El Paso Production Company v. Valence Operating Company

CourtCourt of Appeals of Texas
DecidedMarch 20, 2003
Docket01-01-00195-CV
StatusPublished

This text of El Paso Production Company v. Valence Operating Company (El Paso Production Company v. Valence Operating Company) is published on Counsel Stack Legal Research, covering Court of Appeals of Texas primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
El Paso Production Company v. Valence Operating Company, (Tex. Ct. App. 2003).

Opinion

Opinion issued March 20, 2003




In The

Court of Appeals

For The

First District of Texas





NO. 01-01-00195-CV





EL PASO PRODUCTION COMPANY, Appellant


V.


VALENCE OPERATING COMPANY, Appellee





On Appeal from the 270th District Court

Harris County, Texas

Trial Court Cause No. 99-25806





O P I N I O N

           El Paso Production Company, the successor in interest to Sonat Exploration Company (together, Sonat), owned a working interest in the Holmes A-1 Well (the well) in Freestone County, Texas. Sonat sued appellee, Valence Operating Company (Valence), for breach of a joint operating agreement (the JOA) under which Valence was the operator and Sonat was one of the non-operators. After a jury trial, the trial court entered a take-nothing judgment against Sonat, and Sonat appealed. We reverse and remand.

BACKGROUND

           Texas Oil & Gas Corporation and the owners of oil and gas leases and interests entered into a JOA for the exploration and production of oil and gas from a 680-acre contract area in Freestone County. The well was drilled on that contract area under the JOA. The JOA provided that, if any party to the agreement desired to rework, deepen, or plug the well that was drilled at the parties’ joint expense,

[That party] shall give the other parties written notice of the proposed operation, specifying the work to be performed, the location, proposed depth, objective formation and the estimated cost of the operation. The parties receiving such a notice shall have thirty (30) days after receipt of the notice within which to notify the parties wishing to do the work whether they elect to participate in the cost of the proposed operation.


The JOA further provided that the parties electing to participate in the proposed operation (consenting parties) would receive, in proportion to their respective interest, the share of production of any party not electing to participate (non-consenting parties) until the non-consenting parties’ share was equal to “400% of that portion of the costs and expenses of drilling, reworking, deepening, or plugging back . . . which would have been chargeable to such non-consenting party if it had participated therein.”

           Regarding the sale of the oil and gas produced, the JOA granted each party the right to take its proportionate share in kind. In addition, the JOA provided,

Operator shall have the right, subject to the revocation at will by the party owning it, but not the obligation, to purchase such oil and gas or sell it to others at any time and from time to time, for the account of the non-taking party at the best price obtainable . . . .


The JOA also provided, under “Maintenance of Uniform Interest,”

For the purpose of maintaining uniformity of ownership in the oil and gas leasehold interests covered by this agreement, and notwithstanding any other provisions to the contrary, no party shall sell, encumber, transfer or make other disposition of its interest in the leases embraced within the Contract Area and in wells, equipment and production unless such disposition covers either:

1.the entire interest of the party in all leases and equipment and production; or

2.an equal undivided interest in all leases and equipment and production in the Contract Area.

Every such sale, encumbrance, transfer or other disposition made by any party shall be made expressly subject to this agreement, and shall be made without prejudice to the right of the other parties.


           The JOA included a Gas Balancing Agreement, which provided for any period when a party had no market for its share of gas, its purchaser was unable to take the gas, or the party failed to take the gas. In that event, the other parties were entitled to produce each month 100% of the allowable gas production, and each of those parties was to receive its pro rata share. The party who was unable to take or market its share “shall be credited with gas in storage equal to its share of the gas produced,” and the operator was to “maintain a current account of the gas balance between the parties . . . .” When the party began to take its share of the gas, the party could take, in addition to its share, 25% of each “over-produced party’s share of gas produced.” If production permanently ceased before the accounts were balanced, the accounts were to be balanced through a monetary settlement.

           Valence succeeded to the rights of Texas Oil & Gas Corporation, which was the operator under the JOA. Sonat acquired a 17.58407% non-operating working interest in the well. Houston Lighting & Power Company (HL&P) was, and is, the owner of the surface of the land.

           In 1993, HL&P, needing to enlarge its ash disposal area, began negotiations with Valence to acquire access rights to a tract of land within the unit. The negotiations were unsuccessful, and HL&P informed Valence that HL&P would pursue efforts to purchase rights of the individual mineral interest owners and would also proceed with a condemnation action.

           HL&P offered Sonat $204,000 for the release of Sonat’s surface rights to a 91-acre tract at the well site. Sonat accepted the offer and, on November 14, 1994, executed the following release:

That the undersigned, who owns or claims a working interest or leasehold estate in the mineral estate presently being produced in the Marcus Holmes “A” Gas Unit . . . hereby: 1) releases Houston Lighting & Power Company (“HL&P”) from any and all claims for compensation . . . directly or indirectly resulting from the acquisition by HL&P of the right to utilize the surface of that certain 91.217 acre tract of land . . . and 2) quitclaims to HL&P all of my right, title and interest, if any, to directly or indirectly utilize or authorize the utilization of any portion of the surface of the Tract for the exploration, development or production of the underlying mineral estate.

The undersigned further, to the extent possible under the terms of that certain Operating Agreement dated October 11, 1979 between Texas Oil & Gas Corporation, as Operator, and Seneca Resources, assign to HL&P the right to cause or otherwise authorize the Holmes A#1 Gas Well, which is presently being operated on the surface of the tract, to be plugged and abandoned, provided that such well shall not be plugged and abandoned prior to December 31, 1995.

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Bluebook (online)
El Paso Production Company v. Valence Operating Company, Counsel Stack Legal Research, https://law.counselstack.com/opinion/el-paso-production-company-v-valence-operating-com-texapp-2003.