Commingle Permit Application

Just received certified letter that says it is a notice of Commingle Permit Application. It says it is provided to give me 21 days notice as they are requesting exemption to statewide rules 26 and/ or 27. Anyone have knowledge about this rule to share? It says it is for offsite storage and separation of oil; and casing gas metering by allocation of test well. Other items are also checked. Thanks for any information and feedback.

I got the same letter today. Hope someone replies with more information.

This means they want to comingle the oil production from two or more wells into a single set of tanks. When they do this they are required to periodically test each well in order to have a basis for allocating the commingled production. The exact requirements should be spelled out in the commingling order.

Doing it this way saves the Operator money, which in turn will make the wells last longer and therefore generate more royalties.

Thank you for the reply. The sampling event is once a year which for newly producing horizontal wells does not seem reasonable.

Is wanting sampling at least weekly the first 18 months (while production is greatest) reasonable or even feasible. I want to make sure I am being paid correctly for the oil and gas leaving the property.

For the operator, they own royalties in all the oil wells being commingled and I don’t. I have no idea if they own the same royalty amount in every commingled well and if that is the case they would receive the same amount regardless of where the oil came from (which lease) and that measurement of the split of oil from each lease is how they pay me.

I agree that once a year is too far apart for new wells, but once a week is probably excessive. Once a month might be more reasonable for the first year then less frequently as the wells become more predictable.