Mika Meyers Beckett & Jones PLC

Transcription

1 Mika Meyers Beckett & Jones PLC 900 Monroe Avenue NW Grand Rapids, Michigan Tel Fax Web mmbjlaw.com Attorneys at Law James R. Brown Stephen J. Mulder Daniel J. Parmeter, Jr. Matthew E. Fink Leonard M. Hoffius 1 Also Admitted In Larry J. Gardner Douglas A. Donnell 5 Mark E. Nettleton 3 Kimberly M. Large 2 1 Daniel J. Kozera, Jr. Colorado Claude L. Vander Ploeg Scott E. Dwyer John C. Arndts Nikole L. Canute 4 2 Delaware John M. DeVries 5 William A. Horn 6 3 Andrea D. Crumback Steffany J. Dunker Retired Illinois Michael C. Haines Daniel R. Kubiak Scott D. Broekstra Amy L. VanDyke Ernest A. Mika 4 New York Scott S. Brinkmeyer Mark A. Van Allsburg Jennifer A. Puplava Veryl N. Meyers 5 Ohio John T. Sperla Elizabeth K. Bransdorfer Nathaniel R. Wolf Of Counsel 6 Wisconsin David R. Fernstrum Neil L. Kimball Benjamin A. Zainea James B. Beckett Mark A. Kehoe Ross A. Leisman Ronald M. Redick John C. Jones Fredric N. Goldberg Neil P. Jansen James J. Rosloniec Steven L. Dykema James K. White Eric S. Richards Brian M. Andrew Ronald J. Clark April 29, 2008 Ms. Mary Jo Kunkle Executive Secretary Michigan Public Service Commission P.O. Box Lansing, MI Re: Application of Terra Energy Company LLC Case No. U Dear Ms. Kunkle: Attached for electronic filing please find the Application of Terra Energy Company LLC. Enclosed with a hard copy of this letter (sent by first class mail) is a check made payable to the State of Michigan in the amount of $100 to cover the filing fee. Should you have questions, feel free to contact me. Sincerely, William A. Horn bjb Enclosure cc w/enc: Mr. Nelson Fairchild H:\WAH\CLN\Vacuum Operations Group.34614\Vacuum Operations.34289\BreitBurn-Terra\Ltr MPSC Terra-Corwith.doc

2 STATE OF MICHIGAN BEFORE THE MICHIGAN PUBLIC SERVICE COMMISSION In the matter of the Application of ) Terra Energy Company LLC ) for Approval to Operate Certain Natural Gas ) Wells Under a Vacuum in Otsego ) County, Michigan ) ) Case No. U APPLICATION Terra Energy Company LLC ( Applicant ) requests approval from the Michigan Public Service Commission pursuant to administrative rule 1999 AC R and 1929 PA 9, as amended, to operate certain natural gas wells under a vacuum, and represents to the Commission as follows: 1. Applicant is a limited liability company with its principal place of business in Michigan located at 720 South Otsego, Gaylord, Michigan It is an oil and gas exploration and producing company and is engaged, among other things, in the production, transportation, and sale of natural gas. 2. Applicant proposes to operate certain natural gas wells under a vacuum, and seeks Michigan Public Service Commission approval to do so pursuant to administrative rule R The legal description of the lands on which these wells are or may be located is as follows: The Corwith Antrim Project (MPSC # 651) 2,520 acres. Township 32 North - Range 2 West, Corwith Township, Otsego County, Michigan, Section 33: S/2, E/2 NE/4; Section 34: S/2, S/2 NW/4, NE/4 NW/4, S/2 NE/4. Township 31 North Range 2 West, Dover Township, Otsego County, Michigan, Section 3: NW/4 NW/4, E/2 NE/4, NW/4 NE/4; Section 4: Entire; Section 5: E/2 NE/4; Section 8: E/2; Section 9: Entire except SE/4.

3 4. A map showing the location of the project is attached as Exhibit A to this Application. 5. By operating wells under a vacuum, both the production rate and the ultimate amount of gas recovered will be increased. As explained in the testimony of Steven Kohler, which will be filed in this matter, the gas in the Antrim Shale formation is adsorbed on the matrix of the shale and is produced by desorption through the fractures in the shale to the wellbore. Each additional increment of pressure drawdown results in more gas desorption and ultimately greater gas production rates and ultimate recovery of gas. The use of vacuum operations will afford everyone equal opportunity to recover their fair share of gas underlying their property and thus will be protective of correlative rights. As Mr. Kohler further explains in his testimony, the nature of the Antrim Shale formation is such that vacuum operations will present no risk of damage to the reservoir. 6. As is set forth in the pre-filed testimony of Nelson R. Fairchild Jr. and Daniel Cooper, which will be filed in this matter, Applicant will operate the wells in a manner that will be protective of the public health, safety and welfare. Well casings, well heads, piping components and compressors used in connection with vacuum operations will be of sufficient strength to be suitable for vacuum service. Oxygen and vacuum pressure sensors will be used as appropriate to detect the leakage of air to a well or related piping and to shut down a system until any leak is located and repaired. 7. Applicant will comply with all applicable provisions of the Michigan Department of Environmental Quality Oil and Gas Rules and Regulations as well as the Michigan Public Service Commission Gas Safety Standards. 2

4 8. Notice of the filing of this application will be provided to adjoining operators as directed by the Michigan Public Service Commission. WHEREFORE, Applicant respectfully requests that the Commission, under the authority of administrative rule R and 1929 PA 9, approve Applicant s operation of natural gas wells under a vacuum within the area described in paragraph 3 and grant such other relief as is just. Respectfully submitted, MIKA MEYERS BECKETT & JONES PLC Attorneys for Applicant Dated: April 29, 2008 By: William A. Horn (P33855) 900 Monroe Avenue, NW Grand Rapids, MI (616) H:\WAH\CLN\Vacuum Operations Group.34614\Vacuum Operations.34289\BreitBurn-Terra\MPSC Application Terra-Corwith.doc 3

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