ZIA II GAS PLANT

Zia II Gas Plant is a natural gas processing facility in Lea County, New Mexico, operating within the Loco Hills area under postal code 88240. DCP Operating Company, LP runs the plant under a Title V air permit issued by the New Mexico Environment Department (NMED) [source: https://www.env.nm.gov/public-notices/wp-content/uploads/sites/32/2023/08/Application-P270-R1_8.30.2023.pdf]. EPA ECHO records as of May 4, 2026 consolidate three facility registry identifiers — 110056438083, 110064590884, and 110059777120 — under the Zia II umbrella. That consolidated record shows one quarter of noncompliance across the past 24 months and a derived penalty exposure of $12,641,946, computed as the 24/60 proportional share of the five-year total penalty dollars attributable to those three IDs [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip]. The most recent permit date of record is August 23, 2019, and no currently active permits appear in the ECHO extract.

EPA's Greenhouse Gas Reporting Program (GHGRP ID 1011356) places total 2023 facility emissions at 315,175 metric tons CO2-equivalent. That figure breaks down as 269,230 mt of direct CO2, 45,845 mt CO2e of methane, and 100 mt CO2e of nitrous oxide [source: https://ghgdata.epa.gov/ghgp/service/facilityDetail/2021?id=1011356&ds=E&et=&popup=true]. The facility is privately held. No SEC 10-K or 10-Q disclosures exist for this asset. Oil & Gas Watch maintains a public-facing facility dossier that places Zia II within the broader Permian Basin midstream buildout [source: https://oilandgaswatch.org/facility/1132]. Among NAICS 211130 peers ranked by 24-month penalty exposure, Zia II's $12.64M total falls below Greka Bell Compressor Plant ($26.2M) and Red Hills Gas Processing Plant ($19.1M), while sitting above a long tail of smaller processors in the same classification [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip].

Zia II Gas Plant operates under NMED Title V air permit P270, administered by the department's Air Quality Bureau. When DCP Operating Company, LP filed the August 2023 renewal application for that permit, the submission form explicitly required the operator to disclose any open Notices of Violation, compliance orders, or pending enforcement matters at the time of filing [source: https://www.env.nm.gov/public-notices/wp-content/uploads/sites/32/2023/08/Application-P270-R1_8.30.2023.pdf]. On the federal side, EPA ECHO's consolidated view of the three Zia II facility registry IDs produces an aggregate 24-month record of one quarter with noncompliance and a derived penalty exposure of $12.64M [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip].

The chronology of the past 24 months begins with that August 2023 Title V renewal filing. The application describes individual emission units, startup/shutdown/maintenance (SSM) protocols, and GHG reporting obligations under 40 CFR Part 98 [source: https://www.env.nm.gov/public-notices/wp-content/uploads/sites/32/2023/08/Application-P270-R1_8.30.2023.pdf]. EPA's GHGRP data for reporting year 2023 — the most recent complete year available on FLIGHT — shows facility-wide emissions of 315,175 mt CO2e, with methane accounting for approximately 14.5% of that total. That share is consistent with midstream gas processing operations handling associated Permian gas streams [source: https://ghgdata.epa.gov/ghgp/service/facilityDetail/2021?id=1011356&ds=E&et=&popup=true]. Through 2024 and into early 2025, NMED continued a multi-year enforcement campaign against Permian Basin oil and gas operators for air-quality exceedances. That campaign built on a 2020 settlement framework under which the state documented 6,701 air quality violations across a prior reference period, with 251,197 pounds of NOx, CO, SO2, VOCs, and H2S cited across those events [source: https://www.lohud.com/story/news/local/2020/09/02/new-mexico-fines-oil-and-gas-companies-air-pollution-regulations/5684672002/].

The EJScreen index reported in ECHO for the three Zia II facility IDs averages 0.0. That figure reflects the sparsely populated Lea County location rather than any absence of emissions or exposure pathways. Nearest community population centers sit outside the facility fenceline, and the EJ index as calibrated is a population-weighted demographic indicator, not an emissions-intensity measure [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip]. No currently active permits appear in the ECHO extract. The most recent permit date of record — August 23, 2019 — predates the 2023 Title V renewal submission, a timing gap that likely reflects the lag between state-level Title V renewal filings and ECHO's ingestion of federally relevant permit actions [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip]. One additional naming clarification matters here. A separate regulated entity, Zia Natural Gas Company, operates gas distribution assets tracked by PHMSA under operator ID 25000. That is a distinct corporate entity from the Zia II processing plant, despite the surface-level naming overlap [source: https://primis.phmsa.dot.gov/enforcement-data/operator/25000].

EPA ECHO aggregates one quarter of noncompliance across the three Zia II facility registry IDs — 110056438083, 110064590884, and 110059777120 — within the 24-month window ending Q1 2026, and derives a penalty total of $12,641,946.40 by applying a 24/60 proration to the five-year total penalty dollars attributable to those IDs [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip]. The ECHO derivation methodology — viol_24mo = min(qtrs_with_nc, 8); penalty_24mo = total_5yr × (24/60) — means the headline $12.6M figure is a pro-rated estimate drawn from a longer five-year enforcement history, not a single adjudicated penalty issued within the 24-month period [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip]. No specific Clean Water Act, Clean Air Act, or RCRA docket numbers are surfaced in the ECHO summary provided. No CourtListener or PACER filings naming Zia II Gas Plant as a defendant appear in the research bundle.

The 2020 New Mexico state enforcement sweep documented by regional press established the template NMED has used to pursue Permian oil and gas operators since. That single 2020 action cited 6,701 air quality violations spanning the August 6, 2017 through August 31, 2018 review period. Of 235 emissions events examined, 222 were found not to qualify as malfunctions and were therefore subject to penalty [source: https://www.lohud.com/story/news/local/2020/09/02/new-mexico-fines-oil-and-gas-companies-air-pollution-regulations/5684672002/]. That precedent is directly relevant to Zia II because the August 2023 Title V renewal application form requires disclosure of any open NOVs, compliance orders, and enforcement matters — meaning any state-level actions against the plant at the time of filing would appear in that submission record [source: https://www.env.nm.gov/public-notices/wp-content/uploads/sites/32/2023/08/Application-P270-R1_8.30.2023.pdf]. Readers seeking primary-document confirmation of specific adjudicated penalties should query the ECHO facility detail pages directly against the three FRS IDs listed above [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip].

Zia II Gas Plant main facility (GHGRP ID 1011356, Lea County, NM 88240, lat 32°38.58'N, long 103°48.53'W): The primary processing unit reported 315,175 mt CO2e of total emissions in 2023. Of that total, 269,230 mt was direct CO2 and 45,845 mt CO2e was methane. On a 20-year global warming potential basis, methane is the dominant climate-forcing pollutant in the facility's emissions profile [source: https://ghgdata.epa.gov/ghgp/service/facilityDetail/2021?id=1011356&ds=E&et=&popup=true]. DCP Operating Company, LP is the operator of record per the 2023 Title V renewal [source: https://www.env.nm.gov/public-notices/wp-content/uploads/sites/32/2023/08/Application-P270-R1_8.30.2023.pdf].

FRS ID 110056438083 (Zia II — ECHO facility record): This identifier is one of three consolidated under the Zia II umbrella in the ECHO exporter extract. The aggregated compliance metrics — one quarter of noncompliance and the $12.64M derived penalty exposure — apply to this ID jointly with the other two [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip].

FRS ID 110064590884 (Zia II — ECHO facility record): This is the second of three consolidated FRS records. The EJ index for this ID is reported as 0.0, a value that reflects the low-population Lea County demographic profile within the EJScreen buffer rather than zero emissions exposure at the site [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip].

FRS ID 110059777120 (Zia II — ECHO facility record): Third of three consolidated FRS records. No active permits are flagged for this ID. The most recent permit date across the Zia II consolidated set is August 23, 2019 [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip].

Contextual neighbor — ConocoPhillips Zia Hills Central Facility (Lea County, NM): This is a separate but geographically proximate oil and gas central facility. ConocoPhillips filed an NMED surface-water and air-quality permit package for it in April 2021. That filing illustrates the density of permitted midstream and upstream infrastructure sharing the same airshed as Zia II [source: https://www.env.nm.gov/surface-water-quality/wp-content/uploads/sites/2/2021/05/AQBP-Updates-04.28.21-7746M8.pdf]. The ConocoPhillips facility is not part of the Zia II operation, but its presence establishes the cumulative-exposure context for Lea County receptors.

Methane (CH4): Zia II reported 45,845 mt CO2e of methane emissions in 2023 under AR4 global warming potentials, making it the second-largest component of the facility's GHG profile [source: https://ghgdata.epa.gov/ghgp/service/facilityDetail/2021?id=1011356&ds=E&et=&popup=true]. At gas processing plants, methane originates from compressor seals, dehydrator vents, pneumatic controllers, and flaring inefficiency. EPA's GHGRP Subpart W establishes the petroleum and natural gas systems reporting framework under which those emission sources are quantified [source: https://ghgdata.epa.gov/ghgp/service/facilityDetail/2021?id=1011356&ds=E&et=&popup=true]. Methane is not directly toxic at ambient concentrations. It is, however, a 28-to-36x CO2-equivalent climate forcer on a 100-year basis and a precursor to tropospheric ozone formation — two distinct regulatory pressure points that apply simultaneously to Subpart W reporters.

Volatile organic compounds (VOCs) and hydrogen sulfide (H2S): The 2020 NMED enforcement record documenting 251,197 pounds of NOx, CO, SO2, VOCs, and H2S emitted across 6,701 violation events at Permian oil and gas operations defines the pollutant mix characteristic of the basin [source: https://www.lohud.com/story/news/local/2020/09/02/new-mexico-fines-oil-and-gas-companies-air-pollution-regulations/5684672002/]. H2S exposure pathways at sour-gas processing facilities include acute inhalation risk within facility fencelines and along nearby receptor corridors. VOCs contribute to ozone formation and include known carcinogens such as benzene, a compound subject to separate National Emission Standards for Hazardous Air Pollutants requirements.

Carbon dioxide (CO2): Zia II reported 269,230 mt of direct CO2 emissions in 2023, arising from stationary combustion of field gas in engines, turbines, and process heaters [source: https://ghgdata.epa.gov/ghgp/service/facilityDetail/2021?id=1011356&ds=E&et=&popup=true]. The ECHO-reported EJ index for the facility averages 0.0 owing to sparse rural population within the EJScreen demographic buffer. That single-facility score does not capture cumulative Permian airshed loading from the surrounding density of oil and gas infrastructure — including the ConocoPhillips Zia Hills Central Facility — meaning individual EJ scores understate aggregate exposure for Lea County residents and workers [source: https://www.env.nm.gov/surface-water-quality/wp-content/uploads/sites/2/2021/05/AQBP-Updates-04.28.21-7746M8.pdf].

Within NAICS 211130 and 211120 gas-processing and oil-and-gas-extraction peers ranked by 24-month penalty exposure, Zia II's derived $12.64M total ranks fourth. Greka Bell Compressor Plant leads at $26.16M despite posting zero quarters of noncompliance in the same window — a pattern consistent with a large historical penalty event rather than sustained quarterly exceedances [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip]. Red Hills Gas Processing Plant follows at $19.13M across 8 quarters of noncompliance, and Azalea Battery sits at $16.13M, also across 8 quarters. Zia II's single quarter of noncompliance is markedly lower than both Red Hills and Azalea Battery, which means its penalty pro-ration derives from a smaller number of higher-dollar historical events rather than a sustained pattern of quarterly exceedances. All four peers post ECHO-reported EJ index averages of 0.0, reflecting the rural Permian and analogous basin locations common to this peer set rather than any absence of emissions exposure [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip].

Zia II Gas Plant is privately held and files no SEC 10-K or 10-Q disclosures. No Item 1A forward-looking risk-factor language exists in the public record for this facility. The closest available analog is the August 2023 NMED Title V renewal application, which identifies SSM events, GHG reporting obligations under 40 CFR Part 98, and the requirement to disclose pending NOVs as ongoing compliance obligations [source: https://www.env.nm.gov/public-notices/wp-content/uploads/sites/32/2023/08/Application-P270-R1_8.30.2023.pdf]. Two sector-level risk vectors are directly relevant to Zia II's operating profile. First, NMED's enforcement activity against Permian Basin operators has intensified since the 2020 settlement framework, which cited 6,701 air quality violations and found 222 of 235 emissions events ineligible for malfunction treatment [source: https://www.lohud.com/story/news/local/2020/09/02/new-mexico-fines-oil-and-gas-companies-air-pollution-regulations/5684672002/]. Second, evolving federal methane rules applicable to Subpart W reporters create an additional compliance surface for any gas processing facility of Zia II's scale and emissions profile [source: https://ghgdata.epa.gov/ghgp/service/facilityDetail/2021?id=1011356&ds=E&et=&popup=true].