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🛢️ DANNY NOONAN 28-21-16 1H
Phoenix Operating LLC · Divide County, ND · File #42670 · Generated 2026-02-13 12:33
- API
- 3302301752
- Target Formation
- Middle Bakken
- Permit Explained
- Partially
📋 Permit Cycle Assessment
The file contains direct regulatory conditioning of the permit via Commission Order No. 34326 (setback geometry tied to production liner design) and contemporaneous state mandate for geological sample collection. The permit approval on 2026-02-02 is explained by these structural requirements. However, the file does not contain a formal permit decision letter, rationale statement, or reference to environmental review, spacing approval, or operator qualification. The cores/samples mandate and backbuild notification were issued/submitted near the permit date but do not independently justify the permit—they operationalize it. The drilling plan and APD form contain standard conditions (closed mud system, remote shutoff, conductor conductor approval) that are boilerplate and do not differentiate this permit from routine horizontal approvals. No waiver requests, variance justifications, or contested issues appear in the record. The permit appears to have been approved as a standard horizontal well under existing field orders, with geometry and geological collection requirements as the primary non-routine constraints.
🔍 Permit Cycle Signals (4)
📄 Permit APD, STIPULATIONS section, NDIC Field Order Info
📅 2026-02-02 (Exact confidence)
Non-routine setback condition directly tied to well geometry (production liner wet shoe) and completion method (frac-out). This is the regulatory constraint that conditions the permit approval and differentiates this horizontal well from boilerplate spacing.
📄 Cores and Samples letter dated 2/2/2026 from Ross Edison, Geologist, ND Department of Mineral Resources
📅 2026-02-02 (Exact confidence)
State-mandated geological documentation requirement issued contemporaneously with permit approval. Operative constraint on drilling operations (collection timing, sample depth trigger, submission deadline). Directly conditions drilling execution.
📄 Proposed Drilling Plan, Section 5 (STIMULATION)
📅 Unknown (Missing confidence)
Operator-committed restriction on stimulation chemistry. Non-routine constraint on completion design. No regulatory order cited, but integrated into drilling plan submitted for permit approval.
📄 Letter to Todd Holweger, NDIC Permit Manager, dated January 28th, 2026
📅 2026-01-28 (Exact confidence)
Pre-permit notification of cross-boundary drilling triggered by Order 31848. Demonstrates awareness of regulatory requirement and satisfaction of notice condition prior to permit issuance. Relevant to trajectory design and adjacent-unit compliance.
📖 Historical Context (4)
Noonan-Bakken Pool definition (Permit stipulations) establishes cumulative stratigraphic interval from 50 ft above Bakken top to 50 ft below Three Forks top. This pool definition applies to all future operations in the spacing unit and constrains perforating, completion, and production accounting.
📄 Permit APD, STIPULATIONS section, NDIC Field Order Info (pool definition) · 📅 Referenced as standing definition; no revision date provided
Pool definition is permanent regulatory framework for this well and unit. All future completions, workovers, conversions, and abandonment must reference this interval. Affects future permitting of offset wells, SWD designations, and production allocation.
Closed mud system mandate with cuttings disposal to Smoky Butte Environmental LLC (13310 94th Street NW, Fortuna, ND 58844). All drill cuttings to be temporarily collected in metal containers and hauled to licensed facility. No cuttings pit permitted.
📄 Proposed Drilling Plan, Section 4 (DISPOSAL OF DRILL CUTTINGS) · 📅 Unknown
Operational constraint persisting through entire drilling phase. Cuttings management vendor identified; deviations require sundry notice. Affects drilling schedule, logistics, and cost. Regulatory non-compliance risk if alternative disposal attempted.
Filter sock and waste material containment requirement (May 30, 2025 letter from Mark F. Bohrer, NDIC Assistant Director). Leak-proof, covered container required on-site from spud through flowback when filtration is conducted. Container must remain on-site during all phases. NDAC 43-02-03-19.2 compliance mandatory.
📄 May 30, 2025 letter RE: Filter Socks and Other Filter Media · 📅 2025-05-30
Standing operational requirement applicable to this well drilling and any future well operations. Container requirement extends from spud through flowback. Non-compliance triggers civil penalty exposure (up to $12,500 per violation, each day separate). Affects site logistics and environmental controls.
Conductor setting restriction: 'Conductor may be set on permitted wells only.' Applies to this well and constrains early casing program decisions. Standard language but operationally binding.
📄 Permit APD, STIPULATIONS section, Conditions of Approval · 📅 2026-02-02
Casing design constraint. Conductor shoe depth and shoe track cement planning must comply. Affects wellbore pressure regimes and intermediate casing design.
🔧 Operator Pattern
Phoenix Operating LLC demonstrates multi-well development of common pad (five laterals planned: 1H, 2H, 3H, 4H, 5H) with centralized infrastructure and unified drilling/completion logistics. Operator self-identifies as responsible steward ('committed to conducting operations in a responsible and safe manner') and proactively manages neighbor relations and regulatory notification.
Backbuild letter (2026-01-28) demonstrates advance notice strategy and cross-unit operator coordination (Phoenix Energy identified as adjacent operator). Pad design documents show integrated containment (10,593 bbls primary, 72,269 bbls secondary) and centralized waste management (single cuttings disposal vendor). APD includes voluntary diesel restrictions (no statutory mandate cited) and closed mud system commitment, suggesting environmental compliance posture beyond minimum regulatory baseline.
Confidence: Medium
The permit approval date is definitive (2026-02-02, stated on APD). Commission Order No. 34326 and the cores/samples mandate are explicitly tied to permit issuance and represent direct regulatory conditioning. However, the file lacks a formal permit decision letter, stated rationale, or approval documentation explaining why this specific permit was granted on this date. Standard boilerplate conditions (mud system, shutoff devices, pool definition, setbacks) are present but do not differentiate this permit. The backbuild notification (2026-01-28) precedes permit approval by 5 days, suggesting pre-permit coordination, but no correspondence showing NDIC approval of the cross-boundary drilling strategy appears in the file. Drilling plan and APD are operator submissions; regulator approval/modification is not documented. The file is functionally complete for operational execution but incomplete for permit-cycle causation analysis. Confidence is reduced by absence of formal approval letter and permitting rationale.