SEC Company Response from DYNAMIC OIL & GAS INC (CIK 0000847535) — Aug 9, 2005
DYNAMIC OIL & GAS INC (CIK 0000847535)
Date: Aug. 9, 2005 · CIK: 0000847535 · Accession: 0001062993-05-001829
AI Filing Summary & Sentiment
Referenced dates: July 20, 2005
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CORRESP
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Filed by Automated Filing Services Inc. (604) 609-0244 - Dynamic Oil & Gas, Inc. - Corresp
August 9, 2005
United States Securities
and Exchange Commission
Division of Corporate Finance
Mail Stop 05-05
Washington, D.C. 20549-0405
Re:
Dynamic Oil & Gas, Inc. (“Dynamic”)
Form 20-F for Fiscal Year Ended December 31, 2004
Filed March 31, 2005
File No. 0-17551
Your Letter Dated July 20, 2005 In Review
Of Our July 15, 2005 Response Letter
Dear Sirs:
In connection with the above-referenced comment
letter, our responses are as follows:
Form 20-F for the Fiscal Year Ended December 31, 2004
Engineering Comments
Estimated Reserves of Crude Oil, Natural Gas and Natural Gas Liquids, page 28
SEC comment:
1.
Regarding your response number 6, please provide performance graphs of production versus time for the following wells:
Cypress
St. Albert
00/d-38-E/94-N-9/0
03/13-25-53-26W4/6
00/a-70-F/94-B-15/0
00/06-25-53-26W4/6
00/d-67-F/94-B-15/0
00/15-36-53-26W4/2
02/b-27-K/94-B-15/0
02/03-01-54-26W4/3
Please annotate on each graph the forecasted future production that you
estimated as of December 31, 2003.
Management’s response:
The above-requested performance graphs are attached
to this letter.
SEC comment:
2.
Even though you report reserves under NI 51-101, for U.S. investors please
provide a comparative table and reconciliation narrative explaining any
differences between the estimates using Commission definitions and the National
Instrument 51-101 definitions.
Management’s response:
Management’s response to this comment is prepared
with the assistance of our independent engineering firm, Sproule Associates
Limited. The following comments highlight the key differences between
SEC reserves determined according to SEC and NI 51-101 definitions:
SEC rules require disclosure only of proved reserves. NI 51-101 requires
disclosure of proved and probable reserves;
SEC rules require that proved reserves and associated future net revenue
be estimated under “existing economic and operating conditions”.
NI 51-101 requires disclosure of proved reserves and associated future net
revenue on a “constant price and cost basis”, and of proved, probable
and proved plus probable reserves and associated future net revenue on a “forecasted
price and cost basis”;
Proved reserves assigned under SEC definitions would be most likely, equal
to or greater than, proved reserves assigned under NI 51-101 definitions;
Proved reserves assigned under SEC definitions are those reserves that
can be ultimately recovered using “reasonable certainty”;
Proved reserves assigned under NI 51-101 definitions are those reserves
that can be ultimately recovered using a “90%+ probability”;
Approximately 74% of total proved reserves assigned to Dynamic under NI
51- 101 in Fiscal 2004 were evaluated using decline analysis or analogy techniques.
Such reserves are expected to be less than or equal to those assigned using
SEC definitions; and
Approximately 24% of the total proved reserves assigned to Dynamic under
NI 51-101 in Fiscal 2004 were evaluated using volumetric methods. These proved
reserves are expected to be equal to those assigned using SEC definitions.
Sincerely,
Dynamic Oil & Gas, Inc.
Per:
“signed”
Michael A. Bardell
Chief Financial Officer