compulsory pooling & landowner protections
DESCRIPTION
Presentation to Compulsory Pooling Study Group of the North Caroling Mining & Energy Commission. January 11, 2013. Presentation by John HumphreyTRANSCRIPT
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Comp lsor Poolin &Compulsory Pooling & Landowner Protections
Presentation to Compulsory Pooling Study Groupof the North Caroling Mining & Energy Commission
McSwain Agriculture CenterMcSwain Agriculture CenterSanford, NC
January 11, 2013
John H mphreJohn Humphrey
The Humphrey Law Firm107 S. West St., PMB 325Alexandria VA 22314Alexandria, VA 22314
[email protected]‐599‐7919
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Unitization and pooling f l d i l
Cox Homestead Kelly Farm
of leased mineral estates
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Unitization and pooling f l d i l
Cox Homestead Kelly Farm
of leased mineral estates
Leased mineral estate Leased mineral estateLeased mineral estate Leased mineral estate
NC law authorizes the State to combine leased estates like the Cox homestead and Kelly
farm here into a single drilling unit ( ) ( )(G.S. § 113‐393) (1945).
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Unitization and pooling f l d i l
Cox Homestead Kelly Farm
of leased mineral estates
Leased mineral estate Leased mineral estateLeased mineral estate Leased mineral estate
NC law authorizes the State to compel leased mineral estates within a drilling unit into a
pool to share production and costs ( ) ( )(G.S. § 113‐393) (1945).
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Unitization and pooling f l d i l
Cox Homestead Kelly Farm
of leased mineral estates
Leased mineral estate Leased mineral estateLeased mineral estate Leased mineral estate
How drilling, production, and reclamation will proceed will be determined by the operator’s leases with the Cox family and with the Kelly
family, supplemented by State rules.5
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Unitization and pooling of leased with l d i l
Cox Homestead Kelly Farm
unleased mineral estates
Leased mineral estate Unleased mineral estateLeased mineral estate Unleased mineral estate
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Unitization and pooling of leased with l d i l
Cox Homestead Kelly Farm
unleased mineral estates
Leased mineral estate Unleased mineral estateLeased mineral estate Unleased mineral estate
NC law authorizes the State to combine leased estates like the Cox land and unleased estates like the Kelly farm into a single drilling unit
(G.S. § 113‐393) (1945).7
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Unitization and pooling of leased with l d i l
Cox Homestead Kelly Farm
unleased mineral estates
Leased mineral estate Unleased mineral estateLeased mineral estate Unleased mineral estate
NC law authorizes the State to compel leased mineral estates and unleased mineral estates into a pool to share production and costs
( ) ( )(G.S. § 113‐393) (1945).8
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State power to compel granting access
Leased Cox Unified Estate
Pooled Kelly Unified Estate
easements to gas operators
Unified Estate Unified Estate
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State power to compel granting access
Leased Cox Unified Estate
Pooled Kelly Unified Estate
easements to gas operators
Unified Estate Unified Estate
What are the effects on production of the pKellys’ gas resource if the State compels
pooling?p g
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State power to compel granting access
Leased Cox Unified Estate
Pooled Kelly Unified Estate
easements to gas operators
Unified Estate Unified Estate
In a “loose gas” formation, pooling would enable g p gthe Kellys’ gas to be produced from the Cox well without surface or subsurface access because
“loose gas” migrates.CH4CH4
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State power to compel granting access
Leased Cox Unified Estate
Pooled Kelly Unified Estate
easements to gas operators
Unified Estate Unified Estate
A “loose gas” formation is the circumstance gthat the 1945 NC Oil & Gas Conservation Act
contemplated.
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State power to compel granting access
Leased Cox Unified Estate
Pooled Kelly Unified Estate
easements to gas operators
Unified Estate Unified Estate
But NC’s Triassic Basin is a “tight gas” formation. g gGas, locked in the shale, is unlikely to migrate to a nearby well in significant quantities, if at all.
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State power to compel granting access
Leased Cox Unified Estate
Pooled Kelly Unified Estate
easements to gas operators
Unified Estate Unified Estate
“Tight gas” formations undercut the primary g g p yconsumer protection basis for pooling –preventing gas in an adjacent estate from p g g jbeing produced without compensation.
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State power to compel granting access
Leased Cox Unified Estate
Pooled Kelly Unified Estate
easements to gas operators
Unified Estate Unified Estate
However, the inability of tight gas to migrate y g g gstrengthens the economic rationale for pooling for operators and “orphaned” mineral rights p p g
owners who need a larger pool to recover costs.CH4CH4
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State power to compel granting access
Leased Cox Unified Estate
Pooled Kelly Unified Estate
easements to gas operators
Unified Estate Unified Estate
Which raises the question, if the State pools an q punleased property like the Kelly farm, can the State also compel the Kellys to grant surface p y g
and subsurface easements?CH4CH4
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State power to compel granting access
Leased Cox Unified Estate
Pooled Kelly Unified Estate
easements to gas operators
Unified Estate Unified Estate
Put differently, after the Kelly property is y y p p ypooled, what rights will the gas operator have on and under the Kelly family farm?
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State power to compel granting access
Leased Cox Unified Estate
Pooled Kelly Unified Estate No surface
easements to gas operators
Unified Estate Unified Estateaccess?
Will the State’s authority be limited to ycompelling the Kelly family into a pool with
the Cox family?
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No drilling or drill‐through access?
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State power to compel granting access
Leased Cox Unified Estate
Pooled Kelly Unified Estate Surface
easements to gas operators
Unified Estate Unified Estateaccess?
Or will the State have the authority to compel y pthe Kellys to grant the operator access to the surface and subsurface of the Kelly property?
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y p p y
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Subsurface drilling or drill‐through access?
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State power to compel granting access
Leased Cox Unified Estate
Pooled Kelly Unified Estate
easements to gas operators
Unified Estate Unified Estate
Whether or not operators are granted surface p gand subsurface access rights significantly
affects estate owners beyond whether estate yowners’ mineral resources are produced.
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State power to compel granting access
Leased Cox Unified Estate
Pooled Kelly Unified Estate
easements to gas operators
Unified Estate Unified Estate
Without surface and subsurface easements, “tight gas” cannot be produced via wells on adjacent properties, but many other impacts j p p y p
to adjacent land also are avoided.CH4CH4
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Rules governing development and d i f l
Leased Cox Unified Estate
Pooled Kelly Unified Estate
production of pools
Unified Estate Unified Estate
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Rules governing development and d i f l
Leased Cox Unified Estate
Pooled Kelly Unified Estate
production of pools
Unified Estate Unified Estate
Another significant issue affecting landowners g gis which rules govern drilling, production, and
reclamation on pooled properties.p p p
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Rules governing development and d i f l
Leased Cox Unified Estate
Pooled Kelly Unified Estate
production of pools
Unified Estate Unified Estate
In an example like the one above where the pCox family has a lease and the Kelly family does not, what rules govern how drilling, g g
production, and reclamation will proceed on the pooled Cox and Kelly family properties?p y y p p
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Rules governing development and d i f l
Leased Cox Unified Estate
Pooled Kelly Unified Estate
production of pools
Unified Estate Unified Estate
In this example, what rules govern how drilling, p g gproduction, and reclamation will proceed on the pooled Cox and Kelly family properties?
Cox Estate: Lease
p y y p p
and State rules 25
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Rules governing development and d i f l
Leased Cox Unified Estate
Pooled Kelly Unified Estate
production of pools
Unified Estate Unified Estate
In this example, what rules govern how drilling, p g gproduction, and reclamation will proceed on the pooled Cox and Kelly family properties?
Cox Estate: Lease Kelly Estate:
p y y p p
and State rules State rules only26
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How easements and governing rules affect l d
Leased Cox Unified Estate
Pooled Kelly Unified Estate
landowners
Unified Estate Unified Estate
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How easements and governing rules affect l d
Leased Cox Unified Estate
Pooled Kelly Unified Estate
landowners
Unified Estate Unified Estate
How surface and subsurface easements and how the source of rules governing gas
operations will affect landowners can be seen pby considering the lifecycle of a lease on the
pooled Cox and Kelly family properties.p y y p p
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How easements and governing rules affect l d
Leased Cox Unified Estate
Pooled Kelly Unified Estate
landowners
Unified Estate Unified Estate
Scene 1
After the pooling order is completed, a truck arrives with a crew ready to begin surveyingarrives with a crew ready to begin surveying
and conducting seismic tests.
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How easements and governing rules affect l d
Leased Cox Unified Estate
Pooled Kelly Unified Estate
landowners
Unified Estate Unified Estate
1. Operator survey and seismic test
Cox Lease‐ Notice: Notice prior to testing
Current State rules‐ No notice
to enable landowner to secure fenced or gated areas or move equipment or activities
‐ No limitations on testing
‐ Testing Limits: Types, timing, and manner of testing limited
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Rules governing development and d i f l
Leased Cox Unified Estate
Pooled Kelly Unified Estate
production of pools
Unified Estate Unified Estate
1. Operator survey and seismic test (cont.)
Cox Lease‐ Vegetation:Minimize
Current State rules‐ No limitations on vegetation
vegetation impacts, prior written approval to destroy vegetation, pay fair market l f d l
impacts, damages negotiated after fact or determined in court
value for damages, set valuation method
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Rules governing development and d i f l
Leased Cox Unified Estate
Pooled Kelly Unified Estate
production of pools
Unified Estate Unified Estate
1. Operator survey and seismic test (cont.)
Cox Lease‐ Structures: No impacts (gates,
Current State rules‐ Damages to structures
fences, buildings) without prior written approval & agreement on compensation
negotiated after fact or determined in court
‐ No limits on off‐road access, ‐ Roads: Use existing access roads
except by written approval, remediate grass and turf
damages negotiated after fact or determined in court
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Rules governing development and d i f l
Leased Cox Unified Estate
Pooled Kelly Unified Estate
production of pools
Unified Estate Unified Estate
1. Operator survey and seismic test (cont.)
Cox Lease‐ Holes drilled to be smallest bore
Current State rules‐ Note limits on bore holes or
possible, plugged & remediated
‐ Minimum buffer established for testing activities from
remediation mandated
‐ No buffer between testing and existing infrastructure,
structures, water sources, underground pipes, livestock
water sources, or livestock
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Rules governing development and d i f l
Leased Cox Unified Estate
Pooled Kelly Unified Estate
production of pools
Unified Estate Unified Estate
1. Operator survey and seismic test (cont.)
Cox Lease‐ Sounds and vibrations from
Current State rules‐ No limits on sound and
seismic work to be muffled to protect occupants and livestock
‐ Remediation: Operator agrees
vibrations
‐ No remediation required from testing activities
to return property to original condition within set time
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Rules governing development and d i f l
Leased Cox Unified Estate
Pooled Kelly Unified Estate
production of pools
Unified Estate Unified Estate
1. Operator survey and seismic test (cont.)
Cox Lease‐ Liability: Operator strictly liable
Current State rules‐ No shifting of risk to operator
and agrees to indemnify landowner against any claims or regulatory enforcement actions
‐ No dispute resolution methods agreed to
‐ Dispute resolutionmethods agreed to
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Rules governing development and d i f l
Leased Cox Unified Estate
Pooled Kelly Unified Estate
production of pools
Unified Estate Unified Estate
1. Operator survey and seismic test (cont.)
Cox Lease‐ Insurance: Operator to maintain
Current State rules‐ Minimal if any insurance
prescribed amount of worker’s comp, employer’s liability, comprehensive general liability, d b d h l
liability required for survey and seismic testing activities
and business auto and vehicle liability insurance
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Rules governing development and d i f l
Leased Cox Unified Estate
Pooled Kelly Unified Estate
production of pools
Unified Estate Unified Estate
Scene 2:
Environmental consultant arrives to begin gathering of baseline datagathering of baseline data
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Rules governing development and d i f l
Leased Cox Unified Estate
Pooled Kelly Unified Estate
production of pools
Unified Estate Unified Estate
2. Baseline data collection and environmental monitoring
Cox Lease‐ Requires specific schedule,
Current State rules‐ Baseline testing and monitoring
required but standards notlocations, and disclosure of monitoring groundwater, surface water, soil, and air
required but standards not established and may be less rigorous that what landowner would negotiate [§2(c)]
‐ Original survey documents to be provided to landowner
‐ No requirements to provide survey documents
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Rules governing development and d i f l
Leased Cox Unified Estate
Pooled Kelly Unified Estate
production of pools
Unified Estate Unified Estate
3. Surface Use Agreement Standards – Construction PhaseScene 3:
Sanford Herald has article about operator transferring some leases. Inquiries totransferring some leases. Inquiries to
operator yield no reply until letter from new company arrives.company arrives.
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Rules governing development and d i f l
Leased Cox Unified Estate
Pooled Kelly Unified Estate
production of pools
Unified Estate Unified Estate
3. Limits on transfer of lease
Cox Lease‐ Advance notice to mineral rights
Current State rules‐ Notice of lease assignment
owner of lease transfer or written consent of mineral rights owner prior to transfer
required within 30 days [§4(d)]
‐ No restrictions on lease transfer
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Rules governing development and d i f l
Leased Cox Unified Estate
Pooled Kelly Unified Estate
production of pools
Unified Estate Unified Estate
3. Surface Use Agreement Standards – Construction PhaseScene 4:
Three years pass.
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Rules governing development and d i f l
Leased Cox Unified Estate
Pooled Kelly Unified Estate
production of pools
Unified Estate Unified Estate
4. Renewal Terms
Cox Lease‐ 3‐year lease not renewed unless
Current State rules‐ 10‐year lease term
“drilling operations” have commenced. If no operations, can negotiate new lease.
‐ No standard of “bit in ground” or “strata reached” provisions to trigger lease renewalForce majeure clause‐ No force majeure clause
renewal at 3 years
‐ Force majeure clause operational for ten years [§4(d)]
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Rules governing development and d i f l
Leased Cox Unified Estate
Pooled Kelly Unified Estate
production of pools
Unified Estate Unified Estate
3. Surface Use Agreement Standards – Construction PhaseScene 5:
3 years pass. Drilling finally begins.
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Rules governing development and d i f l
Leased Cox Unified Estate
Pooled Kelly Unified Estate
production of pools
Unified Estate Unified Estate
5. Surface Use Agreement Standards – Construction Phase
Cox Lease‐ Written construction land‐use plan
Current State rules‐ No timeline or written plan for
t ti id dcontaining setbacks from buildings and water agreed to and provided to landowner
construction provided‐ No agreement on mitigation of
light and noise from construction phase
‐ Lights and noise impacts minimized
‐ Right of inspection of construction
construction phase‐ No right of inspection
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Rules governing development and d i f l
Leased Cox Unified Estate
Pooled Kelly Unified Estate
production of pools
Unified Estate Unified Estate
5. Surface Use Agreement Standards – Construction Phase (cont.)
Cox Lease‐ Operator pays fair market value
Current State rules‐ No compensation schedule or
l ti th d f dfor all timber, crops, and structures (including fences and gates) removed or damaged
valuation method for damage established
‐ No temporary fencing set up No erosion control measures‐ Temporary fencing , drainage
and erosion control measures agreed to and established
‐ No erosion control measures agreed to
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Rules governing development and d i f l
Leased Cox Unified Estate
Pooled Kelly Unified Estate
production of pools
Unified Estate Unified Estate
3. Surface Use Agreement Standards – Construction Phase5. Surface Use Agreement Standards – Construction Phase (cont.)
Cox Lease‐ Soil quality maintained through
Current State rules‐ No provisions for soil quality
double ditching to separate top soil and subsoil
‐ Soil compaction avoided
protection or avoiding soil compaction made
‐ Rocks removed from surface where unearthed
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Rules governing development and d i f l
Leased Cox Unified Estate
Pooled Kelly Unified Estate
production of pools
Unified Estate Unified Estate
5. Surface Use Agreement Standards – Construction Phase (cont.)
Cox Lease‐ Lease must specify allowable
Current State rules‐ Lease must specify allowable
water use, not conflict with landowner water usage, and provide for fair market value for
[ (d)]
water use, not conflict with landowner water usage, and provide for fair market value f [ (d)]water [§4(d)] for water [§4(d)]
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Rules governing development and d i f l
Leased Cox Unified Estate
Pooled Kelly Unified Estate
production of pools
Unified Estate Unified Estate
3. Surface Use Agreement Standards – Construction Phase5. Surface Use Agreement Standards – Construction Phase (cont.)
Cox Lease‐ Plans, timeline, and payment
Current State rules‐ No provisions for additional
schedule for infrastructure development beyond well
‐ Specific easements for
infrastructure development
‐ No limits on infrastructure development rights arising
appurtenant infrastructure granted with geographic, height, and depth limits
from pooling rights
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Rules governing development and d i f l
Leased Cox Unified Estate
Pooled Kelly Unified Estate
production of pools
Unified Estate Unified Estate
3. Surface Use Agreement Standards – Construction Phase5. Surface Use Agreement Standards – Construction Phase (cont.)
Cox Lease‐ Production phase land‐use plan
Current State rules‐ No written production phase
l d l dagreed to in writing
‐ Reclamation plan agreed to in writing
land‐use plan prepared‐ No written reclamation plan
agreed toNo drilling and construction
‐ Drilling and construction phase damages valued and paid
‐ No drilling and construction damages measured and paid
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Rules governing development and d i f l
Leased Cox Unified Estate
Pooled Kelly Unified Estate
production of pools
Unified Estate Unified Estate
3. Surface Use Agreement Standards – Construction PhaseScene 6:
Check arrives in the mail from operator.
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Rules governing development and d i f l
Leased Cox Unified Estate
Pooled Kelly Unified Estate
production of pools
Unified Estate Unified Estate
3. Surface Use Agreement Standards – Construction Phase6. Receive a royalty check – is it for the right amount?
Cox Lease‐ After bonus check for acreage,
Current State rules‐ No bonus payment ever
monthly royalty payments above statutory minimum once production starts
received
‐ 12.5% statutory minimum royalty received
‐ Royalties paid without deductions on greater of market value or gross proceeds 51
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Rules governing development and d i f l
Leased Cox Unified Estate
Pooled Kelly Unified Estate
production of pools
Unified Estate Unified Estate
3. Surface Use Agreement Standards – Construction Phase6. Receive a royalty check – is it for the right amount? (cont.)
Cox Lease‐ Royalty statement includes lessor
Current State rules‐ No details required on
name; lessor’s ID #; lease #; well and property name; API #; month and year of sale; oil, gas, and NGL l b l
payments
volumes; price per barrel or MMBtu; taxes; lessor’s interest, share of sale, deductions & codes 52
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Rules governing development and d i f l
Leased Cox Unified Estate
Pooled Kelly Unified Estate
production of pools
Unified Estate Unified Estate
3. Surface Use Agreement Standards – Construction Phase6. Receive a royalty check – is it for the right amount? (cont.)
Cox Lease‐ Right of royalty audit can be
Current State rules‐ No royalty payment audit rights
exercised
‐ Rents paid for use of lands
‐ Lease terms supercede any
‐ No rental payments for surface use of land
p yDivision Order language
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Rules governing development and d i f l
Leased Cox Unified Estate
Pooled Kelly Unified Estate
production of pools
Unified Estate Unified Estate
3. Surface Use Agreement Standards – Construction PhaseScene 7:
Cox Lease Current State rulesStranger drops in for coffee. Tenders offer for gas and hunting lease above undevelopedgas and hunting lease above undeveloped
portion of mineral estate.
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Rules governing development and d i f l
Leased Cox Unified Estate
Pooled Kelly Unified Estate
production of pools
Unified Estate Unified Estate
7. Who can lease out undeveloped portions of land?
Cox Lease‐ Horizontal and vertical Pugh
Current State rules‐ No division of property
clauses limited depth and range of minerals leased originally
‐ Retained acreage and depth
allowing leasing of unused portion of land.
clause frees from lease areas and zones leased but not developed 55
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Rules governing development and d i f l
Leased Cox Unified Estate
Pooled Kelly Unified Estate
production of pools
Unified Estate Unified Estate
7. Who can lease out undeveloped portions of land? (cont.)
Cox Lease‐ Specific contract terms retaining
Current State rules‐ No specific terms governing
right of alternate uses for timber, crops, and hunting and preserving acreage for these
alternate uses or payment for loss of alternate uses.
purposes.
‐ Hunting rights near wellheads leased to operator. 56
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Rules governing development and d i f l
Leased Cox Unified Estate
Pooled Kelly Unified Estate
production of pools
Unified Estate Unified Estate
7. Who can lease out undeveloped portions of land? (cont.)
Cox Lease‐ Mineral estate leased limited
Current State rules‐ No limits on mineral types
specifically to oil, gas, and natural gas liquids
pooled specifically identified
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Rules governing development and d i f l
Leased Cox Unified Estate
Pooled Kelly Unified Estate
production of pools
Unified Estate Unified Estate
Scene 8:Scene 8:
Is there supposed to be a pool of oil there?
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Rules governing development and d i f l
Leased Cox Unified Estate
Pooled Kelly Unified Estate
production of pools
Unified Estate Unified Estate
8. Responding to accidents
Cox Lease‐ Operator must indemnify surface
Current State rules‐ Operator must indemnify
owner against any claims related to operator’s activities on property [§4(c)]
surface owner against any claims related to operator’s activities on property [§4(c)]
‐ Adequate operator bonding, capitalization, and insurance requirements 59
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Rules governing development and d i f l
Leased Cox Unified Estate
Pooled Kelly Unified Estate
production of pools
Unified Estate Unified Estate
8. Responding to accidents (cont.)
Cox Lease‐ Operator must have and inform
Current State rules‐ Operator must indemnify
f i tsurface owner of emergency response operation plans and disclose details of all accidents
surface owner against any claims related to operator’s activities on property [§4(c)]
‐ Disclosure of hazardous‐ Disclosure of hazardous chemicals
used on or injected into land
Disclosure of hazardous materials to emergency responders and regulators
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Rules governing development and d i f l
Leased Cox Unified Estate
Pooled Kelly Unified Estate
production of pools
Unified Estate Unified Estate
Scene 9:Scene 9:
Honey, they’re just not listening to what I’m sayingsaying.
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Rules governing development and d i f l
Leased Cox Unified Estate
Pooled Kelly Unified Estate
production of pools
Unified Estate Unified Estate
9. Dispute resolution process agreed upon
Cox Lease‐ Operator agrees in writing to best
Current State rules‐ No dispute resolution
efforts to resolve dispute, mediation, then court proceedings in county in which well located
procedures identified
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Rules governing development and d i f l
Leased Cox Unified Estate
Pooled Kelly Unified Estate
production of pools
Unified Estate Unified Estate
Scene 10:Scene 10:
Then one day, the pump stopped.
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Rules governing development and d i f l
Leased Cox Unified Estate
Pooled Kelly Unified Estate
production of pools
Unified Estate Unified Estate
10. Payments and renewals when operations are suspended
Cox Lease‐ Habendum (continuous
Current State rules‐ No lease provision protecting
operations) clause releases mineral estate when production stops.
shutting‐in of production
‐ If well shut‐in or flow reduced temporarily, shut‐in royalties paid.
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Rules governing development and d i f l
Leased Cox Unified Estate
Pooled Kelly Unified Estate
production of pools
Unified Estate Unified Estate
Scene 11:Scene 11:
When you were a little girl . . . .
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Rules governing development and d i f l
Leased Cox Unified Estate
Pooled Kelly Unified Estate
production of pools
Unified Estate Unified Estate
11. Reclaiming and restoring land
Cox Lease‐ Detailed written reclamation and
Current State rules‐ No reclamation plan
monitoring plan
‐ Warranty of adequate operator capitalization and operator
‐ Requirement that operator provide financial assurance of well closure, reclamation,
bonding to cover reclamation and ongoing monitoring
ongoing monitoring [§2(c)]
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Protecting Landowners in the Law
Leased Cox Unified Estate
Pooled Kelly Unified Estate
Protecting Landowners in the Law
Unified Estate Unified Estate
Conclusions
.‐ Under current NC law, landowners compelled into a pool have
significantly fewer opportunities to protect themselves than those who negotiate their leasesthose who negotiate their leases.
‐ Compelling the granting of surface and subsurface easements affects a wider range of landowner rights than compulsory pooling alone.
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Protecting Landowners in the Law
Leased Cox Unified Estate
Pooled Kelly Unified Estate
Protecting Landowners in the Law
Unified Estate Unified Estate
Conclusions
.‐ If a compulsory pooling rule that compels granting surface or
subsurface easements is implemented, the State should integrate into pooling orders the full array of measuresintegrate into pooling orders the full array of measures generally available in oil and gas leases to protect owners of any pooled mineral estate or appurtenant surface estate, h th ifi d dwhether unified or severed.
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Cox Homestead Kelly Farm
Compulsory Pooling & Landowner Protectionsp y g
Presentation to Compulsory Pooling Study Groupof the North Caroling Mining & Energy Commission
McSwain Agriculture CenterSanford, NCJanuary 11, 2013
John Humphrey
The Humphrey Law Firm107 S. West St., PMB 325Alexandria VA 22314
69
Alexandria, VA [email protected]‐599‐7919