TOP GUN 30-19-18-7 2HF

Phoenix Operating LLC · Divide County, ND · File #43355 · Generated 2026-10-14 06:31

API: 3302301896
Target Formation: Bakken
Permit Explained: Yes

Permit Cycle Assessment

The permit approval is directly explained by contemporaneous regulatory communications and operator submissions. Key factors include: a specific setback condition tied to wellbore design and spacing unit geometry (Order 35009), a pre-submitted waiver for drilling outside the target unit (Order 31848), and a notification regarding Federal mineral clearance requirements.

Permit Cycle Signals (4)

Permit granted on condition that well bore not isolated by cement maintain 150' setback from N/S boundaries and 500' from E/W boundaries within the 2560-acre spacing unit (Sections 7, 18, 19, 30). The north setback is based on a production liner cemented in the lateral with a wet shoe and the ability to frac out the shoe.

Direct

Permit Information, Conditions of Approval
2026-09-30 (Exact confidence)

This condition, citing Order 35009, specifically ties permit approval to a non-standard north setback justification (wet shoe design) and explicitly defines the spacing unit geometry.

Backbuild Order Waiver request (citing Order 31848) submitted, stating the wells (including this one) will enter the Bakken Petroleum System outside the target spacing unit. Waiver justification is that Phoenix is the majority WI owner in adjacent sections.

Supporting

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

This pre-permit waiver request directly addresses a regulatory requirement (Order 31848) for drilling outside the target unit and provides the operator's justification for waiver, conditioning permit approval.

Federal mineral notification from NDIC engineer Nathaniel Erbele to operator, noting the permit applications (including this well) are within a spacing unit that may be subject to a Federal permit and instructing contact with BLM.

Direct

Email from Nathaniel Erbele, September 22, 2026
2026-09-22 (Exact confidence)

Direct regulatory communication highlighting a specific, non-routine permitting constraint (Federal minerals) that the operator must address for permit validity.

Operator must contact NDIC Field Inspector Marc Binns prior to location construction.

Direct

Permit Information, Stipulations
2026-09-30 (Exact confidence)

A specific, non-boilerplate pre-construction notification requirement tied to a named inspector, conditioning permit approval.

Historical Context (2)

Affidavit of Surface Damage Agreement executed for the multi-well pad, covering this well and others. Acknowledges drilling multiple wells off-spacing from a surface location in Section 31.
Affidavit of Surface Damage Agreement, dated September 24, 2026 · 2026-09-24
This surface use agreement is a binding legal obligation that governs land access and damages for the entire pad, persisting through drilling and completion of all listed wells.

The well is part of a multi-well pad (TOP GUN ROOSTER MAVERICK 31 Pad) with detailed engineered pad layout, containment plans, and traffic flow diagrams.
Various engineering and survey plats (Pad Layout, Traffic Flow Diagram, Multi-Well Plan) · 2026-08-27
The pad-scale design imposes shared physical constraints (well spacing, containment, access roads) that will affect the sequencing, safety, and environmental management of all operations on this pad.

Operator Pattern

Engages in detailed pre-permit coordination for multi-well pads involving surface agreements, regulatory waivers, and federal mineral notifications.
Submission of a backbuild order waiver letter, execution of a surface damage affidavit for the entire pad, and receipt of BLM notification from NDIC demonstrate proactive regulatory and surface owner engagement.

Confidence: High
The well file contains clear, date-stamped documents (permit, waiver request, regulatory email, affidavit) that directly link to the permit's conditions of approval. No critical dates are missing or invented.