TOP GUN 30-19-18-7 3HF

Phoenix Operating LLC · Divide County, ND · File #43356 · Generated 2026-10-14 06:31

API: 3302301897
Target Formation: Bakken
Permit Explained: Partially

Permit Cycle Assessment

The permit stipulations contain a direct explanation for the north setback condition. A waiver request addresses the backbuild requirement for drilling outside the target unit. No contemporaneous documents fully explain the specific 1220' east/west setback or reference Commission Order 35009's full content.

Permit Cycle Signals (3)

Permit approval conditioned on Commission Order No. 35009, with a 150' setback from N/S boundaries and a 1220' setback from E/W boundaries within the 2560-acre spacing unit.

Direct

Permit Information / Stipulations
Relative (Inferred confidence)

Sets specific, non-standard setback distances tied to the well geometry and spacing unit.

North setback justification: 'based on a production liner cemented in the lateral with a wet shoe and the ability to frac out the shoe'.

Direct

Permit Information / Stipulations
Relative (Inferred confidence)

Directly explains the rationale for the specific north setback, linking permit condition to proposed completion technique.

Backbuild Order Waiver request (NDIC Order 31848) submitted, stating Phoenix is majority WI owner in adjacent sections and thus notification is not necessary.

Supporting

Waiver Letter from Phoenix Operating to NDIC
2026-09-09 (Exact confidence)

Waiver request justifies drilling outside the target spacing unit, a key condition for permit approval.

Historical Context (2)

Backbuild requirement per NDIC Order 31848 persists for wells entering the Bakken Petroleum System outside the target spacing unit, requiring notification to adjacent unit operators.
Waiver Letter from Phoenix Operating to NDIC · Unknown
This regulatory obligation applies to any future wells drilled from this pad with similar geometry traversing adjacent units, requiring waivers or notifications.

Affidavit of Surface Damage Agreement confirms a multi-well pad with wells drilled off-spacing from the surface location.
Affidavit of Surface Damage Agreement · 2026-09-24
Establishes a surface use agreement covering multiple wells, creating a persistent obligation for all pad development.

Operator Pattern

Operator proactively submits regulatory waivers and manages surface agreements for multi-well pad development.
Submission of Backbuild Order Waiver letter and Affidavit of Surface Damage Agreement for the pad.

Confidence: Medium
Key permit conditions (setbacks, Order 35009) are stated but not fully sourced. The waiver letter provides clear supporting context for one major permit requirement. Some dates (e.g., for Order 35009) are missing or inferred from context.