Item 1A. Risk Factors
ITEM 1A. RISK FACTORS
Except as set forth below, there have been no material changes to the Risk Factors disclosed in Part I, Item 1A, Risk Factors , of the Company's 2024 Form 10-K.
Our Electric and Coal Operations are subject to extensive and costly laws and regulations, and such current and future laws and regulations could increase current operating costs or limit our ability to produce coal.
In October 2025, the Company submitted an application for a National Pollutant Discharge Elimination System (“NPDES”) permit under the proposed U.S. Environmental Protection Agency’s ("EPA") Steam Electric Power Generating Effluent Guidelines ("ELG") Deadline Extensions Rule, published October 2, 2025. The proposed rule extends multiple compliance deadlines originally established by the 2024 ELG rule including deadlines for zero-discharge systems (e.g., flue gas desulfurization wastewater, bottom ash transport water, and combustion residual leachate) by five to six years (e.g., from December 31, 2029 to December 31, 2034) and includes new provisions for alternative applicability dates, transferability between compliance options and authorize alternative applicability dates based on site-specific considerations.
The Company’s permit application was approved November 7, 2025 and is consistent with the extended deadlines and flexibility provided by the proposed Deadline Extensions Rule. The rule is currently in the public comment stage, with comments due November 3, 2025, and has not yet been finalized.
If the finalized ruling does not include the extension of the compliance deadlines the Company would be unable to discharge under the current ELG rule and thus would be out of compliance with the Clean Water Act as of December 31, 2025 , potentially subjecting it to enforcement actions, penalties, or required to implement alternative discharge controls immediately.
ITEM 4. MINE SAFETY DISCLOSURES
See Exhibit 95.1 to this Form 10-Q for a listing of our mine safety violations.
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ITEM 6. EXHIBITS
Exhibit No.
Document
31.1
SOX 302 Certification - Chief Executive Officer
31.2
SOX 302 Certification - Chief Financial Officer
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SOX 906 Certification
95.1
Mine Safety Disclosures
101.INS
Inline XBRL Instance Document
101.SCH
Inline XBRL Schema Document
101.CAL
Inline XBRL Calculation Linkbase Document
101.LAB
Inline XBRL Labels Linkbase Document
101.PRE
Inline XBRL Presentation Linkbase Document
101.DEF
Inline XBRL Definition Linkbase Document
104
Cover Page Interactive Data File (embedded with the Inline XBRL document)
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SIGNATURES
Pursuant to the requirements of the Securities Exchange Act of 1934, the registrant has duly caused this report to be signed on its behalf by the undersigned thereunto duly authorized.
HALLADOR ENERGY COMPANY
Date: November 10, 2025
/s/ TODD E. TELESZ
Todd E. Telesz, CFO (Principal Financial Officer and Principal Accounting Officer)
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Text extracted from the filing as submitted to EDGAR. Formatting, tables and exhibits are simplified for reading; the original document is authoritative for anything you rely on.