filed - fs.ogm.utah.gov · filed feb 2 \ 2020 seoretary boafd of oil, gas & mining before the...

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FILED FEB 2 \ 2020 SEoRETARY BOAFD OF OIL, GAS & MINING BEFORE THE BOARD OF OIL, GAS AND MINING DEPARTMENT OF NATURAL RESOURCES STATE OF UTAH IN THE MATTER OF THE REQUEST FOR AGENCY ACTION OF CH4 ENERGY- FINLEY UTAH, LLC FOR AN ORDER: (I) AMENDING THE BOARD'S ORDER IN DOCKET NO. 2015-0200 CAUSE NO. 139-134 AND (II) AMENDING THE BOARDOS ORDER IN DOCKET NO. 2OI8-020, CAUSE NO. 139. 158 WITH RESPECT TO: (1) VERTICAL/DIRECTIONAL WELL DENSITY AND (2) NORTH-SOUTH DRTLLTNG UNrT BOUNDARY PRODUCING INTERVAL SETBACKS, FOR THE PRODUCTION OF OIL, GAS AND ASSOCIATED HYDROCARBONS FROM THE LOWER GREEN RIVER AND GREEN RIVER- WASATCH FORMATIONS IN PORTIONS OF SECTIONS 13-t6, 2t-27 AND 34-36, TOWNSHIP 3 SOUTH, RANGE I WEST, U.S.M., IN DUCHESNE AND UINTAH CO UTAH COMES NOW, CH4 Energy-Finley Utah, LLC ("eFl4lFidey"), by and through its attomeys Steptoe & Johnson PLLC, and pursuant to Utah Admin. Code Rule R641-105-300, hereby files its Response to: (i) Motion for Leave to File Out of Time the Division of Oil, Gas and Mining ("Division") Memorandum and Exhibit dated February 20,2020 ("Motion") and (ii) the Division of Oil, Gas and Mining's Technical Memorandum dated February 20, 2020 ("Memorandum"), with the State of Utah Board of Oil, Gas and Mining ("Board"). RESPONSE TO: (I) MOTION FOR LEAVE TO FILE OUT OF TIME THE DIVISION OF OIL, GAS AND MINING MEMORANDUM AND EXHIBIT AND (II) THE DIVISION OF OIL, GAS AND MINING'S TECHNICAL MEMORANDUM Docket No. 2020-002 Cause No. 600-01

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Page 1: FILED - fs.ogm.utah.gov · filed feb 2 \ 2020 seoretary boafd of oil, gas & mining before the board of oil, gas and mining department of natural resources state of utah in the matter

FILEDFEB 2 \ 2020

SEoRETARY BOAFD 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 CH4 ENERGY-FINLEY UTAH, LLC FOR AN ORDER: (I)AMENDING THE BOARD'S ORDER INDOCKET NO. 2015-0200 CAUSE NO. 139-134AND (II) AMENDING THE BOARDOS ORDERIN DOCKET NO. 2OI8-020, CAUSE NO. 139.158 WITH RESPECT TO: (1)VERTICAL/DIRECTIONAL WELL DENSITYAND (2) NORTH-SOUTH DRTLLTNG UNrTBOUNDARY PRODUCING INTERVALSETBACKS, FOR THE PRODUCTION OFOIL, GAS AND ASSOCIATEDHYDROCARBONS FROM THE LOWERGREEN RIVER AND GREEN RIVER-WASATCH FORMATIONS IN PORTIONS OFSECTIONS 13-t6, 2t-27 AND 34-36,TOWNSHIP 3 SOUTH, RANGE I WEST,U.S.M., IN DUCHESNE AND UINTAHCO UTAH

COMES NOW, CH4 Energy-Finley Utah, LLC ("eFl4lFidey"), by and through its

attomeys Steptoe & Johnson PLLC, and pursuant to Utah Admin. Code Rule R641-105-300,

hereby files its Response to: (i) Motion for Leave to File Out of Time the Division of Oil, Gas

and Mining ("Division") Memorandum and Exhibit dated February 20,2020 ("Motion") and (ii)

the Division of Oil, Gas and Mining's Technical Memorandum dated February 20, 2020

("Memorandum"), with the State of Utah Board of Oil, Gas and Mining ("Board").

RESPONSE TO: (I) MOTION FORLEAVE TO FILE OUT OF TIME THE

DIVISION OF OIL, GAS ANDMINING MEMORANDUM AND

EXHIBIT AND (II) THE DIVISIONOF OIL, GAS AND MINING'S

TECHNICAL MEMORANDUM

Docket No. 2020-002

Cause No. 600-01

Page 2: FILED - fs.ogm.utah.gov · filed feb 2 \ 2020 seoretary boafd of oil, gas & mining before the board of oil, gas and mining department of natural resources state of utah in the matter

2

The Division’s Motion and Memorandum were filed in response to CH4/Finley’s: (i)

Request for Agency Action dated January 10, 2020 (“RAA”) and (ii) the Exhibits dated January

27, 2020 (collectively, “Exhibits”) filed in the above-captioned matter by CH4/Finley.

RESPONSE TO MOTION

CH4/Finley does not oppose the relief sought in the Division’s Motion, and the Proposed

Order field therewith, with respect to the Board’s granting of leave for the Division to file its

Memorandum out of time.

RESPONSE TO MEMORANDUM

Based upon CH4/Finley’s review of the Memorandum, and its communications with the

Division regarding the same, CH4/Finley continues to believe that the relief sought in its RAA is

just and reasonable, will prevent waste, and will protect correlative rights. Specifically, CH/4-

Finley believes that the testimony of its land, geology and engineering professionals at the

pending February 26, 20202 Board hearing, in conjunction with the amended exhibits attached

hereto, incorporated herein and filed herewith as Exhibit “A” (collectively, “Amended

Exhibits”) will provide the Division and Board with satisfactory support for relief sought in the

RAA.

To the extent the same is required pursuant to Utah Admin. Code Rule R641-105-500,

CH/4-Finley hereby requests that the Board accept CH4/Finley’s filing of its Amended Exhibits

in support of the relief sought in the RAA.

WHEREFORE, based on the foregoing, CH4/Finley respectfully requests that:

I. The Board execute the Division’s Proposed Order associated with its Motion,

granting leave to file the Memorandum out of time;

Page 3: FILED - fs.ogm.utah.gov · filed feb 2 \ 2020 seoretary boafd of oil, gas & mining before the board of oil, gas and mining department of natural resources state of utah in the matter
Page 4: FILED - fs.ogm.utah.gov · filed feb 2 \ 2020 seoretary boafd of oil, gas & mining before the board of oil, gas and mining department of natural resources state of utah in the matter

EXHIBIT “A”

Page 5: FILED - fs.ogm.utah.gov · filed feb 2 \ 2020 seoretary boafd of oil, gas & mining before the board of oil, gas and mining department of natural resources state of utah in the matter

Amended Exhibits

Proposed Amendment to the Board’s Orders in Docket No. 2015-020, Cause 139-134

&Docket No. 2018-020, Cause 139-158

State of UtahDivision of Oil, Gas & Mining

Board Hearing—February 26, 2020

Docket No. 2020-002Cause No. 600-01

1

Page 6: FILED - fs.ogm.utah.gov · filed feb 2 \ 2020 seoretary boafd of oil, gas & mining before the board of oil, gas and mining department of natural resources state of utah in the matter

Table of ContentsLand Exhibits

◦ Exhibit L-1 Regional Locator Map ◦ Exhibit L-2 Regional Locator Map with Application Area Outline◦ Exhibit L-3 Close up of Proposed Spacing Area with Existing Wells◦ Exhibit L-4 Notice Outline and ¼ Mile Buffer◦ Exhibit L-5 Mineral Ownership and Working Interest◦ Exhibit L-6 Common Spacing in Other Basins

Geology & Engineering Exhibits◦ Exhibit G&E-1 Application Area with Existing Wells◦ Exhibit G&E-2 Geologic Cross Section with Locator Map◦ Exhibit G&E-3 Micro Seismic Data Wells Within Application Area◦ Exhibit G&E-4 Micro Seismic Data – Example of Data Used in Application

Area◦ Exhibit G&E-5 Micro Seismic Data – Data Showing Stimulated Volume◦ Exhibit G&E-6 Core Data Wells with Horizontal Target Permeability Data◦ Exhibit G&E-7 Current Heel/Toe Setback Diagram◦ Exhibit G&E-8 New Heel/Toe Setback Diagram◦ Exhibit G&E-9 New Heel/Toe Setback Diagram Illustrating Double Fracture

Half-Length◦ Exhibit G&E-10 Original Oil in Place

2

Page 7: FILED - fs.ogm.utah.gov · filed feb 2 \ 2020 seoretary boafd of oil, gas & mining before the board of oil, gas and mining department of natural resources state of utah in the matter

Table of ContentsGeology & Engineering Exhibits

◦ Exhibit G&E-11 Volumetrics – Drainage (Map View) Real Data◦ Exhibit G&E-12 Volumetrics – Ellipse Dimensions Real Data◦ Exhibit G&E-13 Volumetrics – Drainage (Map View) Theoretical Double

Fracture Half-Length◦ Exhibit G&E-14 Volumetrics – Ellipse Dimensions for Theoretical Double

Fracture Half-Length◦ Exhibit G&E-15 Project Economics◦ Exhibit G&E-16 Development Model◦ Exhibit G&E-17 Green River Reservoir Geometries – 80 Acre Drill Pattern

Example◦ Exhibit G&E-18 Green River Reservoir Geometries – 2 Wells per 80 Acre Drill

Pattern Example◦ Exhibit G&E-19 80 Acre Vertical Development◦ Exhibit G&E-20 2 Wells Per 80 Acre Vertical Development

Witness Resumes◦ Exhibit R-1 Resume of Deidre Stoley◦ Exhibit R-2 Resume of Shea Atkins◦ Exhibit R-3 Resume of Patrick L. Porter

3

Page 8: FILED - fs.ogm.utah.gov · filed feb 2 \ 2020 seoretary boafd of oil, gas & mining before the board of oil, gas and mining department of natural resources state of utah in the matter

Land ExhibitsState of Utah

Division of Oil, Gas & Mining

Board Hearing—February 26, 2020

Docket No. 2020-002Cause No. 600-01

4

Page 9: FILED - fs.ogm.utah.gov · filed feb 2 \ 2020 seoretary boafd of oil, gas & mining before the board of oil, gas and mining department of natural resources state of utah in the matter

Regional Locator Map

5

Duchesne Uintah

CarbonRocky Point

Exhibit L-1

Page 10: FILED - fs.ogm.utah.gov · filed feb 2 \ 2020 seoretary boafd of oil, gas & mining before the board of oil, gas and mining department of natural resources state of utah in the matter

Rocky Point Locator Map

6

Rocky Point

APPLICATION LANDS

LEGEND

Scale = 6 miles

N

Exhibit L-2

Page 11: FILED - fs.ogm.utah.gov · filed feb 2 \ 2020 seoretary boafd of oil, gas & mining before the board of oil, gas and mining department of natural resources state of utah in the matter

Proposed Spacing AreaTo effectively produce the available oil in place in the Rocky Point area, horizontal drilling with 100 foot setbacks at the heel and toe sections of the well are requested along with increased vertical drilling density to 2 wells per 80 acre unit

7

Scale = 1 mile

NAPPLICATION LANDS

LEGEND

Exhibit L-3

Page 12: FILED - fs.ogm.utah.gov · filed feb 2 \ 2020 seoretary boafd of oil, gas & mining before the board of oil, gas and mining department of natural resources state of utah in the matter

Notification Area

8

N

Scale = 1 mile

APPLICATION LANDS

LEGEND

NOTIFICATION BUFFER

Exhibit L-4

Page 13: FILED - fs.ogm.utah.gov · filed feb 2 \ 2020 seoretary boafd of oil, gas & mining before the board of oil, gas and mining department of natural resources state of utah in the matter

Mineral Ownership & CH4-Finley Working Interest

9

Exhibit L-5

Page 14: FILED - fs.ogm.utah.gov · filed feb 2 \ 2020 seoretary boafd of oil, gas & mining before the board of oil, gas and mining department of natural resources state of utah in the matter

Common Spacing in Other BasinsLand Exhibits

◦ North Dakota Oil and Gas Division Case No. 25305, McKenzie County, ND, Bakken Formation50 ft. heel and toe

◦ New Mexico Oil and Gas Conservation Commission Case No.16376, New Mexico, Statewide All Formations100 ft. heel and toe

◦ RRC of Texas Docket No. 06-0220580, Houston County, TX, Buda Formation 100 ft. heel and toe

◦ RRC of Texas Docket No. 08-0310856, Culberson/Loving/Reeves/Ward/Winkler Counties, TX, Wolfcamp Formation100 ft. heel and toe

◦ RRC of Texas Docket No. 02-0297714, Dewitt, Karnes, Lavaca, Live Oak, and Bee Counties, TX, Eagleford Formation 100 ft. heel and toe

◦ RRC of Texas Docket No. 05-0277710, Leon County, TX, Eagleford Formation 100 ft. heel and toe

◦ RRC of Texas Docket No. 02-0297183, Atascosa, Bee, Dewitt, Live Oak, and Karnes Counties, TX, Austin Chalk Formation 100 ft. heel and toe

◦ RRC of Texas Docket No. 7C-0297471, Multiple fields across RRC districts 7C & 8, Spraberry Formation 100 ft. heel and toe

◦ Ohio Oil and Gas Commission Case No. 1501:9-1-04, Statewide All Formations 150 feet heel and toe

10

Exhibit L-6

Page 15: FILED - fs.ogm.utah.gov · filed feb 2 \ 2020 seoretary boafd of oil, gas & mining before the board of oil, gas and mining department of natural resources state of utah in the matter

Geology & Engineering ExhibitsState of Utah

Division of Oil, Gas & Mining

Board Hearing—February 26, 2020

Docket No. 2020-002Cause No. 600-01

11

Page 16: FILED - fs.ogm.utah.gov · filed feb 2 \ 2020 seoretary boafd of oil, gas & mining before the board of oil, gas and mining department of natural resources state of utah in the matter

Existing Wells

12

Scale = 1 mile

N

SHORT LATERAL HORIZONTAL (7)

VERTICAL PRODUCING WELL (3)

LONG LATERAL HORIZONTAL (17)

LEGEND

APPLICATION LANDS

The application area consists of 27 existing wells that are currently producing. Of these, 3 are vertical wells, 7 are short lateral horizontal wells, and 17 are long lateral horizontal wells.

Exhibit G&E-1

Page 17: FILED - fs.ogm.utah.gov · filed feb 2 \ 2020 seoretary boafd of oil, gas & mining before the board of oil, gas and mining department of natural resources state of utah in the matter

Cross Section W-E

13

CROSS SECTION LINE

APPLICATION LANDSLEGEND

Scale = 1 mile

W

E

N

Exhibit G&E-2

Garden Gulch

Douglas Creek

Black ShaleCastle Peak

Uteland Butte

WasatchLo

wer

Gre

en R

iver

Was

atch

W E

UG

R

34

00

Hz

Dev

elo

pm

ent

Ver

tica

l Dev

elo

pm

ent

GAMMA RES.

Page 18: FILED - fs.ogm.utah.gov · filed feb 2 \ 2020 seoretary boafd of oil, gas & mining before the board of oil, gas and mining department of natural resources state of utah in the matter

Micro-Seismic Wells

14

Project 1 Project 2 Project 3 AverageFracture Azimuth N81W N90W N83W N85W

Fracture Half Length 199 343 215 252

MICRO-SEISMIC WELL

APPLICATION LANDSLEGEND

Scale = 1 mile

N

CH4-Finley has obtained actual down hole fracture data (micro-seismic) from 3 horizontal wells inside the application lands that support the reduction of setbacks at the heel and toe interval of horizontal wells. These data points show an average fracture half length of 252 feet in the N85W orientation.

Exhibit G&E-3

Page 19: FILED - fs.ogm.utah.gov · filed feb 2 \ 2020 seoretary boafd of oil, gas & mining before the board of oil, gas and mining department of natural resources state of utah in the matter

Micro-Seismic Wells

15

MICRO-SEISMIC WELL

APPLICATION LANDSLEGEND

Scale = 1 mile

N

Shown is an example of micro-seismic data from a horizontal well in the application area with a vertical and horizontal listening well to increase accuracy. The full fracture azimuth is N88W.

Exhibit G&E-4

Page 20: FILED - fs.ogm.utah.gov · filed feb 2 \ 2020 seoretary boafd of oil, gas & mining before the board of oil, gas and mining department of natural resources state of utah in the matter

Micro-Seismic Wells

16

MICRO-SEISMIC WELL

APPLICATION LANDSLEGEND

Scale = 1 mile

N

Shown is the micro-seismic data from the previous slide but broken into the events observed during pad, proppant, and post proppant portion of the job. The initial proppant free events represent the primary extent of the stimulated volume while the proppant portion of the job is focused on enhancing the near well bore complexity to enhance drainage of that area.

Exhibit G&E-5

Page 21: FILED - fs.ogm.utah.gov · filed feb 2 \ 2020 seoretary boafd of oil, gas & mining before the board of oil, gas and mining department of natural resources state of utah in the matter

Core Data Wells

17

CORE DATA WELL

APPLICATION LANDSLEGEND

Shown is an example of core data through the three primary horizontal target intervals in the immediate vicinity of the application area. As shown the rock has a significantly low natural permeability. Due to the extremely low permeability consistent with source rock quality, CH4-Finley believes that the only rock effectively drained is that of which is connected through hydraulic fracturing to enhance permeability of existing porosity.

Exhibit G&E-6

Scale = 1 mile

N

Well Formation Depth Permeability (md)

Cox 13-31-3-1E Castle Peak 7445 0.0004

Cox 13-31-3-1E Castle Peak 7453 0.0005

Cox 13-31-3-1E Castle Peak 7463 0.001

Cox 13-31-3-1E Castle Peak 7483.15 0.0002

Cox 13-31-3-1E Castle Peak 7487.05 0.0002

Cox 13-31-3-1E Castle Peak 7495 0.0003

Cox 13-31-3-1E Castle Peak 7499 0.002

Cox 13-31-3-1E Castle Peak 7563 0.0001

Cox 13-31-3-1E Castle Peak 7580.9 0.001

Cox 13-31-3-1E Castle Peak 7616.9 0.0003

Ute 2-23-3-1W Uteland Butte 8578.05 0.001

Ute 2-23-3-1W Uteland Butte 8584 0.0002

Ute 2-23-3-1W Uteland Butte 8587 0.009

Ute 2-23-3-1W Uteland Butte 8589.05 0.0002

Ute 2-23-3-1W Uteland Butte 8593 0.005

Ute 2-23-3-1W Uteland Butte 8603 0.0002

Ute 2-23-3-1W Uteland Butte 8629 0.001

Ute 2-23-3-1W Uteland Butte 8636 0.014

Ute 2-23-3-1W Uteland Butte 8640.05 0.0002

Ute 2-23-3-1W Uteland Butte 8666.95 0.001

Cox 13-31-3-1E Wasatch 7924 0.0002

Cox 13-31-3-1E Wasatch 7934.05 0.0002

Cox 13-31-3-1E Wasatch 7958 0.001

Cox 13-31-3-1E Wasatch 7966 0.003

Cox 13-31-3-1E Wasatch 7968 0.003

Cox 13-31-3-1E Wasatch 7997 0.0004

Cox 13-31-3-1E Wasatch 8006 0.004

Cox 13-31-3-1E Wasatch 8042 0.001

Cox 13-31-3-1E Wasatch 8051.95 0.004

Cox 13-31-3-1E Wasatch 8056 0.003

Page 22: FILED - fs.ogm.utah.gov · filed feb 2 \ 2020 seoretary boafd of oil, gas & mining before the board of oil, gas and mining department of natural resources state of utah in the matter

Current Spacing

18

330’

85°252’

Avg FractureOrientation

N85W

Toe Interval of HZWellbore

Wellbore

308’UnrecoveredHydrocarbon

Utilizing the micro-seismic data from 3 existing horizontal wells inside the application area shows that there is considerable waste of bypassed hydrocarbons at the existing 330 foot heel/toe setback.

Exhibit G&E-7

Page 23: FILED - fs.ogm.utah.gov · filed feb 2 \ 2020 seoretary boafd of oil, gas & mining before the board of oil, gas and mining department of natural resources state of utah in the matter

Micro-Seismic Wells

19

100’

85°252’

Avg FractureOrientation

N85W

Toe Interval of HZWellbore

Wellbore

78’

85° 252’22’

251’

Vertical Exaggeration for Illustration

Utilizing the micro-seismic data from 3 existing horizontal wells inside the application area, it is proven that an average fracture half length of 252 feet at the azimuth of N85W will reduce the amount of unrecoverable hydrocarbons while also protecting correlative rights in the adjacent lands.

Exhibit G&E-8

Page 24: FILED - fs.ogm.utah.gov · filed feb 2 \ 2020 seoretary boafd of oil, gas & mining before the board of oil, gas and mining department of natural resources state of utah in the matter

Micro-Seismic Wells

20

100’

85° 504’

Avg FractureOrientation

N85W

Toe Interval of HZWellbore

Wellbore

56’

85° 504’44’

502’

Vertical Exaggeration for Illustration

As an illustrative measure to show the cautionary safety net in these calculations, we double the fracture half length of the micro-seismic data from 252’ to 504’ while maintaining the determined stress orientation. The resulting geometry still allows a 56’ buffer to the adjacent lease boundary.

Exhibit G&E-9

Page 25: FILED - fs.ogm.utah.gov · filed feb 2 \ 2020 seoretary boafd of oil, gas & mining before the board of oil, gas and mining department of natural resources state of utah in the matter

Original Oil in Place

21

CH4-Finley utilized third party analysis to evaluate OOIP using a combination of wireline logs and core data as an input into drainage calculations. Above is the result of this analysis for the primary horizontal target intervals.

Exhibit G&E-10

OOIP

FORMATION MMBO/sec

CASTLE PEAK 24.171

LOWER CASTLE PEAK 24.259

UTELAND BUTTE 36.503

WASATCH 61.704

Page 26: FILED - fs.ogm.utah.gov · filed feb 2 \ 2020 seoretary boafd of oil, gas & mining before the board of oil, gas and mining department of natural resources state of utah in the matter

Volumetrics – Drainage (Map View)

22

Elliptical + Rectangle

Stage Spacing 150 Feet

Frac Half-Length 252 Feet

Heigth 163 Feet

Lateral Length 10000' Feet

Elliptical Growth 75' Feet

Rectangular Volume 18860 Ac-Ft

Elliptical Cylinder Volume 111 Ac-Ft

Total Volume 18971 Ac-Ft

Oil Content 350 BBL/AcFt

Oil in Place 6,639,714 BBL

Well EUR 800,000

Recovery Factor 12.05%

Ellipse Volume

Volume (V) = π × A × B × h

75'252'

10000'

Exhibit G&E-11

Page 27: FILED - fs.ogm.utah.gov · filed feb 2 \ 2020 seoretary boafd of oil, gas & mining before the board of oil, gas and mining department of natural resources state of utah in the matter

Volumetrics – Ellipse Dimensions

23

X y y'

0 75.00 75.00 Frac Azimuth

50 73.51 77.87 85 degrees E-W Frac Component251'

100 68.84 77.56 1.484 Radians N-S Frac Component22'

150 60.27 73.34

200 45.63 63.06

250 9.43 31.22

300

350

400

450

500

504'

Unit Boundary

��

��+��

��= 1

85

75'

252'

251'

22' y

100 Setback

y'a=

b=

Exhibit G&E-12

Page 28: FILED - fs.ogm.utah.gov · filed feb 2 \ 2020 seoretary boafd of oil, gas & mining before the board of oil, gas and mining department of natural resources state of utah in the matter

Volumetrics – Drainage (Map View)

24

Elliptical + Rectangle

Stage Spacing 150 Feet

Frac Half-Length 504 Feet

Heigth 163 Feet

Lateral Length 10000' Feet

Elliptical Growth 75' Feet

Rectangular Volume 37719 Ac-Ft

Elliptical Cylinder Volume 222 Ac-Ft

Total Volume 37941 Ac-Ft

Oil Content 350 BBL/AcFt

Oil in Place 13,279,427 BBL

Well EUR 800,000

Recovery Factor 6.02%

Ellipse Volume

Volume (V) = π × A × B × h

75'504'

10000'

Exhibit G&E-13

Page 29: FILED - fs.ogm.utah.gov · filed feb 2 \ 2020 seoretary boafd of oil, gas & mining before the board of oil, gas and mining department of natural resources state of utah in the matter

Volumetrics – Ellipse Dimensions

25

X y y'

0 75.00 75.00 Frac Azimuth

50 74.63 78.99 85 degrees E-W Frac Component502'

100 73.51 82.22 1.484 Radians N-S Frac Component44'

150 71.60 84.67

200 68.84 86.27

250 65.12 86.91

300 60.27 86.41

350 53.97 84.47

400 45.63 80.49

450 33.78 73.00

500 9.43 53.01

504' 1.49 45.41

Unit Boundary

��

��+��

��= 1

85

75'

504'

502'

44' y

100 Setback

y'a=

b=

Exhibit G&E-14

Page 30: FILED - fs.ogm.utah.gov · filed feb 2 \ 2020 seoretary boafd of oil, gas & mining before the board of oil, gas and mining department of natural resources state of utah in the matter

Project Economics

26

• Long Lateral Hz well = additional 460 feet of completed reservoir• CH4-Finley estimates 36,800 additional Barrels of oil per well• 36,800 x $55 per barrel = $2,024,000 additional revenue per well• This yields a project ROI of approximately 6.5:1• Additional severance tax at 4.5% = $91M+ per well• 102 additional Long Lateral wells = $9.2MM+ additional severance tax collected

Exhibit G&E-15

Page 31: FILED - fs.ogm.utah.gov · filed feb 2 \ 2020 seoretary boafd of oil, gas & mining before the board of oil, gas and mining department of natural resources state of utah in the matter

Development Model

27

CP

UB

WS1,320’

5,080’ SL Length

5,080’ SL Length

+920’

+460’

10,360’ LL Length

CH4-Finley plans to execute a dual horizontal and vertical development plan to include 2 shallow vertical wells per 80 acre tract as well as 17 Long Lateral Horizontal wells or 8 Short Lateral Horizontal wells. Exclusive vertical drilling or exclusive horizontal drilling will ultimately result in waste of hydrocarbon reserves.

Exhibit G&E-16

Page 32: FILED - fs.ogm.utah.gov · filed feb 2 \ 2020 seoretary boafd of oil, gas & mining before the board of oil, gas and mining department of natural resources state of utah in the matter

Green River Reservoir Geometries – 80 Acre Drill Pattern Example

28

80 Acre Drilling Pattern

2640 feet

• Channel Reservoir Ave. 15-50 ft. High and 145-375 ft. Wide• Shoreline Related Reservoir Ave. 20 ft. High and 1650 ft. Wide

The scaled outcrop example above highlights sand bodies deposited in an environment analogous to that of the Rocky Point area. Sand bodies penetrated by the well bores 2640 feet apart (80 acre spacing) are highlighted in green while sand bodies not penetrated are highlighted yellow and orange. This example shows that many hydrocarbon charged sand bodies would not be produced by 80 acre well density.

Exhibit G&E-17

Page 33: FILED - fs.ogm.utah.gov · filed feb 2 \ 2020 seoretary boafd of oil, gas & mining before the board of oil, gas and mining department of natural resources state of utah in the matter

Green River Reservoir Geometries – 2 Wells per 80 Acre Drill Pattern Example

29

2 Wells per 80 Acre Drilling Pattern

1320 feet

• Channel Reservoir Ave. 15-50 ft. High and 145-375 ft. Wide• Shoreline Related Reservoir Ave. 20 ft. High and 1650 ft. Wide

The 2 wells per 80 acre well density proposed by CH4-Finley for the Rocky Point area is 1320 feet. The diagram above shows that well bores spaced a minimum distance of 1320 feet would penetrate most sand bodies and few would be penetrated by multiple well bores. At this distance CH4-Finley does not believe interference will occur between wells, even within sand bodies continuous between wells.

Exhibit G&E-18

Page 34: FILED - fs.ogm.utah.gov · filed feb 2 \ 2020 seoretary boafd of oil, gas & mining before the board of oil, gas and mining department of natural resources state of utah in the matter

80 ACRE VT DEVELOPMENT

30

1 WELL PER 80 ACRE DEVELOPMENT(109)

VERTICAL PRODUCING WELL (3)

LEGEND

APPLICATION LANDS

Full vertical development of the application lands spaced on 1 well per 80 acre tract would result in the drilling of 109 vertical wells and leave sizeable reserves un-recovered.

Scale = 1 mile

N

Exhibit G&E-19

Page 35: FILED - fs.ogm.utah.gov · filed feb 2 \ 2020 seoretary boafd of oil, gas & mining before the board of oil, gas and mining department of natural resources state of utah in the matter

2 WELLS PER 80 ACRE

31

1 WELL PER 80 ACRE DEVELOPMENT(109)

VERTICAL PRODUCING WELL (3)

2 WELLS PER 80 ACRE DEVELOPMENT (221)

LEGEND

APPLICATION LANDS

Full vertical development of the application lands spaced on 2 wells per 80 acre tract would result in the drilling of 221 vertical wells and result in full recovery of the resource in place.

Scale = 1 mile

N

Exhibit G&E-20

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Witness ResumesState of Utah

Division of Oil, Gas & Mining

Board Hearing—February 26, 2020

Docket No. 2020-002Cause No. 600-01

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Patrick L. Porter (405) 471-3808 (Cell)

[email protected]

Summary of Qualifications Reservoir engineer/manager with 30+ years of oilfield experience. Extensive experience with evaluation and development of conventional and unconventional resource plays in various basins in the US. Skilled in reserve preparation & reporting, data analysis, preparation and presentation of projects for senior management and investment community. Testifying in many protested and unprotested hearings at state regulatory agencies.

States Qualified as Expert Witness: • Oklahoma • Utah

Professional Experience 2017 – Present Finley Resources

Exploitation Manager Fort Worth, TX Responsible for reservoir engineering analysis company wide. Manage geology and reservoir groups to maximize value of company assets. Accomplished thru drilling projects, acquisitions, recompletions, workovers and production surveillance. Rockies Team lead. Manage active drilling projects in the Uinta and Powder River Basin. Assess and evaluate acreage for potential development.

2016-2017 Torero Oil & Gas LLC Vice President Reservoir Engineering Oklahoma City, Oklahoma

Identify, evaluate and recommend drilling projects suitable for a private equity venture. Build the reserve justification and economic cashflow sensitivities and modeling for presentation to potential investors. Primary focus in Mid-Continent Region.

2015-2016 Bright Horizon Resources, LLC Sr. Reservoir / Acquisition Engineer Tulsa, Oklahoma

Extensive evaluation of STACK, SCOOP, Cana/Woodford, Cleveland, Marmaton and Granite Wash reservoirs and generating acquisition targets for well and leasehold acquisition. Areas / Acquisitions evaluated in Mid-Continent, Ark-La-Tex and Permian Regions.

- Identified key extension acreage in the STACK play in central Oklahoma. This was in the overpressured area west of the area Newfield was drilling. Within 6 months, companies were aggressively drilling wells with exceptional results.

2007-2015 Range Resources - Midcontinent, LLC Dist Res Eng VP Reservoir Engineering-Midcontinent Oklahoma City, Oklahoma

Managed reservoir engineering for all of Range Midcontinent Division’s reservoir activities. Develop and managed department of 3 engineers and 3 technicians. Main responsibilities included reserves booking and presentation, budget preparation and presentation, division strategic planning, monthly production planning and guidance, identification of Division resource potential. Major operating areas include Northern Oklahoma Mississippian, Texas Panhandle St Louis, Woodford Shale (Ardmore Basin, Cana, Northern Oklahoma), and Texas Panhandle Granite Wash plays. Responsible for identification, evaluation and application of new/evolving technology in unconventional resource plays. Started as District Reservoir Engineer responsible for Shale Plays and Unconventional Plays for the Midcontinent Division.

- Engineer responsible for evaluation and recommendation of testing the Mississippian formation horizontally on the Nemaha Ridge. Based on analysis and well performance, Range acquired 150,000+ acres and had as many as 4 drilling rigs running in the play

- Acquired 25,000 acres in the Ardmore Basin before Woodford was identified as productive in the Basin. Drilled 20+ wells for the Woodford shale. Average well 7 BCF + 80 MBO

- Managed 80,000 net acres in the Cana Woodford and measured well performance and economic expectations of the play. Determined if well performance merited reallocation of capital resources from other plays in Division.

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Continued…

Patrick Porter… Page 2

2001-2007 Newfield Exploration Mid-Continent, Inc. Sr. Reservoir Engineer Tulsa, Oklahoma

Conventional and non-conventional resource assessment, pre-drill/post-drill economic evaluation, log analysis, completion recommendation and evaluation, drill site determination and prioritization, tactical and strategic planning, OCC testimony, and reserve reporting. Other activities include budgetary planning, recompletion/workover identification and evaluation, production enhancement identification, lead role in numerous acquisition evaluation efforts in the Permian and Mid-Continent. Areas of responsibility at Newfield have included Arkoma Basin (Engineer responsible for identification of Arkoma Woodford Play), Western Oklahoma, Texas Panhandle (early identification of resource potential in the Granite Wash as part of acquisition efforts), and Permian Basin.

- Led testing, assessment and development of the Woodford Shale in the Arkoma Basin (identified the formation was a reservoir as much or more than a hydrocarbon source rock) Newfield acquired 150,000 net acres in the play and ran a multi rig program for several years. Peak production realized of over 200MMCFD

- Identified infill and deeper potential in the Granite Wash. Newfield acquire approximately 10,000 acres in a developed Granite was field that I was able to convince management of the infill and deeper potential. Exploitation began as a vertical testing program but migrated to a multi rig horizontal program with several wells IP’ing over 10 MMCFD. Peak production over 100 MMCFD

1997-2001 Questar Exploration and Production Company / HS Resources (1998-2001) Staff Petroleum Engineer Tulsa, Oklahoma Reservoir Group Supervisor

Reservoir and Production engineering responsibility covering the entire division (Eastern Oklahoma, Arkansas, Louisiana, Mississippi, and Texas. Duties include coordinating, preparing, and submission of quarterly reserve reports, division planning and budgeting, acquisition analysis, drilling/ recompletion/ workover evaluations, maintaining and increasing production of properties through workovers and enhanced recovery methods (i.e. plunger lift, compression, beam pump...).

HS Resources, Inc. (district office and properties sold to Questar)(1997-1998) Reservoir Engineer Tulsa, Oklahoma

Major responsibility includes generating engineering prospects in the Arkoma and Anadarko Basins (workovers, recompletions, and drilling prospects), and identification of acquisition targets. 1993-1997 Southwestern Energy Production Company

Reservoir Engineer Oklahoma City, Oklahoma Responsible for all aspects of Reservoir Engineering. Areas actively working include Mid-Continent, Gulf Coast, and Permian Basins. Minor emphasis Williston Basin.

1990-1992 Union Oil Company of California dba UNOCALPetroleum Engineer Oklahoma City, Oklahoma

Development Team Leader with oversight responsibility for all activity in the SE Oklahoma and Arkansas area.

1987-1990 Merrico Resources, Inc.Acquisition Engineer Ardmore, Oklahoma

Responsibilities involved all aspect of property acquisition. Responsible for evaluations in all areas with primary emphasis in Mid-Continent, Gulfcoast, Permian, Rockies and Williston Basins. 1987 Samedan Oil Corporation

Temporary Position Ardmore, Oklahoma Identified additional perforating potential and pattern changes to improve recovery in 4 waterfloods.

EducationBS Petroleum Engineering, December 1986 - University of Tulsa, Tulsa, Oklahoma