No completion test filed in Tx RRC

What happens in Texas when a company won't file a completion test on a well that has been producing in Texas for about 10 months? They have filed the 3rd permit on the same well 3 different times in the past year.

It appears that they are trying to permit as a gas well when 98% of the production has been oil!

This would allow them to increase the unit size by 2/3 and HBP acreage. They are trying to get it in a field that is many miles away in order to produce from two separate formations in a vertical well at the same time. This is East Texas. The field designated is the Ft. Trinidad Field.

Houston County, Texas

I believe the fines were set in the bad old days and are probably irrelevant today. Fines need to be attention getting but which oil producer is going to pay attention eo a $250 fine, if it's even that much? It would probably cost the state more to collect the fine than the amount of the fine. If someone knows the exact amount of the fine involved, I'd be curious to know.

It looks to me like a company can try to permit any field they choose and it's likely that the Texas RRC even cares. It's just a formality. The two leases in the current production unit specifically don't allow for this size unit at the depth that it is producing from. IF the RRC allows them to classify it in the FT. Trinidad field, it will require that the unit be 640A or near that acreage. This is the reason I think that they are trying to classify it in that field. They can HBP more acreage and not have to re-lease or pay the 2 year option terms. All to their advantage!