TOP GUN 30-19-18-7 1HF

Phoenix Operating LLC · Divide County, ND · File #43354 · Generated 2026-10-14 06:31

API: 3302301895
Target Formation: Bakken
Permit Explained: Yes

Permit Cycle Assessment

The permit approval is directly conditioned on specific, non-standard geometry (wet shoe/liner justifying reduced north setback) and a requirement to drill in conjunction with another well meeting a 1220' setback. Supporting waiver requests and surface agreements justify the off-spacing surface location and entry into the target formation.

Permit Cycle Signals (4)

Permit approval is conditioned on all portions of the well bore not isolated by cement maintaining a 150' setback from north/south boundaries and 500' from east/west boundaries within the 2560-acre unit. The north setback is specifically justified by a production liner cemented in the lateral with a wet shoe and ability to frac out the shoe.

Direct

Permit Stipulations section, Page 1
2026-09-30 (Exact confidence)

Direct condition of approval tied to specific well geometry and completion design (wet shoe, liner) rather than standard setback.

In order to justify the spacing unit, this well must be drilled in conjunction with a well that meets a 1220' setback from the east and west spacing unit boundaries.

Direct

Permit Stipulations section, Page 2
2026-09-30 (Exact confidence)

Direct condition of approval that links this permit's validity to the drilling of another specific well with a defined geometry.

Operator waiver request letter citing NDIC Order 31848 for wells entering the Bakken system outside the target spacing unit. States no additional notification is needed as Phoenix is majority WI owner in adjacent sections.

Supporting

Letter from Meaghan Coughlan to Todd Holweger, dated September 9, 2026
2026-09-09 (Exact confidence)

Supporting submission justifying regulatory compliance for off-spacing entry, directly tied to permit approval for this well and others on the pad.

Affidavit of Surface Damage Agreement executed with landowner for drilling multiple wells, including this one, from an off-spacing surface location.

Supporting

Affidavit signed by Ashleigh Borud
2026-09-24 (Exact confidence)

Supporting legal document required for permit approval of off-spacing surface location, covering this well.

Historical Context (3)

NDIC Order No. 35009 establishes the 2560-acre spacing unit (Sections 7, 18, 19, 30) and defines the Alkabo-Bakken Pool. This order is the foundational authority for the well's permit.
Permit Stipulations section, Page 1 · Unknown
The well's legal authorization to produce from the defined pool and its required placement within the specified spacing unit are governed by this order for the life of the well.

Federal mineral review may be required. NDIC engineer notification that the spacing unit may be subject to a Federal permit and instruction to contact BLM.
Email from Nathaniel Erbele to Meaghan Coughlan, dated September 22, 2026 · 2026-09-22
This creates a potential ongoing federal coordination obligation for operations within the spacing unit, impacting future permits or modifications.

NDIC Order No. 31848 imposes notification requirements for wells entering the Bakken Petroleum System outside the target spacing unit.
Operator waiver request letter, September 9, 2026 · Unknown
This order establishes a persistent regulatory rule for any future wells drilled from off-spacing surface locations into adjacent units, requiring similar waiver justifications.

Confidence: High
The permit document contains explicit, non-boilerplate conditions of approval directly tied to the well's specific geometry and drilling plan. Supporting contemporaneous documents (waiver request, surface affidavit) are dated pre-approval and clearly linked to permit requirements. Key dates (approval, submissions) are explicitly provided.