Regulatory and Unit Records
A decision-grade, source-backed study of Montana oil-and-gas change-of-operator record lineage, with reproducible controls, limitations, and land-work applications.
10 official source routes
5 evidence layers
Checked October 2, 2026
How should a land team trace a Montana Form 20 operator change through the listed wells, transferor, transferee, bond condition, Board approval, effective date, and current data?
Montana Form 20 makes the transfer conditional: the transferor remains responsible until Board approval, and the transferee must satisfy bonding requirements. A signed notice, requested effective date, approval, and current operator display therefore represent different events.
This study starts with the Montana Board of Oil and Gas Conservation's official Form 20. The form defines the parties, requested change, listed wells, certifications, proposed effective date, and conditions printed by the agency. It is the primary template for the event being studied, but a blank form cannot prove that a particular transfer was filed or approved. A completed filing and its attachments belong in the Board public-file repository, while the Online Oil and Gas Information System supplies a dated observation of the public well record.
Those sources answer different questions. The submitted Form 20 records what the transferor and transferee asked the Board to recognize. An approval notation or Board record documents agency action. Bond material addresses a condition named by the form. Data Miner shows what the public system displayed when the researcher checked it. The packet keeps these layers separate so a current operator name is not mistaken for the application, the approval, or the effective date.
The well attachment is the center of a Montana operator-change review. Create one row for every listed well and preserve the complete API number as text. Add the lease name and type, county, field, well name, and legal location exactly as they appear. Record the attachment page or row for each transcription. The number of worksheet rows must reconcile to the form's stated well count. Blank identifiers, duplicate API numbers, or a count mismatch are exceptions that require the original attachment or a corrected filing.
Next, query each complete API number in Data Miner and record the displayed operator, well status, lease name, county, field, and access time. This is a comparison, not an overwrite. A current value that differs from the form may reflect an approval, a later transfer, a correction, or a public-system update. The online row alone does not identify which explanation is right. Where available, the Board public file should be searched for the approval or other filing that bridges the two observations.
Record transferor and transferee names exactly as signed, including corporate suffixes. Keep any normalized comparison name in a separate field. If Data Miner uses a shortened name or a different suffix, do not merge the organizations on text similarity alone. The reviewer should look for an agency identifier, organization filing, or Board record that explicitly connects them. This matters because Form 20 concerns responsibility for specifically listed wells, not merely the appearance of a familiar trade name.
The form's bonding language creates another independent control. A transferee signature is evidence of the party's stated acceptance; it is not proof that the Board found the bond adequate. Capture the bond reference, status, or approval locator only when the public file supplies it. If the accessible record contains no bond evidence, label that field unavailable and request the relevant Board record. Do not fill the gap from the current operator display.
The chronology uses labels rather than a single generic transfer date. Preserve execution dates for both parties, a Board receipt date if shown, the requested effective date, a bond-related date, the approval date, and the date on which Data Miner was observed. If the requested effective date precedes approval, list both. The research record should not decide their legal relationship without the governing Board action and professional review.
A second researcher should be able to reproduce the work from the packet. That requires the form version, public-file locator, attachment page, complete API number, Data Miner query path, access time, and a short explanation for every unresolved mismatch. Screenshots without locators are supporting images, not the sole evidence. Negative searches should identify the repository, terms, and date searched so the next reviewer knows what was actually checked.
Montana’s Notice of Intent to Change Operator asks for lease name and type, county, field, each API well number and exact location, transferor, transferee, number of wells, and proposed effective date. Its certifications distinguish intent from approval and explicitly connect the transferee to bonding. A research packet should preserve the signed form as submitted, including attachments, rather than reducing it to a two-column old/new operator list.
Treat the attached well schedule as a controlled population. Count listed wells, retain every API number as text, and compare county, field, lease, well name, and location to the online system. Record missing, duplicate, or extra wells as exceptions. A blanket statement that “the lease transferred” is unsafe when the form identifies wells individually or mixes lease types. The operational question is whether the packet’s population matches the population the reviewer intends to evaluate.
The transferee’s signature shows acceptance of stated responsibility, while the form says approval depends on bonding compliance. That makes a bond reference, Board approval notation, and effective date distinct evidence fields. Do not infer approval from signatures or current operator display. Conversely, a current display can help identify the state of the public system on the access date, but it should not be copied backward as proof of the requested effective date.
Retain the exact organization names and any agency company identifiers shown by the form and online data. Normalize punctuation or corporate suffixes only in separate comparison columns. If a successor uses a trade name in one source and a legal entity name in another, state the difference and seek an organization filing or explicit agency cross-reference. Name similarity alone cannot establish which entity assumed plugging and restoration obligations.
A useful chronology includes execution by transferor, execution by transferee, Board receipt if available, bond evidence, approval, stated effective date, and later online observation. Each date keeps its label. If the proposed effective date precedes approval, show both without deciding their legal consequence. If public files omit an approval page, the gap remains open and the packet requests that specific record.
Imagine a Form 20 attachment lists eight wells, but the current Data Miner shows the transferee on six and the transferor on two. Confirm the complete API numbers and access date, then examine whether the two exceptions share lease type, bond treatment, location, or a separate disposition. Do not revise the attachment or presume delay. The review packet presents an eight-row reconciliation and asks whether approval excluded, deferred, or separately handled the two wells.
The same table can reveal whether the apparent split is a population problem rather than a timing problem. Two records may use an API format or well name that was transcribed incorrectly, or they may belong to a separate attachment. Recheck the filing pages before attributing the difference to agency processing. If identity is confirmed and no public approval explains the two rows, preserve the exception with the exact search path and request the Board record for those wells. The packet should distinguish a failed join from a genuine operator difference.
The second-pass reviewer recounts the well attachment, verifies API and location transcriptions, reopens the Form 20 version, and checks that every approval or bond statement has a locator. They compare the online operator observation without treating it as the approval instrument. Material exceptions include a well absent from the attachment, a mismatched lease type, an entity-name conflict, a missing bond reference, or an effective date with no identified event source.
The study used public Montana Board and DNRC routes and did not inspect a particular operator’s complete bond file, confidential correspondence, or legal authority. Online data may lag Board action, and public files may not contain every attachment. This method organizes evidence for professional review. It does not determine whether a transfer was legally effective, whether bonding was sufficient, who owns a lease, or who bears liability for a specific well.
A sound Montana operator-change history begins with the filed well population and follows each listed API number through the available Board evidence. Party signatures, a requested effective date, bonding material, approval, and a later Data Miner display answer separate questions and keep their own dates. The packet is ready for professional review when the well count reconciles, entity differences are explained or flagged, and every bond or approval statement has a locator. A current online operator can corroborate the result, but it cannot replace the filed Form 20 or the Board action that gives the change its administrative context.
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