Comstock filed for two drilling permits to day:
Surface location of the two wells is 8.2 miles NE of Franklin. This is 0.4 miles from the surface location of Comstock’s first Robertson County well, the Circle M Allocation 1H. This is Comstock’s first Robertson County permit submission since March 2025.
The plats indicate these will be stacked laterals. Will be interesting to see the vertical separation.
Is this a new drilling strategy for Comstock in regard to deep horizontal wells in this part of East Texas? Might it indicate that Comstock’s petroleum geologists are now seeing two distinct reservoirs/source rocks at depths where they are drilling?
Comstock has already drilled at least one other set of stacked laterals in this play (in Leon County I believe). My understanding is that the Bossier/Haynesville potential pay area is more than 3,000 feet thick in some locations, so there are multiple possible landing zones.
Dang those are some thick zones of natural gas.
I’m having a heck of a time with locating my interests re the Leon- Bossier prospect. I have leases in regard to this that started in 2006 then released in 2012. Now I am getting offers in regard to my Haynesville mineral rights. I’m trying to tie all this together. I’ve enlisted help but I’m not sure if they are up to the task. I have the abstracts in question. The ownership goes back more than a century. Im am waiting on copies of royalties checks etc from crest and Chesapeake as I’m not sure I’ve saved everything in the last 23 yrs.
This well will follow along the other side of my fence line several hundred feet away. I guess that means I won’t see anything from this well but my neighbors on the opisite side of the road are in the PLAT. Hopefully Adamas (formerly Aethon) will come back to Robertson County and put us in a second well.
Do you know your Block, Abstract Name and Number and the Section numbers? If you have them, then you can located the general areas on the Texas Railroad Commission GIS map.
Alan or Martha: Do you, or anyone else who reads this, know whether a permit is required to perforate and frack a well that is currently an unperfed completion? Over the past few months Hilcorp has been applying for drilling permits to re-complete some horizontal wells that they acquired from XTO in Leon County. My family has some mineral rights in a horizontal well (API 28932178, Blazek-Pullen 2H) that XTO drilled but left as an unperfed completion in 2020, shortly before Hilcorp acquired it. A few other wells in the vicinity are in the same situation. If Hilcorp doesn’t have to request a drilling permit, is there any other public filing that would precede perfing and fracking the well?
That’s a really good question! I posed it to grok, the ai assistant, and here is the response I got:
Yes, they generally need to address permitting through the Texas Railroad Commission (RRC), but it typically does not require a entirely new “drilling” permit if the original one is still active and unexpired. Instead, they would likely file (or amend) under the existing framework for completion/recompletion.
Key points from RRC rules and procedures (governed primarily by Statewide Rules and Form W-1 processes):
Original drilling permit (Form W-1): This is an “Application for Permit to Drill, Recomplete, or Re-Enter.” For a drilled but unperforated/uncompleted (often called DUC or “unperforated completion”) horizontal well, the original W-1 permit covers the wellbore. If it has not expired (typically valid for 2 years from approval, with amendments not extending it), and no completion report (e.g., Form W-2 or G-1) has been filed to “close” it, the new operator can often proceed with completion activities under that permit once operatorship is transferred.
Operator transfer: The new company must file a Form P-4 (Producer’s Transportation Authority and Certificate of Compliance) to become the operator of record. This transfers responsibility. For inactive/uncompleted wells, there may be additional compliance timelines (e.g., 6 months under rules like HB 2259/Statewide Rule 15 for inactive wells), but an unperforated drilled well is often treated as having an open permit rather than being fully “inactive” in the plugging sense.
Completion activities: Perforating, hydraulic fracturing, and final completion do not usually require a brand-new W-1 if the original permit is open. However:
If the original permit has expired or been closed (via completion report), a new Recompletion W-1 is typically required.
Changes (e.g., to depths, fields, restrictions like No Perforation Zones/NPZs common on horizontal permits) often need an amendment or new filing.
A completion report (W-2/G-1) must be filed within 90/150 days after completion.
Supporting requirements: Expect to handle P-16 (acreage designation, especially for horizontal/UFT fields), plats, SWR 13 groundwater protection, potential exceptions (e.g., SWR 37/38 spacing), and other standard filings. The new operator must have an active P-5 Organization Report and financial assurance.
Recommendation: Contact the RRC Drilling Permits Unit (drillingpermits-info@rrc.texas.gov or 512-463-6751) or the relevant District Office with the specific API/well details for confirmation, as it depends on the status of the original permit (open/expired, any restrictions). Practices can vary slightly by district or well specifics. Unperforated wells are common (tracked in RRC data), and operators routinely complete them after transfer without starting from a full new drill permit when the wellbore permit remains valid.
This is not legal advice—regulations can have nuances, and official RRC guidance or a regulatory consultant is best for your exact situation.
For a horizontal well in shale, if they don’t frac in a zone, there won’t be much chance of production.
Thanks very much for this information. I will try to find out whether the original permit is still open.
Alan, what AI app that you have found that is User friendly for oil and gas research?
I’m no expert on that subject. I’ve been using grok because it’s easy to use. You should check with poster ai_land.
The recommendation to contact the RRC drilling permits office was a good one. Ownership of the permit was simply transferred from XTO to Hilcorp, so the permit remains open. Hilcorp can perforate and frack without filing an amendment if the well remains in the Bear Grass. It looks like the only way to know if Hilcorp is planning to or has begun to perforate and frack the well is to see the work actually being done. I’m guessing that their schedule for fracking in this part of Leon County is what could be slowing down their actual completion of the well.