United States securities and exchange commission logo
August 3, 2021
James P. Henderson
Excutive Vice President Finance and Chief Financial Officer
Whiting Petroleum Corporation
1700 Lincoln Street, Suite 4700
Denver, Colorado 80203-4547
Re: Whiting Petroleum
Corporation
Form 10-K for the
Fiscal Year Ended December 31, 2020
Filed February 25,
2021
File No. 001-31899
Dear Mr. Henderson:
We have reviewed your filing and have the following comments. In
some of our
comments, we may ask you to provide us with information so we may better
understand your
disclosure.
Please respond to these comments within ten business days by
providing the requested
information or advise us as soon as possible when you will respond. If
you do not believe our
comments apply to your facts and circumstances, please tell us why in
your response.
After reviewing your
response to these comments, we may have additional comments.
Form 10-K for the Fiscal Year Ended December 31, 2020
Properties
Proved Undeveloped Reserves, page 42
1. Please provide a
narrative explanation of the material changes relating to each of the items
you identify in your
tabular reconciliation of the changes in your proved undeveloped
reserves. To the extent
that two or more unrelated factors are combined to arrive at the
overall change for an
item, your disclosure should separately identify and quantify each
individual factor that
contributed to the material change so that the change in net reserve
quantities between
periods is fully explained.
The disclosure of
revisions in the previous estimates of your proved undeveloped reserves
in particular should
identify the individual factors such as the changes caused by
commodity prices and/or
costs, well performance, unsuccessful and/or uneconomic
proved undeveloped
locations or the removal of proved undeveloped locations due to
James P. Henderson
FirstName LastNameJames P. Henderson
Whiting Petroleum Corporation
Comapany
August NameWhiting Petroleum Corporation
3, 2021
August
Page 2 3, 2021 Page 2
FirstName LastName
changes in a previously adopted development plan. Refer to Item
1203(b) of Regulation
S-K.
2. The reserves report, filed as Exhibit 99.1, indicates your estimates
of proved undeveloped
reserves include certain locations that would generate positive future
net revenue but have
negative present worth when discounted at 10 percent based on year-end
constant prices
and costs. Please tell us the net quantities of proved reserves
attributed to such locations
and clarify for us if the referenced locations are a part of
development plan and schedule
adopted by management, including approval by the Board if such
approval is required,
with respect to such reserves. Refer to Rule 4-10(a)(31)(ii) of
Regulation S-X and
Question 131.04 in our Compliance and Disclosure Interpretations
regarding Oil and Gas
Rules.
3. If there are material quantities of net proved undeveloped reserves
relating to such
locations, expand the disclosure here or in an appropriate section
elsewhere to describe the
marginal nature of these wells and the economic risk that they pose.
Refer to FASB ASC
932-235-50-10.
Acreage, page 43
4. We note your disclosure that the portion of your net undeveloped acres
subject to
expiration over the next three years is approximately 29% in 2021, 33%
in 2022 and 3%
in 2023. Please tell us the extent to which you have assigned any
proved undeveloped
reserves to locations which are currently scheduled to be drilled
after lease expiration. If
there are material quantities of net proved undeveloped reserves
relating to such locations,
expand the disclosure here or in an appropriate section elsewhere to
describe in reasonable
detail the steps and related costs that would be necessary to extend
the time to the
expiration of such leases. Refer to Rule 4-10(a)(26) of Regulation S-X
and FASB ASC
932-235-50-10.
Supplemental Disclosures About Oil and Gas Producing Activities (Unaudited)
Oil and Gas Reserve Quantities, page 113
5. You disclose that there were 120.7 MMBoe of negative revisions in the
previous estimates
of your proved reserves for the period ending December 31, 2020,
primarily attributable to
reservoir and engineering analysis and well performance. Please
explain to us in
reasonable detail the reason(s) for the revisions in such estimates
and tell us how you
concluded that the estimates disclosed as of December 31, 2019
complied with the
requirements for reasonable certainty and disclosure as proved
reserves. Refer to the
definitions of reasonable certainty and proved oil and gas reserves in
Rule 4-10(a)(24) and
(a)(22) of Regulation S-X, respectively, in formulating your response.
Standardized Measure of Discounted Future Net Cash Flows, page 115
6. Expand the discussion accompanying the presentation of the
standardized measure to
clarify, if true, that future cash flows take into account the
estimated abandonment costs
James P. Henderson
Whiting Petroleum Corporation
August 3, 2021
Page 3
for your proved properties. Refer to FASB ASC 932-235-50-36.
7. If the abandonment costs, including such costs related to your proved
undeveloped
locations, have not been included, tell us the undiscounted dollar
amounts and the dollar
amounts discounted at ten percent for each of the periods presented,
e.g. as of December
31, 2020, 2019 and 2018, respectively, and explain to us your
rationale for excluding
these costs from your calculation of the standardized measure. Refer
to the definition of
Discounted Future Net Cash Flows Related to Proved Oil and Gas
Reserves under
Amendments to the XBRL Taxonomy, Accounting Standards Update 2010-03,
Extractive
Activities-Oil and Gas (Topic 932), Oil and Gas Reserve Estimation and
Disclosures,
January 2010.
We remind you that the company and its management are responsible for
the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action
or absence of
action by the staff.
You may contact John Hodgin, Petroleum Engineer, at (202) 551-3699 if
you have
questions regarding comments. Please contact Craig Arakawa, Branch Chief, at
(202) 551-
3650 with any other questions.
FirstName LastNameJames P. Henderson Sincerely,
Comapany NameWhiting Petroleum Corporation
Division of
Corporation Finance
August 3, 2021 Page 3 Office of Energy &
Transportation
FirstName LastName