🛢️ DANNY NOONAN 28-21-16 3H

Phoenix Operating LLC · Divide County, ND · File #42671 · Generated 2026-02-13 12:33

API: 3302301753
Target Formation: Middle Bakken
Permit Explained: Yes

📋 Permit Cycle Assessment

The permit approval (2026-02-02, File No. 42671) is directly explained by Commission Order No. 34326, which establishes the 1920-acre spacing unit, setback distances (150' N/S, 1220' E/W), and pool definition. The permit cites this order as the condition of approval. The non-routine setback justification—tied to production liner design with wet shoe and frac-out capability—is affirmatively stated in the permit stipulations and operationalized in the drilling plan. Contemporaneous State Geologist mandate (dated 2026-02-02) conditions core/sample collection protocols binding operational execution. Pre-permit backbuild notification (2026-01-28) demonstrates compliance with NDIC Order No. 31848 regarding directional entry into adjacent units. Proposed drilling plan (casing, mud, closed system, diesel prohibition) supports and implements the permit conditions. All material permit-cycle signals are documented and time-bound to the approval date or immediately antecedent (backbuild letter).

🔍 Permit Cycle Signals (5)

Commission Order No. 34326 establishes spacing unit (1920 acres, Sections 16, 21, 28) and setback requirements: 150' from north/south boundaries, 1220' from east/west boundaries. Setback justification tied to production liner cemented in lateral with wet shoe and ability to frac out shoe.

Direct

📄 Permit for New Well - Horizontal, STIPULATIONS section, NDIC Field Order Info
📅 2026-02-02 (Exact confidence)

Directly conditions the approved well geometry and lateral placement. Non-routine setback justification (wet shoe, frac-out capability) is affirmatively tied to the permit approval and constrains completion design.

Noonan-Bakken Pool definition established: 50 feet above top of Bakken to 50 feet below top of Three Forks Formation. Defines target interval and regulatory pool for spacing compliance.

Direct

📄 Permit for New Well - Horizontal, STIPULATIONS section, NDIC Field Order Info
📅 2026-02-02 (Exact confidence)

Pool definition is prerequisite for permit issuance and establishes regulatory target; required by Commission order for spacing unit governance.

State Geologist (via letter dated 2026-02-02) mandates core and sample collection commencing at Base of Last Charles Salt, with specified intervals (30' vertical/build, 200' horizontal), sample packaging, and delivery to ND Geological Survey within 30 days of drilling completion. Violation carries civil penalty up to $12,500/day per NDCC §38-08-16.

Direct

📄 Letter from Ross Edison, Geologist, dated 2026-02-02, citing NDCC §38-08-04 and NDAC §43-02-03-38.1
📅 2026-02-02 (Exact confidence)

Regulatory mandate conditioning drilling operations and requiring specific stratigraphic sampling protocol. Issued contemporaneously with permit approval; directly binds operational execution.

Backbuild waiver letter (dated 2026-01-28) to NDIC Permit Manager addresses horizontal well entry into adjacent spacing unit under NDIC Order No. 31848. Operator notifies of directional plan details and confirms Phoenix Energy (operator of adjacent unit) notification satisfied. Backbuild does not appear to require formal waiver but is documented as operator commitment to regulatory compliance.

Supporting

📄 Letter from Meaghan Coughlan, Senior Regulatory Specialist, Phoenix Operating LLC, dated 2026-01-28, to Todd Holweger, Permit Manager/Geophysical Supervisor, NDIC
📅 2026-01-28 (Exact confidence)

Pre-permit notification letter documenting operator's compliance with backbuild notification requirement (Order 31848). Demonstrates due diligence prior to permit approval and establishes trajectory plan commitment.

Proposed Drilling Plan specifies: (1) Casing program with production liner (4.5" @ 7875'-24354' MD) set as horizontal liner with wet shoe and frac-out capability; (2) Mud program transitions from fresh water (0-1733') to invert (1733-8880') to brine (8880-24354'); (3) Closed-loop cuttings system with disposal at Smoky Butte Environmental LLC; (4) Prohibition on diesel-based compounds in hydraulic stimulation (six CAS registry numbers explicitly banned).

Supporting

📄 Proposed Drilling Plan section of permit package; Cementing Program shows Production Liner tail cement Class G/POZ with specified additives and top of cement at liner top
📅 Unknown (Missing confidence)

Drilling and completion plan operationalizes the permit conditions (wet shoe, frac-out design, closed mud system). Diesel prohibition is explicit regulatory constraint on stimulation fluids. Provides technical justification for the setback waiver tied to liner design.

📖 Historical Context (1)

Filter sock and waste container requirement (per NDAC §43-02-03-19.2, effective 2014-06-01). All wells spud in North Dakota require on-site leak-proof, covered, placoded container for filter disposal commencing at spud and remaining through completion and flow-back. Violation enforced via solid waste disposal permits under ND Department of Environmental Quality.
📄 Letter dated 2026-05-30 from Mark F. Bohrer, Assistant Director, Oil and Gas Division, to Operators (general circulation); references NDAC §43-02-03-19.2 and NDAC §33.1-20-02.1-01 · 📅 2014-06-01
Standing operational requirement for all future drilling phases (well construction, completion, flow-back). Does not condition this specific permit but persists as a compliance obligation throughout the well life. Operator may waive via Form 4 Sundry Notice only if no filtration system is used.

🔧 Operator Pattern

Phoenix Operating LLC demonstrates regulatory engagement and multi-well pad development strategy. The Danny Noonan pad consolidates five horizontal wells (1H–5H) from single location with coordinated spacing unit notification and backbuild compliance.
Five well applications (1H, 2H, 3H, 4H, 5H) from same pad; pre-permit backbuild notification letter addressing adjacent-unit directional entry; operator-specific contact (Meaghan Coughlan, Senior Regulatory Specialist, 855-565-4244) indicating dedicated regulatory function.

Confidence: High
Permit file contains direct regulatory orders (Commission Order No. 34326), contemporaneous State Geologist mandate, proposed drilling plan with specific design parameters, pre-permit backbuild notification, and surface location survey with registered surveyor certification. Permit approval date (2026-02-02) is explicit. All permit-cycle signals are document-linked and time-anchored. No material dates are missing from the critical path (backbuild notification 2026-01-28, permit issuance 2026-02-02, core/sample letter same date). Casing design, cementing, mud program, and stimulation constraints are fully specified. Historical obligations (filter containers) are regulatory background with no permit-specific innovation.