HALLADOR ENERGY CO

Except as set forth below, there have been no material changes to the Risk Factors disclosed in Part I, Item 1A,Risk Factors, of the Company's 2024 Form 10-K.

Our Electric and Coal Operations are subject to extensive and costly laws and regulations, and such current and future laws and regulations could increase current operating costs or limit our ability to produce coal.

In October 2025, the Company submitted an application for a National Pollutant Discharge Elimination System (“NPDES”) permit under the proposed U.S. Environmental Protection Agency’s ("EPA") Steam Electric Power Generating Effluent Guidelines ("ELG") Deadline Extensions Rule, published October 2, 2025. The proposed rule extends multiple compliance deadlines originally established by the 2024 ELG rule including deadlines for zero-discharge systems (e.g., flue gas desulfurization wastewater, bottom ash transport water, and combustion residual leachate) by five to six years (e.g., from December 31, 2029 to December 31, 2034) and includes new provisions for alternative applicability dates, transferability between compliance options and authorize alternative applicability dates based on site-specific considerations.

The Company’s permit application was approved November 7, 2025 and is consistent with the extended deadlines and flexibility provided by the proposed Deadline Extensions Rule. The rule is currently in the public comment stage, with comments due November 3, 2025, and has not yet been finalized.

If the finalized ruling does not include the extension of the compliance deadlines the Company would be unable to discharge under the current ELG rule and thus would be out of compliance with the Clean Water Act as of December 31, 2025**,** potentially subjecting it to enforcement actions, penalties, or required to implement alternative discharge controls immediately.