FORMING THE UNIT: THE AREA AND DEPTH (DESIGNATION) MEETING

JurisdictionUnited States
Onshore Pooling and Unitization
(Jan 1997)

CHAPTER 13A
FORMING THE UNIT: THE AREA AND DEPTH (DESIGNATION) MEETING

Neal Brecheisen
Bureau of Land Management
Carson City, Nevada


INTRODUCTION

This paper reviews some of the procedures commonly employed by the oil and gas industry and the Bureau of Land Management (BLM), to form a federal oil and gas exploratory unit. This paper is not intended to present official Bureau policy on federal units nor be a legal analysis. It is, rather, intended to be a guide as to the purpose and intent of each step in the process up to and including designating an area as a logical unit area. Other papers presented in this compendium address additional aspects of unit agreements.

GENERAL BACKGROUND

THE AUTHORITY FOR UNITIZATION

The Mineral Leasing Act of February 25, 1920, 41 Stat. 437, as amended, 30 U.S.C. Sec. 181 et seq., authorizes Federal lessees and their representatives to unite with each other, or jointly or separately with others, in collectively adopting and operating a unit plan of development or operations of any oil and gas pool, field or like area, or any part thereof for the purpose of more properly conserving the natural resources thereof whenever determined and certified by the Secretary of the Interior to be necessary or advisable in the public interest.1

BENEFITS OF UNITIZATION

The Bureau of Land Management's 3180 Manual characterizes the benefits of unitization as:

Unitization provides for the exploration, development, and operation of an entire structure or area by a single operator so that drilling and production may proceed in the most efficient and economical manner.2

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OBJECTIVES OF UNITIZATION

As extracted from the BLM 3180 Handbook which accompanies the 3180 Manual, the objectives of unitization are:

...to proceed with a program for all lands within the unit that will adequately and timely explore and develop the committed leases within the unit area without regard to the interior boundaries of the leases. Exploratory units normally embrace a prospective area that has been delineated on the basis of geological and/or geophysical inferences. Such agreements usually encompass all oil and gas interests in all formations within the unit area and provide for the allocation of unitized production to the committed lands reasonably proven to be productive of unitized substances in paying quantities on the basis of the surface acreage included within the controlling participating area. The consolidation of separate leasehold interests through unitization eliminates the need to drill protective wells along common boundaries between unitized leases and serves to maximize benefits through a continuing exploration and development program.3

PURPOSE OF THE AREA AND DEPTH MEETING

The unit proponent should plan to meet with the authorized officer to discuss these aspects:

-The geological model or play which will define the logical unit boundary;

-The depth and location of the obligation well(s);

-The type of agreement which is proposed and any modifications or stipulations which are planned to be incorporated into the unit agreement;

-The proposed area of the unit; and

-The unit name which is traditionally, a short local name based upon a natural or topographic feature in the vicinity.

A more detailed explanation of the steps involved in the designation of a logical unit area can be found in the BLM Handbook:

To initiate the formation of an exploratory unit, the proponent of the unit files an application formally requesting the Authorized Officer (AO) to (1) designate the proposed area as logically subject to exploration and development under a unit plan of operation; (2) approve the maximum depth and objective formation proposed for the initial test well(s) and or development obligations (if the area contains a discovery but is not fully developed); and (3) approve the text of the proposed form of unit agreement. The request for designation must be

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accompanied by a map or diagram showing the area sought to be designated and indicating the types of geological and geophysical information. After consideration of the application, the applicant will be advised of the decision with respect to the designation of the area, the specific form of agreement, and the number and depth of the initial well(s) required. Copies of the approved designation letter, signed by the Authorized Officer, are furnished to other appropriate BLM offices and to appropriate State and Federal agencies having jurisdiction over lands in the unit area. The application and all supporting information will be retained by the Authorized Officer.4

WHO IS THE AUTHORIZED OFFICER?

The BLM is an agency of the Department of the Interior and derives the authority to enter into unit agreements from the 1920 Mineral Leasing Act as amended.5 This authority is not held near the top of the organization in the BLM but delegated to the field office level which is closest to the effects of each decision. This decentralization of authority throughout the BLM often puts the authority to approve unit agreements upon a field office level such as a Resource Area Manager. However, differing levels of workload and personnel ceilings often limit the available expertise to centralized locations such as District Offices or State Offices. The authorized officer in any given area may be different than an adjacent State or another District within the same state. Inquire with the local office of the BLM to determine who the authorized officer is for unit agreements in your area of interest.

LOGICAL UNIT BOUNDARY

Unitization allows a single pool or structure to be defined, tested and developed as if there were no intervening lease boundaries. The unit operator has the expressed authority to locate the wells such that the best target could be drilled and the pool exploited in the most efficient manner. The unit boundary should encompass the entire geological structure or trap to diminish the possibility of adjacent lease owners competing to drain the reservoir. The geologists and geophysicists cannot accurately predict the exact location of the oil or gas pool. However, without some geologic framework upon which to base a logical boundary, conservation of the resources may be unattainable.

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GEOLOGIC BOUNDARIES

The geologic model or play used to define a unit proposal may be supported by geologic data such as surface mapping, detailed stratigraphic sections, gravity data, magnetic data, nearby well data, surface sampling for hydrocarbons, regional or local structural analyses, or any number of geophysical or electronic data which come in a myriad of forms, applications and usefulness. These geological data are blended together by the unit proponent to create a three dimensional picture of the expected reservoir. Unit proponents use cross-sections, subsurface contour and thickness maps of the primary reservoir, fence diagrams or any other method which depicts the presumed shape, thickness and depth of the target. The unit proponents should be prepared to discuss the geologic data which support the geologic model.

A reasonable geologic model supported by defendable data should provide an adequate basis for drawing the unit boundary. In those instances where there is a paucity of existing geological data and acquisition of additional data is precluded, discussion of the proposal at an early stage with the BLM...

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