Energy Transfer LP

For information regarding legal proceedings, see our Annual Report on Form 10-K filed with the SEC on February 19, 2026 and Note 10 in “Item 1. Financial Statements” in this Quarterly Report on Form 10-Q for the quarter ended March 31, 2026.

Additionally, we have received notices of violations and potential fines under various federal, state and local provisions relating to the discharge of materials into the environment or protection of the environment. While we believe that even if any one or more of the following environmental proceedings were decided against us, it would not be material to our financial position, results of operations or cash flows, we are required to report environmental governmental proceedings if we reasonably believe that such proceedings reasonably could result in monetary sanctions in excess of $1 million (previously $0.3 million).

On February 3, 2022, the State of New Mexico, ex rel. Hector Balderas, Attorney General filed a complaint against ETO, Transwestern, Kinder Morgan, Inc., El Paso Natural Gas L.L.C. and Northwest Pipeline, LLC in Cause No. D-101-CV-2022-00174 in the First Judicial District Court, County of Santa Fe, State of New Mexico, seeking to recover statewide damages for contamination with PCBs used for decades by the oil and gas industry in the operation and maintenance of pipeline infrastructure. The complaint alleged discharge or release of PCBs into the natural environment from compressor stations in connection with the operation of Transwestern. The State sought damages in the range of $50 million to $60 million plus attorneys’ fees from Transwestern. The parties agreed to a settlement in September 2025. The parties executed a settlement agreement in February 2026 and dismissed the case.

On June 15, 2023, PHMSA issued a Notice of Probable Violation, Proposed Civil Penalty, and Proposed Compliance Order (collectively “NOPV”), CPF 4-2023-011-NOPV, identifying three probable violations with compliance order actions associated with two of them and civil penalties proposed in an amount totaling approximately $2 million. The NOPV related to a PHMSA Accident Investigation Division investigation of a pigging incident which occurred on March 26, 2020 at the Partnership’s Borcher Station in Kansas and resulted in a fatality. The Partnership challenged PHMSA’s alleged violations and related civil penalties and compliance order actions contained in the NOPV. After an administrative hearing, which was held on April 24, 2024 before a PHMSA Presiding Official, the PHMSA Southwest Region recommended to remain relatively firm on the NOPV, only slightly reducing the civil penalty by approximately $19 thousand. The Partnership challenged the PHMSA administrative process in federal court, alleging among other things that PHMSA’s in-house administrative enforcement process was unconstitutional. In response, PHMSA has withdrawn the NOPV, terminated its in-house administrative action, and elected to file an enforcement action in federal court. The Partnership paid approximately $1.4 million and settled the case on December 31, 2025. The Court terminated the case on January 12, 2026.

On October 13, 2023, Mid Valley received a Notice of Proposed Safety Order (“NOPSO”) from the PHMSA related to various historical accidents and complaints reported to PHMSA on the Mid Valley system. The NOPSO requests that Mid Valley perform several proposed corrective measures within six months of receipt of a Safety Order; however, in response, Mid Valley requested that PHMSA engage in informal consultations prior to issuing a Safety Order in an effort for the parties to potentially enter into a Consent Agreement and Order. Informal consultation is underway. In the event a Consent Agreement and Order is not reached between the parties during this process, Mid Valley may request a Hearing on the NOPSO. The informal consultation process has concluded with PHMSA and Mid Valley reaching agreement on the Corrective Measures. PHMSA issued the Consent Agreement which was signed by Mid Valley on March 21, 2025. The fully executed version of the Consent Agreement was received by Mid Valley on April 24, 2025. All items required by the Consent Agreement have been completed and documentation, including the bi-annual report on the internal corrosion control program, submitted to PHMSA for review. Mid Valley met with PHMSA over the week of April 6, 2026 in the ETC Houston office to review records related to the Consent Agreement and are planning field inspections in the second quarter and the third quarter of 2026 to verify actions. Mid Valley is anticipating closure of the Consent Agreement in the third quarter of 2026.

On January 31, 2025, a release of refined products was discovered from the 14-inch Twin Oaks to Newark Pipeline in Upper Makefield Township, Bucks County, Pennsylvania. The release allegedly impacted certain properties and water wells near the release location. On February 13, 2025, SPLP voluntarily entered into the Pennsylvania remediation program through a Notice of Intent to Remediate, which was revised on March 4, 2025. On March 6, 2025, the Pennsylvania Department of Environmental Protection issued an Administrative Order directing that SPLP conduct the remediation. On May 2, 2025, PHMSA entered a Consent Order, adopting an agreement SPLP entered into with PHMSA on April 30, 2025. Finally, on April 9, 2025, SPLP was advised that the Bucks County District Attorney’s Office has referred the matter to the Pennsylvania Attorney General’s Office, Environmental Crimes Unit. The Attorney General’s Office has accepted the referral and opened an investigation, and on December 19, 2025, a Pennsylvania Statewide Investigating Grand Jury issued a subpoena requesting materials relating to the release. Potential charges, penalties or damages are not known at this time. PHMSA issued a Warning Letter to the Partnership on September 11, 2025 alleging certain violations of the Consent Order but stating that it would not conduct additional enforcement action at this time. In addition, certain property owners near the release location have filed individual civil suits and a class action in Philadelphia County Court, 1st Judicial District of Pennsylvania, against SPLP,

Energy Transfer and Energy Transfer R&M, alleging damages for lost property values, nuisance, remediation costs and other tort damages relating to the release. The class action was removed to federal court. We cannot predict the ultimate outcome of this litigation or the amount of time and expense that will be required to resolve it.