6 unchanged sentences
Our activities in this segment are underpinned by long-term, fixed fee contracts and acreage dedications, some of which contain minimum volume commitments with leading oil and gas companies including large, investment grade producer customers.
−Removed: • Our Crude Oil Logistics segment purchases crude oil from producers and marketers and transports it to refineries or for resale at pipeline injection stations, storage terminals, barge loading facilities, rail facilities, refineries, and other trade hubs, and provides storage, terminaling and transportation services through its owned assets.
−Removed: Our activities in this segment are supported by certain long-term, fixed rate contracts which include minimum volume commitments on our owned and leased pipelines and storage tanks.
−Removed: • Our Liquids Logistics segment conducts supply operations for natural gas liquids, refined petroleum products and biodiesel to a broad range of commercial, retail and industrial customers across the United States and Canada.
−Removed: These operations are conducted through our 23 owned terminals, third-party storage and terminal facilities, nine common carrier pipelines and a fleet of leased railcars.
+Added: • Our Crude Oil Logistics segment purchases crude oil from producers and marketers and transports it to refineries or for resale at pipeline injection stations, storage terminals, barge loading facilities, rail facilities and other trade hubs, and provides storage, terminaling and transportation services through its owned assets.
+Added: Our activities in this segment are supported by certain long-term, fixed rate contracts with acreage dedications and which include minimum volume commitments on our storage tanks and owned and leased pipelines.
+Added: • Our Liquids Logistics segment conducts supply operations for natural gas liquids to commercial, retail and industrial customers across the United States and Canada.
+Added: These operations are conducted through our five owned terminals, third-party storage and terminal facilities, nine common carrier pipelines and a fleet of leased railcars (updated for the transactions discussed below).
We also provide services for marine exports of butane through our facility located in Chesapeake, Virginia and we also own a propane pipeline in Michigan.
1 unchanged sentence
We also enter into financially settled derivative contracts as economic hedges of our physical inventory, physical sales and physical purchase contracts.
+Added: Sale of Refined Products Business and Exiting Biodiesel Business
+Added: As of March 31, 2025, we completed winding down our biodiesel business (see Note 1 to our consolidated financial statements included in this Annual Report for a further discussion).
+Added: On March 17, 2025, we signed a purchase and sale agreement to sell our refined products business, including certain working capital items, to a third-party (see Note 1 to our consolidated financial statements included in this Annual Report for a further discussion).
+Added: This sale closed on April 30, 2025.
+Added: The sale of our refined products business and winding down of our biodiesel business represent a strategic shift in our operations and will have a significant effect on our operations and financial results going forward.
+Added: Accordingly, the results of operations and cash flows for our refined products and biodiesel businesses within our Liquids Logistics segment have been classified as discontinued operations for all periods presented and prior periods have been retrospectively adjusted in the consolidated statements of operations and consolidated statements of cash flows.
+Added: In addition, the assets and liabilities related to our refined products and biodiesel businesses have been classified as either held for sale or discontinued operations within our
+Added: March 31, 2025 and 2024 consolidated balance sheets (see Note 18 to our consolidated financial statements included in this Annual Report for a further discussion).
+Added: Sale of Certain Natural Gas Liquids Terminals and Most of Our Wholesale Propane Business
+Added: On February 5, 2025, we signed a purchase and sale agreement to sell 17 of our natural gas liquids terminals, most of our wholesale propane business, our interest in an unconsolidated entity and working capital to a third-party (see Note 1 to our consolidated financial statements included in this Annual Report for a further discussion).
+Added: This sale closed on April 30, 2025.
+Added: The assets and liabilities of this portion of our Liquids Logistics segment have been classified as held for sale within our March 31, 2025 consolidated balance sheet (see Note 18 to our consolidated financial statements included in this Annual Report for a further discussion).
+Added: As this sale transaction did not represent a strategic shift that will have a major effect on our operations or financial results, operations related to this portion of our Liquids Logistics segment have not been classified as discontinued operations.
Business Repositioning
−Removed: Over the past several years, we have undertaken a number of important strategic actions in an effort to leverage the Partnership’s core areas of competitive strength and focus on generating stable, growing and predictable cash flows, while improving our credit profile.
−Removed: We believe our actions have substantially simplified our business mix and have allowed us to focus on what we believe are the core areas of our business and improved our overall financial position.
−Removed: These actions are expected to position us for sustained growth in the future.
+Added: Over the past several years, we have undertaken a number of important strategic actions in an effort to capitalize on the Partnership’s core areas of competitive strength and focus on generating stable, growing and predictable cash flows, while improving our credit profile.
+Added: We believe our actions have simplified our business mix and have allowed us to focus on what we believe are the core areas of our business and improved our overall financial position.
For more information regarding our results of operations and reportable segments, see Part II, Item 7–“Management’s Discussion and Analysis of Financial Condition and Results of Operations” and Note 11 to our consolidated financial statements included in this Annual Report.
−Removed: For more information regarding our dispositions and acquisitions transactions and the impact to our operations, see Note 17 to our consolidated financial statements included in this current Annual Report and our Annual Reports on Form 10-K for the years ended March 31, 2023 and 2022 .
+Added: For more information regarding our dispositions and acquisitions transactions and the impact to our operations, see Note 1 and Note 17 to our consolidated financial statements included in this current Annual Report and our Annual Reports on Form 10-K for the years ended March 31, 2024 and 2023 .
Debt Refinancing
2 unchanged sentences
We also entered into a new seven-year $700.0 million senior secured term loan “B” credit facility (“Term Loan B”).
−Removed: In addition, in connection with the closing of the refinancing, our $600.0 million asset-based revolving credit facility (“ABL Facility”) was amended to extend the maturity and to make certain other changes to the terms thereof.
−Removed: No changes were made to the aggregate amount of commitments under the ABL Facility.
+Added: In addition, in connection with the closing of the refinancing, our asset-based revolving credit facility (“ABL Facility”) was amended to extend the maturity and to make certain other changes to the terms thereof.
For additional information related to the 2029 Senior Secured Notes, 2032 Senior Secured Notes, Term Loan B and ABL Facility, see Note 7 to our consolidated financial statements included in this Annual Report.
Primary Service Areas
−Removed: The following map shows the primary service areas of our businesses at March 31, 2024:
+Added: The following map shows the primary service areas of our businesses at May 29, 2025:
Organizational Chart
−Removed: The following chart provides a summarized overview of our legal entity structure at March 31, 2024:
−Removed: (1) Includes (i) NGL Water Solutions, LLC, which includes the operations of our Water Solutions segment, (ii) NGL Crude Logistics, LLC, which includes the operations of our Crude Oil Logistics segment and certain of our businesses within our Liquids Logistics segment and (iii) NGL Liquids, LLC, which includes the operations of certain of our businesses within our Liquids Logistics segment.
+Added: The following chart provides a summarized overview of our legal entity structure at May 29, 2025:
+Added: (1) Includes (i) NGL Water Solutions, LLC, which includes the operations of our Water Solutions segment, (ii) NGL Crude Assets and Marketing, LLC, which includes the operations of our Crude Oil Logistics segment and (iii) NGL Liquids, LLC, which includes the remaining operations of our Liquids Logistics segment.
Our Business Strategies
2 unchanged sentences
• Prudently managing our balance sheet to provide us with maximum financial flexibility for funding our operations, capital projects and strategic acquisitions.
−Removed: Our primary focus is to reduce our absolute debt and leverage and maintain sufficient liquidity to continue to reduce our overall leverage and reinstate the payment of common unit distributions.
+Added: Our primary focus is to reduce our 9.00% Class D Preferred Units (“Class D Preferred Units”) and debt, lower our leverage and maintain sufficient liquidity to finance growth projects and eventually reinstate the payment of common unit distributions.
We are also focused on maintaining credit metrics to manage existing and future capital requirements as well as to take advantage of market opportunities.
7 unchanged sentences
We intend to focus on generating revenues under long-term fixed fee contracts in addition to back-to-back contracts which minimize commodity price exposure.
−Removed: We seek to continue to increase cash flows that are supported by certain fixed fee, multi-year contracts, some of which include acreage dedications from producers or minimum volume commitments.
+Added: We seek to continue to increase cash flows that are supported by certain fixed fee, multi-year contracts, some of which include acreage dedications or minimum volume commitments from producers.
• Achieving growth by utilizing our existing footprint of assets, investing in new assets, customers and ventures that increase volume and enhance our operations, and generate attractive rates of return .
9 unchanged sentences
Our system located in the Northern Delaware Basin is an integrated network of large diameter produced water pipelines, recycling facilities and disposal wells that collectively provides reliable service to producer customers and would be difficult for competitors to replicate at this time.
−Removed: • Our network of crude oil transportation and storage assets, which allows us to serve customers over a wide geographic area and optimize sales.
−Removed: Our strategically deployed terminals, as well as our owned and contracted pipeline capacity, provide access to a wide range of customers and markets.
−Removed: We use this expansive network of transportation assets to deliver crude oil to optimal markets.
−Removed: These operations are supported by certain long-term, fixed rate contracts with producers, refiners and marketers and include minimum volume commitments on our owned and leased pipelines and storage tanks.
+Added: • Our network of crude oil transportation and storage assets located in the DJ Basin and Cushing, Oklahoma.
+Added: Our strategically deployed terminals, as well as our owned and contracted pipeline capacity, provide access to producers in the DJ Basin.
+Added: These operations are supported by certain long-term, fixed rate contracts and acreage dedications with producers, refiners and marketers and include minimum volume commitments on our owned and leased pipelines and storage tanks.
• Our network of natural gas liquids transportation, terminal, and storage assets, which allows us to provide multiple services across the United States and Canada.
−Removed: Our strategically located terminals, propane pipeline in Michigan, large leased railcar fleet, shipper status on common carrier pipelines, and substantial leased storage
−Removed: enable us to be a preferred purchaser and seller of natural gas liquids.
+Added: Our strategically located natural gas liquid supply terminals, propane pipeline in Michigan, large leased railcar fleet, shipper status on common carrier pipelines, and
+Added: leased storage enable us to be a preferred purchaser and seller of butane and other natural gas liquids.
We have a diverse base of long-standing customers and believe that our performance metrics allow us to reliably supply, store and transport products throughout the United States and Canada.
−Removed: • Our diversified operations allow us to generate more predictable and stable cash flows on a year-to-year basis.
−Removed: Our ability to provide multiple services to customers in numerous geographic areas enhances our competitive position.
+Added: • Our contracted operations allow us to generate more predictable and stable cash flows on a year-to-year basis.
+Added: Our ability to provide multiple services to customers enhances our competitive position.
Our three business segments are diversified by geography, customer base and commodity sensitivities, which we believe provides us with more stable cash flows through the typical commodity cycles.
3 unchanged sentences
We believe that our management’s knowledge of the industry, relationships within the industry, and experience provide us with the opportunities to optimize our existing assets.
−Removed: Our management team also has experience in identifying, evaluating and completing acquisitions and other ventures that provide us with additional opportunities to complement, grow and expand our existing operations.
+Added: Our management team also has experience in identifying and evaluating other ventures that provide us with additional opportunities to complement, grow and expand our existing operations.
Our Businesses
7 unchanged sentences
With a system that handled approximately 958.3 million barrels of produced water across its areas of operation during the year ended March 31, 2025, we believe that we are the largest independent produced water transportation and disposal company in the United States.
−Removed: We currently have approximately 664,000 acres dedicated to our system under long-term agreements in the Northern Delaware Basin.
−Removed: In addition, we have several minimum volume commitments and other commercial agreements covering the Delaware, DJ and Eagle Ford Basins.
−Removed: Our focus in building our Water Solutions business has been to secure long-term, fixed fee contracts that contain minimum volume commitments, acreage dedications or similarly strong contractual relationships with large, well-capitalized producer customers.
Our core asset in the Water Solutions segment is our system located in the Northern Delaware Basin, where we own and operate the largest integrated network of large diameter produced water pipelines, recycling facilities and disposal wells.
1 unchanged sentence
Our system has over 800 miles of newly-built, in-service large diameter produced water pipelines connected to 58 active saltwater disposal facilities and 132 active disposal wells.
−Removed: We currently have approximately 664,000 acres dedicated to the Northern Delaware system providing a multi-decade drilling inventory and significant growth opportunity.
−Removed: On January 22, 2024, we announced that our Water Solutions business is commencing expansion of its Lea County Express Pipeline System from a capacity of 140,000 barrels of water per day to 340,000 barrels per day in 2024 (“LEX II Expansion”).
−Removed: We expect the LEX II Expansion to be completed during the second half of fiscal year 2025.
−Removed: The addition of a second large-diameter pipeline, disposal wells, and facilities will greatly expand the capabilities of our existing produced water super-system and create a significantly larger outlet for produced water disposal within the Delaware Basin.
−Removed: The construction of the 27-mile, 30-inch produced water pipeline will transport water to areas outside the core of the basin thereby further diversifying the geographic location of our disposal operations.
−Removed: The LEX II Expansion is fully underwritten by a recently executed minimum volume commitment contract that includes an acreage dedication extension with an investment grade oil and gas producer.
+Added: We currently have approximately 765,000 acres dedicated to our Northern Delaware system under long-term agreements providing a multi-decade drilling inventory and significant growth opportunity.
+Added: In addition, we have several minimum volume commitments and other commercial agreements covering the Delaware, DJ and Eagle Ford Basins.
+Added: Our focus in building our Water Solutions business has been to secure long-term, fixed fee contracts that contain minimum volume commitments, acreage dedications or similarly strong contractual relationships with large, well-capitalized producer customers.
+Added: During the quarter ended December 31, 2024, we completed the expansion of our Lea County Express Pipeline System (“LEX II Expansion”) from a capacity of 140,000 barrels of water per day to 340,000 barrels of water per day.
+Added: The addition of a second large-diameter pipeline, disposal wells, and facilities has expanded the capabilities of our existing produced water super-system and created a significantly larger outlet for produced water disposal within the Delaware Basin.
+Added: The 27-mile, 30-inch produced water pipeline will transport water to areas outside the core of the basin thereby further diversifying the geographic location of our disposal operations.
+Added: The LEX II Expansion is fully underwritten by a minimum volume commitment contract that includes an acreage dedication extension with an investment grade oil and gas producer.
The LEX II Expansion includes an incremental increase in committed acreage and volumes under dedication from the producer.
−Removed: Additionally, the LEX II Expansion is expandable up to 500,000 barrels per day.
+Added: Additionally, the LEX II Expansion is expandable up to 500,000 barrels of water per day.
As part of our operations, we also recycle water, which includes the sale of produced water and recycled water for use in our customers’ completion activities.
During the year ended March 31, 2025, we sold approximately 42.4 million barrels of recycled water.
+Added: Our customers bring produced and flowback water generated by crude oil and natural gas exploration and production operations to our facilities for treatment through pipeline gathering systems and by truck.
+Added: During the year ended March 31, 2025, in the Delaware Basin, we received approximately 98% of produced and flowback water via pipelines.
+Added: Once we take delivery of the water, the level of processing is determined by the ultimate disposition of the water.
+Added: Our facilities dispose of produced water primarily into deep underground formations via injection wells.
+Added: At our disposal facilities, we use proprietary well maintenance programs to enhance injection rates and extend the useful lives of the wells.
We own 90 water treatment and disposal facilities, including 194 injection wells.
7 unchanged sentences
Total - All Facilities 90 194 2,186,000 4,271,800 6,457,800
+Added: (1) We own the land on which 39 of the 90 water treatment and disposal facilities are located and we either have easements or lease the land on which the remaining water treatment and disposal facilities are located.
(2) These facilities are located on lands we own.
1 unchanged sentence
(4) Certain facilities can dispose of both produced water and solids such as tank bottoms, drilling fluids and drilling muds.
−Removed: (4) Includes one facility with a permitted processing capacity of 40,000 barrels per day in which we own a 75% interest and one facility with a permitted processing capacity of 65,000 barrels per day in which we own a 50% interest.
−Removed: We own the land on which 39 of the 89 water treatment and disposal facilities are located and we either have easements or lease the land on which the remaining water treatment and disposal facilities are located.
+Added: (5) Includes one facility with a permitted processing capacity of 40,000 barrels per day in which we own a 75% interest and two facilities, one with a permitted processing capacity of 60,000 barrels per day and the other with a permitted processing capacity of 65,000 barrels per day, in which we own a 50% interest.
On March 31, 2023, we sold certain saltwater disposal assets in the Midland Basin (see Note 17 to our consolidated financial statements included in this Annual Report).
On July 25, 2023, we entered into an agreement in which we terminated a minimum volume water disposal contract and sold certain saltwater disposal assets and intangible assets in the Pinedale Anticline Basin (see Note 17 to our consolidated financial statements included in this Annual Report).
−Removed: On April 5, 2024, we sold approximately 122,250 acres of real estate on two ranches located in Eddy and Lea Counties, New Mexico (see Note 18 to our consolidated financial statements included in this Annual Report).
−Removed: In addition, the assets and liabilities related to these ranches have been classified as held for sale within our March 31, 2024 consolidated balance sheet (see Note 17 to our consolidated financial statements included in this Annual Report).
−Removed: Our customers bring produced and flowback water generated by crude oil and natural gas exploration and production operations to our facilities for treatment through pipeline gathering systems and by truck.
−Removed: During the year ended March 31, 2024, in the Delaware Basin, we received approximately 98% of produced and flowback water via pipelines.
−Removed: Once we take delivery of the water, the level of processing is determined by the ultimate disposition of the water.
−Removed: Our facilities dispose of produced water primarily into deep underground formations via injection wells.
−Removed: At our disposal facilities, we use proprietary well maintenance programs to enhance injection rates and extend the service lives of the wells.
+Added: On April 5, 2024, we sold approximately 122,250 acres of real estate on two ranches located in Eddy and Lea Counties, New Mexico.
+Added: In addition, the assets and liabilities related to these ranches were classified as held for sale within our March 31, 2024 consolidated balance sheet (see Note 17 to our consolidated financial statements included in this Annual Report).
The primary customers of our operations consist mainly of large publicly traded, oil and gas companies with diversified acreage positions across multiple leading oil and gas plays.
During the year ended March 31, 2025, 73% of the revenues of our Water Solutions segment were generated from our ten largest customers of the segment.
−Removed: Additionally, certain key customers of the Water Solutions segment contribute significantly to the cash flows and profitability of the organization.
+Added: Additionally, certain key customers of the Water Solutions segment contribute significantly to the cash flows and profitability of the Partnership.
Any loss of those customers or their contracts could have an adverse impact on our financial results.
7 unchanged sentences
(a) minimum volume commitments requiring the customer to deliver a specified minimum volume of produced water over a specified period of time;
−Removed: (b) acreage dedications requiring the customer to deliver all volumes produced from the dedicated acreage with us;
+Added: (b) acreage dedications requiring the customer to deliver all volumes produced from the
+Added: dedicated acreage with us;
and (c) produced water pipeline and trucked disposal agreements providing interruptible service in exchange for a fee per barrel of produced water received.
5 unchanged sentences
Crude Oil Logistics
−Removed: Our Crude Oil Logistics segment purchases crude oil from producers and marketers and transports it to refineries or for resale at pipeline injection stations, storage terminals, barge loading facilities, rail facilities, refineries, and other trade hubs, and provides storage, terminaling and transportation services through its owned assets.
−Removed: Our activities in this segment are supported by certain long-term, fixed rate contracts which include minimum volume commitments on our owned and leased pipelines and storage tanks.
−Removed: Our operations are concentrated in and around four prolific crude oil producing regions in the United States, including the DJ Basin in Colorado, the Permian Basin in Texas and New Mexico, the Eagle Ford Basin in Texas and the United States Gulf Coast.
+Added: Our Crude Oil Logistics segment purchases crude oil from producers and marketers and transports it to refineries or for resale at pipeline injection stations, storage terminals, barge loading facilities, rail facilities and other trade hubs, and provides storage, terminaling and transportation services through its owned assets.
+Added: Our activities in this segment are supported by certain long-term, fixed rate contracts with acreage dedications and which include minimum volume commitments on our storage tanks and owned and leased pipelines.
+Added: Our operations are concentrated in and around four prolific crude oil producing regions in the United States, including the DJ Basin in Colorado, the Delaware Basin in Texas and New Mexico, the Eagle Ford Basin in Texas and the United States Gulf Coast.
Our foundational asset in this segment is the Grand Mesa Pipeline, a 550-mile pipeline that transports crude oil from its origin in Weld County, Colorado to our terminal in Cushing, Oklahoma.
−Removed: The Grand Mesa Pipeline commenced operations on November 1, 2016 and has operated continuously since then.
−Removed: The main line portion of this pipeline is comprised of an undivided interest with Saddlehorn Pipeline Company, LLC (“Saddlehorn”) in which we have ownership of 150,000 barrels per day of capacity of the pipeline.
−Removed: During the year ended March 31, 2024, approximately 25.6 million barrels of crude oil were transported on the Grand Mesa Pipeline.
+Added: The main line portion of this pipeline is comprised of a 34.09% undivided interest with Saddlehorn Pipeline Company, LLC (“Saddlehorn”) in which we have ownership of 150,000 barrels per day of capacity.
+Added: During the year ended March 31, 2025, approximately 61,000 barrels per day of crude oil were transported on the Grand Mesa Pipeline.
Operating costs associated with the Grand Mesa Pipeline are allocated to us based on our proportionate ownership interest and throughput.
We also own and operate origin terminals at Lucerne and Riverside, Colorado, where we aggregate crude oil volumes of different types and grades and store them until they are ready for transfer to the Grand Mesa Pipeline.
−Removed: The Lucerne terminal has 950,000 barrels of storage and a 12 bay truck loading facility.
−Removed: The Riverside terminal has 20,000 barrels of storage and a four bay truck loading facility.
+Added: The Lucerne terminal has approximately 950,000 barrels of storage and a 12 bay truck loading facility.
+Added: The Riverside terminal has approximately 20,000 barrels of storage and a four bay truck loading facility.
Through our ownership in the Grand Mesa Pipeline, we have sufficient capacity to service our customer contracts at the same origin and termination points with the ability to accept additional volume commitments.
1 unchanged sentence
With the consent and participation of Saddlehorn, we and Saddlehorn may consider future opportunities using these easements, to the extent such easements remain in effect, for projects involving the transportation of crude oil and condensate.
−Removed: On December 6, 2023, we announced an open season for the Grand Mesa Pipeline.
−Removed: This open season ended at the close of business on January 5, 2024, and resulted in a new shipper with a five-year minimum volume commitment contract commencing on January 6, 2024.
We own and operate a large scale crude oil terminal located in Cushing, Oklahoma with 3,626,000 barrels of storage capacity, seven off-loading lease automatic custody transfer units (“LACTs”), a full control room, on-site quality management building, and three 24-inch bi-directional pipelines each capable of moving 360,000 barrels per day.
1 unchanged sentence
Our terminal is situated on 200 acres and is designed to be expanded based on customer demand.
−Removed: Cushing is one of the most liquid crude oil trading hubs in the world and is the delivery point for West Texas Intermediate futures contracts.
+Added: Cushing is one of the most liquid crude oil trading hubs in the world and is the delivery point for Light Sweet Crude Oil futures contracts.
We own and operate a crude oil marine terminal in Point Comfort, Texas with 370,000 barrels of storage capacity and six off-loading LACTs.
2 unchanged sentences
We purchase crude oil from producers and marketers and transport it to refineries or for resale.
−Removed: Our strategically deployed terminals, as well as our owned and contracted pipeline capacity, provide access to a wide range of customers and markets.
−Removed: We use this expansive network of transportation assets to deliver crude oil to optimal markets.
−Removed: We currently transport crude oil using the following assets:
−Removed: • The Grand Mesa Pipeline, which is described above, and 19 other common carrier pipelines owned by third parties;
−Removed: • 396 owned railcars (all of which are leased to third parties).
−Removed: We are in the process of requalifying our 396 owned railcars to be compliant with the standards for railcars for the commodities they are transporting.
−Removed: As of March 31, 2024, 130 railcars have been requalified (see “–Government Regulation”).
−Removed: We also own 27 strategically located pipeline injection stations, the locations of which are summarized below.
+Added: Our strategically deployed terminals, as well as our owned and contracted pipeline capacity, provide access to producers in the DJ Basin.
+Added: We currently transport crude oil on the Grand Mesa Pipeline, which is described above, and 19 other common carrier pipelines owned by third parties.
+Added: As of May 29, 2025, all railcars have been sold or are under purchase and sale agreements.
+Added: We also own 25 pipeline injection stations, the locations of which are summarized below.
State Number of Pipeline Injection Stations
−Removed: On March 30, 2023, we sold our marine assets (see Note 17 to our consolidated financial statements included in this Annual Report).
+Added: See Note 17 to our consolidated financial statements included in this Annual Report for all related dispositions in the current and prior years for the Crude Oil Logistics segment.
Our customers include crude oil refiners, producers, and marketers.
During the year ended March 31, 2025, 79% of the revenues of our Crude Oil Logistics segment were generated from our ten largest customers of the segment.
−Removed: Additionally, certain key customers of the Crude Oil Logistics segment contribute significantly to the cash flows and profitability of the organization.
+Added: Additionally, certain key customers of the Crude Oil Logistics segment contribute significantly to the cash flows and profitability of the Partnership.
Any loss of those customers or their contracts could have an adverse impact on our financial results.
4 unchanged sentences
• open credit;
−Removed: • logistics capabilities, including the availability of railcars, proprietary terminals, and owned pipeline and railcars;
+Added: • logistics capabilities, including the availability of railcars, proprietary terminals, and owned pipeline;
• long-term customer relationships.
4 unchanged sentences
James, Louisiana, and Magellan East Houston.
−Removed: We seek to manage price risk by entering into purchase and sale contracts of similar volumes based on similar indexes and by hedging exposure due to fluctuations in actual volumes and scheduled volumes.
+Added: We attempt to reduce our exposure to price fluctuations by using back-to-back physical contracts whenever possible.
+Added: When back-to-back physical contracts are not optimal, we enter into financially settled derivative contracts as economic hedges of our physical inventory, physical sales and physical purchase contracts.
Our profitability is impacted by forward crude oil prices.
Crude oil markets can either be in contango (a condition in which forward crude oil prices are higher than spot prices) or can be in backwardation (a condition in which forward crude oil prices are lower than spot prices).
−Removed: Our Crude Oil Logistics segment benefits when the market is in contango, as increasing
−Removed: prices result in inventory value gains during the time between when we purchase the inventory and when we sell it.
+Added: Our Crude Oil Logistics segment benefits when the market is in contango, as increasing prices result in inventory value gains during the time between when we purchase the inventory and when we sell it.
In addition, we are able to better utilize our storage assets when contango markets justify storing barrels.
1 unchanged sentence
To help mitigate the impact of changing prices, we enter into derivative instruments to hedge our inventory.
−Removed: Our Crude Oil Logistics segment operates primarily under the NGL Crude Logistics, NGL Crude Transportation, NGL Crude Terminals and NGL Crude Cushing trade names.
+Added: Our Crude Oil Logistics segment operates primarily under the NGL Crude Assets and Marketing, NGL Crude Transportation, NGL Crude Terminals and NGL Crude Cushing trade names.
Liquids Logistics
−Removed: Our Liquids Logistics segment conducts supply operations for natural gas liquids, refined petroleum products and biodiesel to a broad range of commercial, retail and industrial customers across the United States and Canada.
−Removed: These operations are conducted through our 23 owned terminals, third-party storage and terminal facilities, nine common carrier pipelines and a fleet of leased railcars.
+Added: Our Liquids Logistics segment conducts supply operations for natural gas liquids to commercial, retail and industrial customers across the United States and Canada.
+Added: These operations are conducted through our five owned terminals, third-party storage and terminal facilities, nine common carrier pipelines and a fleet of leased railcars.
We also provide services for marine exports of butane through our facility located in Chesapeake, Virginia and we also own a propane pipeline in Michigan.
2 unchanged sentences
We employ a number of contractual and hedging strategies to minimize commodity exposure and maximize earnings stability of this segment.
−Removed: During the year ended March 31, 2024, we sold approximately 2.5 billion gallons of natural gas liquids, refined products and renewables products, or 6.97 million gallons (approximately 166,000 barrels) per day.
+Added: During the year ended March 31, 2025, we sold approximately 1.6 billion gallons of natural gas liquids or 4.26 million gallons (approximately 101,000 barrels) per day.
We procure natural gas liquids from refiners, natural gas processing plants, producers and other resellers for delivery to leased or owned storage space, common carrier pipelines, railcar terminals, and direct to certain customers.
12 unchanged sentences
We provide transportation, storage, and throughput services to third parties at our facilities in Port Hudson, Louisiana, Chesapeake, Virginia and Shelton, Washington.
−Removed: We purchase refined petroleum and renewable products primarily in the Gulf Coast, West Coast and Midwest regions of the United States and schedule them for delivery at various locations throughout the country.
−Removed: We conduct just-in-time sales at a nationwide network of terminals owned by third parties via rack spot sales or delivered sales that do not involve continuing contractual obligations to purchase or deliver product.
−Removed: Rack spot sales are priced and delivered on a daily basis through truck loading racks.
−Removed: At the end of each day for each of the terminals that we market from, we establish the next day selling price for each product for each of our delivery locations.
−Removed: We announce or “post” to customers via website, e-mail, and telephone communications the rack spot sale price of various products for the following morning.
−Removed: When customers decide to purchase product from us, we purchase the same volume of product from a supplier at a previously agreed-upon price.
−Removed: For these just-in-time transactions, our purchase from the supplier occurs at the same time as our sale to our customer.
−Removed: Typical rack spot sale purchasers include commercial and industrial end users, independent retailers and small, independent marketers who resell
−Removed: product to retail gasoline stations or other end users.
−Removed: Our selling price of a particular product on a particular day is a function of our supply at that delivery location or terminal, our estimate of the costs to replenish the product at that delivery location, and our desire to reduce product volume at that particular location that day.
−Removed: A significant percentage of our business is priced on a back-to-back basis which minimizes our commodity price exposure.
The following table summarizes the location of our facilities and respective storage capacity and interconnects to those facilities.
1 unchanged sentence
Location Number of Facilities Own (1) Lease (2) Total Terminal Interconnects
−Removed: Virginia 2 20,888,000 — 20,888,000 Rail Facility;
−Removed: Marine Facility
−Removed: Arkansas 3 3,765,000 90,000 3,855,000 Connected to Enterprise Texas Eastern Products Pipeline;
−Removed: Rail Facility
−Removed: Missouri 3 2,124,000 — 2,124,000 Connected to Enterprise Texas Eastern Products Pipeline, Phillips66 Blue Line Pipeline and Magellan (OKE) #6 Pipeline
−Removed: Minnesota 1 1,829,000 — 1,829,000 Connected to Enterprise Mid-America Pipeline;
−Removed: Rail Facility
−Removed: Indiana 1 1,530,000 — 1,530,000 Connected to Enterprise Texas Eastern Products Pipeline;
−Removed: Rail Facility
−Removed: Wisconsin 2 696,000 390,000 1,086,000 Connected to Enterprise Mid-America Pipeline;
−Removed: Rail Facility
−Removed: Massachusetts 2 788,400 — 788,400 Rail Facility
+Added: Virginia 2 20,888,000 — 20,888,000 Rail, Truck and Marine Facility
Louisiana 1 720,000 — 720,000 Truck Facility
−Removed: Illinois 1 480,000 — 480,000 Connected to Phillips66 Blue Line Pipeline
−Removed: Michigan 1 480,000 — 480,000 Connected to Ambassador Pipeline
−Removed: New York 2 — 450,000 450,000 Rail Facility
−Removed: Maine 1 — 120,000 120,000 Rail Facility
−Removed: Vermont 1 — 120,000 120,000 Rail Facility
−Removed: Washington 1 — 120,000 120,000 Rail Facility
−Removed: United States Total 22 33,300,400 1,290,000 34,590,400
−Removed: Ontario, Canada (3) 1 — 120,000 120,000 Truck Facility
−Removed: Canada Total 1 — 120,000 120,000
+Added: Michigan 1 480,000 — 480,000 Truck and Pipeline Facility
+Added: Washington 1 — 120,000 120,000 Rail and Truck Facility
Total 5 22,088,000 120,000 22,208,000
1 unchanged sentence
(2) These facilities are located on lands we lease.
−Removed: (3) This facility is operated by a third party under a year-to-year agreement.
−Removed: During the year ended March 31, 2024, we sold three natural gas liquids terminals (see Note 17 to our consolidated financial statements included in this Annual Report).
−Removed: We own the land on which 15 of the 23 natural gas liquids terminals are located and we either have easements or lease the land on which the remaining terminals are located.
+Added: We own the land on which four of the five natural gas liquids terminals are located and we lease the land on which the remaining terminal is located.
We own a natural gas liquids terminal that supports refined products blending in Port Hudson, Louisiana, and a marine export/import terminal in Chesapeake, Virginia.
−Removed: The Port Hudson terminal is located near Baton Rouge, Louisiana, and is in proximity to other refined products infrastructure along the Colonial pipeline.
+Added: The Port Hudson terminal is located near Baton Rouge, Louisiana, and is in
+Added: proximity to other refined products infrastructure along the Colonial pipeline.
This truck unloading and storage facility allows for the aggregation and supply of butane and naphtha for motor fuel blending and consists of storage tanks with a total capacity of 720,000 gallons.
2 unchanged sentences
The facility has an aggregate storage capacity of 20,408,000 gallons.
−Removed: We own 28 transloading units, which enable customers to transfer product from railcars to trucks.
−Removed: These transloading units can be moved to locations along a railroad where it is most convenient for customers to transfer their product.
+Added: See Note 1 and Note 17 to our consolidated financial statements included in this Annual Report for all related dispositions in the current and prior years for the Liquids Logistics segment.
+Added: We own 28 transloading units, which enable transfer of product from railcars to trucks.
+Added: These transloading units can be moved to locations along a railroad where it is most economical to transfer product at sites which otherwise would be out of reach of this product.
We own the Ambassador Pipeline, an approximately 225-mile propane pipeline, which runs from the Kalkaska gas plant in Kalkaska County, Michigan to a termination point near Marysville in St.
1 unchanged sentence
The Wheeler propane terminal, in central Michigan, is located at the mid-point of the pipeline.
−Removed: These assets complement our existing assets in the upper Midwest and will expand our presence in Michigan, one of the top propane markets in the United States.
We utilize a fleet of approximately 3,300 high-pressure and general purpose leased railcars of which 102 railcars are subleased by third parties.
We lease storage space to accommodate the supply requirements and contractual needs of our retail and wholesale customers.
−Removed: The following table summarizes our significant leased storage space at natural gas liquids and refined products storage facilities and interconnects to those facilities:
+Added: The following table summarizes our significant leased storage space at natural gas liquids storage facilities and interconnects to those facilities:
Leased Storage Space
1 unchanged sentence
2025 Storage Interconnects
−Removed: Kansas 44,100,000 56,700,000 Connected to Enterprise Mid-America Pipeline, NuStar Pipelines and ONEOK North System Pipeline;
−Removed: Rail Facility;
−Removed: Truck Facility
−Removed: Michigan 21,000,000 26,692,050 Rail Facility;
−Removed: Truck Facility
−Removed: Arizona 5,510,400 5,510,400 Kinder Morgan West Pipeline;
−Removed: Truck Facility
+Added: Michigan 10,500,000 21,000,000 Rail and Truck Facility
+Added: Mississippi 8,400,000 3,150,000 Pipeline and Rail Facility
Utah 5,880,000 5,250,000 Rail Facility
−Removed: Texas 4,830,000 4,830,000 Connected to Enterprise Texas Eastern Products Pipeline;
−Removed: Truck Facility
−Removed: Mississippi 3,150,000 1,680,000 Connected to Enterprise Dixie Pipeline;
−Removed: Rail Facility
−Removed: Oregon 2,100,000 2,100,000 Rail Facility;
−Removed: Truck Facility
+Added: Texas 210,000 210,000 Pipeline and Rail Facility
United States Total 24,990,000 29,610,000
+Added: Alberta, Canada 1,323,420 1,323,420 Pipeline and Rail Facility
Ontario, Canada — 8,467,200 Rail Facility
−Removed: Alberta, Canada 1,323,420 1,323,420 Connected to Cochin Pipeline;
−Removed: Rail Facility
Canada Total 1,323,420 9,790,620
Total 26,313,420 39,400,620
−Removed: Our Liquids Logistics segment serves approximately 1,200 customers in 48 states, Mexico and Canada, including national, regional and independent retail, industrial, wholesale, petrochemical, refiner and natural gas liquids production customers.
+Added: Our customers include national, regional and independent retail, industrial, wholesale, petrochemical, refiner and natural gas liquids production customers.
During the year ended March 31, 2025, 36% of the revenues of our Liquids Logistics segment were generated from our ten largest customers of the segment.
+Added: Additionally, certain key customers of the Liquids Logistics segment contribute significantly to the cash flows and profitability of the Partnership.
+Added: Any loss of those customers or their contracts could have an adverse impact on our financial results.
Seasonality .
−Removed: Our wholesale liquids business is largely seasonal as the primary users of propane as heating fuel generally purchase propane during the typical fall and winter heating season.
+Added: Our wholesale liquids business is largely seasonal as the primary users of propane as heating fuel generally purchase propane during the typical fall and winter heating season, while butane seasonality is driven primarily by winter gasoline blending.
However, we are able to partially mitigate the effects of seasonality by preselling a portion of our wholesale volumes to retailers and wholesalers and requiring the customer to take delivery of the product regardless of the weather.
−Removed: The demand for gasoline typically peaks during the summer driving season, which extends from April to September, and declines during the fall and winter months.
−Removed: However, the demand for diesel typically peaks during the fall and winter months due to colder temperatures, and peaks in the Midwest during spring planting and fall harvest.
−Removed: Our Liquids Logistics segment faces significant competition from other natural gas liquids wholesalers, trading companies and companies involved in the natural gas liquids midstream industry (such as terminal and refinery operations), some of which have greater financial resources than we do.
+Added: Our Liquids Logistics segment faces competition from other natural gas liquids wholesalers, trading companies and companies involved in the natural gas liquids midstream industry (such as terminal and refinery operations), some of which have greater financial resources than we do.
The primary factors on which we compete are:
• availability of supply;
−Removed: • reliability of service;
• available space on common carrier pipelines;
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Our philosophy is to maintain minimum commodity price exposure through a combination of purchase contracts, sales contracts and financial derivatives.
−Removed: A significant percentage of our refined products and biodiesel businesses is priced on a back-to-back basis which minimizes our commodity price exposure.
For discretionary inventory, and for those instances where physical transactions cannot be appropriately matched, we utilize financial derivatives to mitigate commodity price exposure.
Specific exposure limits are mandated in our market risk policy.
−Removed: The value of refined products in any local delivery market is the sum of the commodity price as reflected on the New York Mercantile Exchange (“NYMEX”) and the basis differential for that local delivery market.
−Removed: The basis differential for any local delivery market is the spread between the cash price in the physical market and the quoted price in the futures markets for the prompt month.
−Removed: We typically utilize NYMEX futures contracts to mitigate commodity price exposure.
−Removed: We generally do not manage the financial impact on us from changes in basis differentials affected by local market supply and demand disruptions.
Pricing Policy.
5 unchanged sentences
We are able to match our supply and sales commitments by offering our customers purchase contracts with flexible price, location, storage, and ratable delivery.
−Removed: However, certain common carrier pipelines require us to keep minimum in-line inventory balances year round to conduct our daily business, and these volumes are not matched with a sales commitment.
−Removed: We generally require deposits from our customers for fixed price future delivery if the delivery date is more than 30 days after the time of contractual agreement.
−Removed: Legal and Regulatory Considerations.
−Removed: Demand for ethanol and biodiesel is driven in large part by government mandates and incentives.
−Removed: Refiners and producers are required to blend a certain percentage of renewables into their refined products, although the percentage can vary from year to year based on the United States Environmental Protection Agency (“EPA”) mandates.
−Removed: In addition, the federal government has in recent years granted certain tax credits for the use of biodiesel, although on several occasions these tax credits have expired.
−Removed: In August 2022, the federal government extended the tax credit, with the tax credit now expiring on December 31, 2024.
−Removed: Changes in future mandates and incentives, or decisions by the federal government related to future reinstatement of the biodiesel tax credit, could result in changes in demand for ethanol and biodiesel.
−Removed: Our Liquids Logistics segment operates primarily under the NGL Supply Wholesale, NGL Supply Terminal Company, Centennial Energy, Centennial Gas Liquids and NGL Crude Logistics trade names.
+Added: We can require deposits from our customers for fixed price future delivery if the delivery date is more than 30 days after the time of contractual agreement.
+Added: Our Liquids Logistics segment operates primarily under the Centennial Energy, Centennial Gas Liquids and NGL Supply Terminal Company trade names.
Human Capital
69 unchanged sentences
Generally, these laws (i) regulate air and water quality, impose limitations on the discharge of pollutants and establish standards for the use, handling, storage, treatment, transport and disposal of solid and hazardous wastes;
−Removed: (ii) subject our operations to certain permitting and registration requirements;
+Added: (ii) subject our operations to certain permitting, registration and reporting requirements;
(iii) may result in the suspension or revocation of necessary permits, licenses and authorizations;
2 unchanged sentences
and (vi) may result in the assessment of administrative, civil and criminal penalties for failure to comply with such laws.
−Removed: These laws include, among others, the Resource Conservation and Recovery Act (“RCRA”), the Comprehensive Environmental Response, Compensation and Liability Act (“CERCLA”), the federal Clean Air Act (“CAA”), the Homeland Security Act of 2002, the
−Removed: Emergency Planning and Community Right to Know Act, the Clean Water Act (“CWA”), the Safe Drinking Water Act, the Oil Spills Prevention and Preparedness Regulations, each as amended, and comparable state statutes.
+Added: These laws include, among others, the Resource Conservation and Recovery Act (“RCRA”), the Comprehensive Environmental Response, Compensation and Liability Act (“CERCLA”), the federal Clean Air Act (“CAA”), the Homeland Security Act of 2002, the Emergency Planning and Community Right to Know Act (“EPCRA”), the Clean Water Act (“CWA”), the Safe Drinking Water Act, the Oil Spills Prevention and Preparedness Regulations, each as amended, and comparable state statutes.
CERCLA, also known as the “Superfund” law, and similar state laws, impose liability on certain classes of potentially responsible persons that are considered to have contributed to the release of a “hazardous substance” into the environment.
4 unchanged sentences
RCRA, and comparable state statutes and their implementing regulations, regulate the generation, transportation, treatment, storage, disposal and cleanup of solid and hazardous wastes.
−Removed: Under a delegation of authority from the EPA, most states administer some or all of the provisions of RCRA, sometimes in conjunction with their own, more stringent requirements.
+Added: Under a delegation of authority from the United States Environmental Protection Agency (“EPA”), most states administer some or all of the provisions of RCRA, sometimes in conjunction with their own, more stringent requirements.
Federal and state regulatory agencies can seek to impose administrative, civil and criminal penalties for alleged non-compliance with RCRA and analogous state requirements.
3 unchanged sentences
Legislation has been proposed from time to time in Congress to regulate certain oil and natural gas wastes as “hazardous wastes under RCRA.” Any such change could result in an increase in our costs to manage and dispose of wastes, which could have a material adverse effect on our consolidated results of operations and financial position.
−Removed: Wastes containing naturally occurring radioactive materials (“NORM”) may also be generated in connection with our operations.
−Removed: Certain processes used to produce oil and gas may enhance the radioactivity of NORM, which may be present in oilfield wastes.
−Removed: NORM is subject primarily to individual state radiation control regulations.
−Removed: Texas and New Mexico have both enacted regulations governing the handling, treatment, storage and disposal of NORM.
−Removed: In addition, NORM handling and management activities are governed by regulations promulgated by the federal Occupational Safety and Health Act (“OSHA”).
−Removed: These state and OSHA regulations impose certain requirements concerning worker protection, the treatment, storage and disposal of NORM waste, the management of waste piles, containers and tanks containing NORM, as well as restrictions on the uses of land with NORM contamination.
+Added: Wastes containing naturally occurring radioactive materials (“NORM”) and technologically enhanced naturally occurring radioactive material (“TENORM”) may also be generated or concentrated, respectively, in connection with our operations.
+Added: Certain processes used to produce oil and gas may enhance the radioactivity of NORM or concentrations of TENORM, which may be present in oilfield wastes.
+Added: NORM and TENORM are subject primarily to individual state radiation control regulations.
+Added: Texas, New Mexico and Colorado have enacted regulations governing the handling, treatment, storage and disposal of NORM and TENORM.
+Added: In addition, NORM and TENORM handling and management activities are governed by regulations promulgated by the federal Occupational Safety and Health Act (“OSHA”).
+Added: These state and OSHA regulations impose certain requirements concerning worker protection, the treatment, storage and disposal of NORM and TENORM waste, the management of waste piles, containers and tanks containing NORM and TENORM, as well as restrictions on the uses of land with NORM or TENORM contamination.
We currently own or lease properties where crude oil is being or has been handled for many years.
−Removed: Although previous operators have utilized operating and disposal practices that were standard in the industry at the time, crude oil or other wastes may have been disposed of or released on or under the properties owned or leased by us or on or under the other locations where the crude oil and wastes have been transported for treatment or disposal.
+Added: Although previous operators have utilized operating and disposal practices that were standard in the industry at the time, crude oil or other wastes, including Per- and Polyfluoroalkyl Substances (“PFAS”), may have been disposed of or released on or under the properties owned or leased by us or on or under the other locations where the crude oil and wastes have been transported for treatment or disposal.
These properties and the wastes disposed or released thereon may be subject to CERCLA, RCRA and analogous state laws.
3 unchanged sentences
In 1973, the EPA adopted oil pollution prevention regulations under the CWA.
−Removed: These oil pollution prevention regulations, as amended several times since their original adoption, require the preparation of a Spill Prevention Control and Countermeasure (“SPCC”) plan for facilities engaged in drilling, producing, gathering, storing, processing, refining, transferring, distributing, using, or consuming crude oil and oil products, and which due to their location, could reasonably be expected to discharge oil in harmful quantities into or upon the navigable waters of the United States.
−Removed: SPCC requirements under the CWA require appropriate containment berms and similar structures to help prevent the discharge of pollutants into regulated waters in the event of a crude oil or other constituent tank spill, rupture or leak.
−Removed: The owner or operator of an SPCC-regulated facility is required to prepare a written, site-specific SPCC plan, which details how a facility’s operations comply with the spill prevention and control requirements.
−Removed: To be in compliance, the facility’s SPCC plan must satisfy all of the applicable requirements for drainage, bulk storage tanks, tank car and truck loading and unloading, transfer operations (intra-facility piping), inspections and records, security, and training.
−Removed: Most importantly, the facility must fully implement the SPCC plan and train personnel in its execution.
−Removed: Where applicable, we strive to maintain and implement SPCC
−Removed: plans for our facilities.
−Removed: Violation of SPCC requirements could subject us to monetary penalties, injunctions, conditions or restrictions on operations and, potentially, criminal enforcement actions.
+Added: These oil pollution prevention regulations, as amended several times since their original adoption, require the preparation of either a Spill Prevention Control and Countermeasure (“SPCC”) plan or Facility Response Plan (“FRP”), depending on the site specific substantial harm criteria, for facilities engaged in drilling, producing, gathering, storing, processing, refining, transferring, distributing, using, or consuming crude oil and oil products, and which due to their location, could reasonably be expected to discharge oil in harmful quantities into or upon the navigable waters of the United States.
+Added: SPCC and FRP requirements under the CWA require appropriate containment berms and similar structures to help prevent the discharge of pollutants into regulated waters in the event of a crude oil or other constituent tank spill, rupture or leak.
+Added: The owner or operator of an SPCC or FRP-regulated is required to prepare a written, site-specific plan, which details how a facility’s operations comply with the spill prevention and control requirements.
+Added: To be in compliance, the facility’s plan must satisfy all of the applicable requirements for drainage, bulk storage tanks, tank car and truck loading and unloading, transfer operations (intra-facility piping), inspections and records, security, and training.
+Added: Most importantly, the facility must fully implement the plan and train personnel in its execution.
+Added: Where applicable, we strive to maintain and implement SPCC plans and/or FRP plans for our facilities.
+Added: Violation of SPCC and FRC requirements could subject us to monetary penalties, injunctions, conditions or restrictions on operations and, potentially, criminal enforcement actions.
Air Emissions .
1 unchanged sentence
Under a delegation of authority from the EPA, most states administer some or all of the provisions of the CAA, sometimes in conjunction with their own, more stringent requirements.
−Removed: The CAA and its implementing regulations on the federal and state level may require that we obtain permits prior to the construction, modification or operation of certain projects or facilities expected to emit or increase air emissions above certain threshold levels, that we obtain and strictly comply with air permits containing emissions and operational limitations, or utilize specific emission control technologies to limit emissions, any of which could impose significant costs on our business.
+Added: The CAA and its implementing regulations on the federal and state level may require that we obtain permits prior to the construction, modification or operation of certain projects or facilities expected to emit or increase air emissions above certain threshold levels, that we obtain and strictly comply with air permits containing emissions and operational limitations, or utilize specific emission control technologies to limit
+Added: emissions, any of which could impose significant costs on our business.
Violation of CAA requirements could subject us to monetary penalties, injunctions, conditions or restrictions on operations and, potentially, criminal enforcement actions.
2 unchanged sentences
The CWA and analogous state laws impose restrictions and strict controls regarding the discharge of pollutants into state waters as well as navigable waters, defined as waters of the United States (“WOTUS”), and impose requirements affecting our ability to conduct construction activities in waters and wetlands.
−Removed: Certain state regulations and the general permits issued under the CWA’s National Pollutant Discharge Elimination System program prohibit the discharge of pollutants and chemicals.
+Added: Certain state regulations and the general permits issued under the CWA’s National Pollutant Discharge Elimination System program prohibit the discharge of pollutants and chemicals unless permitted to do so.
The CWA prohibits the placement of dredge or fill material in wetlands or other WOTUS unless authorized by a permit issued by the U.S.
1 unchanged sentence
In addition, the CWA and analogous state laws require individual permits or coverage under general permits for discharges of storm water runoff from certain types of facilities.
−Removed: We maintain a number of discharge permits, some of which may require us to monitor and sample storm water runoff from such facilities.
+Added: We maintain a number of discharge permits, some of which may require us to monitor and sample storm water runoff or other discharges from such facilities.
Some states also maintain groundwater protection programs that require permits for discharges or operations that may impact groundwater conditions.
13 unchanged sentences
Congress will likely continue to consider legislation to amend the Safe Drinking Water Act to subject hydraulic fracturing operations to regulation under the Act’s UIC program and/or require disclosure of chemicals used in the hydraulic fracturing process.
−Removed: Federal agencies, including the EPA and the United States Department of the Interior, have asserted their regulatory authority to, for example, study the potential impacts of hydraulic fracturing on the environment, and initiate rulemakings to compel disclosure of the chemicals used in hydraulic fracturing operations, and establish pretreatment standards and effluent limitation guidelines for produced
−Removed: water from hydraulic fracturing operations.
+Added: Federal agencies, including the EPA and the United States Department of the Interior, have asserted their regulatory authority to, for example, study the potential impacts of hydraulic fracturing on the environment, and initiate rulemakings to compel disclosure of the chemicals used in hydraulic fracturing operations, and establish pretreatment standards and effluent limitation guidelines for produced water from hydraulic fracturing operations.
In addition, some states and local governments have also proposed or adopted legislative or regulatory restrictions on hydraulic fracturing, which include additional permit requirements, public disclosure of fracturing fluid contents, operational restrictions, and/or temporary or permanent bans on hydraulic fracturing.
3 unchanged sentences
Similar protections are offered to migratory birds under the federal Migratory Bird Treaty Act (“MBTA”) and the Bald and Golden Eagle Protection Act (“BGEPA”).
−Removed: To the degree that species listed under the ESA or similar state laws, or are protected under the MBTA or BGEPA, live, breed or nest in or migrate through the areas where we or our oil and gas producing customers operate, our and our customers’ abilities to conduct or expand operations and construct facilities could be limited or be forced to incur material additional costs.
+Added: To the degree that species listed under the ESA or similar state laws, or are protected under the MBTA or BGEPA, live, breed or nest in or migrate through the areas where we or our oil and gas producing customers operate, our and our customers’ abilities to conduct or expand operations and construct
+Added: facilities could be limited or be forced to incur material additional costs.
Moreover, our customers’ drilling activities may be delayed, restricted, or cancelled in protected habitat areas or during certain seasons, such as breeding and nesting seasons.
2 unchanged sentences
Fish and Wildlife Service (“USFWS”) may make determinations on the listing of currently unlisted species as endangered or threatened under the ESA.
−Removed: For example, on July 3, 2023, the USFWS proposed that the dunes sagebrush lizard, which is found in areas where we operate, be listed as endangered under the ESA.
+Added: For example, in May 2024, the dunes sagebrush lizard, which is found in areas where we operate, was listed as endangered under the ESA which sparked allegations that the designation occurred to hinder fossil fuel production.
+Added: This resulted in a federal lawsuit filed in the Western District of Texas aimed at overturning the designation.
In addition, the lesser prairie-chicken, which can also be found in areas where we operate, was listed under the ESA effective March 27, 2023.
11 unchanged sentences
In addition, several states have already adopted legal measures to reduce emissions of GHGs, primarily through the planned development of GHG emission inventories and/or regional GHG cap-and-trade programs.
−Removed: For example, on October 7, 2023, California Governor Gavin Newsome signed SB 253, the Climate Corporate Data Accountability Act, and SB 261, the Climate-Related Financial Risk Act.
−Removed: These two bills apply to companies doing business in California and require disclosure of, amongst certain other climate-related financial risk information, scope 1 and 2 GHG emissions, beginning in 2026 (on prior fiscal year information), and scope 3 GHG emissions, beginning in 2027 (on prior fiscal year information).
+Added: For example, on October 7, 2023, California Governor Gavin Newsom signed SB 253, the Climate Corporate Data Accountability Act, and SB 261, the Climate-Related Financial Risk Act.
+Added: These two bills apply to companies doing business in California and require disclosure of, among certain other climate-related financial risk information, Scope 1 and 2 GHG emissions, beginning in 2026 (on prior fiscal year information), and Scope 3 GHG emissions, beginning in 2027 (on prior fiscal year information).
On December 15, 2009, the EPA published its findings that emissions of carbon dioxide, methane and other GHGs present an endangerment to public health and the environment because emissions of such gases are, according to the EPA, contributing to warming of the earth’s atmosphere and other climatic changes.
2 unchanged sentences
During the Trump Administration, rulemaking was undertaken resulting in a substantial relaxation in the GHG NSPS’s requirements, including those relating to fugitive emissions, pneumatic pump standards, and closed vent system certification, among other things, which were finalized on August 13, 2020.
−Removed: The Biden Administration announced its intention to review the revisions to the GHG NSPS in President Biden’s January 20, 2021 Executive Order on Protecting Public Health and the Environment and Restoring Science to Tackle the Climate Crisis .
+Added: The Biden Administration announced its intention to review the revisions to the GHG NSPS in former President Biden’s January 20, 2021 Executive Order on Protecting Public Health and the Environment and Restoring Science to Tackle the Climate Crisis .
On November 15, 2021, the EPA issued a proposal to revise the GHG NSPS regulations.
2 unchanged sentences
The rule became effective May 7, 2024 and requires monitoring and repair of methane leaks and certain reporting requirements.
−Removed: On March 6, 2024, the Securities and Exchange Commission (“SEC”) adopted a new set of rules that require a wide range of climate-related disclosures, including material climate-related risks, information on any climate-related targets or goals that are material to the registrant’s business, results of operations, or financial condition, Scope 1 and Scope 2 GHG emissions
−Removed: on a phased-in basis by certain larger registrants when those emissions are material and the filing of an attestation report covering the same, and disclosure of the financial statement effects of severe weather events and other natural conditions including costs and losses.
+Added: On March 6, 2024, the Securities and Exchange Commission (“SEC”) adopted a new set of rules that require a wide range of climate-related disclosures, including material climate-related risks, information on any climate-related targets or goals that are material to the registrant’s business, results of operations, or financial condition, Scope 1 and Scope 2 GHG emissions on a phased-in basis by certain larger registrants when those emissions are material and the filing of an attestation report covering the same, and disclosure of the financial statement effects of severe weather events and other natural conditions including costs and losses.
Compliance dates under the final rule are phased in by registrant category.
1 unchanged sentence
Court of Appeals for the Eighth Circuit.
−Removed: On April 4, 2024, the SEC issued an order staying the final rules until judicial review is complete.
+Added: On April 4, 2024, the SEC issued an order staying the final rules pending judicial review before ultimately voting to withdraw its defense of the rule on March 27, 2025.
Some scientists have suggested climate change could increase the severity of extreme weather, such as increased hurricanes and floods, which could damage our facilities.
−Removed: Another possible consequence of climate change is increased volatility in seasonal temperatures.
+Added: Another possible consequence of climate change is increased
+Added: volatility in seasonal temperatures.
The market for our natural gas liquids is generally improved by periods of colder weather and impaired by periods of warmer weather, so any changes in climate could affect the market for our products and services.
23 unchanged sentences
The law also provides for (i) additional pipeline damage prevention measures;
−Removed: (ii) allowing the Secretary of
−Removed: Transportation to require automatic and remote-controlled shut-off valves on new pipelines;
+Added: (ii) allowing the Secretary of Transportation to require automatic and remote-controlled shut-off valves on new pipelines;
(iii) requiring the Secretary of Transportation to evaluate the effectiveness of expanding pipeline integrity management and leak detection requirements;
3 unchanged sentences
Railcar Regulation
−Removed: We transport a significant portion of our natural gas liquids and biodiesel via rail transportation, and we own and/or lease a fleet of crude oil, high-pressure and general purpose railcars for this purpose.
+Added: We transport a significant portion of our natural gas liquids via rail transportation, and we lease a fleet of crude oil, high-pressure and general purpose railcars for this purpose.
Our railcar operations are subject to the regulatory jurisdiction of the Federal Railroad Administration of the DOT, as well as other federal and state regulatory agencies.
11 unchanged sentences
Compared sentence by sentence after normalising whitespace, quotation marks, case and digits, so re-formatting and restated figures do not read as changed language. Wording changes appear as one removal and one addition. The current filing and the prior one are authoritative.