🛢️ AKEMI FERRARI 14-11-2 1H-LLR

Phoenix Operating LLC · Divide County, ND · File #43217 · Generated 2026-08-28 04:09

API: 3302301859
Target Formation: Bakken
Permit Explained: Yes

📋 Permit Cycle Assessment

The permit approval is directly conditioned by Commission Order 35013, which mandates specific wellbore geometry and setbacks. Additional direct conditions include a well sequencing requirement with an associated waiver. Supporting submissions include affidavits and letters requesting waivers for the three-day waiting period and Backbuild Order notification, justifying the permit's non-routine aspects.

🔍 Permit Cycle Signals (4)

Approval conditioned on Commission Order No. 35013, requiring the wellbore to be located down the north-south axis within the 500' drilling corridor and no closer than 150' setback from north & south boundaries of the 3840-acre spacing unit. North setback is based on a production liner cemented in the lateral with a wet shoe and ability to frac out the shoe.

Direct

📄 Permit Stipulations section
📅 2026-08-17 (Exact confidence)

This is the primary regulatory condition justifying the permit approval, directly referencing a Commission Order and specifying non-routine geometric constraints and engineering justifications for setbacks.

Condition that one horizontal well shall be drilled and completed in the standup 1920-acre spacing unit (Sections 2, 11, 14) prior to completing any horizontal well in the standup lease-line 3840-acre spacing unit (Sections 2, 3, 10, 11, 14, 15). Waiver granted based on supplied affidavit - NE*.

Direct

📄 Page 2 of 10
📅 2026-08-17 (Exact confidence)

This is a specific, non-routine sequencing condition attached to the permit approval, with an explicit waiver notation indicating a regulatory decision.

Affidavit from operator requesting waiver of the three-day waiting period, citing that the well pad is already constructed and the drilling rig is on site to facilitate timely operations.

Supporting

📄 Affidavit of Working Interest
📅 2026-08-14 (Exact confidence)

This is a direct, pre-approval submission justifying a waiver of a standard permit condition, tied to operational readiness.

Letter from operator requesting waiver of 'Backbuild Order' (NDIC Order 31848) notification requirements, stating Phoenix Energy is the operator of the adjacent spacing unit traversed, so no additional notification is necessary.

Supporting

📄 Letter dated August 13th, 2026 to Todd Holweger
📅 2026-08-13 (Exact confidence)

This is a direct, pre-approval submission addressing a specific regulatory order (31848) and justifying a waiver, conditioning the permit for a well that enters the target zone outside its spacing unit.

📖 Historical Context (1)

NDIC Order No. 31848 ('Backbuild Order') requires operators to provide directional drilling and completion plans, start dates, and contact info to operators of adjacent spacing units when a wellbore traverses outside its target unit.
📄 Operator letter dated August 13th, 2026 · 📅 Unknown
This order establishes a persistent regulatory obligation for any well that drills through an adjacent unit, affecting planning and communication for future wells with similar trajectories.

🔧 Operator Pattern

Proactive use of waivers and affidavits to expedite permitting and address regulatory conditions.
Submitted affidavit to waive three-day waiting period and letter to waive Backbuild Order notification requirements.

Confidence: High
The permit document contains explicit stipulations referencing Commission Orders and conditional approvals. Supporting waiver requests and affidavits are dated close to the permit submission and approval, providing clear contemporaneous explanation for the permit action.