🛢️ ALE 2335-4BHN

KODA Resources Operating, LLC · Divide County County, ND · File #42595 · Generated 2026-02-13 12:33

API: 3302301728
Target Formation: Middle Bakken
Permit Explained: Yes

📋 Permit Cycle Assessment

The permit approval dated 12/29/2025 is explained by five contemporaneous regulatory signals. The aquifer stipulation and closed-mud-system requirement directly condition approval on environmental site controls. The Bakken setback statement grounds the 150-ft north/500-ft east-west boundaries in specific completion geometry (wet shoe, frac-out capability), representing a non-standard engineering justification issued with the permit. Core and sample collection requirements from the State Geologist (same date) establish mandatory evaluation deliverables and compliance deadlines post-spud. Anticollision modeling dated 10/29/2025 demonstrates Level 3 risk at TD relative to offset well Ale 2335-3BHN but confirms acceptable separation (1,560.2 ft center-to-center), supporting approval of the approved trajectory. The waiver to Order 31973 (11/06/2025) addresses multi-DSU drilling by confirming single-operator control, eliminating a cross-operator notification delay. All five signals bind to the anchor approval date and constrain operational execution.

🔍 Permit Cycle Signals (5)

Aquifer stipulation issued with requirement for onsite inspection and conditional approval (closed mud system, impermeable liner on entire location)

Direct

📄 APD Permit Page 1 - Stipulations section
📅 2025-12-29 (Exact confidence)

Non-routine environmental constraint tied to well location on aquifer. Condition precedent to operations.

Bakken Setback Summary Statement: north setback (150') based on production liner cemented in lateral with wet shoe and ability to frac out shoe

Direct

📄 APD Permit Page 1 - Stipulations section
📅 2025-12-29 (Exact confidence)

Departure from standard setback language. Explicitly conditions setback on completion method (wet shoe, frac-out capability). Geologist-specific engineering constraint justifying non-default boundary clearance.

Core and sample collection requirements issued by State Geologist: samples from Base of Last Charles Salt at specified intervals (30' vertical, 200' horizontal); core submission within 180 days; penalty threshold $12,500/day

Direct

📄 State Geologist letter dated 12/29/2025 (RE: CORES AND SAMPLES)
📅 2025-12-29 (Exact confidence)

State-mandated geological evaluation program tied directly to Middle Bakken target. Strict submission timeline and penalty structure condition operational execution post-approval.

Anticollision analysis submitted and reviewed; closest approach to offset well Ale 2335-3BHN at measured depth 29,562.5 ft with separation factor 1.799 (Level 3 warning); minimum center-to-center separation 1,560.2 ft

Supporting

📄 KLX Anticollision Report dated 10/29/2025; Summary table and Ladder Plot
📅 2025-10-29 (Exact confidence)

Risk-based directional constraint. Single Level 3 warning flag at TD indicates marginal but acceptable collision avoidance. Technical justification for approved lateral trajectory geometry; prerequisite for drilling clearance on multi-well pad.

Waiver to Commission Order No. 31973 (adjacent spacing unit notification) granted; KODA is operator of both relevant spacing units, eliminating cross-operator communication requirement

Supporting

📄 KODA letter dated 11/06/2025 requesting waiver; Affidavit of Working Interest dated 11/06/2025
📅 2025-11-06 (Exact confidence)

Regulatory streamlining based on vertical ownership integration. Eliminates delay trigger but confirms well trajectory crosses into adjacent DSU (Sections 2, 3, 10, 11, 14 & 15, T161N, R103W), justifying directional design and approvals for both DSUs.

📖 Historical Context (5)

Surface Use Agreement (SUA) executed 12/18/2025 with surface owner Albert & Michelle Metz covering drilling, completion, and production damages and injuries
📄 Affidavit of Surface Use Agreement dated 12/18/2025 · 📅 Unknown
SUA binding covenant persists through well life. Operator indemnity and damage claims limitation remain enforceable conditions on operations and reclamation.

Field Order No. 34629 incorporated into permit stipulations, imposing 150' north and south setback, 500' east-west setback within 3840-acre DSU (Sections 34, 35, T162N, R103W and Sections 2, 3, 10, 11, 14, 15, T161N, R103W)
📄 APD Permit Stipulations section · 📅 Unknown
Standing pool definition and isolation requirements for East Goose Lake-Bakken Pool (interval 50 ft above Bakken top to 50 ft below Three Forks top) condition all future completions, production, and communitization within the DSU.

Prohibition on diesel compounds (BTEX, fuel oils, kerosene listed by CAS number) in hydraulic fracture stimulation fluids
📄 KODA Drilling Plan Section 7 (Hydraulic Fracturing Stimulation) · 📅 Unknown
Recurring operational constraint on all frac stages. Fluid composition compliance required throughout well life and affects chemical procurement, disposal, and environmental monitoring.

Closed-loop drilling system mandate with cuttings disposal at 13 Mile Landfill, Williston, ND
📄 KODA Drilling Plan Section 4 (Drilling Fluids Program), note at end · 📅 Unknown
Waste management obligation ties operations to specific authorized facility. Persistence of logistics and cost burden through drilling phase; non-compliance triggers regulatory enforcement risk.

Filter sock and filter media container requirements (leak-proof, covered, placard-marked) effective June 1, 2014, per NDAC Section 43-02-03-19.2; on-site during spud through clean-out, completion, flow-back
📄 State letter dated 5/30/2025 (RE: Filter Socks and Other Filter Media) · 📅 Unknown
Statutory waste management condition applies to all wells spudded in North Dakota. Extends through all drilling and early completion phases; non-compliance incurs civil penalties and operational holds.

🔧 Operator Pattern

Majority interest operator (51.64% in 3840-acre DSU; 83.33% in 2880-acre DSU) consolidating multi-well development on single pad (8 wells: ALE 2335-1BHN through 8BH) with integrated directional planning and coordinated permitting across two adjacent spacing units.
Affidavit of Working Interest (11/06/2025) establishes KODA as majority stakeholder in both DSUs. Anti-collision report integrates seven offset wells (six KODA, three third-party offset) in single design envelope, indicating planned co-development strategy. Single surface use agreement covers all eight wells. Waiver request to Order 31973 reflects operator's vertical control of both drilling and adjacent spacing units, enabling streamlined permitting without external notifications.

Confidence: High
Well file contains dated, signatory regulatory documents (permit approval, State Geologist letter, field order incorporation) with explicit stipulation language and technical justifications (anticollision, setback engineering, core/sample program). APD application, drilling plan, and directional design documents provide contemporaneous detail on geometry, equipment, and compliance triggers. Surface use agreement and working interest affidavit establish legal preconditions. All permit-cycle signals are directly issued by NDIC or state agencies on or within 60 days prior to permit approval; none are inferred or reconstructed. No material gaps in documentation of approval conditions or technical justifications.