TOP GUN 30-19-18-7 4HF

Phoenix Operating LLC · Divide County, ND · File #43357 · Generated 2026-10-14 06:31

API: 3302301898
Target Formation: Bakken
Permit Explained: Yes

Permit Cycle Assessment

The permit approval is directly explained by regulatory stipulations referencing Order 35009 for setbacks and a spacing unit condition, supported by a pre-submitted waiver request for backbuild order requirements.

Permit Cycle Signals (3)

Permit approval conditioned on adherence to setbacks defined in Commission Order No. 35009, with a specific explanation for the north setback based on a production liner cemented in the lateral with a wet shoe and ability to frac out the shoe.

Direct

Permit Information - STIPULATIONS section
2026-09-30 (Exact confidence)

The stipulation directly ties permit approval to a specific regulatory order and provides a unique technical justification (wet shoe design) for the north setback, differentiating it from standard setback rules.

Regulator requires the well be drilled in conjunction with another well that meets a 1220' setback from the east and west spacing unit boundaries to justify the spacing unit.

Direct

Page 2 of 10, Permit Information
2026-09-30 (Exact confidence)

This is a specific, non-routine condition of approval that constrains the execution of this permit, tying it to the drilling of another well with specific geometry.

Operator's waiver request for backbuild order (NDIC Order 31848) requirements, citing majority WI ownership in adjacent sections as justification for no additional notification.

Supporting

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

This is a pre-permit submission directly seeking relief from a regulatory order condition. Its acceptance is likely a prerequisite for approving a well that will enter the target formation outside its designated spacing unit.

Historical Context (2)

Permit stipulates that any changes to casing point, total depth, or completion technique within the Bakken-Three Forks system require prior NDIC approval.
Page 9 of 10, Operator Assertions · 2026-09-30
This is a standing regulatory control that persists beyond permit approval and governs any future operational deviations during drilling or completion.

Surface damage agreement affidavit covering multiple wells on the pad, including this one, for off-spacing operations from the surface location.
Affidavit of Surface Damage Agreement · 2026-09-24
This executed agreement with the surface landowner is a persistent legal obligation allowing multi-well pad development from a single surface location outside target spacing units.

Operator Pattern

Operator utilizes multi-well pads and drills wells from surface locations outside target spacing units, requiring regulatory waivers and surface agreements.
Affidavit covers multiple wells (MAVERICK and TOP GUN series) on the same pad. The permit package includes a waiver request for backbuild order requirements related to drilling into adjacent units.

Confidence: High
Key permit-conditioning documents (stipulations letter, waiver request) are present and dated close to the permit approval. The regulatory orders referenced are explicit. The separation between permit-cycle and historical signals is clear based on temporal anchoring to the approval date.