HILCORP - HUERFANITO UNIT 79N

Hilcorp Energy Company's Huerfanito Unit 79N is a single oil and gas production asset in Huerfano County, New Mexico (NAICS 211111), operating within the San Juan Basin development footprint that parent operator Hilcorp has expanded through a disclosed 2026 capital program [source: https://www.prnewswire.com/news-releases/san-juan-basin-royalty-trust-announces-hilcorps-2026-capital-plan-302693218.html]. EPA ECHO records attribute zero formally recorded quarters of non-compliance to facility identifier 110046351354 over the trailing 24 months. The exporter's derived five-year-penalty prorating, however, yields approximately $3.76 million in allocated civil penalties tied to that registry ID [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip]. That allocation connects directly to the October 17, 2024 parent-level Clean Air Act settlement between EPA, DOJ, and Hilcorp Energy Company — a resolution covering well completion operations across Hilcorp's New Mexico portfolio, a category that encompasses the Huerfanito Unit [source: https://www.epa.gov/enforcement/hilcorp-energy-company-new-mexico-clean-air-act-stationary-source-settlement].

Hilcorp is privately held. No 10-K or 10-Q is on file, so forward-looking risk disclosure available under SEC Regulation S-K is absent from the public record entirely. Company-level corporate responsibility statements emphasize extending production from legacy infrastructure rather than expanding greenfield development [source: https://www.hilcorp.com/corporate-responsibility/]. EPA's 2024 New Mexico settlement — described by the agency as the first Clean Air Act and New Mexico Air Quality Control Act action of its kind tied to well completions — carries a $9.4 million civil penalty and injunctive relief applicable across Hilcorp's San Juan Basin operations, a category that includes the Huerfanito Unit [source: https://www.epa.gov/enforcement/hilcorp-energy-company-new-mexico-clean-air-act-stationary-source-settlement]. One month after that resolution, a separate November 21, 2024 Pennsylvania settlement added a $1.275 million civil penalty alongside injunctive compliance projects at Hilcorp's western Pennsylvania facilities [source: https://www.epa.gov/enforcement/hilcorp-energy-company-pennsylvania-settlement-summary]. Together, those two resolutions define the enterprise-level compliance backdrop against which the Huerfanito Unit's facility-level record must be read.

The compliance record at Huerfanito Unit 79N itself, as derived from the EPA ECHO exporter dated May 4, 2026, shows no quarters of non-compliance across the trailing eight-quarter window and no currently active major permits reported at facility registry ID 110046351354 [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip]. The $3.76 million 24-month penalty figure is a derivation — ECHO's exporter prorates five-year penalty totals across 24 months — rather than a discrete case-level judgment. It should be read as an allocated share of parent-company resolutions that touch this registry ID, not as a standalone fine assessed against the Huerfanito Unit [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip].

Chronologically, the most consequential 24-month events occurred at the parent-company level. On October 17, 2024, EPA and DOJ announced a settlement with Hilcorp Energy Company resolving Clean Air Act and New Mexico Air Quality Control Act violations at the company's oil and gas production operations in New Mexico. EPA described it as the first CAA/AQCA action addressing well completion operations against an oil and gas producer [source: https://www.epa.gov/enforcement/hilcorp-energy-company-new-mexico-clean-air-act-stationary-source-settlement]. One month later, on November 21, 2024, a second settlement was filed in the Western District of Pennsylvania as Civil Action No. 2:24-cv-01596, resolving Clean Air Act and Pennsylvania-law violations at western Pennsylvania operations. Hilcorp paid a $1.275 million civil penalty and agreed to compliance and mitigation projects [source: https://www.epa.gov/enforcement/hilcorp-energy-company-pennsylvania-settlement-summary] [source: https://www.epa.gov/system/files/documents/2024-11/hilcorp-24-cv-1596-complaint.pdf]. Earlier New Mexico Oil Conservation Division records document remedial activity at a nearby Hilcorp location — the San Juan 28-7 Unit 183M in Rio Arriba County — under OCD Incident No. NCS1901627746 [source: https://ocdimage.emnrd.nm.gov/Imaging/FileStore/santafe/NF/20220706/nCS1901627746_07_06_2022_02_50_33.pdf].

By 2025 and into 2026, the public-record narrative shifted toward operational incidents and capital deployment. On February 20, 2026, the San Juan Basin Royalty Trust disclosed Hilcorp's 2026 capital plan: approximately $14 million across 32 drilling and repair projects in the basin, following $8.3 million spent on drilling and workovers in 2025 [source: https://www.stocktitan.net/news/SJT/san-juan-basin-royalty-trust-announces-hilcorp-s-2026-capital-9bkvvdhfu3si.html] [source: https://www.prnewswire.com/news-releases/san-juan-basin-royalty-trust-announces-hilcorps-2026-capital-plan-302693218.html]. A separate, higher figure — $100 million in San Juan Basin development — has also circulated in news coverage [source: https://www.geneonline.com/hilcorp-energy-plans-100-million-investment-in-san-juan-basin-development-for-2026/]. Late-April and early-May 2026 reporting documented fire-department responses to a tank incident at a Hilcorp site in Columbiana County, Ohio, and a separate incident on Fairfield School Road in Fairfield Township, Ohio [source: https://www.wkbn.com/news/local-news/fairfield-twp-news/crews-respond-to-incident-at-hilcorp/] [source: https://dailydispatch.com/fire-news/ohio/crews-respond-to-tank-incident-at-hilcorp-in-columbiana-county/]. On May 4, 2026, the Anchorage Daily News reported Hilcorp would exit the Yukon Flats drilling program after completing one of two planned wells on Indigenous-owned land [source: https://www.adn.com/business-economy/energy/2026/05/04/with-one-of-two-wells-drilled-hilcorp-to-pull-out-of-yukon-flats/].

New Mexico Clean Air Act / AQCA settlement, announced October 17, 2024: EPA and DOJ resolved CAA and New Mexico Air Quality Control Act violations tied to well completion operations — the process of bringing oil or natural gas to the surface after drilling. Hilcorp agreed to pay a $9.4 million civil penalty and implement injunctive measures at New Mexico oil and gas production operations, including the San Juan Basin assets within which Huerfanito Unit 79N sits [source: https://www.epa.gov/enforcement/hilcorp-energy-company-new-mexico-clean-air-act-stationary-source-settlement]. EPA's own announcement called it the first CAA/AQCA action of its kind against an oil and gas producer for well completion violations — a distinction that signals the settlement's significance within the agency's enforcement history.

Pennsylvania Clean Air Act settlement, filed November 21, 2024 (United States and Commonwealth of Pennsylvania v. Hilcorp Energy Company, Case No. 2:24-cv-01596, W.D. Pa.): EPA, DOJ, and the Pennsylvania Department of Environmental Protection resolved CAA and state-law violations at western Pennsylvania oil and gas production operations. Hilcorp agreed to a $1.275 million civil penalty and committed to compliance projects designed to offset past emissions and bring facilities into federal and state compliance, with EPA estimating project costs in addition to the civil penalty [source: https://www.epa.gov/enforcement/hilcorp-energy-company-pennsylvania-settlement-summary] [source: https://www.epa.gov/system/files/documents/2024-11/hilcorp-24-cv-1596-complaint.pdf].

At the Huerfanito Unit 79N registry ID (110046351354) itself, ECHO's derived 24-month values show zero discrete quarters of non-compliance and $3,760,000 in allocated penalty total — a figure produced by prorating five-year penalty totals attributed to the registry [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip]. No active major permits are listed in the exporter snapshot for this facility as of May 4, 2026 [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip]. State-level records for the nearby San Juan 28-7 Unit 183M document ongoing remedial reporting under OCD Incident No. NCS1901627746 through at least the first quarter of 2021, providing additional context for the regulatory treatment of Hilcorp's western New Mexico acreage [source: https://ocdimage.emnrd.nm.gov/Imaging/FileStore/santafe/NF/20220706/nCS1901627746_07_06_2022_02_50_33.pdf].

Huerfanito Unit 79N (Huerfano County, New Mexico; FRS ID 110046351354) is the single asset within the scope of this briefing. ECHO's May 4, 2026 exporter snapshot attributes zero quarters of non-compliance and an allocated $3.76 million 24-month penalty share to this registry, with no active major permits listed [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip]. The facility falls within Hilcorp's broader New Mexico production footprint that was the subject of the October 17, 2024 Clean Air Act / AQCA settlement [source: https://www.epa.gov/enforcement/hilcorp-energy-company-new-mexico-clean-air-act-stationary-source-settlement].

San Juan 28-7 Unit 183M (Rio Arriba County, New Mexico) is a related Hilcorp site appearing in New Mexico Oil Conservation Division records with remedial activity tracked under OCD Incident No. NCS1901627746, situated on federal land managed by the Bureau of Land Management [source: https://ocdimage.emnrd.nm.gov/Imaging/FileStore/santafe/NF/20220706/nCS1901627746_07_06_2022_02_50_33.pdf]. That record provides context for the regulatory treatment of Hilcorp's western New Mexico acreage adjacent to the Huerfanito Unit.

An additional Hilcorp facility appears in EPA's Facility Registry Service under registry ID 110046478398, with FRS metadata publicly viewable through EPA's Envirofacts detail report [source: https://frs-public.epa.gov/ords/frs_public2/fii_query_detail.disp_program_facility?p_registry_id=110046478398]. This record is relevant for cross-referencing Hilcorp's New Mexico registry inventory.

Western Pennsylvania oil and gas production operations — the set of facilities addressed in the November 21, 2024 consent decree — are outside New Mexico but bear on enterprise-level compliance posture. The complaint filed as Case No. 2:24-cv-01596 describes the operations and statutory claims in detail [source: https://www.epa.gov/system/files/documents/2024-11/hilcorp-24-cv-1596-complaint.pdf].

Ohio operations were the site of two reported incidents in the seven days preceding this briefing: a response at Hilcorp Energy Company on Fairfield School Road in Fairfield Township [source: https://www.wkbn.com/news/local-news/fairfield-twp-news/crews-respond-to-incident-at-hilcorp/] and a tank incident in Columbiana County [source: https://dailydispatch.com/fire-news/ohio/crews-respond-to-tank-incident-at-hilcorp-in-columbiana-county/]. Regulatory characterization of either incident was not available at the time of publication.

ECHO's exporter snapshot lists no top pollutants for the Huerfanito Unit 79N registry ID. That absence reflects the lack of discrete reported violations at this single-facility record — not an affirmative zero-emissions determination [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip]. The substantive pollutant picture therefore derives from the parent-company enforcement record.

Volatile organic compounds (VOCs) and methane from well completion operations sit at the core of the 2024 New Mexico CAA/AQCA settlement. EPA characterized the case as the first CAA/AQCA action against an oil and gas producer for well completion violations. Well completion — the process of bringing a drilled well into production — carries documented potential to release VOCs, methane, and hazardous air pollutants during flowback [source: https://www.epa.gov/enforcement/hilcorp-energy-company-new-mexico-clean-air-act-stationary-source-settlement]. VOCs contribute to ground-level ozone formation. Methane is a short-lived climate forcer with high global warming potential relative to CO2 over 20-year horizons.

The Pennsylvania settlement addressed additional Clean Air Act emission categories at production operations, with injunctive projects designed to offset past illegal emissions and bring facilities into federal and state compliance [source: https://www.epa.gov/enforcement/hilcorp-energy-company-pennsylvania-settlement-summary]. Environmental-justice exposure at the Huerfanito Unit itself is reported by ECHO as 0.0 on the EJ index average, which in ECHO's methodology reflects either low surrounding demographic exposure or the absence of a computed index for this single rural registry [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip]. San Juan Basin air-quality conditions, however, affect communities across Rio Arriba and San Juan Counties more broadly, with federal land and BLM-managed surface interests documented in state OCD filings [source: https://ocdimage.emnrd.nm.gov/Imaging/FileStore/santafe/NF/20220706/nCS1901627746_07_06_2022_02_50_33.pdf].

Against three NAICS-adjacent peers drawn from ECHO's exporter, Huerfanito Unit 79N's derived $3.76 million 24-month allocated penalty total sits materially below Greka Bell Compressor Plant ($26.16 million, zero reported quarters of non-compliance), Red Hills Gas Processing Plant ($19.13 million, eight quarters), and HP Gas Pad ($16.13 million, eight quarters) [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip]. Huerfanito's zero reported quarters of non-compliance aligns with Greka Bell. It diverges from Red Hills and HP Gas Pad, both of which hit the eight-quarter ceiling in the derivation window [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip]. EJ index averages are reported as 0.0 across the full peer set, which limits demographic-exposure differentiation from this dataset alone.

Hilcorp Energy Company is privately held; no SEC 10-K or 10-Q is on file, so there is no Item 1A risk-factor disclosure or Item 7 MD&A available in EDGAR for this issuer. Forward-looking regulatory risk must therefore be inferred from primary regulatory records and trust-level disclosures. The October 17, 2024 New Mexico CAA/AQCA consent decree imposes ongoing compliance obligations on well completion operations [source: https://www.epa.gov/enforcement/hilcorp-energy-company-new-mexico-clean-air-act-stationary-source-settlement]. The November 21, 2024 Pennsylvania consent decree imposes injunctive projects at western Pennsylvania facilities [source: https://www.epa.gov/enforcement/hilcorp-energy-company-pennsylvania-settlement-summary]. Both decrees remain active constraints. The San Juan Basin Royalty Trust's February 20, 2026 disclosure of Hilcorp's 2026 capital plan — 32 drilling and repair projects totaling approximately $14 million — signals continued activity in the basin that will be executed under those compliance constraints [source: https://www.prnewswire.com/news-releases/san-juan-basin-royalty-trust-announces-hilcorps-2026-capital-plan-302693218.html]. A separate Alaska policy item — the April 13, 2026 rejection of a measure to apply corporate income tax to Hilcorp and other private oil companies — bears on the company's state-tax exposure but not directly on environmental compliance [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/].