Does anyone have a suitable template we can use to object to P17 filings?
RRC will accept a letter which details all the reasons for your protest, with relevant exhibits attached. Letter should cite the P-17 (with copy), names of protesting owners, list of wells. You need to be clear about your exact reasons - such as commingling is not allowed under your lease (with copy of lease) or that RRC records are incomplete or conflicting with check detail or production filings. At the end, you need to state that you are asking for the permit to be denied or for RRC to schedule a hearing so you can present evidence in support of your request for denial of the P-17. Protests are rare so the RRC does not have a system to handle this kind of protest. RRC will ask the parties to come to a resolution. I expect you will need an attorney if you have to go the hearing route.