What changed in this filing

/stocks — the workspaceLOADING

Item 1. Business

2026-03-24 compared with 2025-03-20 · 84 added, 76 removed, 537 unchanged (23% of the section changed)

7 unchanged sentences

The Delaware Trustee has only minimal rights and duties as are necessary to satisfy the requirements of the Delaware Statutory Trust Act.

The Trustee does not maintain a website for filings by the Trust with the Securities and Exchange Commission (the “SEC”).

Electronic filings by the Trust with the SEC are available free of charge through the SEC’s website at www.sec.gov and at http://voc.q4web.com/home/default.aspx .

The Trust maintains a website at http://voc.q4web.com/home/default.aspx .

The Trust’s filings under the Exchange Act are available through its website and are also available electronically from the website maintained by the Securities and Exchange Commission (the “SEC”) at www.sec.gov .

On May 10, 2011, VOC Brazos and the Trust completed an initial public offering of units of beneficial interest in the Trust (the “Trust Units”).

125 unchanged sentences

These releases will be made only in connection with a sale by VOC Brazos to a non-affiliate of the relevant Underlying Properties and are conditioned upon the Trust receiving an amount equal to the fair value to the Trust of such net profits interest.

Any net sales proceeds paid to the Trust are distributable to Trust unitholders for the quarter in which they are received.

Any net sales proceeds paid to the Trust are distributed to the Trust unitholders for the quarter in which they are received.

As the designated operator of a property comprising the Underlying Properties, VOC Brazos may enter into farm-out, operating, participation and other similar agreements to develop the property.

121 unchanged sentences

Future Development Costs

Non-Producing

(dollars in thousands)

80% Net Profits Interest Net Operating Income (NPI) (1)

7 unchanged sentences

The price adjustments were based on oil price differentials forecast at −$4.50 per Bbl for all Kansas Underlying Properties.

For Texas properties, oil price differentials were applied at −$1.00 per Bbl for the Kurten (Woodbine) Field and Madisonville West Field wells, −$2.50 per Bbl for the Sand Flat Unit Field Wells and −$4.50 per Bbl for the Hitts Lake North Field wells.

For Texas properties, oil price differentials were applied at −$0.50 per Bbl for the Kurten (Woodbine) Field and Madisonville West Field wells, −$2.00 per Bbl for the Sand Flat Unit Field Wells and Hitts Lake North Field wells.

Oil price differentials were not escalated.

15 unchanged sentences

Producing Acreage and Well Counts

For the following data, “gross” refers to the total wells or acres in which VOC Brazos owns a working interest and “net” refers to gross wells or acres multiplied by the percentage working interest owned by VOC Brazos.

Although many of VOC Brazos’ wells produce both oil and natural gas, a well is categorized as an oil well or a natural gas well based upon the ratio of oil to natural gas production.

5 unchanged sentences

Operated Wells

The following is a summary of the number of developmental wells drilled by VOC Brazos on the Underlying Properties during the last three years.

VOC Brazos did not drill any exploratory wells during the periods presented.

Year Ended December 31,

Natural gas wells

Non-productive

In 2022, two wells were drilled and completed.

Total capital expenditures for these wells were $1,655,613.

In 2023, no wells were drilled and completed.

In 2024, no wells were drilled and completed.

VOC Brazos did not drill any developmental wells or exploratory wells on the Underlying Properties during the years ended December 31, 2023, 2024, and 2025.

VOC Brazos continues to develop further proved undeveloped reserves pursuant to its planned development and workover program.

23 unchanged sentences

As of December 31, 2025, proved reserves attributable to the portion of the Kansas Underlying Properties were approximately 1.7 MMBoe and were located in three primary areas:

Kansas Uplift, Western Kansas and South-Central Kansas.

Central Kansas Uplift, Western Kansas and South-Central Kansas.

As of December 31, 2025, the VOC Operators operated 97.6% of the total proved reserves attributable to the Kansas Underlying Properties based on PV-10 value.

The major fields in the Central Kansas Uplift include Fairport Field, Marcotte Field and Chase-Silica Field, all of which are producing primarily from the Arbuckle and Lansing Kansas City zones.

The major fields in Western Kansas include the Bindley, Griston SW and Rosa Northwest fields, which are producing primarily from the Mississippian, Morrow, Lansing Kansas City and Cherokee zones.

fields in Western Kansas include the Bindley, Griston SW and Rosa Northwest fields, which are producing primarily from the Mississippian, Morrow, Lansing Kansas City and Cherokee zones.

The major fields in South Central Kansas include the Gerberding, Spivey Grabs and Alford fields, which are producing primarily from the Mississippian, Simpson and Lansing Kansas City zones.

22 unchanged sentences

These sales to purchasers are under terms ranging from one month to six months, using market-sensitive pricing.

Five purchasers, including MV Purchasing, have been purchasing substantially all of the crude oil production, and a substantial portion of the crude oil production may continue to be acquired by one or more single purchasers.

For the years ended December 31, 2022, 2023 and 2024, MV Purchasing purchased 35%, for each year, of the production sold from the Underlying Properties.

Five purchasers, including MV Purchasing, have been purchasing substantially all of the crude oil production, and a substantial portion of the crude oil production

may continue to be acquired by one or more single purchasers.

For the years ended December 31, 2023, 2024 and 2025, MV Purchasing purchased 35%, 35% and 37%, respectively, of the production sold from the Underlying Properties.

VOC Brazos does not believe that loss of any of these parties as a purchaser would have a material adverse impact on the business of VOC Brazos, as substitute purchasers are generally available;

20 unchanged sentences

Any net sales proceeds paid to the Trust are distributable to Trust unitholders for the quarter in which they are received.

No Underlying Properties were sold, and therefore no

net sales proceeds were paid to the Trust for its share of interest in any such Underlying Properties, during 2023 or 2024.

Any net sales proceeds paid to the Trust are distributed to Trust unitholders for the quarter in which they are received.

No Underlying Properties were sold, and therefore no net sales proceeds were paid to the Trust for its share of interest in any such Underlying Properties, during 2024 or 2025.

VOC Brazos has not identified any of the Underlying Properties for sale as of December 31, 2025.

17 unchanged sentences

In a bankruptcy of VOC Brazos, creditors of VOC Brazos would be able to claim the net profits interest as an asset of the bankruptcy estate to satisfy obligations to them if the conveyance of the net profits interest did not constitute the conveyance of a real property interest or interests in hydrocarbons in place or to be produced under applicable state law or a production payment, in which case the Trust would be an unsecured creditor of VOC Brazos at risk of losing the entire value of the net profits interest to senior creditors.

VOC Brazos believes that its title to the Underlying Properties is, and the Trust’s title to the net profits interest is, good and defensible in accordance with standards generally accepted in the oil and gas industry, subject to such exceptions as are not so material to detract substantially from the use or value of such properties

or royalty interests.

Please see “Item 1A.

26 unchanged sentences

The transportation of oil in common carrier pipelines is subject to rate and access regulation.

The FERC regulates interstate oil pipeline transportation

rates under the Interstate Commerce Act.

The FERC regulates interstate oil pipeline transportation rates under the Interstate Commerce Act.

In general, interstate oil pipeline rates must be just and reasonable and may not be unduly discriminatory or confer any undue preference upon any shipper.

Rates generally are cost-based, although settlement rates agreed to by all shippers are permitted and market-based rates may be permitted in certain circumstances.

Rates generally

are cost-based, although settlement rates agreed to by all shippers are permitted and market-based rates may be permitted in certain circumstances.

Although the price at which VOC Brazos sells oil and natural gas is not currently subject to federal rate regulation and, for the most part, is not subject to state regulation, with regard to physical sales of natural gas and oil, VOC Brazos is required to observe anti-market manipulation laws and related regulations enforced by the FERC and/or the Commodity Futures Trading Commission and the Federal Trade Commission.

47 unchanged sentences

CWT facilities can either discharge treated water directly to surface waters or send it to a POTW.

In 2018, the EPA concluded a study of the treatment and discharge of oil and gas

wastewater that could lead to changes in requirements for discharge of produced water under federal regulations, including more stringent requirements or a prohibition on discharge of produced water from CWT facilities.

In 2018, the EPA concluded a study of the treatment and discharge of oil and gas wastewater that could lead to changes in requirements for discharge of produced water under federal regulations, including more stringent requirements or a prohibition on discharge of produced water from

CWT facilities.

Any restriction of disposal options for hydraulic fracturing waste and other changes to CWA discharge requirements may result in increased costs.

3 unchanged sentences

In some instances, this process could result in a delay in issuance of the permit, more stringent permit requirements, or denial of the permit.

How the EPA and the USACE define “waters of the United States” (“WOTUS”), which defines the extent of geographic jurisdiction under the CWA, can impact VOC Brazos’ regulatory and permitting obligations under the CWA.

In 2023, the EPA and the USACE issued a final rule (the “2023 rule”) that is described by the EPA and the USACE as following the 1986 regulations as modified by subsequent U.S.

Supreme Court decisions and guidance issued by the EPA and USACE interpreting the decisions.

Shortly thereafter, the Supreme Court issued its decision in Sackett II which overturned a substantial portion of the basis for the 2023 rule.

The USACE and the EPA subsequently amended the 2023 rule and excluded a number of types of wetlands and streams from CWA jurisdiction, but the rule is subject to litigation regarding the sufficiency of the agencies’ interpretation of the Sackett II decision.

The 2023 rule is presently in effect in about half of the states while it is enjoined in the other half.

In those states where the rule is enjoined, the EPA and the USACE define WOTUS in accordance with an earlier regulatory definition adjusted in light of the Supreme Court’s Sackett II decision.

How the EPA and the USACE define “waters of the United States” (“WOTUS”), which defines the extent of geographic jurisdiction under the CWA, has been the subject of controversy and litigation for decades and can impact VOC Brazos’ regulatory and permitting obligations under the CWA.

In 2023, in Sackett v.

EPA , the Supreme Court issued a landmark decision interpreting WOTUS more narrowly than the then-current definition contemplated, resulting in diminished jurisdiction over wetlands and streams that lacked certain connections to other waters or consistent water flow.

Following Sackett , because of ongoing litigation, the regulatory landscape currently remains unsettled.

The regulations currently in effect in 24 states define WOTUS using a 2023 regulation modified after the Sackett decision.

In the rest of the country, the agencies base jurisdiction on an earlier WOTUS definition as implemented in light of a number of Supreme Court decisions, including Sackett .

Despite the two approaches, jurisdiction over WOTUS is essentially consistent across the United States.

In November 2025, the USACE released a proposed rule revising the regulatory definition of WOTUS.

That new definition is expected to go into effect in early 2026 without substantial changes from the proposed definition.

Regardless of the ultimate details, the revised definition likely will further reduce CWA jurisdiction, especially over wetlands and streams, leading to fewer permitting requirements.

Once the new WOTUS definition is final, litigation will likely continue challenging the legality of the definition.

This litigation could have the effect of delaying or precluding implementation of the new rule.

VOC Brazos’ regulatory obligations and permitting costs will continue to be subject to remaining uncertainty around the definition of WOTUS and the scope of CWA regulation, given the ongoing litigation.

1 unchanged sentence

Some NWPs are also used to authorize activities that impact traditional navigable waters under the Rivers and Harbors Act.

NWP 12 will expire in March 2026 and be replaced with a new version.

In addition, a federal court in Washington, D.C.

is currently hearing a challenge to NWP 12.

An adverse decision in the litigation may restrict or remove the ability to use NWP 12 to permit regulated impacts, resulting in the need to apply for a more time-consuming individual permit.

This could result in additional cost and time for permitting projects.

The NWPs expire in March 2026 and will be replaced, simultaneously, with new versions that are largely unchanged from the previous set.

Litigation challenging the NWPs, if filed, could result in additional cost and time for permitting projects.

In February 2025, the USACE began implementing emergency permitting procedures as directed by President Trump’s Executive Order Declaring a National Energy Emergency.

This may result in substantially decreased timeframes for receiving Section 404 permits in the case of energy projects subject to the Executive Order.

This has resulted, in many instances, in substantially decreased timeframes for receiving Section 404 permits in the case of energy projects subject to the Executive Order.

The Oil Pollution Act of 1990, as amended (“OPA”), which amends the CWA, establishes standards for prevention, containment and cleanup of oil spills into waters of the United States.

7 unchanged sentences

It is customary to recover oil and natural gas from deep shale and tight sand formations through the use of hydraulic fracturing, combined with sophisticated horizontal drilling.

Hydraulic fracturing involves the injection of water, sand and chemical additives under pressure into rock formations to stimulate gas production.

The federal Energy Policy Act of 2005 amended the Underground Injection Control provisions

of the federal Safe Drinking Water Act to exclude certain hydraulic fracturing activities from the definition of “underground injection.” At present, hydraulic fracturing is regulated at the state and local level.

Hydraulic fracturing involves

the injection of water, sand and chemical additives under pressure into rock formations to stimulate gas production.

The federal Energy Policy Act of 2005 amended the Underground Injection Control provisions of the federal Safe Drinking Water Act to exclude certain hydraulic fracturing activities from the definition of “underground injection.” At present, hydraulic fracturing is regulated at the state and local level.

Due to public concerns raised regarding potential impacts of hydraulic fracturing on groundwater quality, legislative and regulatory efforts at the federal, state and local level and in some states have been initiated to require or make more stringent the permitting and compliance requirements for hydraulic fracturing operations.

16 unchanged sentences

The existing source emissions guidelines are to be implemented through state plans, with expected compliance dates for existing sources arriving in 2029.

The results of the 2024 presidential election and President Trump’s energy agenda prioritizing domestic oil and gas production likely will impact the air quality-related requirements that apply to VOC Brazos.

In March 2025, the EPA announced it was reconsidering the 2024 rules that established new volatile organic compound and methane emissions standards for both new and existing sources.

Following that announcement, the EPA adopted amendments to the NSPS and existing source performance standards that extended the compliance deadlines for many of the new source requirements adopted in 2024 and extended the state plan submittal deadlines, which will effectively extend the dates by which existing sources must come into compliance with the existing source emissions guidelines.

It is currently unknown whether the EPA’s reconsideration of the 2024 rules will result in further changes.

Similar to prior changes to the air pollution control standards for oil and gas sources, the most recent changes will be subject to judicial review, as well as the potential for future presidential administrations to take a different approach.

The EPA is also charged with establishing National Ambient Air Quality Standards (“NAAQS”), the implementation of which can indirectly impact VOC Brazos’ operations.

2 unchanged sentences

In December 2020, the EPA published a final rule that retained without revision the 2015 NAAQS ozone standard.

More recently, however, in February 2024, the EPA announced a final rule that will lower the annual standard for fine particulate matter from 12 micrograms per cubic meter to 9 micrograms per cubic meter.

Likewise, in March 2024, the EPA issued a final rule that lowered the annual standard for fine particulate matter from 12 to 9 micrograms per cubic meter.

In March 2025, however, the EPA announced that it would reconsider the rule lowering the fine particulate matter standard, and the EPA has filed a request that the U.S.

Court of Appeals vacate the 2024 rule.

In 2026, the EPA also has delayed taking certain actions necessary to implement air quality requirements under the lower 2024 standard.

No regulatory action or court decision has changed the 2024 rule lowering the fine particulate matter standard, and the EPA’s delayed implementation of the 2024 standard likely will be subject to judicial review.

State or federal implementation of the NAAQS could result in stricter permitting or regulatory requirements, delay or prohibit VOC Brazos’ ability to obtain such permits, and result in increased expenditures for pollution control equipment.

The 2024 presidential election in the United States may impact the air quality-related requirements that apply to VOC Brazos.

The Trump Administration may adopt a different approach to many actions taken

under the prior presidential administration, including the 2024 revisions to the emissions standards and guidelines for new and existing sources in the oil and gas industry, as well as the 2024 changes to the NAAQS for fine particulate matter.

The outcome of the Trump Administration’s evaluation of the prior administration’s regulatory approach is not certain at this time, but President Trump has made it clear that his energy agenda prioritizes an increase in domestic oil and gas production.

VOC Brazos may be required to incur certain capital expenditures for air pollution control equipment or other air emissions-related issues., VOC Brazos currently does not expect that such requirements will have a material adverse effect on its operations.

VOC Brazos may be required to incur certain capital expenditures for air pollution control equipment or other air emissions-related issues.

VOC Brazos currently does not expect that such requirements will have a material adverse effect on its operations.

Climate Change.

In response to its 2009 finding that emissions of carbon dioxide, methane and other greenhouse gases (“GHGs”) may present an endangerment to public health and the environment, the EPA has issued regulations to restrict emissions of greenhouse gases under existing provisions of the CAA.

The Trump Administration’s efforts to roll back federal regulation of greenhouse gases (“GHGs”) represent a significant shift in federal climate policy, though the ultimate impact of those efforts on VOC Brazos is unclear.

In 2009, the EPA found that emissions of carbon dioxide, methane and GHGs may present an endangerment to public health and the environment and subsequently issued regulations to restrict emissions of greenhouse gases under existing provisions of the CAA.

These regulations include limits on tailpipe emissions from motor vehicles, preconstruction and operating permit requirements for certain large stationary sources, and methane emissions standards for certain new, modified and reconstructed oil and gas sources — as well as the EPA’s methane emissions guidelines for existing oil and gas sources that were adopted in 2024.

The EPA also has adopted rules requiring the reporting of GHG emissions from specified large greenhouse gas emission sources in the United States, as well as certain onshore oil and natural gas production facilities, on an annual basis.

Shortly after President Trump took office in January 2025, the federal government embarked on a series of changes relating to climate policy and regulation.

On January 20, 2025, President Trump announced the withdrawal of the United States from the Paris Climate Agreement.

President Trump also issued an executive order directing the EPA to review the legality and continuing applicability of its 2009 GHG endangerment finding.

The outcome of that review is not currently known;

however, it has the potential to eliminate the basis for the EPA’s regulation of GHGs under the CAA.

The EPA has established GHG standards for oil and gas sources based on the GHG endangerment finding.

In 2024, the EPA adopted a final rule that will directly regulate volatile organic compound and methane emissions from new oil and gas sources and will require reductions in GHG and volatile organic compound emissions through its regulation of flaring, compressors, pumps, storage vessels, process controllers, well completions and liquids unloading, and equipment leaks.

In July 2025, the EPA issued a proposed rule to rescind the 2009 GHG endangerment finding that provided a basis for GHG regulation under the CAA.

In September 2025, the EPA proposed to rescind the GHG reporting program for sectors other than the oil and gas sector, while proposing to suspend GHG reporting requirements for the oil and gas sector until 2034.

In February 2026, the EPA adopted a final rule repealing its prior endangerment finding, which opens the door for the EPA to repeal its GHG rules for the oil and gas sector.

The EPA has established methane standards for oil and gas sources based on the now-repealed GHG endangerment finding.

In 2024, the EPA adopted a final rule that will directly regulate volatile organic compound and methane emissions from new oil and gas sources and will require reductions in methane and volatile organic compound emissions through its regulation of flaring, compressors, pumps, storage vessels, process controllers, well completions and liquids unloading, and equipment leaks.

At the same time, the EPA adopted emissions guidelines that will apply to existing oil and gas sources and that require reductions in volatile organic compound and methane emissions that are largely equivalent to the requirements for new sources.

The existing source emissions guidelines are to be implemented through state plans, with expected compliance dates for existing sources arriving in 2029.

The existing source emissions guidelines are to be implemented through state plans, with expected compliance dates arriving in 2029.

In 2025, however, the EPA extended certain compliance deadlines for both new and existing sources, and the 2026 endangerment finding repeal provides a basis for undoing the oil and gas methane standards — though the fact that the oil and gas standards address both methane and volatile organic compounds, which are regulated independently of the EPA’s authority to regulate GHGs, may limit the impact of future changes to the methane standards that currently apply to oil and gas sources.

The Inflation Reduction Act of 2002 (the “IRA”) included new Clean Air Act section 136(c) directing the EPA to collect the Waste Emissions Charge (“WEC”) from facilities in the oil and gas sector that report more than 25,000 tons of carbon dioxide equivalent emissions in a calendar year.

The charge will first apply to methane emissions from calendar year 2024.

The charge will first

apply to methane emissions from calendar year 2024.

The charge is determined by comparing actual reported methane emissions to statutorily established “methane intensity figures” that are based on gas production or throughput, with a charge assessed for every ton of methane emissions that exceeds the facility’s allowable emissions based on the applicable methane intensity figure.

3 unchanged sentences

however, the fate of the WEC and the EPA rules implementing the WEC is unclear.

In February 2025, the United States House of Representatives and Senate both passed resolutions to repeal the EPA’s 2024 WEC rules under the Congressional Review Act (“CRA”), and on March 14, 2025 President Trump signed the resolution repealing those rules under the CRA.

In addition, the United States House of Representatives and Senate may be considering amendment or repeal of certain portions of the IRA, including the statutory provisions establishing the WEC.

In addition to the federal actions, more than one third of the states have begun taking actions to control and/or reduce emissions of GHGs, primarily through the planned development of GHG emission inventories and/or regional GHG cap and trade programs.

In March 2025, President Trump signed legislation repealing the EPA’s 2024 WEC rules under the Congressional Review Act.

The repeal of EPA’s WEC rules did not eliminate the statutory requirement to pay the WEC, but it eliminated the rules established by the EPA to determine the WEC due, the payment mechanism, and any payment deadlines.

Congress may be considering amendment or repeal of certain portions of the IRA, including the statutory provisions establishing the WEC.

Meanwhile, more than one third of the states have begun taking actions to control and/or reduce emissions of GHGs, primarily through the planned development of GHG emission inventories and/or regional GHG cap and trade programs.

Although most of the state level initiatives to date have focused on large sources of GHG emissions, such as coal fired electric plants, it is possible that smaller sources of emissions could become subject to GHG emission limitations or allowance purchase requirements in the future.

For example, the states of Colorado and New Mexico have adopted rules

regulating GHGs from the oil and gas industry that are based on the federal standards.

For example, the states of Colorado and New Mexico have adopted rules regulating GHGs from the oil and gas industry that are based on the federal standards.

Congress may in the future consider adopting other legislation to reduce emissions of greenhouse gases.

12 unchanged sentences

Under the ESA, federal agencies are obligated to consult with the U.S.

Fish and Wildlife Service or National Marine Fisheries Service if an agency’s actions, including permit actions, may affect listed species or designated critical habitat.

Fish and Wildlife Service or National Marine Fisheries Service (the “Services”) if an agency’s actions, including permit actions, may affect listed species or designated critical habitat.

If endangered species are located in areas of the Underlying Properties where seismic surveys, development activities or abandonment operations may be conducted, the work could be prohibited or delayed or expensive mitigation may be required, depending on the implications for protected species and designated critical habitat.

On August 27, 2019, the U.S.

Fish and Wildlife Service published a final rule adopting several changes to the federal regulations that implement the ESA, including changes to the procedures and criteria for listing or removing species from the Lists of Endangered and Threatened Wildlife and Plants and for designating critical habitat.

The Biden Administration rescinded one of the rules adopted by the prior administration, dealing with critical habitat, and issued a revised rule making changes to the federal consultation process.

These changes could make a federal review process occasioned by the application for permits, rights of way, or leases more complex in certain circumstances.

Changes to implementing rules in the Biden Administration may, in some instances, make a federal review process occasioned by the application for permits, rights of way, or leases more complex in certain

circumstances.

In addition, designation of new species as threatened or endangered could cause VOC Brazos to incur additional costs arising from species protection measures, could result in limitations on activities, and could require a more complex regulatory compliance process.

However, in 2025, the Services issued proposed revisions to the regulations implementing the ESA Section 7 consultation process and the scope of the definition of the term “take.” These regulations, if finalized, generally would be deregulatory in nature, modestly reducing the coverage of the ESA and streamlining the ESA section 7 consultation process.

Nevertheless, these rules are expected to be immediately challenged in litigation, which will create uncertainty as to if and when these rules will go into effect.

In January 2025, the Trump Administration directed the use of the emergency consultation procedures for permitting for energy projects in the Declaring a National Energy Emergency Executive Order.

1 unchanged sentence

The National Environmental Policy Act (“NEPA”) requires the federal government to undertake an environmental review prior to making a decision on most proposed federal actions — such as permits, leases, and rights-of-way.

Until 2025, agencies undertook NEPA reviews pursuant to binding regulations issued by the White House Council on Environmental Quality (“CEQ”) as well as pursuant to the federal agency’s own NEPA procedures.

CEQ issued its rules after being directed to do so by an Executive Order issued in the Carter Administration.

After two federal courts held that CEQ did not have authority to issue binding regulations, the Trump Administration revoked the Carter Administration Executive Order and directed CEQ to withdraw the regulations.

In their place, agencies are directed to develop procedures that hew to the statutory text over the course of 2025 with the goal of having them finalized in early 2026.

In the meantime, agencies will continue to use their own NEPA procedures and may

continue to follow the CEQ regulations, using them as guidance.

This may result in delays and uncertainty in permitting reviews as agencies adjust to a new NEPA approach.

Driven by court decisions and Administration policy, NEPA implementation and resulting litigation changed dramatically in 2025.

Key changes are driving agencies narrow their NEPA reviews and complete them faster and are driving courts to show more deference to agencies when reviewing the adequacy of an agency’s analysis under NEPA, benefitting private projects that may require federal permits and reviews.

In particular, until 2025, agencies undertook NEPA reviews pursuant to binding regulations issued by the White House Council on Environmental Quality (“CEQ”) as well as pursuant to the federal agency’s own NEPA procedures.

After two federal courts found that CEQ did not have authority to issue binding regulations, CEQ withdrew their regulations.

In their place, agencies each issued their own NEPA procedures and, for the most part, put those procedures in agency guidance rather than binding regulations, although the USACE (which issues permits that can be critical to construction) regulatory program is a notable exception, keeping its NEPA procedures in regulations.

While the agency procedures were based on a CEQ template, there are inconsistencies among the agencies on various topics, including the requirement for public comment and consideration of various types of impacts.

These procedures make changes that are intended to streamline reviews.

Also, on May 29, 2025, the Supreme Court decided Seven County Infrastructure Coalition v.

Eagle County, Colorado , in which the Court expressed clear intention that NEPA should be brought “back in line with the statutory text and common sense.” Significantly for permits that may be needed for private projects, the Court clarified that agencies need only evaluate the effects of the specific “proposed action” before them, not the impacts of “other future or geographically separate projects that may be built (or extended) as a result of or in the wake of the immediate project under consideration.” The Court also emphasized that courts must afford agencies substantial deference in reviewing agency actions under NEPA and that agencies “must have broad latitude to draw a ‘manageable line’” when determining the appropriate scope of analysis.

The Court’s decision may reduce litigation risk and help streamline federal reviews.

Employee Health and Safety.

The operations of VOC Brazos are subject to a number of federal and state laws and regulations, including the federal Occupational Safety and Health Act, or “OSHA,” and comparable state statutes, whose purpose is to protect the health and safety of workers.

The operations of VOC Brazos are subject to a number of federal and state laws and regulations, including the federal Occupational Safety and Health Act (“OSHA”) and comparable state statutes, whose purpose is to protect the health and safety of workers.

In addition, the OSHA hazard communication standard, the EPA community right-to-know regulations under Title III of the federal Superfund Amendment and Reauthorization Act and comparable state statutes require in certain circumstances that information be maintained concerning hazardous materials used or produced in VOC Brazos’ operations and that this information be provided to employees, state and local government authorities and citizens.

2 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.

What changed 10-K

Item 1. Business