🛢️ DC GUNNER 6-7-18-19 2H

Phoenix Operating LLC · Williams County, ND · File #42731 · Generated 2026-04-04 15:56

API: 3310506801
Target Formation: Bakken-Three Forks Petroleum System (Little Muddy-Bakken Pool)
Permit Explained: Yes

📋 Permit Cycle Assessment

The permit approval dated 2026-02-25 is substantiated by Commission Order No. 34678 and contemporaneous directional drilling, completion, and pad engineering plans (dated 2026-02-16 to 2026-02-18). The permit conditions setbacks (150'/500') and spacing unit justification requirement to a coordinated offset well are explained by the well's horizontal geometry and multi-well pad layout. The completion design (wet shoe with frac-out capability) and closed mud system are explicit conditions conditioning approval. The backbuild waiver letter (2026-02-17) confirms operator control of adjacent spacing unit and satisfies Order 31848 notification requirements. All permit-cycle signals directly reference regulatory orders and technical plans submitted within the approval window.

🔍 Permit Cycle Signals (4)

Commission Order No. 34678 conditioning approval on well bore setback compliance (150' north/south, 500' east/west from 2560-acre spacing unit boundaries)

Direct

📄 Permit, Stipulations section, page 1
📅 2026-02-25 (Exact confidence)

Regulatory order directly conditions permit approval and defines mandatory wellbore geometry constraints that differentiate this horizontal well from standard lateral drilling.

Spacing unit justification requirement: well must be drilled in conjunction with offset well meeting 1220' setback from east/west boundaries

Direct

📄 Permit, Conditions of Approval, page 2
📅 2026-02-25 (Exact confidence)

Non-routine spacing condition ties this well's approval to coordinated offset well drilling; backbuild waiver letter (2026-02-17) confirms Phoenix Energy controls adjacent spacing unit, eliminating need for third-party operator notification under Order 31848.

Production liner cemented in lateral with wet shoe and ability to frac out shoe; south setback basis conditioned on this completion design

Direct

📄 Permit, Stipulations section, page 1
📅 2026-02-25 (Exact confidence)

Specific completion design (wet shoe, frac-out capability) is explicit condition of approval; setback relaxation depends on this design choice, making it non-routine and operationally material.

Closed mud system with no cuttings pit required; all cuttings to 13 Mile Landfill disposal facility

Supporting

📄 Permit Conditions and Drilling Plan, pages 1–2; Drilling Operations Plan section
📅 2026-02-25 (Exact confidence)

Closed-loop system stipulation differentiates from open pit baseline; tied to operational execution and waste management compliance.

📖 Historical Context (3)

Filter sock disposal requirement per NDIC directive effective 2014-06-01: leak-proof, covered, placarded container mandatory on-site from spud through flowback whenever filtration operations conducted
📄 NDIC letter dated 2025-05-30; Permit acknowledgment, page 9 · 📅 2014-06-01
Standing waste management obligation for all North Dakota wells; persists throughout drilling, completion, and flowback phases. Non-compliance exposes operator to enforcement under 43-02-03-19.2.

Operator assertion: acknowledge 21–31 day advance notice requirement to adjacent pool operators if completion intervals within 2,640 feet of one another (per NDIC regulation)
📄 Permit, Operator Assertions, page 7 · 📅 2026-02-25
Standing operational obligation upon spud; conditions communication and scheduling with neighboring operators during completion planning and execution.

Diesel-based compound prohibition in hydraulic stimulation: seven specific CAS Registry Numbers (68334-30-5, 68476-34-6, 68476-30-2, 68476-31-3, 8008-20-6, and two others) explicitly forbidden
📄 Drilling Plan, Stimulation section, page 2 · 📅 2026-02-25
Non-waivable constraint on completion fluids; restricts contractor fluid selection and persists throughout frac design and execution phases.

🔧 Operator Pattern

Phoenix Operating LLC demonstrates multi-well coordinated development strategy on shared pad with common infrastructure and spacing unit consolidation.
DC GUNNER pad engineered for five wells (1H-LL, 2H, 3H, 4H, 5H) with shared production facilities, centralized containment, and single access road. Backbuild waiver letter (2026-02-17) confirms Phoenix Energy majority working interest in adjacent spacing unit, eliminating third-party notification requirements and enabling optimized lateral placement across spacing unit boundaries.

Confidence: High
Permit file contains explicit regulatory order (Commission Order No. 34678), dated directional plans, completion design specifications, and contemporaneous waiver letter addressing spacing/offset well coordination. All permit-cycle conditions are traceable to specific document citations with exact approval date (2026-02-25). No missing critical dates or unexplained regulatory orders. OCR quality is sufficient for identification of regulatory signals and technical parameters.