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Home My WebLink AboutCO 788CONSERVATION ORDER 788 Docket Number: CO -20-019 1. September 22, 2020 Hilcorp Alaska, LLC application for a Spacing Exception KU 21-07 2. September 27, 2020 Notice of hearing, affidavit of publication, email distribution, mailings ORDERS STATE OF ALASKA ALASKA OIL AND GAS CONSERVATION COMMISSION 333 West 7" Avenue Anchorage, Alaska 99501 Re: THE APPLICATION OF Hilcorp Alaska, LLC for an exception to the spacing requirements of 20 AAC 25.055(a) to perforate, test, and produce the Kenai Unit 21-07 development gas well within 1,500 feet of a property line where owners are different on both sides of the line, and within the same governmental section as, and within 3,000 feet of, wells that are, or may be, capable of producing from the same pool. IT APPEARING THAT: Docket Number: CO -20-019 Conservation Order 788 Kenai Unit Kenai Unit 21-07 Development Gas Well Kenai Peninsula Borough, Alaska October 27, 2020 1. By letter received September 22, 2020, Hilcorp Alaska, LLC, (Hilcorp) requests the Alaska Oil and Gas Conservation Commission (AOGCC) issue an order for an exception to the spacing requirements of 20 AAC 25.055(a)(2) and (4) to allow the Kenai Unit 21-07 (KU 21- 07) development gas well to be perforated, tested, and produced within 1,500 feet of a property line where owners are different on both sides of the line, and within the same governmental section as, and within 3,000' of, a well that is, or maybe capable of, producing from the same pool. Hilcorp's planned operations in KU 21-07 target the Undefined Sterling Gas Pool, which lies stratigraphically above Sterling Gas Pool 3, as defined in CO 510A. 2. Pursuant to 20 AAC 25.540, the AOGCC tentatively scheduled a public hearing for October 29, 2020. On September 25, 2020, the AOGCC published notice of the opportunity for that hearing on the State of Alaska's Online Public Notice website and on the AOGCC's website, electronically transmitted the notice to all persons on the AOGCC's email distribution list and mailed printed copies of the notice to all persons on the AOGCC's mailing distribution list. On September 27, 2020, the AOGCC published the notice in the ANCHORAGE DAILY NEWS. 3. Hilcorp sent, by certified mail, notice of the application to all owners, landowners, and operators of all properties within 3,000 feet of the proposed KU 21-07 development gas well and provided the notice, addresses to which the notices were delivered, and Certified Mail receipts. 4. No comments or request for hearing were received regarding Hilcorp's application. 5. The tentatively scheduled public hearing was vacated. 6. Hilcorp's application provided sufficient information upon which to make an informed decision. FINDINGS: Hilcorp is the operator for the Kenai Unit (KU), located within the Kenai Peninsula Borough, Alaska and is the owner of the affected oil and gas leases. Landowners for the properties within 1500' of KU 21-07 are the U.S. Bureau of Land Management (Lease A-028143), the State of Alaska (ADL0392670), and Hilcorp Alaska, LLC (FEE A028142). The affected landowners within 3,000 feet of KU 21-07 are the State of Alaska (ADL0392670), U.S. CO 788 October 27, 2020 Page 2 of 3 Bureau of Land Management (A-028143), Pacific American Fisheries, Inc., and Hilcorp Alaska, LLC, which owns 100% of the subsurface of FEE AA093836 & FEE A028142. 2. Conservation Order No. 510A governs Sterling Gas Pools 3, 4, 5.1, 5.2, and 6, Beluga/Upper Tyonek Gas Pool, Tyonek Gas Pool 1, and Kenai Deep Tyonek Gas Pool within the Kenai Unit. The statewide well spacing provisions of 20 AAC 25.055 govern the Undefined Sterling Gas Pool within the Kenai Unit. 3. KU 21-07 was an onshore, "s -shaped," development gas well drilled directionally in 2006. Recently, perforations in all Sterling pools were isolated from the proposed new perforations in the Undefined Sterling Gas Pool through approval of Sundry 320-282, received on 07/02/2020. 4. The surface location for KU 21-07, the top of the prospective producing interval, and the bottom -hole location will all lie within Federal lease A029657. The current productive intervals, and bottom -hole location all lie on lease FEE A028142: Surface Hole Location (SHL): 450' FSL, 935' FWL, Sec. 06, T04N, RI IW, SM, AK Top of Productive Zone (TPZ): 110' FSL, 1,401' FWL, Sec. 06, T04N, Rl l W, SM, AK Bottom Hole Location (BHL): 17' FNL, 1,589' FWL, Sec. 07, T04N, RI IW, SM, AK 5. Hilcorp's planned perforations in KU 21-07 target reservoirs within Undefined Sterling gas pool. 6. A spacing exception is necessary because KU 21-07 will be within 3,000 of the KU 42-12 which is open to or capable of producing from the same pool. The KU 21-07 is located on the KGF 14-06 Pad within the Kenai Unit. 7. Adding perforations to the Undefined Sterling Gas Pool affords an opportunity to produce gas in a new target sand, after plugging back depleted Sterling intervals lower in the stratigraphic section. With KU 42-12 as the only competing well, the spacing exception is further justified by allowing the operator to produce the Undefined Sterling more efficiently from two wells simultaneously. 8. If operated as approved in the forthcoming sundry for adding perforations to the Undefined Sterling Gas Pool, KU 21-07 will not cause waste or result in an increased risk of fluid movement into freshwater. CONCLUSIONS: 1. An exception to the well spacing provisions of 20 AAC 25.055 is necessary to allow the perforating, testing, and regular production of the Sterling Undefined Gas Pool in the KU 21- 07 development gas well in order to maximize ultimate resource recovery. 2. Granting an exception to the well spacing provisions of 20 AAC 25.055 for KU 21-07 will not result in waste or jeopardize correlative rights of adjoining or nearby owners, is based on sound engineering and geoscience principles, and will not result in an increased risk of fluid movement into freshwater. CO 788 October 27, 2020 Page 3 of 3 NOW THEREFORE IT IS ORDERED: The AOGCC grants Hilcorp's September 22, 2020, application for an exception to the well spacing provisions of 20 AAC 25.055 to allow perforating, testing, and regular production of the KU 21- 07 development gas well within the Sterling Undefined Gas Pool. Hilcorp may proceed and must comply with all applicable laws, and all other legal requirements. DONE at Anchorage, Alaska and dated October 27, 2020. Jeremy Digitally ,oris.° Date.2020.102r M. Price 1110208N Jeremy M. Price Commissioner, Chair Daniel T. Digitally signed by Daniel T. Seasount Jr. Seamount, Jr. Date: 2020.10.27 112533-0800' Daniel T. Seamount, Jr. Commissioner Jessie L. Digitally sign`" by Jessie L. Chmlelowski Chmielowski 11211.10.27 11:27D548'Gly Jessie L. Chmielowski Commissioner As provided in AS 31.05.OWa), within 20 days after written notice of the entry of this order or decision, or such further time as the AOGCC grants for good cause shown, a person affected by it may file with the AOGCC an application for reconsideration of the matter determined by it. If the notice was mailed, then the period of time shall be 23 days. An application for reconsideration must set out the respect in which the order or decision is believed to be erroneous. The AOGCC shall grant or refuse the application for reconsideration in whole or in part within 10 days after it is filed. Failure to act on it within 10 -days is a denial of reconsideration. If the AOGCC denies reconsideration, upon denial, this order or decision and the denial of reconsideration are FINAL and may be appealed to superior court. The appeal MUST be filed within 33 days after the date on which the AOGCC mails, OR 30 days if the AOGCC otherwise distributes, the order or decision denying reconsideration, UNLESS the denial is by inaction, in which case the appeal MUST be filed within 40 days after the date on which the application for reconsideration was filed. If the AOGCC grants an application for reconsideration, this order or decision does not become final Rather, the order or decision on reconsideration will be the FINAL order or decision of the AOGCC, and it may be appealed to superior court. That appeal MUST be filed within 33 days after the date on which the AOGCC mails, OR 30 days if the AOGCC otherwise distributes, the order or decision on reconsideration. In computing a period of time above, the date of the event or default after which the designated period begins to run is not included in the period; the last day of the period is included, unless it falls on a weekend or state holiday, in which event the period runs until 5:00 p.m. on the next day Bernie Karl K&K Recycling Inc. P.O. Box 58055 Fairbanks, AK 99711 George Vaught, Jr. P.O. Box 13557 Denver, CO 80201-3557 Gordon Severson 3201 Westmar Cir. Anchorage, AK 99508-4336 Darwin Waldsmith P.O. Box 39309 Ninilchik, AK 99639 Richard Wagner P.O. Box 60868 Fairbanks, AK 99706 INDEXES Notice of Public Hearing STATE OF ALASKA ALASKA OIL AND GAS CONSERVATION COMMISSION Re: Docket Number: CO -20-019 The application of Hilcorp Alaska, LLC (Hilcorp) to amend Conservation Order No. 510A to allow for the addition of perforations in Undefined Sterling Pool in KU 21-07 above Sterling Gas Pool 3, defined in CO 510A for the Kenai Gas Field. By application received September 22, 2020, Hilcorp requests that Alaska Oil and Gas Conservation Commission (AOGCC) amend Conservation Order No. 510A to allow regular production for the KU 21-07 gas development well from an Undefined Sterling Gas Pool within 1,500 feet of a property line where the owners and landowners are not the same on both sides of the line and within 3,000 feet of a well open to or capable of producing from the same pool (KU 42-12). Pursuant to 20 AAC 25.537 (a)(1) and (a)(2), Kenai Unit 21-07 well: Surface Hole Location (SHL): 450' FSL, 935' FWL, Sec. 6, T4N, Rl l W, Seward Meridian Top of Production Horizon (TPH): 110' FSL, 1,401' FWL, Sec. 6, T4N, RI IW, Seward Meridian Bottom -hole Location (BHL): 17' FNL, 1,589' FWL, Sec. 7, T4N, RI IW, Seward Meridian The AOGCC has tentatively scheduled a public hearing on this subject for October 29, 2020, at 10:00 a.m. at 333 West 7'h 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 15, 2020. If a request for a hearing is not timely filed, and the AOGCC deems the information submitted in support of Hilcorp's application sufficient to make a decision, the AOGCC may issue an order without a hearing. To learn if the AOGCC will hold the hearing, call (907) 279-1433 after October 16, 2020. If a hearing is requested, the COVID-19 virus may necessitate that the hearing be held telephonically. Those desiring to participate or be present at the hearing should check with AOGCC the day before the hearing to ascertain if the hearing will be telephonic. If the hearing is telephonic, on the day of the hearing, those desiring to be present or participate should call 1-800-315-6338 and, when instructed to do so, enter the code 14331 followed by the # sign. Because the hearing will start at 10:00 a.m., the phone lines will be available starting at 9:45 a.m. Depending on call volume, those calling in may need to make repeated attempts before getting through. In addition, written comments regarding this application may be submitted to the AOGCC, at 333 West 7th Avenue, Anchorage, Alaska 99501. Written comments must be received no later than 4:30 p.m. October 28, 2020, except that if a hearing is held, comments will be accepted until the conclusion of the October 29, 2020 hearing. If, because of a disability, special accommodations may be needed to comment or attend the hearing, contact the AOGCC at (907) 279-1433, no later than October 23, 2020. V � 4�— Jeremy M. Price Chair, Commissioner Carlisle, Samantha J (CED) From: Carlisle, Samantha 1 (CED) Sent: Friday, September 25, 2020 9:27 AM To: AOGCC Public Notices Subject: CO -20-019 Public Hearing Notice.pdf Attachments: CO -20-019 Public Hearing Notice.pdf The application of Hilcorp Alaska, LLC (Hilcorp) to amend Conservation Order No. 510A to allow for the addition of perforations in Undefined Sterling Pool in KU 21-07 above Sterling Gas Pool 3, defined in CO 510A for the Kenai Gas Field. Samantha Carlisle Fwcutive 4ecretary III A Liska Oil and Gas Conservation Commission 333 West 7'" Avenue ,Anchor age, AK 99501 Or) 793-1703 I s m...�' a C 0. ITIDFN'TIriLlITNOTICI;:Thisul mt sagc.Lvht,hng anvallathawnts,ctmtdmsinronriallon&6mIN! Alaska Oil and tris Convctvatioo Cnmmi+cion (,-UX,( I, ), Stater ul Vaska anJ is for the "'le use ul the uri.Illicit recipiont(s). It rnac Cot tit if) aof fidvntIII I alit] /o] III iViIq;ed in (Irma lion. The nnnutharized renew, 111 or d isclosinc, of such irdocnration maty t Iola Io stah' of tiderl law. IT you 4) 10 an unintended i 'ipieut of Ihis e-inaiI, pI(',I do If I1, Ili II'OW Fret sacinl; Or lot wardin}{ II, and. so that that rAOGC Civ aware ul lhr mistake m .ending; it to You, cunt. ct Samantha (-,II INIe dt (`i(r I -v? [22 nr SAIIWT t l h.i.C'arI � Ii,k_a qo��. Bernie Karl K&K Recycling Inc. Gordon Severson Richard Wagner P.O. Box 58055 3201 Westmar Cir. P.O. Box 60868 Fairbanks, AK 99711 Anchorage, AK 99508-4336 Fairbanks, AK 99706 George Vaught, Jr. P.O. Box 13557 Denver, CO 80201-3557 Darwin Waldsmith P.O. Box 39309 Ninilchik, AK 99639 .�� Nti1P J STATE OF ALASKA ADVERTISINGNOTICE ORDER TO PUBLISHER SUBMIT INVOICE SHOWING ADVERTISING ORDER NO., CERTIFIED AFFIDAVIT OFPUBLICATION DVERT MENT.TTACHEDCOPY OF ADVERTISING ORDER NUMBER AO -08-21-008 FROM: AGENCY CONTACT: Jody Colombie/Samantha Carlisle Alaska Oil and Gas Conservation Commission DATE OF A.O.AGENCY PHONE: 333 West 7th Avenue 9/24/2020 (907 279-1433 Anchorage, Alaska 99501 DATES ADVERTISEMENT REQUIRED: COMPANY CONTACT NAME: PHONE NUMBER: ASAP FAX NUMBER: (907) 276-7542 TO PUBLISHER: SPECIAL INSTRUCTIONS: Anchorage Daily News, LLC PO Box 140147 Anchorage, Alaska 99514-0174 TYPE OF ADVERTISEMENT: R_ LEGAL r DISPLAY F CLASSIFIED i— OTHER (Specify below) DESCRIPTION PRICE CO -20-019 Initials of who prepared AO: Alaska Non -Taxable 92-600185 SUBMIT INVOICE SHOWING ADVERTISING ORDER NO., CFFITTFI ED AFFIDAVIT OF PUBLICATION\\I'fNATTACIIR COPY OF ADVERTISMENT TO: AOGCC 333 West 7th Avenue Anchors e, Alaska 99501 Pae 1 of 1 Total of All Pages $ REF Type I Number Amount Date Comments I PVN IVCO21795 2 Ao AO -08-21-008 3 4 FIN AMOUNT SY Act. Template PGM LGR Object FY DIST I,IQ I 21 AOGCC 3046 21 z 3 4 S Purchasing Authority Name: Title: Purchasin uth iry's Signature Telephone Number Tracie L Paladijczuk, Admin Officer II 1. A.O.# and receiving agency name must appear on all Invoices and dowments relating to this purchase. 2. The slate is registered for tax free transactions under Chapter 32, IRS code. Registration number 92-73-0006 K. Items are for the exclusive use of the state and notforresale. DISTRIBUTION: Division Fiscal/Original AO Copies: Publisher (faxed), Division Fiscal, Receiving Form: 02-901 Revised: 9/24/2020 ANCHORAGE DAILY NEWS AFFIDAVIT OF PUBLICATIONRECEIVED Account #: 270227 ST OF AK/AK OIL AND GAS CONSERVATION COMMISSIOIJ�EP J 0 2020 333 W. 7TH AVE STE 100, ANCHORAGE, AK 99501 Order #: W0018062 STATE OF ALASKA THIRD JUDICIAL DISTRICT Lisi Misa being first duly sworn on oath deposes and says that she is a representative of the An- chorage Daily News, a daily newspaper. That said newspaper has been approved by the Third Judicial Court, Anchorage, Alaska, and it now and has been published in the English language continually as a daily newspaper in Anchorage, Alaska, and it is now and during all said time was printed in an office maintained at the afore- said place of publication of said newspaper. That the annexed is a copy of an advertisement as it was published in regular issues (and not in supplemental form) of said newspaper on 09/27/2020 and that such newspaper was regularly distrib- uted to its subscribers during all of said period. That the full amount of the fee charged for the foregoing publication is not in excess of the rate charged private individuals. le Signed U \/ V V 1 Subscribed and sworn to before me this 28th day of September 202 .� 95! C_ _1 2 �PTiDy 0 r X 70 % -n Z 1 G — O -0 Ocitary Public in artd or m C The State of Alaska. % Z �r- Third Division L_ n Anchorage, Alaska c w A MY COMMI ION E IRES Cost: $353.62 AOGCC Notice of Public Hearing STATE OF ALASKA ALASKA OIL AND GAS CONSERVATION COMMISSION Re: Docket Number: CO -20-019 The application of Hilcorp Alaska, LLC (Hilcorp) to amend Conservation Order No. 510A to allow for the addition of perforations in Undefined Sterling Pool in KU 21-07 above Sterling Gas Pool 3, defined in CO 510A for the Kenai Gas Field. By application received September 22, 2020, Hilcorp requests that Alaska Oil and Gas Conservation Commission (AOGCC) amend Conservation Order No. 510A to allow regular production for the KU 21-07 gas development well from an undefined Sterling Gas Pool within 1,500 feet of a property line where the owners and landowners are not the same on both sides of the line and within 3,000 feet of a well open to or capable of producing from the same pool (KU 42-12). Pursuant to 20 AAC 25.537 (a)(1) and (a)(2), Kenai Unit 21-07 well: Surface Hole Location (SHL): 450' FSL, 935' FWL, Sec. 6, T4N, R11 W, Seward Meridian Top of Production Horizon (rPH): 110' FSL, 1,401' FWL, Sec. 6, T4N, R11 W, Seward Meridian Bottom -hole Location (BHU: 17' FNL, 1,589' FWL, Sec, 7, T4N, R11W, Seward Meridian The AOGCC has tentatively scheduled a public hearing on this subject for October 29, 2020, at 10:00 a.m. at 333 West 7th Avenue, Anchorage, Alaska 99501. To request that the tentatively scheduled hearing be held, a written request must be filed with the AOGCC no later t an 4:30 p.m. on October 15, 2020. If a request for a hearing Is not timely filed, and the AOGCC deems the information submitted In support of Hilcorp's application sufficient to make a decision, the AOGCC may Issue an order without a hearinS. To learn if the AOGCC will hold the hearing, call (907) 279-1433 after October 16, 2020. If a hearing is requested, the COVID-19 virus may necessitate that the hearing be held telephonically. Those desiring to participate or be present at the hearing should check with AOGCC the day before the hearing to ascertain if the hearing will be telephonic. If the hearing is telephonic, on the day of the hearing, those desiring to be present or participate should call 1-800-315-6338 and, when instructed to do so, enter the code 14331 followed by the # sign. Because the hearing will start at 10:00 a.m., thephone lines will be available starting at 9:45 a.m. Depending on call volume, those calling in may need to make repeated attempts before getting through. In addition, written comments regarding this application may be submitted to the AOGCC, at 333 West 7th Avenue, Anchorage, Alaska 99501. Written comments must be received no later than 4:30 p.m. October 28, 2020, except that if a hearing is held, comments will be accepted until the conclusion of the October 29, 2020 hearing. If, because of a disability, special accommodations may be needed to comment or attend the hearing, contact the AOGCC at (907) 279-1433, no later than October 23, 2020. Jeremy M. Price Chair, Commissioner Published: September 27, 2020 F Hilcorp Alaska, LLC September 22, 2020 Jeremy Price, Chair Commissioner Alaska Oil and Gas Conservation Commission 333 West 7s' Avenue, Suite 100 Anchorage, Alaska 99501 RE: Application for Spacing Exception KU 21-07 Well Kenai Unit, Alaska Dear Commissioner Price: Post Office Box 244027 Anchorage, AK 99524-4027 3800 Centerpoint Drive Suite 1400 Anchorage, AK 99503 Phone: 907/777-8432 Fax: 907/777-8301 Email: cterrellohllcorp.com RECEIVED By Samantha Carlisle a11:39 pm, Sep 24, 3020 Hilcorp Alaska, LLC ("Hilcorp?), as Operator of the Kenai Unit ("KU"), requests permission to complete, test and produce the KU 21-07 Well in the Undefined Sterling Gas Pool within 1,500' of a property line where the owners are different on both sides and within 3,000' of one (1) other KU well, all within the same gas pool, in accordance with 20 AAC 25.055(a). The anticipated start date for the perforations is expected to commence on October 26"', 2020. The . KU 21-07 Well will be targeting the Undefined Sterling Gas Pool. Prior to completing and producing the KU 21-07 Well within the Undefined Sterling Gas Pool, this spacing exception will be required under 20 AAC 25.055(a)(2) and 25.055(a)(4): Per 20 AAC 25.055(a)(2), for a well drilling for gas, a wellbore may be open to test or regular production within 1,500 feet of a property line only if the owner is the same and the land owner is the same on both sides of the line; Per 20 AAC 25.055(a)(4), if gas has been discovered, the drilling unit for the pool is a governmental section; not more than one well may be drilled to and completed in that pool on any governmental section; a well may not be drilled or completed closer than 3,000 feet to any well drilling to or capable of producing from the same pool. A spacing exception is necessary because KU 21-07 will be within 3,000' of the KU 42-12 which is open to or capable of producing from the same pool. The KU 21-07 Well is located on the KGF 14-06 Pad within the KU. The Well is located on a Fee lease owned by Hilcorp (FEE A028142), shown on Attachment 1. The KU 21-07 Well will be within 1,500' of State of Alaska Lease ADL 392670 and Bureau of Land Management Lease A-028143. The surface hole, anticipated productive intervals, and bottom hole are located on FEE A028142: Surface Hole Location (SHL): 450' FSL, 935' FWL, Sec 6, T4N, Rl IW, SM, AK Top of Productive Horizon (TPH): 110' FSL, 1,401' FWL, Sec 6, T4N, R11 W, SM, AK Bottom Hole Location (BHL): 17' FNL, 1,589' FWL, Sec 7, T4N, RI 1W, SM, AK Kenai Unit Application for Spacing Exception Page 2 of 4 Hilcorp is a 100.00% Mineral Owner and Working Interest Owner of the affected oil and gas leases. The affected landowners within 3,000' of the KU 21-07 Well are the State of Alaska (ADL 392670), Bureau of Land Management (A028143), Pacific American Fisheries, Inc, and Hilcorp (FEE AA093836 & FEE A028142). Hilcorp believes that the correlative rights of all owners and landowners will be protected by the KU Agreement and its corresponding Participating Areas. In accordance with 20 AAC 25.055(d), at the date of this mailing, a copy of this proposed spacing exception was sent by certified mail to the potentially affected (within 3000') owners, landowners and operators. Also, enclosed is an affidavit stating the undersigned is acquainted with the facts and verifying that all facts asserted herein are true (see Attachment 2). Should you have any technical questions, please contact the undersigned at (907) 777-8432. Sincerely, Cody T. Terrell, Landman Hilcorp Alaska, LLC Enclosures: Attachment 1 (KU 21-07 Well Map); Attachment 2 (Affidavit) CC: Jody Colombie, AOGCC (via email) Kenai Unit Application for Spacin.- Exception Pa, -e 3 of 4 ATTACHMENT Application for Spacing Exception KU 21-07 Well Map A028143 FEE AA093836 11. 1 QC�9 BGI- c ALIctucA•1 rl !IC i L000593 ADI -392670 I 1 ' ,^u91'A7 "C KU 21-07 SILL KL'?9aT BI❑ ENAtUNR FEE A028142 A028143� 11• 1 � J Legend ADL392670 • KU42-12_SHL X KU 42-12 TPH KU 42.12_OHL C3 Gil and Gas Unit Boundary Q 1.500' buffer 3.000' buffer Kenai Unit KU 21-07 well wp06 0 530 1.100 1,650 2200 Feet A'i s Sul. Pena Z. 4. "D27 I&P oat. 9.22fmo Kenai Unit Application for Spacing Exception Page 4 of 4 ATTACHMENT 2 Application for Spacing Exception Affidavit VERIFICATION OF APPLICATION FOR SPACING EXCEPTION COOK INLET, ALASKA KENAI UNIT KU 21-07 Well 1, CODY T. TERRELL, Landman, Hilcorp Alaska, LLC ("Hilcorp"), do hereby verify the following: I am acquainted with Hilcorp's application for a spacing exception submitted to the Alaska Oil and Gas Conservation Commission for the drilling of the KU 21-07 Well in the Kenai Unit, near Cook Inlet, Alaska, pursuant to 20 AAC 25.055(d)(3). I assert all facts outlined in the above -referenced application are true. I further assert the requested spacing exception is necessary to drill and develop existing production from the Undefined Sterling Gas Pool in the Kenai Unit. I have reviewed the mailing list and plat attached to said application and it correctly portrays the pertinent and required data for the Commission to take action on this request. DATED at Anchorage, Alaska this22nd day of September 2020. Cody f Terrell, Landman Hilcorp Alaska, LLC STATE OF ALAKSA ) ) ss THIRD JUDICIAL DISTRICT ) ;WORN before me t is 22i' day of September, 2020. TARY PUBLIC IN AND FOR THE STATE OF ALSKA My Commission expires: Wts-1-2011