Public Notice System. DATE: November 8, 2005 Anchorage í\ "'..'\ ø I ~r\ ,; ti il t'd \ '"',. . ~-Jr-. í J (1.1 't"i\ 0 / .1\.,./-'.......-. .,- ì '---.L¡ \o.O,'WV'tr-- o JodyJ. Co!gmbie Special Staff Assistant SUBSCRIBED AND SWORN TO before me this 8th day of November, 2005. ,~~~ r;~~ ~Ñotary Pub~ ~~ for the State of Alaska / ' J My commission expires: ¡ ( I r¡ LT.· e e Subject: Notice of Proposed Changes in AOGCC Regulations From: Jody Colombie <jody_colombie@admin.state.ak.us> Date: Thu, 04 Aug 2005 12:56:41 -0800 To: undisclosed-recipients:; BCC: Con Bunde <senator_con_bunde@legis.state.ak.us>, John Cowdery <senatorjohn_cowdery@legis.state.ak.us>, Bettye J Davis <senator_bettye_davis@legis.state.ak.us>, Johnny Ellis JR <senatorjohnny_ellis@legis.state.ak.us>, Kim S Elton <senator _ kim _ elton@legis.state.ak.us>, Hollis French <senator _ hollis _ french@legis.state.ak.us>, Lyda N Green <senator_Iyda_green@legis.state.ak.us>, Gretchen G Guess <senator _gretchen _guess@legis.state.ak.us>, Lyman F Hoffman <senator _lyman _ hoffman@legis.state.ak.us>, senator _ ben_stevens <senator _ ben _ stevens@legis.state.ak.us>, senator _gary_stevens <senator _gary _ stevens@legis.state.ak.us>, senator_gene _ therriault <senator_gene _ therriault@legis.state.ak.us>, senator _ thomas_wagoner <senator _ tho mas _ wagoner@legis.state.ak.us>, senator _gary_wilken <senator _gary _ wilken@legis.state.ak.us>, mike chenault <representative_mike _ chenault@legis.state.ak.us>, sharon cissna <representative_sharon _ cissna@legis.state.ak.us>, John Coghill <representative john _ coghill@legis.state.ak.us>, harry crawford <representative_harry _ crawford@legis.state.ak.us>, eric croft <representative _ eric _ croft@legis.state.ak.us>, nancy dahlstrom <representative _ nancy _ dahlstrom@legis.state.ak.us>, richard foster <representative _richard _ foster@legis.state.ak.us>, les gara <representative _les _gara@legis.state.ak.us>, Carl Gatto <representative_carl_gatto@legis.state.ak.us>, max gruenberg <representative _ max _gruenberg@legis.state.ak.us>, david guttenberg <representative _ david _guttenberg@legis.state.ak.us>, John Harris <representati ve john _ harris@legis.state.ak.us>, mike hawker <representative_mike _ hawker@legis.state.ak.us>, Jim Holm <representative Jim _ holm@legis.state.ak.us>, reggie joule <representative _reggie joule@legis.state.ak.us>, mary kapsner <representative _ mary _ kapsner@legis.state.ak.us>, Beth Kerttula <representative_beth _ kerttula@legis.state.ak.us>, vic kohring <representative _ vic _ kohring@legis.state.ak.us>, Albert Kookesh <representative _ albert_ kookesh@legis.state.ak.us>, pete kott <representative yete _ kott@legis.state.ak.us>, Bob Lynn <representative_bob _lynn@legis.state.ak.us>, lesil mcguire <representative_Iesil_mcguire@legis.state.ak.us>, kevin meyer <representative _ kevin _ meyer@legis.state.ak.us>, carl morgan <representative _ carl_ morgan@legis.state.ak.us>, carl moses <representative _ carl_ moses@legis.state.ak.us>, norman rokeberg <representative _ norman _rokeberg@legis.state.ak.us>, ralph samuels <representative Jalph _ samuels@legis.state.ak.us>, paul seaton <representative yaul_ seaton@legis.state.ak.us>, Bill Stoltze <representative _ bill_ stoltze@legis.state.ak.us>, Bruce Weyhrauch <representative _ bruce _ weyhrauch@legis.state.ak.us>, peggy wilson <representative yeggy _ wilson@legis.state.ak.us>, Donny Olson 10f2 8/4/2005 1 :07 PM e e <senator _ donny _ olson@legis.state.ak.us>, Ralph Seekins <senator Jalph _seekins@legis.state.ak.us>, Tom Anderson <representative_tom _ anderson@legis.state.ak.us>, Ethan Berkowitz <representative _ ethan _ berkowitz@legis.state.ak.us>, Fred Dyson <senator _ fred _ dyson@legis.state.ak.us>, Bert K Stedman <senator _ bert _ stedman@legis.state.ak.us>, Kurt E Olson <kurt_olson@legis.state.ak.us>, repjaYJamras@legis.state.ak.us, rep jay _ramras@legis.state.ak.us, Albert Kookesh <representative _ albert _ kookesh@legis.state.ak.us>, senator_charlie _ huggins@legis.state.ak.us, rep jim _ elkins@legis.state.ak.us, rep _ berta _gardner@legis.state.ak.us, rep _mike _ kelly@legis.state.ak.us, rep _mark _ neuman@legis.state.ak.us, rep _gabrielle _ledoux@legis.state.ak.us Content-Type: application/pdf Additional Regulation Notice.pdf b 64 Content-Encoding: ase Content-Type: application/pdf Public Notice.pdf Content-Encoding: base64 20f2 8/4/2005 I :07 PM e e Subject: Notice of Proposed Changes in the AOGCC Regulations From: lody Colombie <jody_colombie@admin.state.ak.us> Date: Thu, 04 Aug 2005 13:03:56 -0800 To: undisclosed-recipients:; BCC: Tom Wagoner <senator_tom_wagoner@legis.state.ak.us>, Vic Kohring <representative_ vic_kohring@legis.state.ak.us>, Tom Anderson <representative _ tom_ anderson@legis.state.ak.us>, Pete Kott <representative-pete _ kott@legis.state.ak.us>, mary -pagenkopf@legis.state.ak.us Content-Type: application/pdf Public Notice.pdf Content-Encoding: base64 Content-Type: application/pdf iAdditional Regulation Notice.pdf Content-Encoding: base64 Content-Type: application/msword 1-Regulation.doc Content-Encoding: base64 I of 1 8/4/2005 I :07 PM David McCaleb IHS Energy Group GEPS 5333 Westheimer, Ste 100 Houston, TX 77056 George Vaught, Jr. PO Box 13557 Denver, CO 80201-3557 John Levorsen 200 North 3rd Street, #1202 Boise, ID 83702 Michael Parks Marple's Business Newsletter 117 West Mercer St, Ste 200 Seattle, WA 98119-3960 Schlumberger Drilling and Measurements 2525 Gambell Street #400 Anchorage, AK 99503 Ivan Gillian 9649 Musket Bell Cr.#5 Anchorage, AK 99507 Jack Hakkila PO Box 190083 Anchorage, AK 99519 Kenai National Wildlife Refuge Refuge Manager PO Box 2139 Soldotna, AK 99669-2139 Cliff Burglin PO Box 70131 Fairbanks, AK 99707 e Citgo Petroleum Corporation PO Box 3758 Tulsa, OK 74136 Mona Dickens Tesoro Refining and Marketing Co. Supply & Distribution 300 Concord Plaza Drive San Antonio, TX 78216 Jerry Hodgden Hodgden Oil Company 408 18th Street Golden, CO 80401-2433 Kay Munger Munger Oil Information Service, Inc PO Box 45738 Los Angeles, CA 90045-0738 Mark Wedman Halliburton 6900 Arctic Blvd. Anchorage, AK 99502 David Cusato 200 West 34th PMB 411 Anchorage, AK 99503 Jill Schneider US Geological Survey 4200 University Dr. Anchorage, AK 99508 Darwin Waldsmith PO Box 39309 Ninilchick, AK 99639 Penny Vadla 399 West Riverview Avenue Soldotna, AK 99669-7714 Bernie Karl K&K Recycling Inc. PO Box 58055 Fairbanks, AK 99711 e Mary Jones XTO Energy, Inc. Cartography 810 Houston Street, Ste 2000 Ft. Worth, TX 76102-6298 Robert Gravely 7681 South Kit Carson Drive Littleton, CO 80122 Richard Neahring NRG Associates President PO Box 1655 Colorado Springs, CO 80901 Samuel Van Vactor Economic Insight Inc. 3004 SW First Ave. Portland, OR 97201 Baker Oil Tools 4730 Business Park Blvd., #44 Anchorage, AK 99503 Ciri Land Department PO Box 93330 Anchorage, AK 99503 Gordon Severson 3201 Westmar Cr. Anchorage, AK 99508-4336 James Gibbs PO Box 1597 Soldotna, AK 99669 Richard Wagner PO Box 60868 Fairbanks, AK 99706 Williams Thomas Arctic Slope Regional Corporation Land Department PO Box 129 Barrow, AK 99723 /l}a/)ect'" ~~5 North Slope Borough PO Box 69 Barrow, AK 99723 e e e //~ / e Debra Behr Assistant Attorney General Department of Law PO Box 110300 Juneau, AK 99811 Legislative Reference Library Legislative Affairs Agency State Capitol Juneau, AK 99801 Mail Stop: 3101 ~ Mat\ashOVJS\<.\ Ray . . oef coO'O' \S~âO' \0 istfatioO oept o~ 00 pO BoX ~~2 998 ~ 1 Juneau, / /7çíl /é'L 17; y/f)c; e e STATE OF ALASKA ) ) ss. ) THIRD JUDICIAL DISTRICT AFFIDAVIT OF COMMISSION ACTION I, John K. Norman, Chairman for the Alaska Oil and Gas Conservation Commission, being duly sworn, state the following: The attached motion dealing well branches, applications for a permit to drill, changes in a drilling program, redrilling, and plugging was passed by the Alaska Oil and Gas Conservation Commission during its October 26, 2005 meeting. Date: November 8, 2005 Anchorage SUBSCRIBED AND SWORN TO before me this 8th day of November, 2005. ¿?¢:.~~~ C-/N otary Public in and for the State of Alaska / / My commission expires: / / / / //tJ6 · e ALASKA OIL AND GAS CONSERV A nON COMMISSION MEETING October 26, 2005 Excerpt From Unapproved Minutes Chairman John K. Norman moved and Commissioner Cathy P. Foerster seconded the following motion: "I move to adopt the amendments, specifically to 20 AAC 25.005(e), Sections 25.015(a)(1), 25.015(b)(I~, and 25.990(74), all of which pertain generally to the same subject as written in the October 11 t draft of regulations marked Version 2." The motion carried unanimously. . . STATE OF ALASKA ) ) ss. ) THIRD JUDICIAL DISTRICT AFFIDAVIT OF ORAL HEARING I, Jody J. Colombie, Special Staff Assistant of the Alaska Oil and Gas Conservation Commission, being sworn, state the following: On September 6,2005, at 9:00 a.m., 333 West th Avenue, Suite 100, Anchorage, Alaska 99501, a public hearing presided over by John K. Norman, Chairman, was held in accordance with AS 44.62.210 for the purpose of taking testimony in connection with the adoption of changes to 20 AAC 25.005; 20 AAC 25.015; and 20 AAC 25.990 dealing with well branches, applications for a permit to drill, changes in a drilling program, redrilling, and plugging. DATE: November 17, 2005 Anchorage C0cVvv~C ~~ U Jody .(C~~ Speciàrstaff Assistant SUBSCRIBED AND SWORN TO before me this 17th day of November, 2005. ~ LÞ (~---r7 ;¿'Á-J/' -~ d ?2--/;:!-IL-L. / . - .... Notary Publ~c'(n arid for the State of Alaska My commission expires: 11/11/06 #10 ,,----y L"'" ? L~ ~ 7/;;/"("?/Ò'·" Fairbanks PrincesS Riverside Lodge / ,.-y" k' I .) ,. ) :'Î<O ,··<--t /1) L/ " .. L-I I.. - , 1..-... ,I. / , ,/ __ /1'-.-1-7 i) .VI ."7 ,/ ./- .":'¡ . 1 \,?'" I . /.,.'/ .I .'") /"? /~ ,<A ',;r" /j-.,(/17''l /1 ) ~. {.....". . /-;'(;:; {.,J /'" it:;"L-/".t:. ,/ v'' .. c... '--- ,L I"', ," ,f." _ . "-·',.n f "-'".? .,,--. /./ . l,.. l"'~' / .? /. I . / ') .(,/ /...-' e--}.,::" ,,'1. 7_)'--. /..I.---?,I¿ 7/. v ,. Iy /" ..' I. I ) ../7 _'//' I r ,:;:J .Þ- /)'1:(;;:/;':::0/ (..//, 11«/;'.7 //>6Ct a/,I' e- l/- t c ~//-" ./. . /"-' -- ¡ ¿:;::/;;/:,lc;/¿; /;J?" . For Contracted & Corporate Reservations Call 800-777-1725 j/"ì www.princesslodges.com ,. 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I ~ ,¡9 ,,0 ¡¿,bite 4 e.Ar/ ~5U S ú/7I1-p I" H.u f~cI¡ dIU' 10 .5én s. ¡., ~ "/ ,/Ve /S8 q~f ð r ..¡llt?/ r e þ'¡;:;' cis dlvea,Lð-V h'Lo/,~.. 1ÂA-NÆ y~ · vf~M/:/-~ d o-~ dJl ft!,(/'/- ;?¿:)oß ~;I~ /It' -.3 S 13 <';>( 5,/.3,?'" W /J-5 /1//9 / ,¡t)Æ- 9965" Y #9 \ ) ) Alaska Oil and Gas Association A0GA 121 W. Fireweed Lane, Suite 207 Anchorage, Alaska 99503-2035 Phone: (907)272-1481 Fax: (907)279-8114 Email: brady@aoga.org Judith Brady, Executive Direct% <.. ,;"'J .1' '^" Ô" ;~") September 13, 2005 <{/¿'3~ Commissioner John Norman Alaska Oil and Gas Conservation Commission 333 W. 7th Avenue, Suite 100 Anchorage, AK 99501 RE: Regulation Changes in Title 20, Chapter 25, of the Alaska Administrative Code, dealing with well branches Dear Commissioner Norman: The Alaska Oil and Gas Association (AOGA) is pleased to have this opportunity to provide written comments to the Alaska Oil and Gas Conservation Commission (AOGCC) on the proposed regulation changes in Title 20, Chapter 25, of the Alaska Administrative Code dealing with well branches. AOGA is a private, nonprofit trade association whose 18 member companies account for the majority of oil and gas exploration, development, production, transportation, refining and marketing activities in Alaska. AOGA's task group for AOGCC, chaired by Barbara Fullmer of ConocoPhillips Alaska, has reviewed the proposed regulations. As we stated in public testimony last week, we understand the purpose of these proposed changes is to clarify the definition of "well branch" and permit to drill requirements for well branches. We also understand that the proposed regulation changes will not add additional burden to operators, nor do they cause any impacts with respect to the current process for applying for permits to drill for well branches. We appreciate the Commission's diligence in clarifying regulations to assist the industry and we support the proposed regulation changes as outlined in the August 4, 2005 public notice. We appreciate the opportunity to provide comments on this proposal. egar s, '~¿~ J ITH BRADY . ecutive Director #8 ) ) 1 ALASKA OIL AND GAS CONSERVATION COMMISSION ) 2 Before Commissioners: John K. Norman, Chair Daniel T. Seamount Cathy Foerster 3 4 Regulation Changes in Title 20, Chapter 25 of the Alaska 5 Administrative Code: Changes to Drilling Programs 6 7 ALASKA OIL and GAS CONSERVATION COMMISSION Anchorage, Alaska 8 9 September 6, 2005 9:00 o'clock a.m. 10 VOLUME I PUBLIC HEARING 11 BEFORE: John K. Norman, Chair Daniel T. Seamount, Commissioner Cathy Foerster, Commissioner 12 13 ') ,) 14 15 16 17 18 19 20 21 22 23 24 25 '} R & R C 0 U R T R E P 0 R T E R S 810 N STREET (907)277-0572/Fax 274-8982 ANCHORAGE, ALASKA 99501 ) 1 2 3 4 5 6 7 8 9 10 11 12 ) 13 14 15 16 17 18 19 20 21 22 23 24 25 1 r ) ) PRO C E E DIN G S Tape 1 0015 (On record - 9:07 a.m.) CHAIR NORMAN: Good morning. I'll call this hearing to order. This is a hearing to review a proposed change to the regulations of the Alaska oil and Gas Conservation commission. Notice of this hearing has been duly published in the Anchorage Daily News. Any persons desiring to get a copy of the notice of the Affidavit of Publication can see the commission special assistant Jody Columbie. My name is John Norman. I'm Chairman of the Alaska oil and Gas Conservation commission. To my right is commissioner Dan Seamount. To my left Commissioner Cathy Foerster. A quorum is present and we are entitled to proceed with conduct of legal business. A transcript will be made of these proceedings and any person desiring to get a transcript following the proceedings may contract the -- either the Commission's public assistant or R & R Court Reporting. If at this time there are any persons present who may require special accommodations to participate in these hearings you may let us know and we will do our best to accommodate you. We try to operate all of our services and programs and activities including the conduct of hearings in a manner so R & R C 0 U R T R E P 0 R T E R S 810 N STREET (907)277-0572/Fax 274-8982 ANCHORAGE, ALASKA 99501 2 3 ANCHORAGE, ALASKA 99501 810 N STREET (907)277-0572/Fax 274-8982 R & R C 0 U R T R E P 0 R T E R S ,) 25 will help with the understanding of what we're attempting to 24 exhibit there, can you elaborate on that and, perhaps, that COMMISSIONER SEAMOUNT: I have no questions. COMMISSIONER FOERSTER: I have none (ph) . . . . . CHAIR NORMAN: Commissioner Foerster. Okay. I see an 23 22 21 CHAIR NORMAN: Commissioner Seamount? 20 19 panel if that's appropriate. DR. AUBERT: I would like to open it to questions from the 18 CHAIR NORMAN: Very well. Do you have anything more? 17 16 the use of those terms and to clarify potential ambiguities. 15 abandon. The proposed regulation change aims to standardize common usage of the terms side track, lateral, redrill and 14 Code and we've also identified some likely ambiguities in 13 ) 12 regulations at Chapter 20 Title 25 of the Alaska Administrative 11 Department of Law have identified some potential gaps in the DR. AUBERT: Commissioner Staff and Staff of the Alaska 10 9 comments from the public. Dr. Aubert. 8 concerning the proposed regulations and then we will take 7 We will first hear briefly from the Commission's Staff 6 Administrative Code. 5 being held in accordance with 20 AAC 25.540 of the Alaska 4 review will be discussed, specifically these proceedings are 3 The specific regulations that have been proposed for 2 disabilities. that they are usable and accessible to individuals with 1 ) ") ) ) 1 2 3 4 5 6 7 8 9 10 11 12 ) 13 14 15 16 17 18 19 20 21 22 23 24 25 ) ') ) accomplish here. DR. AUBERT: If you'll address Exhibits A and B, Exhibit A represents a situation of a well that -- part of which had been plugged and then another well path drilled away from part of the existing well bore and the second well path is denoted by the dashed line. Contrast that with Exhibit B where two well paths have been drilled away from a given well bore and they are active concurrently rather than subsequently as in Exhibit A, so therein lies the crux of this regulation change. Common usage refers to -- or has been referring to Exhibit A as a side track and the two well paths in Exhibit Bare generally referred to as laterals within a multi-lateral well system. We are proposing to standardize the language describing those two situations and use the term well branch to denote each and every well path that is visible there. CHAIR NORMAN: Okay. And there is a second change in the regulations also that adds the word proposed to before bottom hole location in 20 25.015 and that is for clarity. It's my understanding that that's always been the intention that it applied to proposed, but that's added for clarity. DR. AUBERT: That is correct. And that particular regulation treats proposed changes to the existing permits to drill either before drilling operations start or after drilling operations have commenced. R & R C 0 U R T R E P 0 R T E R S 810 N STREET (907)277-0572/Fax 274-8982 ANCHORAGE, ALASKA 99501 4 5 ANCHORAGE, ALASKA 99501 810 N STREET (907)277-0572/Fax 274-8982 R & R C 0 U R T R E P 0 R T E R S time there's only one bottom hole location, by convention the well where there's been a plug back and redrill so at anyone For example, it's my understanding that in the case of a requirements won't change. some differences in terminology used, but the substantive that maybe it would be more complete to say that there may be MR. MINTZ: If I could just add something there, I think CHAIR NORMAN: Okay. administration. DR. AUBERT: There will not be any differences in previously? regulations be administered differently than they were CHAIR NORMAN: And following this change how will the DR. AUBERT: That's correct. CHAIR NORMAN: .....industry or the public? DR. AUBERT: That's correct. expense to..... neutral change in your opinion and will not add any additional understanding if they neither add nor detract than it's a think that's implicit in what you just said, but I'm CHAIR NORMAN: will there be any additional expense? I regulation -- after the proposed regulation change. industry. All existing requirements remain in place after the neither add nor take away from existing requirements on The proposed regulations Oh, let me add one last thing. \ ) ) ) 1 2 3 4 5 6 7 8 9 10 11 12 ) 13 14 15 16 17 18 19 20 21 22 23 24 25 ~ " ) 1 2 3 4 5 6 7 8 9 10 11 12 ) 13 14 15 16 17 18 19 20 21 22 23 24 25 ) ) ) plug back has, sort of, been referred to as abandonment which is intuitively okay, but is not really consistent with the technical definition of abandonment that the regs use because that implies the complete plugging of the entire well. So this will make it clear that what's really being plugged is a well branch and therefore the -- all of the implications -- all the way that a well branch is treated under the regs such as getting permission to plug a well branch under section 107 and the requirement to file well data within 30 days after a well branch has been completed or plugged will be more clear that these apply in the same way to a portion of a well that's been plugged back to allow redrill. CHAIR NORMAN: Okay. Thank you. And for the record that was Mr. Rob Mintz, Assistant Attorney General, legal counsel for the Commission. Dr. Aubert, is it correct to say as a general matter that because of the advances and innovations in drilling technology it's given rise to the ability to drill these well branches and to engage in greater variation from directional drilling and that's created the, perhaps, ambiguity since our regulations were originally adopted? DR. AUBERT: It certainly contributed to it because technology now exists allowing multiple well branches under our -- under the new definition of the term. Align multiple well branches to be completed or de-completed, produce during or R & R C 0 U R T R E P 0 R T E R S 810 N STREET (907)277-0572/Fax 274-8982 ANCHORAGE, ALASKA 99501 6 7 ANCHORAGE, ALASKA 99501 810 N STREET (907)277-0572/Fax 274-8982 R & R C 0 U R T R E P 0 R T E R S ) DR. AUBERT: You're better informed than I am. 25 24 four miles, is that true? 23 bottom location there's a well out at Colville that's more than COMMISSIONER SEAMOUNT: I believe from surface location to 22 21 an extremely long reach well such as that. 20 than one accumulation within a given pool that is accessed by DR. AUBERT: Certainly within a pool. There may be more 19 COMMISSIONER SEAMOUNT: And within the reservoir? 18 DR. AUBERT: It's on the order of approximately two miles. 17 16 farthest reach now in Alaska of a lateral well? COMMISSIONER SEAMOUNT: Dr. Aubert, do you know what's the 15 CHAIR NORMAN: Commissioner Seamount? 14 DR. AUBERT: I have nothing else at this time. 13 ') ) CHAIR NORMAN: Anything more? 12 11 maximum number that exists world wide, also. 10 called pinta (ph) lateral well and I believe that is the 9 active well bores drilled from a single surface location, a so- DR. AUBERT: In Alaska there are -- there have been five 8 7 single well bore in the State of Alaska? 6 number of well branches out of -- with a single -- out of a CHAIR NORMAN: To your knowledge what is the greatest 5 3 ago, certainly at the time of the last redaction of our 4 regulations, the technology that exists today did not. 2 branches within a multi-lateral well system. And a few years concurrently with or subsequently with any other number of well 1 ) ) ) 8 ANCHORAGE, ALASKA 99501 810 N STREET (907)277-0572/Fax 274-8982 R & R C 0 U R T R E P 0 R T E R S We will limit public comment to 15 minutes per person for we would appreciate it if you could remain where you are. remain in case there are further questions from the Commission proceed to take public comment. Dr. Aubert, if you would CHAIR NORMAN: If there's nothing more then we will then DR. AUBERT: That's correct. recovery from the reservoir by these new technologies? COMMISSIONER FOERSTER: .....increasing the ultimate DR. AUBERT: certainly. for less money you can get additional barrels so you're..... COMMISSIONER FOERSTER: And if you can get your barrels is the primary advantage to operators. more barrels of reserves per dollar of well cost which I think DR. AUBERT: It is and it's also allowing access of many correct? recovery from the existing reservoirs in Alaska, is that allowing enhanced recovery. Well, not like EOR, but additional otherwise be uneconomical, so this technological advance is the operators to get smaller bits of reserves that would these technological advances have occurred primarily to enable COMMISSIONER FOERSTER: Dr. Aubert, I understand that CHAIR NORMAN: Okay. Commissioner Foerster. COMMISSIONER SEAMOUNT: That's all I have, Mr. Chairman. MR. MAUDER: Yes, that is close. COMMISSIONER SEAMOUNT: Okay. Is that true? ') '1) ') 1 2 3 4 5 6 7 8 9 10 11 12 ) 13 14 15 16 17 18 19 20 21 22 23 24 25 ~ ) ) } 1 any of those who wish to offer any additional comments. You 2 may also submit comments in writing if you choose to do so and 3 the Commission will certainly consider those. 4 Are there any persons who have any comments that they wish 5 to offer on the proposed regulatory change? Yes, ma'am, if you 6 want to come forward and you may have a seat, please. 7 MS. OLSON: For the record my name is Dana Olson. And I 8 come here to ask you some questions. I'm sorry, I'm not 9 familiar with all your regulatory things. 10 I haven't checked the legal authority of the Commission. 11 I was wondering if someone could briefly tell me what the legal 12 capacity of the Commission is? Under the Alaska Lands Interest ) 13 Act it says that oil and gas activity shall not be done 14 regulatory. 15 CHAIR NORMAN: certainly, I can respond to that. 16 MS. OLSON: Okay. 17 CHAIR NORMAN: Although I would tell you our main 18 intention this morning is to listen to you,..... 19 MS. OLSON: Yeah. 20 CHAIR NORMAN: .....but the authority of the Alaska oil & 21 Gas Conservation commission arises under Title 31 of Alaska 22 Statutes. 23 MS. OLSON: Okay. 24 CHAIR NORMAN: That was adopted in 1955 as a territorial 25 commission. This Commission is one of the oldest commissions ) R & R C 0 U R T R E P 0 R T E R S 810 N STREET (907}277-0572/Fax 274-8982 ANCHORAGE, ALASKA 99501 9 ) 1 2 3 4 5 6 7 8 9 10 11 12 ') 13 i 14 15 16 17 18 19 20 21 22 23 24 25 ) ') ) in the state of Alaska and our regulatory authority is similar in varying degrees to what you would find in virtually every other oil and gas producing state. MS. OLSON: Well, it does -- the Alaska Lands Interest Act does say that it's an interpretation of Article 8, section 10 of the Alaska Constitution and that is not implicable (sic) to other states and so that's why I'm going to be raising these issues. I have a federal petition that I filed when I went to the Alaska not -- what it is, the National Petroleum Preserve. I filed a petition asking how the federal government would deviate from the state standards that was set previously and so that is out there. I have a problem where in the Constitution it requires that grants and privileges have the right to sue and at this time I don't know what the public's means for the right to sue because what I'm seeing here is a lot of grants and privileges without the right to sue and so this, I believe, is a legal problem. The other thing I see is the diversity issue. The commissioner recently denied me -- of Natural Resources recently denied me an administrative appeal. The Alaska Lands Interest Act is supposed to be under the Administrative Code and so that brings up an issue when I went to the Courts then the Courts were confused whether or not this should be R & R C 0 U R T R E P 0 R T E R S 810 N STREET (907)277-0572/Fax 274-8982 ANCHORAGE, ALASKA 99501 10 ) 1 2 3 4 5 6 7 8 9 10 11 12 ) 13 14 15 16 17 18 19 20 21 22 23 24 25 ) ') ) administrative or whether this should be a civil suit. I told them it had to be both so that issue is a recently filed case in Anchorage where the Courts themselves cannot determine whether this is an administrative issue or whether it's a civil. Let's see what else, one of the issues I raised federally was the issue of tax credits actually creating a different type of interest than originally under the leases. And I want to state for the record that Alaska Survival versus DNR has been implemented for a standard for oil and gas activities and I wanted to state that for 21 years I've not paid any taxes so I guess I got a tax credit. So that's why I'm here tonight is because I'm a pipeline standard. I'm the state equivalency of the NEPA and I don't find that -- that those issues are being adequately addressed and this is why the diversity issue of the commissioner having a different standard than you. You having a different standard than under a land use plan. They're all different standards and there's no means to show what one you should be prevailing. So the I also raised the issue federally under the Code of civil Procedure 104(A) and split jurisdiction where you have narrative water quality standards and the -- under the Clean Water Act the issue of not being fully delegated to the state. You can't have narrative water quality standards that can't be interpreted because of the diversity of different peoples R & R C 0 U R T R E P 0 R T E R S 810 N STREET (907)277-0572/Fax 274-8982 ANCHORAGE, ALASKA 99501 11 ) ) 1 opinions of what they are and that affects drilling. 2 I bought up the issue that the oil industry, its own 3 activities in the past was reported that their activities 4 impaired the pollination of grasses, for example. 5 The rules of civil procedure federal require that there be 6 scientific analyst (sic) and I believe that violates the Alaska 7 Lands Interest Act if it were solely implemented that way 8 because of our requirement of public notice. 9 Lastly in there is the other safeguards as prescribed by 10 law and I don't think you've ever really defined what the other 11 safeguards prescribed by law are and in not doing it so it 12 it leaves a potential to challenge and I really think that you ) 13 should have defined what other safeguards as prescribed by law 14 are if you are solely the authority. I don't think you are, 15 but then I'm not a legal professional. 16 I just know that I've been held as a mitigation standard 17 for coal bed methane. I have been a legal standard for a 18 pipeline. I've been a narrative quality water standard. I've 19 been a permeability standard and I'm having problems with, I 20 guess, the Alaska Lands Act where classifications are being 21 changed without the public process and an interpretation of 22 what the classification is. 23 I have been involved in several appeals on that issue so I 24 would have to say from what you've given to me I am going to 25 have a difficulty in commenting because you have not disclosed ) R & R C 0 U R T R E P 0 R T E R S 810 N STREET (907)277-0572/Fax 274-8982 ANCHORAGE, ALASKA 99501 12 13 ANCHORAGE, ALASKA 99501 810 N STREET (907)277-0572/Fax 274-8982 R & R C 0 U R T R E P 0 R T E R S BP. who is the chair person of the task force and Harry Engel for audience today. They are Barbara Fullmer from conocoPhillips regulations. Representatives of the task group are in the The AOGA's task group for AOGCC has reviewed the proposed with well branches and applications for a Permit to Drill. the proposed regulation changes in Title 20, Chapter 25 dealing testimony to the Alaska oil & Gas Conservation commission on We are pleased to have this opportunity to provide transportation, refining and marketing activities in Alaska. represent the majority of oil and gas exploration, production, AOGA is a non-profit trade association whose member companies Ms. Brady, can you state your name for the record, please? MS. BRADY: Yes, for the record my name is Judy Brady. I'm the Executive Director of the Alaska oil & Gas Association. commission. assuming that nothing has changed the opinion of the commission we will then proceed to adopt the regulation and reviewed any written comments that are filed with the will entertain any comments and then after we have done that that have comments on the proposed regulation? The Commission CHAIR NORMAN: Thank you, Ms. Olson. Are there any others Thank you. by law are. You -- I'm (ph) judging your presumptive capacity. what the other safeguards of law are -- I mean, as prescribed ) ) ) 1 2 3 4 5 6 7 8 9 10 11 12 ) 13 14 15 16 17 18 19 20 21 22 23 24 25 \ .1" 14 810 N STREET (907)277-0572/Fax 274-8982 ANCHORAGE, ALASKA 99501 R & Reo U R T R E P 0 R T E R S statement. CHAIR NORMAN: Okay. Well, thank you very much for the COMMISSIONER FOERSTER: None. CHAIR NORMAN: Commissioner Foerster? COMMISSIONER SEAMOUNT: No questions or comment. just a moment. commissioner Seamount, any questions? CHAIR NORMAN: Thank you, Ms. Brady, if you'd remain for opportunity to provide testimony. August 4, 2005 public notice. We also appreciate the support the proposed regulation changes as outlined in the regulations to assist the public and the industry and we We appreciate the Commission's diligence in clarifying And third, the proposed regulations do not alter the current process for applying for permits to drill, nor will they add additional burden to operators. clear definition of a well branch. clarity in permitting proposed drilling locations and provide a Second, the proposed regulations clarify -- provide environmental standards. First, the proposed regulation changes do not diminish we believe these regulations do. explanation that was given this morning that comports with what requirements for well branches. And we appreciate the clarify the definition of well branch and permit to drill We understand the purpose of these proposed changes is to ') ') ) 1 2 3 4 5 6 7 8 9 10 11 12 ) 13 14 15 16 17 18 19 20 21 22 23 24 25 ..~ I ) 1 2 3 4 5 6 7 8 9 10 11 12 ) 13 14 15 16 17 18 19 20 21 22 23 24 25 ): ) ',) Are there any others in the audience that have any comments that they would like to offer for the benefit of the Commission as we consider the adoption of this proposed regulations? Okay. The Chair would note for the record I don't see anyone else asking to be recognized. I'll ask finally to see if any of the Commissioners have any general comments on the proposed regulations? COMMISSIONER SEAMOUNT: No, I have none. COMMISSIONER FOERSTER: I just want to thank the AOGA task force and the AOGCC Staff for the time that they have spent and the thoughtfulness they put into this, and also Mr. Mintz for his participation. CHAIR NORMAN: Yes, we thank all of you that have worked on this and have appeared and testified today. And it is the intent of this Commission that this proposed regulatory change not add to the financial or regulatory burden, that it be essentially a neutral change that will provide clarity to the regulations, but will not add any additional expense to persons operating under the regulations. If there are no other comments, and again the Chair does not for the record see any persons asking to be recognized, so accordingly without objection we will stand adjourned. (Recessed - 9:32 a.m.) 0828 R & R C 0 U R T R E P 0 R T E R S 810 N STREET (907)277-0572/Fax 274-8982 ANCHORAGE, ALASKA 99501 15 ) 1 2 3 4 5 6 7 8 9 10 11 12 ) 13 14 15 16 17 18 19 20 21 22 23 24 25 ) ) ) C E R T I F I CAT E UNITED STATES OF AMERICA ) )ss. STATE OF ALASKA ) I, Rebecca Nelms, Notary Public in and for the State of Alaska, residing at Anchorage, Alaska, and Reporter for R & R Court Reporters, Inc., do hereby certify: THAT the annexed and foregoing Public Hearing Regarding Proposed Changes to the Regulations regarding Drilling Programs was taken by Suzan Olson on the 6th day of September, 2005, commencing at the hour of 9:00 a.m., at the Alaska oil and Gas Conservation Commission, Anchorage, Alaska; THAT this Hearing Transcript, as heretofore annexed, is a true and correct transcription of the proceedings taken and transcribed by Suzan Olson; IN WITNESS WHEREOF, I have hereunto set my hand and affixed my seal this 12th day of September, 2005. Notary Public in and for Alaska My Commission Expires: 10/10/06 R & R C 0 U R T R E P 0 R T E R S 810 N STREET (907)277-0572/Fax 274-8982 ANCHORAGE, ALASKA 99501 16 ) ) 1. Like to call this hearing to order Date: Time: Located: September 6, 2005 Approximately 9:00 am 333 W. 7th Ave., Ste 100, Anchorage, Alaska Offices of the Alaska Oil and Gas Conservation Commission 2. Introduce the bench . Two Commissioners )- John Norman Chairman )- Daniel Seamount Commissioner )- Cathy Foerster, Commissioner . Lynn Hall/Suzan Olson ofR&R reporting making transcript of proceedings Can get copy from R&R court reporting. At this time I will inform the public of this agencies policy in regards to the Americans with Disabilities Act. No qualified individual with a disability shall be excluded, by reason of such disability, from participation in or be denied the benefits of the services, programs, or activities of a state agency; or be subjected to discrimination by any such agency. This agency operates each of its services, programs and activities so that a service, program or activity, when viewed in its entirely, is readily accessible to and useable by individuals with disabilities. Purpose- Alaska Oil and Gas Conservation Commission's Amendment to regulations re: Applications; Changes to Drilling Programs; Definitions. Hearing Notice of duly published on August 5, 2005 in Anchorage Daily News. 3. Proceedings held in accordance wi 20AAC 25.540- regulations governing public hearings. 4. Hearing will be recorded. 5. Appropriate to go ahead and close the meeting Register _, ) LUO ) MISCELLANEOUS tluARDS 10 I Dr) VQ,(I;/O(\ Z 20 AAC 25.005(e) is amended to read: (e) [IF A WELL HAS MULTIPLE WELL BRANCHES,] Each [EACH] well branch requires a separate Permit to Drill. If a previouslv drilled well is proposed to be redrilled below the structural or conductor casinp" to a new bottom-hole location, the application for a Permit to Drill must be accompanied bv all items required under (c) of this section. If concurrent multiple well branches are proposed from a single conductor, surface, or production casing, ill the applicant shall designate one well branch as the primary wellbore and include all items [INFORMATION] required under (c) of this section for a Permit to Drill for that well branchi[.] (2) for [FOR] each other [SUBSEQUENT] well branch, the application for a Permit to Drill need only include information under (c) of this section that is unique to that well branch and need not be accompanied bv [INCLUDE] the $100 fee. (Eff. 4/13/80, Register 74; am 4/2/86, Register 97; am 11/7/99, Register 152; am 6/4/2000, Register 154; am / / -- , Register _) Authority: AS 31.05.030 AS 31.05.090 20 AAC 25.015(a)(I) is amended to read: (1) submit and obtain the commission's approval of a new application for a Permit to Drill if the proposed surface location is changed, if the proposed bottom-hole location or the proposed location of an objective formation is changed by more than 500 feet laterally or vertically, or if the change requires a spacing exception under 20 AAC 25.055; however, no additional fee is required; 20 AAC 25.015(b)(l) is amended to read (1) submit and obtain the commission's approval of a new application for a Permit to Drill, accompanied by a fee of $1 00, if the proposed bottom-hole location or the proposed location of an 1 Register _, ) 200 ) MISCELLANEOUS BOARDS objective formation is changed by more than 500 feet laterally or vertically, or if the change requires a spacing exception under 20 AAC 25.055; (Eff. 4/13/80, Register 74; am 4/2/86, Register 97; am 11/7/99, Register 152; am --.1--.1 Register ~ Authority: AS 31.05.030 AS 31.05.090 20 AAC 25.990(74) is amended to read: (74) "well branch" means that portion of a well drilled below the structural or conductor casing to access a !!iven [SEP ARA TE] objective in a well with more than one bottom-hole location .2! whose bottom-hole location is beinp" or has been chanp"ed bv plup"p"inp" back and redrillinp"; (Eff. 11/7/99, Register 152; am, _/--.1 , Register ~ Authority: AS 31.05.030 2 ) ) Testimony of the Alaska Oil and Gas Association Alaska Oil and Gas Conservation Commissiòn (AOGCC) Regulation Changes in Title 20, Chapter 25 September 6, 2005 Good morning. My name is Judy Brady and I am the Executiv~ Director of the Alaska Oil & Gas Association (AOGA). AOGA is a non-profit trade association whose member companies represent the majority of oil and gas exploration, production, transportation, refining and marketing activities in Alaska. We are pleased to have this opportunity to provide public testimony to the Alaska Oil and Gas Conservation Commission (AOGCC) on the proposed regulation changes in Title 20, Chapter 25, of the Alaska Administrative Code dealing with well branches and applications for a Permit to Drill. AOGA's1ask group for AOGCC has reviewed the proposed regulations. Representatives of the task group are present in the audience. They are Barbara Fullmer - ConocoPhillips, and Harry Engel - BP. We understand the purpose of these proposed changes is to clarify the definition of "well branch" and permit to drill requirements for well branches. · First, these proposed regulation changes do not diminish environmental standards. · Second, the proposed regulations provide clarity in permitting proposed drilling locations and provide a clear definition of a "well branch". · Third, the proposed regulations do not alter the current process for applying for permits to drill, nor will they add additional burden to operators. We appreciate the Commission's diligence in clarifying regulations to assist the industry an; we support the proposed regulation changes as outlined in the August 4,2005 public notice. We appreciate the opportunity to provide testimony. :omments on Well Branch ) ) Subject: Comments on Well Branch From: Kara Moriarty <moriarty@aoga.org> Date: Tue, 13 Sep 2005 14:42:10 -0800 To:. 'JolmNotman'··<john ~ normàn@ådiÍ1in.state.ak.us> CC:'Jody J Colombie' <jody_colo11lbi~@admin.state.akus>, 'Judy Brady' <brady@aoga.org>, 'Tamara Sheffield' <sheffield@aoga.org> ' Commissioner Norman: Attached are AOGA's written comments regarding Regulation Changes in Title 20, Chapter 25, of the Alaska Administrative Code, dealing with well branches. The original letter will be mailed. Thank you. Kara Kara Moriarty Alaska Oil & Gas Association 121 W. Fireweed Lane, #207 Anchorage, AK 99503 (907)272-1481 Fax: (907)279-8114 moriarty@aoga.org I Content-Type: application/pdf Well Branch Written Comments 091305.pdf I C E do b 64 : ontent- nco Ing: ase 1 of 1 9/13/2005 2:44 PM #7 ~~-<: ÇJo 1 ~a No y~ No TESTIFY (Yes or No) (PLEASE PRINT~ ~~ \l\~ù~· ts- '- ~ffiC,- '\~.~ ~-\~£Q ~~\ste-n Neko(\ P'J~~ NP(I~~- _ì (U11 f3 r ¿¿ J¡ f.J . ¡ J _.~ fJ,¡¡ 7~J 't'ð-I ßAfLi)A1tA t='l> LUY\~ c.P A~ ( AOL.A ~It's:- 13'-1 , n ~) ~-, . .. .... t¿/ÆSí;/~ c //T1/v1ß- (;;~f-F'1 ..;/t:~.qS- J?:;1[5¿/~?'ç¿v f I'rR.-O¡J) Ðv G G- ßf fA- S be¡ -lj- /11 lJ~ '-:0 "'-- A ,,\JD ût Ao6LL 7 fL-! Z ~ I ADDRESS/PHONE NUMBER NAME - AFFILIATION Regulations: Changes to Drilling Programs September 6, 2005 9:00 AM STATE OF ALASKA OIL AND GAS CONSERVATION COMMISSION ) / ) ) ) STATE OF ALASKA OIL AND GAS CONSERVATION COMMISSION Regulations: Changes to Drilling Programs September 6, 2005 9:00 AM NAME - AFFILIATION ADDRESS/PHONE NUMBER -7 (PLEASE PRINT~ ~~ \J\o.-.~~. t.\... ~C'- ~~.~ -\~SZ) K",,\1.+e.n NeI<:.öf\ f,~~-eum !\k(,~!,~- .LU11 f!..rdi¡ Ærll:f1_.~.~2eJl¡~/ bAfJ)A.e.A F0 L.LJYlSz.. cP A~ r AO~,':t e1~$- , 3~ , ~7)/lAjß- (9!¿.~( ¡J~--,?ç I0lf~(ft1P- t:Moú) EJvGe- -ßftA- Sb<l-iJ-f'1Q lJ~-b "- A",,Jo Ut- Ao6CL 7 P ~ 12 ~ I /<..Ù bc:;r1 !lA ~ ~+t-- Do f-, TESTIFY (Yes or No) ~a No ye<Z. No :! (-$ fJD 1 CO ~ ---' #6 (,.. ~ I;;¡¡ ,;;) ·r:;lß: I, .~ ï"':"r:::l \.'\ 1\,1kIJ II i {/ III '~\ ¡ i i! '\,\; [U! / ,/1" \ :: ¡ ¡:'''"J 'iiI') , :. ",'r~' ,: ,L· t.:!./ l !~ij \\JJ l"",, l~ ·:Ir i·'r',·- il .- I ' U ) m"· ,.- ,"'."'\ .,~~ /8\\ ¡ r /8\ (S~ Ui ¡:ï \~ : i .f nr '., \ ì"U"~ ':1 !,' 'u ¡~ w \,,\J I·,,~V ) IjjÎf\ l'!(' / . , " / /1: \. j ,~\ FRANK H. MURKOWSKI, GOVERNOR AI1ASIiA. OILAlVD GAS CONSERVATION COMMISSION 333 W. pH AVENUE, SUITE 100 ANCHORAGE, ALASKA 99501-3539 PHONE (907) 279-1433 FAX (907) 276-7542 August 31, 2005 Dana L. Olson HC-35 Box 5438 Wasilla, AK 99564 Re: Your Special Accommodations Request Dear Ms. Olson: I am writing in response to your request, in your August 23, 2005, letter to the Alaska Oil and Gas Conservation Commission ("AOGCC"), for special accommodations for the September 6, 2005, AOGCC hearing. That hearing concerns proposed changes in Title 20, Chapter 25, of the Alaska Administrative Code, dealing with well branches, applications for a Permit to Drill, changes in a drilling program, redrilling, and plugging. In your letter, you stated that you have a "disability in communication in writing and in speech." You requested that the AOGCC provide you with a facilitator during the September 6th hearing to help you "focus," and you requested up to three hours to present your comments. The type of assistance you are seeking from a facilitator is not clear. In any event however, the AOGCC does not have facilitators available tó assist persons in formulating and communicating their comments. Neither can the AOGCC reasonably provide persons with up to three hours to present their comments, but you and others who wish to testify at the hearing will have the same reasonable amount of time in which to do so. Please note that other means of presenting your comments are available. You may have someone else speak on your behalf at the hearing. And, if you believe that you cannot orally communicate your comments in the reasonable time allowed, you can submit (during or after the hearing) a tape recording of your comments; any such tape recording will become part of the official record of the hearing. Also, you can make any written submission on the proposed regulation changes. There is no restriction on the length of the written comments that can be submitted by you or someone acting on your behalf. To be considered by the Commission, your tape recorded and/or written comments must be received by the AOGCC (at 333 W. 7th Avenue, Suite 100, Anchorage, AK 99501) no later than 4:30 p.m. on September 13,2005. Thank you for contacting the AOGCC and we hope this information is helpful. Sincerely, (1~ QC~fe~ JJJy J.ctotbmble Special Staff Assistant #5 L7 æ-.-1A,)? Ú ¿~L,--) /./C" -,5,5 go ---1,5 ý" 3 Þ-" ~;. / J., ~/ ,.(.4.-' /'9;S"/ '/:¿Z #'7, J -<'"T,/ ~~/ 99/' _ ~ ~ , ~."'",Sy 'L5 ~<9 ó? CJo --I t/ S /Ó,. P V 0¿é . ,~.'" f /(,¿J.'e',I,I, S f), ~í!l!e¡/>Jì SC/!ChO¡! ðvl9'- bfrS, J /f¿" ,,' /f E l' ¡¿ .,c 5;/ h v /l CLðm /?? 0 0/4* ð-:7-é)' d~tfl rb /J ¿;Y/:_C;/?~ /../y /PJ ~?77¿¿n/C/2//ð-2--7 //J úJn-h/?ý /'7//{JO ;/PJ S/eec;{, 7 ú);/l/?-'"".-,_I /1 / / / 7'0 <, '¿. "-';, 9-;h? r' ð-77 ¿ ro ø¿ / P' ,/?7é' /0 c c «s ~ Þ/,/cj/77VO ßr" /¿¿.r~¿>s,-.. III r/?o/lll-4-fev .) /' vt_/¡// /7é'ed.h7 /ð7l;Jer h~e Þ.P9n?é' r/~~ /1 cJ7 ß? /9//';/' /7c C -¿? ß?/-C c1- ;/ Þl ¿y rc/<" {/ ~#~YCJ<é' fi;:;" c7" 4t ~ ¿¿ /1 c:Ie (/Ç 1/1-.Æ/..o /n I" _ t::2E' '-C·'E-r\tE-~ f·,""" ,,_..., 'y \"""' ",' ß~fl ß(" q ":ì! ?l)nr It, !!.J! \l)J Z .iJ) do. ,I U ,) A~ ()j &. Ga GeN. ~41I .AI¡~~_'~ /l7f //711"/'/5/5 þ¿, /lei Sole+- my ð-v-Yn / p{7¿v./LJ ~ J'w//I rJ-e-ccl J?Jtl7't" In??/' /úß /-0 .3 ,lours) /or'evzhAl-:l!y ;þ Þ?z;/d/¿S.5 Ý/5/' !/#n~ l7'¿r;r /S~(/c=S, Ie-tic 5'ð/YC;/S'é'C/9')/99'7/ '#~phný'P9- '/", '--/...lJ",.ln) ~ '" ¿ k. c/ ,Jj4 x:n4../~, 1"/ It"" " j¿¿Cl,¿4¿ 4~é/5"-~_ /171/0 ?¿jft~ o~ /n-C;''4 1 ." :I_ V /: j, J ./ -1:.' _rei AZS ,,& /??/~9 «J~hcn/) S-r/9;PL/¿}/iH,rC . _ . ¿: /l ;";177/ 1"" ¡j€..~ /1"" J ¡79'/1J 0/9 '/ ~ :ç;;-.Ç ,I» Í,¡ ,6..#5> N LA c ef} c. e !z/J/71 tJ¡}¡:JO/;dJ9 /?J ¿CJV-v7'-~), ,dl ,;J~/I¿f yilt" /l~6. .. O¡://;,é"...._ .. .. /8/)/C1') r /¿/!5/ rr " ) (L) ~ß? ---0 3 - /7'-/. .,. ('--.5;//7--05 -0 9'/~?é( ~ 1 ~~!Í ¡;It4/L-£1 /Ú4~ c? '-/~ /l¿L1 3 t.9----ð ¿5 . . / /fJ, ¡- '2, 7¿: - a 7!?¿J W dl/ØJ ' . / J/( / 1: 5 F Ú~.pc;4 3-/;2 /!~ {)~¡;I'C('~ #4 ) ) MEMORANDUM State of Alaska Department of Law To: John K. Norman, Chair Alaska Oil and Gas Conservation Commission Dept. of Administration Date: August 12, 2005 File No.: 993-06-0055 Tel. No.: 465-3600 ~¿:~I From: Deborah E. Behr Chief Assistant Attorney General and Regulations Attorney Legislation and Regulations Section Re: Regulations File Opening Re: Applications; Changes to Drilling Programs; Definitions (20 AAC 25.005 - .990) We have received your memorandum of August 5, 2005 regarding this project, along with a copy of the proposed regulations and related documents. The project has been assigned to Assistant Attorney General Rob Mintz, phone number 269-5100. Our department's file number for this project is 993-06-0055. This file number should be used on any further correspondence pertaining to this project. cc: Mike Tibbles, Regulations Contact Dept. of Administration RECEiVE[) AUG 1 7 2005 DEB:pvp Jodie Colombie Alaska Oil and Gas Conservation Commission Dept. of Administration Alaska Oil & Gas Cons. Co!'nrn¡~~ir.m A!lthm:a[~e Robert Pearson, AAC Coordinator Lt. Governor's Office Larry Ostrovsky, Supervising Attorney Oil, Gas and Mining Section Rob Mintz Assistant Attorney General Anchorage #3 ") ) MEMORANDUM STATE OF ALASKA ALASKA OIL AND GAS CONSERV A TION COMMISSION TO: Deborah E. Behr Assistant Attorney General And Regulations Attorney Legislation and Regulations Section DATE: August 5, 2005 SUBJECT: File-opening request for new regulations project 20 AAC 25.005 Applications for a Permit to Drill; 20 AAC 25.015 changes to a drilling program; and 20 AAC 25.990 definitions / Regulations Contact Department of Administration We are requesting that you open a new file for a regulations project regarding changes in Title 20, Chapter 25, of the Alaska Administrative Code, dealing with well branches, applications for a permit to drill, changes in a drilling program, redrilling, and plugging. Enclosed is a copy of the public notice, Additional Regulations Notice Information, and a draft of the regulation. Please assign assistant attorney general Robert Mintz to this project. Our contact person for the project is Jody Colombie at 793-1221. #2 STATE OF ALASKA ) NOTICE TO PUBLISHER ) ADVERTISING ORDER NO. ADVERTISING ORDER SEE BOTTOM FOR INVOI.CE ADDRESS INVOICE MUST BE IN TRIPLICATE SHOWING ADVERTISING ORDER NO., CERTIFIED AFFIDAVIT OF PUBLICATION (PART 2 OF THIS FORM) WITH ATTACHED COpy OF ADVERTISEMENT MUST BE SUBMITTED WITH INVOICE AO-02614004 F AOGCC R 333 W 7th Ave, Ste 100 o Anchorage, AK 99501 AGENCY CONTACT DATE OF A.D. lady Colombie PHONE August 4, 2005 PCN M (907) 793 -1 ??l DATES ADVERTISEMENT REQUIRED: b Anchorage Daily News PO Box 149001 Anchorage, AK 99514 .August 5, 2005 THE MATERIAL BETWEEN THE DOUBLE LINES MUST BE PRINTED IN ITS ENTIRETY ON THE DATES SHOWN. SPECIAL INSTRUCTIONS: Type of Advertisement X Legal D Display Advertisement to be published was e-mailed D Classified DOther (Specify) SEE ATTACHED SEND INVOICE IN TRIPLICATE AOGCC, 333 W. 7th Ave., Suite 100 TO A nchcmu!e. A K 99:-;01 NUMBER AMOUNT DATE PAGE 1 OF 2 PAGES COMMENTS TOTAL OF ALL PAGES$ REF TYPE 1 VEN 2 ARD 3 4 ~IN 6MnllNT 02910 c::v r.r. P~M Ir. 6r.r.T ~v NMR DIST LlQ 05 02140100 73451 2 3 R:QUls¡;nóÑÈì)\¡¡t:~(! (. ~) ¡J ." ~-"...J. L'4BvvvL--- r/ " VI DIVISION APPROVAL: ) ') STATE OF ALASKA NOTICE OF PROPOSED CHANGES IN THE REGULATIONS OF THE ALASKA OIL AND GAS CONSERVATION COMMISSION The Alaska Oil and Gas Conservation Commission ("AOGCC") proposes to adopt regulation changes in Title 20, Chapter 25, of the Alaska Administrative Code, dealing with well branches, applications for a Permit to Drill, changes in a drilling program, redrilling, and plugging, including the following: the definition of "well branch" is proposed to be amended in 20 AAC 25.990(74) to make clear that it applies where an initial bottom-hole location is changed by plugging back and redrilling; 20 AAC 25.005(e) is proposed to be amended to clarify the Permit to Drill requirements for well branches; and 20 AAC 25.015 is proposed to be amended to make clear that it applies to prospective-only changes in drilling locations. You may comment on the proposed regulation changes, including the potential costs to private persons of complying with the proposed changes, by submitting written comments to the AOGCC, 333 W. ih Avenue, Suite 100, Anchorage, AK 99501. The comments must be received no later than 4:30 p.m. on September 13, 2005. Additionally, oral or written comments may be submitted at a hearing to be held on September 6, 2005, at 333 W. 7th Avenue, Suite 100, Anchorage, AK 99501. The hearing will begin at 9:00 a.m. and may be extended from day to day if necessary to accommodate those present before 9:30 a.m. who did not have an opportunity to comment. If you are a person with a disability who may need special accommodations, auxiliary aid or service, or an alternative communication format in order to participate in the process on the proposed regulation changes, please contact, the Commission's Special Staff Assistant, lody Colombie at 793-1221 by 4:00 p.m., September 1,2005 to ensure that any necessary accommodations can be provided. Copies of the proposed regulation changes may be obtained from the AOGCC office, 333 W. ih Avenue, Anchorage, Alaska 99501, or by telephoning the AOGCC at 907-793- 1221, or on the AOGCC website at: http://v-vww.aogcc.alaska.gov . After the public comment period ends, the AOGCC will either adopt this or another proposal dealing with the same subject, without further notice, or decide to take no action on it. The language of the final regulations may be different from that of the proposed regulations. YOU SHOULD COMMENT DURING THE TIME ALLOWED IF YOUR ) ) INTERESTS COULD BE AFFECTED. Written comments received are public records and are subject to public inspection. Statutory Authority: AS 31.05.030; AS 31.05.040. Statutes Being Implemented, Interpreted, or Ma Fiscal Information: The proposed regulation c increased appropriation. /7 .- Date: August 4,2005 (( --f Sp cific: AS 31.05.030. re not expected to require an Published: August 5, 2005 AO: 02614004 ) ) ADDITIONAL REGULATIONS NOTICE INFORMATION (AS 44.62. 190(d)) 1. Adopting agency: Alaska Oil and Gas Conservation Commission. 2. General subject of regulations: wells drilled in search of oil or gas 3. Citation of regulations: 20 AAC 25.005; 20 AAC 25.015; and 20 AAC 25.990. 4. Reason for the proposed action: updating and clarifying regulatory provisions in light of experience and information. 5. Program category and BRU affected: Alaska Oil and Gas Conservation Commission. 6. Cost of implementation to the state agency: zero. 7. The name of the contact person for the regulations John K. Norman, Alaska Oil and Gas Conservation Commission, 333 W. ih Avenue, Suite 100, Anchorage, AK 99501, (907) 279-1433. 8. / ~e: Public Notice ) Subject: Re: Public Notice From: "Ads, Legal" <legalads@adn.com> Date: Thu, 04 Aug 2005 15 :46:47 -0800 To: lady Colombie <jody_colombie@admin.state.ak.us> Hello Jody: BE SURE TO CHECK OUT THE LEGAL NOTICES ON-LINE. WE RECENTLY CREATED NEW LEGAL SECTIONS ON-LINE ESPECIALLY FOR THE STATE OF ALASKA. WE ARE OFFERING A 90 DAY FREE TRIAL ON ALL LEGAL ADVERTISING AS OF MAY 9TH TO PROMOTE OUR NEW ON-LINE, USER FRIENDLY CATEGORY'S. PLEASE TAKE THIS TIME TO TRACK YOUR CUSTOMERS AND SEE IF ON-LINE ADVERTISING IS RIGHT FOR YOU. Following is the confirmation information on your legal notice. Please review and let me know if you have any questions or need additional information. Account Number: STOF 0330 Legal Ad Number: 567271 Publication Date(s): August 5, 2005 Your Reference or PO#: 02614004 Cost of Legal Notice: $300.96 Additional Charges: Web Link: E-Mail Link: Bolding: Total Cost To Place Legal Notice: $300.96 Your Legal Notice Will Appear On The Web: www.adn.com: XXXX Your Legal Notice Will Not Appear On The wël;·····..·www...:···a·drl·..·:com: Thank You, Kim Kirby Anchorage Daily News Legal Classified Representative E-Mail: legalads@adn.com Phone : ( ..ši·Ö7"j·......257...~Lf2·§6.....·---......·... Fax: (907) 279-8170 On 8/4/05 11:40 AM, "Jody Colombie" <jody colombie@admin.state.ak.us> wrote: Please publish on 8/5/05. Jody Colombie 1 of 1 8/5/2005 8:21 AM ) ) Anchorage Daily News Affidavit of Publication 8/~/2005 1001 Northway Drive, Anchorage, AK 99508 PRICE OTHER OTHER OTHER OTHER OTHER GRAND AD# DATE PO ACCOUNT PER DAY CHARGES CHARG ES #2 CHARGES #3 CHARGES #4 CHARGES #5 TOTAL 567271. 08 I. 05 /2005 02614004 STOF0330 $300.96 $300.96 $0.00 $0.00 $0.00 $0.00 $0.00 $300.96 STATE OF ALASKA THIRD JUDICIAL DISTRICT Kimberly Kirby, being first duly sworn on oath deposes and says that she is an advertising representative of the Anchorage 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 aforesaid 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 the above dates and that such newspaper was regularly distributed 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 ;¡~11J;J ~~ Subscribed and sworn to me before ~~te: 5 ~..21Jt¡S Notary Public in and for the State of Alaska. Third Division. Anchorage, Alaska MY COMMISSION EXPIRES: f.a ~ dc¡; i~ ---l I\W 1 ~ \\\lrr({({llr \.\\.~"'" 'rt. SJ.¡JJ 1"''',.-: \.: J"";I .... ""'/ r"'" ~ ~. .' .... eo . . . ~~ ~ ~ ~:.~OTA~;':.Q ~ ~ a~Q· ~ := ÞUBl~C. ~ -~' ¡p ...... -.:¡¡::, ':';'\ ........ .I':r: ~~ -::. Q' .41~ ~T. ~-:--. ~% '.<i,; Of ,,~~. 'IQ'~ ~ ~~ .. . . . . . ~~~\\ :'¿././ ~1Of1 S'(pireS· \\\ ))11""1'" . ···,'ST~+É·:O·F·ALA!fi¿Ä"":~~';··;C:' . NOTICE OF PROPO')ED CHANGES IN THE REGUL.ATIONS OF THE AL.A,)KA OIL. AND GAS CON')ERVATIO~ COMMISSION . :.~¿~~ ~~ :~~'~'J\~.~r:~;~~)~~~~\ '~;:r~~i,~' ~~ '~!~,~~'~~nihs;.;'~~n'" ~ :'~':~CaC ~.~~,~;:~;::~~;, '~ l.O,Ot:!J ,,]":-lJllrl:;' J\¡,rr. J~'c-II tJr,)n.:nr.-~ aDDIIr.ar,l')n·~ lor t] t"'~rrr'.r I,., Dr.!.1 ~_h~rn~":":I .r. a d~ill..1.:;a ['.rl:U;I't:)m r-:-,]r.lllnl~ IJr.c úllJ;'9ln9 ,]: 1I)11':"";II-..:II.,,'].n'3 'nt." r'JI UI",n~ t,h'e,:c.:-I,nl"Ùrl 'jl I\I~II [Jran\:" I~ Dr.')J:.·O:..;-.J 1(. [11:- ~)I'T..?'r"]':-I'J .n 20 A"(!5 <;'1(11 "~, loJ ,".)k·' .:h:'ar rhal·" (Jljljl,,,¡ ·^,r,.,.r~ .)r, ,r"llol böttorr.·n':;I'; ,:..:,]I,,]r, "UII]"3'i'.j b. phJ~~,n~ each. .]r..] r.,.,jrll¡'n~· 20 AAC 25·:005.' o? , i, èr'JD·.j,:;~,j·toJ bo? ,]rr'~!Ìp.;ü I,] .:ll]r" , In'; P.;orm.l I" Dr"l requir~'TIents l.jr,^,~lll)rùr,er,~ ¡ 1]1'1]... '..: ',. .:..'~:":':">.:, 20 AAC 2S.OlSis'prOI?O~edtlJ t.:;o";"'~nrj"'d to "'¡"'òl<o? :~Ie::'rt~,adt o'cèl:;:sto' p'rospective·ohiY·ch!Jnge~ ,r, ,]r "I ,ng 1·).:ùl,oJr" :You:mdY·comm~t:ltohthe Ijr,:'ljr:",,'j r"'3,.d,JI..)r, .:r,ùn,~';" ,r1elu·),ng In", p.jl.,.rd,ù' I.costs:töprivateè~r:on~··ot ,;.:,mpl,ing I\¡,", Ir,.,. JroJPQ~"'I] ,r..)r'9';-: O. :.I.ID,""· fing·\NriNenC9f:1m.,.nl; Iv 'r,t.' ..,j(i(( 3D '1'1 'In.. ,.;on'JO:- 5,,:1.';- I('¡() ~ne."."roJ':JO; ÄK·99,50l..The .;.J.......m"'r": rY'u:.1 I)'" r.;>.:.,., ..';>,] r,.j h]I.,.r ",,)r, 1 JU P n", Qr, ~.,.PI.;orY,. ber:13., 2005.' . u,jd; I ;,:,n.)II,' o~ alorwritfen·ë()·"m:,~;"ty'~ü.:b~ 'lJb':;';tt~:.j·åfd·"h~'å":;~:9"t¿.b;;' n';ll] .)n ':'.,.tll.,.ml).,.r ¿ ~OOS·· at '])j \IIJ ;tn ...,~n'J'" .)"".,. 100. "r,..:~,,]r(J'3p. ..~ r 19~1) i r no:- rl-:.:.r I rig ,n, .11 1:11: ';II r. ':J I .: I),) 0 rT". or,ü ."nO. De ~ 'I( 1'~"lj-?rJ I ro,:" CQ.' lu .j,] , " ,,~'';>: :.Jr, 'oJ a"c,IT,moJO·)I.; If,'],.;> pr",:.,.nr c.o:-Ior.;o" ]() a.m "'''0 ,j,d r,OI "tJ.~ 0,', l:JaJJ,:,r~~II"III, Ie. ,:ümm.:nr II .1)'.1 or.; oJ p~r¡ùrl ""In ,] Q',,'JD"", ¡,nlJ m'J. 1',;.,.,] :.pE'e..]1 oe.:QrnmOaOI':Jn" ')III(III,Jr ~ .).C .)r ~.:-r" .(-= .)r an .'J11.::-rr"JTI.lf:: (('Immun,(OII')rl rarmor In Or"dr."r II') ~~~II\:~:0.'~~~"':1 Ij~?£ 1;'f.:,'·)L~ ~~ i~!:::~ '~~:. 7J.~: ~ ~~~~~S~~~L~)~~;:,~,;~: ~.~I!g~ ¿~:¡~I]:~(theprv';~J"~d r~~lJla'l ;"n ': horl~es n1,~~:~è;·obtClrned}r6~f.h~ .~~G:q·¢i ':.' q~fice, '3.33W: "If, ~. .,.I1u'; ~ n, r:,:,: 9 ~:.Ala,~.~q;:~?,5911.0r} Y ;~el:Pho?mgt~~< AOGCCot.907·''; 3·1,'1' ,)r ,:,r, rr,~ ""JL''-'~ webslte·?t.,.: .".,.' 0;.:;< http://w.ww:dó~C::c:åï<;l~·kà·:9bv .... .. ". .; I,~:"i .. Afterth;: cubl;'; c~mm,~,-,t ,r.I,:;r¡r:i¡ri;~'¡'::tÚ:~:~·ðbCt:N¡,,?¡¡.¡,;>~~~:~ih,';:.:,:;?ò, .otl)erpr.~úel>.]1 ·j.,.al,r,.; . JI¡ ,In rr.~ :am~ "ul:;,.;o ,^"In·]ul lurrn.,.r nQI,.~ oJr d:e,al:" to:tak.; no ·K,..)r, ,]r," Tn.,. IlJr'ÇI'JIJ~'" ':" In", I,r.a' r£o3'JI,]I,on;. m~.· 0.,. ~lIt.;>r~n! rr,)n-,n"JI 'J; Ir,,, cr.:;pr,:..,..] r"'3'J1al'ùn: VOU ')t-iOlILD CùMMt:.I"IIT.UURI!IG THE Tlrllt': ~LLCIJ\/t':O rt= VûuR ,r TI=RE:'T~(oJ'JI.D BE AFt-E(Tt:D J~lrltr.;-n (OI'T1menr: 1"',="r:~I."?'] ,':.re CUt'I..: r-:-\:or,'j1 aria 'JI"'': ~IJtJl'Ii?'C' I.J p\JDI.c 11"'.· .,Pt.'~ ..]n ;::~::~:~~ '6~ :~~:'),r~~I~rr,.,.~~~~5'~~~e;~~.,.~:,~5';:~~')Q'" ~ O~.:' ",:.::.A{~1:~9f·ô'~9:..; . F,,.,¡r Ir,lI]rm(JI,·:,n Tn.,. 1j'ljc·J''''·J r",~,.,I'JI..:;r, .:r,ùr, 3"'" IJr.,. r'oJtexpecte~t,o. "O::·Ju.r..; .Jr. ....,.:r-:-·J~t"a ù.:Jar'jtJr,t,J'I,)n Date: August 4, 2005 15/:' John K. Norman Chairman AO: 02614004 Published: August 5, 2005 02-902 (Rev. 3/94) ) Publisher/Onginal ) Copies: Department Fiscal, Department, Receiving AO.FRM STATE OF ALASKA ADVERTISING ORDER seE BOTTOM FOR INVOICE ADDRESS NOTICE TO PUBLISHER ADVERTISING ORDER NO. INVOICE MUST BE IN TRIPLICATE SHOWING ADVERTISING ORDER NO., CERTIFIED AFFIDAVIT OF PUBLICATION (PART 2 OF THIS FORM) WITH ATIACHED COPY OF ADVERTISEMENT MUST BE SUBMITIED WITH INVOICE AO-02614004 F R o M AOGCC 333 West ih Avenue. Suite 100 A nr.nor:;¡crf' A K qq"n 1 907 - 793-1221 AGENCY CONTACT DATE OF A.O. Joòv Colombie Aup"ust 4. ?005 PHONE PCN (907) 793 -1 ??1 DA TES ADVERTISEMENT REQUIRED: T o Anchorage Daily News PO Box 149001 Anchorage, AK 99514 August 5, 2005 THE MATERIAL BETWEEN THE DOUBLE LINES MUST BE PRINTED IN ITS ENTIRETY ON THE DATES SHOWN. SPECIAL INSTRUCTIONS: United states of America AFFIDAVIT OF PUBLICATION REMINDER State of ss INVOICE MUST BE IN TRIPLICATE AND MUST REFERENCE THE ADVERTISING ORDER NUMBER. A CERTIFIED COpy OF THIS AFFIDAVIT OF PUBLICATION MUST BE SUBMITTED WITH THE INVOICE. ATTACH PROOF OF PUBLICATION HERE. division. Before me, the undersigned, a notary public this day personally appeared who, being first duly sworn, according to law, says that he/she is the of Published at in said division and state of and that the advertisement, of which the annexed is a true copy, was published in said publication on the day of 2005, and thereafter for _ consecutive days, the last publication appearing on the _ day of , 2005, and that the rate charged thereon is not in excess of the rate charged private individuals. Subscribed and sworn to before me This _ day of 2005, Notary public for state of My commission expires 02-901 (Rev. 3/94) AO.FRM \!otice of Proposed Changes in AOGCC Regula! ) ) Subject: Notice of Proposed Changes in AOGCC Regulations From: Jody Colombie <jody _ colombie@admin.state.ak.us> Date: Thu, 04 Aug 2005 12:56:41 -0800 To: undisclosed-recipients:; BCC: Con Bunde <senator_con_bunde@legis.state.ak.us>, John Cowdery <senator john _ cowdery@legis.state.ak.us>, Bettye J Davis <senator _ bettye _ davis@legis.state.ak.us>, Johnny Ellis JR <senatorjohnny_ellis@legis.state.ak.us>, Kim S Elton <senator _ kim _ elton@legis.state.ak.us>, Hollis French <senator _ hollis _ french@legis.state.ak.us>, Lyda N Green <senator_lyda_green@legis.state.ak.us>, Gretchen G Guess <senator_gretchen_guess@legis.state.ak.us>, Lyman F Hoffman <senator _lyman _ hoffman@legis.state.ak.us>, senator _ ben_stevens <senator _ ben _ stevens@legis.state.ak.us>, senator _gary _stevens <senator _gary _ stevens@legis.state.ak. us>, senator_gene _ therriault <senator_gene _ therriault@legis.state.ak. us>, senator_ tho mas _ wagoner <senator _ thomas _ wagoner@legis.state.ak.us>, senator_gary _ wilken <senator _gary _ wilken@legis.state.ak.us>, mike chenault <representative_mike_chenault@legis.state.ak.us>, sharon cissna <representati ve _sharon _ cissna@legis.state.ak. us>, John Coghill <representativejoOO_coghill@legis.state.ak.us>, harry cra\VÍord <representati ve _harry _ crawford@legis.state.ak.us>, eric croft <representative _ eric _ croft@legis.state.ak.us>, nancy dahlstrom <representati ve _ nancy _ dahlstrom@legis.state.ak.us>, richard foster <representative _ richard _ foster@legis.state.ak.us>, les gara <representative _les _gara@legis.state.ak.us>, Carl Gatto <representative_carl_gatto@legis.state.ak.us>, max gruenberg <representative _ max _gruenberg@legis.state.ak.us>, david guttenberg <representative_david_guttenberg@legis.state.ak.us>, John Harris <representati ve john _ harris@legis.state.ak. us>, mike hawker <representative_mike _ hawker@legis.state.ak.us>, Jim Holm <representative j im _ holm@legis.state.ak.us>, reggie joule <representative _reggie joule@legis.state.ak.us>, mary kapsner <representative _ mary _ kapsner@legis.state.ak.us>, Beth Kerttula <representati ve _beth _ kerttula@legis.state.ak.us>, vic kohring <representative_ vic_kohring@legis.state.ak.us>, Albert Kookèsh <representative _ albert _ kookesh@legis.state.ak.us>, pete kott <representative -'pete _ kott@legis.state.ak.us>, Bob Lynn <representative_bob _lynn@legis.state.ak.us>, lesil mcguire <representative_Iesil_mcguire@legis.state.ak.us>, kevin meyer <representative _ kevin_ meyer@legis.state.ak.us>, carl morgan <representative _ carl_ morgan@legis.state.ak.us>, carl moses <representative _ carl_ moses@legis.state.ak.us>, norman rokeberg <representative _ norman _rokeberg@legis.state.ak.us>, ralph samuels <representati ve _ ralph _ samuels@legis.state.ak. us>, paul seaton <representative'-paul_seaton@legis.state.ak.us>, Bill Stoltze <representative_bill_stoltze@legis.state.ak.us>, Bruce Weyhrauch <representati ve _ bruce _ weyhrauch@legis.state.ak. us>, peggy wilson <representative-.peggy _ wilson@legis.state.ak.us>, Donny Olson of? 8/4/2005 I :07 PM \Iotice of Proposed Changes in AOGCC Regulat ) f ) <senator_donny _olson@legis.state.ak.us>, Ralph Seekins <senator_ralph_seekins@legis.state.ak.us>, Tom Anderson <representative_tom_anderson@legis.state.ak.us>, Ethan Berkowitz <representati ve _ ethan _ berkowitz@legis.state.ak. us>, Fred Dyson <senator_fred_dyson@legis.state.ak.us>, Bert K Stedman <senator_bert_stedman@legis.state.ak.us>, Kurt EDIson <kurt_olson@legis.state.ak.us>, repjay_ramras@Iegis.state.ak.us, rep jay _ ramras@legis.state.ak. us, Albert Kookesh <representative _ al bert _ kookesh@Iegis.state.ak.us>, senator_charlie _ huggins@legis.state.ak. us, rep Jim _ elkins@legis.state.ak.us, rep _ berta _gardner@legis.state.ak.us, rep _mike _ kelly@legis.state.ak.us, rep _mark_ neuman@legis.state.ak.us, rep _gabrielle _ledoux@legis.state.ak.us Content-Type: application/pdf Additional Regulation N otice.pdf C . b 64 on tent-Encoding: ase Content-Type: application/pdf Public N otice.pdf ' Content-Encoding: base64 of? 8/4000) I :07 PM ~otice of Proposed Changes in the AOGCC Reg tons ? ') Subject: Notice of Proposed Changes in the AOGCC Regulations From: lady Colombie <jody _colombie@admin.state.ak.us> Date: Thu, 04 Aug 2005 13:03:56 -0800 To: undisclosed-recipients:; BCC: Tom Wagoner <senator_tom_wagoner@legis.state.ak.us>, Vic Kohring <representative_ vic_kohring@legis.state.ak.us>, Tom Anderson <representative_tom_anderson@legis.state.ak.us>, Pete Kott <representative -pete _kott@legis.state.ak.us>, mary -pagenkopf@legis.state.ak.us , Content-Type: applicationlpdf Public Notice.pdf! ¡Content-Encoding: base64 I Content-Type: application/pdf Additional Regulation Notice.pdf Content-Encoding: base64 Content-Type: applicationlmsword i-Regulation.doc Content-Encoding: base64 of 1 8/4/7005 1 :07 PM >ublic Notice Regulations ) ) Subject: Public Notice Regulations From: Jody Colombie <jody_colombie@admin.state.ak.us> Date: Thu, 04 Aug 2005 12:54:20 -0800 To:undisclosed-recipientà:; , ,'. .' '.", ".,..'. , " . ,'. ' " ' BCe : Robert EMintz <robert_mintz@la\V.state.akus>,ChristilleHansen <c.hansen@iogcc.state.okus>, Te1JiefIubble~hubbletl~bp.com>, Sondra Stewrnan ,', .. '.,' <StewmaSD@BP.com>, Scott & Cammy TGtyl~r<staylår@~fªska.net>, stane~j <stanekj@unoca1.com>, ecolaw <ecolaw@trustees.org:, ros~rags(hde<roseragsdale@g9i.~et>,trmj~ 1 4trmjr l@aoLcom>, jbn.·,ddl, e.<",J.'·b..ri.dd. le,@m,arathon.o.,l,·.l".."..c,o"m>,'.".', sh, an.· "",.e,. g" <s,.h,....an.'·, e":"g@,e,..".v,',erg"re,."e.n,g"as.",,,c.o, m" >..'..:', Jd., "ar", lin,gt.on . I " ' ' , ' , , ' " , ' , ' , , ' ' , " "I' : " : " " '", " : : " , ' ", , ,,' , ¡ " " " " " I, ' ", " I ~' ':', ' :' I I , ',' , , " , <jdarlington@forestoi1.com>, nels()n-<:knels~)l1@p~trol~pm11ews.c(}Il1>'Cboddy' ""'., ' <cboddy@usibel1Lcom~, Mark Dalton<p1~~.dalton@hdrinc.com>,Shann<?nDonnel1y <shannon~donnelly.@con?cophillips.com>~"Mark P. ::V?rce~ter'" .....,.'" / ....' .', '..'"" ...,', ','., <markp.worcester@conocophillip~.col11> ~'. :ßob. <b9,þ@ip.le!keeper·org~,\Vdv<wdy@dnr.sta.te.a1\.us>, tjr <tjr@dnr.state.ak.us>, bbtdtch,,<bbrit~h@alas~a.ne~:,mjneIson '<~jnelson~p~r,\il1gertz.com>, Charles .O'DoB11ell <charles.o'donneU@veco~co~>,"ltandy k~ Skillet~"<Sk.ille~@~P.com>, "Deborah J. Jones" <JonesD6@BP.com>,"Steven R;Rossberg"<RdssbeRS@BP .com> ~Lois <lois@inletkeeper.org>, Dan Bross<kqacne\Vs,@kuac~org>, Gordon Po~pisi1 <PospisG@BP.com>, "Francis S. Sommer"<S0111m~rFS@BP ;9()l113,¥ikelSchultz <Mikel.Schultz@BP . com::>, "Nick W. Glover" <GloverNW@BP.com>,"Daryl J'I(I~ppil1" <l{leþpiD~@BP;f()ll1>,"Janet D.Pla1t" <PlattJD@BP .com>, "Rosanne M~ J acopsell" <J acpbsRM.@BP.col11>,ddo1Ù(el <dd0nkel@cfl.rr.com>, mckay <mckay@gci.net>, Barbara F Fullrner<barbara;Lfulbner@c01'l0cøphillips.com>,·bo9astWf <Þocastwf@bp.com>, Charles Barker <barker@usg~.gov>~ doug_~chultz~ ' . , <doug~ scJ;1ultze@xtoenergy.com> ,Hank Alfof~ <hani<.alford@exxolllTlöbi1.com>,Mark Kövac <yesno 1 @gcLnet>, gspfoff <gspfoff@aurorapower.com>, Gregg N ady<:gregg.nady@shel1.com>, Fred Steece <fred.steece@state.sd. us>, rcrotty <rcrotty@ch2m.com>, j ejones <j ej ones@aurorapower.com>, dapa <dapa@alaska.net>,jroderick <jroderick@gci.net>, eyancy <eyancy@seal-tite.net>~. "James M. Ruud" <james.m.ruud@conocophillips.com>,Brit Lively <mapalaska@ak.net>,jah <jah@dnr.state.ak.us>, Kurt E Olson <kurt_olson@l~gis.state.akus>, buonoje<buonoje@bp.com>, Mark Hanley <mark_hanley@anadarko.com>, loren_Iernan <loren_Ieman@gov.state.ak.us>,Julie Houle <julie_houle@dnr.state.ak.us>,John W Katz <jwkatz@sso.org>, Suzan J Hill <suzan _ hill@dec.state.ak.us>, tablerk <tablerk@unoca1.com>, Brady <brady@aoga.org>, Brian Havelock <beh@dnr.state.ak.us>, bpopp <bpopp@borough.kenaLak.us>, Jim White <jimwhite@satx.rr.com>, "John S. Haworth" <john.s.haworth@exxonmobi1.com>, marty <marty@rkindustria1.com>, ghammons <ghammons@ao1.com>, rmclean <rmclean@pobox.alaska.net>, mkm7200 <mkm7200@ao1.com>, Brian Gillespie <itbmg@uaa.alaska.edu>, David L Boelens <dboelens@aurorapower.com>, Todd Durkee <TDURKEE@KMG.com>, Gary Schultz <gary_schultz@dnr.state.ak.us>, Wayne Rancier <RANCIER@petro-canada.ca>, Bill Miller <Bill_Miller@xtoalaska.com>, Brandon Gagnon <bgagnon@brenalaw.com>, Paul Winslow <pmwinslow@forestoi1.com>, Garry Catron <catrongr@bp.com>, Sharmaine Copeland <copelasv@bp.com>, Kristin Dirks <kristin_dirks@dnr.state.ak.us>, Kaynell Zeman <kjzeman@marathonoi1.com>, John Tower <John.Tower@eia.doe.gov>, Bill Fowler <Bill_Fowler@anadarko.COM>, Vaughn Swartz <vaughn.swartz@rbccm.com>, Scott Cranswick <scott.cranswick@mms.gov>, Brad McKim <mckimbs@BP .com>, Steve Lambe <lambes@unoca1.com>, jack newell <jacknewell@acsalaska.net>, James Scherr <james_scherr@yahoo.com>, david roby <David.Roby@mms.gov>, Tim Lawlor 10f2 8/4/2005 1 :08 PM >ublic Notice Regulations ) ) <Tim_ Lawlor@ak.blm.gov>,Lynnda I(ahn <Lynnda_l(ahn@fws.gov>,Jerry Dethlefs <Jerry. C.Dethlefs@conocophillips~com> , Jerry Dethlefs <n 161 7@conocophillips.com>, crockett@aoga.org, Tamera Sheffield <sheffield@aoga.org>, Jon.Goltz <Jon.Goltz@conocophillips.com>, Roger Belm~ <roger.belman@conocophillips.com>, Mindy Lewis <mlewis@brenalaw.com>, Harry Lampert <harryJampert@honeyweILcom>,Kari Moriarty <moriarty@aoga.org>, Patty. Alfaro <palfaro@yahoo.com>, Jeff<smetankaj@unocal.com>, Todd Kratz <ToddKratz@chevron.com>,.Gary. Rogers <gary _Iogers@revel1lle.state~ak. us> Please disregard the Public. Notice that you received on 8/3/05, regardJ..ngproposed changes to the AOGCÇ regulations. Thank you. Jody Colombie' Special Staff Assistant , . I . . I Content-Type: application/pdf I: Public NOÍlce.pdf C E d· ... ·b6i. 4· ' I I .. ontent~ nco· lUg: ase , .. ' ..... .. .' ..... application/pdfi ' Additional Regulation Notice.pdf .. . ... ... . b·· · 64·· ' ConteDt~Encoding: . ase 20f2 8/4/2005 1 :08 PM >ublic Notice ) ~, " Subject: Public Notice From: lody Colombie <jody_colombie@admin.state.ak.us> Date: Thu, 04 Aug 2005 13: 10:20 -0800 To: Cynthia BMciver <bren_mciver@aâmin.state.ak.us> Content-Type: application/msword Additional Regulation Notice.doc,¡ C . b 64 ontent-Encodlng: ase Content-Type: application/msword I-Regulation.doc , Content-Encoding: base64 I I , I Content-Type: application/msword Public N otice.doc ' Content-Encoding: base64 1 of 1 8/4/2005 1: 10 PM )ublic Notice ') ¡ Subject: Public Notice From: Jody Colombie <jody _ colombie@admin.state.ak.us> Date: Thu, 04 Aug 2005 11 :40:36 -0800 To: Legal Ads· Anchorage Daily News <legalads@adn.com> Please publish on 8/5/05. Jody Colombie Content-Type: application/msword Ad Order form.doc Content-Encoding: base64 I I Content-Type: application/msword Notice of Well Branch.doc. C . b 64 . . ontent-Encodlng: ase ! 1 of 1 8/4/2005 1 :08 PM ) ) Citgo Petroleum Corporation PO Box 3758 Tulsa, OK 74136 Mary Jones XTO Energy, Inc. Cartography 810 Houston Street, Ste 2000 Ft. Worth, TX 76102-6298 David McCaleb IHS Energy Group GEPS 5333 Westheimer, Ste 100 Houston, TX 77056 Mona Dickens Tesoro Refining and Marketing Co. Supply & Distribution 300 Concord Plaza Drive San Antonio, TX 78216 Robert Gravely 7681 South Kit Carson Drive Littleton, CO 80122 George Vaught. Jr. PO Box 13557 Denver, CO 80201-3557 Jerry Hodgden Hodgden Oil Company 408 18th Street Golden, CO 80401-2433 Richard Neahring NRG Associates President PO Box 1655 Colorado Springs, CO 80901 John Levorsen 200 North 3rd Street, #1202 Boise, ID 83702 Kay Munger Munger Oi/lnformation Service, Inc PO Box 45738 Los Angeles, CA 90045-0738 Samuel Van Vactor Economic Insight Inc. 3004 SW First Ave. Portland, OR 97201 Michael Parks Marple's Business Newsletter 117 West Mercer St, Ste 200 Seattle, WA 98119-3960 Mark Wedman Halliburton 6900 Arctic Blvd. Anchorage, AK 99502 Baker Oil Tools 4730 Business Park Blvd., #44 Anchorage, AK 99503 Schlumberger Drilling and Measurements 2525 Gambell Street #400 Anchorage, AK 99503 David Cusato 200 West 34th PMB 411 Anchorage, AK 99503 Ciri Land Department PO Box 93330 Anchorage, AK 99503 Ivan Gillian 9649 Musket Bell Cr.#5 Anchorage, AK 99507 Jill Schneider US Geological Survey 4200 University Dr. Anchorage, AK 99508 Gordon Severson 3201 Westmar Cr. Anchorage, AK 99508-4336 Jack Hakkila PO Box 190083 Anchorage, AK 99519 Darwin Waldsm ith PO Box 39309 Ninilchick, AK 99639 James Gibbs PO Box 1597 Soldotna, AK 99669 Kenai National Wildlife Refuge Refuge Manager PO Box 2139 Soldotna, AK 99669-2139 Penny Vadla 399 West Riverview Avenue Soldotna, AK 99669-7714 Richard Wagner PO Box 60868 Fairbanks, AK 99706 Cliff Burglin PO Box 70131 Fairbanks, AK 99707 Bernie Karl K&K Recycling Inc. PO Box 58055 Fairbanks, AK 99711 Williams Thomas Arctic Slope Regional Corporation Land Department PO Box 129 Barrow, AK 99723 /J7a//ed' ~~5 J ) North Slope Borough PO Box 69 Barrow, AK 99723 ) ) Debra Behr Assistant Attorney General Department of Law PO Box 110300 Juneau, AK 99811 / /" ./ Legislative Reference Library Legislative Affairs Agency State Capitol Juneau, AK 99801 Mail Stop: 3101 Mat\ashO\NS\<.\ RaV . . ooer con1n1 \S~dr('Úo \strat\O 0 oept of 00 pO ßO)(. Ä.~2 998"\ "\ Juoeaù, , ?' "'. OJ / / ~ cL ( ~. 1 I ... / / ¿,(. : ¡! ?/F);; Register _, ) 2uO ) MISCELLANEOUS BUARDS 20 AAC 25.005(e) is amended to read: ( e) [IF A WELL HAS MULTIPLE WELL BRANCHES,] Each [EACH] well branch requires a separate Permit to Drill. If a previously drilled well is proposed to be redrilled below the structural or conductor casin2; to a new bottom-hole location, the application for a Permit to Drill must be accompanied bv all items required under (c) of this section. If concurrent multiple well branches are proposed from a single conductor, surface, or production casing, ill the applicant shall designate one well branch as the primary wellbore and include all items [INFORMATION] required under (c) of this section for a Permit to Drill for that well branch~[.] (2) for [FOR] each other [SUBSEQUENT] well branch, the application for a Permit to Drill need only include information under (c) of this section that is unique to that well branch and need not be accompanied by [INCLUDE] the $100 fee. 20 AAC 25.015(a)(1) and (b)(1) are amended to read: (a) To change a program approved in a Permit to Drill (Form 10-401) before drilling operations start, the operator shall (1) submit and obtain the commission's approval of a new application for a Permit to Drill if the proposed surface location is changed, if the proposed bottom-hole location or the proposed location of an objective formation is changed by more than 500 feet laterally or vertically, or if the change requires a spacing exception under 20 AAC 25.055; however, no additional fee is required; (b) To change a program approved in a Permit to Drill or to change information under 20 AAC 25.005(c) after drilling operations start, the operator shall (1) submit and obtain the commission's approval of a new application for a Permit to Drill, accompanied by a fee of $1 00, if the proposed bottom-hole location or the proposed location of an objective formation is changed by more than 500 feet laterally or vertically, or if the change requires a spacing exception under 20 AAC 25.055; 20 AAC 25.990(74) is amended to read: (74) "well branch" means that portion of a well drilled below the structural or conductor casing to access a 2;iven [SEP ARA TE] objective in a well with more than one bottom- hole location or whose bottom-hole location is bein2; or has been chan2;ed by plu2;2;in2; back and redrillin2;; #1 ) ) JUN 0 8 Z005 MEMORANDUM f~,la$!(a Oil ~tt t,,~¡¡nmi~r.Ïi~u~ State ófe~laska Department of Law To: John Norman, Chair Cathy Foerster, Commissioner Dan Seamount, Commissioner Alaska Oil & Gas Conservation COll1mission Date: June 7, 2005 Tel. No.: 269-5254 File No.: 661-05-0467 From: Robert E. Mintz ~ ~ fh- Assistant Attorney General Oil, Gas & Mining-Anchorage Re: Redrilling, well branches and plugging Review of recent applications to plug back the productive portion of a wellbore and "sidetrack" to a new target has brought to light some apparent regulatory ambiguities and possibly gaps, as well as tenninological issues, regarding wells that experience such sequential plugging and drilling operations. The terminological issues involve the proper use of the tenns "abandon," "sidetrack," "well branch," and "redrill." These issues, however, can be easily disposed of once it is decided how to address the underlying substantive issues. The substantive issues involve how to apply regulatory provisions governing: applications for a Permit to Drill, including the application fee; assignment of API numbers; single-well bonds; filing of data and reports upon completion or plugging; and Commission approval of plugging operations. To provide context for understanding these issues, it will be helpful to compare several different scenarios. The descriptions below are based on my reading of the Commission's regulations and on information provided to me by Winton Aubert as to actual Commission practices. Simple well First, consider the conventional case of a simple well with a single bottom-hole location. Before commencing drilling operations, the operator must submit an application for a Pennit to Drill (Form 10-401), meeting all the requirements of 20 AAC 25.005, including payment of a $100 application fee. The operator must also file a single-well bond, which contains an identification of the specific well in question, unless a blanket state-wide bond is in effect. 20 AAC 25.025. The well is assigned a unique API number by the Commission. 20 AAC 25.005(f). If, after drilling operations ) · John Nom1an, Cathy Foerster & Dan Seamount Re: Redrilling, well branches and plugging ) June 7, 2005 Page 2 start, the operator wishes to change the bottom-hole location by more than 500 feet, a new application for a Permit to Drill, accompanied by a fee of $100, is required. Smaller changes can be approved in response to an Application for Sundry Approvals (Form 10- 403). When a divergence from the planned the well path is necessary only "for the pUlpose of straightening the original hole, bypassing junk, or correcting mechanical difficulties in the original hole," this is known as a "sidetrack operation," 20 AAC 25.990(63), and it does not usually even require a sundry approval. See 20 AAC 25.050(a)(1). If the well is completed, within 30 days thereafter the operator n1ust file with the Commission (1) a digital copy of each inclination and directional survey not previously filed, 20 AAC 25.050(d); (2) a complete well record on the Well Completion or Recompletion Report and Log (Form 10-407), 20 AAC 25.070(3); and (3) logs, cutting samples, tests, and other geologic data, 20 AAC 25.071. If the well produces, the volumes of produced gas, oil, and water must be reported. monthly to the Commission using the well's API nun1ber. 20 AAC 25.230. Ultimately, the well will have to be abandoned, i.e., plugged in accordance with the plugging requirements of 20 AAC 25.112. See 20 AAC 25.990(1). However, under ce1iain conditions, the well may be suspended before being abandoned, which means that all but the surface plugging requirements for well abandonment must be 111et and the operator reserves the right later to re-enter the suspended well for redrilling or completion. 20 AAC 25.110; 20 AAC 25.990(70). In either case, the operator must submit for Comn1ission approval an Application for Sundry Approvals before carrying out the plugging operations. 20 AAC 25.105; 20 AAC 25.110. If the well had not previously been completed, the filing requiren1ents for a well record, geologic data, etc., referred to above must be met within 30 days after the well is suspended or abandoned. No later than a year after an onshore well is abandoned, the operator must satisfactorily perform location clearance operations, 20 AAC 25.170, and install a well abandonment marker, 20 AAC 25.120. Then, the Commission releases the single-well bond covering the well. 20 AAC 25.025(c). Multilateral well Now let's consider a "well with multiple well branches drilled to different bottom- hole locations." 20 AAC 25.990(73). Each well branch is a "portion of a well drilled below the structural or conductor casing to access a separate objective." 20 AAC 25.990(74). A well branch is often referred to as a "lateral," and a well with multiple well branches is often referred to as a "multilateral" well, although the regulations do not use these terms. ) . John N onnan, Cathy Foerster & Dan Seamount Re: Redrilling, well branches and plugging ) June 7, 2005 Page 3 Each branch of a well with multiple branches requires a separate Permit to Drill, but only one $100 application fee need be paid. 20 AAC 25.005(e). One branch is designated the primary wellbore. [d. Each well branch is assigned an API number by adding a suffix to the basic API number. 20 AAC 25.005(f). It appears that one single- well bond will suffice for a well with multiple branches. It is possible to complete fewer than all branches in a multilateral well. 20 AAC 25.990(14). Within 30 days after completing a well branch, the operator must file with the COlnmission (1) a digital copy of each inclination and directional survey not previously filed, 20 AAC 25.050(d); (2) a complete well record on the Well Completion or Recompletion Report and Log (Form 10-407), 20 AAC 25.070(3); and (3) logs, cutting samples, tests, and other geologic data, 20 AAC 25.071. If the well produces, the volumes of produced gas, oil, and water must be aggregated for all well branches and reported monthly to the Con1mission using the primary wellbore's API number. 20 AAC 25.230. An operator n1ay plug a well branch before abandoning or suspending the well. 20 AAC 25.107. An Application for Sundry Approvals must be submitted and approved before plugging operations are begun. Plugging a well branch does not trigger location clearance or well abandonment marker requirements or affect continued bond coverage. However, it does trigger the requirement to file reports and data under 20 AAC 25.050(d), 25.070(3), and 25.071, as described above. RedrilIing The regulatory treatment of the above two scenarios is reasonably clear and wen defined. N ow we con1e to the remaining scenario, whose regulatory treatment is less clear. Under this scenario, after a well has been drilled to a single bottom-hole location, and often has been completed and producing for some period of time, the operator wishes to plug back most of the wellbore and drill to a new bottomhole location from below the existing structural or conductor casing. Although the new drilling operation is often referred to as "sidetracking," that usage is inconsistent with the regulations' definition of sidetrack operation (see above). Probably the correct term under the regulations is "redrilling." Although that term is not defined, the way it is used in 20 AAC 25.005(a), 20 AAC 25.110(a)(I)(B), and 20 AAC 25.990(70) is consistent with this scenario. The central unresolved question is this: is the newly-drilled portion of the well a "well branch" under the regulations, or is it something different? If it is a well branch, then the existing regulations prescribe how to treat it. (However, in practice the Commission does not treat it in all respects like a well branch in a multilateral well.) If ) , John Norman, Cathy Foerster & Dan Seamount Re: Redrilling, well branches and plugging ) June 7, 2005 Page 4 the newly-drilled portion of the well is not a "well branch," then there are gaps in the existing regulations. The Commission's current administrative practice is to treat the redrilled well as a new and different well. I believe that, unlike with a branch in a multilateral well, a new $100 fee is required in connection with the application for a Permit to Drill. Although the basic API number remains the same, a new suffix is assigned to the well, using a numbering convention that differs from that used for a branch in a multilateral well. After the redrill, production is reported under the new API number. Also, the wellbore associated with the original API number is shown as "abandoned" in the Con1mission's records. This is an incorrect usage, because in order to be abandoned a well l11Ust be completely plugged, including surface plugs, and if the well is onshore the operator is required to perform site clearance and install an abandonment marker. Also, treating the redrill as a new well raises questions about the applicability of a single-well bond, unless the Con1mission requires the filing of an additional bond. Presumably, the surety on the original bond would resist demands to pay for abandoning the redrill, on the ground that it only undertook obligations with respect to the original well. If there are good regulatory reasons for treating redrills differently from well branches in a multilateral well, then the regulations should be amended to explicitly cover the plugging of the initial wellbore portion and the drilling to a new bottomhole location. Right now, the operator's report-and-data-filing obligations are triggered by abandoning or suspending a well and by plugging a well branch, but not by plugging back a portion of a wellbore to allow for a redrill. And while the regulations authorize an operator to apply for the Commission's approval to abandon or suspend a well or plug a well branch, there is no express procedure for approving the plugging back of a portion of a wellbore to allow for a redrill. On the other hand, if there is no good reason to distinguish between a redrill and a well branch, then the definition of well or well branch or both should be revised to make clear that a well can have more than one branch consecutively even if only one well branch exists at anyone time. Or if the appropriate treatment of redrills and well branches is generally identical but there are one or two differences that should be observed - e.g., a greater need for updated information in the Form 10-401 in the former case - it would be possible to include redrills in the definition of well branch but also provide where necessary for special regulatory treatment of a well branch that is drilled long after the well was initially completed. REM:tag cc: Winton Aubert