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🛢️ PETERSON 22-15-10-3 4H
Phoenix Operating LLC · Williams County, ND · File #42626 · Generated 2026-02-13 12:33
- API
- 3310506776
- Target Formation
- Middle Bakken
- Permit Explained
- Partially
📋 Permit Cycle Assessment
The APD approval dated April 1, 2026 is conditioned on Commission Order No. 34633 and setback stipulations (150'/500' isolation from unit boundaries). However, the file contains a critical unresolved signal: a permit suspension letter dated January 14, 2026 suspends five Peterson permits (including 42626) pending a February 2026 revocation hearing initiated by Koda Resources Operating, LLC. The APD approval date (April 1, 2026) falls post-hearing, suggesting the suspension was lifted or revocation was denied, but no contemporaneous documentation confirms the hearing outcome or removal of suspension. The Backbuild Order Waiver request (January 8, 2026) and Cores/Samples directive (January 12, 2026) are pre-permit regulatory submissions that support but do not directly justify approval conditioned on Order 34633. The permit file does not contain the hearing decision, revocation order denial, or any written relief from suspension that would explain why drilling approval issued despite the active suspension.
🔍 Permit Cycle Signals (4)
📄 Letter dated January 14, 2026, from Todd L. Holweger, Sr. Permit Manager, page 1
📅 2026-01-14 (Exact confidence)
Five Peterson permits (42623–42627, including 42626) are suspended pending revocation hearing scheduled February 2026. Koda Resources Operating, LLC requested permit revocation. Mobilization, conductor setting, and spudding are prohibited.
📄 APD Form, Page 1 of 10, Permit Information section and Stipulations section
📅 2026-04-01 (Exact confidence)
APD approval is issued prospectively (post-hearing, post-suspension resolution presumed). Stipulations condition wellbore position: 150' setback (north/south), 500' setback (east/west) within 2,560-acre spacing unit (Sections 3, 10, 15, 22, T159N, R103W). Production liner cemented in lateral with wet shoe and frac-out capability required.
📄 Letter from Jessica Wentz, Regulatory Specialist, Phoenix Operating LLC, dated January 8, 2026
📅 2026-01-08 (Exact confidence)
Operator acknowledges proposed wells will enter Bakken outside target spacing unit and notifies adjacent operator per NDIC Order 31848. Waiver request issued 6 days before permit suspension letter; temporal overlap suggests regulatory engagement concurrent with suspension action.
📄 Letter dated January 12, 2026, from Ross Edison, Geologist, on letterhead of ND Geological Survey
📅 2026-01-12 (Exact confidence)
State Geologist imposes mandatory sample and core collection requirements under ND Century Code § 38-08-04 and NDAC 43-02-03-38.1. Samples from Base of Last Charles Salt at 30' intervals (vertical/build), 200' intervals (horizontal); cores to state library within 180 days of drilling completion. Penalty up to $12,500/day per violation.
📖 Historical Context (2)
Koda Resources Operating, LLC initiated revocation proceeding against five Peterson permits under NDAC 43-02-03-16.2
📄 Letter dated January 14, 2026, from Todd L. Holweger; cc to Lawrence Bender, Fredrikson & Byron, P.A., Attorneys for Koda Resources · 📅 2026-01-14
Revocation hearing scheduled for February 2026 creates regulatory and title uncertainty. If hearing outcome is not documented in file, operational risk persists: permits could remain suspended if revocation is granted, or conditions imposed in settlement could affect drilling authorization. Adjacent spacing-unit operator engagement in formal proceeding suggests potential offset well conflict (consistent with backbuild waiver request).
Backbuild geometry—wells proposed to enter Bakken outside target spacing unit; requires notification of adjacent operator per NDIC Order 31848
📄 Letter dated January 8, 2026, from Jessica Wentz, Phoenix Operating LLC · 📅 2026-01-08
Non-standard well geometry creates ongoing compliance obligation: operator must confirm adjacent operator notification and document waiver approval (if required) before drilling laterals outside unit. Conflict between operators (evidenced by Koda's revocation request) may require formal NDIC mediation or well-path redesign during drilling operations.
🔧 Operator Pattern
Phoenix Operating LLC submitted coordinated pre-permit filings (Backbuild Waiver, Cores/Samples directive acknowledgment) in advance of APD, demonstrating regulatory awareness. However, concurrent revocation action by adjacent operator suggests potential boundary or spacing disputes not fully resolved in permit file.
Backbuild waiver letter (Jan 8) precedes suspension (Jan 14) by 6 days; operator proactively engaged NDIC on well geometry. Cores/Samples letter (Jan 12) issued 2 days before suspension, indicating regulatory engagement pipeline. APD approval (Apr 1) issued ~2.5 months after suspension, implying hearing interval and resolution. No post-suspension operational communications in file.
Confidence: Medium
APD approval is clearly documented with setback and completion stipulations. However, the permit file lacks critical post-suspension documentation: (1) no hearing decision or revocation order outcome dated post-January 14, 2026; (2) no explicit waiver or relief from suspension prior to April 1 approval date; (3) no minutes or settlement agreement from February 2026 hearing. The temporal sequence is chronologically coherent but causally incomplete. Permit approval is explained by regulatory order and design parameters, but justification for issuance despite active suspension is absent from file. If OCR is incomplete or pages missing, confidence may be artificially suppressed.