HILCORP - DAVIS A FED 1N

Hilcorp Energy Company's Davis A Fed 1N well site (EPA Facility ID 110046351407) sits within the San Juan Basin operations headquartered in Aztec, New Mexico. EPA ECHO records associated with the facility show zero formally-coded violations over the trailing 24 months. Yet the same records carry an allocated penalty exposure of $3.76 million, derived from the five-year penalty history prorated to a 24-month window [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip]. That number is not a site-specific fine. It traces back to the October 17, 2024 Clean Air Act consent decree among Hilcorp Energy Company, the U.S. Department of Justice, and the New Mexico Environment Department — a decree requiring Hilcorp to pay a $9.4 million civil penalty for well-completion-related CAA and New Mexico Air Quality Control Act violations across its New Mexico oil and gas production operations [source: https://www.epa.gov/enforcement/hilcorp-energy-company-new-mexico-clean-air-act-stationary-source-settlement].

The New Mexico action does not stand alone. A second federal consent decree, entered November 21, 2024, resolved Clean Air Act violations at Hilcorp's western Pennsylvania oil and gas operations for a $1.275 million civil penalty plus mitigation projects [source: https://www.epa.gov/enforcement/hilcorp-energy-company-pennsylvania-settlement-summary]. A still-earlier Clean Air Act Consent Agreement and Final Order against Hilcorp Alaska, LLC — Docket CAA-10-2022-0035 — established the regulatory pattern that predated both 2024 actions [source: https://s3.documentcloud.org/documents/21398364/hilcorp-alaska-consent-agreement-and-final-order.pdf]. Combined civil penalties across the three proceedings exceed $10.6 million. Hilcorp is privately held; no SEC 10-K or 10-Q disclosures are available for cross-reference, which limits the stated-versus-measured analysis to the company's own corporate responsibility website [source: https://www.hilcorp.com/corporate-responsibility/environmental-stewardship/]. That absence of audited disclosure is itself a material constraint for any ESG assessment.

The 24-month compliance picture for Davis A Fed 1N is driven less by site-specific ECHO quarterly non-compliance flags — which register zero — and more by the parent-company-level CAA enforcement arc that concluded in late 2024. ECHO's exporter attributes a $3.76 million penalty share to the facility through prorated allocation of Hilcorp's multi-year penalty total, using the formula `penalty_24mo = total_5yr * (24/60)` per the exporter's published derivation methodology [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip]. Treat that figure as an apportionment, not a facility-specific fine.

The chronology runs as follows. In February 2022, EPA Region 10 entered a Consent Agreement and Final Order with Hilcorp Alaska, LLC under CAA Section 113(d), docketed as CAA-10-2022-0035 [source: https://s3.documentcloud.org/documents/21398364/hilcorp-alaska-consent-agreement-and-final-order.pdf]. That Alaska order set the stage for what followed. On October 17, 2024, the United States and the New Mexico Environment Department filed Civil Action 1:24-cv-01055 in the District of New Mexico, producing a consent decree that required a $9.4 million civil penalty — the first CAA and New Mexico Air Quality Control Act case of its kind targeting well-completion operations at an oil and gas producer [source: https://www.justice.gov/enrd/media/1373866/dl?inline=]. Five weeks later, on November 21, 2024, a parallel consent decree was lodged in the Western District of Pennsylvania as Civil No. 2:24-cv-01596, imposing a $1.275 million civil penalty and compliance requirements covering storage vessels, flares, and leak detection at western Pennsylvania production sites [source: https://www.justice.gov/enrd/media/1377991/dl?inline=].

The public record then shifts from enforcement to operational and political developments. An August 11, 2025 post from the NGO Big Gas Polluters flagged Hilcorp's trade-association role in opposing federal methane emission penalties [source: https://biggaspolluters.org/polluter-of-the-month-hilcorp/]. In April 2026, the Alaska House rejected a measure that would have applied corporate income tax to Hilcorp and other privately held producers [source: https://www.adn.com/politics/alaska-legislature/2026/04/13/alaska-house-rejects-measure-to-apply-corporate-income-tax-to-hilcorp-and-other-private-oil-companies/]. On May 4, 2026, Hilcorp announced it would exit the Yukon Flats drilling program on Indigenous-owned land after completing one of two planned wells [source: https://www.northernjournal.com/with-one-of-two-wells-drilled-hilcorp-to-pull-out-of-yukon-flats/]. Separately, an explosion was reported at a Hilcorp gas facility on Fairfield School Road near Columbiana, Ohio in late April 2026, drawing a response led by Columbiana Assistant Fire Chief Frank Nulf [source: https://www.wfmj.com/news/local-news/columbiana_city/crews-respond-to-explosion-near-columbiana-gas-facility/article_e912c6d3-2b82-4b3e-8ec4-9ce88a1fb02b.html]. None of these post-settlement events carry formal ECHO violation codes, but each bears on forward compliance monitoring.

Action 1 — New Mexico CAA/AQCA Consent Decree, October 17, 2024. Caption: United States and New Mexico Environment Department v. Hilcorp Energy Company, Civil Action 1:24-cv-01055, D.N.M. Program: Clean Air Act (federal) and New Mexico Air Quality Control Act. Civil penalty: $9.4 million. Scope: well-completion operations at Hilcorp's New Mexico oil and gas production sites — the first federal case brought against an oil and gas producer under CAA and the New Mexico Air Quality Control Act specifically for well-completion-phase violations. The decree imposes compliance requirements, third-party verification, and mitigation obligations [source: https://www.epa.gov/enforcement/hilcorp-energy-company-new-mexico-clean-air-act-stationary-source-settlement] [source: https://www.justice.gov/enrd/media/1373866/dl?inline=]. A companion filing is publicly available at the Justice Department's ENRD document repository [source: https://www.justice.gov/enrd/media/1373861/dl?inline=].

Action 2 — Pennsylvania CAA Consent Decree, November 21, 2024. Caption: United States and Commonwealth of Pennsylvania, Department of Environmental Protection v. Hilcorp Energy Company, Civil No. 2:24-cv-01596, W.D. Pa. Program: Clean Air Act and Pennsylvania law. Civil penalty: $1.275 million. Scope: compliance failures at western Pennsylvania oil and gas production operations. The decree includes compliance projects, periodic reporting, stipulated penalties, and force majeure provisions. EPA states the mitigation projects are expected to cost additional sums beyond the civil penalty itself [source: https://www.epa.gov/enforcement/hilcorp-energy-company-pennsylvania-settlement-summary] [source: https://www.justice.gov/enrd/media/1377991/dl?inline=].

Action 3 — Hilcorp Alaska, LLC, CAA Consent Agreement and Final Order, 2022. Docket: CAA-10-2022-0035, EPA Region 10 (Seattle). Program: Clean Air Act Section 113(d). This administrative agreement predates the 24-month window but establishes the pattern of CAA-focused enforcement against Hilcorp subsidiaries across multiple states and operating environments [source: https://s3.documentcloud.org/documents/21398364/hilcorp-alaska-consent-agreement-and-final-order.pdf].

Facility-level: ECHO attributes a prorated $3.76 million penalty share to Davis A Fed 1N (Facility ID 110046351407), with zero quarterly non-compliance flags in the trailing 24 months. The derivation formula is `penalty_24mo = total_5yr * (24/60)` per the exporter's published methodology [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip].

Davis A Fed 1N (EPA Facility ID 110046351407), San Juan County, New Mexico. This is the single facility in scope for this record. ECHO data shows zero quarterly non-compliance flags over 24 months and a prorated penalty allocation of $3.76 million tied to the broader Hilcorp Energy Company enforcement history [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip]. No active permits are listed and no top-pollutant series is reported in the exporter snapshot as of May 4, 2026. The site falls within the New Mexico operational footprint that was the subject of the October 2024 federal consent decree, meaning compliance requirements under Civil Action 1:24-cv-01055 — including third-party verification of well-completion emissions controls — apply to the parent operator at sites of this type [source: https://www.justice.gov/enrd/media/1373866/dl?inline=].

Sister-site context fills out the geographic picture. Hilcorp's western Pennsylvania production sites are covered by the November 2024 consent decree and subject to leak-detection, storage vessel, and flare compliance schedules [source: https://www.justice.gov/enrd/media/1377991/dl?inline=]. The Hilcorp facility on the 5000 block of Fairfield School Road near Columbiana, Ohio was the site of an explosion reported by WFMJ in late April 2026; local fire response was led by Columbiana Assistant Fire Chief Frank Nulf [source: https://www.wfmj.com/news/local-news/columbiana_city/crews-respond-to-explosion-near-columbiana-gas-facility/article_e912c6d3-2b82-4b3e-8ec4-9ce88a1fb02b.html]. Hilcorp's Yukon Flats Alaska drilling program, conducted on Indigenous-owned land, was partially wound down on May 4, 2026 after one of two planned wells reached total depth [source: https://www.adn.com/business-economy/energy/2026/05/04/with-one-of-two-wells-drilled-hilcorp-to-pull-out-of-yukon-flats/]. Hilcorp Alaska, LLC remains subject to the 2022 EPA Region 10 CAA Consent Agreement [source: https://s3.documentcloud.org/documents/21398364/hilcorp-alaska-consent-agreement-and-final-order.pdf]. The New Mexico cluster — including Davis A Fed 1N — remains the primary regulatory reference point for air-quality analysis of this operator [source: https://www.epa.gov/enforcement/hilcorp-energy-company-new-mexico-clean-air-act-stationary-source-settlement].

The ECHO exporter returns no top-pollutants vector for Davis A Fed 1N as of the May 4, 2026 snapshot [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip]. Pollutant context must therefore be inferred from the program scope of the governing consent decrees. The October 2024 New Mexico consent decree targets emissions from well-completion operations, which under CAA New Source Performance Standards for oil and gas — 40 CFR Part 60 Subparts OOOO and OOOOa — principally concern volatile organic compounds (VOCs) and methane, with associated hazardous air pollutants including benzene [source: https://www.epa.gov/enforcement/hilcorp-energy-company-new-mexico-clean-air-act-stationary-source-settlement]. Benzene is a known human carcinogen. VOCs drive ground-level ozone formation, creating respiratory exposure pathways for nearby residents.

Methane carries a global warming potential roughly 80 times that of CO2 over a 20-year horizon. Its release during well-completion is the central regulatory concern the New Mexico decree was designed to address. The decree's third-party verification and mitigation requirements reflect EPA's emphasis on closing the gap between modeled and actual emission rates [source: https://www.justice.gov/enrd/media/1373866/dl?inline=]. The Pennsylvania decree addresses a related but distinct set of emission points: storage vessel vapors, flare combustion efficiency, and fugitive leaks — all VOC, methane, and hazardous air pollutant sources at production sites [source: https://www.justice.gov/enrd/media/1377991/dl?inline=].

On environmental-justice exposure, ECHO reports an EJ index average of 0.0 for Davis A Fed 1N. That figure reflects low surrounding population density in the San Juan Basin rather than an absence of community exposure [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip]. A different EJ dimension surfaces in Alaska. The Yukon Flats program placed wells on Indigenous-owned land and drew opposition from area tribes before Hilcorp's May 4, 2026 withdrawal [source: https://www.northernjournal.com/with-one-of-two-wells-drilled-hilcorp-to-pull-out-of-yukon-flats/]. The Big Gas Polluters NGO post dated August 11, 2025 alleges trade-association activity aimed at ending federal methane emission penalties; if accurate, that posture would bear directly on the forward pollutant-control outlook [source: https://biggaspolluters.org/polluter-of-the-month-hilcorp/].

Within NAICS 211120/211130 peers ranked by 24-month penalty exposure, Davis A Fed 1N's $3.76 million allocation sits at the low end of the comparison set. Greka Bell Compressor Plant carries $26.2 million in allocated penalties despite also showing zero quarterly non-compliance flags — a reminder that prorated parent-level settlements can dominate facility-level figures regardless of site-specific compliance status. Red Hills Gas Processing Plant and HP Gas Pad each show $19.1 million and $16.1 million respectively, both paired with eight quarterly non-compliance flags apiece. Davis A Fed 1N shows zero such flags. That contrast is the key analytical point: the Hilcorp facility's penalty exposure is driven entirely by parent-level settlement allocation, not by site-level quarterly non-compliance events [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip].

Hilcorp Energy Company is privately held; no SEC 10-K Item 1A filing is on file and no forward-looking environmental risk factors are available through EDGAR for this issuer. Forward risk indicators from public sources cluster around four areas. First, the operational compliance schedule and stipulated-penalty framework under the November 2024 Pennsylvania consent decree create ongoing financial exposure if Hilcorp misses reporting or remediation milestones [source: https://www.justice.gov/enrd/media/1377991/dl?inline=]. Second, the third-party verification and mitigation obligations under the October 2024 New Mexico consent decree impose external audit requirements on well-completion emissions controls across the New Mexico footprint, including sites of the same type as Davis A Fed 1N [source: https://www.justice.gov/enrd/media/1373866/dl?inline=]. Third, the April 2026 Alaska legislative debate over applying corporate income tax to privately held producers — a measure the Alaska House ultimately rejected on April 13, 2026 — illustrates the fiscal-policy uncertainty that bears on how Hilcorp allocates cash flow to compliance capital expenditure [source: https://www.adn.com/politics/alaska-legislature/2026/04/13/alaska-house-rejects-measure-to-apply-corporate-income-tax-to-hilcorp-and-other-private-oil-companies/]. Fourth, operational incidents such as the late-April 2026 explosion at the Fairfield School Road facility near Columbiana, Ohio add an unquantified tail-risk dimension to the forward picture [source: https://www.wfmj.com/news/local-news/columbiana_city/crews-respond-to-explosion-near-columbiana-gas-facility/article_e912c6d3-2b82-4b3e-8ec4-9ce88a1fb02b.html].