Mark Robinette will again deliver the Arkansas oil and gas law update at the Ark-La-Tex Association of Professional Landmen annual conference in Shreveport, Louisiana. Mr. Robinette’s presentation will cover legislation, appellate court opinons, and rule changes relevant to landmen and oil and gas operators in Arkansas. The past year saw many important cases come through the appellate courts including cases addressing the effectiveness of quiet title decrees, refunding of bonus payments, and rights of parties in possession. Notable legislative changes also occurred. The conference is February 14 and 15, 2014, at the Shreveport Convention Center. More information is available from website of the ALTAPL: www.altapl.org.
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Mark Robinette to Speak at Arkansas Banker’s Association Annual Trust Conference
Mark Robinette will deliver a continuing education presentation to The Arkansas Banker’s Association Trust Conference on October 23, 2012. The topic of Mr. Robinette’s presentation will be managing mineral interests in Arkansas. The talk is geared towards those acting in a fiduciary capacity. The topics covered include basic oil and gas geology, basic oil and gas technology, oil and gas title, forced pooling, and implied lease covenants.
Mark Robinette to Speak at Arkansas Bar Association Best of CLE
Mark Robinette will speak at Arkansas Bar Association’s 2012 Best of CLE. The program will be at the William H. Bowen School of Law at the University of Arkansas Little Rock on Tuesday, June 26, 2012. Registration will be through the Arkansas Bar Association. Mr. Robinette’s talk will be on capacity and authority to execute mineral leases and conveyances.
Mark Robinette Recognized by Mid-South Superlawyers Magazine
Mid-South Superlawyers Magazine named Mark Robinette to its Rising Star list for Natural Resources and Energy Law. The magazine bestows the honor based on 12 indicators of peer recognition and professional achievement. Superlawyers does not receive payment of any kind for a lawyer to be considered or named to its listings.
Mark Robinette to Deliver Arkansas Oil and Gas Law Update at Annual Ark-La-Tex Association of Professional Landmen Conference
Mark Robinette will deliver the annual Arkansas Oil and Gas law update at the annual ArkLaTex Association of Professional Landmen conference on February 9, 2013. Those interested in attending my register throughALTAPL.
When is a hydraulically fractured well “complete?”
The expiration of an oil and gas lease’s primary term does not necessarily release all non-producing lands. This can be so even when the lease contains a Pugh Clause. Typically, most leases contain savings provisions that extend the lease beyond the primary term when the lessee “continuously prosecutes” drilling operations. A sample of this saving provision from the Producer’s 88 lease form is as follows:
Subject to the other provisions herein contained, this lease shall remain in force for a term of ____ years from this date (herein called “primary term”) and as long thereafter as oil and gas, or either of them, is produced from the above described land or drilling operations are continuously prosecuted as hereinafter provided. “Drilling operations” includes operations for the drilling of a new well, the reworking, deepening or plugging back of a well or hole or other operations conducted in an effort to obtain or re-establish production or oil or gas; and drilling operations shall be considered to be “continuously prosecuted” if not more than 180 days shall elapse between the completion or abandonment of one well or hole and the commencement of drilling operations on another well or hole. If, after the expiration of the primary term of this lease, oil or gas is not being produced from the leased premises but lessee is then engaged in drilling operations, this lease shall continue in force so long as drilling operations are continuously prosecuted; and if production of oil or gas results from any such drilling operations, this lease shall continue in force so long as oil or gas shall be produced from the leased premises. If after the expiration of the primary term of this lease, production on the leased premises should cease, this lease shall not terminate if lessee is then prosecuting drilling operations, or within 180 days after each such cessation of production commences drilling operations, and this lease shall remain in force so long as such operations are continuously prosecuted, and if production results therefrom, then as long thereafter as oil or gas is produced from the leased premises.
Even a Pugh clause does not ordinarily defeat these savings provisions. The function of the Pugh clause is to prevent the lessee from holding non-producing lands with a single production unit. It does not prohibit the establishment of production and holding of lands by savings provisions. The typical Pugh clause reads as follows:
If at the end of the primary term, a part but not all of the land covered by this lease, on a surface acreage basis, is not included within a unit or units in accordance with the other provisions hereof, this lease shall terminate as to such part, or parts, of the land lying outside such unit or units, unless this lease is perpetuated as to such land outside such unit or units by operations conducted thereon or by the production of oil, gas or other minerals, or by such operations and such production in accordance with the provisions hereof.
Note that not only does the typical Pugh clause not conflict with the “continuously prosecuted” savings provisions, but it acknowledges the possibility that the lease may be perpetuated beyond the primary term by those very savings provisions.
In a bid to test these savings provisions, a large Colorado landowner argued that a “completion” was an ambiguous term in the savings provisions. That is, it the completion date could be the date on which the well cased and perforated or the date on which the well was hydraulically fractured. The case of Bledsoe Land Company, LLLP v. Forest Oil was decided on June 23, 2011. See the opinion at http://scholar.google.com/scholar_case?case=3498925303401075223.
To understand the landowner’s argument, a little background on completion is instructive. A conventional oil and gas reservoir has its own energy to force the migration of oil and gas to the surface (“up hole”). Completion is a simple matter of drilling the well, setting production casing, and perforating the production casing. The perforations are the holes in the casing that allow oil and gas to flow from the reservoir rock into the casing. The casing is the pipe that contains the oil and gas on its way up to the surface. The reservoir releases its energy without any further stimulation allowing the oil and gas to flow up hole. There is, therefore, an argument that “completion” means what it does in the conventional sense–the setting and perforation of production casing.
With tight gas and oil found in shale formations, it takes more than the setting and perforation of production casing to recover the oil or gas because there is no readily available reservoir energy. The producer must create cracks in the formation to release the formation’s energy so that the oil and gas to flows up hole. The producer accomplishes this with hydraulic fracturing. Using thousands of pounds of pressure, the producer forces a cocktail of chemicals, sand, and water through the production casing perforations. The force applied to the water breaks the formation apart and the sand props these fractures open so that oil and gas can flow up hole.
In Bledsoe, the landowners’ acreage was being held beyond the primary term by continuous operations with 180 day continuous drilling savings provisions. The lessee commenced a subsequent well 184 days past the casing of the first well and 197 days past the perforation of the casing in the first well, but only 176 days after the hydraulic fracturing of the first well. The landowner won at the trial level, with trial court declaring the term “completion” to be ambiguous. After reviewing the extrinsic evidence, the trial court found that “completion” meant the setting and perforation of production casing.
The appeals court in Bledsoe overturned the trial court’s ruling that the term “completion” was ambiguous. Citing to a number of authorities that the ordinary accepted usage in the oil and gas industry of the word “completion” meant the well was “capable or ready to produce gas,” the court reasoned that term was meant in its ordinary and accepted meaning in the oil and gas industry. As a result, the completion date occurred after the hydraulic fracturing treatment rather than on the date the casing was set and perforated, keeping the lease alive for the drilling of a subsequent well.
The Bledsoe decision has application for leases in unconventional oil and gas areas where hydraulic fracturing is the norm. In Arkansas, the decision may provide some secondary authority for similarly worded leases. Additionally, the case may serve as secondary authority that “completion” as used in the statutory Pugh Clause should occur upon the hydraulic fracturing treatment rather than upon the setting and perforation of casing.
Arkansas Oil and Gas Commission Issues Emergency Order Shutting Down Disposal Wells in Earthquake Zone
In a brief hearing to confirm a consent administrative order, the Arkansas Oil and Gas Commission (AOGC) reached an agreement with the operators of two disposal wells in the Enola Swarm seismic zone to immediately cease disposal operations. The wells were located in S17-T8N-R12W and S6-T7N-R12W in Faulkner County, Arkansas.
The order will be in effect until the last day of the March, 2011, AOGC regular hearing. At the regularly scheduled March hearing, the AOGC will hear the entire docket including evidence and public comment. There will be pre-hearing conferences between the AOGC staff and the operating companies prior to the hearing. In giving the consent order, the companies operating the disposal wells admitted no culpability for the recent seismic activity in the vicinity of their wells.
The matter of disposal wells causing seismic activity is under study, and the AOGC placed a moratorium on all new disposal wells in the Enola Swarm area in December 2010. Read more about the docket here. The documents from the December hearing, including an article about the theory of induced seismicity by disposal wells are here: Part1 and Part2.
AOGC staff reiterated that they had no evidence that hydraulic fracturing, a process related to extracting gas from the Fayetteville Shale, had any connection with the seismic activity. Hydraulic fracturing takes place at a much shallower depth than disposal, and the fluids used in fracturing are recovered and not left in the ground. There is speculation that seismic activity related to disposal wells occurs because the disposal fluids remain in the ground at a depth where seismic activity occurs, possibly lubricating faults to induce seismic activity.
Many media outlets, industry representatives, and interested citizens were present at the hearing. Because the order was admitted by consent, no evidence was taken at the hearing.
Arkansas Supreme Court Revisits Law on Pipeline Gathering System Condemnation and “Statutory Pugh Clause”
The Arkansas Supreme Court ruled against landowner who challenged to the authority of a gas gathering system to use the power of eminent domain to acquire rights of way. In Ralph Loyd Martin Revocable Trust v. Arkansas Midstream Gas Services Corp., a landowner challenged whether a gas gathering system’s condemnation was for a public use pursuant to Ark. Code Ann. 23-15-101. (2010 Ark. 480). The court ruled that the gas gathering system is for public use because the system was available to multiple royalty owners and working interest owners from many different drilling units with equal access for all at a fixed rate. In industry language, the gathering system was a “common carrier.”
A gathering system provides a conduit for gas from a wellhead to reach larger interstate pipelines. Without the power of eminent domain, it would be difficult for the public to have access to natural gas. Landowners should be aware–as this case illustrates–that challenges to eminent domain cases for reasons other than the amount of compensation are seldom successful. It takes a truly egregious abuse of eminent domain to mount a successful challenge on the merits. Just 5 years ago, the United States Supreme Court upheld a taking of property for purely economic reasons. See Kelo v. City of New London, 545 U.S. 469 (2005).
The Court also re-examined the Statutory Pugh Clause codified at Ark. Code Ann. 15-73-201. Southwestern Energy Production Co. v. Elkins, 2010 Ark. 481. A bit of background is necessary for those readers who do not understand the basics of oil and gas leases. When a well begins to produce, an oil and gas lease enters its secondary term. The secondary term continues until there is no longer a commercially viable oil or gas well. A lease holder may drill wells perpetually to extend the secondary term.
But suppose all of the drilling takes place on one tract, but the lease also covers tracts several miles away. A standard oil and gas lease always has some language to the effect that operations on one part of the lands extend to the whole of the leasehold. Therefore, a well on one part of the leasehold holds all lands covered by the lease into the secondary term. This idea is also incorporated into Ark. Code Ann. 15-73-201. If one area of the leasehold is very attractive and easy to develop, it may be decades before the operator gets around to developing the less attractive areas. This is a source of frustration for many landowners. Enter a Louisiana lawyer named Pugh. Lawyer Pugh drafted a simple clause to remedy the problem:
If at the end of the primary term, a part but not all of the land covered by this lease, on a surface acreage basis, is not included within a unit or units in accordance with the other provisions hereof, this lease shall terminate as to such part, or parts, of the land lying outside such unit or units, unless this lease is perpetuated as to such land outside such unit or units by operations conducted thereon or by the production of oil, gas or other minerals, or by such operations and such production in accordance with the provisions hereof.
Put simply, when operator finishes the drilling started in the primary term, the lease becomes severable, freeing up the lands the operator failed to develop.
In response to outrage by mineral owners who did not see all of their lands developed in a timely manner, the General Assembly enacted the following as Ark. Code Ann. 15-73-201:
Lease extended by production — Scope
(a) The term of an oil and gas, or oil or gas, lease extended by production in quantities in lands in one (1) section or pooling unit in which there is production shall not be extended in lands in sections or pooling units under the lease where there has been no production or exploration.
(b) This section shall not apply when drilling operations have commenced on any part of lands in sections or pooling units under the lease within one (1) year after the expiration of the primary term, or within one (1) year after the completion of a well on any part of lands in sections or pooling units under the lease.
(c) The provisions of this section shall apply to all oil and gas, or oil or gas, leases entered into on and after July 4, 1983.
The plain reading of this statute is that an operator must continue drilling, or lose the lease. This is not quite a Pugh clause, but it is close. In the latest case examining this statute, the landowner plaintiffs attempted to re-argue the correct interpretation of the statute. The court did not see fit to alter the interpretation it adopted in Snowden v. JRE Investments, 2010 Ark. 276. That is, the plain reading of the statute prevailed, and in this case, the operator complied with what the statute required. Like the Snowden case, this case drew some dissenting opinions. The gist of those dissents is that the General Assembly meant to write a true Pugh clause, but as the dissenters note, it is up to the General Assembly to change its statutes, not the courts.
Landowners should not rely on the so-called statutory Pugh as true Pugh clause because it isn’t one. When writing this law, the General Assembly compromised between the operator and landowner viewpoints. The statute ended the days landowners languishing over the operator sitting on a single well to hold a leasehold spread over a large area, but it also allowed the operator a reasonable cushion of time for development. Like all other aspects of an oil and gas lease, a landowner can negotiate for true Pugh clause.
The ads that appear on this site were placed by Google and are not endorsed by the author or otherwise approved by the author.
The above represents the opinion of the author and not of any organization or group to which the author may belong. This material is general information, and it is not intended to create any lawyer-client relationship. Neither the transmission nor receipt of this information is an offer to extend representation by the author. Any information, opinion, and comment provided herein should not be taken as legal advice or relied upon by the reader for any purpose. The author is licensed in the state of Arkansas. Commentary on cases and law from jurisdictions where the author does not hold license to practice are for demonstrative or scholarly purposes
and do not represent the author is licensed or accepts cases in the applicable jurisdiction. If you are need of legal services, you should contact a licensed attorney in your jurisdiction.
Arkansas Oil and Gas Commission Approves Hydraulic Fracturing Rule, Places Moratorium on Enola Swarm Disposal Wells, Rules in Favor of Operators on Mineral Owner Contested Dockets
At its December meeting, the Arkansas Oil and Gas Commission adopted proposed rule B-19 to disclose the constituents of hydraulic fracturing fluids. There was little fanfare and little debate on the adoption of the rule. Representatives of CARE, The League of Women Voters, and Halliburton proposed changes to the proposed rule at the hearing. With minor modification, the Commission adopted the rule. The final proposed rule can be found here. The rule will take effect on January 15, 2011. This will make Arkansas the third state to require disclosure of the chemical makeup of fracturing fluid.
In a Commission staff docket, Director Larry Bengal proposed a moratorium on new disposal wells in the following townships: 6N-12W, 6N-11W, 7N-11W, 7N-12W, 7N-13W, 7N-14W, 7N-15W, 8N-11W, 8N-12W, 8N-13W, 8N-14W, 9N-11W, 9N-12W, 9N-13W, Sections 7-36 of 8N-15W, Sections 25-36 or 9N-14W. These Townships are in the area of the Enola Swarm, a cluster of seismic activity that began in 1982 around the Faulkner County town of Enola.This was due to the existence of some circumstantial evidence that the disposal well activities may induce seismic activity. The Commission granted the moratorium. During the moratorium period, the Arkansas Geological Survey, the Arkansas Oil and Gas Commission, United States Geological Survey, and the Center for Earthquake Research and Information will study whether the disposal wells have some effect on seismic activity in the area. The oil and gas industry uses disposal wells to inject used drilling fluids deep into the earth so that fluids cannot migrate into fresh water aquifers or the biosphere. The Commission will hear the results of the studies at its July 2011 hearing.
There were several contested dockets at the December hearings,most of which were between operators, but there were three contested dockets involving a mineral owner’s challenge to an integration order. In two of these dockets, the heirs of a long deceased mineral owner made some novel arguments to the Commission about the remedy due them for being missed in an integration application, and in the other docket, the same heirs contested whether the operator exercised reasonable efforts to find the long dead mineral owner’s heirs.
In the dockets testing the remedy available for being missed in an integration application, the operator conceded that it failed to determine the existence of the mineral owner’s interest in the original integration proceeding. The heirs argued that they were entitled to punitive measures along with the right to split their election between participation for completed wells and leases for proposed wells. The Commission declined to extend punitive measures because the relief was out of the Commission’s jurisdiction. The Commission recognized that the statutes requiring interest and penalties for operators who fail to pay royalties are causes of action in court rather thanbefore the Commission.The Commissionan so upheld its policy of disallowing split elections for parties missed in the original integration.
In the docket testing reasonable efforts to locate missing mineral owners, the Commission placed the burden to prove the inadequacy of the efforts on the heirs. The heirs utilized two landmen to demonstrate how to find these particular missing heirs. In this case, the heirs were located in Texas. The only evidence in Arkansas of a link to Texas was the acknowledgement in the last deed of record from the heirs’ predecessor in title. The heirs put on evidence that a search of the probate records in the Texas counties shown in the acknowledgment would have turned up the heirs. The operator put on evidence of its efforts, which were extensive and included some search of Texas records, but not the probate records in the counties shown on the deed acknowledgment. The Commission ruled that the heirs did not meet their burden to show that the operator’s heirs were unreasonable.
The ads that appear on this site were placed by Google and are not endorsed by the author or otherwise approved by the author.
The above represents the opinion of the author and not of any organization or group to which the author may belong. This material is general information, and it is not intended to create any lawyer-client relationship. Neither the transmission nor receipt of this information is an offer to extend representation by the author. Any information, opinion, and comment provided herein should not be taken as legal advice or relied upon by the reader for any purpose. The author is licensed in the state of Arkansas. Commentary on cases and law from jurisdictions where the author does not hold license to practice are for demonstrative or scholarly purposes and do not represent the author is licensed or accepts cases in the applicable jurisdiction. If you are need of legal services, you should contact a licensed attorney in your jurisdiction.
Integration necessary and no cause for concern for mineral owners
Occasionally, I receive questions from people who are upset because they got a letter from a lawyer for an oil and gas company stating that the oil and gas company applied to the Oil and Gas Commission to integrate their land. The letter includes a legal notice giving the date and time for a hearing along with instructions on how to notify the Commission of any opposition to the integration. The first reaction from most getting these letters is that they’ve been sued or the oil and gas company is taking something from them. Neither is the case, and being subject to an integration is no cause for concern.
The hearing before the Oil and Gas Commission is the culmination of months and sometimes years worth of work on the part of the oil and gas company. The company has to identify an area prospective for oil and gas, run title on the area, attempt to lease everyone in the area, and attempt to get all other companies with leases in the area to agree to the operation of the unit before going to the Commission. I will omit identification of the geology, and start with running title.
Running title is ordinarily a precursor to leasing and a must prior to integration. In order to know who owns the oil and gas, a company must check the land records at the county courthouse or in a private title plant. In some cases, oil and gas companies simply buy out a private title plant. This happened in a few instances in Fayetteville Shale Counties, allowing the plant owners to retire wealthy. The oil and gas company examines the title back to when the United States owned the land. Once they determine ownership, the companies send out landmen to make a lease offer to the mineral owner.
If the landowner and landman agree to a lease, the landowner is out of the integration process. The lessee becomes the only “interested party” in the integration. If the landowner says “no thanks” to the lease, the landman will haggle and persist for a time, sometimes until the landowner cuts off communication with the landman. At some point between negotiating and persisting, the company meets its obligation to make “reasonable efforts” to lease. There is no published case on how far a company has to go to lease, but it probably isn’t a high bar to clear. Once the company makes reasonable efforts to lease, the company (assuming it meets other requirements) may apply to the Oil and Gas Commission to “integrate” the unleased interest.
The term “integrate” is a polite term for “compulsory pooling.” The Oil and Gas Commission holds a power granted by statute to compel parties in a prospective oil and gas unit to come to an agreement as to how to share costs and revenues for the production oil and gas from the unit. The proceeding before the Commission is administrative in nature. Thus, nobody is being sued. The company seeking to operate the drilling unit is the “operator” or “applicant.” The unleased mineral owners and uncommitted working interest owners (other companies with leasehold interests) are “interested parties.” A lease mineral owner or not interested because the oil and gas lease effectively transfers the mineral owner’s interest to the control of the lessee.
A company seeking to integrate drilling unit must hold a majority leasehold acreage interest in the unit. They must prepare an application documenting their efforts to lease the unleased parties, documenting efforts to get other companies with acreage in the unit to agree to the operation of the unit, listing the drilling costs of the first well, listing the highest bonus and royalty it paid in the unit, and detailing the geological risk of drilling the well. The company gives notice of the pending integration to all interested parties by certified mail and by publication in the newspaper. Once the applicant submits the application and notice delivered, the company goes to hearing before the Oil and Gas Commission.
The hearings are usually uneventful. The company and its attorney will present the application to the Commission, and a landman representative of the company will be present to answer questions about the company’s acreage position in the unit and efforts to lease. The Commission usually has few questions for the company and will approve the application if it is in order.
Occasionally, a landowner will object or otherwise appear before the Commission at the hearing for one reason or another. The most common complaints are ownership disputes and surface use issues. The Commission has no jurisdiction to resolve either problem. The Commissioners will listen to the complaint, though they cannot take any legally binding action on ownership of surface use issues. I’ve seen this happen many times. Once the landowner finishes speaking, one of the Commissioners will explain why they cannot take action.
Sometimes, the landowner will bring an attorney. I’ve seen many times where an attorney unfamiliar with the Commission’s powers will make a number of arguments about the propriety of the proceeding. Perhaps the greatest misconception among general practice attorneys is that the Commission’s proceeding is an eminent domain proceeding. Pursuing this line of reasoning, they present arguments about the amount of compensation paid. An integration proceeding is not a “taking” under the Constitution. The proceeding is an exercise of police power by the state to prevent the drilling of unnecessary wells and the waste of a non-renewable resource.
Yet another angle taken by attorneys representing landowners is that the lease bonus and royalty stated by the applicant is not the highest paid in the section. The best known case of this is where the United States received $8,000 an acre for their acreage in a unit, and the landowner’s attorney argued that should be the highest bonus paid. The statute authorizing integration says the terms of the integration “shall be upon terms and conditions which are just and reasonable.” In that case, the attorney didn’t realize the “just and reasonable” applies to both the applicant and the unleased mineral owner. Most of Commissioners were appointed to serve because they are industry professionals. Because of their own experiences and their hearing of integration applications, they have extensive knowledge what bonus and royalty is reasonable. A common bit of industry knowledge is that leases from the United States are always sold at an extreme premium in producing areas. The Commissioners took this into consideration, and they chose to accept the applicant’s highest bonus and royalty rather than that paid to the United States.
The only points of dispute in an integration that are likely to make any headway with the Commission are deficiencies in the contents of the application or lack of a majority interest. If a landowner finds a deficiency, the applicant will move to amend the application or delay the proceeding until they can correct the deficiency. At best, this type of objection will simply buy the landowner a bit more time to find a better lease than what will be offered by the Commission. Theoretically, the landowner could object or dispute more technical things in the application such as the geological risk or the drilling costs, but doing so would require the retention of an expert such as a petroleum geologist or drilling engineer.
After the hearing, the Commission will enter and order setting forth the integrated party’s options. The applicant sends out a lease form and election letter to each unleased interest. The interested parties have 15 days after the order to make their election. For an unleased mineral owner, the options are to affirmatively accept the commission lease at the applicant’s highest bonus and royalty, do nothing and being deemed to accept the lease, participate in the well, or affirmatively reject the lease and be deemed “non-consent.” The choice to participate makes the interest owner a partner in the well. As a well partner, the interest owner must pay Joint Interest Billing Statements (JIBS) issued by the operator for well costs. For example, if well #1 costs $2,000,000 and the participating owner owns 64 acres out of a 640 acre unit, the JIBS for that owner for well #1 will be $200,000. The non-consent choice subjects the unleased mineral owner to a geological risk factor penalty of 300% to 600%. That is, the non-consenting interest gets all of the money attributable to the interest from the well, but has to forfeit 1 to 6 times the cost that would have been paid had the owner participated with the interest. In the example above, Well #1 would have to pay out 6 to 12 million before the non consenting interest sees their first payout. Typically risk factors are 300% to 400%.
Uncommitted working interest owners may either participate in the well or be non-consent. The same risk factor is imposed on non-consenting working interest owners as non-consenting mineral owners except that the royalty is paid out to the lessor and the remaining balance of the revenue goes to satisfy the risk factor.
Integration and oversight by the Oil and Gas Commission provides an important function. Without regulation, profit demands that everyone drill as many wells as possible as quickly as possible. In order to prevent the drainage by neighboring tracts, each and every landowner has an incentive to drill their own well. As a result, several expensive wells could drain one pool, scarring the surface estate of each Tract and decreasing the overall profitability of the enterprise by drilling unnecessary wells. Further, excessive wells decrease the reservoir pressure leading to lower overall recovery and the intrusion of fossil brine causing the resource to become less recoverable.
Landowners who are noticed for Integration should not be alarmed. Integration is a not a lawsuit, and nothing will be lost by being a party. Integration is fair and efficient means to give every interested party a fair share of production while minimizing economic waste, damage to the surface estate, and maximizing the overall recovery from the pool of oil or gas.
For more information about integration, consult the Arkansas Code in title 15, section 72 along with Arkansas Oil and Gas Commission Rule B-43.
The ads that appear on this site were placed by Google and are not endorsed by the author or otherwise approved by the author.
The above represents the opinion of the author and not of any organization or group to which the author may belong. This material is general information, and it is not intended to create any lawyer-client relationship. Neither the transmission nor receipt of this information is an offer to extend representation by the author. Any information, opinion, and comment provided herein should not be taken as legal advice or relied upon by the reader for any purpose. The author is licensed in the state of Arkansas. Commentary on cases and law from jurisdictions where the author does not hold license to practice are for demonstrative or scholarly purposes and do not represent the author is licensed or accepts cases in the applicable jurisdiction. If you are need of legal services, you should contact a licensed attorney in your jurisdiction.