HILCORP - SAN JUAN 29-7 139N

Hilcorp San Juan 29-7 139N is a single wellsite within Hilcorp Energy Company's San Juan Basin natural gas portfolio (NAICS 211130), operated in Rio Arriba County, New Mexico. EPA ECHO records tied to Facility Registry ID 110046478316 show zero formal quarterly violations in the trailing 24 months. Yet a derived penalty exposure of approximately $3.76 million emerges when a pro-rata share of Hilcorp's five-year enforcement total is allocated against this site [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip]. That allocation traces directly to the October 17, 2024 Clean Air Act settlement between EPA, DOJ, and Hilcorp Energy Company — a $9.4 million civil penalty covering New Mexico well-completion operations that EPA characterized as the first CAA/AQCA case of its kind against an oil and gas producer [source: https://www.epa.gov/enforcement/hilcorp-energy-company-new-mexico-clean-air-act-stationary-source-settlement].

Hilcorp's 2025 San Juan stewardship brochure claims an 81% methane reduction from 2023 to 2024 at the basin level and reports 119,000+ BOEPD of net production across 11,600+ producing wells [source: https://www.hilcorp.com/wp-content/uploads/2025/05/SJ-2025.pdf]. A separate company case study reports a 58% cumulative greenhouse-gas reduction against a 2016 baseline [source: https://www.hilcorp.com/san-juan-methane-reduction/]. Those self-reported figures sit alongside the 2024 federal settlement and an active NMED Air Quality Bureau public-notice record for the San Juan Gas Plant [source: https://www.env.nm.gov/public-notices/hilcorp-energy-company-san-juan-gas-plant-2/]. The coexistence of a declining emissions trajectory and a resolved federal consent decree is not inherently contradictory, but readers should weigh both data streams together rather than in isolation. Hilcorp is privately held; no CIK, no 10-K, and no 10-Q disclosures are available for independent cross-reference [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip].

The San Juan 29-7 139N wellsite is registered in EPA's Facility Registry Service and maps to the broader Hilcorp San Juan operating footprint [source: https://frs-public.epa.gov/ords/frs_public2/fii_query_detail.disp_program_facility?p_registry_id=110046478398]. ECHO's quarterly non-compliance counter shows no flagged quarters for this specific Registry ID over the trailing 24 months, and no active major permits are catalogued at the wellsite level [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip]. The $3.76 million penalty figure is a derived allocation, not a site-specific assessment; ECHO's methodology pro-rates the five-year parent enforcement total using a 24/60 ratio across associated facility IDs [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip].

Two federal settlements anchor the 24-month enforcement record for the parent company. On October 17, 2024, EPA and DOJ announced a Clean Air Act and New Mexico Air Quality Control Act settlement with Hilcorp covering well-completion emissions at oil and gas production operations statewide — a $9.4 million civil penalty paired with injunctive relief requiring emission controls on completion activities [source: https://www.epa.gov/enforcement/hilcorp-energy-company-new-mexico-clean-air-act-stationary-source-settlement]. Approximately five weeks later, on November 21, 2024, EPA, DOJ, and the Pennsylvania Department of Environmental Protection reached a parallel CAA settlement with Hilcorp covering western Pennsylvania operations [source: https://www.epa.gov/enforcement/hilcorp-energy-company-pennsylvania-settlement-summary]. Those two consent actions define the federal enforcement posture bearing on the San Juan asset group.

State-level records add texture. New Mexico Oil Conservation Division documents show remedial activity at the nearby San Juan 28-7 Unit 183M in Rio Arriba County under OCD Incident No. NCS1901627746, with quarterly status reports filed through 2022 [source: https://ocdimage.emnrd.nm.gov/Imaging/FileStore/santafe/NF/20220706/nCS1901627746_07_06_2022_02_50_33.pdf]. NMED's Air Quality Bureau maintains a standing public-notice docket for the Hilcorp San Juan Gas Plant, signaling ongoing permit-level interaction with state air regulators [source: https://www.env.nm.gov/public-notices/hilcorp-energy-company-san-juan-gas-plant-2/]. Capital signals point toward higher activity volumes ahead. On February 20, 2026, San Juan Basin Royalty Trust disclosed a Hilcorp 2026 capital plan totaling $14 million across 32 drilling and repair projects, following $8.3 million of drilling and workover spend in 2025 [source: https://www.prnewswire.com/news-releases/san-juan-basin-royalty-trust-announces-hilcorps-2026-capital-plan-302693218.html]. Separate reporting places total 2026 San Juan Basin development at approximately $100 million [source: https://www.geneonline.com/hilcorp-energy-plans-100-million-investment-in-san-juan-basin-development-for-2026/]. That step-up in drilling pace expands the air-emissions and produced-water compliance surface area across the asset group in which the 29-7 139N site sits.

October 17, 2024 — Clean Air Act / New Mexico Air Quality Control Act settlement, U.S. EPA and U.S. DOJ v. Hilcorp Energy Company. Scope: well-completion operations at New Mexico oil and gas production sites. Civil penalty: $9.4 million. Injunctive relief: emission-control requirements on completion activities. EPA characterized the matter as the first CAA/AQCA case of its kind against an oil and gas producer [source: https://www.epa.gov/enforcement/hilcorp-energy-company-new-mexico-clean-air-act-stationary-source-settlement].

November 21, 2024 — Clean Air Act settlement, U.S. EPA, U.S. DOJ, and Pennsylvania Department of Environmental Protection v. Hilcorp Energy Company. Scope: oil and gas production operations in western Pennsylvania. Outcome: civil penalty plus compliance measures under Pennsylvania law and the CAA [source: https://www.epa.gov/enforcement/hilcorp-energy-company-pennsylvania-settlement-summary].

Rio Arriba County, NM — New Mexico OCD Incident No. NCS1901627746 at the San Juan 28-7 Unit 183M, an adjacent unit in the same lease group as 29-7 139N. Timberwolf Environmental filed a first-quarter 2021 status report dated May 5, 2021 with OCD District 3 in Aztec, documenting remedial activity on federal BLM surface [source: https://ocdimage.emnrd.nm.gov/Imaging/FileStore/santafe/NF/20220706/nCS1901627746_07_06_2022_02_50_33.pdf].

Ongoing — NMED Air Quality Bureau public-notice docket for the Hilcorp San Juan Gas Plant [source: https://www.env.nm.gov/public-notices/hilcorp-energy-company-san-juan-gas-plant-2/]. ECHO reports zero formal non-compliance quarters at FRS ID 110046478316 over the trailing 24 months [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip].

San Juan 29-7 139N (Rio Arriba County, NM) — the subject wellsite. FRS ID 110046478316. Zero flagged non-compliance quarters in the trailing 24 months; no active major permits enumerated at the wellsite level; derived 24-month penalty allocation of $3.76 million reflects a pro-rata share of parent enforcement, not a site-specific fine [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip].

San Juan 28-7 Unit 183M (Rio Arriba County, NM) — adjacent Hilcorp unit on BLM surface, subject to OCD Incident NCS1901627746 and quarterly remedial status reporting through 2022. The site sits in the same federal-lease neighborhood as 29-7 139N [source: https://ocdimage.emnrd.nm.gov/Imaging/FileStore/santafe/NF/20220706/nCS1901627746_07_06_2022_02_50_33.pdf].

Hilcorp San Juan Gas Plant (New Mexico) — midstream processing asset with an open NMED Air Quality Bureau public-notice docket, indicating active permit-level engagement with state air regulators [source: https://www.env.nm.gov/public-notices/hilcorp-energy-company-san-juan-gas-plant-2/].

Hilcorp New Mexico well-completion fleet — the universe of sites covered by the October 17, 2024 CAA/AQCA settlement. EPA's enforcement summary does not enumerate individual wellsites, but the consent decree's injunctive scope applies across Hilcorp's New Mexico completion operations [source: https://www.epa.gov/enforcement/hilcorp-energy-company-new-mexico-clean-air-act-stationary-source-settlement].

Hilcorp western Pennsylvania production footprint — sites covered by the November 21, 2024 CAA settlement with EPA, DOJ, and Pennsylvania DEP. Not co-located with the San Juan asset, but relevant to parent-level compliance posture and recidivism risk assessment [source: https://www.epa.gov/enforcement/hilcorp-energy-company-pennsylvania-settlement-summary].

Methane (CH4) is the defining pollutant for San Juan Basin gas production. Hilcorp's own San Juan case study identifies methane as the basin's primary reduction focus and attributes a 58% GHG reduction to emission-control tiering on legacy assets [source: https://www.hilcorp.com/san-juan-methane-reduction/]. Methane is a short-lived climate forcer with a 20-year global warming potential substantially above CO2. EPA's CAA enforcement construct against Hilcorp's New Mexico completion operations reflects that regulatory emphasis directly [source: https://www.epa.gov/enforcement/hilcorp-energy-company-new-mexico-clean-air-act-stationary-source-settlement].

Volatile organic compounds (VOCs) are co-emitted with methane during well completions, storage-tank flashing, and pneumatic venting. VOCs drive ground-level ozone formation across the Four Corners airshed — a regional air-quality concern that gives the 2024 CAA/AQCA settlement particular geographic weight. Completion-phase emissions are a primary VOC release pathway, and the settlement targets them directly [source: https://www.epa.gov/enforcement/hilcorp-energy-company-new-mexico-clean-air-act-stationary-source-settlement]. NMED's Air Quality Bureau docket for the San Juan Gas Plant covers permit-level VOC and NOx controls at the midstream facility as well [source: https://www.env.nm.gov/public-notices/hilcorp-energy-company-san-juan-gas-plant-2/].

Produced-water and hydrocarbon soil impacts represent the legacy pathway captured by NMOCD remedial incidents. The San Juan 28-7 Unit 183M status report documents quarterly remedial activity under OCD oversight, covering hydrocarbon-impacted soils on federal BLM surface in Rio Arriba County [source: https://ocdimage.emnrd.nm.gov/Imaging/FileStore/santafe/NF/20220706/nCS1901627746_07_06_2022_02_50_33.pdf]. Rio Arriba County surface use includes grazing allotments and tribal-adjacent communities. ECHO does not publish an EJ index value for FRS ID 110046478316 [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip].

Within the NAICS 211120/211130 peer set surfaced by ECHO's exporter, San Juan 29-7 139N sits at the low end of the derived penalty range at $3.76 million. That compares to $16.1 million at HP Gas Pad, $19.1 million at Red Hills Gas Processing Plant, and $26.2 million at Greka Bell Compressor Plant [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip]. The subject site also shows zero flagged non-compliance quarters — matching Greka Bell's clean quarterly record and contrasting with the eight-quarter flags logged at both Red Hills and HP Gas Pad [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip]. Peer EJ indices are reported as 0.0 across the extract, indicating the field is either unpopulated or the facilities are sited in areas that do not trigger the EJScreen composite threshold [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip].

Hilcorp is privately held; no SEC Form 10-K or 10-Q exists for Item 1A or Item 7 extraction [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip]. Forward-looking environmental risk must therefore be inferred from operator disclosures and third-party trust filings. The San Juan Basin Royalty Trust's February 20, 2026 disclosure of Hilcorp's 2026 capital plan — $14 million across 32 drilling and repair projects — signals a step-up in activity that will expand the air-emissions and remedial-compliance surface area covered by the October 2024 CAA/AQCA consent decree [source: https://www.prnewswire.com/news-releases/san-juan-basin-royalty-trust-announces-hilcorps-2026-capital-plan-302693218.html]. More drilling means more completion events; more completion events means more exposure to the exact emission pathways the 2024 settlement was designed to curtail. Separate state-tax policy risk surfaced on April 13, 2026, when the Alaska House rejected a measure to extend corporate income tax to Hilcorp and other private oil companies, illustrating the ongoing legislative scrutiny that Hilcorp's pass-through structure attracts across multiple jurisdictions [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/].