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USD Partners

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FY2019 Annual Report · USD Partners
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UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 20549

x

ANNUAL REPORT PURSUANT TO SECTION 13 OR 15(d) OF THE

FORM 10-K

SECURITIES EXCHANGE ACT OF 1934
For the fiscal year ended December 31, 2019
or

☐ TRANSITION REPORT PURSUANT TO SECTION 13 OR 15(d) OF THE SECURITIES EXCHANGE ACT OF 1934

For the transition period from             to       

Commission file number 001-36674

USD PARTNERS LP
(Exact name of registrant as specified in its charter)

(State or other jurisdiction of incorporation or organization)

(I.R.S. Employer Identification No.)

Delaware

30-0831007

811 Main Street, Suite 2800
Houston, Texas 77002
(Address of principal executive offices) (Zip Code)
Registrant’s telephone number, including area code (281) 291-0510
Securities registered pursuant to Section 12(b) of the Act:

Title of each class

  Trading Symbol

  Name of each exchange on which registered

Common Units Representing Limited Partner
Interests

USDP

New York Stock Exchange

Securities registered pursuant to Section 12(g) of the Act: None
Indicate by check mark if the registrant is a well-known seasoned issuer, as defined in Rule 405 of the Securities Act. Yes ☐ No x
Indicate by check mark if the registrant is not required to file reports pursuant to Section 13 or Section 15(d) of the Act. Yes ☐ No x
Indicate by check mark whether the registrant (1) has filed all reports required to be filed by Section 13 or 15(d) of the Securities Exchange Act of 1934 during the preceding 12 months (or

for such shorter period that the registrant was required to file such reports), and (2) has been subject to such filing requirements for the past 90 days. Yes x No ☐   

Indicate by check mark whether the registrant has submitted electronically, if any, every Interactive Data File required to be submitted pursuant to Rule 405 of Regulation S-T (§ 232.405 of

this chapter) during the preceding 12 months (or for such shorter period that the registrant was required to submit such files). Yes x No ☐ 

Indicate by check mark whether the registrant is a large accelerated filer, an accelerated filer, a non-accelerated filer, a smaller reporting company, or an emerging growth company. See the

definitions of “large accelerated filer,” “accelerated filer,” “smaller reporting company,” and “emerging growth company” in Rule 12b-2 of the Exchange Act.

Large Accelerated Filer ☐

Non-Accelerated Filer ☐

Accelerated Filer x

Smaller reporting company x

Emerging growth company ☐

If an emerging growth company, indicate by check mark if the registrant has elected not to use the extended transition period for complying with any new or revised financial accounting

standards provided pursuant to Section 13(a) of the exchange Act. ☐

Indicate by check mark whether the registrant is a shell company (as defined in Rule 12b-2 of the Act). Yes ☐ No x
As of June 30, 2019,  the  last  business  day  of  the  registrant’s  most  recently  completed  second  fiscal  quarter,  the  aggregate  market  value  of  the  registrant’s  Common  Units  held  by  non-

affiliates was $158,543,748 computed by reference to the price at which the common equity was last sold, or the average bid and asked price of such common equity.

As of February 28, 2020, the registrant has outstanding 26,842,393 common units and 461,136 general partner units.

DOCUMENTS INCORPORATED BY REFERENCE: NONE

 
 
 
 
 
TABLE OF CONTENTS

PART I

Business

Risk Factors

Unresolved Staff Comments

Properties

Legal Proceedings

Mine Safety Disclosures

PART II

Market for Registrant’s Common Equity, Related Unitholder Matters and Issuer Purchases of Equity Securities

Selected Financial Data

Management’s Discussion and Analysis of Financial Condition and Results of Operations

Quantitative and Qualitative Disclosures About Market Risk

Financial Statements and Supplementary Data

Changes in and Disagreements with Accountants on Accounting and Financial Disclosure

Controls and Procedures

Other Information

PART III

Directors, Executive Officers and Corporate Governance

Executive Compensation

Security Ownership of Certain Beneficial Owners and Management and Related Stockholder Matters

Certain Relationships and Related Transactions, and Director Independence

Principal Accountant Fees and Services

PART IV

Exhibits and Financial Statement Schedules

Form 10-K Summary

Item 1.

Item 1A.

Item 1B.

Item 2.

Item 3.

Item 4.

Item 5.

Item 6.

Item 7.

Item 7A.

Item 8.

Item 9.

Item 9A.

Item 9B.

Item 10.

Item 11.

Item 12.

Item 13.

Item 14.

Item 15.

Item 16.

Exhibits

Signatures

Page

1

21

50

51

51

51

52

53

55

86

87

140

140

142

143

151

155

157

161

162

162

163

165

Unless the context otherwise requires, all references in this Annual Report on Form 10-K, or this “Annual Report” or this “Form 10-K” to “USD Partners,” “USDP,” “the Partnership,”

“we,” “our,” “us,” or like terms refer to USD Partners LP and its subsidiaries.

Unless the context otherwise requires, all references in this Annual Report to (i) “our general partner” refer to USD Partners GP LLC, a Delaware limited liability company; (ii) “USD” refers
to US Development Group, LLC, a Delaware limited liability company, and where the context requires, its subsidiaries; (iii) “USDG” and “our sponsor” refer to USD Group LLC, a Delaware
limited liability company and currently the sole direct subsidiary of USD; (iv) “Energy Capital Partners” refers to Energy Capital Partners III, LP and its parallel and co-investment funds and
related investment vehicles; and (v) “Goldman Sachs” refers to The Goldman Sachs Group, Inc. and its affiliates.

This  Annual  Report  includes  forward-looking  statements,  which  are  statements  that  frequently  use  words  such  as  “anticipate,”  “believe,”  “continue,”  “could,”  “estimate,”  “expect,”
“forecast,” “intend,” “may,” “plan,” “position,” “projection,” “should,” “strategy,” “target,” “will” and similar words. Although we believe that such forward-looking statements are reasonable
based on currently available information, such statements involve risks, uncertainties and assumptions and are not guarantees of performance. Future actions, conditions or events and future results
of operations may differ materially from those expressed in these forward-looking statements. Any forward-looking statement made by us in this Annual Report speaks only as of the date on which it
is made, and we undertake no obligation to publicly update any forward-looking statement. Many of the factors that will determine these results are beyond our ability to control or predict. Specific
factors that could cause actual results to differ from those in the forward-looking statements include: (1) changes in general economic conditions; (2) the effects of competition, in particular, by
pipelines  and  other  terminalling  facilities;  (3)  shut-downs  or  cutbacks  at  upstream  production  facilities,  refineries  or  other  related  businesses;  (4)  the  supply  of,  and  demand  for,  terminalling
services for crude oil and biofuels; (5) the price and availability of debt and equity financing; (6) actions by third parties, including customers, lenders and our sponsors; (7) hazards and operating
risks that may not be covered fully by insurance; (8) disruptions due to equipment interruption or failure at our facilities or third-party facilities on which our business is dependent; (9) natural
disasters, weather-related delays, casualty losses and other matters beyond our control; (10) changes in laws or regulations to which we are subject, including compliance with environmental and
operational safety regulations, that may increase our costs; and (11) our ability to successfully identify and finance acquisitions and other growth opportunities. For additional factors that may
affect results, see Item 1A. Risk Factors included elsewhere in this Annual Report and our subsequently filed Quarterly Reports on Form 10-Q, which are available to the public over the internet at
the website of the U.S. Securities and Exchange Commission, or SEC, (www.sec.gov) and at our website (www.usdpartners.com).

ii

 
 
 
 
 
 
 
 
 
 
 
 
The following abbreviations, acronyms and terms used in this Form 10-K are defined below:

Glossary

API Gravity

Bitumen

Diluent

  American Petroleum Institute Gravity

  A dense, highly viscous, petroleum-based hydrocarbon that is found in deposits such as oil sands

Refers  to  lighter  hydrocarbon  products  such  as  natural  gasoline  or  condensate  that  are  blended  with  heavy  crude  oil  to
allow for pipeline transportation of heavy crude oil

Diluent Recovery Unit

USD’s patented diluent recovery unit, or DRU, technology separates the diluent that has been added to raw bitumen in the
production process

DRUbit™

Ethanol

Heavy crude

Crude-by-rail

Legacy railcar

Manifest train

Oil sands

PADD III

Throughput

Unit train

DRUbit™ is crude oil or bitumen that has been returned to a more concentrated, viscous state that is classified as a non-
hazardous, non-flammable commodity when transported by rail in Canada

A  clear,  colorless,  flammable  oxygenated  liquid  typically  produced  chemically  from  ethylene,  or  biologically  from
fermentation of various sugars from carbohydrates found in agricultural crops and cellulosic residues from crops or wood,
which is used in the United States as a gasoline octane enhancer and oxygenate

A crude oil with a low API Gravity characterized by high relative density and viscosity. Heavy crude oils require greater
levels of processing to produce high value products such as gasoline and diesel

  The transportation of hydrocarbons, such as crude oil and ethanol, by rail, particularly through the use of unit trains

A Department of Transportation, or DOT, Specification 111 railcar that does not comply with the Association of American
Railroads (AAR) Casualty Prevention Circular (CPC) letter known as CPC-1232 which specifies requirements for railcars
built for the transportation of certain hazardous materials, including crude oil and ethanol

  Trains that are composed of mixed cargos and often stop at several destinations

Deposits of loose sand or partially consolidated sandstone that are saturated with highly viscous bitumen, such as those
found in Western Canada

Petroleum Administration for Defense District consisting of Alabama, Arkansas, Louisiana, Mississippi, New Mexico and
Texas

  The volume processed through a terminal or refinery

Refers to trains comprised of up to 120 railcars and are composed of one cargo shipped from one point of origin to one
destination

iii

 
 
 
 
 
 
 
 
 
Item 1. Business

OVERVIEW

PART I

We  are  a  fee-based,  growth-oriented  master  limited  partnership  formed  in  2014  by  US  Development  Group  LLC,  or  USD,  to  acquire,  develop  and
operate midstream infrastructure and complementary logistics solutions for crude oil, biofuels and other energy-related products. We generate substantially all
of  our  operating  cash  flows  from  multi-year,  take-or-pay  contracts  with  primarily  investment  grade  customers,  including  major  integrated  oil  companies,
refiners and marketers. Our network of crude oil terminals facilitates the transportation of heavy crude oil from Western Canada to key demand centers across
North America. Our operations include railcar loading and unloading, storage and blending in onsite tanks, inbound and outbound pipeline connectivity, truck
transloading, as well as other related logistics services. We also provide our customers with leased railcars and fleet services to facilitate the transportation of
liquid hydrocarbons and biofuels by rail.

We generally do not take ownership of the products that we handle nor do we receive any payments from our customers based on the value of such
products.  On  occasion  we  enter  into  buy-sell  arrangements  in  which  we  take  temporary  title  to  commodities  while  in  our  terminals.  We  expect  any  such
arrangements to be at fixed prices where we do not take commodity price exposure.

We believe rail will continue as an important transportation option for energy producers, refiners and marketers due to its unique advantages relative to
other  transportation  means.  Specifically,  rail  transportation  of  energy-related  products  provides  flexible  access  to  key  demand  centers  on  a  relatively  low
fixed-cost basis with faster physical delivery, while preserving the specific quality of customer products over long distances.

USD  Group  LLC,  or  USDG,  a  wholly-owned  subsidiary  of  USD  and  the  sole  owner  of  our  general  partner,  is  engaged  in  designing,  developing,
owning,  and  managing  large-scale  multi-modal  logistics  centers  and  energy-related  infrastructure  across  North  America.  USDG’s  solutions  create  flexible
market access for customers in significant growth areas and key demand centers, including Western Canada, the U.S. Gulf Coast and Mexico. Among other
projects, USDG is currently pursuing the development of a premier energy logistics terminal on the Houston Ship Channel with capacity for substantial tank
storage, multiple docks (including barge and deepwater), inbound and outbound pipeline connectivity, as well as a rail terminal with unit train capabilities.
USD is also pursuing long-term solutions to transport heavier grades of crude oil produced in Western Canada, which USD believes will maximize benefits to
producers, refiners and railroads, as discussed below. In January 2019, USDG completed an expansion project at the Partnership’s Hardisty terminal, also
referred to as Hardisty South, which added one and one-half 120-railcar unit trains of transloading capacity per day, or approximately 112,500 barrels per day,
or bpd, and is subject to our existing right of first offer.

The following table summarizes information about our current terminalling facility assets:

Terminal Name

Location

Hardisty terminal

Casper terminal

Stroud terminal

West Colton terminal

Alberta, Canada

Wyoming, U.S.

Oklahoma, U.S.

California, U.S.

Designed 
Capacity 
(Bpd)

~150,000 (1)

~105,000 (2)
~50,000 (3)
13,000

Commodity
Handled

Crude Oil

Crude Oil

Crude Oil

Ethanol

Primary
Customers
Producers/Refiners
/Marketers

Refiners

Producers

Refiners/Blenders

Terminal
Type 

Origination

Origination

Destination

Destination

(1) 

(2) 

Based on two 120-railcar unit trains comprised of 28,371 gallon (approximately 675.5 barrels, or bbls) railcars being loaded at 92% of volumetric capacity per day. Actual amount of crude
oil loading capacity may vary based on factors including the size of the unit trains, the size, type and volumetric capacity of the railcars utilized and the type and specifications of crude oil
loaded, among other factors.
Based on one 112-railcar unit train comprised of 28,371 gallon (approximately 675.5 bbls) railcars being loaded at 92% of volumetric capacity per day and up to 56 manifest railcars per day.
Actual amount of crude oil loading capacity may vary based on factors including the size of the unit train, the size, type and volumetric capacity of the railcars utilized and the type and
specifications of crude oil loaded, among other factors.

1

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
(3) 

Our  current  Stroud  terminal  capacity  of  approximately  50,000  Bpd  includes  pipeline  pumping  capacity  constraints  on  the  pipeline  that  is  utilized  to  move  crude  oil  between  our  Stroud
terminal storage tanks and third-party storage tanks at Cushing. With pump modifications, the 104-railcar unit train could unload up to 64,376 Bpd based on 28,371 gallon (approximately
675.5 bbls) railcars being unloaded at 92% of volumetric capacity per day. Actual amount of crude oil loading capacity may vary based on factors including the size of the unit train, the size,
type and volumetric capacity of the railcars utilized and the type and specifications of crude oil unloaded, among other factors.

We offer our terminalling services pursuant to multi-year, take-or-pay agreements with high quality, investment grade customers, which provides us with
a steady and reliable stream of cash flows. Our agreements typically range in term between three and five years and include renewal options. During 2019, we
successfully renewed and extended multiple agreements on a long-term basis at our rail terminals. As of December 31, 2019, the volume-weighted average
remaining contract life of our take-or-pay terminal service agreements was 3.1 years. Refer to the Business Segments section below for further information
regarding our customer contracts for each of our rail terminals.

In  addition  to  terminalling  services,  we  currently  provide  customers  with  leased  railcars  and  fleet  services  related  to  the  transportation  of  liquid
hydrocarbons and biofuels by rail on a multi-year, take-or-pay basis for periods ranging from five to nine years. In the aggregate, our master fleet services
agreements have a weighted-average remaining contract life of 2.3 years as of December 31, 2019.

One  of  our  key  strengths  is  our  relationship  with  our  sponsor,  USDG,  the  sole  direct  subsidiary  of  USD.  USD  was  among  the  first  companies  to
successfully develop the hydrocarbon-by-rail concept and has built or operated unit train-capable terminals with an aggregate capacity of over one million
bpd. Ten of these terminals were subsequently sold in multiple transactions for an aggregate sales price in excess of $740 million. From January 2006 through
December 2019, USD has loaded or handled through its terminal network a total of 302 million barrels, or MMbbls, of liquid hydrocarbons and biofuels.
USD also has a nationally recognized safety record with no reportable spills at any of its terminals since its inception, as defined by the U.S. Department of
Transportation, or DOT, Pipeline and Hazardous Materials Safety Administration, or PHMSA. USD is currently owned by Energy Capital Partners, Goldman
Sachs and certain of USD’s management team members.

In  September  2014,  Energy  Capital  Partners  made  a  significant  investment  in  USD  and  indicated  an  intention  to  invest  an  additional  $1.0  billion  of
equity  capital  in  USD,  subject  to  market  and  other  conditions,  to  support  future  growth  and  expansion  plans.  Energy  Capital  Partners,  together  with  its
affiliates  and  affiliated  funds,  is  a  private  equity  firm  with  over  $20.0  billion  in  capital  commitments  that  primarily  invests  in  North  America’s  energy
infrastructure. Energy Capital Partners has significant energy infrastructure, midstream, master limited partnership and financial expertise to complement its
investment in USD. To date, Energy Capital Partners and its affiliated funds have 50 investment platforms with investments in the power generation, electric
transmission, midstream and renewable sectors of the energy industry.

USD,  through  its  direct  ownership  of  USDG,  has  stated  that  it  intends  for  us  to  be  its  primary  growth  vehicle  in  North  America.  We  intend  to
strategically  expand  our  business  by  acquiring  energy-related  logistics  assets  related  to  the  storage  and  transportation  of  liquid  hydrocarbons  and  biofuels
from both USDG and third parties. We also intend to grow organically by opportunistically pursuing growth projects and enhancing the profitability of our
existing  assets.  We  believe  that  our  relationship  with  USD  and  its  successful  project  development  and  operating  history,  safety  track  record  and  industry
relationships provide us with many avenues to execute our growth strategy.

The following chart depicts a simplified organization and ownership structure as of December 31, 2019. The ownership percentages referred to below
illustrate the relationships among us, our general partner, USDG, USD, Energy Capital Partners and Goldman Sachs, and excludes 1,346,480 Phantom Units
outstanding under our Long-Term Incentive Plan at December 31, 2019.

2

3

BUSINESS STRATEGY

Our primary business objective is to continue increasing the quarterly cash distributions we make to our unitholders over time. We intend to accomplish

this objective by executing the following business strategies:

• Generate stable and predictable fee-based cash flows.    A substantial amount of the operating cash flow we expect to generate is attributable to
multi-year, take-or-pay agreements. We intend to continue to seek stable and predictable cash flows by extending the term of our agreements with
existing customers, as well as executing additional multi-year, take-or-pay agreements with existing and new customers across our terminal network.

• Pursue accretive acquisitions.    We intend to pursue strategic and accretive acquisitions of energy-related logistics assets related to the storage and
transportation of liquid hydrocarbons and biofuels from both USD and third parties. We regularly evaluate and monitor the marketplace to identify
acquisitions within our existing geographies and in new regions that may be pursued independently or jointly with USD.

• Pursue organic growth initiatives.    We intend to pursue organic growth opportunities and seek operational efficiencies that complement, optimize
or  improve  the  profitability  of  our  assets.  For  example,  our  Casper  terminal  includes  the  foundation  for  two  additional  storage  tanks,  which  if
constructed, may result in additional long-term volume commitments and cash flows.

• Maintain a conservative capital structure.    We intend to maintain a conservative capital structure which, when combined with our focus on stable,
fee-based cash flows, should afford us access to capital at a competitive cost. Consistent with our disciplined financial approach, we intend to fund
the capital required for expansion and acquisition projects through a balanced combination of equity and debt financing. We believe this approach
provides us the flexibility to effectively pursue accretive acquisitions and organic growth projects as they become available.

• Maintain safe, reliable and efficient operations.    We are committed to safe, efficient and reliable operations that comply with environmental and
safety  regulations.  We  strive  to  continually  improve  operating  performance  through  our  commitment  to  technologically-advanced  logistics  and
operations systems, employee training programs and other safety initiatives and programs with railroads, railcar producers and first responders. All
of our facilities currently meet or exceed applicable government safety regulations and are in compliance with recently enacted orders regarding the
movement of liquid hydrocarbons and biofuels by rail. We believe these objectives are integral to the success of our business as well as to our access
to growth opportunities.

BUSINESS SEGMENTS

We conduct our business through two distinct reporting segments: Terminalling services and Fleet services.

These  segments  have  unique  business  activities  that  require  different  operating  strategies.  For  information  relating  to  revenues  from  external
customers,  operating  income  and  total  assets  for  each  segment,  refer  to  Note  15.  Segment  Reporting of  our  consolidated  financial  statements  included  in
Item 8. Financial Statements and Supplementary Data of this Annual Report. For information relating to revenues from material customers, refer to Note 17.
Major  Customers  and  Concentration  of  Credit  Risk  of  our  consolidated  financial  statements  included  in  Item 8. Financial  Statements  and  Supplementary
Data of this Annual Report.

Terminalling services

The Terminalling services segment includes a network of strategically-located terminals that provide customers with railcar loading and/or unloading
capacity, as well as related logistics services, for crude oil and biofuels. These services are primarily provided under multi-year, take-or-pay agreements that
include minimum monthly commitment fees. We generally have no direct exposure to risks associated with fluctuating commodity prices, although changes
in crude oil prices could indirectly influence our activities and results of operations over the long term. We may on occasion enter into buy-sell and other
arrangements in which we take temporary title to commodities while held in our terminals. We expect any such agreements to be at fixed prices where we do
not take commodity price exposure.

4

Our Terminalling services business consists of the following operations:

Hardisty Terminal

Our Hardisty terminal, which commenced operations in June 2014, is an origination terminal where we load various grades of Canadian crude oil onto
railcars for transportation to end markets. Hardisty is one of the major crude oil hubs in North America and is an origination point for approximately 90% of
the export pipeline capacity to the United States. At the Partnership level, the Hardisty terminal can load up to two 120-railcar unit trains per day and consists
of  a  fixed  loading  rack  with  approximately  30  railcar  loading  positions,  a  unit  train  staging  area  and  loop  tracks  capable  of  holding  five  unit  trains
simultaneously.  The  terminal  is  also  equipped  with  an  onsite  vapor  management  system  that  allows  our  customers  to  minimize  hydrocarbon  loss  while
improving safety during the loading process. Our Hardisty terminal receives inbound deliveries of crude oil through a direct pipeline connection from Gibson
Energy Inc.’s, or Gibson’s, Hardisty storage terminal. Gibson is one of the largest independent midstream companies in Canada with 12 MMbbls of crude oil
storage facilities at Hardisty and another 1.5 MMbbls under construction, plus the greatest number of connections to inbound and outbound pipelines in the
Hardisty hub. Our Hardisty terminal’s strategic location and direct pipeline connection to substantial storage capacity provides efficient access to the major
producers in the region. Our Hardisty terminal is also connected to the Canadian Pacific Railway’s North Main Line, a high capacity line with the ability to
service key refining markets across North America.

We have a facilities connection agreement with Gibson under which Gibson operates and maintains a 24-inch diameter pipeline and related facilities
connecting Gibson’s storage terminal with our Hardisty terminal, which we operate and maintain. Gibson is responsible for transporting product through the
pipeline to our Hardisty terminal. This pipeline from Gibson’s storage terminal is the exclusive means by which our Hardisty terminal receives crude oil.
Subject to certain limited exceptions regarding manifest train facilities, our Hardisty terminal is also the exclusive means by which crude oil from Gibson’s
Hardisty storage terminal may be transported by rail. We remit pipeline fees to Gibson for the transportation of crude oil to the Hardisty terminal based on a
predetermined formula. The facilities connection agreement also gives Gibson a right of first refusal in the event of a sale of our Hardisty terminal to a third
party. The agreement will expire in 2034 unless renewed. Our and Gibson’s obligations under this facilities connection agreement may be suspended in the
case of a force majeure event. Additionally, the agreement may be terminated by the non-defaulting party in case of specified events of default.

Substantially all of the capacity at our Hardisty terminal is contracted under multi-year, take-or-pay terminal services agreements with five customers,
including  major  integrated  oil  companies,  refiners  and  marketers.  To  date,  we  have  renewed  and  extended  100%  of  the  capacity  at  our  Hardisty  terminal
through mid-2022, with 73% extended through mid-2023 with customers under multi-year take-or-pay agreements. Upon the successful completion of USD’s
Diluent Recovery Unit project discussed below, 32% of the Hardisty terminal’s capacity will be automatically extended through mid-2031.

Our terminal services agreements generally include automatic renewal provisions for periods up to one-year following the conclusion of the initial term
and will only terminate if written notice is given by either party within a specified time period before the end of the initial term or a renewal term. Most of our
terminal  services  agreements  contain  annual  inflation-based  rate  escalators  based  upon  the  consumer  price  index  of  either  Canada  or  Alberta.  If  a  force
majeure  event  occurs,  a  customer’s  obligation  to  pay  us  may  be  suspended,  in  which  case  the  length  of  the  contract  term  will  be  extended  by  the  same
duration as the force majeure event. We will not be liable for any losses of crude oil handled at our Hardisty terminal unless due to our negligence.

Under the terminal services agreements we have entered into with customers of our Hardisty terminal, our customers are obligated to pay the greater of
a minimum monthly commitment fee or a throughput fee based on the actual volume of crude oil loaded at our Hardisty terminal. If a customer loads fewer
unit trains or barrels than its allotted amount in any given month, that customer will receive a credit for up to 12 months, which may be used to offset fees on
throughput volumes in excess of its minimum monthly commitments in future periods, to the extent capacity is available for the excess volume.

5

Sponsor and USD’s Initiatives at Hardisty

USD’s Diluent Recovery Unit Project

USD is pursuing long-term solutions to transport heavier grades of crude oil produced in Western Canada, which USD believes will maximize benefits

to producers, refiners and railroads.

USD’s patented diluent recovery unit “DRU” technology separates the diluent that has been added to the raw bitumen in the production process which
meets  two  important  market  needs  –  it  returns  the  recovered  diluent  for  reuse  in  the  Alberta  market,  reducing  delivered  costs  for  diluent,  and  it  creates
DRUbit™, a proprietary heavy Canadian crude oil specifically designed for rail transportation. DRUbit™ is crude oil or bitumen that has been returned to a
more concentrated, viscous state that is classified as a non-hazardous, non-flammable commodity when transported by rail in Canada and the U.S. DRUbit™
is a market access solution that will satisfy demand for heavy Canadian crude oil on the U.S. Gulf Coast and in other markets at a cost that is economically
competitive to the crude oil that is transported by pipeline today.

USD and Gibson jointly announced in December 2019 an agreement to construct and operate a DRU near Hardisty, Alberta, Canada. A subsidiary of
ConocoPhillips has contracted to process 50,000 barrels per day of inlet bitumen blend through the DRU to be shipped by Canadian Pacific and Kansas City
Southern Railway Company to the U.S. Gulf Coast.

In  addition,  USD  is  constructing  a  new  destination  terminal  in  Port  Arthur,  Texas  for  the  DRUbit™  that  will  be  transloaded  at  the  Hardisty
origination terminal. The Port Arthur terminal will have the capability for rail unloading, barge dock loading and unloading, tank storage and blending and
will be pipeline connected to Phillips 66’s Beaumont Terminal, providing customers access to a large network of refining and marine facilities.

In February 2020, USD and Gibson jointly announced the receipt of all required regulatory approvals from the Government of Alberta to proceed
with the construction of a DRU. Additionally, USD and Gibson have finalized all required commercial agreements with a subsidiary of ConocoPhillips to
fully  underpin  and  sanction  the  construction  of  the  initial  phase  of  the  DRU  at  50,000  barrels  per  day  of  inlet  bitumen  blend  capacity  and  enable  rail
shipments of DRUbit™ to the U.S. Gulf Coast.

Construction of the DRU is expected to begin in April 2020, and the DRU could be placed into service later in the second quarter of 2021. USD and
Gibson are currently in commercial discussions with other potential producer and refiner customers to secure additional long-term, take-or-pay agreements to
support future expansions of capacity at the DRU.

A proposed sale or transfer by USD of its ownership interest in this project would be subject to our existing right of first offer.

Management  believes  that  the  successful  completion  of  USD’s  DRU  project  will  enhance  the  sustainability  and  quality  of  our  cash  flows  at  the
Partnership by significantly increasing the tenor of three terminalling services agreements at our Hardisty terminal through 2031. Expirations and renewals for
some  of  our  terminalling  services  agreements  at  our  Hardisty  and  Stroud  terminals  will  depend  on  whether  USD’s  DRU  project  will  be  successful.  For
instance,  with  respect  to  three  terminalling  services  agreements  at  our  Hardisty  terminal,  upon  the  successful  completion  and  commissioning  of  the  DRU
project,  all  three  terminalling  services  agreements  will  extend  through  mid-2031,  with  two-thirds  of  the  volume  commitment  for  one  of  these  agreements
terminating at the end of June 2022. If the DRU project is not completed, all three agreements at our Hardisty terminal will expire in June 2024 (rather than in
2031), with two-thirds of the volume commitment for one agreement expiring in June 2022.

 With respect to one terminalling services agreement at our Stroud terminal, if the DRU project has occurred prior to June 30, 2022, then the volume
commitment will be reduced by one-third of the current commitment from the day following the DRU conversion through June 30, 2022, at which point the
agreement will terminate and there will be no renewal period. If the DRU project has not occurred prior to June 30, 2022, the volume commitment will be
reduced  by  two-thirds  of  the  current  commitment  and  will  extend  through  June  30,  2024.  Management  believes  that  the  lower  utilization  at  the  Stroud
terminal as a result of successful completion of the DRU project will be short-term

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in nature and will allow the Partnership the opportunity to offer terminalling services to other customers in need of access to the numerous markets connected
to the Cushing oil hub.

Hardisty South Expansion

Pursuant  to  the  increased  market  demand  for  terminalling  services  at  Hardisty,  our  sponsor  completed  the  Hardisty  South  expansion  (“Hardisty
South”) in January 2019. The existing Hardisty terminal, which is owned by us, has designed capacity for two unit trains per day, or approximately 150,000
barrels per day. Hardisty South, which is owned by our sponsor, added one and one-half unit trains per day, or approximately 112,500 barrels per day, of
takeaway capacity to the terminal by modifying the existing loading rack and building additional infrastructure and trackage. We believe the Hardisty South
Expansion could present an attractive acquisition opportunity for us pursuant to our existing right of first offer with respect to midstream projects developed
by our sponsor.

Stroud Terminal

Our Stroud terminal, which we purchased in June 2017, is a crude oil destination terminal in Stroud, Oklahoma. We use the terminal to facilitate rail-to-
pipeline shipments of crude oil from our Hardisty terminal in Western Canada to the crude oil storage hub located in Cushing, Oklahoma. The Stroud terminal
includes 76-acres with current unit train unloading capacity of approximately 50,000 bpd, two onsite tanks with 140,000 barrels of capacity, one truck bay and
a 12-inch diameter, 17-mile pipeline with a direct connection to the crude oil storage hub in Cushing, Oklahoma. We have also secured 300,000 bbls of crude
oil tank storage at the Cushing hub to facilitate outbound shipments of crude oil from the Stroud terminal. Inbound product is delivered by the Stillwater
Central Rail, which handles deliveries from both the BNSF Railway, or BNSF, and the Union Pacific Railroad, or UP.

Concurrent  with  the  Stroud  acquisition,  we  entered  into  a  multi-year,  take-or-pay  terminalling  services  agreement  with  an  investment  grade  multi-
national energy company for the use of approximately 50% of the available capacity at the Stroud terminal. Our customer is obligated to pay a minimum
monthly commitment fee and can load an allotted number of barrels per month. If our customer loads fewer barrels than its allotted amount in any given
month, the customer will receive a credit for up to 12 months. This credit may be used to offset fees on throughput volumes in excess of our customer’s
minimum monthly commitments in future periods to the extent capacity is available for the excess volume. We will receive a per-barrel fee on any volumes
handled in excess of our customer’s allowed amount, to the extent the additional volume is not subject to the credit discussed above. Upon the successful
completion  of  USD’s  Diluent  Recovery  Unit  project  discussed  above,  our  Stroud  customer  will  have  the  right  to  terminate  their  agreement  at  our  Stroud
terminal in June 2022.

In addition, we entered into a Marketing Services Agreement, or MSA, in May 2017, with USD Marketing LLC, or USDM, a wholly-owned subsidiary
of USDG, whereby we granted USDM the right to market the capacity at the Stroud terminal in excess of the original capacity of our initial customer in
exchange for a nominal per barrel fee. USDM is obligated to fund any related capital costs associated with increasing the throughput or efficiency of the
terminal to handle additional throughput. Upon expiration of our contract with the initial Stroud customer in June 2020, the same marketing rights will apply
to  all  throughput  at  the  Stroud  terminal  in  excess  of  the  throughput  necessary  for  the  Stroud  terminal  to  generate  adjusted  earnings  before  interest,  taxes,
depreciation and amortization, or Adjusted EBITDA, that is at least equal to the average monthly Adjusted EBITDA derived from the initial Stroud customer
during the 12 months prior to expiration. We also granted USDG the right to develop other projects at the Stroud terminal in exchange for the payment to us
of market-based compensation for the use of our property for such development projects. Our sponsor is also evaluating a potential expansion of the Stroud
terminal to meet incremental demand. If successful, these efforts would provide us with cash flows incremental to those provided by our currently-contracted
capacity. Any such development projects would be wholly-owned by USDG and would be subject to our existing right of first offer with respect to midstream
projects they develop.

Casper Terminal

The Casper terminal, which we acquired in November 2015, is a crude oil storage, blending and railcar loading terminal located in Casper, Wyoming,
where the Express Pipeline from Western Canada (~280,000 bpd of capacity) interconnects with the Platte Pipeline to Wood River, Illinois (~145,000 bpd of
capacity).  The  Casper  terminal  currently  offers  six  storage  tanks  with  900,000  bbls  of  total  capacity,  unit  train-capable  railcar  loading  capacity  of
approximately

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100,000 bpd, as well as truck transloading capacity. The terminal’s approximately 300-acre footprint and modular design allow for the addition of a second
loading station and an additional 1.1 MMbbls of storage capacity with minimal disruption to existing operations and relatively low incremental capital costs.

Inbound crude oil is delivered to the Casper terminal primarily through our dedicated 24-inch diameter, six-mile direct pipeline connection from the
Express Pipeline, which provides our customers with access to multiple grades of Canadian crude oil. Additionally, the Casper terminal has a connection from
the Platte terminal, where it has access to other pipelines and can receive other grades of crude oil. The Casper terminal can also receive volumes through one
truck unloading station and is also equipped with one truck loading station. Inbound volumes are typically fed directly into the customer’s dedicated storage
tank(s), which enhances their ability to control the quality of the product from origin to end market. This also allows customers to blend multiple grades of
crude oil to optimize the economics associated with refining varying grades of crude oil.

Outbound crude oil from our Casper terminal is loaded onto railcars and is then transported to end markets by BNSF, in either manifest or unit train
shipments.  The  terminal’s  location  on  BNSF’s  main  line  offers  advantageous  transportation  costs  to  key  U.S.  refining  markets  where  several  customer-
preferred destinations are also served by BNSF. Shipping with a single Class 1 railroad reduces railroad switching fees and enables faster train turn-times,
thus  improving  railcar  fleet  utilization.  Additionally,  to  supplement  the  rail  loading  options  from  the  terminal,  we  constructed  an  outbound  pipeline
connection from the Casper Terminal to the nearby Platte Terminal located at the termination point of the Express pipeline that was placed into service in
December 2019.

In July 2019, Enbridge Inc. (“Enbridge”) announced a program to increase the capacity of the Express pipeline by up to an additional 50,000 bpd with
the use of drag reducing agent, or DRA, and pump stations. Enbridge anticipates that the additional capacity of 50,000 bpd will be placed into service in the
first half of 2020. We anticipate that some of the additional volumes resulting from the increased capacity on the Express pipeline could be delivered to our
Casper terminal, as we believe outbound pipeline connections from the Express pipeline and nearby terminals are at or near full capacity.

We provide service at the Casper terminal under terminalling services agreements with a high quality, investment grade multi-national customer and a
producer  customer.  The  multi-year  agreements  with  these  customers  contain  take-or-pay  terms  for  terminalling  and  storage  services  and  variable  fees
associated  with  actual  throughput  volumes  and  other  services.  Additionally,  we  may  on  occasion  utilize  our  available  storage  and  throughput  capacity  to
support our customers’ spot activity through buy-sell agreements that generate cash flows in addition to those provided by our multi-year agreements.

West Colton Terminal

Our  West  Colton  terminal,  completed  in  November  2009,  is  a  unit  train-capable  destination  terminal  that  can  transload  up  to  13,000  bpd  of  ethanol
received from producers by rail onto trucks to meet local demand in the San Bernardino and Riverside County-Inland Empire region of Southern California.
The West Colton terminal has 20 railcar offloading positions and three truck loading positions. Our terminal receives inbound deliveries exclusively by rail on
the UP high speed lines.

Due to corrosion concerns unique to biofuels such as ethanol, the long-haul transportation of biofuels by multi-product pipelines is less efficient and less
economical  than  transportation  by  rail.  We  believe  these  corrosion  concerns,  combined  with  the  proximity  of  our  terminals  to  local  demand  markets,
strategically position our terminal to benefit from anticipated changes in environmental and gasoline blending regulations that are expected to increase the use
of ethanol in the market for transportation fuel.

We receive fixed fees per gallon of ethanol transloaded at our terminal pursuant to a terminal services agreement with a subsidiary of an investment
grade  company.  Our  West  Colton  terminal  operates  under  a  minimum  monthly  commitment  fee  agreement  that  has  been  in  place  since  July  2009  and  is
terminable at any time by either party upon 150 days’ notice.

8

Fleet Services

We provide our customers with leased railcars and fleet services related to the transportation of liquid hydrocarbons and biofuels by rail on a multi-year,
take-or-pay  basis  under  master  fleet  services  agreements  for  initial  terms  ranging  from  five  to  nine  years.  We  do  not  own  any  railcars.  As  of
December 31, 2019, our fleet consisted of 1,683 railcars, which we leased from various railcar manufacturers and financial entities, including 1,308 coiled
and  insulated,  or  C&I,  railcars.  We  have  assigned  certain  payment  and  performance  obligations  under  the  leases  and  master  fleet  services  agreements  for
1,483 of the railcars to other parties, but we have retained certain rights and obligations with respect to the provision of fleet services regarding these railcars.
Substantially all of our current railcar fleet is dedicated to customers of our Hardisty terminal, including USDM. In the aggregate, our master fleet services
agreements have a weighted-average remaining contract life of 2.3 years as of December 31, 2019.

Under  the  master  fleet  services  agreements,  we  provide  customers  with  railcar-specific  fleet  services,  which  may  include,  among  other  things,  the
provision of relevant administrative and billing services, the repair and maintenance of railcars in accordance with standard industry practice and applicable
law, the management and tracking of the movement of railcars, the regulatory and administrative reporting and compliance as required in connection with the
movement of railcars, and the negotiation for and sourcing of railcars. Our customers typically pay us and our assignees monthly fees per railcar for these
services,  which  include  a  component  for  railcar  use  and  a  component  for  fleet  services.  The  master  fleet  services  agreements  will  expire  unless  notice  to
renew is provided by our customers.

All of our railcars currently in service were constructed in 2013 or later. The average age of our fleet currently in service is six years, as compared with
the estimated 50-year life associated with these types of railcars. We have partnered with leaders in the railcar supply industry, such as CIT Rail, Union Tank
Car Company and others. We believe that our relationships with these industry leaders enable us to obtain railcar market insight and to procure railcars for our
terminalling  customers  on  beneficial  terms,  with  shorter  lead  times  than  some  of  our  competitors.  Our  current  railcars  are  designed  at  a  minimum  to  be
compliant with all regulatory railcar standards currently in effect.

As of December 31, 2019, our railcar fleet consisted of a mix of 1,308 C&I railcars and 375 non-coiled, non-insulated railcars. Our C&I railcars can

reheat heavy viscous grades of crude oil, reducing the need to blend these heavier grades with diluents.

Historically we have assisted our customers with procuring railcars to facilitate their use of our terminalling services. Our wholly-owned subsidiary
USD Rail LP has entered into leases with third-party manufacturers of railcars and financial firms, which it has then leased to customers. Although we expect
to continue assisting our customers with obtaining railcars for their use transporting crude oil from our terminals, as our existing lease agreements expire, or
are otherwise terminated, we do not expect to enter into similar leasing arrangements in the future. Should market conditions change, we would potentially
assist with the procurement and management of railcars on behalf of our customers again in the future.

BENEFITS OF RAIL

The following benefits of rail have established, or have the potential to establish, rail as a preferred mode of transportation for crude oil, biofuels, and

other energy-related products:

Market access for areas without adequate pipeline transportation infrastructure. Certain producing regions, such as the Western Canadian oil sands,
have  concentrated  production  in  areas  without  adequate  existing  pipeline  takeaway  capacity.  The  extensive  existing  rail  infrastructure  network  provides
additional takeaway capacity for these producing regions and flexible access to multiple demand centers.

Faster deployment. Rail terminals can be constructed at a fraction of the time required to lay a long-haul pipeline, providing a timely solution to meet
new  and  evolving  market  demands.  Relative  to  rail,  new  pipeline  construction  faces  challenges  such  as  lengthier  build  times  and  more  extensive
environmental permitting processes, geographic constraints and, in some cases, the lack of required political and regulatory support.

Flexibility  to  deliver  to  different  end  markets.  Unlike  pipelines,  which  typically  transport  product  to  a  single  demand  market,  rail  offers  customers

access to many of the most advantageous demand centers throughout North

9

America, enabling producers and shippers to obtain competitive prices for their products and to retain the flexibility to determine the ultimate destination until
the time of transportation.

Comprehensive  solution  for  refiners.  Rail  provides  refiners  flexible  access  to  multiple  qualities  and  grades  of  crude  oil  (feedstock)  from  multiple
production  sources.  Additionally,  shipping  in  railcars  improves  the  customer’s  ability  to  preserve  the  specific  quality  of  the  product  over  long  distances
relative to pipelines.

Faster delivery to demand markets. Rail can transport energy-related products to end markets much faster than pipelines, trucks or waterborne tankers.
While a pipeline can take 30-45 days to transport crude oil to the Gulf Coast from Western Canada, unit trains can move crude oil along a similar path in
approximately nine days.

Reduced shipper commitment requirements. Whereas all of the pipeline transportation fee is typically subject to long-term shipper commitments, only a
portion of rail transportation costs require long-term shipper commitments (railroads have historically been contracted on a spot basis or only require partial
term commitments). Consequently, pipeline customers bear greater risk of shifts in regional price differentials and the location of demand markets.

Reduced shipper transportation cost. Rail provides shippers a competitive transportation option, particularly in situations where either (i) the amount
of  diluent  required  for  the  transportation  of  crude  oil  by  pipeline  is  high,  which  is  generally  the  case  for  production  from  the  Canadian  oil  sands,  or  (ii)
multiple modes of transportation are required to reach a particular end market.

RIGHT OF FIRST OFFER

In connection with our initial public offering, or IPO, we entered into an omnibus agreement with USD and USDG, or Omnibus Agreement, pursuant
to which we were granted a right of first offer on any midstream infrastructure assets that they may develop, construct, or acquire for a period of seven years
after the October 15, 2014, closing of our IPO. This right expires on October 15, 2021. Additional information about the Omnibus Agreement and the right of
first offer are included in Note 13. Transactions with Related Parties of our consolidated financial statements at  Part  II,  Item  8.  Financial  Statements  and
Supplementary Data of this Annual Report on Form 10-K.

We cannot assure you that USD will be able to develop or construct, or that we or USD will be able to acquire, any additional midstream infrastructure
projects. Among other things, the ability of USD to further develop the Hardisty and Stroud terminals, the DRU project, or any other project, and our ability
to acquire such projects, will depend upon USD’s and our ability to raise additional equity and debt financing. We are under no obligation to make any offer,
and  USD  and  USDG  are  under  no  obligation  to  accept  any  offer  we  make,  with  respect  to  any  asset  subject  to  our  right  of  first  offer.  Additionally,  the
approval of Energy Capital Partners is required for the sale of any assets by USD or its subsidiaries, including us (other than sales in the ordinary course of
business), acquisitions of securities of other entities that exceed specified materiality thresholds and any material unbudgeted expenditures or deviations from
our approved budgets. Energy Capital Partners may make these decisions free of any duty to us and our unitholders. This approval would be required for the
potential acquisition by us of any project to expand the Hardisty and Stroud terminals, as well as any other projects or assets that USD may develop or acquire
in the future or any third-party acquisition we may pursue independently or jointly with USD. Energy Capital Partners is under no obligation to approve any
such transaction. Please refer to the discussion under Item 10. Directors, Executive Officers and Corporate Governance—Special Approval Rights of Energy
Capital Partners regarding the rights of Energy Capital Partners. If we are unable to acquire any projects to expand the Hardisty and Stroud terminals from
USD,  such  expansions  may  compete  directly  with  our  existing  business  for  future  throughput  volumes,  which  may  impact  our  ability  to  enter  into  new
terminal services agreements, including with our existing customers, following the expiration of our existing agreements, or the terms thereof, and our ability
to compete for future spot volumes. Furthermore, cyclical changes in the demand for crude oil and other liquid hydrocarbons may cause USD, or us, to further
re-evaluate any future expansion projects, including expansion of the Hardisty and Stroud terminals.

COMPETITION 

The energy-related logistics infrastructure business is highly competitive. The ability to secure additional agreements for rail terminalling and railcar

fleet services is primarily based on the availability of alternative means of

10

transportation, primarily pipelines, as well as the reputation, efficiency, flexibility, location, market economics and reliability of the services provided and
pricing for those services.

Our crude oil terminals face competition from other logistics services providers, such as pipelines and other terminalling service providers. In addition,
our customers may also choose to construct or acquire their own terminals. If our customers choose to ship crude oil via alternative means, we may only
receive the minimum monthly commitment fees at our terminals and may be unable to renew, extend or replace customer agreements following expiration of
their terms. Our West Colton terminal business faces competition from other terminals and trucks that may be able to supply end-user markets with ethanol
and other biofuels on a more competitive basis due to terminal location, price, rail rates, versatility or services provided. The West Colton terminal is served
by the UP and competes directly with ethanol facilities in the Fontana, Carson and San Diego areas, which are served by the BNSF. A combination of rail
freight and trucking economics, which comprise the largest share of the value chain, make it very difficult to compete with other facilities in this market based
on terminalling throughput fees alone.

We believe that we are favorably positioned to compete in our industry due to the strategic location of our terminals, quality of service provided at our
terminals,  our  independent  strategy,  our  reputation  and  industry  relationships,  and  the  versatility  and  complementary  nature  of  our  services.  The
competitiveness of our service offerings could be significantly impacted by the entry of new competitors into the markets in which we operate. However, we
believe that significant barriers to entry exist in the energy-related logistics business. These barriers include significant costs and execution risk, a lengthy
permitting  and  development  cycle,  financing  challenges,  shortage  of  personnel  with  the  requisite  expertise,  and  a  finite  number  of  sites  suitable  for
development.

SEASONALITY

The amount of throughput at our terminals is affected by the level of supply and demand for crude oil, refined products and biofuels, as well as, to a
lesser  extent,  seasonality.  Demand  for  gasoline  is  generally  higher  during  the  summer  months  than  during  the  winter  months  due  to  seasonal  increases  in
highway  traffic  and  construction  work.  Production  in  Western  Canada  may  be  impeded  by  severe  winter  conditions  that  reduce  production  and  volumes.
However,  many  effects  of  seasonality  on  our  revenues  are  substantially  mitigated  due  to  our  terminal  service  agreements  with  our  customers  that  include
minimum  monthly  commitment  fees,  as  well  as  our  master  fleet  services  agreements  which  require  our  customers  to  pay  a  base  monthly  fee  per  railcar.
Furthermore, because there are multiple end markets for the crude oil and biofuels handled at our terminals, the effect of seasonality otherwise attributable to
one particular end market is mitigated.

IMPACT OF REGULATION

General

Our  operations  are  subject  to  complex  and  frequently-changing  federal,  state,  provincial  and  local  laws  and  regulations  regarding  the  protection  of
health, property and the environment, including laws and regulations that govern the handling and release of crude oil and other liquid hydrocarbon materials.
Compliance with existing and anticipated environmental and safety laws and regulations increases our overall cost of business, including our capital costs to
construct, maintain, operate, and upgrade equipment and facilities. While these laws and regulations may affect our maintenance capital expenditures and net
income, customers typically place additional value on utilizing established and reputable third-party providers to satisfy their terminalling and logistics needs.
As a result, we expect increased regulations to provide opportunities for us to increase our market share in relation to customer-owned operations or smaller
operators that lack an established track record of safety and environmental compliance.

Violations  of  environmental  or  safety  laws  or  regulations  can  result  in  the  imposition  of  significant  administrative,  civil  and  criminal  fines  and
penalties,  permit  modifications  or  revocations,  and  in  some  instances,  operational  interruptions  or  injunctions  banning  or  delaying  certain  activities.  We
believe our facilities are in substantial compliance with applicable environmental and safety laws and regulations. However, these laws and regulations are
subject to frequent change at the federal, state, provincial and local levels, and the legislative and regulatory trend has been to place increasingly stringent
limitations on activities that may affect the environment.

11

Our  operations  contain  risks  of  accidental  releases  into  the  environment,  such  as  releases  of  crude  oil,  ethanol  or  hazardous  substances  from  our
terminals.  To  the  extent  an  event  is  not  covered  by  our  insurance  policies,  such  accidental  releases  could  subject  us  to  substantial  liabilities  arising  from
environmental cleanup and restoration costs, claims made by neighboring landowners and other third parties for personal injury and property damage, and
fines or penalties for any related violations of environmental or safety laws or regulations.

Air Emissions

Our  operations  are  subject  to  and  affected  by  the  Clean  Air  Act,  or  CAA,  and  its  implementing  regulations,  as  well  as  comparable  state  and  local
statutes and regulations. Our operations are subject to the CAA’s permitting requirements and related emission control requirements relating to specific air
pollutants,  as  well  as  the  requirement  to  maintain  a  risk  management  program  to  help  prevent  accidental  releases  of  certain  regulated  substances.  We  are
currently  required  to  obtain  and  maintain  various  construction  and  operating  permits  under  the  CAA  and  have  incurred  capital  expenditures  to  maintain
compliance with all applicable federal and state laws regarding air emissions. We may, nonetheless, be required to incur additional capital expenditures in the
near future for the installation of certain air pollution control devices at our terminals when regulations change, when we add new equipment, or when we
modify our existing equipment. Our Canadian operations are similarly subject to federal and provincial air emission regulations.

Our  customers  are  also  subject  to,  and  similarly  affected  by,  environmental  regulations  restricting  air  emissions.  These  include  U.S.  and  Canadian
federal and state or provincial actions to develop programs for the reduction of greenhouse gas, or GHG, emissions such as proposals to create a cap-and-
trade system that would require companies to purchase carbon dioxide emission allowances for emissions at manufacturing facilities and emissions caused by
the use of the fuels sold. In addition, the U.S. Environmental Protection Agency, or EPA, and the federal Bureau of Land Management, or BLM, has begun to
regulate  emissions  of  carbon  dioxide  and  other  GHGs.  As  a  result  of  these  regulations,  our  customers  could  be  required  to  undertake  significant  capital
expenditures,  operate  at  reduced  levels,  and/or  pay  significant  penalties.  These  regulations’  impact  on  our  oil  and  natural  gas  exploration  and  production
customers could result in a decreased demand for the services that we provide. We are uncertain what our customers’ responses to these emerging issues will
be.  Those  responses  could  reduce  throughput  at  our  terminals,  as  well  as  impact  our  cash  flows  and  our  ability  to  make  distributions  or  satisfy  debt
obligations.

Climate Change

Following its December 2009 “endangerment finding” that GHG emissions pose a threat to public health and welfare, the Environmental Protection
Agency, or EPA, has begun to regulate GHG emissions under the authority granted to it by the federal CAA. Based on these findings, the EPA has adopted
regulations under existing provisions of the federal CAA that require Prevention of Significant Deterioration, or PSD, pre-construction permits and Title V
operating permits for GHG emissions from certain large stationary sources that already are potential major sources of certain principal, or criteria, pollutant
emissions.  Under  these  regulations,  facilities  required  to  obtain  PSD  permits  must  meet  “best  available  control  technology”  standards  for  their  GHG
emissions  established  by  the  states  or,  in  some  cases,  by  the  EPA  on  a  case-by-case  basis.  The  EPA  has  also  adopted  rules  requiring  the  monitoring  and
reporting  of  GHG  emissions  from  specified  sources  in  the  United  States,  including,  among  others,  certain  onshore  oil  and  natural  gas  processing  and
fractionating facilities and, starting in October 2015, onshore petroleum and natural gas gathering and boosting activities as well as natural gas transmission
pipelines. We believe we are in substantial compliance with all GHG emissions permitting and reporting requirements applicable to our operations.

In response to studies suggesting that emissions of CO2, methane and certain other gases may be contributing to warming of the Earth’s atmosphere,
over 190 countries, including the United States and Canada where we operate, committed to a legally binding treaty to reduce GHG emissions, the terms of
which were defined at the Paris climate conference in December 2015. The terms of the Paris treaty to reduce GHG emissions are to become effective in
2020. In June 2017, however, President Trump stated that the United States intends to withdraw from the Paris treaty, but may enter into a future international
agreement related to GHGs. In August 2017, the U.S. State Department officially informed the United Nations of its intent to withdraw from the Paris treaty
unless  it  renegotiated.  In  November  2019,  the  Trump  administration  formally  moved  to  exit  the  Paris  agreement  initiating  the  treaty  mandated  one-year
process at the end of which the United States can officially exit the agreement. The United States’ adherence to the exit process is uncertain and the terms on
which the United States may reenter the Paris treaty or a separately negotiated agreement

12

are unclear at this time. With regard to the oil and gas industry, it is unclear at this time what direction the government of the United States plans to take.
Increased costs associated with compliance with any future legislation or regulation of GHG emissions, if it occurs, may have a material adverse effect on our
results of operations, financial condition and cash flows. In addition, climate change legislation and regulations may result in increased costs not only for our
business but also for our customers, thereby potentially decreasing demand for our services. Decreased demand for our services may have a material adverse
effect on our results of operations, financial condition and cash flows. Finally, many scientists believe that increasing concentrations of GHGs in the Earth’s
atmosphere produce climate changes that can have significant physical effects, such as increased frequency and severity of storms, droughts and floods, as
well as other climatic events. If any such effects were to occur, it is uncertain if they would have an adverse effect on our financial condition and results of
operations.

Waste Management and Related Liabilities

To a large extent, the environmental laws and regulations affecting our operations relate to the release of hazardous substances or solid wastes into soils,
groundwater,  and  surface  water,  and  include  measures  to  control  pollution  of  the  environment.  These  laws  generally  regulate  the  generation,  storage,
treatment, transportation, and disposal of solid and hazardous waste. They also require corrective action, including investigation and remediation, at a facility
where such waste may have been released or disposed.

Site Remediation.    The federal Comprehensive Environmental Response, Compensation, and Liability Act, commonly referred to as CERCLA or the
Superfund  law,  and  comparable  state  laws  impose  liability  without  regard  to  fault  or  to  the  legality  of  the  original  conduct  on  certain  classes  of  persons
regarding the presence or release of a “hazardous substance” in (or into) the environment. Those persons include the former and present owner or operator of
the site where the release occurred and the transporters and generators of the hazardous substance found at the site. Under CERCLA, these persons may be
subject to joint and several liability for the costs of cleaning up the hazardous substances and for damages to natural resources. CERCLA also authorizes the
EPA and, in some instances, third parties, to act in response to threats to the public health or the environment and to seek to recover the costs they incur from
the responsible classes of persons. Claims filed for personal injury and property damage allegedly caused by hazardous substances or other pollutants released
into the environment are not uncommon from neighboring landowners and other third parties. Petroleum  products  are  typically  excluded  from  CERCLA’s
definition of “hazardous substances.” In the ordinary course of operating our business, we do not handle wastes that are designated as hazardous substances
and, as a result, we have limited exposure under CERCLA for all or part of the costs required to clean up sites at which hazardous substances have been
released into the environment. Costs for any such remedial actions, as well as any related claims, could have a material adverse effect on our maintenance
capital expenditures and operating expenses to the extent not covered by insurance. Canadian and provincial laws also impose liabilities for releases of certain
substances into the environment.  

We  currently  own  or  lease  properties  where  hydrocarbons  are  currently  handled  or  have  been  handled  for  many  years.  Although  we  have  utilized
operating and disposal practices that were standard in the industry at the time, petroleum hydrocarbons or other wastes may have been disposed of or released
on or under the properties owned or leased by us, or on or under other locations where these wastes have been taken for disposal. These properties and wastes
disposed  thereon  may  be  subject  to  CERCLA,  the  federal  Resource  Conservation  and  Recovery  Act,  as  amended,  or  RCRA,  and  comparable  state  and
Canadian federal and provincial laws and regulations. Under these laws and regulations, we could be required to remove or remediate previously disposed
wastes (including wastes disposed of or released by prior owners or operators), to clean up contaminated property (including contaminated groundwater), or
to perform remedial operations to prevent future contamination. We have not been identified by any state or federal agency as a Potentially Responsible Party
under CERCLA in connection with the transport and/or disposal of any waste products to third-party disposal sites. We maintain insurance of various types
with varying levels of coverage that we consider adequate under the circumstances to cover our operations and properties. Our insurance policies are subject
to deductibles and retention levels that we consider reasonable and not excessive. Consistent with insurance coverage generally available in the industry, in
certain circumstances our insurance policies provide limited coverage for losses or liabilities relating to certain pollution events, including gradual pollution
or sudden and accidental occurrences. 

Solid and Hazardous Wastes.    Our operations generate solid wastes, including some hazardous wastes, which are subject to the requirements of RCRA

and analogous state and Canadian federal and provincial laws that impose

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requirements on the handling, storage, treatment and disposal of hazardous wastes. Many of the wastes that we generate are not subject to the most stringent
requirements of RCRA because our operations generate primarily oil and gas wastes, which currently are excluded from consideration as RCRA hazardous
wastes. Specifically, RCRA excludes from the definition of hazardous waste produced waters and other wastes intrinsically associated with the exploration,
development, or production of crude oil and natural gas. However, these oil and gas exploration and production wastes may still be regulated under state solid
waste laws and regulations. Oil and gas wastes may be included as hazardous wastes under RCRA in the future, in which event our wastes as well as the
wastes  of  our  competitors  will  be  subject  to  more  rigorous  and  costly  disposal  requirements,  resulting  in  additional  capital  expenditures  or  operating
expenses.

Water

The Federal Water Pollution Control Act, as amended, also known as the Clean Water Act, or CWA, and analogous state and Canadian federal and
provincial laws impose restrictions and strict controls regarding the discharge of pollutants into navigable waters of the United States or into any type of water
body  in  Canada,  as  well  as  state  and  provincial  waters.  Federal,  state  and  provincial  regulatory  agencies  can  impose  administrative,  civil  and/or  criminal
penalties for non-compliance with discharge permits or other requirements of the CWA and comparable laws, in addition to requiring remedial action to clean
up such water body and surrounding land. In June 2015, the EPA revised the definition of “waters of the United States,” or WOTUS, in a manner which was
widely viewed as expanding the jurisdictional reach of all Clean Water Act programs. However, in September 2019 the EPA rescinded this rule and in January
2020 announced a revised rule clarifying the WOTUS definition. Litigation surrounding the repeal of the 2015 rule is ongoing and litigation over the new
revised rule is anticipated once the rule is published in the Federal Register.

The  Oil  Pollution  Act  of  1990,  or  OPA,  amended  certain  provisions  of  the  CWA,  as  they  relate  to  the  release  of  petroleum  products  into  navigable
waters. OPA subjects owners of facilities to strict, joint and potentially unlimited liability for containment and removal costs, natural resource damages, and
certain other consequences of an oil spill. These laws impose regulatory burdens on our operations. We believe that we are in substantial compliance with
applicable  OPA  requirements.  State  and  Canadian  federal  and  provincial  laws  also  impose  requirements  relating  to  the  prevention  of  oil  releases  and  the
remediation  of  areas  affected  by  releases  when  they  occur.  We  believe  that  we  are  in  substantial  compliance  with  all  such  federal,  state  and  Canadian
requirements.

Endangered Species Act

The Endangered Species Act restricts activities that may affect endangered species or their habitats. While some of our facilities are in areas that may
be designated as habitat for endangered species, we believe that we are in substantial compliance with the Endangered Species Act. However, the discovery of
previously unidentified endangered species could cause us to incur additional costs or become subject to operating restrictions or bans in the affected area.  

Rail Safety

We facilitate the transport of crude oil and related products by rail in the United States and Canada. We do not own or operate the railroads on which
crude  oil  carrying  railcars  are  transported;  however,  we  currently  lease  or  manage  a  large  railcar  fleet  on  behalf  of  our  customers.  Accordingly,  we  are
indirectly subject to regulations governing railcar design and manufacture, and increasingly stringent regulations pertaining to the shipment of crude oil by
rail.  

High-profile  accidents  involving  crude  oil  unit  trains  in  Quebec,  North  Dakota,  Virginia,  West  Virginia  and  Illinois  have  raised  concerns  about  the
environmental and safety risks associated with transporting crude oil by rail, and the associated risks arising from railcar design. In August 2013, the Federal
Railroad Administration, or FRA, issued both an Action Plan for Hazardous Materials Safety and an order imposing new standards on railroads for properly
securing rolling equipment. A proposed rule with regard to the latter was subsequently released in September 2014. In August 2013, the FRA and PHMSA
began conducting inspections of crude oil carrying railcars from the Bakken formation to make sure cargo is properly identified to railroads and emergency
responders.  In  February  2014,  the  DOT  and  transportation  industry  agreed  to  certain  voluntary  measures  designed  to  enhance  the  safety  of  crude  oil
shipments  by  rail,  which  include  lowering  speed  limits  for  crude  oil  trains  traveling  in  high-risk  areas,  modifying  routes  to  avoid  such  high-risk  areas,
increasing the frequency of track inspections, implementing improved braking mechanisms, and improving the training of certain emergency responders.

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In February 2014, as amended and restated in March 2014, the DOT issued another order, immediately requiring all carriers who transport crude oil
from the Bakken region by rail to ensure that the product is properly tested and classified in accordance with federal safety regulations, and further requiring
that all crude oil shipments be designated in the two highest risk categories, effectively mandating that crude oil be transported in more robust railcars. Any
person  failing  to  comply  with  the  order  is  subject  to  potential  civil  penalties  up  to  $175,000  for  each  violation  or  for  each  day  they  are  found  to  be  in
violation,  as  well  as  potential  criminal  prosecution.  Similarly,  in  February  2014,  the  Canadian  Department  of  Transport,  which  we  refer  to  as  Transport
Canada, finalized new regulations requiring shippers and carriers of crude oil by rail to properly sample, classify, certify and disclose certain characteristics of
the crude oil being shipped, and gave shippers and carriers six months to comply with these new regulatory procedures. In April 2014, the Canadian Minister
of  Transport,  who  oversees  Transport  Canada,  announced  a  series  of  directives  and  other  actions  to  address  the  Transportation  Safety  Board  of  Canada’s
initial recommendations on rail safety. Effective immediately, Transport Canada prohibited the least crash-resistant and non-upgraded or retrofitted DOT-111
railcars  from  carrying  dangerous  goods.  Additionally,  Transport  Canada  ordered  DOT-111  railcars  used  to  transport  crude  oil  and  ethanol  that  are  not
compliant  with  required  safety  standards  be  phased  out  or  retrofitted  by  May  2017.  Retrofitted  DOT-111  railcars  are  now  permitted  to  be  used  only  with
respect to certain packing groups until May 2025. We currently provide railcar services for 1,683 railcars, all of which are compliant with this Canadian safety
standard.

In May 2014, the DOT issued another order, immediately requiring railroads operating trains carrying more than one million gallons of Bakken crude
oil to notify State Emergency Response Commissions regarding the estimated volume, frequency, and transportation route of those shipments. Also in May
2014, the FRA and PHMSA issued a joint Safety Advisory to the rail industry advising those shipping or offering Bakken crude oil to use railcar designs with
the highest available level of integrity and to avoid using older legacy DOT-111 or CTC-111 railcars. In July 2014, Transport Canada adopted the CPC-1232
technical standards as the minimum safety threshold for railcars transporting dangerous goods after May 2017.

In  May  2015,  the  DOT,  in  coordination  with  Transport  Canada,  finalized  new  rail  safety  rules.  The  final  rule  includes  more  stringent  construction
standards  for  rail  tank  cars  constructed  after  October  1,  2015.  The  final  rule  also  creates  a  new  North  American  tank  car  standard  known  as  the  DOT
Specification 117 (DOT-117) with thicker steel and redesigned bottom outlet valves, among other improvements, over the DOT-111 tank car. U.S. crude oil
shippers had until January 1, 2018, to phase out or upgrade older DOT-111 tank cars, while Canadian shippers were required to phase DOT-111 cars out of
crude oil service by May 1, 2017. The rule also requires companies hauling crude in the U.S. or Canada to retrofit or phase out non-jacketed CPC-1232 tank
cars by April 1, 2020. In addition, the final rule includes mandates for using electronically controlled pneumatic braking systems and for performing routing
analyses and makes permanent the provisions of an emergency order issued by DOT in April 2015 imposing a speed limit of 40 miles per hour (mph) in high-
threat urban areas for crude oil trains containing at least one older-model tank car. The speed limit for all other crude-by-rail service will be restricted to 50
mph, in line with the speed limit railroads voluntarily adopted in 2013. The final rule requires offerors to develop and carry out sampling and testing programs
for all unrefined petroleum-based products, including crude oil, and to certify that hazardous materials subject to the program are packaged in accordance
with the test results, but does not require oil companies to process their products to make them less volatile before shipment.

In February 2019, PHMSA, in cooperation with the FRA, issued a Final Rule that requires railroads to develop and submit Comprehensive Oil Spill
Response Plans for route segments traveled by High Hazard Flammable Trains, or HHFTs. This new rule applies to HHFTs that are transporting crude oil in a
block of 20 or more loaded tank cars and trains that have a total of 35 loaded crude oil tank cars. It will require railroads to establish geographic response
zones with personnel and equipment ready to respond in the event of an accident. It will also require railroads to identify the qualified individual responsible
for each response zone, as well as the organization, personnel, and equipment capable of handling a worst-case discharge scenario. Lastly, it will require rail
carriers to provide information about HHFTs to state and tribal emergency response commissions in accordance with the FAST Act of 2015, Fixing America’s
Surface Transportation. The new regulations took effect on April 1, 2019. Railroads were required to submit response plans by August 27, 2019. PHMSA has
two years to review and comment on these plans.

On August 23, 2019, the Department of Energy and Sandia National Laboratory published a study that investigated whether Bakken crude presents a
unique  safety  hazard  due  to  explosions.  Sandia  National  Laboratory  performed  fire  experiments  to  compare  the  burn  rate,  surface  emissive  power,  flame
height, and heat flux to an engulfed object of

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different types of oil. The crude oil samples used for the experiments were obtained from several U.S. locations, including “tight” oils from the Bakken region
of North Dakota and Permian region of Texas, and a conventionally produced oil from the U.S. Strategic Petroleum Reserve stockpile. The results showed
that there is no material difference in the explosive characteristics or burn rates between the petroleum samples, and that the vapor pressure of Bakken crude
is not a statistically significant factor in affecting these outcomes. The maximum average surface emissive power for all crude oil samples were below the
Center for Chemical Process Safety (CCPS) recommendation to use a value of 350 kW/m2 for thermal hazard evaluation. Thus, the results from this work do
not support additional regulation of Bakken crude based on oil vapor pressure, which could have limited the ability to move Bakken crude via rail.

All  of  our  fleet  was  manufactured  in  2013  or  later  and  has  been  constructed  or  retrofitted  to  comply  with  the  DOT  117,  the  jacketed  CPC-1232
standard,  or  the  unjacketed  CPC-1232  standard.  As  of  December  31,  2019,  we  do  not  have  any  railcars  that  will  require  retrofitting  to  comply  with  the
jacketed  CPC-1232  rules  since  our  customers  have  informed  us  that  they  intend  to  use  these  railcars  for  transporting  diesel  fuel,  which  does  not  require
retrofitting. However, if the railcars require retrofitting due to the customers’ decision to use the railcars for transporting crude oil, as opposed to diesel fuel,
and if DOT were to adopt more strict specifications for tank cars, it would likely result in increased difficulty and costs to obtain compliant cars after the
applicable phase-out dates. While we might be able to pass some of these costs on to our customers, there might be additional costs that we cannot pass on to
our  customers.  We  are  continuously  monitoring  the  railcar  regulatory  landscape  and  remain  in  close  contact  with  railcar  suppliers  and  other  industry
stakeholders to stay informed of railcar regulation rulemaking developments. Given the current railcar design compliance requirements and timelines outlined
in the most recent Transport Canada and DOT rules, we do not anticipate a material impact to our ability to transport crude oil under our existing contracts. If
future rulemakings result in more stringent design requirements and compressed compliance timelines, then our ability to transport these volumes could be
affected by a delay in the railcar industry’s ability to provide adequate railcar modification repair services. We may not have access to a sufficient number of
compliant cars to transport the required volumes under our existing contracts. This may lead to a decrease in revenues and other consequences. DOT and
Transport  Canada  have  also  required  operators  to  take  certain  precautions  relating  to  rail  routing,  and  mandated  reductions  in  train  speed  and  the
implementation of new braking technology, to address rail safety concerns. On February 16, 2020, the Minister of Transport Canada announced that the speed
limit for key trains that carry 20 or more cars containing dangerous goods, such as petroleum crude oil, liquefied petroleum gas, gasoline and ethanol, is 35
mph in metropolitan areas and 40 mph in other areas where there are no track signals. For the high risk key trains, which are unit trains where tank cars are
loaded with a single dangerous goods commodity moving to the same point of destination or trains that include any combination of 80 or more tank cars
containing dangerous goods, the speed limit is 25 mph where there are no track signals and 30 mph for metropolitan areas unless it is in a non-signal territory
where the speed limit will be 25 mph. We do not expect that this new regulation will have an immediate impact on our results of operations. However, it could
reduce the number of train sets our customers are able to cycle through our Hardisty terminal, which may adversely affect the ability of our customers to meet
their minimum volume commitments. As a result, our customers may be unwilling to renew or extend their existing contracts at current volumes and rates.

 Certain of the railroads serving our terminals have in the past and are currently considering imposing tariffs, fees or other limitations on the utilization
of older railcar designs.  These tariffs, fees and limitations could have the effect of imposing limits on the use of railcars that are more stringent than current
regulatory standards, and could reduce the size of the overall railcar fleet available to be loaded at our terminals and increase the costs of obtaining usable
railcars.  Similar  to  other  industry  participants,  compliance  with  existing  and  any  additional  environmental  laws  and  regulations,  or  the  imposition  of
additional  tariffs,  fees  or  limitations  on  the  transportation  of  crude  oil  in  certain  railcars  or  all  railcars  by  the  railroads,  could  increase  our  overall  cost  of
business, including our capital costs to construct, maintain, operate and upgrade equipment and facilities, or the costs of our customers, which may reduce the
attractiveness  of  rail  transportation  and  limit  our  ability  to  extend  existing  agreements  or  attract  new  customers.  Our  master  fleet  services  agreements
generally obligate our customers to pay for modifications and other required repairs to our leased and managed railcar fleet. However, we cannot assure that
we will be able to successfully pass all such regulatory costs on to our customers.

The adoption of additional federal, state, provincial or local laws or regulations, including any voluntary measures by the rail industry regarding railcar
design or crude oil and liquid hydrocarbon rail transport activities, or efforts by local communities to restrict or limit rail traffic involving crude oil, could
affect  our  business  by  increasing  compliance  costs  and  decreasing  demand  for  our  services,  which  could  adversely  affect  our  financial  position  and  cash
flows.

16

Crude Oil Pipeline Safety

In connection with our acquisition of the Casper and Stroud terminals and related facilities, we became subject to regulation by the Federal Energy
Regulatory Commission, or FERC, the DOT through PHMSA, as well as other federal, state and local laws and regulations relating to the operation of our
dedicated crude oil pipelines, rates charged for transportation service, and protection of health, property and the environment. The transportation and storage
of crude oil and refined petroleum products involve a risk that hazardous liquids may be released into the environment, potentially causing harm to the public
or  the  environment.  In  turn,  such  incidents  may  result  in  substantial  expenditures  for  response  actions,  significant  government  penalties,  liability  to
government  agencies  for  natural  resources  damages,  and  significant  business  interruption.  DOT  has  adopted  safety  regulations  with  respect  to  the  design,
construction, operation, maintenance, inspection and management of our crude oil pipeline and related assets. These regulations contain requirements for the
development  and  implementation  of  pipeline  integrity  management  programs,  which  include  the  inspection  and  testing  of  pipelines  and  necessary
maintenance  or  repairs.  These  regulations  also  require  that  pipeline  operation  and  maintenance  personnel  meet  certain  qualifications  and  that  pipeline
operators develop comprehensive spill response plans.

We are subject to regulation by the DOT under the Hazardous Liquid Pipeline Safety Act of 1979, also known as the HLPSA. The HLPSA delegated to
DOT the authority to develop, prescribe, and enforce minimum federal safety standards for the transportation of hazardous liquids by pipeline. Congress also
enacted  the  Pipeline  Safety  Act  of  1992,  also  known  as  the  PSA,  which  added  the  environment  to  the  list  of  statutory  factors  that  must  be  considered  in
establishing safety standards for hazardous liquid pipelines, required that regulations be issued to define the term “gathering line” and that safety standards for
certain  “regulated  gathering  lines”  be  established,  and  mandated  that  regulations  be  issued  to  establish  criteria  for  operators  to  use  in  identifying  and
inspecting pipelines located in High Consequence Areas, or HCAs, defined as those areas that are unusually sensitive to environmental damage, that cross a
navigable waterway, or that have a high population density. In 1996, Congress enacted the Accountable Pipeline Safety and Partnership Act, also known as
the APSPA, which limited the operator identification requirement mandate to pipelines that cross a waterway where a substantial likelihood of commercial
navigation  exists,  required  that  certain  areas  where  a  pipeline  rupture  would  likely  cause  permanent  or  long-term  environmental  damage  be  considered  in
determining  whether  an  area  is  unusually  sensitive  to  environmental  damage,  and  mandated  that  regulations  be  issued  for  the  qualification  and  testing  of
certain  pipeline  personnel.  In  the  Pipeline  Inspection,  Protection,  Enforcement,  and  Safety  Act  of  2006,  also  known  as  the  PIPES  Act,  Congress  required
mandatory  inspections  for  certain  U.S.  crude  oil  and  natural  gas  transmission  pipelines  in  HCAs  and  mandated  that  regulations  be  issued  for  low-stress
hazardous liquid pipelines and pipeline control room management. We are also subject to the Pipeline Safety, Regulatory Certainty and Job Creation Act of
2011, which reauthorized funding for federal pipeline safety programs through 2015, increased penalties for safety violations, established additional safety
requirements for newly constructed pipelines, and required studies of certain safety issues that could result in the adoption of new regulatory requirements for
existing  pipelines.  The  Protecting  Our  Infrastructure  of  Pipelines  and  Enhancing  Safety  Act  of  2016  reauthorized  the  federal  pipeline  safety  programs  of
PHMSA through September, 2019. Congress is currently in the process of reauthorizing these safety programs.

PHMSA  administers  compliance  with  these  statutes  and  has  promulgated  comprehensive  safety  standards  and  regulations  for  the  transportation  of
hazardous liquids by pipeline, including regulations for the design and construction of new pipeline systems or those that have been relocated, replaced or
otherwise changed; pressure testing of new pipelines; operation and maintenance of pipeline systems, establishing programs for public awareness and damage
prevention, and managing the operation of pipeline control rooms; protection of steel pipelines from the adverse effects of internal and external corrosion; and
integrity management requirements for pipelines in HCAs. On January 13, 2017, PHMSA issued a final rule amending federal safety standards for hazardous
liquid  pipelines.  The  final  rule  is  the  latest  step  in  a  lengthy  rulemaking  process  that  began  in  2010  with  a  request  for  comments  and  continued  with
publication  of  a  rulemaking  proposal  in  October  2015.  The  general  effective  date  of  this  final  rule  was  to  be  six  months  from  publication  in  the  Federal
Register, but it was never sent to the Office of the Federal Register by the new Presidential administration, and was therefore effectively withdrawn. The final
rule addressed several areas including reporting requirements for gravity and unregulated gathering lines, inspections after weather or climatic events, leak
detection  system  requirements,  revisions  to  repair  criteria  and  other  integrity  management  revisions.  In  addition,  PHMSA  issued  new  regulations  on
January 23, 2017, on operator qualification, cost recovery, accident and incident notification and other pipeline safety changes. These new regulations were to
become  effective  March  24,  2017.  These  regulations  were  also  subject,  however,  to  further  review  in  connection  with  the  transition  of  Presidential
administrations. PHMSA

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released  its  final  safety  standards  for  hazardous  liquid  pipelines,  as  well  as  rules  for  gas  transmission  pipelines,  including  maximum  allowable  operating
pressure (MAOP) reconfirmation (for pipelines constructed before 1970) and records rules in September 2019, but the rules are not effective until July 1,
2020. Also in September 2019, PHMSA finalized enhanced emergency order procedures allowing the agency to issue an emergency order which may impose
emergency restrictions, prohibitions, or other safety measures on owners and operators of gas or hazardous liquid pipeline facilities.

We monitor the structural integrity of our pipeline system through a program of periodic internal assessments using high resolution internal inspection
tools, as well as hydrostatic testing and direct assessment that conforms to federal standards. We accompany these assessments with a review of the data and
repair anomalies, as required, to ensure the integrity of the pipeline. We then utilize sophisticated risk algorithms and a comprehensive data integration effort
to  ensure  that  the  greatest  risk  areas  receive  the  highest  priority  for  scheduling  subsequent  integrity  assessments.  We  use  external  coatings  and  impressed
current cathodic protection systems to protect against external corrosion. We conduct all cathodic protection work in accordance with National Association of
Corrosion Engineers standards. We continually monitor, test, and record the effectiveness of these corrosion inhibiting systems.

Crude Oil Pipeline Rate Regulation

The rates we charge for use of our dedicated crude oil pipeline are subject to regulation by various federal, state and local agencies. FERC regulates the
transportation of crude oil on our dedicated Casper and Stroud pipelines under the Interstate Commerce Act, or ICA, Energy Policy Act of 1992, or EPAct
1992, and the rules and regulations promulgated under those laws. FERC regulations require that rates charged by pipelines that provide transport services in
interstate or foreign commerce for crude oil and refined petroleum products (collectively referred to as “petroleum pipelines”) and certain other liquids be just
and reasonable, not unduly discriminatory, and not confer any undue preference upon any shipper. FERC regulations also require interstate common carrier
petroleum pipelines to file with FERC and publicly post tariffs stating their transportation rates and terms and conditions of service. Under the ICA, FERC or
interested persons may challenge existing or changed rates or services. FERC is authorized to investigate such charges and may suspend the effectiveness of a
new rate for up to seven months. A successful rate challenge could result in a common carrier paying refunds together with interest for the period that the rate
was in effect. FERC may also order a pipeline to change its rates and may require a common carrier to pay shippers reparations for damages sustained for a
period up to two years prior to the filing of a complaint.

EPAct 1992 required FERC to establish a simplified and generally applicable methodology to adjust tariff rates for inflation for interstate petroleum
pipelines.  As  a  result,  FERC  adopted  an  indexing  rate  methodology  which,  as  currently  in  effect,  allows  common  carriers  to  change  their  rates  within
prescribed  ceiling  levels  that  are  tied  to  changes  in  the  Producer  Price  Index  for  Finished  Goods,  or  PPIFG.  FERC’s  indexing  methodology  is  subject  to
review every five years. Beginning July 1, 2016, the indexing method provided for annual changes equal to the change in PPIFG plus 1.23%. The indexing
methodology is applicable to existing rates, including grandfathered rates, with the exclusion of market-based rates. A pipeline is not required to raise its rates
up to the index ceiling, but it is permitted to do so and rate increases made under the index are presumed to be just and reasonable unless a protesting party
can demonstrate that the portion of the rate increase resulting from application of the index is substantially in excess of the pipeline’s increase in costs. Under
the indexing rate methodology, in any year in which the index is negative, pipelines must file to lower their rates if those rates would otherwise be above the
rate ceiling. In October 2016, FERC issued an Advance Notice of Proposed Rulemaking seeking comment on a number of proposals, including: (1) whether
the Commission should deny any increase in a rate ceiling or annual index-based rate increase if a pipeline’s revenues exceed total costs by 15% for the prior
two years; (2) a new percentage comparison test that would deny a proposed increase to a pipeline’s rate or ceiling level greater than 5% above the barrel-mile
cost  changes;  and  (3)  a  requirement  that  all  pipelines  file  indexed  ceiling  levels  annually,  with  the  ceiling  levels  subject  to  challenge  and  restricting  the
pipeline’s ability to carry forward the full indexed increase to a future period. The comment period with respect to the proposed rules extended until March
17, 2017. The FERC has not taken any further action following the close of the comment period. While common carriers often use the indexing methodology
to change their rates, common carriers may elect to support proposed rates by using other methodologies such as cost-of-service ratemaking, market-based
rates, and settlement rates. A pipeline can follow a cost-of-service approach when seeking to increase its rates above the rate ceiling (or when seeking to avoid
lowering  rates  to  the  reduced  rate  ceiling).  A  common  carrier  can  charge  market-based  rates  if  it  establishes  that  it  lacks  significant  market  power  in  the
affected markets. In addition, a common carrier can establish rates under settlement if agreed upon by all current shippers. We have used settlement rates for
our dedicated crude oil

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pipelines. If we used cost-of-service rate making to establish or support our rates, the issue of the proper allowance for federal and state income taxes could
arise.

In July 2016, the United States Court of Appeals for the District of Columbia Circuit issued its opinion in United Airlines, Inc., et al. v. FERC, finding
that FERC had acted arbitrarily and capriciously when it failed to demonstrate that permitting an interstate petroleum products pipeline organized as a master
limited partnership, or MLP, to include an income tax allowance in the cost of service underlying its rates, in addition to the discounted cash flow return on
equity, would not result in the pipeline partnership owners double-recovering their income taxes. The court vacated FERC’s order and remanded to FERC to
consider mechanisms for demonstrating that there is no double recovery as a result of the income tax allowance. On December 23, 2016, FERC issued an
Inquiry Regarding the Commission’s Policy for Recovery of Income Tax Credits. On March 15, 2018, FERC issued a Revised Policy Statement on Treatment
of Income Taxes in which FERC found that an impermissible double recovery results from granting an MLP pipeline both an income tax allowance and a
return on equity pursuant to FERC’s discounted cash flow methodology. FERC revised its previous policy, stating that it would no longer permit an MLP
pipeline to recover an income tax allowance in its cost of service. FERC stated it will address the application of the United Airlines decision to non-MLP
partnership forms as those issues arise in subsequent proceedings. Further, FERC stated that it will incorporate the effects of the post-United Airlines policy
changes and the Tax Cuts and Jobs Act of 2017 on industry-wide crude oil pipeline costs in the 2020 five-year review of the crude oil pipeline index level.
FERC will also apply the revised Policy Statement and the Tax Cuts and Jobs Act of 2017 to initial crude oil pipeline cost-of-service rates and cost-of-service
rate changes on a going-forward basis under FERC’s existing ratemaking policies, including cost-of-service rate proceedings resulting from shipper-initiated
complaints. On July 18, 2018, FERC dismissed requests for rehearing and clarification of the March 15, 2018 Revised Policy Statement, but provided further
guidance, clarifying that a pass-through entity will not be precluded in a future proceeding from arguing and providing evidentiary support that it is entitled to
an income tax allowance and demonstrating that its recovery of an income tax allowance does not result in a double recovery of investors’ income tax costs.
Several parties have appealed the order to the United States Court of Appeals for the District of Columbia Circuit. The consolidated appeal is still pending.

Intrastate  services  provided  by  our  pipeline  are  subject  to  regulation  by  the  Wyoming  Public  Service  Commission.  This  state  commission  uses  a
complaint-based system of regulation, both as to matters involving rates and priority of access. The Wyoming Public Service Commission could limit our
ability to increase our rates or to set rates based on our costs or order us to reduce our rates and require the payment of refunds to shippers. FERC and state
regulatory  commissions  generally  have  not  investigated  rates,  unless  the  rates  are  the  subject  of  a  protest  or  a  complaint.  However,  FERC,  or  a  state
commission, could investigate our rates on its own initiative or at the urging of a third party.

If our rate levels were investigated by FERC or a state commission, the inquiry could result in a comparison of our rates to those charged by others or

to an investigation of our costs, including:

•

•

•

•

•

•

•

the overall cost of service, including operating costs and overhead;

the allocation of overhead and other administrative and general expenses to the regulated entity;

the appropriate capital structure to be utilized in calculating rates;

the appropriate rate of return on equity and interest rates on debt;

the rate base, including the proper starting rate base;

the throughput underlying the rate; and

the proper allowance for federal and state income taxes

If the FERC, or the Wyoming Public Service Commission, on their own initiative or due to challenges by third parties, were to lower our tariff rates or
deny  any  rate  increase  or  other  material  changes  to  the  types,  or  terms  and  conditions,  of  service  we  might  propose,  the  profitability  of  our  pipeline  and
terminals located in Casper, Wyoming and Stroud, Oklahoma, may suffer.

Employee Safety

We are subject to the requirements of the U.S. federal Occupational Safety and Health Act, or OSHA, and comparable state and Canadian federal and
provincial statutes that regulate the protection of the health and safety of workers. In addition, the OSHA hazard communication standard and the Canadian
Workplace Hazardous Materials

19

Information System, or WHMIS, require that information be maintained about hazardous materials used or produced in operations and that this information
be provided to employees, state and local government authorities and citizens. We believe that our operations are in substantial compliance with OSHA in the
United States and comparable state and Canadian federal and provincial requirements, including general industry standards, record keeping requirements, and
monitoring of occupational exposure to regulated substances.  

Security

While  we  are  not  currently  subject  to  governmental  standards  for  the  protection  of  computer-based  systems  and  technology  from  cyber  threats  and
attacks, proposals to establish such standards are being considered in the U.S. Congress and by U.S. Executive Branch departments and agencies, including
the  U.S.  Department  of  Homeland  Security,  or  DHS,  and  we  may  become  subject  to  such  standards  in  the  future.  We  have  implemented  our  own  cyber
security programs and protocols; however, we cannot guarantee their effectiveness. A significant cyber-attack could have a material effect on our operations
and those of our customers.

EMPLOYEES

We  are  managed  and  operated  by  the  board  of  directors  and  executive  officers  of  USD  Partners  GP  LLC,  our  general  partner.  Neither  we  nor  our
subsidiaries have any employees. Our general partner has the sole responsibility for providing the employees and other personnel necessary to conduct our
operations.  All  of  the  employees  that  conduct  our  business  are  employed  by  affiliates  of  our  general  partner.  Our  general  partner  and  its  affiliates  have
approximately 90 employees performing services for our operations. We believe that our general partner and its affiliates have a satisfactory relationship with
those employees.

INSURANCE

Our rail terminals, pipelines, storage tanks and railcars may experience damage as a result of an accident or natural disaster. These hazards can cause
personal  injury  and  loss  of  life,  severe  damage  to  and  destruction  of  property  and  equipment,  pollution  or  environmental  damage  and  suspension  of
operations.  We  maintain  insurance  and  are  insured  under  the  property,  business  interruption  and  liability  policies  of  USD  and  certain  of  its  subsidiaries,
subject to the deductibles and limits under those policies, which we consider to be reasonable and prudent under the circumstances to cover our operations
and assets. However, such insurance does not cover every potential risk associated with our assets, and we cannot ensure that such insurance will be adequate
to protect us from all material expenses related to potential future claims for personal and property damage, or that these levels of insurance will be available
in the future at commercially reasonable prices. Although we believe that our assets are adequately covered by insurance, a substantial uninsured loss could
have a material adverse effect on our financial position, results of operations and cash flows. As we grow, we will continue to monitor our policy limits and
retentions as they relate to the overall cost and scope of our insurance program.

AVAILABLE INFORMATION

We make available free of charge on or through our Internet website at www.usdpartners.com our Annual Reports on Form 10-K, Quarterly Reports on
Form 10-Q, Current Reports on Form 8-K and other information statements, and if applicable, amendments to those reports filed or furnished pursuant to
Section 13(a) of the Securities Exchange Act of 1934, as amended, or the Exchange Act, as soon as reasonably practicable after we electronically file such
material with the SEC. We intend to post information for public disclosure, in accordance with Regulation FD, on our website. Information contained on our
website is not part of this report.

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Item 1A. Risk Factors

You should carefully consider the risk factors below in connection with the other sections of this Annual Report. Realization of one or more of these
risk factors could have an adverse effect on our business, operating results, cash flows and financial condition, as well as the value of an investment in our
common units.

Risks Related to our Business

We  may  not  have  sufficient  cash  from  operations  following  the  establishment  of  cash  reserves  and  payment  of  fees  and  expenses,  including
reimbursements  to  our  general  partner,  to  enable  us  to  pay  the  minimum  quarterly  distribution,  or  any  distribution,  to  holders  of  our  common,
subordinated and general partner units. 

In order to pay the minimum quarterly distribution of $0.2875 per unit per quarter, or $1.15 per unit on an annualized basis, we require available cash of
$7.8  million  per  quarter,  or  $31.0  million  per  year,  based  on  the  number  of  common,  subordinated  and  general  partner  units  outstanding  at
December 31, 2019. We may not have sufficient available cash from operating surplus each quarter to enable us to pay the minimum quarterly distribution.
The amount of cash we can distribute on our units principally depends upon the amount of cash we generate from our operations, which will fluctuate from
quarter to quarter based on, among other things:

• our entitlement to minimum monthly payments associated with our take-or-pay terminal services agreements and the impact of credits for unutilized

contractual capacity;

• our ability to acquire new customers and retain existing customers;

• the rates and terminalling fees we charge for the volumes we handle;

• the volume of crude oil and other liquid hydrocarbons we handle;

• damage to terminals, railroads, pipelines, facilities, related equipment and surrounding properties caused by hurricanes, earthquakes, floods, fires,
severe  weather,  explosions  and  other  natural  disasters  and  acts  of  terrorism  including  damage  to  third-party  pipelines,  railroads  or  facilities  upon
which our customers rely for transportation services;

• leaks  or  accidental  releases  of  products  or  other  materials  into  the  environment,  including  explosions,  chemical  fumes  or  other  similar  events,

whether as a result of human error, natural disaster or otherwise;

• prevailing economic and market conditions; including low or volatile commodity prices and their effect on our customers;

• the level of our operating, maintenance and general and administrative costs;

• regulatory action affecting railcar design or the transportation of crude oil by rail;

• delays or increased costs caused by blockades or other interruptions in rail services; and

• the supply of, or demand for, crude oil and other liquid hydrocarbons.

In  addition,  the  actual  amount  of  cash  we  will  have  available  for  distribution  will  depend  on  other  factors,  some  of  which  are  beyond  our  control,

including:

• the level and timing of capital expenditures we make;

• the cost of acquisitions, if any;

• our debt service requirements and other liabilities;

• our requirements to pay distribution equivalents on phantom unit awards, or Phantom Units, pursuant to the terms of the USD Partners LP 2014

Amended and Restated Long-Term Incentive Plan, or A/R LTIP;

• fluctuations in our working capital needs;

• fluctuations in the values of foreign currencies in relation to the U.S. dollar, including the Canadian dollar;

• our ability to borrow funds and access capital markets;

• restrictions contained in our debt agreements;

• the amount of cash reserves established by our general partner; and

• other business risks affecting our cash levels.

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The amount of cash we have available for distribution to holders of our common units, subordinated units and general partner units depends primarily
on  our  cash  flow  rather  than  on  our  profitability,  which  may  prevent  us  from  making  distributions,  even  during  periods  in  which  we  record  net
income.  

The amount of cash we have available for distribution depends primarily upon our cash flow and not solely on profitability, which will be affected by
non-cash items. As a result, we may make cash distributions during periods when we record losses for financial accounting purposes and may not be able to
make cash distributions during periods when we record net earnings for financial accounting purposes.

Our contracts subject us to renewal risks.  

We provide terminalling services for liquid hydrocarbons and biofuels under contracts with terms of various durations and renewal. Of the six terminal
services agreements with customers of our Hardisty terminal, one agreement will expire at the end of June 2022, two agreements will expire at the end of
June 2023 and the remaining agreements could expire at the end of 2024, depending on the outcome of the USD’s DRU project. Our sole customer contract
for our West Colton terminal is terminable at any time by either party on 150 days’ notice. Of the three terminal services agreements with our Casper terminal
customers, one agreement expires in August 2021, one agreement expires in December 2021 and one agreement expires in December 2022. Our sole third-
party customer contract for our Stroud terminal expires in June 2024, but possibly in June 2022, depending on the outcome of USD’s DRU project.

Furthermore,  as  discussed  under  Item  1.  Business-Business  Segments-Sponsor  Initiatives  at  Hardisty-USD’s  Diluent  Recovery  Unit  Project,  with  its
patented diluent recovery unit “DRU” technology, USD is pursing long-term solutions to transport heavier grades of crude oil produced in Western Canada.
Expirations and renewals for some of our contracts at Hardisty terminal and Stroud terminal will depend on whether USD’s DRU project will be successful.
The completion of the DRU project is subject to risk associated with construction projects, including USD having sufficient financing, permits and approvals,
and the actions of third party construction personnel. USD is under no obligation to us to complete the DRU conversion or compensate us for lost revenue
under our contracts related to the status of the DRU project.

As these contracts expire, we will have to negotiate extensions or renewals with existing customers or enter into new contracts with other customers.
We may not be able to obtain new contracts on favorable commercial terms, if at all. We also may be unable to maintain the economic structure of a particular
contract with an existing customer or maintain the overall mix of our contract portfolio if, for example, prevailing crude oil prices and the associated spreads
between different grades of crude oil remain at levels, or decline below levels, where transportation of crude oil by rail is economic. Depending on prevailing
market  conditions  at  the  time  of  a  contract  renewal,  customers  with  fee-based  contracts  may  desire  to  enter  into  contracts  under  different  fee  or  term
arrangements or may seek to purchase such capacity on an uncommitted basis. To the extent we are unable to renew our existing contracts on terms that are
favorable  to  us  or  successfully  manage  our  overall  contract  mix  over  time,  or  replace  lost  revenue  upon  changes  in  contract  terms  (including  those  in
connection with the DRU project), our revenue and cash flows could decline and both our ability to make cash distributions to our unitholders and our ability
to remain in compliance with the covenants under our credit facility could be materially and adversely affected.

We depend on a limited number of customers for a significant portion of our revenues. The loss of, or material nonpayment or nonperformance by,
any one or more of these customers could adversely affect our ability to make cash distributions to our unitholders.

We generate the vast majority of our operating cash flow in connection with providing terminalling services at our crude oil terminals. Substantially all
of the capacity at our crude oil terminals is contracted under multi-year, take-or-pay terminal services agreements. A  continued  sustained  reduction  in  the
prices of crude oil and other commodities could have a material adverse effect on our customers’ businesses. In particular, oil sands production in Canada is
particularly susceptible to decline as a result of long-term reductions in the price of crude oil due to its relatively high production costs. As a result, some of
our customers may have material financial or liquidity issues or may, as a result of operational incidents or other events, be disproportionately affected as
compared to larger or better-capitalized companies. Any material nonpayment or nonperformance by any of our key customers could have a material adverse
effect on our business, financial condition, results of operations, and ability to make quarterly distributions to our unitholders. In addition, liquidity issues
resulting  from  sustained  lower  crude  oil  prices  could  lead  our  customers  to  go  into  bankruptcy  or  could  encourage  them  to  seek  to  repudiate,  cancel,
renegotiate or fail to renew their agreements with us for various reasons. We expect our exposure to concentrated risk of non-payment or non-performance to
continue as long as we remain substantially dependent on a relatively limited number of customers for a substantial portion of our revenue.

Additionally, the sole contract at our West Colton terminal is terminable at any time upon 150 days’ notice. If we were unable to renew our contract

with one or more of these customers, including customers at our Hardisty, Stroud or Casper

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terminals, on favorable terms, we may not be able to replace any of these customers in a timely fashion, on favorable terms or at all.

Any reduction in our or our customers’ ability to utilize third-party storage facilities, pipelines, railroads or trucks that interconnect with our terminals
or to continue utilizing them at current costs could negatively impact customer volumes and renewal rates at our terminals.  

We and the customers of our terminals are dependent upon access to third-party storage facilities, pipelines, railroads and truck fleets to receive and
deliver crude oil and other liquid hydrocarbons to or from us. The continuing operation of such third-party storage facilities, pipelines, railroads and other
midstream  facilities  or  assets  is  not  within  our  control.  Any  interruptions  or  reduction  in  the  capabilities  of  these  third  parties  due  to  testing,  line  repair,
reduced  operating  pressures,  or  other  causes  in  the  case  of  pipelines,  or  track  repairs,  derailments  or  other  causes,  in  the  case  of  railroads,  could  result  in
reduced volumes transported through our terminals.

We entered into a facilities connection agreement with Gibson whereby Gibson constructed a pipeline to provide our Hardisty terminal with exclusive
pipeline access to Gibson’s Hardisty storage terminal, which is the source of all of the crude oil handled by our Hardisty terminal. In addition, substantially all
of the crude oil handled by our Casper terminal has historically been sourced from the Express Pipeline. Our customer base is accordingly constrained by
customer access to Gibson’s Hardisty storage terminal in the case of our Hardisty terminal, and the Express Pipeline in the case of our Casper terminal. If our
existing customers don’t maintain their capacity with Gibson or Express, or in the case of our Casper terminal, our customers’ capacity allocations on the
Express pipeline are reduced by prorations due to the capacity demands of other shippers or other reasons, the volume shipped by our existing customers may
be reduced or our customers may choose not to renew their agreements with us at existing rates and volumes, if at all, which would have a material adverse
effect on our results of operations and ability to make quarterly distributions to our unitholders.

Similar  issues  could  arise  based  on  other  capacity  issues  arising  before  or  after  a  customer’s  products  reach  or  leave  our  terminals,  including  rail
capacity constraints and constraints at receiving terminals or other midstream facilities downstream of receiving terminals. For example, in the past, increase
in demand for utilization of our Hardisty terminal has been limited by the ability of the railroads to increase staffing to meet this demand. If the railroads are
unwilling  or  unable  to  meet  the  existing  and  potential  future  demand  for  our  terminals,  our  ability  to  retain  customers  or  grow  our  terminal  would  be
materially impacted.

We may not be able to compete effectively and our business is subject to the risk of a capacity overbuild of midstream infrastructure and the entrance
of new competitors in the areas where we operate.  

We face competition in all aspects of our business and can give no assurances that we will be able to compete effectively. Our terminals compete
with existing and potential new hydrocarbon by rail terminals, as well as alternative modes of transporting hydrocarbons from production centers to refining
or aggregation centers, such as existing and potential new crude oil pipelines and water-borne vessels. Our competitors include other midstream companies,
major  integrated  energy  companies,  independent  producers  and  refiners,  as  well  as  commodity  marketers  and  traders  of  widely  varying  sizes,  financial
resources  and  experience.  We  compete  on  the  basis  of  many  factors,  including  geographic  proximity  to  production  areas,  market  access,  rates,  terms  of
service, connection costs and other factors. Many of our competitors have access to capital resources significantly greater than ours. 

A significant driver of competition in some of the markets where we operate is the risk of development of new midstream infrastructure capacity driven
by  the  combination  of  (i)  significant  increases  in  oil  and  gas  production  and  development  in  the  particular  production  areas,  both  actual  and  anticipated,
(ii) low barriers to entry and (iii) generally widespread access to relatively low cost capital. This environment exposes us to the risk that these areas become
overbuilt, resulting in an excess of midstream infrastructure capacity. We face these risks in particular with respect to the potential development of additional
pipeline  takeaway  capacity  from  the  Canadian  oil  sands  region,  where  our  customers  source  the  majority  of  the  crude  oil  handled  at  our  terminals.  Most
midstream  projects  require  several  years  of  “lead  time”  to  develop  and  companies  like  us  that  develop  such  projects  are  exposed  (to  varying  degrees
depending on the contractual arrangements that underpin specific projects) to the risk that expectations for oil and gas development in the particular area may
not be realized or that too much capacity is developed relative to the demand for services that ultimately materializes. If we experience a significant capacity
overbuild in one or more of the areas where we operate, it could have a material adverse effect on our business, financial condition, results of operations, and
as a result, our ability to make distributions to our unitholders.

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The lack of diversification of our assets and geographic locations could adversely affect our ability to make distributions to our common unitholders.

We generate the vast majority of our operating cash flow in connection with providing terminalling services at our crude oil terminals, all of which
receive the majority of their crude oil from the Canadian oil sands through the Hardisty hub. Due to the lack of diversification in our assets and geographic
location, an adverse development in our businesses or areas of operations, especially to our crude oil terminals, including those due to catastrophic events,
weather, regulatory action or decreases in the price of, or demand for, crude oil, could have a significantly greater impact on our results of operations and
distributable  cash  flow  to  our  common  unitholders  than  if  we  maintained  more  diverse  assets  and  locations.  In  particular,  due  in  part  to  relatively  high
production costs, oil sands production in Canada may be particularly susceptible to decline as a result of long-term declines in the price of crude oil, which
could materially impact our ability to secure additional long-term customer contracts and renewals at our Hardisty terminal and our Casper terminal, and the
ability  of  USD  Group  LLC  to  contract  for  and  complete  expansions.  In  addition,  events  that  impact  the  supply  of  crude  oil  in  Western  Canada,  such  as
extreme weather, forest fires, and facility downtime, and events that increase the take-away capacity, such as the construction of new pipelines would have a
similar impact.

We do not own some of the land on which our terminals are located, which could disrupt our operations.  

We do not own all of the land on which our West Colton terminal is located, which land we obtained the right to use through leases from the Class I
railroad servicing this terminal. Our  ability  to  provide  comprehensive  services  to  our  customers  on  the  leased  land  depends  in  large  part  on  our  ability  to
maintain and extend these leases, which are currently cancellable at will by either party. We are therefore subject to the possibility of lease cancellation, more
onerous  terms  and/or  increased  costs  to  retain  the  land  necessary  to  operate  this  terminal.  Our  loss  of  these  rights,  through  our  inability  to  renew  or  the
unwillingness of the land owner to negotiate right-of-way contracts or leases, or otherwise, could cause us to cease operations on the affected land, incur costs
to dismantle and remove existing facilities, increase costs related to continuing operations elsewhere and reduce our revenue.

The  fees  charged  to  customers  under  our  agreements  with  them  for  the  transportation  of  crude  oil  may  not  escalate  sufficiently  or  at  all  to  cover
increases in costs, and the agreements may be temporarily suspended or terminated in some circumstances, which would affect our profitability. 

We generate the vast majority of our operating cash flow in connection with providing terminalling services at our crude oil terminals. A substantial
amount of the capacity at our crude oil terminals is contracted under multi-year, take-or-pay terminal services agreements, which, in the case of our Hardisty
and  Stroud  terminals,  are  subject  to  inflation-based  rate  escalators.  Some  of  the  terminal  services  agreements  at  our  Casper  terminal  are  not  subject  to
inflation-based  rate  escalators. Any  inflation-based  escalators  in  our  terminal  services  agreements  may  be  insufficient  to  compensate  for  increases  in  our
costs. Additionally, some customers’ obligations under their agreements with us may be temporarily suspended upon the occurrence of certain events, some
of which are beyond our control, or may be terminated in the case of uninterrupted force majeure events of over one year wherein the supply of crude oil is
curtailed or cut off. Force majeure events may include (but are not limited to) revolutions, wars, acts of enemies, embargoes, import or export restrictions,
strikes, lockouts, fires, storms, floods, acts of God, explosions, mechanical or physical failures of our equipment or facilities of our customers, or any cause or
causes  of  any  kind  or  character  (except  financial)  reasonably  beyond  the  control  of  the  party  failing  to  perform.  If  either  the  escalation  of  fees  under  the
terminal  services  agreements  at  our  terminals  is  insufficient  to  cover  increased  costs  or  if  any  customer  suspends  or  terminates  its  contracts  with  us,  our
profitability and ability to make quarterly distributions to our unitholders could be materially and adversely affected.

We  serve  customers  who  are  involved  in  drilling  for,  producing  and  transporting  crude  oil  and  other  liquid  hydrocarbons.  Adverse  developments
affecting the fossil fuel industry or drilling activity, including continuing low or further reduced prices of crude oil or biofuels, reduced demand for
crude  oil  products  and  increased  regulation  of  drilling,  production  or  transportation  could  cause  a  reduction  of  volumes  transported  through  our
terminals.

Our business, including our ability to grow our business through the contracting and development of new terminals, as well as our ability to secure
renewals or extensions of agreements with customers at our existing terminals, depends on the continued development, production and demand for crude oil
and other liquid hydrocarbons from our existing markets, as well as other areas unserved or underserved by existing alternative transportation solutions. The
willingness  of  exploration  and  production  companies  to  develop  and  produce  crude  oil  in  particular  producing  regions  in  Canada  and  the  United  States
depends largely on their ability to conduct these activities profitably, which in turn depends largely upon the markets for and prices of crude oil and other
commodities. A continued sustained reduction in the prices of crude oil and other commodities would have a material adverse effect on our business. The
factors impacting the prices of crude oil and other commodities

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include the supply of and demand for these commodities, which fluctuate with changes in market and economic conditions, and other factors, including:

• worldwide and regional economic conditions;

• worldwide and regional political events, including actions taken by foreign oil producing nations;

• worldwide and regional weather events and conditions, including natural disasters and seasonal changes that could decrease supply or demand;

• worldwide health events including the recent coronavirus outbreak;

•

•

•

•

•

•

•

•

•

•

•

•

•

•

•

•

the levels of domestic and international production and consumer demand;

the availability of transportation systems with adequate capacity;

fluctuations in demand for crude oil, such as those caused by refinery downtime or turnarounds;

fluctuations in the price of crude oil, which may have an impact on the spot prices for the transportation of crude oil by pipeline or railcar;

increased government regulation or prohibition of the transportation of hydrocarbons by rail;

the volatility and uncertainty of world crude oil prices as well as regional pricing differentials;

fluctuations in gasoline consumption;

the price and availability of alternative fuels;

changes in mandates to blend renewable fuels, such as ethanol, into petroleum fuels;

the price and availability of the raw materials used to produce ethanol, such as corn;

the effect of energy conservation measures, such as more efficient fuel economy standards for automobiles;

the  nature  and  extent  of  governmental  regulation  and  taxation,  including  the  amount  of  subsidies  for  ethanol  and  other  alternative  sources  of
energy;

fluctuations in demand from electric power generators and industrial customers;

expected political or regulatory changes that could restrict development or production of crude oil and other, liquid hydrocarbons;

a decline in investor sentiment regarding the oil and gas industry; and

the anticipated future prices of oil and other commodities.

The prices of crude oil and related products remain volatile and subject to the influence of many global factors, such as OPEC policy, the balance of
supply versus demand for those products in various markets and geopolitical risks. Our terminals primarily transport crude oil produced from the Canadian oil
sands,  which  are  considered  to  have  relatively  high  production  costs.  Exploration  and  production  companies  operating  in  the  Canadian  oil  sands  have
reduced, and may further reduce, capital spending for expansion projects designed to increase crude oil production. We expect that declines in crude oil prices
for a prolonged period of time may result in reductions in capital spending, which would likely decrease the likelihood that our existing customers would
renew their contracts with us at current prices or at all, reduce the opportunities for us to grow our assets and otherwise have a material adverse impact on our
business and results of operations.

 The  dangers  inherent  in  our  operations  could  cause  disruptions  and  expose  us  to  potentially  significant  losses,  costs  or  liabilities  and  reduce  our
liquidity. We are particularly vulnerable to disruptions in our operations because most of our terminalling operations are concentrated at the Hardisty,
Stroud and Casper terminals.  

Our operations are subject to significant hazards and risks inherent in transporting and storing crude oil, intermediate products and refined products.
These hazards and risks include, but are not limited to, natural disasters, fires, explosions, pipeline or railcar ruptures and spills, third-party interference and
mechanical  failure  of  equipment  at  our  terminals,  any  of  which  could  result  in  disruptions,  pollution,  personal  injury  or  wrongful  death  claims  and  other
damage to our properties and the property of others. There is also risk of mechanical failure and equipment shutdowns both in the normal course of operations
and following unforeseen events. Because the vast majority of our cash flow is generated from operations conducted at our crude oil terminals, any sustained
disruption at any of these terminals, the Gibson storage terminal, which is the source of all of the crude oil handled by our Hardisty terminal, the Express
pipeline, which is the primary source of the crude oil handled by the Casper terminal, or the Cushing hub and pipelines feeding into or out of the Cushing
hub, which is the destination of the crude oil handled by the Stroud terminal, would have a material adverse effect on our business, financial condition, results
of operations and cash flows and, as a result, our ability to make distributions to our unitholders. 

25

Some of our customers’ operations cross the U.S./Canada border and are subject to cross-border regulation.

Our customers’ cross border activities subject them to regulatory matters, including import and export licenses, tariffs, Canadian and U.S. customs and
tax issues and toxic substance certifications. Such regulations include the Short Supply Controls of the Export Administration Act, the North American Free
Trade Agreement (as well as its anticipated successor agreement, the U.S.-Mexico-Canada Agreement, which is still subject to approval by the respective
government of each of the three countries) and the Toxic Substances Control Act. Violations of these licensing, tariff and tax reporting requirements could
result in the imposition of significant administrative, civil and criminal penalties on our customers. Our revenue and cash flows could decline and our ability
to  make  cash  distributions  to  our  unitholders  could  be  materially  and  adversely  affected  should  our  customers  fail  to  comply  with  these  cross-border
regulations.

Changes in the provincial royalty rates and drilling incentive programs in Canada could decrease the oil and gas exploration and production activities
in Canada, which could adversely affect the demand for our terminalling services.

Certain provincial governments collect royalties on the production from lands owned by the government of Canada. These fiscal royalty regimes are
reviewed and adjusted from time to time by the respective provincial governments for appropriateness and competitiveness. Any increase in the royalty rates
assessed by, or any decrease in the drilling incentive programs offered by, a provincial government could negatively affect the drilling activity, which could
adversely affect the demand for our terminalling services.

Government regulation of oil production could have an adverse effect on our throughput volumes and distributable cash flow.

On December 3, 2018, the Alberta Government announced a temporary 8.7% cut (or a decrease of 325,000 barrels per day) in the production of raw
crude  oil  and  bitumen  at  facilities  subject  to  its  jurisdiction,  starting  on  January  1,  2019.  In  late  August  2019,  the  Alberta  Government  extended  the
curtailment  end  date  to  December  31,  2020,  with  possible  earlier  termination.  During  2019,  however,  the  Alberta  Government  increased  the  allowed
production levels. For example, in late October 2019, the Alberta Government announced a special production allowance, whereby effective November 8,
2019,  new  wells  drilled  for  conventional  oil  are  exempt  and,  beginning  with  the  December  2019  production  month,  producers  were  allowed  to  apply  to
produce above their curtailment order, as long as this extra production is shipped out of Alberta through additional rail capacity. Although such change in the
policy may increase demand for transloading services of our Hardisty terminal and Hardisty South, the Alberta Government’s curtailment policy may further
change in ways that can have a negative impact on our business. This and similar future actual or anticipated governmental restrictions on the production of
crude oil in the producing regions served by our terminals may cause our customers to reduce their production activities and delay or cancel new projects,
which could in turn reduce the demand for our terminalling services. Except to the extent of our take-or-pay type arrangements, reductions in demand for our
terminalling services resulting from governmentally imposed production cuts could reduce our cash flows and results of operations, and limit our ability to
execute new terminalling services contracts, or extend existing terminalling services contracts.

Exposure to currency exchange rate fluctuations will result in fluctuations in our cash flows and operating results.  

Currency exchange rate fluctuations could have an adverse effect on our results of operations. A substantial portion of the cash flows from our current
assets will be generated in Canadian dollars, but we intend to make distributions to our unitholders in U.S. dollars. As such, a portion of our distributable cash
flow  will  be  subject  to  currency  exchange  rate  fluctuations  between  U.S.  dollars  and  Canadian  dollars.  For  example,  if  the  Canadian  dollar  weakens
significantly, the corresponding distributable cash flow in U.S. dollars could be less than what is necessary to pay our minimum quarterly distribution.  

A  significant  strengthening  of  the  U.S.  dollar  relative  to  other  currencies  could  result  in  an  increase  in  our  financing  expenses  and  could  materially
affect  our  financial  results  under  generally  accepted  accounting  policies,  or  GAAP.  In  addition,  because  we  report  our  operating  results  in  U.S.  dollars,
changes  in  the  value  of  the  U.S.  dollar  also  result  in  fluctuations  in  our  reported  revenues  and  earnings.  In  addition,  under  GAAP,  all  foreign  currency-
denominated  monetary  assets  and  liabilities  such  as  cash  and  cash  equivalents,  accounts  receivable,  restricted  cash,  accounts  payable  and  capital  lease
obligations  are  revalued  and  reported  based  on  the  prevailing  exchange  rate  at  the  end  of  the  reporting  period.  This  revaluation  may  cause  us  to  report
significant non-monetary foreign currency exchange gains and losses in certain periods.

Increases in rail freight costs may adversely affect our results of operations.  

The  largest  component  of  a  shipment  of  crude  by  rail  is  the  rail  freight  transportation  costs.  Unlike  terminal  services  fees,  which  are  typically
established by multi-year contracts, railroad freight transportation has traditionally been purchased on a spot basis. Recently the railroads servicing some of
our terminals have begun to seek multi-year term agreements,

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which also increase costs to our customers to the extent not utilized. High spot rail freight costs from or to our terminals, or high term rates or long contract
terms,  may  make  the  shipment  of  crude  or  other  liquid  hydrocarbons  less  attractive  or  unattractive  to  our  customers  and  potential  customers.  In  addition,
transporters of hydrocarbons by rail compete with other parties, such as coal, grain and corn, which ship their product by rail. Demand for transportation of
crude or other products by rail is currently and has previously caused shortages in available locomotives and railroad crews. Such shortages may ultimately
increase the cost to transport hydrocarbons by rail. Additionally, diesel fuel costs generally fluctuate with increasing and decreasing world crude oil prices,
and accordingly are subject to political, economic and market factors that are outside of our control. Diesel fuel prices are a significant component of the costs
to our customers of shipping hydrocarbons by rail. Increased costs to ship hydrocarbons by rail could curtail demand for shipment of hydrocarbons by rail
which would have an adverse effect on our results of operations and cash flows and our ability to attract new customers and retain existing customers.

Our business could be adversely affected if service on the railroads is interrupted or if more stringent regulations are adopted regarding railcar design
or the transportation of crude oil by rail.  

We do not own or operate the railroads on which crude oil carrying railcars are transported; however, we do manage a railcar fleet that is subject to
regulations governing railcar design and manufacture. The volume of crude oil and liquid hydrocarbons transported in North America by rail has increased
substantially in recent years. High-profile accidents involving crude oil carrying trains in recent years, in conjunction with increased use of rail transportation,
have raised concerns about the environmental and safety risks associated with crude oil transport by rail and railcar design.

The DOT and Transport Canada released a series of directives and other actions to address rail safety concerns. Among the directives is a final rule
requiring that CPC-1232 railcars used to transport crude oil and ethanol that are not compliant with required safety standards be phased out or retrofitted as
early as April 1, 2020, with none in use after May 1, 2025. We currently provide railcar services for 1,683 railcars, 375 of which will still be under contract
and require retrofitting pursuant to this directive.  However, our customers have informed us that they intend to use these 375 railcars for transporting diesel
fuel, as opposed to crude oil, which would require retrofitting. While we do not foresee that these railcars will require retrofitting over the life of our lease or
that  these  leases  may  expire  before  the  regulatory  deadline,  certain  of  our  lease  agreements  may  permit  for  early  retrofit  of  the  railcars  and  will  require
retrofitting in the event that our customer decides to use these railcars to transport crude oil. We do not own any of the railcars in our railcar fleet and are not
directly responsible for costs associated with the retrofitting of CPC-1232 railcars. However, costs associated with the retrofitting of railcars would increase
the incremental monthly cost of the applicable railcar lease, which cost we may not always be able to pass through to our customers and could affect demand
for our services. The timing of retrofits to the railcars we manage could disrupt our operations particularly if we are unable to work with our railcar suppliers
on modification scheduling that avoids major disruptions.

Certain of the railroads serving our terminals have in the past and are currently considering imposing tariffs, fees or other limitations on the utilization
of older railcar designs.  These tariffs, fees and limitations could have the effect of imposing limits on the use of railcars that are more stringent than current
regulatory standards, and could reduce the size of the overall railcar fleet available to be loaded at our terminals and increase the costs of obtaining usable
railcars.  Similar  to  other  industry  participants,  compliance  with  existing  and  any  additional  environmental  laws  and  regulations,  or  the  imposition  of
additional  tariffs,  fees  or  limitations  on  the  transportation  of  crude  oil  in  certain  railcars  or  all  railcars  by  the  railroads,  could  increase  our  overall  cost  of
business, including our capital costs to construct, maintain, operate and upgrade equipment and facilities, or the costs of our customers, which may reduce the
attractiveness  of  rail  transportation  and  limit  our  ability  to  extend  existing  agreements  or  attract  new  customers.  Our  master  fleet  services  agreements
generally obligate our customers to pay for modifications and other required repairs to our leased and managed railcar fleet. However, we cannot assure that
we will be able to successfully pass all such regulatory costs on to our customers.

DOT and Transport Canada have also required operators to take certain precautions relating to rail routing, and mandated reductions in train speed and
the  implementation  of  new  braking  technology,  to  address  rail  safety  concerns.  The  recent  changes  to  U.S.  and  Canadian  regulations  and  the  adoption  of
additional federal, state, provincial or local laws or regulations, including any additional voluntary measures by the rail industry regarding railcar design or
crude oil and liquid hydrocarbon rail transport activities, or efforts by local communities to restrict or limit rail traffic involving crude oil, could affect our
business  by  increasing  compliance  costs  and  decreasing  demand  for  our  services,  which  could  adversely  affect  our  financial  position  and  cash  flows.
Moreover,  any  disruptions  in  the  operations  of  railroads,  including  those  due  to  shortages  of  railcars  or  qualified  personnel,  weather-related  problems,
flooding, drought, accidents, mechanical difficulties, strikes, lockouts or bottlenecks, could adversely impact our customers’ ability to move their products
and, as a result, could affect our business.

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We may be subject to liability or expense in connection with the use of our railcars by our customers.

We  lease  an  aggregate  of  1,683  railcars  from  various  railcar  manufacturers  and  financial  entities  and  we  provide  these  railcars  to  our  customers
pursuant  to  master  fleet  services  agreements.  We  have  assigned  certain  payment  and  performance  obligations  under  the  leases  and  master  fleet  services
agreements for 1,483 of these railcars to other parties, but have retained certain rights and obligations with respect to the servicing of these railcars. Although
our customers are generally responsible for the use, maintenance and condition of the railcars subject to their master fleet services agreements with us, we,
and not our customers, are directly responsible to our lessors. In the event that our lessors seek to recover any costs at lease expiration resulting from the
condition of the railcars, they will primarily look to us to recoup these amounts. Although our customers have generally agreed to be responsible for any costs
we incur as a result of their use of our railcars, our customers may deny culpability for any specific costs. In the event that we are unable to resolve disputes
related  to  return  costs  with  our  lessors  and  our  customers,  we  may  be  obligated  to  pay  the  associated  costs  ourselves  or  the  disputes  may  result  in  legal
proceedings. Any  such  legal  proceedings  may  be  costly  and  we  may  not  be  able  to  recover  our  costs  of  participation  in  such  proceedings  from  either  the
lessors or our customers. In addition, in the event that any such legal proceeding results in a judgment against us that is not reimbursable by our customer,
such judgment could result in material costs for us. Finally, as the lessee of our railcars, we may be named in any legal proceedings related to any damage to
third  parties  or  the  environment  caused  by  the  use  of  our  railcars  by  our  customers.  In  the  event  that  we  are  unable  to  obtain  indemnification  from  our
customers as a result of such potential claims, we may incur material costs and liabilities. Any costs or liabilities resulting from our customers’ use of our
railcars could have a material adverse effect on our business, financial condition, results of operations and cash flows and, as a result, our ability to make
distributions.

Changes  in,  or  challenges  to,  our  pipeline  rates  and  other  terms  and  conditions  of  service  could  have  a  material  adverse  effect  on  our  financial
condition and results of operations.

Our  dedicated  crude  oil  pipelines,  CCR  Pipeline  and  SCT  Pipeline,  are  subject  to  regulation  by  various  federal,  state  and  local  agencies.  FERC
regulates the interstate transportation services provided on these pipelines under the ICA, the EPAct 1992 and the rules and regulations promulgated under
those laws. FERC regulations require that rates for interstate service on pipelines that transport crude oil and refined petroleum products (collectively referred
to as “petroleum pipelines”) and certain other liquids be just and reasonable, not be unduly discriminatory and not confer any undue preference upon any
shipper.  FERC  regulations  also  require  interstate  common  carrier  petroleum  pipelines  to  file  with  FERC  and  publicly  post  tariffs  stating  their  interstate
transportation rates and terms and conditions of service. Under the ICA, FERC or interested persons may challenge existing or changed rates or services.
FERC is authorized to investigate such changes and may suspend the effectiveness of a new rate upon its filing for up to seven months. A successful rate
challenge could result in a common carrier paying refunds together with interest for the period during which the challenged rate was in effect. FERC may also
order a pipeline to change its rates, and may require a common carrier to pay shippers reparations for damages sustained for a period up to two years prior to
the filing of a complaint.

Intrastate  transportation  services  provided  by  CCR  Pipeline,  the  crude  oil  pipelines  serving  our  Casper  Terminal,  are  subject  to  regulation  by  the
Wyoming Public Service Commission. The Wyoming Public Service Commission uses a complaint-based system of regulation, both as to matters involving
rates and priority of access. In response to a complaint, the Wyoming Public Service Commission could limit our ability to increase our rates or to set rates
based on our costs or order us to reduce our rates and require the payment of refunds to shippers. If we were to provide intrastate transportation services
through  our  SCT  Pipeline,  the  crude  oil  pipeline  serving  our  Stroud  terminal,  we  could  elect  to  file  a  tariff  covering  such  services  with  the  Oklahoma
Corporation  Commission,  which  does  not  require  such  filings  and  does  not  regulate  intrastate  crude  oil  pipeline  rates  but  does  make  filed  pipeline  tariffs
available for public viewing.

FERC and state regulatory commissions generally have not investigated petroleum pipeline rates unless the rates are the subject of a shipper protest or
a complaint. However, FERC or the Wyoming Public Service Commission could investigate our rates on their own initiative or at the urging of a third party.
If  FERC  or  the  Wyoming  Public  Service  Commission  were  to  direct  us  to  lower  our  tariff  rates  or  decline  to  permit  any  proposed  rate  increase  or  other
material changes to the types, or terms and conditions, of service we might propose, the profitability of our CCR Pipeline and terminal located in Casper,
Wyoming,  or  of  our  SCT  Pipeline  and  terminal  located  in  Stroud,  Oklahoma,  could  suffer.    In  addition,  if  we  were  permitted  to  raise  our  tariff  rates  for
services  provided  through  the  CCR  Pipeline  or  SCT  Pipeline  but  the  rate  increase  was  suspended  for  the  maximum  statutory  period,  there  might  be  a
significant delay between the time the tariff rate increase is approved and the time that the rate increase actually goes into effect, which could adversely affect
our cash flow.  Furthermore, competition from other pipelines and terminals may prevent us from raising our tariff rates even if FERC or the Wyoming Public
Service Commission permits us to do so.

FERC and the Wyoming Public Service Commission periodically implement new rules, regulations and policies that can have a bearing on petroleum

pipeline rates and terms and conditions of service.  New initiatives or orders may adversely

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affect the rates charged for our services or otherwise adversely affect our financial condition, results of operations and cash flows and our ability to make cash
distributions to our unitholders.

Restrictions  in  our  senior  secured  credit  agreement  could  adversely  affect  our  business,  financial  condition,  results  of  operations,  ability  to  make
distributions to unitholders and value of our common units.  

We are dependent upon the earnings and cash flow generated by our operations in order to meet our debt service obligations under our senior secured
credit agreement and to allow us to make cash distributions to our unitholders. The operating and financial restrictions and covenants in our senior secured
credit  agreement  and  any  future  financing  agreements  could  restrict  our  ability  to  finance  future  operations  or  capital  needs  or  to  expand  or  pursue  our
business activities, which may, in turn, limit our ability to make cash distributions to our unitholders. Our senior secured credit agreement limits our ability to,
among other things:

• incur or guarantee additional debt;

• make distributions on or redeem or repurchase units;

• make certain investments and acquisitions;

• incur certain liens or permit them to exist;

• enter into certain types of transactions with affiliates;

• merge or consolidate with other affiliates;

• transfer, sell or otherwise dispose of assets;

• engage in a materially different line of business;

• enter into certain burdensome agreements; and

• prepay other indebtedness.  

Our senior secured credit agreement also includes covenants requiring us to maintain certain financial ratios. Our ability to meet those financial ratios
and tests can be affected by events beyond our control, and we cannot assure you that we will meet those ratios and tests. In addition, if we are unable to
maintain our existing revenues and cash flows, particularly in connection with the potential renewal or extension of our existing take or pay agreements, we
may be required to reduce our indebtedness or fall out of compliance with one or more of these ratios or tests.

The provisions of our senior secured credit agreement may affect our ability to obtain future financing and pursue attractive business opportunities and
our flexibility in planning for, and reacting to, changes in business conditions. In addition, a failure to comply with the provisions of our senior secured credit
agreement could result in a default or an event of default that could enable our lenders to declare the outstanding principal of that debt, together with accrued
and unpaid interest, to be immediately due and payable along with triggering the exercise of other remedies. If the payment of our debt is accelerated, our
assets may be insufficient to repay such debt in full, and our unitholders could experience a partial or total loss of their investment.

Uncertainty relating to the LIBOR calculation process and potential phasing out of LIBOR after 2021 may adversely affect the market value of our
current or future debt obligations, including our Revolving Credit Facility.

Regulators and law enforcement agencies in the United Kingdom and elsewhere are conducting civil and criminal investigations into whether the banks
that contributed to the British Bankers’ Association (the “BBA”) in connection with the calculation of daily London Interbank Offered Rate, or LIBOR, may
have been under-reporting or otherwise manipulating or attempting to manipulate LIBOR. A number of BBA member banks have entered into settlements
with their regulators and law enforcement agencies with respect to this alleged manipulation of LIBOR. Actions by the BBA or any other administrator of
LIBOR,  regulators  or  law  enforcement  agencies  may  result  in  changes  to  the  manner  in  which  LIBOR  is  determined,  the  phasing  out  of  LIBOR  or  the
establishment of alternative reference rates. For example, on July 27, 2017, the U.K. Financial Conduct Authority announced that it intends to stop persuading
or  compelling  banks  to  submit  LIBOR  rates  after  2021.  As  a  result,  LIBOR  may  be  discontinued  by  2021.  Furthermore,  in  the  United  States,  efforts  to
identify a set of alternative U.S. dollar reference interest rates that could replace LIBOR include proposals by the Alternative Reference Rates Committee of
the Federal Reserve Board and the Federal Reserve Bank of New York. At this time, it is not possible to predict whether any such changes will occur, whether
LIBOR will be phased out or any such alternative reference rates or other reforms to LIBOR will be enacted in the United Kingdom, the United States or
elsewhere or the effect that any such changes, phase out, alternative reference rates or other reforms, if they occur, would have on the amount of interest paid
on,  or  the  market  value  of,  our  current  or  future  debt  obligations,  including  our  Revolving  Credit  Facility.  Uncertainty  as  to  the  nature  of  such  potential
changes, phase out, alternative reference rates or other reforms may materially adversely affect the trading market for LIBOR-based securities, including the
terms of our Revolving Credit Facility and any interest rate swaps or other derivative agreements to which we are a party. Reform of, or the replacement or
phasing out of, LIBOR and proposed

29

regulation of LIBOR and other “benchmarks” may materially adversely affect the market value of, the applicable interest rate on and the amount of interest
paid on our current or future debt obligations, including our Revolving Credit Facility. In addition, even if we have entered into interest rate swaps or other
derivative instruments for purposes of managing our interest rate exposure, our strategies may not be effective as a result of the replacement or phasing out of
LIBOR and other “benchmarks,” and we may incur substantial losses as a result.

The credit and risk profile of our general partner and its owner, USD Group LLC, could adversely affect our credit ratings and risk profile, which
could  increase  our  borrowing  costs  or  hinder  our  ability  to  raise  capital  and  additionally  have  a  direct  impact  on  our  ability  to  pay  our  minimum
quarterly distribution.  

The credit and business risk profiles of our general partner and USD Group LLC, neither of which has a rating from any credit agency, may be factors
considered in credit evaluations of us. This is because our general partner, which is owned by USD Group LLC, controls our business activities, including our
cash distribution policy and growth strategy. In addition, a wholly-owned affiliate of our general partner is a customer of ours at our Hardisty terminal and
Stroud  terminal  and  may  become  a  customer  at  other  terminals  we  own  or  control  in  the  future.  Any  adverse  change  in  the  financial  condition  of  USD
Group LLC, including the degree of its financial leverage and its dependence on cash flow from us to service its indebtedness, if any, may adversely affect
our credit ratings and risk profile. If we were to seek a credit rating in the future, our credit rating may be adversely affected by the leverage of our general
partner or USD Group LLC, as credit rating agencies such as Standard & Poor’s Ratings Services and Moody’s Investors Service may consider the leverage
and credit profile of USD Group LLC and its affiliates because of their ownership interest in and control of us. Any adverse effect on our credit rating would
increase our cost of borrowing or hinder our ability to raise financing in the capital markets, which would impair our ability to grow our business and make
distributions to common unitholders.

Our growth strategy requires access to new capital. Tightened capital markets or increased competition for investment opportunities could impair our
ability to grow.  

We regularly consider and evaluate potential acquisitions and other opportunities to grow our business. Any limitations on our access to new capital
will  impair  our  ability  to  execute  this  strategy.  If  the  cost  of  such  capital  becomes  too  expensive,  our  ability  to  develop  or  acquire  strategic  and  accretive
assets will be limited. We may not be able to raise the necessary funds on satisfactory terms, if at all. The primary factors that influence our initial cost of
equity include market conditions, including our then current unit price, fees we pay to underwriters and other offering costs, which include amounts we pay
for legal and accounting services. The primary factors influencing our cost of borrowing include interest rates, credit spreads, covenants, underwriting or loan
origination fees and similar charges we pay to lenders.  

Weak economic conditions, more stringent lending standards, higher interest rates and volatility in the financial markets have increased, and could in
the future increase, the cost of raising money in the debt and equity capital markets, while diminishing the availability of funds from those markets. These
factors among others may limit our ability to execute our growth strategy.

While Energy Capital Partners has indicated an intention to invest over an additional $1.0 billion of equity capital in USD, subject to market and other
conditions, it has not made a commitment to provide any direct or indirect financial assistance to us. Furthermore, Energy Capital Partners must approve any
issuances of additional equity by us, and its determination may be made free of any duty to us or our unitholders, and members of our general partner’s board
of  directors  appointed  by  Energy  Capital  Partners  must  approve  the  incurrence  by  us  or  refinancing  of  our  indebtedness  outside  of  the  ordinary  course  of
business, which may limit our flexibility to obtain financing and to pursue other business opportunities.

Our  existing  debt  and  any  additional  debt  we  incur  in  the  future  may  limit  our  flexibility  to  obtain  financing  and  to  pursue  other  business
opportunities.  

As of December 31, 2019, we had approximately $220.0 million of outstanding borrowings under our senior secured credit agreement. We have the
ability to incur additional debt, including under our existing senior secured credit agreement. Our level of indebtedness could have important consequences
for us, including the following:

• our ability to obtain additional financing, if necessary, for working capital, capital expenditures, acquisitions, or other purposes, may be impaired, or

such financing may not be available on favorable terms;

• our funds available for operations, future business opportunities and cash distributions to unitholders may be reduced by that portion of our cash

flow required to make interest payments on our debt;

• we may be more vulnerable to competitive pressures or a downturn in our business or the economy generally; and

• our flexibility in responding to changing business and economic conditions may be limited.  

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Our  ability  to  service  our  debt  depends  upon,  among  other  things,  our  financial  and  operating  performance,  which  will  be  affected  by  prevailing
economic conditions and financial, business, regulatory and other factors, some of which are beyond our control. If our operating results are not sufficient to
service indebtedness, we will be forced to take actions such as reducing distributions, reducing or delaying our business activities, acquisitions, investments or
capital expenditures, selling assets or seeking additional equity capital. We may not be able to take any of these actions on satisfactory terms or at all.

If  we  are  unable  to  make  acquisitions  on  economically  acceptable  terms  from  USD  or  third  parties,  our  future  growth  would  be  limited,  and  any
acquisitions we may make could reduce, rather than increase, our cash flows and ability to make distributions to unitholders.  

A portion of our strategy to grow our business and increase distributions to unitholders is dependent on our ability to make acquisitions that result in an
increase in cash flow. If we are unable to make acquisitions from USD or third parties, because we are unable to identify attractive acquisition candidates or
negotiate  acceptable  purchase  agreements,  we  are  unable  to  obtain  financing  for  these  acquisitions  on  economically  acceptable  terms,  we  are  outbid  by
competitors  or  we  or  the  seller  are  unable  to  obtain  any  necessary  consents,  our  future  growth  and  ability  to  increase  distributions  to  unitholders  will  be
limited.  Energy  Capital  Partners  must  also  approve  the  acquisition  of  the  securities  of  any  entity  by  us  if  the  acquisition  exceeds  specified  thresholds.
Furthermore, even if we do consummate acquisitions that we believe will be accretive, we may not realize the intended benefits, and the acquisition may in
fact result in a decrease in cash flow. Any acquisition involves potential risks, including, among other things:

• mistaken assumptions about revenues and costs, including synergies;

• the assumption of unknown liabilities;

• limitations on rights to indemnity from the seller;

• mistaken assumptions about the overall costs of equity or debt;

• the diversion of management’s attention from other business concerns;

• unforeseen difficulties operating in new product areas or new geographic areas; and

• customer or key employee losses at the acquired businesses.

 If  we  consummate  any  future  acquisitions,  our  capitalization  and  results  of  operations  may  change  significantly,  and  unitholders  will  not  have  the
opportunity to evaluate the economic, financial and other relevant information that we will consider in determining the application of these funds and other
resources.

We may be unsuccessful in integrating future acquisitions with our existing operations, and in realizing all or any part of the anticipated benefits of
any such acquisitions.  

From  time  to  time,  we  evaluate  and  expect  to  acquire  assets  and  businesses  that  we  believe  complement  our  existing  assets  and  businesses.  These
acquisitions may require substantial capital or the incurrence of substantial indebtedness. Our capitalization and results of operations may change significantly
as  a  result  of  future  acquisitions.  Acquisitions  and  business  expansions  involve  numerous  risks,  including  difficulties  in  the  assimilation  of  the  assets  and
operations of the acquired businesses, inefficiencies and difficulties that arise because of unfamiliarity with new assets and the businesses associated with
them and new geographic areas and the diversion of management’s attention from other business concerns. Further, unexpected costs and challenges may
arise whenever businesses with different operations or management are combined, and we may experience unanticipated delays in realizing the benefits of an
acquisition. Also, following an acquisition, we may discover previously unknown liabilities associated with the acquired business or assets for which we have
no recourse under applicable indemnification provisions. Our inability to successfully integrate any future acquisitions into our existing operations and asset
platform  could  have  a  material  adverse  effect  on  our  business,  financial  condition,  results  of  operations,  and  ability  to  make  quarterly  distributions  to  our
unitholders. Furthermore, even if we are able to successfully integrate future acquisitions into our existing operations and asset platform, we may not be able
to capitalize on expected business opportunities, and general industry and business conditions may deteriorate. 

Our right of first offer to acquire certain of USD’s existing assets and projects and certain projects that it may develop, construct or acquire in the
future is subject to risks and uncertainty, and ultimately we may not acquire any of those assets or businesses.  

The Omnibus Agreement provides us with a right of first offer on certain of USD’s existing assets and projects as well as any additional midstream
infrastructure that it may develop, construct or acquire, subject to certain exceptions. This right expires on October 15, 2021. The consummation and timing
of any future acquisitions pursuant to this right will depend upon, among other things, USD’s continued development of midstream infrastructure projects and
successful  execution  of  such  projects,  USD’s  willingness  to  offer  assets  for  sale  and  obtain  any  necessary  consents,  our  ability  to  negotiate  acceptable
purchase agreements and commercial agreements with respect to such assets and our ability to obtain financing on acceptable

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terms. We can offer no assurance that we will be able to successfully consummate any future acquisitions or successfully integrate assets acquired pursuant to
our right of first offer. Furthermore, USD is under no obligation to accept any offer that we may choose to make. Additionally, the approval of Energy Capital
Partners is required for the sale of any assets by USD or its subsidiaries, including us (other than sales in the ordinary course of business), acquisitions of
securities of other entities that exceed specified materiality thresholds and any material unbudgeted expenditures or deviations from our approved budgets.
Energy Capital Partners may make these decisions free of any duty to us and our unitholders. This approval would be required for the potential acquisition by
us of any of USD’s projects, as well as any other projects or assets that USD may develop or acquire in the future or any third-party acquisition we may
intend  to  pursue  jointly  or  independently  from  USD.  Energy  Capital  Partners  is  under  no  obligation  to  approve  any  such  transaction.  Please  refer  to  the
discussion under Item 10. Directors, Executive Officers and Corporate Governance—Special Approval Rights of Energy Capital Partners regarding the rights
of Energy Capital Partners. In addition, we may decide not to exercise our right of first offer if and when any assets are offered for sale, and our decision will
not be subject to unitholder approval. Further, our right of first offer may be terminated by USD at any time in the event that it no longer controls our general
partner. Please refer to the discussion under Part II, Item 8. Financial Statements and Supplementary Data, Note 13. Transactions with Related Parties for
additional information regarding the Omnibus Agreement. 

Growing our business by constructing new assets subjects us to construction risks and risks that supplies for such facilities will not be available upon
completion thereof.  

One of the ways we intend to grow our business is through the construction of new assets. The construction of new assets requires the expenditure of
capital, some of which may exceed our resources, and involve regulatory, environmental, political and legal uncertainties. If we undertake the construction of
new assets, we may not be able to complete them on schedule or at all or at the budgeted cost. Actions by third parties that we do not control may cause delay
in construction, which could result in lost revenue or contract termination rights relating to the new asset. Moreover, our revenues may not increase upon the
expenditure of funds on a particular project. For instance, if we build a new significant asset, the construction will occur over a period of time, and we will not
receive any revenues until after completion of the project, if at all. Moreover, we may construct assets to provide services to capture revenue which does not
materialize  or  for  which  we  are  unable  to  acquire  new  customers.  We  may  also  rely  on  estimates  of  potential  demand  for  our  services  in  our  decision  to
construct new assets, which may prove to be inaccurate because there are numerous uncertainties inherent in estimating demand for our services. As a result,
new assets we construct may not be able to attract sufficient demand to achieve our expected investment return, which could materially and adversely affect
our results of operations, cash flows and financial condition.

We operate in a highly regulated industry and increased costs of compliance with, or liability for violation of, existing or future laws, regulations and
other requirements could significantly increase our costs of doing business, thereby adversely affecting our profitability.  

Our  industry  is  subject  to  laws,  regulations  and  other  requirements  including,  but  not  limited  to,  those  relating  to  the  environment,  safety,  working
conditions, public accessibility and other requirements. These laws and regulations are enforced by federal agencies including, but not limited to, the EPA, the
DOT, PHMSA, the FERC, the FRA, the Federal Motor Carrier Safety Administration, or FMCSA, OSHA, state agencies such as the Texas Commission on
Environmental  Quality,  the  Railroad  Commission  of  Texas,  the  California  Environmental  Protection  Agency,  or  Cal/EPA,  the  California  Public  Utilities
Commission, or CPUC,  and  Canadian  agencies  such  as  Environment  Canada  and  Transport  Canada  as  well  as  numerous  other  state  and  federal  agencies.
Ongoing compliance with, or a violation of, these laws, regulations and other requirements could have a material adverse effect on our business, financial
condition, results of operations, and ability to make quarterly distributions to our unitholders.  

In addition, these laws and regulations, and the interpretation or enforcement thereof, are subject to frequent change by regulatory authorities, and we
are unable to predict the ongoing cost to us of complying with these laws and regulations or the future impact of these laws and regulations on our operations.
Violation of environmental laws, regulations and permits can result in the imposition of significant administrative, civil and criminal penalties, injunctions
and construction bans or delays.  

Under various federal, state, provincial and local environmental requirements, as the owner or operator of terminals, we may be liable for the costs of
removal or remediation of contamination at our existing locations, whether we knew of, or were responsible for, the presence of such contamination. The
failure to timely report and properly remediate contamination may subject us to liability to third parties and may adversely affect our ability to sell or rent our
property or to borrow money using our property as collateral. Additionally, we may be liable for the costs of remediating third-party sites where hazardous
substances from our operations have been transported for treatment or disposal, regardless of whether we own or operate that site. In the future, we may incur
substantial expenditures for investigation or remediation of contamination that has not yet been discovered at our current or former locations or locations that
we may acquire.  

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A discharge of hydrocarbons or hazardous substances into the environment could, to the extent the event is not insured or insurance is not otherwise
available,  subject  us  to  substantial  expense,  including  the  cost  to  respond  in  compliance  with  applicable  laws  and  regulations,  fines  and  penalties,  natural
resource  damages  and  claims  made  by  employees,  neighboring  landowners  and  other  third  parties  for  personal  injury  and  property  damage.  We  may
experience  future  catastrophic  sudden  or  gradual  releases  into  the  environment  from  our  pipeline  or  terminals  or  discover  historical  releases  that  were
previously  unidentified  or  not  assessed.  Although  our  inspection  and  testing  programs  are  designed  in  compliance  with  applicable  legal  requirements  to
prevent,  detect  and  address  these  releases  promptly,  damages  and  liabilities  incurred  due  to  any  future  environmental  releases  from  our  assets  have  the
potential to substantially affect our business. Such discharges could also subject us to media and public scrutiny that could have a negative effect on the value
of our common units.  

Environmental,  safety  and  other  regulations  are  stringent.  Penalties  for  violations  have  increased  and  may  increase  further  in  amount,  and  new
environmental laws and regulations may be proposed and enacted. Moreover, interpretations of existing requirements change from time to time. While we
cannot  predict  the  impact  that  future  environmental,  health  and  safety  requirements  or  changed  interpretations  of  existing  requirements  may  have  on  our
operations,  such  future  activity  may  result  in  material  expenditures  to  ensure  our  continued  compliance  and  material  costs  if  we  are  found  not  to  be  in
compliance. Such future activity could adversely affect our operations, cash flow and net revenues.

We are subject to stringent environmental and safety laws and regulations that may expose us to significant costs and liabilities.  

Our operations are subject to stringent and complex federal, state, provincial and local environmental and safety laws and regulations that govern the

discharge of materials into the environment or otherwise relate to environmental protection.

These  laws  and  regulations  may  impose  numerous  obligations  that  are  applicable  to  our  operations,  including  the  acquisition  of  permits  to  conduct
regulated activities, the incurrence of capital or operating expenditures to limit or prevent releases of materials from pipelines, railcars and terminals, and the
imposition  of  substantial  liabilities  and  remedial  obligations  for  pollution  resulting  from  our  operations  or  at  locations  currently  or  previously  owned  or
operated by us. Numerous governmental authorities, such as the EPA, the DOT, Environment Canada, Transport Canada and analogous state and provincial
agencies, have the power to enforce compliance with these laws and regulations and the permits issued under them, oftentimes requiring difficult and costly
corrective  actions  or  costly  pollution  control  measures.  Failure  to  comply  with  these  laws,  regulations  and  permits  may  result  in  the  assessment  of
administrative, civil and criminal penalties, the imposition of remedial obligations and the issuance of injunctions limiting or preventing some or all of our
operations. In addition, we may experience a delay in obtaining or be unable to obtain required permits or regulatory authorizations, which may cause us to
lose potential and current customers, interrupt our operations and limit our growth and revenue.

 We may incur significant environmental costs and liabilities in connection with our operations due to historical industry operations and waste disposal
practices, our handling of hydrocarbon and other wastes and potential emissions and discharges related to our operations. Joint and several, strict liability may
be  incurred,  without  regard  to  fault,  under  certain  of  these  environmental  laws  and  regulations  in  connection  with  discharges  or  releases  of  hydrocarbon
wastes  on,  under,  or  from  our  properties  and  terminals.  In  addition,  changes  in  environmental  laws  occur  frequently,  and  any  such  changes  that  result  in
additional permitting obligations or more stringent and costly waste handling, storage, transport, disposal or remediation requirements could have a material
adverse effect on our operations or financial position. We may not be able to recover all or any of these costs from insurance.

Also,  some  states  have  adopted,  and  other  states  are  considering  adopting,  legal  requirements  that  could  impose  more  stringent  permitting,  public
disclosure, or well construction requirements on oil and gas production. States or localities could also elect to prohibit hydraulic fracturing altogether, as the
State of New York announced in 2014, and the federal government could limit development on federal lands. While our operations are not directly affected by
these  actions,  their  impact  on  our  oil  and  natural  gas  exploration  and  production  customers  could  result  in  a  decreased  demand  for  the  services  that  we
provide.

We  could  incur  substantial  costs  or  disruptions  in  our  business  if  we  cannot  obtain  or  maintain  necessary  permits  and  authorizations  or  otherwise
comply with health, safety, environmental and other laws and regulations.

Our operations require authorizations and permits that are subject to revocation, renewal or modification and can require operational changes to limit
the  effect  or  potential  effect  on  the  environment  and/or  health  and  safety.  A  violation  of  authorization  or  permit  conditions  or  other  legal  or  regulatory
requirements could result in substantial fines, criminal sanctions, permit revocations, injunctions, and/or facility shutdowns. In addition, major modifications
of our operations could require modifications to our existing permits or upgrades to our existing pollution control and safety-related equipment. Any or all of
these matters could have a material adverse effect on our business, financial condition, results of operations, and ability to make quarterly distributions to our
unitholders.

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Our business involves many hazards and operational risks, some of which may not be fully covered by insurance. If a significant accident or event
occurs for which we are not adequately insured, or if we fail to recover anticipated insurance proceeds for significant accidents or events for which we
are insured, our operations and financial results could be adversely affected.  

Our operations are subject to all of the risks and hazards inherent in the provision of terminalling services, including:

• damage to railroads and terminals, related equipment and surrounding properties caused by natural disasters, acts of terrorism and actions by third

parties;

• damage from construction, vehicles, farm and utility equipment or other causes;

• leaks of crude oil and other hydrocarbons or regulated substances or losses of oil as a result of the malfunction of equipment or facilities or operator

error;

• blockades of rail lines or other interruptions in service due to actions of third parties;

• ruptures, fires and explosions; and

• other hazards that could also result in personal injury and loss of life, pollution and suspension of operations.

 These and similar risks could result in substantial costs due to personal injury and/or loss of life, severe damage to and destruction of property and
equipment  and  pollution  or  other  damage.  These  risks  may  also  result  in  curtailment  or  suspension  of  our  operations.  A  natural  disaster  or  other  hazard
affecting the areas in which we operate could also have a material adverse effect on our operations. We are not fully insured against all risks inherent in our
business. In addition, although we are insured for environmental pollution resulting from environmental accidents that occur on a sudden and accidental basis,
we may not be insured against all environmental accidents that might occur, some of which may result in claims for remediation, damages to natural resources
or injuries to personal property or human health. If a significant accident or event occurs for which we are not fully insured, it could adversely affect our
operations and financial condition. Furthermore, we may not be able to maintain or obtain insurance of the type and amount we desire at reasonable rates,
particularly following a significant accident or event for which we seek insurance. As a result of market conditions, premiums and deductibles for certain of
our insurance policies may substantially increase. In some instances, certain insurance could become unavailable or available only for reduced amounts of
coverage.

Legislation,  regulatory  initiatives,  litigation  and  investor  sentiment  relating  to  climate  change  could  result  in  increased  operating  costs,  reduced
demand for the services we provide and limits on our access to capital.  

In  response  to  studies  suggesting  that  emissions  of  carbon  dioxide,  methane  and  certain  other  gases  may  be  contributing  to  warming  of  the  Earth’s
atmosphere, over 190 countries, including the United States and Canada, reached an agreement to reduce GHG emissions at the Paris climate conference in
December 2015. The terms of the Paris treaty to reduce GHG emissions are to become effective in 2020. In June 2017, President Trump announced that the
United States intends to withdraw from the Paris treaty and to seek negotiations either to reenter the Paris treaty on different terms or a separate agreement. In
August  2017,  the  U.S.  Department  of  State  officially  informed  the  United  Nations  of  the  intent  of  the  United  States  to  withdraw  from  the  Paris  treaty.  In
November 2019, the Trump administration formally moved to exit the Paris Agreement, initiating the treaty mandated one-year process at the end of which
the United States can officially exit the agreement. The United States’ adherence to the exit process or the terms on which the United States may re-enter the
Paris treaty or a separately negotiated agreement are unclear at this time, particularly given the federal election in November 2020.

In addition, the U.S. Congress has considered legislation to restrict or regulate emissions of GHGs. Comprehensive climate legislation appears unlikely
to be passed by either house of Congress in the near future, although additional energy legislation and other initiatives may be proposed that address GHGs
and  related  issues.  In  addition,  almost  half  of  the  states  (including  California  and  Texas,  in  which  we  operate),  either  individually  or  through  multi-state
regional  initiatives,  have  begun  to  address  GHG  emissions,  primarily  through  the  planned  development  of  emission  inventories  or  regional  GHG  cap  and
trade programs. Although most of the state-level initiatives have to date been focused on large sources of GHG emissions, such as electric power plants, it is
possible  that  smaller  sources  could  become  subject  to  GHG-related  regulation.  Depending  on  the  particular  program,  we  could  be  required  to  control
emissions or to purchase and surrender allowances for GHG emissions resulting from our operations, and to the extent federal or state measures are successful
in reaching hydrocarbon fuel usage, they could have an indirect effect on our business. 

Independent of Congress, the EPA has adopted regulations to address GHG emissions under its existing CAA authority. For example, in 2009, the EPA
adopted  rules  regarding  regulation  of  GHG  emissions  from  motor  vehicles.  In  addition,  in  September  2009,  the  EPA  issued  a  final  rule  requiring  the
monitoring and reporting of GHG emissions from specified large GHG emission sources in the United States. In November 2010, EPA expanded this existing
GHG emissions reporting rule to petroleum facilities, requiring reporting of GHG emissions by regulated petroleum facilities to the EPA beginning in 2012
and annually thereafter. In October 2015, EPA further expanded its GHG emissions reporting program to include onshore

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petroleum  and  natural  gas  gathering  and  boosting  activities,  as  well  as  natural  gas  transmission  pipelines.  We  monitor  and  report  our  facilities’  GHG
emissions. However, operational or regulatory changes or stakeholder demands could require additional monitoring and reporting at some or all of our other
facilities  at  a  future  date.  In  2010,  the  EPA  also  issued  a  final  rule,  known  as  the  “Tailoring  Rule,”  that  makes  certain  large  stationary  sources  and
modification projects subject to permitting requirements for GHG emissions under the CAA. In October 2015, the EPA finalized the Clean Power Plan, or
CPP, which imposes additional obligations on the power generation sector to reduce GHG emissions and which generally promoted a reduction in the demand
for fossil fuels. However, in August 2019, the EPA finalized the repeal of the CPP and replaced it with the Affordable Clean Energy rule, or ACE, which
designates heat rate improvement, or efficiency improvement, as the best system of emissions reduction for carbon dioxide from existing coal-fired electric
utility generating units. Both the appropriateness of the repeal of the CPP and the adequacy of ACE are currently subject to litigation.

Although it is not possible at this time to predict exactly how potential future laws or regulations addressing GHG emissions in Canada or the United
States would impact our business, any future federal, state or provincial laws or implementing regulations that may be adopted to address GHG emissions
could require us to incur increased operating costs and could adversely affect demand for the crude oil and other liquid hydrocarbons we handle in connection
with our services. Moreover, the change in a regulation landscape means we may incur additional expenses that would not be applicable in a steady set of
regulations. The potential increase in the costs of our operations resulting from any legislation or regulation to restrict emissions of GHGs could include new
or increased costs to operate and maintain our facilities, install new emission controls on our facilities, acquire allowances to authorize our GHG emissions,
pay any taxes related to our GHG emissions and administer and manage a GHG emissions program. While we may be able to include some or all of such
increased costs in the rates charged by our terminals, such recovery of costs is uncertain. Moreover, incentives to conserve energy or use alternative energy
sources  could  reduce  demand  for  oil,  resulting  in  a  decrease  in  demand  for  our  services.  We  cannot  predict  with  any  certainty  at  this  time  how  these
possibilities may affect our operations.

Scientists  have  concluded  that  increasing  concentrations  of  GHGs  in  the  earth’s  atmosphere  may  produce  climate  changes  that  have  significant
physical effects, such as increased frequency and severity of storms, floods and other climatic events; if any such effects were to occur, they could have an
adverse effect on our operations. In addition, there have been increasing efforts in recent years to influence the investment community, including investment
advisors and certain sovereign wealth, pension and endowment funds promoting divestment of fossil fuel equities and pressuring lenders to limit funding to
companies engaged in the extraction of fossil fuel reserves. Such environmental activism and initiatives aimed at limiting climate change and reducing air
pollution could interfere with our business activities, operations and ability to access capital. Finally, increasing attention to the risks of climate change has
resulted in an increased possibility of lawsuits or investigations brought by public and private entities against oil and natural gas companies. Should we be
targeted by any such litigation or investigations, we may incur liability, which, to the extent that societal pressures or political or other factors are involved,
could be imposed without regard to the causation of or contribution to the asserted damage, or to other mitigating factors.

We may recognize impairment on long-lived assets, goodwill and intangible assets.

Periodically, we review our long-lived assets for impairment whenever economic events or changes in circumstances indicate that the carrying value of
an asset may not be recoverable. For example, when a customer contract for terminalling services at our Casper terminal expired and was not renewed in late
August 2019, we considered such expiration of the contract as an event that required us to assess the recoverability of our long-lived assets associated with
the Casper terminal at August 31, 2019. Based on our assessment under certain assumptions underlying our cash flow projections, including our ability to
renew  existing  contracts  and  expand  business  with  current  customers  and  our  ability  to  enter  into  contracts  with  new  customers  and  obtain  additional
commitments  regarding  the  use  of  these  facilities,  we  determined  that  we  did  not  need  to  recognize  an  impairment  loss.  However,  to  the  extent  that  the
assumptions underlying the assessment do not materialize, or projection of future financial performance underlying our cash flow projection for the Casper
terminal could yield undiscounted cash flows and a fair value that indicate our long-lived assets are impaired. Furthermore, in the event that there is another
termination of a contract without renewal, we may recognize an impairment of our long-lived asset or goodwill, and we may be unable to replace the cash
flows  derived  from  such  contract  on  a  long-term  contracted  basis.  We  also  review  our  goodwill  and  intangible  assets  for  indicators  of  impairment  in
accordance  with  applicable  accounting  standards.  Significant  negative  industry  or  general  economic  trends,  disruptions  to  our  business  and  unexpected
significant changes or planned changes in our use of the assets may result in impairments to our goodwill, intangible assets and other long-lived assets. Any
reduction in or impairment of the value of goodwill or intangible assets will result in a charge against earnings, which could have a material adverse impact
on our reported results of operations and financial condition.

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The implementation of derivatives regulations could have an adverse effect on our ability to use derivatives contracts to reduce the effect of foreign
exchange, interest rate and other risks associated with our business.  

The Dodd-Frank Wall Street Reform and Consumer Protection Act (“Dodd-Frank Act”), establishes federal oversight and regulation of the over-the-
counter  derivatives  market  and  entities  that  participate  in  that  market.  Although  the  U.S.  Commodity  Futures  Trading  Commission  and  the  other  relevant
regulators  have  finalized  most  of  the  regulations  under  the  Dodd-Frank  Act,  they  continue  to  review  and  refine  initial  rulemakings  through  additional
interpretations  and  supplemental  rulemakings.  As  a  result,  it  is  not  possible  at  this  time  to  predict  the  ultimate  effect  of  the  rules  and  regulations  on  our
business  and  while  most  of  the  regulations  have  been  adopted,  any  new  regulations  or  modifications  to  existing  regulations  may  increase  the  cost  of
derivatives contracts, materially alter the terms of derivatives contracts, reduce the availability of derivatives to protect against risks we encounter and reduce
our ability to monetize or restructure our existing derivatives contracts. If we reduce our use of derivatives as a result of the legislation and regulations, our
results of operations may become more volatile and our cash flows may be less predictable, which could adversely affect our ability to plan for and fund
capital expenditures. Any of these consequences could have a material adverse effect on us, our financial condition, our results of operations and our cash
flows.  

Our ability to operate our business effectively could be impaired if we fail to attract and retain key management personnel.  

We are managed and operated by the board of directors and executive officers of our general partner. All of the personnel that conduct our business are
employed  by  affiliates  of  our  general  partner,  but  we  sometimes  refer  to  these  individuals  as  our  employees.  Our  ability  to  operate  our  business  and
implement our strategies depends on our continued ability and the ability of affiliates of our general partner to attract and retain highly skilled management
personnel. Competition for these persons is intense. Given our size, we may be at a disadvantage, relative to our larger competitors, in the competition for
these personnel. We or affiliates of our general partner may not be able to attract and retain qualified personnel in the future, and the failure to retain or attract
senior executives and key personnel could have a material adverse effect on our ability to effectively operate our business. Neither we nor our general partner
maintains key person life insurance policies for any of our senior management team.  

Terrorist or cyber-attacks and threats, escalation of military activity in response to these attacks or acts of war could have a material adverse effect on
our business, financial condition, results of operations and ability to make quarterly distributions to our unitholders.

Terrorist  attacks  and  threats,  cyber-attacks,  escalation  of  military  activity,  acts  of  war  or  other  civil  unrest  may  have  significant  effects  on  general
economic  conditions,  fluctuations  in  consumer  confidence  and  spending  and  market  liquidity,  each  of  which  could  materially  and  adversely  affect  our
business. Future terrorist or cyber-attacks, rumors or threats of war, actual conflicts involving the United States, Canada or their respective allies, or military
or  trade  disruptions  may  significantly  affect  our  operations  and  those  of  our  customers.  Strategic  targets,  such  as  energy-related  assets  and  transportation
assets, may be at greater risk of future terrorist or cyber-attacks than other targets in the United States and Canada. The disruption or a significant increase in
energy prices could result in government-imposed price controls. It is possible that any of these occurrences, or a combination of them, could have a material
adverse effect on our business, financial condition, results of operations, and ability to make quarterly distributions to our unitholders.

We rely on information technology in all aspects of our business. A cyber-attack involving our information systems and related infrastructure could

negatively impact our operations in a variety of ways, including, but not limited to, the following:

• data corruption, communication interruption, or other operational disruption during transporting crude oil;

• a cyber-attack on a communications network or power grid could cause operational disruption resulting in loss of revenues;

• a cyber-attack on our automated and surveillance systems could cause a loss in crude oil and potential environmental hazards;

• a  deliberate  corruption  of  our  financial  or  operating  data  could  result  in  events  of  non-compliance  which  could  then  lead  to  regulatory  fines  or

penalties; and

• a cyber-attack resulting in the loss or disclosure of, or damage to, our or any of our customer’s or supplier’s data or confidential information could
harm  our  business  by  damaging  our  reputation,  subjecting  us  to  potential  financial  or  legal  liability,  and  requiring  us  to  incur  significant  costs,
including costs to repair or restore our systems and data or to take other remedial steps.

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Additionally, we do not maintain specialized insurance for possible liability resulting from a cyber-attack on our assets that may shut down all or part
of our business. There can be no assurance that a system failure or data security breach will not have a material adverse effect on our financial condition,
results of operations or cash flows. Furthermore, the growth of cyber-attacks has resulted in evolving legal and compliance matters which impose significant
costs that are likely to increase over time.

If we fail to maintain an effective system of internal controls, we may not be able to report our financial results timely and accurately or prevent fraud,
which would likely have a negative impact on the market price of our common units.

We  are  subject  to  the  public  reporting  requirements  of  the  Exchange  Act.  We  prepare  our  financial  statements  in  accordance  with  U.S.  generally
accepted accounting principles, or GAAP. Effective internal controls are necessary for us to provide reliable financial reports, prevent fraud and to operate
successfully  as  a  publicly  traded  partnership.  We  may  be  unsuccessful  in  maintaining  our  internal  controls,  and  we  may  be  unable  to  maintain  effective
controls over our financial processes and reporting in the future or to comply with our obligations under Section 404 of the Sarbanes-Oxley Act of 2002,
which we refer to as Section 404. For example, Section 404 requires us, among other things, to annually review and report on, and our independent registered
public accounting firm to assess, the effectiveness of our internal controls over financial reporting.  

Any failure to maintain effective internal controls or to improve our internal controls could harm our operating results or cause us to fail to meet our
reporting obligations. Given the difficulties inherent in the design and operation of internal controls over financial reporting, we can provide no assurance as
to our, or our independent registered public accounting firm’s conclusions about the effectiveness of our internal controls, and we may incur significant costs
in our efforts to comply with Section 404. Ineffective internal controls will subject us to regulatory scrutiny and a loss of confidence in our reported financial
information, which could have an adverse effect on our business and would likely have a material adverse effect on the trading price of our common units.  

For as long as we are a smaller reporting company, we will not be required to comply with certain disclosure requirements that apply to other public
companies.

We  are  currently  a  “smaller  reporting  company,”  meaning  that  we  are  not  an  investment  company,  an  asset-backed  issuer,  or  a  majority-owned
subsidiary of a parent company that is not a smaller reporting company and have a public float of less than $250 million as of the end of the second fiscal
quarter.  “Smaller  reporting  companies”  are  able  to  provide  simplified  executive  compensation  disclosures  in  their  filings,  and  have  certain  other  scaled
disclosure obligations in their SEC filings, including, among other things, being required to provide only two years of audited financial statements in annual
reports. The scaled disclosures we provide in our SEC filings due to our status as a “smaller reporting company” may make it harder for investors to analyze
our results of operations and financial prospects. If some investors find our common units to be less attractive as a result of the scaled disclosures, there also
may be a less active trading market for our common units and our trading price may be more volatile.

Risks Inherent in an Investment in Us

Our general partner and its affiliates, including USD, have conflicts of interest with us and limited duties to us and our unitholders, and they may
favor their own interests to our detriment and that of our unitholders.

USD indirectly owns a 42.9% limited partner interest and indirectly owns and controls our general partner, which owns a 1.7% general partner interest
in us. Although our general partner has a duty to manage us in a manner that is not adverse to the best interests of our partnership and our unitholders, the
directors and officers of our general partner also have a duty to manage our general partner in a manner that is not adverse to the best interests of its owner,
USD. Conflicts of interest may arise between USD and its affiliates, including our general partner, on the one hand, and us and our unitholders, on the other
hand. In resolving these conflicts, the general partner may favor its own interests and the interests of its affiliates, including USD, over the interests of our
common unitholders. These conflicts include, among others, the following situations:

• neither  our  Second  Amended  and  Restated  Agreement  of  Limited  Partnership  of  USD  Partners  LP,  or  our  partnership  agreement,  nor  any  other
agreement  requires  USD  to  pursue  a  business  strategy  that  favors  us,  and  the  directors  and  officers  of  USD  have  a  fiduciary  duty  to  make  these
decisions in the best interests of the members of USD. USD may choose to shift the focus of its investment and growth to areas not served by our
assets;

• USD may be constrained by the terms of its debt instruments, if any, from taking actions, or refraining from taking actions, that may be in our best

interests;

• our partnership agreement replaces the fiduciary duties that would otherwise be owed by our general partner with contractual standards governing its
duties,  limiting  our  general  partner’s  liabilities  and  restricting  the  remedies  available  to  our  unitholders  for  actions  that,  without  the  limitations,
might constitute breaches of fiduciary duty;

37

• except in limited circumstances, our general partner has the power and authority to conduct our business without unitholder approval;

• our general partner will determine the amount and timing of asset purchases and sales, borrowings, issuance of additional partnership securities and

the creation, reduction or increase of cash reserves, each of which can affect the amount of cash that is distributed to our unitholders;

• our  general  partner  will  determine  the  amount  and  timing  of  many  of  our  cash  expenditures  and  whether  a  cash  expenditure  is  classified  as  an
expansion capital expenditure, which would not reduce operating surplus, or a maintenance capital expenditure, which would reduce our operating
surplus. This determination can affect the amount of cash that is distributed to our unitholders and to our general partner, the amount of adjusted
operating surplus generated in any given period, and the ability of the subordinated units to convert into common units;

• our general partner will determine which costs incurred by it are reimbursable by us;

• our general partner may cause us to borrow funds in order to permit the payment of cash distributions, even if the purpose or effect of the borrowing
is to make a distribution on the subordinated units, to make incentive distributions, or to satisfy the conditions required to convert subordinated units
to common units;

• our partnership agreement permits us to classify up to $18.5 million as operating surplus, even if it is generated from asset sales, non-working capital
borrowings or other sources that would otherwise constitute capital surplus. This cash may be used to fund distributions on our subordinated units or
to our general partner in respect of the general partner interest or the incentive distribution rights;

• our partnership agreement does not restrict our general partner from causing us to pay it or its affiliates for any services rendered to us or entering

into additional contractual arrangements with any of these entities on our behalf;

• our general partner intends to limit its liability regarding our contractual and other obligations;

• our general partner may exercise its right to call and purchase all of the common units not owned by it and its affiliates if it and its affiliates own

more than 80.0% of the common units;

• our general partner controls the enforcement of obligations owed to us by our general partner and its affiliates;

• our general partner decides whether to retain separate counsel, accountants or others to perform services for us; and

• our general partner may elect to cause us to issue common units to it in connection with a resetting of the target distribution levels related to our
general partner’s incentive distribution rights without the approval of the conflicts committee of the board of directors of our general partner, which
we  refer  to  as  our  conflicts  committee,  or  our  unitholders.  This  election  may  result  in  lower  distributions  to  our  common  unitholders  in  certain
situations.  

Under the terms of our partnership agreement, the doctrine of corporate opportunity, or any analogous doctrine, does not apply to our general partner or
any of its affiliates, including its executive officers, directors and owners. Any such person or entity that becomes aware of a potential transaction, agreement,
arrangement or other matter that may be an opportunity for us will not have any duty to communicate or offer such opportunity to us. Any such person or
entity will not be liable to us or to any limited partner for breach of any fiduciary duty or other duty by reason of the fact that such person or entity pursues or
acquires such opportunity for itself, directs such opportunity to another person or entity or does not communicate such opportunity or information to us. This
may create actual and potential conflicts of interest between us and affiliates of our general partner and result in less than favorable treatment of us and our
unitholders. Please refer to the discussion under Item 13. Certain Relationships and Related Transactions, and Director Independence regarding conflicts of
interests and fiduciary duties of our general partner.  

Energy  Capital  Partners  has  substantial  influence  over  USD  and  our  general  partner,  and  its  interests  may  differ  from  those  of  USD,  us  and  our
public unitholders.  

Energy Capital Partners currently has the right to appoint three of seven members of USD’s board of directors and three of nine members of our general
partner’s board of directors and may in the future have the right to appoint the majority of USD’s board of directors if it invests a specified amount in USD, or
certain other conditions are met. For so long as Energy Capital Partners is able to appoint more than one member to USD’s board of directors, USD will not,
and will not permit its subsidiaries, including us and our general partner, to take or agree to take certain actions without the affirmative vote of Energy Capital
Partners, including, among others, any acquisitions or dispositions and any issuances of additional equity interests in us. Energy Capital Partners may make
these decisions free of any duty to us and our unitholders. Additionally, members of our general partner’s board of directors appointed by Energy Capital
Partners, if any, must approve any distributions made by us, any incurrence of debt by us and the approval, modification or revocation of our budget. As a
result,  Energy  Capital  Partners  is  able  to  significantly  influence  the  management  and  affairs  of  USD  and  our  general  partner,  including  the  amount  of
distributions we make, if any, our policies and operations, the appointment of management, future issuances of securities, amendments to our organizational
documents and the entering into of extraordinary transactions. The interests

38

of Energy Capital Partners may not in all cases be aligned with the interests of our common unitholders and, in certain situations, they have no duty to us or
our unitholders.  

Energy Capital Partners may have an interest in pursuing acquisitions, divestitures and other transactions that, in its judgment, could enhance its equity
investment, even though such transactions might involve risks to our common unitholders, or Energy Capital Partners may have an interest in not pursuing
transactions  that  would  otherwise  benefit  us.  For  example,  Energy  Capital  Partners  could  influence  us  to  make  acquisitions,  investments  and  capital
expenditures  that  increase  our  indebtedness  or  to  sell  revenue-generating  assets  or  to  not  make  such  acquisitions,  investments  or  capital  expenditures.  In
addition, Energy Capital Partners may have different tax considerations that could influence its position, including regarding whether and when to dispose of
assets and whether and when to incur new or refinance existing indebtedness. In addition, the structuring of future transactions by our general partner may
take  into  consideration  these  tax  or  other  considerations  even  where  no  similar  benefit  would  accrue  to  our  common  unitholders  or  us.  Energy  Capital
Partners may make the decisions to approve any acquisition or disposition by us free of any duty to us and our unitholders.  

Energy Capital Partners’ influence on USD and our general partner may have the effect of delaying, preventing or deterring a change of control of our
company. Energy Capital Partners and its affiliates and affiliated funds are in the business of making investments in companies in the energy industry and
may  from  time  to  time  acquire  and  hold  interests  in  businesses  that  compete  directly  or  indirectly  with  us.  USD’s  limited  liability  company  agreement
provides that Energy Capital Partners shall not have any duty to refrain from engaging directly or indirectly in the same or similar business activities or lines
of business as us or any of our subsidiaries, and that in the event that Energy Capital Partners acquires knowledge of a potential transaction or matter which
may be a corporate opportunity for itself and us or any of our subsidiaries, neither we nor any of our subsidiaries shall, to the fullest extent permitted by law,
have  any  expectancy  in  such  corporate  opportunity,  and  Energy  Capital  Partners  shall  not,  to  the  fullest  extent  permitted  by  law,  have  any  duty  to
communicate or offer such corporate opportunity to us or any of our subsidiaries and may pursue or acquire such corporate opportunity for itself or direct
such corporate opportunity to another person. Energy Capital Partners and its affiliates may also pursue acquisition opportunities that are complementary to
our business and, as a result, those acquisition opportunities may not be available to us. Please refer to the discussion under Item 10. Directors, Executive
Officers and Corporate Governance—Special Approval Rights of Energy Capital Partners regarding the rights of Energy Capital Partners. 

Energy Capital Partners, upon giving written notice, shall have the right to compel USD to effect the total sale of Energy Capital Partners’ interests in
USD, which we refer to as an ECP Exit. Such a sale could include an acquisition by the remaining owners of USD of Energy Capital Partners’ interests in
USD  or  an  initial  public  offering  of  USD.  If  the  ECP  Exit  has  not  been  completed  within  180  days  of  the  date  USD  receives  notice  of  Energy  Capital
Partners’ desire to sell, Energy Capital Partners shall have the right to compel USD to effect a total sale of USD pursuant to an auction process on terms and
conditions determined by, and in a process managed by, the members of USD’s board of directors that are appointed by Energy Capital Partners, provided that
certain conditions in connection with the sale are met.  

We intend to distribute a significant portion of our available cash, which could limit our ability to pursue growth projects and make acquisitions.  

Pursuant to our cash distribution policy we intend to distribute most of our available cash, as that term is defined in our partnership agreement, to our
unitholders. As a result, we expect to rely primarily upon external financing sources, including commercial bank borrowings and the issuance of debt and
equity securities, to fund our acquisitions and expansion capital expenditures. Therefore, to the extent we are unable to finance our growth externally, our cash
distribution policy will significantly impair our ability to grow. In addition, because we intend to distribute most of our available cash, our growth may not be
as fast as that of businesses that reinvest their available cash to expand ongoing operations. To the extent we issue additional units in connection with any
acquisitions or expansion capital expenditures, the payment of distributions on those additional units may increase the risk that we will be unable to maintain
or increase our per unit distribution level. There are no limitations in our partnership agreement or our senior secured credit agreement on our ability to issue
additional units, including units ranking senior to the common units as to distribution or liquidation, and our unitholders will have no preemptive or other
rights (solely as a result of their status as unitholders) to purchase any such additional units. The incurrence of additional commercial borrowings or other debt
to  finance  our  growth  strategy  would  result  in  increased  interest  expense,  which,  in  turn,  may  reduce  the  amount  of  cash  available  to  distribute  to  our
unitholders.  

39

The  board  of  directors  of  our  general  partner  may  modify  or  revoke  our  cash  distribution  policy  at  any  time  at  its  discretion  and  our  partnership
agreement does not require us to pay any distributions at all. Additionally, members of our general partner’s board of directors appointed by Energy
Capital Partners must approve any distributions made by us.  

The board of directors of our general partner has adopted a cash distribution policy pursuant to which we intend to distribute quarterly at least $0.2875
per unit on all of our units to the extent we have sufficient cash after the establishment of cash reserves and the payment of our expenses, including payments
to  our  general  partner  and  its  affiliates.  However,  the  board  may  change  such  policy  at  any  time  at  its  discretion.  Additionally,  members  of  our  general
partner’s board of directors appointed by Energy Capital Partners, if any, must approve any distributions made by us. Our partnership agreement does not
require  us  to  pay  distributions  at  all  and  our  general  partner’s  board  of  directors  has  broad  discretion  in  setting  the  amount  of  cash  reserves  each  quarter.
Investors are cautioned not to place undue reliance on the permanence of our cash distribution policy in making an investment decision. Any modification or
revocation of our cash distribution policy could substantially reduce or eliminate the amounts of distributions to our unitholders. The amount of distributions
we  make  and  the  decision  to  make  any  distribution  is  determined  by  the  board  of  directors  of  our  general  partner  as  well  as  the  members  of  our  general
partner’s board of directors appointed by Energy Capital Partners, whose interests may differ from those of our common unitholders. Our general partner has
limited duties to our unitholders, which may permit it to favor its own interests or the interests of our sponsor or its affiliates to the detriment of our common
unitholders.  

Our partnership agreement replaces our general partner’s fiduciary duties to holders of our common units with contractual standards governing its
duties.  

Our  partnership  agreement  contains  provisions  that  eliminate  the  fiduciary  standards  to  which  our  general  partner  would  otherwise  be  held  by  state
fiduciary duty law and replaces those duties with several different contractual standards. For example, our partnership agreement permits our general partner
to make a number of decisions in its individual capacity, as opposed to in its capacity as our general partner, free of any duties to us and our unitholders. This
provision entitles our general partner to consider only the interests and factors that it desires and relieves it of any duty or obligation to give any consideration
to any interest of, or factors affecting, us, our affiliates or our limited partners. By purchasing a common unit, a unitholder is treated as having consented to
the provisions in our partnership agreement, including the provisions discussed above. Please refer to the discussion under Item 13. Certain Relationships and
Related Transactions, and Director Independence regarding conflicts of interests and fiduciary duties of our general partner.  

Our partnership agreement restricts the remedies available to holders of our common and subordinated units for actions taken by our general partner
that might otherwise constitute breaches of fiduciary duty.  

Our  partnership  agreement  contains  provisions  that  restrict  the  remedies  available  to  unitholders  for  actions  taken  by  our  general  partner  that  might

otherwise constitute breaches of fiduciary duty under state fiduciary duty law. For example, our partnership agreement:

• provides that whenever our general partner makes a determination or takes, or declines to take, any other action in its capacity as our general partner,
our general partner is required to make such determination, or take or decline to take such other action, in good faith and will not be subject to any
higher standard imposed by our partnership agreement, Delaware law, or any other law, rule or regulation, or at equity;

• provides that our general partner and its officers and directors will not be liable for monetary damages to us or our limited partners resulting from
any act or omission unless there has been a final and non-appealable judgment entered by a court of competent jurisdiction determining that our
general  partner  or  its  officers  and  directors,  as  the  case  may  be,  acted  in  bad  faith  or  engaged  in  fraud  or  willful  misconduct  or,  in  the  case  of  a
criminal matter, acted with knowledge that the conduct was criminal; and

• provides that our general partner will not be in breach of its obligations under our partnership agreement or its fiduciary duties to us or our limited
partners if a transaction with an affiliate or the resolution of a conflict of interest is approved in accordance with, or otherwise meets the standards
set forth in, our partnership agreement.  

In  connection  with  a  situation  involving  a  transaction  with  an  affiliate  or  a  conflict  of  interest,  our  partnership  agreement  provides  that  any
determination  by  our  general  partner  must  be  made  in  good  faith,  and  that  our  conflicts  committee  and  the  board  of  directors  of  our  general  partner  are
entitled to a presumption that they acted in good faith. In any proceeding brought by or on behalf of any limited partner of the partnership, the person bringing
or prosecuting such proceeding will have the burden of overcoming such presumption. Please refer to the discussion under Item 13. Certain Relationships and
Related Transactions, and Director Independence regarding conflicts of interests and fiduciary duties of our general partner.  

40

Our general partner has limited liability regarding our obligations.  

Our general partner has limited liability under our contractual arrangements so that the counterparties to such arrangements have recourse only against
our assets, and not against our general partner or its assets. Our general partner may therefore cause us to incur indebtedness or other obligations that are
nonrecourse to our general partner. Our partnership agreement provides that any action taken by our general partner to limit its liability is not a breach of our
general partner’s fiduciary duties, even if we could have obtained more favorable terms without the limitation on liability. In addition, we are obligated to
reimburse or indemnify our general partner to the extent that it incurs obligations on our behalf. Any such reimbursement or indemnification payments would
reduce the amount of cash otherwise available for distribution to our unitholders.  

If you are not both a citizenship eligible holder and a rate eligible holder, your common units may be subject to redemption.  

In order to avoid (1) any material adverse effect on the maximum applicable rates that can be charged to customers by our subsidiaries on assets that are
subject to rate regulation by the FERC or analogous regulatory body, and (2) any substantial risk of cancellation or forfeiture of any property, including any
governmental permit, endorsement or other authorization, in which we have an interest, we have adopted certain requirements regarding those investors who
may  own  our  common  units.  Citizenship  eligible  holders  are  individuals  or  entities  whose  nationality,  citizenship  or  other  related  status  does  not  create  a
substantial risk of cancellation or forfeiture of any property, including any governmental permit, endorsement or authorization, in which we have an interest,
and  will  generally  include  individuals  and  entities  who  are  U.S.  citizens.  Rate  eligible  holders  are  individuals  or  entities  subject  to  U.S.  federal  income
taxation on the income generated by us or entities not subject to U.S. federal income taxation on the income generated by us, so long as all of the entity’s
owners are subject to such taxation. If you are not a person who meets the requirements to be a citizenship eligible holder and a rate eligible holder, you run
the risk of having your units redeemed by us at the market price as of the date three days before the date the notice of redemption is mailed. The redemption
price  will  be  paid  in  cash  or  by  delivery  of  a  promissory  note,  as  determined  by  our  general  partner.  In  addition,  if  you  are  not  a  person  who  meets  the
requirements to be a citizenship eligible holder, you will not be entitled to voting rights.  

Cost reimbursements, which are determined in our general partner’s sole discretion, and fees due to our general partner and its affiliates for services
provided are substantial and reduce our distributable cash flow to you.  

Under our partnership agreement, we are required to reimburse our general partner and its affiliates for all costs and expenses that they incur on our
behalf  for  managing  and  controlling  our  business  and  operations.  Except  to  the  extent  specified  under  the  Omnibus  Agreement,  our  general  partner
determines the amount of these expenses. Under the terms of the Omnibus Agreement we are required to reimburse USD for providing certain general and
administrative services to us. Our general partner and its affiliates also may provide us other services for which we will be charged fees. Payments to our
general partner and its affiliates are substantial and reduce the amount of distributable cash flow to unitholders. For the twelve months ending December 31,
2020,  we  estimate  that  these  expenses  will  be  approximately  $3.3 million,  which  includes,  among  other  items,  compensation  expense  for  all  employees
required to manage and operate our business. For a description of the cost reimbursements to our general partner, please read the discussion under Part II,
Item 8. Financial Statements and Supplementary Data, Note 13. Transactions with Related Parties regarding reimbursements to our general partner under the
Omnibus Agreement.  

Unitholders have very limited voting rights and, even if they are dissatisfied, they cannot remove our general partner without its consent.  

Unlike  the  holders  of  common  stock  in  a  corporation,  unitholders  have  only  limited  voting  rights  on  matters  affecting  our  business  and,  therefore,
limited  ability  to  influence  management’s  decisions  regarding  our  business.  Unitholders  do  not  elect  our  general  partner  or  the  board  of  directors  of  our
general partner and have no right to elect our general partner or the board of directors of our general partner on an annual or other continuing basis. The board
of directors of our general partner is chosen by the members of our general partner, which is indirectly owned by USD. Furthermore, if the unitholders are
dissatisfied with the performance of our general partner, they will have little ability to remove our general partner. As a result of these limitations, the price at
which our common units trade could be diminished because of the absence or reduction of a takeover premium in the trading price.  

The unitholders are unable initially to remove our general partner without its consent because our general partner and its affiliates own sufficient units
to prevent its removal. The vote of the holders of at least 66 2/3% of all outstanding units voting together as a single class is required to remove our general
partner. At December 31, 2019, our general partner and its affiliates own 42.9% of the limited partnership interests entitled to vote in this matter (excluding
general partner units and without consideration of any common units held by our officers, directors, employees and certain other persons affiliated

41

with us). Also, if our general partner is removed without cause during the time any subordinated units are outstanding and the subordinated units held by our
general partner and its affiliates are not voted in favor of that removal, all remaining subordinated units will automatically be converted into common units,
and any existing arrearages on the common units will be extinguished. A removal of our general partner under these circumstances would adversely affect the
common units by prematurely eliminating their distribution and liquidation preference over the subordinated units, which would otherwise have continued
until we had met certain distribution and performance tests.  

“Cause”  is  narrowly  defined  under  our  partnership  agreement  to  mean  that  a  court  of  competent  jurisdiction  has  entered  a  final,  non-appealable
judgment finding the general partner liable for actual fraud or willful misconduct in its capacity as our general partner. Cause does not include most cases of
charges  of  poor  management  of  the  business,  so  the  removal  of  our  general  partner  because  of  the  unitholders’  dissatisfaction  with  our  general  partner’s
performance in managing us will most likely result in the automatic conversion to common units of all remaining outstanding subordinated units. 

Furthermore, unitholders’ voting rights are further restricted by the partnership agreement provision providing that any units held by a person that owns
20.0% or more of any class of units then outstanding, other than our general partner, its affiliates, their transferees, and persons who acquired such units with
the prior approval of the board of directors of our general partner, cannot vote on any matter.  

Our partnership agreement also contains provisions limiting the ability of unitholders to call meetings or to acquire information about our operations, as

well as other provisions limiting the unitholders’ ability to influence the manner or direction of management.  

Our general partner interest or the control of our general partner may be transferred to a third party without unitholder consent.  

Our general partner may transfer its general partner interest to a third party at any time without the consent of the unitholders. Furthermore, there is no
restriction in our partnership agreement on the ability of USD Group LLC to transfer its membership interest in our general partner to a third party. The new
owners of our general partner would then be in a position to replace the board of directors and officers of our general partner with their own choices and to
control the decisions taken by the board of directors and officers.  

The incentive distribution rights of our general partner may be transferred to a third party without unitholder consent.

Our  general  partner  may  transfer  its  incentive  distribution  rights  to  a  third  party  at  any  time  without  the  consent  of  our  unitholders.  If  our  general
partner transfers its incentive distribution rights to a third party but retains its general partner interest, our general partner may not have the same incentive to
grow our partnership and increase quarterly distributions to unitholders over time as it would if it had retained ownership of its incentive distribution rights.
For example, a transfer of incentive distribution rights by our general partner could reduce the likelihood of USD selling or contributing additional midstream
infrastructure assets and businesses to us, as USD would have less of an economic incentive to grow our business, which in turn would impact our ability to
grow our asset base.

We may issue additional units without unitholder approval, which would dilute unitholder interests.  

At any time, we may issue an unlimited number of limited partner interests of any type without the approval of our unitholders and our unitholders will
have  no  preemptive  or  other  rights  (solely  as  a  result  of  their  status  as  unitholders)  to  purchase  any  such  limited  partner  interests.  Further,  neither  our
partnership agreement nor our senior secured credit agreement prohibits the issuance of equity securities that may effectively rank senior to our common units
as to distributions or liquidations. The issuance by us of additional common units or other equity securities of equal or senior rank will have the following
effects:

• our unitholders’ proportionate ownership interest in us will decrease;

• the amount of distributable cash flow on each unit may decrease;

• because a lower percentage of total outstanding units will be subordinated units, the risk that a shortfall in the payment of the minimum quarterly

distribution will be borne by our common unitholders will increase;

• the ratio of taxable income to distributions may increase;

• the relative voting strength of each previously outstanding unit may be diminished; and

• the market price of our common units may decline.  

42

USD Group LLC may sell or transfer our units in the public or private markets, and such sales could have an adverse impact on the trading price of
the common units.  

USD  Group  LLC  held  9,464,381  common  units  and  2,092,709  subordinated  units  at  December  31,  2019.  All  of  the  remaining  subordinated  units
converted into common units on a one-for-one basis on February 20, 2020. We have agreed to provide USD Group LLC with certain registration rights. USD
Group LLC and its affiliates may sell, transfer or pledge as security all or some of the units held by them without any duty to us. Such sale of units in the
public or private markets, or pledging or transfer of units, could have an adverse impact on the price of the common units.  At December 31, 2019, a value of
up to $10.0 million of these common units were pledged as collateral by USD Group LLC for their letter of credit facility.

Our general partner’s discretion in establishing cash reserves may reduce the amount of distributable cash flow to unitholders.  

Our  partnership  agreement  requires  our  general  partner  to  deduct  from  operating  surplus  cash  reserves  that  it  determines  are  necessary  to  fund  our
future operating expenditures. In addition, our partnership agreement permits the general partner to reduce available cash by establishing cash reserves for the
proper conduct of our business, to comply with applicable law or agreements to which we are a party, or to provide funds for future distributions to partners.
These cash reserves will affect the amount of distributable cash flow to unitholders.  

Affiliates  of  our  general  partner,  including  USD,  and  Energy  Capital  Partners  and  its  affiliates  may  compete  with  us,  and  none  of  Energy  Capital
Partners, our general partner or any of their respective affiliates have any obligation to present business opportunities to us.  

Neither our partnership agreement nor the Omnibus Agreement prohibits USD or any other affiliates of our general partner or Energy Capital Partners
or its affiliates from owning assets or engaging in businesses that compete directly or indirectly with us. In addition, USD and other affiliates of our general
partner,  and  Energy  Capital  Partners  and  its  affiliates  may  acquire,  construct  or  dispose  of  additional  midstream  infrastructure  in  the  future  without  any
obligation to offer us the opportunity to purchase any of those assets. For example, USD Group LLC currently owns the right to construct and further develop
the Hardisty terminal, which USD Group LLC expects to complete in a future period. If we are unable to acquire these facilities from USD Group LLC, these
expansions may compete directly with our Hardisty terminal for future throughput volumes, which may impact our ability to enter into new terminal services
agreements, including with our existing customers, following the termination of our existing agreements or the terms thereof and our ability to compete for
future spot volumes. As a result, competition from USD and other affiliates of our general partner could materially adversely impact our results of operations
and distributable cash flow to unitholders.

Our general partner may cause us to borrow funds in order to make cash distributions, even where the purpose or effect of the borrowing benefits the
general partner or its affiliates.  

In some instances, our general partner may cause us to borrow funds under our Revolving Credit Facility, from USD or otherwise from third parties in
order to permit the payment of cash distributions. These borrowings are permitted even if the purpose and effect of the borrowing is to enable us to make a
distribution on the subordinated units, to make incentive distributions or to satisfy the conditions required to convert subordinated units into common units.  

Our general partner has a limited call right that it may exercise at any time it or its affiliates own more than 80.0% of the outstanding limited partner
interests and that may require you to sell your common units at an undesirable time or price.  

If at any time our general partner and its affiliates own more than 80.0% of the then issued and outstanding common units, our general partner has the
right, but not the obligation, which it may assign to any of its affiliates or to us, to acquire all, but not less than all, of the common units held by unaffiliated
persons at a price not less than their then-current market price. As a result, you may be required to sell your common units at an undesirable time or price and
may not receive any return on your investment. You may also incur a tax liability upon a sale of your units. Our general partner and its affiliates own 35.1%
of our common units (excluding any common units held by our officers, directors, employees and certain other persons affiliated with us) and 42.9% of our
common units assuming the conversion of all subordinated units into common units.

 Your liability may not be limited if a court finds that unitholder action constitutes control of our business.  

A general partner of a partnership generally has unlimited liability for the obligations of the partnership, except for those contractual obligations of the
partnership  that  are  expressly  made  non-recourse  to  the  general  partner.  Our  partnership  is  organized  under  Delaware  law,  and  we  conduct  business  in  a
number of other states. The limitations on the liability of

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holders of limited partner interests for the obligations of a limited partnership have not been clearly established in some jurisdictions. You could be liable for
our obligations as if you were a general partner if a court or government agency were to determine that:

• we were conducting business in a state but had not complied with that particular state’s partnership statute; or

• your right to act with other unitholders to remove or replace the general partner, to approve some amendments to our partnership agreement or to

take other actions under our partnership agreement constitute “control” of our business.  

Unitholders may have to repay distributions that were wrongfully distributed to them.  

Under certain circumstances, unitholders may have to repay amounts wrongfully distributed to them. Under Section 17-607 of the Delaware Revised
Uniform Limited Partnership Act, we may not make a distribution to you if the distribution would cause our liabilities to exceed the fair value of our assets.
Delaware law provides that for a period of three years from the date of the impermissible distribution, limited partners who received the distribution and who
knew at the time of the distribution that it violated Delaware law will be liable to the limited partnership for the distribution amount. Transferees of common
units are liable for the obligations of the transferor to make contributions to the partnership that are known to the transferee at the time of the transfer and for
unknown obligations if the liabilities could be determined from our partnership agreement. Liabilities to partners on account of their partnership interest and
liabilities that are non-recourse to the partnership are not counted for purposes of determining whether a distribution is permitted.

Because our common units are yield-oriented securities, increases in interest rates could adversely impact our unit price, our distributable cash flow,
our ability to issue equity or incur debt for acquisitions or other purposes and our ability to make cash distributions at our intended levels.  

Interest rates may increase in the future. As a result, interest rates on our future indebtedness could be higher than current levels, causing our financing
costs to increase accordingly. As with other yield-oriented securities, our unit price is affected by the level of our cash distributions and implied distribution
yield.  The  distribution  yield  is  often  used  by  investors  to  compare  and  rank  yield-oriented  securities  for  investment  decision-making  purposes.  Therefore,
changes  in  interest  rates,  either  positive  or  negative,  may  affect  our  interest  expense  and  distributable  cash  flow,  the  yield  requirements  of  investors  who
invest  in  our  units,  and  a  rising  interest  rate  environment  could  have  an  adverse  impact  on  our  unit  price,  our  ability  to  issue  equity  or  incur  debt  for
acquisitions or other purposes and our ability to make cash distributions at our intended levels. 

The  holder  of  our  incentive  distribution  rights  may  elect  to  cause  us  to  issue  common  units  and  general  partner  units  to  it  in  connection  with  a
resetting of the target distribution levels related to its incentive distribution rights, without the approval of our conflicts committee or the holders of our
common units. This could result in lower distributions to holders of our common units.  

Our  general  partner  has  the  right,  at  any  time  when  there  are  no  subordinated  units  outstanding  and  it  has  received  distributions  on  its  incentive
distribution rights at the highest level to which it is entitled (48.0%, in addition to distributions paid on its general partner interest) for each of the prior four
consecutive  fiscal  quarters,  to  reset  the  initial  target  distribution  levels  at  higher  levels  based  on  our  distributions  at  the  time  of  the  exercise  of  the  reset
election.  Following  a  reset  election,  the  minimum  quarterly  distribution  will  be  adjusted  to  equal  the  reset  minimum  quarterly  distribution,  and  the  target
distribution levels will be reset to correspondingly higher levels based on percentage increases above the reset minimum quarterly distribution.  

If our general partner elects to reset the target distribution levels, it will be entitled to receive a number of common units and general partner units. The
number of common units to be issued to our general partner will be equal to that number of common units that would have entitled the general partner to a
quarterly cash distribution equal to distributions to our general partner on the incentive distribution rights in the prior quarter. Our general partner will also be
issued the number of general partner units necessary to maintain our general partner’s interest in us at the level that existed immediately prior to the reset
election. We anticipate that our general partner would exercise this reset right in order to facilitate acquisitions or internal growth projects that would not be
sufficiently accretive to cash distributions per common unit without such conversion. It is possible, however, that our general partner could exercise this reset
election at a time when it is experiencing, or expects to experience, declines in the cash distributions it receives related to its incentive distribution rights and
may, therefore, desire to be issued common units rather than retain the right to receive distributions based on the initial target distribution levels. This risk
could be elevated if our incentive distribution rights have been transferred to a third party. As a result, a reset election may cause our common unitholders to
experience a reduction in the amount of cash distributions that they would have otherwise received had we not issued new common units and general partner
units in connection with resetting the target distribution levels. Additionally, our general partner has the right to transfer all or any portion of our

44

incentive distribution rights at any time, and such transferee shall have the same rights as the general partner relative to resetting target distributions if our
general partner concurs that the tests for resetting target distributions have been fulfilled.

The  New  York  Stock  Exchange,  or  NYSE,  does  not  require  a  publicly  traded  limited  partnership  like  us  to  comply  with  certain  of  its  corporate
governance requirements.  

Our common units are listed on the NYSE. Because we are a publicly traded limited partnership, the NYSE does not require us to have a majority of
independent  directors  on  our  general  partner’s  board  of  directors  or  to  establish  a  compensation  committee  or  a  nominating  and  corporate  governance
committee. Accordingly, unitholders will not have the same protections afforded to shareholders of corporations that are subject to all of the NYSE corporate
governance requirements.

The price of our common units may fluctuate significantly, and you could lose all or part of your investment.

The market price of our common units may also be influenced by many factors, some of which are beyond our control, including:

our quarterly distributions;

our quarterly or annual earnings or those of other companies in our industry;

announcements by us or our competitors of significant contracts or acquisitions;

changes in accounting standards, policies, guidance, interpretations or principles;

general economic conditions;

the failure of securities analysts to cover our common units or changes in financial estimates by analysts;

future sales of our common units; and

other factors described in these “Risk Factors.”

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Tax Risks

Our tax treatment depends on our status as a partnership for U.S. federal income tax purposes. If the Internal Revenue Service, or IRS, were to treat
us  as  a  corporation  for  U.S.  federal  income  tax  purposes,  which  would  subject  us  to  entity-level  taxation,  then  our  distributable  cash  flow  to  our
unitholders would be substantially reduced.  

The anticipated after-tax economic benefit of an investment in our common units depends largely on our being treated as a partnership for U.S. federal

income tax purposes.  

Despite the fact that we are a limited partnership under Delaware law, it is possible in certain circumstances for a partnership such as ours to be treated
as a corporation for U.S. federal income tax purposes. Although we do not believe based upon our current operations that we are so treated, the IRS could
disagree with the positions we take or a change in our business or a change in current law could cause us to be treated as a corporation for U.S. federal income
tax purposes or otherwise subject us to taxation as an entity.

     If we were treated as a corporation for U.S. federal income tax purposes, we would pay U.S. federal income tax on our taxable income at the corporate tax
rate, which is currently a maximum of 21.0%, and would likely pay state and local income tax at varying rates. Distributions would generally be taxed again
as corporate dividends (to the extent of our current and accumulated earnings and profits), and no income, gains, losses, deductions, or credits would flow
through to you. Because a tax would be imposed upon us as a corporation, our distributable cash flow would be substantially reduced. Therefore, if we were
treated  as  a  corporation  for  U.S.  federal  income  tax  purposes,  there  would  be  a  material  reduction  in  the  anticipated  cash  flow  and  after-tax  return  to  our
unitholders, likely causing a substantial reduction in the value of our common units.

Our  partnership  agreement  provides  that,  if  a  law  is  enacted  or  existing  law  is  modified  or  interpreted  in  a  manner  that  subjects  us  to  taxation  as  a
corporation or otherwise subjects us to entity-level taxation for federal, state or local income tax purposes, the minimum quarterly distribution amount and the
target distribution levels may be adjusted to reflect the impact of that law on us.  

Notwithstanding  our  treatment  for  U.S.  federal  income  tax  purposes,  we  are  subject  to  certain  non-U.S.-taxes.  If  a  taxing  authority  were  to
successfully assert that we have more tax liability than we anticipate or legislation were enacted that increased the taxes to which we are subject, the
distributable cash flow to our unitholders could be further reduced.

Some of our business operations and subsidiaries are subject to income, withholding and other taxes in the non-U.S. jurisdictions in which they are
organized or from which they receive income, reducing the amount of distributable cash flow. In computing our tax obligation in these non-U.S. jurisdictions,
we are required to take various tax accounting and reporting

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positions on matters that are not entirely free from doubt and for which we have not received rulings from the governing tax authorities, such as whether
withholding taxes will be reduced by the application of certain tax treaties. Upon review of these positions the applicable authorities may not agree with our
positions.  A  successful  challenge  by  a  taxing  authority  could  result  in  additional  tax  being  imposed  on  us,  reducing  the  distributable  cash  flow  to  our
unitholders. In addition, changes in our operations or ownership could result in higher than anticipated tax being imposed in jurisdictions in which we are
organized or from which we receive income and further reduce the distributable cash flow. Although these taxes may be properly characterized as foreign
income taxes, you may not be able to credit them against your liability for U.S. federal income taxes on your share of our earnings.  

If we were subjected to a material amount of additional entity-level taxation by individual states, counties or cities, it would reduce our distributable
cash flow to our unitholders.  

Changes in current state, county or city law may subject us to additional entity-level taxation by individual states, counties or cities. Several states have
subjected, or are evaluating ways to subject partnerships to entity-level taxation through the imposition of state income, franchise and other forms of taxation.
Imposition of any such taxes may substantially reduce the distributable cash flow to you and the value of our common units could be negatively impacted.
Our partnership agreement provides that, if a law is enacted or existing law is modified or interpreted in a manner that subjects us to entity-level taxation, the
minimum quarterly distribution amount and the target distribution levels may be adjusted to reflect the impact of that law on us.  

The tax treatment of publicly traded partnerships, companies with multinational operations or an investment in our common units could be subject to
potential legislative, judicial or administrative changes and differing interpretations, possibly on a retroactive basis.  

The  present  U.S.  federal  income  tax  treatment  of  publicly  traded  partnerships,  companies  with  multinational  operations,  or  an  investment  in  our
common  units  may  be  modified  by  administrative,  legislative  or  judicial  interpretation  at  any  time.  From  time  to  time,  members  of  Congress  and  the
Department  of  Treasury  have  proposed  and  considered  substantive  changes  to  the  existing  U.S.  federal  income  tax  laws  that  affect  publicly  traded
partnerships,  including  a  prior  legislative  proposal  that  would  have  eliminated  the  qualifying  income  exception  to  the  treatment  of  all  publicly-traded
partnerships as corporations upon which we rely for our treatment as a partnership for U.S. federal income tax purposes. In addition, the Treasury Department
has issued, and in the future may issue, regulations interpreting those laws that affect publicly traded partnerships. Although there are no current legislative or
administrative proposals, there can be no assurance that there will not be further changes to the U.S. federal income tax laws or the Treasury Department’s
interpretation of the qualifying income rules in a manner that could impair our ability to qualify as a publicly traded partnership in the future.

Any  modification  to  the  U.S.  federal  income  tax  laws  and  interpretations  thereof  may  or  may  not  be  retroactively  applied  and  could  make  it  more
difficult or impossible to meet the exception for us to be treated as a partnership for U.S. federal income tax purposes. We are unable to predict whether any
changes  or  other  proposals  will  ultimately  be  enacted.  Any  future  legislative  changes  could  negatively  impact  the  value  of  an  investment  in  our  common
units. You are urged to consult your own tax advisor with respect to the status of regulatory or administrative developments and proposals and their potential
effect on your investment in our common units.  

Our unitholders’ share of our income will be taxable to them for U.S. federal income tax purposes even if they do not receive any cash distributions
from  us.  A  unitholder’s  share  of  our  taxable  income,  and  its  relationship  to  any  distributions  we  make,  may  be  affected  by  a  variety  of  factors,
including our economic performance, transactions in which we engage or changes in law. 

Because a unitholder is treated as a partner to whom we will allocate taxable income that could be different in amount than the cash we distribute, a
unitholder’s allocable share of our taxable income will be taxable to the unitholder, which may require the payment of U.S. federal income taxes and, in some
cases,  state  and  local  income  taxes,  on  the  unitholder’s  share  of  our  taxable  income  even  if  the  unitholder  receives  no  cash  distributions  from  us.  Our
unitholders may not receive cash distributions from us equal to their share of our taxable income or even equal to the actual tax liability that results from that
income.

A unitholder’s share of our taxable income, and its relationship to any distributions we make, may be affected by a variety of factors, including our
economic performance, which may be affected by numerous business, economic, regulatory, legislative, competitive and political uncertainties beyond our
control, and certain transactions in which we might engage. For example, we may engage in transactions that produce substantial taxable income allocations
to some or all of our unitholders without a corresponding increase in cash distributions to our unitholders, such as a sale or exchange of assets, the proceeds of
which are reinvested in our business or used to reduce our debt. A unitholder’s ratio of its share of taxable income to the cash received by it may also be
affected by changes in law. For instance, under the tax reform law commonly

46

known  as  the  Tax  Cuts  and  Jobs  Act,  the  net  interest  expense  deductions  of  certain  business  entities,  including  us,  are  limited  to  30%  of  such  entity’s
“adjusted taxable income,” which is generally taxable income with certain modifications. If the limit applies, a unitholder’s taxable income allocations will be
more (or its net loss allocations will be less) than would have been the case absent the limitation. 

If the IRS contests the U.S. federal income tax positions we take, the market for our common units may be adversely impacted and the cost of any IRS
contest will reduce our distributable cash flow to our unitholders.  

We have not requested a ruling from the IRS with respect to our treatment as a partnership for U.S. federal income tax purposes. The IRS may adopt
positions that differ from the positions we take, and the IRS’s positions may ultimately be sustained. It may be necessary to resort to administrative or court
proceedings to sustain some or all of the positions we take and such positions may not ultimately be sustained. Any contest with the IRS, and the outcome of
any IRS contest, may have a materially adverse impact on the market for our common units and the price at which they trade. In addition, our costs for any
contest with the IRS will be borne indirectly by our unitholders and our general partner because the costs will reduce our distributable cash flow.

Some of our activities may not generate qualifying income, and we conduct these activities in a separate subsidiary that is treated as a corporation for
U.S. federal income tax purposes. Corporate U.S. federal income tax paid by this subsidiary reduces our cash available for distribution. 

  In  order  to  maintain  our  status  as  a  partnership  for  U.S.  federal  income  tax  purposes,  90%  or  more  of  our  gross  income  in  each  tax  year  must  be
qualifying income under Section 7704 of the Internal Revenue Code. To ensure that 90% or more of our gross income in each tax year is qualifying income,
we currently conduct a portion of our business, relating to railcar fleet services, in a separate subsidiary that is treated as a corporation for U.S. federal income
tax purposes.

Such corporate subsidiary is subject to corporate-level federal income tax on its taxable income at the corporate tax rate, which is currently a maximum
of 21%, and will also likely pay state (and possibly local) income tax at varying rates, on its taxable income. If the IRS were to successfully assert that such
corporate  subsidiary  has  more  tax  liability  than  we  anticipate  or  legislation  were  enacted  that  increased  the  corporate  tax  rate,  our  cash  available  for
distribution to our unitholders would be further reduced.

If the IRS makes audit adjustments to our income tax returns for tax years beginning after December 31, 2017, it (and some states) may assess and
collect  any  taxes  (including  any  applicable  penalties  and  interest)  resulting  from  such  audit  adjustments  directly  from  us,  in  which  case  our  cash
available for distribution to our unitholders might be substantially reduced and our current and former unitholders may be required to indemnify us
for any taxes (including any applicable penalties and interest) resulting from such audit adjustments that were paid on such unitholders’ behalf.

For tax years beginning after December 31, 2017, if the IRS makes audit adjustments to our income tax returns, it (and some states) may assess and
collect any taxes (including any applicable penalties and interest) resulting from such audit adjustments directly from us. To the extent possible under the new
rules, our general partner may elect to either pay the taxes (including any applicable penalties and interest) directly to the IRS or, if we are eligible, issue a
revised information statement to each unitholder and former unitholder with respect to an audited and adjusted return. Although our general partner may elect
to have our unitholders and former unitholders take such audit adjustments into account and pay any resulting taxes (including applicable penalties or interest)
in  accordance  with  their  interests  in  us  during  the  tax  year  under  audit,  there  can  be  no  assurance  that  such  election  will  be  practicable,  permissible  or
effective in all circumstances. As a result, our current unitholders may bear some or all of the tax liability resulting from such audit adjustment, even if such
unitholders did not own units in us during the tax year under audit. If, as a result of any such audit adjustment, we are required to make payments of taxes,
penalties and interest, our cash available for distribution to our unitholders might be substantially reduced and our current and former unitholders may be
required  to  indemnify  us  for  any  taxes  (including  any  applicable  penalties  and  interest)  resulting  from  such  audit  adjustments  that  were  paid  on  such
unitholders behalf.

Tax gain or loss on the disposition of our common units could be more or less than expected.  

If our unitholders sell common units, they will recognize a gain or loss for U.S. federal income tax purposes equal to the difference between the amount
realized and their tax basis in those common units. Because distributions in excess of their allocable share of our net taxable income decrease their tax basis in
their common units, the amount, if any, of such prior excess distributions with respect to the common units a unitholder sells will, in effect, become taxable
income to the unitholder if it sells such common units at a price greater than its tax basis in those common units, even if the price received is less than its
original cost. Furthermore, a substantial portion of the amount realized on a sale of common units, whether or not representing gain, may be taxed as ordinary
income due to potential recapture of depreciation deductions. Thus, selling

47

unitholders may recognize both ordinary income and capital loss from the sale of their units if the amount realized on a sale of their units is less than their
adjusted basis in the units. Net capital loss may only offset capital gains and, in the case of individuals, up to $3,000 of ordinary income per year. In the
taxable period in which a selling unitholder sells their units, they may recognize ordinary income from our allocations of income and gain to them prior to the
sale and from recapture items that generally cannot be offset by any capital loss recognized upon the sale of units. In addition, because the amount realized
includes a unitholder’s share of our nonrecourse liabilities, a unitholder that sells common units, may incur a tax liability in excess of the amount of cash
received from the sale.  

Certain actions that we may take, such as issuing additional units, may increase the U.S. federal income tax liability of unitholders.

In the event we issue additional units or engage in certain other transactions in the future, the allocable share of nonrecourse liabilities allocated to the
unitholders will be recalculated to take into account our issuance of any additional units. Any reduction in a unitholder’s share of our nonrecourse liabilities
will  be  treated  as  a  distribution  of  cash  to  that  unitholder  and  will  result  in  a  corresponding  tax  basis  reduction  in  a  unitholder’s  units.  A  deemed  cash
distribution may, under certain circumstances, result in the recognition of taxable gain by a unitholder, to the extent that the deemed cash distribution exceeds
such  unitholder’s  tax  basis  in  its  units.  In  addition,  the  U.S.  federal  income  tax  liability  of  a  unitholder  could  be  increased  if  we  take  advantage  of  debt
reduction opportunities (e.g., debt exchanges, debt repurchases or modifications of existing debt), dispose of assets or make a future offering of units and use
the proceeds in a manner that does not produce substantial additional deductions, such as (i) to repay indebtedness currently outstanding or (ii) to acquire
property that is not eligible for depreciation or amortization for U.S. federal income tax purposes or that is depreciable or amortizable at a rate significantly
slower than the rate currently applicable to our existing assets.

There are limits on the deductibility of losses that may adversely affect unitholders.

In  the  case  of  taxpayers  subject  to  the  passive  loss  rules  (generally,  individuals,  closely-held  corporations  and  regulated  investment  companies),  any
losses generated by us will only be available to offset our future income and cannot be used to offset income from other activities, including other passive
activities  or  investments.  Unused  losses  may  be  deducted  when  the  unitholder  disposes  of  the  unitholder’s  entire  investment  in  us  in  a  fully  taxable
transaction with an unrelated party. A unitholder’s share of our net passive income may be offset by unused losses from us carried over from prior years, but
not  by  losses  from  other  passive  activities,  including  losses  from  other  publicly  traded  partnerships.  Further,  in  addition  to  the  other  limitations  described
above, non-corporate taxpayers may only deduct business losses up to the gross income or gain attributable to such trade or business plus $250,000 ($500,000
for unitholders filing jointly). Amounts that may not be deducted in a taxable year may be carried forward into the following taxable year. This limitation
shall be applied after the passive loss limitations and, unless amended, applies only to taxable years beginning prior to December 31, 2025.

Tax-exempt entities and non-U.S. persons face unique tax issues from owning our common units that may result in adverse tax consequences to them.

Investment in common units by tax-exempt entities, such as employee benefit plans and individual retirement accounts, or IRAs, and non-U.S. persons
raises issues unique to them. For example, virtually all of our income allocated to organizations that are exempt from U.S. federal income tax, including IRAs
and  other  retirement  plans,  will  be  unrelated  business  taxable  income  and  will  be  taxable  to  them.  Further,  subject  to  the  proposed  aggregation  rules  for
certain  similarly  situated  businesses  or  activities  issued  by  the  Treasury  Department,  a  tax-exempt  entity  with  more  than  one  unrelated  trade  or  business
(including  by  attribution  from  investment  in  a  partnership  such  as  ours)  is  required  to  compute  the  unrelated  business  taxable  income  of  such  tax-exempt
entity separately with respect to each such trade or business (including for purposes of determining any net operating loss deduction). As a result, it may not
be possible for tax-exempt entities to utilize losses from an investment in our partnership to offset unrelated business taxable income from another unrelated
trade or business and vice versa. If you are a tax-exempt entity, you should consult a tax advisor before investing in our common units.

Non-U.S. unitholders are generally taxed and subject to income tax filing requirements by the United States on income effectively connected with a
U.S.  trade  or  business  (“effectively  connected  income”).  Income  allocated  to  our  unitholders  and  any  gain  from  the  sale  of  our  units  will  generally  be
considered to be “effectively connected” with a U.S. trade or business. As a result, distributions to non-U.S. persons will be reduced by withholding taxes at
the highest applicable effective tax rate, and non-U.S. persons will be required to file U.S. federal income tax returns and pay tax on their share of our taxable
income. If you are a non-U.S. person, you should consult a tax advisor before investing in our common units.

48

 
We may be required to deduct and withhold amounts from distributions to foreign unitholders related to withholding tax obligations arising from the
sale or disposition of our units by foreign unitholders.

Upon  the  sale,  exchange  or  other  disposition  of  a  unit  by  a  foreign  unitholder,  the  transferee  is  generally  required  to  withhold  10%  of  the  amount
realized  on  such  sale,  exchange  or  other  disposition  if  any  portion  of  the  gain  on  such  sale,  exchange  or  other  disposition  would  be  treated  as  effectively
connected with a U.S. trade or business. If the transferee fails to satisfy this withholding requirement, we will be required to deduct and withhold such amount
(plus interest) from future distributions to the transferee. Because the “amount realized” would include a unitholder’s share of our nonrecourse liabilities, 10%
of the amount realized could exceed the total cash purchase price for such disposed units. Due to this fact, our inability to match transferors and transferees of
units, and other uncertainty surrounding the application of these withholding rules, the U.S. Department of the Treasury and the IRS have currently suspended
these rules for transfers of certain publicly traded partnership interests, including transfers of our units, until regulations or other guidance has been issued. It
is  unclear  when  such  regulations  or  other  guidance  will  be  issued.  If  you  are  a  non-U.S.  person,  you  should  consult  a  tax  advisor  before  investing  in  our
common units.

We  treat  each  purchaser  of  common  units  as  having  the  same  tax  benefits  without  regard  to  the  actual  common  units  purchased.  The  IRS  may
challenge this treatment, which could adversely affect the value of the common units.  

Because we cannot match transferors and transferees of common units and because of other reasons, we have adopted depreciation and amortization
positions  that  may  not  conform  to  all  aspects  of  existing  Treasury  regulations  promulgated  under  the  Internal  Revenue  Code  and  referred  to  as  “Treasury
Regulations.” A successful IRS challenge to those positions could adversely affect the amount of tax benefits available to you. A successful IRS challenge
could also affect the timing of these tax benefits or the amount of gain from your sale of common units and could have a negative impact on the value of our
common units or result in audit adjustments to your tax returns.

We prorate our items of income, gain, loss and deduction for U.S. federal income tax purposes between transferors and transferees of our units each
month  based  upon  the  ownership  of  our  units  on  the  first  business  day  of  each  month,  instead  of  on  the  basis  of  the  date  a  particular  unit  is
transferred. The IRS may challenge aspects of our proration method, which could change the allocation of items of income, gain, loss and deduction
among our unitholders.  

We prorate our items of income, gain, loss and deduction between transferors and transferees of our units each month based upon the ownership of our
units on the first day of each month, instead of on the basis of the date a particular unit is transferred. The U.S. Department of Treasury and the IRS have
issued  Treasury  Regulations  that  permit  publicly  traded  partnerships  to  use  a  monthly  simplifying  convention  that  is  similar  to  ours,  but  they  do  not
specifically authorize all aspects of the proration method we have adopted. If the IRS were to successfully challenge this method, we could be required to
change the allocation of items of income, gain, loss and deduction among our unitholders.

A unitholder whose common units are loaned to a “short seller” to effect a short sale of common units may be considered as having disposed of those
common units. If so, he would no longer be treated for U.S. federal income tax purposes as a partner with respect to those common units during the
period of the loan and may be required to recognize gain or loss from the disposition.  

Because a unitholder whose common units are loaned to a “short seller” to effect a short sale of common units may be considered as having disposed of
the loaned common units, he may no longer be treated for federal income tax purposes as a partner with respect to those common units during the period of
the loan to the short seller and the unitholder may be required to recognize gain or loss from such disposition. Moreover, during the period of the loan to the
short seller, any of our income, gain, loss or deduction with respect to those common units may not be reportable by the unitholder and any cash distributions
received by the unitholder as to those common units could be fully taxable as ordinary income. Unitholders desiring to assure their status as partners and
avoid the risk of gain recognition from a loan to a short seller are urged to modify any applicable brokerage account agreements to prohibit their brokers from
loaning their common units.  

We  have  adopted  certain  valuation  methodologies  in  determining  a  unitholder’s  allocations  of  income,  gain,  loss  and  deduction.  The  IRS  may
challenge these methodologies or the resulting allocations, and such a challenge could adversely affect the value of our common units.  

In determining the items of income, gain, loss and deduction allocable to our unitholders, in certain circumstances, including when we issue additional
units, we must determine the fair market value of our assets. Although we may from time to time consult with professional appraisers regarding valuation
matters, we make many fair value estimates using a methodology based on the market value of our common units as a means to measure the fair market value
of our assets. The IRS may challenge these valuation methods and the resulting allocations of income, gain, loss and deduction. For example,

49

our methodology may be viewed as understating the value of our assets. In that case, there may be a shift of income, gain, loss and deduction between certain
unitholders and our general partner, which may be unfavorable to such unitholders.

A successful IRS challenge to these methods or allocations could adversely affect the amount, character and timing of taxable income or loss allocated
to our unitholders. It also could affect the amount of gain from our unitholders’ sale of common units and could have a negative impact on the value of our
common units or result in audit adjustments to our unitholders’ tax returns without the benefit of additional deductions.

As a result of investing in our common units, you may become subject to state, local and foreign taxes and return filing requirements in jurisdictions
where we operate or own or acquire properties.  

In  addition  to  U.S.  federal  income  taxes,  our  unitholders  are  likely  subject  to  other  taxes,  including  state,  local  and  foreign  taxes,  unincorporated
business taxes and estate, inheritance or intangible taxes that are imposed by the various jurisdictions in which we conduct business or control property now
or in the future, even if they do not live in any of those jurisdictions. Our unitholders are likely required to file state, local and foreign income tax returns and
pay state and local income taxes in some or all of these various jurisdictions. Further, our unitholders may be subject to penalties for failure to comply with
those  requirements.  We  currently  own  assets  and  conduct  business  in  Alberta,  Canada,  California,  Texas,  Wyoming  and  Oklahoma.  Some  of  these
jurisdictions  currently  impose  a  personal  income  tax  on  individuals.  As  we  make  acquisitions  or  expand  our  business,  we  may  control  assets  or  conduct
business in additional states that impose a personal income tax. Our unitholders bear responsibility for filing all federal, state, local and foreign tax returns and
pay any taxes due in these jurisdictions. Unitholders should consult with their own tax advisors regarding the filing of such tax returns, the payment of such
taxes, and the deductibility of any taxes paid.

Item 1B. Unresolved Staff Comments

Not Applicable.

50

Item 2. Properties

A description of our properties is included in Item 1. Business, which is incorporated herein by reference.

Our Hardisty terminal is located on land we own. Our Casper terminal is located on land we own, as well as land owned by others, but operated by us
under leases with private land owners, public authorities, railways, or public utilities. Our West Colton terminal is located on land owned by others and is
operated by us under easements and rights-of-way, licenses, leases or permits that have been granted by private land owners, public authorities, railways or
public utilities. Our Stroud terminal is located on land we own, as well as land owned by others, but operated by us under licenses, rights-of-way or leases
with private land owners, public authorities, railways, or public utilities.

We have satisfactory title and other rights to our real estate assets.

Obligations under our senior secured credit facility are secured by a first priority lien on our assets and those of our restricted subsidiaries (as such term
is defined in our senior secured credit facility), other than certain excluded assets. Title to the real property necessary for us to operate our business may also
be subject to encumbrances in some cases, such as customary interests generally retained in connection with the acquisition of real property, liens that can be
imposed  in  some  jurisdictions  for  government-initiated  action  to  clean  up  environmental  contamination,  liens  for  current  taxes  and  other  burdens,  and
easements, restrictions, and other encumbrances to which the underlying properties were subject at the time of lease or acquisition by us. However, we do not
believe  that  any  of  these  burdens  would  materially  detract  from  the  value  of  these  properties  or  from  our  interest  in  these  properties  or  would  materially
interfere with their use in the operation of our business.

Item 3. Legal Proceedings

Although  we  may,  from  time  to  time,  be  involved  in  litigation  and  claims  arising  out  of  our  operations  in  the  normal  course  of  business,  we  are  not
currently  a  party  to  any  litigation  or  governmental  or  other  proceeding  that  we  believe  will  have  a  material  adverse  impact  on  our  consolidated  financial
condition  or  results  of  operations.  In  addition,  under  the  Omnibus  Agreement,  USD  has  agreed  to  indemnify  us  for  certain  liabilities  attributable  to  the
ownership or operation of the assets contributed to us in connection with the IPO that occurred prior to the closing of the IPO.

Item 4. Mine Safety Disclosures

Not Applicable.

51

PART II

Item 5. Market for Registrant’s Common Equity, Related Unitholder Matters and Issuer Purchase of Equity Securities

Our common units are listed and traded on the NYSE, under the ticker symbol “USDP”.

On February 28, 2020, the last reported sales price of our common units on the NYSE was $9.04 per common unit. On February 28, 2020, there were
approximately 5,300 common unitholders, ten of which were registered common unitholders of record. An established public trading market does not exist
for our general partner units. All of our general partner units are held by USD Partners GP LLC.

Under our current cash distribution policy, we intend to make minimum quarterly distributions to the holders of our common and general partner units
of at least $0.2875 per unit, or $1.15 per unit on an annualized basis, to the extent we have sufficient available cash after the establishment of cash reserves
and the payment of costs and expenses, including the payment of expenses to our general partner and its affiliates.

SECURITIES AUTHORIZED FOR ISSUANCE UNDER EQUITY COMPENSATION PLANS

Please see Item 12. Security Ownership of Certain Beneficial Owners and Management and Related Stockholder Matters—Securities Authorized for

Issuance Under Equity Compensation Plans for information regarding our equity compensation plans as of December 31, 2019.

UNREGISTERED SALES OF EQUITY SECURITIES

None not previously reported on a current report on Form 8-K.

ISSUER PURCHASES OF EQUITY SECURITIES

None.

52

Item 6. Selected Financial Data

The  following  table  sets  forth,  for  the  periods  and  at  the  dates  indicated,  the  summary  historical  financial  data  of  USD  Partners  LP  and  our
Predecessor. The table is derived from and should be read in conjunction with our audited consolidated financial statements and notes thereto included in Item
8. Financial Statements and Supplementary Data. See also Item 7. Management’s Discussion and Analysis of Financial Condition and Results of Operations.

Income Statements Data (1)(2)(3)

Operating revenues

Operating costs

Operating income

Interest expense

Loss (gain) associated with derivative instruments

Foreign currency transaction loss (gain)

Other expense (income), net

Provision for (benefit from) income taxes

Net income

Net income attributable to limited partner interest

Net income per common unit (basic and diluted) 

Net income per subordinated unit (basic and diluted) 

Distributions declared per limited partner interest

Cash Flow Data (1)(4)

Net cash provided by operating activities

Net cash used in investing activities

Net cash provided by (used in) financing activities

Balance Sheet Data (at period end) (1)(3)(5)

Property and equipment, net

Total assets

Long-term debt, net

Total liabilities

Partners’ Capital

Common units

Class A units

Subordinated units

General partner

Accumulated other comprehensive income (loss)

Total Partners’ Capital

Operating Information

For the Year Ended December 31,

2019

2018

2017

2016

2015

(in thousands, except per unit amounts and Bpd)

$

113,656   $

119,226   $

108,805   $

113,167   $

93,023  

20,633  

12,006  

1,420  

365  

(336)  

662  

89,777  

29,449  

11,358  

(374)  

(14)  

16  

(2,669)  

6,516   $

21,132   $

5,720   $

20,356   $

0.22   $

0.19   $

0.77   $

0.78   $

79,327  

29,478  

9,925  

937  

(456)  

(330)  

(1,929)  

21,331   $

20,750   $

0.84   $

0.85   $

78,705  

34,462  

9,847  

140  

(750)  

(85)  

(247)  

25,557   $

25,048   $

1.12   $

1.08   $

1.465   $

1.425   $

1.370   $

1.275   $

38,442   $

45,129   $

47,819   $

53,730   $

(8,440)  

(32,406)  

(8,580)  

(36,890)  

(27,580)  

(23,790)  

(93)  

(51,298)  

$

$

$

$

$

$

$

147,737   $

145,308   $

146,573   $

125,702   $

289,566  

217,651  

248,510  

61,013  

—  

(22,597)  

2,767  

(127)  

287,295  

205,581  

217,831  

107,903  

1,018  

(39,723)  

3,275  

(3,009)  

301,012  

200,627  

216,122  

136,645  

1,468  

(55,237)  

180  

1,834  

299,115  

220,894  

240,589  

128,903  

1,929  

(70,936)  

356  

(1,726)

$

41,056   $

69,464   $

84,890   $

58,526   $

81,763

59,309

22,454

4,432

(5,161)

(201)

(64)

5,755

17,693

17,339

0.83

0.82

1.170

35,334

(213,283)

147,957

133,010

328,398

239,444

278,638

141,374

1,749

(93,445)

220

(138)

49,760

Average daily terminal throughput (Bpd) (6)

119,566  

112,289  

41,328  

31,727  

27,430

Non-GAAP Measures (3)(7)

Adjusted EBITDA

Distributable cash flow

$

$

50,496   $

37,299   $

56,722  

45,669  

$

$

56,458  

47,408  

$

$

64,026  

54,221  

$

$

42,752

35,062

(1)    Our income statement, cash flow and balance sheet data reflect the following acquisitions:

Month of Acquisition

  Description of Acquisition

June 2017

November 2015

Acquisition of Stroud terminal by Stroud Crude Terminal LLC and STC Pipeline LLC (each a wholly-
owned subsidiary of the Partnership) located in Stroud, Oklahoma

  Acquisition of Casper Crude to Rail, LLC and subsidiary located in Casper, Wyoming.

(2)  Operating costs for the fourth quarter of 2017 include a non-cash impairment loss of $1.7 million to reduce the value of idle assets included in our Terminalling services

segment to their net realizable value less selling costs. Operating costs for the

53

 
 
 
 
 
 
 
 
   
   
   
   
 
   
   
   
   
 
   
   
   
   
 
   
   
   
   
 
 
   
   
   
   
 
   
   
   
   
    
    
 
fourth quarter of 2016 include a non-cash impairment loss of $3.5 million to write down the non-current assets of the San Antonio rail terminal to fair market value.
(3)  Amounts prior to 2016 do not reflect the impact of our adoption of Accounting Standards Codification 606 Revenue from Contracts with Customers, or ASC 606. For
more information refer to Note 2. Summary of Significant Accounting Policies of our consolidated financial statements included in Part II, Item 8. Financial Statements
and Supplementary Data of this Annual Report.

(4)  All amounts have been adjusted to reflect our adoption of Accounting Standards Update 2016-18 Statement of Cash Flows: Restricted Cash, or ASU 2016-18. For more
information refer to Note 2. Summary of Significant Accounting Policies of our consolidated financial statements included in Part II, Item 8. Financial Statements and
Supplementary Data of this Annual Report.

(5)  Total assets and total liabilities presented at December 31, 2019 include operating lease right-of-use assets and operating lease liabilities resulting from our adoption and
implementation of ASC 842, Leases. Refer to Item 8. Financial Statements and Supplementary Data — Note 2. Summary of Significant Accounting Pronouncements and
Note 8. Leases for further discussion.
Includes the average daily throughput of the Stroud terminal which commenced operations in October 2017 and the Casper terminal from our acquisition in November
2015.

(6) 

(7)  A  reconciliation  of  our  non-GAAP  financial  measures  is  included  in  Part  II.  Item  7.  Management’s  Discussion  and  Analysis  of  Financial  Condition  and  Results  of

Operations—How We Evaluate Our Operations—Adjusted EBITDA and Distributable Cash Flow of this Report.

54

 Item 7. Management’s Discussion and Analysis of Financial Condition and Results of Operations

The  following  discussion  and  analysis  of  our  financial  condition  and  results  of  operations  is  based  on  and  should  be  read  in  conjunction  with  our
consolidated financial statements and the accompanying notes included in Item 8. Financial Statements and Supplementary Data of this Annual Report on
Form 10-K. Unless the context otherwise requires, references in this discussion to USD Partners, USDP, the Partnership, we, our, us or like terms refer to
USD partners and the following subsidiaries, collectively: Casper Crude to Rail LLC, CCR Pipeline LLC, Stroud Crude Terminal LLC, SCT Pipeline LLC,
San  Antonio  Rail  Terminal  LLC,  USD  Logistics  Operations  GP  LLC,  USD  Logistics  Operations  LP,  USD  Rail  LP,  USD  Rail  Canada  ULC,  USD  Rail
International S.A.R.L., USD Terminals Canada ULC, USD Terminals International S.A.R.L. and West Colton Rail Terminal LLC. This discussion contains
forward-looking  statements  that  involve  risks  and  uncertainties.  Our  actual  results  could  differ  materially  from  those  discussed  below.  Factors  that  could
cause or contribute to such differences include, but are not limited to, those identified below and those discussed in Part I, Item 1A. Risk Factors included
elsewhere in this report.

We denote amounts denominated in Canadian dollars with “C$” immediately prior to the stated amount.

Overview and Recent Developments

We are a fee-based, growth-oriented master limited partnership formed by our sponsor, USD, to acquire, develop and operate midstream infrastructure
and complementary logistics solutions for crude oil, biofuels and other energy-related products. We generate substantially all of our operating cash flows from
multi-year, take-or-pay contracts with primarily investment grade customers, including major integrated oil companies, refiners and marketers. Our network
of  crude  oil  terminals  facilitates  the  transportation  of  heavy  crude  oil  from  Western  Canada  to  key  demand  centers  across  North  America.  Our  operations
include railcar loading and unloading, storage and blending in onsite tanks, inbound and outbound pipeline connectivity, truck transloading, as well as other
related  logistics  services.  We  also  provide  our  customers  with  leased  railcars  and  fleet  services  to  facilitate  the  transportation  of  liquid  hydrocarbons  and
biofuels by rail.

We generally do not take ownership of the products that we handle nor do we receive any payments from our customers based on the value of such
products. We may on occasion enter into buy-sell arrangements in which we take temporary title to commodities while in our terminals. We expect any such
arrangements to be at fixed prices where we do not take any exposure to changes in commodity prices.

We believe rail will continue as an important transportation option for energy producers, refiners and marketers due to its unique advantages relative to
other  transportation  means.  Specifically,  rail  transportation  of  energy-related  products  provides  flexible  access  to  key  demand  centers  on  a  relatively  low
fixed-cost basis with faster physical delivery, while preserving the specific quality of customer products over long distances.

USDG, a wholly-owned subsidiary of USD, and the sole owner of our general partner, is engaged in designing, developing, owning, and managing
large-scale  multi-modal  logistics  centers  and  energy-related  infrastructure  across  North  America.  USDG’s  solutions  create  flexible  market  access  for
customers in significant growth areas and key demand centers, including Western Canada, the U.S. Gulf Coast and Mexico. Among other projects, USDG is
currently pursuing the development of a premier energy logistics terminal on the Houston Ship Channel with capacity for substantial tank storage, multiple
docks (including barge and deepwater), inbound and outbound pipeline connectivity, as well as a rail terminal with unit train capabilities. USDG completed
an expansion project in January 2019 at the Partnership’s Hardisty terminal, referred to herein as Hardisty South, which added one and one-half 120-railcar
unit trains of transloading capacity per day, or approximately 112,500 barrels per day, or bpd.

Market Update

Substantially  all  of  our  operating  cash  flows  are  generated  from  take-or-pay  contracts  and,  as  a  result,  are  not  directly  related  to  actual  throughput
volumes at our crude oil terminals. Throughput volumes at our terminals are primarily influenced by the difference in price between Western Canadian Select,
or WCS, and other grades of crude oil, commonly referred to as spreads, rather than absolute price levels. WCS spreads are influenced by several market
factors, including the availability of supplies relative to the level of demand from refiners and other end users, the price

55

and availability of alternative grades of crude oil, the availability of takeaway capacity, as well as transportation costs from supply areas to demand centers.

In December 2018, the Alberta Government announced that it would curtail crude oil and bitumen production by 325,000 bpd beginning January 1,
2019, to an allowed production level of 3.56 million bpd. The Alberta Government’s objective was to reduce inventory levels to a targeted level to ensure
more  economical  prices  for  WCS.  In  late  August  2019,  the  Alberta  Government  announced  changes  to  the  curtailment  policy  including  extending  the
curtailment end date to December 31, 2020, with possible earlier termination.

To  date,  the  Alberta  Government  has  announced  reductions  to  the  curtailment  level  and  increased  the  allowed  production  levels  as  depicted  in  the

following chart:

Production Month

Allowed Production Level
(Million barrels per day)

January 2019

February and March 2019

April 2019

May 2019

June and July 2019

August 2019

September 2019

October 2019

November 2019

December 2019

January, February, March and April 2020

3.56

3.63

3.66

3.68

3.71

3.74

3.76

3.79

3.80

3.81

3.81

In  late  October  2019,  the  Alberta  Government  announced  a  special  production  allowance,  whereby  beginning  with  the  December  2019  production
month, producers will be allowed to produce above their curtailment order, as long as this extra production is shipped out of Alberta through additional rail
capacity, which could increase demand for the transloading services of our Hardisty terminal and those of Hardisty South.

To  address  pipeline  capacity  constraints  from  Western  Canada  and  to  increase  Alberta’s  overall  export  capacity,  the  Alberta  Government  also
announced  an  initiative  to  increase  rail  capacity  in  order  to  export  WCS  to  markets  with  more  economical  returns.  This  initiative  included  leasing
approximately 4,400 new rail cars to move up to 120,000 bpd of crude oil by 2020, as well as agreements for terminalling services (including an agreement
with USDG) and rail transportation contracts. In June 2019, the Alberta Government announced that they engaged CIBC Capital Markets to help oversee the
divestment of this crude-by-rail program and its transition to the private sector. In February 2020, the Alberta Government announced that it has agreed to
divest of its contracts to move additional crude by rail to market, but did not release any other details as the agreements are still being finalized.

In response to the Alberta Government’s efforts discussed above, the WCS to West Texas Intermediate, or WTI, crude oil spread narrowed to between
$7-$23 per barrel during 2019 as compared to $11-$50 per barrel during the fourth quarter of 2018. The WCS to WTI spread has averaged approximately $21
per barrel to date in 2020. Additionally, apportionment levels on the primary heavy crude oil pipelines of the largest export pipeline system from Western
Canada to the U.S. averaged approximately 42% and apportionment on the light crude oil pipelines on the system averaged approximately 37% during 2019
(representing the percentage of barrels nominated that were not shipped due to pipeline capacity constraints). Inventory levels decreased steadily through the
end of the third quarter in 2019, relative to 2018, due to the impacts of the production curtailment. However, during the fourth quarter of 2019, inventory
levels increased significantly as a result of increased Western Canadian oil sands production levels coupled with a decrease in available pipeline takeaway
capacity from Canada to the U.S., resulting from a leak on a major export pipeline.

Future WCS to WTI spreads published by Bloomberg through 2024 average approximately $20 per barrel and are indicative of the continued expected
imbalance between supply and takeaway capacity. The latest data available as published by the U.S. Energy Information Administration, or EIA, indicates
Canadian crude-by-rail imports into the

56

 
 
 
 
 
 
 
 
 
 
 
 
United  States  increased  to  approximately  293,000  bpd  through  November  2019  on  a  year-to-date  basis.  This  represents  an  approximate  29%  increase  in
crude-by-rail imports from Canada into the United States over the 2018 comparative period and a 23% increase over the 2018 yearly average. As such, based
on current customer indications, we expect future demand for and utilization of our terminals to remain high.

Western Canadian crude oil production is projected to continue to increase throughout the next decade, driven primarily by developments in Alberta’s
oil sands region. In June 2019, the Canadian Association of Petroleum Producers, or CAPP, projected that the supply of crude oil from Western Canada will
grow by approximately 350,000 bpd by 2020 and 1.2 million bpd by 2030 relative to 2018 levels. The forecasted supply of crude oil from Western Canada
remains  well  in  excess  of  existing  pipeline  takeaway  capacity  out  of  the  region.  Pipeline  export  capacity  from  Western  Canada  remains  constrained  and
projects  to  increase  export  capacity  have  continued  to  experience  significant  regulatory  delays.  For  example,  the  anticipated  in-service  date  of  Enbridge’s
Line 3 Replacement project to upgrade and expand an existing pipeline delivering Western Canadian crude to U.S. markets in the second half of 2020 is now
uncertain, due to regulatory issues on the U.S. portion of the pipeline.

In  prior  years,  the  industry  has  experienced  a  consolidation  of  Western  Canadian  oil  sands  producing  assets  among  active  Canadian  producers.  We
expect  this  will  continue  to  drive  further  expansions  of  crude  oil  production  capacity,  particularly  at  existing  projects,  as  cost  savings  and  technological
advancements made during the recent commodity price downturn are incorporated into future development plans.

We expect demand for rail capacity at our terminals to increase over the next several years and potentially longer if proposed pipeline developments do
not meet currently planned timelines and regulatory or other challenges persist. Our Hardisty and Casper terminals, with established capacity and scalable
designs, are well-positioned as strategic outlets to meet growing takeaway needs as Western Canadian crude oil supplies continue to exceed available pipeline
takeaway  capacity.  Additionally,  we  believe  our  Stroud  terminal  provides  an  advantageous  rail  destination  for  Western  Canadian  crude  oil  given  the
optionality  provided  by  its  connectivity  to  the  Cushing  hub  and  multiple  refining  centers  across  the  United  States.  Rail  also  generally  provides  a  greater
ability to preserve the specific quality of a customer’s product relative to pipelines, providing value to a producer or refiner. We expect these advantages,
including our recently established origin-to-destination capabilities, to continue to result in long-term contract extensions and expansion opportunities across
our terminal network.

Growth Opportunities for our Operations

We apply a disciplined approach to pursuing our growth strategy, which may include organic growth initiatives as well as acquisitions of energy-related
logistics assets. Potential acquisitions may include assets developed by our sponsor or by third-party logistics providers. We believe these represent attractive
opportunities to leverage our established and scalable network footprint to enhance and extend our currently-contracted cash flows.

USD is currently pursuing several development projects related to long-term solutions to transport heavier grades of crude oil produced in Western
Canada, as well as projects related to the storage and the transportation of liquid hydrocarbons and biofuels. These development projects are expected to be
supported  by  multi-year,  take-or-pay  agreements  with  strategic  customers  which  would  generate  stable  and  predictable  cash  flows,  as  discussed  in  further
detail below.

Opportunities Related to USD’s Diluent Recovery Unit Project

USD is pursuing long-term solutions to transport heavier grades of crude oil produced in Western Canada, which USD believes will maximize benefits

to producers, refiners and railroads.

USD’s  patented  diluent  recovery  unit,  or  DRU,  technology  separates  the  diluent  that  has  been  added  to  the  raw  bitumen  in  the  production  process
which meets two important market needs – it returns the recovered diluent for reuse in the Alberta market, reducing delivered costs for diluent, and it creates
DRUbit™, a proprietary heavy Canadian crude oil specifically designed for rail transportation. DRUbit™ is crude oil or bitumen that has been returned to a
more concentrated, viscous state that is classified as a non-hazardous, non-flammable commodity when transported by rail in Canada and the U.S. DRUbit™
is a market access solution that will satisfy demand for heavy Canadian crude

57

oil on the U.S. Gulf Coast and in other markets at a cost that is economically competitive to the crude oil that is transported by pipeline today.

USD and Gibson jointly announced in December 2019 an agreement to construct and operate a DRU near Hardisty, Alberta, Canada. A subsidiary of
ConocoPhillips has contracted to process 50,000 barrels per day of inlet bitumen blend through the DRU to be shipped by Canadian Pacific Railway and
Kansas City Southern Railway Company to the U.S. Gulf Coast.

In  addition,  USD  is  constructing  a  new  destination  terminal  in  Port  Arthur,  Texas  for  the  DRUbit™  that  will  be  transloaded  at  our  Hardisty
origination terminal. The Port Arthur terminal will have the capability for rail unloading, barge dock loading and unloading, tank storage and blending and
will be pipeline connected to Phillips 66’s Beaumont Terminal, providing customers access to a large network of refining and marine facilities.

In February 2020, USD and Gibson jointly announced the receipt of all required regulatory approvals from the Government of Alberta to proceed
with the construction of a DRU. Additionally, USD and Gibson have finalized all required commercial agreements with a subsidiary of ConocoPhillips to
fully  underpin  and  sanction  the  construction  of  the  initial  phase  of  the  DRU  at  50,000  barrels  per  day  of  inlet  bitumen  blend  capacity  and  enable  rail
shipments of DRUbit™ to the U.S. Gulf Coast.

Construction of the DRU is expected to begin in April 2020, and the DRU could be placed into service later in the second quarter of 2021. USD and
Gibson are currently in commercial discussions with other potential producer and refiner customers to secure additional long-term, take-or-pay agreements to
support future expansions of capacity at the DRU.

A proposed sale or transfer by USD of its ownership interest in this project would be subject to our existing right of first offer.

Management  believes  that  the  successful  completion  of  USD’s  DRU  project  will  enhance  the  sustainability  and  quality  of  our  cash  flows  at  the
Partnership by significantly increasing the tenor of three terminalling services agreements at our Hardisty terminal through 2031. Expirations and renewals for
some  of  our  terminalling  services  agreements  at  our  Hardisty  and  Stroud  terminals  will  depend  on  whether  USD’s  DRU  project  will  be  successful.  For
instance,  with  respect  to  three  terminalling  services  agreements  at  our  Hardisty  terminal,  upon  the  successful  completion  and  commissioning  of  the  DRU
project,  all  three  terminalling  services  agreements  will  extend  through  mid-2031,  with  two-thirds  of  the  volume  commitment  for  one  of  these  agreements
terminating at the end of June 2022. If the DRU project is not completed, all three agreements at our Hardisty terminal will expire in June 2024 (rather than in
2031), with two-thirds of the volume commitment for one agreement expiring in June 2022.

 With respect to one terminalling services agreement at our Stroud terminal, if the DRU project has occurred prior to June 30, 2022, then the volume
commitment will be reduced by one-third of the current commitment from the day following the DRU conversion through June 30, 2022, at which point the
agreement will terminate and there will be no renewal period. If the DRU project has not occurred prior to June 30, 2022, the volume commitment will be
reduced  by  two-thirds  of  the  current  commitment  and  will  extend  through  June  30,  2024.  Management  believes  that  the  lower  utilization  at  the  Stroud
terminal  as  a  result  of  successful  completion  of  the  DRU  project  will  be  short-term  in  nature  and  will  allow  the  Partnership  the  opportunity  to  offer
terminalling services to other customers in need of access to the numerous markets connected to the Cushing oil hub.

Opportunities Related to Our Crude Oil Terminal Network

Western Canadian crude oil production is projected to increase throughout the next decade, driven primarily by developments in Alberta’s oil sands
region. Additionally, certain end users, including refineries across North America, have made substantial investments in recent years in order to efficiently
process heavy grades of crude oil, such as those from Western Canada. Additions to pipeline takeaway capacity from Western Canada to key demand centers
in the United States are not expected to keep pace with forecasted production growth. As such, demand for rail takeaway out of Western Canada is expected
to increase over the next several years and potentially longer if currently planned timelines are not met. Our strategically-located crude oil terminal network,
with established capacity and scalable design, is well-positioned to meet these growing takeaway needs.

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Hardisty Terminal

Current  market  demand  for  the  services  provided  at  our  Hardisty  terminal  exceeds  our  available  capacity.  To  date,  we  have  renewed  and  extended
100% of the capacity at our Hardisty terminal through mid-2022, with approximately 73% extended through mid-2023 with customers under multi-year take-
or-pay agreements. Upon the successful completion of USD’s DRU project discussed above, approximately 32% of the Hardisty terminal’s capacity will be
automatically extended through mid-2031.

In addition, USD and Gibson are currently discussing the DRU value proposition with existing and other potential producer and refiner customers to
secure long-term, take-or-pay agreements for additional capacity at the DRU, which would also likely be contracted for transloading at the Hardisty terminal
on a long-term basis.

Additionally,  USDG,  pursuant  to  its  development  rights  at  the  Hardisty  terminal,  completed  the  Hardisty  South  expansion  (“Hardisty  South”)  in
early 2019. The existing Hardisty terminal, which is owned by us, has designed capacity for two unit trains per day, or approximately 150,000 barrels per day.
Hardisty South, which is owned by USDG, added one and one-half unit trains per day, or approximately 112,500 barrels per day, of takeaway capacity to the
terminal by modifying the existing loading rack and building additional infrastructure and trackage. Once fully contracted, we believe Hardisty South could
present an attractive acquisition opportunity for us pursuant to our existing right of first offer, should USDG propose to sell or transfer the asset.

Stroud Terminal

Approximately 50% of the Stroud terminal’s current capacity is contracted with us under a multi-year, take-or-pay terminal services agreement with an

investment grade, multi-national energy company, also referred to as the Stroud customer.

USDM  has  contracted  the  other  50%  of  the  Stroud  terminal’s  current  capacity  pursuant  to  the  Marketing  Services  Agreement,  or  MSA,  that  was
established at the time of the acquisition of the Stroud terminal. Per the MSA, we granted USDM the right to market the capacity at the Stroud terminal in
excess of the capacity of our initial customer in exchange for a nominal per barrel fee.

Our sponsor is also evaluating a potential expansion of the Stroud terminal to meet incremental customer demand, which could include the unloading
of  both  WCS  or  DRUbit™.  If  pursued  and  successful,  these  efforts  could  provide  us  with  cash  flows  incremental  to  those  provided  by  our  currently-
contracted capacity. Additionally, any such development project would be wholly-owned by USDG and would be subject to our existing right of first offer,
should USDG propose to sell or transfer the asset.

Casper Terminal

Our  Casper  terminal  currently  includes  approximately100,000  bpd  of  loading  capacity  and  900,000  barrels  of  tank  storage  capacity.  The  Casper
terminal  receives  inbound  crude  oil  primarily  through  our  dedicated  direct  pipeline  connection  from  Enbridge’s  Express  Pipeline,  which  is  subsequently
loaded onto unit or manifest trains.

The  Casper  Terminal  executed  an  agreement  with  a  multi-national,  investment  grade  customer  for  an  initial  three-year  term  that  commenced  on
September 1, 2018. The agreement contains take-or-pay terms for terminalling and storage services, as well as fees associated with actual throughput volumes
and other services. Pursuant to this agreement and to supplement rail loading options from the terminal, we constructed an outbound pipeline connection from
the Casper Terminal to the nearby Platte Terminal located at the termination point of the Express pipeline, which was placed into service during December
2019.

In December 2019, an existing customer of our Casper terminal extended its terminalling services agreement that was to expire December 31, 2019, for
an additional two years. This agreement contains take-or-pay terms for storage services and variable fees associated with actual throughput volumes and other
services.

In July 2019, Enbridge announced a program to increase the capacity of the Express pipeline by up to an additional 50,000 bpd with the use of drag

reducing agent, or DRA, and pump stations. Enbridge anticipates that the additional

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capacity of 50,000 bpd will be placed into service during the first half of 2020. We anticipate that some of the additional volumes resulting from the increased
capacity  on  the  Express  pipeline  could  be  delivered  to  our  Casper  terminal,  as  we  believe  outbound  pipeline  connections  from  the  Express  pipeline  and
nearby terminals are at or near full capacity.

Opportunities Related to Our Sponsor’s Texas Deepwater Development on U.S. Gulf Coast

In October 2015, our sponsor entered into a joint venture to develop a premier U.S. Gulf Coast logistics terminal on a 988-acre parcel of property on
the Houston Ship Channel. Its strategic location is uniquely positioned to provide customers with flexible market access to key demand centers, both domestic
and abroad. Preliminary master planning efforts suggest that the property footprint is capable of supporting up to twelve million barrels of storage capacity,
multiple docks (including barge and deep water), inbound and outbound pipeline connectivity, and a rail terminal with capacity to unload multiple unit trains
per day. The property is in proximity to substantially all major inbound and outbound pipelines and can be directly accessed by multiple Class 1 railroads.

In August 2019, our Sponsor’s Texas Deepwater development joint venture and Equilon Enterprises LLC d/b/a Shell Oil Products US, or SOPUS,
completed a project to retrofit and refurbish the Deer Park Rail Terminal, or DPRT, on the Houston Ship Channel. The DPRT has the capability of loading up
to 48 railcars per day, or approximately 33,000 barrels of refined products per day. The terminal also has the advantage of providing additional value-added
services, including the capability of adding lubricity additives and red dye. The facility is equipped with two operational tanks with 50,000 barrels of total
storage capacity, which will service the railcar loading rack at the terminal with direct pipeline connectivity to the Deer Park Refinery and the Colex Products
Terminal. While the initial focus will be on loading diesel into railcars initially destined to Mexico and the Permian Basin, there may be a potential to further
expand the DPRT by adding incremental storage capacity and rail loading capabilities to handle additional refined products.

According to the latest data available as published by the EIA, worldwide fuel consumption is estimated to have increased by approximately 740,000
bpd in 2019 and is projected to increase by another two and one-half million bpd by 2021. Recent industry developments highlight the Gulf Coast’s strategic
importance within global energy markets and its ability to meet growing demand. Since the ban on exports of crude oil was lifted in 2015, exports of crude oil
and petroleum products from PADD III have increased from approximately 3.6 million bpd to approximately 7.1 million bpd in 2019. Included within the
crude oil and petroleum products growth discussed above, exports from PADD III of natural gas liquids, or NGLs, and liquefied petroleum gases, or LPGs,
have grown from approximately 625 thousand bpd in 2015 to approximately 1.3 million bpd in 2019. Crude oil exports have grown significantly from less
than 300 thousand bpd in 2015 to approximately 2.7 million bpd in 2019, while finished petroleum product exports from PADD III have grown at a slightly
lower rate from approximately 2.3 million bpd in 2015 to approximately 2.7 million bpd in 2019. The EIA's Annual Outlook published in January 2020 in its
base case forecasts that U.S. demand for crude oil and petroleum products will continue a trend of declining growth, indicating that all incremental crude oil
and  petroleum  products  supply  growth  in  North  America  will  need  to  be  exported.  Our  Sponsor's  Texas  Deepwater  development  will  continue  to  pursue
projects that position the terminal to take advantage of this macro trend, and participate heavily in export markets.

Our sponsor expects that these industry dynamics will contribute to growing demand for storage, staging, blending, export and other logistics services
along the Gulf Coast, including at its Houston Ship Channel property. Accordingly, our sponsor is actively engaged in commercial negotiations with potential
customers to provide export solutions for crude oil, refined products, petrochemicals and natural gas liquids. Any such development project would be wholly-
owned by USDG and would be subject to our existing right of first offer should USDG propose to sell or transfer the asset. If successful, the Texas Deepwater
development  represents  a  meaningful  opportunity  to  add  complementary  logistics  assets  that  diversify  our  current  network  and  have  the  potential  to  add
additional high-quality take-or-pay agreements with terms beyond those related to our existing network.

Right of First Offer

In connection with our IPO, we entered into the Omnibus Agreement with USD and USDG, pursuant to which we were granted a right of first offer on
any midstream infrastructure assets that they may develop, construct, or acquire for a period of seven years after the closing of our IPO, or until October 15,
2021. Additional information about the Omnibus Agreement and the right of first offer are included in Note 13. Transactions with Related Parties of our

60

consolidated financial statements at Part II, Item 8. Financial Statements and Supplementary Data of this Annual Report on Form 10-K.

We cannot assure you that USD will be able to develop or construct, or that we or USD will be able to acquire, any additional midstream infrastructure
projects. Among other things, the ability of USD to further develop the Hardisty and Stroud terminals, or any other project, and our ability to acquire such
projects, will depend upon USD’s and our ability to raise additional equity and debt financing. We are under no obligation to make any offer, and USD and
USDG are under no obligation to accept any offer we make, with respect to any asset subject to our right of first offer. Additionally, the approval of Energy
Capital Partners is required for the sale of any assets by USD or its subsidiaries, including us (other than sales in the ordinary course of business), acquisitions
of securities of other entities that exceed specified materiality thresholds and any material unbudgeted expenditures or deviations from our approved budgets.
Energy Capital Partners may make these decisions free of any duty to us and our unitholders. This approval would be required for the potential acquisition by
us of any projects to expand the Hardisty and Stroud terminals, as well as any other projects or assets that USD may develop or acquire in the future or any
third-party acquisition we may pursue independently or jointly with USD. Energy Capital Partners is under no obligation to approve any such transaction.
Please refer to the discussion under Item 10. Directors, Executive Officers and Corporate Governance—Special Approval Rights of Energy Capital Partners
regarding  the  rights  of  Energy  Capital  Partners.  If  we  are  unable  to  acquire  any  projects  to  expand  the  Hardisty  and  Stroud  terminals  from  USD,  these
expansion projects, once completed, may compete directly with our existing business for future throughput volumes, which may impact our ability to enter
into new terminal services agreements, including with our existing customers, following the termination of our existing agreements, or the terms thereof, and
our ability to compete for future spot volumes. Furthermore, cyclical changes in the demand for crude oil and other liquid hydrocarbons may cause USD, or
us, to further re-evaluate any future expansion projects, including expansion of the Hardisty and Stroud terminals.

How We Generate Revenue

We  conduct  our  business  through  two  distinct  reporting  segments:  Terminalling  services  and  Fleet  services.  We  have  established  these  reporting
segments  as  strategic  business  units  to  facilitate  the  achievement  of  our  long-term  objectives,  to  assist  in  resource  allocation  decisions  and  to  assess
operational performance.

Terminalling Services

The Terminalling services segment includes a network of strategically-located terminals that provide customers with railcar loading and/or unloading
capacity,  as  well  as  related  logistics  services,  for  crude  oil  and  biofuels.  Substantially  all  of  our  cash  flows  are  generated  under  multi-year,  take-or-pay
terminal services agreements that include minimum monthly commitment fees. We generally have no direct commodity price exposure, although fluctuating
commodity prices could indirectly influence our activities and results of operations over the long term. We may on occasion enter into buy-sell arrangements
in  which  we  take  temporary  title  to  commodities  while  in  our  terminals.  We  expect  any  such  agreements  to  be  at  fixed  prices  where  we  do  not  take
commodity price exposure.

Hardisty Terminal Services Agreements.    We have terminal services agreements with five high-quality, primarily investment grade counterparties or
their  subsidiaries:  Cenovus  Energy,  Gibson,  Suncor  Energy,  ConocoPhillips,  and  USDM.  USDM’s  agreement  is  supported  by  commitments  from  an
investment grade rated multi-national energy company, who is also a customer of our Stroud terminal. Substantially all of the terminalling capacity at our
Hardisty  terminal  is  contracted  under  multi-year,  take-or-pay  terminal  services  agreements  subject  to  inflation-based  escalators  with  a  volume-weighted
average remaining contract life of 3.1 years as of December 31, 2019. Assuming the successful completion of USD’s DRU project as previously discussed,
the  volume-weighted  average  remaining  contract  life  of  our  Hardisty  terminal  increases  to  approximately  7.4  years  as  of  December  31,  2019.  All  of  our
counterparties are obligated to pay a minimum monthly commitment fee for the capacity to load an allotted number of unit trains, representing a specified
number of barrels per month. If a customer loads fewer unit trains than its allotted amount in any given month, that customer will receive a credit for up to12
months. This credit may be used to offset fees on throughput volumes in excess of the customer’s minimum monthly commitments in future periods to the
extent capacity is available for the excess volume. We will receive a per-barrel fee on any volumes handled in excess of the customers’ allowed amount, to the
extent the additional volume is not subject to the credit discussed above. If a force majeure

61

event occurs, a customer’s obligation to pay us may be suspended, in which case the length of the contract term will be extended by the same duration as the
force majeure event.

Stroud  Terminal  Services  Agreements.        Concurrent  with  the  Stroud  acquisition,  we  entered  into  a  multi-year,  take-or-pay  terminalling  services
agreement  with  ConocoPhillips  for  the  use  of  approximately  50%  of  the  available  capacity  at  the  Stroud  terminal.  The  term  of  the  initial  agreement  was
scheduled to conclude on June 30, 2020 and has been extended through June 2024. Our customer is obligated to pay a minimum monthly commitment fee
and can load an allotted number of barrels per month. If our customer loads fewer barrels than its allotted amount in any given month, the customer receives a
credit for up to 12 months. This credit may be used to offset fees on throughput volumes in excess of our customer’s minimum monthly commitments in
future periods to the extent capacity is available for the excess volume. We will receive a per-barrel fee on any volumes handled in excess of our customer’s
allotted amount, to the extent the additional volume is not subject to the credit discussed above.

We also entered into a Marketing Services Agreement, or MSA, effective as of May 31, 2017, with USDM, whereby we granted USDM the right to
market the capacity at the Stroud terminal in excess of the capacity of our initial customer in exchange for a nominal per barrel fee. Upon expiration of our
contract  with  the  initial  Stroud  customer  in  June  2020,  the  same  marketing  rights  will  apply  to  all  throughput  at  the  Stroud  terminal  in  excess  of  the
throughput necessary for the Stroud terminal to generate Adjusted EBITDA that is at least equal to the average monthly Adjusted EBITDA derived from the
initial Stroud customer during the 12 months prior to expiration.

Casper Terminal Services Agreements.    Our Casper terminal includes terminalling services agreements with a high quality, investment grade multi-
national  customer  and  with  a  producer  customer.  The  multi-year  agreements  with  these  customers  contain  take-or-pay  terms  for  terminalling  and  storage
services and variable fees associated with actual throughput volumes and other services.

Additionally,  we  may  on  occasion  utilize  our  available  storage  and  throughput  capacity  to  support  our  customers’  spot  activity  through  buy-sell
agreements  that  generate  cash  flows  in  addition  to  those  provided  by  our  multi-year  agreements,  and  have  also  entered  into  a  short-term  agreement  to
facilitate spot transactions on behalf of USDM. We are actively pursuing term agreements with these spot customers.

West  Colton  Terminal  Services  Agreements.        Our  West  Colton  terminal  is  supported  by  a  terminal  services  agreement  with  a  subsidiary  of  an
investment  grade  company  pursuant  to  which  we  are  paid  fixed  fees  per  gallon  of  ethanol  transloaded  at  the  terminal.  The  West  Colton  terminal  services
agreement has been in place since July 2009 and is terminable at any time by either party upon 150 days’ notice.

Fleet Services

We provide our customers with leased railcars and fleet services related to the transportation of liquid hydrocarbons and biofuels by rail on multi-year,
take-or-pay  terms  under  master  fleet  services  agreements  for  initial  periods  ranging  from  five  to  nine  years.  We  do  not  own  any  railcars.  As  of
December 31, 2019, our railcar fleet consisted of 1,683 railcars, which we leased from various railcar manufacturers and financial entities, including 1,308
C&I railcars. We have assigned certain payment and performance obligations under the leases and master fleet service agreements for 1,483 of the railcars to
other parties, but we have retained certain rights and obligations with respect to the servicing of these railcars. Substantially all of our current railcar fleet is
dedicated  to  customers  of  our  Hardisty  terminal.  Our  master  fleet  services  agreements  have  a  weighted-average  remaining  contract  life  of  2.3 years as of
December 31, 2019.

Under  the  master  fleet  services  agreements,  we  provide  customers  with  railcar-specific  fleet  services,  which  may  include,  among  other  things,  the
provision of relevant administrative and billing services, the repairs and maintenance of railcars in accordance with standard industry practice and applicable
law, the management and tracking of the movement of railcars, the regulatory and administrative reporting and compliance as required in connection with the
movement of railcars, and the negotiation for and sourcing of railcars. Our customers typically pay us and our assignees monthly fees per railcar for these
services, which include a component for railcar use and a component for fleet services.

62

Historically,  we  contracted  with  railroads  on  behalf  of  some  of  our  customers  to  arrange  for  the  movement  of  railcars  from  our  terminals  to  the
destinations  selected  by  our  customers.  We  were  the  contracting  party  with  the  railroads  for  those  shipments  and  were  responsible  to  the  railroads  for  the
related fees charged by the railroads, for which we were reimbursed by our customers. Both the fees charged by the railroads to us and the reimbursement of
these fees by our customers are included in our consolidated statements of income in the revenues and operating costs line items entitled “Freight and other
reimbursables.”

How We Evaluate Our Operations

Our management uses a variety of financial and operating metrics to evaluate our operations. When we evaluate our consolidated operations and related
liquidity, we consider these metrics to be significant factors in assessing our ability to generate cash and pay distributions and include: (i) Adjusted EBITDA
and  DCF;  (ii)  operating  costs;  and  (iii)  volumes.  We  define  Adjusted  EBITDA  and  DCF  below.  When  evaluating  our  operations  at  the  segment  level,  we
evaluate using Segment Adjusted EBITDA. Refer to Part II, Item 8. Financial Statements and Supplementary Data, Note 15. Segment Reporting.

Adjusted EBITDA and Distributable Cash Flow

We  define  Adjusted  EBITDA  as  “Net  cash  provided  by  operating  activities”  adjusted  for  changes  in  working  capital  items,  interest,  income  taxes,
foreign currency transaction gains and losses, and other items which do not affect the underlying cash flows produced by our businesses. Adjusted EBITDA is
a non-GAAP, supplemental financial measure used by management and external users of our financial statements, such as investors and commercial banks, to
assess:

•

•

our liquidity and the ability of our business to produce sufficient cash flows to make distributions to our unitholders; and

our ability to incur and service debt and fund capital expenditures.

We define Distributable Cash Flow, or DCF, as Adjusted EBITDA less net cash paid for interest, income taxes and maintenance capital expenditures.
DCF does not reflect changes in working capital balances. DCF is a non-GAAP, supplemental financial measure used by management and by external users
of our financial statements, such as investors and commercial banks, to assess:

•

•

•

the amount of cash available for making distributions to our unitholders;

the excess cash flows being retained for use in enhancing our existing business; and

the sustainability of our current distribution rate per unit.

We believe that the presentation of Adjusted EBITDA and DCF in this report provides information that enhances an investor’s understanding of our
ability to generate cash for payment of distributions and other purposes. The GAAP measure most directly comparable to Adjusted EBITDA and DCF is “Net
cash provided by operating activities.” Adjusted EBITDA and DCF should not be considered alternatives to “Net cash provided by operating activities” or
any  other  measure  of  liquidity  presented  in  accordance  with  GAAP.  Adjusted  EBITDA  and  DCF  exclude  some,  but  not  all,  items  that  affect  “Net  cash
provided by operating activities,” and these measures may vary among other companies. As a result, Adjusted EBITDA and DCF may not be comparable to
similarly titled measures of other companies.

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The following table sets forth a reconciliation of Net cash provided by operating activities, the most directly comparable financial measure calculated

and presented in accordance with GAAP, to Adjusted EBITDA and DCF:

Reconciliation of Net cash provided by operating activities to Adjusted EBITDA and Distributable
cash flow:

Net cash provided by operating activities

Add (deduct):

Amortization of deferred financing costs

Deferred income taxes

Changes in accounts receivable and other assets

Changes in accounts payable and accrued expenses

Changes in deferred revenue and other liabilities

Interest expense, net

Provision for (benefit from) income taxes

Foreign currency transaction loss (gain) (1)

Other income

Non-cash lease items (2)
Non-cash deferred amounts (3)

Adjusted EBITDA

Add (deduct):

Cash received (paid) for income taxes (4)

Cash paid for interest

Maintenance capital expenditures

Distributable cash flow

Year Ended December 31,

2019

2018

(in thousands)

2017

$

38,442   $

45,129   $

47,819

(1,072)  

(79)  

2,895  

604  

(6,066)  

11,936  

662  

365  

—  

—  

2,809  

50,496  

(1,206)  

(11,775)  

(216)  

(866)  

3,971  

(815)  

639  

196  

11,356  

(2,669)  

(14)  

—  

—  

(205)  

56,722  

(814)  

(10,038)  

(201)  

$

37,299   $

45,669   $

(861)

987

(3,503)

(397)

4,562

9,917

(1,929)

(456)

(22)

341

—

56,458

1,250

(9,754)

(546)

47,408

(1)  Represents foreign exchange transaction amounts associated with activities between our U.S. and Canadian subsidiaries.
(2)  Represents non-cash lease revenues and expenses associated with our lease contracts.
(3)  Represents  the  change  in  non-cash  contract  assets  and  liabilities  associated  with  revenue  recognized  at  blended  rates  based  on  tiered  rate  structures  in  certain  of  our
customer contracts and deferred revenue associated with deficiency credits that are expected to be used in the future prior to their expiration. Amounts presented are net of
the corresponding prepaid Gibson pipeline fee that will be recognized as expense concurrently with the recognition of revenue.

(4)  Includes refunds of $3.3 million (representing C$4.3 million) received in 2017 for our foreign income taxes associated with prior years.

Operating Costs

Our operating costs are comprised primarily of subcontracted rail services, pipeline fees, repairs and maintenance expenses, materials and supplies,
utility costs, insurance premiums and lease costs for facilities and equipment. In addition, our operating expenses include the cost of leasing railcars from
third-party railcar suppliers and the shipping fees charged by railroads, which costs are generally passed through to our customers. We expect our expenses to
remain relatively stable, but they may fluctuate from period to period depending on the mix of activities performed during a period and the timing of these
expenditures. We expect to incur additional operating costs, including subcontracted rail services and pipeline fees, when we handle additional volumes at our
terminals.

Our management seeks to maximize the profitability of our operations by effectively managing both our operating and maintenance expenses. As our
terminal facilities and related equipment age, we expect to incur regular maintenance expenditures to maintain the operating capabilities of our facilities and
equipment in compliance with sound business practices, our contractual relationships and regulatory requirements for operating these assets. We record these
maintenance and other expenses associated with operating our assets in “Operating and maintenance” costs in our consolidated statements of income.

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Volumes

The amount of Terminalling services revenue we generate depends on minimum customer commitment fees and the throughput volume that we handle
at our terminals in excess of those minimum commitments. These volumes are primarily affected by the supply of and demand for crude oil, refined products
and biofuels in the markets served directly or indirectly by our assets. Additionally, these volumes are affected by the spreads between the benchmark prices
for these products, which are influenced by, among other things, the available takeaway capacity in those markets. Although customers at our terminals have
committed to minimum monthly fees under their terminal services agreements with us, which will generate the majority of our Terminalling services revenue,
our results of operations will also be affected by:

•

•

•

our customers’ utilization of our terminals in excess of their minimum monthly volume commitments;

our ability to identify and execute accretive acquisitions and commercialize organic expansion projects to capture incremental volumes; and

our  ability  to  renew  contracts  with  existing  customers,  enter  into  contracts  with  new  customers,  increase  customer  commitments  and  throughput
volumes at our terminals, and provide additional ancillary services at those terminals.

General Trends and Outlook

In  addition  to  the  discussion  provided  below,  refer  also  to  the  Market  Update  section included in Part  II,  Item  7.  Management’s  Discussion  and

Analysis, Overview and Recent Developments.

Hardisty and Stroud Terminals Customer Contract Renewals

During 2019, we successfully re-contracted the remaining available capacity of our Hardisty terminal with multi-year take-or-pay agreements with
investment grade customers. To date, we have renewed and extended 100% of the capacity at our Hardisty terminal through mid-2022, with approximately
73% extended through mid-2023 with customers under multi-year take-or-pay agreements. Upon the successful completion of USD’s DRU project previously
discussed,  approximately  32%  of  the  Hardisty  terminal’s  capacity  will  be  automatically  extended  through  mid-2031.  In  addition,  we  successfully  re-
contracted  the  capacity  at  our  Stroud  terminal  that  was  going  to  expire  in  June  2020  and  extended  the  agreement  through  June  2024.  However,  upon  the
successful completion of USD’s DRU project, our Stroud customer will have the right to terminate their agreement at our Stroud terminal in June 2022.

Casper Terminal Customer Contract Renewals and Expirations

The final legacy terminalling services agreement at our Casper Terminal expired at the end of August 2019 and was not renewed or extended. We
continue to seek other opportunities to enhance the utilization and profitability of the Casper terminal with other producers, refiners and marketers of crude
oil. For example, in late 2018, we executed a three-year agreement with an investment-grade rated customer at the Casper Terminal. Additionally, we have
entered  into  a  two-year  terminalling  service  agreement,  effective  January  1,  2020,  which  contains  take-or-pay  terms  for  storage  services  and  variable  fees
associated  with  actual  throughput  volumes  and  other  services.  The  revenue  provided  by  these  new  agreements  may  be  less  predictable  than  the  revenue
historically provided by the legacy contracts, which was based on minimum volume commitments. We have not yet entered into arrangements to replace all
of the revenue previously provided by the legacy contracts at the Casper Terminal. Our ability to secure additional commercial opportunities and replace the
revenue previously generated under the expired contracts may be limited until Enbridge successfully completes its DRA project, which we expect to occur in
the first half of 2020. If we cannot replace the revenue as discussed above at our Casper terminal, we anticipate that we would recognize an impairment of the
Casper terminal’s goodwill. We cannot make any assurances regarding the success of Enbridge’s DRA project or the outcome of our efforts. For a discussion
of the risks associated with our ability to renew, extend or replace customer contracts, see Item 1A. Risk Factors—Our contracts subject us to renewal risks.

65

Factors That May Impact Future Results of Operations

Demand for Rail Transportation of Crude Oil and Biofuels

High-growth crude oil production areas in North America are often located at significant distances from refining centers, creating constantly evolving
regional  imbalances,  which  require  the  expedited  development  of  flexible  and  sustainable  transportation  solutions.  The  extensive  existing  rail  network,
combined with rail transportation’s relatively low capital and fixed costs compared to other transportation alternatives, has strategically positioned rail as a
long-term transportation solution for growing and evolving energy infrastructure needs. In the event that additional pipeline capacity is constructed, or crude
oil  production  decreases  significantly,  demand  for  transportation  of  crude  oil  by  rail  may  be  adversely  impacted.  Please  also  refer  to  the  Market  Update
section included in Part II Item 7. Management’s Discussion and Analysis, Overview and Recent Developments.

Changes  in  environmental  and  gasoline  blending  regulations  may  affect  the  use  of  ethanol  in  the  market  for  transportation  fuel.  Due  to  corrosion
concerns unique to biofuels, such as ethanol, the long-haul transportation of biofuels via multi-product pipelines is less efficient and less economical than rail.
Rail also helps aggregate fragmented ethanol production across the country. In the event that dedicated pipelines are constructed, or additional technologies
are  developed  to  allow  for  more  economical  transportation  of  biofuels  on  multi-product  pipelines,  demand  for  transportation  of  biofuels  by  rail  may  be
affected.

Supply and Demand for Crude Oil and Refined Products

The volume of crude oil and biofuels that we handle at our terminals and the number of railcars for which we provide and perform railcar-specific fleet
services  ultimately  depends  on  refining  and  blending  margins.  Refining  and  blending  margins  are  dependent  mostly  upon  the  price  of  crude  oil  or  other
refinery  feedstocks  and  the  price  of  refined  products.  These  prices  are  affected  by  numerous  factors  beyond  our  control,  including  the  global  supply  and
demand  for  crude  oil  and  gasoline  and  other  refined  products.  The  supply  of  crude  oil  will  depend  on  numerous  factors,  including  commodity  pricing,
improvements in extractive technology, environmental regulation and other factors. We believe that our Adjusted EBITDA and DCF will not be affected in
the near term to the extent of our multi-year, take-or-pay terminal services agreements. However, our ability to grow through expansion or acquisitions and
our ability to renew or extend our terminalling services agreements could be affected by a long-term reduction in supply or demand.

Customer Contracts

Our business is subject to the risk that we may not be able to renew, extend or replace our customer contracts as their terms expire. During 2019, we
renewed and extended multiple terminalling services agreements at the Hardisty and Stroud terminals with existing customers for terms that are generally
improved  from  the  original  agreements.  Additionally,  although  all  legacy  contracts  at  our  Casper  terminal  terminated,  we  have  partially  replaced  these
agreements with arrangements that we have negotiated with new customers. While the legacy contracts provided for minimum volume commitments, the new
agreements provide for committed storage fees and variable fees associated with actual throughput volumes. Refer to the discussion above under the heading
General Trends and Outlook for information regarding customer contract renewals and expirations and changes in fee structures. For a discussion of the risks
associated with our ability to renew, extend or replace customer contracts, see Item 1A. Risk Factors—Our contracts subject us to renewal risks.

Regulatory Environment

Our operations are subject to federal, state, and local laws and regulations relating to the protection of health and the environment, including laws and
regulations that govern the handling of liquid hydrocarbons and biofuels. Additionally, we are subject to regulations governing railcar design and evolving
regulations pertaining to the shipment of liquid hydrocarbons and biofuels by rail as discussed in greater detail in Item 1. Business—Impact of Regulation.
Similar to other industry participants, compliance with existing environmental laws and regulations, as well as those that may be added in the future, could
increase our overall cost of doing business. Such costs, include the costs we incur to construct, maintain, operate and upgrade equipment and facilities, or the
costs of our customers, which may reduce the attractiveness of rail transportation. Our master fleet services agreements generally obligate our customers to
pay for modifications and other required repairs to our leased and managed railcar fleet. However, we cannot assure

66

that we will be able to successfully pass all such regulatory costs on to our customers. While changes in these laws and regulations could indirectly affect our
Adjusted EBITDA and DCF, we believe that consumers of our services place additional value on utilizing established and reputable third-party providers to
satisfy their rail terminalling and logistics needs, which may allow us to increase market share relative to customer-owned operations or smaller operators that
lack an established track record of safety and regulatory compliance.

Acquisition Opportunities

We  plan  to  continue  to  pursue  strategic  acquisitions  of  energy-related  logistics  assets  from  both  USD  and  third  parties  that  will  provide  attractive
returns  to  our  unitholders,  including  facilities  that  provide  for  storage  and  transportation  of  liquid  hydrocarbons  and  biofuels.  We  intend  to  leverage  our
industry relationships and market knowledge to successfully execute on such opportunities, which we may pursue independently or jointly with USD. We
have  entered  into  the  Omnibus  Agreement  with  USD  and  USDG,  pursuant  to  which  USDG  has  granted  us  a  right  of  first  offer  on  any  midstream
infrastructure assets that they may develop, construct, or acquire until October 15, 2021, seven years after the closing of our IPO. Additional information
regarding our growth opportunities is discussed in Growth Opportunities for our Operations and information regarding the Omnibus Agreement is presented
in Note 13. Transactions with Related Parties—Omnibus Agreement of Item 8. Financial Statement and Supplementary Data. We cannot assure you that USD
will be able to develop or construct, or that we or USD will be able to acquire, any other midstream infrastructure projects, including any projects to expand
the Hardisty and Stroud terminals. Among other things, the ability of USD to further develop the Hardisty and Stroud terminals, or any other project, and our
ability to acquire such projects, will depend upon USD’s and our ability to raise additional equity and debt financing. We are under no obligation to make any
offer, and USD and USDG are under no obligation to accept any offer we make, with respect to any asset subject to our right of first offer. Additionally, the
approval of Energy Capital Partners is required for the sale of any assets by USD or its subsidiaries, including us (other than sales in the ordinary course of
business), acquisitions of securities of other entities that exceed specified materiality thresholds and any material unbudgeted expenditures or deviations from
our approved budget. Energy Capital Partners may make these decisions free of any duty to us and our unitholders. This approval would be required for the
potential  acquisition  by  us  of  any  projects  to  expand  the  Hardisty  and  Stroud  terminals,  as  well  as  any  other  projects  or  assets  that  USD  may  develop  or
acquire  in  the  future  or  any  third-party  acquisition  we  may  pursue  independently  or  jointly  with  USD.  Energy  Capital  Partners  is  under  no  obligation  to
approve  any  such  transaction.  Additional  discussion  of  the  special  approval  rights  of  Energy  Capital  Partners  is  included  in  Item 10. Directors, Executive
Officers and Corporate Governance—Special Approval Rights of Energy Capital Partners. If we are unable to acquire any projects to expand the Hardisty
and Stroud terminals from USD, which USD retained the right to develop and operate, these projects may compete directly with our current terminal assets
for  future  throughput  volumes.  As  a  result,  our  ability  to  enter  into  new  terminal  services  agreements,  or  to  renew  such  agreements  with  our  existing
customers, following the termination of our existing agreements or the terms thereof and our ability to compete for future spot volumes could be affected.
Furthermore, cyclical changes in the demand for crude oil and other liquid hydrocarbons may cause USD or us to reevaluate any future expansion projects,
including  any  projects  to  expand  the  Hardisty  and  Stroud  terminals.  Lastly,  if  we  do  not  make  acquisitions  on  economically  beneficial  terms,  our  future
growth will be limited, and the acquisitions we do make may reduce, rather than increase, our DCF.

Interest Rate Environment

The interest rates available in U.S. and international credit markets remain near historic lows. This could affect our future ability to access the credit
markets at rates we consider reasonable to fund our future growth. Additionally, as with other yield-oriented securities, our unit price could be affected by the
level of our cash distributions and the associated implied distribution yield. Therefore, changes in interest rates, either positive or negative, may affect the
yield requirements of investors who invest in our units, and, as such, a rising interest rate environment could have an adverse impact on our unit price and our
ability  to  issue  additional  equity,  or  increase  the  cost  of  issuing  equity.  However,  we  expect  that  our  cost  of  capital  would  remain  competitive,  as  our
competitors would face similar circumstances. We have entered into interest rate collar contracts to partially mitigate our exposure to interest rate fluctuations
on our variable rate debt. The collar contracts establish a range where we will pay the counterparty if the one-month Overnight Index Swap, or OIS, falls
below the established floor rate of 1.70%, and the counterparty will pay us if the one-month OIS exceeds the ceiling rate of 2.50%.

67

Factors Affecting the Comparability of Our Financial Results

The comparability of our current financial results in relation to prior periods are affected by the factors described below.

Our  historical  results  of  operations  include  revenues  and  expenses  related  to  the  operations  of  our  Hardisty,  Casper,  San  Antonio  and  West  Colton

terminals and our railcar fleet services throughout North America.

Stroud Terminal Asset Purchase

Our operating results include costs from June 2017 and revenues after October 1, 2017, associated with our operation of the Stroud terminal, which we

purchased in June 2017.

Casper Terminal Agreement Expiration

The last of our legacy terminalling services agreements at our Casper Terminal expired at the end of August 2019 and was not renewed or extended.
The  expired  agreement  contributed  $9.3  million  to  our  “Terminalling  Services”  revenue  and  $6.5  million  of  Adjusted  EBITDA  during  the  twelve  months
preceding  the  expiration  of  the  agreement.  Additionally,  a  legacy  customer  of  our  Casper  terminal,  whose  terminal  services  agreement  with  us  expired  in
October 2018, extended until December 2018, and did not renew. The expired agreement contributed $7.3 million to our “Terminalling services” revenue and
$5.6 million of Adjusted EBITDA during the twelve months preceding termination of the agreement. Also, one of our initial legacy terminalling services
agreements  expired  in  late  August  2017.  The  expired  agreement  contributed  $15.0  million  to  our  “Terminalling  services”  revenue  and  $12.0  million  of
Adjusted EBITDA during the twelve months preceding expiration of the agreement.

Selling, General and Administrative Costs

Our sponsor charges us a fixed annual fee for the management and operation of our assets and for the provision of various centralized administrative
services, as well as allocates general and administrative costs and expenses incurred by them on our behalf. In 2019 and 2018, the fixed annual fee increased
by $0.2 million and $0.1 million to $3.6 million and $3.4 million, respectively, primarily as a result of our sponsor hiring new employees dedicated to our
operations and adjustments to salaries and bonuses to existing employees. The Board of Directors of our General Partner approved a fixed annual fee of $3.3
million for 2020.

We incur unit based compensation expenses associated with the Phantom Units granted to directors, officers and employees of our sponsor pursuant to
the USD Partners LP Amended and Restated 2014 Long-Term Incentive Plan, or A/R LTIP, and Class A units granted to certain executive officers and other
key employees of USDG. We recognize the expense associated with the outstanding Phantom Units and with each Class A vesting tranche ratably over its
requisite service period. All of the remaining unvested and outstanding Class A units vested in February 2019 and converted into common units. We have not
granted  any  additional  Class  A  units  and  therefore  no  additional  compensation  expense  will  be  recognized  with  respect  to  the  Class  A  units.  For  more
information related to our A/R LTIP and Class A units, refer to Note 20. Unit based compensation expense of our consolidated financial statements included
in Item 8. Financial Statements and Supplementary Data of this Annual Report

Foreign Currency Exchange Rates

We  derive  a  significant  amount  of  operating  income  from  our  Canadian  operations,  particularly  our  Hardisty  terminal.  Given  our  exposure  to
fluctuations in the exchange rate between the Canadian dollar and the U.S. dollar, our operating income and assets which are denominated in Canadian dollars
will be positively affected when the Canadian dollar increases in relation to the U.S. dollar and will be negatively affected when the Canadian dollar decreases
relative to the U.S. dollar, assuming all other factors are held constant. Conversely, our operating expenses and liabilities which are denominated in Canadian
dollars will be positively affected when the Canadian dollar decreases in relation to the U.S. dollar and will be negatively affected when the Canadian dollar
increases relative to the U.S. dollar.

We entered into derivative contracts to mitigate a significant portion of the potential impact that fluctuations in the value of the Canadian dollar relative
to the U.S. dollar may have on approximately C$33.5 million of cash flows generated by our Hardisty terminal operations through 2017. As a result, foreign
currency exchange rates did not have

68

a  significant  impact  on  our  operating  cash  flows  in  2017.  Our  derivative  contracts,  which  covered  the  majority  of  our  Canadian  cash  flows,  secured  a
minimum exchange rate of 0.78 U.S. dollars per Canadian dollar for our 2017 fiscal year. The average exchange rates for the Canadian dollar in relation to the
U.S. dollar were 0.7538, 0.7718 and 0.7712 for 2019, 2018 and 2017, respectively. We did not enter into any derivative contracts to mitigate the potential
impact from fluctuations in the value of the Canadian dollar in 2019 or 2018.

Income Tax

In June 2019, the Canadian Province of Alberta enacted a tax rate decrease that reduces the tax rate on business income from the previous rate of 12% to
an ultimate rate of 8% effective for 2022. The reduction in the tax rate on business income is phased in over three years beginning with a reduction to an 11%
rate effective July 1, 2019, with further reductions of 1% in each successive year until it reaches 8% on January 1, 2022. As a result, the effective income tax
rate on business income for Alberta businesses in 2019 is 11.5%, representing a blended rate of 12% from January 1, 2019 through June 30, 2019 and 11%
from July 1, 2019 through December 31, 2019.

In conjunction with our adoption of ASC 606 in 2018, we recognized a deferred tax liability associated with the previously deferred revenues net of
previously  deferred  pipeline  fees.  For  Canadian  tax  purposes,  the  previously  deferred  revenue,  net  of  previously  deferred  expenses  associated  with  our
adoption of ASC 606 was recovered during the year ended December 31, 2018. The deferred tax recovery of $3.8 million (representing C$4.9 million) for
year  ended  December  31,  2018,  was  partially  offset  by  the  Canadian  tax  liability  attributable  to  our  earnings  for  the  year  ended  December  31,  2018.  Our
financial results for the year ended December 31, 2019 were not affected by similar activities.

In 2016 we adopted the current methodology for determining the return attributable to our Canadian subsidiaries based upon the completion of a study
we commissioned. As a result of this methodology adoption, our 2017 provision for income taxes includes a reduction to our income tax liability for 2016,
based upon the Canadian federal and provincial income tax returns for 2016 that we filed in June 2017.

Cash Distributions

We intend to make minimum quarterly distributions of at least $0.2875 per common unit ($1.15 per unit on an annualized basis) to the extent we have
sufficient cash from operations after establishment of cash reserves and payment of fees and expenses, including payments to our general partner. We intend
to pay distributions no later than 60 days after the end of each quarter. We paid our most recent distribution on February 19, 2020,  at  a  rate  of  $0.37 per
common unit ($1.48 per unit on an annualized basis) for the quarter ended December 31, 2019, to unitholders of record on February 10, 2020.

69

RESULTS OF OPERATIONS

We  conduct  our  business  through  two  distinct  reporting  segments:  Terminalling  services  and  Fleet  services.  We  have  established  these  reporting
segments as strategic business units to facilitate the achievement of our long-term objectives, to aid in resource allocation decisions and to assess operational
performance.

The following table summarizes our operating results by business segment and corporate charges for each of the years indicated:

Operating income (loss)

Terminalling services

Fleet services

Corporate and other

Total operating income

Interest expense

Loss (gain) associated with derivative instruments

Foreign currency transaction loss (gain)

Other expense (income), net

Provision (benefit) from income taxes

Net income

For the Year Ended December 31,

2019

2018

2017

(in thousands)

$

32,334   $

41,766   $

20  

(11,721)  

20,633  

12,006  

1,420  

365  

(336)  

662  

$

6,516   $

(723)  

(11,594)  

29,449  

11,358  

(374)  

(14)  

16  

(2,669)  

21,132   $

37,367

1,201

(9,090)

29,478

9,925

937

(456)

(330)

(1,929)

21,331

Summary Analysis of Operating Results

Year ended December 31, 2019 compared to the year ended December 31, 2018

Our operating results for the year ended December 31, 2019, compared with our operating results for the year ended December 31, 2018, were largely

driven by the following:

•

activities associated with our terminalling services business including:

– higher rates on certain of our terminalling services agreements at our Hardisty terminal that became effective July 1, 2019;

– higher revenues at our Stroud terminal from price escalations;

– lower  depreciation  resulting  from  a  revised  estimate  of  the  asset  retirement  obligation  associated  with  the  decommissioned  San  Antonio  rail

terminal;

– lower operating income resulting from the conclusion of contracts at our Casper terminal in December 2018 and August 2019;

– increased costs associated with subcontracted rail services at our Hardisty terminal; and

– increased maintenance costs at our Stroud terminal related to our steaming equipment.

•

•

•

an increase in interest expense due to higher weighted average interest rates and additional amounts outstanding on our credit facility;

non-cash losses associated with declines in the fair value of our interest rate derivatives resulting from decreases in the forward interest rate index upon
which the derivative values are based; and

an increase in our provision for income taxes for the current year due to a partial recovery of a deferred tax liability we recognized in 2018 in conjunction
with our adoption of ASC 606 that we did not have in 2019, partially offset by a reduction in the Alberta provincial tax rates on business income.

70

 
 
 
 
 
 
   
   
A more comprehensive discussion regarding our results of operations and financial condition for the year ended December 31, 2019 compared to the
year ended December 31, 2018 is presented below. The results for both 2019 and 2018 have been accounted for and presented to reflect our adoption of ASC
606 and ASC 842, neither of which materially impacted our financial condition or results of operations for 2019 or 2018. A discussion regarding our financial
condition and results of operation for the year ended December 31, 2018 as compared with the year ended December 31, 2017 can be found under Item 7 in
our Annual Report on Form 10-K for the year ended December 31, 2018, filed with the SEC on March 7, 2019, which is available free of charge on the SEC’s
website at www.sec.gov and on our website at www.usdpartners.com.

RESULTS OF OPERATIONS - BY SEGMENT

TERMINALLING SERVICES

The following table sets forth the operating results of our Terminalling services business and the approximate average daily throughput volumes of our

terminals for the periods indicated:

Revenues

Terminalling services

Freight and other reimbursables

Total revenues

Operating costs

Subcontracted rail services

Pipeline fees

Freight and other reimbursables

Operating and maintenance

Selling, general and administrative

Depreciation and amortization

Total operating costs

Operating income

Interest expense

Loss associated with derivative instruments

Foreign currency transaction loss (gain)

Other expense (income), net

Provision for (benefit from) income taxes

Net income

Average daily terminal throughput (Bpd)

For the Year Ended December 31,

2019

2018

2017

(in thousands, except Bpd)

$

106,753   $

110,215   $

99,235

1,171  

1,443  

26

107,924  

111,658  

99,261

14,777  

20,971  

1,171  

11,848  

6,159  

20,664  

75,590  

32,334  

—  

—  

(90)  

(324)  

634  

13,785  

21,679  

1,443  

6,375  

5,507  

21,103  

69,892  

41,766  

—  

—  

138  

16  

(2,709)  

$

32,114   $

44,321   $

119,566  

112,289  

8,953

22,524

26

3,195

5,064

22,132

61,894

37,367

170

1,083

(33)

(330)

(2,027)

38,504

41,328

Year ended December 31, 2019 compared to the year ended December 31, 2018

Terminalling Services Revenue

Revenue generated by our Terminalling services segment decreased $3.7 million to $107.9 million for the year ended December 31, 2019, as compared
with the year ended December 31, 2018. This decrease was primarily due to lower revenue at our Casper terminal resulting from the conclusion of customer
agreements  at  the  end  of  2018  and  August  2019,  partially  offset  by  additional  contracts  that  we  have  executed  and  our  commercial  efforts  to  market  the
available capacity. Additionally, we deferred revenue from our Hardisty terminal during the fourth quarter of 2019

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associated with the make-up right options we granted to our customers that are expected to be exercised in 2020. These factors contributing to the decrease in
terminalling  services  revenue  were  partially  offset  by  increased  revenue  at  our  Hardisty  terminal  resulting  from  higher  rates  included  in  some  of  our
terminalling services agreements that became effective July 1, 2019 due to our re-contracting efforts. The revenue at our Stroud terminal also increased due to
price escalations.

Our average daily terminal throughput increased to 119,566 bpd for the year ended December 31, 2019, as compared with 112,289 bpd for the year
ended December 31, 2018. Our throughput volumes increased primarily due to the greater demand for export capacity by customers of our Hardisty terminal
a portion of which drives the demand for deliveries at our Stroud terminal and its connection to the Cushing oil hub. The volume increases at our Hardisty and
Stroud  terminals  were  partially  offset  by  lower  throughput  volumes  at  our  Casper  terminal.  The  increased  demand  associated  with  our  Hardisty  terminal
resulted from increased Western Canadian crude oil production and constrained pipeline takeaway capacity out of the region during 2019. Our terminalling
services revenues are recognized based upon the contractual terms set forth in our agreements that contain primarily “take-or-pay” provisions, where we are
entitled to the payment of minimum monthly commitment fees from our customers, which are recognized as revenue as we provide terminalling services.
Increases  in  the  average  daily  terminal  throughput  activity  usually  only  affect  revenue  to  the  extent  such  amounts  are  in  excess  of  the  minimum  monthly
committed volumes. However, increases in actual and expected throughput activity can result in increases in the variable operating costs associated with our
terminals, as discussed below.

Our  terminalling  services  revenue  for  the  year  ended  December 31, 2019,  would  have  been  $1.7 million  more  if  the  average  exchange  rate  for  the
Canadian  dollar  in  relation  to  the  U.S.  dollar  for  the  year  ended  December  31,  2019,  was  the  same  as  the  average  exchange  rate  for  the  year  ended
December 31, 2018. The average exchange rate for the Canadian dollar in relation to the U.S. dollar was 0.7538 for December 31, 2019 as compared with
0.7718 for the year ended December 31, 2018.

Operating Costs

The operating costs of our Terminalling services segment increased $5.7 million to $75.6 million for the year ended December 31, 2019, as compared
with $69.9 million for the year ended December 31, 2018. The increase is primarily attributable to expenses incurred pursuant to a new servicing agreement at
our Hardisty terminal, as discussed below under “Operating and maintenance,” coupled with additional variable operating costs at our Hardisty and Stroud
terminals resulting from subcontracted rail service costs that increased due to higher throughput volumes. We also incurred increased operating costs at our
Stroud terminal from utilization of the steaming equipment we installed to alleviate unloading issues due to cold weather. These costs were partially offset by
a decrease in pipeline fees and depreciation expense, as discussed in more detail below.

The operating costs of our terminalling services business for the year ended December 31, 2019 would have been $0.9 million  more  if  the  average
exchange rate for the Canadian dollar in relation to the U.S. dollar for the year ended December 31, 2019, was the same as the average exchange rate for the
year ended December 31, 2018.

 Subcontracted rail services. Our costs for subcontracted rail services increased $1.0 million to $14.8 million for the year ended December 31, 2019, as

compared with $13.8 million  for  the  year  ended  December  31,  2018.  This  increase  was  primarily  due  to  the  additional  throughput  at  our  Stroud  terminal
associated with the contracts that were executed in March and April of 2018 and increased throughput at our Hardisty terminal, offset by a reduction in such
services at our Casper terminal resulting from the conclusion of customer agreements at the end of 2018 and in August 2019.

Pipeline fees. We  incur  pipeline  fees  related  to  a  facilities  connection  agreement  with  Gibson  for  the  delivery  of  crude  oil  from  Gibson’s  Hardisty
storage terminal to our Hardisty terminal via pipeline. The pipeline fees we pay to Gibson are based on a predetermined formula, which includes amounts
collected from customers at our Hardisty terminal less direct operating costs. Our pipeline fees decreased $0.7 million to $21.0 million  for  the  year  ended
December 31, 2019, as compared with $21.7 million for the year ended December 31, 2018 primarily due to higher direct operating costs, which reduce the
amounts  we  pay  to  Gibson,  partially  offset  by  higher  revenues  at  our  Hardisty  terminal,  which  increase  the  amounts  we  pay.  Additionally,  we  deferred
pipeline fees for the year ended December 31, 2019, associated with the revenue we deferred for our customers’ expected future use of make-up rights

72

at our Hardisty terminal, as discussed above. We will recognize the expense for pipeline fees concurrently with our recognition of the related revenue.

Operating and maintenance. Our operating and maintenance expense increased $5.5 million to $11.8 million for the year ended December 31, 2019, as
compared with the year ended December 31, 2018. The increased operating and maintenance expenses are primarily due to expenses incurred pursuant to a
new  agreement  with  a  related  party  for  providing  terminalling  services  on  our  behalf  to  a  customer  of  our  Hardisty  terminal  for  contacted  capacity  that
exceeds the current transloading capacity available at our Hardisty terminal. These costs represent the same rate, on a per barrel basis, that we received as
revenue from our third-party customer. Additionally, we incurred higher costs for operating the steaming equipment at our Stroud terminal, which was placed
into service in July 2018 to alleviate unloading issues related to cold weather at the terminal.

Selling,  general  and  administrative.  Our  selling,  general  and  administrative  expense  increased  $0.7  million  to  $6.2  million  for  the  year  ended
December 31, 2019, as compared with $5.5 million for the year ended December 31, 2018. The increase was primarily due to increased costs associated with
resources dedicated to the further commercialization of our terminals and higher compliance consulting and legal costs at our Casper terminal associated with
our pipeline projects.

Depreciation and amortization. Depreciation and amortization expense decreased $0.4 million to $20.7 million for the year ended December 31, 2019,
from $21.1 million for the year ended December 31, 2018. The decrease is due primarily to a revised estimate of our asset retirement obligations, or ARO,
that we recorded during the first quarter of 2019 for our decommissioned San Antonio rail terminal.

Other Expenses

Other expense (income), net. Other income increased $0.3 million to $0.3 million for the year ended December 31, 2019, compared with the year ended
December  31,  2018.  This  increase  is  primarily  attributable  to  income  that  we  earned  in  2019  as  an  incentive  for  railcar  movements  of  a  customer  of  our
Hardisty terminal associated with a new agreement that commenced in April 2019. For further information regarding our railroad incentive income, refer to
Part II, Item 8. Financial Statements and Supplementary Data, Note 2. Summary of Significant Accounting policies.

Provision for (benefit from) income taxes. A significant amount of our operating income is generated by our Hardisty terminal located in the Canadian
province  of  Alberta.  As  a  Canadian  business,  operating  income  derived  from  our  Hardisty  terminal  is  subject  to  corporate  income  taxes  assessed  at  rates
enacted  by  the  Canadian  federal  and  provincial  governments  which  totaled  26.5%  for  2019  on  a  combined  basis.  In  late  June  2019,  the  Provincial
Government of Alberta enacted legislation to reduce the provincial tax on business income by 1% each year through 2022 from the previous rate of 12% to a
rate of 8% in 2022. The provincial tax on business income was reduced to 11% effective July 1, 2019, which resulted in a blended rate of 11.5% for 2019.
While the provincial tax on business income will reduce our income tax expense in future periods, we do not anticipate these reductions to significantly affect
our operating results or cash flows.

Our  provision  for  income  taxes  of  the  Terminalling  services  segment  increased  $3.3  million  to  a  provision  of  $0.6  million  for  the  year  ended
December 31, 2019, from a benefit of $2.7 million for the year ended December 31, 2018. In connection with our adoption of ASC 606 in 2018, we recovered
a deferred tax liability associated with previously deferred revenues net of previously deferred pipeline fees. During the year ended December 31, 2018, we
recovered $3.8 million  (representing  C$4.9 million),  which  produced  a  benefit  from  income  taxes.  We  did  not  have  a  similar  recovery  of  a  deferred  tax
liability for the year ended December 31, 2019.

73

FLEET SERVICES

The following table sets forth the operating results of our Fleet services business for the periods indicated:

Revenues

Fleet leases

Fleet services

Freight and other reimbursables

Total revenues

Operating costs

Freight and other reimbursables

Operating and maintenance

Selling, general and administrative

Total operating costs

Operating income (loss)

Foreign currency transaction loss (gain)

Provision for income taxes

Net income (loss)

For the Year Ended December 31,

2019

2018

2017

(in thousands)

$

3,935   $

3,935   $

1,118  

679  

5,732  

679  

4,069  

964  

5,712  

20  

9  

28  

1,483  

2,150  

7,568  

2,150  

4,820  

1,321  

8,291  

(723)  

(14)  

43  

$

(17)   $

(752)   $

6,541

2,506

497

9,544

497

6,919

927

8,343

1,201

5

275

921

Year ended December 31, 2019 compared to the year ended December 31, 2018

Operating Results

Revenues from our Fleet services segment decreased $1.8 million to $5.7 million for the year ended December 31, 2019, as compared to the year ended
December 31, 2018. The decrease in revenue was primarily attributable to fewer customer reimbursements to us for freight and other reimbursables charges
that we have incurred on their behalf. The decrease in Freight and other reimbursables revenue was exactly offset by a corresponding decrease in Freight and
other reimbursables operating costs that primarily arose from railcar returns and associated repairs, which occurred during the year ended December 31, 2018.
We did not incur similar costs during the year ended December 31, 2019, as we had no returns of railcars during the current year. Fleet services revenues also
decreased  from  the  prior  year  due  to  fewer  leased  railcars  outstanding  throughout  2019  for  which  we  provided  fleet  services,  as  compared  with  2018.
Throughout  2018,  approximately  1,130  railcars  were  returned  due  to  the  conclusion  of  leases  on  the  railcars.  Directly  correlated  with  a  lesser  number  of
railcars outstanding was a decrease in Operating and maintenance expense of $0.8 million to $4.1 million for the year ended December 31, 2019, as compared
to the year ended December 31, 2018. Selling, general and administrative costs of our Fleet services segment also decreased $0.4 million to $1.0 million for
the year ended December 31, 2019, as compared to the year ended December 31, 2018, primarily due to higher consulting fees we incurred in 2018.

Historically we have assisted our customers with procuring railcars to facilitate their use of our terminalling services. Our wholly-owned subsidiary
USD  Rail  LP  has  historically  entered  into  leases  with  third-party  manufacturers  of  railcars  and  financial  firms,  which  it  has  then  leased  to  customers.
Although we expect to continue assisting our customers with obtaining railcars for their use transporting crude oil from our terminals, as our existing lease
agreements expire, or are otherwise terminated, we do not expect to enter into similar leasing arrangements in the future. Should market conditions change,
we would potentially assist with the procurement and management of railcars on behalf of our customers again in the future.

74

 
 
 
 
 
 
   
   
 
   
   
CORPORATE ACTIVITIES

The following table sets forth our corporate charges for the periods indicated:

For the Year Ended December 31,

2019

2018

2017

(in thousands)

Operating costs

Selling, general and administrative

$

11,721   $

11,594   $

Operating loss

Interest expense

Loss (gain) associated with derivative instruments

Foreign currency transaction loss (gain)

Other income, net

Provision for (benefit from) income taxes

(11,721)  

12,006  

1,420  

446  

(12)  

—  

(11,594)  

11,358  

(374)  

(138)  

—  

(3)  

9,090

(9,090)

9,755

(146)

(428)

—

(177)

Net loss

$

(25,581)   $

(22,437)   $

(18,094)

Year ended December 31, 2019 compared to the year ended December 31, 2018

Costs associated with our corporate activities increased by $3.1 million to $25.6 million for the year ended December 31, 2019, as compared to the year
ended December 31, 2018 primarily due to increased interest expense and non-cash losses associated with derivative instruments, as discussed below. Our
“Interest expense” increased $0.6 million to $12.0 million due to an increase in the interest rates we were charged under our Credit Agreement, as well as a
higher weighted average balance of debt outstanding during the year ended December 31, 2019, as compared with the same period in 2018. Also contributing
to the increase in costs associated with our corporate activities during the year was a non-cash loss of $1.4 million on our interest rate derivatives for the year
ended December 31, 2019, as compared to a non-cash gain of $0.4 million for the same period in 2018.

75

 
 
 
 
 
 
   
   
LIQUIDITY AND CAPITAL RESOURCES

Our principal liquidity requirements include:

•

•

•

financing current operations;

servicing our debt;

funding capital expenditures, including potential acquisitions and the costs to construct new assets; and

• making distributions to our unitholders

We have historically financed our operations with cash generated from our operating activities, borrowings under our Revolving Credit Facility and

loans from our sponsor.

Liquidity Sources

We expect our ongoing sources of liquidity to include borrowings under our $385 million senior secured credit agreement, issuances of debt securities
and  additional  partnership  interests  as  well  as  cash  generated  from  our  operating  activities.  We  believe  that  cash  generated  from  these  sources  will  be
sufficient to meet our ongoing working capital and capital expenditure requirements and to make quarterly cash distributions.

Equity Offering

In June 2017, we issued and sold 3,000,000 common units in an underwritten public offering at a public offering price of $11.60 per unit. We received
proceeds, net of underwriting discounts, commissions and offering costs of $33.7 million. We used the net proceeds we received from this offering to repay
amounts outstanding under our Revolving Credit Facility, a portion of which we borrowed to fund our acquisition of the Stroud terminal.

Credit Agreement

Our Credit Agreement is a $385 million revolving credit facility (subject to limits set forth therein) with Citibank, N.A., as administrative agent, and a
syndicate of lenders. Our Credit Agreement is a four year committed facility that initially matures on November 2, 2022. Our Credit Agreement provides us
with the ability to request two one-year maturity date extensions, subject to the satisfaction of certain conditions, and allows us the option to increase the
maximum amount of credit available up to a total facility size of $500 million, subject to receiving increased commitments from lenders and satisfaction of
certain  conditions.  Our  Credit  Agreement  contains  customary  representations,  warranties,  covenants  and  events  of  default  for  facilities  of  this  type.  In
connection with establishing the Credit Agreement, which replaced the prior credit agreement entered into in October 2014, we incurred additional deferred
financing costs of $2.9 million in 2018, which, in addition to any remaining deferred financing costs from our previous credit agreement, will be amortized
over the four-year term of the Credit Agreement using the straight line method, which approximates the effective interest method.

Our Credit Agreement and any issuances of letters of credit are available for working capital, capital expenditures, general partnership purposes. The
Credit Agreement includes an aggregate $20 million sublimit for standby letters of credit and a $20 million sublimit for swingline loans. Obligations under
the Credit Agreement are guaranteed by our restricted subsidiaries (as such term is defined therein) and are secured by a first priority lien on our assets and
those of our restricted subsidiaries, other than certain excluded assets.

Our borrowings under the Credit Agreement bear interest at either a base rate plus an applicable margin ranging from 1.00% to 2.00%, or at a rate based
on the London Interbank Offered Rate, or LIBOR, or a comparable or successor rate plus an applicable margin ranging from 2.00% to 3.00%. The applicable
margin,  as  well  as  a  commitment  fee  of  0.375%  to  0.50%  per  annum  on  unused  commitments  under  the  Credit  Agreement,  will  vary  based  upon  our
consolidated net leverage ratio, as defined in our Credit Agreement.

Our Credit Agreement contains affirmative and negative covenants that, among other things, limit or restrict our ability and the ability of our restricted
subsidiaries  to  incur  or  guarantee  debt,  incur  liens,  make  investments,  make  restricted  payments,  engage  in  certain  business  activities,  engage  in  mergers,
consolidations and other organizational changes, sell, transfer or otherwise dispose of assets, enter into burdensome agreements or enter into transactions with
affiliates on terms that are not at arm’s length, in each case, subject to exceptions.

76

Additionally, we are required to maintain the following financial ratios, each determined on a quarterly basis for the immediately preceding four quarter

period then ended (or such shorter period as shall apply, on an annualized basis): 

•

•

•

Consolidated Interest Coverage Ratio (as defined in the Credit Agreement) of at least 2.50 to 1.00;

Consolidated Net Leverage Ratio of not greater than 4.50 to 1.00 (or 5.00 to 1.00 at any time after we have issued at least $150 million of certain
qualified unsecured notes and for so long as the notes remain outstanding (the “Qualified Notes Requirement”)). In addition, upon the consummation
of a Specified Acquisition (as defined in our Credit Agreement), for the fiscal quarter in which the Specified Acquisition is consummated and for
two fiscal quarters immediately following such fiscal quarter (the “Specified Acquisition Period”), if timely elected by us by written notice to the
Administrative Agent, the maximum permitted ratio shall be increased to 5.00 to 1.00 (or 5.50 to 1.00 if the Qualified Notes Requirement has been
met); and  

after we have met the Qualified Notes Requirement, a Consolidated Senior Secured Net Leverage Ratio (as defined in the Credit Agreement) of not
greater than 3.50 to 1.00 (or 4.00 to 1.00 during a Specified Acquisition Period).

Our Credit Agreement generally prohibits us from making cash distributions (subject to exceptions as set forth in the Credit Agreement). However, so
long  as  no  default  exists  or  would  be  caused  by  making  a  cash  distribution,  we  may  make  cash  distributions  to  our  unitholders  up  to  the  amount  of  our
available cash (as defined in our partnership agreement).

The Credit Agreement contains events of default, including, but not limited to (and subject to grace periods in circumstances set forth in the Credit
Agreement), the failure to pay any principal, interest or fees when due, failure to perform or observe any covenant (subject in some cases to certain grace
periods or other qualifications), any representation, warranty or certification made or deemed made in the agreements or related loan documentation being
untrue in any material respect when made, default under certain material debt agreements, commencement of bankruptcy or other insolvency proceedings,
certain changes in our ownership or the ownership of our general partner, certain material judgments or orders, ERISA events or the invalidity of the loan
documents. Upon the occurrence and during the continuation of an event of default under the agreements, the lenders may, among other things, terminate their
commitments, declare any outstanding loans to be immediately due and payable and/or exercise remedies against us and the collateral as may be available to
the lenders under the agreements and related documentation or applicable law.

As of December 31, 2019, we were in compliance with the covenants set forth in our Credit Agreement.

The  weighted  average  interest  rate  on  our  outstanding  indebtedness  was  4.24%  and  4.86%  at  December  31,  2019  and  2018,  respectively,  without
consideration  to  the  effect  of  our  derivative  contracts.  We  had  Interest  payable  of  $0.6  million  and  $0.9  million  in  “Other  current  liabilities”  on  our
consolidated balance sheets at December 31, 2019 and 2018, respectively.

The following table presents our available liquidity as of the dates indicated:

Cash and cash equivalents (1)
Aggregate borrowing capacity under Credit Agreement

     Less: Revolving Credit Facility amounts outstanding

     Less: Letters of credit outstanding

Available liquidity based on Credit Agreement capacity

Available liquidity based on Credit Agreement covenants (2)

(1)  Excludes amounts that are restricted pursuant to our collaborative agreement with Gibson.

77

December 31,

2019

2018

(in millions)
3.1   $

385.0  

220.0  

—  

168.1   $

31.9   $

6.4

385.0

209.0

0.6

181.8

65.7

$

$

$

 
 
 
 
    
(2)  Pursuant to the terms of our Credit Agreement, our borrowing capacity is limited to 4.5 times our trailing 12-month consolidated EBITDA, which equates to $28.8 million of borrowing capacity

available at December 31, 2019 and $59.3 million of borrowing capacity available at December 31, 2018.

Energy  Capital  Partners  must  approve  any  additional  issuances  of  equity  by  us,  and  its  determinations  may  be  made  free  of  any  duty  to  us  or  our
unitholders. Members of our general partner’s board of directors appointed by Energy Capital Partners must also approve the incurrence by us of additional
indebtedness or refinancing outside of our existing indebtedness that is not in the ordinary course of business.

Cash Flows

The  following  table  and  discussion  summarizes  the  cash  flows  associated  with  our  operating,  investing  and  financing  activities  for  the  periods

indicated.

Net cash provided by (used in):

Operating activities

Investing activities

Financing activities

Effect of exchange rates on cash

Net change in cash and cash equivalents

Operating Activities

For the Year Ended December 31,

2019

2018

(in thousands)

2017

$

$

38,442   $

45,129   $

47,819

(8,440)  

(8,580)  

(32,406)  

(36,890)  

705  

(1,064)  

(1,699)   $

(1,405)   $

(27,580)

(23,790)

201

(3,350)

Net cash provided by operating activities decreased by $6.7 million to $38.4 million for the year ended December 31, 2019, from $45.1 million for the
year ended December 31, 2018.  The  decrease  in  net  cash  provided  by  operating  activities  was  primarily  due  to  lower  operating  income  generated  by  our
Terminalling  Services  segment,  as  previously  discussed,  coupled  with  the  timing  of  receipts  and  payments  on  accounts  receivable,  accounts  payable  and
deferred revenue balances.

Investing Activities

Net cash used in investing activities decreased by $0.1 million to $8.4 million for the year ended December 31, 2019, as compared with the year ended
December  31,  2018.  The  cash  used  in  2019  and  2018  was  primarily  associated  with  the  construction  of  an  outbound  pipeline  connection  at  the  Casper
Terminal, which was completed in December 2019.

Financing Activities

Net cash used for financing activities decreased by $4.5 million to $32.4 million for the year ended December 31, 2019, from $36.9 million for the year
ended December 31, 2018. Our net proceeds from long-term debt were $4.0 million higher for the year ended December 31, 2019, as compared with our net
proceeds for the year ended December 31, 2018. We used these proceeds to fund construction of the outbound pipeline at our Casper terminal. In addition we
did not use $2.9 million of cash to pay financing costs in 2019 that we used in 2018 for amending and restating our senior secured credit agreement. Partially
offsetting the cash provided from our borrowing activities, are increases in cash we used for distributions and participant withholding taxes associated with
vested Phantom Units both of which exceeded amounts paid during the year ended December 31, 2018, for similar items.

Cash Requirements

Our primary requirements for cash are: (1) financing current operations, (2) servicing our debt, (3) funding capital expenditures, including potential

acquisitions and the costs to construct new assets, and (4) making distributions to our unitholders.

78

 
 
 
 
   
   
Capital Requirements

Our  historical  capital  expenditures  have  primarily  consisted  of  the  costs  to  construct  and  acquire  energy-related  logistics  assets.  Our  operations  are

expected to require investments to expand, upgrade or enhance existing facilities and to meet environmental and operational regulations.

Our  partnership  agreement  requires  that  we  categorize  our  capital  expenditures  as  either  expansion  capital  expenditures,  maintenance  capital

expenditures, or investment capital expenditures.

•

Expansion capital expenditures are cash expenditures incurred for acquisitions or capital improvements that we expect will increase our operating
income  or  operating  capacity  over  the  long  term.  Examples  of  expansion  capital  expenditures  include  the  acquisition  of  terminals  or  other
complementary  midstream  assets  from  USD  or  third  parties  and  the  construction  or  development  of  new  terminals  or  additional  capacity  at  our
existing  terminals  to  the  extent  such  capital  expenditures  are  expected  to  expand  our  operating  capacity  or  operating  income.  Expansion  capital
expenditures include interest payments (and related fees) on debt incurred to finance all or a portion of expansion capital expenditures in respect of
the period from the date that we enter into a binding obligation to commence the construction, development, replacement, improvement or expansion
of a capital asset and ending on the earlier to occur of the date that such capital improvement commences commercial service and the date that such
capital improvement is disposed of or abandoned.

• Maintenance capital expenditures are cash expenditures made to maintain, over the long term, our operating capacity, operating income or our asset

base. Examples of maintenance capital expenditures are expenditures to repair and refurbish our terminals.

•

Investment capital expenditures are those capital expenditures that are neither maintenance capital expenditures nor expansion capital expenditures.
Investment  capital  expenditures  will  largely  consist  of  capital  expenditures  made  for  investment  purposes.  Examples  of  investment  capital
expenditures include traditional capital expenditures for investment purposes, such as purchases of securities, as well as other capital expenditures
that might be made in lieu of such traditional investment capital expenditures, such as the acquisition of a capital asset for investment purposes or
development of facilities that are in excess of the maintenance of our existing operating capacity or operating income, but that are not expected to
expand our operating capacity or operating income over the long term.

We have not experienced significant maintenance capital expenditures in prior years, however, as the age of our assets increase, we expect that costs we
incur  to  maintain  our  assets  in  compliance  with  sound  business  practice,  our  contractual  relationships  and  applicable  regulatory  requirements  will  likely
increase.  Some  of  these  costs  will  be  characterized  as  maintenance  capital  expenditures.  We  incurred  $216  thousand  and  $201  thousand  of  maintenance
capital expenditures during the year ended December 31, 2019 and December 31, 2018, respectively.

Our total expansion capital expenditures for the year ended December 31, 2019, amounted to $8.4 million, primarily for construction of the outbound
pipeline connection from the Casper Terminal to the Platte Terminal. We expect to fund future capital expenditures from cash on our balance sheet, cash flow
generated by our operations, borrowings under our Credit Agreement and the issuance of additional partnership interests or long-term debt.

Our total capital expenditures for the year ended December 31, 2018 of $8.8 million were primarily associated with the construction of an outbound

pipeline connection at the Casper Terminal.

Debt Service

We anticipate reducing our outstanding indebtedness to the extent we generate cash flows in excess of our operating, investing and distribution needs.
During  the  year  ended  December  31,  2019,  we  received  proceeds  from  borrowing  of  $38.0 million  on  our  Revolving  Credit  Facility  which  we  used  for
general partnership purposes including funding the construction of the outbound pipeline at our Casper terminal and made repayments of $27.0 million on our
Revolving Credit Facility from cash flow in excess of our operating and investing needs.

79

Distributions

We intend to pay a minimum quarterly distribution of at least $0.2875 per unit per quarter. Our current quarterly distribution of $0.37 per unit equates
to  $10.2  million  per  quarter,  or  $40.7  million  per  year,  based  on  the  number  of  common,  subordinated,  and  general  partner  units  outstanding  as  of
February 10, 2020. We do not have a legal obligation to distribute any particular amount per common unit. Additionally, members of our general partner’s
board of directors appointed by Energy Capital Partners, if any, must approve any distribution made by us.

Other Items Affecting Liquidity

Credit Risk

Our exposure to credit risk may be affected by the concentration of our customers within the energy industry, as well as changes in economic or other
conditions.  Our  customers’  businesses  react  differently  to  changing  conditions.  We  believe  that  our  credit-review  procedures,  customer  deposits  and
collection procedures have adequately provided for amounts that may become uncollectible in the future.

Foreign Currency Exchange Risk

We currently derive a significant portion of our cash flows from our Canadian operations, particularly our Hardisty terminal. As a result, portions of
our cash and cash equivalents are denominated in Canadian dollars and are held by foreign subsidiaries, which amounts are subject to fluctuations resulting
from changes in the exchange rate between the U.S. dollar and the Canadian dollar. We employ derivative financial instruments to minimize our exposure to
the effect of foreign currency fluctuations, as we deem necessary based upon anticipated economic conditions.

Contractual Obligations and Commitments

In  the  ordinary  course  of  business,  we  enter  into  a  variety  of  contractual  obligations  and  other  commitments.  The  following  table  summarizes  the
principal  amount  of  our  future  minimum  obligations  and  commitments  that  have  remaining  non-cancellable  terms  in  excess  of  one  year  at
December 31, 2019:

Total

2020

2021

2022

2023

2024

Thereafter

Payments Due by Year

(in thousands)

Operating services agreements (1)

$

8,635   $

8,635   $

—   $

—   $

—   $

—   $

Operating leases (2)

Interest (3)

Credit Agreement (4)

Total

13,167  

5,286  

4,074  

3,787  

28,934  

10,156  

10,156  

8,622  

220,000  

—  

—  

220,000  

20  

—  

—  

—  

—  

—  

$

270,736   $

24,077   $

14,230   $

232,409   $

20   $

—   $

—

—

—

—

—

(1) 
(2) 
(3) 
(4) 

These future obligations represent labor service agreements at our terminal facilities.
Future minimum lease payments under non-cancellable operating leases for land, building, storage tanks, track, and railcars.
Interest payable on our Credit Agreement is variable. We estimated interest through maturity using rates in effect on December 31, 2019.
Principal repayment obligations under our Credit Agreement as of December 31, 2019.

SUBSEQUENT EVENTS

Refer to Note 22. Subsequent Events of our consolidated financial statements included in Item 8. Financial Statements and Supplementary Data of this

Annual Report for a discussion regarding subsequent events.

Recent Accounting Pronouncements Not Yet Adopted

Refer to Note 2. Summary of Significant Accounting Policies  of  our  consolidated  financial  statements  included  in  Item 8. Financial  Statements  and

Supplementary Data of this Annual Report for a discussion regarding recent accounting pronouncements that we have not yet adopted.

80

 
 
 
 
 
 
 
 
 
   
    
OFF-BALANCE SHEET ARRANGEMENTS

In the normal course of business, we are a party to off-balance sheet arrangements relating to various master fleet services agreements, whereby we
have agreed to assign certain payment and other obligations to third-party special purpose entities that are not consolidated with us. We have also entered into
agreements to provide fleet services to these special purpose entities for fixed servicing fees and reimbursement of out-of-pocket expenses. The purpose of
these transactions is to remove the risk to us of non-payment by our customers, which would otherwise negatively impact our financial condition and results
of operations. For more information on these special purpose entities, see the discussion of our relationship with the variable interest entities described in Note
12. Nonconsolidated Variable Interest Entities to our consolidated financial statements for the years ended December 31, 2019, 2018 and 2017 included in
Part II, Item 8. Financial Statements and Supplementary Data of this Annual Report. Liabilities related to these arrangements are generally not reflected in
our consolidated balance sheets, and we do not expect any material impact on our cash flows, results of operations or financial condition as a result of these
off-balance sheet arrangements.

CRITICAL ACCOUNTING POLICIES AND ESTIMATES

Our  selection  and  application  of  accounting  policies  is  an  important  process  that  has  developed  as  our  business  activities  have  evolved  and  as  new
accounting  pronouncements  have  been  issued.  Accounting  decisions  generally  involve  an  interpretation  of  existing  accounting  principles  and  the  use  of
judgment in applying those principles to the specific circumstances existing in our business. We make every effort to comply with all applicable accounting
principles  and  believe  the  proper  implementation  and  consistent  application  of  these  principles  is  critical.  However,  not  all  situations  we  encounter  are
specifically addressed in the accounting literature. In such cases, we must use our best judgment to implement accounting policies that clearly and accurately
present the substance of these situations. We accomplish this by analyzing similar situations and the accounting guidance governing them and consulting with
experts about the appropriate interpretation and application of the accounting literature to these situations.

In  addition  to  the  above,  certain  amounts  included  in  or  affecting  our  consolidated  financial  statements  and  related  disclosures  must  be  estimated,
requiring  us  to  make  certain  assumptions  with  respect  to  values  or  conditions  that  cannot  be  known  with  certainty  at  the  time  the  consolidated  financial
statements  are  prepared.  These  estimates  affect  the  reported  amounts  of  assets,  liabilities,  revenues,  expenses  and  related  disclosures  with  respect  to
contingent assets and liabilities. The basis for our estimates is historical experience, consultation with experts and other sources we believe to be reliable.
While we believe our estimates are appropriate, actual results can and often do differ from these estimates. Any effect on our business, financial position,
results  of  operations  and  cash  flows  resulting  from  revisions  to  these  estimates  are  recorded  in  the  period  in  which  the  facts  that  give  rise  to  the  revision
become known.

We believe our critical accounting policies and estimates discussed in the following paragraphs address the more significant judgments and estimates
we use in the preparation of our consolidated financial statements. Each of these areas involve complex situations and a high degree of judgment either in the
application  and  interpretation  of  existing  accounting  literature  or  in  the  development  of  estimates  that  affect  our  consolidated  financial  statements.  Our
management has discussed the development and selection of the critical accounting policies and estimates related to the reported amounts of assets, liabilities,
revenues and expenses and disclosure of contingent liabilities with the Audit Committee of the board of directors of our general partner.

The  following  discussion  relates  to  the  critical  accounting  policies  and  estimates  for  USD  Partners  LP.  Our  consolidated  financial  statements  are
prepared  in  accordance  with  accounting  principles  generally  accepted  in  the  United  States.  The  preparation  of  consolidated  financial  statements  requires
management  to  make  judgments,  assumptions  and  estimates  based  on  the  best  available  information  at  the  time.  The  following  accounting  policies  are
considered critical because they are important to the portrayal of our financial condition and results, and involve a higher degree of complexity and judgment
on the part of management. Actual results may differ based on the accuracy of the information utilized and subsequent events, some over which we may have
little  or  no  control.  Significant  estimates  by  management  include  the  estimated  lives  of  depreciable  property  and  equipment,  recoverability  of  long-lived
assets and goodwill, and provision or benefit for income taxes.

81

Revenue

We recognize revenue from contracts with customers by applying the provisions of ASC 606, Revenue from Contracts with Customers. We recognize
revenue under the core principle to depict the transfer of control to our customers of goods or services in an amount reflecting the consideration for which we
expect to be entitled. In order to achieve the core principle, we apply the following five step approach:

(1) identify the contract with a customer;

(2) identify the performance obligations in the contract;

(3) determine the transaction price;

(4) allocate the transaction price to the performance obligations in the contract; and

(5) recognize revenue when a performance obligation is satisfied.

We define a performance obligation as a promise in a contract to transfer a distinct good or service to the customer, which also represents the unit of
account under ASC 606. We allocate the transaction price in a contract to each distinct performance obligation, which we recognize as revenue when, or as,
the  performance  obligation  is  satisfied.  For  contracts  with  multiple  performance  obligations,  we  allocate  the  transaction  price  in  the  contract  to  each
performance obligation using our best estimate of the standalone selling price for each distinct good or service in the contract, utilizing market-based and
cost-plus margin inputs. We have elected to account for sales taxes received from customers on a net basis.

We apply the right-to-invoice practical expedient to contracts for which we recognize revenue at the amount to which we have the right to invoice for

services performed.

Terminalling Services Revenues

We  derive  a  majority  of  our  revenues  from  contracts  to  provide  terminalling  services,  which  include  pipeline  transportation,  storage,  loading  and
unloading of crude oil and related products from and into railcars and trucks, as well as the transloading of biofuels from railcars into trucks. Our terminalling
services agreements for crude oil and related products are generally established under multi-year, take-or-pay provisions that require monthly payments from
our  customers  for  their  minimum  monthly  volume  commitments  in  exchange  for  our  performance  of  the  terminalling  services  enumerated  above.  Our
terminalling  services  for  biofuels  typically  require  monthly  payments  for  actual  volumes  handled.  Variable  consideration,  such  as  volume-based  pricing,
included in our agreements is typically resolved within the applicable accounting period.

We  recognize  revenue  for  the  terminalling  services  we  provide  based  upon  the  contractual  rates  set  forth  in  our  agreements  related  to  throughput
volumes. We recognize revenue over time as we render services based on the throughput delivered as this best represents the value we provide to customers
for  our  services.  All  of  the  contracted  capacity  at  our  Hardisty  and  Stroud  terminals  is  contracted  under  multi-year  agreements  that  contain  “take-or-pay”
provisions where we are entitled to the payment of minimum monthly commitment fees from our customers, regardless of whether the specified throughput
volumes to which the customer committed is achieved.

Our  terminalling  services  agreements  at  our  Hardisty  and  Stroud  terminals  generally  grant  our  customers  make-up  rights  that  allow  them  to  load
volumes  in  excess  of  their  minimum  monthly  commitment  in  future  periods,  without  additional  charge,  to  the  extent  capacity  is  available  for  the  excess
volume. The make-up rights typically expire, if unused, in subsequent periods up to 12 months following the period for which the volumes were originally
committed.  We  currently  recognize  substantially  all  of  the  amounts  we  receive  for  minimum  commitment  fees  as  revenue  when  collected,  since  breakage
associated  with  these  make-up  rights  options  has  varied  between  97%  and  99%  based  on  our  experience  and  expectations  around  usage  of  these  options.
Breakage rates are regularly evaluated and modified as necessary to reflect our current expectations and experience. If we do not expect to be entitled to a
breakage amount, we defer the recognition of revenue associated with volumes that are below the minimum monthly commitment until we determine that the
likelihood that the customer will be able to make up the minimum volume is remote or the make-up right expires. If we expect to be entitled to a breakage
amount, we estimate expected breakage and recognize the expected breakage amount as revenue in proportion to the trend of rights exercised by the customer.

82

Fleet Services Revenues

Our fleet services contracts provide for the sourcing of railcar fleets and related logistics and maintenance services. We allocate revenue between the
lease and service components based on the relative standalone values, typically utilizing market-based and cost-plus margin estimates, and account for each
component under the applicable accounting guidance. We record revenues for fleet leases on a gross basis, since we are deemed the primary obligor for the
services.

We recognize revenue for fleet leases and related party administrative services ratably over the contract period as services are consistently provided
throughout  the  period.  Revenue  for  reimbursable  costs  is  recognized  on  a  gross  basis  on  our  consolidated  statements  of  income  as  “Freight  and  other
reimbursables,” as the costs are incurred. We have deferred revenues for amounts collected in advance from customers in our Fleet services segment, which
we will recognize as revenue as the underlying services are performed pursuant to the terms of our contracts. We have prepaid rent associated with these
deferred revenues on our railcar leases, which we will recognize as expense as these railcars are used.

Capitalization Policies and Depreciation Methods

We record property and equipment at its original cost, which we depreciate on a straight-line basis over the estimated useful lives of the assets, which
range from three to 30 years. Our determination of the useful lives of property and equipment requires us to make various assumptions when the assets are
acquired  or  placed  into  service  about  the  expected  usage,  normal  wear  and  tear  and  the  extent  and  frequency  of  maintenance  programs.  Expenditures  for
repairs and maintenance are charged to expense as incurred, while improvements that extend the service life or capacity of existing property and equipment
are capitalized. Upon the sale or retirement of an asset, the related costs and accumulated depreciation are removed from the accounts and any gain or loss is
recognized in our operating results.

During  construction  we  capitalize  direct  costs,  such  as  labor,  materials  and  overhead,  as  well  as  interest  cost  we  may  incur  on  indebtedness  at  our

incremental borrowing rate.

Impairment of Long-lived Assets

We  evaluate  long-lived  assets  for  impairment  whenever  events  or  changes  in  circumstances  indicate  the  carrying  amount  of  an  asset  may  not  be

recoverable.

We consider a long-lived asset to be impaired when the sum of the estimated, undiscounted future cash flows from the use of the asset and its eventual
disposition is less than the carrying amount of the asset. Factors that indicate potential impairment include: a significant decrease in the market value of the
asset, operating or cash flow losses associated with the use of the asset, or a significant change in the asset’s physical condition or use.

When alternative courses of action to recover the carrying amount of a long-lived asset are under consideration, estimates of future undiscounted cash
flows take into account possible outcomes and probabilities of their occurrence. If the carrying amount of the long-lived asset is not recoverable based on the
estimated future undiscounted cash flows, an impairment loss is recognized to the extent the carrying value exceeds the estimated fair value of the long-lived
asset.

In late August 2019, a customer contract for terminalling services at our Casper terminal expired and was not renewed. The expiration of this contract
represented a trigger event that required us to assess the recoverability of our long-lived assets associated with the Casper terminal at August 31, 2019. Our
assessment  of  recoverability  includes  assumptions  regarding  the  projected  cash  flows  expected  to  be  derived  from  our  operation  of  the  Casper  terminal
without regard to any expansion of its existing service potential at August 31, 2019. The assumptions underlying our cash flow projections include our ability
to  renew  existing  contracts  and  expand  business  with  current  customers,  and  our  ability  to  enter  into  contracts  with  new  customers  and  obtain  additional
commitments regarding the use of these facilities. The critical assumptions underlying our projections include:

• Widening price differentials, or spreads, between the WCS and WTI crude oil pricing indices;

•

Incremental  volumes  at  our  Casper  terminal  of  approximately  20,000  to  40,000  bpd  for  terminalling  and  storage  services  resulting  from  the
anticipated successful completion of the Enbridge DRA project in the first

83

half  of  2020,  as  discussed  above  in  Growth  opportunities  for  our  Operations  —  Opportunities  Related  To  Our  Crude  Oil  Terminal  Network  —
Casper Terminal;

•

•

•

Expansion of the customer base for our blended services business for distribution to local refineries;

A six year remaining useful life of the primary asset, represented by our customer service agreement intangible asset of the Casper terminal asset
group; and

A residual value of 9x projected cash flows for the Casper terminal at the end of the six year remaining life of the primary asset.

To  the  extent  that  our  assumptions  as  set  forth  above  do  not  materialize,  our  projections  of  future  financial  performance  underlying  our  cash  flow

projections for the Casper terminal could yield undiscounted cash flows and a fair value that indicate our long-lived assets are impaired.

Assessment of Recoverability of Goodwill

Goodwill  represents  the  future  economic  benefits  arising  from  assets  acquired  in  a  business  combination  that  are  not  individually  identified  and

separately recognized. Currently, goodwill is only included in our Terminalling services segment as part of our Casper terminal reporting unit.

We do not amortize goodwill, but test it for impairment annually based on the carrying values of our reporting units on the first day of the third quarter
of  each  year  or  more  frequently  if  impairment  indicators  arise  that  suggest  the  carrying  value  of  goodwill  may  be  impaired.  Our  assessment  of  the
recoverability  of  goodwill  is  highly  subjective  due  to  frequent  changes  in  economic  conditions  underlying  the  assumptions  upon  which  the  valuations  are
based and global factors affecting the prices for various grades of crude oil and demand for our services. In assessing our ability to recover the carrying value
of goodwill, we make critical assumptions that include but are not limited to:

(1) our projections of future financial performance;

(2) our expectations for contract renewals for existing and additional capacity with current customers;

(3) our ability to expand our services and attract new customers;

(4) our expected market weighted average cost of capital;

(5) an expected range of EBITDA multiples derived from equity prices of public companies with similar operating and investment characteristics; and

(6) an expected range of EBITDA multiples for transactions based on actual sales and purchases of comparable businesses.

We recognize an impairment loss when the carrying amount of a reporting unit exceeds its implied fair value. We reduce the carrying value of goodwill

to its fair value at the time we determine that an impairment has occurred.

The $33.6 million balance of our goodwill originated from our acquisition of the Casper terminal in November 2015 and is wholly attributed to this
reporting unit. We measured the fair value of our Casper terminal reporting unit using customary business valuation techniques including an income analysis,
market analysis and transaction analysis, which we weighted at 50%, 25% and 25%, respectively. Our weighting of the measurement methods is consistent
with weightings used to value organizations that are similar to the Casper terminal reporting unit. The critical assumptions used in our analysis include the
following:

(1) Capital expenditures for additional terminalling connectivity;

(2) A  range  of  incremental  volumes  expected  at  our  Casper  terminal  of  approximately  20,000  to  40,000  bpd  for  terminalling  and  storage  services

resulting from the anticipated successful completion of the Enbridge DRA project in the first half of 2020;

(3) A weighted average cost of capital of 11%;

(4) A capital structure consisting of approximately 40% debt and 60% equity based on the capital structure of market participants;

(5) A range of EBITDA multiples derived from stock prices of public companies with similar operating and investment characteristics, from 8.25x to

9.25x; and

84

(6) A range of EBITDA multiples for transactions based on actual sales and purchases of comparable businesses, from 9.0x to 10.0x.

The key assumptions listed above were based upon economic and other operational conditions existing at or prior to our July 1, 2019 valuation date.
Our weighted average cost of capital is subject to variability and is dependent upon such factors as changes in benchmark rates of interest established by the
Federal Open Market Committee of the Federal Reserve Board, the British Bankers Association and other central banking regulatory authorities, as well as
perceptions of risk and market uncertainty regarding our business, industry and those of our peers and our underlying capital structure. We expect our long-
term  underlying  capital  structure  to  approximate  a  weighting  of  50%  debt  and  50%  equity.  Each  of  the  above  assumptions  are  likely  to  change  due  to
economic uncertainty surrounding global and North American energy markets that are highly correlated with crude oil, natural gas and other energy-related
commodity prices and other market factors.

Assumptions we make under the income approach include our projections of future financial performance of the Casper terminal reporting unit, which
include our ability to obtain additional connectivity at the terminal, our ability to renew existing contracts and expand business with current customers, and
our  ability  to  enter  into  contracts  with  new  customers  and  obtain  additional  commitments  regarding  the  use  of  their  facilities.  To  the  extent  that  our
assumptions vary from what we experience in the future, our projections of future financial performance underlying the fair value derived from the income
approach for the Casper terminal reporting unit could yield results that are significantly different from those projected. Further, in the event we are unable to
execute a majority of our growth plans underlying our financial projections for the Casper terminal reporting unit, we will likely realize an impairment of
goodwill.

The  EBITDA  multiples  we  used  to  estimate  the  fair  value  of  the  Casper  terminal  reporting  unit  are  subject  to  uncertainty  associated  with  market
conditions  in  the  energy  sector.  We  derived  the  assumption  based  upon  the  EBITDA  multiples  from  several  comparable  businesses  that  operate  in  the
midstream energy sector, generally providing services associated with the transportation of energy-related products. The EBITDA multiples of each of these
entities is affected by changes in the supply of and demand for energy-related products, which affects the demand for the services they provide. Declines in
the production of energy-related products as well as lower demand for these products can reduce the operating results of these organizations, and accordingly,
the multiples that market participants are willing to pay. Changes in the EBITDA multiples of these comparable businesses we use to estimate fair value could
significantly affect the fair value of the Casper terminal reporting unit we derived using this approach.

The EBITDA multiples from executed purchase and sales transactions of businesses that are similar to our Casper terminal reporting unit we used to
estimate the fair value are also subject to variability, which is dependent upon market conditions in the energy sector, as well as the perceived benefits the
acquiring  entity  expects  to  derive  from  the  transaction.  The  transactions  comprising  the  pool  occurred  during  the  immediately  preceding  three  years  and
future transactions may have no correlation to the EBITDA multiples for similar transactions in the future. Further deterioration in economic conditions in the
energy sector could result in a greater number of distressed sales at lower EBITDA multiples than currently estimated. Additionally, a representative sample
of transactions in the future may not provide a sufficient population upon which to derive an EBITDA multiple. These factors, among others, could cause our
estimates of fair value for the Casper terminal reporting unit to vary significantly from the amounts determined under this method.

As indicated above, our estimate of fair value for the Casper terminal reporting unit required us to use significant unobservable inputs representative of
Level  3  fair  value  measurements,  including  assumptions  related  to  the  future  performance  of  our  Casper  terminal.  During  the  third  quarter  of  2019,  we
completed our annual goodwill impairment analysis and determined that the fair value of the Casper terminal reporting unit exceeded its carrying value at
July 1, 2019. An impairment charge would have resulted if our estimate of the fair value of the Casper terminal reporting unit was approximately 5% less than
the amount determined. We have not observed any events or circumstances subsequent to our analysis that would suggest the fair value of our Casper terminal
is below its carrying amount as of December 31, 2019.

Income Taxes

We are not a taxable entity for U.S. federal income tax purposes or for a majority of the states that impose an income tax. Taxes on our net income are
generally borne by our unitholders through the allocation of taxable income, except for USD Rail LP, which, in October 2014, elected to be classified as an
entity taxable as a corporation. Our

85

income tax expense is predominantly attributable to Canadian federal and provincial income taxes imposed on our operations based in Canada. Additionally,
we are also subject to state franchise tax in the State of Texas, which is treated as an income tax under the applicable accounting guidance. This state income
tax  is  computed  on  our  modified  gross  margin,  which  we  have  determined  to  be  an  income  tax  as  set  forth  in  the  authoritative  accounting  guidance.  Our
current and historical provision for income taxes also reflects income taxes associated with USD Rail LP.

We recognize deferred income tax assets and liabilities for temporary differences between the relevant basis of our assets and liabilities for financial
reporting and tax purposes. We record the impact of changes in tax legislation on deferred income tax assets and liabilities in the period the legislation is
enacted.

Pursuant to the authoritative accounting guidance regarding uncertain tax positions, we recognize the tax effects of any uncertain tax position as the
largest  amount  that  will  more  likely  than  not  be  realized  upon  ultimate  settlement  with  the  taxing  authority  having  full  knowledge  of  the  position  and  all
relevant facts. Under this criterion, we evaluate the most likely resolution of an uncertain tax position based on its technical merits and on the outcome that
we expect would likely be sustained under examination.

Our policy is to recognize any interest or penalties related to the underpayment of income taxes as a component of income tax expense or benefit. We

have not historically incurred any significant interest or penalties for the underpayment of income taxes.

Net income for financial statement purposes may differ significantly from taxable income we allocated to our unitholders as a result of differences
between  the  tax  basis  and  financial  reporting  basis  of  assets  and  liabilities  and  the  taxable  income  allocation  requirements  set  forth  in  our  partnership
agreement. The aggregate difference in the basis of our net assets for financial and tax reporting purposes cannot be readily determined because information
regarding each partner’s tax attributes in us is not available.

Foreign Currency

A substantial portion of our operations are conducted in Canada and are accounted for in the local currency, the Canadian dollar, which we translate
into our reporting currency, the U.S. dollar. We translate most Canadian dollar denominated balance sheet accounts at the end of period exchange rate, while
most  income  statement  accounts  are  translated  monthly  based  on  the  average  exchange  rate  for  each  monthly  period.  Amounts  translated  from  foreign
currencies into our U.S. dollar reporting currency can vary between periods due to fluctuations in the exchange rates between the foreign currency and the
U.S. dollar.

Item 7A. Quantitative and Qualitative Disclosures About Market Risk

As a smaller reporting company, we are not required to provide the information required by this item.

86

Item 8. Financial Statements and Supplementary Data

INDEX TO CONSOLIDATED FINANCIAL STATEMENTS,
SUPPLEMENTARY INFORMATION AND
CONSOLIDATED FINANCIAL STATEMENT SCHEDULES
USD PARTNERS LP

Report of Independent Registered Public Accounting Firm

Consolidated Statements of Income

Consolidated Statements of Comprehensive Income

Consolidated Statements of Cash Flows

Consolidated Balance Sheets

Consolidated Statements of Partners’ Capital

Notes to the Consolidated Financial Statements

Page

88

89

90

91

92

93

94

Financial  statement  schedules  not  included  in  this  report  have  been  omitted  because  they  are  not  applicable  or  the  required  information  is  either

immaterial or shown in the consolidated financial statements or notes thereto.

FINANCIAL STATEMENT SCHEDULES

87

 
Partners of USD Partners LP and Board of Directors of USD Partners GP LLC, as General Partner of USD Partners LP
Houston, Texas

Report of Independent Registered Public Accounting Firm

Opinion on the Consolidated Financial Statements

We have audited the accompanying consolidated balance sheets of USD Partners LP and subsidiaries (the “Partnership”) as of December 31, 2019 and 2018,
the  related  consolidated  statements  of  income,  comprehensive  income,  partners’  capital,  and  cash  flows  for  each  of  the  three  years  in  the  period  ended
December  31,  2019,  and  the  related  notes  (collectively  referred  to  as  the  “consolidated  financial  statements”).  In  our  opinion,  the  consolidated  financial
statements present fairly, in all material respects, the financial position of the Partnership at December 31, 2019 and 2018, and the results of their operations
and their cash flows for each of the three years in the period ended December 31, 2019, in conformity with accounting principles generally accepted in the
United States of America.

We also have audited, in accordance with the standards of the Public Company Accounting Oversight Board (United States) (“PCAOB”), the Partnership’s
internal control over financial reporting as of December 31, 2019, based on criteria established in Internal Control - Integrated Framework (2013) issued by
the Committee of Sponsoring Organizations of the Treadway Commission (“COSO”) and our report dated March 5, 2019 expressed an unqualified opinion
thereon.

Change in Accounting Principle

As discussed in Note 2 to the consolidated financial statements, the Company changed its method of accounting for leases in 2019 due to the adoption of
Accounting Standards Update (ASU) No. 2016-02, Leases (Topic 842), and the related amendments.

Basis for Opinion

These  consolidated  financial  statements  are  the  responsibility  of  the  Partnership’s  management.  Our  responsibility  is  to  express  an  opinion  on  the
Partnership’s  consolidated  financial  statements  based  on  our  audits.  We  are  a  public  accounting  firm  registered  with  the  Public  Company  Accounting
Oversight Board (United States (“PCAOB”) and are required to be independent with respect to the Partnership in accordance with the U.S. federal securities
laws and the applicable rules and regulations of the Securities and Exchange Commission and the PCAOB.

We conducted our audits in accordance with the standards of the PCAOB. Those standards require that we plan and perform the audit to obtain reasonable
assurance about whether the consolidated financial statements are free of material misstatement, whether due to error or fraud.

Our audits included performing procedures to assess the risks of material misstatement of the consolidated financial statements, whether due to error or fraud,
and performing procedures that respond to those risks. Such procedures included examining, on a test basis, evidence regarding the amounts and disclosures
in the consolidated financial statements. Our audits also included evaluating the accounting principles used and significant estimates made by management, as
well as evaluating the overall presentation of the consolidated financial statements. We believe that our audits provide a reasonable basis for our opinion.

/s/ BDO USA, LLP

We have served as the Partnership’s auditor since 2014.

Houston, Texas
March 5, 2020

88

USD PARTNERS LP
CONSOLIDATED STATEMENTS OF INCOME

Revenues

Terminalling services

Terminalling services — related party

Fleet leases

Fleet leases — related party

Fleet services

Fleet services — related party

Freight and other reimbursables

Freight and other reimbursables — related party

Total revenues

Operating costs

Subcontracted rail services

Pipeline fees

Freight and other reimbursables

Operating and maintenance

Operating and maintenance — related party

Selling, general and administrative

Selling, general and administrative — related party

Depreciation and amortization

Total operating costs

Operating income

Interest expense

Loss (gain) associated with derivative instruments

Foreign currency transaction loss (gain)

Other expense (income), net

Income before income taxes

Provision for (benefit from) income taxes

Net income

Net income attributable to limited partner interest

Net income per common unit (basic and diluted) (Note 3)

Weighted average common units outstanding

Net income per subordinated unit (basic and diluted) (Note 3)

Weighted average subordinated units outstanding

For the Years Ended December 31,

2019

2018

2017

(in thousands of US dollars, except per unit amounts)

$

87,173   $

88,066   $

85,466

19,580  

22,149  

13,769

—  

—  

3,935  

3,935  

208  

910  

573  

910  

1,612  

3,589  

238  

4  

2,140

4,401

1,854

652

521

2

113,656  

119,226  

108,805

14,777  

13,785  

8,953

20,971  

21,679  

22,524

1,850  

3,593  

523

10,953  

11,195  

10,114

4,964  

—  

10,716  

10,840  

8,128  

7,582  

—

9,214

5,867

20,664  

21,103  

22,132

93,023  

89,777  

79,327

20,633  

29,449  

29,478

12,006  

11,358  

9,925

1,420  

(374)  

365  

(336)  

(14)  

16  

937

(456)

(330)

7,178  

18,463  

19,402

662  

(2,669)  

(1,929)

$

$

$

$

6,516   $

21,132   $

5,720   $

20,356   $

0.22   $

0.77   $

24,078  

21,590  

0.19   $

0.78   $

2,379  

4,472  

21,331

20,750

0.84

17,924

0.85

6,565

The accompanying notes are an integral part of these consolidated financial statements.

89

 
 
 
 
 
 
   
   
   
   
USD PARTNERS LP
CONSOLIDATED STATEMENTS OF COMPREHENSIVE INCOME

Net income

Other comprehensive income (loss) — foreign currency translation

Comprehensive income

For the Years Ended December 31,

2019

2018

2017

(in thousands of US dollars)

$

$

6,516   $

21,132   $

21,331

2,882  

(4,843)  

3,560

9,398   $

16,289   $

24,891

The accompanying notes are an integral part of these consolidated financial statements.

90

 
 
 
 
 
USD PARTNERS LP
CONSOLIDATED STATEMENTS OF CASH FLOWS

Cash flows from operating activities:

Net income

Adjustments to reconcile net income to net cash provided by operating activities:

Depreciation and amortization

Loss (gain) associated with derivative instruments

Settlement of derivative contracts

Unit based compensation expense

Deferred income taxes

Other

Changes in operating assets and liabilities:

Accounts receivable

Accounts receivable — related party

Prepaid expenses and other assets

Other assets — related party

Accounts payable and accrued expenses

Accounts payable and accrued expenses — related party

Deferred revenue and other liabilities

Deferred revenue — related party

Net cash provided by operating activities

Cash flows from investing activities:

Additions of property and equipment

Proceeds from the sale of assets

Net cash used in investing activities

Cash flows from financing activities:

Payments for deferred financing costs

Distributions

Vested Phantom Units used for payment of participant taxes

Net proceeds from issuance of common units

Proceeds from long-term debt

Repayment of long-term debt

Other financing activities

Net cash used in financing activities

Effect of exchange rates on cash

Net change in cash, cash equivalents and restricted cash

For the Years Ended December 31,

2019

2018

2017

(in thousands of US dollars)

$

6,516   $

21,132   $

21,331

20,664  

21,103  

22,132

1,420  

1  

(374)  

(38)  

937

46

6,066  

6,358  

4,143

79  

(3,971)  

1,129  

939  

(109)  

(1,046)  

(1,122)  

1,868  

(1,484)  

(180)  

(606)  

(86)  

79  

816  

2  

(1,455)  

(987)

879

222

(226)

3,760

(253)

377

20

6,529  

(213)  

(5,517)

(463)  

17  

955

38,442  

45,129  

47,819

(8,440)  

(8,816)  

(27,580)

—  

236  

—

(8,440)  

(8,580)  

(27,580)

(7)  

(2,906)  

—

(41,557)  

(39,632)  

(35,075)

(1,829)  

(1,352)  

(1,073)

—  

—  

33,700

38,000  

34,000  

50,000

(27,000)  

(27,000)  

(71,342)

(13)  

—  

—

(32,406)  

(36,890)  

(23,790)

705  

(1,064)  

201

(1,699)  
12,383  

(1,405)  
13,788  

(3,350)

17,138

 
 
 
 
 
 
   
 
   
   
 
   
   
 
   
   
 
   
   
Cash, cash equivalents and restricted cash — beginning of year

Cash, cash equivalents and restricted cash — end of year

$

10,684   $

12,383   $

13,788

The accompanying notes are an integral part of these consolidated financial statements.

91

USD PARTNERS LP
CONSOLIDATED BALANCE SHEETS

ASSETS

December 31,

2019

2018

(in thousands of US dollars, except unit amounts)

$

3,083   $

7,601  

5,313  

1,778  

1,915  

954  

343  

20,987  

147,737  

74,099  

33,589  

11,804  

1,335  

15  

6,439

5,944

5,132

624

2,115

634

79

20,967

145,308

86,705

33,589

—

631

95

Current assets

Cash and cash equivalents

Restricted cash

Accounts receivable, net

Accounts receivable — related party

Prepaid expenses

Other current assets

Other current assets — related party

Total current assets

Property and equipment, net

Intangible assets, net

Goodwill

Operating lease right-of-use assets

Other non-current assets

Other non-current assets — related party

Total assets

Current liabilities

LIABILITIES AND PARTNERS’ CAPITAL

$

289,566  

$

287,295

Accounts payable and accrued expenses

Accounts payable and accrued expenses — related party

Deferred revenue

Deferred revenue — related party

Operating lease liabilities, current

Other current liabilities

Total current liabilities

Long-term debt, net

Deferred income tax liabilities, net

Operating lease liabilities, non-current

Other non-current liabilities

Total liabilities

Commitments and contingencies (Note 14)

Partners’ capital

Common units (24,411,892 authorized and issued at December 31, 2019 and 21,916,024 authorized and
issued at December 31, 2018)

Class A units (250,000 authorized, 38,750 issued at December 31, 2018)

Subordinated units (10,463,545 authorized, 2,092,709 issued at December 31, 2019 and 4,185,418 issued
at December 31, 2018)

General partner units (461,136 authorized and issued at December 31, 2019 and 2018)

Accumulated other comprehensive loss

Total partners’ capital

$

3,087   $

465  

6,104  

1,482  

4,649  

3,150  

18,937  

217,651  

458  

7,386  

4,078  

3,464

460

2,921

1,885

—

2,804

11,534

205,581

360

—

356

248,510  

217,831

61,013  

—  

(22,597)  

2,767  

(127)  
41,056  

107,903

1,018

(39,723)

3,275

(3,009)

69,464

 
 
 
 
 
 
   
 
   
 
   
 
 
   
Total liabilities and partners’ capital

$

289,566   $

287,295

The accompanying notes are an integral part of these consolidated financial statements.

92

Common units

Beginning balance

Units issued

Conversion of units

Common units issued for vested Phantom Units

Net income

Unit based compensation expense

Distributions

Ending balance

Class A units

Beginning balance

Conversion of units

Net income

Unit based compensation expense

Forfeited units

Distributions

Ending balance

Subordinated units

Beginning balance

Conversion of units

Net income

Unit based compensation expense

Distributions

Ending balance

General partner units

Beginning balance

Capital contributions

Net income

Unit based compensation expense

Distributions

Ending balance

Accumulated other comprehensive income (loss)

Beginning balance

Cumulative translation adjustment

Ending balance

Total partners’ capital at December 31,

USD PARTNERS LP
CONSOLIDATED STATEMENTS OF PARTNERS’ CAPITAL

For the Years Ended December 31,

2019

2018

2017

Units

Amount

Units

Amount

Units

Amount

(in thousands, except unit amounts)

21,916,024   $

—  
2,131,459  
364,409  
—  
—  
—  
24,411,892  

38,750  
(38,750)  
—  
—  
—  
—  
—  

4,185,418  
(2,092,709)  
—  
—  
—  
2,092,709  

461,136  
—  
—  
—  
—  
461,136  

107,903  
—  
(19,631)  
(1,829)  
5,258  
5,576  
(36,264)  
61,013  

1,018  
(1,018)  
—  
14  
—  
(14)  
—  

(39,723)  
20,637  
462  
2  
(3,975)  
(22,597)  

3,275  
—  
796  
—  
(1,304)  
2,767  

19,537,971   $

—  
2,131,459  
246,594  
—  
—  
—  
21,916,024  

82,500  
(38,750)  
—  
—  
(5,000)  
—  
38,750  

6,278,127  
(2,092,709)  
—  
—  
—  
4,185,418  

461,136  
—  
—  
—  
—  
461,136  

136,645  
—  
(18,245)  
(1,352)  
16,796  
5,617  
(31,558)  
107,903  

1,468  
(674)  
36  
186  
73  
(71)  
1,018  

(55,237)  
18,919  
3,524  
26  
(6,955)  
(39,723)  

180  
3,366  
776  
1  
(1,048)  
3,275  

14,185,599   $
3,000,000  
2,162,084  
190,288  
—  
—  
—  
19,537,971  

138,750  
(46,250)  
—  
—  
(10,000)  
—  
82,500  

8,370,836  
(2,092,709)  
—  
—  
—  
6,278,127  

461,136  
—  
—  
—  
—  
461,136  

(3,009)    
2,882    
(127)    
41,056    

  $

1,834    
(4,843)    
(3,009)    
69,464    

  $

  $

128,903

33,700

(19,047)

(1,073)

15,093

3,694

(24,625)

136,645

1,929

(606)

80

450

(247)

(138)

1,468

(70,936)

19,653

5,577

23

(9,554)

(55,237)

356

—

581

1

(758)

180

(1,726)

3,560

1,834

84,890

The accompanying notes are an integral part of these consolidated financial statements.

93

 
 
 
 
 
 
 
 
 
 
 
 
   
   
   
   
   
 
   
   
   
   
   
 
   
   
   
   
   
 
   
   
   
   
   
 
   
   
   
   
   
 
 
 
 
 
 
 
 
 
 
 
 
 
USD PARTNERS LP
NOTES TO THE CONSOLIDATED FINANCIAL STATEMENTS

1. ORGANIZATION AND DESCRIPTION OF BUSINESS

General

USD  Partners  LP  and  its  consolidated  subsidiaries,  collectively  referred  to  herein  as  we,  us,  our,  the  Partnership  and  USDP,  is  a  fee-based,  growth-
oriented master limited partnership formed in 2014 by US Development Group, LLC, or USD, through its wholly-owned subsidiary USD Group LLC, or
USDG.  We  were  formed  to  acquire,  develop  and  operate  midstream  infrastructure  and  complimentary  logistics  solutions  for  crude  oil,  biofuels  and  other
energy-related  products.  We  generate  substantially  all  of  our  operating  cash  flows  from  multi-year,  take-or-pay  contracts  with  primarily  investment  grade
customers, including major integrated oil companies, refiners and marketers. Our network of crude oil terminals facilitates the transportation of heavy crude
oil from Western Canada to key demand centers across North America. Our operations include railcar loading and unloading, storage and blending in onsite
tanks, inbound and outbound pipeline connectivity, truck transloading, as well as other related logistics services. We also provide our customers with leased
railcars and fleet services to facilitate the transportation of liquid hydrocarbons and biofuels by rail. We do not generally take ownership of the products that
we handle nor do we receive any payments from our customers based on the value of such products. We may on occasion enter into buy-sell arrangements in
which we take temporary title to commodities while in our terminals. We expect such arrangements to be at fixed prices where we do not take commodity
price exposure.

Our  capital  accounts  at  both  December  31,  2019  and  2018 include a 1.7%  general  partner  interest  held  by  USD  Partners  GP  LLC,  a  wholly-owned

subsidiary of USDG.

The composition of our capital accounts was as follows at the specified dates:

Common units held by the Public

Common units held by USDG

Subordinated units held by USDG

Class A units held by management

General partner interest held by USD Partners GP LLC

US Development Group, LLC

December 31,

2019

2018

55.4%  

35.1%  

7.8%  

—%  

1.7%  

100.0%  

54.8%

27.7%

15.7%

0.1%

1.7%

100.0%

USD  and  its  affiliates  are  engaged  in  designing,  developing,  owning  and  managing  large-scale  multi-modal  logistics  centers  and  energy-related
infrastructure  across  North  America.  USD  is  the  indirect  owner  of  our  general  partner  through  its  direct  ownership  of  USDG  and  is  currently  owned  by
Energy Capital Partners, Goldman Sachs and certain members of USD’s management team.

2. SUMMARY OF SIGNIFICANT ACCOUNTING POLICIES

Basis of Presentation and Use of Estimates

We  prepare  our  consolidated  financial  statements  in  accordance  with  accounting  principles  generally  accepted  in  the  United  States  of  America,  or
GAAP. Our preparation of these consolidated financial statements requires us to make estimates and assumptions that affect the reported amounts of assets,
liabilities, and the disclosure of contingent assets and liabilities at the date of the financial statements and the reported amounts of revenues and expenses
during the reporting period. We regularly evaluate these estimates utilizing historical experience, consultation with experts and other methods we consider
reasonable in the circumstances. Nevertheless, actual results may differ from these estimates. We record the effect of any revisions to these estimates in our
consolidated financial statements in the period

94

 
 
 
 
 
 
 
 
 
 
 
 
in  which  the  facts  that  give  rise  to  the  revision  become  known.  Significant  estimates  we  make  include,  but  are  not  limited  to,  the  estimated  lives  of
depreciable property and equipment, recoverability of long-lived assets, the collectability of accounts receivable, the amounts of deferred revenue and related
prepaid pipeline fees.

Principles of Consolidation

The  consolidated  financial  statements  include  our  accounts  and  those  of  our  wholly-owned  subsidiaries  on  a  consolidated  basis.  All  significant
intercompany  accounts  and  transactions  have  been  eliminated  in  consolidation.  We  consolidate  the  accounts  of  entities  over  which  we  have  a  controlling
financial interest through our ownership of the general partner or the majority voting interests of the entity.

Comparative Amounts

We  have  made  certain  reclassifications  to  the  amounts  reported  in  the  prior  year  to  conform  with  the  current  year  presentation.  None  of  these

reclassifications have an impact on our operating results, cash flows or financial position.

We adopted the provisions of ASC 842 Leases on January 1, 2019. We elected to implement the provisions of the new standard to our existing leases
by  recognizing  and  measuring  lease  assets  and  liabilities  on  our  balance  sheet  as  of  January  1,  2019,  as  well  as  any  cumulative-effect  adjustment  to  the
opening balance of Partners’ Capital. Refer to the Leases section below and Note 8. Leases for further discussion.

Foreign Currency Translation

We  conduct  a  substantial  portion  of  our  operations  in  Canada,  which  we  account  for  in  the  local  currency,  the  Canadian  dollar.  We  translate  most
Canadian  dollar  denominated  balance  sheet  accounts  into  our  reporting  currency,  the  U.S.  dollar  at  the  end  of  period  exchange  rate,  while  most  income
statement accounts are translated into our reporting currency based on the average exchange rate for each monthly period. Fluctuations in the exchange rates
between the Canadian dollar and the U.S. dollar can create variability in the amounts we translate and report in U.S. dollars.

Within these consolidated financial statements, we denote amounts denominated in Canadian dollars with “C$” immediately prior to the stated amount.

Revenue Recognition

We recognize revenue from contracts with customers under the core principle to depict the transfer of control to our customers of goods or services in

an amount reflecting the consideration for which we expect to be entitled. In order to achieve the core principle, we apply the following five step approach:

(1) identify the contract with a customer;

(2) identify the performance obligations in the contract;

(3) determine the transaction price;

(4) allocate the transaction price to the performance obligations in the contract; and

(5) recognize revenue when a performance obligation is satisfied.

We define a performance obligation as a promise in a contract to transfer a distinct good or service to the customer. We allocate the transaction price in
a contract to each distinct performance obligation, which we recognize as revenue when, or as, the performance obligation is satisfied. For contracts with
multiple performance obligations, we allocate the transaction price in the contract to each performance obligation using our best estimate of the standalone
selling price for each distinct good or service in the contract, utilizing market-based and cost-plus margin inputs. We have elected to account for sales taxes
received from customers on a net basis.

We applied the right-to-invoice practical expedient to contracts for which we recognize revenue at the amount to which we have the right to invoice for

services performed.

95

Terminalling Services Revenues

We  derive  a  majority  of  our  revenues  from  contracts  to  provide  terminalling  services,  which  include  pipeline  transportation,  storage,  loading  and
unloading of crude oil and related products from and into railcars and trucks, as well as the transloading of biofuels from railcars into trucks. Our terminalling
services agreements for crude oil and related products are generally established under multi-year, take-or-pay arrangements that require monthly payments
from our customers for their minimum monthly volume commitments in exchange for our performance of the terminalling services enumerated above. Our
terminalling  services  for  biofuels  typically  require  monthly  payments  for  actual  volumes  handled.  Variable  consideration,  such  as  volume-based  pricing,
included in our agreements is typically resolved within the applicable accounting period.

We  recognize  revenue  for  the  terminalling  services  we  provide  based  upon  the  contractual  rates  set  forth  in  our  agreements  related  to  throughput
volumes. We recognize revenue over time as we render services based on the throughput volumes handled at our terminals as this best represents the value of
the  services  we  provide  to  customers.  Substantially  all  of  the  contracted  capacity  at  our  Hardisty  and  Stroud  terminals  is  contracted  under  multi-year
agreements that contain “take-or-pay” provisions where we are entitled to the payment of minimum monthly commitment fees from our customers, regardless
of whether the specified throughput volume to which the customer committed is achieved.

Our  terminalling  services  agreements  at  our  Hardisty  and  Stroud  terminals  generally  grant  our  customers  make-up  rights  that  allow  them  to  load
volumes  in  excess  of  their  minimum  monthly  commitment  in  future  periods,  without  additional  charge,  to  the  extent  capacity  is  available  for  the  excess
volume. The make-up rights typically expire, if unused, in subsequent periods up to 12 months following the period for which the volumes were originally
committed.  We  currently  recognize  substantially  all  of  the  amounts  we  receive  for  minimum  commitment  fees  as  revenue  when  collected,  since  breakage
associated  with  these  make-up  rights  options  has  varied  between  97%  and  99%  based  on  our  experience  and  expectations  around  usage  of  these  options.
Breakage rates are regularly evaluated and modified as necessary to reflect our current experience and expectations. If we do not expect to be entitled to a
breakage amount, we defer the recognition of revenue associated with volumes that are below the minimum monthly commitment until we determine that the
likelihood  that  the  customer  will  be  able  to  make  up  the  minimum  volume  is  remote.  If  we  expect  to  be  entitled  to  a  breakage  amount,  we  estimate  the
expected breakage and recognize the expected breakage amount as revenue in proportion to the trend of rights exercised by the customer.

Fleet Services Revenues

Our fleet services contracts provide for the sourcing of railcar fleets and related logistics and maintenance services. We allocate revenue between the
lease  and  service  components  based  on  relative  standalone  values,  typically  utilizing  market-based  and  cost-plus  margin  estimates,  and  account  for  each
component under the applicable accounting guidance. We record revenues for fleet leases on a gross basis, since we are deemed the primary obligor for the
services.

We  recognize  revenue  for  fleet  leases  and  related  party  administrative  services  ratably  over  the  lease  contract  period  as  services  are  consistently
provided throughout the period. Revenue for reimbursable costs is recognized on a gross basis on our consolidated statements of income as “Freight and other
reimbursables,” as the costs are incurred. We have deferred revenues for amounts collected in advance from customers in our Fleet services segment, which
will be recognized as revenue as the underlying services are performed pursuant to the terms of our lease contracts. We have prepaid rent associated with
these deferred revenues on our railcar leases, which we will recognize as expense as these railcars are used.

Railroad Incentives

Our Hardisty terminal entered into a binding agreement with a major railway transportation company, which we refer to as the “Railway,” effective
April 2019, whereby in consideration for the Railway being the rail freight transportation service provider at the Hardisty terminal for certain customers, the
Railway agreed to pay us an average of $50 per railcar loaded and moved for utilizing the services of the Railway through March 31, 2022. We recognize the
amounts  we  expect  to  receive  for  the  specific  customer  railcars  transported  on  the  Railway  pursuant  to  the  terms  of  this  agreement  in  “Other  expense
(income), net” in our consolidated statements.

96

Income Taxes

We are not a taxable entity for U.S. federal income tax purposes or for a majority of the states that impose an income tax. Taxes on our net income are
generally borne by our unitholders through the allocation of taxable income, except for USD Rail LP, which, has elected to be classified as an entity taxable as
a corporation. Our provision for income taxes is predominantly attributable to Canadian federal and provincial income taxes imposed on our operations based
in Canada. We are also subject to franchise tax in the State of Texas, that is, computed on our modified gross margin, which we have determined to be an
income tax under the applicable accounting guidance. Our current and historical provision for income taxes also reflects income taxes associated with USD
Rail LP.

We recognize deferred income tax assets and liabilities for temporary differences between the relevant basis of our assets and liabilities for financial
reporting and tax purposes. We record the impact of changes in tax legislation on deferred income tax assets and liabilities in the period the legislation is
enacted.

Pursuant to the authoritative accounting guidance regarding uncertain tax positions, we recognize the tax effects of any uncertain tax position as the
largest  amount  that  will  more  likely  than  not  be  realized  upon  ultimate  settlement  with  the  taxing  authority  having  full  knowledge  of  the  position  and  all
relevant facts. Under this criterion, we evaluate the most likely resolution of an uncertain tax position based on its technical merits and on the outcome that
we expect would likely be sustained under examination.

Our policy is to recognize any interest or penalties related to the underpayment of income taxes as a component of income tax expense or benefit. We

have not historically incurred any significant interest or penalties for the underpayment of income taxes.

Net income for financial statement purposes may differ significantly from the taxable income we allocate to our unitholders as a result of differences
between  the  tax  basis  and  financial  reporting  basis  of  assets  and  liabilities  and  the  taxable  income  allocation  requirements  set  forth  in  our  partnership
agreement. The aggregate difference in the basis of our net assets for financial and tax reporting purposes cannot be readily determined because information
regarding each partner’s tax attributes in us is not available.

Cash and Cash Equivalents

Cash and cash equivalents consist of all unrestricted demand deposits and funds invested in highly liquid instruments with original maturities of three
months  or  less.  We  periodically  assess  the  financial  condition  of  the  financial  institutions  where  these  funds  are  held  and  believe  that  our  credit  risk  is
minimal.

Accounts Receivable

Accounts  receivable  consist  of  billed  and  unbilled  amounts  due  from  our  customers,  which  include  crude  oil  producing  and  petroleum  refining
companies, as well as marketers of petroleum, petroleum products and biofuels, for services we have provided. We perform ongoing credit evaluations of our
customers.  When  appropriate,  we  use  the  specific  identification  method  to  estimate  allowances  for  doubtful  accounts  based  on  our  customers’  financial
condition and collection history, as well as other pertinent factors. Accounts are written-off against the allowance for doubtful accounts when significantly
past due and we have deemed the amounts uncollectible.

Capitalization Policies and Depreciation Methods

We record property and equipment at its original cost or fair value if acquired as part of a business acquisition, which we depreciate on a straight-line
basis  over  the  estimated  useful  lives  of  the  assets,  which  range  from  three  to  30 years.  Our  determination  of  the  useful  lives  of  property  and  equipment
requires us to make various assumptions when the assets are acquired or placed into service about the expected usage, normal wear and tear and the extent
and frequency of maintenance programs. Expenditures for repairs and maintenance are charged to expense as incurred, while improvements that extend the
service  life  or  capacity  of  existing  property  and  equipment  are  capitalized.  Upon  the  sale  or  retirement  of  an  asset,  the  related  costs  and  accumulated
depreciation are removed from the accounts and any gain or loss is recognized in our operating results.

97

During  construction  we  capitalize  direct  costs,  such  as  labor,  materials  and  overhead,  as  well  as  interest  cost  we  may  incur  on  indebtedness  at  our

incremental borrowing rate.

Asset Retirement Obligations

We record a liability for the fair value of asset retirement obligations and conditional asset retirement obligations that we can reasonably estimate. We
collectively refer to asset retirement obligations and conditional asset retirement obligations as ARO. Typically, we record an ARO at the time an asset is
constructed or acquired, if a reasonable estimate of fair value can be made. In connection with establishing an ARO, we capitalize the expected costs as part
of the carrying value of the related assets. We recognize any ongoing expense for the accretion component of the liability resulting from changes in value of
the  ARO  due  to  the  passage  of  time  as  part  of  accretion  expense.  We  depreciate  the  initial  capitalized  cost  over  the  useful  lives  of  the  related  assets.  We
extinguish the liabilities for an ARO when assets are taken out of service or otherwise abandoned.

Legal obligations exist for our San Antonio and West Colton terminal facilities due to terms within our lease agreements with the lessor that require us
to remove our facilities at final abandonment. We generally own the land on which our Casper, Stroud and Hardisty terminals and related facilities reside and
as a result, similar legal obligations generally do not exist that would require us to remove our Casper, Stroud and Hardisty facilities at final abandonment.
However, a portion of the Casper terminal and the Stroud pipeline are on land that is leased, where the lessor has the option to either purchase the facilities
from us at salvage value, or to require us to remove our facilities at the termination of the lease and restore the land to its original condition.

We  have  an  asset  retirement  obligation  for  our  San  Antonio  terminal  facility  with  a  remaining  balance  of  $0.2  million  at  December  31,  2019,
representing the costs we expect to incur at final abandonment resulting from the conclusion of our customer agreement that occurred May 1, 2017. The West
Colton terminal operates in a geographical and regulatory environment that is significantly different from that of our San Antonio terminal and has unique
operating characteristics that make determination of the economic life of the asset, coupled with the methods of settlement necessary for estimating the fair
value  of  the  ARO  related  to  this  facility,  impracticable.  With  respect  to  the  Casper  and  Stroud  terminals,  we  cannot  reasonably  estimate  the  timing  nor
determine the method that the lessor will elect with regard to the action we will be required to take at the termination of the lease. In each of these cases, the
asset  retirement  obligation  cost  is  considered  indeterminate  because  there  is  limited  data  or  information  that  can  be  derived  from  past  practice,  industry
practice, our intentions or the estimated economic life of the asset. Useful lives of our terminal facilities are primarily derived from available supply resources
and  ultimate  consumption  of  those  resources  by  end  users.  Many  variables  can  affect  the  remaining  lives  of  the  assets,  which  preclude  us  from  making  a
reasonable estimate of the ARO. We will recognize the fair value of an ARO for the Casper, Stroud and West Colton terminal facilities in the periods in which
sufficient information exists that will allow us to reasonably estimate potential settlement dates and methods.

Impairment of Long-lived Assets

We  evaluate  long-lived  assets  for  impairment  whenever  events  or  changes  in  circumstances  indicate  the  carrying  amount  of  an  asset  may  not  be

recoverable.

We consider a long-lived asset to be impaired when the sum of the estimated, undiscounted future cash flows from the use of the asset and its eventual
disposition is less than the carrying amount of the asset. Factors that indicate potential impairment include: a significant decrease in the market value of the
asset, operating income or cash flows associated with the use of the asset and a significant change in the asset’s physical condition or use.

When alternative courses of action to recover the carrying amount of a long-lived asset are under consideration, estimates of future undiscounted cash
flows take into account possible outcomes and probabilities of their occurrence. If the carrying amount of the long-lived asset is not recoverable based on the
estimated future undiscounted cash flows, an impairment loss is recognized to the extent the carrying value exceeds the estimated fair value of the long-lived
asset.

98

Intangible Assets

Our  intangible  assets  primarily  consist  of  customer  relationships  at  the  Casper  terminal.  We  amortize  these  assets  on  a  straight-line  basis  over  the
estimated useful lives of the underlying assets, representing the period over which the assets are expected to contribute directly or indirectly to our future cash
flows.

Goodwill

Goodwill  represents  the  future  economic  benefits  arising  from  assets  acquired  in  a  business  combination  that  are  not  individually  identified  and
separately  recognized.  Currently,  goodwill  is  only  included  in  our  Terminalling  services  segment  as  part  of  our  Casper  terminal  reporting  unit.  As  of
December 31, 2019, the carrying amount of goodwill was $33.6 million.

We do not amortize goodwill but test it for impairment annually based on the carrying values of our reporting unit on the first day of the third quarter
of  each  year  or  more  frequently  if  impairment  indicators  arise  that  suggest  the  carrying  value  of  goodwill  may  be  impaired.  In  testing  goodwill  for
impairment, we make critical assumptions that include but are not limited to:

(1) projections of future financial performance, which includes contract renewal expectations;

(2) market weighted average cost of capital;

(3) EBITDA multiples derived from stock prices of public companies with similar operating and investment characteristics; and

(4) EBITDA multiples for transactions based on actual sales and purchases of comparable businesses.

We recognize an impairment loss when the carrying amount of a reporting unit exceeds its implied fair value. We reduce the carrying value of goodwill

to its fair value when we determine that an impairment has occurred.

We had no impairment of goodwill for the year ended December 31, 2019.

Leases

We adopted the provisions of ASC 842 Leases on January 1, 2019. This standard requires us to recognize right-of-use assets and lease liabilities on our
consolidated balance sheet for identified property that is subject to operating lease agreements for which we are considered a lessee. We elected to adopt this
standard by applying the additional transition method set forth in ASU 2018-11, whereby we implement the provisions of the new standard to our existing
leases by recognizing and measuring lease assets and lease liabilities on our balance sheet as of January 1, 2019, as well as a cumulative-effect adjustment to
the opening balances of Partners’ Capital. Consequently, our reporting of leases for the prior year continues to be provided in accordance with ASC Topic
840, which was effective during that period. We elected the package of practical expedients permitted under the transition guidance within ASC 842, which,
among  other  things,  allowed  us  to  carry  forward  our  historical  lease  classification  without  the  need  to  re-evaluate  such  classification  pursuant  to  the
provisions of ASC 842.

We  classify  our  leases  as  operating,  financing  or  sales-type  leases  based  on  the  criteria  set  forth  in  ASC  842  that  considers  whether  a  lease  is
economically similar to the purchase of a nonfinancial asset. We have adopted as our accounting policy the definition of “substantially all” of the fair value of
the  underlying  asset  to  mean  90%  or  greater  and  a  “major  part”  of  the  remaining  economic  life  to  mean  75%  or  greater  in  performing  our  classification
assessment. We exclude variable lease payments that are based on performance or use from our lease classification determination. We include the exercise
price  of  a  purchase  option  when  reasonable  certainty  exists  that  we  will  exercise  the  option.  We  also  include  termination  penalties  unless  it  is  reasonably
certain  that  we  will  not  exercise  any  option  to  terminate  the  lease,  and  therefore  will  not  incur  the  penalty.  Lastly,  we  also  include  any  residual  value
guarantees that we provided to lessors in our classification determination.

Our  adoption  of  ASC  842  required  us  to  recognize  lease  assets  and  lease  liabilities  for  all  leases  where  we  are  the  lessee  and  present  them  on  our
balance sheet, which did not affect our consolidated statement of income, consolidated statement of cash flows or consolidated statement of partners’ capital.
Upon adoption we recognized a right-of-use

99

lease  asset  and  corresponding  liability  of  $17.3  million  on  our  consolidated  balance  sheet.  Additionally,  our  adoption  of  ASC  842  did  not  affect  our
accounting for leases where we are the lessor.

Lessee Accounting

We lease assets from third parties for use in our operations, which primarily include railcars, buildings, storage tanks, equipment, offices, railroad track
and  land.  The  general  terms  of  our  lease  agreements  require  monthly  payments  in  advance,  in  arrears  or  upon  receipt,  some  of  which  include  variable
payments attributable to index-based rate escalations and freight associated with railcar returns. A majority of our leases do not include renewal options, or
rights  to  early  termination  of  the  lease  agreements.  Additionally,  our  leases  do  not  include  residual  value  guarantees,  nor  do  they  impose  any  significant
covenants  or  restrictions  on  us.  As  discussed  below  under  Lessor  Accounting,  we  effectively  sublease  all  of  our  leased  railcars  to  customers  under  terms
similar to the terms of our lease agreements with the railcar manufacturing and finance companies from whom we lease the railcars. We also lease a storage
tank from a third party provider of crude oil storage that we sublease to a customer of our Stroud terminal.

We have elected as an accounting policy not to apply the recognition requirements of ASC 842 to short-term leases for all classes of assets underlying
our leases. As a result, we recognize the lease payments we make as expense in our consolidated statements of income over the lease term, regardless of the
underlying class of asset being leased. We define a short-term lease as a lease that at the commencement date has a term of 12 months or less and does not
include an option to purchase the underlying asset that we are reasonably certain to exercise.

We deem a contract to be a lease when the terms of the agreement indicate we have the right to control the use of an identified asset for a period of
time  in  exchange  for  consideration.  We  establish  our  right  to  control  the  use  of  an  identified  asset  when  the  contract  terms  set  forth  our  right  to  obtain
substantially all of the economic benefits from use of the identified asset, or to direct its use throughout the contract period. We consider substantially all of
the economic benefits to mean 90% or more of the utility of the identified asset.

We have elected to apply the portfolio approach to account for our railcar leases due to our expectation that this method would not significantly differ
from  an  individual  lease  approach.  Additionally,  we  have  elected  to  use  the  practical  expedient  that  allows  us  not  to  separate  amounts  of  contract
consideration between lease and non-lease components. Non-lease components of our agreements include maintenance of property, common area costs such
as cleaning and landscape services and reimbursement of the suppliers’ insurance, taxes or administrative costs.

We determine the discount rate for our leases by estimating a borrowing rate we would pay on a collateralized basis over the term of the underlying
lease, based on our creditworthiness and the interest rate environment at the time we enter into the lease. We establish our credit quality by performing a
synthetic credit analysis based on operational, liquidity and solvency metrics, which are weighted to produce an estimated rating. We then develop an interest
rate curve for various periods of time by applying an adjustment factor to the risk free rates as established from yields on U.S. Treasury securities. We utilize
this interest rate curve to establish an approximate discount rate based upon the term of the underlying lease.

We determine our right-of-use assets based on the initial measurement amount of the lease liability, as discussed below, increased by any prepayments
that we make to the lessor at or before the lease commencement date and any initial direct costs we may incur, reduced by any incentive amounts we may
receive.

We measure our lease liabilities based upon the discounted present value of the payment amounts we expect to make over the noncancelable terms of
the underlying leases. We exclude variable lease payments that are based on performance or use in our measurement of the right of use assets and liabilities.
We include in our measurement of the right of use assets and lease liabilities the exercise price of purchase options when reasonable certainty exists that we
will exercise the option and any termination penalties when reasonable certainty exists that we will exercise an option to terminate the lease. We also include
any residual value guarantees provided to lessors to the extent that we consider the likelihood we will have to pay the lessor at the end of the lease term for a
deficiency to be probable.

Over the lease term, we amortize the right-of-use asset and record interest expense on the lease liability recorded at commencement of the lease. Our
income statement recognition of the expense is dependent on whether the lease is classified as an operating, direct financing, or sales-type lease. We recognize
amortization expense and interest expense

100

associated  with  operating  leases  as  a  single  item  of  expense  in  our  consolidated  statements  of  income.  We  recognize  amortization  expense  and  interest
expense associated with any direct financing and sales-type leases as separate items of expense within our consolidated statements of income.

We present all leases, where we are the lessee, on our balance sheet subject to the practical expedients we have elected and capitalization limitations we

have established.

Lessor Accounting

We effectively lease railcars and storage tanks to customers of our terminalling facilities to meet their logistical needs for the movement of crude oil to
refineries and market centers. The general terms of our lease agreements require monthly payments, some of which include variable payments attributable to
index-based rate escalations and freight associated with railcar returns. Under the master service agreements for the railcars we lease, we also charge a fee for
the  various  freight  monitoring,  scheduling,  maintenance  and  related  services  we  provide  to  customers  that  lease  railcars  from  us,  representing  a  non-lease
component that we account for separately. Our storage tank leases contain standard renewal options for periods up to 12 months following the end of the
initial lease term. Additionally, our storage tank leases include charges for blending and mixing services as well as pump over charges, representing non lease
components  that  we  account  for  separately.  Our  railcar  master  fleet  services  agreements  and  storage  tank  leases  do  not  generally  include  rights  to  early
termination  of  the  agreements,  nor  do  they  include  residual  value  guarantees.  None  of  the  customers  on  our  railcar  master  fleet  services  agreements  and
storage tank leases have options to purchase the underlying assets. As discussed above under Lessee Accounting, we effectively sublease all of our leased
railcars to customers under terms similar to the terms of our lease agreements with the railcar manufacturing and finance companies from whom we lease the
railcars. We also lease a storage tank from a third party provider of crude oil storage that we sublease to a customer of our Stroud terminal.

We recognize revenue from our lessor operating lease contracts that contain escalation clauses for fixed amounts during the lease term, on a straight-line
basis over the term of the lease in our Consolidated Statements of Income. The difference between fleet lease revenue and the amounts received under the
lease contract are currently included in “Other current assets — related party” and “Other non-current assets — related party” in our Consolidated Balance
Sheets.   

We  deem  a  contract  to  be  a  lease  when  the  terms  of  the  agreement  indicate  we  have  transferred  to  another  party  the  right  to  control  the  use  of  an
identified asset for a period of time in exchange for consideration. We determine that we have transferred the right to control the use of an identified asset
when the contract terms set forth the rights of another party to obtain substantially all of the economic benefits from use of the identified asset, or to direct its
use throughout the contract period. We consider substantially all of the economic benefits to mean 90% or more of the utility of the identified asset during the
contract term.

We allocate consideration in a contract between lease and non-lease components based upon the rates and terms that are specified in our agreements.
We recognize revenue from fees we charge for freight services related to railcars and from fees we charge for blending, mixing and pump over charges related
to our storage services pursuant to the requirements of ASC 606 as set forth in our Revenue Policy.

We continue to depreciate property that we own and lease to third party customers in accordance with our standard depreciation policies. We record

lease income typically on a straight-line basis over the lease term.

Refer to Note 8. Leases for further discussion.

Fair Value Measurements

We apply the authoritative accounting provisions for measuring fair value to our financial instruments and related disclosures, which include cash and
cash  equivalents,  accounts  receivable,  accounts  payable,  debt,  and  derivative  instruments.  We  define  fair  value  as  an  exit  price  representing  the  expected
amount we would receive to sell an asset or pay to transfer a liability in an orderly transaction with market participants at the measurement date.

101

We employ a hierarchy which prioritizes the inputs we use for recurring fair value measurements into three distinct categories based upon whether such
inputs are observable in active markets or unobservable. We classify assets and liabilities in their entirety based on the lowest level of input that is significant
to  the  fair  value  measurement.  Our  methodology  for  categorizing  assets  and  liabilities  that  are  measured  at  fair  value  pursuant  to  this  hierarchy  gives  the
highest priority to unadjusted quoted prices in active markets and the lowest level to unobservable inputs, summarized as follows:

•

•

•

Level 1 — Quoted prices in active markets for identical assets or liabilities.

Level 2 — Other significant observable inputs (including quoted prices in active markets for similar assets or liabilities).

Level 3 — Significant unobservable inputs (including our own assumptions in determining fair value).

 We use the cost, income or market valuation approaches to estimate the fair value of our assets and liabilities when insufficient market-observable data

is available to support our valuation assumptions.

The carrying amounts of cash and cash equivalents, accounts receivable, accounts payable, and the long-term debt represented by our $385 million
senior secured credit facility as presented on our consolidated balance sheets approximate fair value due to the short-term nature of these items and, with
respect to the senior secured credit facility, the frequent re-pricing of the underlying obligations. The fair value of our accounts receivable and payables with
affiliates cannot be determined due to the related party nature of these items.

Derivative Financial Instruments

Our net income and cash flows are subject to volatility stemming from changes in interest rates on our variable rate debt obligations and fluctuations in
foreign currency exchange rates. In order to manage our exposure to fluctuations in interest rates and foreign currency exchange rates and the related risks to
our unitholders, we use derivative financial instruments to offset a portion of these risks. We have a program that utilizes swaps, options and other financial
instruments with similar characteristics to reduce the risks associated with volatility in our interest rates on our variable rate debt and the effects of foreign
currency exposures related to our Canadian subsidiaries, which have cash flows denominated in Canadian dollars. Under this program, our strategy is for the
changes in value of the derivative contracts to mitigate adverse changes in our cash flows associated with the changes in interest rates and foreign currency
exchange rates to the extent practical. Economically, the derivative contracts help us to limit our exposure such that the interest rates on our variable rate debt
and foreign currency exchange rates will effectively lie between the floor and the ceiling of the rates set forth in the derivative contacts or otherwise fix the
rates at a specified date and amount.

All of our derivative financial instruments are employed in connection with an underlying asset, liability and/or forecast transaction and are not entered

into for speculative purposes.

In  accordance  with  the  authoritative  accounting  guidance,  we  record  all  derivative  financial  instruments  in  our  consolidated  balance  sheets  at  fair
market value as current or non-current assets or liabilities on a net basis by counterparty. We do not designate, nor have we historically designated, any of our
derivative financial instruments as hedges of an underlying asset, liability and/or forecast transaction. To qualify for hedge accounting treatment as set forth in
the authoritative accounting guidance, very specific requirements must be met in terms of hedge structure, hedge objective and hedge documentation. As a
result, changes in the fair value of our derivative financial instruments and the related cash settlement of matured contracts are recognized in “Loss (gain)
associated with derivative instruments” on our consolidated statements of income. Refer to Note 18. Derivative Financial Instruments.

102

Recently Adopted Accounting Pronouncements

Accounting for Nonemployee Unit based Compensation (ASU 2018-07)

In June 2018, the FASB, issued Accounting Standards Update No. 2018-07, or ASU 2018-07, which amends Topic 718 to include share-based payment
transactions  for  acquiring  goods  and  services  from  nonemployees.  The  provisions  of  this  standard  specify  that  ASC  Topic  718  applies  to  all  share-based
payment transactions in which a grantor acquires goods or services to be used or consumed in a grantor’s own operations by issuing share-based payment
awards. We adopted the provisions of ASU 2018-07 prospectively on January 1, 2019, which affected the method we used to value the phantom units we
granted to our directors and consultants domiciled in the United States. In periods prior to our adoption of ASU 2018-07, we were required to revalue the
outstanding phantom units granted to these individuals each reporting period. Pursuant to the requirements of ASU 2018-07 and under the provisions of ASC
Topic 718, these phantom units are now valued at the grant date fair value, consistent with the method we use to value phantom units granted to employees
that are domiciled in the United States. The adoption of this standard did not have a material impact on our financial statements.

Leases

In February 2016, the FASB issued Accounting Standards Update No. 2016-02, or ASU 2016-02, which created ASC Topic 842 Leases, to require
balance  sheet  recognition  of  lease  assets  and  lease  liabilities  by  lessees  for  those  leases  classified  as  operating  leases.  The  standard  also  expanded  the
disclosure requirements for lessors with respect to their leasing activities. In July 2018, the FASB issued ASU 2018-11, to provide another transition method
in  addition  to  the  existing  transition  method,  allowing  entities  to  initially  apply  the  new  standard  at  the  adoption  date  and  recognize  a  cumulative-effect
adjustment to the opening balance of retained earnings in the period of adoption. Additionally, the FASB has issued other Accounting Standards Updates to
clarify application of the guidance in the original standard and to provide practical expedients for applying the standard, all of which were effective upon
adoption. The pronouncement was effective for years beginning after December 15, 2018, with early adoption permitted.

We adopted the provisions of ASC Topic 842 on January 1, 2019. This standard requires us to recognize right-of-use assets and lease liabilities on our
consolidated balance sheet for identified property that is subject to operating lease agreements for which we are considered a lessee. We elected to adopt this
standard by applying the additional transition method set forth in ASU 2018-11, whereby we applied the provisions of the new standard to our existing leases
by recognizing and measuring lease assets and liabilities on our balance sheet as of January 1, 2019, as well as a cumulative-effect adjustment to the opening
balances of Partners’ Capital. Consequently, our reporting of leases for the prior year continues to be provided in accordance with ASC Topic 840, which was
effective during that period. We elected the package of practical expedients permitted under the transition guidance within ASC 842, which, among other
things, allowed us to carry forward our historical lease classification without the need to re-evaluate such classification pursuant to the provisions of ASC
842. 

Recent Accounting Pronouncements Not Yet Adopted

Income Taxes (ASU 2019-12)

In December 2019, the FASB issued Accounting Standards Update No. 2019-12, or ASU 2019-12, which amends ASC Topic 740 by removing certain
exceptions related to the approach for intraperiod tax allocation, the methodology for calculating income taxes in an interim period and the recognition of
deferred tax liabilities for outside basis differences. It also simplifies aspects of the accounting for franchise taxes and enacted changes in tax laws or rates and
clarifies the accounting for transactions that result in a step-up in the tax basis of goodwill. In addition, under the provisions of ASU 2019-12, single-member
limited  liability  companies  and  similar  disregarded  entities  that  are  not  subject  to  income  tax  are  not  required  to  recognize  an  allocation  of  consolidated
income tax expense in their separate financial statements, but they could elect to do so.

The pronouncement is effective for fiscal years beginning after December 15, 2020, or for any interim periods within those fiscal years, with early
adoption permitted. We do not expect to early adopt the provisions of this standard, nor do we anticipate that our adoption of this standard will have a material
impact on our financial statements.

103

Intangibles — Goodwill and Other

In January 2017, the FASB issued Accounting Standards Update No. 2017-04, or ASU 2017-04, which amends ASC Topic 350 to modify the concept
of  impairment  from  the  condition  that  exists  when  the  carrying  amount  of  goodwill  exceeds  its  implied  fair  value  to  the  condition  that  exists  when  the
carrying amount of a reporting unit exceeds its fair value. Pursuant to the provisions of ASU 2017-04, an entity will no longer determine goodwill impairment
by calculating the implied fair value of goodwill by assigning the fair value of a reporting unit to all of its assets and liabilities as if that reporting unit had
been acquired in a business combination. Rather, an entity will recognize an impairment loss for the amount by which the carrying amount of a reporting unit
exceeds the reporting unit’s fair value. However, the loss recognized should not exceed the total amount of goodwill allocated to that reporting unit.

The pronouncement is effective for fiscal years beginning after December 15, 2019, or for any interim impairment testing within those fiscal years and
is  required  to  be  applied  prospectively,  with  early  adoption  permitted.  We  do  not  expect  to  early  adopt  the  provisions  of  this  standard.  Any  impairment
assessment we perform subsequent to our adoption of the standard could produce an impairment of goodwill in a different amount than would result under
current guidance to the extent the carrying amount of a reporting unit exceeds its fair value.

3. NET INCOME PER LIMITED PARTNER AND GENERAL PARTNER INTEREST

We allocate our net income among our general partner and limited partners using the two-class method in accordance with the applicable authoritative
accounting  guidance.  Under  the  two-class  method,  we  allocate  our  net  income  and  any  net  income  in  excess  of  distributions  to  our  limited  partners,  our
general  partner  and  the  holder  of  the  incentive  distribution  rights,  or  IDRs,  according  to  the  distribution  formula  for  available  cash  as  set  forth  in  our
partnership agreement. We allocate any distributions in excess of earnings for the period to our limited partners and general partner based on their respective
proportionate ownership interests in us, as set forth in our partnership agreement, after taking into account distributions to be paid with respect to the IDRs.
The formula for distributing available cash as set forth in our partnership agreement is as follows:

Distribution Targets
Minimum Quarterly Distribution

First Target Distribution

Second Target Distribution

Third Target Distribution

Thereafter

(1)  Assumes our general partner maintains a 2% general partner interest in us.

Portion of Quarterly
Distribution Per Unit
Up to $0.2875

> $0.2875 to $0.330625

> $0.330625 to $0.359375

> $0.359375 to $0.431250

Amounts above $0.431250

104

Percentage Distributed to
Limited Partners
98%

Percentage Distributed to
General Partner
(including IDRs) (1)
2%

98%

85%

75%

50%

2%

15%

25%

50%

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
    
We determined basic and diluted net income per limited partner unit as set forth in the following tables:

For the Year Ended December 31, 2019

Common
Units

Subordinated
Units

Class A
Units (7) 

General
Partner
Units

Total

(in thousands, except per unit amounts)

Net income attributable to general and limited
partner interests in USD Partners LP (1)

  $

5,258   $

462   $

—   $

796   $

6,516

Less: Distributable earnings (2)

37,473  

3,214  

—  

1,392  

42,079

Distributions in excess of earnings

  $ (32,215)   $

(2,752)   $

—   $

(596)   $ (35,563)

Weighted average units outstanding (3)

24,078  

2,379  

Distributable earnings per unit (4)
Overdistributed earnings per unit (5)
Net income per limited partner unit (basic and

  $

1.56   $

1.35   $

(1.34)  

(1.16)  

461    

—  

—    

—    

diluted) (6)

  $

0.22   $

0.19   $

—    

(1)  Represents net income allocated to each class of units based on the actual ownership of the Partnership during the period. The net income for each class of limited partner interest has been

reduced by its proportionate amount of the approximate $685 thousand attributed to the general partner for its incentive distribution rights.

(2)  Represents the per unit distributions paid of $0.3625 per unit for the three months ended March 31, 2019, the per unit distribution of $0.365 per unit for the three months ended June 30, 2019,
and the per unit distribution of $0.3675 per unit for the three months ended September 30, 2019, and the per unit distributable of $0.37 per unit for the three months ended December 31, 2019,
representing the full year-distribution amount of $1.465 per unit. Amounts presented for each class of units include a proportionate amount of the $1.4 million distributed and $477 thousand
distributable  to  holders  of  the  Equity-classified  Phantom  Units  pursuant  to  the  distribution  equivalent  rights  granted  under  the  USD  Partners  LP  2014  Amended  and  Restated  Long-Term
Incentive Plan.

(3)  Represents the weighted average units outstanding for the year.
(4)  Represents the total distributable earnings divided by the weighted average number of units outstanding for the year.
(5)  Represents the distributions in excess of earnings divided by the weighted average number of units outstanding for the year.
(6)  Our computation of net income per limited partner unit excludes the effects of 1,289,683 equity-classified phantom unit awards outstanding as they were anti-dilutive for the period presented.
(7) 

In February 2019, pursuant to the terms set forth in our partnership agreement, the fourth and final vesting tranche of 38,750 Class A units vested and were converted into Common units. Refer
to Note 19. Partners’ Capital for more information.

For the Year Ended December 31, 2018

Common
Units

Subordinated
Units

Class A
Units

General
Partner
Units

Total

(in thousands, except per unit amounts)

Net income attributable to general and limited
partner interests in USD Partners LP (1)

  $ 16,796   $

3,524   $

36   $

776   $ 21,132

Less: Distributable earnings (2)

32,685  

6,238  

57  

1,097  

40,077

Distributions in excess of earnings

  $ (15,889)   $

(2,714)   $

(21)   $

(321)   $ (18,945)

Weighted average units outstanding (3)

21,590  

4,472  

44  

461    

Distributable earnings per unit (4)
Overdistributed earnings per unit (5)
Net income per limited partner unit (basic and

  $

1.51   $

1.39   $

1.29    

(0.74)  

(0.61)  

(0.48)    

diluted) (6)

  $

0.77   $

0.78   $

0.81    

(1)  Represents net income allocated to each class of units based on the actual ownership of the Partnership during the period. The net income for each class of limited partner interest has been

reduced by its proportionate amount of the approximate $410 thousand attributed to the general partner for its incentive rights.

(2)  Represents the per unit distributions paid of $0.3525 per unit for the three months ended March 31, 2018, the per unit distribution of $0.355 per unit for the three months ended June 30, 2018,
the per unit distribution of $0.3575 per unit for the three months ended September 30, 2018 and the per unit distribution of $0.36 per unit for the three months ended December 31, 2018,
representing the full year distribution of $1.425 per unit. Amounts presented for each class of unit include a proportionate amount of the $1.7 million distributed for the year to holders of the
Equity-classified Phantom Units pursuant to the distribution equivalent rights granted under the USD Partners LP 2014 Amended and Restated Long-Term Incentive Plan.

(3)  Represents the weighted average units outstanding for the year.

105

 
 
 
 
 
 
 
 
 
 
   
 
 
   
 
   
   
    
 
 
 
 
 
 
 
 
 
 
 
 
   
 
   
   
    
(4)  Represents the total distributable earnings divided by the weighted average number of units outstanding for the year.
(5)  Represents the distributions in excess of earnings divided by the weighted average number of units outstanding for the year.
(6)  Our computation of net income per limited partner unit excludes the effects of 1,165,296 equity-classified phantom unit awards outstanding, as they were anti-dilutive for the period presented.

For the Year Ended December 31, 2017

Common
Units

Subordinated
Units

Class A
Units

General
Partner
Units

Total

(in thousands, except per unit amounts)

Net income attributable to general and limited
partner interests in USD Partners LP (1)

  $ 15,093   $

5,577   $

80   $

581   $ 21,331

Less: Distributable earnings (2)

26,909  

8,986  

120  

845  

36,860

Distributions in excess of earnings

  $ (11,816)   $

(3,409)   $

(40)   $

(264)   $ (15,529)

Weighted average units outstanding (3)

17,924  

6,565  

94  

461    

Distributable earnings per unit (4)
Overdistributed earnings per unit (5)
Net income per limited partner unit (basic and

  $

1.50   $

1.37   $

1.27    

(0.66)  

(0.52)  

(0.42)    

diluted) (6)

  $

0.84   $

0.85   $

0.85    

(1)  Represents net income allocated to each class of units based on the actual ownership of the Partnership during the year.
(2)  Represents  the  per  unit  distributions  paid  of  $0.335  per  unit  for  the  three  months  ended  March  31,  2017,  the  per  unit  distributions  paid  of  $0.34  per  unit  for  the  three  months  ended
June 30, 2017, the per unit distributions paid of $0.345 per unit for the three months ended September 30, 2017 and the per unit distributions paid of $0.35 per unit for the three months ended
December 31, 2017, representing the full year distribution of $1.37 per unit. Amounts presented for each class of units include a proportionate amount of the $1.6 million distributed for the
year to holders of the Equity-classified Phantom Units pursuant to the distribution equivalent rights granted under the USD Partners LP 2014 Amended and Restated Long-Term Incentive Plan.

(3)  Represents the weighted average units outstanding for the year.
(4)  Represents the total distributable earnings divided by the weighted average number of units outstanding for the year.
(5)  Represents the distributions in excess of earnings divided by the weighted average number of units outstanding for the year.
(6)  Our computation of net income per limited partner unit excludes the effects of 1,136,848 equity-classified phantom unit awards outstanding, as they were anti-dilutive for the period presented.

4. REVENUES

We have included in the discussion below, information regarding our revenues from contracts with customers. Refer to Note 2. Summary of Significant

Accounting Policies for further discussion of our revenue recognition accounting policy.

Disaggregated Revenues

We manage our business in two reportable segments: Terminalling services and Fleet services. Our segments offer different services and are managed
accordingly. Our chief operating decision maker, or CODM, regularly reviews financial information about both segments in order to allocate resources and
evaluate performance. As such, we have concluded that disaggregating revenue by reporting segments appropriately depicts how the nature, amount, timing,
and uncertainty of revenue and cash flows are affected by economic factors. Refer to Note 15. Segment Reporting for our disaggregated revenues by segment
and summarized geographic data.

106

 
 
 
 
 
 
 
 
 
 
 
 
   
 
   
   
    
Remaining Performance Obligations

The  transaction  price  allocated  to  the  remaining  performance  obligations  associated  with  our  terminalling  and  fleet  services  agreements  as  of

December 31, 2019 are as follows for the periods indicated:

2020

2021

2022

2023

  Thereafter  

Total

(in thousands)

Terminalling Services (1)(2)(3)
Fleet Services

$ 100,542   $ 96,612   $

72,949   $

36,949   $ 146,460   $ 453,512

1,030  

1,016  

1,269  

38  

8  

3,361

Total

$ 101,572   $ 97,628   $

74,218   $

36,987   $ 146,468   $ 456,873

(1)  A significant portion of our terminalling services agreements are denominated in Canadian dollars. We have converted the remaining performance obligations associated with these Canadian

dollar-denominated contracts using the year-to-date average exchange rate of 0.7538 U.S. dollars for each Canadian dollar at December 31, 2019.

(2) Includes fixed monthly minimum commitment fees per contract and excludes constrained estimates of variable consideration for rate-escalations associated with an index, such as the consumer

price index, as well as any incremental revenue associated with volume activity above the minimum volumes set forth within the contracts.

(3) Assumes  USD’s  Diluent  Recovery  Unit  project  goes  into  service  in  the  second  half  of  2021,  which  will  result  in  certain  terminalling  services  agreements  of  our  Hardisty  terminal  being

automatically extended through mid-2031 and certain agreements at our Stroud terminal having a termination right in June 2022.

We have applied the practical expedient that allows us to exclude disclosure of performance obligations that are part of a contract that has an expected

duration of one year or less.

Contract Assets

Our contract assets represent cumulative revenue that has been recognized in advance of billing the customer due to tiered billing provisions. In such
arrangements, revenue is recognized using a blended rate based on the billing tiers of the agreement, as the services are consistently provided throughout the
duration of the contractual arrangement.

We had the following amounts outstanding associated with our contract assets on our consolidated balance sheets in the financial statement line items

presented below in the following table for the indicated periods:

Other current assets

Other non-current assets

Other current assets — related party

Deferred Revenue

December 31,

2019

2018

$

$

$

(in thousands)
171   $

—   $

264   $

68

171

—

Our deferred revenue is a form of a contract liability and consists of amounts collected in advance from customers associated with their terminalling
and fleet services agreements and deferred revenues associated with make-up rights, which will be recognized as revenue when earned pursuant to the terms
of  our  contractual  arrangements.  We  currently  recognize  substantially  all  of  the  amounts  we  receive  for  minimum  volume  commitments  as  revenue  when
collected, since breakage associated with these make-up rights options has varied between 97% and 99% based on our experience and expectations around
usage of these options. We deferred $1.1 million in revenues at December 31, 2019, for estimated breakage associated with the make-up rights options we
granted to our customers, which we included in the table below in “Customer Prepayments” and in “Deferred revenue” on our consolidated balance sheets.

We also have deferred revenue that represents cumulative revenue that has been deferred due to tiered billing provisions. In such arrangements, revenue
is  recognized  using  a  blended  rate  based  on  the  billing  tiers  of  the  agreement,  as  the  services  are  consistently  provided  throughout  the  duration  of  the
contractual arrangement, which we included in “Other non-current liabilities” on our consolidated balance sheets.

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We  had  the  following  amounts  outstanding  associated  with  our  deferred  revenue  on  our  consolidated  balance  sheets  in  the  financial  statement  line

items presented below in the following table for the indicated periods:

Deferred revenue
Deferred revenue — related party (1)
Other non-current liabilities

December 31,

2019

2018

$

$

$

(in thousands)

6,104   $

1,072   $

3,391   $

2,921

1,475

—

(1) 

Includes  deferred  revenue  associated  with  customer  prepayments  from  related  parties.  Refer  to  Note  13.  Transactions  with  Related  Parties for  additional  discussion  of  deferred  revenues
associated with related parties. Excludes deferred revenue from related parties associated with our fleet leases discussed below.

The following table presents the changes associated with the balance of our deferred revenue for the year ended December 31, 2019:

December 31, 2018

Cash Additions for
Customer
Prepayments

  Revenue Recognized  

December 31, 2019

Customer prepayments
Customer prepayments — related party (1)
Other contract liabilities

  $

  $

  $

2,921   $

1,475   $

—   $

(in thousands)
6,104   $

1,072   $

3,391   $

(2,921)   $

(1,475)   $

—   $

6,104

1,072

3,391

(1) 

Includes  deferred  revenue  associated  with  customer  prepayments  from  related  parties.  Refer  to  Note  13.  Transactions  with  Related  Parties for  additional  discussion  of  deferred  revenues
associated with related parties. Excludes deferred revenue from related parties associated with our fleet leases discussed below.

Deferred Revenue — Fleet Leases

Our deferred revenue also includes advance payments from customers of our Fleet services business, which will be recognized as Fleet leases revenue
when earned pursuant to the terms of our contractual arrangements. We have likewise prepaid the rent on railcar leases that are associated with the deferred
revenues of our fleet services business, which we will recognize as expense concurrently with our recognition of the associated revenue. We have included
$0.4  million  at  December  31,  2019  and  2018,  in  “Deferred  revenue  —  related  party”  on  our  consolidated  balance  sheets  associated  with  customer
prepayments for our fleet lease agreements. Refer to Note 8. Leases for additional discussion of our lease revenues.

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5. RESTRICTED CASH

We include in restricted cash amounts representing a cash account for which the use of funds is restricted by a facilities connection agreement among
us  and  Gibson  Energy  Inc.,  or  Gibson,  that  we  entered  into  during  2014  in  connection  with  the  development  of  our  Hardisty  terminal.  The  collaborative
arrangement is further discussed in Note 11. Collaborative Arrangement.

The  following  table  provides  a  reconciliation  of  cash,  cash  equivalents  and  restricted  cash  reported  within  our  consolidated  balance  sheets  to  the

amount shown in our consolidated statements of cash flows for the specified periods:

Cash and cash equivalents

Restricted cash

Total cash, cash equivalents and restricted cash

6. ACCOUNTS RECEIVABLE

2019

December 31,

2018

2017

$

$

(in thousands)
3,083   $

7,601  

6,439   $

5,944  

10,684   $

12,383   $

7,874

5,914

13,788

We  had  no  allowances  for  doubtful  accounts  at  December  31,  2019  and  2018.  In  addition,  we  had  no  bad  debt  expense  for  the  years  ended

December 31, 2019, 2018 and 2017 in our consolidated statements of income.

7. PROPERTY AND EQUIPMENT

Our property and equipment is composed of the following asset classifications as of the dates indicated:

Land

Trackage and facilities
Pipeline (1)

Equipment

Furniture

Total property and equipment

Accumulated depreciation
Construction in progress (2)

Property and equipment, net

Estimated 
Useful Lives 
(Years)

N/A

10-30

20-30

3-20

5-10

December 31,

2019

2018

(in thousands)

$

$

10,224  
126,008  
32,916  
16,857  
66  

186,071  
(38,919)  
585  

$

147,737  

$

10,004  
123,080  
16,336  
16,455  
64  

165,939    
(29,479)    
8,848    

145,308    

(1) We had $0.6 million of capitalized interest costs included in our Pipeline assets for the year ended December 31, 2019, and no capitalized interest costs for the years ended December 31, 2018 and

2017.

(2) The amounts classified as “Construction in progress” are excluded from amounts being depreciated. These amounts represent property that has not been placed into productive service as of the

respective consolidated balance sheet date.

Depreciation

Depreciation  expense  associated  with  Property  and  equipment  totaled  $8.1  million,  $8.5  million,  and  $9.5  million  for  the  years  ended

December 31, 2019, 2018 and 2017, respectively.

In  December  2017,  we  recognized  non-cash  impairment  charges  totaling  $1.7  million  to  reduce  the  book  value  of  certain  assets  included  in  our
Terminalling  services  segment  to  their  fair  value.  We  included  this  charge  for  impairment  in  “Depreciation  and  amortization”  within  our  consolidated
statements of income.

109

 
 
 
 
 
   
 
 
 
 
 
 
   
    
In August 2016, we received notification from the sole customer of our San Antonio terminal stating their intent to terminate our terminalling services
agreement with them. The agreement subsequently ended in May 2017. In connection with conclusion of this agreement, the lessor of the real property upon
which  the  San  Antonio  terminal  resides  notified  us  of  their  intent  to  terminate  our  lease  with  them  concurrently  with  the  conclusion  of  our  terminalling
services agreement discussed above. As a result of these events, we recognized a non-cash impairment loss of $3.5 million for the year ended December 31,
2016, to write down the non-current assets of the terminal to fair market value, the charge for which we have included in “Depreciation and amortization”
within our consolidated statements of income. The impairment loss included an asset retirement obligation of $1.0 million for amounts we expected to spend
to restore the property to its original condition. We determined the fair market value of these assets to be $0.2 million, based upon market prices for similar
assets and discounted cash flows we expected to derive from their use through the contract end date. The asset retirement obligation associated with the San
Antonio terminal totaled $0.2 million and $0.8 million as of December 31, 2019 and 2018, respectively, and is recorded in “Other current liabilities” on our
consolidated balance sheet. The San Antonio terminal is included in our Terminalling services segment as reported in our segment results included in Note 15.
Segment Reporting.

8. LEASES

We have noncancelable operating leases for railcars, buildings, storage tanks, offices, railroad tracks, and land. Refer to Note 2. Summary of Significant

Accounting Policies for additional discussion of our lease policies.

Weighted-average discount rate

Weighted average remaining lease term

Our total lease cost consisted of the following items for the dates indicated:

Operating lease cost

Short term lease cost

Sublease income

Total

For the Year Ended
December 31, 2019

6.4%

2.77 years

For the Year Ended
December 31, 2019

(in thousands)

5,935

196

(5,344)

787

  $

  $

The maturity analysis below presents the undiscounted cash payments we expect to make each period for property that we lease from others under

noncancelable operating leases as of December 31, 2019 (in thousands): 

2020

2021

2022

2023

Total lease payments

Less: imputed interest

Present value of lease liabilities

$

$

$

5,286

4,074

3,787

20

13,167

(1,132)

12,035

We  serve  as  an  intermediary  to  assist  our  customers  with  obtaining  railcars.  In  connection  with  our  leasing  of  railcars  from  third  parties,  we
simultaneously  enter  into  lease  agreements  with  our  customers  for  noncancelable  terms  that  are  designed  to  recover  our  costs  associated  with  leasing  the
railcars plus a fee for providing this service. In addition to these leases we also have lease income from storage tanks.

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Lease income (1)

Weighted average remaining lease term

For the Year Ended
December 31, 2019

  $

9,509

2.76 years

(1)  Lease income associated with crude oil storage tanks we lease to customers of our terminals totaling $5.5 million is included in “Terminalling services” revenues on our consolidated statement

of income for the year ended December 31, 2019.

The maturity analysis below presents the undiscounted future minimum lease payments we expect to receive from customers each period for property

they lease from us under noncancelable operating leases as of December 31, 2019 (in thousands): 

2020

2021

2022

Total

9. GOODWILL AND INTANGIBLE ASSETS

Goodwill

  $

  $

8,028

6,868

4,639

19,535

Goodwill  represents  the  excess  of  the  purchase  price  of  an  entity  over  the  estimated  fair  value  of  the  assets  acquired  and  liabilities  assumed.  Our
goodwill  originated  from  our  acquisition  of  the  Casper  terminal,  which  is  included  in  our  Terminalling  services  segment.  As  of  December  31,  2019,  the
carrying amount of our goodwill was $33.6 million.

There were no changes in the balance of Goodwill for the years ended December 31, 2019 and 2018.

We test goodwill for impairment annually based on the carrying values of our reporting units on the first day of the third quarter of each year, or more
frequently if events or changes in circumstances suggest that the fair value of a reporting unit is less than its carrying value. During the third quarter of 2019,
we completed our annual goodwill impairment analysis and determined that the fair value of the Casper terminal reporting unit exceeded its carrying value at
July 1, 2019. An impairment charge would have resulted if our estimate of the fair value of the Casper terminal reporting unit was approximately 5% less than
the amount determined. The critical assumptions used in our analysis include the following:

1)

2)

3)

a weighted average cost of capital of 11%;

a capital structure consisting of approximately 40% debt and 60% equity based on the capital structure of market participants;

a range of EBITDA multiples derived from equity prices of public companies with similar operating and investment characteristics, from 8.25x to
9.25x;

4)

a range of EBITDA multiples for transactions based on actual sales and purchases of comparable businesses, from 9.0x to 10.0x;

(5) a  range  of  incremental  volumes  expected  at  our  Casper  terminal  of  approximately  20,000  to  40,000  bpd  for  terminalling  and  storage  services

resulting from the anticipated successful completion of the Enbridge DRA project in the first half of 2020; and

(6) capital expenditures for additional terminalling connectivity.

We measured the fair value of our Casper terminal reporting unit by using an income analysis, market analysis and transaction analysis with weightings
of 50%, 25%  and  25%,  respectively.  Our  estimate  of  fair  value  required  us  to  use  significant  unobservable  inputs  representative  of  a  Level  3  fair  value
measurement, including assumptions related to the future performance of our Casper terminal. We have not observed any events or circumstances subsequent
to our analysis that would suggest the fair value of our Casper terminal is below its carrying amount as of December 31, 2019.

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Intangible Assets

The composition, gross carrying amount and accumulated amortization of our identifiable intangible assets are as follows as of the dates indicated:

Carrying amount:

Customer service agreements

Other

Total carrying amount

Accumulated amortization:

Customer service agreements

Other

Total accumulated amortization

Total intangible assets, net

December 31, 2019

December 31, 2018

(in thousands)

$

$

125,960   $

106  

126,066  

(51,923)  

(44)  

(51,967)  

74,099   $

125,960

106

126,066

(39,328)

(33)

(39,361)

86,705

Our identifiable intangible assets at December 31, 2019 and 2018, originated from our acquisition of the Casper terminal and are directly associated
with our Terminalling services segment. The acquisition date fair value attributed to the intangible assets was based on the present value of the future revenue
stream expected to be derived from our relationships with existing customers of the Casper terminal and the additional service potential associated with these
assets, which we expect to continue over a period of approximately 10 years. We amortize our intangibles on a straight-line basis over the 10 year estimated
useful lives of these assets.

We  determined  the  expiration  of  a  customer  contract  for  terminalling  services  at  our  Casper  terminal  was  an  event  that  required  us  to  evaluate  our
Casper terminal asset group for impairment. Our projections of the undiscounted cash flows expected to be derived from the operation and disposition of the
Casper terminal asset group exceeded the carrying value of the asset group as of August 31, 2019, the date of our evaluation, indicating cash flows were
expected  to  be  sufficient  to  recover  the  carrying  value  of  the  Casper  terminal  asset  group.  No  further  triggering  events  were  identified  through
December 31, 2019.

The pre-tax amortization expense associated with intangible assets totaled $12.6 million for the years ended December 31, 2019, 2018 and 2017. We
expect the annual pre-tax amortization expense associated with our intangible assets at December 31, 2019, to approximate $12.6 million for each of the next
five years.

10. DEBT

Credit Agreement

In  November  2018,  we  amended  and  restated  our  senior  secured  credit  agreement,  which  we  originally  established  at  the  time  of  our  initial  public
offering in October 2014. We refer to the amended and restated senior secured credit agreement executed in November 2018 as the Credit Agreement and the
original senior secured credit agreement as the Previous Credit Agreement. Our Credit Agreement is a $385 million revolving credit facility (subject to limits
set  forth  therein)  with  Citibank,  N.A.,  as  administrative  agent,  and  a  syndicate  of  lenders.  Our  Credit  Agreement  amends  and  restates  in  its  entirety  our
Previous Credit Agreement.

Our Credit Agreement is a four year committed facility that initially matures on November 2, 2022. Our Credit Agreement provides us with the ability
to request two one-year maturity date extensions, subject to the satisfaction of certain conditions, and allows us the option to increase the maximum amount
of credit available up to a total facility size of $500 million, subject to receiving increased commitments from lenders and satisfaction of certain conditions.
The Credit Agreement keeps the financial covenants substantially consistent with our Previous Credit Agreement. Our Credit Agreement contains customary
representations,  warranties,  covenants  and  events  of  default  for  facilities  of  this  type.  In  connection  with  establishing  the  Credit  Agreement,  we  incurred
additional deferred financing costs of $2.9 million, which, in addition to any remaining deferred financing costs from our Previous Credit Agreement, will

112

 
 
 
 
   
 
   
be amortized over the four-year term of the Credit Agreement using the straight line method, which approximates the effective interest method.

Our Credit Agreement and any issuances of letters of credit are available for working capital, capital expenditures, general partnership purposes and
continue the indebtedness outstanding under the Previous Credit Agreement. The Credit Agreement includes an aggregate $20 million sublimit for standby
letters of credit and a $20 million sublimit for swingline loans. Obligations under the Credit Agreement are guaranteed by our restricted subsidiaries (as such
term is defined therein) and are secured by a first priority lien on our assets and those of our restricted subsidiaries, other than certain excluded assets.

Our borrowings under the Credit Agreement bear interest at either a base rate plus an applicable margin ranging from 1.00% to 2.00%, or at a rate based
on the London Interbank Offered Rate, or LIBOR, or a comparable or successor rate plus an applicable margin ranging from 2.00% to 3.00%. The applicable
margin,  as  well  as  a  commitment  fee  of  0.375%  to  0.50%  per  annum  on  unused  commitments  under  the  Credit  Agreement,  will  vary  based  upon  our
consolidated net leverage ratio, as defined in our Credit Agreement.

Our Credit Agreement contains affirmative and negative covenants that, among other things, limit or restrict our ability and the ability of our restricted
subsidiaries  to  incur  or  guarantee  debt,  incur  liens,  make  investments,  make  restricted  payments,  engage  in  certain  business  activities,  engage  in  mergers,
consolidations and other organizational changes, sell, transfer or otherwise dispose of assets, enter into burdensome agreements or enter into transactions with
affiliates on terms that are not at arm’s length, in each case, subject to exceptions.

Additionally, we are required to maintain the following financial ratios, each determined on a quarterly basis for the immediately preceding four quarter

period then ended (or such shorter period as shall apply, on an annualized basis): 

•

•

•

Consolidated Interest Coverage Ratio (as defined in the Credit Agreement) of at least 2.50 to 1.00;

Consolidated Net Leverage Ratio of not greater than 4.50 to 1.00 (or 5.00 to 1.00 at any time after we have issued at least $150 million of certain
qualified unsecured notes and for so long as the notes remain outstanding (the “Qualified Notes Requirement”)). In addition, upon the consummation
of a Specified Acquisition (as defined in our Credit Agreement), for the fiscal quarter in which the Specified Acquisition is consummated and for
two fiscal quarters immediately following such fiscal quarter (the “Specified Acquisition Period”), if timely elected by us by written notice to the
Administrative Agent, the maximum permitted ratio shall be increased to 5.00 to 1.00 (or 5.50 to 1.00 if the Qualified Notes Requirement has been
met); and  

after we have met the Qualified Notes Requirement, a Consolidated Senior Secured Net Leverage Ratio (as defined in the Credit Agreement) of not
greater than 3.50 to 1.00 (or 4.00 to 1.00 during a Specified Acquisition Period).

Our Credit Agreement generally prohibits us from making cash distributions (subject to exceptions as set forth in the Credit Agreement). However, so
long  as  no  default  exists  or  would  be  caused  by  making  a  cash  distribution,  we  may  make  cash  distributions  to  our  unitholders  up  to  the  amount  of  our
available cash (as defined in our partnership agreement).

The Credit Agreement contains events of default, including, but not limited to (and subject to grace periods in circumstances set forth in the Credit
Agreement), the failure to pay any principal, interest or fees when due, failure to perform or observe any covenant (subject in some cases to certain grace
periods or other qualifications), any representation, warranty or certification made or deemed made in the agreements or related loan documentation being
untrue in any material respect when made, default under certain material debt agreements, commencement of bankruptcy or other insolvency proceedings,
certain changes in our ownership or the ownership of our general partner, certain material judgments or orders, ERISA events or the invalidity of the loan
documents. Upon the occurrence and during the continuation of an event of default under the agreements, the lenders may, among other things, terminate their
commitments, declare any outstanding loans to be immediately due and payable and/or exercise remedies against us and the collateral as may be available to
the lenders under the agreements and related documentation or applicable law.

As of December 31, 2019, we were in compliance with the covenants set forth in our Credit Agreement.

113

The  weighted  average  interest  rate  on  our  outstanding  indebtedness  was  4.24%  and  4.86%  at  December  31,  2019  and  2018,  respectively,  without
consideration  to  the  effect  of  our  derivative  contracts.  We  had  interest  payable  of  $0.6  million  and  $0.9  million  in  “Other  current  liabilities”  on  our
consolidated balance sheets at December 31, 2019 and 2018, respectively.

Effective November 2017, we entered into an interest rate derivative with a notional amount of $100 million to manage our exposure to fluctuations in
the rates of interest we are charged on our Credit Agreement. Refer to Note 18. Derivative Financial Instruments for additional discussion of these derivative
contracts.

Our long-term debt balances included the following components as of the specified dates:

Revolving Credit Facility

Less: Deferred financing costs, net

Total long-term debt, net

December 31,

2019

2018

(in thousands)

220,000   $

209,000

(2,349)  

217,651   $

(3,419)

205,581

$

$

We determined the capacity available to us under the terms of our Credit Agreement was as follows as of the specified dates:

Aggregate borrowing capacity under the Credit Agreement

Less: Revolving Credit Facility amounts outstanding

     Letters of credit outstanding

Available under the Credit Agreement based on capacity

Available under the Credit Agreement based on covenants (1)

December 31,

2019

2018

(in millions)

385.0   $

220.0  

—  

165.0   $

28.8   $

385.0

209.0

0.6

175.4

59.3

$

$

$

(1)  Pursuant  to  the  terms  of  our  Credit  Agreement,  our  borrowing  capacity,  currently,  is  limited  to  4.5  times  our  trailing  12-month  consolidated  EBITDA,  which  equates  to  $28.8 million  of

borrowing capacity available at December 31, 2019 and $59.3 million of borrowing capacity available at December 31, 2018.

Interest expense associated with our outstanding indebtedness was as follows for the specified periods:

Interest expense on Credit Agreement

Capitalized interest on construction in progress

Amortization of deferred financing costs

Total interest expense

11. COLLABORATIVE ARRANGEMENT

For the Years Ended December 31,

2019

2018

(in thousands)

2017

$

$

11,492   $

10,492   $

(558)  

1,072  

—  

866  

12,006   $

11,358   $

9,064

—

861

9,925

We entered into a facilities connection agreement in 2014 with Gibson under which Gibson developed, constructed and operates a pipeline and related
facilities connected to our Hardisty terminal. Gibson’s storage terminal is the exclusive means by which our Hardisty terminal receives crude oil. Subject to
certain limited exceptions regarding manifest train facilities, our Hardisty terminal is the exclusive means by which crude oil from Gibson’s Hardisty storage
terminal may be transported by rail. We remit pipeline fees to Gibson for the transportation of crude oil to our Hardisty terminal based on a predetermined
formula.  Pursuant  to  our  arrangement  with  Gibson,  we  incurred  pipeline  fees  of  $21.0  million,  $21.7  million  and  $22.5  million  for  the  years  ended
December  31,  2019, 2018  and  2017,  respectively,  which  are  presented  as  “Pipeline  fees”  in  our  consolidated  statements  of  income.  We  have  included  a
liability related

114

 
 
 
 
 
 
 
 
    
 
 
 
 
 
to this agreement in “Other Current Liabilities” on our consolidated balance sheets of $1.2 million at December 31, 2019. There were no significant amounts
at December 31, 2018.

12. NONCONSOLIDATED VARIABLE INTEREST ENTITIES

We  have  entered  into  purchase,  assignment  and  assumption  agreements  to  assign  payment  and  performance  obligations  for  certain  operating  lease
agreements with lessors, as well as customer fleet service payments related to these operating leases, with unconsolidated entities in which we have variable
interests. These variable interest entities, or VIEs, include LRT Logistics Funding LLC, USD Fleet Funding LLC, USD Fleet Funding Canada Inc., and USD
Logistics Funding Canada Inc. We treat these entities as variable interests under the applicable accounting guidance due to their having an insufficient amount
of equity invested at risk to finance their activities without additional subordinated financial support. We are not the primary beneficiary of the VIEs, as we do
not  have  the  power  to  direct  the  activities  that  most  significantly  affect  the  economic  performance  of  the  VIEs,  nor  do  we  have  the  power  to  remove  the
managing  member  under  the  terms  of  the  VIEs’  limited  liability  company  agreements.  Accordingly,  we  do  not  consolidate  the  results  of  the  VIEs  in  our
consolidated financial statements.

The  following  tables  summarize  the  total  assets  and  liabilities  between  us  and  the  VIEs  as  reflected  in  our  consolidated  balance  sheets  at
December  31,  2019  and  2018,  as  well  as  our  maximum  exposure  to  losses  from  entities  in  which  we  have  a  variable  interest,  but  are  not  the  primary
beneficiary. Generally, our maximum exposure to losses is limited to amounts receivable for services we provided, reduced by any deferred revenues.

Accounts receivable

Deferred revenue

Accounts receivable

Deferred revenue

Total assets

December 31, 2019

Total liabilities

(in thousands)

Maximum exposure to
loss

$

$

11   $

—  

11   $

—   $

10  

10   $

1

—

1

Total assets

December 31, 2018

Total liabilities

(in thousands)

Maximum exposure to
loss

$

$

17   $

—  

17   $

—   $

10  

10   $

7

—

7

We have assigned certain payment and performance obligations under the leases and master fleet service agreements for 1,483 of the railcars to the

VIEs, but we have retained certain rights and obligations with respect to the servicing of these railcars.

During  the  years  2019,  2018  and  2017,  we  provided  no  explicit  or  implicit  financial  or  other  support  to  these  VIEs  that  were  not  previously

contractually required.

13. TRANSACTIONS WITH RELATED PARTIES

Nature of Relationship with Related Parties

USD is engaged in designing, developing, owning and managing large-scale multi-modal logistics centers and other energy-related infrastructure across
North America. USD is also the sole owner of USDG and the ultimate parent of our general partner. USD is owned by Energy Capital Partners, Goldman
Sachs and certain members of its management.

USDG is the sole owner of our general partner and at December 31, 2019, owns 9,464,381 of our common units and all 2,092,709 of our subordinated

units representing a combined 42.9% limited partner interest in us. As of

115

 
 
 
 
 
 
 
 
 
 
 
 
December  31,  2019,  a  value  of  up  to  $10.0 million  of  these  common  units  were  pledged  as  collateral  under  USDG’s  letter  of  credit  facility.  USDG  also
provides us with general and administrative support services necessary for the operation and management of our business.

USD Partners GP LLC, our general partner, currently owns all 461,136 of our general partner units representing a 1.7% general partner interest in us, as
well  as  all  of  our  incentive  distribution  rights.  Pursuant  to  our  partnership  agreement,  our  general  partner  is  responsible  for  our  overall  governance  and
operations.

USD Marketing LLC, or USDM, is a wholly-owned subsidiary of USDG organized to promote contracting for services provided by our terminals and

to facilitate the marketing of customer products.

USD Terminals Canada II ULC, or USDTC II, is an indirect, wholly-owned Canadian subsidiary of USDG, organized for the purposes of pursuing
expansion  and  other  development  opportunities  associated  with  our  Hardisty  Terminal,  pursuant  to  the  Development  Rights  and  Cooperation  agreement
between our wholly-owned subsidiary USD Terminals Canada ULC, or USDTC, and USDG. USDTC owns the legacy crude oil loading facility we refer to as
the Hardisty terminal. USDTC II completed construction of the Hardisty South expansion (“Hardisty South”) which commenced operations in January 2019.
Hardisty South, which is owned and operated by USDTC II, added one and one-half 120-railcar unit trains of transloading capacity per day, or approximately
112,500 barrels per day, of takeaway capacity to the terminal by modifying the existing loading rack and building additional infrastructure and trackage.

Omnibus Agreement

We are a party to an omnibus agreement with USD, USDG and certain of their subsidiaries, or Omnibus Agreement, including our general partner that

provide for the following:

•

•

•

•

our  payment  of  an  annual  amount  to  USDG  for  providing  certain  general  and  administrative  services  by  USDG  and  its  affiliates  and  executive
management services by officers of our general partner. We also incur and pay additional amounts that are based on the costs actually incurred by
USDG and its affiliates in providing the services;

our right of first offer to acquire any Hardisty expansion projects, as well as other additional midstream infrastructure that USD and USDG may

construct or acquire in the future;

our  obligation  to  reimburse  USDG  for  any  out-of-pocket  costs  and  expenses  incurred  by  USDG  in  providing  general  and  administrative  services
(which reimbursement is in addition to certain expenses of our general partner and its affiliates that are reimbursed under our partnership agreement),
as well as any other out-of-pocket expenses incurred by USDG on our behalf; and

an indemnity by USDG for certain environmental and other liabilities, and our obligation to indemnify USDG and its subsidiaries for events and
conditions  associated  with  the  operation  of  our  assets  that  occur  after  the  closing  of  the  initial  public  offering,  or  IPO,  and  for  environmental
liabilities related to our assets to the extent USDG is not required to indemnify us. 

So long as USDG controls our general partner, the Omnibus Agreement will remain in full force and effect. If USDG ceases to control our general partner,
either party may terminate the Omnibus Agreement, provided that the indemnification obligations will remain in full force and effect in accordance with their
terms.

Payment of Annual Fee and Reimbursement of Expenses  

We  pay  USDG,  in  equal  monthly  installments,  the  annual  amount  USDG  estimates  will  be  payable  by  us  during  the  calendar  year  for  providing
services for our benefit. The Omnibus Agreement provides that this amount, which included a fixed annual fee of $3.6 million, $3.4 million and $3.3 million
for the years ended December 31, 2019, 2018 and 2017 respectively, may be adjusted annually to reflect, among other things, changes in the scope of the
general and administrative services provided to us due to a contribution, acquisition or disposition of assets by us, or our subsidiaries, or for changes in any
law, rule or regulation applicable to us, which affects the cost of providing the general and administrative services. We also reimburse USDG for any out-of-
pocket costs and expenses incurred on our behalf in providing general and administrative services to us. This reimbursement is in addition to the amounts we
pay  to  reimburse  our  general  partner  and  its  affiliates  for  certain  costs  and  expenses  incurred  on  our  behalf  for  managing  our  business  and  operations,  as
required by our partnership agreement.

116

The total amounts charged to us under the Omnibus Agreement for the years ended December 31, 2019, 2018 and 2017 was $8.1 million, $7.6 million
and  $5.9  million,  respectively,  which  amounts  are  included  in  “Selling,  general  and  administrative  —  related  party”  in  our  consolidated  statements  of
income. We had a payable balance of $0.4 million with respect to these costs at December 31, 2019 and 2018, included in “Accounts payable and accrued
expenses — related party” in our consolidated balance sheets.

Right of First Offer

Under  the  Omnibus  Agreement,  until  October  15,  2021,  prior  to  engaging  in  any  negotiation  regarding  the  sale,  transfer  or  disposition  of  certain
specified  expansion  projects  at  our  Hardisty  terminal  retained  by  USDG  or  any  other  midstream  infrastructure  assets  that  USD  or  USDG  may  develop,
construct or acquire, USD or USDG is required to provide written notice to us setting forth the material terms and conditions upon which USD or USDG
would sell or transfer such assets or businesses to us. Following the receipt of such notice, we will have 60 days to determine whether the asset is suitable for
our business at that particular time and to propose a transaction with USD or USDG. We and USD or USDG will then have 60 days to negotiate in good faith
to reach an agreement on such transaction. If we and USD or USDG, as applicable, are unable to agree on terms during such 60-day period, then USD or
USDG, as applicable, may transfer such asset to any third party during a 180-day period following the expiration of such 60-day period on terms generally no
less favorable to the third party than those included in the written notice.

Our decision to make any offer will require the approval of the conflicts committee of the board of directors of our general partner. The consummation
and timing of any acquisition by us of the assets covered by our right of first offer will depend on, among other factors, USD or USDG’s decision to sell an
asset covered by our right of first offer, our ability to reach an agreement with USD or USDG on the price and other terms and our ability to obtain financing
on acceptable terms. USD or USDG are under no obligation to accept any offer that we may choose to make.

Additionally, the approval of Energy Capital Partners is required for the sale of any assets by USD or its subsidiaries, including sales to or by USDG
and us (other than sales in the ordinary course of business), acquisitions of securities of other entities that exceed specified materiality thresholds and any
material unbudgeted expenditures or deviations from our approved budgets. Energy Capital Partners may make these decisions free of any duty to us and our
unitholders. This approval would be required for the potential acquisition by us of any Hardisty expansion projects, as well as any other projects or assets that
USD or USDG may develop or acquire in the future or any third-party acquisition we may intend to pursue jointly or independently from USD or USDG.
Energy Capital Partners is under no obligation to approve any such transaction.

Indemnification

USDG indemnifies us for liabilities, subject to an aggregate deductible of $500,000 relating to:

the consummation of the IPO contribution transactions;

events and conditions associated with any assets retained by USDG; and

all tax liabilities attributable to the assets contributed to us that arose prior to the closing of the IPO or otherwise related to USDG’s contribution of
those assets to us in connection with the IPO.

•

•

•

Marketing Services Agreement

In  connection  with  our  purchase  of  the  Stroud  terminal,  we  entered  into  a  Marketing  Services  Agreement,  with  USDM,  in  May  2017,  whereby  we
granted USDM the right to market the capacity at the Stroud terminal in excess of the original capacity of our initial customer in exchange for a nominal per
barrel fee. USDM is obligated to fund any related capital costs associated with increasing the throughput or efficiency of the terminal to handle additional
throughput. Upon expiration of our contract with the initial Stroud customer in June 2020, the same marketing rights will apply to all throughput at the Stroud
terminal in excess of the throughput necessary for the Stroud terminal to generate Adjusted EBITDA that is at least equal to the average monthly Adjusted
EBITDA derived from the initial Stroud customer during the 12 months prior to expiration. We also granted USDG the right to develop other projects at the
Stroud  terminal  in  exchange  for  the  payment  to  us  of  market-based  compensation  for  the  use  of  our  property  for  such  development  projects.  Any  such
development projects would be wholly-owned by USDG and would be subject to our existing right of first offer with respect to midstream projects developed
by USDG. Payments made under the

117

Marketing  Services  Agreement  during  the  periods  presented  in  this  report  are  discussed  below  under  the  heading  “Related  Party  Revenue  and  Deferred
Revenue.”  

Hardisty Terminal Services Agreement

We  entered  into  a  terminal  services  agreement  with  USDTC  II  during  the  third  quarter  of  2019,  whereby  Hardisty  South  will  provide  terminalling
services for a third-party customer of our Hardisty terminal for contracted capacity that exceeds the transloading capacity currently available, if needed. We
incurred $5.0 million of expenses pursuant to the terms of this arrangement for the year ended December 31, 2019, which amounts are included in “Operating
and  maintenance  expense  —  related  party”  in  our  consolidated  statements  of  income.  These  costs  represent  the  same  rate,  on  a  per  barrel  basis,  that  we
received as revenue from our third-party customer, which is included in “Terminalling Services” revenue in our consolidated statements of income.

Hardisty Shared Facilities Agreement

USDTC  facilitates  the  provision  of  services  on  behalf  of  USDTC  II  pursuant  to  the  terms  of  a  shared  facilities  agreement,  which  includes  all
subcontracted railcar loading, operating, maintenance, pipeline and management services for the entire Hardisty terminal, including Hardisty South owned by
USDTC II, USDTC passes through a proportionate amount of the cost of such services to USDTC II. Our financial statements only reflect the cost incurred
by USDTC.

Contribution of Capital at the Stroud Terminal

Pursuant to the Marketing Services Agreement discussed above, USDM provided a temporary steaming solution and constructed a permanent steaming
solution  at  the  Stroud  terminal  to  alleviate  operational  railcar  unloading  issues  that  resulted  from  cold  weather  at  the  terminal.  The  construction  of  the
steaming equipment was completed in July 2018 and contributed to us. The non-cash capital contribution was valued at the $3.4 million of original cost to
construct the asset, which resulted in an increase in “Property and equipment” and the capital account of our general partner included in “General partner
units” on our December 31, 2018 consolidated balance sheet. We did not issue additional general partner units in connection with this contribution.

Related Party Revenue and Deferred Revenue

We have agreements to provide terminalling and fleet services for USDM with respect to our Hardisty terminal and terminalling services with respect

to our Stroud terminal, which also include reimbursement to us for certain out-of-pocket expenses we incur.

USDM  assumed  the  rights  and  obligations  for  terminalling  capacity  at  our  Hardisty  terminal  from  another  customer  in  June  2017  to  facilitate  the
origination of crude oil barrels by the Stroud customer from our Hardisty terminal for delivery to the Stroud terminal. As a result of USDM assuming these
rights and obligations and in order to accommodate the needs of the Stroud customer, the contracted term for the capacity held by USDM at our Hardisty
terminal was extended from June 30, 2019 to June 30, 2020. USDM controlled approximately 25% of the available monthly capacity of the Hardisty terminal
at December 31, 2019. The terms and conditions of these agreements are similar to the terms and conditions of agreements we have with other parties at the
Hardisty terminal that are not related to us.

In  connection  with  our  purchase  of  the  Stroud  terminal,  we  also  entered  into  a  Marketing  Services  Agreement  with  USDM,  as  discussed  above.
Pursuant to the terms of the agreement, we receive a fixed amount per barrel from USDM in exchange for marketing the additional capacity available at the
Stroud  terminal.  We  also  received  revenue  for  providing  additional  terminalling  services  at  our  Hardisty  terminal  to  USDM  pursuant  to  the  terms  of  its
existing agreements with us. Additionally, effective January 2019, we entered into a six month terminalling services agreement with USDM at our Casper
terminal to maximize utilization of available terminalling and storage capacity by offering these services to customers on an uncommitted basis at current
market rates. This agreement automatically renews for successive periods of six months on an evergreen basis unless otherwise canceled by either party. We
include amounts received pursuant to these arrangements as revenue in “Terminalling services — related party” in our consolidated statements of income.
Additionally, we received revenue from USDM for the lease of 200 railcars pursuant to the terms

118

of an existing agreement with us, which is included in “Fleet leases — related party” on our consolidated statements of income.

Our related party revenue from USD and affiliates are presented below in the following table for the indicated periods:

Terminalling services — related party

Fleet leases — related party

Fleet services — related party

Freight and other reimbursables — related party

For the Years Ended December 31,

2019

2018

(in thousands)

2017

$

$

19,580   $

22,149   $

3,935  

3,935  

910  

238  

910  

4  

13,769

4,401

652

2

24,663   $

26,998   $

18,824

We had the following amounts outstanding with USD and affiliates on our consolidated balance sheets as presented below in the following table for the

indicated periods:

Accounts receivable — related party
Accounts payable and accrued expenses — related party (1)
Other current and non-current assets — related party (2)
Deferred revenue — related party (3)

December 31,

2019

2018

(in thousands)

1,778   $

87   $

358   $

1,482   $

624

67

174

1,885

$

$

$

$

(1) 

Includes amounts payable to a related party pursuant to the Hardisty Terminal Services Agreement, discussed above, as well as other accounts payable related party amounts associated with our
terminalling services business. Does not include amounts payable to related parties associated with the Omnibus Agreement, as discussed above.

(2)  Represents a contract asset associated with a lease agreement with USDM and cumulative revenue that has been recognized in advance of billing the customer due to tiered billing provisions.

Refer to Note 4. Revenue for further discussion.

(3)  Represents  deferred  revenues  associated  with  our  terminalling  and  fleet  services  agreements  with  USD  and  affiliates  for  amounts  we  have  collected  from  them  for  their  prepaid  leases  and

prepaid minimum volume commitment fees.

Cash Distributions

We paid the following aggregate cash distributions to USDG as a holder of our common units and as the sole owner of our subordinated units and to

USD Partners GP LLC for their general partner interest and as holder of our IDRs.

For the Year Ended December 31, 2019

Distribution
Declaration Date

Record Date

Distribution
Payment Date

Amount Paid to
 USDG

Amount Paid to
USD Partners GP
LLC

January 31, 2019

  February 11, 2019

  February 19, 2019

  $

April 26, 2019

  May 7, 2019

  May 15, 2019

July 24, 2019

  August 6, 2019

  August 14, 2019

October 24, 2019

  November 4, 2019

  November 14, 2019

(in thousands)

4,161   $

4,189  

4,218  

4,247  

  $

16,815   $

119

285

308

329

351

1,273

 
 
 
 
 
 
 
 
 
 
    
 
 
 
 
 
   
   
 
 
 
 
 
   
   
For the Year Ended December 31, 2018

Distribution
Declaration Date

Record Date

Distribution
Payment Date

Amount Paid to
 USDG

Amount Paid to
USD Partners GP
LLC

February 1, 2018

  February 12, 2018

  February 16, 2018

  $

April 26, 2018

  May 7, 2018

  May 11, 2018

July 27, 2018

  August 7, 2018

  August 14, 2018

October 25, 2018

  November 6, 2018

  November 14, 2018

(in thousands)

4,045   $

4,074  

4,103  

4,132  

  $

16,354   $

238

249

261

272

1,020

Distribution
Declaration Date

Record Date

Distribution
Payment Date

Amount Paid to
 USDG

Amount Paid to
USD Partners GP
LLC

Year Ended December 31, 2017

February 1, 2017

  February 13, 2017

  February 17, 2017

  $

April 27, 2017

  May 8, 2017

  May 12, 2017

July 27, 2017

  August 7, 2017

  August 11, 2017

October 26, 2017

  November 6, 2017

  November 13, 2017

(in thousands)

3,814   $

3,872  

3,929  

3,987  

  $

15,602   $

152

170

194

216

732

14. COMMITMENTS AND CONTINGENCIES

Rail Service Agreements

We have rail service agreements at our terminal facilities with labor service providers that expire at various dates through 2020. After the initial term
of the agreements, the rail service contracts will continue to be in effect for consecutive one-year terms unless either party provides the other party written
notice prior to the end of the term. Under these agreements, we incurred $14.8 million, $13.8 million and $9.0 million  in  service  fees  for  the  years  ended
December 31, 2019, 2018 and 2017, respectively, which are recorded in “Subcontracted rail services” within our consolidated statements of income.

The future minimum payments for these rail services agreements are as follows (in thousands):

Year ending December 31,

2020

Operating Leases and Fleet Lease Income

$

8,635

We  have  non-cancellable  operating  leases  for  railroad  tracks,  land  surfaces,  and  railcars  that  expire  on  various  dates  from  2020  through  2023.  We
incurred $6.4 million and $6.8 million in lease expenses and other rental charges for buildings, storage tanks, offices, tracks, land and railcars for the years
ended December 31, 2018 and 2017, respectively, which are recorded in “Operating and maintenance” within our consolidated statements of income.

We adopted the provisions of ASC 842 as of January 1, 2019. We applied the provisions of ASC 840 in years prior to 2019, which was applicable
during the periods presented above. Refer to Note 8. Leases for lease expense for the year ended December 31, 2019 and a further discussion on our current
leases.

120

 
 
 
 
 
   
   
 
 
 
 
 
   
   
 
 
 
 
 
   
   
 
 
 
 
 
   
   
 
Contingent Liabilities

From time to time, we may be involved in legal, tax, regulatory and other proceedings in the ordinary course of business. We do not believe that we are

currently a party to any such proceedings that will have a material adverse impact on our financial condition or results of operations.

15. SEGMENT REPORTING

We manage our businesses in two reportable segments: Terminalling services and Fleet services. The Terminalling services segment charges minimum
monthly commitment fees under multi-year take-or-pay contracts to load and unload various grades of crude oil into and from railcars, as well as fixed fees
per gallon to transload ethanol from railcars, including related logistics services. We also facilitate rail-to-pipeline shipments of crude oil. Our terminalling
services  segment  also  charges  minimum  monthly  fees  to  store  crude  oil  in  tanks  that  are  leased  to  our  customers.  The  Fleet  services  segment  provides
customers with railcars and fleet services related to the transportation of liquid hydrocarbons and biofuels under multi-year, take-or-pay contracts. Corporate
activities  are  not  considered  a  reportable  segment,  but  are  included  to  present  shared  services  and  financing  activities  which  are  not  allocated  to  our
established reporting segments.

Our  segments  offer  different  services  and  are  managed  accordingly.  Our  chief  operating  decision  maker,  or  CODM,  regularly  reviews  financial
information about both segments in order to allocate resources and evaluate performance. Our CODM assesses segment performance based on the cash flows
produced by our established reporting segments using Segment Adjusted EBITDA. Segment Adjusted EBITDA is a measure calculated in accordance with
GAAP.  Historically,  we  have  defined  Segment  Adjusted  EBITDA  as  “Net  cash  provided  by  operating  activities”  adjusted  for  changes  in  working  capital,
interest,  income  taxes,  foreign  currency  transaction  gains  and  losses  and  other  items  which  do  not  affect  the  underlying  cash  flows  produced  by  our
businesses. Beginning in the first quarter of 2019, we define Segment Adjusted EBITDA as “Net income (loss)” of each segment adjusted for depreciation
and amortization, interest, income taxes, changes in contract assets and liabilities, deferred revenues, foreign currency transaction gains and losses and other
items  which  do  not  affect  the  underlying  cash  flows  produced  by  our  businesses.  As  such,  we  have  concluded  that  disaggregating  revenue  by  reporting
segments appropriately depicts how the nature, amount, timing, and uncertainty of revenue and cash flows are affected by economic factors.

121

Revenues

Terminalling services

Terminalling services — related party

Fleet leases

Fleet leases — related party

Fleet services

Fleet services — related party

Freight and other reimbursables

Freight and other reimbursables — related party

Total revenues

Operating costs

Subcontracted rail services

Pipeline fees

Freight and other reimbursables

Operating and maintenance

Selling, general and administrative

Depreciation and amortization

Total operating costs

Operating income (loss)

Interest expense

Loss associated with derivative instruments

Foreign currency transaction loss (gain)

Other income, net

Provision for income taxes

Net income (loss)

Total assets

Capital expenditures

For the Year Ended December 31, 2019

Terminalling
services

Fleet
services

Corporate

Total

$

87,173   $

19,580  

—  

—  

—  

—  

1,164  

7  

(in thousands)

—   $

—  

—  

3,935  

208  

910  

448  

231  

107,924  

5,732  

14,777  

20,971  

1,171  

11,848  

6,159  

20,664  

75,590  

32,334  

—  

—  

(90)  

(324)  

634  

—  

—  

679  

4,069  

964  

—  

5,712  

20  

—  

—  

9  

—  

28  

—   $

—  

—  

—  

—  

—  

—  

—  

—  

—  

—  

—  

—  

11,721  

—  

11,721  

(11,721)  

12,006  

1,420  

446  

(12)  

—  

32,114   $

(17)   $

(25,581)   $

276,248   $

12,398   $

8,440   $

—   $

920   $

—   $

$

$

$

122

87,173

19,580

—

3,935

208

910

1,612

238

113,656

14,777

20,971

1,850

15,917

18,844

20,664

93,023

20,633

12,006

1,420

365

(336)

662

6,516

289,566

8,440

 
 
 
 
 
 
 
   
   
   
 
   
   
   
Revenues

Terminalling services

Terminalling services — related party

Fleet leases

Fleet leases— related party

Fleet services

Fleet services — related party

Freight and other reimbursables

Freight and other reimbursables — related party

Total revenues

Operating costs

Subcontracted rail services

Pipeline fees

Freight and other reimbursables

Operating and maintenance

Selling, general and administrative

Depreciation and amortization

Total operating costs

Operating income (loss)

Interest expense

Gain associated with derivative instruments

Foreign currency transaction loss (gain)

Other expense, net

Provision for (benefit from) income taxes

Net income (loss)

Total assets

Capital expenditures

For the Year Ended December 31, 2018

Terminalling
services

Fleet
services

Corporate

Total

(in thousands)

—   $

—  

—  

3,935  

573  

910  

2,149  

1  

7,568  

—  

—  

2,150  

4,820  

1,321  

—  

8,291  

(723)  

—  

—  

(14)  

—  

43  

—   $

—  

—  

—  

—  

—  

—  

—  

—  

—  

—  

—  

—  

11,594  

—  

11,594  

(11,594)  

11,358  

(374)  

(138)  

—  

(3)  

(752)   $

(22,437)   $

88,066

22,149

—

3,935

573

910

3,589

4

119,226

13,785

21,679

3,593

11,195

18,422

21,103

89,777

29,449

11,358

(374)

(14)

16

(2,669)

21,132

287,295

8,816

$

88,066   $

22,149  

—  

—  

—  

—  

1,440  

3  

111,658  

13,785  

21,679  

1,443  

6,375  

5,507  

21,103  

69,892  

41,766  

—  

—  

138  

16  

(2,709)  

44,321   $

$

$

$

123

282,523   $

1,966   $

2,806   $

8,816   $

—   $

—   $

 
 
 
 
 
 
 
   
   
   
 
   
   
   
Revenues

Terminalling services

Terminalling services — related party

Fleet leases

Fleet leases — related party

Fleet services

Fleet services — related party

Freight and other reimbursables

Freight and other reimbursables — related party

Total revenues

Operating costs

Subcontracted rail services

Pipeline fees

Freight and other reimbursables

Operating and maintenance

Selling, general and administrative

Depreciation and amortization

Total operating costs

Operating income (loss)

Interest expense

Loss (gain) associated with derivative instruments

Foreign currency transaction loss (gain)

Other income, net

Provision for (benefit from) income taxes

Net Income (loss)

Total assets

Capital expenditures

For the Year Ended December 31, 2017

Terminalling
services

Fleet
services

Corporate

Total

(in thousands)

$

85,466   $

13,769  

—   $

—  

—  

—  

—  

—  

25  

1  

2,140  

4,401  

1,854  

652  

496  

1  

99,261  

9,544  

8,953  

22,524  

26  

3,195  

5,064  

22,132  

61,894  

37,367  

170  

1,083  

(33)  

(330)  

(2,027)  

38,504   $

—  

—  

497  

6,919  

927  

—  

8,343  

1,201  

—  

—  

5  

—  

275  

921   $

297,937   $

2,229   $

27,580   $

—   $

$

$

$

124

—   $

—  

—  

—  

—  

—  

—  

—  

—  

—  

—  

—  

—  

9,090  

—  

9,090  

(9,090)  

9,755  

(146)  

(428)  

—  

(177)  

(18,094)   $

846   $

—   $

85,466

13,769

2,140

4,401

1,854

652

521

2

108,805

8,953

22,524

523

10,114

15,081

22,132

79,327

29,478

9,925

937

(456)

(330)

(1,929)

21,331

301,012

27,580

 
 
 
 
 
 
 
   
   
   
 
   
   
   
Segment Adjusted EBITDA

The following tables present the computation of Segment Adjusted EBITDA, which is a measure determined in accordance with GAAP, for each of our

segments for the periods indicated:

Terminalling Services Segment

Net income
Interest expense (income), net (1)
Depreciation and amortization

Provision for (benefit from) income taxes

Loss associated with derivative instruments

Settlement of derivative contracts
Foreign currency transaction loss (gain) (2)
Loss associated with disposal of assets

Other income
Non-cash deferred amounts (3)

Segment Adjusted EBITDA

For the Years Ended December 31,

2019

2018

(in thousands)

2017

$

32,114   $

44,321   $

(58)  

20,664  

634  

—  

—  

(90)  

57  

—  

$

2,809  

56,130   $

(2)  

21,103  

(2,709)  

—  

—  

138  

73  

—  

(205)  

38,504

162

22,132

(2,027)

1,083

83

(33)

18

(22)

—

62,719   $

59,900

(1)  Represents  interest  expense  associated  with  our  Terminalling  Services  segment  net  of  interest  income  that  is  included  in  “Other  expense  (income),  net”  in  our  consolidated  statements  of

income.    

(2)  Represents foreign exchange transaction amounts associated with activities between our U.S. and Canadian subsidiaries.
(3)  Represents the change in non-cash contract assets and contract liabilities associated with revenue recognized at blended rates based on tiered rate structures in certain of our customer contracts
and  deferred  revenue  associated  with  deficiency  credits  that  are  expected  to  be  used  in  the  future  prior  to  their  expiration.  Amounts  presented  are  net  of  the  corresponding  prepaid  Gibson
pipeline fee that will be recognized as expense concurrently with the recognition of revenue.

Fleet Services Segment

Net income (loss)

Provision for income taxes
Foreign currency transaction loss (gain) (1)
Non-cash lease item

Segment Adjusted EBITDA

For the Years Ended December 31,

2019

2018

(in thousands)

2017

$

$

(17)   $

28  

9  

—  

20   $

(752)   $

43  

(14)  

—  

921

275

5

341

(723)   $

1,542

(1)  Represents foreign exchange transaction amounts associated with activities between our U.S. and Canadian subsidiaries.

The following tables summarize the geographic data for our continuing operations:

Revenues

Third party

Related party

Total assets

For the Year Ended December 31, 2019

U.S.

Canada

(in thousands)

Total

$

$

$

32,459   $

56,534   $

9,013   $

15,650   $

88,993

24,663

218,778   $

70,788   $

289,566

125

 
 
 
 
    
 
 
 
 
    
 
 
 
 
 
 
   
   
Revenues

Third party

Related party

Total assets

Revenues

Third party

Related party

Total assets

For the Year Ended December 31, 2018

U.S.

Canada

(in thousands)

Total

$

$

$

$

$

$

44,570   $

47,658   $

7,214   $

19,784   $

92,228

26,998

224,588   $

62,707   $

287,295

For the Year Ended December 31, 2017

U.S.

Canada

(in thousands)

Total

38,452   $

51,529   $

5,054   $

13,770   $

89,981

18,824

229,241   $

71,771   $

301,012

16. INCOME TAXES

U.S. Federal and State Income Taxes

We are treated as a partnership for U.S. federal and most state income tax purposes, with each partner being separately taxed on their share of our
taxable income. We have elected to classify one of our subsidiaries, USD Rail LP, as an entity taxable as a corporation for U.S. federal income tax purposes
due to treasury regulations that do not permit the income of this subsidiary to be classified as “qualifying income” as such term is defined in §7704(d) of the
Internal Revenue Code. We are also subject to state franchise tax in the state of Texas, which is treated as an income tax under the applicable accounting
guidance. Our U.S. federal income tax expense is based on the statutory federal income tax rate of 21% as applied to USD Rail LP’s taxable loss of $0.2
million  and  $1.3 million,  for  the  years  ended  December  31,  2019  and  2018,  respectively.  Our  U.S.  federal  income  tax  expense  for  the  fiscal  year  ended
December 31, 2017, is based on the statutory federal income tax rate of 34% in effect for the period as applied to USD Rail LP’s taxable income of $2.0
million. We recorded a provision for U.S. federal income tax in 2017, utilizing net operating loss carryforwards to offset a portion of our taxable income.     

Foreign Income Taxes

Our Canadian operations are conducted through entities that are subject to Canadian federal and Alberta provincial income taxes. The Canadian federal
income tax on business income is currently 15%.  In  June  2019,  the  Canadian  province  of  Alberta  enacted  a  tax  rate  decrease  that  reduces  the  tax  rate  on
business income from the previous rate of 12% to an ultimate rate of 8% effective for 2022. The reduction in the tax rate on business income is phased in over
three years beginning with a reduction to a rate of 11% effective July 1, 2019, with further reductions of 1% in each successive year until it reaches 8% on
January  1,  2022.  As  a  result,  the  effective  tax  rate  on  business  income  for  Alberta  businesses  in  2019 is 11.5%,  representing  a  blended  rate  of  12%  from
January 1, 2019 through June 30, 2019, and 11% from July 1, 2019 through December 31, 2019.

We recognize income tax expense in our consolidated financial statements based upon enacted rates in effect for the periods presented. As such for the
year ended December 31, 2019, income tax expense for our Canadian operations is determined based upon the combined federal and provincial income tax
rate of 26.5%, representing a 15% federal income tax rate and a 11.5% provincial income tax rate. For the years ended December 31, 2018 and 2017, income
tax expense of our Canadian operations was determined based on the combined federal and provincial income tax rate of 27%. We computed the deferred
income tax benefit, representing the impact of temporary differences that are expected to reverse in the future using the combined income tax rate of 23%,
representing a 15% federal income tax rate and an 8% provincial income tax rate.

The 2017 income tax expense of our Canadian operations includes a reduction to our estimate for 2016 income tax expense resulting from refunds of

$2.6 million (C$3.4 million) in connection with our Canadian federal and provincial income tax returns for 2016, which we filed in June 2017.

126

 
 
 
 
 
 
   
   
 
 
 
 
 
 
   
   
Tax Effects of ASC 606 Adoption

In  connection  with  our  adoption  of  ASC  606,  in  2018,  we  recovered  a  deferred  tax  liability  associated  with  previously  deferred  revenues  net  of
previously deferred pipeline fees. We recovered this deferred tax liability during the year ended December 31, 2018. The recovery of the deferred tax liability
of $3.8 million (representing C$4.9 million) contributed to our benefit from income taxes for the year ended December 31, 2018. 

Consolidated Provision for (Benefit from) Income Taxes

The domestic and foreign components of our income before income taxes is presented in the following table:

Domestic

Foreign

Income before income taxes

Estimated Annual Effective Income Tax Rate

Years Ended December 31,

2019

2018

2017

(in thousands)

$

$

4,497   $

28,918   $

26,779

2,681  

(10,455)  

7,178   $

18,463   $

(7,377)

19,402

The following table presents a reconciliation of our income tax based on the U.S. federal statutory income tax rate and our effective income tax rate:

Income tax expense at the U.S. federal statutory rate

$

1,507  

21 %   $

3,877  

21 %   $

6,597  

Amount attributable to partnership not subject to income tax

(957)  

(13)%  

(6,193)  

(34)%  

(8,590)  

34 %

(44)%

2019

Years Ended December 31,

2018

(in thousands)

2017

Foreign income tax rate differential

Alberta provincial tax rate change

State income tax expense (benefit) (1)

Other

Change in valuation allowance

140  

2 %  

(605)  

(3)%  

137  

1 %

(56)  

(1)%  

22  

—  

— %  

— %  

—  

31  

30  

— %  

—  

— %

— %  

(132)  

(1)%

— %  

28  

31  

— %

— %

6  

— %  

191  

1 %  

Provision for (benefit from) income taxes

$

662  

9 %   $

(2,669)  

(15)%   $

(1,929)  

(10)%

(1) 

Net of the federal income tax expense or benefit for the deduction associated with state income taxes.

127

 
 
 
 
 
 
 
 
 
 
    
We determined our year-to-date 2019 provision for income taxes using an estimated annual effective income tax rate of 9% on a consolidated basis for

fiscal year 2019. This rate incorporates the applicable income tax rates of the various domestic and foreign tax jurisdictions to which we are subject.

Current income tax expense (benefit)

U.S. federal income tax

U.S. federal operating loss carryforward

State income tax expense (benefit)

Canadian federal and provincial income tax expense (benefit)

Total current income tax expense (benefit)

Deferred income tax expense (benefit)

U.S. federal income tax expense (benefit)

Canadian federal and provincial income tax expense (benefit)

Total change in deferred income tax expense (benefit)

Provision for (benefit from) income taxes

Years Ended December 31,

2019

2018

2017

(in thousands)

$

—   $

4   $

—  

28  

555  

583  

—  

79  

79  

—  

16  

1,282  

1,302  

16  

(3,987)  

(3,971)  

687

(200)

(115)

(1,314)

(942)

(262)

(725)

(987)

$

662   $

(2,669)   $

(1,929)

Our deferred income tax assets and liabilities reflect the income tax effect of differences between the carrying amounts of our assets and liabilities for
financial reporting purposes and the amounts used for income tax purposes. Major components of deferred income tax assets and liabilities associated with
our operations were as follows as of the dates indicated:

Deferred income tax assets

Property and equipment

Capital loss carryforwards

Operating loss carryforwards

Deferred income tax liabilities

Prepaid expenses

Unbilled revenue

Property and equipment

Valuation allowance

   Deferred income tax liability, net

$

128

U.S.

December 31, 2019

Foreign

(in thousands)

Total

$

—   $

272   $

—  

320  

(46)  

—  

—  

(274)  

—   $

387  

—  

—  

(730)  

—  

(387)  

(458)   $

272

387

320

(46)

(730)

—

(661)

(458)

 
 
 
 
 
 
   
   
 
   
   
 
 
 
 
 
 
   
   
 
   
 
Deferred income tax assets

Property and equipment

Capital loss carryforwards

Operating loss carryforwards

Deferred income tax liabilities

Prepaid expenses

Unbilled revenue

Property and equipment

Valuation allowance

U.S.

December 31, 2018

Foreign

(in thousands)

Total

$

—   $

—   $

—  

183  

(10)  

—  

—  

(173)  

—   $

432  

—  

—  

(336)  

(24)  

(432)  

(360)   $

—

432

183

(10)

(336)

(24)

(605)

(360)

   Deferred income tax liability, net

$

We had loss carryforwards for U.S. federal tax purposes of $1.5 million and $1.3 million remaining as of December 31, 2019 and 2018, respectively.
These loss carryforward amounts originated in 2018 and 2019 and do not expire under currently enacted tax law. We had loss carryforwards for Canadian tax
purposes of $4.3 million and $4.2 million as of December 31, 2019 and 2018, respectively. A portion of our Canadian loss carryforward is for capital items
that do not expire under currently enacted Canadian tax law, while $1.0 million  of  the  carryforward  amount  relates  to  Canadian  operating  losses  that  will
expire in 2034.

We are subject to examination by the taxing authorities for the years ended December 31, 2018, 2017 and 2016. We did not have any unrecognized

income tax benefits or any income tax reserves for uncertain tax positions as of December 31, 2019 and 2018.

17. MAJOR CUSTOMERS AND CONCENTRATION OF CREDIT RISK

The following tables provide the percentage of total revenues attributable to a single customer from which 10% or more of total revenues are derived:

Customer A

Customer B

Customer C

Customer D

Customer A

Customer B

Customer C

Customer D

For the Year Ended December 31, 2019

Total Revenues by
Major Customer
(in thousands)

Percentage of Total
Company Revenues

Percentage of
Customer Revenues in
Terminalling Services
Segment

Percentage of Customer
Revenues in Fleet
Services Segment

34,908  

24,677  

13,558  

12,634  

31 %  

22 %  

12 %  

11 %  

100 %  

79 %  

100 %  

100 %  

— %

21 %

— %

— %

For the Year Ended December 31, 2018

Total Revenues by
Major Customer
(in thousands)

Percentage of Total
Company Revenues

Percentage of
Customer Revenues in
Terminalling Services
Segment

Percentage of Customer
Revenues in Fleet
Services Segment

25 %  

23 %  

4 %  

10 %  

100 %  

82 %  

100 %  

100 %  

— %

18 %

— %

— %

29,563  

27,014  

5,199  

12,286  

129

$

$

$

$

$

$

$

$

 
 
 
 
 
 
   
   
 
   
   
 
 
 
 
 
 
 
 
 
 
A substantial portion of our revenues are from a limited number of customers. Our revenues are derived mainly from railcar loading and unloading,
storage and other terminalling services as well as railcar fleet services. The concentration of these customers in the energy industry may impact our overall
exposure to credit risk, either positively or negatively, since our customers may be similarly affected by changes in commodity prices, regulation, and other
economic factors. We seek high-quality customers with investment grade credit ratings and perform ongoing credit evaluations of our customers.

18. DERIVATIVE FINANCIAL INSTRUMENTS

Our  net  income  and  cash  flows  are  subject  to  fluctuations  resulting  from  changes  in  interest  rates  on  our  variable  rate  debt  obligations  and  from
changes in foreign currency exchange rates, particularly with respect to the U.S. dollar and the Canadian dollar. In limited circumstances, we may also hold
long positions in the commodities we handle on behalf of our customers, which exposes us to commodity price risk. We use derivative financial instruments,
including  futures,  forwards,  swaps,  options  and  other  financial  instruments  with  similar  characteristics,  to  manage  the  risks  associated  with  market
fluctuations in interest rates, foreign currency exchange rates and commodity prices, as well as to reduce volatility in our cash flows. We have not historically
designated,  nor  do  we  expect  to  designate,  our  derivative  financial  instruments  as  hedges  of  the  underlying  risk  exposure.  All  of  our  derivative  financial
instruments are employed in connection with an underlying asset, liability and/or forecasted transaction and are not entered into for speculative purposes.

Interest Rate Derivatives

We use interest rate derivative financial instruments to partially mitigate our exposure to interest rate fluctuations on our variable rate debt. Under our
Credit Agreement, one-month LIBOR is used as the index rate for the interest we are charged on amounts borrowed under our Revolving Credit Facility.
Effective November 2017, we entered into a five-year interest rate collar contract with a $100 million notional value. The collar establishes a range where we
will pay the counterparty if the one-month Overnight Index Swap, or OIS, falls below the established floor rate of 1.70%, and the counterparty will pay us if
the one-month OIS rate exceeds the established ceiling rate of 2.50%. The collar settles monthly through the termination date in October 2022. No payments
or receipts are exchanged on the interest rate collar contracts unless interest rates rise above or fall below the pre-determined ceiling or floor rate. Prior to
February 2019, our interest rate collar contract discussed above was based on one-month LIBOR, which is being phased out by financial institutions in the
United States.

Foreign Currency Derivatives

We derive a significant portion of our cash flows from our Hardisty terminal operations in the province of Alberta, Canada, which are denominated in
Canadian dollars. As a result, fluctuations in the exchange rate between the Canadian dollar and the U.S. dollar could have a significant effect on our results
of  operations,  cash  flows  and  financial  position.  We  endeavor  to  limit  our  foreign  currency  risk  exposure  using  various  types  of  derivative  financial
instruments with characteristics that effectively reduce or eliminate the impact to us of declines in the exchange rate for a specified value of Canadian dollar
denominated cash flows we expect to exchange into U.S. dollars. We have not entered into any derivative financial instruments to mitigate our exposure to
changes in foreign currency exchange rates for the years ended December 31, 2019 and 2018 or for any future period.

In  April  2016,  we  entered  into  four  separate  forward  contracts  with  an  aggregate  notional  amount  of  C$33.5  million  to  manage  our  exposure  to
fluctuations in the exchange rate between the Canadian dollar and the U.S. dollar resulting from our Canadian operations during the 2017 calendar year. Each
forward contract effectively fixed the exchange rate we received for each Canadian dollar we sold to the counterparty. One of these forward contracts settled
at the end of each fiscal quarter during 2017 and secured an exchange rate where a Canadian dollar was exchanged for an amount between 0.7804 and 0.7809
U.S. dollars.

Commodity Derivatives

In June 2017, as a part of our purchase of the Stroud terminal and related facilities, we acquired crude oil used by the prior owner for line fill in the
crude oil pipeline and tank bottoms for the storage tanks at the Stroud terminal. We agreed to sell the approximately 18,000 barrels, or bbls, of crude oil used
for tank bottoms in July 2017 and the

130

approximately 13,000 bbls of crude oil used for line fill in October 2017 to an unrelated party at a price which varied with the price of crude oil during the
months  of  July  and  October  of  2017.  In  June  2017,  we  entered  into  two  separate  fixed-for-floating  swap  contracts  with  an  aggregate  notional  amount  of
31,778 bbls to manage our exposure to fluctuating crude oil prices. Each swap contract effectively fixed the price we received upon our delivery of the crude
oil. The first contract for approximately 18,000 bbls settled in July 2017 at $47.20 per barrel, and the second contract for approximately 13,000 bbls settled in
October 2017 at $47.70 per barrel.

In September 2017, we also acquired crude oil used by the prior owner of the Stroud terminal for tank bottoms in a leased storage tank at a third-party
facility in Cushing, Oklahoma. We agreed to sell this crude oil in October 2017 to an unrelated party at a price which varied with the price of crude oil during
the month of October 2017. We entered into a fixed-for-floating swap contract with an aggregate notional amount of 30,000 bbls to manage our exposure to
the variability in crude oil prices during the month of October 2017. The swap contract effectively fixed the price we received upon our delivery of the crude
oil and settled in October 2017 at $47.90 per barrel.

Derivative Positions

We recorded all of our derivative financial instruments at their fair values in the line items specified below within our consolidated balance sheets, the

amounts of which were as follows at the dates indicated:

Other current assets

Other non-current assets

Other current liabilities

Other non-current liabilities

December 31,

2019

2018

$

(in thousands)
—   $

—  

(139)  

(687)  

(826)  

260

335

—

—

595

We have not designated our derivative financial instruments as hedges of our interest rate, foreign currency rate or commodity exposures. As a result,
changes in the fair value of these derivatives are recorded as “Loss (gain) associated with derivative instruments” in our consolidated statements of income.
The gains or losses associated with changes in the fair value of our derivative contracts do not affect our cash flows until the underlying contract is settled by
making  or  receiving  a  payment  to  or  from  the  counterparty.  In  connection  with  our  derivative  activities,  we  recognized  the  following  amounts  during  the
periods presented:

Loss (gain) associated with derivative instruments

$

1,420   $

(374)   $

937

We determine the fair value of our derivative financial instruments using third-party pricing information that is derived from observable market inputs,

which we classify as level 2 with respect to the fair value hierarchy.

The following table presents summarized information about the fair values of our outstanding interest rate contracts for the periods indicated:

Years Ended December 31,

2019

2018

2017

(in thousands)

Notional

Interest Rate
Parameters

  December 31, 2019   December 31, 2018

Fair Value

Fair Value

(in thousands)

Collar Agreements Maturing in 2022    

Ceiling

Floor

Total

  $

  $

100,000,000  

100,000,000  

2.5%   $

1.7%  

  $

83   $

(909)  

(826)   $

1,238

(643)

595

131

 
 
 
 
 
 
 
 
 
 
 
 
   
 
 
 
 
 
 
   
   
 
   
   
   
   
   
We record the fair market value of our derivative financial instruments in our consolidated balance sheets as current and non-current assets or liabilities
on a net basis by counterparty. The terms of the International Swaps and Derivatives Association Master Agreement, which governs our financial contracts,
include master netting agreements that allow the parties to our derivative contracts to elect net settlement in respect of all transactions under the agreements.
The effect of the rights of offset are presented in the tables below as of the dates indicated.

December 31, 2019

Current
assets

Non-current
assets

Current
liabilities

Non-current
liabilities

Total

(in thousands)

Fair value of derivatives - gross presentation

Effects of netting arrangements

Fair value of derivatives - net presentation

  $

  $

—   $

—  

—   $

83   $

(139)   $

(770)   $

(83)  

—  

83  

—   $

(139)   $

(687)   $

(826)

—

(826)

December 31, 2018

Current
assets

Non-current
assets

Current
liabilities

Non-current
liabilities

Total

(in thousands)

Fair value of derivatives - gross presentation

Effects of netting arrangements

Fair value of derivatives - net presentation

  $

  $

260   $

—  

260   $

978   $

(643)  

335   $

—   $

—  

—   $

(643)   $

643  

—   $

595

—

595

For more information on our accounting policies regarding derivatives, refer to the derivative financial instruments discussion in Note 2. Summary of

Significant Accounting Policies.

19. PARTNERS’ CAPITAL

Our common units and subordinated units represent limited partner interests in us. The holders of common units and subordinated units are entitled to

participate in partnership distributions and to exercise the rights and privileges available to limited partners under our partnership agreement.

In February 2019, pursuant to the terms set forth in our partnership agreement, the fourth and final vesting tranche of 38,750 Class A units vested and
was  converted  into  our  common  units.  We  determined  that  each  vested  Class  A  unit  would  receive  one  common  unit  at  conversion  based  upon  our
distributions paid for the four preceding quarters. As a result, the final tranche of 38,750 Class A units were converted into 38,750 common units and no Class
A  units  remain  outstanding  at  December  31,  2019.  Our  Class  A  units  were  limited  partner  interests  in  us  that  entitled  the  holders  to  nonforfeitable
distributions  that  were  equivalent  to  the  distributions  paid  with  respect  to  our  common  units  (excluding  any  arrearages  of  unpaid  minimum  quarterly
distributions from prior quarters) and, as a result, were considered participating securities. Our Class A units did not have voting rights and vested in four
equal annual installments over the four years following the consummation of our IPO only if we grew our annualized distributions each year. If we did not
achieve positive distribution growth in any of those years, the Class A units that would otherwise vest for that year would be forfeited. The Class A units
contained a conversion feature, which, upon vesting, provided for the conversion of the Class A units into common units based on a conversion factor that
was tied to the level of our distribution growth for the applicable year. The conversion factor was 1.00 for the first vesting tranche, 1.50 for the second vesting
tranche, 1.00 for the third vesting tranche, and 1.00 for the fourth vesting tranche.

Subordinated  units  convert  into  common  units  on  a  one-for-one  basis  in  separate  sequential  tranches.  Each  tranche  is  comprised  of  20.0%  of  the
subordinated units issued in conjunction with our IPO. Each separate tranche is eligible to convert on or after December 31, 2015 (but no more frequently
than once in any twelve-month period), provided on such date: (i) distributions of available cash from operating surplus on each of the outstanding common
units, Class A units, subordinated units and general partner units equaled or exceeded $1.15 per unit (the annualized minimum quarterly distribution) for the
four quarter period immediately preceding that date; (ii) the adjusted operating

132

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
surplus generated during the four quarter period immediately preceding that date equaled or exceeded the sum of $1.15 per unit (the annualized minimum
quarterly distribution) on all of the common units, Class A units, subordinated units and general partner units outstanding during that period on a fully diluted
basis;  and  (iii)  there  are  no  arrearages  in  the  payment  of  the  minimum  quarterly  distribution  on  our  common  units.  For  each  successive  tranche,  the  four
quarter period specified in clauses (i) and (ii) above must commence after the four quarter period applicable to any prior tranche of subordinated units. In
February 2019,  pursuant  to  the  terms  set  forth  in  our  partnership  agreement,  we  converted  the  fourth  tranche  of  2,092,709  of  our  subordinated  units  into
common units upon satisfaction of the conditions established for conversion.

Our partnership agreement provides that, while any subordinated units remain outstanding, holders of our common units will have the right to receive
distributions of available cash from operating surplus each quarter in an amount equal to our minimum quarterly distribution per unit, plus (with respect to the
common units) any arrearages in the payment of the minimum quarterly distribution on the common units from prior quarters, before any distributions of
available cash from operating surplus may be made on the subordinated units.

Pursuant to the terms of the USD Partners LP Amended and Restated 2014 Long-Term Incentive Plan, which we refer to as the A/R LTIP, our phantom
unit awards, or Phantom Units, granted to directors and employees of our general partner and its affiliates, which are classified as equity, are converted into
our common units upon vesting. Equity-classified Phantom Units totaling 454,334 vested during 2019, of which 364,409 were converted into our common
units after 163,242 Phantom Units were withheld from participants for the payment of applicable employment-related withholding taxes. The conversion of
these Phantom Units did not have any economic impact on Partners’ Capital, since the economic impact is recognized over the vesting period. Additional
information and discussion regarding our unit based compensation plans is included below in Note 20. Unit Based Compensation.

The board of directors of our general partner has adopted a cash distribution policy pursuant to which we intend to distribute at least the minimum
quarterly distribution of $0.2875 per unit ($1.15 per unit on an annualized basis) on all of our units to the extent we have sufficient available cash after the
establishment of cash reserves and the payment of our expenses, including payments to our general partner and its affiliates. The board of directors of our
general partner may change our distribution policy at any time and from time to time. Our partnership agreement does not require us to pay cash distributions
on a quarterly or other basis. The amount of distributions we pay under our cash distribution policy and the decision to make any distributions are determined
by our general partner.

In June 2017, we completed an underwritten public offering of 3,000,000 common units that we used to repay a portion of the amounts outstanding on

our revolving credit facility, including amounts we borrowed to fund our acquisition of the Stroud terminal.

The following table presents the net proceeds from our common unit issuances:

Number of Common Units
Issued

Public Offering Price per
Common Unit

Net Proceeds to the
Partnership (1)

(in millions)

June 7, 2017 Issuance

3,000,000   $

11.60   $

33.7

(1)    Net of underwriter’s fees and discounts, commissions and issuance costs.

20. UNIT BASED COMPENSATION

Class A units

As provided for in our partnership agreement, we granted 250,000 non-voting Class A units to certain executive officers and other key employees of
our general partner who provided services to us, of which 38,750 and 82,500 were outstanding as of December 31, 2018 and 2017, respectively. In February
2019,  pursuant  to  the  terms  set  forth  in  our  partnership  agreement,  the  fourth  and  final  vesting  tranche  of  38,750  Class  A  units  vested  based  upon  our
distributions paid for the four preceding quarters and were converted on a basis of one common unit for each Class A unit. As a

133

 
 
 
 
 
   
 
        
result  we  converted  38,750  class  A  units  into  38,750  common  units.  The  grant  date  average  fair  value  of  all  Class  A  units  was  $25.71  per  unit  at
December 31, 2018 and 2017.

Class A units outstanding at beginning of period

Vested

Forfeited

Class A units outstanding at end of period

Years Ended December 31,

2019

2018

2017

38,750  

(38,750)  

—  

—  

82,500  

(38,750)  

(5,000)  

38,750  

138,750

(46,250)

(10,000)

82,500

Our Class A units vested over a four  year  period  if  established  distribution  target  thresholds  were  met  each  year  of  the  four year vesting period. If
distributions  exceeded  the  threshold  by  more  than  the  target  amount,  the  Class  A  units  in  that  tranche  vested  and  became  convertible  into  more  than  one
common unit (each Class A unit was convertible into a maximum number of additional common units of 1.25 to 2.0 times, depending on the tranche). Each of
the Class A units had an accompanying distribution equivalent right, or DER, until they were forfeited, expired, or terminated. However, distributions over
the vesting period were not paid in arrears if the Class A units became convertible into more than one common unit.

We measured the compensation cost associated with the Class A units based on the fair value at the October 15, 2014 effective date of the grant. We
determined the fair value of our Class A units at the grant date to be $25.71 per Class A unit based on the market price of the underlying common units on the
date  of  our  IPO,  adjusted  for  vesting  probabilities  associated  with  the  performance-based  vesting  requirements  and  the  present  value  of  the  expected
distributions. We assumed distribution rates ranging from $0.2438 per quarter to $0.4905 per quarter during the vesting period which we discounted assuming
a 13% annual cost of equity. For the years ended December 31, 2018 and 2017, we revised our assumptions regarding the vesting probabilities associated with
the performance-based vesting requirements to reflect our current expectations regarding future quarterly distribution rates.

The  ultimate  percentage  of  units  vesting  in  each  tranche  depended  on  a  performance  condition:  specifically,  the  total  distributions  paid  in  the  four
quarters of the vesting period for each tranche. If distributions met or fell below a threshold, the Class A units in that tranche were forfeited. If distributions
exceeded a threshold by less than a target amount, the Class A units in that tranche vested and became convertible into one common unit. If distributions
exceeded the threshold by the target amount or more, the Class A units in that tranche vested and became convertible into more than one common unit (1.25
to 2.0 times common units per Class A unit, depending on the tranche). We did not assume any forfeitures in our initial determination of fair value, although
we reflected actual forfeitures in our determination of compensation expense with respect to the Class A units.

We estimated the expense for each tranche as the number of unit equity awards, multiplied by the per unit grant date fair value of those awards less
actual  forfeitures  in  the  probable  vesting  scenario  for  each  tranche  (equaling  the  applicable  conversion  multiple  times  the  value  of  the  unit  excluding  the
expected distributions paid over the vesting period (the common unit price at October 15, 2014, less the present value of the expected distributions) plus the
present  value  of  the  expected  distributions  for  any  tranches  that  vested).  The  estimated  fair  value  of  our  Class  A  units  were  amortized  over  the  four-year
vesting period using the straight-line method. The Class A unit awards converted into our common units upon vesting.

We recognized compensation expense in “Selling, general and administrative” in our consolidated statements of income with regard to our Class A units

of the following amounts during the periods presented:

Selling, general and administrative

$

14   $

259   $

201

Each holder of a Class A unit was entitled to nonforfeitable cash distributions equal to the product of the number of Class A units outstanding for the

participant and the cash distribution per unit paid to our common unitholders. These

2019

Years Ended December 31,

2018

(in thousands)

2017

134

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
distributions were included in “Distributions” as presented in our consolidated statements of cash flows and our consolidated statements of partners’ capital.
However, any distributions paid on Class A units that were forfeited were reclassified to unit based compensation expense when we determined that the Class
A units are not expected to vest. We recognized compensation expense of $15 thousand and $30 thousand for the years ended December 31, 2018 and 2017,
respectively, for distributions paid on Class A units that were forfeited. We had no compensation expense recognized for distributions paid on Class A units
that were not expected to vest for the year ended December 31, 2019.

Long-term Incentive Plan

In connection with the completion of our initial public offering in 2014, our general partner adopted the USD Partners LP 2014 Long-Term Incentive
Plan, or the LTIP. The total number of our Phantom Units initially authorized for issuance under the LTIP was 1,654,167, which amount was subsequently
increased to 3,654,167 Phantom Units pursuant to the A/R LTIP that became effective November 16, 2017. In 2019, 2018 and 2017, the board of directors of
our general partner, acting in its capacity as the general partner, approved grants of 633,637, 553,940 and 695,099 Phantom Units, respectively, to directors
and employees of our general partner and its affiliates under the A/R LTIP and the LTIP. At December 31, 2019, we had 1,406,883 Phantom Units remaining
available for issuance. The Phantom Units are subject to all of the terms and conditions of the A/R LTIP and the Phantom Unit award agreements, which are
collectively referred to as the Award Agreements. Award amounts for each of the grants are generally determined by reference to a specified dollar amount
based on an allocation formula which included a percentage multiplier of the grantee’s base salary, among other factors, converted to a number of units based
on the closing price of one of our common units preceding the grant date, as determined by the board of directors of our general partner and quoted on the
NYSE.

Phantom unit awards generally represent rights to receive our common units upon vesting. However, with respect to the awards granted to directors
and employees of our general partner and its affiliates domiciled in Canada, for each Phantom Unit that vests, a participant is entitled to receive cash for an
amount equivalent to the closing market price of one of our common units on the vesting date. Each Phantom Unit granted under the Award Agreements
includes an accompanying distribution equivalent right, or DER, which entitles each participant to receive payments at a per unit rate equal in amount to the
per unit rate for any distributions we make with respect to our common units. The Award Agreements granted to employees of our general partner and its
affiliates  generally  contemplate  that  the  individual  grants  of  Phantom  Units  will  vest  in  four  equal  annual  installments  based  on  the  grantee’s  continued
employment  through  the  vesting  dates  specified  in  the  Award  Agreements,  subject  to  acceleration  upon  the  grantee’s  death  or  disability,  or  involuntary
termination  in  connection  with  a  change  in  control  of  the  Partnership  or  our  general  partner.  Awards  to  independent  directors  of  the  board  of  our  general
partner and an independent consultant typically vest over a one-year period following the grant date.

135

The following table presents the award activity for our Equity-classified Phantom Units:

Phantom unit awards at December 31, 2016

Granted

Vested

Forfeited

Phantom unit awards at December 31, 2017

Granted

Vested

Forfeited

Phantom unit awards at December 31, 2018

Granted

Vested

Forfeited

Phantom unit awards at December 31, 2019

Independent Director and
Consultant Phantom Units

Employee Phantom
Units

Weighted-Average
Grant Date Fair Value
Per Phantom Unit

64,830  

24,999  

(64,830)  

—  

24,999  

34,611  

(24,999)  

—  

34,611  

37,139  

(34,611)  

—  

37,139  

730,808   $

641,955   $

(204,831)   $

(56,083)   $

1,111,849   $

487,839   $

(412,263)   $

(56,740)   $

1,130,685   $

544,857   $

(419,723)   $

(3,275)   $

1,252,544   $

8.51

12.78

8.48

10.94

10.90

11.54

10.89

11.07

11.19

11.37

11.00

10.99

11.34

The following table presents the award activity for our Liability-classified Phantom Units:

Phantom Unit awards at December 31, 2016

Granted
Vested (1)(2)

Phantom unit awards at December 31, 2017

Granted
Vested (1)(2)

Phantom unit awards at December 31, 2018

Granted
Vested (1)(2)

Phantom unit awards at December 31, 2019

Independent Director and
Consultant Phantom Units

  Employee Phantom Units  

Weighted-Average
Grant Date Fair Value
Per Phantom Unit

21,610  

8,333  

(21,610)  

8,333  

11,348  

(8,333)  

11,348  

12,177  

(11,348)  

12,177  

21,615   $

19,812   $

(13,633)   $

27,794   $

20,142   $

(18,671)   $

29,265   $

39,464   $

(24,109)   $

44,620   $

7.70

12.80

6.29

11.29

11.55

11.55

11.98

11.37

11.06

11.53

(1)  Phantom  Units  granted  to  employees  domiciled  in  Canada  vested  on  December 31, 2019, 2018 and 2017  at  the  closing  price  for  our  common  units  as  quoted  on  the  NYSE.  We  paid  $239

thousand, $195 thousand and $153 thousand, respectively, for Phantom Units granted to employees domiciled in Canada that vested on December 31, 2019, 2018 and 2017.

(2)  Phantom Unit grants to Directors and independent consultants domiciled in Canada vested on February 16, 2019, February 16, 2018 and February 25, 2017, at the closing price for our common

units as quoted on the NYSE, resulting in our payment of $129 thousand, $96 thousand and $277 thousand, respectively, for the vested Phantom Units.

The  total  fair  value  of  all  Phantom  Units  that  vested  in  2019, 2018  and  2017  was  $5.5 million, $5.3 million,  and  $4.0  million,  respectively,  which

included cash payments of $368 thousand, $291 thousand, and $430 thousand respectively, for Liability-classified Phantom Units.

The fair value of each Phantom Unit on the grant date is equal to the closing market price of our common units on the grant date. We account for the
Phantom  Unit  grants  to  independent  directors  and  employees  of  our  general  partner  and  its  affiliates  domiciled  in  Canada  that  are  paid  out  in  cash  upon
vesting, throughout the requisite vesting period, by revaluing the unvested Phantom Units outstanding at the end of each reporting period and recording a
charge to

136

 
 
 
 
compensation  expense  in  “Selling,  general  and  administrative”  in  our  consolidated  statements  of  income  and  recognizing  a  liability  in  “Other  current
liabilities” in our consolidated balance sheets. With respect to the Phantom Units granted to consultants, independent directors and employees of our general
partner and its affiliates domiciled in the United States, we amortize the initial grant date fair value over the requisite service period using the straight-line
method with a charge to compensation expense in “Selling, general and administrative” in our consolidated statements of income, with an offset to common
units within the Partners’ Capital section of our consolidated balance sheet.

For each of the years ended December 31, 2019 and 2018, we recognized $6.1 million of compensation expense associated with outstanding Phantom
Units and $3.9 million for the year ended December 31, 2017. As of December 31, 2019, we have unrecognized compensation expense associated with our
outstanding Phantom Units totaling $10.2 million, which we expect to recognize over a weighted average period of 2.40 years. We have elected to account for
actual forfeitures as they occur rather than using an estimated forfeiture rate to determine the number of awards we expect to vest.

We made payments to holders of the Phantom Units pursuant to the associated DERs we granted to them under the Award Agreements as follows:

Equity-classified Phantom Units (1)
Liability-classified Phantom Units

Total

2019

Years Ended December 31,

2018

(in thousands)

1,832   $

104  

1,936   $

1,712   $

76  

1,788   $

$

$

2017

1,439

65

1,504

(1)  We reclassified $8 thousand, $84 thousand and $64 thousand for the years ended December 31, 2019, 2018 and 2017, respectively, to unit based compensation expense for

DERs paid in relation to Phantom Units that have been forfeited.

21. SUPPLEMENTAL CASH FLOW INFORMATION

The following table provides supplemental cash flow information for the periods indicated:

Cash paid (received) for income taxes

Cash paid for interest, net of amount capitalized

Cash paid for operating leases (1)

For the Years Ended December 31,

2019

2018

2017

(in thousands)

$

$

$

1,206   $

814   $

(1,250)

11,217   $

10,038   $

9,754

6,101   $

—   $

—

(1)  We adopted the provisions of ASC 842 as of January 1, 2019. We applied the provisions of ASC 840 in years prior to 2019, which did not produce comparable amounts to disclose for the prior

years presented.

The following table provides supplemental information for the item labeled “Other” in the “Net cash provided by operating activities” section of our

consolidated statements of cash flows:

Loss associated with disposal of assets

Amortization of deferred financing costs

For the Years Ended December 31,

2019

2018

2017

(in thousands)

$

$

57   $

1,072  

1,129   $

73   $

866  

939   $

18

861

879

137

 
 
 
 
 
    
 
 
 
 
 
    
 
 
 
 
 
 
Non-cash activities

In July 2018, our general partner made a $3.4 million non-cash capital contribution of tangible property to us, representing a non-cash investing and

financing activity for cash flow purposes. Refer to Note 13. Transactions with Related Parties for additional discussion of the non-cash contribution.

At December 31, 2019 accounts payable and accrued expenses included $0.2 million of capital expenditures for which cash payment has not been

made. There were no significant balances at December 31, 2018.

We  recorded  $17.3  million  of  right-of-use  lease  assets  and  the  associated  liabilities  on  our  consolidated  balance  sheet  as  of  January  1,  2019,
representing  non-cash  activities  resulting  from  our  adoption  and  implementation  of  ASC  842,  Leases.  See  Note  2.  Summary  of  Significant  Accounting
Pronouncements and Note 8. Leases for further discussion.

22. SUBSEQUENT EVENTS

Distribution to Partners

On January 30, 2020, the board of directors of USD Partners GP LLC, acting in its capacity as our general partner, declared a quarterly cash distribution
payable of $0.37 per unit, or $1.48 per unit on an annualized basis, for the three months ended December 31, 2019. The distribution represents an increase of
$0.0025 per unit or 0.7% over the prior quarter distribution per unit, and is 28.7% over our minimum quarterly distribution per unit. We paid the distribution
on February 19, 2020, to unitholders of record at the close of business on February 10, 2020. We paid $5.5 million  to  our  public  common  unitholders,  an
aggregate of $4.3 million to USDG as the holder of our common units and our subordinated units and $372 thousand to USD Partners GP LLC for its general
partner interest and as holder of the IDRs.

Long-term Incentive Plan

In February 2020, awards of 528,831 Phantom Units vested. The following table provides details of these vested awards:

U.S. domiciled directors and independent consultants

U.S. domiciled employee

Canadian domiciled directors and independent consultants

Phantom Units
Vested

  Common Units Issued (1)

Cash Paid (2)
(in thousands)

37,139  

479,515  

12,177  

528,831  

37,139   $

300,653  

—  

337,792   $

—

—

124

124

(1)  Upon vesting, one common unit is issued for each equity classified Phantom Unit that vests. Employees have the option of using a portion of their vested Phantom Units
to satisfy any tax liability resulting from the vesting and as a result, the actual number of common units issued may be less than the number of Phantom Units that vest.
(2)  Each Liability-classified Phantom Unit that vests is redeemed in cash for an amount equivalent to the closing market price of one of our common units on the vesting date,

which was $10.15.

In February 2020, the board of directors of USD Partners GP LLC, acting in its capacity as our general partner approved the grant of 694,140 Phantom
Units to directors and employees of our general partner and its affiliates under the A/R LTIP. The Phantom Units are subject to all of the terms and conditions
of the Award Agreements. Following the February 2020 Phantom Unit award activity, we have 905,236 Phantom Units available for grant pursuant to the A/R
LTIP. Phantom unit awards generally represent rights to receive our common units or, with respect to awards granted to individuals domiciled in Canada, cash
equal to the fair value of our common units upon vesting. The Award Agreements granted to employees of our general partner generally vest in four equal
annual installments. Awards to independent directors of the board of our general partner vest over a one year period following the grant date.

138

 
 
 
    
Subordinated Units Conversion

On February  20,  2020,  pursuant  to  the  terms  set  forth  in  our  partnership  agreement,  we  converted  the  fifth  and  final  subordinated  unit  tranche  of

2,092,709 subordinated units into our common units upon satisfaction of the conditions established for conversion.

Revolving Credit Facility Activity

Subsequent  to  December  31,  2019,  we  borrowed  an  additional  $10.0 million  and  repaid  $4.0 million  under  the  terms  of  our  existing  $385  million
Revolving  Credit  Facility.  Our  borrowings  under  the  Revolving  Credit  Facility  bear  interest  at  either  a  base  rate  plus  an  applicable  margin  ranging  from
1.00% to 2.00%, or at LIBOR or a comparable or successor rate plus an applicable margin ranging from 2.00% to 3.00%. The Credit Agreement provides for
borrowings of up to $385 million, expandable to $500 million, with lender consent, and expires on November 2, 2022. As of March 2, 2020, we had amounts
outstanding of $226.0 million under the Revolving Credit Facility.

23. QUARTERLY FINANCIAL DATA (Unaudited)

2019 Quarters

Operating revenue

Operating expense

Operating income

Net income

Net income attributable to limited partner ownership interests in USD Partners LP

Net income per limited partner unit, basic and diluted

$

$

$

$

$

$

2018 Quarters  

Operating revenue

Operating expense

Operating income

Net income

Net income attributable to limited partner ownership interests in USD Partners LP

Net income per limited partner unit, basic and diluted

$

$

$

$

$

$

First

Second

Third

Fourth

(in thousands, except per unit amounts)

27,368   $

21,962   $

5,406   $

1,319   $

1,155   $

0.04   $

29,733   $

22,719   $

7,014   $

6,600   $

6,399   $

0.24   $

26,815   $

21,639   $

5,176   $

951   $

774   $

0.03   $

29,577   $

21,330   $

8,247   $

6,712   $

6,498   $

0.25   $

29,894   $

24,163   $

5,731   $

2,106   $

1,888   $

0.08   $

29,586   $

21,764   $

7,822   $

5,928   $

5,719   $

0.21   $

29,579

25,259

4,320

2,140

1,903

0.07

30,330

23,964

6,366

1,892

1,740

0.07

139

 
 
 
 
 
 
   
   
   
   
   
   
Item 9. Changes in and Disagreements with Accountants on Accounting and Financial Disclosure

None.

Item 9A. Controls and Procedures

DISCLOSURE CONTROLS AND PROCEDURES

As required by Rule 13a-15(b) of the Securities Exchange Act of 1934, as amended, or the Exchange Act, we have evaluated, under the supervision and
with  the  participation  of  our  management,  including  our  principal  executive  officer  and  principal  financial  officer,  the  effectiveness  of  the  design  and
operation of our disclosure controls and procedures (as defined in Rules 13a-15(e) and 15d-15(e) under the Exchange Act) as of the end of the period covered
by this report. Our disclosure controls and procedures are designed to provide reasonable assurance that the information required to be disclosed by us in
reports that we file or submit under the Exchange Act is accumulated and communicated to our management, including our principal executive officer and
principal  financial  officer,  as  appropriate,  to  allow  for  timely  decisions  regarding  required  disclosure  and  to  ensure  information  is  recorded,  processed,
summarized and reported within the time periods specified in the rules and forms of the SEC. Based upon that evaluation, our principal executive officer and
principal financial officer concluded that our disclosure controls and procedures were effective as of the end of the period covered by this Annual Report at
the reasonable assurance level.

INTERNAL CONTROL OVER FINANCIAL REPORTING

Attestation Report of the Independent Registered Public Accounting Firm

Report of Independent Registered Public Accounting Firm

Partners of USD Partners LP and Board of Directors of USD Partners GP LLC, as General Partner of USD Partners LP

Houston, Texas

Opinion on Internal Control over Financial Reporting

We have audited USD Partners LP’s (the “Partnership’s”) internal control over financial reporting as of December 31, 2019, based on criteria established in
Internal Control - Integrated Framework (2013) issued by the Committee of Sponsoring Organizations of the Treadway Commission (the “COSO criteria”).
In our opinion, the Partnership maintained, in all material respects, effective internal control over financial reporting as of December 31, 2019, based on the
COSO criteria.

We also have audited, in accordance with the standards of the Public Company Accounting Oversight Board (United States) (“PCAOB”), the consolidated
balance sheets of the Partnership as of December 31, 2019 and 2018, the related consolidated statements of income, comprehensive income, partners’ capital,
and cash flows for each of the three years in the period ended December 31, 2019, and the related notes and our report dated March 5, 2020 expressed an
unqualified opinion thereon.

Basis for Opinion

The Partnership’s management is responsible for maintaining effective internal control over financial reporting and for its assessment of the effectiveness of
internal  control  over  financial  reporting,  included  in  the  accompanying  Management’s  Annual  Report  on  Internal  Control  over  Financial  Reporting.  Our
responsibility  is  to  express  an  opinion  on  the  Partnership’s  internal  control  over  financial  reporting  based  on  our  audit.  We  are  a  public  accounting  firm
registered  with  the  PCAOB  and  are  required  to  be  independent  with  respect  to  the  Partnership  in  accordance  with  U.S.  federal  securities  laws  and  the
applicable rules and regulations of the Securities and Exchange Commission and the PCAOB.

140

We conducted our audit of internal control over financial reporting in accordance with the standards of the PCAOB. Those standards require that we plan and
perform the audit to obtain reasonable assurance about whether effective internal control over financial reporting was maintained in all material respects. Our
audit  included  obtaining  an  understanding  of  internal  control  over  financial  reporting,  assessing  the  risk  that  a  material  weakness  exists,  and  testing  and
evaluating the design and operating effectiveness of internal control based on the assessed risk. Our audit also included performing such other procedures as
we considered necessary in the circumstances. We believe that our audit provides a reasonable basis for our opinion.

Definition and Limitations of Internal Control over Financial Reporting

A company’s internal control over financial reporting is a process designed to provide reasonable assurance regarding the reliability of financial reporting and
the preparation of financial statements for external purposes in accordance with generally accepted accounting principles. A company’s internal control over
financial reporting includes those policies and procedures that (1) pertain to the maintenance of records that, in reasonable detail, accurately and fairly reflect
the  transactions  and  dispositions  of  the  assets  of  the  company;  (2)  provide  reasonable  assurance  that  transactions  are  recorded  as  necessary  to  permit
preparation of financial statements in accordance with generally accepted accounting principles, and that receipts and expenditures of the company are being
made  only  in  accordance  with  authorizations  of  management  and  directors  of  the  company;  and  (3)  provide  reasonable  assurance  regarding  prevention  or
timely detection of unauthorized acquisition, use, or disposition of the company’s assets that could have a material effect on the financial statements.

Because of its inherent limitations, internal control over financial reporting may not prevent or detect misstatements. Also, projections of any evaluation of
effectiveness to future periods are subject to the risk that controls may become inadequate because of changes in conditions, or that the degree of compliance
with the policies or procedures may deteriorate.

/s/ BDO USA, LLP

Houston, Texas

March 5, 2020

Management’s Annual Report on Internal Control Over Financial Reporting

Management  of  the  Partnership  is  responsible  for  establishing  and  maintaining  adequate  internal  control  over  financial  reporting  as  such  term  is

defined in Exchange Act Rule 13a-15(f).

The  Partnership’s  internal  control  over  financial  reporting  is  a  process  designed  under  the  supervision  and  with  the  participation  of  our  principal
executive  and  principal  financial  officers,  and  effected  by  the  board  of  directors  of  our  general  partner,  management  and  other  personnel,  to  provide
reasonable assurance regarding the reliability of financial reporting and the preparation of the financial statements for external purposes in accordance with
generally accepted accounting principles.

Our internal control over financial reporting includes policies and procedures that:

•

•

•

Pertain to the maintenance of records that in reasonable detail accurately and fairly reflect transactions and dispositions of assets of the Partnership;

Provide reasonable assurance that transactions are recorded as necessary to permit preparation of financial statements in accordance with generally
accepted accounting principles, and that receipts and expenditures of the Partnership are being made only in accordance with the authorizations of
the Partnership’s management and directors; and

Provide reasonable assurance regarding prevention or timely detection of unauthorized acquisition, use or disposition of the Partnership’s assets that
could have a material effect on the Partnership’s financial statements.

141

Because  of  its  inherent  limitations,  internal  control  over  financial  reporting  may  not  prevent  or  detect  misstatements.  Also,  projections  of  any
evaluation of effectiveness to future periods are subject to the risk that controls may become inadequate because of changes in conditions, or that the degree
of compliance with our policies or procedures may deteriorate.

Management assessed the effectiveness of the Partnership’s internal control over financial reporting as of December 31, 2019, with the participation of
our principal executive officer and principal financial officer, based on the framework established in Internal Control—Integrated Framework (2013) issued
by  the  Committee  of  Sponsoring  Organizations  of  the  Treadway  Commission,  or  COSO.  Based  on  this  assessment,  management  concluded  that  the
Partnership’s internal control over financial reporting was effective as of December 31, 2019.

Changes in Internal Control Over Financial Reporting

We did not make any changes in our internal control over financial reporting during the three months ended December 31, 2019, that have materially

affected, or are reasonably likely to materially affect, our internal control over financial reporting.

Item 9B. Other Information

None.

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Item 10. Directors, Executive Officers and Corporate Governance

EXECUTIVE OFFICERS AND DIRECTORS

PART III

We  are  managed  by  the  directors  and  executive  officers  of  our  general  partner,  USD  Partners  GP  LLC.  Our  general  partner  is  not  elected  by  our
unitholders and will not be subject to re-election by our unitholders in the future. USD indirectly owns all of the membership interests in our general partner.
Our general partner has a board of directors, and our unitholders are not entitled to elect the directors or directly or indirectly to participate in our management
or operations. Our general partner will be liable, as general partner, for all of our debts (to the extent not paid from our assets), except for indebtedness or
other obligations that are made specifically nonrecourse to it. Whenever possible, we intend to incur indebtedness that is nonrecourse to our general partner.

Our general partner’s board of directors has nine directors, three of whom are independent as defined under the independence standards established by
the  NYSE  and  the  Exchange  Act.  Our  general  partner’s  board  of  directors  has  affirmatively  determined  that  Ms.  O’Hagan,  Mr.  Smith  and  Mr.  Wood  are
independent as described in the rules of the NYSE and the Exchange Act. The NYSE does not require a listed publicly traded partnership, such as ours, to
have  a  majority  of  independent  directors  on  the  board  of  directors  of  our  general  partner,  or  to  establish  a  compensation  committee  or  a  nominating  and
corporate governance committee.

Set forth below is information concerning the directors and executive officers of our general partner, USD Partners GP LLC. Directors are elected by
the sole member of our general partner and hold office until their successors have been elected or qualified or until their earlier death, resignation, removal or
disqualification.  Executive  officers  are  appointed  by,  and  serve  at  the  discretion  of,  the  board  of  directors.  The  following  table  shows  information  for  the
executive officers and directors of USD Partners GP LLC:

Name

Dan Borgen

Josh Ruple

Adam Altsuler

Jay Stanford

Keith Benson

Schuyler Coppedge

Mike Curry

Douglas Kimmelman

Thomas Lane

Jane O’Hagan

Brad Sanders

Stacy Smith

Jeff Wood

Age

58

39

46

56

47

46

66

59

63

56

62

51

49

Position

  Chairman of the Board, Chief Executive Officer and President

  Senior Vice President, Chief Operating Officer

  Senior Vice President, Chief Financial Officer

  Vice President, Chief Accounting Officer

  General Counsel

  Director

  Director

  Director

  Director

  Director

  Director

  Director

  Director

Dan Borgen.    Mr. Borgen has been Chief Executive Officer and President of our general partner since June 2014 and became Chairman of the Board
of our general partner prior to the close of our IPO. Mr. Borgen is a co-founder of USD and its predecessor companies and has served as chairman, CEO and
President of USD since its inception. Additionally, Mr. Borgen served as President of U.S. Right-of-Way Corporation, a private company, since 1993. Prior to
USD, Mr. Borgen worked for 11 years in investment banking in mergers and acquisitions, portfolio management and strategic planning. He began his career
with  a  private  investment  firm  focused  on  the  oil  and  gas  industry.  Mr.  Borgen  has  served  on  the  board  of  directors  of  several  corporations  and  currently
serves  on  the  board  of  Vertex  Energy  Inc.,  an  environmental  services  company  that  recycles  industrial  waste  streams  and  off-specification  commercial
chemical  products.  Active  in  several  community  organizations,  he  is  chair  of  the  USD  Foundation  and  a  trustee  of  Boys  and  Girls  Club  of  America.
Mr. Borgen received a degree in Petroleum Management and Finance from the University of

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Oklahoma. He was recognized by Goldman Sachs as one of 100 Most Intriguing Entrepreneurs in 2013 and was a finalist for Ernst and Young’s 2014 Gulf
Coast  Entrepreneur  of  the  Year.  Mr.  Borgen’s  experience  in  founding  and  leading  USD  and  its  predecessors  provides  the  board  with  broad  business  and
leadership expertise in the financial and energy industries.

Josh Ruple.    Mr. Ruple has been Senior Vice President and Chief Operating Officer of our general partner and for USD since January 1, 2017. In this
role, Mr. Ruple is responsible for all operations and project development activities in support of USD and our commercial development vision, mission and
tactical growth strategies. Mr. Ruple previously served as Vice President, Project Development Group of USD from February 2015 to December 2016 and as
Director, Project Development Group from June 2014 to January 2015. From July 2013 through June 2014, Mr. Ruple was the Senior Development Manager
for TransDevelopment Group, a developer of specialized transportation facilities for shippers and carriers in the rail, highway, and marine cargo industries.
From March 2011 through December 2013, Mr. Ruple was the Vice President Construction Services for Powerhouse Retail Services, a national provider of
retail  construction  and  maintenance  services.  From  August  2004  through  March  2011,  Mr.  Ruple  worked  at  the  BNSF  Railway  in  positions  of  increasing
responsibility,  most  recently  as  Senior  Manager  of  Facility  Development.  Mr.  Ruple  received  a  BS  in  Civil  and  Environmental  Engineering  from  the
University of Utah and is an active member of both professional and public community organizations.  

Adam Altsuler.    Mr. Altsuler has been Senior Vice President and Chief Financial Officer of our general partner since January 1, 2018. Prior to that,
Mr. Altsuler served as Vice President and Chief Financial Officer from June 2014 to December 2017, after joining USD in April 2014 as Vice President,
Finance  with  a  primary  focus  on  corporate  finance,  capital  markets  and  investor  relations  activities.  From  2009  to  2014,  Mr. Altsuler  served  in  various
leadership roles at Eagle Rock Energy Partners, a master limited partnership headquartered in Houston, Texas, most recently serving as Vice President and
Treasurer. Prior to joining Eagle Rock, Mr. Altsuler was an Investment Analyst at Kenmont Investments, an energy-focused hedge fund located in Houston,
where he managed the fund’s master limited partnership investment portfolio from 2007 to 2009. Prior to Kenmont, Mr. Altsuler worked the majority of his
career in investment banking with Donaldson, Lufkin and Jenrette/Credit Suisse First Boston and a boutique investment bank in Dallas and San Francisco.
Mr. Altsuler graduated from the University of Texas at Austin with a BBA in Finance and received an MBA from Rice University, graduating Beta Gamma
Sigma.

Jay Stanford. Mr. Stanford has been the Vice President and Chief Accounting Officer of our general partner since January 1, 2018 and is responsible
for overseeing the accounting, SEC reporting, taxation and cash management functions in support of our Sponsor and the Partnership. Mr. Stanford served as
Senior Director, Accounting and Financial Reporting of the Partnership from July 2017 to December 2017, with responsibility for overseeing the accounting
and SEC reporting functions of the Partnership. Mr. Stanford was also the Director, Financial Reporting for the Sponsor, with responsibility for addressing
technical accounting matters and overseeing SEC reporting activities of USD Partners LP from November 2014 to July 2017. From January 2005 through
November  2014,  Mr.  Stanford  held  various  management  level  positions  with  Enbridge  Energy  Company,  Inc.,  the  general  partner  of  Enbridge  Energy
Partners,  L.P.,  a  master  limited  partnership  headquartered  in  Houston,  Texas,  with  responsibility  for  accounting  and  finance  functions  including:  SEC
reporting, technical accounting matters, strategic planning, budgeting and forecasting, among other duties. Mr. Stanford has also held similar positions with
responsibility  for  financial  accounting  and  reporting  activities  with  other  public  and  private  companies  and  began  his  career  with  KPMG  LLP,  where  he
served  clients  for  five  years  in  the  banking  and  healthcare  industries.  Mr.  Stanford  is  a  Certified  Public  Accountant  and  Certified  Global  Management
Accountant  and  a  two-time  graduate  of  Texas  Tech  University  where  he  received  BBAs  in  Finance  and  Accounting.  Additionally,  Mr.  Stanford  earned  a
Master of Taxation degree from the Graduate Tax Program of the University of Denver’s Sturm College of Law and is an active member of the American
Institute of Certified Public Accountants.

Keith Benson.    Mr. Benson became General Counsel of our general partner and Co-General Counsel of USD in March 2015. From  January  2008
through February 2015, Mr. Benson was a partner with the international law firm of Latham & Watkins LLP in their Houston and San Francisco offices. Mr.
Benson’s practice focused on public company representation, corporate governance, capital markets and mergers & acquisitions, with a focus on midstream
and upstream energy companies, master limited partnerships and real estate investment trusts. From July 2000 through December 2007, Mr. Benson was an
associate with Latham & Watkins LLP and from October 1998 through June 2000

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Mr. Benson was an associate with the law firm of Cahill, Gordon & Reindel LLP. Mr. Benson received a JD with high honors from Rutgers School of Law
and a BA in Political Science from The College of New Jersey.

Schuyler Coppedge.    Mr. Coppedge has been a member of the board of directors of our general partner since September 2016. Mr. Coppedge has
been with Energy Capital Partners since 2005 and currently serves as a Partner and a member of the Investment Committee and Compliance/ESG Committee.
He is involved in all areas of the firm’s investment activities, with a particular emphasis on renewable and fossil generation and environmental and oil field
services. Mr. Coppedge serves on the boards of CIG Logistics, Cormetech Inc., Terra-Gen, LLC, US Development Group, LLC and USD Partners, LP. Mr.
Coppedge previously served on the board of ProPetro Holding Corp., and prior to realization, served on the board of FirstLight Power Enterprises, Inc. Prior
to  joining  Energy  Capital  Partners  in  2005,  Mr.  Coppedge  spent  over  six  years  at  JP  Morgan  in  New  York  and  London  in  the  firm’s  Energy  Investment
Banking  Division.  At  JP  Morgan,  Mr.  Coppedge  was  involved  in  numerous  financing  and  merger  and  acquisition  transactions  across  various  business
segments  of  the  energy  sector.  Mr.  Coppedge  received  a  B.A.  from  Middlebury  College  and  an  M.B.A.  from  the  Wharton  School  at  the  University  of
Pennsylvania. Mr. Coppedge’s substantial knowledge and experience investing in and governing the activities of diverse energy companies makes him well
suited to serve on the board of directors of our general partner.

Mike Curry.    Mr. Curry has been a member of the board of directors of our general partner since June 2014. Mr. Curry is co-founder of USD and its
predecessor companies, and currently serves as Executive Vice President and Head of Finance and Risk for USD. From 2006 to June 2014, Mr. Curry served
as Chief Financial Officer of USD. Throughout the years he has been extensively involved with and directed numerous aspects of USD, including strategic
planning, project development, construction and heading finance. Prior to USD, Mr. Curry served as Treasurer and Chief Accounting Officer for integrated oil
and gas producer An-Son Corp., located in Oklahoma City, from 1982 to 1985 and was employed by Arthur Andersen & Co. from 1978 to 1981. Mr. Curry is
a  Certified  Public  Accountant  and  holds  a  Master’s  Degree  in  Accountancy  from  the  University  of  Illinois.  Mr.  Curry’s  experience  and  involvement  with
USD from its founding to its present day operations, along with his accounting background, bring the board financial, strategic and operational expertise and
leadership.  

Douglas Kimmelman.    Mr. Kimmelman has been a member of the board of directors of our general partner since October 2014. Mr. Kimmelman
established Energy Capital Partners in April 2005 and serves as its Senior Partner. Mr. Kimmelman currently serves on the boards of Calpine Corporation, US
Development Group LLC, USD Partners, LP, Sunnova Energy Corp., and NESCO Holdings LP. Prior to realization, he served on the board of CE2 Carbon
Capital, LLC. He is a member of ECP’s Management Committee and Investment Committee. Prior to founding Energy Capital Partners, Mr. Kimmelman
spent 22 years with Goldman Sachs, starting in 1983 in the firm’s Pipeline and Utilities Department within the Investment Banking Division. He was named a
General Partner of the firm in 1996 and remained exclusively focused on the energy and utility sectors in the Investment Banking Division until 2002 when
he transferred to the firm’s J. Aron commodity group to help form a new business for the firm in becoming an intermediary in electricity trading markets. Mr.
Kimmelman was instrumental in developing the Constellation Power Source concept as the initial entry point for Goldman Sachs as a principal into electricity
markets. Mr. Kimmelman also played a leadership role at Goldman Sachs in building a principal investing business in power generation and related energy
assets. Mr. Kimmelman received a B.A. in Economics from Stanford University and an M.B.A. from the Wharton School at the University of Pennsylvania.
Mr. Kimmelman’s extensive knowledge of the energy industry, together with his substantial experience with public company governance matters make him
well suited to serve on the board of directors of our general partner.

Thomas Lane.     Mr. Lane has been a member of the board of directors of our general partner since October 2014. Mr. Lane is a Vice Chairman of
Energy  Capital  Partners.  He  previously  served  as  a  Partner  of  the  firm  from  its  inception  in  2005  through  the  end  of  2016,  during  which  time  he  was
responsible for establishing and executing on Energy Capital Partners midstream strategy. As Vice Chairman, Mr. Lane leverages his relationships to source
investment opportunities for the firm. Mr. Lane also serves on the boards of US Development Group, LLC, USD Partners, LP, Summit Midstream Partners,
LLC, Summit Midstream Partners, L.P. and Sendero Midstream Partners, LP. Prior to joining Energy Capital Partners in 2005, Mr. Lane worked for 17 years
in the Investment Banking Division at Goldman Sachs. As a Managing Director at Goldman Sachs, Mr. Lane had senior-level coverage responsibility for
electric and gas utilities, independent power companies and midstream energy companies throughout the United States. Mr. Lane has extensive experience in
financing and merger related transactions and helped to source a number of

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Goldman Sachs’ principal investments within the energy sector. He has testified before the House Energy Subcommittee on energy related matters. Mr. Lane
received a B.A. in Economics from Wheaton College and an M.B.A. from the University of Chicago. Mr. Lane’s extensive knowledge and experience with
investing  in  and  governing  midstream  energy  companies  and  public  company  governance  make  him  well  suited  to  serve  on  the  board  of  directors  of  our
general partner.

Jane O’Hagan, ICD.D.    Ms. O’Hagan has been a member of the board of directors of our general partner since October 2014. Ms. O’Hagan is an
independent director of our general partner and serves as Chairman of our conflicts committee and as a member of our audit committee. She also serves as a
Director of Descartes Systems Group and of Pinnacle Renewable Energy. Ms. O’Hagan is a former railway executive and held several management positions
at  Canadian  Pacific  Railroad,  most  recently  as  the  Chief  Marketing  Officer  and  Executive  Vice  President  from  2011  to  2014.  Ms.  O’Hagan  served  as  the
Senior Vice President of Marketing and Sales from 2010 to 2011, Senior Vice President of Strategy & Yield from 2008 to 2009, Vice President of Strategy
and External Affairs from 2005 to 2008, Vice President of Strategy Research and New Market Development from 2003 to 2005 and Assistant Vice President,
Strategy and Research from 2002 to 2003. Ms. O’Hagan holds a bachelor of arts (hons.) and a bachelor of administrative and commercial studies from the
University of Western Ontario. Ms. O’Hagan is also a holder of the Director designation from the Institute of Corporate Directors, which she achieved in June
2016,  and  earned  the  CERT  Certificate  in  Cybersecurity  Oversight  from  the  National  Association  of  Corporate  Directors  in  March  2018.  Ms.  O'Hagan's
extensive experience providing strategic operational and management oversight and direction in the rail industry makes her well suited to serve on the board
of directors of our general partner.

Brad Sanders.        Mr.  Sanders  has  been  a  member  of  the  board  of  directors  of  our  general  partner  since  October  2014.  Mr.  Sanders  joined  USD  as
Executive Vice President, Head of Market Strategy for USD in May 2014 and became Executive Vice President, Chief Commercial Officer in October 2014.
Mr. Sanders’ main focus at USD is working with the leadership team to identify, develop and execute strategic commercial and market opportunities. Prior to
USD,  Mr.  Sanders  spent  32  years  at  Koch  Industries  where  he  was  primarily  responsible  for  building  and  managing  several  of  Koch’s  global  trading
businesses, including businesses in the crude oil, NGLs, distillates, gasoline and gasoline components, and plastics value chains. He is a 1979 graduate of the
University  of  Kansas  with  a  degree  in  business.  He  is  a  current  Trustee  for  KU  Endowment  and  a  current  member  of  the  KU  Endowment  Investment
Committee. Mr. Sanders provides the board with strategic planning and business development leadership and expertise in the energy industry.

Stacy Smith. Mr. Smith has been a member of the board of directors of our general partner since October 2015. Mr. Smith co-founded in February 2013
and remains a partner of Trinity Investment Group, a firm which invests in private equity transactions, public equity securities and other assets. Since 2013,
Mr.  Smith  has  also  served  as  partner  of  SCW  Capital,  LP,  an  equity  hedge  fund  co-founded  by  Mr.  Smith.  In  1997,  Mr.  Smith  co-founded  Walker  Smith
Capital, a Dallas-based small- and mid-cap equity hedge fund, where he was a partner and served as a portfolio manager until December 2012. Mr. Smith
currently serves on the boards of directors of Independent Bank Group, a bank holding company, to which he was elected in February 2013, and WhiteHorse
Finance,  Inc.,  an  externally  managed,  non-diversified,  closed-end  management  investment  company,  to  which  he  was  elected  in  August  2015.  Mr.  Smith
received a bachelor of business administration in finance and accounting from the University of Texas at Austin. Mr. Smith brings extensive experience in
finance  and  corporate  governance  to  the  board  of  directors  of  our  general  partner  in  addition  to  his  knowledge  of  the  energy  and  financial  institution
industries, which makes him well suited to serve on the board of directors of our general partner.

Jeff  Wood.  Mr.  Wood  has  been  a  member  of  the  board  of  directors  of  our  general  partner  since  January  2015  and  serves  as  chairman  of  the  audit
committee and as a member of the conflicts committee. Mr. Wood currently serves as the President and Chief Financial Officer of Black Stone Minerals, L.P.,
a publicly traded MLP and one of the largest oil and natural gas mineral and royalty companies in the United States. Previously, from May 2014 to October
2016, Mr. Wood served as Executive Vice President and Chief Financial Officer of Siluria Technologies, Inc., a leading innovator of process technologies for
the energy and petrochemical industries. Before joining Siluria, Mr. Wood served as Senior Vice President and Chief Financial Officer of Eagle Rock Energy
Partners, LP, a publicly traded MLP, from 2009 through 2014. Prior to that, Mr. Wood was one of the founding principals of the Lehman Brothers’ MLP
Investment Fund, which focused on direct investments in the MLP sector. He also spent 10 years with the Natural Resources Investment Banking team at
Lehman Brothers where he primarily focused on MLP transactions. Mr. Wood began his

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career at Price Waterhouse in its audit and compliance practice. Mr. Wood’s extensive knowledge of MLP organizations and his substantial expertise with
providing financial, strategic and operational leadership makes him well suited to serve on the board of directors of our general partner.

Board Leadership Structure

The chief executive officer of our general partner serves as the chairman of the board. The board of directors of our general partner has no policy with
respect to the separation of the offices of chairman of the board of directors and chief executive officer. Instead, that relationship is defined and governed by
the amended and restated limited liability company agreement of our general partner, which permits the same person to hold both offices. Directors of the
board of directors of our general partner are designated or elected by USD. Accordingly, unlike holders of common stock in a corporation, our unitholders
have  only  limited  voting  rights  on  matters  affecting  our  business  or  governance,  subject  in  all  cases  to  any  specific  unitholder  rights  contained  in  our
partnership agreement.  

Energy Capital Partners Investment in USD

In September 2014, Energy Capital Partners made a significant investment in USD and indicated an intention to invest over an additional $1.0 billion of
equity capital in USD, subject to market and other conditions, to support future growth and expansion plans. In  connection  with  Energy  Capital  Partners’
investment,  USD  repurchased  a  substantial  portion  of  Goldman  Sachs’  investment  in  USD  and  used  the  remaining  proceeds  to  fund  growth  projects  and
strengthen its balance sheet to allow for additional flexibility to pursue its goal of providing energy infrastructure solutions.  

Special Approval Rights of Energy Capital Partners

For  so  long  as  Energy  Capital  Partners  is  able  to  appoint  more  than  one  member  to  USD’s  board  of  directors,  USD  will  not,  and  will  not  permit  its
subsidiaries, including us and our general partner, to take or agree to take any of the following actions (or take or agree to take any action that is reasonably
likely to require or result in any of the following actions) without the affirmative vote of Energy Capital Partners (or, with respect to distributions by us or our
subsidiaries, the members of our general partner’s board of directors appointed by Energy Capital Partners):

•

•

•

•

any sale of USD, any subsidiary of USD, including us, or any of their assets (other than asset sales in the ordinary course of business), including by
way of merger, consolidation, public offering or otherwise, other than to USD or a wholly-owned subsidiary of USD;

(A) any capital contribution or issuance of or redemption of securities of USD or any subsidiary of USD, including us, (B) any issuance of profits
interests in USD, (C) any distributions, except distributions by us and our subsidiaries (which distributions shall be subject to the affirmative vote of
the members of our general partner’s board of directors appointed by Energy Capital Partners), (D) any incurrence or refinancing of indebtedness
(whether  directly,  through  a  guaranty  or  otherwise)  outside  of  the  ordinary  course  of  business,  other  than  any  incurrence  or  refinancing  of
indebtedness by us or our subsidiaries (which incurrences and refinancings shall be subject to the affirmative vote of the members of our general
partner’s board of directors appointed by Energy Capital Partners), (E) any acquisition of securities of any other entity in excess of the lesser of the
consolidated  earnings  before  interest,  taxes,  depreciation  and  amortization  of  USD  Group  LLC  or  $50  million  or  (F)  any  making  of  any  loan  or
advance to any entity other than a wholly-owned subsidiary of USD;

the approval, modification or revocation of any budget or a material deviation from or a material expenditure not part of any such budget (including
any  material  change  with  respect  to  the  nature  of  any  budgeted  capital  expenditure),  other  than  the  approval,  modification  or  revocation  of  any
budget related to us or our subsidiaries (which approvals, modifications or revocations shall be subject to the affirmative vote of the members of our
general partner’s board of directors appointed by Energy Capital Partners);

(A) amending the organizational documents of USD in a manner adverse to the holders of the common membership interests of USD, (B) amending
the organizational documents of any subsidiary of USD, including us, (C) expanding the purpose of any of USD or any of its subsidiaries, including
us, (D) causing or taking any action with the purpose or effect of causing the bankruptcy, liquidation, dissolution or winding up of USD or any of its
subsidiaries, (E) making any material change to USD or any of its subsidiaries’ federal tax

147

treatment,  (F)  entering  into  or  amending  any  transaction  with  any  member  of  USD  or  their  affiliates  or  (G)  creating  or  materially  amending  any
employee incentive plan; or

•

the determination of significant regulatory issues or litigation, including any decision to initiate, forego or settle any material litigation or arbitration,
or the entering into discussions, or negotiations, with any governmental authority in connection with any investigation, proceedings or threatened
investigation or proceedings, or any material inquiry.

Energy Capital Partners’ Right to Sell USD or Its Interests in USD

At any time Energy Capital Partners, upon giving written notice, has the right to compel USD to effect the total sale of Energy Capital Partners’ interests
in USD (an ECP Exit). Such a sale could include an acquisition by the remaining owners of USD of Energy Capital Partners’ interests in USD or an initial
public offering of USD. If the ECP Exit has not been completed within 180 days of the date USD receives notice of Energy Capital Partners’ desire to sell,
Energy Capital Partners shall have the right to compel USD to effect a total sale of USD pursuant to an auction process on terms and conditions determined
by, and in a process managed by, the members of USD’s board of directors that are appointed by Energy Capital Partners, provided that certain conditions in
connection with the sale are met.

Board Role in Risk Oversight

Our corporate governance guidelines provide that the board of directors of our general partner is responsible for reviewing the process for assessing the
major risks facing us and the options for their mitigation. This responsibility is largely satisfied by our audit committee, which is responsible for reviewing
and discussing with management and our registered public accounting firm our major risk exposures and the policies that management has implemented to
monitor such exposures.

Communication with the Board of Directors

A holder of our common units or other interested party who wishes to communicate with the non-management directors or independent directors of our
general partner may do so by writing to: Independent Directors, c/o Corporate Secretary, USD Partners GP LLC, at 811 Main Street, Suite 2800, Houston,
Texas  77002.  Communications  will  be  relayed  to  the  intended  recipient  of  the  board  of  directors  except  in  instances  where  it  is  deemed  unnecessary  or
inappropriate to do so. Any communications withheld will nonetheless be recorded and available for any director who wishes to review them.

CODE OF BUSINESS CONDUCT AND ETHICS AND CORPORATE GOVERNANCE GUIDELINES

We have adopted a Code of Business Conduct and Ethics applicable to the directors and senior officers of our general partner including the principal
executive officer, principal financial officer and principal accounting officer of USD Partners GP LLC. A copy of the Code of Business Conduct and Ethics is
available on our website at www.usdpartners.com. We intend to post on our website any amendments to or waivers of our Code of Business Conduct and
Ethics, within four business days following the date of the amendment or waiver, and we intend to satisfy any disclosure requirements that may arise under
Form 8-K relating to this information through such postings. Additionally, this material is available in print, free of charge, to any person who requests the
information.  Persons  wishing  to  obtain  this  printed  material  should  submit  a  request  to  Corporate  Secretary,  c/o  USD  Partners  GP  LLC,  811  Main  Street,
Suite 2800, Houston, Texas 77002.

We  also  have  a  statement  of  Corporate  Governance  Guidelines  that  sets  forth  the  expectation  of  how  our  board  of  directors  should  function  and  its
position  with  respect  to  key  corporate  governance  issues.  A  copy  of  the  Corporate  Governance  Guidelines  is  available  on  our  website  at
www.usdpartners.com. We post on our website any amendments to our Corporate Governance Guidelines. Additionally, this material is available in print, free
of charge, to any person who requests the information. Persons wishing to obtain this printed material should submit a request to Corporate Secretary, c/o
USD Partners GP LLC, 811 Main Street, Suite 2800, Houston, Texas 77002.

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AUDIT COMMITTEE

Our  general  partner  has  an  audit  committee  currently  comprised  of  three  board  members,  Jane  O’Hagan,  Stacy  Smith  and  Jeff  Wood,  who  are
independent as the term is used in Section 10A of the Exchange Act, and are not relying upon any exemptions from the foregoing independence requirements.
Mr. Wood serves as chair of the committee.

The  audit  committee  provides  independent  oversight  with  respect  to  our  internal  controls,  accounting  policies,  financial  reporting,  internal  audit
function and the report of the independent registered public accounting firm. Our audit committee also has the sole authority for retaining and terminating our
independent  registered  public  accounting  firm,  approving  all  auditing  services  and  related  fees  and  the  terms  thereof,  and  pre-approving  any  non-audit
services to be rendered by our independent registered public accounting firm. Our audit committee is also responsible for confirming the independence and
objectivity  of  our  independent  registered  public  accounting  firm.  Our  independent  registered  public  accounting  firm  has  unrestricted  access  to  our  audit
committee.

The charter of the audit committee is available on our website at www.usdpartners.com. The charter of the audit committee complies with the listing
standards  of  the  NYSE  currently  applicable  to  us.  This  material  is  available  in  print,  free  of  charge,  to  any  person  who  requests  the  information.  Persons
wishing to obtain this printed material should submit a request to Corporate Secretary, c/o USD Partners GP LLC, 811 Main Street, Suite 2800, Houston,
Texas 77002.

The board of directors of our general partner has determined that Jeff Wood, who serves as chairman of the audit committee, qualifies as an “audit
committee  financial  expert”  as  defined  in  Item  407(d)(5)(ii)  of  Regulation  S-K  and  that  each  of  the  members  of  the  audit  committee  are  independent  as
defined by Section 303A of the listing standards of the NYSE.

The  audit  committee  of  our  general  partner  has  established  procedures  for  the  receipt,  retention  and  treatment  of  complaints  we  receive  regarding
accounting,  internal  accounting  controls  or  auditing  matters  and  the  confidential,  anonymous  submission  by  our  employees  of  concerns  regarding
questionable  accounting  or  auditing  matters.  Persons  wishing  to  communicate  with  our  audit  committee  may  do  so  by  writing  to  the  Chairman,  Audit
Committee, c/o USD Partners GP LLC, 811 Main Street, Suite 2800, Houston, Texas 77002.

AUDIT COMMITTEE REPORT

The audit committee of our general partner oversees the Partnership’s financial reporting process on behalf of the board of directors. Management has

the primary responsibility for the financial statements and the reporting process, including the systems of internal controls.

In fulfilling its oversight responsibilities, the audit committee reviewed and discussed with management the audited financial statements contained in

this Annual Report on Form 10-K.

The Partnership’s independent registered public accounting firm, BDO USA, LLP, is responsible for expressing an opinion on the conformity of the
audited consolidated financial statements in accordance with accounting principles generally accepted in the United States of America. The audit committee
reviewed  with  BDO  USA,  LLP  the  firm’s  judgment  as  to  the  quality,  not  just  the  acceptability,  of  the  Partnership’s  accounting  principles  and  such  other
matters as are required to be discussed with the audit committee under the applicable requirements of the Public Company Accounting Oversight Board, or
PCAOB, and the SEC.

The audit committee discussed with BDO USA, LLP the matters required to be discussed by PCAOB Auditing Standard 1301, Communications with
Audit Committees. The audit committee received written disclosures and the letter from BDO USA, LLP required by applicable requirements of the PCAOB
regarding BDO USA, LLP’s communications with the audit committee concerning independence, and has discussed with BDO USA, LLP its independence
from management and the Partnership.

149

Based  on  the  reviews  and  discussions  referred  to  above,  the  audit  committee  recommended  to  the  board  of  directors  that  the  audited  financial

statements be included in this Annual Report on Form 10-K for the year ended December 31, 2019, for filing with the SEC.

Jeff Wood, Chairman

Jane O’Hagan

Stacy Smith

CONFLICTS COMMITTEE

Our general partner has established a conflicts committee to review specific matters that may involve conflicts of interest in accordance with the terms
of our partnership agreement. Our conflicts committee will determine if the resolution of the conflict of interest is fair and reasonable to us. The conflicts
committee will be comprised of at least two members of the board of directors of our general partner. Jane O’Hagan, Stacy Smith and Jeff Wood currently
serve as members of the conflicts committee. The members of our conflicts committee may not be officers or employees of our general partner or directors,
officers, or employees of its affiliates, and must meet the independence and experience standards established by the NYSE and the Exchange Act to serve on
an audit committee of a board of directors. In addition, the members of our conflicts committee may not own any interest in our general partner or any interest
in us or our subsidiaries other than common units or awards under our incentive compensation plan. We anticipate that once appointed to our general partner’s
board of directors, any additional independent members appointed to our audit committee will also serve on the conflicts committee. Any matters approved
by our conflicts committee will be presumed to have been approved in good faith, will be deemed to be approved by all of our partners and will not be a
breach by our general partner of any duties it may owe us or our unitholders.

The charter of the conflicts committee is available on our website at www.usdpartners.com. This material is available in print, free of charge, to any
person who requests the information. Persons wishing to obtain this printed material should submit a request to Corporate Secretary, c/o USD Partners GP
LLC, 811 Main Street, Suite 2800, Houston, Texas 77002.

EXECUTIVE SESSIONS OF NON-MANAGEMENT DIRECTORS

In  accordance  with  our  Corporate  Governance  Guidelines,  the  non-management  members  of  the  board  of  directors  of  our  general  partner  meet  in
executive  session  without  management  participation  at  each  meeting.  In  addition,  the  independent  directors  of  our  general  partner  meet  separately  in
executive  session  at  least  once  per  year.  These  executive  sessions  are  chaired  by  the  chairman  of  the  audit  committee  of  the  board,  who  is  presently  Jeff
Wood, or in his absence by an independent director chosen by the chairman. Interested parties may communicate directly with the independent directors by
submitting a communication in care of Mr. Wood at Corporate Secretary, c/o USD Partners GP LLC, 811 Main Street, Suite 2800, Houston, Texas 77002.

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Item 11. Executive Compensation

General

We do not directly employ any of the persons responsible for managing our business. Our general partner, under the direction of its board of directors,
is responsible for managing our operations and for obtaining the services of the employees that operate our business. However, we sometimes refer to the
employees and officers of our general partner as our employees and officers in this report.

As a “smaller reporting company,” or SRC, as defined under the Securities Exchange Act of 1934, as amended, Rule 12b-2, we are not required to
include  a  Compensation  Discussion  and  Analysis  section  and  have  elected  to  comply  with  the  scaled  disclosure  requirements  applicable  to  SRCs.  This
executive compensation disclosure provides an overview of the executive compensation paid to the named executive officers, or NEOs, identified below for
their services to us in 2019. For 2019, we determined the NEOs to be as follows:

•

•

•

Dan Borgen, Principal Executive Officer and Director;

Adam Altsuler, Senior Vice President and Chief Financial Officer; and

Keith Benson, General Counsel

For 2019 and all prior periods, all of the individuals who served as executive officers of our business were employed by USD or its affiliates other than
us and, in addition to their responsibilities related to our business, also performed services for USD that were unrelated to us. Except with respect to our Class
A units and with respect to awards granted under our A/R LTIP all responsibility and authority for compensation-related decisions for the NEOs remains with
USD and its affiliates, and such decisions are not subject to any approval by us, our general partner’s board of directors or any committees thereof. Other than
the  Class  A  units  or  awards  granted  under  the  A/R  LTIP,  USD  and  its  affiliates  have  the  ultimate  decision-making  authority  with  respect  to  the  total
compensation of their and their subsidiaries’ executive officers and their employees. We incur a fixed annual cash charge for the services rendered to us and
our general partner by the NEO’s, the amount of which is set forth under the terms of the Omnibus Agreement. We also reimburse USD and its affiliates a
separate amount in respect of the salaries and matching contributions associated with 401(k) deferrals of our NEOs based upon the percentage of time that an
NEO estimates is devoted to us and our subsidiaries for a given year. Compensation related to awards granted under the LTIP are presented in the summary
compensation  table  below  at  the  fair  value  of  the  units  on  the  grant  date,  although  for  financial  reporting  purposes,  such  amounts  are  recognized  as
compensation expense ratably over the vesting period, typically a four-year period.

Summary Compensation Table

The following table summarizes total compensation for services rendered to us by the NEOs during 2019 and 2018. All of our NEOs provide services
to both us and USD and its affiliates other than us. Cash amounts paid for services to us (which amounts are shown in the “Salary” column of the table below)
include the fixed fees that we pay to USD for the services of each of the NEOs under the terms of the Omnibus Agreement as well as the portion of the base
salary that is separately allocated to us and reimbursed by us to USD. The NEOs also received other compensation from USD for services unrelated to us.

151

SUMMARY COMPENSATION TABLE

Name and Principal Position
Dan Borgen

Principal Executive Officer and Director

Adam Altsuler

Senior Vice President and Chief Financial Officer

Keith Benson

General Counsel

Salary (1)
($)
444,150

380,700

330,750

333,000

327,994

260,313

Stock
Awards (2)
($)

1,373,746

1,224,219

457,915

384,072

251,379

246,546

Total
($)

1,817,896

1,604,919

788,665

717,072

579,373

506,859

Year
2019

2018

2019

2018

2019

2018

(1) The amounts presented reflect the portion of the fixed fee and variable amounts that we pay to USD for the NEOs’ services under Schedule C of the Omnibus Agreement
and as otherwise set forth under the terms of the Omnibus Agreement, as well as the portion of the base salary that is separately allocated to us and reimbursed by us to
USD.

(2) The amounts presented for 2019 and 2018 represent the grant date fair value of phantom unit awards granted pursuant to our A/R LTIP. Each Phantom Unit is the economic
equivalent  of  one  of  our  common  units.  Awards  vest  in  four  equal  annual  installments  commencing  on  the  one-year  anniversary  of  the  grant  date,  subject  to  vesting
acceleration in certain circumstances as discussed below under the heading “Potential Payments Upon Termination or Change in Control.” The value attributed to each
Phantom Unit is $11.37 for the phantom unit awards granted in 2019 and $11.55 for the phantom unit awards granted in 2018, in each case representing the closing price of
our common units as stated on the NYSE on February 15, 2019 and February 16, 2018, respectively. For additional information about our phantom unit awards and the A/R
LTIP,  refer  to  the  discussion  below  as  well  as  the  discussion  included  in  Note  20.  Unit  Based  Compensation  of  our  financial  statements  included  in  Part  II,  Item  8,
Financial Statements and Supplementary Data of this Annual Report.

Narrative Disclosure to Summary Compensation Table

Neither  we,  our  general  partner,  nor  any  of  our  subsidiaries  have  employees.  USD  is  contractually  obligated  to  provide  its  and  its  subsidiaries’
employees and other personnel necessary for us to conduct our operations. This includes all of our executive officers. The executive officer compensation is
paid by USD or its applicable affiliate. We pay USD a fixed and variable amounts each month for the services of our executive officers.

Our general partner’s board of directors has adopted the A/R LTIP on our behalf. Substantially all officers, employees, consultants and directors of our
general partner and its affiliates who contribute to our business are eligible to receive awards under the A/R LTIP. Awards under the A/R LTIP are approved
by our general partner’s board of directors. Our general partner’s board of directors has granted awards of Phantom Units pursuant to the A/R LTIP, which
represent the right to receive our common units or, in the discretion of the board, cash payments based on the value of our common units. The following table
sets forth the Phantom Units granted to our NEOs for the respective year:

Name

Dan Borgen

Adam Altsuler

Keith Benson

Year
2019

2018

2019

2018

2019

2018

Phantom Units Awarded

120,822

105,993

40,274

33,253

22,109

21,346

The  Phantom  Units  vest  in  four  equal  annual  installments  over  a  four-year  period,  subject  to  accelerated  vesting  in  certain  circumstances.  For  more
information about accelerated vesting of the Phantom Units, see the discussion below under the heading “Potential Payments Upon Termination or Change in
Control.” In addition, the phantom unit awards to our NEOs were granted with corresponding distribution equivalent rights, or DERs, which represent the
right

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to receive payments in an amount equal to any distributions made by us with respect to our common units underlying the Phantom Units. The distribution
equivalent rights remain outstanding until the earlier of the vesting or forfeiture of the related Phantom Unit.

Prior to our IPO, our general partner also granted Class A units in us to certain of our NEOs and certain other key employees as discussed below.

Class A Unit Awards

In August 2014, our general partner’s board of directors granted Class A unit awards to our NEOs as follows: Mr. Borgen - 55,000 Class A units and
Mr.  Altsuler  -  20,000  Class  A  units.  The  Class  A  units  were  limited  partner  interests  in  our  partnership  that  entitled  the  holder  to  distributions  that  were
equivalent to the distributions paid in respect of our common units (excluding any arrearages of unpaid minimum quarterly distributions from prior quarters).
The Class A units vested in four equal annual installments over a four-year period (each of which we refer to as a Class A Vesting Tranche), subject to us
growing  our  annualized  distributions  each  year.  If  we  did  not  achieve  positive  distribution  growth  in  any  of  these  years,  the  Class  A  units  in  the  Class  A
Vesting Tranche that would otherwise vest for that year would have been forfeited.

The Class A units converted into our common units upon vesting. The number of common units into which the Class A units converted upon vesting
was tied to the level of our distribution growth for the applicable year. If the Class A units in a Class A Vesting Tranche vest, but we grow our annualized
distribution  by  less  than  10%,  the  Class  A  units  in  that  Class  A  Vesting  Tranche  converted  into  common  units  one-for-one.  If  we  grew  our  annualized
distribution by 10% or more, the Class A units in that Class A Vesting Tranche converted into common units based on a conversion factor of 1.25 for the first
Class A Vesting Tranche, 1.5 for the second Class A Vesting Tranche, 1.75 for the third Class A Vesting Tranche and 2.0 for the last Class A Vesting Tranche.
In February 2016, 2017, 2018 and 2019, the first, second, third and fourth Class A Vesting Tranches vested and were converted into common units on a one-
for-one basis for 2019, 2018 and 2017 and a one and a half-for-one basis for 2016.

Outstanding Equity Awards at Fiscal Year-End 2019

The following table shows outstanding equity awards for our NEOs. All values are shown as of December 31, 2019.

Name

Number of shares or units of stock that have
not vested (#) (1)

Market value of shares or units of stock that
have not vested
($) (2)

Stock Awards

Phantom Units

261,535

81,398

60,660

2,591,812

806,654

601,141

Dan Borgen

Adam Altsuler

Keith Benson

(1)  Each Phantom Unit represents the economic equivalent of one of our common units, and awards vest in four equal annual installments commencing on approximately the
one-year  anniversary  of  the  issuance  date,  subject  to  continued  employment.  Refer  to  the  discussion  included  in  Note  20.  Unit  Based  Compensation of  our  financial
statements included in Part II, Item 8, Financial Statements and Supplementary Data of this Annual Report.

(2)  The value is based on the closing market price of a common unit on December 31, 2019, the last trading day for 2019, of $9.91 per unit.

Potential Payments Upon Termination or Change in Control

None of our NEOs have entered into any employment, severance or similar agreements in relation to their services to us or our general partner and,
except with respect to the Phantom Units issued pursuant to our A/R LTIP, as of December 31, 2019, there were no arrangements pursuant to which our NEOs
would receive any payments or benefits in connection with a change in control of us.

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The phantom unit awards granted pursuant to the A/R LTIP generally contemplate that the individual grants of Phantom Units will vest in four equal
annual installments based on the grantee’s continued employment through the vesting dates, subject to acceleration upon (i) the grantee’s death or disability,
(ii) upon a change in control of the Partnership or our general partner that also results in the grantee’s involuntary termination, or (iii) upon termination of the
grantee’s service without cause (as defined in the A/R LTIP) or resignation for good reason, in either case following a change in control of the Partnership or
our  general  partner.  The  board  of  directors  of  our  general  partner  may  also  accelerate  the  vesting  of  the  Phantom  Units  in  its  discretion  within  60  days
following the grantee’s termination for any reason other than cause.

“Cause” when defined for purposes of the Phantom Units generally means (i) any material failure to perform the executive’s duties and responsibilities
under any written agreement between the executive and USD or its affiliates; (ii) any act of fraud, embezzlement, theft or misappropriation by the executive
relating to USD, us or any of our affiliates; (iii) the executive’s commission of a felony or a crime involving moral turpitude; (iv) any gross negligence or
intentional misconduct on the part of the executive in the conduct of the executive’s duties and responsibilities with USD or its affiliates or which adversely
affects the image, reputation or business of USD, us or our affiliates; or (v) any material breach by the executive of any agreement between USD or any of its
affiliates, on the one hand, and the executive on the other.

2019 Director Compensation Table

As a partnership, we are managed by our general partner. The members of the board of directors of our general partner perform for us the functions of a
board of directors of a business corporation. Our general partner has implemented a director compensation policy for members of the board of directors who
are not officers, employees or paid consultants or advisors of us or our general partner or USD or Energy Capital Partners. We are allocated 100% of the
director compensation of such board members. Such directors are expected to receive an annual compensation package valued at approximately $200,000.
For 2019, approximately one-third of this amount was paid in the form of a cash retainer and the remaining two-thirds was provided in the form of a unit
based award (with distribution equivalent rights) under the A/R LTIP. The Phantom Units (with distribution equivalent rights) granted to the directors are
subject to the same terms and conditions, including vesting acceleration, as the grants to our NEOs, except the awards vest over a one-year period (instead of
a  four-year  period)  following  the  grant  date.  Such  directors  also  receive  reimbursement  for  out-of-pocket  expenses  associated  with  attending  board  or
committee meetings and director and officer liability insurance coverage. Officers, employees or paid consultants or advisors of us or our general partner or
its affiliates who also serve as directors do not receive additional compensation for their service as directors. All directors are indemnified by us for actions
associated with being a director to the fullest extent permitted under Delaware law and are reimbursed for all expenses incurred in attending to his or her
duties as a director.

Jane O’Hagan

Stacy Smith

Jeff Wood

DIRECTOR COMPENSATION

Name

Fees Earned or
Paid in Cash (1)
($)
66,667

66,667

66,667

Stock Awards (2)
($)

Total (3)
($)

138,452

138,452

138,452

205,119

205,119

205,119

(1)  The amounts reflected in this column represent the director cash retainer payments made during 2019.
(2)  Each of Ms. O’Hagan, Mr. Smith and Mr. Wood were granted 12,177 phantom unit awards on February 16, 2019, pursuant to our A/R LTIP, with a fair value of $11.37 per
unit, which amount is based on the closing price of one of our common units on the day of the grant. At December 31, 2019, Ms. O’Hagan, Mr. Smith and Mr. Wood each
held 12,177 Phantom Units. Each of the Phantom Units granted will fully vest on the one-year anniversary of the grant date.

(3)  The  difference  between  the  expected  annual  compensation  package  valued  at  approximately  $200,000  discussed  above  and  the  total  Director  Compensation  amount

presented herein is due to the change in the unit price between the determination date for the Unit Awards and the grant date.

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Compensation Committee Interlocks and Insider Participation

As discussed above, the board of directors of our general partner is not required to maintain and does not maintain a compensation committee.

Mr. Borgen and Mr. Sanders do not participate in the determination of their respective compensation as officers of our general partner.

Item 12. Security Ownership of Certain Beneficial Owners and Management and Related Stockholder Matters

The following tables set forth information with respect to persons known to us to be the beneficial owners of more than 5% of any class of our units, and
NEOs, directors and executive officers of USD Partners GP LLC as a group. The amounts and percentage of units beneficially owned are reported on the
basis of regulations of the SEC governing the determination of beneficial ownership of securities. Under the rules of the SEC, a person is deemed to be a
“beneficial owner” of a security if that person has or shares “voting power,” which includes the power to vote or to direct the voting of such security, or
“investment power,” which includes the power to dispose of or to direct the disposition of such security. The percentage of units beneficially owned is based
on a total of 26,842,393 common units outstanding. In computing the number of common units beneficially owned by a person and the percentage ownership
of that person, common units subject to options or warrants held by that person that are currently exercisable or exercisable within 60 days of February 28,
2020, if any, are deemed outstanding, but are not deemed outstanding for computing the percentage ownership of any other person. Except as indicated by
footnote, the persons named in the table below have sole voting and investment power with respect to all units shown as beneficially owned by them, subject
to community property laws where applicable.

SECURITY OWNERSHIP OF CERTAIN BENEFICIAL OWNERS

The following table sets forth information as of February 28, 2020, with respect to persons, other than the NEOs, directors and executive officers of

USD Partners GP LLC as a group, known to us to be the beneficial owners of more than 5% of any class of our units:

Name of Beneficial Owner (1)
US Development Group, LLC (2)

USD Holdings LLC (3)

ECP ControlCo, LLC (4)

Tortoise Capital Advisors, L.L.C. (5)

Common Units
Beneficially Owned

Percentage of Total
Common Units Beneficially
Owned

11,557,090  

5,258,476  

5,686,088  

1,888,997  

43.1%

19.6%

21.2%

7.0%

(1) Unless otherwise indicated, the address for each beneficial owner is 811 Main Street, Suite 2800, Houston, Texas 77002.
(2) USD, through its 100% ownership of USD Group LLC (which owns 100% of our general partner), is the indirect owner of 11,557,090 common units and 461,136 general
partner units. USD is the parent company of USD Group LLC who holds the common units directly and is the sole owner of the member interests of our general partner.
USD  Group  LLC  is  managed  by  USD.  USD  is  managed  by  a  seven  person  board  of  directors  that  includes  Dan  Borgen,  Mike  Curry,  James  Hutson-Wiley,  Schuyler
Coppedge, Douglas Kimmelman, Thomas Lane and Alan Crown. The board of directors of USD exercises voting and dispositive power over the units held by USD Group
LLC,  and  acts  by  majority  vote.  Please  read  Item  13.  Certain  Relationships  and  Related  Transactions,  and  Director  Independence. Messrs.  Borgen,  Coppedge,  Curry,
Hutson-Wiley, Kimmelman, Lane and Crown are thus not deemed to have beneficial ownership of the units owned by USD Group LLC.

(3)  USD Holdings, LLC is a 45.5% member of USD and may therefore be deemed to indirectly beneficially own 5,258,476 common units and 209,817 general partner units
held  by  USD.  As  holders  of  a  45.5%  voting  interest  of  USD,  USD  Holdings,  LLC  is  entitled  to  elect  three  directors  of  USD.  USD  Holdings  LLC  is  managed  by  its
managers,  Mike  Curry,  Dan  Borgen  and  James  Hutson-Wiley.  Neither  Messrs.  Curry,  Borgen  nor  Hutson-Wiley  are  deemed  to  beneficially  own,  and  they  disclaim
beneficial ownership of, any common units beneficially owned by our general partner or USD.

(4)  Based solely on the Form 4 filed jointly on February 24, 2020 by USD Group LLC (“USDG”) and related entities. Energy Capital Partners III, LP, Energy Capital Partners
III-A,  LP,  Energy  Capital  Partners  III-B  (USD  IP),  LP,  and  Energy  Capital  Partners  III-C  (USD  IP),  LP  (collectively,  the  “ECP  Funds”)  are  members  of  USD.  ECP
ControlCo, LLC (“ECP ControlCo”), Energy Capital Partners III, LLC (“ECP”), Energy Capital Partners GP III, LP (“ECP GP”) and the ECP Funds collectively hold a
49.2% interest

155

 
 
 
 
 
 
    
in USD, and may therefore be deemed to indirectly beneficially own 5,686,088 common units and 226,879 general partner units held directly by USD. ECP ControlCo is
the managing member of ECP, which is the general partner of ECP GP, which is the general partner of each of the ECP Funds, and, as such, each of ECP Control Co, ECP
GP and ECP may be deemed to beneficially own the securities beneficially owned by the ECP Funds. Douglas Kimmelman, Thomas Lane, Andrew Singer, Peter Labbat,
Tyler Reeder and Rahman D’Argenio are the managing members of ECP ControlCo and share the power to vote and dispose of the securities beneficially owned by ECP
Control  Co.  Each  of  Messrs.  Kimmelman,  Lane,  Singer,  Labbat,  Reeder  and  D’Argenio  disclaim  any  beneficial  ownership  of  the  units  beneficially  owned  by  ECP
ControlCo. As holders of a 49.2% voting interest of USD, the ECP Funds are entitled to elect three directors of USD and have veto rights over certain actions by USD and
its subsidiaries. Douglas Kimmelman, Thomas Lane and Schuyler Coppedge are each a member of the board of directors of our general partner as representatives of the
ECP Funds. The business address for each of the entities and individuals listed in this footnote (other than USD) is 40 Beechwood Road, Summit, New Jersey, 07901.
(5)  Based solely on a Schedule 13G/A filed by Tortoise Capital Advisors, L.L.C. (“TCA”) on February 14, 2020. The Schedule 13G/A states that TCA has sole voting power
over 70 of the common units and shared dispositive power over 1,888,997 of the common units. The Schedule 13G/A states that TCA, an investment adviser registered
under Section 203 of the Investment Advisers Act of 1940, is the beneficial owner of the 1,888,997 common units as a result of acting as investment adviser to various
clients. However, TCA disclaims beneficial ownership of such common units. The address of TCA is 5100 W 115th Place, Leakwood, KS 66211.

SECURITY OWNERSHIP OF MANAGEMENT AND DIRECTORS

The following table sets forth information as of February 28, 2020, with respect to each class of our units beneficially owned by the NEOs, directors and

executive officers of USD Partners GP LLC as a group:

Name of Beneficial Owner (1)
Dan Borgen (2)

Schuyler Coppedge

Mike Curry (3)

Douglas Kimmelman

Thomas Lane
Jane O’Hagan (4)
Brad Sanders (5)

Stacy Smith (6)

Jeff Wood (7)

Adam Altsuler (8)

Keith Benson (9)

Common Units
Beneficially Owned

Percentage of Total
Common Units
Beneficially Owned

264,337  

—  

65,694  

50,000  

50,000  

—  

293,497  

103,421  

65,024  

64,919  

55,130  

*

*

*

*

*

*

1.1%

*

*

*

*

All Directors and Executive Officers as a group (13 Persons) (10)

1,095,124  

4.1%

Less than 1.0%.

*
(1)  Unless otherwise indicated, the address for each beneficial owner is 811 Main Street, Suite 2800, Houston, Texas 77002.
(2)  Excludes 297,160 Phantom Units granted under the A/R LTIP. The Phantom Units generally vest in equal annual installments over a four year service

period commencing on the one year anniversary of the grant.

(3)  Excludes 62,297 Phantom Units granted under the A/R LTIP. The Phantom Units generally vest in equal annual installments over a four year service

period commencing on the one year anniversary of the grant.

(4)  Excludes 13,136 Phantom Units granted under the A/R LTIP. The Phantom Units will vest on February 16, 2021.
(5)  Excludes 171,588 Phantom Units granted under the A/R LTIP. The Phantom Units generally vest in equal annual installments over a four year service

period commencing on the one year anniversary of the grant.

(6)  Excludes 13,136 Phantom Units granted under the A/R LTIP. The Phantom Units will vest on February 16, 2021.
(7)  Excludes 13,136 Phantom Units granted under the A/R LTIP. The Phantom Units will vest on February 16, 2021.
(8)  Excludes 93,169  Phantom  Units  granted  under  the  A/R  LTIP.  The  Phantom  Units  vest  in  equal  annual  installments  over  a  four  year  service  period

commencing on the one year anniversary of the grant.

(9)  Excludes 61,854 Phantom Units granted under the A/R LTIP. The Phantom Units generally vest in equal annual installments over a four-year service

period commencing on the one-year anniversary of the grant.

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(10)  Excludes 866,874 Phantom Units granted under the A/R LTIP.

SECURITIES AUTHORIZED FOR ISSUANCE UNDER EQUITY COMPENSATION PLANS

The following table provides information as of December 31, 2019, with respect to common units that may be issued under the A/R LTIP:

Plan category

  Equity compensation plans approved by security holders
Equity compensation plans not approved by security
holders

  Total

Number of securities to be
issued upon exercise of
outstanding options, warrants
and rights (1)

Weighted average exercise price
of outstanding options, warrants
and rights

Number of securities remaining
available for future issuance under
equity compensation
plans (2)

1,346,480  

—

1,346,480  

—  

—

—  

1,406,883

—

1,406,883

(1)  Reflects  the  number  of  previously  granted  equity  incentive  awards,  representing  Phantom  Units  outstanding  at  December  31,  2019,  issued  pursuant  to  the  A/R  LTIP  and  includes  56,797
Phantom Units issued pursuant to the LTIP that upon vesting entitle the participant to receive cash for an amount equivalent to the closing market price for one of our common units on the
vesting date multiplied by the number of vested Phantom Units.

(2)  Reflects the remaining equity incentive awards, representing Phantom Units that are convertible into common units available for issuance pursuant to the A/R LTIP.

Item 13. Certain Relationships and Related Transactions, and Director Independence

As  of  February  28,  2020,  USD  Group  LLC  owns  11,557,090  common  units  representing  an  aggregate  43.1%  limited  partner  interest  in  us.  As  of
December 31, 2019, a value of up to $10.0 million of these common units were pledged as collateral under USDG’s letter of credit facility. In addition, as of
February 28, 2020, our general partner owns 461,136 general partner units representing a 1.7% general partner interest in us.

CASH DISTRIBUTIONS

During the year ended December 31, 2019, we paid the following aggregate cash distributions to USDG as a holder of our common units and all of our

subordinated units and to USD Partners GP LLC for their general partner interest.

Distribution
Declaration Date

Record Date

Distribution
Payment Date

Amount Paid to
 USDG

Amount Paid to
USD Partners GP
LLC

January 31, 2019

  February 11, 2019

  February 19, 2019

  $

April 26, 2019

  May 7, 2019

  May 15, 2019

July 24, 2019

  August 6, 2019

  August 14, 2019

October 24, 2019

  November 4, 2019

  November 14, 2019

(in thousands)

4,161   $

4,189  

4,218  

4,247  

  $

16,815   $

285

308

329

351

1,273

CONFLICTS OF INTEREST

Conflicts of interest exist and may arise in the future as a result of the relationships between our general partner and its affiliates, including USD, on the
one hand, and us and our limited partners, on the other hand. The directors and officers of our general partner have fiduciary duties to manage our general
partner  in  a  manner  beneficial  to  USD.  At  the  same  time,  our  general  partner  has  a  duty  to  manage  our  partnership  in  a  manner  it  believes  is  in  our  best
interests. Our partnership agreement specifically defines the remedies available to unitholders for actions taken that, without these defined liability standards,
might constitute breaches of fiduciary duty under applicable Delaware law. The

157

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
   
   
 
 
 
 
 
   
   
Delaware  Revised  Uniform  Limited  Partnership  Act,  which  we  refer  to  as  the  Delaware  Act,  provides  that  Delaware  limited  partnerships  may,  in  their
partnership agreements, expand, restrict or eliminate the fiduciary duties otherwise owed by the general partner to the limited partners and the partnership.

Whenever a conflict arises between our general partner or its affiliates, on the one hand, and us or our limited partners, on the other hand, the resolution
or course of action in respect of such conflict of interest shall be permitted and deemed approved by all our limited partners and shall not constitute a breach
of our partnership agreement, of any agreement contemplated thereby or of any duty, if the resolution or course of action in respect of such conflict of interest
is:

•

•

approved by the conflicts committee of our general partner, although our general partner is not obligated to seek such approval; or

approved  by  the  holders  of  a  majority  of  the  outstanding  common  units,  excluding  any  such  units  owned  by  our  general  partner  or  any  of  its
affiliates, although our general partner is not obligated to seek such approval.

Our general partner may, but is not required to, seek the approval of such resolutions or courses of action from the conflicts committee of its board of
directors  or  from  the  holders  of  a  majority  of  the  outstanding  common  units  as  described  above.  If  our  general  partner  does  not  seek  approval  from  the
conflicts committee or from holders of common units as described above and the board of directors of our general partner takes or declines the course of
action taken with respect to the conflict of interest, then it will be presumed that, in making its decision, the board of directors of our general partner acted in
good faith, and in any proceeding brought by or on behalf of us or any of our unitholders, the person bringing or prosecuting such proceeding will have the
burden of overcoming such presumption. Unless the resolution of a conflict is specifically provided for in our partnership agreement, the board of directors of
our  general  partner  or  the  conflicts  committee  of  the  board  of  directors  of  our  general  partner  may  consider  any  factors  they  determine  in  good  faith  to
consider when resolving a conflict. An independent third-party is not required to evaluate the resolution. Under our partnership agreement, a determination,
other action or failure to act by our general partner, the board of directors of our general partner or any committee thereof (including the conflicts committee)
will be deemed to be “in good faith” unless our general partner, the board of directors of our general partner or any committee thereof (including the conflicts
committee) believed such determination, other action or failure to act was adverse to the interests of the partnership. Please read Item 10. Directors, Executive
Officers and Corporate Governance—Conflicts Committee for information about the conflicts committee of our general partner’s board of directors.

REVIEW, APPROVAL OR RATIFICATION OF TRANSACTIONS WITH RELATED PERSONS

The board of directors of our general partner have adopted a related party transactions policy that provides that the board of directors of our general
partner or its authorized committee will review on at least a quarterly basis all related person transactions that are required to be disclosed under SEC rules
and,  when  appropriate,  initially  authorize  or  ratify  all  such  transactions.  In  the  event  that  the  board  of  directors  of  our  general  partner  or  its  authorized
committee  considers  ratification  of  a  related  person  transaction  and  determines  not  to  so  ratify,  the  code  of  business  conduct  and  ethics  provides  that  our
management will make all reasonable efforts to cancel or annul the transaction.

The related party transactions policy provides that, in determining whether or not to recommend the initial approval or ratification of a related person
transaction, the board of directors of our general partner or its authorized committee should consider all of the relevant facts and circumstances available,
including (if applicable) but not limited to: (i) whether there is an appropriate business justification for the transaction; (ii) the benefits that accrue to us as a
result of the transaction; (iii) the terms available to unrelated third parties entering into similar transactions; (iv) the impact of the transaction on a director’s
independence (in the event the related person is a director, an immediate family member of a director or an entity in which a director or an immediate family
member  of  a  director  is  a  partner,  shareholder,  member  or  executive  officer);  (v)  the  availability  of  other  sources  for  comparable  products  or  services;
(vi) whether it is a single transaction or a series of ongoing, related transactions; and (vii) whether entering into the transaction would be consistent with the
code of business conduct and ethics.

TRANSACTIONS WITH RELATED PERSONS

We believe the terms and provisions of our related party agreements are fair to us; however, such agreements and transactions may not be as favorable

to us as we could have obtained from unaffiliated third parties. Refer to Part

158

II, Item 8. Financial Statements and Supplementary Data, Note 13. Transactions with Related Parties for a comprehensive discussion and disclosure of our
transactions with related parties.

Omnibus Agreement Transactions

Pursuant to the Omnibus Agreement entered into by us with USD and USD Group LLC, we incurred charges of $8.1 million, which are recorded in

“Selling, general and administrative — related party” in our consolidated statements of income.

The Omnibus Agreement also addresses the following matters:

•

•

•

our  right  of  first  offer  to  acquire  certain  USD-retained  Hardisty  development  projects,  as  well  as  other  additional  midstream  infrastructure  that
USD and USDG may construct or acquire in the future;

our obligation to reimburse USDG for any out-of-pocket costs and expenses incurred by USDG in providing general and administrative services
(which  reimbursement  is  in  addition  to  certain  expenses  of  our  general  partner  and  its  affiliates  that  are  reimbursed  under  our  partnership
agreement), as well as any other out-of-pocket expenses incurred by USDG on our behalf; and,

an  indemnity  by  USD  for  certain  environmental  and  other  liabilities,  and  our  obligation  to  indemnify  USD  and  its  subsidiaries  for  events  and
conditions associated with the operation of our assets that occur after the closing of our IPO and for environmental liabilities related to our assets
to the extent USD is not required to indemnify us.

So long as USD controls our general partner, the Omnibus Agreement will remain in full force and effect. If USD ceases to control our general partner,
either party may terminate the Omnibus Agreement, provided that the indemnification obligations will remain in full force and effect in accordance with their
terms.

From  time  to  time,  in  the  ordinary  course  of  business,  USD  and  its  affiliates  may  receive  vendor  payments  or  other  amounts  due  to  us  or  our
subsidiaries. In addition, we may make payments to vendors and other unrelated parties on behalf of USD and its affiliates for which they routinely reimburse
us.

Related Party Transactions with USD and affiliates

Marketing Services Agreement

In connection with our purchase of the Stroud terminal, we entered into a Marketing Services Agreement, with USD Marketing LLC, or USDM, a
wholly-owned subsidiary of USDG, in May 2017, whereby we granted USDM the right to market the capacity at the Stroud terminal in excess of the original
capacity of our initial customer in exchange for a nominal per barrel fee. USDM is obligated to fund any related capital costs associated with increasing the
throughput or efficiency of the terminal to handle additional throughput. Upon expiration of our contract with the initial Stroud customer in June 2020, the
same marketing rights will apply to all throughput at the Stroud terminal in excess of the throughput necessary for the Stroud terminal to generate Adjusted
EBITDA that is at least equal to the average monthly Adjusted EBITDA derived from the initial Stroud customer during the 12 months prior to expiration.
We also granted USDG the right to develop other projects at the Stroud terminal in exchange for the payment to us of market-based compensation for the use
of our property for such development projects. Any such development projects would be wholly-owned by USDG and would be subject to our existing right
of first offer with respect to midstream projects developed by USDG. Payments made under the Marketing Services agreement during the periods presented in
this report are discussed below under the heading “Related Party Revenue and Deferred Revenue.” 

Hardisty Terminalling Services Agreement and Shared Facilities Agreement

We entered into a terminal services agreement with USD Terminals Canada II ULC, or USDTC II, a wholly-owned Canadian subsidiary of USDG,
during the third quarter of 2019, whereby Hardisty South owned by USDTC II, will provide terminalling services for a third-party customer of our Hardisty
terminal for contracted capacity that exceeds the transloading capacity currently available, if needed.

159

In  addition,  our  wholly-owned  subsidiary  USD  Terminals  Canada  ULC,  or  USDTC,  facilitates  the  provision  of  services  on  behalf  of  USDTC  II
pursuant  to  the  terms  of  a  shared  facilities  agreement,  which  includes  all  subcontracted  railcar  loading,  operating,  maintenance,  pipeline  and  management
services for the entire Hardisty terminal, including Hardisty South. USDTC passes through a proportionate amount of the cost of such services to USDTC II.
Our financial statements only reflect the cost incurred by USDTC.

Related Party Revenue and Deferred Revenue

We have agreements to provide terminalling and fleet services for USDM with respect to our Hardisty terminal and terminalling services with respect

to our Stroud terminal, which also include reimbursement to us for certain out-of-pocket expenses we incur.

In  connection  with  our  acquisition  of  the  Stroud  terminal,  USDM  assumed  the  rights  and  obligations  for  additional  terminalling  capacity  at  our
Hardisty terminal from another customer in June 2017 to facilitate the origination of crude oil barrels by the Stroud customer from our Hardisty terminal for
delivery to the Stroud terminal. As a result of USDM assuming these rights and obligations and in order to accommodate the needs of the Stroud customer,
the  contracted  term  for  the  capacity  held  by  USDM  at  our  Hardisty  terminal  was  extended  from  June  30,  2019  to  June  30,  2020.  USDM  controlled
approximately 25%  of  the  available  monthly  capacity  of  the  Hardisty  terminal  at  December  31,  2019.  The  terms  and  conditions  of  these  agreements  are
similar to the terms and conditions of agreements we have with other parties at the Hardisty terminal that are not related to us.

In  connection  with  our  purchase  of  the  Stroud  terminal,  we  also  entered  into  a  Marketing  Services  Agreement  with  USDM  as  discussed  above.
Pursuant to the terms of the agreement, we receive a fixed amount per barrel from USDM in exchange for marketing the additional capacity available at the
Stroud  terminal.  We  also  received  revenue  for  providing  additional  terminalling  services  at  our  Hardisty  terminal  to  USDM  pursuant  to  the  terms  of  its
existing agreements with us. Additionally, effective January 2019, we entered into a six month terminalling services agreement with USDM at our Casper
terminal to maximize utilization of available terminalling and storage capacity by offering these services to customers on an uncommitted basis at current
market rates. This agreement automatically renews for successive periods of six months on an evergreen basis unless otherwise canceled by either party. We
include  amounts  received  pursuant  to  this  arrangement  as  revenue  in  the  table  below  under  “Terminalling  services  —  related  party”  in  our  consolidated
statements of income. Additionally, we received revenue from USDM for the lease of 200 railcars pursuant to the terms of an existing agreement with us,
which is included in “Fleet leases — related party” on our consolidated statements of income.

Development Rights and Cooperation Agreement

Our subsidiary that owns the Hardisty terminal entered into a Development Rights and Cooperation Agreement with USD pursuant to which:

•

•

•

•

•

our subsidiary granted to USD the right to develop, construct and operate certain development projects in, on, over, across and under the property
on which the Hardisty terminal is located, including the exclusive right to develop and construct such expansions for a period of seven years after
the closing of our IPO (October 15, 2021);

our subsidiary granted to USD the right to use (both on a temporary and permanent basis) certain portions of the property on which the Hardisty
terminal is located in connection with the development, construction and operation of USD’s development projects;

our  subsidiary  will  cooperate  with  USD  in  connection  with  the  development,  construction  and  operation  of  USD’s  development  projects  at  the
Hardisty terminal;

our subsidiary will enter into such further agreements or instruments with or for the benefit of USD and any land owned by USD and will grant
further rights in, on, over, across and under the property on which the Hardisty terminal is located to or for the benefit of USD and any land owned
by USD, as USD may reasonably request in connection with certain development projects;

USD’s development projects at the Hardisty terminal will be at the sole cost and expense of USD, and will be subject to the observance by USD of
certain customary construction-related requirements and obligations; and

160

•

all improvements constructed or installed by USD in connection with USD’s development projects at the Hardisty terminal will be owned by USD
and USD will be entitled to grant liens on such improvements and/or in and to any rights acquired by USD under the Development Rights and
Cooperation Agreement.

Director Independence

See Item 10. Directors, Executive Officers and Corporate Governance,  for  information  regarding  director  independence  required  by  Item  407(a)  of

Regulation S-K.

Item 14. Principal Accountant Fees and Services

The  following  table  sets  forth  the  aggregate  fees  billed  for  professional  services  rendered  by  BDO  USA,  LLP (“BDO”),  our  principal  independent

auditors, for each of the last two fiscal years.

Audit fees (1)
Audit-related fees (2)
Tax fees (3)
All other fees (4)

Total

For the year ended December 31,

2019

2018

(in millions)
1.1   $

—  

—  

—  

1.1   $

0.6

—

—

—

0.6

$

$

(1)  Audit fees consist of fees for professional services rendered for the audit of our consolidated financial statements and internal controls, reviews of our interim consolidated financial statements

and work related to registration statements and offerings.

(2)  Audit-related fees represent fees for assurance and related services. BDO did not provide any audit-related services to us during the last two fiscal years.

(3)  BDO did not provide any tax services to us during the last two fiscal years.

(4)  All other fees represent fees for services not classifiable under the categories listed in the above table. No such services were rendered by BDO to us during the last two fiscal years.

Engagements for services provided by BDO are subject to pre-approval by the audit committee of the board of directors for USD Partners GP LLC. All

services in 2019 were pre-approved by the audit committee.

161

 
 
 
 
Item 15. Exhibits and Financial Statement Schedules

The following documents are filed as a part of this report:

(1)    Financial Statements.

PART IV

The  following  financial  statements  and  supplementary  data  are  incorporated  by  reference  in  Part  II,  Item  8.  Financial  Statements  and
Supplementary Data of this Annual Report.

a.

b.

c.

d.

e.

f.

g.

Report of BDO USA, LLP, Independent Registered Public Accounting Firm.

Consolidated Statements of Income for the years ended December 31, 2019, 2018 and 2017.

Consolidated Statements of Comprehensive Income for the years ended December 31, 2019, 2018 and 2017.

Consolidated Statements of Cash Flows for the years ended December 31, 2019, 2018 and 2017.

Consolidated Balance Sheets as of December 31, 2019 and 2018.

Consolidated Statements of Partners’ Capital for the years ended December 31, 2019, 2018 and 2017.

Notes to the Consolidated Financial Statements.

(2)    Financial Statement Schedules.

All schedules have been omitted because they are not applicable, the required information is shown in the consolidated financial statements or
Notes thereto or the required information is immaterial.

(3)    Exhibits.

Reference is made to the “Index of Exhibits” immediately preceding the signature pages, which is hereby incorporated into this Item.

Item 16. Form 10-K Summary

None.

162

Each exhibit identified below is filed as a part of this Annual Report.

INDEX OF EXHIBITS

Exhibit Number

Description

3.1

3.2

4.1*

10.1

10.2#

10.3

10.4#

10.5†

10.6

10.7†

10.8*††

10.9

10.10†

10.11

21.1

23.1*

24.1*

31.1*

31.2*

32.1**

32.2**

101.INS*

101.SCH*

101.CAL*

101.DEF*

101.LAB*

101.PRE*

Certificate of Limited Partnership of USD Partners LP (incorporated by reference herein to Exhibit 3.1 to the Registration Statement on Form S-1
(File No. 333-198500) filed on August 29, 2014, as amended).

Second Amended and Restated Agreement of Limited Partnership of USD Partners LP dated October 15, 2014, by and between USD Partners GP
LLC and USD Group LLC (incorporated by reference herein to Exhibit 3.1 to the Current Report on Form 8-K (File No. 001-36674) filed on October
21, 2014).

  Description of the securities registered under Section 12 of the Exchange Act.

Omnibus Agreement dated as of October 15, 2014, by and among U.S. Development Group, LLC, USD Group LLC, USD Partners GP LLC, USD
Partners LP and USD Logistics Operations LP (incorporated by reference herein to Exhibit 10.2 to the Current Report on Form 8-K (File No. 001-
36674) filed on October 21, 2014).

USD Partners LP Amended and Restated 2014 Long-term Incentive Plan (incorporated by reference herein to Exhibit 10.4 to the Annual Report on
10-K (File No. 001-36674) filed on March 9, 2018).

Development Rights and Cooperation Agreement between USD Terminals Canada ULC, as Current Operator, and USD Terminals Canada II ULC, as
Developer, dated as of October 16, 2014 (incorporated by reference herein to Exhibit 10.6 to the Current Report on Form 8-K (File No. 001-36674)
filed on October 21, 2014).

Form of USD Partners LP Long-Term Incentive Plan Phantom Unit Agreement (U.S.) (incorporated by reference to Exhibit 10.1 to the Current Report
on Form 8-K (File No. 001-36674) filed on February 20, 2015).

Services Agreement Between USD Terminals Canada ULC and USD Marketing LLC, effective July 7, 2014 (incorporated by reference to Exhibit
10.6 to the Registration Statement on Form S-1 (File No. 333-1985) filed on August 29, 2014).

Facilities Connection Agreement Between USD Terminals Canada Inc. and Gibson Energy Partnership, dated June 4, 2013 (incorporated by reference
to Exhibit 10.5 to the Registration Statement on Form S-1 (File No. 333-1985) filed on September 22, 2014).

First Amendment to Facilities Connection Agreement between USD Terminals Canada ULC and Gibson Energy Partnership dated November 2, 2018
(incorporated by reference herein to Exhibit 10.7 to the Annual Report on 10-K (File No. 001-36674) filed on March 7, 2019).

Second  Amendment  to  Facilities  Connection  Agreement  between  USD  Terminals  Canada  ULC  and  Gibson  Energy  Partnership  dated  August  23,
2019.

Registration Rights Agreement between USD Partners LP and Cogent Energy Solutions, LLC dated November 17, 2015 (incorporated by reference
herein to Exhibit 10.1 to the Current Report on Form 8-K (File No. 001-36674) filed on November 17, 2015).

Marketing  service  agreement  dated  as  of  May  31,  2017  by  and  between  USD  Marketing  LLC  and  Stroud  Crude  Terminal  LLC.  (incorporated  by
reference herein to Exhibit 10.1 of the Quarterly Report on Form 10-Q (File No. 001-36674) filed on August 8, 2017).

Amended and Restated Credit Agreement dated as of November 2, 2018, among USD Partners LP, USD Terminals Canada ULC, Citibank, N.A., as
administrative agent, swing line lender, and L/C issuer, U.S. Bank National Association and Bank of Montreal as L/C issuers, and the other lenders
party thereto. (incorporated by reference herein to Exhibit 10.1 to the current report on Form 8-K (File No 001-36674) filed on November 8, 2018).

Subsidiaries of the Registrant (incorporated herein by reference to Exhibit 21.1 to the Annual Report on Form 10-K (File No. 001-36674) filed on
March 9, 2018.

  Consent of BDO USA, LLP.

Powers of Attorney (included on the signature page to this Annual Report).

  Certification of Chief Executive Officer Pursuant to Section 302 of the Sarbanes-Oxley Act of 2002.

  Certification of Chief Financial Officer Pursuant to Section 302 of the Sarbanes-Oxley Act of 2002.

  Certification of Chief Executive Officer Pursuant to Section 906 of the Sarbanes-Oxley Act of 2002.

  Certification of Chief Financial Officer Pursuant to Section 906 of the Sarbanes-Oxley Act of 2002.

  XBRL Instance Document.

  XBRL Taxonomy Extension Schema Document.

  XBRL Taxonomy Extension Calculation Linkbase Document.

  XBRL Taxonomy Extension Definition Linkbase Document.

  XBRL Taxonomy Extension Label Linkbase Document.

  XBRL Taxonomy Extension Presentation Linkbase Document.

163

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
*
Filed herewith.
** Furnished herewith.
# Management contract or compensatory plan arrangement required pursuant to Item 15(b) of Form 10-K.
†
††

Certain portions have been omitted pursuant to a confidential treatment request. Omitted information has been separately filed with the Securities and Exchange Commission.
Portions of this exhibit (indicated by asterisks) have been omitted pursuant to Regulation S-K Item 601(b)(10). Such omitted information is not material and would likely cause competitive
harm to the registrant if publicly disclosed.

Copies of Exhibits may be obtained upon written request of any Unitholder to Investor Relations, USD Partners LP, 811 Main Street, Suite 2800, Houston, Texas 77002.

164

Pursuant to the requirements of Section 13 or 15(d) of the Securities Exchange Act of 1934, the Registrant has duly caused this report to be signed on its

behalf by the undersigned, thereunto duly authorized.

SIGNATURES

Date: March 5, 2020

USD PARTNERS LP
(Registrant)

USD Partners GP LLC,
its General Partner

 /s/ Dan Borgen

Dan Borgen
Chief Executive Officer and President

By:

By:

165

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
POWER OF ATTORNEY

KNOW  ALL  BY  THESE  PRESENTS,  that  each  of  the  undersigned  officers  and  directors  of  USD  Partners  GP  LLC,  a  Delaware  limited  liability
company and general partner of USD Partners LP, a Delaware limited partnership (the “Registrant”), does hereby constitute and appoint Dan Borgen, Adam
Altsuler and Keith Benson, and each of them, as his true and lawful attorney or attorneys-in-fact, with full power of substitution and revocation, for each of
the undersigned and in the name, place, and stead of each of the undersigned, to sign on behalf of each of the undersigned any and all amendments to the
Annual Report on Form 10-K, and to file the same, with all exhibits thereto, and other documents in connection therewith including, without limitation, a
Form 12b-25 with the Securities and Exchange Commission, granting to said attorney or attorneys-in-fact, and each of them, full power and authority to do so
and perform each and every act and thing requisite and necessary to be done in and about the premises, as fully to all intents and purposes as the undersigned
might or could do in person, hereby ratifying and confirming all that said attorney or attorneys-in-fact or any of them or their substitute or their substitutes
may lawfully do or cause to be done by virtue thereof.

Pursuant  to  the  requirements  of  the  Securities  Exchange  Act  of  1934,  this  report  has  been  signed  below  by  the  following  persons  on  behalf  of  the

Registrant and in the capacities indicated.

Signature

Title

Date

 /s/ Dan Borgen

Dan Borgen

 /s/ Adam Altsuler

Adam Altsuler

 /s/ Jay Stanford

Jay Stanford

 /s/ Schuyler Coppedge

Schuyler Coppedge

 /s/ Mike Curry

Mike Curry

 /s/ Douglas Kimmelman

Douglas Kimmelman

 /s/ Thomas Lane

Thomas Lane

 /s/ Jane O’Hagan

Jane O’Hagan

 /s/ Brad Sanders

Brad Sanders

 /s/ Stacy Smith

Stacy Smith

 /s/ Jeff Wood

Jeff Wood

  Chairman of the Board, Chief Executive Officer and President
(Principal Executive Officer)

  March 5, 2020

  Senior Vice President, Chief Financial Officer
(Principal Financial Officer)

  Vice President, Chief Accounting Officer
(Principal Accounting Officer)

  Director

  Director

  Director

  Director

  Director

  Director

  Director

  Director

166

  March 5, 2020

  March 5, 2020

  March 5, 2020

  March 5, 2020

  March 5, 2020

  March 5, 2020

  March 5, 2020

  March 5, 2020

  March 5, 2020

  March 5, 2020

 
 
 
   
 
   
 
   
   
   
   
   
   
   
   
   
   
   
   
   
   
   
   
   
Exhibit 4.1

DESCRIPTION OF THE REGISTRANT’S SECURITIES REGISTERED PURSUANT TO SECTION 12 OF THE SECURITIES EXCHANGE
ACT OF 1934

The following description sets forth certain material terms and provisions of our common units, which are registered under Section 12 of the Securities
Exchange  Act  of  1934,  as  amended.  The  following  description  of  our  common  units  is  not  complete  and  is  qualified  in  its  entirety  by  reference  to,  our
certificate  of  limited  partnership  and  our  partnership  agreement,  which  are  filed  as  exhibits  to  our  Annual  Report  on  Form  10-K.  References  to  “our
partnership,”  “we,”  “our,”  “us”  or  like  terms  refer  to  USD  Partners  LP  and  its  consolidated  subsidiaries,  unless  otherwise  specified.  References  to  “our
general  partner”  refer  to  USD  Partners  GP  LLC,  our  general  partner.  References  to  “USDG”  refer  to  USD  Group  LLC,  the  direct  owner  of  our  general
partner. References to “USD” refer to US Development Group, LLC, the indirect owner of our general partner. References to “Energy Capital Partners” refer
to Energy Capital Partners III, LP and its parallel and co-investment funds and related investment vehicles, which are a direct owner of USD. When we refer
to “you,” we mean the holders of the applicable series of securities.

Common Units

The common units represent limited partner interests in us. The holders of common units, along with the holders of subordinated units, are entitled to
participate in partnership distributions and are entitled to exercise the rights and privileges available to limited partners under our partnership agreement. Our
common units are listed on the New York Stock Exchange, or NYSE, under the symbol “USDP.”

Cash Distribution Policy

General

Our  partnership  agreement  provides  that  our  general  partner  will  make  a  determination  as  to  whether  to  make  a  distribution,  but  our  partnership
agreement does not require us to pay distributions at any time or in any amount. Pursuant to our cash distribution policy adopted by the board of directors of
our general partner, within 60 days after the end of each quarter, we intend to make a minimum quarterly distribution of $0.2875 per unit, or $1.15 on an
annualized basis, on all of our units to the extent we have sufficient available cash after establishment of cash reserves and payment of fees and expenses,
including payments to our general partner and its affiliates. Our ability to make cash distributions at the minimum quarterly distribution rate is subject to the
factors described below under “—Limitations on Cash Distributions and Our Ability to Change Our Cash Distribution Policy.”

Definition of Available Cash

Available cash generally means, for any quarter, all cash on hand at the end of that quarter:

•

less, the amount of cash reserves established by our general partner to:

•

•

•

provide  for  the  proper  conduct  of  our  business  (including  cash  reserves  for  our  future  capital  expenditures  and  anticipated  future  debt
service requirements subsequent to that quarter);

comply with applicable law, any of our debt instruments or other agreements; or

provide funds for distributions to our unitholders and to our general partner for any one or more of the next four quarters (provided that our
general  partner  may  not  establish  cash  reserves  for  distributions  if  the  effect  of  the  establishment  of  such  reserves  will  prevent  us  from
distributing the minimum quarterly distribution on all common units and any cumulative arrearages on such common units for the current
quarter);

•

plus, if our general partner so determines, all or any portion of the cash on hand on the date of determination of available cash for the quarter
resulting from working capital borrowings made subsequent to the end of such quarter. 

Limitations on Cash Distributions and Our Ability to Change Our Cash Distribution Policy

There is no guarantee that we will make quarterly cash distributions to our unitholders at our minimum quarterly distribution rate or at any other rate, and
we have no legal or contractual obligation to do so. Our partnership agreement does not require us to pay cash distributions on a quarterly or other basis. Our
current cash distribution policy is subject to certain restrictions, including those under our debt agreements, as well as the discretion of our general partner and
the approval of members of our general partner’s board of directors that are appointed by Energy Capital Partners, which may change our cash distribution
policy at any time from time to time without a vote from unitholders. Under Section 17-607 of the Delaware Revised Uniform Limited Partnership Act, or the
Delaware Act, we may not make a distribution if the distribution would cause our liabilities to exceed the fair value of our assets.

To  the  extent  that  our  general  partner  determines  not  to  distribute  the  full  minimum  quarterly  distribution  with  respect  to  any  quarter  while  any
subordinated units are outstanding, the common units will accrue an arrearage equal to the difference between the minimum quarterly distribution and the
amount of the distribution actually paid with respect to that quarter. The aggregate amount of any such arrearages must be paid on the common units before
any  distributions  of  available  cash  from  operating  surplus  may  be  made  on  the  subordinated  units  and  before  any  subordinated  units  may  convert  into
common units.

Distributions from Operating Surplus and Capital Surplus

General

Any distributions we make will be characterized as made from “operating surplus” or “capital surplus.” Distributions from operating surplus are made
differently than cash distributions that we would make from capital surplus. Operating surplus distributions will be made to our unitholders and, if we make
quarterly distributions above the first target distribution level described below, to the holder of our incentive distribution rights. We do not anticipate that we
will make any distributions from capital surplus. In such an event, however, any capital surplus distribution would be made pro rata to all unitholders, but the
holder of the incentive distribution rights would generally not participate in any capital surplus distributions with respect to those rights.

Operating Surplus

We define operating surplus as:

•

•

•

•

•

$18.5 million (as described below); plus

all of our cash receipts after the closing of our initial public offering (IPO), excluding cash from interim capital transactions (as defined below),
provided  that  cash  receipts  from  the  termination  of  a  commodity  hedge  or  interest  rate  hedge  prior  to  its  specified  termination  date  shall  be
included in operating surplus in equal quarterly installments over the remaining scheduled life of such commodity hedge or interest rate hedge;
plus

working capital borrowings made after the end of a quarter but on or before the date of determination of operating surplus for that quarter; plus

cash distributions (including incremental distributions on incentive distribution rights) paid in respect of equity issued, other than equity issued
in  our  IPO,  to  finance  all  or  a  portion  of  expansion  capital  expenditures  in  respect  of  the  period  from  the  date  that  we  enter  into  a  binding
obligation to commence the construction, development, replacement, improvement or expansion of a capital asset and ending on the earlier to
occur of the date the capital asset commences commercial service and the date that it is abandoned or disposed of; plus

cash distributions (including incremental distributions on incentive distribution rights) paid in respect of equity issued, other than equity issued
in  our  IPO,  to  pay  interest  and  related  fees  on  debt  incurred,  or  to  pay  distributions  on  equity  issued,  to  finance  the  expansion  capital
expenditures referred to in the prior bullet; less

•

•

•

•

all of our operating expenditures (as defined below) after the closing of our IPO; less

the amount of cash reserves established by our general partner to provide funds for future operating expenditures; less

all working capital borrowings not repaid within twelve months after having been incurred, or repaid within such twelve-month period with the
proceeds of additional working capital borrowings; less

any cash loss realized on disposition of an investment capital expenditure.

The  proceeds  of  working  capital  borrowings  increase  operating  surplus  and  repayments  of  working  capital  borrowings  are  generally  operating
expenditures (as described below) and thus reduce operating surplus when repayments are made. However, if working capital borrowings, which increase
operating  surplus,  are  not  repaid  during  the  twelve-month  period  following  the  borrowing,  they  will  be  deemed  repaid  at  the  end  of  such  period,  thus
decreasing operating surplus at such time. When such working capital borrowings are in fact repaid, they will not be treated as a further reduction in operating
surplus because operating surplus will have been previously reduced by the deemed repayment.

We define operating expenditures as all of our cash expenditures, including, but not limited to, taxes, reimbursements of expenses of our general partner
and its affiliates, officer, director and employee compensation, debt service payments, payments made in the ordinary course of business under interest rate
hedge  contracts  and  commodity  hedge  contracts  (provided  that  payments  made  in  connection  with  the  termination  of  any  interest  rate  hedge  contract  or
commodity hedge contract prior to the expiration of its settlement or termination date specified therein will be included in operating expenditures in equal
quarterly installments over the remaining scheduled life of such interest rate hedge contract or commodity hedge contract and amounts paid in connection
with the initial purchase of an interest rate hedge contract or commodity hedge contract will be amortized over the life of such interest rate hedge contract or
commodity hedge contract), maintenance capital expenditures (as discussed in further detail below), and repayment of working capital borrowings; provided,
however, that operating expenditures will not include:

•

•

•

•

•

•

•

repayments of working capital borrowings where such borrowings have previously been deemed to have been repaid (as described above);

payments (including prepayments and prepayment penalties) of principal of and premium on indebtedness other than working capital borrowings;

expansion capital expenditures;

investment capital expenditures;

payment of transaction expenses (including taxes) relating to interim capital transactions;

distributions to our partners; or

repurchases of partnership interests (excluding repurchases we make to satisfy obligations under employee benefit plans);

Capital Surplus

Capital surplus is defined in our partnership agreement as any distribution of available cash in excess of our cumulative operating surplus. Accordingly,

except as described above, capital surplus would generally be generated by:

•

•

borrowings other than working capital borrowings;

sales of our equity and debt securities; and

•

sales or other dispositions of assets, other than inventory, accounts receivable and other assets sold in the ordinary course of business or as part
of ordinary course retirement or replacement of assets.

Characterization of Cash Distributions

Our  partnership  agreement  requires  that  we  treat  all  available  cash  distributed  as  coming  from  operating  surplus  until  the  sum  of  all  available  cash
distributed since the closing of our IPO equals the operating surplus from the closing of our IPO through the end of the quarter immediately preceding that
distribution.  Our  partnership  agreement  requires  that  we  treat  any  amount  distributed  in  excess  of  operating  surplus,  regardless  of  its  source,  as  capital
surplus.

Capital Expenditures

Expansion capital expenditures are cash expenditures incurred for acquisitions or capital improvements that we expect will increase our operating income
or  operating  capacity  over  the  long  term.  Expansion  capital  expenditures  include  interest  payments  (and  related  fees)  on  debt  incurred  to  finance  all  or  a
portion  of  expansion  capital  expenditures  in  respect  of  the  period  from  the  date  that  we  enter  into  a  binding  obligation  to  commence  the  construction,
development,  replacement,  improvement  or  expansion  of  a  capital  asset  and  ending  on  the  earlier  to  occur  of  the  date  that  such  capital  improvement
commences commercial service and the date that such capital improvement is abandoned or disposed.

Maintenance capital expenditures are cash expenditures made to maintain, over the long term, our operating capacity, operating income or our asset base.

Investment capital expenditures are those capital expenditures that are neither maintenance capital expenditures nor expansion capital expenditures.

Capital  expenditures  that  are  made  in  part  for  maintenance  capital  purposes,  investment  capital  purposes  and/or  expansion  capital  purposes  will  be

allocated as maintenance capital expenditures, investment capital expenditures or expansion capital expenditures by our general partner.

General Partner Interest and Incentive Distribution Rights

Our general partner currently owns general partner units representing a general partner interest in us, as well as all of our incentive distribution rights.
Our  partnership  agreement  provides  that  our  general  partner  initially  was  entitled  to  2.0%  of  all  distributions  that  we  make  prior  to  our  liquidation.  Our
general partner has the right, but not the obligation, to contribute a proportionate amount of capital to us in order to maintain its 2.0% general partner interest
if we issue additional units. Our general partner’s 2.0% interest, and the percentage of our cash distributions to which it is entitled from such 2.0% interest,
will  be  proportionately  reduced  if  we  issue  additional  units  in  the  future  (other  than  the  issuance  of  common  units  upon  conversion  of  outstanding
subordinated  units  or  the  issuance  of  common  units  upon  a  reset  of  the  incentive  distribution  rights)  and  our  general  partner  does  not  contribute  a
proportionate  amount  of  capital  to  us  in  order  to  maintain  its  2.0%  general  partner  interest.  Our  partnership  agreement  does  not  require  that  our  general
partner fund its capital contribution with cash. Our general partner may instead fund its capital contribution by the contribution to us of common units or other
property.

Incentive distribution rights represent the right to receive an increasing percentage (13.0%, 23.0% and 48.0%) of quarterly distributions from operating
surplus  after  the  minimum  quarterly  distribution  and  the  target  distribution  levels  have  been  achieved.  Our  general  partner  currently  holds  the  incentive
distribution rights, but may transfer these rights at any time.

The following discussion assumes that our general partner maintained its 2.0% general partner interest, and that our general partner continues to own the

incentive distribution rights.

If for any quarter:

•

•

we have distributed cash from operating surplus to the common unitholders and subordinated unitholders in an amount equal to the minimum
quarterly distribution; and

we eliminate any cumulative arrearages in payment of the minimum quarterly distribution;

then, we will make additional distributions from operating surplus for that quarter among the unitholders and our general partner in the following manner:

•

•

•

•

first, 98.0% to all unitholders, pro rata, and 2.0% to our general partner, until each unitholder receives a total of $0.330625 per unit for that
quarter (the “first target distribution”);

second, 85.0% to all unitholders, pro rata, and 15.0% to our general partner, until each unitholder receives a total of $0.359375 per unit for that
quarter (the “second target distribution”);

third, 75.0% to all unitholders, pro rata, and 25.0% to our general partner, until each unitholder receives a total of $0.431250 per unit for that
quarter (the “third target distribution”); and

thereafter, 50.0% to all unitholders, pro rata, and 50.0% to our general partner.

Subordinated Units and Subordination Period

General

Our partnership agreement provides that, while any subordinated units remain outstanding, the common units will have the right to receive distributions
of available cash from operating surplus each quarter in an amount equal to $0.2875 per unit, which amount is defined in our partnership agreement as the
minimum quarterly distribution, plus (with respect to the common units) any arrearages in the payment of the minimum quarterly distribution on the common
units from prior quarters, before any distributions of available cash from operating surplus may be made on the subordinated units. The subordinated units
will not be entitled to receive any distributions until the common units have received the minimum quarterly distribution plus (with respect to the common
units) any arrearages on the common units from prior quarters. Furthermore, no arrearages will be paid on the subordinated units.

The subordinated units will convert into common units on a one-for-one basis in separate, sequential tranches as described below. Each tranche will be
comprised of 20.0% of the subordinated units outstanding immediately following our IPO. The first tranche of 2,092,709 subordinated units converted into
common  units  in  February  2016.  Additional  tranches  may  convert  on  any  business  day  following  the  distribution  of  Available  Cash  occurring  on  or  after
January 1, 2016 (but not more frequently than once in any twelve-month period), provided that on such date the following conditions are satisfied:

•

•

•

distributions of available cash from operating surplus on each of the outstanding common units, subordinated units and general partner units
equaled or exceeded $1.15 per unit (the annualized minimum quarterly distribution) for the four quarter period immediately preceding that date;

the adjusted operating surplus generated during the four quarter period immediately preceding that date equaled or exceeded the sum of $1.15
per unit (the annualized minimum quarterly distribution) on all of the common units, subordinated units and general partner units outstanding
during that period on a fully diluted basis; and

there are no arrearages in the payment of the minimum quarterly distribution on the common units. 

For each successive tranche, the four quarter period specified in the first and second bullet above must commence after the four quarter period applicable

to any prior tranche of subordinated units.

Conversion upon Removal of the General Partner

In addition, if the unitholders remove our general partner other than for cause:

•

•

•

the subordinated units held by any person will immediately and automatically convert into common units on a one-for-one basis, provided (i)
neither such person nor any of its affiliates voted any of its units in favor of the removal and (ii) such person is not an affiliate of the successor
general partner;

if  all  of  the  subordinated  units  convert  pursuant  to  the  foregoing,  all  cumulative  common  unit  arrearages  on  the  common  units  will  be
extinguished; and

our general partner will have the right to convert its general partner interest and its incentive distribution rights into common units or to receive
cash in exchange for those interests.

Adjusted Operating Surplus

Adjusted operating surplus is intended to reflect the cash generated from operations during a particular period and therefore excludes net drawdowns of

reserves of cash generated in prior periods. Adjusted operating surplus consists of:

•

•

•

•

•

•

operating  surplus  generated  with  respect  to  that  period  (excluding  any  amounts  attributable  to  the  items  described  in  the  first  bullet  of  the
definition of operating surplus); less

any net increase in working capital borrowings with respect to that period; less

any net increase in cash reserves for operating expenditures with respect to that period required by any debt instrument for the repayment of
principal, interest or premium; plus

any net decrease in working capital borrowings with respect to that period; plus

any  net  decrease  in  cash  reserves  for  operating  expenditures  with  respect  to  that  period  not  relating  to  an  operating  expenditure  made  with
respect to that period; plus

any net decrease made in subsequent periods in cash reserves for operating expenditures initially established with respect to such period to the
extent such decrease results in a reduction of adjusted operating surplus in subsequent periods.

Distributions from Operating Surplus While Any Subordinated Units are Outstanding

If we make a distribution of cash from operating surplus for any quarter while any subordinated units remain outstanding, our partnership agreement

requires we make the distribution in the following manner (assumes our general partner maintained a 2% general partner interest in us):

•

•

•

•

first, 98.0% to the common unitholders, and 2.0% to our general partner, until we distribute for each outstanding common unit an amount equal
to the minimum quarterly distribution for that quarter;

second, 98.0% to the common unitholders, pro rata, and 2.0% to our general partner, until we distribute for each outstanding common unit an
amount equal to any arrearages in payment of the minimum quarterly distribution on the common units for any prior quarters;

third, 98.0% to the subordinated unitholders, pro rata, and 2.0% to our general partner, until we distribute for each outstanding subordinated unit
an amount equal to the minimum quarterly distribution for that quarter; and

thereafter, in the manner described in “—General Partner Interest and Incentive Distribution Rights” below.

Distributions from Operating Surplus After All Subordinated Units have Converted into Common Units

If  we  make  a  distribution  from  operating  surplus  for  any  quarter  after  all  subordinated  units  have  converted  into  common  units,  our  partnership

agreement requires that we make the distribution in the following manner (assumes our general partner maintained a 2% general partner interest in us):

•

•

first, 98.0% to all unitholders, pro rata, and 2.0% to our general partner, until we distribute for each outstanding unit an amount equal to the
minimum quarterly distribution for that quarter; and

thereafter, in the manner described in “—General Partner Interest and Incentive Distribution Rights” below. 

Percentage Allocations from Operating Surplus

The following table illustrates the percentage allocations of distributions from operating surplus between the unitholders and our general partner based on
the specified target distribution levels. The formula for distributing available cash as set forth in our partnership agreement is as follows (assumes our general
partner maintained a 2% general partner interest in us):

Distribution Targets

Minimum Quarterly Distribution

First Target Distribution

Second Target Distribution

Third Target Distribution

Thereafter

Portion of Quarterly
Distribution Per Unit

Up to $0.2875

> $0.2875 to $0.330625

> $0.330625 to $0.359375

> $0.359375 to $0.431250

Amounts above $0.431250

General Partner’s Right to Reset Incentive Distribution Levels

Percentage Distributed to
Limited Partners

Percentage Distributed to
General Partner
(including IDRs)

98%

98%

85%

75%

50%

2%

2%

15%

25%

50%

Our general partner, as the initial holder of our incentive distribution rights, has the right under our partnership agreement to elect to relinquish the right to
receive incentive distribution payments based on the initial target distribution levels and to reset, at higher levels, the target distribution levels upon which the
incentive distribution payments to our general partner would be set. Our general partner’s right to reset the target distribution levels upon which the incentive
distributions payable to our general partner are based may be exercised, without approval of our unitholders or the conflicts committee of our general partner,
at any time when there are no subordinated units outstanding and after we have made cash distributions to the holders of the incentive distribution rights at the
highest  level  of  incentive  distribution  for  the  prior  four  consecutive  fiscal  quarters.  The  reset  target  distribution  levels  will  be  higher  than  the  target
distribution levels prior to the reset such that our general partner will not receive any incentive distributions under the reset target distribution levels until cash
distributions per unit following this event increase as further described in our Partnership Agreement

Distributions from Capital Surplus

How Distributions from Capital Surplus will be Made

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Our  partnership  agreement  requires  that  we  make  distributions  from  capital  surplus,  if  any,  in  the  following  manner  (assumes  our  general  partner

maintained a 2% general partner interest in us):

•

•

•

first, 98.0% to all unitholders, pro rata, and 2.0% to our general partner, until the minimum quarterly distribution is reduced to zero, as described
below;

second, 98.0% to all unitholders, pro rata, and 2.0% to our general partner, until we distribute for each common unit, an amount from capital
surplus equal to any unpaid arrearages in payment of the minimum quarterly distribution on the outstanding common units; and

thereafter, as if they were from operating surplus.

Effect of a Distribution from Capital Surplus

Our partnership agreement treats a distribution of capital surplus as the repayment of the initial value contributed by unitholders for their units, which
we refer to as the “initial unit price” for each unit, which is a return of capital. Each time a distribution of capital surplus is made, the minimum quarterly
distribution and the target distribution levels will be reduced in the same proportion as the corresponding reduction in relation to the fair market value of the
common  units  prior  to  the  announcement  of  the  distribution.  However,  any  distribution  of  capital  surplus  before  the  minimum  quarterly  distribution  is
reduced to zero cannot be applied to the payment of the minimum quarterly distribution or any arrearages.

Once we reduce the minimum quarterly distribution and the target distribution levels to zero, all future distributions will be made such that (assuming
our general partner maintained a 2% general partner interest in us) 50.0% is paid to all unitholders, pro rata, 2.0% is paid to our general partner and 48.0% is
paid to the holder of our incentive distribution rights.

Distributions of Cash Upon Liquidation

If we dissolve in accordance with our partnership agreement, we will sell or otherwise dispose of our assets in a process called liquidation. We will first
apply the proceeds of liquidation to the payment of our creditors. We will distribute any remaining proceeds to the unitholders and our general partner, in
accordance with their capital account balances, as adjusted to reflect any gain or loss upon the sale or other disposition of our assets in liquidation. 

Voting Rights

The  following  is  a  summary  of  the  unitholder  vote  required  for  approval  of  the  matters  specified  below.  Matters  that  require  the  approval  of  a  “unit

majority” require:

•

•

while any subordinated units remain outstanding, the approval of a majority of the common units, excluding those common units held by USDG
and its affiliates, and a majority of the subordinated units, voting as separate classes; and

after all subordinated units have been converted into common units, the approval of a majority of the common units, voting as a single class.

In voting their common and subordinated units, USDG and its affiliates will have no duty or obligation whatsoever to us or the limited partners, including

any duty to act in good faith or in the best interests of us or the limited partners.

Holders of incentive distribution rights may be entitled to vote in certain circumstances as may be expressly provided in our partnership agreement.

 
 
Issuance of additional units

No approval right.

Amendment of the partnership agreement

Certain amendments may be made by our general partner without the
approval of the unitholders. Other amendments generally require the approval
of a unit majority. Please read “—Amendment of Our Partnership
Agreement.”

For so long as Energy Capital Partners is able to appoint more than one
member to USD’s board of directors, Energy Capital Partners must approve
any amendment to our partnership agreement. Please read “—Special
Approval Rights of Energy Capital Partners.”

Modification of cash distribution policy

No approval right.

Merger of our partnership or the sale of all or substantially all of our assets

Unit majority in certain circumstances. Please read “—Merger, Consolidation,
Conversion, Sale or Other Disposition of Assets.”

Dissolution of our partnership

Unit majority. Please read “—Dissolution.”

Continuation of our business upon dissolution

Unit majority. Please read “—Dissolution.”

Withdrawal of the general partner

Under most circumstances, the approval of a majority of the common units,
excluding common units held by our general partner and its affiliates, is
required for the withdrawal of our general partner prior to September 30,
2024 in a manner that would cause a dissolution of our partnership.

Removal of the general partner

Not less than 66 2/3% of the outstanding units, voting as a single class,
including units held by our general partner and its affiliates.

Transfer of the general partner interest

Our general partner may transfer any or all of its general partner interest to an
affiliate of another person without a vote of our unitholders.

Transfer of incentive distribution rights

Our general partner may transfer any or all of its incentive distribution rights
to an affiliate or another person without a vote of our unitholders.

Reset of incentive distribution levels

No approval right.

Transfer of ownership interests in our general partner

No approval right.

 
Capital Contributions

Unitholders are not obligated to make additional capital contributions, except as described below under “—Limited Liability.”

Limited Liability

Assuming that a limited partner does not participate in the control of our business within the meaning of the Delaware Act and that he otherwise acts in
conformity with the provisions of the partnership agreement, his liability under the Delaware Act will be limited, subject to possible exceptions, to the amount
of capital he is obligated to contribute to us for his common units plus his share of any undistributed profits and assets. The Delaware Act generally provides
that a limited partner does not participate in the control of the business within the meaning of the Delaware Act by virtue of possessing or exercising the right
or power to admit, remove or retain the general partner, amend the partnership agreement or certificate of limited partnership, or cause the taking or refraining
from taking of any action with respect to such other matters as are stated in the partnership agreement. However, if a court were to determine that the right, or
exercise of the right, by the limited partners as a group to take any action under the partnership agreement constituted “participation in the control” of our
business for the purposes of the Delaware Act, then the limited partners could be held personally liable for our obligations under the laws of Delaware, to the
same extent as our general partner. This liability would extend to persons who transact business with us under the reasonable belief that the limited partner is
a  general  partner.  Neither  our  partnership  agreement  nor  the  Delaware  Act  specifically  provides  for  legal  recourse  against  our  general  partner  if  a  limited
partner were to lose limited liability through any fault of our general partner. While this does not mean that a limited partner could not seek legal recourse, we
know of no precedent for this type of a claim in Delaware case law.

Under the Delaware Act, a limited partnership may not make a distribution to a partner if, after the distribution, all liabilities of the limited partnership,
other than liabilities to partners on account of their partnership interests and liabilities for which the recourse of creditors is limited to specific property of the
partnership,  would  exceed  the  fair  value  of  the  assets  of  the  limited  partnership.  For  the  purpose  of  determining  the  fair  value  of  the  assets  of  a  limited
partnership, the Delaware Act provides that the fair value of property subject to liability for which recourse of creditors is limited shall be included in the
assets of the limited partnership only to the extent that the fair value of that property exceeds the nonrecourse liability. The Delaware Act provides that a
limited partner who receives a distribution and knew at the time of the distribution that the distribution was in violation of the Delaware Act shall be liable to
the limited partnership for the amount of the distribution for three years.

Issuance of Additional Securities

Our  partnership  agreement  authorizes  us  to  issue  an  unlimited  number  of  additional  partnership  interests  for  the  consideration  and  on  the  terms  and
conditions determined by our general partner without the approval of the unitholders. The issuance of additional common units or other partnership interests
may dilute the value of the interests of the then-existing common unitholders in our net assets.

In accordance with Delaware law and the provisions of our partnership agreement, we may also issue additional partnership interests that, as determined
by  our  general  partner,  may  have  rights  to  distributions  or  special  voting  rights  to  which  the  common  units  are  not  entitled.  In  addition,  our  partnership
agreement  does  not  prohibit  our  current  or  future  subsidiaries  from  issuing  equity  interests,  which  may  effectively  rank  senior  to  the  common  units. The
common unitholders do not have preemptive rights under our partnership agreement to acquire additional common units or other partnership interests.

Amendment of Our Partnership Agreement

General

Amendments to our partnership agreement may be proposed only by our general partner. However, our general partner will have no duty or obligation to
propose any amendment and may decline to do so free of any fiduciary duty or obligation whatsoever to us or the limited partners, including any duty to act in
good faith or in the best interests of us or the limited partners. In order to adopt a proposed amendment, other than the amendments discussed below, our
general partner is required to seek written approval of the holders of the number of units required to approve the amendment or to call a meeting of the limited
partners to consider and vote upon the proposed amendment. Except as described below, an amendment must be approved by a unit majority.

For so long as Energy Capital Partners is able to appoint more than one member to USD’s board of directors, Energy Capital Partners must approve any

amendment to our partnership agreement. Please read “—Special Approval Rights of Energy Capital Partners.”

Prohibited Amendments

No amendment may be made that would:

•

•

enlarge the obligations of any limited partner without his consent, unless approved by at least a majority of the type or class of limited partner
interests so affected; or

enlarge  the  obligations  of,  restrict,  change  or  modify  in  any  way  any  action  by  or  rights  of,  or  reduce  in  any  way  the  amounts  distributable,
reimbursable or otherwise payable by us to our general partner or any of its affiliates without the consent of our general partner, which consent
may be given or withheld in its sole discretion. 

The  provision  of  our  partnership  agreement  preventing  the  amendments  having  the  effects  described  in  the  clauses  above  can  be  amended  upon  the
approval  of  the  holders  of  at  least  90.0%  of  the  limited  partner  interests,  voting  as  a  single  class  (including  units  owned  by  our  general  partner  and  its
affiliates).

Unitholder Approval

Our  general  partner  may  make  specified  amendments  to  our  partnership  agreement,  without  the  approval  of  any  limited  partner,  as  described  in  our
Partnership Agreement. Any amendment that our general partner determines adversely affects in any material respect one or more particular classes of limited
partners  will  require  the  approval  of  at  least  a  majority  of  the  class  or  classes  so  affected,  but  no  vote  will  be  required  by  any  class  or  classes  of  limited
partners that our general partner determines are not adversely affected in any material respect. Any amendment that would have a material adverse effect on
the rights or preferences of any type or class of outstanding units in relation to other classes of units will require the approval of at least a majority of the type
or class of units so affected. Any amendment that would reduce the voting percentage required to take any action other than to remove our general partner or
call a meeting of unitholders is required to be approved by the affirmative vote of limited partners whose aggregate outstanding units constitute not less than
the voting requirement sought to be reduced. Any amendment that would increase the percentage of units required to remove the general partner or call a
meeting of unitholders must be approved by the affirmative vote of limited partners whose aggregate outstanding units constitute not less than the percentage
sought to be increased. For amendments of the type not requiring unitholder approval, our general partner will not be required to obtain an opinion of counsel
that an amendment will neither result in a loss of limited liability to the limited partners nor result in our being treated as a taxable entity for federal income
tax purposes in connection with any of the amendments. No other amendments to our partnership agreement will become effective without the approval of
holders of at least 90.0% of the outstanding units, voting as a single class, unless we first obtain an opinion of counsel to the effect that the amendment will
not affect the limited liability under applicable law of any of our limited partners.

Merger, Consolidation, Conversion, Sale or Other Disposition of Assets

A merger, consolidation or conversion of us requires the prior consent of our general partner and Energy Capital Partners. However, neither our general
partner nor Energy Capital Partners will have any duty or obligation to consent to any merger, consolidation or conversion and may decline to do so free of
any fiduciary duty or obligation whatsoever to us or the limited partners, including any duty to act in good faith or in the best interest of us or the limited
partners.

In addition, our partnership agreement generally prohibits our general partner, without the prior approval of the holders of a unit majority, from causing
us to sell, exchange or otherwise dispose of all or substantially all of our assets in a single transaction or a series of related transactions, including by way of
merger,  consolidation  or  other  combination.  Our  general  partner  may,  however,  mortgage,  pledge,  hypothecate  or  grant  a  security  interest  in  all  or
substantially  all  of  our  assets  without  such  approval.  Our  general  partner  may  also  sell  all  or  substantially  all  of  our  assets  under  a  foreclosure  or  other
realization  upon  those  encumbrances  without  such  approval.  Finally,  our  general  partner  may  consummate  any  merger  without  the  prior  approval  of  our
unitholders if we are the surviving entity in the transaction, our general partner has received an opinion of counsel regarding limited liability and tax matters,
the transaction would not result in a material amendment to the partnership agreement (other than an amendment that the general partner could adopt without
the consent of other partners), each of our units will be an identical unit of our partnership following the transaction and the partnership securities to be issued
do not exceed 20.0% of our outstanding partnership interests (other than incentive distribution rights) immediately prior to the transaction.

If the conditions specified in our partnership agreement are satisfied, our general partner may convert us or any of our subsidiaries into a new limited
liability entity or merge us or any of our subsidiaries into, or convey all of our assets to, a newly formed entity, if the sole purpose of that conversion, merger
or  conveyance  is  to  effect  a  mere  change  in  our  legal  form  into  another  limited  liability  entity,  we  have  received  an  opinion  of  counsel  regarding  limited
liability  and  tax  matters  and  the  governing  instruments  of  the  new  entity  provide  the  limited  partners  and  our  general  partner  with  the  same  rights  and
obligations as contained in our partnership agreement. Our unitholders are not entitled to dissenters’ rights of appraisal under our partnership agreement or
applicable Delaware law in the event of a conversion, merger or consolidation, a sale of substantially all of our assets or any other similar transaction or event.

Special Approval Rights of Energy Capital Partners

For  so  long  as  Energy  Capital  Partners  is  able  to  appoint  more  than  one  member  to  USD’s  board  of  directors,  USD  will  not,  and  will  not  permit  its
subsidiaries, including us and our general partner, to take or agree to take any of the following actions (or take or agree to take any action that is reasonably
likely to require or result in any of the following actions) without the affirmative vote of Energy Capital Partners (or, with respect to distributions by us or our
subsidiaries, the members of our general partner’s board of directors appointed by Energy Capital Partners):

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any sale of USD, any subsidiary of USD, including us, or any of their assets (other than asset sales in the ordinary course of business), including
by way of merger, consolidation, public offering or otherwise, other than to USD or a wholly owned subsidiary of USD;

any capital contribution or issuance of or redemption of securities of USD or any subsidiary of USD, including us, (B) any issuance of profits
interests in USD, (C) any distributions, except distributions by us and our subsidiaries (which distributions shall be subject to the affirmative
vote  of  the  members  of  our  general  partner’s  board  of  directors  appointed  by  Energy  Capital  Partners),  (D)  any  incurrence  or  refinancing  of
indebtedness  (whether  directly,  through  a  guaranty  or  otherwise)  outside  of  the  ordinary  course  of  business,  other  than  any  incurrence  or
refinancing of  

indebtedness by us or our subsidiaries (which incurrences and refinancings shall be subject to the affirmative vote of the members of our general
partner’s board of directors appointed by Energy Capital Partners), (E) any acquisition of securities of any other entity in excess of the lesser of
the consolidated earnings before interest, taxes, depreciation and amortization of USD Group or $50 million or (F) any making of any loan or
advance to any entity other than a wholly owned subsidiary of USD;

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the  approval,  modification  or  revocation  of  any  budget  or  a  material  deviation  from  or  a  material  expenditure  not  part  of  any  such  budget
(including  any  material  change  with  respect  to  the  nature  of  any  budgeted  capital  expenditure),  other  than  the  approval,  modification  or
revocation of any budget related to us or our subsidiaries (which approvals, modifications or revocations shall be subject to the affirmative vote
of the members of our general partner’s board of directors appointed by Energy Capital Partners);

amending the organizational documents of USD in a manner adverse to the holders of the common membership interests of USD, (B) amending
the  organizational  documents  of  any  subsidiary  of  USD,  including  us,  (C)  expanding  the  purpose  of  any  of  USD  or  any  of  its  subsidiaries,
including us, (D) causing or taking any action with the purpose or effect of causing the bankruptcy, liquidation, dissolution or winding up of
USD  or  any  of  its  subsidiaries,  (E)  making  any  material  change  to  USD  or  any  its  subsidiaries’  federal  tax  treatment,  (F)  entering  into  or
amending any transaction with any member of USD or their affiliates or (G) creating or materially amending any employee incentive plan; or
Energy Capital Partners’ Right to Sell USD or Its Interests in USD; or

the  determination  of  significant  regulatory  issues  or  litigation,  including  any  decision  to  initiate,  forego  or  settle  any  material  litigation  or
arbitration,  or  the  entering  into  discussions,  or  negotiations,  with  any  governmental  authority  in  connection  with  any  investigation  or
proceedings, or any material inquiry.

Dissolution

We will continue as a limited partnership until dissolved under our partnership agreement. We will dissolve upon:

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•

the election of our general partner to dissolve us, if approved by the holders of units representing a unit majority;

there being no limited partners, unless we are continued without dissolution in accordance with applicable Delaware law;

the entry of a decree of judicial dissolution of our partnership; or

the withdrawal or removal of our general partner or any other event that results in its ceasing to be our general partner other than by reason of a
transfer of its general partner interest in accordance with our partnership agreement or its withdrawal or removal following the approval and
admission of a successor.

Upon a dissolution under the last clause above, the holders of a unit majority may also elect, within specific time limitations, to continue our business on
the same terms and conditions described in our partnership agreement by appointing as a successor general partner an entity approved by the holders of units
representing a unit majority, subject to our receipt of an opinion of counsel to the effect that:    

•

•

the action would not result in the loss of limited liability under Delaware law of any limited partner; and

neither we nor any of our subsidiaries would be treated as an association taxable as a corporation or otherwise be taxable as an entity for U.S.
federal income tax purposes upon the exercise of that right to continue (to the extent not already so treated or taxed).

Limited Call Right

If at any time USDG and its controlled affiliates own more than 80.0% of the then-issued and outstanding limited partner interests of any class, USDG
will have the right, which it may assign in whole or in part to any of its affiliates or beneficial owners or to us, to acquire all, but not less than all, of the
limited partner interests of the class held by unaffiliated persons as of a record date to be selected by our general partner, on at least 10, but not more than 60,
days’ notice.

The purchase price in the event of this purchase is the greater of:

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•

the highest price paid by our general partner or any of its affiliates for any limited partner interests of the class purchased within the 90 days
preceding the date on which our general partner first mails notice of its election to purchase those limited partner interests; and

the average of the daily closing prices of the partnership securities of such class over the 20 consecutive trading days preceding the date that is
three days before the date the notice is mailed. 

Non-Taxpaying Holders; Redemption

To avoid any adverse effect on the maximum applicable rates chargeable to customers by us or any of our future subsidiaries, or in order to reverse an
adverse  determination  that  has  occurred  regarding  such  maximum  rate,  our  partnership  agreement  provides  our  general  partner  the  power  to  amend  the
agreement. If our general partner, with the advice of counsel, determines that our not being treated as an association taxable as a corporation or otherwise
taxable as an entity for U.S. federal income tax purposes, coupled with the tax status (or lack of proof thereof) of one or more of our limited partners, has, or
is reasonably likely to have, a material adverse effect on the maximum applicable rates chargeable to customers by our subsidiaries, then our general partner
may adopt such amendments to our partnership agreement as it determines necessary or advisable to:

•

•

obtain proof of the U.S. federal income tax status of our limited partners (and their owners, to the extent relevant); and

permit us to redeem the units held by any person whose tax status has or is reasonably likely to have a material adverse effect on the maximum
applicable rates or who fails to comply with the procedures instituted by our general partner to obtain proof of the federal income tax status. The
redemption price in the case of such a redemption will be the average of the daily closing prices per unit for the 20 consecutive trading days
immediately prior to the date set for redemption. 

Non-Citizen Assignees; Redemption

If  our  general  partner,  with  the  advice  of  counsel,  determines  we  are  subject  to  U.S.  federal,  state  or  local  laws  or  regulations  that,  in  the  reasonable
determination of our general partner, create a substantial risk of cancellation or forfeiture of any property that we have an interest in because of the nationality,
citizenship or other related status of any limited partner, then our general partner may adopt such amendments to our partnership agreement as it determines
necessary or advisable to:

•

•

obtain proof of the nationality, citizenship or other related status of our limited partners (and their owners, to the extent relevant); and

permit us to redeem the units held by any person whose nationality, citizenship or other related status creates substantial risk of cancellation or
forfeiture  of  any  property  or  who  fails  to  comply  with  the  procedures  instituted  by  the  general  partner  to  obtain  proof  of  the  nationality,
citizenship or other related status. The redemption price in the case of such a redemption will be the average of the daily closing prices per unit
for the 20 consecutive trading days immediately prior to the date set for redemption.

Meetings; Voting

Except  as  described  below  regarding  a  person  or  group  owning  20.0%  or  more  of  any  class  of  units  then  outstanding,  record  holders  of  units  on  the

record date will be entitled to notice of, and to vote at, meetings of our limited partners and to act upon matters for which approvals may be solicited.

Any action that is required or permitted to be taken by the unitholders may be taken either at a meeting of the unitholders or without a meeting if consents
in writing describing the action so taken are signed by holders of the number of units necessary to authorize or take that action at a meeting. Meetings of the
unitholders may be called by our general partner or by unitholders

owning at least 20.0% of the outstanding units of the class for which a meeting is proposed. Unitholders may vote either in person or by proxy at meetings.
The  holders  of  a  majority  of  the  outstanding  units  of  the  class  or  classes  for  which  a  meeting  has  been  called,  represented  in  person  or  by  proxy,  will
constitute a quorum, unless any action by the unitholders requires approval by holders of a greater percentage of the units, in which case the quorum will be
the greater percentage.

Each record holder of a unit has a vote according to its percentage interest in us, although additional limited partner interests having special voting rights
could  be  issued.  Please  read  “—Issuance  of  Additional  Securities.”  However,  if  at  any  time  any  person  or  group,  other  than  our  general  partner  and  its
affiliates, or a direct or subsequently approved transferee of our general partner or its affiliates and purchasers specifically approved by our general partner,
acquires, in the aggregate, beneficial ownership of 20.0% or more of any class of units then outstanding, that person or group will lose voting rights on all of
its  units  and  the  units  may  not  be  voted  on  any  matter  and  will  not  be  considered  to  be  outstanding  when  sending  notices  of  a  meeting  of  unitholders,
calculating required votes, determining the presence of a quorum or for other similar purposes. common units held in nominee or street name account will be
voted by the broker or other nominee in accordance with the instruction of the beneficial owner unless the arrangement between the beneficial owner and his
nominee provides otherwise. This loss of voting rights does not apply to any person or group that acquires the units from our general partner or its affiliates
and any transferees of that person or group who are notified by our general partner that they will not lose their voting rights or to any person or group who
acquires  the  units  with  the  prior  approval  of  the  board  of  directors  of  our  general  partner.  Except  as  our  partnership  agreement  otherwise  provides,
subordinated units will vote together with common units as a single class.

Transfer of Common Units

By transfer of common units in accordance with our partnership agreement, each transferee of common units shall be admitted as a limited partner with

respect to the common units transferred when such transfer and admission are reflected in our books and records. Each transferee:

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•

•

automatically agrees to be bound by the terms and conditions of, and is deemed to have executed, our partnership agreement;

represents and warrants that the transferee has the right, power, authority and capacity to enter into our partnership agreement; and

gives the consents, waivers and approvals contained in our partnership agreement. 

Our general partner will cause any transfers to be recorded on our books and records no less frequently than quarterly.

We may, at our discretion, treat the nominee holder of a common unit as the absolute owner. In that case, the beneficial holder’s rights are limited solely

to those that it has against the nominee holder as a result of any agreement between the beneficial owner and the nominee holder.

Common units are securities and transferable according to the laws governing the transfer of securities. In addition to other rights acquired upon transfer,

the transferor gives the transferee the right to become a substituted limited partner in our partnership for the transferred common units.

Until a common unit has been transferred on our books, we and the transfer agent may treat the record holder of the common unit as the absolute owner

for all purposes, except as otherwise required by law or stock exchange regulations.

Transfer Agent and Registrar

Computershare Trust Company, N.A. serves as the registrar and transfer agent for our common units. We pay all fees charged by the transfer agent for

transfers of common units, except the following that must be paid by our unitholders:

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•

surety bond premiums to replace lost or stolen certificates, or to cover taxes and other governmental charges in connection therewith;

special charges for services requested by a holder of a common unit; and

other similar fees or charges.

Unless  our  general  partner  determines  otherwise  in  respect  of  some  or  all  of  any  classes  of  our  partnership  interests,  our  partnership  interests  are

evidenced by book entry notation on our partnership register and not by physical certificates.

There  is  no  charge  to  our  unitholders  for  disbursements  of  our  cash  distributions.  We  will  indemnify  the  transfer  agent,  its  agents  and  each  of  their
respective stockholders, directors, officers and employees against all claims and losses that may arise out of acts performed or omitted for its activities in that
capacity, except for any liability due to any gross negligence or intentional misconduct of the indemnified person or entity.

 
 
Portions of this agreement have been redacted in accordance with Regulation S-K Item 601(b)(10). The redactions are indicated with six asterisks (******).
Such omitted information is not material and would likely cause competitive harm to the registrant if publicly disclosed.

Exhibit 10.8

SECOND AMENDMENT TO FACILITIES CONNECTION AGREEMENT

THIS SECOND AMENDMENT TO FACILITIES CONNECTION AGREEMENT (this "Second Amendment") is made
effective at of the 23rd day of August, 2019 (the “Second Amendment Effective Date”).

BETWEEN:

USD TERMINALS CANADA ULC ("USD")
(formerly USD Terminals Canada, Inc.)

— and —

GIBSON ENERGY INFRASTRUCTURE PARTNERSHIP ("Gibson")
(formerly Gibson Energy Partnership)

(collectively referred to as the "Parties", and "Party" means either one of them)

WHEREAS  the  Parties  are  parties  to  that  certain  Facilities  Connection  Agreement  dated  June  4,  2013  (together  with  all
exhibits,  schedules,  annexes  and  other  attachments  thereto,  as  well  as  any  amendments  thereto,  collectively,  the  "Facilities
Agreement");

AND WHEREAS the Parties desire to amend the Facilities Agreement in order to memorialize the Parties’ agreement with

respect to the matters set forth herein;

NOW  THEREFORE  in  consideration  the  covenants  and  agreements  between  the  Parties  contained  in  this  Second
Amendment and other good and valuable consideration, the receipt and sufficiency of which are hereby acknowledged, the Parties
agree as follows:

1. Definitions. Unless otherwise defined, capitalized words and phrases used herein, including in the preamble, shall have

the meanings set out in the Facilities Agreement.

2. Proposed Customers. The Parties acknowledge and agree that ***** and ***** satisfy all of the requirements set forth

in Section 3(b) and Exhibit I of the Facilities Agreement relating to acceptance of Proposed Customers.

3. Section 2 Amendment/Capital Project Approval. The Parties acknowledge and agree that Section 2(j) as set forth in
the First Amendment to the Facilities Agreement dated as of November 2, 2018 (the "First Amendment") is in full force
and effect. By this Second Amendment, the Parties agree that the following shall be included at the end of Section 2(j)
as set forth in the First Amendment:

Exhibit 10.8

The foregoing notwithstanding, neither Party shall have the right to make any capital investment or fund any capital
costs  related  to  an  expansion  (or  otherwise  affecting  the  Rail  Terminal  or  the  Pipeline  Facilities)  greater  than
$500,000 CAD without the other Party's prior written consent.

4. The Gibson Investment. Gibson shall fund and execute the capital investments required (the "Gibson Investment") to
improve  the  operational  efficiency  of  the  Gibson  Terminal  and  the  Pipeline  Facilities  to  reliably  accommodate  a
maximum pipeline pumping rate of 16,000 USgpm, including:

i)        the  installation  of  an  additional  HET  boost  pump  (P-86160)  and  HET  valve  matrix  actuators  at  the  Gibson
Terminal sufficient to maintain reliable delivery service to the Rail Terminal from the HET tanks (Tanks 19 to 27) at
the Gibson Terminal for an estimated cost of $****** (+/-15%);

ii)    increase the diameter of a section of the dedicated Top of the Hill tanks (Tanks 530 to 534, 536, 538, Future
535,  Future  537,  Future  539)  delivery  header  to  the  HURC  ship  pumps  at  the  Gibson  Terminal  to  support  the
increased pumping rate for an estimated cost of $****** (+/-15%);

iii)        the  installation  of  an  additional  suction  line  from  Tank  13  to  the  existing  HURC  boost  pumps  (P-
81100/10/20/30) to maximize shipping rate from the BRT tanks (Tanks 13 to 18) while minimizing restrictions on
tank level requirements for an estimated cost of $****** (+/-15%);

iv)        the  installation  of  an  additional  HURC  ship  pump  (P-81240)  at  the  Gibson  Terminal  to  maintain  reliable
delivery service to the Rail Terminal from all product source locations for an estimated cost of $****** (+/-15%);

v)    the supply and installation of Drag Reducing Agent (DRA) injection equipment to reduce piping losses in the
pipeline between the Gibson Terminal pig launcher and the Rail Terminal pig receiver in order to achieve a thirty
percent (30%) drop in pipeline frictional losses for an estimated cost of $****** (+/-15%).

The Parties hereto acknowledge and agree that USD Terminals Canada II ULC, pursuant to the Facilities Agreement, is
responsible for ******% of the total cost of the Gibson Investment. Upon completion of the Gibson Investment, Gibson
shall invoice USD Terminals Canada II ULC for USD's portion of the total cost. USD Terminals Canada II ULC shall
pay such invoice within fifteen (15) days of receipt. Gibson shall provide appropriate back-up documentation for such
invoice;  provided,  however,  in  the  event  that  Gibson's  costs  exceed  the  upper  estimate  set  forth  above  (i.e.,  the
cumulative cost that is 15% above the total of the estimates set forth above), then Gibson shall be solely responsible for
any such cost overruns and shall not be entitled to reimbursement for such cost overruns. In addition, the parties may
mutually agree

Exhibit 10.8

to offset capital reimbursements against amounts owing relative to the First Amendment or this Second Amendment.

5. The USD Terminals Canada II Investment. USD Terminals Canada II ULC shall fund and execute a capital project
(estimated cost: $******CAD (+/-15%); to install additional track at the Rail Terminal to accommodate the additional
volume  as  required  by  USD  Terminal  Canada  Il's  Terminal  Services  Agreement  with  *****  Commission  (the  "USD
Terminals  Canada  II  Investment").  Solely  for  the  purposes  of  the  Facilities  Agreement,  such  assets  constructed  by
USD Terminals Canada II ULC shall be treated for all purposes under the Facilities Agreement as if such assets were
included  in  the  definition  of  the  Rail  Terminal.  Upon  completion  of  the  USD  Terminals  Canada  II  Investment,  USD
Terminals II shall invoice Gibson for ******% of the total cost of the USD Terminals Canada II Investment, and Gibson
shall  pay  such  invoice  within  fifteen  (15)  days  of  receipt.  USD  Terminals  Canada  II  ULC  shall  provide  appropriate
back-up  documentation  for  such  invoice;  provided,  however,  in  the  event  that  USD  Terminal  Canada  II  ULC's  costs
exceed  the  upper  estimate  set  forth  above  (i.e.,  the  cost  that  is  15%  above  the  estimates  set  forth  above),  then  USD
Terminal  Canada  II  ULC  shall  be  solely  responsible  for  any  such  cost  overruns  and  shall  not  be  entitled  to
reimbursement  for  such  cost  overruns.  In  addition,  the  parties  may  mutually  agree  to  offset  capital  reimbursements
against amounts owing relative to the First Amendment or this Second Amendment.

6. USD and Gibson Proportion Adjustment. As of the Second Amendment Effective Date, the USD Proportion shall be

******percent (******%) and the Gibson Proportion shall be ******percent (******%).

In addition, USD and Gibson agree to revise the distribution percentages as detailed in Section 6 (b) of the Facilities
Connection  Agreement  dated  June  4,  2013  revising  the  USD  portion  from  ******percent  (******%)  to  that  of
******percent  (******%),  and  the  Gibson  proportion  from  to  ******percent  (******%)  to  that  of  ******percent
(******%) to align with the proportional percentages outlined above.

7. Fixed Fee Accounting System. Following the Second Amendment Effective Date, the Management Committee shall
meet and consider a modification to the method of accounting for operating costs of the Rail Terminal and the Pipeline.
The Management Committee shall adopt additional accounting guidelines for the calculation of operating costs such that
all  direct  costs  for  the  operation  of  the  Rail  Terminal  and  the  Pipeline  Facilities  shall  be  included  as  operating  costs
(whether or not previously included). The Parties acknowledge and agree that the operating costs for each Party (and for
the Pipeline Facilities and the Rail Terminal) shall be comprehensive (i.e., all operating costs should be included), but
shall also be consistent in scope with each other and agreed upon no later than September 30, 2019.

Exhibit 10.8

8. Measurement Changes. Following the Second Amendment Effective Date, USD and Gibson agree to meet and resolve

the following deficiencies with a formalized written plan to be completed by October 31, 2019.

• No pressure correction factor being applied to the meter for volume correction.
• No proving on different commodities to capture the MF and calculating the impact on volume to be shared and

discussed with the group.

• No  documentation  of  the  configuration  (text  file)  from  the  Microload  to  BOL  and  custody  transfer  tickets  to
confirm how the volume being calculated using the proper API table to a reference standard conditions at l 5°C
and 101.3 kPa or 60°F.
Proving frequency and practice does not follow closely to API and industry standards.

•
• Develop third party prover audit procedure and dispute resolution.

9. Further Assurances. USD and Gibson agree that each shall do and perform, or cause to be done and performed, all
such further acts and things, and shall execute and deliver all such other agreements or amendments as may reasonably
be  requested  in  order  to  carry  out  the  intent  and  accomplish  the  purposes  of  this  Second  Amendment  and  the
consummation of the transactions contemplated hereby.

10. Continuing  Effect.  Each  of  the  Parties  acknowledges  and  agrees  that  the  Facilities  Agreement,  as  amended  by  this
Second Amendment, shall be and continue in full force and effect and is hereby ratified and confirmed and the rights
and  obligations  of  the  Parties  thereunder  shall  not  be  affected  or  prejudiced  in  any  manner  except  as  specifically
provided  for  herein.  The  Parties  each  agree  that  all  of  their  respective  obligations  and  liabilities  under  the  Facilities
Agreement, as amended by this Second Amendment, shall not have been nor shall they be released, discharged or in any
way whatsoever reduced or diminished as a result of the execution and delivery of this Second Amendment.

11. Headings. The headings used in this Second Amendment are inserted for convenience of reference only and shall not

affect the construction or interpretation of this Second Amendment.

12. Severability. If any term or other provision of this Second Amendment is invalid, illegal or incapable of being enforced
under any applicable rule or law, such provision shall be ineffective only to the extent of such invalidity, illegality or
unenforceability  and  all  other  conditions  and  provisions  of  this  Second  Amendment  shall  nevertheless  remain  in  full
force and effect.

13. Amendment or Waiver. This  Second  Amendment  may  be  amended,  modified,  supplemented,  restated  or  discharged
(and  the  provisions  hereof  may  be  waived)  only  by  one  or  more  instruments  in  writing  signed  by  the  Party  against
whom enforcement of the amendment, modification, supplement, restatement, discharge or waiver is sought.

Exhibit 10.8

14. Governing Law. This  Second  Amendment  shall  be  governed  by  and  construed  and  enforced  in  accordance  with  the

laws of the Province of Alberta.

15. Amendments and Supplements. Any reference herein to this Second Amendment shall be deemed to include reference

to the same as it may be amended, modified and supplemented from time to time.

16. Enurement. This Second Amendment shall be binding upon and enure to the benefit of the Parties and their respective

successors and permitted assigns.

17. Counterpart  Execution.  This  Second  Amendment  may  be  executed  and  delivered  in  separate  counterparts  and
delivered by one Party to the others by facsimile or other electronic means (such as an e-mail exchange of .pdf, .tif or
similar files), each of which when so executed and delivered shall be deemed an original and all such counterparts shall
together constitute one and the same agreement.

[Remainder of this page left intentionally blank; signature page(s) to follow.]

IN WITNESS WHEREOF the Parties have executed this Second Amendment as of the date first written above.

Exhibit 10.8

GIBSON ENERGY PARTNERSHIP, by its
Managing partner, Gibson Energy ULC

/s/ Steve Spaulding                    
Name:    Steve Spaulding
Title:    President & CEO

USD TERMINALS CANADA ULC

/s/ Jim Albertson                    
Name:    Jim Albertson
Title:    SVP Canadian Business Unit

For purposes of Sections 4 and 5 and any other sections required to implement the intent hereof:

USD TERMINALS CANADA II ULC

______________________________________
/s/ Jim Albertson                    
Name:    Jim Albertson
Title:    SVP Canadian Business Unit

Exhibit 23.1

CONSENT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM

USD Partners LP
Houston, Texas

We hereby consent to the incorporation by reference in the Registration Statements on Form S 3 (No.333-214565) and Form S-8 (No. 333-228260 and 333-
201275) of USD Partners LP of our reports dated March 5, 2020, relating to the consolidated financial statements, and the effectiveness of USD Partners LP’s
internal control over financial reporting which appears in this Form 10-K.

/s/ BDO USA, LLP

Houston, Texas
March 5, 2020

 
Certification Pursuant to
Rules 13a-14 and 15d-14 Under the Securities Exchange Act of 1934

I, Dan Borgen, certify that:

Exhibit 31.1

1.

I have reviewed this Annual Report on Form 10-K for the year ended December 31, 2019 (this “report”) of USD Partners LP (the “registrant”);

2. Based on my knowledge, this report does not contain any untrue statement of a material fact or omit to state a material fact necessary to make
the statements made, in light of the circumstances under which such statements were made, not misleading with respect to the period covered by
this report;

3. Based on my knowledge, the financial statements, and other financial information included in this report, fairly present in all material respects

the financial condition, results of operations and cash flows of the registrant as of, and for, the periods presented in this report;

4. The registrant’s other certifying officer and I are responsible for establishing and maintaining disclosure controls and procedures (as defined in
Exchange Act Rules 13a-15(e) and 15d-15(e)) and internal control over financial reporting (as defined in Exchange Act Rules 13a-15(f) and
15d-15(f)) for the registrant and have:

(a) Designed  such  disclosure  controls  and  procedures,  or  caused  such  disclosure  controls  and  procedures  to  be  designed  under  our
supervision, to ensure that material information relating to the registrant, including its consolidated subsidiaries, is made known to us
by others within those entities, particularly during the period in which this report is being prepared;

(b) Designed such internal control over financial reporting, or caused such internal control over financial reporting to be designed under
our  supervision,  to  provide  reasonable  assurance  regarding  the  reliability  of  financial  reporting  and  the  preparation  of  financial
statements for external purposes in accordance with generally accepted accounting principles;

(c) Evaluated the effectiveness of the registrant’s disclosure controls and procedures and presented in this report our conclusions about the
effectiveness of the disclosure controls and procedures, as of the end of the period covered by this report based on such evaluation; and

(d) Disclosed in this report any change in the registrant’s internal control over financial reporting that occurred during the registrant’s most
recent fiscal quarter (the registrant’s fourth fiscal quarter in the case of an annual report) that has materially affected, or is reasonably
likely to materially affect, the registrant’s internal control over financial reporting; and

5. The registrant’s other certifying officer and I have disclosed, based on our most recent evaluation of internal control over financial reporting, to

the registrant’s auditors and the audit committee of the registrant’s board of directors (or persons performing the equivalent functions):

(a) All significant deficiencies and material weaknesses in the design or operation of internal control over financial reporting which are

reasonably likely to adversely affect the registrant’s ability to record, process, summarize and report financial information; and

(b) Any fraud, whether or not material, that involves management or other employees who have a significant role in the registrant’s internal

control over financial reporting.

Date: March 5, 2020

/s/ Dan Borgen

Dan Borgen

Chief Executive Officer and President

 
 
 
 
 
 
 
 
Certification Pursuant to
Rules 13a-14 and 15d-14 Under the Securities Exchange Act of 1934

I, Adam Altsuler, certify that:

Exhibit 31.2

1.

I have reviewed this Annual Report on Form 10-K for the year ended December 31, 2019 (this “report”) of USD Partners LP (the “registrant”);

2. Based on my knowledge, this report does not contain any untrue statement of a material fact or omit to state a material fact necessary to make
the statements made, in light of the circumstances under which such statements were made, not misleading with respect to the period covered by
this report;

3. Based on my knowledge, the financial statements, and other financial information included in this report, fairly present in all material respects

the financial condition, results of operations and cash flows of the registrant as of, and for, the periods presented in this report;

4. The registrant’s other certifying officer and I are responsible for establishing and maintaining disclosure controls and procedures (as defined in
Exchange Act Rules 13a-15(e) and 15d-15(e)) and internal control over financial reporting (as defined in Exchange Act Rules 13a-15(f) and
15d-15(f)) for the registrant and have:

(a) Designed  such  disclosure  controls  and  procedures,  or  caused  such  disclosure  controls  and  procedures  to  be  designed  under  our
supervision, to ensure that material information relating to the registrant, including its consolidated subsidiaries, is made known to us
by others within those entities, particularly during the period in which this report is being prepared;

(b) Designed such internal control over financial reporting, or caused such internal control over financial reporting to be designed under
our  supervision,  to  provide  reasonable  assurance  regarding  the  reliability  of  financial  reporting  and  the  preparation  of  financial
statements for external purposes in accordance with generally accepted accounting principles;

(c) Evaluated the effectiveness of the registrant’s disclosure controls and procedures and presented in this report our conclusions about the
effectiveness of the disclosure controls and procedures, as of the end of the period covered by this report based on such evaluation; and

(d) Disclosed in this report any change in the registrant’s internal control over financial reporting that occurred during the registrant’s most
recent fiscal quarter (the registrant’s fourth fiscal quarter in the case of an annual report) that has materially affected, or is reasonably
likely to materially affect, the registrant’s internal control over financial reporting; and

5. The registrant’s other certifying officer and I have disclosed, based on our most recent evaluation of internal control over financial reporting, to

the registrant’s auditors and the audit committee of the registrant’s board of directors (or persons performing the equivalent functions):

(a) All significant deficiencies and material weaknesses in the design or operation of internal control over financial reporting which are

reasonably likely to adversely affect the registrant’s ability to record, process, summarize and report financial information; and

(b) Any  fraud,  whether  or  not  material,  that  involves  management  or  other  employees  who  have  a  significant  role  in  the  registrant’s

internal control over financial reporting.

Date: March 5, 2020

/s/ Adam Altsuler

Adam Altsuler

Senior Vice President and Chief Financial Officer

 
 
 
 
 
 
 
 
Exhibit 32.1

Certification Pursuant to
Section 906 of the Sarbanes-Oxley Act of 2002
(Subsections (a) and (b) of Section 1350, Chapter 63 of Title 18, United States Code)

Pursuant to Section 906 of the Sarbanes-Oxley Act of 2002 (Subsections (a) and (b) of Section 1350, Chapter 63 of Title 18, United States Code),
I, Dan Borgen, Chief Executive Officer and President of USD Partners GP LLC, as general partner of USD Partners LP (the “Partnership”), hereby certify, to
the best of my knowledge, that:

(1)

(2)

The  Partnership’s  Annual  Report  on  Form  10-K  for  the  year  ended  December  31,  2019  (the  “Report”)  fully  complies  with  the
requirements of Section 13(a) or 15(d) of the Securities Exchange Act of 1934, as amended; and

The information contained in the Report fairly presents, in all material respects, the financial condition and results of operations of
the Partnership.

Date: March 5, 2020

/s/ Dan Borgen

Dan Borgen

Chief Executive Officer and President

 
 
 
 
 
 
 
Exhibit 32.2

Certification Pursuant to
Section 906 of the Sarbanes-Oxley Act of 2002
(Subsections (a) and (b) of Section 1350, Chapter 63 of Title 18, United States Code)

Pursuant to Section 906 of the Sarbanes-Oxley Act of 2002 (Subsections (a) and (b) of Section 1350, Chapter 63 of Title 18, United States Code),
I, Adam Altsuler, Chief Financial Officer of USD Partners GP LLC, as general partner of USD Partners LP (the “Partnership”), hereby certify, to the best of
my knowledge, that:

(1)

(2)

The  Partnership’s  Annual  Report  on  Form  10-K  for  the  year  ended  December  31,  2019  (the  “Report”)  fully  complies  with  the
requirements of Section 13(a) or 15(d) of the Securities Exchange Act of 1934, as amended; and

The information contained in the Report fairly presents, in all material respects, the financial condition and results of operations of
the Partnership.

Date: March 5, 2020

/s/ Adam Altsuler

Adam Altsuler

Senior Vice President and Chief Financial Officer