SEC Comment Letter for CNX Gas CORP (CIK 0001335793) — Nov 28, 2005
CNX Gas CORP (CIK 0001335793)
Date: Nov. 28, 2005 · CIK: 0001335793 · Accession: 0000000000-05-059596
AI Filing Summary & Sentiment
File numbers found in text: 333-127483
Letter
November 22, 2005 VIA FACSIMILE and U.S. Mail FAX NO. (412)-562-1041 Mr. Nicholas J. DeIuliis Chief Executive Officer CNX Gas Corporation 1800 Washington Road Pittsburg, PA 15241
Re: CNX Gas Corporation Registration Statement on Form S-1 Filed August 12, 2005 and amended October 27, 2005 File No. 333-127483
Dear Mr. DeIuliis:
We have completed the engineering review of your response letter and amended registration statement and have the following comment. Where indicated, we think you should revise your document in response to these comments. If you disagree, we will consider your explanation as to why our comment is inapplicable or a revision is unnecessary. Please be as detailed as necessary in your explanation. In some of our comments, we may ask you to provide us with information so we may better understand your disclosure. After reviewing this information, we may raise additional comments.
Please understand that the purpose of our review process is to assist you in your compliance with the applicable disclosure requirements and to enhance the overall disclosure in your filing. We look forward to working with you in these respects. We welcome any questions you may have about our comments or on any other aspect of our review. Feel free to call us at the telephone numbers listed at the end of this letter.
1. Paragraph three in your response 13 states, "[Schlumberger Data & Consulting Services] feel this ending decline rate [4 percent] is justified based on the performance of the older 80 acre wells in the project, the performance of other CBM wells in the Appalachian Basin, and has confirmed this using simulation models." With a view towards possible disclosure, tell us how many 80 acre wells have demonstrated a 4 percent or less terminal decline rate and how you determined that this could be reliably applied to all your vertical CBM wells. Include the recovery efficiencies required by this decline rate projection. Address whether you have applied this decline rate to your 40 acre infill PUD locations and, if so, tell us the estimated recovery efficiency thus required. Compare this methodology with that of Ralph E. Davis Associates which produced a decline rate nearly twice as large.
Closing Comments
As appropriate, please amend your registration statement in response to these comments or provide us with a written response within ten business days of your receipt of this letter providing us with the relevant information. Please understand that we may have additional comments after reviewing your response to our comments.
You may contact Lily Dang at (202) 551-3867 or Karl Hiller at (202) 551-3686 if you have questions regarding comments on the financial statements and related matters. Direct your questions relating to the engineering comments to Ronald Winfrey, Petroleum Engineer, at (202) 551-3704. Please contact Carmen Moncada-Terry at (202) 551-3687 or, in her absence, the undersigned at (202) 551- with any other questions.
Sincerely,
H. Roger Schwall
Assistant Director
Show Raw Text
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<FILENAME>filename1.txt
<TEXT>
November 22, 2005
VIA FACSIMILE and U.S. Mail
FAX NO. (412)-562-1041
Mr. Nicholas J. DeIuliis
Chief Executive Officer
CNX Gas Corporation
1800 Washington Road
Pittsburg, PA 15241
Re: CNX Gas Corporation
Registration Statement on Form S-1
Filed August 12, 2005 and amended October 27, 2005
File No. 333-127483
Dear Mr. DeIuliis:
We have completed the engineering review of your response
letter and amended registration statement and have the following
comment. Where indicated, we think you should revise your
document
in response to these comments. If you disagree, we will consider
your explanation as to why our comment is inapplicable or a
revision
is unnecessary. Please be as detailed as necessary in your
explanation. In some of our comments, we may ask you to provide
us
with information so we may better understand your disclosure.
After
reviewing this information, we may raise additional comments.
Please understand that the purpose of our review process is
to
assist you in your compliance with the applicable disclosure
requirements and to enhance the overall disclosure in your filing.
We look forward to working with you in these respects. We welcome
any questions you may have about our comments or on any other
aspect
of our review. Feel free to call us at the telephone numbers
listed
at the end of this letter.
1. Paragraph three in your response 13 states, "[Schlumberger Data
&
Consulting Services] feel this ending decline rate [4 percent] is
justified
based on the performance of the older 80 acre wells in the
project,
the performance of other CBM wells in the Appalachian Basin, and
has
confirmed this using simulation models." With a view towards
possible disclosure, tell us how many 80 acre wells have
demonstrated
a 4 percent or less terminal decline rate and how you determined that
this
could be reliably applied to all your vertical CBM wells. Include
the recovery efficiencies required by this decline rate
projection.
Address whether you have applied this decline rate to your 40 acre
infill PUD locations and, if so, tell us the estimated recovery
efficiency thus required. Compare this methodology with that of
Ralph E. Davis Associates which produced a decline rate nearly
twice
as large.
Closing Comments
As appropriate, please amend your registration statement in
response to these comments or provide us with a written response
within ten business days of your receipt of this letter providing
us
with the relevant information. Please understand that we may have
additional comments after reviewing your response to our comments.
You may contact Lily Dang at (202) 551-3867 or Karl Hiller at
(202) 551-3686 if you have questions regarding comments on the
financial statements and related matters. Direct your questions
relating to the engineering comments to Ronald Winfrey, Petroleum
Engineer, at (202) 551-3704. Please contact Carmen Moncada-Terry
at
(202) 551-3687 or, in her absence, the undersigned at (202) 551-
3740
with any other questions.
Sincerely,
H. Roger Schwall
Assistant Director
cc: C. Moncada-Terry
L. Dang
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CNX Gas Corporation
November 22, 2005
page 1
UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-7010
DIVISION OF
CORPORATION FINANCE
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