OEPA Oil and Gas Tax Benchmark Analysis

OEPA Oil and Gas Tax Benchmark Analysis

The following PowerPoint presentation illustrates research findings conducted by WPA Intelligence in a statewide study among 2018 likely voters in Oklahoma regarding the oil and natural gas industry. Specifically, this research demonstrates strong support for the restoration of the Gross Production Tax to 7% on all oil wells, preferred areas for the funds from the tax to be spent, and the impact the oil and natural gas industry has on Oklahoma.

 

PowerPoint Presentation:

<OEPA Oil and Gas Tax Benchmark Analysis>

 

 

Top 10 reasons Oklahoma should restore 2% gross production tax rate to 7%. 

Correction:

Representative Jon Echols replied that our last sentence in our top 10 reasons to raise GPT  letter was in need of correction.  We always intend to be accurate and we missed one here.  We said:  “It’s disingenuous to call the negotiation which resulted in the 1% rate going to a 4% rate a tax increase. It was sunsetting and would have gone to 7%. So in practicality, it was a tax  decrease.”   

While there was no intent to mislead, it was a misstatement of the facts that we wish to correct. The negotiation that resulted in the 1% rate going to 4% was additional tax revenue and the 4% rate will still go to 7% after the original 48 months from the drilling of the wells. So the best case scenario is that a well drilled June 30, 2015, would still have a 4% rate for only 24 more months, at which time the rate would increase to 7%.  We stand by our position that this was a trade-off to protect the 2% rate without giving up much in reality.  

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1. Even at 7% GPT, Oklahoma’s effective rate on oil and gas production would still be the lowest overall tax rate of any major oil and gas state. Much of that is due to the fact that Oklahoma doesn’t levy ad valorem tax on oil and gas minerals in place. Almost all other major producing states do have property tax on minerals.

2. Oklahoma is home to two of the most prolific and economic world-class oil and gas players (Scoop and Stack). Public oil company presentations inform us that these Oklahoma plays have the lowest break-even cost (+/-$24.40/barrel). These oil and gas assets will be drilled regardless of a marginal increase in the tax rate.

3. Using companies own reporting numbers rate of returns are as high or higher than in North Dakota (May 2017) – and comparable to Texas; there is no need for a 2% tax rate.

First-year returns reported as:

  • ND Bakken – 40-50%
  • Okla Stack- 100%
  • Okla Scoop-70%

4. Changing the 2% rate to 7% would impact only a small number of taxpayers, most of whom are the same big oil companies that pay the higher rates everywhere else.

5. If having a 2% tax rate is so crucial to big oil company profitability, why aren’t these same companies threatening to pull out of North Dakota and Texas? Why aren’t these companies moving their headquarters or their major drilling operations to Oklahoma? Why aren’t the big oil lobbyists descending on the North Dakota and Texas capitals threatening them with leaving if they don’t lower their rate to 2%?

6. There is absolutely no correlation between tax rates and the rig count! You drill where the oil and gas is!

We get the same economic benefit from a 7% rate as a 2% rate.

7. This tax break for big oil producers vs small, vertical producers is 71.4% (the difference between 2% and 7% tax). Most of this massive tax subsidy goes to out-of-state stockholders, investors, foreign companies (partners) and even foreign governments. So Oklahoma really doesn’t get a significant bump from the multiplier effect of a low tax rate.

8. Horizontal frack jobs are destroying hundreds of marginal, but still profitable vertical wells which pay a 7% rate. (Damage to 451 wells has been documented in Kingfisher County alone!)

9. Horizontally fracked wells recover 60-80% of all the oil and gas within the three-year period of the 2% rate. With low oil prices, we are incentivizing the accelerated taking of a valuable but finite resource at low prices. Whatever happen to conservation and allowables?

10. Bottom line, this massive tax subsidy is a fairness issue. Why should operators of 2,000-6,000 barrel per day wells only pay 2% when low-volume stripper wells, most only marginally profitable at today’s prices, are just hanging on… and must pay 7%?

Speaking of fairness, horizontal drillers championed the repeal of several minor tax provisions which meant nothing to them just so they could claim that their taxes have been “dramatically” raised already. It’s disingenuous to call the negotiation which resulted in the 1% rate going to a 4% rate a tax increase. It was sunsetting and would have gone to 7%. So in practicality, it was a tax decrease.

Your call to action is:

  1. Call Governor Fallin at (405) 521-2342 and ask her to support restoring the 2% GPT to 7%.
  2. Contact your Legislators at  https://okpolicy.org/resources/find-your-legislator/ and tell them to put Oklahoma first and restore the GPT from 2% to 7%.

Thank you for your support. Please share!

The Double “Chumping” of Oklahoma

Big oil companies CEOs fly into OKC in their corporate jets and their $5000 Armani suits and hold press conference after press conference boasting about getting 2000-6000 barrel per day wells. They talk about how the Stack and the Scoop are the best plays in America with the lowest breakeven cost ($24.40 per barrel) and some of the best production rates.

Then they sell the Oklahoma legislature that they’re going to invest billions in taking more of a vital but finite Oklahoma resource at low oil prices; but only if they get to keep a 2% tax rate.

The cruelest and most cynical of all hypocrisies is to brag about how good our resources are but then to scare Oklahoma citizens by threatening that unless they get to pay a 2% tax rate they will take their rigs and go home!

We are waiting to see them tell the North Dakota and Texas legislatures that unless they lower their rates, from 10% and 8.5% respectfully, to 2%, that they will take their rigs away. Honestly, that would generate a good laugh in those states.

We should call their bluff. There are companies trying feverishly to get in on our oil plays.

Now mind you, every stripper well in the state pays 7% and the best rate for new wells anywhere else they drill is 8.3% (10% in North Dakota)!

It’s like we should all bow down and worship them for taking our resources on the cheap while our schools are bleeding teachers and our infrastructure crumbles.

The Oklahoma Energy Producers Alliance, made up of small oil and gas producers living all across Oklahoma, has commissioned a poll that shows that 67% of all likely voters (and 57% of Republican voters) want the 2% raised to 7%.

Our legislative leadership will likely listen to the Daily Oklahoman when they try to compare this poll result to a similar poll result on the sales tax initiative. Thats like saying the Dallas Cowboys have no greater chance of winning the Super Bowl than the Ada Cougars just because they both play football! The sales tax increase would have hit everyone. Restoring the 2% tax to 7% only cost the companies making out like bandits, who have no way to pass the cost on to the voters. This should be a no-brainer!

WC Fields said, ” if you look around the room and can’t spot the chump, it’s you!” The Oklahoma legislature is looking for the chump on a daily basis.

Perhaps it’s them!

We don’t even know if these companies are taking the 5% subsidy and funding their drilling in states where they pay a higher rate than they would here if the tax was restored to 7%.

By the way, to add insult to the injury, they are destroying hundreds of existing vertical wells that were paying 7% with their massive frack jobs! (451 in Kingfisher county alone)

Is there such a thing as being “double chump-ed”?

Mike Cantrell

Co- Chairman of the Oklahoma Energy Producers Alliance

Rebates in Texas would not apply to the wells like they are drilling in Oklahoma

Let us introduce you to Donelle Harder. She is the VP of the Big oil association in Oklahoma.

Below you’ll find her comments to a guest post (link) from a former industry insider who advocated for 7% GPT across the board and our response. Please reprimand us if we ever try to pull the wool over the public eyes like this.

They know that the rebates in Texas have no effect on the wells like they are drilling here.

The same similar rebates which we gave up voluntarily in Oklahoma last year also didn’t apply to their new horizontal wells; just to ours!

It’s time they put their skin in the game and agree to a 7% tax rate, which is still lower than the effective rate anywhere else they drill; and pay our teachers.

Donelle Harder:

In the meantime, here are all the different rates and incentives Texas offers for the gross production tax rate, so that people can look into it themselves. Oklahoma has ended all 11 gross product tax rebates over the past three years. As of July 2017, there are ZERO rebates to GPT in Oklahoma, unlike the several offered by Texas that drive down the overall rate of 7.5% to 3.7%. https://comptroller.texas.gov/taxes/natural-gas

 

 

Donelle, in full disclosure, folks should know you are the VP of the big oil lobby in Oklahoma.

Your response cannot have been sent from a position of a lack of knowledge. So it’s purpose must have been to mislead and confuse.

Yes, there are rebates in Texas. But none of them would apply to the wells drilled in Texas like are getting the 2% rate in Oklahoma. The rebate on gas is only on pure gas wells – those not coming off oil wells- and only then if the well makes less than 90mcf per day.

Virtually none of the horizontals being drilled in Oklahoma meet this criteria as they are either oil wells producing casing head gas or high condensate wells. And they make more than 90 mcf per day for the 3 years they get the 2% rate. On oil, the Texas rebate is virtually irrelevant. It only applies to wells making less than 15 barrels per day and then only if oil is less than $30 per day for three consecutive months.  This entire argument is bogus!

But you know that! You just think Oklahomans are too uneducated to figure it out; which they will soon be if we continue to bleed teachers and fall even further behind in the education of our children.

We are on opposite sides of this issue but it is painful to watch an important segment of our industry using messages that are blatantly wrong hoping no one notices.

We want you to be better than that.

What the 2% rate is costing Okla in tax revenue

Article  in the IHS Drilling Wire

Here is an example of what the 2% rate is costing Okla in tax revenue in just 2 sections,- and that’s at $45 oil. This is almost criminal!! It also demonstrates how difficult this is to put in plain language every day Oklahomans can understand. Oklahoma reminds me of the brother Esau in the Old Testament story of Jacob and Esau. As I recall he sold his birthright for a bowl of stew.  We are selling our states birthright on the cheap!

OEPA

 

This article was sent to us by Steve Altman, a Petroleum Engineer and President of Brown and Borrelli Inc.

Article is from August 25, 2017, Volume 64, No. 164, page 5:

IHS Copyright and disclaimer, 8-25-17 <link>

 

Couple this with the previous article from July 14, 2017, volume 64, No. 134, page 1:

Devon frac density <link>

 

It talks about the Devon well completed for 6000 BOE/d.  On the second page, next to the last paragraph, Devon talks about their increased density pilot (Showboat) coming up in the third quarter where they plan to drill 25 – 2 mile lateral wells in sections 3 and 10 T16N R9W, landing in two upper Meramec intervals, one lower Meramec interval, and the Woodford.  This would make 6 wells per level, which would match their talk at the SPE luncheon a couple of months ago where they indicated 5 wells per landing zone, in their opinion, was not enough.

When you figure 25 wells and the payment is $2500 per acre, you are talking about $100 per acre ($200 for the 2 mile lateral) for a well that is making 6000 BOE/d.  That is a heck of a deal for them.

And the State of Oklahoma keeps taking it in the shorts on taxes.  Assuming $10,000,000 per well cost, and assuming the wells only break even, which takes $13,000,000 after taxes and royalty and operating, the gross income is $325,000,000.  The 5% GPT we lose is $16,250,000 in just these two sections, with 50% to 75% of that coming in the first three years.

It once again confirms what Joe Warren and others have been shouting from the rooftops: Forced Pooling is being used to artificially hold down lease prices.

Since the STACK play is now being talked about as an equal in quality to the Eagle Ford and Permian plays, the only difference in prices is Forced Pooling in Oklahoma.

By a factor of 10 or more!!

Steve Altman

 

OIPA demands Dewey Bartlett Jr.s Resignation

The Disintegration of a Petroleum Association

 

Dewey F. Bartlett Jr. Is a lifetime OIPA board member, former mayor of Tulsa, Former Chairman of OIPA, Former Chairman of the Oklahoma Energy Resources Board, former Chairman of the National Stripper Well Association and a leader in the Oil and Gas industry in America. For OIPA to demand that he resign his “lifetime” position on the board would be like asking Will Rogers children to give up their Oklahoma heritage.

 

Dewey Bartlett Sr. was the Governor and U.S. Senator of Oklahoma as well as a founding board member of the OIPA. The late Senator Bartlett coined the term “stripper well” in the American consciousness and passed significant legislation to save Oklahoma’s valuable natural resources.

We have no quarrel with the OIPA, even though we disagree on their responsibility to our state and to its conventional legacy producers. We might suggest they change their name to more adequately reflect who they represent to the “Oklahoma Horizontal Well Association.”

 

Click here for Letter from Wigley

 

Click here for Wigley Response

It’s Not Fake News. It’s Just Not Quite Accurate News.

Recently Adam Wilmoth at the Daily Oklahoman wrote a very well written piece on the landmark benefits of legislation (SB867) that allows horizontals drillers to drill laterally for more than a mile, for the first time ever: Oklahoma oil fields gain recognition.

 

The article touts as facts two assertions that we question.

 

  1. The first assertion is that now companies can drill 2 miles laterally in any formation for the first time ever. That is just not factual.

 

  1. The article also asserts that this bill will create a tremendous economic boom for our state. We believe that to also be inaccurate.

 

It is accurate that horizontal drilling combined with massive Hydraulic Fracking has allowed us to produce more oil and gas “quicker “creating another “boom” in the Oklahoma oil fields. (This is with $40 oil and a 2% tax rate but that’s another subject)

 

That has already happened; before the “so called” long lateral bill.

 

Horizontal drillers could already drill two miles in any formation- and many did. All they had to do was to stack a 320 acre tract on top of another 320 acre tract to create a rectangular 640 acre unit that is two miles long but only 1/2 mile wide.

 

So, if the industry wanted to drill a 2 mile lateral and they could already, why did we need legislation?

 

The answer is legislation wasn’t needed to drill 2 mile laterals. Legislation was needed to take more than 640 acres at a time by a process that only occurs in Oklahoma known as “forced pooling”.

 

So, SB 867 was not a “drill long laterals” bill. It was a “get more acreage bill”.

 

What they can do now that is different is take twice as much acreage as before using the power of the state to “force pool” (which is like subsurface eminent domain executed by the state for private interest).

Let us explain.

 

Oklahoma is the only state that has a process that allows drillers to use the state to set values and terms for mineral acreage. In all other states terms are negotiated between mineral owners and drillers.  That is why Texas mineral owners get up to ten times more for their comparable minerals and a larger percentage of the production than in Oklahoma. You cannot force a mineral owner to let you drill in Texas. You must come to terms. Texas mineral owners are not smarter or better negotiators than we are, they just get to make deals without state interference.

 

Oh, one more slight correction. The article asserts that this new ability will generate tremendous economic growth.

 

How does it generate more economic benefit when it requires fewer rigs, which means fewer jobs, allows drillers to hold more acreage without paying mineral owners more, and even results in fewer wells drilled and less acreage drained?

 

We are sure you could pay for some study to show how that works, but it seems to defy common sense.

 

OEPA

 

Another Battle is Indeed Looming

 

OIPA calls for Campaign for 2% rate

As posted below, the OIPA has a new call to their membership to fund a campaign to make sure they keep the “special 2% “ rate on new wells. They say they want to raise money to put a new face on the industry!

They’ve put a ” new” face of the industry in Oklahoma alright – one of destruction of property and greed.

It is disheartening to see so much of the work so many of us have done over the last 30 years to improve our relationship with the Oklahoma public goes down the drain so fast.

The OIPA we belonged to put our state’s interest at least on par with our own.

Setting the priority of protecting a 2% tax rate that is so obviously low, especially in light of our states serious budget deficits, simply is an indefensible position – even more so when considering that the historical rate of 7% is lower than in any other horizontal drilling state in the US.

Our industry should lead by example, relinquish the special 2% rate, and ask that other tax give always be abolished as well.

Government should stick to funding it’s core functions. The marketplace should pick winners and losers in business.

Oil and gas industry Leadership should put civic responsibility ahead of our own special interest, especially when we have become a big part of our funding problems by getting the legislature to approve the lowest -in – the-nation- Gross Production tax at the expense of our children, our state’s infrastructure, healthcare, and safety net.

Join with us at the Oklahoma Energy Producers Alliance ( okenergyproducers.org).

Let’s put on “our Oklahoma hat” and lead by example, return our state to fiscal sanity and start by restoring the Gross Production Tax from 2% on new wells to the historical rate of 7% that 86% of producers and royalty owners already pay. Only then will our states largest industry have the moral standing required of civic leadership.

Read the OIPA Newsletter…

 

 

ANOTHER BATTLE IS LOOMING AND WE NEED YOUR CONTINUED SUPPORT

In the past week, I’ve had the privilege to meet with Oklahoma’s legislative leadership to discuss current trends in the state’s oil and natural gas industry as well as the upcoming 2018 legislative session AND the potential special session this fall.

With the Oklahoma Supreme Court rejecting the 2017 tobacco “fee,” it’s becoming clear that there will likely be a special session sometime this fall to deal with the budget shortfall. The court has yet to rule on the excise tax issue, but if they rule it as unconstitutional, the budget hole will be even greater.

What does this mean? Once again there will be cries to raise the gross production tax on oil and natural gas development. Our legislative team fought all session long to protect our drilling tax incentive on new wells which places the incentive rate at 2 percent for three years. After the three years, these wells go to 7 percent. This tax incentive has helped Oklahoma companies stay competitive and attract additional capital investment.

In recent weeks, you should have received your membership renewal invoice for the 2017-18 year. I respectfully request that you consider continuing your generous support of OIPA’s efforts to protect you and your business. I would also like you to consider an additional commitment for a new and aggressive public education campaign that will help put a “face” on our great industry.

Your OIPA team works hard every single day to ensure that the interests of our great industry are protected and promoted among policy makers at both the state and federal level. The more resources we have – the more effective we can be for you!

This past spring, OIPA led the way to pass historic legislation to allow for long lateral drilling. This will lead to incredible investment in Oklahoma production. We also led the way in protecting your gross production tax rate to incentivize new drilling in Oklahoma.

There is no other group in Oklahoma that represents the oil and natural gas industry better than OIPA. We like to call ourselves THE ASSOCIATION!

So please consider completing your membership renewal and send it in so that we can continue to fight for you. If you can add an additional amount to your membership dues, your efforts and commitment will be greatly appreciated.

I deeply appreciate your support of our efforts and we look forward to another great year in your service.

Tim Wigley
President OIPA

Hydraulic Fracturing

HYDRAULIC FRACTURING
Small producer wins verdict against Devon in ‘frack hit’ case

An Oklahoma jury has awarded $220,000 to a company that says hydraulic fracturing of a horizontal oil well damaged its conventional oil well.

Advocates for vertical well owners called the verdict against Devon Energy Corp. a significant victory in the bitter fight between small producers and large independents in the state.

“This might just open the floodgates of justice for producers who have lost wells to horizontal fracking,” said Mike Cantrell, legislative director and board member of the small producers’ group, called the Oklahoma Energy Producers Alliance.

Small companies operating vertical wells have filed numerous lawsuits in Oklahoma against larger independent producers that drill long horizontal wells nearby. The small companies say their wells have been damaged by the high-pressure fracture treatments performed on the horizontal wells. The fight has also spilled into the state Legislature.

Devon, based in Oklahoma City, declined comment on the verdict, first reported by OK Energy Today.

The jury sided with H&S Equipment Inc. of Oklahoma City on private nuisance and “subsurface trespass” claims but with Devon on claims of negligence. H&S had said it suffered $2.5 million in damage for the profits it would have made from the damaged well and the costs of plugging the well and drilling a new one.

H&S had a conventional vertical well in Blaine County, Okla., that had been producing oil since 1981. In August 2015, Felix Energy of Denver fracked a well nearby. Devon bought Felix assets in the area in a deal announced in 2015.

In fracturing, water, sand and chemicals are pumped at high pressure into a well to crack open rock and release oil and gas. H&S alleges the frack fluid shot past the area where Felix was to produce and toward the H&S production area.

The day after, the frack fluid started erupting from the well into the air, H&S alleged, as a result of what’s called a “frack hit.”

The frack hit caused serious damage, H&S claimed in the suit, “ruining the well and rendering it incapable of producing oil and gas.” H&S alleged that Felix had fracked “recklessly.”

Devon attorneys argued that Felix had “fully complied” with the rules of the state oil and gas regulators at the Oklahoma Corporation Commission.

They also argued that Felix had not been reckless.

“If a ‘frack hit’ occurred, it was at most inadvertent, and Felix’s engineers did not consciously disregard the risk,” Devon attorneys wrote in a motion, saying fracking fissures are hard to control.

They cited a previous ruling that the cracks created by fracking are “of immeasurable length and uncontrollable direction.”

 

Mike Soraghan, E&E News reporter

Published: Thursday, August 17, 2017

Sharing Our Thoughts

OEPA:
This is a message from one of the 3000+ small Oklahoma oil and gas producers that we are trying to protect. He asked to remain anonymous because he doesn’t want to offend the handful of companies doing this work that will even consider negotiations to pay for the damage they have done. Most say “sue us”.

AUTHOR:

I am a Small oil and gas producer from Kingfisher County. I would like to respond to the recent Journal record article where one of the horizontal fracking associations tried to gloss over the damage they are doing in the stack and scoop plays talking about all their “so-called” community service.

To start this off with I would like to state that I am part of a small family owned oil and gas company in the middle of the stack play. I have no problem with horizontal drilling, in fact, I believe it is a great tool to unlock reserves on the “tight” shale and lime stone zones. I have seen many wells drilled in these “tighter” formation and coexist and just fine with existing vertical wells and be “good neighbors” Where the problem lies is drilling these wells in the very loose, or porous, zones. This is where the good neighbor issue comes to play, in my opinion, with in the oil and gas industry.

I am going to start off with what I am seeing from a community side first then transition to the oil and gas side.

So, from the article, it appears that the major oil companies and the cronies in the OKOGA got together and put on a pig show for kids in Kingfisher. That is 20 miles from me and I heard 0 about this event. Granted, I don’t run in those circles but you would think word would get out about some “huge” pig show 20 miles away.

I want to start this good neighbor debate by comparing the Horizontal industry to the Wind Industry that is also active in my area. The wind company came into our area and rocked all the roads they plan on using to build the farms. They run water trucks up and down the roads all day to cut down on dust. The wind farm company is also very strict on their drivers when it comes to driving the county roads. They don’t tolerate the nonsense that happens on county roads. You get caught messing up, you’re fired. The company that is putting in the wind farm even donated to the town for their fireworks show this year.

Contrast that to the big oil companies drilling around here. They leave these roads in much worse shape than they were before they were drilling. Sure, they might put a little rock down in some spots but the pot holes in those roads are awful. The rock, sand, and water haulers fly up and down these county roads. They are giving any warm body with a CDL a truck to drive and letting them run free. They are constantly running people off the road and tearing up the county roads. Good luck getting them to fix it, too. The only way you get them to fix it is if it is too muddy to get an oil truck in. I know several roads around here that are almost impassable because of the holes beat in them from the truck traffic.

As far as financial help the major oil companies drilling around here have yet, to my knowledge, to donate to the town or school. There is a local Frac company that is donating to the town and school but that is it. The actual companies doing the drilling have not given anything financially to the local community. If you were to get the donor list from the local, school, church, or town event, you not see any major horizontal companies that are drilling in the area but countless local companies, many of them being the mom and pop oil companies that are getting ran out of business because of the number of wells that are being ruined by the horizontal drilling in porous lime stone formations. Because of this, the donor list will soon be shrinking at the local level and people will begin to wonder what happened, by then it will be too late. The majors will have come, filled their pockets, and left; leaving us to once again fend for ourselves and pick up the pieces.

The next part of “being a good neighbor” is not coming into a community and getting family, neighbors, and old friends to sue each other over minerals and stripper wells holding up leases so the majors can get their leases cheaper and easier and not have to worry about protest at the commission from the small producers already here. When I first started out in this industry 10 years I had countless mineral owners thank me for keeping their wells going while all the majors were leaving so they could still have a little “mailbox money”. I have even had a couple older ladies thank me for trying to fix their wells while in tears when I was plugging the wells on their lands because the old well was just too far gone to repair. Fast forward to the last 3 years and those same people are suing the small companies, being pushed to do this by the leasing agents of the majors with the promise of a “large” lease bonus when in reality it is actually less than they would have to pay the small producer that already bought the lease years ago.

Finally, being a “good neighbor” would be to right the wrong and fairly compensate your neighbor when you ruin their property. The small producers have been through the ups and down of the industry and kept that little stripper well going so you can drill the horizontal well, that in most cases the small producers were forced into through force pooling. When the major companies Frac that horizontal well it waters out the stripper well essentially killing it. When this happens, the small producer is left with nothing but a hefty plugging bill. When they approach the larger companies they are basically told, not our problem – sue us. This is very rare and option since the small producers most likely Don’t have the money to spend on 1 attorney, much the less multiple attorneys it would take to take on the big oil companies and their team of lawyers. Occasionally you hear of companies working out these differences but they are settling for pennies on the dollar for the same reason I mentioned above.

All of that being said, once again, I am not slamming horizontal drilling as a whole, I believe it is a great thing when applied in the proper place. I do believe that drilling these wells in depleted zones already being produced by vertical wells for 30-50 years prior is an awful idea and that is where the problems are lying.

Thank you for listening…

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