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COMPLETION
Completion: The permit approval is directly explained by Commission Order 34482 conditioning approval on specific spacing unit setbacks, with a technical justification for the north setback. Additional regulatory conditions include a BLM coordination requirement and a submitted waiver for drilling outside the t
Updated 2026-10-14 · was Sep 29, 2026 · +-23 pages · Full diff →

Huron State 44-36 36-25 TF4H

True Oil LLC · McKenzie County, ND · File #43346 · Generated 2026-10-14 06:31

API
3305310896
Target Formation
Three Forks
Permit Explained
Yes

Permit Cycle Assessment

The permit approval is directly explained by Commission Order 34482 conditioning approval on specific spacing unit setbacks, with a technical justification for the north setback. Additional regulatory conditions include a BLM coordination requirement and a submitted waiver for drilling outside the target unit.

Permit Cycle Signals (4)

Approval conditioned on adherence to spacing unit setbacks (150' north/south, 500' east/west) within the 1280-acre unit (Sections 25 & 36, T148N, R102W) pursuant to Commission Order No. 34482.
Direct
Page 1 - Stipulations section
Unknown (Missing confidence)
The permit approval is explicitly granted on the condition of meeting these specific spacing unit setbacks, directly referencing a Commission Order.
The north setback condition is justified by a specific wellbore construction detail: 'production liner cemented in the lateral with a wet shoe and the ability to frac out the shoe.'
Direct
Page 1 - Stipulations section, following setback condition
Unknown (Missing confidence)
This technical detail provides a specific, non-boilerplate justification for a modified setback requirement (150' north), differentiating it from standard conditions.
Waiver request and compliance statement regarding NDIC Order 31848 requirements for wellbores entering the Bakken Petroleum System outside the target spacing unit.
Supporting
Drill Back Waiver Request Letter (located near end of file)
Unknown (Missing confidence)
This waiver request directly addresses a regulatory condition for approval, as the wellbore is noted to enter outside the target unit.
Regulator notification to operator about potential Federal permit requirement due to location within a spacing unit containing Federal minerals, directing contact with BLM.
Direct
Email from Nathaniel Erbele dated 9/25/2026
2026-09-25 (Exact confidence)
Direct communication from the permitting engineer on the approval date, indicating a specific, non-routine regulatory condition for permit validity.

Historical Context (2)

Waiver and compliance plan for NDIC Order 31848 regarding notification to operators of adjacent spacing units when a wellbore enters the Bakken Petroleum System outside its target unit.
Drill Back Waiver Request Letter · Unknown
The obligation to notify any future operator who permits in the adjacent unit (Sec 1, T147N, R102W) persists beyond this permit's approval and must be executed if conditions change.
Anticollision analysis shows separation factors below 2.0 (as low as 1.852) with offset wells Huron State 44-36 36-25 B3H, requiring 'Collision Risk Procedures'.
Anticollision Report pages (e.g., page referencing '1.852 Collision Risk Procedures Req., SF') · 2025-10-30
The identified collision risk with nearby wells on the pad imposes a persistent operational constraint requiring specific drilling procedures during execution.

Operator Pattern

Proactive submission of regulatory compliance statements (diesel fuel, cuttings disposal, pad containment) and waiver requests ahead of permit application.
File contains dated letters from operator regarding no diesel fuel in fracs, approved cuttings disposal, and pad dike construction.
Confidence: High
The permit document contains explicit, regulator-written stipulations that condition approval. Supporting waiver requests and direct regulator correspondence are present and clearly dated or contextualized.