71 added · 53 removed between the two most recent 10-Ks. The risks a company starts — or stops — disclosing are often the story.
Newly disclosed
In May 2025, CEQ also withdrew its January 2023 interim guidance to federal agencies regarding consideration of the effects of GHG emissions and climate change when conducting environmental reviews pursuant to NEPA.
Also in February 2025, CEQ issued a memorandum to federal agencies and departments providing guidance to agencies establishing or revising their agency-specific NEPA implementing procedures.
Court of Appeals for the Eighth Circuit granted the BLM an initial 60-day stay of the litigation in February 2025, and the case continues to be held in abeyance.
The guidance document was updated and replaced by a subsequent memorandum issued by CEQ in September 2025.
We own an equity method investment in MVP C, which was formed on November 1, 2025 for the purpose of constructing and owning certain assets associated with the MVP Boost project, a contemplated project to add compression to MVP Mainline, which is projected to increase the capacity on MVP Mainline by 0.6 Bcf per day (MVP Boost).
As designed, MVP Boost would add compression at three existing compressor stations in West Virginia and construct a new compressor station in Virginia. 18 Table of Contents On October 23, 2025, the MVP Joint Venture applied to the FERC for authorization to construct MVP Boost.
In November 2025, the FERC declined to readopt the lower rate established by the January 2022 order on rehearing and withdrew its October 2024 supplemental notice of proposed rulemaking, effectively setting the five-year index level for 2021 through 2026 at the level initially established in 2021.
In November 2021, the EPA announced a proposed rule expanding upon its New Source Performance Standards (NSPS) rule in Subpart OOOOa, establishing standards for methane and volatile organic compounds from new and modified oil and natural gas production and natural gas processing and transmission facilities.
Following this decision, in July 2025, a number of federal agencies, including the Department of the Interior, the Department of Transportation, the Corps and the Department of Energy, revised their NEPA implementing regulations and issued interim final rules.
In March 2025, a Joint Resolution of Disapproval under the Congressional Review Act disapproved implementing the waste emissions charge, and in July 2025, the OBBBA rescinded unobligated funds from the Methane Emissions Reduction Program and postponed the EPA's imposition of the program's waste emissions charge to calendar year 2034. 27 Table of Contents In May 2024, the EPA finalized revisions to the Greenhouse Gas Reporting Program for petroleum and natural gas systems (Subpart W).
However, in September 2025, the EPA proposed to permanently remove program obligations from the Greenhouse Gas Reporting Program for most source categories and suspend program obligations for some sources subject to Subpart W until 2034.
Mega Rule Part II, which was finalized in November 2021 and went into effect on May 16, 2022, extends existing design, operational and maintenance, and reporting requirements to onshore natural gas gathering pipelines in rural areas.
No longer disclosed
In November 2021, the EPA announced a proposed rule expanding upon its New Source Performance Standards (NSPS) rule in Subpart OOOOa, establishing standards for methane and volatile organic compounds (VOCs) from new and modified oil and natural gas production and natural gas processing and transmission facilities which would establish standards for existing wells, impose more frequent and stringent leak monitoring, and mandate that all pneumatic controllers have zero emissions, among other requirements.
In August 2024, the European Union adopted a regulation to track and reduce methane emissions in the energy sector, including requiring new monitoring, reporting and verification measures to be applied by exporters to the European Union by January 1, 2027 and "maximum methane intensity values" must be met by 2030 and every year thereafter.
Additionally, at COP28, nearly 200 countries, including the United States, agreed to transition away from fossil fuels while accelerating action in this decade to achieve net zero by 2050 and entered into an agreement that calls for actions towards achieving, at a global scale, a tripling of renewable energy capacity and doubling energy efficiency improvements by 2030.
However, in January 2025, President Trump issued an executive order directing immediate notice to the United Nations of the United States’ withdrawal from the Paris Agreement and all other agreements made under the United Nations Framework Convention on Climate Change.
In October 2021, the Department of the Interior issued an advance notice of proposed rulemaking seeking comment on the Department's plan to develop regulations that authorize incidental taking under certain prescribed conditions.
In addition, in September 2021, the Biden Administration publicly announced the Global Methane Pledge, a pact that aims to reduce global methane emissions to at least 30% below 2020 levels by 2030.
The waste emissions charge imposed under the program for 2024 is $900 per ton emitted over the annual methane emissions threshold, and will increase to $1,200 in 2025, and $1,500 in 2026.
MVP Southgate is estimated to have a total cost of approximately $370 million to $430 million, excluding allowance for funds used during construction (AFUDC) and certain costs incurred for purposes of the originally certificated project (see Note 11 to the Consolidated Financial Statements for further details), of which we will fund our proportionate share through capital contributions to the MVP Joint Venture (defined in Note 11 to the Consolidated Financial Statements). 17 Table of Contents Seasonality Generally, but not always, the demand for natural gas (including the demand for its gathering, transmission or storage) decreases during the summer months and increases during the winter months.
For petroleum and natural gas production facilities, the threshold is methane emissions in excess of 0.2% of the natural gas sent to sale from the facility or 10 metric tons of methane per million barrels of oil sent to sale from facility if the facility sends no natural gas to sale.
Pursuant to the terms of the Paris Agreement, the Biden Administration announced goals aimed at reducing the U.S.'s GHG emissions by 50 to 52% (compared to 2005 levels) by 2030.
Certain of California's climate disclosure rules took effect in January 2025, with the disclosure of Scope 1 and 2 GHG emissions data scheduled to take effect beginning in 2026.
As a result of these risks, we are also sometimes a defendant in legal proceedings and litigation arising in the ordinary course of business.