COMSTOCK RESOURCES INC (CRK) Business
This page reproduces the company's own Item 1 Business text from the linked SEC filing. It is filer text, not grepcent analysis, scoring, or investment advice.
Informational only - not investment advice. See Disclaimer.
ITEM 1. BUSINESS
We are a leading independent natural gas producer operating primarily in the Haynesville shale, a premier natural gas basin located in North Louisiana and East Texas with superior economics given its geographical proximity to the Gulf Coast natural gas markets. As of December 31, 2025, substantially all of our proved natural gas and oil reserves were in the Haynesville and Bossier shale plays. We are focused on creating value through the development of our substantial inventory of highly economic drilling opportunities in the Haynesville and Bossier shales and through our exploration activities in our Western Haynesville play. Our common stock is listed and traded on the New York Stock Exchange and New York Stock Exchange Texas under the symbol "CRK".
Our operations are concentrated in Louisiana and Texas. Our natural gas and oil properties are estimated to have proved reserves of 7.0 Tcfe with a PV 10 Value of $4.5 billion as of December 31, 2025 based on SEC prices. Our proved reserves are principally natural gas, which were 41% developed as of December 31, 2025 with an average reserve life of approximately 16 years. Using NYMEX futures market natural gas and oil prices as of December 31, 2025, proved reserves are estimated at 7.2 Tcfe with a PV 10 Value of $5.2 billion. Using these prices, our proved reserves were 40% developed as of December 31, 2025, with an average reserve life of approximately 16 years.
Strengths
High Quality Properties. As of December 31, 2025, we have 1,069,991 acres (802,769 net) prospective for the Haynesville and Bossier shale plays, located in North Louisiana and East Texas, including our extension of the plays in our Western Haynesville area. Our Haynesville/Bossier shale properties have extensive development and exploration potential. Advances in drilling and completion technology have allowed us to increase the reserves recovered through drilling longer horizontal lateral lengths, drilling horseshoe wells and applying substantially improved well stimulations, as well as successfully drilling horizontal wells in our deeper Western Haynesville extension of the Haynesville and Bossier Shale plays. As a result of the improved economic returns, we have focused our development activities primarily on drilling Haynesville and Bossier horizontal wells since 2015.
Our Haynesville and Bossier shale acreage is located in one of the premier North American natural gas basins and has access to the growing natural gas demand in the Gulf Coast markets related to LNG exports, expansion of power generation for data centers and the petrochemical industry due to its geographic proximity. We believe we are well positioned for future growth due to the following:
•
Premier natural gas resource. The Haynesville and Bossier shales in our legacy area have been substantially delineated since commercial operations started in 2008 and the consistent and successful results of our first 30 wells in our Western Haynesville area indicate substantial upside to our extension of the Haynesville and Bossier shale plays. We believe that these shale plays represent some of the most economic natural gas drilling opportunities in North America.
•
Management and operating team with extensive experience in developing the Haynesville and Bossier shales. We were among the first exploration and production companies to effectively apply horizontal drilling techniques in the Haynesville and Bossier shales beginning in 2007. In 2015, we restarted a drilling program in the Haynesville and Bossier shales utilizing enhanced completion well designs that have significantly improved the economics of these wells. In 2022, we started exploratory drilling in the Western Haynesville area and now have 30 successful wells turned to sales through the end of 2025. We have also drilled some of the longest lateral wells in the basin. We successfully drilled 41 wells with laterals of 15,000 feet or greater from 2021 through 2025. We were one of the first operators in the Haynesville shale to drill a horseshoe lateral well, which allows us to replace two short lateral wells with one drilling location with a longer lateral length resulting in a higher economic return.
•
Attractive economic returns. The Haynesville and Bossier shales offer highly economic drilling opportunities through application of advanced drilling and completion technologies, including the use of longer laterals, horseshoe laterals and high intensity fracture stimulation using tighter frac stages and higher proppant loading. Our Western Haynesville wells are some of the deepest horizontal wells in a high pressure and high temperature shale in the industry. Our management and operating teams are instrumental in developing and optimizing some of the most effective completion techniques in the Haynesville and Bossier shales and such completion techniques have resulted in a substantial improvement in initial production rates and recoverable reserves, which has resulted in some of the highest single well rates of return when compared to results from other natural gas basins in North America.
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•
Proximity to premium natural gas markets. Our natural gas production benefits from the strong regional Gulf Coast demand growth driven by a substantial increase in LNG exports, exports to Mexico and new or expanded petrochemical facilities. Producers, such as us, with access to the Gulf Coast natural gas markets are receiving higher net realized prices than most producers in other regions. We are also able to realize higher margins due to our ability to access an extensive midstream infrastructure with lower cost, flexible gas marketing arrangements. In addition, our access to natural gas storage allows for greater operational flexibility as well as the ability to take advantage of seasonal pricing during winter months when natural gas demand has been historically higher.
•
Company-owned Midstream. In 2023, we formed Pinnacle Gas Services LLC to provide gathering and treating services for our emerging Western Haynesville. At December 31, 2025, the Pinnacle system included gas treating plants in Bethel and Marquez, Texas and 246 miles of high-pressure pipelines, which allows us to keep pace with volume growth while maintaining access to strong markets at favorable transportation rates.
•
Organic Drilling Inventory Growth. We focus on growing our inventory of drilling locations organically by acquiring undeveloped leasehold through direct leasing or acquisitions of undeveloped acreage in contrast to many of our peers who have focused on mergers or acquisitions of producing properties to replenish drilling inventory. Over the last six years we have acquired a total of approximately 535,480 net undeveloped acres prospective for the Haynesville and Bossier shales.
•
Successful Drilling Program. We spent $1.05 billion on exploration and development activities in 2025, almost exclusively in the Haynesville and Bossier shale. We spent $1.01 billion on drilling and completion activities and an additional $47.1 million on other development costs. We drilled 52 (44.2 net) wells in 2025, which had an average lateral length of approximately 11,187 feet. Our drilling program in 2025 replaced 830% of our 2025 production based on proved reserves added in our SEC price case and 229% based on proved reserves added in our alternative price case.
•
Efficient Operator. We operated 99% of our proved reserve base as of December 31, 2025. As the operator, we are better able to control operating costs, the timing and plans for future development, the level of drilling and lifting costs, and the marketing of production. As an operator, we receive reimbursements for overhead from other working interest owners, which reduces our general and administrative expenses.
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Data Center Opportunity. We are partnering with NextEra Energy Resources, LLC ("NextEra") to provide natural gas for new power generation in Western Haynesville to support hyperscaler data center development with initial capacity of 2 gigawatts and potential expansion to 8 gigawatts.
Business Strategy
Our strategy consists of the following principal elements:
•
Prudently grow cash flow, production and reserves through development of our high-quality inventory of drilling locations. We have an extensive inventory of de-risked, high-return drilling locations prospective for the Haynesville and Bossier shales. As of December 31, 2025, we have identified 1,848 drilling locations (886 net to us) in our legacy Haynesville and Bossier shale area and 3,343 drilling locations (2,561 net to us) in our Western Haynesville area, which gives us decades of drilling activity. We have optimized the economics of our drilling location inventory by extending the lateral lengths. In 2024, we successfully drilled our first "horseshoe" well, which allowed us to convert two 4,500-foot lateral locations to one 9,382 horizontal well. Our drilling inventory now includes 115 horseshoe locations with superior economics compared to the short lateral locations they replaced. The average lateral length of our drilling location inventory in our legacy Haynesville and Bossier shale area and Western Haynesville area is 10,077 feet and 8,873 feet, respectively.
•
Grow reserve base through active exploration program. We are investing a substantial portion of our annual capital budget to delineate our emerging Western Haynesville and Bossier shale plays in East Texas. Through December 31, 2025, we have turned 30 wells to sales in this emerging play. In 2026, we currently intend to drill an additional 19 Haynesville and Bossier shale wells in this play.
•
Evaluate and pursue strategic acquisition opportunities and conduct an active leasing program to grow our reserves, production, and drilling location inventory. We intend to leverage our management and operating team's significant technical expertise and experience in the Haynesville and Bossier shale plays to continue to pursue acquisition opportunities in that region and to successfully execute and integrate acreage acquisitions that will add to our drilling inventory. We also plan to continue to acquire prospective acreage with an active leasing program.
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•
Maintain disciplined financial strategy. We intend to maintain an operating plan in 2026 that will allow us to continue to delineate the Western Haynesville play while protecting our balance sheet. Our current plan is to fund our exploration and development activity primarily with operating cash flow and we believe our low operating cost structure combined with maximizing the capital efficiency of our drilling program and maintaining financial discipline will allow us to achieve this goal.
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Focus on environmental stewardship. We achieved independent, third-party audited certification of our natural gas operations under the MiQ standard for methane emissions. We became one of the first operators to certify all operated natural gas production. The certification allows us to document to both domestic and international customers that we provide responsibly sourced natural gas. We utilize cleaner burning natural gas rather than diesel fuel when possible to reduce emissions in our drilling and completion operations and design our wells to drill longer laterals and utilize multi-well pad locations to minimize our above-ground footprint.
•
Manage commodity price exposure. We maintain an active natural gas price hedging program designed to mitigate volatility in natural gas prices and to protect a portion of our expected future cash flows to insure that we have adequate cash flow to meet our financial obligations. We also have access to gas storage in the Western Haynesville area that will allow us greater operational flexibility and take advantage of seasonal natural gas pricing.
Property Acquisitions
In 2025, we added 17,856 net Haynesville and Bossier shale acres in the Western Haynesville area through an active leasing program at a cost of $54.7 million. In 2024, we added 265,290 net acres to our Western Haynesville area through acquisitions and a leasing program at a cost of $106.4 million. In 2023, we added 79,741 net Haynesville and Bossier shale acres in Western Haynesville for $98.6 million.
Western Haynesville Midstream Venture
To support the continued development of the Western Haynesville and Bossier shale, we entered into a partnership with Quantum Capital Solutions ("Quantum") in 2023 to finance the buildout of natural gas gathering and treating facilities required to handle the expected growth in our natural gas production from wells we plan to drill in this area. Pinnacle Gas Services LLC ("Pinnacle") was formed by the contribution of a high pressure pipeline and natural gas treating plant which we acquired in 2022. We invested $30.0 million in these midstream assets including the initial acquisition costs. Quantum agreed to fund up to $300 million for the future build out of the gathering and gas treating system. We manage the operations of Pinnacle under a management contract and appoint the majority of Pinnacle's board of directors. Quantum is entitled to a 12% dividend on its invested capital and 80% of any distributions from Pinnacle until certain return hurdles are met. After the return hurdles are met, Quantum's ownership reduces to 30%. In 2025, 2024 and 2023, Quantum contributed $215.5 million, $60.5 million and $24.0 million, respectively, to fund Pinnacle's capital expansion. In January 2026, Pinnacle entered into an agreement with Quantum to redeem all of Quantum's outstanding Class B Units in exchange for cash consideration of $440 million plus any accrued but unpaid distributions. The redemption is expected to be completed in the first half of 2026.
Property Dispositions
In 2025, we sold our Shelby Trough assets in Nacogdoches, San Augustine and Sabine counties of Texas and our Cotton Valley assets in East Texas and North Louisiana for aggregate net proceeds after selling expenses of $432.4 million. In 2024 and 2023, we sold our working interest in certain non-strategic, non-operated properties for $1.2 million and $41.3 million, respectively.
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Natural Gas and Oil Reserves
The following table sets forth our estimated proved natural gas and oil reserves as of December 31, 2025:
| Oil (MBbls) | Natural Gas (MMcf)(1) | Total (MMcfe)(1) | PV 10 Value (000's)(2) | ||||||||||||
|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|
| Proved Developed: | |||||||||||||||
| Producing | 198 | 2,813,569 | 2,814,757 | $ | 3,042,599 | ||||||||||
| Non-producing | — | 27,069 | 27,069 | 17,309 | |||||||||||
| Total Proved Developed | 198 | 2,840,638 | 2,841,826 | 3,059,908 | |||||||||||
| Proved Undeveloped | — | 4,163,483 | 4,163,483 | 1,403,430 | |||||||||||
| Total Proved | 198 | 7,004,121 | 7,005,309 | 4,463,338 | |||||||||||
| Discounted Future Income Taxes | (596,264 | ) | |||||||||||||
| Standardized Measure of Discounted Cash Flows | $ | 3,867,074 |
______________
(1)
Natural gas volumes include NGLs. Oil and NGLs are converted to natural gas equivalents by using a conversion factor of one barrel of oil or NGLs for six Mcf of natural gas based upon the approximate relative energy content of oil to natural gas, which is not indicative of natural gas and oil prices.
(2)
The PV 10 Value represents the discounted future net cash flows attributable to our proved natural gas and oil reserves before income tax, discounted at 10%. Although it is a non-GAAP measure, we believe that the presentation of PV 10 Value is relevant and useful to our investors because it presents the discounted future net cash flows attributable to our proved reserves prior to taking into account corporate future income taxes and our current tax structure. We use this measure when assessing the potential return on investment related to our natural gas and oil properties. The standardized measure of discounted future net cash flows represents the present value of future cash flows attributable to our proved natural gas and oil reserves after income tax, discounted at 10%.
The following table sets forth our year end reserves as of December 31 for each of the last three fiscal years:
| 2025 | 2024 | 2023 | |||||||||||||||||||||
|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|
| Oil (MBbls) | Natural Gas (MMcf) (1) | Oil (MBbls) | Natural Gas (MMcf) (1) | Oil (MBbls) | Natural Gas (MMcf) (1) | ||||||||||||||||||
| Proved Developed | 198 | 2,840,638 | 331 | 2,731,812 | 548 | 2,734,175 | |||||||||||||||||
| Proved Undeveloped | — | 4,163,483 | — | 1,030,286 | — | 2,206,051 | |||||||||||||||||
| Total Proved Reserves | 198 | 7,004,121 | 331 | 3,762,098 | 548 | 4,940,226 |
______________
(1)
Natural gas volumes include NGLs. NGLs are converted to natural gas equivalents by using a conversion factor of one barrel of NGLs for six Mcf of natural gas based upon the approximate relative energy content.
Substantially all of our proved reserves are in the Haynesville and Bossier shales in North Louisiana and East Texas. These wells produce from depths of 10,500 to 19,200 feet. All of our proved undeveloped reserves represent wells to be drilled in the next five years on our Haynesville and Bossier shale acreage.
Proved reserves that are attributable to existing producing wells are primarily determined using decline curve analysis and rate transient analysis, which incorporates the principles of hydrocarbon flow. Proved reserves attributable to producing wells with limited production history and for undeveloped locations are estimated using performance from analogous wells in the surrounding area and geologic data to assess the reservoir continuity. Technologies relied on to establish reasonable certainty of economic producibility include electrical logs, radioactivity logs, core analyses, geologic maps and available production data, seismic data and well test data.
There are numerous uncertainties inherent in estimating quantities of proved natural gas and oil reserves. Natural gas and oil reserve engineering is a subjective process of estimating underground accumulations of natural gas and oil that cannot be precisely measured. The accuracy of any reserve estimate is a function of the quality of available data and of engineering and geological interpretation and judgment. Results of drilling, testing and production subsequent to the date of the estimate may justify revision of such estimate. Accordingly, reserve estimates are often different from the quantities of natural gas and oil that are ultimately recovered.
Prices used in determining quantities of natural gas and oil reserves and future cash inflows from natural gas and oil reserves represent the average first of the month prices received at the point of sale for the last twelve months. These prices have been adjusted from index prices for both location and quality differences.
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The natural gas and oil prices used for reserves estimation were as follows:
| Year | Natural Gas Price (per Mcf) | Oil Price (per Bbl) | |||||
|---|---|---|---|---|---|---|---|
| 2025 | $ | 3.07 | $ | 61.98 | |||
| 2024 | $ | 1.84 | $ | 71.07 | |||
| 2023 | $ | 2.39 | $ | 72.63 |
Reserves may be classified as proved undeveloped if there is a high degree of confidence that the quantities will be recovered, and they are scheduled to be drilled within five years of their initial inclusion as proved reserves, unless specific circumstances justify a longer time. In connection with estimating proved undeveloped reserves for our reserve report, reserves on undrilled acreage were limited to those that are reasonably certain of production when drilled where we can verify the continuity of the reservoir. We only include wells in our proved undeveloped reserves that we currently plan to drill and in which we have adequate capital resources to enable us to drill them. Using empirical evidence, we utilize control points and sample sizes to show continuity in the reservoir. We reflect changes to undeveloped reserves that occur in the same field as revisions to the extent that proved undeveloped locations are revised due to changes in future development plans, including changes to proposed lateral lengths, development spacing and timing of development. As of December 31, 2025, our proved undeveloped reserves did not include any undrilled wells with a rate of return less than 10%.
As of December 31, 2025, our proved undeveloped reserves were comprised of 4.2 Tcf of natural gas consisting of 332 undeveloped locations. All of our natural gas undeveloped reserves are associated with our Haynesville and Bossier shale properties where our 2026 drilling program is focused. Our natural gas and oil proved undeveloped reserves increased by 3.1 Tcf during 2025 due to higher natural gas prices used to determine the proved reserves. During 2025, thirteen proved undeveloped locations included in our 2024 reserves were converted to proved developed reserves. Certain of our proved undeveloped locations that were excluded from our proved reserves at December 31, 2024 due to the low natural gas price that was used to determine proved reserves were included in our 2025 proved reserves given the significant improvement in natural gas prices during 2025.
As of December 31, 2024, our proved undeveloped reserves were comprised of 1.0 Tcf of natural gas consisting of 56 undeveloped locations. All of our natural gas undeveloped reserves are associated with our Haynesville and Bossier shales (including Western Haynesville and Bossier) properties. Our natural gas proved undeveloped reserves decreased by 1.2 Tcf during 2024. During 2024, 21 proved undeveloped locations were converted to proved developed reserves.
The following table presents the changes in our estimated proved undeveloped natural gas and oil reserves for the years ended December 31, 2025, 2024 and 2023:
| Proved Undeveloped Reserves | ||||||||||||||||||||||||
|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|
| 2025 | 2024 | 2023 | ||||||||||||||||||||||
| Oil (MBbls) | Natural Gas (MMcf) | Oil (MBbls) | Natural Gas (MMcf) | Oil (MBbls) | Natural Gas (MMcf) | |||||||||||||||||||
| Beginning Balance | — | 1,030,286 | — | 2,206,051 | 69 | 4,166,108 | ||||||||||||||||||
| Revisions | — | 13,241 | — | (996,816 | ) | — | (1,634,178 | ) | ||||||||||||||||
| Extension and Discoveries | — | 3,175,001 | — | 94,538 | — | 407,629 | ||||||||||||||||||
| Conversion from Undeveloped to Developed | — | (55,045 | ) | — | (273,487 | ) | (69 | ) | (733,508 | ) | ||||||||||||||
| Total Change | — | 3,133,197 | — | (1,175,765 | ) | (69 | ) | (1,960,057 | ) | |||||||||||||||
| Ending Balance | — | 4,163,483 | — | 1,030,286 | — | 2,206,051 |
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The timing, by year, when our proved undeveloped reserve quantities are estimated to be converted to proved developed reserves is as follows:
| Proved Undeveloped Reserves | |||||||||||||||||||||||
|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|
| 2025 | 2024 | 2023 | |||||||||||||||||||||
| Year ended December 31, | Oil (MBbls) | Natural Gas (MMcf) | Oil (MBbls) | Natural Gas (MMcf) | Oil (MBbls) | Natural Gas (MMcf) | |||||||||||||||||
| 2024 | — | — | — | — | — | 273,487 | |||||||||||||||||
| 2025 | — | — | — | 162,370 | — | 425,458 | |||||||||||||||||
| 2026 | — | 451,393 | — | 90,525 | — | 656,609 | |||||||||||||||||
| 2027 | — | 615,813 | — | 70,859 | — | 509,227 | |||||||||||||||||
| 2028 | — | 900,524 | — | 302,749 | — | 341,270 | |||||||||||||||||
| 2029 | — | 1,212,891 | — | 403,783 | — | — | |||||||||||||||||
| 2030 | — | 982,862 | — | — | — | — | |||||||||||||||||
| Total | — | 4,163,483 | — | 1,030,286 | — | 2,206,051 |
The following table presents the timing of our estimated future development capital costs to be incurred for the years ended December 31, 2025, 2024 and 2023:
| Future Development Costs Total Proved Undeveloped Reserves | |||||||||||
|---|---|---|---|---|---|---|---|---|---|---|---|
| 2025 | 2024 | 2023 | |||||||||
| Year ended December 31, | (in millions) | ||||||||||
| 2024 | $ | — | $ | — | $ | 184.5 | |||||
| 2025 | — | 97.1 | 427.2 | ||||||||
| 2026 | 411.6 | 65.7 | 728.7 | ||||||||
| 2027 | 643.2 | 55.4 | 522.4 | ||||||||
| 2028 | 1,013.5 | 279.1 | 351.3 | ||||||||
| 2029 | 1,458.9 | 394.2 | — | ||||||||
| 2030 | 1,175.1 | — | — | ||||||||
| Total | $ | 4,702.3 | $ | 891.5 | $ | 2,214.1 |
The following table presents the changes in our estimated future development costs for the years ended December 31, 2025 and December 31, 2024:
| (in millions) | ||||
|---|---|---|---|---|
| Total as of December 31, 2023 | $ | 2,214.1 | ||
| Development Costs Incurred | (422.6 | ) | ||
| Additions | 96.2 | |||
| Revisions | (996.2 | ) | ||
| Total Changes | (1,322.6 | ) | ||
| Total as of December 31, 2024 | 891.5 | |||
| Development Costs Incurred | (393.2 | ) | ||
| Additions | 3,645.5 | |||
| Revisions | 558.5 | |||
| Total Changes | 3,810.8 | |||
| Total as of December 31, 2025 | $ | 4,702.3 |
Our estimated future capital costs to develop proved undeveloped reserves as of December 31, 2025 of $4.7 billion increased by $3.8 billion from our estimated future capital costs of $0.9 billion as of December 31, 2024. This increase was attributable to the increase in future proved undeveloped locations included in the 2025 proved reserves with the higher natural gas prices in 2025. Our estimated future capital costs to develop proved undeveloped reserves as of December 31, 2024 of $0.9 billion decreased by $1.3 billion from our estimated future capital costs of $2.2 billion as of December 31, 2023 due to a lower number of future proved undeveloped locations expected to generate an economic return as a result of lower natural gas prices.
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We performed an analysis to compare our proved reserve estimates as of December 31, 2025, to proved reserve estimates using year-end market prices of $3.23 per Mcf natural gas price and a $56.82 per Bbl oil price, which represents the NYMEX futures market prices as of December 31, 2025, adjusted for basis differentials ("alternative price case"), to show the sensitivity of our proved reserve estimates to price fluctuations. This sensitivity analysis is meant to demonstrate the impact that changing natural gas and oil prices may have on our proved reserve estimates and the related PV 10 Value and there is no assurance this outcome will be realized.
Our proved natural gas and oil reserves utilizing SEC prices and the alternative price case are as follows:
| SEC Price Case | Alternative Price Case | ||||||
|---|---|---|---|---|---|---|---|
| Oil (MBbls) | |||||||
| Proved Developed | 198 | 194 | |||||
| Proved Undeveloped | — | — | |||||
| Total | 198 | 194 | |||||
| Natural Gas (MMcf) (1) | |||||||
| Proved Developed | 2,840,638 | 2,842,840 | |||||
| Proved Undeveloped | 4,163,483 | 4,339,833 | |||||
| Total | 7,004,121 | 7,182,673 | |||||
| Total Proved Reserves (MMcfe) (1) | 7,005,309 | 7,183,837 | |||||
| PV 10 Value (in thousands) (2) | $ | 4,463,338 | $ | 5,180,999 |
______________
(1)
Natural gas volumes include NGLs. Oil and NGLs are converted to natural gas equivalents by using a conversion factor of one barrel of oil or NGLs for six Mcf of natural gas based upon the approximate relative energy content of oil to natural gas, which is not indicative of natural gas and oil prices.
(2)
The PV 10 Value represents the discounted future net cash flows attributable to our proved natural gas and oil reserves before income tax, discounted at 10%. Although it is a non-GAAP measure, we believe that the presentation of PV 10 Value is relevant and useful to our investors because it presents the discounted future net cash flows attributable to our proved reserves prior to taking into account corporate future income taxes and our current tax structure. We use this measure when assessing the potential return on investment related to our natural gas and oil properties. The standardized measure of discounted future net cash flows represents the present value of future cash flows attributable to our proved natural gas and oil reserves after income tax, discounted at 10%.
Proved reserve information in this report is based on estimates prepared by our petroleum engineering staff and is the responsibility of management. We retained an independent petroleum consultant to conduct an audit of our December 31, 2025 reserve estimates. Netherland, Sewell & Associates, Inc. ("NSAI") audited 100% of our total PV 10 Value as of December 31, 2025. The purpose of this audit was to provide additional assurance on the reasonableness of internally prepared reserve estimates. NSAI was selected for its geographic expertise and historical experience.
The audit letter prepared by NSAI is included as an exhibit to this report. The technical persons at the independent petroleum consulting firm responsible for reviewing the reserve estimates presented herein meet the requirements regarding qualifications, independence, objectivity and confidentiality as set forth in the Standards Pertaining to the Estimating and Auditing of Oil and Gas Reserves Information promulgated by the Society of Petroleum Engineers.
The independent consultant's estimates of proved reserves and the pretax present value of such reserves discounted at 10% did not differ from our estimates by more than 7% in the aggregate. However, when compared on a lease-by-lease, field-by-field or area-by-area basis, some of our estimates may be greater than those of our independent consultant and some may be less than the estimates of the independent consultant. When such differences do not exceed 10% in the aggregate, our reserve auditor is satisfied that the proved reserves and pretax present value of such reserves discounted at 10% are reasonable and will issue an unqualified opinion. The remaining differences are not resolved due to the limited cost benefit of continuing such analysis. During the year, our reserves group also performs separate, detailed technical reviews of reserve estimates for significant acquisitions or for properties with problematic indicators such as excessively long lives, sudden changes in performance or changes in economic or operating conditions.
We have established and maintain internal controls designed to provide reasonable assurance that the estimates of proved reserves are computed and reported in accordance with rules and regulations promulgated by the SEC. These internal controls include documented process workflows, employing qualified engineering and geological personnel, and on-going education for personnel involved in our reserves estimation process. Our internal audit function routinely tests our processes and controls. Throughout the year, our technical team meets periodically with representatives of our independent petroleum consultants to
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review properties and discuss methods and assumptions. We provide historical information to our consultants for our largest producing properties such as ownership interest, production, well test data, commodity prices and operating and development costs. In some cases, additional meetings are held to review identified reserve differences.
All of our reserve estimates are reviewed with our executive management, our independent consultants perform an independent analysis, and ultimately our reserve estimates are approved by our Director of Reservoir Engineering, Kristine Bartlett. Ms. Bartlett holds a Bachelor of Science degree in Petroleum Engineering and Geoscience from the University of Texas at Austin and has 13 years of engineering experience in the oil and gas industry.
We did not provide estimates of total proved natural gas and oil reserves during the three-year period ended December 31, 2025 to any federal authority or agency, other than the SEC.
Production, Price and Cost Summary
Annual production, average prices that we realized from sales of natural gas and oil and the associated lifting costs for each of the last three fiscal years were as follows:
| Year Ended December 31, | |||||||||||
|---|---|---|---|---|---|---|---|---|---|---|---|
| 2025 | 2024 | 2023 | |||||||||
| Net Production Volumes: | |||||||||||
| Natural gas - MMcf | 450,202 | 527,548 | 524,467 | ||||||||
| Oil - MBbls | 37 | 50 | 70 | ||||||||
| Average Prices: | |||||||||||
| Natural Gas - $/Mcf | $ | 3.17 | $ | 1.98 | $ | 2.40 | |||||
| Oil - $/Bbl | $ | 61.95 | $ | 71.94 | $ | 73.73 | |||||
| Lifting Costs - $/Mcfe: | |||||||||||
| Lease operating | $ | 0.27 | $ | 0.25 | $ | 0.25 | |||||
| Gathering and transportation | $ | 0.37 | $ | 0.37 | $ | 0.35 | |||||
| Production and ad valorem taxes | $ | 0.09 | $ | 0.11 | $ | 0.18 |
Drilling Activity Summary
During the three-year period ended December 31, 2025, we drilled development and exploratory wells as set forth in the table below:
| 2025 | 2024 | 2023 | |||||||||||||||||||||
|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|
| Gross | Net | Gross | Net | Gross | Net | ||||||||||||||||||
| Development: | |||||||||||||||||||||||
| Oil | — | — | — | — | — | — | |||||||||||||||||
| Gas | 34 | 26.2 | 39 | 31.9 | 63 | 47.6 | |||||||||||||||||
| Dry | — | — | — | — | 1 | 1.0 | |||||||||||||||||
| 34 | 26.2 | 39 | 31.9 | 64 | 48.6 | ||||||||||||||||||
| Exploratory: | |||||||||||||||||||||||
| Oil | — | — | — | — | — | — | |||||||||||||||||
| Gas | 18 | 18.0 | 11 | 11.0 | 7 | 6.9 | |||||||||||||||||
| Dry | — | — | — | — | — | — | |||||||||||||||||
| 18 | 18.0 | 11 | 11.0 | 7 | 6.9 | ||||||||||||||||||
| Total | 52 | 44.2 | 50 | 42.9 | 71 | 55.5 |
As of December 31, 2025, 2024 and 2023, we had 35 (28.8 net), 21 (17.3 net), and 30 (26.9 net), respectively, operated wells in the process of being drilled and completed.
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Producing Well Summary
The following table sets forth the gross and net producing natural gas and oil wells in which we owned an interest as of December 31, 2025:
| Oil | Natural Gas | ||||||||||||||
|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|
| Gross | Net | Gross | Net | ||||||||||||
| Louisiana | — | — | 1,212 | 669.6 | |||||||||||
| Oklahoma | 6 | 0.6 | 98 | 8.8 | |||||||||||
| Texas | 10 | 5.2 | 372 | 273.6 | |||||||||||
| Wyoming | — | — | 26 | 1.9 | |||||||||||
| Total | 16 | 5.8 | 1,708 | 953.9 |
We operate 1,074 of the 1,724 producing wells presented in the above table. As of December 31, 2025, we did not own an interest in any wells containing multiple completions, which means that a well is producing from more than one completed zone.
Acreage
The following table summarizes our developed and undeveloped leasehold acreage as of December 31, 2025, all of which is onshore in the continental United States. We have excluded acreage in which our interest is limited to a royalty or overriding royalty interest.
| Developed | Undeveloped | ||||||||||||||
|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|
| Gross | Net | Gross | Net | ||||||||||||
| Louisiana | 193,399 | 151,439 | 25,608 | 18,856 | |||||||||||
| Oklahoma | 26,080 | 3,382 | — | — | |||||||||||
| Texas | 194,617 | 159,082 | 725,954 | 516,742 | |||||||||||
| Wyoming | 13,440 | 927 | — | — | |||||||||||
| Total | 427,536 | 314,830 | 751,562 | 535,598 |
As of December 31, 2025, our undeveloped acreage expires as follows:
| Gross | Net | |||||||||||||||
|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|
| 2026 | 79,799 | 11 | % | 54,529 | 10 | % | ||||||||||
| 2027 | 57,925 | 8 | % | 42,319 | 8 | % | ||||||||||
| 2028 | 46,116 | 6 | % | 28,696 | 5 | % | ||||||||||
| 2029 | 5,733 | 1 | % | 2,815 | 1 | % | ||||||||||
| 2030 | 12,191 | 2 | % | 5,170 | 1 | % | ||||||||||
| Thereafter | 549,798 | 72 | % | 402,069 | 75 | % | ||||||||||
| 751,562 | 100 | % | 535,598 | 100 | % |
The title to our natural gas and oil properties is subject to royalty, overriding royalty, carried and other similar interests and contractual arrangements customary in the natural gas and oil industry, liens incident to operating agreements and for current taxes not yet due and other minor encumbrances. All of our natural gas and oil properties are pledged as collateral under our bank credit facility. As is customary in the natural gas and oil industry, we are generally able to retain our ownership interest in undeveloped acreage by production from wells producing from a different reservoir, by drilling activity which establishes commercial reserves sufficient to maintain the lease, by payment of delay rentals or by the exercise of contractual extension rights.
Markets and Customers
The market for our production of natural gas and oil depends on factors beyond our control, including the extent of domestic production and imports of natural gas and oil, the proximity and capacity of natural gas pipelines and other transportation facilities, demand for natural gas and oil, the marketing of competitive fuels and the effects of state and federal regulation. The natural gas and oil industry also competes with other industries in supplying the energy and fuel requirements of industrial, residential and commercial consumers along with electric generator customers.
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Our natural gas production is primarily sold under contracts with various terms and priced on first of the month index prices or on daily spot market prices or fixed prices. We target selling approximately 70% to 75% of our natural gas on first of month index price, with the remaining volumes on daily spot market pricing. The percentage of natural gas sold on spot market pricing can be impacted when new wells commence production as such production is typically sold on daily spot market pricing during the month the well is first brought on line. Enterprise Products Operating and its subsidiaries, Venture Global LNG, Inc. and Shell Energy North America US, L.P. accounted for 18%, 11%, and 10%, respectively, of our total 2025 sales. The loss of any of these customers would not have a material adverse effect on us as there is an available market for our natural gas and oil production from other purchasers.
We have entered into longer-term transportation arrangements to ensure that we have adequate transportation to deliver our natural gas production in North Louisiana and East Texas to various markets. As an alternative to constructing our own gathering and treating facilities, we have entered into a variety of gathering and treating agreements with midstream companies to transport our natural gas to a central point or other long-haul natural gas pipelines. We currently have agreements with certain natural gas midstream companies to provide us with firm transportation for an average of approximately 1.7 Bcf per day in 2026 on the long-haul pipelines. To the extent we are not able to deliver the contracted natural gas volumes, we may be responsible for the transportation costs.
Competition
The natural gas and oil industry is highly competitive. Competitors include major oil companies, other independent energy companies and individual producers and operators, many of which have financial resources, personnel and facilities substantially greater than we do. We face intense competition for the acquisition of natural gas and oil properties and leases for natural gas and oil exploration.
Regulation
General. Various aspects of our natural gas and oil operations are subject to extensive and continually changing regulation, as legislation affecting the natural gas and oil industry is under constant review for amendment or expansion. Numerous departments and agencies, both federal and state, are authorized by statute to issue, and have issued, rules and regulations binding upon the natural gas and oil industry and its individual members. The Federal Energy Regulatory Commission ("FERC") regulates the transportation and sale for resale of natural gas in interstate commerce pursuant to the Natural Gas Act of 1938 ("NGA") and the Natural Gas Policy Act of 1978. In 1989, however, Congress enacted the Natural Gas Wellhead Decontrol Act, which removed all remaining price and nonprice controls affecting all "first sales" of natural gas, effective January 1, 1993, subject to the terms of any private contracts that may be in effect. While sales by producers of natural gas and all sales of crude oil, condensate and natural gas liquids can currently be made at uncontrolled market prices, in the future Congress could reenact price controls or enact other legislation with detrimental impact on many aspects of our business. Under the provisions of the Energy Policy Act of 2005 (the "2005 Act"), the NGA has been amended to prohibit any form of market manipulation with the purchase or sale of natural gas, and the FERC has issued new regulations that are intended to increase natural gas pricing transparency. The 2005 Act has also significantly increased the penalties for violations of the NGA. The FERC has issued Order No. 704 et al. which requires a market participant to make an annual filing if it has sales or purchases equal to or greater than 2.2 million MMBtu in the reporting year to facilitate price transparency.
Regulation and transportation of natural gas. Our sales of natural gas are affected by the availability, terms and cost of transportation. The price and terms for access to pipeline transportation are subject to extensive regulation. The FERC requires interstate pipelines to provide open-access transportation on a not unduly discriminatory basis for similarly situated shippers. The FERC frequently reviews and modifies its regulations regarding the transportation of natural gas, with the stated goal of fostering competition within the natural gas industry.
Intrastate natural gas transportation is subject to regulation by state regulatory agencies. The Texas Railroad Commission has been changing its regulations governing transportation and gathering services provided by intrastate pipelines and gatherers. While the changes by these state regulators affect us only indirectly, they are intended to further enhance competition in natural gas markets. We cannot predict what further action the FERC or state regulators will take on these matters; however, we do not believe that we will be affected differently in any material respect than other natural gas producers with which we compete by any action taken.
Additional proposals and proceedings that might affect the natural gas industry are pending before Congress, the FERC, state commissions and the courts. The natural gas industry historically has been very heavily regulated; therefore, there is no assurance that the less stringent regulatory approach pursued by the FERC, Congress and state regulatory authorities will continue.
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Federal leases. Some of our operations are located on federal natural gas and oil leases that are administered by the Bureau of Land Management ("BLM") of the United States Department of the Interior. These leases are issued through competitive bidding and contain relatively standardized terms. These leases require compliance with detailed Department of Interior and BLM regulations and orders that are subject to interpretation and change. These leases are also subject to certain regulations and orders promulgated by the Department of Interior's Bureau of Ocean Energy Management, Regulation & Enforcement, through its Minerals Revenue Management Program, which is responsible for the management of revenues from both onshore and offshore leases. Our operations located on federal natural gas and oil leases are insignificant to our total operations.
Oil and natural gas liquids transportation rates. Our sales of crude oil, condensate and natural gas liquids are not currently regulated and are made at market prices. In a number of instances, however, the ability to transport and sell such products is dependent on pipelines whose rates, terms and conditions of service are subject to FERC jurisdiction under the Interstate Commerce Act. In other instances, the ability to transport and sell such products is dependent on pipelines whose rates, terms and conditions of service are subject to regulation by state regulatory bodies under state statutes. The price received from the sale of these products may be affected by the cost of transporting the products to market.
The FERC's regulation of pipelines that transport crude oil, condensate and natural gas liquids under the Interstate Commerce Act is generally more light-handed than the FERC's regulation of natural gas pipelines under the NGA. FERC-regulated pipelines that transport crude oil, condensate and natural gas liquids are subject to common carrier obligations that generally ensure non-discriminatory access. With respect to interstate pipeline transportation subject to regulation of the FERC under the Interstate Commerce Act, rates generally must be cost-based, although settlement rates agreed to by all shippers are permitted and market-based rates are permitted in certain circumstances. Effective January 1, 1995, the FERC implemented regulations establishing an indexing system (based on inflation) for transportation rates governed by the Interstate Commerce Act that allowed for an increase or decrease in the transportation rates. The FERC's regulations include a methodology for such pipelines to change their rates through the use of an index system that establishes ceiling levels for such rates. The mandatory five-year review in 2005 revised the methodology for this index to be based on Producer Price Index for Finished Goods (PPI-FG) plus 1.3 percent for the period July 1, 2006 through June 30, 2011. The mandatory five-year review in 2012 revised the methodology for this index to be based on PPI-FG plus 2.65 percent for the period July 1, 2011 through June 30, 2016. The regulations provide that each year the Commission will publish the oil pipeline index after the PPI-FG becomes available.
With respect to intrastate crude oil, condensate and natural gas liquids pipelines subject to the jurisdiction of state agencies, such state regulation is generally less rigorous than the regulation of interstate pipelines. State agencies have generally not investigated or challenged existing or proposed rates in the absence of shipper complaints or protests. Complaints or protests have been infrequent and are usually resolved informally.
We do not believe that the regulatory decisions or activities relating to interstate or intrastate crude oil, condensate or natural gas liquids pipelines will affect us in a way that materially differs from the way it affects other crude oil, condensate and natural gas liquids producers or marketers.
Environmental regulations. We are subject to stringent federal, state and local laws. These laws, among other things, govern the issuance of permits to conduct exploration, drilling and production operations, the amounts and types of materials that may be released into the environment, the discharge and disposition of waste materials, the remediation of contaminated sites and the reclamation and abandonment of wells, sites and facilities. Numerous governmental departments issue rules and regulations to implement and enforce such laws, which are often difficult and costly to comply with and which carry substantial civil and even criminal penalties for failure to comply. Some laws, rules and regulations relating to protection of the environment may, in certain circumstances, impose strict liability for environmental contamination, rendering a person liable for environmental damages and cleanup cost without regard to negligence or fault on the part of such person. Other laws, rules and regulations may restrict the rate of natural gas and oil production below the rate that would otherwise exist or even prohibit exploration and production activities in sensitive areas. In addition, state laws often require various forms of remedial action to prevent pollution, such as closure of inactive pits and plugging of abandoned wells. The regulatory burden on the natural gas and oil industry increases our cost of doing business and consequently affects our profitability. These costs are considered a normal, recurring cost of our on-going operations. Our domestic competitors are generally subject to the same laws and regulations.
We believe that we are in substantial compliance with current applicable environmental laws and regulations and that continued compliance with existing requirements will not have a material adverse impact on our operations. Environmental laws and regulations have been subject to frequent changes over the years, and the imposition of more stringent requirements or new regulatory schemes such as carbon "cap and trade" or pricing programs could have a material adverse effect upon our
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capital expenditures, earnings or competitive position, including the suspension or cessation of operations in affected areas. The Biden administration has made, and the Trump administration may also make additional changes to applicable regulations. There are costs associated with responding to changing regulations and policies, whether such regulations are more or less stringent. As such, there can be no assurance that material costs and liabilities will not be incurred in the future.
The Comprehensive Environmental Response, Compensation and Liability Act ("CERCLA") imposes liability, without regard to fault, on certain classes of persons that are considered to be responsible for the release of a "hazardous substance" into the environment. These persons include the current or former owner or operator of the disposal site or sites where the release occurred and companies that disposed or arranged for the disposal of hazardous substances at such sites. Under CERCLA, such persons may be subject to joint and several liability for the cost of investigating and cleaning up hazardous substances that have been released into the environment, for damages to natural resources and for the cost of certain health studies. In addition, companies that incur liability frequently also confront third party claims because it is not uncommon for neighboring landowners and other third parties to file claims for personal injury and property damage allegedly caused by hazardous substances or other pollutants released into the environment from a polluted site. Many states have adopted similar statutes that impose liability for the release of hazardous substances and petroleum. In addition, from time to time the U.S. Environmental Protection Agency ("EPA"), states, and other agencies make new findings that certain chemicals are potential environmental concerns, sometimes referred to as emerging contaminants. These agencies may also adjust risk-based assessment or cleanup levels, in some instances, to be more stringent. The EPA and other agencies may impose new restrictions or cleanup requirements on such chemicals. We may incur costs to comply with such requirements.
The Federal Solid Waste Disposal Act, as amended by the Resource Conservation and Recovery Act of 1976 ("RCRA"), regulates the generation, transportation, storage, treatment and disposal of hazardous wastes and can require cleanup of hazardous waste disposal sites. RCRA currently excludes drilling fluids, produced waters and other wastes associated with the exploration, development or production of natural gas and oil gas from regulation as "hazardous waste". Disposal of such non-hazardous natural gas and oil exploration, development and production wastes usually are regulated by state law. Other wastes handled at exploration and production sites or used in the course of providing well services may not fall within this exclusion. Moreover, stricter standards for waste handling and disposal may be imposed on the natural gas and oil industry in the future. From time to time, legislation is proposed in Congress that would revoke or alter the current exclusion of exploration, development and production wastes from RCRA's definition of "hazardous wastes", thereby potentially subjecting such wastes to more stringent handling, disposal and cleanup requirements. If such legislation were enacted, it could have a significant impact on our operating costs, as well as the natural gas and oil industry in general. The impact of future revisions to environmental laws and regulations cannot be predicted.
Certain natural gas and oil wastes may also contain naturally occurring radioactive material ("NORM"), which is regulated by the federal Occupational Safety and Health Administration and state agencies. These regulations require certain worker protections and waste handling and disposal procedures. We believe our operations comply in all material respects with these worker protection and waste handling and disposal requirements.
Our operations are also subject to the Clean Air Act ("CAA"), and comparable state and local requirements. Amendments to the CAA were adopted in 1990 and contain provisions that may result in the gradual imposition of certain pollution control requirements with respect to air emissions from our operations. EPA issued its final rule on December 2, 2023 that has a number of provisions intended to reduce methane emissions from natural gas and oil operations. On March 12, 2025, EPA Administrator Lee Zeldin announced that the EPA was reconsidering the prior rule, and, on July 28, 2025 and December 3, 2025, the EPA issued an interim final rule and final rule, respectively, extending the deadlines for certain provisions on the rule. We believe our operations will not be materially adversely affected by the new requirements, and the requirements will not be any more burdensome to us than to other similarly situated companies involved in natural gas and oil exploration and production activities.
The Federal Water Pollution Control Act of 1972, as amended (the "Clean Water Act"), imposes restrictions and controls on the discharge of produced waters and other wastes into navigable waters. Permits must be obtained to discharge pollutants into state and federal waters and to conduct construction activities in waters and wetlands. In January 2023, the EPA and the U.S. Army Corps of Engineers ("USACE") issued a new rule that revises the definition of "waters of the United States" ("WOTUS"). The new rule has been challenged by several states and industry groups. If upheld, such regulations may impact certain exploration and production activities. On November 17, 2025, the EPA and the USACE announced a proposed rule to further revise the definition of WOTUS. Certain state regulations and the general permits issued under the Federal National Pollutant Discharge Elimination System program prohibit the discharge of produced waters and sand, drilling fluids, drill cuttings and certain other substances related to the natural gas and oil industry into certain coastal and offshore waters, unless otherwise authorized. Further, the EPA has adopted regulations requiring certain natural gas and oil exploration and production
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facilities to obtain permits for storm water discharges. Costs may be associated with the treatment of wastewater or developing and implementing storm water pollution prevention plans. The Clean Water Act and comparable state statutes provide for civil, criminal and administrative penalties for unauthorized discharges for oil and other pollutants and impose liability on parties responsible for those discharges for the cost of cleaning up any environmental damage caused by the release and for natural resource damages resulting from the release. We believe that our operations comply in all material respects with the requirements of the Clean Water Act and state statutes enacted to control water pollution and that the requirements, including those under the 2023 WOTUS rule and 2025 WOTUS rule, are not any more burdensome to us than to other similarly situated companies involved in natural gas and oil exploration and production activities.
The Federal Safe Drinking Water Act of 1974, as amended, requires the EPA to develop minimum federal requirements for Underground Injection Control ("UIC") programs and other safeguards to protect public health by preventing injection wells from contaminating underground sources of drinking water. The UIC program does not regulate wells that are solely used for production. However, the EPA has authority to regulate hydraulic fracturing when diesel fuels are used in fluids or propping agents. In February 2014, the EPA issued guidance on when UIC permitting requirements apply to fracking fluids containing diesel. We believe that our operations comply in all material respects with the requirements of the Federal Safe Drinking Water Act and similar state statutes. We believe the requirements are not any more burdensome to us than to other similarly situated companies involved in natural gas and oil exploration and production activities.
State and federal regulatory agencies have studied possible connections between hydraulic fracturing related activities and the increased occurrence of seismic activity. When caused by human activity, such events are called induced seismicity. In a few instances, operators of injection wells in the vicinity of seismic events have been ordered to reduce injection volumes or suspend operations. Some state regulatory agencies, including those in Arkansas, California, Colorado, Illinois, Kansas, Ohio, Oklahoma, and Texas, have modified their regulations to account for induced seismicity. There continues to be research into the possible linkage between natural gas and oil activity and induced seismicity. A 2012 report published by the National Academy of Sciences, as well as a more recent paper published in the journal Reviews of Geophysics and cited on the U.S. Geological Survey website, concluded that only a very small fraction of the tens of thousands of injection wells have been suspected to be, or have been, the likely cause of induced seismicity. In 2015, the U.S. Geological Survey identified eight states, including Texas, with areas of increased rates of induced seismicity that could be attributed to fluid injection or natural gas and oil extraction. In March 2016, the U.S. Geological Survey identified six states with the most significant hazards from induced seismicity, including Texas, Colorado, Oklahoma, Kansas, New Mexico, and Arkansas. In addition, a number of lawsuits have been filed, including in Oklahoma, alleging that disposal well operations have caused damage to or injury at nearby properties or otherwise violated state and federal rules regulating waste disposal. It is possible that the EPA or other agencies may develop rules to specifically address the disposal of wastewater from natural gas and oil development and the potential for induced seismicity from wastewater injection. Future regulatory developments could adversely affect our operations by placing restrictions on the use of injection wells and hydraulic fracturing and/or causing us to incur increased operating expenses.
In December 2016, the EPA finalized its report on the potential impacts of hydraulic fracturing on drinking water resources, which concluded that hydraulic fracturing activities could impact drinking water resources under some circumstances. Other governmental agencies, including the U.S. Department of Energy, have evaluated or are evaluating various other aspects of hydraulic fracturing. These ongoing or proposed studies have the potential to impact the likelihood or scope of future legislation or regulation.
Federal regulators require certain owners or operators of facilities that store or otherwise handle oil to prepare and implement spill prevention, control, countermeasure and response plans relating to the possible discharge of oil into surface waters. The Oil Pollution Act of 1990 ("OPA") contains numerous requirements relating to the prevention and response to oil spills in the WOTUS. The OPA subjects owners of facilities to strict joint and several liability for all containment and cleanup costs and certain other damages relating to a spill. Noncompliance with OPA may result in varying civil and criminal penalties and liabilities.
Executive Order 13158, issued on May 26, 2000, directs federal agencies to safeguard existing Marine Protected Areas, or MPAs, in the United States and establish new MPAs. The order requires federal agencies to avoid harm to MPAs to the extent permitted by law and to the maximum extent practicable. It also directs the EPA to propose new regulations under the Clean Water Act to ensure appropriate levels of protection for the marine environment. This order has the potential to adversely affect our operations by restricting areas in which we may carry out future exploration and development projects and/or causing us to incur increased operating expenses.
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Certain flora and fauna that have officially been classified as "threatened" or "endangered" are protected by the Endangered Species Act. This law prohibits any activities that could "take" a protected plant or animal or reduce or degrade its habitat area. If endangered species are located in an area we wish to develop, the work could be prohibited or delayed and/or expensive mitigation might be required.
Other statutes that provide protection to animal and plant species and which may apply to our operations include, but are not necessarily limited to, the Oil Pollution Act, the Emergency Planning and Community Right to Know Act, the Marine Mammal Protection Act, the Marine Protection, Research and Sanctuaries Act, the Fish and Wildlife Coordination Act, the Fishery Conservation and Management Act, the Migratory Bird Treaty Act and the National Historic Preservation Act. These laws and regulations may require the acquisition of a permit or other authorization before construction or drilling commences and may limit or prohibit construction, drilling and other activities on certain lands lying within wilderness or wetlands and other protected areas and impose substantial liabilities for pollution resulting from our operations. The permits required for our various operations are subject to revocation, modification and renewal by issuing authorities. In addition, laws such as the National Environmental Policy Act and the Coastal Zone Management Act may make the process of obtaining certain permits more difficult or time consuming, resulting in increased costs and potential delays that could affect the viability or profitability of certain activities. Administrative policies with respect to such laws are also changing, and we incur costs to follow such changes and comply as changes become effective.
Certain statutes, such as the Emergency Planning and Community Right to Know Act, require the reporting of hazardous chemicals manufactured, processed, or otherwise used, which may lead to heightened scrutiny of the company's operations by regulatory agencies or the public. In 2012, the EPA adopted the Petroleum and Natural Gas Systems Greenhouse Gas Reporting Rule (40 C.F.R. Part 98, Subpart W), which requires certain onshore petroleum and natural gas facilities to collect data on their emissions of greenhouse gases ("GHG"). GHGs include gases such as methane, a primary component of natural gas, and carbon dioxide, a byproduct of burning natural gas. Different GHGs have different global warming potentials with CO2 having the lowest global warming potential, so emissions of GHGs are typically expressed in terms of CO2 equivalents ("CO2e"). The rule applies to facilities that emit 25,000 metric tons of CO2e or more per year, and requires onshore petroleum and natural gas operators to group all equipment under common ownership or control within a single hydrocarbon basin together when determining if the threshold is met. These greenhouse gas reporting rules were amended on October 22, 2015 to expand the number of sources and operations that are subject to these rules, and again on November 18, 2016 to provide less burdensome reporting requirements. We have determined that these reporting requirements apply to us and we believe we have met all of the EPA required reporting deadlines and strive to ensure accurate and consistent emissions data reporting. On September 12, 2025, the EPA announced a proposed rule to end the GHG Reporting Rule. Other EPA actions with respect to the reduction of greenhouse gases (such as the EPA's Greenhouse Gas Endangerment Finding, and the EPA's Prevention of Significant Deterioration and Title V Greenhouse Gas Tailoring Rule) and various state actions have or could impose mandatory reductions in greenhouse gas emissions. We are unable to predict at this time how much the cost of compliance with any legislation or regulation of greenhouse gas emissions will be in future periods.
The U.S. has not passed legislation to expressly regulate GHG emissions; however, in recent years the EPA moved ahead with its efforts to regulate GHG emissions from certain sources by rule. Beyond requiring measurement and reporting of GHGs as discussed above, the EPA issued an "Endangerment Finding" under section 202(a) of the Clean Air Act, concluding greenhouse gas pollution threatens the public health and welfare of current and future generations. However, in 2025, President Trump directed the EPA to reevaluate the Endangerment Finding, which could impact the EPA's prior and future rulemaking. On July 29, 2025, the EPA proposed to rescind the Endangerment Finding and, on January 7, 2026, the EPA sent its draft final rule to the White House Office of Management and Budget for review. The EPA has adopted regulations that would require permits for and reductions in greenhouse gas emissions for certain facilities. States in which we operate may also require permits and reductions in GHG emissions. Additionally, as discussed above, the EPA has promulgated rules that require reductions in volatile organic compounds ("VOCs") and methane generation from natural gas and oil operations. In addition, on April 10, 2024, the BLM finalized a rule establishing new requirements designed to reduce waste of natural gas from venting, flaring and leaks. Since all of our natural gas and oil production is in the United States, laws or regulations that have been or may be adopted to restrict or reduce emissions of greenhouse gases could require us to incur substantial increased operating costs, and could have an adverse effect on demand for the natural gas and oil we produce. In addition, efforts have been made and continue to be made in the international community toward the adoption of international treaties or protocols that would address global climate change issues. In 2015, the United States participated in the United Nations Conference on Climate Change, which led to the creation of the Paris Agreement. The Paris Agreement requires ratifying countries to review and "represent a progression" in the ambitions of their nationally determined contributions, which set GHG emission reduction goals, every five years. The United States signed the Paris Agreement on April 22, 2016; although the Trump administration provided notice of its intent to withdraw from the Paris Agreement in 2017 and again in 2025. Further, the United States has made additional commitments with respect to GHG emissions through the United Nations Climate Change Conference,
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including with respect to reducing methane emissions. It is difficult to predict the timing and certainty of any future government action and the effect on our operations. Future legislation or regulations adopted to address climate change could also make our products more or less desirable than competing sources of energy. However, we expect that the impacts to our operations will not be materially different from other similarly situated companies involved in natural gas and oil exploration and production activities.
The Inflation Reduction Act (the "IRA"), which was signed into law on August 16, 2023, established a new program, the Methane Emission Reduction Program, that imposes a first-time federal fee on methane emissions for the oil and gas sector, the Waste Emissions Charge ("WEC"). In general, under the EPA's November 12, 2024 final rule implementing the WEC, covered facilities that emit 25,000 metric tons of carbon dioxide equivalent or more per year are required to pay for "excess" methane emissions, with the fee starting at $900 per metric ton in 2024, and increasing to $1,500 per metric ton by 2026. The calculation of the methane fee is determined by (1) the facility's reported emissions under the federal Greenhouse Gas Reporting Program, and (2) an emissions threshold that varies by facility type. For example, for offshore and onshore petroleum and natural gas production facilities, the fee applies to the number of reported tons of methane that exceed (i) 0.2% of the natural gas sent to sale from the facility. On March 14, 2025, President Trump signed a Joint Resolution of Disapproval under the Congressional Review Act overturning the EPA's WEC rule. The One Big Beautiful Bill Act signed into law by President Trump on July 4, 2025 postpones the implementation of the WEC to 2034. We believe our operations will not be materially adversely affected by the IRA, and the requirements will not be any more burdensome to us than to other similarly situated companies involved in natural gas and oil exploration and production activities.
In 2021, the Biden administration issued an Executive Order pausing new natural gas and oil leasing and drilling permits for U.S. public lands and offshore waters until the Secretary of the Interior conducts a comprehensive review and reconsideration of Federal natural gas and oil permitting and leasing practices. In 2022, the Biden administration reopened federal lands for natural gas and oil leasing under a reformed program that significantly reduces the acreage available for lease and, in 2025, President Trump revoked the 2021 Executive Order. We believe our operations will not be materially adversely affected by these changes and expect that the impacts to our operations will be similar to other similarly situated companies involved in natural gas and oil exploration and production activities.
Such changes in environmental laws and regulations which result in more stringent and costly reporting, or waste handling, storage, transportation, disposal or cleanup activities, could materially affect companies operating in the energy industry. Adoption of new regulations further regulating emissions from natural gas and oil production could adversely affect our business, financial position, results of operations and prospects, as could the adoption of new laws or regulations which levy taxes or other costs on greenhouse gas emissions from other industries, which could result in changes to the consumption and demand for natural gas. We may also be assessed administrative, civil and/or criminal penalties if we fail to comply with any such new laws and regulations applicable to natural gas and oil production.
Regulation of natural gas and oil exploration and production. Our exploration and production operations are subject to various types of regulation at the federal, state and local levels. Such regulations include requiring permits and drilling bonds for the drilling of wells, regulating the location of wells, the method of drilling and casing wells and the surface use and restoration of properties upon which wells are drilled. Many states also have statutes or regulations addressing conservation matters, including provisions for the unitization or pooling of natural gas and oil properties, the establishment of maximum rates of production from natural gas and oil wells and the regulation of spacing, plugging and abandonment of such wells. Some state statutes limit the rate at which natural gas and oil can be produced from our properties. It is also possible that certain states may increase regulatory activity in response to changing federal regulations or policies.
State regulation. Most states regulate the production and sale of natural gas and oil, including requirements for obtaining drilling permits, the method of developing new fields, the spacing and operation of wells and the prevention of waste of natural gas and oil resources. The rate of production may be regulated and the maximum daily production allowable from both natural gas and oil wells may be established on a market demand or conservation basis or both.
Office and Operations Facilities
Our executive offices are located at 5300 Town and Country Blvd., Suite 500 in Frisco, Texas 75034, and our telephone number is (972) 668-8800. We lease office space in Frisco, Texas covering 66,382 square feet. This lease expires on December 31, 2031. We have an option to terminate the lease on December 31, 2028. We also own production offices and pipe yard facilities near Carthage, Franklin, Marshall, Marquez and Tennessee Colony in Texas and Bossier City, Grand Cane, Greenwood, Homer, Mansfield and Logansport in Louisiana.
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Human Capital
As of December 31, 2025, we had 252 employees and utilized contract employees for certain of our drilling, completion and production operations. We seek to attract a qualified workforce and maintain strong non-discrimination and anti-harassment policies.
The safety of our employees, contractors and the community is a core business value and in order to achieve our goals of operational excellence and an injury-free workplace, we maintain a strong health and safety management system. The framework includes policies and procedures outlining how we do our work, programs to engage employees and drive a proactive safety culture, employee training to help ensure our employees have the knowledge to perform their work safely, setting targets and objectives for clearly defined deliverables and accountabilities and periodic audit and inspection of results using data collection of key performance indicators and scorecards to measure our success and develop improvement strategies.
We utilize a third-party contractor management service to ensure a consistent approach in aligning our expectations with all third parties involved in our operations. We hold our contractors accountable to the highest performance standards through our contractor onboarding and continuous auditing process.
Directors and Executive Officers
The following table sets forth certain information concerning our executive officers and directors.
| Name | Position with Company | Age | ||
|---|---|---|---|---|
| M. Jay Allison | Chief Executive Officer and Chairman of the Board of Directors | 70 | ||
| Roland O. Burns | President, Chief Financial Officer, Secretary and Director | 65 | ||
| Daniel S. Harrison | Chief Operating Officer | 62 | ||
| Clifford "Trey" D. Newell | Chief Commercial Officer and Vice President of Corporate Development | 47 | ||
| Patrick H. McGough | Vice President of Operations | 45 | ||
| Ronald E. Mills | Vice President of Finance and Investor Relations | 53 | ||
| Daniel K. Presley | Vice President of Accounting, Controller and Treasurer | 65 | ||
| LaRae L. Sanders | Vice President of Land | 63 | ||
| Brian C. Claunch | Vice President of Financial Reporting | 51 | ||
| Elizabeth B. Davis | Director | 63 | ||
| Morris E. Foster | Director | 83 | ||
| Jim L. Turner | Director | 80 |
A brief biography of each person who serves as an executive officer or director follows below.
Executive Officers
M. Jay Allison has been our Chief Executive Officer since 1988. Mr. Allison was elected Chairman of the Board in 1997 and has been a director since 1987. From 1988 to 2013, Mr. Allison served as our President. From 1981 to 1987, he was a practicing oil and gas attorney with the firm of Lynch, Chappell & Alsup in Midland, Texas. He received B.B.A., M.S. and J.D. degrees from Baylor University in 1978, 1980 and 1981, respectively.
Roland O. Burns has been our President since 2013, Chief Financial Officer since 1990, Secretary since 1991 and a director since 1999. Mr. Burns served as our Senior Vice President from 1994 to 2013 and Treasurer from 1990 to 2013. From 1982 to 1990, Mr. Burns was employed by the public accounting firm, Arthur Andersen. During his tenure with Arthur Andersen, Mr. Burns worked primarily in the firm's oil and gas audit practice. Mr. Burns received B.A. and M.A. degrees from the University of Mississippi in 1982 and is a Certified Public Accountant.
Daniel S. Harrison has been our Chief Operating Officer since 2019 and served as Vice President of Operations since 2017. Mr. Harrison has been with us since 2008 and served in various engineering and operations management positions of increasing responsibility during that time. Prior to joining us, Mr. Harrison was an operations engineer at Cimarex Energy Company from 2005 to 2008. Prior to 2005, he worked in various petroleum engineering operations management positions for
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several independent oil and gas exploration and development companies. Mr. Harrison received a B.S. Degree in Petroleum Engineering from the Louisiana State University in 1985.
Clifford "Trey" D. Newell has been our Chief Commercial Officer and Vice President of Corporate Development since 2022. Mr. Newell has over two decades of experience in commercial, marketing and operations experience in the midstream energy industry. Prior to joining us, Mr. Newell was responsible for producer relationships, business development, project management, scheduling and marketing as Commercial Vice President at Trace Midstream, Blue Mountain Midstream and Penntex Midstream. He received his Bachelor of Business Administration in Economics and Pre-Law and Executive Master of Business Administration from Centenary College of Louisiana in 2006 and 2013, respectively. He also received his Master of Energy Business from the University of Tulsa in 2015.
Patrick H. McGough has been our Vice President of Operations since 2019 following our acquisition of Covey Park Energy, LLC. He joined Covey Park in August 2018 as the Vice President of Operations, where he was responsible for drilling, completion, and production operations and engineering. Prior to his time at Covey Park, Mr. McGough held significant roles as a drilling, completion, and production engineer at Brammer Engineering. Mr. McGough received a Bachelor of Science in Chemical Engineering from Louisiana Tech University in 2003 and an MBA from Centenary College of Louisiana in 2010.
Ronald E. Mills has been our Vice President of Finance and Investor Relations since 2019. Prior to joining us, Mr. Mills was an Equity Member and Senior Analyst responsible for covering exploration and production companies at Johnson Rice & Company LLC. Mr. Mills joined Johnson Rice in August 1995. Mr. Mills received a Bachelor of Arts in Economics and Master of Business Administration from Tulane University in 1994 and 1995, respectively.
Daniel K. Presley has been our Treasurer since 2013. Mr. Presley, who has been with us since 1989, also continues to serve as our Vice President of Accounting and Controller, positions he has had held since 1997 and 1991, respectively. Prior to joining us, Mr. Presley had six years of experience with several independent oil and gas companies including AmBrit Energy, Inc. Prior thereto, Mr. Presley spent two and one-half years with B.D.O. Seidman, a public accounting firm. Mr. Presley received a Bachelor of Business Administration degree from Texas A & M University in 1983.
LaRae L. Sanders has been our Vice President of Land since 2014. Ms. Sanders has been with us since 1995. She has served as Land Manager since 2007 and has been instrumental in all of our active development programs and major acquisitions. Prior to joining us, Ms. Sanders held positions with Bridge Oil Company and Kaiser-Francis Oil Company, as well as other independent exploration and production companies. Ms. Sanders is a Certified Professional Landman and became the nation's first Certified Professional Lease and Title Analyst in 1990.
Brian C. Claunch has been our Vice President of Financial Reporting since 2021. Mr. Claunch joined the Company in 2020 as Director of Financial Reporting. Prior to joining Comstock, Mr. Claunch served as Director of Financial Reporting at Guidon Energy and Controller at Pioneer Natural Resources Company. He received his Bachelor of Business Administration and Master of Science in Accounting degrees from the University of Texas at Arlington in 1999 and is a Certified Public Accountant.
Outside Directors
Elizabeth B. Davis has served as a director since 2014. Dr. Davis is currently the President of Furman University. Dr. Davis was the Executive Vice President and Provost for Baylor University until July 2014 and served as Interim Provost from 2008 until 2010. Prior to her appointment as Provost, she was a professor of accounting at the Hankamer School of Business at Baylor University where she also served as associate dean for undergraduate programs and as acting chair for the Department of Accounting and Business Law. Prior to joining Baylor University, she worked for the public accounting firm Arthur Andersen from 1984 to 1987.
Morris E. Foster has served as a director since 2017. Mr. Morris retired in 2008 as Vice President of ExxonMobil Corporation and President of ExxonMobil Production Company following more than 40 years of service with the ExxonMobil group. Mr. Foster served in a number of production engineering and management roles domestically as well as in the United Kingdom and Malaysia prior to his appointment in 1995 as a Senior Vice President in charge of the upstream business of Exxon Company, USA. In 1998, Mr. Foster was appointed President of Exxon Upstream Development Company and following the merger of Exxon and Mobil in 1999, he was named to the position of President of ExxonMobil Development Company. In 2004, Mr. Foster was named President of Exxon Mobil Production Company, the division responsible for ExxonMobil's upstream oil and gas exploration and production business, and a Vice President of ExxonMobil Corporation. Mr. Foster currently serves as Chairman of Stagecoach Properties Inc., a real estate holding corporation with properties in Salado, Houston
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and College Station, Texas and Carmel, California and as a member of the Board of Regents of Texas A&M University. In addition, Mr. Foster currently serves on the board of directors of Scott & White Medical Institute.
Jim L. Turner has served as a director since 2014. Mr. Turner currently serves as Chairman of Turner Holdings, LLC and CEO of JLT Automotive, Inc. Mr. Turner served as President and Chief Executive Officer of Dr Pepper/Seven Up Bottling Group, Inc. from its formation in 1999 through 2005, when he sold this interest in that company. Prior to that, Mr. Turner served as Owner/Chairman of the Board and Chief Executive Officer of the Turner Beverage Group, the largest privately owned independent bottler in the United States. Mr. Turner is past-Chairman and served on the Board of Trustees of Baylor Scott and White Health, the largest not-for-profit healthcare system in the State of Texas from 2013 through 2025, where he also served as Chairman of the Finance Committee and as a member of the Executive Committee. He is a past board member of Crown Holdings where he also served as Chairman of the Compensation Committee and as a member of the Nominating and Governance Committee. He is on the Board of Directors of INSURICA, a full-service insurance agency. Mr. Turner is former Chairman of Dean Foods Company where he also served as Chairman of the Compensation Committee and as a member of the Governance Committee.
Available Information
We file annual, quarterly and current reports, proxy statements and other documents with the SEC under the Securities Exchange Act of 1934. The SEC maintains a website that contains reports, proxy and information statements, and other information that is electronically filed with the SEC. The public can obtain any documents that we file with the SEC at www.sec.gov. We also make available free of charge on our website (www.comstockresources.com) our Annual Report on Form 10-K, quarterly reports on Form 10-Q, current reports on Form 8-K and, if applicable, amendments to those reports filed or furnished pursuant to Section 13(a) of the Exchange Act as soon as reasonably practicable after we file such material with, or furnish it to, the SEC.