Exhibit (c)15
Citigroup Global Markets Inc. | Global Energy Group March 2019 Project Prairie Discussion Materials Strictly Private and Confidential
Proposed State / Local Regulations Proposed Regulation Impacted Area Potential TGE Exposure Description The Delaware River Basin Commission (“DRBC”) is a legislated regional body tasked to oversee the river system’s planning, Low—development and regulation for water resource management Litigation is ongoing and New York, Pennsylvania, New impacted area represents Due to concerns with water use and impact to water quality, the Delaware River Basin Fracking Ban Jersey, Delaware a small subset of DBRC has proposed a ban on hydraulic fracturing completion (Marcellus and Utica Shale Plays) Marcellus and Utica techniques for new wells drilled in the region resource areas Area landowners have responded by filing a lawsuit to block the proposed ban, claiming the DRBC lacks authority to block drilling Recent challenges to the Army Corps of Engineers’ environmental impact studies and permitting required for new pipeline projects Low—have impeded the approval and construction of new projects North Dakota Pipeline North Dakota DAPL placed (including Energy Transfer’s Dakota Access Pipeline (“DAPL”)) Environmental Impacts (Williston Basin)in-service May 2017 Aside from the impact to timing, subsequent reviews of these challenges have not resulted in material impacts to project scope Medium—Trans Mountain Pipeline Recent challenges to the thoroughness of government regulators’ project ison-hold; environmental impact studies, consultation with tribal stakeholders Canada Pipeline Environmental Canada however, there is potential and permitting of new pipeline projects have impeded the approval Impacts (Alberta and Williston Basins) for favorable impacts to and construction timing and actionability of new projects (including TGE supply/demand the Canadian government-owned Trans Mountain Pipeline) dynamics Without accepting liability, three oil companies recently settled with Low—plaintiffs in a class-action lawsuit claiming saltwater disposal well Risk of future litigation is operations led to earthquakes impacting Oklahoma communities mitigated by new operator Oklahoma protocols issued. Under new protocols issued by the Oklahoma state government in Oklahoma SWD Concerns (SCOOP, STACK, Woodford, and Oklahoma basins are not February 2018, operators are required to maintain access to a Anadarko Basin) currently a source of seismic array with real-time information on earthquakes. The rules production for TGE crude lower the threshold of earthquake magnitude for which an operator and natural gas must take action to mitigate, and require some operators to pause transportation operations the event of an earthquake of 2.5 magnitude Source: State and Local regulators. 1
Methane / Flaring Regulations Regulation Impacted Area Potential TGE Exposure Description In January 2016, the Department of the Interior instructed the Bureau of Land Management to insitutue new rules limiting the venting and flaring of natural gas Low—Federal Venting / Flaring Regulation United StatesPro-industry regulations In March 2017, federal executive order reversed these restrictive enacted regulations and empowered states to maintain standards for operators, citing “regulatory burdens that unnecessarily encumber energy production, constrain economic growth, and prevent job creation” Colorado: In early 2014, Colorado fully adopted the EPA’s standards for venting/flaring and became the fist state to regulate methane emissions from oil and gas drilling North Dakota: Producers are required to submit plans for capturing gas and are limited on the percentage of gas burned as waste; Low—additionally, visible emissions must not exceed 20% opacity State dependent, though State Venting / Flaring Regulation Subject to Individual State Laws federal precedent is Wyoming: Flaring must incorporate Best Available Control favorable Technology (“BACT”); flaring or venting must be reported monthly and include duration and total estimated volume of gas Pennsylvania: Operators must direct all pipeline-quality gas into a pipeline for sales; any gas not captured and put into the sales pipeline may not be vented and must be flared Source: Bureau of Land Management, Environmental Protection Agency, state regulators. 2
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