🛢️ LOGAN FED 4-9-16 3HF

Phoenix Operating LLC · McKenzie County, ND · File #42762 · Generated 2026-04-04 15:56

API: 3305310766
Target Formation: Bakken (Middle Bakken)
Permit Explained: Yes

📋 Permit Cycle Assessment

The permit approval is justified by multiple contemporaneous compliance signals. Commission Order No. 34507 provides the regulatory authority and spacing unit definition (1920 acres, Sections 4, 9, 16) that conditions the directional well approval with specific north/south (150') and east/west (500') setbacks from unit boundaries. The south setback is explicitly tied to completion design—a production liner cemented in the lateral with wet shoe and frac-out capability, documented in the well design plan. Pre-permit coordination with federal BLM (notified 3/11/2026 by NDIC) and adjacent operator notification under Order 31848 (affidavit filed 3/11/2026) establish that operator has met multi-jurisdictional and multi-unit disclosure requirements. Surface use agreement with the landowner (executed February 2026) satisfies the prerequisite for off-spacing drilling from a single pad. The permit issued 3/12/2026 reflects completion of these antecedent regulatory and contractual conditions. No gaps in contemporaneous explanation.

🔍 Permit Cycle Signals (5)

Commission Order No. 34507 - establishes spacing unit and directional well approval conditions

Direct

📄 Permit page 1, Stipulations section
📅 2026-03-12 (Exact confidence)

Order 34507 is the regulatory authority conditioning the permit approval. It defines the 1920-acre spacing unit (Sections 4, 9, 16; T145N, R98W) and mandates 150-foot north/south and 500-foot east/west setbacks from unit boundaries for all un-cemented wellbore.

Production liner cemented in lateral with wet shoe and frac-out capability - South setback justification

Supporting

📄 Permit page 1, Conditions of Approval; Well Design Plan page showing wet shoe sub with HYD toe sleeve
📅 2026-03-12 (Exact confidence)

The south setback permit condition is explicitly tied to completion design: the wet shoe with ability to frac out the toe allows pressure testing and completion below the shoe. This technical feature differentiates the south boundary constraint from routine setback language and conditions approval on a specific completion geometry.

Federal minerals and BLM coordination requirement - email notification 3/11/2026

Direct

📄 Email from Doug Jackson (NDIC) to operator dated 3/11/2026, flagging federal permit requirement
📅 2026-03-11 (Exact confidence)

NDIC Engineering Technician directed operator to contact BLM Dickinson office to verify federal permit filing for spacing unit with federal minerals. This pre-approval signal indicates a condition precedent: operator must confirm BLM compliance before operations commence. Permit issued one day after this notification (3/12/2026).

Adjacent operator notification per NDIC Order 31848 - affidavit filed 3/11/2026

Supporting

📄 Affidavit of Meaghan Coughlan, Sr. Regulatory Specialist, dated 3/11/2026 (notarized); provides directional plan and contact data to Rockport Energy Solutions, LLC
📅 2026-03-11 (Exact confidence)

Order 31848 compliance: operator notified adjacent spacing unit operator of wellbore trajectory entering Bakken outside target unit. Directional drilling and completion plan, formation tops, casing/cement design, and spud date estimates provided. This satisfies a pre-permit regulatory requirement that conditions multi-unit lateral drilling approval.

Surface use agreement with landowner and corrected legal location

Supporting

📄 Affidavit of Ashleigh Borud, Surface Land Lead, dated February 2026; surface location SESE Section 32, T146N, R98W
📅 2026-02-Unknown (Inferred confidence)

Surface damage agreement with John & Brenda K. Kostelecky JT (landowners) is prerequisite for off-spacing horizontal drilling. Multi-well pad development (4 wells from single surface location in Section 32) requires executed surface use agreement before permit approval. Affidavit confirms agreement in place.

📖 Historical Context (3)

NDIC filter sock and filter media disposal requirement - 05/30/2025 regulatory letter
📄 Letter from Mark F. Bohrer, Assistant Director, NDIC, dated May 30, 2025, issued statewide re: 43-02-03-19.2 · 📅 2025-05-30
Effective June 1, 2014 forward-looking rule requires covered, placard'd leak-proof container on site from spud through completion and flowback for filter disposal. Operator assertions on permit (page 7, affirmed by operator) confirm acknowledgment of this standing requirement. Non-compliance can trigger enforcement action and waste disposal violations. Applies to all future operations on this well.

Bakken-Three Forks Petroleum System design change controls - NDIC operational requirement
📄 Permit page 9, Operator Assertions: 'any changes, shortening of casing point or lengthening at Total Depth or change in completion technique within the Bakken-Three Forks Petroleum System must have prior approval by the NDIC.' · 📅 Unknown
Standing NDIC policy restricts operator discretion post-approval. Any deviation from permitted casing point (7-inch intermediate at 12,344 MD), total depth (27,729 MD), or completion method (Middle Bakken perforations via production liner) requires prior NDIC approval. Creates compliance obligation for execution phase that supersedes routine operational flexibility.

Certified directional survey submission and logging requirements - standing NDIC rules
📄 Permit page 8-9, Operator Assertions: survey frequency 100 ft vertical, 30 ft in curve, 90 ft lateral; certified surveys to certsurvey@nd.gov; all logs as TIFF and LAS format to digitallogs@nd.gov · 📅 Unknown
Directional well requires mandatory real-time survey reporting at prescribed frequency. Failure to submit certified surveys and logs in required format can result in non-compliance notices and well shutdown orders. Applies throughout lateral drilling and completion execution.

🔧 Operator Pattern

Phoenix Operating LLC demonstrates multi-well, multi-unit development coordination typical of Bakken horizontal operators. Surface location in Section 32 (off-spacing from target Section 4, 9, 16 unit) used to drill four planned wellbores (LOGAN FED 4-9-16 1HF, 2HF, 3HF, 4HF) into adjacent spacing units. Operator proactively secured BLM notification, adjacent operator disclosures, and landowner agreements prior to permit issuance.
Multi-well location plan (4 wells from single pad), affidavit of adjacent operator notification to Rockport Energy Solutions LLC per Order 31848, surface use agreement with Kostelecky landowners, pad layout showing 4 directional point locations on graded pad. Operator address: 6414 Wickum Drive, Williston, ND 58801.

Confidence: High
Permit file contains complete contemporaneous documentation: (1) dated regulatory authority (Commission Order 34507, dated pre-permit); (2) technical justification for south setback tied to production liner design (wet shoe, frac-out capability); (3) pre-approval federal coordination notification (3/11/2026, one day pre-permit); (4) adjacent operator notification affidavit (3/11/2026) complying with Order 31848; (5) surface use agreement affidavit confirming landowner consent; (6) detailed directional design plan with formation tops, casing schedule, well geometry. Permit issued 3/12/2026 after all pre-requisites demonstrated. No missing dates or ambiguous regulatory citations. APD form completed and signed by qualified submitter (Meaghan Coughlan, Sr. Regulatory Specialist) and approved by Nathaniel Erbele, Petroleum Engineer, NDIC.