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FILEDMAY I 0 20t8
SEcRFTARY BOARD OFOIL, GAS & MINING
BEFORE THE BOARD OF OIL, GAS AND MININGDEPARTMENT OF NATURAL RESOURCES
STATE OF UTAH
IN THE MATTER OF THE REQUEST FORAGENCY ACTION OF EP ENERGY E&PCOMPANY, L.P. FOR AN ORDERAMENDING THE BOARD'S ORDER INDOCKET NO. 2012-013, CAUSE NO. 139-90AND THE BOARD'S ORDER IN DOCKETNO. 2014-035, CAUSE NO. 139_124, ANnESTABLISHING OVERLAPPING 640-ACREDRILLING UNITS AND OVERLAPPING"LAY DOWN" 1,280-ACRE DRILLINGUNITS, FOR THE PRODUCTION OF OIL,GAS AND ASSOCIATED HYDROCARBONSFROM THE LO\ilER GREEN RIVER ANDGREEN RIVER-WASATCH FORMATIONSIN: (1) SECTIONS t9-36, TO\üNSHIP 2SOUTH, RANGES 4 \ryEST THROUGH 5wEsT, u.s.M. AND (2) SECTIONS 3-10, 15-22AND 25-34, TOWNSHIP 3 SOUTH, RANGE 4\ryESTn U.S.M., ALL IN DUCHESNE
REQUEST FOR AGENCY ACTION
Docket No.2018-008
COUNTY UTAH
coMES Now, EP Energy E&p company, L.p. ("Ep Energy"), by and through its
attorneys Fox Rothschild LLP, and pursuant to Utah Code Ann. $$ 40-6-5(3Xb) and, 40-6-6,
hereby respectfully requests that the State of Utah Board of Oil, Gas and Mining (..Board,,) enter
an order: (i) amending the Findings of Fact, Conclusions of Law and Order in Docket No. 2012-
013, cause No. 139-90 dated }/ray 9,2012 ("erdgrl39:9Q"); (ii) amending the Findings of Fact,
Conclusions of Law and Order in Docket No. 2014-035, Cause No. 139-124 dated November 6,
2014 ("Oñer 139-124"); and (iii) establishing overlappin g 640-acredrilling units and overlapping
"lay down" 1,280-acre drilling units, for the production of oil, gas and other hydrocarbons from
Cause No. 139-155
the Lower Green River and Green River-Wasatch Formations, defined for purposes of this Request
for Agency Action ("RAA") as (collectively, ..Suþj_9gl_EoInqatigns") :
The interval from the top of the Lower Green River Formation(TGR3) to the base of the Green River-Wasatch Formation (top ofCretaceous), which base is defined as the stratigraphic equivalent ofthe Dual Induction Log depths lying betwe en16,720 feet and 16,970feet in the Shell-Ute 1-18B5 Well, located in the S/2NE/4, Section18, Township 2 South, Range 5 west, u.s.M.; and 16.970 feet inthe Shell-Brotherson l-11B4 Well located in the S/2NE/4, Section11, Township 2 South, Range 4 Vy'est, U.S.M.
Specifically, Order 139-90 authorizes the drilling of up to 4 vertical and/or directional,
wells per 640-acte (or the substantial equivalent) governmental section drilling unit established
thereby, with 1,320' interwell setbacks and 660' drilling unit boundary setbacks. Similarly, Order
139-124 authorizes the drilling of up to 8 vertical, directional, and/or horizontal wells per 640-acre
(or the substantial equivalent) governmental section drilling unit established thereby, with 990,
interwell setbacks and 660' drilling unit boundary setbacks.
This RAA seeks the amendment of Order 139-90 and Order I3g-124 to: (i) maintain 640-
acre (or the substantial equivalent) drilling units for the drilling of vertical and/or directional wells
on the Subject Lands (as defined below) for the development of the Subject Formations; (ii)
establish 640-acre (or the substantial equivalent) overlapping drilling units for the drilling of short-
lateral horizontal wells on the Subject Lands (as defined below) for the development of the Subject
Formations; and (iii) establish "lay down" 1,280-acre (or the substantial equivalent) overlapping
drilling units for the drilling of long-lateral horizontal wells on the Subject Lands (as defined
below) for the development of the Subject Formations.
The overlapping nature of the forgoing drilling units will not only provide Ep Energy with
the flexibility needed to drill vertical/directional, short-lateral horizontal and long-lateral
horizontal wells in a manner driven by geology, engineering, impact minimization and efficiency,
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but will also afford predictability in the preparation of tribal communitizationagreements, and in
the prosecution of future compulsory pooling proceedings before the Board, offering EP Energy
an opportunity to refine its long-term development plans concerning the Subject Lands. Indeed,
the flexibility requested herein with respect to the development of the Subject Lands is necessary
to allow the orderly development of the Subject Formations, to protect correlative rights, prevent
waste and maximize resource recovery.
In summary, EP Energy's request in this RAA extends to:
I. The maintenance of Order 139-90 and Order 139-124 as to the establishment of
640-acre (or the substantial equivalent) drilling units, each comprised of a govemmental section,
for the vertical/directional well development of the Subject Formations (each ^
"Vertical/Directio 'and collectively, "Veflical/DirectÍonal Well_Units") as to the
following lands located in Duchesne County, Utah (collectively, "Subje.ct Lands"):
Township 2 South. Range 4 West. U.S.M.|Sections 19-36: All
Townshio 2 South. Ranee 5 West- U.S.M.2Sections 19-36: All
Sections 3-10:Sections 15-22:Sections 25-34:
il. The amendment of Order 139-90 and Order 139-124 to include the establishment
of overlapping 640-acre (or the substantial equivalent) drilling units, each comprised of a single
I All portions of the Subject Lands lying within Townsh ip 2 South, Range 4 West, U.S.M. are cunently subject toOrder 139-124.2 All portions of the Subject Lands lying within Township 2 South, Range 5 West, U.S.M. are currently subjecttoOrder 139-124.3 Sections 3,22,25-26,28-29 and 34, Township 3 South, Range 4 West, U.S.M. are currently subject to Order 139-90 (collectively, "4 Wg!!-Dgn$iüJ4[ùs"), while Sections 4-lA,15-21,27 and30-33, Township 3 South, Range 4West, U.S.M. are currently subject to Order 139-124. Accordingly, the 7 govemmental sections comprising tñe 4Well Density Lands are the only portion of the Subject Lands subject ro Order l3g-g0.
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AllAu
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governmental section, for the short-lateral horizontal well development of the Subject Formations
(each an "SLFIZ iMell-Uui1" and collectively, "SLHZ V/ell Units"), as to the Subject Lands.
ilI. The amendment of Order 139-90 and Order 139-124 to include the establishment
of overlapping I,280-acre (or the substantial equivalent) "lay down" drilling units, each comprised
of 2 governmental sections, for the long-lateral well development of the Subject Formations (each
an "LLHZ V/ell Unit" and collectively, "LLHZ Well Units"), as to the Subject Lands.
IV. EP Energy's request herein concerning the Subject Lands is subject to, among other
things, the following:
A. A maximum of 8 vertical and/or directional wells (each a
"Vertical/Directio ' and collectively, "Vertical/Directional Wells") may be drilled and
produced from the Subject Formations in each Vertical/Directional Well Unit established on the
Subject Lands (excluding the 4 Well Density Lands), for a total of 8 Vertical/Directional Wells
per single govemmental section, inclusive of any Vertical/Directional V/ells existing in any such
Vertical/Directional Well Unit as of the date of this RAA (each an "Existing Vertical/Directional
Well" and collectively, "Existing Vertical/Directional Wells',);
B. A maximum of 4 VerticaliDirectional V/ells may be drilled and produced
from the Subject Formations in each Vertical/Directional Well Unit established on the 4 Well
Density Lands, for a total of 4 YerticallDirectional Wells per single govemmental section,
inclusive of any Existing Vertical/Directional Wells in any such Vertical/Directional Well Unit as
of the date of this RAA;
C. A maximum of 12 short-lateral horizontal wells, each comprised of a lateral
wellbore up to I mile in length (each an "SLHZ Well" and collectively, "SLHZ Wells"), may be
drilled and produced from the Subject Formations in each SLHZ Well Unit established on the
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Subject Lands, inclusive of: (l) any SLHZ rWell existing in such SLHZ V/ell Unit as of the date of
this RAA (each an "Existine SLHZ W'ell" and collectively, "Existing SLHZ Wells"); (2)any future
SLHZ V/ells drilled within such SLHZ Well Unit; and (3) any existing (as defined below) and/or
future LLHZ \Mells drilled on any lands contained within such SLHZ Well Unit;
D. A maximum of 12 long-lateral horizontal wells, each comprised of a lateral
wellbore greater than I mile in length (each an"LLHZWell" and collectively, "LLHZ Wells"),
may be drilled and produced from the Subject Formations in each LLHZ Well Unit established on
the Subject Lands, inclusive of: (1) any LLHZ Wells existing in such LLHZ Well Unit as of the
date of this RAA, as set forth more particularly below (each an "Existing LLHZ Well" and
collectively, "Existine LLHZ Wells"); (2) any future and/or Existing SLHZ V/ells drilled on any
lands contained within such LLHZ V/ell Unit; and (3) any future LLHZWells drilled within such
LLHZ Well Unit;
E. The Subject Formations constituting a "common source of supply" as
defined in Utah Code Ann. g a0-6-2(1S);
F. The amendment of Order 139-90 and Order 139-124 to provide that future
Vertical/Directional Wells within each Vertical/Directional Well Unit shall be drilled: (1) no closer
than 330' from any Existing Vertical/Directional V/ell, future Vertical/Directional Well, Existing
LLHZ Well or future LLHZ V/ell and (ii) no closer than 560' from the boundary of any
Vertical/Directional V/ell Unit, absent an exception location approval by the Board pursuant to
Utah Admin. Code Rule R649-3-3;
G. The amendment of Order 139-90 and Order 139-124 to provide that there
shall be no producing interval setbacks between future SLHZ Wells and future and/or Existing
vertical/Directional wells in any vertical/Directional well unit;
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H. No producing interval of any future SLHZ Well may be located: (l) closer
than 330' laterally from the east and west boundaries of the SLHZ Well Unit; (2) closer than 560'
laterally from the north and south boundaries of the SLHZ Well Unit; or (3) closer than 330'
laterally from the producing interval of any Existing SLHZ Well, Existing LLHZ Well, future
SLHZ Well, or future LLHZ Well within the SLHZ Well Unit, absent an exception location
approval by the Board pursuant to Utah Admin. Code Rule R649-3-3;
I. No producing interval of any future LLHZ Well may be located: (1) closer
than 330' laterally from the east and west boundaries of the or LLHZ Well Unit; (2) closer than
560' laterally from the north and south boundaries of the LLHZ Well Unit; or (3) closer than 330'
laterally from the producing interval of any Existing Vertical/Directional Well, Existing SLHZ
Well, Existing LLHZ Well, future Vertical/Directional Well, future SLHZ V/ell, or future LLHZ
V/ell withintheLLHZ Well Unit, absent an exception location approval by the Board pursuant to
Utah Admin. Code Rule R649-3-3;
J- The authority of an operator to adjust the specific lands covered by any
LLHZ V/ell Unit, provided the following conditions are met with respect to each such LLHZ Well
Unit adjustment: (l) there must be no existing SLHZ Well or LLHZ Well located on any of the
lands involved in eachLLHZ Well Unit adjustment; (2) the adjustment of any LLHZ Well Unit
shall require that notice of the same be provided pursuant to Utah Admin. Code Rule R64l-106-
300 to all parties whose legally protected rights may be affected by such LLHZ V/ell Unit
adjustment; (3) within 30 days of the service of any such notice, parties whose legally protected
rights may be affected by the LLHZ Well Unit adjustment shall be entitled to treat such notice as
a request for agency action pursuant to Utah Admin. Code Rule R641-105-100; and (4) in the
event 30 days elapses from the service of any notice concerning the adjustment of any LLHZ Well
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Unit without the f,rling of a response pursuant to Utah Admin. Code Rule R64l-105-200, any order
of the Board issued pursuant to this RAA shall be deemed amended, modified and/or vacated to
the extent necessary to authorize the adjustedLLHZ V/ell Unit.
K. Future SLHZ Wells andLLHZ V/ells drilled to separate zones within the
Subject Formations (each a "siackgd-HZ-Xlç!1" and collectively, "SI¿cked_HZ_]UgllS") within any
SLHZ Well Unit or LLHZ V/ell Unit shall have no interwell setback distance laterally between
one another within the subject SLHZ Well Unit or LLHZ Well Unit, but no producing interval of
an SLHZ Well or LLHZ Well within such SLHZ Well Unit oTLLHZ Well Unit may be located
closer than 100' vertically from the producing interval of another Stacked HZ Well within such
SLHZ V/ell Unit oTLLHZ Well Unit, absent an exception location approval by the Board pursuant
to Utah Admin. Code Rule R649-3-3;
L- The surface location of: (1) any future Vertical/Directional V/ell may be
located pursuant to Order 139-90 or Order 139-124,as the case may be; (2) any future SLHZ Well
ot LLHZ Well may be located anywhere within the SLHZ Well Unit or LLHZ Well Unit,
respectively; and (3) any future SLHZ V/ell or LLHZ Well may be located outside of such SLHZ
rWell Unit or LLHZ Well Unit, respectively, all subject to the acquisition of proper surface and
subsurface estate authorizations (including without limitation mineral and surface owner
subsurface easements) and the casing/cementing of any future SLHZ Well or LLHZ Well to the
330' setback set forth in Paragraphs H-I above, all of which shall be evidenced by a self-
certification of the same executed by the operator of such SLHZWeI Unit oTLLHZ V/ell Unit,
and hled with the Utah Division of Oil, Gas and Mining ("Division"), provided that the other
setbacks set forth in Paragraphs H-I above are otherwise maintained;
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M- The requirement that the operator appear before the Board on the first
anniversary of the effective date of any order of the Board issued pursuant to this RAA, and on
each of the 4 anniversaries thereafter, for the purpose of: (1) providing the Board with information
and data concerning such operator's operations on the Subject Lands pursuant to such order and
(2) based thereon, determining the need, if any, for the Board's amendment, modification and/or
termination of any such order; and
N. The expiration of any order ofthe Board issued pursuant to this RAA within
5 years of the date of such issuance, unless otherwise extended, amended, modified and/or
otherwise made permanent by the Board.
In support of this RAA, EP Energy states, represents and alleges as follows:
1. EP Energy is a Delaware limited partnership, with its principal place of business in
Houston, Texas.
2. EP Energy is duly qualified to conduct business in the State of Utah.
3. EP Energy is fully and appropriately bonded as required by all relevant federal,
tribal and State of Utah governmental agencies.
4. The oil, gas and other hydrocarbons within the Subject Lands are subject to
numerous fee, state, and tribal oil and gas leases, in which EP Energy owns substantial leasehold
working interests.
5. As of the filing of this RAA, there are no well spacing, density, or other orders of
the Board materially affecting the spacing of the Subject Lands, otherthan Order 139-90 and Order
139-124, and as applicable, the general provisions of the Utah Admin. Code regarding drilling
units and well siting.
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6- As of the filing of this RAA, there are 133 Existing Vertical/Directional V/ells,
Existing SLHZ V/ells and ExistingLLHZ rWells (collectively, "Existins Wells") located on and/or
producing from the Subject Formations on the Subject Lands, as set forth more particularly on
Exhibit "A," attached hereto and incorporated herein.
7. V/ith the exception of the Existing Wells, there are no other wells drilled or
producing from the Subject Formations on the Subject Lands as of the filing of this RAA.
8. Based upon the information and data obtained through EP Energy's drilling and
operation of the majority of the Existing Wells in the 640-acre drilling units established pursuant
to order 139-90 and order 139-124, Ep Energy believes and alleges that:
(a). The drilling and production of future Vertical/Directional Wells, future
SLHZ Wells and future LLHZ V/ells in the requested Vertical/Directional Well Units, SLHZ Well
Units and LLHZ Well Units will result in production and productivity increases, and cost
effectiveness, over the drilling and production of the wells currently authorized under Order 139-
90 and Order 139-124 alone, and will allow access to additional resources in the Subject
Formations that would not otherwise be recovered;
(b). V/ith respect to Vertical/Directional Wells, engineering data and operations
conducted by EP Energy on the Subject Lands confirm that: (i) setbacks no closer than 330' from
any Existing Vertical/Directional Well, any future Vertical/Directional Well, any Existin gLLHZ
Well or any future LLHZ Well; (ii) no setbacks between future Vertical/Directional Wells and
SLHZ V/ells; and (iii) setbacks no closer than 560' from the boundary of any Vertical/Directional
Well Unit will allow greater flexibility in locating future Vertical/Directional V/ells, future SLHZ
Wells and future LLHZ Wells upon the Subject Lands, while still protecting correlative rights;
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(c) With respect to SLHZ Wells and LLHZ Wells, the average effective
hydraulic fracture half lengths and average orientation conhrm that: (i) no producing interval
setbacks between future SLHZ V/ells and future and/or Existing VerticaliDirectional V/ells; (ii)
producing interval setbacks of 330' laterally between future LLHZ Wells and future and/or
Existing Vertical/Directional Wells; (iii) producing interval setbacks of 330' laterally from the east
and west boundaries of each SLHZ Well Unit oTLLHZ Well Unit; (iv) producing interval setbacks
of 560' laterally from the north and south boundaries of each SLHZ Well Unit orLLHZWell Unit;
(v) producing interval setbacks of 330' laterally between the producing intervals of any Existing
SLHZ V/ell, ExistingLLHZ Well, future SLHZ V/ell and/or future LLHZ Well within the SLHZ
Well Unit oTLLHZ Well Unit; (vi) no interwell producing interval setback distance laterally within
any SLHZ Well Unit oTLLHZ Well Unit between Stacked HZ V/ells; and (vii) producing interval
setbacks of 100' vertically from the producing interval of another Stacked HZ Well within any
SLHZ 'Well Unit or LLHZ V/ell Unit, will collectively result in effrcient but limited
communication between Existing Wells, future Vertical/Directional V/ells, future SLHZ V/ells,
and future LLHZ Wells, and will allow greater flexibility in locating future Vertical/Directional
Wells, future SLHZ Wells and future LLHZ Wells upon the Subject Lands, while still protecting
correlative rights;
(d). It is difficult, if not impossible, to establish uniform producing interval
setbacks between Existing Wells, future Vertical/Directional Wells, future SLHZ Wells, and future
LLHZ Wells, but the s¿rme may be required to maximize resource recovery from the Subject
Formations, and the separation of individual production intervals within the pool of the Subject
Formations would require separate metering and create additional administrative burdens to either
prevent, or effect, the commingling of production from the Subject Formations;
l0
(e). In order to maximize the recovery of resources from the Subject
Formations: (i) up to 8 Vertical/Directional Wells in each Vertical/Directional Well Unit on the
Subject Lands (excluding the 4 Well Density Lands); (ii) up to 4 Vertical/Directional Wells in
each Vertical/Directional Well Unit on the 4 Well Density Lands; (iii) up to 12 SLHZ Wells in
each SLHZ Well Unit (inclusive of: (I) any Existing SLHZ Wells; (II) any future SLHZ Wells
drilled within such SLHZ Well Unit; and (III) any ExistingLLHZ Wells and/or future LLHZ Wells
drilled on any lands contained within such SLHZ V/ell Unit); and (iv) up to 12 LLHZ Wells in
eachLLHZ Well Unit (inclusive of: (I) any ExistingLLHZ Wells; (II) any tuture LLHZ Wells
drilled within such LLHZ Well Unit; and (III) any ExistingSLHZ Wells or future SLHZ Wells
drilled on any lands contained within such LLHZ Well Unit), are necessary to allow flexibility in
the drilling of wells and to allow the maximum recovery of resources from all zones and intervals
found within the Subject Formations.
9. Based on the foregoing, EP Energy believes and alleges that in order to afford the
continued protection of the correlative rights of the owners of interests in the Subject Lands, the
prevention of waste and the maximization of resource recovery:
(a). The Subject Formations should be declared a "common source of supply"
as contemplated by Utah Code Ann. $ a0-6-2(18);
(b). Effective the date of issuance of any order of the Board issued pursuant to
this RAA, Order 139-90 and Order 139-124 should be maintained as to the establishment of the
Vertical/Directional Well Units upon the Subject Lands for all Existing Vertical/Directional Wells
and future Vertical/Directional Wells, such that all production attributable to the same should be
allocated to such Vertical/Directional Well Units, respectively;
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(c). Effective the date of issuance of any order of the Board issued pursuant to
this RAA, Order 139-90 and Order I39-I24 should be amended to include establishment of the
SLHZ Well Units upon the Subject Lands for all Existing SLHZ V/ells and future SLHZ Wells,
such that all production attributable to the same should be allocated to such SLHZ Well Units,
respectively;
(d). Effective the date of issuance of any order of the Board issued pursuant to
this RAA, Order 139-90 and Order 139-124 should be amended to include establishment of the
LLHZ V/ell Units upon the Subject Lands for all Existing LLHZ V/ells and future LLHZ Wells,
such that all production attributable to the same should be allocated to such LLHZ Well Units,
respectively;
(e). The allocation of proceeds of production of oil, gas and associated
hydrocarbons from the Subject Formations upon the Subject Lands should be effected in a manner
that is tied to overlapping drilling unit establishment for specific well types, l.e. production from
Vertical/Directional Wells should be allocated to each such well's specific existing/maintained
Vertical/Directional Well Unit, production from SLHZ Wells should be allocated to each such
well's specific proposed SLHZ Well Unit, and production from LLHZ Wells should be allocated
to each such well's specific proposed LLHZ Well Unit;
(Ð. The operator should be required to report the results of its operations on the
Subject Lands to the Board annually for a period of 5 years from the date of any order of the Board
issued pursuant to this RAA.
10. EP Energy believes and alleges that the foregoing illustrates its need to maintain
flexibility in order to continue to develop the Subject Lands in a manner focused on guarding the
correlative rights of all affected parties, maximizing resource recovery and preventing waste.
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1 l. EP Energy believes and alleges that in order to facilitate such flexibility and
maintain the foregoing goals, the operator ofLLHZ Wells should be permitted to adjust the specific
governmental sections which comprise a given LLHZ Well Unit, so long as all parties whose
legally protected rights are affected by such adjustment are provided with notice and a fair
opportunity to respond to such adjustment.
12. EP Energy believes and alleges that effective the date of issuance of any order of
the Board pursuant to this RAA, the operator of an LLHZ Well on the Subject Lands should be
authorized to adjust the specific lands covered by such well's LLHZ Well Unit, provided the
following conditions are met with respect to each such LLHZ Well Unit adjustment: (a) there must
be no existing SLHZ Well or LLHZ Well located on any of the lands involved in each such LLHZ
Well Unit adjustment; (b) the adjustment of any LLHZ Well Unit shall require that notice of the
same be provided pursuant to Utah Admin. Code Rule R641-106-300 to all parties whose legally
protected rights may be affected by such LLHZ Well Unit adjustment; (c) within 30 days of the
service of any such notice, parties whose legally protected rights may be affected by the LLHZ
V/ell Unit adjustment shall be entitled to treat such notice as a request for agency action pursuant
to Utah Admin. Code Rule R64l-105-100; and (d) in the event 30 days elapses from the service
of any notice concerning the adjustment of any LLHZ Well Unit without the filing of a response
pursuant to Utah Admin. Code Rule R641-105-200, any order of the Board issued pursuant to this
RAA shall be deemed amended, modified andlor vacated to the extent necessary to authorize the
adjusted LLHZ V/ell Unit.
13. Due to the presence of oil and gas leases issued through the United States
Department of the Interior, Bureau of Indian Affairs ("8I4") covering portions of the Subject
Lands, the preparation and execution of multiple tribal communitization agreements is required
13
(whether by regulation and guideline, or through BIA practice), a prerequisite of which is the
maintenance of the existing Vertical/Directional Well Units and the establishment of the requested
SLHZ Well Units andLLHZ Well Units.
14. EP Energy respectfully asserts that the granting this RAA will further the public
policies of the State of Utah to promote greater recovery of oil, gas and associated hydrocarbons
from the Subject Formations without waste and with protection of the correlative rights of all
affected owners, constitutes the orderly and consistent development of the Subject Lands as to the
Subject Formations, and is just and reasonable under the circumstances.
15. In accordance with the Utah Admin. Code, EP Energy will present testimony and
exhibits in support of the allegations and statements set forth in this RAA at the June 27,2018
Board hearings.
16. EP Energy will separately file a certificate of service listing all parties known to it,
based upon its reasonable search of the Duchesne County, Utah records and the records of the
Division, whose legally protected interests may be affected by this RAA.
17. As of the filing of this RAA, EP Energy knows of no respondents or adverse parties
concerning this RAA.
WHEREFORE, based on the foregoing, EP Energy respectfully requests that:
I. This matter be set for hearing before the Board on June 27,2018, in Salt Lake City,
Utah ("Hearing");
II. Notice of this RAA and the Hearing be given as required by applicable Utah
administrative and statutory law; and
n. Upon production of suffrcient evidence and testimony given at the Hearing, the
Board issue an order:
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A. Declaring the Subject Formations a "common source of supply," as
contemplated by Utah Code Ar¡r. $ a0-6-2(18);
B. Maintaining Order 139-90 and Order 139-124's establishment of the
Vertical/Directional Well Units upon the Subject Lands for the Subject Formations for all Existing
Vertical/Directional Wells and future Vertical/Directional Wells, effective the date of issuance of
any order of the Board issued pursuant to this RAA;
C. Amending Order 139-90 and Order 139-124 to establish the SLHZ Well
Units upon the Subject Lands for the Subject Formations for all Existing SLHZ Wells and future
SLHZ V/ells, effective the date of issuance of any order of the Board issued pursuant to this RAA;
D. Amending Order 139-90 and Order 139-124 to establish the LLHZ V/ell
Units upon the Subject Lands for the Subject Formations for all Existing LLHZ V/ells and future
LLHZ V/ells, effective the date of issuance of any order of the Board issued pursuant to this RAA;
E. Authorizing the drilling, completion and operation of 8 Vertical/Directional
Wells in each Vertical/Directional Well Unit on the Subject Lands (excluding the 4 Well Density
Lands), for a total of 8 Vertical/Directional V/ells per single governmental section (inclusive of
Existing Vertical/Directional V/ells) for the Subject Formations;
F. Authorizing the drilling, completion and operation of 4 Vertical/Directional
Wells in each Vertical/Directional Well Unit on the 4 Well Density Lands, for a total of 4
Vertical/Directional Wells per single governmental section (inclusive of Existing
Vertical/Directional Wells) for the Subject Formations;
G. Authorizing the drilling, completion and operation of up to 12 SLHZ Wells
in each SLHZ Well Unit on the Subject Lands (inclusive of: (I) any Existing SLHZ Wells; (II) any
future SLHZ Wells drilled within such SLHZ Well Unit; and (IIf any ExistingLL[ZWells and/or
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future LLHZ Wells drilled on any lands contained within such SLHZ Well Unit) for the Subject
Formations;
H. Authorizing the drilling, completion and operation of up to I2LLHZ Wells
in each LLHZ Well Unit onthe Subject Lands (inclusive of: (I) any ExistingLLHZ Wells; (II) any
future LLHZ Wells drilled within such LLHZ V/ell Unit; and (III) any ExistingSLHZ Wells or
future SLHZ Wells drilled on any lands contained within such LLHZ Well Unit) for the Subject
Formations;
I. Amending Order 139-90 and Order 139-124 to provide that Future
Vertical/Directional Wells within each Vertical/Directional Unit shall be drilled, completed and
operated: (1) no closer than 330' from any Existing Vertical/Directional Well, future
Vertical/Directional Well, Existing LLHZ Well or future LLHZ Well and (2) no closer than 560'
from the boundary of any Vertical/Directional V/ell Unit, absent exception location approval by
the Board pursuant to Utah Admin. Code Rule R649-3-3;
J. Amending Order 139-90 and Order 139-124 to provide that there shall be
no producing interval setbacks between future SLHZ Wells and future and/or Existing
Vertical/Directional Wells in any Vertical/Directional Well Unit;
K. Providing for future SLHZ Well producing interval setbacks of: (1) 330'
laterally from the east and west boundaries of the SLHZ V/ell Unit; (2) 560' laterally from the
north and south boundaries of the SLHZ Well Unit; and (3) 330' laterally from the producing
interval of any Existing SLHZ Well, ExistingLLHZ Well, future SLHZ Well, or future LLHZ
Well within the SLHZ Well Unit, absent exception location approval by the Board pursuant to
Utah Admin. Code Rule R649-3-3;
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L. Providing for future LLHZ Well producing interval setbacks of: (1) 330'
laterally from the east and west boundaries of the LLHZ Well Unit; (2) 560' laterally from the
north and south boundaries of the LLHZ V/ell Unit; and (3) 330' laterally from the producing
interval of any Existing Vertical/Directional Well, Existing SLHZ Well, Existing LLHZ Well,
future Vertical/Directional Well, future SLHZ Well, or future LLHZ Well within the LLHZ Well
Unit, absent exception location approval by the Board pursuant to Utah Admin. Code Rule R649-
3-3;
M. Providing that there shall be no interwell producing interval setback
distance laterally within any SLHZ Well Unit or LLHZ Well Unit between Stacked HZ Wells,
absent exception location approval by the Board pursuant to Utah Admin. Code Rule R649-3-3;
N. Providing for producing interval setbacks of 100' vertically from the
producing interval of another Stacked HZ Well within such SHLZ Well Unit oTLLHZ Well Unit,
absent exception location approval by the Board pursuant to Utah Admin. Code Rule R649-3-3;
O. Providing that the surface location of any future Vertical/Directional Well
upon the Subject Lands may be located pursuant to Order 139-90 and/or Order 139-124, as the
case may be;
P. Providing that the surface location of any future SLHZ Well or future LLHZ
V/ell may be located anywhere within any SLHZ Well Unit or LLHZ Well Unit, absent an
exception location approval by the Board pursuant to Utah Admin. Code Rule R649-3-3, and
subject to the acquisition of proper surface and subsurface estate authorizations (including without
limitation mineral and surface owner subsurface easements) and the casing/cementing of any
future SLHZ Well or future LLHZ Well to the 330' setbacks set forth in Paragraphs K-L above,
to be evidenced by a self-certification of the same executed by the operator of the subject SLHZ
t7
Well or LLHZ Well and filed with the Division, and provided that the other setbacks set forth
above are otherwise maintained;
a. Providing that the surface location of any future SLHZ Well or future LLHZ
Well may be located anywhere outside of such SLHZ V/ell Unit or LLHZ Well Unit, absent an
exception location approval by the Board pursuant to Utah Admin. Code Rule R649-3-3, and
subject to the acquisition of proper surface and subsurface estate authoúzations (including without
limitation mineral and surface owner subsurface easements) and the casing/cementing of any
future SLHZ Well or future LLHZ Well to the 330' setbacks set forth in Paragraphs K-L above,
to be evidenced by a self-certification of the same executed by the operator of the subject SLHZ
Well or LLHZ V/ell and filed with the Division, and provided that the other setbacks set forth
above are otherwise maintained;
R. Authorizing the operator of an LLHZ Well on the Subject Lands to adjust
the specific lands covered by such well's LLHZ Well Unit, provided the following conditions are
met with respect to each such LLHZ Well Unit adjustment: (1) there must be no existing SLHZ
Well or LLHZ Well located on any of the lands involved in each such LLHZWeII Unit adjustment;
(2) the adjustment of any LLHZ V/ell Unit shall require that notice of the same be provided
pursuant to Utah Admin. Code Rule R641-106-300 to all parties whose legally protected rights
may be affected by such LLHZ Well Unit adjustment; (3) within 30 days of the service of any such
notice, parties whose legally protected rights may be affected by the LLHZ Well Unit adjustment
shall be entitled to treat such notice as a request for agency action pursuant to Utah Admin. Code
Rule R641 - 1 05- 1 00; and (a) in the event 30 days elapses from the service of any notice concerning
the adjustment of any LLHZ Well Unit without the filing of a response pursuant to Utah Admin.
Code Rule R64l-105-200, any order of the Board issued pursuant to this RAA shall be deemed
l8
amended, modified and/or vacated to the extent necessary to authorize the adjusted LLHZ Well
Unit, effective the date of issuance of any order of the Board issued pursuant to this RAA;
S. Providing a requirement that the operator appear before the Board on the
first anniversary of the effective date of any order of the Board issued pursuant to this RAA, and
on each of the 4 anniversaries thereafter, for the pulpose of: (1) providing the Board with
information and data concerning such operator's operations on the Subject Lands pursuant to such
order and (2) based thereon, determining the need, if any, for the Board's amendment, modification
and/or termination of any such order;
T. Providing for the expiration of any order of the Board issued pursuant to
this RAA within 5 years of the date of such issuance, unless otherwise extended, amended,
modified and/or otherwise made permanent by the Board;
U. Making such findings and orders in connection with this RAA as it deems
otherwise necessary; and
V. Providing for such other and further relief as the Board deems just and
equitable.
Respectfully submitted this lOth day of May 2018.
FOX ROTHSCHILD LLP
D. CHICKEN (UT Bar # I4e27)1225 lTth StreetSuite 2200Denver, CO 80202Phone: 303.446.3844Email: [email protected]
Attomey for Petitioner EP Energy E&PCompany, L.P.
t9
Petitioner's Address:EP Energy E&P Company, L.P.1001 Louisiana St. / P.O. Box 4660Houston, TX772l0-4660
20
3.At
OPERATOR: ORIENT:API: WELL NAME:
430 1330087
YOUNG 4-6C4
YOUNG 2.7C4
YOLTNG 2-3084
YOUNG I-2984wrlsoN 3-3685
WILSON I.I8C4WEIKERT 2.2984
VASQUEZ 3-7C4
VANDERPLAATS TRUST4-16C4UTEX 29.1
4301352085
430135 1500
4301331366
4301330246
4301350439
4301351795
430t331298
4301353064
4301352970
4301330242
4301353286
4301352086
43013s3436
4301353289
43013519s4
4301352889
4301350302
4301330577
43013s2875
4301353209
430133 I 130
4301334166
4301333467
4301353365
43013s3366
4301353335
43013s0388
4301353252
4301350571
4301331118
4301352082
4301352084
4301334123
4301353137
4301352901
4301353642
EP ENERGY
EP ENERGY
EP ENERGY
EP ENERGY
EP ENERGY
EP ENERGY
EP ENERGY
EP ENERGY
EP ENERGY
UINTA.TAYLORFUND LTDEP ENERGY
EP ENERGY
EP ENERGY
EP ENERGY
EP ENERGY
EP ENERGY
EP ENERGY
EP ENERGY
EP ENERGY
EP ENERGY
EP ENERGY
EP ENERGY
EP ENERGY
EP ENERGY
EP ENERGY
EP ENERGY
EP ENERGY
EP ENERGY
EP ENERGY
EP ENERGY
EP ENERGY
EP ENERGY
EP ENERGY
EP ENERGY
EP ENERGY
EP ENERGY
EP ENERGY
TWN/RNG:
3S-4W
3S-4W
2S-4V/
2S-4W
2S-5W
3S-4W
2S-4W
3S-4W
3S-4W
3S-4W
2S-4W
3S-4W
SECTION:
6
7
30
29
36
18
29
7
l6
29
28
7
VERT
VERT
VERT
VERT
VERT
VERT
VERT
VERT
VERT
VERT
VERT
DIR
UTE I-28B4
TOMLINSON-BERRETT4-7C4THORNE 3-3I84THOMAS 3-4C4
THOMAS 1.33C4
TAYLOR 3.9C4
SPRATT 3-3284
SPRATT 3-2685
SMITH I-3IB5SILVER 5-20C4
RODACK 9-20C4
ROBB 2.2985
RINKER 2-2185
RHOADES 2.2585
RETZKE 3-25C4
RETZKE 2.25C4
RETZKE 1.25C4
REBEL 3-35B5
POULSON 4-31C4
POTTER 4-2785
POTTER 2-2485
PENFIELD 2-8C4
PENFIELD 2-IOC4
owl. & HAWK 2-3185
OSTLER 7-20C4
OLSEN 4-18C4
OCHENTA 4-3184
VERT
VERT
DIR
VERT
VERT
VERT
VERT
VERT
VERT
VERT
VERT
VERT
VERT
DIR
DIR
VERT
DIR
VERT
VERT
VERT
VERT
DIR
VERT
DIR
DIR
2S-4W
3S-4W
3S-4W
3S-4W
2S-4W
2S-5rü/
2S-5W
3S-4W
3S-4W
2S-5W
2S-5W
2S-5W
3S-4W
3S-4W
3S-4W
2S-5W
3S-4W
2S-5W
2S-5W
3S-4W
3S-4W
2S-5W
3S-4W
3S-4W
2S-4W
3l4
5J
9
32
26
3l20
20
29
2t25
25
25
25
35
3l27
24
8
l03t
20
l83l
2t
4301352242
4301331132
4301331124
43013s3297
4301353257
4301352774
4301353074
4301352990
4301352555
43013s2665
4301352877
4301352879
430135 1653
430 1353438
4301352841
430 135 1909
4301330220
43013s0714
ocAMPO 4-9C4
MURDOCK 2-3485
MURDOCK 2.2685
MOON s-31C4
MOON 3-33C4
MOON 3-32C4
MOON 3-31C4
MOON 3-30C4
MOON 3-15C4
MOON 2-33C4
MOON 2-27C4
MIYA 3.6C4
MERKLEY I-32C4
MCNEILL 4-8C4
MATERN TRUST 4-21C4
MARQUEZ 2-17C4
LAWRENCE I-3084
LAKE FORK RANCH 4-268,4LAKE FORK RANCH 4-25B,4LAKE FORK RANCH 4-24B.4LAKE FORK RANCH 4.23B,4LAKE FORK RANCH 3-26B,4LAKE FORK RANCH 3-25B,4LAKE FORK RANCH 3-2484LAKE FORK RANCH 3.22B,4KUSHMAUL 5-IOC4
KUSHMAUL I-I6C4
KT VI PROPERTIES 2-20c4KRATZER I-27C4
KOZAR2-5C4
KOZAR I-4C4
KOUMBIS I-IOC4
KOFFORD 2-3685
KATHERINE3-2984
KARREN TRUST 4-30C4
JENSEN 2-9C4
HUNT I-21B,4
HOGGE 3-16C4
EP ENERGY
EP ENERGY
EP ENERGY
EP ENERGY
EP ENERGY
EP ENERGY
EP ENERGY
EP ENERGY
EP ENERGY
EP ENERGY
EP ENERGY
EP ENERGY
EP ENERGY
EP ENERGY
EP ENERGY
EP ENERGY
EP ENERGY
EP ENERGY
EP ENERGY
EP ENERGY
EP ENERGY
EP ENERGY
EP ENERGY
EP ENERGY
EP ENERGY
EP ENERGY
EP ENERGY
EP ENERGY
VERT
VERT
VERT
DIR
VERT
DIR
VERT
DIR
VERT
VERT
DIR
VERT
VERT
VERT
VERT
VERT
VERT
DIR
VERT
VERT
VERT
VERT
VERT
VERT
VERT
VERT
VERT
DIR
3S-4W
2S-5W
2S-5W
3S-4W
3S-4W
3S-4W
3S-4W
3S-4W
3S-4W
3S-4W
3S-4W
3S-4V/
3S-4W
3S-4W
3S-4rW
3S-4W
2S-4W
2S-4W
3S-4W
3S-4W
3S-4W
3l
9
34
26
JJ
32
3l30
15
55
27
6
32
8
2lt730
26
4301353116
4301350717
4301350713
4301350707
430135071 I
4301350716
4301334261
430t353251
4301351725
4301352958
2S-4W 25
2S-4W 24
2S-4W 23
2S-4W 26
2S-4W 25
2S-4W 24
2S-4W 22
l0t620
4301352991
4301352551
4301352554
4301352075
430r333988
4301332923
4301353268
4301351375
4301330214
4301352775
EP ENERGY
EP ENERGY
EP ENERGY
EP ENERGY
EP ENERGY
EP ENERGY
EP ENERGY
EP ENERGY
EP ENERGY
EP ENERGY
VERT
VERT
VERT
VERT
VERT
VERT
VERT
VERT
VERT
VERT
3S-4W
3S-4W
3S-4W
3S-4W
2S-5W
2S-4W
3S-4W
3S-4W
2S-4W
3S-4W
27
5
4
l036
29
30
9
2tt6
22
4301352289
43013s 1489
430135 1938
430t330288
4301351404
4301350986
4301353298
4301353167
4301353470
4301353013
43013s2460
4301352295
4301353121
4301333265
4301353467
4301352851
4301351912
4301351727
4301353166
4301352013
430133 1389
4301350208
4301350572
4301351376
4301350474
4301353041
4301334207
4301352850
4301352903
430t352ss0
HISLOP 3-8C4
HEWETT 2.6C4
HAGGARD 2-16C4
GRIFFITH I-3384
GOLINSKI 4-2485
GOLINSKI I-8C4
FOUR LP LLC 6-IOC4
FLYING DUTCHMAN 6-20c4FLYING DUTCHMAN 5-l8c4FLYING DUTCHMAN 5.t7c4FLYING DUTCHMAN 3-2tc4FLYING DUTCHMAN 3-l8c4FLANNERY 3-20C4
FERRARINI3-2784
FAUST 5-7C4
FAIRCLOUGH4.2OC4
EUGSTER 2-28C4
EPLEY I.I5C4EP ENERGY 8-20C4
EP ENERGY I-19C4
ELLSWORTH3.2OB4
EL PASO 4-2985
EL PASO 4-2184
EL PASO 3-5C4
EL PASO 3.2184
DWR4-3285
DWR 3-3285
DW LANDFILL 4-3284
DW LANDFILL3-3384DUCHESNE COUNTY 4-5C4DUCHESNE CITY 3-I9C4
DUCHESNE CITY 2-30C4
DUCHESNE CITY 2-19C4
CHESTNUT 3-17C4
CASE 2-3I84CAHAL 4.15C4
BUTTE 5-5C4
BULLOCK 4-17C4
BROTHERSON 3-2384
BROTHERSON 2-2684
EP ENERGY
EP ENERGY
EP ENERGY
EP ENERGY
EP ENERGY
EP ENERGY
EP ENERGY
EP ENERGY
EP ENERGY
EP ENERGY
EP ENERGY
EP ENERGY
EP ENERGY
EP ENERGY
EP ENERGY
EP ENERGY
EP ENERGY
EP ENERGY
EP ENERGY
EP ENERGY
EP ENERGY
EP ENERGY
EP ENERGY
EP ENERGY
EP ENERGY
EP ENERGY
EP ENERGY
EP ENERGY
EP ENERGY
EP ENERGY
VERT
VERT
DIR
VERT
DIR
VERT
VERT
VERT
DIR
VERT
VERT
DIR
3S-4W
3S-4W
3S-4rW
2S-4W
2S-5W
3S-4W
3S-4W
3S-4W
3S-4W
3S-4W
3S-4W
3S-4W
3S-4W
2S-4W
3S-4W
3S-4V/
3S-4W
3S-4W
3S-4W
3S-4W
2S-4W
2S-sW
2S-4W
3S-4rW
2S-4W
2S-5W
2S-5W
2S-4W
2S-4W
3S-4W
3S-4W
3S-4W
3S-4W
3S-4rW
2S-4W
3S-4W
3S-4W
3S-4W
2S-4W
2S-4W
8
6
l6JJ
24
8
l020
l8
t7
2t
l8
7
20
28
l5
20
t9
20
29
2t5
2l32
32
32
JJ
5
DIR
VERT
VERT
DIR
VERT
VERT
VERT
VERT
VERT
VERT
VERT
DIR
VERT
DIR
VERT
VERT
DIR
VERT
VERT
DIR
VERT
DIR
VERT
DIR
VERT
VERT
VERT
VERT
20
27
4301353284
4301351791
4301352669
4301352616
430t333548
4301353277
4301353287
4301352900
4301331289
4301333139
EP ENERGY
EP ENERGY
EP ENERGY
EP ENERGY
EP ENERGY
EP ENERGY
EP ENERGY
EP ENERGY
EP ENERGY
EP ENERGY
t9
30
l9t"l
3ll5
5
t7
23
26
23
4301332791
430r332695
430133 1086
4301330336
4301330668
4301330483
430133 1036
4301331304
4301331126
4301352291
4301352843
4301352143
4301352667
4301352902
4301351487
4301351460
4301352397
4301352294
BROTHERSON 2-2584
BROTHERSON 2-2484
BROTHERSON2-2284
BROTHERSON I-26B4
BROTHERSON I-2584
BROTHERSON I-2384
BROADHEAD2-3285
BLEAZARD 2-2884
BIRCH 3.27B5
BELL3-28C4
BAGLEY 4-19C4
AYERS TRUST 2-15C4
ARONCO 4-4C4
ANDERSON 2-21C4
ALLEN 4-2585
ALBA I-21C4
ADELMAN 5-9C4
ADELMAN 2-4C4
EP ENERGY
EP ENERGY
EP ENERGY
EP ENERGY
EP ENERGY
EP ENERGY
EP ENERGY
EP ENERGY
EP ENERGY
EP ENERGY
EP ENERGY
EP ENERGY
EP ENERGY
EP ENERGY
EP ENERGY
EP ENERGY
EP ENERGY
EP ENERGY
VERT
VERT
VERT
VERT
VERT
VERT
VERT
VERT
VERT
VERT
VERT
VERT
DIR
VERT
VERT
DIR
VERT
VERT
2S-4W
2S-4W
2S-4W
2S-4W
2S-4W
2S-4W
2S-5W
2S-4W
2S-5W
3S-4W
3S-4W
3S-4V/
3S-4W
3S-4W
2S-5W
3S-4W
3S-4W
3S-4W
25
24
22
26
25
23
32
28
27
28
t9l54
2t25
2t9
4
24
