−Removed: We are a diversified midstream energy partnership that transports, treats, recycles and disposes of produced and flowback water generated as part of the energy production process as well as transports, stores, markets and provides other logistics services for crude oil and liquid hydrocarbons.
Originally formed in September 2010, we are a Delaware master limited partnership and our business is currently organized into the following three segments:
• Our Water Solutions segment transports, treats, recycles and disposes of produced and flowback water generated from crude oil and natural gas production.
−Removed: We also sell produced water for reuse and recycle and brackish non-potable water to our producer customers to be used in their crude oil exploration and production activities.
+Added: We also sell produced water for reuse and recycle to our producer customers to be used in their crude oil exploration and production activities.
As part of processing water, we aggregate and sell recovered crude oil, also known as skim oil.
−Removed: We also dispose of solids such as tank bottoms, drilling fluids and drilling muds and perform other ancillary services such as truck and frac tank washouts.
−Removed: 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.
+Added: We also dispose of solids such as tank bottoms, drilling fluids and drilling muds and perform other ancillary services such as truck washouts.
+Added: Our activities in this segment are underpinned by long-term, fixed fee contracts and acreage dedications, a significant portion of which contain minimum volume commitments with leading oil and gas companies including large, investment grade producer customers.
• 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.
1 unchanged sentence
• Our Liquids Logistics segment conducts supply operations for natural gas liquids to commercial, retail and industrial customers across the United States and Canada.
−Removed: 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).
+Added: These operations are conducted through our five owned terminals, third-party storage and terminal facilities, access to 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.
1 unchanged sentence
We also enter into financially settled derivative contracts as economic hedges of our physical inventory, physical sales and physical purchase contracts.
−Removed: Sale of Refined Products Business and Exiting Biodiesel Business
−Removed: 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).
−Removed: 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).
−Removed: This sale closed on April 30, 2025.
−Removed: 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.
−Removed: 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.
−Removed: 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
−Removed: 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).
−Removed: Sale of Certain Natural Gas Liquids Terminals and Most of Our Wholesale Propane Business
−Removed: 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).
−Removed: This sale closed on April 30, 2025.
−Removed: 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).
−Removed: 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
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.
−Removed: 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.
+Added: We believe our actions have simplified our business mix, have allowed us to focus on moving to becoming a pure play water solutions company and have improved our overall financial position.
+Added: As part of these actions, we completed the below dispositions during the current fiscal year:
+Added: • On April 14, 2025, we sold certain investments in unconsolidated entities, property, plant and equipment and intangible assets in our Water Solutions segment;
+Added: • On April 30, 2025, we sold our refined products business, which was part of our Liquids Logistics segment, including certain working capital items;
+Added: • On April 30, 2025, we sold most of our wholesale propane business, 17 of our natural gas liquids terminals, our interest in an unconsolidated entity and working capital (“Wholesale Propane Disposition”), which was part of our Liquids Logistics segment.
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 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 .
+Added: For more information regarding our disposition transactions and the impact to our operations, see Part II, Item 7–“Management’s Discussion and Analysis of Financial Condition and Results of Operations” and 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, 2025 and 2024 .
Debt Refinancing
−Removed: On February 2, 2024, we closed a debt refinancing transaction of $2.9 billion.
−Removed: The refinancing consisted of a private offering of $2.2 billion of senior secured notes, which includes $900.0 million of 8.125% senior secured notes due 2029 (“2029 Senior Secured Notes”) and $1.3 billion of 8.375% senior secured notes due 2032 (“2032 Senior Secured Notes”).
−Removed: 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 asset-based revolving credit facility (“ABL Facility”) was amended to extend the maturity and to make certain other changes to the terms thereof.
−Removed: 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.
+Added: On March 12, 2026, we closed a debt refinancing transaction of $950.0 million consisting of a new seven-year senior secured 2026 term loan “B” credit facility (“2026 Term Loan B”).
+Added: In connection with the closing of the debt refinancing transaction, our asset-based revolving credit facility (“ABL Facility”) was amended to reduce our total commitments and to make other changes to the terms thereof.
+Added: For additional information related to the 2026 Term Loan B and ABL Facility, see Note 7 to our consolidated financial statements included in this Annual Report.
Primary Service Areas
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We intend to accomplish these business objectives by executing the following strategies:
+Added: • Position the Partnership as a leading pure play produced water infrastructure platform providing water solutions to upstream customers.
+Added: We currently operate the largest integrated produced water pipeline, disposal, and water handling network in the Delaware Basin, supported by long-term, fee-based producer contracts and continue to enhance our ability to transport produced water from the wellhead to treatment for disposal, recycle, or discharge through our expanding pipeline infrastructure and ongoing disposal capacity investments.
+Added: While maintaining complementary crude oil and natural gas liquids logistics operations, capital allocation and strategic focus are centered on providing water solutions services, which will reduce earnings volatility and enhance cash flow stability.
• 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 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.
+Added: Our primary focus is to eliminate our Class D Preferred Units (“Class D Preferred Units”) and reduce 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.
We expect to continue to evaluate the capital markets and may opportunistically pursue financing transactions to optimize our capital structure.
−Removed: • Building a midstream master limited partnership focusing on providing water solutions to upstream customers.
−Removed: We continue to enhance our ability to transport produced water from the wellhead to treatment for disposal, recycle, or discharge.
−Removed: To a lesser extent, we move crude oil from the wellhead to refineries, and natural gas liquids from processing plants and supply hubs to end users.
• Operating in a safe and environmentally responsible manner.
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Our water processing facilities are located among the most prolific crude oil and natural gas producing areas in the United States, including the Delaware Basin, the Denver-Julesburg (“DJ”) Basin and the Eagle Ford Basin.
−Removed: These assets are underpinned by long-term, fixed fee contracts and acreage dedications, some of which contain minimum volume commitments.
+Added: These assets are underpinned by long-term, fixed fee contracts and acreage dedications, a significant portion of which contain minimum volume commitments.
Additionally, we believe that the technological capabilities of our Water Solutions business can be quickly implemented at new facilities and locations as needed.
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Our strategically deployed terminals, as well as our owned and contracted pipeline capacity, provide access to producers in the DJ Basin.
−Removed: 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.
+Added: These operations are supported by certain long-term, fixed rate contracts with acreage dedications with producers, refiners and marketers and which include minimum volume commitments on our storage tanks and owned and leased pipelines.
• 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 natural gas liquid supply terminals, propane pipeline in Michigan, large leased railcar fleet, shipper status on common carrier pipelines, and
−Removed: leased storage enable us to be a preferred purchaser and seller of butane and other 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 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.
10 unchanged sentences
Our Water Solutions segment transports, treats, recycles and disposes of produced and flowback water generated from crude oil and natural gas production.
−Removed: We also sell produced water for reuse and recycle and brackish non-potable water to our producer customers to be used in their crude oil exploration and production activities.
+Added: We also sell produced water for reuse and recycle to our producer customers to be used in their crude oil exploration and production activities.
As part of processing water, we aggregate and sell recovered crude oil, also known as skim oil.
−Removed: We also dispose of solids such as tank bottoms, drilling fluids and drilling muds and perform other ancillary services such as truck and frac tank washouts.
−Removed: 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.
+Added: We also dispose of solids such as tank bottoms, drilling fluids and drilling muds and perform other ancillary services such as truck washouts.
+Added: Our activities in this segment are underpinned by long-term, fixed fee contracts and acreage dedications, a significant portion of which contain minimum volume commitments with leading oil and gas companies including large, investment grade producer customers.
We operate in a number of the most prolific crude oil and natural gas producing areas in the United States including the Delaware Basin in New Mexico and Texas, the DJ Basin in Colorado and the Eagle Ford Basin in Texas.
−Removed: 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.
+Added: With a system that handled approximately 1.063 billion barrels of produced water across its areas of operation during the year ended March 31, 2026, we believe that we are the largest independent produced water transportation and disposal company in the United States.
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.
This system spans six counties in New Mexico and Texas that represent one of the most prolific crude oil producing regions in the United States with some of the most economic hydrocarbon resources and lowest break-even economics for producers.
−Removed: 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.
+Added: Our system has approximately 840 miles of newly-built, in-service large diameter produced water pipelines connected to 59 active saltwater disposal facilities and 141 active disposal wells.
We currently have approximately 766,000 acres dedicated to our Northern Delaware system under long-term agreements providing a multi-decade drilling inventory and significant growth opportunity.
−Removed: In addition, we have several minimum volume commitments and other commercial agreements covering the Delaware, DJ and Eagle Ford Basins.
+Added: In addition, we have significant minimum volume commitments and other commercial agreements covering the Delaware, DJ and Eagle Ford Basins.
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.
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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.
−Removed: 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 27-mile, 30-inch produced water pipeline transports water to areas outside the core of the basin thereby further diversifying the geographic location of our disposal operations.
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.
+Added: On May 7, 2026, we announced a further expansion of our LEX II Pipeline System to increase capacity by 165,000 barrels of water per day with a capability to transport approximately 560,000 barrels of water per day on the LEX II system.
+Added: The LEX II Expansion is un derwritten by a newly executed long-term volume commitment contract that includes increased volume commitments, and an additional four township committed area in Eddy County, New Mexico .
Additionally, the LEX II Expansion is expandable up to 650,000 barrels of water per day.
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(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.
−Removed: 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).
−Removed: 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.
−Removed: 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).
−Removed: 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.
+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 Water Solutions segment.
+Added: Our primary customers 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, 2026, 78% of the revenues of our Water Solutions segment were generated from our ten largest customers of the segment.
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(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
−Removed: dedicated acreage with us;
−Removed: and (c) produced water pipeline and trucked disposal agreements providing interruptible service in exchange for a fee per barrel of produced water received.
+Added: (b) acreage dedications requiring the customer to deliver all volumes produced from the dedicated acreage with us;
+Added: and (c) produced water pipeline and trucked disposal agreements providing interruptible service in
+Added: exchange for a fee per barrel of produced water received.
We also generate revenue from the sale of crude oil we recover in processing the produced water.
−Removed: In addition, we may charge fees for the sale of produced water for reuse by our customers, pipeline transportation fees, pipeline interconnection fees and solids disposal fees.
+Added: In addition, we may charge fees for the sale of produced water for reuse and recycle by our customers, pipeline transportation fees, pipeline interconnection fees and solids disposal fees.
Our Water Solutions segment operates under the NGL Water Solutions trade name.
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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.
−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 Delaware Basin in Texas and New Mexico, the Eagle Ford Basin in Texas and the United States Gulf Coast.
+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 Permian 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.
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We currently transport crude oil on the Grand Mesa Pipeline, which is described above, and 19 other common carrier pipelines owned by third parties.
−Removed: As of May 29, 2025, all railcars have been sold or are under purchase and sale agreements.
We also own 25 pipeline injection stations, the locations of which are summarized below.
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Our Liquids Logistics segment conducts supply operations for natural gas liquids to commercial, retail and industrial customers across the United States and Canada.
−Removed: 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.
−Removed: 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.
+Added: These operations are conducted through our five owned terminals, third-party storage and terminal facilities, access to nine common carrier pipelines and a fleet of leased railcars.
+Added: We also provide services for marine exports of butane through our facility located in Chesapeake, Virginia and we also own a propane
+Added: pipeline in Michigan.
We attempt to reduce our exposure to price fluctuations by using back-to-back physical contracts and pre-sale agreements that allow us to lock in a margin on a percentage of our winter volumes.
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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, 2025, we sold approximately 1.6 billion gallons of natural gas liquids or 4.26 million gallons (approximately 101,000 barrels) per day.
+Added: During the year ended March 31, 2026, we sold approximately 1.2 billion gallons of natural gas liquids or 3.17 million gallons 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.
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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
−Removed: proximity to other refined products infrastructure along the Colonial pipeline.
+Added: The Port Hudson terminal is located near Baton Rouge, Louisiana, and is in 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.
The Chesapeake facility is a marine export/import terminal situated upstream of Norfolk, Virginia on the Elizabeth River.
−Removed: The site includes a proprietary dock with the capacity to berth handy-sized vessels (a dry bulk carrier of an oil tanker with a capacity between 15,000 and 35,000 dead weight tonnage) to very large gas carriers (a carrier capable of loading anywhere between 100,000 cubic meters to 200,000 cubic meters of natural gas), truck loading and off-road racks along with 22 railcar spots, with service provided by Norfolk Southern Railroad.
+Added: The site includes a proprietary dock with the capacity to berth handy-sized vessels (a dry bulk carrier of an oil tanker with a capacity between 15,000 and 35,000 dead weight tonnage) to very large gas carriers (a carrier capable of loading anywhere between 100,000 cubic meters to 200,000 cubic meters of natural gas), truck loading and off-road racks along with 22
+Added: railcar spots, with service provided by Norfolk Southern Railroad.
The facility has an aggregate storage capacity of 20,408,000 gallons.
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Mississippi 8,400,000 8,400,000 Pipeline and Rail Facility
−Removed: Utah 5,880,000 5,250,000 Rail Facility
Texas 210,000 210,000 Pipeline and Rail Facility
+Added: Utah — 5,880,000 Rail Facility
United States Total 19,110,000 24,990,000
Alberta, Canada 1,323,420 1,323,420 Pipeline and Rail Facility
−Removed: Ontario, Canada — 8,467,200 Rail Facility
Canada Total 1,323,420 1,323,420
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• informing decision-making regarding construction activities, such as where to locate and where not to locate a facility;
−Removed: e.g., locating construction activities away from sensitive environmental, cultural or historic areas, including wetlands, coastal regions or areas inhabited by endangered or threatened species, and limiting or prohibiting construction activities during certain sensitive periods, such as when threatened or endangered species are breeding/nesting;
+Added: e.g., locating construction activities away from sensitive environmental, cultural or historic areas,
+Added: including wetlands, coastal regions or areas inhabited by endangered or threatened species, and limiting or prohibiting construction activities during certain sensitive periods, such as when threatened or endangered species are breeding/nesting;
• informing decision-making regarding the timing of activities, for example, we will delay construction or system modification or upgrades during the issuance or renewal periods of certain permits;
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These wastes, instead, are regulated as solid waste under RCRA’s less stringent Subtitle D, state laws or other federal laws.
−Removed: It is possible, however, that certain wastes now classified as non-hazardous solid waste could be classified as hazardous wastes in the future and thereby be subject to more rigorous and costly disposal requirements.
+Added: It is possible, however, that certain wastes
+Added: now classified as non-hazardous solid waste could be classified as hazardous wastes in the future and thereby be subject to more rigorous and costly disposal requirements.
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.
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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
−Removed: 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 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.
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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 unless permitted to do so.
+Added: Certain state regulations and the general permits issued under the CWA’s National Pollutant Discharge Elimination System program prohibit the discharge of
+Added: 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.
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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 water from hydraulic fracturing operations.
+Added: Federal agencies, including the EPA and the United States Department of the Interior (“DOI”), 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.
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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
−Removed: 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 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.
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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.
−Removed: The designation of previously unidentified endangered or threatened species could indirectly cause us to incur additional costs, cause our or our oil and gas producing customers’ operations to become subject to operating restrictions or bans and limit future development activity in affected areas.
+Added: The designation of previously unidentified endangered or threatened species could indirectly
+Added: cause us to incur additional costs, cause our or our oil and gas producing customers’ operations to become subject to operating restrictions or bans and limit future development activity in affected areas.
The USFWS and similar state agencies may also designate critical or suitable habitat areas that they believe are necessary for the survival of threatened or endangered species.
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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).
+Added: These bills are currently subject to various legal challenges, and the outcomes of those challenges are uncertain.
+Added: In November 2025, the U.S.
+Added: Court of Appeals for the Ninth Circuit granted a motion for injunction as to the enforcement of SB 261;
+Added: however, a similar motion for injunction as to the enforcement of SB 253 was denied, meaning SB 253 and its initial reporting deadline in August 2026 currently remain unaffected.
+Added: Additionally, the New York State Department of Environmental Conservation established a mandatory GHG reporting program that requires certain emitters of GHG emission sources to annually report their emissions and related data.
+Added: These mandates could affect our business, and they are being routinely evaluated to determine applicability and relevant requirements.
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.
12 unchanged sentences
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.
+Added: In September 2025, the Eighth Circuit indicated that the case will be held in abeyance until such time that the SEC decides to reconsider the challenged rules by notice-and-comment rulemaking or renews its defense.
Some scientists have suggested climate change could increase the severity of extreme weather, such as increased hurricanes and floods, which could damage our facilities.
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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.