🛢️ Willow Gray 2-11-14-23 6H-LL

Phoenix Operating LLC · Divide County, ND · File #42044 · Generated 2026-02-13 12:33

API: 3302301641
Target Formation: Middle Bakken
Permit Explained: Yes

📋 Permit Cycle Assessment

The permit approval is explained by a coherent set of pre-permit waivers and regulatory requirements submitted between 06-23-2025 and 06-25-2025, all approved prior to the pit (dirt work 05-15-2025) and subsequent permit issuance. The approved waivers (tubing/packer, samples, open hole logs, filter sock) directly address non-standard operational geometry and pad-mate reliance. These waivers are NOT boilerplate—they are operator-submitted technical justifications conditioned on specific casing designs, offset well data substitution, and monitoring commitments. The State Geologist's cores and samples letter (06-23-2025) establishes mandatory baseline sampling independent of waivers. The permit's stipulations reference Field Order No. 33781 (setback and spacing geometry), which is supported by the directional plan showing the well within the 500-foot drilling corridor and compliance with 150-foot north-south setbacks. The Affidavit of Surface Damage Agreement (05-13-2025) confirms operator possession of surface use rights, a pre-permit requirement. All time-sensitive approvals occur within the permit cycle (05-15 to 06-24-2025 approvals relative to permit issuance). Permit approval is justified by prior regulatory findings and operator-provided technical documentation.

🔍 Permit Cycle Signals (5)

Tubing/Packer Waiver (NDAC 43-02-03-21) approved with technical assurances specifying casing design, safety factor, and flowback monitoring protocol.

Direct

📄 Form 255495 (Tubing/Packer Waiver sundry notice)
📅 06-24-2025 (Exact confidence)

Waiver conditions the completion design by mandating specific casing specifications (new #29 and 32# surface casing, API burst 11,220 psi), safety factor (.85), and monitoring equipment. These are not standard boilerplate but rather operator-provided technical commitments tied to omitting traditional tubing/packer requirements.

Drill Cutting Samples Waiver (NDAC 43-02-03-31) approved with offset well reliance protocol: samples collected from vertical section of adjacent Willow Gray 2-11-14-23 1H-LL (42039) rather than this well's vertical section.

Direct

📄 Form 255447 (Drill Cutting Samples Waiver)
📅 06-24-2025 (Exact confidence)

Waiver explicitly substitutes sampling obligation using data from pad-mate well. This is a non-routine geometry accommodation that reflects the pad's multi-well design and requires regulatory approval conditioned on offset well's data sufficiency.

Open Hole Log Waiver (NDAC 43-02-03-31) approved relying on offset well Willow Gray 2-11-14-23 3H (within 1 mile) for formation tops establishment; only GR-CBL (gamma ray-casing bond log) will be run.

Direct

📄 Form 255344 (Open Hole Log Waiver)
📅 06-24-2025 (Exact confidence)

Waiver conditions logging to a reduced scope (GR-CBL only) justified by proximity to offset well. Reflects pad development strategy and allows regulator-approved technical substitution.

Filter Sock Container Waiver (NDAC 43-02-03-19.2) approved for drilling phase only. Operator certifies no filter media used during drilling process.

Direct

📄 Form 255471 (Filter Sock Container Waiver)
📅 06-25-2025 (Exact confidence)

Waiver is conditioned on drilling phase only, creating an operational constraint that persists until drilling completion. Operator's operational choice (no filtration system) is explicitly approved but limits to stated drilling phase.

Cores and Samples Letter (06-23-2025) from State Geologist establishes mandatory sample and core collection protocol: 30' maximum intervals (vertical/build), 200' maximum intervals (lateral), submission within 30 and 180 days respectively. Enforcement provision: NDCC 38-08-16 civil penalty up to $12,500 per offense.

Supporting

📄 State Geologist letter dated 06-23-2025 (Cores and Samples requirement)
📅 06-23-2025 (Exact confidence)

Pre-permit geologist letter establishes mandatory sampling regimen referenced in the permit application process. This is regulatory requirement documentation that conditions drilling operations and is tied to statutory penalty. Acts as a direct constraint on execution.

📖 Historical Context (4)

Commission Order No. 33781 spacing/geometry order: defines 5,120-acre lease-line spacing unit (Sections 1, 2, 11, 12, 13, 14, 23, 24, T159N R98W) and 2,560-acre standup unit (Sections 2, 11, 14, 23); requires one horizontal well drilled in standup unit prior to completing any horizontal in lease-line unit.
📄 APD permit stipulations section (NDIC Field Order Info) · 📅 Unknown
This order establishes a sequencing obligation that affects operational and completion timing for all wells on the pad. Operator must track whether the standup well (Willow Gray 2-11-14-23 6H-LL or a Woods well) was drilled first. The lease-line unit restriction carries forward to all future completions on the pad.

Big Stone-Bakken Pool definition (NDIC Field Order Info): interval defined from 50 feet above Bakken top to 50 feet below Three Forks top. South setback justified by 'production liner cemented in lateral with wet shoe and ability to frac out the shoe.'
📄 APD permit stipulations (NDIC Field Order Info, Bakken Setback Summary Statement) · 📅 Unknown
Pool definition anchors the well's regulatory classification and completion design parameters. The wet-shoe frac-out capability notation is a completion design commitment that persists through operations. South setback is conditioned on this completion method, creating a forward obligation to honor the specified completion geometry.

Offset well obligation under NDIC Orders 31848 & 31973: Operator notified Chord Energy (Whiting) that wellbore will traverse adjacent spacing unit. Operator provided directional plan, trajectory, formation tops, casing design, and cementing details per order requirement. Affidavit dated 05-14-2025.
📄 Affidavit of Adjacent Spacing Unit Notification (dated 05-14-2025) · 📅 05-14-2025
This notification establishes an ongoing obligation to honor the disclosed wellbore geometry and casing/cement plan to the adjacent operator. Any deviation from the submitted trajectory or design that affects the adjacent spacing unit would constitute violation of the offset operator notification protocol. Operator must maintain coordination with Chord Energy.

Cores and Samples mandatory protocol: samples from Base of Last Charles Salt (depth 8,567.39 MD) at 30-foot intervals through vertical/build; 200-foot intervals through lateral. Samples to State Core Library within 30 days; cores within 180 days. Statutory penalty up to $12,500 per offense per day.
📄 State Geologist letter dated 06-23-2025 (Cores and Samples) · 📅 06-23-2025
This is a mandatory post-drilling operational obligation. Failure to collect, package, and submit samples/cores within specified timeframes exposes operator to per-day civil penalties. Operator must establish sample management and courier logistics prior to drilling. Compliance is non-waivable (only sampling waiver for vertical section exists; lateral and curve sections remain mandatory).

🔧 Operator Pattern

Phoenix Operating LLC demonstrates sophisticated pad development and multi-well spacing strategy. Operator proactively submitted four targeted waivers addressing pad geometry constraints (offset well data reliance, reduced logging scope, filter-free drilling operations, modified completion design). All waivers were approved with technical justification, indicating operator capability to justify non-standard configurations. Operator obtained surface use agreement before dirt work, maintained regulatory notification to offset operator per Order 31848/31973, and provided directional plan to adjacent spacing unit holder (Chord Energy). This reflects systematic compliance with pre-drilling notification and coordination protocols.
Five wells on single pad with coordinated directional geometry; offset-well-based data substitution strategy (samples, open hole logs); pre-permit affidavits (surface agreement 05-13-2025, offset notification 05-14-2025); waiver submissions structured with technical assurances (casing burst ratings, safety factors, monitoring commitments); State Geologist mandatory sampling acceptance indicating operator baseline compliance expectations.

Confidence: High
Well file contains complete permit application (APD form with stipulations), five discrete approved sundry notices (waivers) with specific approval dates (06-24-2025 to 06-25-2025), directional well plan with formation tops and MD/TVD trajectories, State Geologist cores/samples letter with regulatory authority citation (NDCC 38-08-04, NDAC 43-02-03-38.1), pad layout and cross-section plans, affidavits of surface agreement and offset notification, and spud notification (08-06-2025). All dates are explicit except historical Field Order numbers (33781, 31848, 31973), which are cited in permit stipulations and affidavits. No OCR errors affect critical permit-cycle signals. Permit explanation rests on four approved waivers plus mandatory geologist letter, all time-stamped within permit cycle window. Signal quality is high: direct regulatory approvals with stated rationale, not inferred or reconstructed.