🛢️ DC GUNNER 6-7-18-19 3H

Phoenix Operating LLC · Williams County, ND · File #42729 · Generated 2026-04-04 15:56

API: 3310506800
Target Formation: Middle Bakken
Permit Explained: Yes

📋 Permit Cycle Assessment

The permit approval (2026-02-24) is conditioned directly on Commission Order No. 34678 and justified by: (1) completion design feature (production liner with wet shoe and frac-out capability) that enables south 150-foot setback waiver; (2) formalized Bakken Pool definition establishing regulatory interval; (3) approved backbuild waiver based on operator's controlling working interest in adjacent spacing unit, eliminating standard neighbor notification requirement per NDIC Order 31848; and (4) pre-permit directional survey and anti-collision analysis submitted 2026-02-16 confirming planned lateral trajectory clears offset wells. All non-routine permit conditions are explained by contemporaneous technical submissions and regulatory orders.

🔍 Permit Cycle Signals (5)

Commission Order No. 34678 referenced as condition of approval

Direct

📄 Permit Stipulations section, Page 2
📅 Unknown (Missing confidence)

The approval is explicitly conditioned on compliance with this Commission Order. The order establishes the legal framework for the well geometry and setback requirements.

Production liner cemented in lateral with wet shoe and ability to frac out shoe basis for south setback approval

Direct

📄 Permit Stipulations section, Page 2
📅 2026-02-24 (Exact confidence)

The permit explicitly conditions the south 150' setback approval on a specific completion design feature (wet shoe with frac-out capability). This ties well geometry to completion technique and justifies waiver of standard setback constraints.

Bakken Pool definition: 50 feet above Bakken Formation top to 50 feet below Three Forks Formation top

Direct

📄 Permit Stipulations section, Page 2
📅 2026-02-24 (Exact confidence)

Pool definition is formalized in the permit approval and establishes the regulatory interval for completion design and offset well notification obligations.

Backbuild Order Waiver requested and approved for multi-well pad (5 wells) with lateral entry outside spacing unit

Supporting

📄 February 17, 2026 letter from Phoenix Energy to NDIC; Permit approval page 3 (well info) and directional plan
📅 2026-02-17 (Exact confidence)

Phoenix Energy holds majority working interest in adjacent spacing unit; waiver of backbuild notification requirement per NDIC Order 31848 was justified by same-entity ownership. This is a non-routine regulatory accommodation directly conditioning the permit approval.

Offset well anti-collision review completed; directional plan submitted with well trajectory design showing clearance from offset wells (PEDERSON 1-18-19H, DC GUNNER 1H-LL, 4H, 5H, 2H)

Supporting

📄 Directional plan (TAKTIKAL Survey Report, dated 2/16/2026); Well location plat with offset well positions annotated
📅 2026-02-16 (Exact confidence)

Operator assertion 'reviewed any wells within 500' and addressed anti-collision concerns' confirmed by directional survey showing planned lateral trajectory relative to offset wellbores. This is pre-permit technical submission supporting approval of the lateral design.

📖 Historical Context (5)

Filter sock disposal requirement: covered leak-proof container with placard required on-site from spudding through completion and flowback
📄 NDIC letter dated May 30, 2025 (RE: Filter Socks and Other Filter Media); Permit conditions page 2-3; Operator assertion page 8 · 📅 Unknown
Statutory requirement per ND Administrative Code Section 43-02-03-19.2 (effective 2014-06-01) that persists across all phases of well operations. Operator must maintain compliant container throughout drilling, completion, and flowback phases.

Closed mud system with no cuttings pit required by permit
📄 Permit Stipulations page 2 · 📅 Unknown
Operational constraint that applies throughout drilling phase. Requires all cuttings disposal through closed circulation system rather than surface pit, affecting drilling execution plan and waste handling logistics.

Certified directional survey submission frequency: 100 feet vertical, 30 feet in curve/sliding, 90 feet lateral; certified surveys to certsurvey@nd.gov
📄 Permit operator assertion page 9 · 📅 Unknown
Mandatory reporting protocol for entire lateral drilling phase. Non-compliance creates regulatory violation risk independent of this permit.

Porosity and resistivity log requirement per ND Administrative Code Section 43-02-03-31 unless waived by Director
📄 Permit operator assertion page 10 · 📅 Unknown
Statutory logging obligation that must be satisfied prior to well completion. Logs must be submitted in TIFF and LAS format to digitallogs@nd.gov at no charge to NDIC.

Any changes to casing point, total depth, or completion technique within Bakken-Three Forks Petroleum System require prior NDIC approval
📄 Permit operator assertion page 9 · 📅 Unknown
Constraint that applies throughout drilling and completion phases. Design modifications cannot be unilaterally executed; each change requires separate regulatory approval.

🔧 Operator Pattern

Phoenix Operating LLC operates multi-well development pads in Williams County Bakken with integrated working interest ownership across adjacent spacing units and related operator relationships
Phoenix Energy (related entity) holds majority working interest in adjacent spacing unit where DC GUNNER laterals enter Bakken; backbuild waiver justified by common ownership (February 17, 2026 letter). Directional plan references 5-well pad development (1H-LL, 2H, 3H, 4H, 5H) with coordinated trajectory design. Operator compliance history appears routine based on permit conditions without special remedial or corrective orders.

Confidence: High
Permit file is complete with signed approval (2026-02-24), contemporaneous directional survey (2026-02-16), backbuild waiver justification letter (2026-02-17), and pad engineering drawings. All material permit conditions are explicitly traced to regulatory orders (Commission Order 34678, NDIC Order 31848) or technical submissions (directional survey, anticollision analysis). No ambiguity regarding approval date, operator, or well identification. OCR text is legible on all critical permit sections and supporting documents.