Montana oil and mining journal., 1946-12-21
Cobb Calls


corrective statement given publicity
equal to that given the said incor-
rect sta m G n I. We realize, OF
course, that you could not be ex-
pected to be personally familiar
with the oil conservation laws of
all the states mentioned in your
statement and, no doubt you relied
upon information furnished by your
staff of technical and legal advisors
in preparing your address. This
Board has, however, for many years
past. cooperated so closely and fire.
uuently with bureaus and officials
of your department, such as the
Bureau of Mines, Conservation
Branch, Geological Survey and Pc
troleum Administration for War,
that is is hard for me to under
stand why you were not better in
formed as to our conservation laws.
We have had an oil conservation
law in effect ever since December
%. 1893. and an oil and gas well
regulatory law in effect since 1925,
and Operating Regulations" draft
ed in conformity with the last men
toned law, that have been enforced
by authority of the Board of Rail
road Commissioners of Montana
throughout the past twenty years
not always as efficiently as many
operators would have preferred |
must admit, but well enough to
prevent, or soon stop, the most OBJ
jectionable wasteful practices IN
the oil and gas fields and assure,
at least, the proper plugging OF
exhausted wells when producing
operations were abandoned. By way
of proof, | enclose two copies of
each of the above mentioned laws
and one copy of the Operating
Regulations" in current effect, ap-
printed pamphlet form.
After studying these copies of our
laws and regulations in force hope
that your legal advisors will agree
that it was a mistake to brand Mon
tana as one of the oil producing
states without any oil conservation
laws. Constructive criticism of our
laws and regulatory administration
we can, and do, accept in good
spirit. we are conscious of the i'm
perfections of the laws and major
ity of the operators stand ready at
all times to- support sound remedial
legislation and improvements in ad-
ministrative practices. Considering
the difficulties that Montana people
have had to face and overcome in
getting even the small amount of
testing and development of the
states oil and gas resources that we
have had by way of the low prices
for crude oil generally prevailing
in all fields of the state when COM
pared with high development and
operating costs; climatic conditions
limiting steady field work; trans
portatiOn difficulties; discriminatory
freight rates; unstable crude mar
kets for many years, but now i'm
proved by erection of local refin-
cries, think it is not unreasonable
to claim that we have not been too
negligent about adopting oil con-
servation measures and preventing
avoidable waste in well drilling and
producing operations
believe that the field supervisors
for your Conservation Branch and
Geological Survey would agree that
they have always received the CO.
operation of members of this Board
and our employees in the field and
offices in connection with any reg
ulatory and administrative matters
arising in which the federal govern
ment is interested; also, that we dc
not ignore or suppress any com
plants about wasteful or imprudent
drilling or oil producing practices
and our field men are capable and
diligent in performing their duties
On the whole, it appears that
Montana people are entitled to q
better rating on oil conservation
laws than you gave us and / hope
you viii be kind enough to issue q
corrective statement for publica
ton. Governor Sam c. Ford would
appreciate it, / am sure, as he was
the chief legal counselor for the
proponents of our 1888 Oil Conser
vation Board Law, and it was