🛢️ PETERSON 22-15-10-3 5H

Phoenix Operating LLC · Williams County, ND · File #42627 · Generated 2026-02-13 12:33

API: 3310506777
Target Formation: Middle Bakken
Permit Explained: Partially

📋 Permit Cycle Assessment

The permit file contains multiple direct and supporting signals that justify approval, but critical gaps exist. Commission Order No. 34633 and the referenced setback framework (150'/500') are the primary regulatory anchor for approval, conditioning the well on production liner design with wet shoe and frac-out capability. The Grenora-Bakken Pool definition establishes spatial boundaries. The backbuild order notification (1/8/2026) demonstrates compliance with NDIC Order 31848 and confirms no adjacent operator objection, addressing the multi-well pad geometry. Mandatory compliance orders (cores/samples collection, filter container requirements) are binding but do not uniquely condition this permit—they apply generally. However, the file does NOT contain: (1) anticollision analysis or offset well clearance certification, (2) any waiver justifications or engineering variance requests, (3) the actual permit approval letter or decision document with approval date (the APD form shows Dirt Work Date 04/01/2026 but no permit issuance/approval date), and (4) evidence that Commission Order 34633 was issued specifically for this well or pre-exists as a field rule. The suspension letter (1/14/2026) indicates a competing revocation petition by Koda Resources Operating LLC is pending hearing in February 2026, creating operational jeopardy that post-dates the presumed permit approval. Without the actual permit approval date and decision memo, the temporal relationship between approval and suspension is ambiguous. The contemporaneous pre-permit submittals (backbuild waiver, drilling plan) are present and adequate, but the permit decision itself is not explicitly documented in the file.

🔍 Permit Cycle Signals (5)

Commission Order No. 34633 referenced in permit stipulations – establishes setback framework (150' north/south, 500' east/west) within 2560-acre spacing unit (Sections 3, 10, 15, 22, T159N, R103W) and conditions approval on production liner cemented in lateral with wet shoe and frac-out capability.

Direct

📄 APD Form – STIPULATIONS section, NDIC Field Order Info
📅 Unknown (Missing confidence)

Directly conditions the permit approval. Setback framework and casing design (wet shoe with frac-out) are explicit approval conditions tied to a non-routine multi-well geometry.

Grenora-Bakken Pool definition (interval from 50 ft above top of Bakken to 50 ft below top of Three Forks) – established by NDIC Field Order in permit stipulations.

Direct

📄 APD Form – STIPULATIONS section
📅 Unknown (Missing confidence)

Pool definition is structural foundation for spacing unit approval and reservoir boundary compliance.

Cores and Samples letter (1/12/2026) from State Geologist specifying collection requirements: samples from Base of Last Charles Salt at 30' max intervals (vertical/build) and 200' max intervals (horizontal sections); samples to State library within 30 days post-drilling; cores within 180 days. ND Century Code § 38-08-04 and NDAC § 43-02-03-38.1 enforcement cited.

Supporting

📄 Letter dated 1/12/2026 from Ross Edison, Geologist; addressed to Tori Siemieniewski, Phoenix Operating LLC
📅 2026-01-12 (Exact confidence)

Mandatory compliance requirement for this well. Ties directly to drilling operations and post-well obligations. Geologist-issued, binding regulatory order conditioning execution.

Filter Socks and Filter Media directive (5/30/2025) from Assistant Director Mark F. Bohrer: leak-proof, covered container required on-site beginning spud through clean-out, completion, and flow-back. NDAC § 43-02-03-19.2 and § 33.1-20-02.1-01 cited. Waiver available via Form 4 Sundry Notice.

Supporting

📄 Letter dated 5/30/2025 from Mark F. Bohrer, Assistant Director, NDIC Oil and Gas Division
📅 2025-05-30 (Exact confidence)

Mandatory operational constraint effective for all wells spud after June 1, 2014. Applies to this well permit. No waiver requested in file.

Backbuild Order Waiver letter (1/8/2026) from Jessica Wentz, Phoenix Operating LLC, to Todd Holweger at NDIC. Notifies that Peterson 22-15-10-3 1H, 2H, 3H, 4H, 5H will enter Bakken Petroleum System outside target spacing unit per NDIC Order 31848. No adjacent operator identified.

Direct

📄 Letter dated 1/8/2026 from Jessica Wentz, Regulatory Specialist, Phoenix Operating LLC, to Todd Holweger, NDIC Permit Manager
📅 2026-01-08 (Exact confidence)

Demonstrates operator notification compliance with NDIC Order 31848 (backbuild boundary rule). Establishes that multi-well geometry triggers cross-unit drilling acknowledgment but no competing claim exists. Directly justifies approval of lateral drilling geometry.

📖 Historical Context (4)

Suspension order (1/14/2026) from NDIC Sr. Permit Manager Cdd L. Holweger: Five Peterson permits (42623–42627) suspended per NDAC 43-02-03-16.2 pending revocation hearing in February 2026 on application by Koda Resources Operating LLC. Mobilization, conductor, and spud prohibited.
📄 Letter dated 1/14/2026 from Cdd L. Holweger, Sr. Permit Manager and Seismic Program Manager, NDIC Oil and Gas Division · 📅 2026-01-14
Operational halt on this well (42627) is active and effective. Even if permit was approved before 1/14/2026, execution is barred pending Commission decision on revocation petition. Reverses operational freedom granted by permit approval. Directly affects drilling schedule and cost.

Proposed Drilling Plan (undated, likely December 2025 based on design date 12/20/2025): 9 5/8" surface casing to 3000' MD, 7" intermediate to 9558' MD, 4.5" production liner to 30305' MD. 70/30 invert mud 3000'–9558', brine water 9558'–30305'. Closed-loop cuttings collection to Secure Waste Infrastructure USA LLC (Williston, ND). No diesel-based stimulation compounds (per CAS registry numbers specified).
📄 PROPOSED DRILLING PLAN document – Well: PETERSON 22-15-10-3 5H (multi-page technical specification) · 📅 2025-12-20
Establishes the technical baseline for well execution. Casing design, mud chemistry, and stimulation restrictions remain operationally binding regardless of permit suspension. If suspension is lifted, operator must adhere to this plan or submit Form 4 Sundry Notice for modifications.

Wellbore geometry and location certification: Surface Hole Location 375' FSL, 1183' FEL (Section 22, T159N, R103W); Bottom Hole Location 190' FNL, 550' FEL. Measured depth 30,305' MD; True vertical depth 9,181' TVD. Build section KOP at 8,671' MD; horizontal section from 9,558' (end of intermediate casing) to 30,305' TD. Directional survey and anticollision model by Taktikal Directional dated 12/22/2025.
📄 Well location plat (certified survey), directional wellbore schematic, target details diagram · 📅 2025-12-22
Fixed geometry constraint on lateral placement. Setback compliance (150'/500') and offset well separation depend on this confirmed trajectory. Any change to BHL location or lateral extent requires regulatory re-approval or waiver. Persists as design baseline.

Pad layout and surface disturbance: Production pad ~12.65 acres (including 8.93-acre pad + 3.72-acre reclaimed area). Six wellheads on single pad (Peterson 1H–5H plus PETERSON 1 SWD). Access roads totaling ~22.96 acres total surface use. 100' separation between wellhead and flare stack (minimum). Gravel pad, containment tanks (bulk oil, knockout), test tanks for oil and water.
📄 Pad layout and typical cross sections drawings; surface acreage summary; earthwork quantities (80,920 cu yd cut, 70,680 cu yd fill) · 📅 2025-12-16
Physical infrastructure footprint is fixed by permit. Co-location of five laterals on single pad creates ongoing operational, environmental, and community impact requiring adherence to layout plan. Reclamation phasing (3.72 acres interim) is forward obligation.

🔧 Operator Pattern

Phoenix Operating LLC demonstrates multi-well pad development strategy in tight formation (Bakken). Five-lateral unit (Peterson 1H–5H) with co-located saltwater disposal well (Peterson 1 SWD) indicates capital-intensive, long-term asset play with vertical integration of produced water handling.
Backbuild order notification (1/8/2026) shows proactive regulatory engagement on cross-boundary drilling geometry. Drilling plan specificity (mud chemistry, casing design, stimulation restrictions) indicates engineering oversight. However, operator failed to anticipate or resolve competing claim by Koda Resources Operating LLC, resulting in suspension of entire pad development 6 days after presumed permit issuance.

Confidence: Medium
File contains comprehensive technical submissions (drilling plan, wellbore geometry, pad layout, cores/samples directive, operational compliance letters) and multiple regulatory reference documents (Commission Order 34633, NDAC citations). Backbuild notification and suspension order are dated and explicit. However, critical deficiency: the actual permit approval letter or decision memo is absent from the file. The APD form shows 'Dirt Work Date 04/01/2026' but does not display a formal approval date or permit issuance date. Without the anchoring permit approval date, the temporal relationship between approval, pre-permit notifications, and the 1/14/2026 suspension cannot be conclusively established. The suspension on 1/14/2026 and pending revocation hearing create operational uncertainty that overshadows permit-cycle analysis. Date confidence on the permit itself is therefore 'Unknown.' Technical and regulatory content is high-confidence; permit decision timing is low-confidence.