🛢️ QUARNE FED 2-11-14-23 2HF

Phoenix Operating LLC · Williams County, North Dakota County, ND · File #42637 · Generated 2026-02-13 12:33

API: 3310506779
Target Formation: Bakken Formation
Permit Explained: Partially

📋 Permit Cycle Assessment

The permit approval is partially explained by contemporaneous documentation. Commission Order No. 34633 directly conditions the approval through setback stipulations tied to liner design (wet shoe with frac-out capability). The Bakken Setback Summary Statement explicitly justifies the south setback variance. NDIC Order No. 31848 (notification requirement to adjacent operators) and the 1/12/26 federal mineral interest alert represent relevant execution constraints, though the federal coordination issue appears unresolved at permit issuance. No pre-permit technical justification document (anticollision study, detailed trajectory analysis, or waiver request) is present in the file. The permit relies on boilerplate pool definitions, closed mud systems, and standard safety devices; these are not elevated as they are routine and non-differentiating. The wet shoe design is the primary technical differentiator supporting permit approval, but detailed engineering justification is absent.

🔍 Permit Cycle Signals (4)

Commission Order No. 34633 establishes setback requirements (150' north/south, 1220' east/west) and defines the 2560-acre spacing unit (Sections 2, 11, 14, and 23, T159N, R103W) within which the wellbore must be isolated by cement.

Direct

📄 Permit Stipulations - NDIC Field Order Info
📅 Unknown (Missing confidence)

Direct regulatory constraint conditioning wellbore geometry and spatial isolation. South setback specifically referenced to production liner cemented in lateral with wet shoe and fracture capability.

Production liner with wet shoe and ability to frac out shoe justifies south setback variance from standard 150' setback policy, as stated in Bakken Setback Summary Statement.

Direct

📄 Permit Stipulations - Bakken Setback Summary Statement
📅 Unknown (Missing confidence)

Regulator-approved liner design explicitly conditions the setback approval, differentiating this permit from routine drilling.

Federal mineral interest notification issued 1/12/26 (post-application). Operator required to contact BLM Dickinson office to ensure federal permit documentation properly filed for wells within 2560-acre spacing unit subject to federal jurisdiction.

Supporting

📄 Email from Nathaniel Erbele (NDIC Petroleum Engineer) to operator, dated 1/12/2026
📅 2026-01-12 (Exact confidence)

Identifies federal permitting requirement parallel to state permit. Temporal proximity to permit approval (05/15/2026 dirt work date) indicates unresolved federal coordination at permit issuance. Creates execution dependency external to NDIC authority.

NDIC Order No. 31848 requires operator to notify adjacent spacing unit operator (Koda Resources) and provide directional plan, drilling commencement date, and contact information prior to wellbore entry into adjacent spacing unit.

Supporting

📄 Affidavit of Tori Siemieniewski, Director—Bakken Regulatory, dated 12/31/2025
📅 2025-12-31 (Exact confidence)

Operator obligation to notify and disclose drilling trajectory details to offset operator. Condition imposed by prior commission order conditioning drilling in multi-spacing context.

📖 Historical Context (2)

Filter sock and waste disposal requirements per NDIC letter dated 5/30/2025 mandating leak-proof container maintenance from spud through flowback, effective 6/1/2014.
📄 NDIC letter from Mark F. Bohrer (Assistant Director) re: Filter Socks and Filter Media, dated 5/30/2025 · 📅 2025-05-30
Operational mandate persisting beyond permit issuance. Defines mandatory container management and waste handling protocol affecting cleanup and reclamation phases. Non-compliance creates regulatory violation independent of drilling permit.

Grenora-Bakken Pool defined as interval from 50 feet above Bakken Formation top to 50 feet below Three Forks Formation top per NDIC Field Order (embedded in permit stipulations).
📄 Permit Stipulations - NDIC Field Order Info · 📅 Unknown
Pool definition controls regulatory jurisdiction for subsequent production and disposition phases. Affects completion design scope, production accounting, and potential future communitization disputes.

🔧 Operator Pattern

Multi-well pad development strategy in Bakken with coordinated federal/state permitting across five horizontal wells (1HF–5HF) within single 2560-acre spacing unit.
Affidavit and survey documentation show simultaneous five-well application portfolio from common pad location (Lot 4, Section 2). Federal notification letter addresses all five wells collectively, indicating integrated permitting approach and federal coordination complexity.

Confidence: Medium
Permit approval date is anchored (05/15/2026 dirt work date). Commission Order No. 34633 and wet shoe design justification are explicit and on-record. However, the file lacks dated permit issuance document itself, making precise temporal alignment difficult. Federal coordination issue (1/12/26 email) post-dates typical application but pre-dates dirt work approval, creating ambiguity about whether federal permitting was resolved prior to NDIC approval. No pre-permit technical reports (trajectory analysis, anticollision studies, or engineering justification) are present, limiting assessment of full justification basis. OCR text quality is degraded in survey pages, potentially obscuring detail. Affidavit and notification requirement are clear and dated.