Pooling Application Exhibit Checklist

A pooling application is usually judged on its exhibits. The form may be complete, the fee may be paid, and the hearing may be scheduled, but a missing ownership schedule, an unresolved tract, or a notice list that cannot be served will stop the application or send it back for correction.

This guide describes an exhibit checklist for pooling and spacing applications. It is an administrative control, not legal advice, a pooling order interpretation, an ownership determination, or a substitute for regulatory counsel or the state commission.

Pooling Application Exhibit Checklist: begin with the jurisdiction

Every state commission has its own form, instructions, exhibit list, notice requirements, and filing channel. Start with the current version from the regulator, not a checklist from a prior project. Record the form number, revision date, filing fee, hearing calendar, and the name of the person who confirmed the requirements.

The same project may need a different packet for a voluntary pooling, a forced pooling, a spacing unit, or an amendment. Do not reuse a prior application without checking the current docket and the current unit description. A form that was accepted last year may be outdated now.

The checklist should have a header with the project, state, commission, application type, unit or tract, applicant, preparer, reviewer, and filing date. Each exhibit row should show the exhibit letter or number, the required content, the source document, the owner, the status, and the reviewer.

Build the core exhibit set

The exact list varies by jurisdiction, but most applications need a core set: the application form, the applicant's authority, the ownership or working interest schedule, the lease or title support, the tract plat, the proposed unit description, the notice list, and proof of service. Some commissions also require an affidavit of publication, a joinder schedule, or a statement of operations.

Use a table that ties each exhibit to the fact it proves:

The table is a starting point; add state-specific exhibits and remove any that do not apply.

Reconcile the ownership schedule to the tracts

The ownership schedule is where many applications lose credibility. The tract numbers, owner names, decimal interests, and acreage must agree with the leases, title support, and unit map. A schedule that totals 100 percent but omits a small tract is still defective.

Build a reconciliation column that shows the source for each interest and the date it was checked. If an owner's interest is disputed, do not force a number into the schedule to make it add up. Show the dispute, identify the reviewer, and decide whether the application can proceed or needs to wait.

The affidavit of heirship document request queue is useful when an ownership gap depends on an estate or heirship document. Keep the two records linked so the application does not stall without a visible reason.

Prepare the notice list and service evidence

Notice is not a mailing list. It is a set of parties, addresses, service methods, dates, and proofs. The list should be built from the ownership schedule and the regulator's notice rules, then checked against the current address record. An owner whose address changed last month may need a new notice even if the prior application used the old address.

Record the notice date, method, recipient, address, tracking number or affidavit reference, and return status. If service is by publication, retain the publisher's affidavit and the publication dates. If service is by certified mail, retain the receipt and the returned envelope. If an owner cannot be located after a documented search, record the search and route the question to the reviewer.

Proof of service should be assembled at the same time as the notice, not reconstructed after the hearing is scheduled. A missing receipt can delay a case that is otherwise ready.

Control versions and filing copies

Pooling applications generate versions: the draft, the filed copy, the amended copy, and the hearing exhibit. Keep each version separate and label it with the date, the exhibit set, and the reason for the change. Do not overwrite the filed copy with a later draft.

Record the filing confirmation, the docket number, the hearing date, and the examiner's requests. If the commission issues a deficiency letter, treat it like a rejection notice: preserve it, assign an owner, correct only what was identified, and track the response date.

Set the authority boundary

The administrator may assemble exhibits, reconcile schedules, prepare notice lists, track service, and maintain the version log. The administrator may not decide ownership, interpret a lease, determine whether notice was legally sufficient, or sign a regulatory certification without authority.

Name the reviewer for the ownership schedule, the legal description, and the notice list. If the application requires a professional certification, confirm who is authorized to sign it before the packet is assembled. A last-minute signature is a common cause of missed filing windows.

Measure completeness before the deadline

Track the percentage of applications with a complete exhibit set at the internal deadline, the number of deficiencies by exhibit type, median days from kickoff to filing, and the age of open ownership or service exceptions. Report the denominator and separate applications that were amended from those filed once.

Review a sample of filed applications after the hearing. Confirm that the filed exhibits match the version log, the service evidence is complete, and the docket outcome is recorded. Feed the deficiency reasons back into the checklist.

A practical launch sequence

Start with one state and one application type. Pull the last five filed applications and map each exhibit to the checklist. Note which items were added late or reconstructed. Those are the controls to build first.

Publish the checklist, the exhibit naming convention, and the reviewer assignments. Train the people who assemble packets and the people who communicate with the commission. Run a pre-filing review at least five business days before the internal deadline. After the first filing cycle, revise the checklist based on actual deficiencies.

For teams that need help assembling exhibits and tracking service, a defined document preparation service can maintain the packet index and the version log. The client keeps ownership, legal, and certification decisions. The Railroad Commission of Texas oil and gas applications page is one example of a state regulator's filing entry point; always use the current instructions for the relevant jurisdiction.

Frequently asked questions

Can one checklist cover every state?

No. The core exhibit categories are similar, but the required forms, notice rules, and filing channels differ. Use the state-specific instructions as the controlling document.

Who should approve the ownership schedule?

The reviewer designated by the client for land and ownership questions. The administrator can reconcile and flag differences but should not decide a disputed interest.

What if an owner cannot be served?

Document the search, follow the regulator's rules for alternate service, and route the question to the reviewer.