Dear Bob,
I was under the impression that the six months began tolling after the date of first production. Is that right?
r w kennedy said:
Shannon, I wouldn't worry about this rule too much. If the operators did not have confidential status, they simply would not report at all. Many of the wellfiles that I have read through have friendly reminder letters from the state that required paperwork is very late. If the operator ignored the state long enough, the eventual fine would probably be smaller than the fine you would receive for driving 10 miles an hour over the speed limit. I think most operators request confidential status when they drill to total depth and the 6 months begins when the request is made. All permits are considered confidential and the 6 months of confidentiality does not truly begin until the operator requests it. I have heard of companies extending the confidential period by not reporting anything to the state and not asking for confidential status until they have fracked the well. Shannon, I understand the frustration and you have my sympathy but I don't think we can make an effective change in this area since we don't even live in the state and the people who make and enforce the rules are bureaucrats and not even elected officials.