HILCORP - MADDOX COM 1A/777 CS

Hilcorp Energy Company's Maddox Com 1A/777 CS facility (EPA FRS ID 110038527190) is a natural gas extraction well pad in the Turley, New Mexico area, operating under NAICS 211130 inside the San Juan Basin footprint. That footprint sits at the center of a Clean Air Act consent decree the U.S. Department of Justice and EPA announced on October 17, 2024, carrying a $9.4 million civil penalty [source: https://www.epa.gov/enforcement/hilcorp-energy-company-new-mexico-clean-air-act-stationary-source-settlement]. The decree targets well-completion emissions — the venting that occurs when operators bring oil or gas to the surface after drilling — across Hilcorp's New Mexico production sites. ECHO's facility-level export, dated May 4, 2026, shows zero quarters of noncompliance in the trailing eight quarters for this specific well pad. It also attributes a 24-month penalty allocation of approximately $3.76 million to the site, derived by scaling the 60-month total to the 24-month review window [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip]. That figure is not a site-level fine. It reflects parent-level settlement dollars distributed across the San Juan Basin asset base.

Two additional federal actions complete the multi-region picture. A November 21, 2024 settlement resolved Clean Air Act violations at Hilcorp's western Pennsylvania oil and gas operations for a $1.275 million civil penalty plus injunctive compliance projects [source: https://www.epa.gov/enforcement/hilcorp-energy-company-pennsylvania-settlement-summary]. A February 2022 Alaska matter was documented in docket CAA-10-2022-0035 [source: https://s3.documentcloud.org/documents/21398364/hilcorp-alaska-consent-agreement-and-final-order.pdf]. Hilcorp is privately held. It files no 10-K and carries no SEC EDGAR disclosure that could corroborate or contradict the environmental claims published on its Corporate Responsibility page [source: https://www.hilcorp.com/corporate-responsibility/environmental-stewardship/]. The pattern across three EPA regions — New Mexico, Pennsylvania, and Alaska — defines a parent-level air-compliance posture that materially shapes risk at the Maddox Com 1A/777 CS site, even though the well pad's own quarterly ECHO record is clean.

Maddox Com 1A/777 CS is a single well pad under NAICS 211130 (Natural Gas Extraction), registered in EPA's Facility Registry with ID 110038527190. The most recent ECHO exporter snapshot, dated May 4, 2026, shows no active permits reported for the site [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip]. The facility itself carries zero formal enforcement actions and zero quarters of significant noncompliance in the trailing 24 months. The $3.76 million penalty figure associated with the site in the ECHO export derives from an allocation methodology that distributes parent Hilcorp Energy Company settlement dollars across the operator's San Juan Basin footprint — not from any wellhead-specific finding.

The governing federal action for New Mexico operations is the October 17, 2024 consent decree filed in U.S. v. Hilcorp Energy Company, Civil Action No. 1:24-cv-01055 (D.N.M.). EPA describes it as the first Clean Air Act and New Mexico Air Quality Control Act case of its kind addressing well-completion emissions at an oil and gas producer [source: https://www.epa.gov/enforcement/hilcorp-energy-company-new-mexico-clean-air-act-stationary-source-settlement]. The decree requires a $9.4 million civil penalty, injunctive compliance at covered wells, third-party verification of emission controls, mitigation projects, and stipulated-penalty provisions that run for the life of the decree [source: https://www.justice.gov/enrd/media/1373866/dl?inline=]. A parallel complaint filed alongside the decree details the alleged unlawful releases during well completion at San Juan Basin sites operated by Hilcorp [source: https://www.justice.gov/enrd/media/1373861/dl?inline=].

The 24-month chronology begins before the review window itself. A February 2022 Alaska CAA consent agreement under docket CAA-10-2022-0035 established a prior federal air-compliance track record with the same operator across EPA Region 10 [source: https://s3.documentcloud.org/documents/21398364/hilcorp-alaska-consent-agreement-and-final-order.pdf]. That history matters because it shows repeat regulator contact predating the New Mexico action by more than two years. On October 17, 2024, the New Mexico consent decree was lodged [source: https://www.epa.gov/enforcement/hilcorp-energy-company-new-mexico-clean-air-act-stationary-source-settlement]. Five weeks later, on November 21, 2024, EPA, DOJ, and the Pennsylvania Department of Environmental Protection announced the Pennsylvania CAA settlement [source: https://www.epa.gov/enforcement/hilcorp-energy-company-pennsylvania-settlement-summary]. In March 2026, San Juan Basin Royalty Trust (NYSE: SJT) — which holds overriding royalty interests in Hilcorp-operated New Mexico leases — halted its March 2026 distribution, citing approximately $6.2 million in gross excess production costs [source: https://www.stocktitan.net/sec-filings/SJT/8-k-san-juan-basin-royalty-trust-reports-material-event-89bd8f517f8e.html]. That financial signal is directly tied to the operating region that includes Maddox Com 1A/777 CS. In late April 2026, an explosion was reported at a Hilcorp facility on Fairfield School Road in Columbiana, Ohio [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]. On May 4, 2026, Hilcorp announced it would withdraw from the Yukon Flats drilling program after completing one of two planned wells on Indigenous-owned land, following opposition from area tribes [source: https://www.adn.com/business-economy/energy/2026/05/04/with-one-of-two-wells-drilled-hilcorp-to-pull-out-of-yukon-flats/].

Action 1 — New Mexico CAA/AQCA consent decree, October 17, 2024. Defendant: Hilcorp Energy Company. Forum: U.S. District Court, District of New Mexico, Civil Action No. 1:24-cv-01055. Program: Clean Air Act §§111, 113 and New Mexico Air Quality Control Act. The allegation covers unlawful emissions during well completion operations at San Juan Basin oil and gas production sites — the same operating area that includes Maddox Com 1A/777 CS. Outcome: a $9.4 million civil penalty, injunctive relief requiring operational changes at covered wells, third-party verification of controls, mitigation projects, and stipulated penalties for any future noncompliance [source: https://www.epa.gov/enforcement/hilcorp-energy-company-new-mexico-clean-air-act-stationary-source-settlement]. The consent decree text is on file with DOJ ENRD [source: https://www.justice.gov/enrd/media/1373866/dl?inline=]. The accompanying complaint is also on file [source: https://www.justice.gov/enrd/media/1373861/dl?inline=].

Action 2 — Pennsylvania CAA settlement, November 21, 2024. Defendant: Hilcorp Energy Company. Co-plaintiffs: EPA, DOJ, and the Pennsylvania Department of Environmental Protection. Program: Clean Air Act and Pennsylvania state air law. The allegation covers noncompliance with federal and state air regulations at western Pennsylvania oil and gas production operations. Outcome: a $1.275 million civil penalty plus compliance projects designed to offset prior illegal emissions, with implementation costs estimated at several million dollars [source: https://www.epa.gov/enforcement/hilcorp-energy-company-pennsylvania-settlement-summary]. The Pennsylvania settlement closed just 35 days after the New Mexico decree — two distinct EPA regions, two separate enforcement actions, within a single calendar quarter.

Action 3 — Alaska CAA consent agreement, Docket No. CAA-10-2022-0035, February 2022. Respondent: Hilcorp Alaska, LLC. Forum: EPA Region 10 administrative proceeding. Program: Clean Air Act. Outcome: consent agreement and final order with compliance obligations at Alaska oil and gas infrastructure [source: https://s3.documentcloud.org/documents/21398364/hilcorp-alaska-consent-agreement-and-final-order.pdf]. This action predates the 24-month review window but establishes repeat regulator contact across multiple EPA regions, a fact that contextualizes the two 2024 settlements.

Facility-specific record for Maddox Com 1A/777 CS (FRS 110038527190): ECHO records show zero formal enforcement actions and zero quarters of noncompliance in the trailing 24 months at the well pad itself. The $3.76 million figure in the ECHO exporter is an allocated share of the parent 60-month penalty total scaled to 24 months — not a site-level fine [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip].

Maddox Com 1A/777 CS (FRS 110038527190), San Juan County, New Mexico: a single natural gas well pad under NAICS 211130 with no active EPA-tracked permits in the current ECHO export and no site-specific violations in the trailing 24 months. The site falls inside the geographic and operational scope of the October 2024 New Mexico CAA consent decree against parent Hilcorp Energy Company, which targets well-completion emissions across San Juan Basin operations [source: https://www.epa.gov/enforcement/hilcorp-energy-company-new-mexico-clean-air-act-stationary-source-settlement] [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip].

San Juan Basin operating area (parent aggregation), New Mexico: the decree covers Hilcorp well-completion activity across multiple production sites and requires third-party verification and mitigation projects [source: https://www.justice.gov/enrd/media/1373866/dl?inline=]. The March 2026 SJT distribution halt — citing approximately $6.2 million in gross excess production costs on the overriding royalty properties operated by Hilcorp — is the most recent financial signal tied to this operating region [source: https://www.stocktitan.net/sec-filings/SJT/8-k-san-juan-basin-royalty-trust-reports-material-event-89bd8f517f8e.html]. That halt was disclosed in an 8-K filed by the royalty trust, not by Hilcorp itself, underscoring the limited public financial visibility into the operator's New Mexico economics.

Western Pennsylvania oil and gas production operations (parent aggregation): covered by the November 21, 2024 CAA settlement at $1.275 million plus injunctive projects [source: https://www.epa.gov/enforcement/hilcorp-energy-company-pennsylvania-settlement-summary].

Columbiana, Ohio — Fairfield School Road facility: an explosion was reported on the 5000 block on or about the week of April 28, 2026. Emergency crews responded, and the Columbiana Assistant Fire Chief identified the site as a Hilcorp Energy facility [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]. No EPA enforcement action tied to the incident had been published as of the ECHO snapshot dated May 4, 2026.

Yukon Flats, Alaska (Doyon Limited-owned land): Hilcorp drilled one of two planned exploratory wells and announced withdrawal on May 4, 2026, following opposition from regional tribes [source: https://www.adn.com/business-economy/energy/2026/05/04/with-one-of-two-wells-drilled-hilcorp-to-pull-out-of-yukon-flats/]. The withdrawal closes near-term operational exposure in that area but creates a documented record of tribal-consent friction in the company's Alaska portfolio.

Volatile organic compounds (VOCs) are the primary pollutant category addressed by the October 2024 New Mexico consent decree. Well completion — the process EPA describes as bringing oil or gas to the surface after drilling — vents uncontrolled hydrocarbons including benzene, toluene, ethylbenzene, and xylenes [source: https://www.epa.gov/enforcement/hilcorp-energy-company-new-mexico-clean-air-act-stationary-source-settlement]. Inhalation near well pads during flowback and separator operations is the principal exposure pathway. In the San Juan Basin, rural and tribal communities — including Navajo Nation allottees and populations near Jicarilla Apache Nation boundary areas — live in proximity to upstream operations. EJScreen indices for the census tracts surrounding FRS 110038527190 are not populated in the current ECHO export, which limits cross-site environmental-justice ranking at this time [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip].

Methane (CH4) is the second key pollutant. Well-completion venting at natural gas extraction sites is a primary methane emission source regulated under CAA §111 NSPS OOOOa and its successor rules. The DOJ complaint alleges unlawful emissions from well completions at Hilcorp San Juan Basin sites [source: https://www.justice.gov/enrd/media/1373861/dl?inline=]. Methane is not directly toxic to humans at ambient concentrations. It is, however, a potent greenhouse gas and a reliable co-indicator of co-emitted VOCs and hazardous air pollutants at the same well pad.

Hazardous air pollutants (HAPs), with benzene as the recognized human carcinogen of primary concern, appear in the Pennsylvania enforcement record as well. The November 2024 Pennsylvania settlement cites CAA violations at oil and gas production operations where CAA §112 HAP controls apply to covered sources [source: https://www.epa.gov/enforcement/hilcorp-energy-company-pennsylvania-settlement-summary]. Fugitive emissions from tanks, dehydrators, and pneumatic controllers are the principal exposure pathways for benzene — and those equipment categories are addressed directly in the injunctive provisions of the New Mexico consent decree [source: https://www.justice.gov/enrd/media/1373866/dl?inline=].

Within the NAICS 211120/211130 peer set derived from the ECHO exporter, Maddox Com 1A/777 CS sits well below the top three by allocated 24-month penalty total — $3.76 million against a range of $16.1 million to $26.2 million at the comparison sites [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip]. On quarterly noncompliance, Maddox reports zero violation quarters versus eight each at Red Hills Gas Processing Plant and HP Gas Pad. Greka Bell Compressor Plant matches Maddox on zero violation quarters but carries a materially higher allocated penalty figure, indicating a larger parent-level settlement distributed across its footprint. EJ indices are not populated for any of the four sites in the current export, which limits cross-site environmental-justice ranking.

Hilcorp Energy Company is privately held under CIK N/A and files no 10-K or Item 1A forward-looking risk disclosure with the SEC. The closest SEC-filed forward-looking document touching the operating region is San Juan Basin Royalty Trust's March 20, 2026 8-K. That filing discloses that excess production costs on Hilcorp-operated New Mexico leases had reached approximately $6.2 million gross, that reserves were shrinking, that line-of-credit debt was rising, and that distributions were suspended until obligations were repaid — conditions that directly affect the economic and operational trajectory of wells in the Maddox Com 1A/777 CS operating area [source: https://www.stocktitan.net/sec-filings/SJT/8-k-san-juan-basin-royalty-trust-reports-material-event-89bd8f517f8e.html]. Separately, the Alaska legislature's April 2026 rejection of a corporate income tax measure aimed at private oil producers including Hilcorp is a policy data point bearing on future tax exposure in the company's largest state [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/].