🛢️ DC GUNNER 6-7-18-19 5H

Phoenix Operating LLC · Williams County, ND · File #42733 · Generated 2026-04-04 15:56

API: 3310506803
Target Formation: Bakken/Three Forks Petroleum System
Permit Explained: Yes

📋 Permit Cycle Assessment

Permit approval (02/25/2026) is explained by Commission Order No. 34678, which conditions authorization on setback compliance (150'/500') and coordinated spacing unit development. Technical submission of production liner design with wet shoe and fracout capability directly justifies the reduced 150' north/south setback. Pre-permit notification (02/17/2026) satisfies NDIC Order No. 31848 backbuild waiver requirement for adjacent spacing unit operator notification, enabling approval of horizontal trajectory entering Bakken outside target unit. All material permit conditions are traceable to explicit regulator orders or technical submissions provided within the permit cycle.

🔍 Permit Cycle Signals (4)

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

Direct

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

Regulator-issued order explicitly conditions the permit approval on specific geometric constraints tied to spacing unit boundaries and lateral isolation by cemented production liner with wet shoe and fracout capability

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

Direct

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

Regulator-imposed condition directly constrains this well's drilling authorization based on coordinated development of adjacent well geometry; indicates multi-well spacing justification

Production liner cemented in lateral with wet shoe and ability to frac out shoe justifies reduced 150' setback from north/south boundaries (vs. standard 500')

Supporting

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

Technical design feature (wet shoe with fracout capability) is explicitly cited by regulator as justification for setback variance, demonstrating permit-specific engineering condition

Backbuild waiver letter (February 17, 2026) documents operator notification and Phoenix Energy majority working interest in adjacent spacing unit, satisfying NDIC Order No. 31848 notification requirement

Supporting

📄 Backbuild Order Waiver letter, dated 02/17/2026
📅 2026-02-17 (Exact confidence)

Pre-permit filing (8 days before approval) explicitly addresses regulatory requirement for adjacent spacing unit operator notification under standing commission order; clears path for approval of wells entering Bakken outside target spacing unit

📖 Historical Context (4)

Little Muddy-Bakken Pool definition (50 feet above Bakken Formation top to 50 feet below Three Forks Formation top) established in permit conditions
📄 Permit page 1, STIPULATIONS section · 📅 2026-02-25
Pool definition persists as structural constraint on future completion and perforation decisions; defines objective interval (10301'-31055' MD) for this well and any future recompletions or sidetrack operations

Closed mud system with no cuttings pit required; all cuttings hauled to licensed facility (13 Mile Landfill, Williston)
📄 Permit page 1, CONDITIONS OF APPROVAL; Proposed Drilling Plan section · 📅 2026-02-25
Operational standard binding for drilling phase and any future workover operations involving drill cuttings; disposal facility identified establishes waste logistics requirement

Diesel-based compounds prohibited in hydraulic stimulation per CAS Registry Numbers 68334-30-5, 68476-34-6, 68476-30-2, 68476-31-3, 8008-20-6
📄 Proposed Drilling Plan section, STIMULATION · 📅 2026-02-25
Completion constraint persists; fracture treatment design and fluid selection must comply with diesel exclusion for all future stimulation operations on this wellbore

Filter sock disposal in leak-proof, covered, placard containers required from spud through flow-back (effective 06/01/2014 per ND Administrative Code 43-02-03-19.2)
📄 NDIC letter dated 05/30/2025; Permit page 8, Operator Assertions · 📅 2014-06-01
Ongoing operational requirement affecting drilling, completion, and flow-back phases; waste management standard persists beyond permit approval and extends through production testing

🔧 Operator Pattern

Phoenix Operating demonstrates awareness of regulatory coordination requirements and proactive multi-well development strategy. Operator filed backbuild waiver addressing adjacent spacing unit notification ahead of permit application and acknowledges inter-well drilling sequencing dependency.
Backbuild waiver letter (02/17/2026) identifies four additional wells (1H-LL, 2H, 3H, 4H) planned on same pad and notes Phoenix Energy majority working interest in adjacent spacing unit, eliminating notification barrier. Permit itself conditions approval on coordinated drilling with offset well meeting specified setback, indicating planned multi-well campaign with geometric interdependencies.

Confidence: High
Permit approval date is explicit (02/25/2026). All permit-cycle signals are directly sourced from regulator-issued conditions, commission orders, and pre-permit technical submissions dated within 8 days of approval. Backbuild waiver letter provides clear evidence of regulatory coordination completed before approval. Pool definition, mud system, and stimulation restrictions are unambiguous permit conditions. No material dates are inferred or missing. OCR text is legible and substantively complete for all permit-conditioning documents.