In Amoco v. Corporation Comm'n, 1986 OK CIV APP 16, 751 P.2d 203, R&R Exploration Co., Inc. (R&R) applied to the OCC to force pool a 640-acre drilling and spacing unit. Amoco Production Co. (Amoco) was designated as operator of the unit under Order No. 199609. R&R elected not to participate in the initial well and was compensated. R&R subsequently assigned a portion of its interest to Bartex Exploration, Inc. (Bartex). Bartex then informed Amoco that it wished to participate in a second well being drilled. Amoco declined, insisting the pooling order and R&R's previous election eliminated Bartex's participation in subsequent wells in the unit. After the parties requested the OCC interpret Order No. 199609, the OCC held Bartex had the right to participate in subsequent wells in the spacing unit. Amoco appealed and the Court of Civil Appeals (COCA) reversed, finding the OCC exceeded its jurisdiction. Citing 52 O.S.1981, 87.1(e), COCA found the statute mandated developing the spacing unit as a unit, specifically rejecting that 87.1(e) authorized pooling by the wellbore. Moreover, citing Helmerich & Payne, Inc. v. Corporation Comm'n, 1975 OK 23, 532 P.2d 419, 422, COCA stated "[w]hen the statute says the Commission shall require the owners 'to pool and develop their lands in the spacing unit as a unit' it is limiting pooling within the designated drilling and spacing unit of 640 acres. . . . [W]e feel the regulatory statute is restrictive." Id.