🛢️ MARY 25-36-1-12 4H

Phoenix Operating LLC · McKenzie County, ND · File #42619 · Generated 2026-02-13 12:33

API: 3305310757
Target Formation: Middle Bakken
Permit Explained: Yes

📋 Permit Cycle Assessment

The permit approval (File No. 42619, dated 02/01/2026) is explained by contemporaneous documentation. The NDIC issued the permit conditioned upon Commission Order No. 34508 setback and pool definition stipulations, which are justified by specific wellbore geometry (wet shoe, frac-out capable production liner). The operator submitted a waiver request (approved 01/09/2026) for open hole logs, supported by offset well data (Twin Tanks 36-32). Pre-approval letters (01/05/2026) documented operator anti-collision mitigation plans and landslide risk review by state geologists, which addressed regulatory concerns. The State Geologist issued mandatory core/sample collection requirements (01/12/2026) prior to permit issuance, establishing pre-production compliance conditions. All permit-cycle signals (waiver approval, stipulations, anti-collision commitment, geologic clearance, sampling directive) are time-bound to the permit approval window (early January through early February 2026) and directly condition or justify the permit action. The file contains no gaps in contemporaneous regulatory justification.

🔍 Permit Cycle Signals (5)

Open Hole Log Waiver (Category: Logs & Testing) — Operator requested waiver of open hole log requirement under NDIC Rule 43-02-03-31. Offsetting well (Twin Tanks 36-32, NDIC File #8167) within one mile has open hole logs; GR-CBL planned from TD to ground level as substitute.

Direct

📄 Sundry Form File No. 42619, Form ID 292059, Page 2; dated 01/09/2026
📅 2026-01-09 (Exact confidence)

Regulator-approved waiver conditioning permit. Demonstrates non-routine logging substitution justified by nearby offset well data and accepted by NDIC Geologist (Ross Edison) as sufficient for formation top establishment.

Core and Sample Collection Requirements Letter (NDIC Regulatory Standard) — State Geologist directive issued 1/12/2026 specifying mandatory core/sample submission protocols: samples from Base of Last Charles Salt at 30° max intervals (vertical/build), 200" max intervals (horizontal); cores within 180 days; all routed to ND Geological Survey Core Library per NDAC 43-02-03-38.1.

Direct

📄 Letter from Ross Edison, Geologist, NDIC Oil & Gas Division, dated 1/12/2026, addressed to Tori Siemieniewski (Phoenix)
📅 2026-01-12 (Exact confidence)

State regulatory order conditioning well execution. Specifies collection thresholds and logistics tied to well file no. 42619. Represents enforceable pre-production obligation (civil penalty up to $12,500/day for violation per NDCC 38-08-16).

Setback Stipulations and Bakken Pool Definition (Commission Order No. 34508) — Permit approval conditioned on 150' north/south and 500' east/west setbacks within 2560-acre spacing unit (Sections 25, 36, 1, 12); south setback justified by production liner with wet shoe and frac-out capability; Ranch Creek-Bakken Pool defined 100 ft above to above Birdbear.

Direct

📄 Application for Permit for New Well—Horizontal, Page 1, Stipulations section; Permit approval dated 02/01/2026
📅 2026-02-01 (Exact confidence)

Core permit stipulation directly justifying approval. Setback geometry tied to specific wellbore completion design (wet shoe). Pool definition establishes regulatory isolation boundaries for this well.

Anti-Collision Mitigation Commitment (Letter dated 1/5/2026) — Operator committed to steering wellbores away from nearby offset wells (Twin Tanks 36-32, Carmona 31-1H, Grassy Butte 12-31H, Woody Watson 1) via original NDIC file data; 30' surveys planned during build/drop/curve sections.

Supporting

📄 Letter from Tyree Abshire, VP Drilling, Phoenix Operating LLC, dated 1/5/2026, to Todd Holweger (NDIC Permit Manager)
📅 2026-01-05 (Exact confidence)

Pre-approval anti-collision commitment tied to permit issuance timeline. Demonstrates operator response to proximity risk posed by dense offset well cluster. Supporting evidence that permit approval conditioned on execution of directional control measures.

Landslide Risk Review and Clearance (Email dated 1/5/2026 from Fred J. Anderson, Surface Geology Section Manager, NDIC) — Geologist reviewed plat, location information, and aerial imagery; noted no major concerns despite noted landslide proximity to eastern edge of proposed pad.

Supporting

📄 Email from fjanderson@nd.gov to tholweger@nd.gov, dated 1/5/2026; Subject: 'Phoenix Mary APD's McKenzie County-landslide review'
📅 2026-01-05 (Exact confidence)

Regulatory clearance addressing specific geologic hazard concern. Permit Manager escalated to Surface Geology Section; clearance issued on expedited basis. Represents direct conditioning factor for pad location approval.

📖 Historical Context (3)

Bakken Spacing Unit Configuration and Backbuild Order Waiver (Letter dated 12/31/2025 from Tori Siemieniewski, Director—Bakken Regulatory, Phoenix) — Operator disclosed that proposed Mary wells will horizontally drill into Bakken outside target spacing unit per NDIC Order 31848; unit to north not currently spaced; operator filed application for 3-mile spacing unit under pending Case #32125 (heard September 2025); no other operators currently in proposed unit.
📄 Letter from Tori Siemieniewski to Todd Holweger, NDIC Permit Manager, dated 12/31/2025, Subject: 'Mary Pad (Mary 25-36-1-12 1H, 2H, 3H, 4H) — Backbuild Order Waiver' · 📅 2025-12-31

Stormwater Pollution Prevention Program (SWPPP) Commitment and Best Management Practices Framework (SWPPP Guidance Document, Rev. 0, dated 6/6/2025, and Operator Letter dated 1/5/2026 detailing environmental controls) — Operator committed to long-term erosion/sediment control, 24-hour SCADA monitoring with alarm systems, spill response protocols, emergency response coordination with Sakakawea Area Spill Response (SASR), and SPCC implementation within 6 months of first oil production.
📄 Phoenix Operating LLC SWPPP Guidance Document (Revision 0, dated 6/6/2025), spanning 21 pages with detailed phasing, inspection, and maintenance protocols; operator letter dated 1/5/2026 from Tori Siemieniewski to Todd Holweger detailing site-specific Best Management Practices for Mary Pad · 📅 2025-06-06; Letter dated 2026-01-05

Multi-Well Pad Development and Spacing Unit Consolidation Risk — File shows four wells planned on single pad (Mary 1H, 2H, 3H, 4H) targeting 2560-acre drilling spacing unit comprised of Sections 25, 36 (T147N-R99W) and Sections 1, 12 (T146N-R99W); operator filed pending Case #32125 for 3-mile spacing unit. Regulatory approval of this DSU configuration and operator's ability to retain operatorship across multi-section pad is forward-dependent on spacing unit adjudication.
📄 Anti-Collision letter dated 1/5/2026 and Backbuild Order Waiver letter dated 12/31/2025; directional well design plan (Taktikal Directional Survey Report); APD Stipulations (permit approval dated 02/01/2026) · 📅 2025-12-31; 2026-01-05; 2026-02-01

🔧 Operator Pattern

Proactive regulatory engagement with pre-approval disclosure of non-routine permit conditions and comprehensive environmental/safety commitment documentation.
Operator submitted (1) backbuild order waiver letter pre-approval (12/31/2025) disclosing out-of-unit lateral entry and pending spacing unit application; (2) anti-collision technical letter with steering/survey protocols (1/5/2026); (3) comprehensive pad-level environmental management documents including SWPPP Guidance Document (6/6/2025, 21 pages), detailed Best Management Practices letter addressing stormwater, erosion, spill response, and 24-hour SCADA monitoring (1/5/2026); (4) Emergency Response Plan for Mary multi-well pad; (5) cores/samples coordination pre-approval (State Geologist letter 1/12/2026 acknowledged operator compliance intent). Operator name 'Phoenix Operating LLC' appears on all primary regulatory submissions. File shows no evidence of non-compliance, violations, or historical enforcement actions. Pattern suggests operator strategy of early regulatory disclosure and technical documentation to facilitate expedited permit processing while establishing documented compliance posture.

Confidence: High
Well file contains complete permit-cycle documentation from pre-application (12/31/2025) through final approval (02/01/2026). All material regulatory signals are contemporaneous, dated, and sourced from either NDIC officers (Geologists Ross Edison, Fred Anderson; Permit Manager Todd Holweger) or operator-submitted letters with specific regulatory references (NDIC Rules, Commission Orders, Administrative Code sections). Directional survey, plat, and technical documents are certified by licensed land surveyors (Scott C. Koterba, LS-9500) and drilling engineers (Taktikal Directional). No dates are inferred; all key signals bear exact dates. Permit approval date is explicit (02/01/2026 dirt work date on APD). Waiver approval date (01/09/2026) and geologic clearance (01/5/2026) are clearly marked. Only temporal uncertainty relates to pending Case #32125 (spacing unit application), which operator disclosed as 'heard in September 2025' with status remaining pending as of letter date (12/31/2025). This pending status is accurately characterized in historical signals section and does not undermine permit-cycle assessment.