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Home My WebLink AboutCO 701 BCONSERVATION ORDER 701B Ninilchik Field 1. November 14, 2017 Public Hearing Transcript 2. November 15, 2007 Response to Directive of AOGCC STATE OF ALASKA ALASKA OIL AND GAS CONSERVATION COMMISSION 333 West Seventh Avenue Anchorage, Alaska 99501 Re: Application of Hilcorp Alaska, LLC., to Amend Conservation Order 701A (Ninilchik Field) to Expand and Redefine the Vertical and Horizontal Extent of Ninilchik Beluga/Tyonek Gas Pool. 1 Docket Number: CO -17-016 Conservation Order 701B Ninilchik Unit Ninilchik Field Beluga/Tyonek Gas Pool Kenai Peninsula Borough, Alaska. November 17, 2017 The Alaska Oil and Gas Conservation Commission ("AOGCC") is in receipt of Hilcorp's November 15, 2017 Response to Directive of AOGCC. In its response, Hilcorp requests that AOGCC withdraw its directive to Hilcorp to identify affected parties and provide proof of service to those parties. Conservation Order (CO) 701A contains a modification of well spacing requirements of 20 AAC 25.055. Hilcorp's request to update the Affected Area defined in Conservation Order 701A and referenced in Pool Rule 1 to add NWI/4NE1A of Section 7, TIN, R12W, SM has the effect of extending the well spacing exception to a new area, and is therefore effectively an exemption from 20 AAC 25.055 for the added land. The request therefore requires Hilcorp give notice to all owners, landowners and operators within 3000 feet of the boundaries of acreage proposed for the exemption which do not abut the current Affected Area. This order does not require notice to any owners or landowners within the current Affected Area. AOGCC has no desire to commence another hearing only to have a continuance necessitated by another affected party claiming it did not receive notice. Hilcorp's request to withdraw the directive is DENIED. Hilcorp shall identify affected parties within 3000 feet of the boundaries of the area it proposes to add to CO 701 A and provide proof of service to those parties. DONE at Anchorage, Alaska and dated November 17, 2017. Hollis S. French Cathy . Forester D� Chair, Commissioner Commissioner D Commissioner Conservation Order 701B November 17, 2017 Page 2 of 2 RECONSIDERATION AND APPEAL NOTICE As provided in AS 31.05.080(a), within 20 days after written notice of the entry of this order or decision, or such further time as the AOGCC grants for good cause shown, a person affected by it may file with the AOGCC an application for reconsideration of the matter determined by it. If the notice was mailed, then the period of time shall be 23 days. An application for reconsideration must set out the respect in which the order or decision is believed to be erroneous. The AOGCC shall grant or refuse the application for reconsideration in whole or in part within 10 days after it is filed. Failure to act on it within 10 -days is a denial of reconsideration. If the AOGCC denies reconsideration, upon denial, this order or decision and the denial of reconsideration we FINAL and may be appealed to superior court. The appeal MUST be filed within 33 days after the date on which the AOGCC mails, OR 30 days if the AOGCC otherwise distributes, the order or decision denying reconsideration, UNLESS the denial is by inaction, in which case the appeal MUST be filed within 40 days after the date on which the application for reconsideration was filed. If the AOGCC grants an application for reconsideration, this order or decision does not become final. Rather, the order or decision on reconsideration will be the FINAL order or decision of the AOGCC, and it maybe appealed to superior court. That appeal MUST be filed within 33 days after the date on which the AOGCC mails, OR 30 days if the AOGCC otherwise distributes, the order or decision on reconsideration. In computing a period of time above, the date of the event or defaultafter which the designated period begins to run is not included in the period; the last day of the period is included, unless it falls on a weekend or state holiday, in which event the period runs until 5:00 p.m. on the next day DECEIVED 0V I 12017 ACC STATE OF ALASKA ALASKA OIL AND GAS CONSERVATION COMMISSION 333 West 7th Avenue, Suite 100 Anchorage Alaska 99501 Re: Application of Hilcorp Alaska, LLC, ) Docket No. CO -17-016 to Amend Conservation Order 701A ) (Ninilchik Field) to Expand and ) Ninilchik Unit Redefine the Vertical and Horizontal ) Ninilchik Field Extent of Ninilchik Beluga/Tyonek ) Beluga/Tyonek Gas Pool Gas Pool ) Kenai Peninsula Borough, Alaska RESPONSE TO DIRECTIVE OF AOGCC Hilcorp Alaska, LLC ("Hilcorp Alaska") herewith responds to the Alaska Oil and Gas Conservation Commission ("AOGCC," the "Commission") directive regarding notice of this application and to clarify the issue under consideration in this matter. First, we request that the Commission revoke its directive stated at the conclusion of the hearing held on November 14, 2017, regarding Hilcorp Alaska's obligation to identify "affected parties" and to provide proof of notice to said parties. Second, we request that the Commission reaffirm that the only issue to be resolved in this matter is Hilcorp Alaska's application to amend Conservation Order 701A regarding the extent of the Ninilchik Beluga/Tyonek Gas Pool. I. Proceedings to Date On August 29, 2017, Hilcorp Alaska submitted a request to the AOGCC to amend Rule 2 in Conservation Order 701A to alter the vertical definition of the Ninilchik Beluga/Tyonek Gas Pool. The requested amendment proposed revising Rule 2 to read: Rule 2. Pool definition The Ninilchik Beluga/Tyonek Gas Pool comprises the gas -bearing intervals common to and correlating with the interval between the measured depths of 1,555 feet and 9,035 feet in the Kalotsa #3 well. The application also updated the Affected Area defined in Conservation Order 701A and referenced in Pool Rule 1 to add the NWl/4NEI/4 of Section 7, TIN, RI 2W. Hilcorp Alaska, LLC, Response to Directive of AOGCC Page 1 November 15, 2017 As provided in 20 AAC 25.540, the AOGCC prepared and published a public notice which, among other items, set a tentative hearing for October 25, 2017, should a person make a request that the hearing be held. Pursuant to discussions with AOGCC staff, Hilcorp Alaska clarified that the Affected Area included the NWI/4NE1/4 of Section 7, TIN, R12W, to coincide with the expansion of the Ninilchik Unit as directed by the Alaska Department of Natural Resources. The original notice was amended to state that Hilcorp Alaska's application sought a redefinition of both the vertical and horizontal boundaries of the Affected Area and to change the date of the tentative hearing. The updated notice was published, setting a hearing date of November 14, 2017. Both the original notice and the updated notice are attached to this Response. In compliance with the AOGCC regulations, the AOGCC published the notices in the Anchorage Daily News. In addition, the AOGCC sent the notices to an email mailing list which the AOGCC maintains 2, posted the notice on the AOGCC website and further posted same on the State of Alaska Online Public Notices website. AOGCC regulations do not require an operator who applies for a change in pool rules to provide public notice or individual notice to anyone.3 Accordingly, Hilcorp Alaska did not provide any public or individual notice of its application. On October 10, 2017, Don Shaw submitted to the AOGCC a request that the hearing be held. Mr. Shaw's request did not set forth any substantive objections to Hilcorp Alaska's application. A copy of the request is attached to this Response.' ' 20 AAC 25.540(a) provides: On its own motion or if a written request is received to issue an order affecting a single well or a single field, the commission will publish notice in an appropriate newspaper as provided in AS 31.05.050 (b). In the notice, the commission will set out the essential details of the requested order, provide an opportunity for public comment, tentatively specify the place, time, and date for a public hearing, and provide a telephone number that the public may use to learn if the commission will hold the tentative hearing. The commission will tentatively set a hearing date that is at least 30 days after the date of publication of the notice. A person may submit a written protest or written comments during that 30 -day period. In addition, a person may request that the tentatively scheduled hearing be held by filing a written request with the commission within 15 days after the publication date of the notice. If the commission receives a timely request for hearing, or if the commission desires to hold a hearing, the commission will hold a hearing on the date and time specified in the notice. If a request for hearing is not timely filed, the commission will, in its discretion, issue an order without a hearing. 2 A person need only ask the Commission to be placed on the email mailing list, and they will be added to the list. 3 AOGCC regulations require an applicant to provide notice in only two proceedings. An applicant seeking a spacing exception must provide notice to certain persons pursuant to 20 AAC 25.055(d). An applicant for an order permitting hydraulic fracturing of a formation must provide notice to certain persons. 20 AAC 25.283 (a)(1). In all other instances where an order would affect a single well or a single field, the Commission undertakes public notice in accordance with 20 AAAC 25.540. Mr. Shaw does not own lands or mineral rights or overriding royalty interests or any other interest included in the Ninilchik Unit. Hilcorp Alaska, LLC, Response to Directive of AOGCC Page 2 November 15, 2017 On November 13, 2017, attorneys representing PLC, LLC, and MH2, LLC (holders of overriding royalty interests in lands currently included in the Ninilchik Unit) wrote a letter to the AOGCC. The letter was apparently submitted to notify the AOGCC of legal proceedings surrounding the expansion of the Falls Creek Participating Area ("FCPA") of the Ninilchik Unit which is the subject of a current proceeding before the Alaska Department of Natural Resources and the Alaska Superior Court. The letter also purported "to remind the AOGCC of its statutory duty in all cases of involuntary unitization—namely, unit -related issues in which one or more parties in interest within or adjacent to a unit to not voluntary agree to one or more terms of the unit, including but not limited to allocation of production (i.e., correlative rights)." A copy of the letter is attached to this Response. A hearing was held on November 14, 2017. At the hearing, the University of Alaska claimed that it had received notice of the matter only the evening before from counsel for owners of overriding royalties on tracts within the Ninilchik Unit. The University provided a letter dated November 14, 2017, restating that it had received notice the evening before, and that they believe the AOGCC is the proper agency to review questions surrounding the FCPA. A copy of the letter is attached to this Response. The AOGCC did not hear the merits of Hilcorp Alaska's application. Rather, at the conclusion of the hearing, the AOGCC directed Hilcorp Alaska to provide a list of all "affected parties," and provide proof that Hilcorp Alaska had provided said affected parties individual notice of the application. II. AOGCC Has Provided Proper Notice in this Matter and No Further Notice is Appropriate As noted above, this matter is an application for an order which affect a single field. Pursuant to 20 AAC 25.540, the Commission provided public notice, not only by publishing the notices in Anchorage Daily News, but also by posting the notices on its website, the State of Alaska Online Public Notice website and sending the notices to the email list maintained for such purposes. There is no requirement that the applicant provide either public or individual notice of its application to anyone. To the knowledge of Hilcorp Alaska, no applicant for an order affecting a single well or a single field (other than spacing exceptions or hydraulic fracturing) has provided individual notice of the application. The notice process was apparently sufficient to allow Don Shaw and the attorneys for PLC, LLC, and MH2, LLC, to respond and either appear at the hearing or file a response with the AOGCC. As the holder of a large endowment of public lands, and as a participant in the DNR proceedings respecting the Ninilchik Unit, one might anticipate that the University of Alaska would follow public notices in newspapers and request to be placed on the AOGCC email mailing list of matters affecting its properties. The University of Alaska has stated it was not individually notified of this proceeding, even though such notice is not required by the regulations. Directing Hilcorp Alaska to list all the "affected Hilcorp Alaska, LLC, Response to Directive of AOGCC Page 3 November 15, 2017 parties" and prove that it had already provided individual notice to such parties is not an appropriate remedy. By reasonable inference, the direction assumes that Hilcorp Alaska should have provided individual notice to the nearly 300 mineral owners (not including overriding interest owners) within the Ninilchik Unit and perhaps those who own land within some unspecified distance of the unit boundaries. This is a burden wholly inappropriate given the nature of the application and the lack of any such requirement in the regulations. The AOGCC has provided notice of this matter in compliance with its regulations. No further notice is or should be required. II. The Only Matter before the AOGCC is the Vertical and Horizontal Extent of CO 701A Pool Rule 2. Hilcorp Alaska initiated this matter by applying for a redefinition of the vertical extent of the pool. The AOGCC issued a public notice of the application. During its review of the application, AOGCC staff correctly noted that the Affected Area described in Hilcorp Alaska's application had been enlarged to include the NWl/4NE1/4 of Section 7, TIN, R12W. Accordingly, the AOGCC prepared and published an updated notice to change the hearing date. Therefore, the only issue before the AOGCC is the requested expansion of the Pool to include the NWl/4NE1/4 of Section 7, TIN, R12W and to modify the vertical depth to include the interval between the measured depths of 1,555 feet and 9,035 feet in the Kalotsa #3 well. There are no other issues properly before the AOGCC. The University of Alaska, PLC, LLC, MH2, LLC, and Don Shaw had suggested there are many other issues surrounding the Ninilchik Unit which the AOGCC should consider and resolve. While these are interesting topics, they are not before the AOGCC and should not be heard in this proceeding. The University of Alaska, PPC, LLC, and MH2, LLC, suggest that AOGCC should take over from the DNR and the Alaska Superior Court the consideration and resolution of the current dispute respecting the extent of the FCPA. Hilcorp Alaska will not opine on the merits of this position except to say that none of these issues are before the AOGCC in this matter. To the extent these persons desire to invoke the AOGCC authority regarding involuntary unitization or any other topic, the proper step is to initiate their own proceeding before the AOGCC. It is difficult to understand the nature of Mr. Shaw's objections. A written philippic authored by Mr. Shaw and dated June 5, 2017, was provided to Hilcorp Alaska at the hearing. These comments were made as part of the DNR proceedings on the proper extent of the FCPA. Suffice to say that none of them are directed to the vertical or horizontal extent of the Ninilchik Beluga/Tyonek Gas Pool. A copy of Mr. Shaw's letter (without the extensive exhibits) is attached to this Response. IIl. Conclusion The AOGCC provided public notice of Hilcorp Alaska's application in accordance with 20 AAC 25. 540. No further notice is required in this matter. Hilcorp Alaska, LLC, Response to Directive of AOGCC Page 4 November 15, 2017 The AOGCC should consider issuing an order directing that all participants in this matter must confine their written comments and any testimony provided at the December 14, 2017, hearing to the question of the vertical and horizontal extent of the Ninilchik Beluga/Tyonek Gas Pool. Dated at Anchorage, Alaska this 15th day of November, 2017 Cody T. Terrell, Landman Hilcorp Alaska, LLC cc: Jody Colombie, Special Assistant, AOGCC (via email) Kenneth J. Diemer, Unit Manager, State of Alaska, DNR (via email) Chantal Walsh, Director, Alaska Division of Oil and Gas (via email) Hilcorp Alaska, LLC, Response to Directive of AOGCC Page 5 November 15, 2017 Notice of Public Hearing STATE OF ALASKA ALASKA OIL AND GAS CONSERVATION COMMISSION Re; Docket Number: CO -17-016 Ninilchik Beluga/Tyonek Gas Pool, Ninilchik Unit Redefine Vertical Boundries of Pool Hilcorp Alaska, LLC, by application received August 29, 2017, requests the Alaska Oil and Gas Conservation Commission (AOGCC) revise Rule 2 of Conservation Order 701A to redefine the vertical boundaries of the Ninilchik Beluga/Tyonek Gas Pool. The AOGCC has tentatively scheduled a public hearing on this application for October 25, 2017, at 10:00 a.m. at 333 West 7s' Avenue, Anchorage, Alaska 99501. To request that the tentatively scheduled hearing be held, a written request must be filed with the AOGCC no later than 4:30 p.m. on October 2, 2017. If a request for a hearing is not timely filed, the AOGCC may consider the issuance of an order without a hearing. To learn if the AOGCC will hold the hearing, call (907) 793-1221 after October 6, 2017. In addition, written comments regarding this application may be submitted to the AOGCC, at 333 West 7�' Avenue, Anchorage, Alaska 99501. Comments must be received no later than 4:30 p.m. on October 17, 2017, except that, if a hearing is held, comments must be received no later than the conclusion of the October 25, 2017 hearing. If, because of a disability, special accommodations may be needed to comment or attend the hearing, contact the AOGCC's Special Assistant, Jody Colombie, at (907) 793-1221, no later than October 19, 2017.' Hollis S. French Chair, Commissioner Notice of Public Hearing STATE OF ALASKA ALASKA OIL AND GAS CONSERVATION COMMISSION Re: Docket Number: CO -17-016 Ninilchik Beluga/Tyonek Gas Pool, Ninilchik Unit Redefine and Expand Vertical and Horizontal Affected Area of Pool Hilcorp Alaska, LLC, by application received August 29, 2017 and amended by email on October 3, 2017, requests the Alaska Oil and Gas Conservation Commission (AOGCC) revise Rule 2 of Conservation Order 701A to redefine the vertical and horizontal boundaries of the Ninilchik Beluga/Tyonek Gas Pool and to expand the Affected Area of the pool to include the NWI/4NE1/4 of Section 7, TIN, R12W. The public hearing scheduled for October 25, 2017 at 10:00 a.m. is VACATED. The AOGCC has tentatively scheduled a public hearing on the amended application for November 14, 2017, at 10:00 a.m. at 333 West 71' Avenue, Anchorage, Alaska 99501. To request that the tentatively scheduled hearing be held, a written request must be filed with the AOGCC no later than 4:30 p.m. on October 27, 2017. If a request for a hearing is not timely filed, the AOGCC may consider the issuance of an order without a hearing. To learn if the AOGCC will hold the hearing, call (907) 793-1221 after November 3, 2017. In addition, written comments regarding this application may be submitted to the AOGCC, at 333 West 7s' Avenue, Anchorage, Alaska 99501. Comments must be received no later than 4:30 p.m. on November 13, 2017, except that, if a hearing is held, comments must be received no later than the conclusion of the November 14, 2017 hearing. If, because of a disability, special accommodations may be needed to comment or attend the hearing, contact the AOGCC's Special Assistant, Jody Colombie, at (907) 793-1221, no later than November 7, 2017. //signature on file// Hollis S. French Chair, Commissioner -7b q% to/ .5� RECEIVED OCT 10 2017 AOGCC Bankston Gronning O"Hara November 13, 2017 Hollis French, Chair Alaska Oil and Gas Conservation Commission 333 West 7`h Avenue Anchorage, Alaska 99501 William M. Bankston,Shareholder Christopher -M. Brecht Shareholder Chris D. Gromdng, Shareholder Steven T. D'Aara, shareholder Renee J. Sbeyko, Associate - Julius J. Brecht Of counsel Mark W. Fullmer, of counsel wbankstonQa bgolaw.pro Sent via facsimile Re: Docket Number: CO -17-016 Ninilchik Belugail'yonek Gas Pool, Ninilchik Unit .Redefine and Expand Vertical and Horizontal Affected Area of Pool Our File .No. C2934-33 Dear`Conimissioner French: The law firm of Bankston Gronning O'Hara represents PLC, LLC and MM2, LLC. The following comments in reference to the above Docket Number are submitted on behalf of those entities. The Alaska oil and Gas Conservation Commission ("AOGCC") has scheduled a hearing on November .13, 2017 regarding the vertical and horizontal boundaries of the pool of gas being produced from and around the Falls Creek Participating Area ("FCPA") in the Beluga and Tyonek formations—specifically in the NW1/4 and NE -1/4 of Section 7, TIN, R12W. This letter is submitted to notify the AOGCC that PLC, LLC and MH2; LLC (the "LLCs") are the owners of record of an overriding royalty interest ("GRRI') in a State of Alaska lease within the Ninilchik Unit ("N17") contiguous with the north boundary of the RCPA, The LLCs have filed two actions in the Superior Court for the State of Alaska, Third Judicial District at Kenai (Case No. 3KN-17-00649 Cl and Case No. 3KN-17-00650 CI) in response to the Alaska Department of Natural Resource's ("DNR") decision. regarding allocation of production from the FCPA. Case Number 3KN-17-00649 Cl includes AOGCC as a named defendant. In addition to written notification regarding Case No. 3KN-17-00649; this letter is submitted to remind the AOGCC of its statutory duty in all cases of involuntary unitization— namely, unit -related issues in which one or more parties in interest within or adjacent to a unit do not voluntary agree to one or more terms of the unit, including but not limited to allocation of production (i, e., correlative rights). .The focus of the LLCs' complain. t centers on the statutory duties and responsibilities of DNR as contrasted with AOGCC with respect to defining the areal extent of pools of oil or gas, 601 West Fifth Avenue; .Suite 900 Anchorage, Alaska 99501 T907,276.1711F907.279.5358 w .bgolaw.prb Alaska Oil and Gas Conservation Commission November 13, 2017 Page 2 and the follow -along boundaries of units and participating areas within these units. More specifically, the complaint focuses on DNB's and AOGCC's respective responsibilities during Voluntary unitization as contrasted with involuntary unitization. For purposes of the hearing on November 13, 2017, I would encourage AOGCC to assume its statutory duties pertaining to involuntary unitization. There is no reason for AOGCC to continue to allow DNR to usurp AOGCC's statutory duties simply because "that's the way we've always done it." AOGCC does not need to wait for a decision from the Alaska court in Case No. 3KN-17-00649 to define the AOGCC's duties when these duties are already clearly defined in statute. In involuntary unitization cases, AOGCC has very specific statutory responsibilities that may not be delegated to DNR' The only responsibility that the AOGCC may delegate to DNR is collection of information as clearly stated in the AOGCC enabling statutes.2 Any :decision regarding the underlying pool(s) of gas and the follow -along decisions about the boundary ofthe NU, and the FCPA 'within the NU, must be determined by the AOGCC after it reviews all available information regarding the regional geology, geophysics, and well data? Data that shouldbe reviewed by the AOGCC pursuant to its statutory duty includes the confidential geological report submitted by Hilcorp when it applied to the DNR for expansion of the FCPA on November 2, 2016. The confidential data does not need to be made public by AOGCC. AOGCC has a long track record of managing proprietary ail and gas data confidentially. However, to properly reach a decision in the context of involuntary unitization proceedings, AOGCC must collect, analyze, and consider all of the available information before it decides about the areal and vertical distribution of,a pool of oil and gas to assure that all parties in interest have their correlative rights protected, If no parties in interestt contest one or more aspects of a proposal to create a unit; a proposal to change an existing unit boundary; a proposal to create a participating area; or a proposal to change an existing participating area boundary, then the proceeding remains voluntary and can be decided exclusively by DNR pursuant to DNR's statutory duties. However, whenever one or more parties in interest within it unit or adjacent to a unit contest allocation of production or assert a violation of correlative rights; then the associated proposal to create a unlit; proposal to change an existing unit boundary; proposal to create a participating area; or, the:proposal to change an existing participating area boundary ceases to be voluntary and is then involuntary. When a unit -related decision becomes involuntary, the AOGCC is the quasi-judicial body that must detennine the unit and/or participating area AS 31.05.110(q). AS 31.05.026(p). 3 AS 31.05.:110(b). i- 601 Wes# fifth Avenue. suite 900 Anchomge Alaska 09501 Y 907276170 F 907:279.53sa www.6rojaw.pro Alaska Oil and. Gas Conservation Commission November 13, 2017 Page 3 boundaries after using all available data .to define one or more pools of oil or gas in the reservoirs below the properties considered for unitization. The DNR has opined that an ORRI is not an interest in a lease and that an owner of an Opti �is not parties in interest. Theselegal issues have been taken on appeal from that DNR decision up by the Alaska Superior Court in Case Number 3KN-17-00650 Cl, ORRI owners aside, if there is an owner of mineral rights in or around the NU and/or FCPA that questions allocation of production, it cannot be argued that such a person lacks standing. In summary, to the extent a party in interest asserts its correlative rights in a manner that shifts decisions about the NU and/or the FCPA from voluntary to involuntary, then the AOGCC has a duty to consider all the available • data and to issue a decision about the pool in a manner that prevents waste and protects correlative rights, and AOGCC may not delegate that duty to DNR or any other entity. For the same reason that AOGCC will not allow waste in the form of drilling.multiple gas wells in one square mile of land (unless an exception to this regulation prevents waste and in izes production of gas reserves), AOGCC has an obligation to prevent waste that would be caused by requiring every mineral right owner within a section to collect his/her own seismic data to prove 'drainage. Any and all existing seismic data, well data, and confidential geologic reports regarding lands involved in an involuntaryunitisation proceeding before AOGCC can and should be reviewed by AOGCC for purposes of preventing waste and protecting the correlative rights of allparties in interest. in closing, I would encourage AOGCC to use the current opportunity to exercise its statutory duties by obtaining the confidential geological report. held by the DNR, the seismic data held by Hilcorp, and any other geological, geophysical; and/or well data that could be made available to AOGCC regarding the FCPA within the NU, and to expand the FCPA in a manner that protects the correlative rights of all private land owners, the University of Alaska, and the LLCs without creating waste by requiring each landowner to collect and analyze its own seismic data. Very truly yours, B NKSTON GRRONNING O'HARA, P.C. WMB:efv ca: PLC, LLC William M. Bankston NM LLC Peter J. 'Caltagirone Tab Ballantine C2934133tLTRaogccWMB6omments.CO-17-016 601 "Jest Fifth Avenua. su,fe goo .vnchor qe Ala lca 9135o7 ! s T go) 276-171111 907279.5356 www6golpw om Christine Klein Chief Facilities & Lands Officer Phone: (907) 786-7781 Fax: (907) 786-7733 Email: ceklein@alaska.edu November 14, 2017 UNIVERSITY of ALASKA Afar v Tmditims flac AWep r"acilities & Land Management University of Alaska System 1815 Bragaw Street, Suite 101 Anchorage, AK 99508 Web: www.ualand.com Hollis French, Chair Sent Via Email and Hand Delivery Alaska Oil and Gas Conservation Commission Hollis. Frencht@alaska.gov 333 West 7th Ave Anchorage, AK 99501 Re: Docket Number CO -17-016 Nilnilchik Beluga/Tyonek Gas Pool, Nilnilchik Unit Redefine and Expand Vertical and Horizontal affected Area of Pool Dear Commissioner French: The University of Alaska is an interested party in this proceeding as it owns Tract 19 (T.IN, R.12W, S.M., AK, Sec 6: SEI/4NE1/4) that was included in Hilcorp Alaska's original Falls Creek PA expansion proposal. The University did not receive notice of this proceeding until yesterday at 4:30 p.m., when it received a copy of the hearing notice from the attorneys representing PLC, LLC and NH2, I.I.C. We therefore request permission to file this comment after your November 13, 2017,430 p.m. comment deadline. The University had prior discussions with the Department of Natural Resources (DNR) in order to understand the methodology the DNR used in its May 16, 2017 "Approval, In Part, of the First Expansion of.the Falls Creek Participating Area" to justify removal of the University's Tract 19 from the proposed Falls Creek Participating Area expansion. The DNR decision concerned the University, in part, because the University was not privyto the geological data underpinning some of the DNB's assumptions. That lack of access was unavoidable because of the confidentiality of the data. The University has reviewed the legal positions of PLC, LLC and NH2, LLC and finds some merit in the assertion the AOGCC is the most appropriate state agency to make determinations regarding reservoir extent in contested PA expansion and contraction decisions. AOGCC is charged with protecting correlative rights. The AOGCC is also able to access and make an independent assessment of all parties' confidential geological data, while maintaining that confidentiality. Most importantly, the AOGCC, unlike the DNR, does not have a direct financial interest in the outcome of the PA expansion and contraction determinations. Unlike the DNR, it does not have title to oil and gas leases being considered for inclusion or exclusion from the proposed participating area. It was likely for these reasons that the Alaska Legislature appear to have placed primary jurisdiction over these matters with the AOGCC, and not the DNR. University Comment Letter to AOGCC Docket Number CO -17-016 November 14, 2017 Page 2 of 2 As mentioned earlier, the University does not have access to the geological data upon which the DNR relied in determining which acreage was in and which was -out of the Falls Creek PA expansion. Even if it did, the University does not have geologists and petroleum reservoir engineers on staff who could assess that data. The AOGCC does. The University supports the AOGCC taking an independent reviewof the Falls Creek Participating Area Expansion as originally proposed by Hilcorp, to determine in a fair and non -conflicted manner the extent of the reservoir that will be productive for oil and gas. The University is not suggesting that the DNR has undertaken any nefarious or improperly motivated action in modifying the original Hilcorp PA expansion proposal. However, to ensure that such a decision is beyond reproach and on solid legal footing, the University believes the. best course of action would be for the AOGCC to undertake an independent review of the original Hilcorp Falls Creek Participating Area Expansion Application such that the AOGCC decision on PA expansion could resolve all of the legal concerns of the PLC, LLC and MH2, LLC parties, as well as providing the University and the other fee owners with an indisputably unbiased analysis that protects all parties correlative rights. For future hearings on this matter, please ensurethat notice is provided to the University through notification of the undersigned. Thank you for allowing us to comment. Sincerely, _ n Christine Klein M Commissioner Catherine Foerster, cathv.foersterlapalaska aov Commissioner Dan Seamount, dan.seamount(Oclasko.aov Ninilchik Unit Falls Creek Participating Area Proposed Expansion Dated: May 16, 2017 Appeal June 5, 2017 Dear Director Walsh, My May 15, 2017 letter to the DNR appeals expressed my concerns of Andrew Mack's March 22, 2017 letter and the term "in due course". This latest ruling justifies my concerns. Geological data submitted by Marathon [the predecessor company to Hilcorp] to the AOGCC clearly shows the outline of the pool, complete with the faults and the horizons on the anticlines surrounding the Falls Creek PA. I am simply relying on public domain data submitted to the State by the owner of the Ninilchik Unit. It is Marathon's (now Hilcorp's) data. Attached you will find the Structure Map for the Ninilchik Unit published by Marathon. Having georeferenced the image and using TOIN-R13W to act as the 4 -comer reference. The parcel is very small when put on this map — look for the green blurb on the 6,000' contour line — that is parcel #13902056, that is me, you should be able to zoom in to enlarge. The heavy lines are faults. The lighter lines with numbers are the horizons on the anticline surrounding the Falls Creek PA. The State of Alaska, the AOGCC, your DNR Division of Oil and Gas, Marathon and Hilcorp ALREADY KNEW how big the Falls Creek PA was when Hilcorp bought it! The AOGCC ordered, in Co 701 and 701A, Affected Area, 1 North, 12 West, section 7, North West '14. That is me and my georeferenced image recently placed on the Structure Map submitted by the former owner of the Ninilchik Unit. 701 was held for the sole purpose, " The AOGCC has chosen to call a hearing on this application INSTEAD OF handling it administratively because the proposed changes in the well spacing and escrow requirements MAY IMPACT the CORRELATIVE RIGHTS of parties that ARE WITHIN the DEFINED AREA of the POOL or UNIT, but are NOT YET COMMITED to the unit". Your March 2, 2017 expansion had a Nov 2, 2016 letter from Hilcorp, in part, "Areal expansion of the Falls Creek Participating Area boundary will also require modification of the Ninilchik Unit boundary. This change involves the unitization of approximately 40 acres of fee mineral property, 100% leased by Hilcorp within the NW4 NE4, Section 7, Township I North, Range 12 West, Seward Meridian Alaska." I'm Section 7 North West '/4, why don't you modify the Ninilchik Unit boundary for me? Oh, that's right, I never signed a Hilcorp lease! You state " Seismic data, though instrumental in identifying prospective structural traps, have proven to be unreliable in the Ninilchik area and other areas in Cook Inlet for detailed subsurface mapping of the internal architecture and outer limits of producing gas accumulations.". That "For this determination, the operator proposed a Falls Creek PA boundary based on the Lowest Known Gas (LKG) method." Also, "The Division felt it was necessary to further simplify the approach to address these issues and the circle and tangent method was chosen." " A fifty percent rule was applied to each aliquot, meaning the maximum convex hull area must cover at least fifty -percent of each aliquot for that aliquot to be included in the PA." "The FCPA boundary established through this method is the most equitable approach with the available data." "The expanded FCPA includes quarter -quarter sections within a 1,500 -foot radius of the Ninilchik Unit — First Expansion of Falls Creek Participating Area 14 portion of the well bores open to production within the proven Tyonek and Beluga reservoirs. Only quarter -quarter sections where fifty percent or more of the reservoir is observed were included in the FCPA. " "C. The Protection of All Parties in Interest, Including the State 1. The economic, geological, geophysical, and engineering data that Hilcorp provided reasonably justify the inclusion of the acreage into the revised FCPA under the terms of the applicable regulations governing formation, expansion, and operation of oil and gas units and participating areas (11 AAC 83.301-11 AAC 83.395) and the terms and conditions under which these lands were leased from the State. With input from the State, Hilcorp has submitted an acceptable methodology for establishing the expanded boundaries of the FCPA." I have expressed concerns in my past appeal of you being able to think on your own, without Hilcorp there to help lead your thoughts. On that you have proven my concerns are correct on this also with your "For this determination, the operator proposed a Falls Creek PA boundary based on the Lowest Known Gas (LKG) method." The "C. The Protection of All Parties in Interest," is NOT PROTECTING MY CORRELATIVE RIGHTS. "and the terms and conditions under which these lands were leased from the State". The State is free to do whatever it chooses to do with the States royalties, as I've stated in the past, I can only continue to hang my head in shame. These are MY CORRELATIVE RIGHTS they ARE NOT for the State to wheel and deal with. As a litigant in the Exxon Valdez Oil Spill, after waiting around 15 years for the case to be heard by the U.S. Supreme Court they decided to hold off on hearing the Exxon case until they heard another case that came after Exxon. They felt that case would have an impact on the Exxon verdict. 5 years before they ruled on Exxon they already knew the answer, they just had to wait for "in due course". What better role model for the guidance of the corporation of Alaska to steal from their citizens than the U.S. Supreme Court? After all, the states broke, give up more of it's citizens rights and maybe the oil companies will throw us another scrap. With YOUR HELP Hilcorp "submitted an acceptable methodology". What kind of scrap did they throw you TO COMPLETELY IGNORE my CORRELATIVE RIGHTS? The "circle and tangent method" is flawed to this Patent Fee Owner. With your 50150 mentality 49.9 means you don't get anything! Now with the Marathon map, as you can see the fault runs well East of me and also to the South of me. My property is 450 yards long, using that for a reference, the fault is 450 yards from my Southern property line. I'm clearly on the 6,000' line with Southwest of my Southern property being a convergence of anticline going up to the 5,000' anticline. ALL of this takes place 500 yards from me. A torrid jumbled uplift from 6,000' to 5,000' in the space of 4,000'. In Your Very Own Words from the last appeal "The Ninilchik anticline is shallowest in the southwest and plunges deeper to the northeast and is segmented by several crosscutting faults along the crest of the structure. These faults are believed to play an integral part in the trapping mechanisms throughout the unit. In addition the stratigraphic trapping mechanism is also likely to be contributing to the overall resource potential of the unit." Your Very Words! "In addition the stratigraphic trapping mechanism is also likely to be contributing to the overall resource potential of the unit." From CO 701, Hilcorp said "1/2 mile East is a 100 feet of gas bearing sand". %: mile East misses me by about 60 feet!!! CO 701 "Reservoir sandstones within these two formations are lenticular in cross-section and laterally discontinuous". I am clearly on the 6,000 foot anticline, just exactly where there's "1/2 mile East is a 100 feet of gas bearing sand" and that's exactly where CO 701 and 701 A says Affected area IN 12W Sec? NW 1/4 is. EXCACTLY UNDER MY FEET!!! Remember, "ALL of this takes place 500 yards from me. A torrid jumbled uplift from 6,000' to 5,000' in the space of 4,0001." From July 2014 through Oct. 2016 the Frances 1 has produced 3,765,366 mcf. Times that by the value the state uses for royalty payment of Ninilchik Unit gas for October 2016, $6.82 and your trying to tell me that all that gas came from that tiny 1,500 foot circle? I haven't add up what has been produced after October 2016 but I'm sure it's a lot. The Structure Map from Marathons own files, on the public domain, CLEARLY shows the pool. This map, made years BEFORE the current 3D data that you have access to, CLEARLY shows the pool. I believe the AOGCC also has the same 3D data that you do when they ordered the Affected area in CO 701. The map shows the size of the pool weather it is within the nice neat pretty unit lines or outside of it like I am. In my 40 years of living in Alaska well over a trillion dollars in oil and gas has been through this state. As mentioned in my last appeal on this matter, that has brought corruption. With the amount of time, people and effort with the State's resources to NOT recognize and address my CORRELATIVE RIGHTS give me cause of concern. It is easy to have an off shore account, a retirement condo in Argentina or Costa Rica complete with a key to a safety deposit box, family vacations, the list can go on. Remember, Pete Koff sold out to an industry worth hundreds of billions of dollars for the price of a Girl Scout uniform. The decision makers are the ones to buy, just like on my last appeal. The average gas station attendant doesn't have much to worry about. Supporters of this kind of robbery should be scrutinized. From the recorded lies of David Duffy, included in the last appeal, [CO 7011 of him playing golf as I had a chance to shortly be in Anchorage, that fall of him telling me "If you read your contract, That You Signed, once our bore penetrates your sub surface property lines, THEN, we owe you money". A few minutes later he called back and offered a fishing charter and I could sign the lease, or a deer hunting charter and I could sign the lease. Within minutes a copy of the lease was e-mailed to me and in a few minutes a copy was going to be mailed General Delivery to me. 2 years later, meeting with Kevin Tablor I was shown a chart of the Frances No.I borehole and the several layers of lenticular and discontinuous sands a little over % mile from me. I was offered then and there a gravel road to my home to sign the lease. That they didn't want anyone to know how much money they were making. 3 years ago, when this STATE SPONCERED ROBBERY started I learned quick from Steve Davies about CORRELATIVE RIGHTS, he dummies right up, can't even find my land now after several attempts. I understand now, it's the same for you and everyone else who works for the State. IT"S YOUR JOB ON THE LINE!!! You'll get fired! P The Texas oil companies haven't given the State of Alaska permission to rightfully give away money they think is theirs. From even before the time of Tony Knowles, oil companies get their way here. Tony just made the SELL OUT public when he choose to fly to Texas just minutes after winning the governors election to be sworn in because Alaska's soil wasn't good enough for him to stand on. I want to vomit every time I remember they named a trail after him. Alaska Statutes Title 31 Definition's: (3) "correlative rights" mean the opportunity afforded, so far as it is practicable to do so, to the owner of each property in a pool to produce without waste the owner's just and equitable share of the oil or gas, or both, in the pool; being an amount, so far as can be practically determined, and so far as can practicably be obtained without waste, substantially in the proportion that the quantity of recoverable oil or gas, or both under the property bears to the total recoverable oil or gas or both in the pool, and for such purposes to use the owner's just and equitable share of the reservoir energy; AOGCC Missing Meter Calibration Reports Other Order 113 Ninilchik Unit Bartolowits Pad Docket Number: OTH-15-036 Custody Transfer Meter October 20, 2016 Nobody truly knows how much Hilcorp stole. "Prior to this violation, AOGCC staff had met with Hilcorp on a number of occasions regarding ongoing compliance issues with Hilcorp, including an unprecedented meeting with field operations staff at Hilcorp's Kenai field office. AOGCC resolved Hilcorp's earlier violations without enforcement actions. (See Table 1, attached to this Decision.) This approach has had little discernible impact on Hilcorp's behavior. Hilcorp's previous commitments to train its personnel have been insufficient to avoid recurrences of regulatory violations.8 Hilcorp's lack of good faith in its attempts to comply with the imposed conditions, its history of regulatory noncompliance and need to deter similar behavior are the factors which most heavily influence this decision." Remember the 3 Hilcorp men who almost died in 2015 Milne Point oil fields. The AOGCC remembers them, "has a significant history of noncompliance" with the its regulations, leading to several enforcement actions against the company." The potential severity of the outcome of Hilcorp's actions, Hilcorp's ongoing history of performing work outside of approved permits or management -of -change protocols, its history of compliance issues and the need to deter are significant factors in the AOGCC's analysis," Hilcorp is a thieving company and with your "circle and tangent" method I have a very strong feeling that your in cahoots with them. I demand a public hearing on this matter. Thank You, Donald Shaw 111$/M)7 RAU: gICORP p( 11UCpTIfIN FlI0. AMcun,u[ut nv rnmm. ALASKA OIL AND GAS CONSERVATION COMMISSION In the Matter of Hilcorp Alaska, ) LLC's Application for Amendment of ) Conservation Order 701A, to Redefine ) the Vertical and Horizontal Boundaries ) of the Ninilchik Beluga/Tyonek Gas ) Pool and to Expand the Affected Area of ) the Pool to Include the NW 1/4, NE 1/4 ) of Section 7, T1N, R12W. Docket No.: OTH 17-016 PUBLIC HEARING ALASKA OIL and GAS CONSERVATION COMMISSION Anchorage, Alaska November 14, 2017 10:00 o'clock a.m. BEFORE: Hollis French, Chair Cathy Foerster, Commissioner Daniel T. Seamount, Commissioner 1 ]S Ckls�emen u.. Sle. z.A¢LL pIC 9950, Plorc: W]-243 f8 Tax 90].20-14]3 Tmn: ubi4pa+m ¢c unsaun amo uuroaPa .rrucnnory enu uaeemmeM or muscavanoenxnm� Page 2 1 TABLE OF CONTENTS 2 Opening remarks by Chair French 03 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 I]5 rki9anrn U.. 4m. ". Nrh AK 9951x1 Pbm^ W7-243 0668 1'ar 907-241 IG13 Fimil saNlaiS&i ml 11I 1111 IIMI]. 1I.11.11 {TFU('ATIONIORAMFT'U.IOFC()NFERV TIOTORU6N7i Page 3 1 1 P R O C E E D I N G S 2 (On record - 10:00 a.m.) 3 CHAIR FRENCH: I'll go ahead and call -- let's 4 call the meeting to order. It is November 14, 2017, 5 it's 10:00 in the morning. We are at 333 West Seventh 6 Avenue, Anchorage, Alaska, the offices of the Alaska 7 Oil and Gas Conservation Commission. To my right is 8 Commissioner Cathy Forester, to my left is Commissioner 9 Dan Seamount. I'm Hollis French, the Chair of the 10 Commission. 11 We're here today regarding docket order CO 17- 12 016, the Ninilchik Beluga/Tyonek gas pool in the 13 Ninilchik unit to redefine and expand the vertical and 14 horizontal affected area of the pool. Hilcorp Alaska, 15 LLC, by application received August 29th, 2017 and 16 amended by email on October 3rd, 2017, has requested 17 that the AOGCC revise Rule 2 of Conservation Order 701A 18 to redefine the vertical and horizontal boundaries of 19 the Ninilchik Beluga/Tyonek gas pool and to expand the 20 affected area of the pool to include the NW 1/4, NE 1/4 21 of Section 7, T1N, R12W. Any other expansions are 22 outside the scope of today's hearing. 23 Mr. Don Shaw filed in writing on October 10th 24 asking that this hearing be held. 25 Computer Matrix will be recording the 135 Ck flcnScn G., $le."..Asch AK 995111 1'I W 24311668 Fac SVI"/-243 1473 Lreil. sa lu lc(�&Incl 11152lll7 11111111R1'pMY AI( RICA] ION FORAl..1111:11 Page 4 1 proceedings, you can get a copy of the transcript from 2 Computer Matrix Reporting. 3 I see that Hilcorp and Mr. Shaw have both asked 4 to testify. Any other parties planning to testify? 5 (No comments) 6 CHAIR FRENCH: I don't see any hands. The 7 Commissioners will ask questions during the testimony. 8 We may also take a recess to consult with Staff and 9 determine whether additional information or clarifying 10 questions are necessary. If a member of the audience 11 has a question that he or she feels should be asked 12 please submit that question in writing to Jody 13 Colombie, she will then provide the question to the 14 Commissioners and if we feel that asking the question 15 will assist us in making our determinations we will ask 16 it. 17 For those testifying please keep in mind that 18 you must speak into the microphone so that the audience 19 and the court reporter can hear your testimony. Also 20 please remember to reference your slides so that 21 someone reading the public record can follow along. 22 For example refer to slides by their numbers if 23 numbered or by their titles if not numbered. 24 We have a few ground rules on what is allowed 25 relative to testimony. First all testimony must be Canq�Nel MtV1t IlG r '111 :3)6 llsCmm,.�eo a. sm 2. nen nc vaso' 1 ar . 9)wv-zal-147av3 .�mr. xzmleg�c� rc1 A(N�Y'C I1 I1 21119 rtMO. 1111('II PAI. 11A' 1I NR10. AM1:NOMEN101-(.NU.1A1 )ON Oft DLR IIIA Page 5 1 relevant to the purposes of the hearing that I outlined 2 a few minutes ago and to the statutory authority of the 3 AOGCC. Anyone desiring to testify may do so, but if 4 the testimony drifts off subject we will limit the 5 testimony accordingly. Additionally testimony may not 6 take the form of cross examination. As I said before 7 the Commissioners will be asking the questions. And 8 finally testimony that is disrespectful or 9 inappropriate will not be allowed. 10 Commissioner Foerster, Commissioner Seamount, 11 do you have anything to add at this time? 12 COMMISSIONER FORESTER: I do not. 13 COMMISSIONER SEAMOUNT: I have nothing. 14 CHAIR FRENCH: Let's go ahead and get started 15 then. I see we have a gentleman here ready to go. Why 16 don't you two first raise your right hands. 17 COMMISSIONER FOERSTER: Wait. First we do need 18 to clear up the matter of whether UAA..... 19 CHAIR FRENCH: Oh, beg your pardon. Yeah, we 20 did just this morning receive a letter from the 21 University of Alaska, from Christine Kline, is she 22 here? 23 (No comments) 24 CHAIR FRENCH: Okay. Our concern is that we -- 25 we just want to make sure the University feels like rwrl4er L1evI1 "I Plow %7-243-0669 � ]s rlm sicn�ai Dr.. se.:. A I,..51s Fe, WI N11411Fnea um1 N@M n'I 11 /1 5 2 011 .0 IIllfOIL'Tk III( 1110\'HIN.pNkmlNI VF ( FOIA Page 6 1 they've had enough time to get their concerns on the 2 record. If after this hearing -- because it was on 3 short notice to the University if after this hearing 4 the University feels like they need to supplement the 5 record, to add something to the record, please feel 6 free to do so. 7 COMMISSIONER FOERSTER: Do you feel you need 8 more time to prepare for this hearing? 9 MR. KELLY: We would say yes. 10 CHAIR FRENCH: Then we'll take that under 11 advisement, yeah, and we'll take that into 12 consideration. We may have to have another hearing 13 after this one, after you -- after the University's 14 had, you know, their 30 days of notice. And so that's 15 a very likely outcome is that we reopen the hearing in 16 30 days and allow you to come up and cleanup if you 17 will or at least put your concerns on the record at 18 that time once you've had, you know, the full length of 19 time to consider what it is -- what points you wish to 20 make before the Commission. 21 Does that make sense? 22 COMMISSIONER FOERSTER: Well, I'd say check 23 with our Assistant AG. Should we -- the University of 24 Alaska has said that they feel that they might need 25 more time to prepare for what we're about to do today. Coo VW u. Ma l., Ile Pml W749466 us UVlnmsm p.. sm 2, T I,."II lex 909-14y liJl pnoli ce Nle@Slni .ff", 11 1121,11 RMU: 1.11,R). !PIXIWIIIIAAMF_IM,1'11I' 1111E11IONO.U.IIA Page 7 1 Should we continue this hearing for 30 days and give 2 them an additional 30 days or should we -- how should 3 we proceed? 4 MR. BALLANTINE: (Indiscernible - away from 5 microphone)..... 6 COMMISSIONER FOERSTER: Okay. Do you need more 7 time to prepare for information regarding this 8 application to expand vertical limits of this pool or 9 the horizontal limits for that one quarter section or 10 is your need for a different expansion? 11 MR. KELLY: (Indiscernible - away from 12 microphone)..... 13 COMMISSIONER FOERSTER: This pool? 14 MR. KELLY: This expansion. 15 COMMISSIONER FOERSTER: This expansion. Okay. 16 Well, then we probably need to give them 30 days and 17 adjourn this hearing. 18 CHAIR FRENCH: Why don't we take a five minute 19 recess right now and we'll decide what to do with the 20 information you've given us. 21 Five minute recess. 22 (Off record) 23 (On record) 24 CHAIR FRENCH: We're back on the record, it's 25 10:12 a.m. We're going to proceed with an abundance of vo�ww.. nwlx ue Pro. 19 v-zwus. )s Ckinlrnaen P.. sez Arch AK 49w1 rzx: W]2431473 Imiil 5alu leQ �ci rc1 1115 I'll 0.11 IROI.R,N YPLAA IION FORA I)M1IN10I'( ONSLF1,1IIONORN. NIA Page 8 1 caution which means we're not going to proceed today. 2 We have an affected party that didn't receive notice of 3 the hearing and so we want to make sure that everybody 4 gets the due process they're entitled to. That means 5 we're going to re -- we're going to continue this for 6 30 days until Thursday, December 14. 7 In the meantime we are going to require that 8 Hilcorp provide us, the Commission, with a list of the 9 affected parties by this pool expansion and proof that 10 those parties have been notified so this doesn't happen 11 again. We would ask that that be submitted to the 12 Commission within 10 days of today's date or November 13 24th. 14 Am I on Thursday now, the..... 15 COMMISSIONER FOERSTER: Thursday, December 16 14th. 17 CHAIR FRENCH: Well, no, Thursday, December 18 14th for the hearing, but I'm also looking at the 10 19 days of the notice. 20 COMMISSIONER FOERSTER: It would be Friday. 21 CHAIR FRENCH: Friday after Thanksgiving. 22 Friday the 24th. Yep, very good. So submit that to us 23 on Friday, the 24th. 24 COMMISSIONER SEAMOUNT: It's got to be a 25 complete list too. Ca�mee wo,., PMS W1 -2N3.0668 IJS Uvulv'vm 0.,9�e 2. 1.1. 99NII Ear AXI]2- 1-I f-, I—I ablc(op ui AC .'( I Ir 15r 2111, ..OIWIOR N. yl`IJl'pi1pN RIR AMINUMENI OF CONSL'RVAlI0N 11RUYM"I Page 9 1 1 COMMISSIONER FOERSTER: Well, if Hilcorp 2 doesn't work Thursday or Friday the 23rd or the 24th; 3 is that correct. 4 CHAIR FRENCH: Then submit it early is probably 5 the best thing. 6 COMMISSIONER FOERSTER: It's something they 7 should have already had prepared and acted upon so that 8 shouldn't be a problem. 9 CHAIR FRENCH: And we regret that someone had 10 to travel a long way for this hearing, but we just 11 can't have the hearing without all the affected parties 12 having notice. It's just bad practice. 13 So with that we are in recess until the -- or 14 continued in recess on this hearing until the 14th of 15 December 16 Commissioner Foerster. 17 COMMISSIONER FOERSTER: Unless the list that 18 Hilcorp provides us demonstrates someone else..... 19 CHAIR FRENCH: Indicates that we missed 20 somebody else. 21 COMMISSIONER SEAMOUNT: Right. 22 COMMISSIONER FOERSTER: .....in which case we 23 will vacate this hearing and reschedule a hearing 24 giving everyone their full 30 days. 25 CHAIR FRENCH: Exactly right. Thanks for the 35 c15 Cklpmwn mPMre. 1ev IX,9l�.'1.. Neh AX 99NII w)2a31 eFo W1 211-1d13 Inell. sakl gclm AIW(C II.I S'2011 "MO:i ONPM �PMATEON FOR MitM)M14NI OF COMFRIeT10N O.MW Page 10 1 help. With that then we are in recess. 2 (Recessed - 10:19 a.m.) 3 (END OF PROCEEDINGS) 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 C.oiTber Matrix LLC PM:MI]-W3 Ms 135 Mrs,— G. Sm. 2.,g h.99501 Fax W?2431473 Fm@vkleQy`gi xl A'' C( 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 IDIS YII] I]W) NO{OIfP '-CA'--'OR MI'.f NI JICONG4AVTTION ORULA RI Page 11 C E R T I F I C A T E UNITED STATES OF AMERICA ) )ss STATE OF ALASKA ) I, Salena A. Hile, Notary Public in and for the State of Alaska, residing in Anchorage in said state, do hereby certify that the foregoing matter in Docket No.: 0TH 17-016 was transcribed under my direction to the best of our ability; IN WITNESS WHEREOF I have hereunto set my hand and affixed my seal this 27th day of November 2017. Salena A. Hile Notary Public, State of Alaska My Commission Expires: 09/16/2018 w�iuee mav¢ uA: Plow. %7 Nl.0668 iS CM1ta unu' Ih, Slc 2. N h 1K I., 13x"AI-241-14]3 Cmil'. wNlelo p lx. STATE OF ALASKA ALASKA OIL AND GAS CONSERVATION COMMISSION Docket No. OTH-17-016 Hilcorp Alaska, LLC November 14, 2017 at 10:00 am NAME AFFILIATION Testify (yes or no) G c b-4 I ERRcL-L HAA 14, Ye S ('%r1s li& a (e 4-p 6 r �,- A/„