Correspondence 0001558370-23-011719 from SOUTHERN COPPER CORP/ (SCCO) (CIK 0001001838) (SCCO)
SOUTHERN COPPER CORP/ (SCCO) (CIK 0001001838)
Date: July 6, 2023 · CIK: 0001001838 · Accession: 0001558370-23-011719
AI Filing Summary & Sentiment
File numbers found in text: 001-14066
Referenced dates: June 22, 2023
Letter
United States Securities and Exchange Commission Division of Corporation Finance Office of Energy & Transportation Southern Copper Corporation Form 10-K for the Fiscal Year Ended December 31, 2022 Filed February 28, 2023 File No. 001-14066
Dear Mr. Coleman:
On behalf of Southern Copper Corporation (the “Company,” “we” or “SCC”), I, Oscar Gonzalez Rocha, the Company’s President and Chief Executive Officer, submit our response to your letter dated June 22, 2023, relating to the above-referenced filing.
To assist in the Staff’s review of the Company’s responses, we have preceded our response with the text (in bold type) of the comment as stated in your letter.
Form 10-K for the Fiscal Year Ended December 31, 2022, filed on February 28, 2023
Item 2. Properties
Individual Property Disclosure, page 37
1.
For each of your material properties identified under this section, please disclose the location, accurate to within one mile, using an easily recognizable coordinate system, as required by Item 1304(b)(1)(i) of Regulation S-K.
We appreciate the staff’s comment and will expand our disclosure in future filings to include the information requested as follows:
The new text is in italic and underlined. Page references are related to Form 10-K for fiscal year 2022.
Page 38
Cuajone
The Cuajone operations consist of an open pit copper mine and a concentrator and are located in the Torata District, Mariscal Nieto Region, of Moquegua, approximately 878 km from the city of Lima and 27 km from the city of Moquegua. The Project centroid is at about 17° 3.130’S latitude; 70° 44.499’W longitude and the open pit is centered at approximately 17° 2.601’S latitude; 70° 42.481’W longitude.
The Cuajone mine is accessible by paved road from Lima or Tacna via the Pan-American Highway. The Quebrada Honda tailings storage facility (“TSF”) is about 120 km via local roads, south of the Cuajone operations. Access within the project area is via developed roads that are routinely maintained. Tacna, Moquegua, and Ilo have
SOUTHERN COPPER CORPORATION
7310 North 16th St. Suite 135, Phoenix AZ 85020
Phone: 1 (602) 264–1375
Executive Presidency
regularly scheduled air services from Lima. Additionally, a spur railway runs from the Toquepala operations to the Cuajone operations.
Page 43
Toquepala
The Toquepala operations are situated in Southern Peru, approximately 150 km by road from the city of Tacna and 30 kilometers from Cuajone. The Project centroid is at about 17° 3.130’S latitude; 70° 44.499’W longitude and the open pit is centered at approximately 17° 2.601’S latitude; 70° 42.481’W longitude. Road access from Tacna is via the Pan-American highway and other local roads. Alternative access is from Lima, using the Pan-American highway to Alto Camiara, and then driving for 70 km on a paved road to the Toquepala camp. The Quebrada Honda tailings storage facility (TSF) is 40 km south of the mine and is located at approximately 17° 27.724’S latitude: 70° 47.810’W longitude. The Quebrada Honda tailings are accessed via the MO-107 route that connects Alto Camiara with Toquepala. Within the operations area, access is by unpaved mine and exploration roads. The city of Tacna has a regional airstrip that provides regular service within Peru. Additionally, railways extend from Ilo to Toquepala, and a spur railway runs from the Toquepala operations to the Cuajone operations.
Page 49
Processing Facilities—Ilo
Our Ilo smelter and refinery complex is located in the southern part of Peru, 17 kilometers north of the city of Ilo, 121 kilometers from Toquepala, 147 kilometers from Cuajone and 871 kilometers from the city of Lima. The smelter and refinery are located at about 17° 29.924’S latitude; 71° 21.608’W longitude and 17° 34.728’S latitude; 71° 21.188’W longitude respectively. Access is by plane from Lima to Tacna (1:40 hours) and then by highway to the city of Ilo (2:00 hours). Additionally, we operate a port facility in Ilo, which we use to ship our products and receive supplies. Products shipped and supplies received are moved between Toquepala, Cuajone and Ilo on our industrial railroad.
Page 54
Michiquillay Project
The Michiquillay project is located in the Western Cordillera of the Andes in northwest Peru, approximately 45 km from Cajamarca and 900 km northeast of Lima. Project centroid coordinates are approximately 7º 02’ 23.65” S and 78º 19’ 23.59” W. and the Michiquillay deposit is located at 7º 02’ 17.53” S and 78º 19’ 29.30” W. The datum used is UTM WGS84. The main access route to the Project is via road from Cajamarca. Initially, the paved Route 8B is used from Cajamarca to the town of La Encañada, approximately 33 km. A gravel road is then used from La Encañada to the project site, approximately 14 km. The communities of Michiquillay and Encañada are 2 km and 14 km from the project, respectively. Access within the project is via various gravel and two-track roads that link areas where drilling is planned. The closest airport is at Cajamarca, which is serviced by regular flights from Lima.
SOUTHERN COPPER CORPORATION
7310 North 16th St. Suite 135, Phoenix AZ 85020
Phone: 1 (602) 264–1375
Executive Presidency
Page 58
Buenavista
The Buenavista mining unit operates an open pit porphyry copper mine, two concentrators and three SX EW plants. It is located within the Cananea mining district in the north-central part of the State of Sonora, Mexico. The property is located about 222 kilometers northeast of the city of Hermosillo, Sonora and 150 kilometers southeast of the city of Tucson, Arizona. The geographical location of the Cananea mining district is between latitudes 30° 42’ and 31° 16’ north and longitude meridians 109° 51’ and 110° 33’ west. The Cananea mining district is located at an altitude between 1,600 and 2,485 meters (m) above mean sea level. The property covers an area of 89,220.5 hectares of mining concessions. The elevation of the mine is 1,604 meters above mean sea level.
Page 64
La Caridad
La Caridad mine and mill are located about 23 kilometers southeast of the town of Nacozari in northeastern Sonora at an average altitude of 1,500 meters above mean sea level. Nacozari is about 266 kilometers northeast of the Sonora state capital of Hermosillo and 125 kilometers south of the U.S.—Mexico border. The municipality of Nacozari de García is located between 30°17’ and 30°20’ of north latitude and 109°32’ and 109 35’ of west longitude with regard to the Greenwich meridian. The average elevation is 1500 m above mean sea level. Limits of the mining unit using UTM coordinates are listed in the following table:
VERTEX
UTM Zone 12 WGS 84
Easting
Northing
629,600.00
3,361,303.35
655,325.58
3,361,303.35
655,325.58
3,350,065.74
629,600.00
3,350,065.74
Nacozari is connected by paved highway with Hermosillo and Agua Prieta and by rail with the international port of Guaymas, and the Mexican and United States rail systems. An airstrip with a reported runway length of 2,500 meters is located 36 kilometers north of Nacozari, less than one kilometer away from the La Caridad copper smelter and refinery. The smelter and the sulfuric acid plants, as well as the refineries and rod plant, are located approximately 24 kilometers from the mine. Access is by paved highway and by railroad.
Page 72
El Pilar Project
The El Pilar Property is located in north central Sonora, Mexico, about 15 kilometers south of the international border with United States. The property is situated within lands of Ejido Miguel Hidalgo (also referred to as San Lazaro), in the Santa Cruz Municipality. The property is situated between UTM coordinates 3,446,000N to 3,455,000N and 526,800 E to 534,700 E. The El Pilar property comprises 9,571.4 hectares in 19 concessions. These concessions are wholly owned by Recursos Stingray de Cobre S.A de C.V., our wholly owned Mexican subsidiary. Additionally, a total of 1,926 hectares of surface rights have been successfully negotiated with Ejido Miguel Hidalgo, which will ensure that the company has all necessary land ownership rights to develop the project.
SOUTHERN COPPER CORPORATION
7310 North 16th St. Suite 135, Phoenix AZ 85020
Phone: 1 (602) 264–1375
Executive Presidency
Page 73
El Arco Project
The El Arco deposit is located near the village of El Arco in Baja California, Mexico, which lies near the center of the Baja California Peninsula in the municipalities of San Quintin, Baja California and Mulegé, Baja California Sur, Mexico. The Project centroid is at approximately 28°03’ 24.08” N; 113° 27’ 35.23” W. The center of the El Arco deposit is located at approximately 28° 02’ 02.97” N; 113° 23’ 46.75” W. Route 1 is the only paved highway connecting the northern and southern parts of the Baja Peninsula. El Arco is located between the towns of Santa Rosalía and Guerrero Negro at kilometer 189. The El Arco site is accessed by taking Highway 1 approximately 30 kilometers south of the town of Guerrero Negro to the intersection with the highway MX 18, and following MX 18 for 42 kilometers east to the project site. Highway 1 is paved and in good condition and Highway 18 was originally paved but is now unpaved, leaving a gravel roadbed.
Page 76
Charcas
The Charcas mining complex is located approximately 110 kilometers north of the city of San Luis Potosi in the State of San Luis Potosi, Mexico. The mine uses the Universal Transverse Mercator (UTM) World Geodetic System (WGS84) Zone 14Q coordinate system and is located at 2 560 223 N and 280 042 E at an altitude of 2,150 meters above sea level. Charcas is connected to the state capital by a paved highway of 130 kilometers. It was discovered in 1573 and operations in the 20th century began in 1911. The complex includes three underground mines (San Bartolo, Rey Reina and La Aurora) and one flotation plant that produces zinc, lead and copper concentrates with significant amounts of silver. The Charcas mine is characterized by low operating costs and good quality ores and is situated near the zinc refinery. Charcas is exploited underground by room and pillar with hydraulic cut and fill. The crushed ore is transported to the surface for processing in the flotation plant.
Page78
Santa Barbara
The Santa Barbara mining complex is located approximately 26 kilometers southwest of the city of Hidalgo del Parral in southern Chihuahua, Mexico. The mine uses the Universal Transverse Mercator (UTM) World Geodetic System (WGS84) Zone 13R coordinate system and is located at 2 965 880 N and 418 948 E at an altitude of 2,000 m above sea level. The area can be reached via a paved road of from Hidalgo del Parral, a city on a federal highway. The area is also connected to the state capital of Chihuahua 250 km along Highway 24. It was discovered in 1536 and mining activities in the 20th century began in 1913. Santa Barbara includes three main underground mines (San Diego, Segovedad and Tecolotes) as well as a flotation plant and produces lead, copper and zinc concentrates with significant amounts of silver.
Page 81
San Martin
The San Martin mining complex is located in the municipality of Sombrerete in the northwestern part of the state of Zacatecas, Mexico. It is located approximately 185 kilometers from the city of Zacatecas. The elevation of the San Martin mining complex is approximately 2,600 meters (m) with geographic coordinates of 629,000 E and 2,614,000 N (WGS84, UTM Zona 13). The nearest major town is the municipality of Sombrerete (17 km away) in the Sierra Madre Occidental geographic province. It was discovered in 1555 and mining operations in the 20th century began
SOUTHERN COPPER CORPORATION
7310 North 16th St. Suite 135, Phoenix AZ 85020
Phone: 1 (602) 264–1375
Executive Presidency
in 1949. The complex includes an underground mine and a flotation plant. The ore body contains lead, copper and zinc concentrates with significant amounts of silver. The state of Zacatecas has an extensive infrastructure of roads and highways that connect the San Martín to the rest of the country. The San Martin mining unit has a paved road to Highway 45, which leads to the town of Sombrerete, 17 kilometers away. Highway 45 then connects Sombrete to Fresnillo, Zacatecas and Durango at distances of 110,171 and 125 kilometers, respectively.
The disclosure of geographic coordinates for Tia Maria, Los Chancas and Pilares was included in the 2022 Form 10-K Annual Report on pages 51, 52 and 71 respectively.
UTM = Universal Transverse Mercator
WGS World Geodetic System
2.
For each of your material properties identified under this section, please ensure the metallurgical recovery factor and the cut-off grade are disclosed with the mineral resource table and the mineral reserve table, as required by Item 1304(d)1 of Regulation S-K. In this regard we note the Buenavista, La Caridad, Pilares, Pilar, Charcas, Santa Barbara, and San Martin mineral resource and/or mineral reserve tables are missing one or both of these items.
We appreciate the staff’s comment and will expand our disclosure in future filings to include the information requested in the tables as follows:
The new text is in italic and underlined. Page references correspond to Form 10-K for fiscal year 2022.
SOUTHERN COPPER CORPORATION
7310 North 16th St. Suite 135, Phoenix AZ 85020
Phone: 1 (602) 264–1375
Executive Presidency
Page 62-64
Buenavista
Mineral resources
The following table contains the summary of copper, molybdenum and zinc mineral resources for Buenavista as of December 31, 2022, based on long-term price assumptions of $3.80, $11.50 and $1.32 per pound, respectively:
Copper plant
Amount (million tonnes)
Copper grades
Molybdenum grades
Zinc grades
Contained copper (million pounds)
Contained molybdenum (million pounds)
Contained zinc (million pounds)
Variation Copper
Variation Molybdenum
Variation Zinc
Measured mineral resources
—
—
%
—
%
—
%
—
—
—
Indicated mineral resources
0.34
%
0.005
%
0.07
%
5,664
1,182
(28.2)
%
(21.6)
%
(18.4)
%
Measured + Indicated mineral resources
0.34
%
0.005
%
0.07
%
5,664
1,182
(28.2)
%
(21.6)
%
(18.4)
%
Inferred mineral resources
13,015
0.21
%
0.004
%
0.03
%
56,584
1,080
8,089
(15.7)
%
(16.9)
%
(14.8)
%
Zinc plant
Amount (million tonnes)
Copper grades
Molybdenum grades
Zinc grades
Contained copper (million pounds)
Contained molybdenum (million pounds)
Contained zinc (million pounds)
Measured mineral resources
—
—
%
—
%
—
%
—
—
—
Indicated mineral resources
0.46
%
0.002
%
0.78
%
1,561
2,416
(16.4)
%
(33.3)
%
(22.8)
%
Measured + Indicated mineral resources
0.46
%
0.002
%
0.78
%
1,561
2,416
(16.4)
%
(33.3)
%
(22.8)
%
Inferred mineral resources
0.43
%
0.003
%
0.49
%
1,393
1,638
(23.9)
%
(50.0)
%
(22.0)
%
Leach plant
Amount (million tonnes)
Copper grades
Molybdenum grades
Zinc grades
Contained copper (million pounds)
Contained molybdenum (million pounds)
Contained zinc (million pounds)
Measure
Show Raw Text
CORRESP 1 filename1.htm Executive Presidency July 6, 2023 Mr. John Coleman United States Securities and Exchange Commission Division of Corporation Finance Office of Energy & Transportation Washington, D.C. 20549 Re: Southern Copper Corporation Form 10-K for the Fiscal Year Ended December 31, 2022 Filed February 28, 2023 File No. 001-14066 Dear Mr. Coleman: On behalf of Southern Copper Corporation (the “Company,” “we” or “SCC”), I, Oscar Gonzalez Rocha, the Company’s President and Chief Executive Officer, submit our response to your letter dated June 22, 2023, relating to the above-referenced filing. To assist in the Staff’s review of the Company’s responses, we have preceded our response with the text (in bold type) of the comment as stated in your letter. Form 10-K for the Fiscal Year Ended December 31, 2022, filed on February 28, 2023 Item 2. Properties Individual Property Disclosure, page 37 1. For each of your material properties identified under this section, please disclose the location, accurate to within one mile, using an easily recognizable coordinate system, as required by Item 1304(b)(1)(i) of Regulation S-K. We appreciate the staff’s comment and will expand our disclosure in future filings to include the information requested as follows: The new text is in italic and underlined. Page references are related to Form 10-K for fiscal year 2022. Page 38 Cuajone The Cuajone operations consist of an open pit copper mine and a concentrator and are located in the Torata District, Mariscal Nieto Region, of Moquegua, approximately 878 km from the city of Lima and 27 km from the city of Moquegua. The Project centroid is at about 17° 3.130’S latitude; 70° 44.499’W longitude and the open pit is centered at approximately 17° 2.601’S latitude; 70° 42.481’W longitude. The Cuajone mine is accessible by paved road from Lima or Tacna via the Pan-American Highway. The Quebrada Honda tailings storage facility (“TSF”) is about 120 km via local roads, south of the Cuajone operations. Access within the project area is via developed roads that are routinely maintained. Tacna, Moquegua, and Ilo have 1 SOUTHERN COPPER CORPORATION 7310 North 16th St. Suite 135, Phoenix AZ 85020 Phone: 1 (602) 264–1375 Executive Presidency regularly scheduled air services from Lima. Additionally, a spur railway runs from the Toquepala operations to the Cuajone operations. Page 43 Toquepala The Toquepala operations are situated in Southern Peru, approximately 150 km by road from the city of Tacna and 30 kilometers from Cuajone. The Project centroid is at about 17° 3.130’S latitude; 70° 44.499’W longitude and the open pit is centered at approximately 17° 2.601’S latitude; 70° 42.481’W longitude. Road access from Tacna is via the Pan-American highway and other local roads. Alternative access is from Lima, using the Pan-American highway to Alto Camiara, and then driving for 70 km on a paved road to the Toquepala camp. The Quebrada Honda tailings storage facility (TSF) is 40 km south of the mine and is located at approximately 17° 27.724’S latitude: 70° 47.810’W longitude. The Quebrada Honda tailings are accessed via the MO-107 route that connects Alto Camiara with Toquepala. Within the operations area, access is by unpaved mine and exploration roads. The city of Tacna has a regional airstrip that provides regular service within Peru. Additionally, railways extend from Ilo to Toquepala, and a spur railway runs from the Toquepala operations to the Cuajone operations. Page 49 Processing Facilities—Ilo Our Ilo smelter and refinery complex is located in the southern part of Peru, 17 kilometers north of the city of Ilo, 121 kilometers from Toquepala, 147 kilometers from Cuajone and 871 kilometers from the city of Lima. The smelter and refinery are located at about 17° 29.924’S latitude; 71° 21.608’W longitude and 17° 34.728’S latitude; 71° 21.188’W longitude respectively. Access is by plane from Lima to Tacna (1:40 hours) and then by highway to the city of Ilo (2:00 hours). Additionally, we operate a port facility in Ilo, which we use to ship our products and receive supplies. Products shipped and supplies received are moved between Toquepala, Cuajone and Ilo on our industrial railroad. Page 54 Michiquillay Project The Michiquillay project is located in the Western Cordillera of the Andes in northwest Peru, approximately 45 km from Cajamarca and 900 km northeast of Lima. Project centroid coordinates are approximately 7º 02’ 23.65” S and 78º 19’ 23.59” W. and the Michiquillay deposit is located at 7º 02’ 17.53” S and 78º 19’ 29.30” W. The datum used is UTM WGS84. The main access route to the Project is via road from Cajamarca. Initially, the paved Route 8B is used from Cajamarca to the town of La Encañada, approximately 33 km. A gravel road is then used from La Encañada to the project site, approximately 14 km. The communities of Michiquillay and Encañada are 2 km and 14 km from the project, respectively. Access within the project is via various gravel and two-track roads that link areas where drilling is planned. The closest airport is at Cajamarca, which is serviced by regular flights from Lima. 2 SOUTHERN COPPER CORPORATION 7310 North 16th St. Suite 135, Phoenix AZ 85020 Phone: 1 (602) 264–1375 Executive Presidency Page 58 Buenavista The Buenavista mining unit operates an open pit porphyry copper mine, two concentrators and three SX EW plants. It is located within the Cananea mining district in the north-central part of the State of Sonora, Mexico. The property is located about 222 kilometers northeast of the city of Hermosillo, Sonora and 150 kilometers southeast of the city of Tucson, Arizona. The geographical location of the Cananea mining district is between latitudes 30° 42’ and 31° 16’ north and longitude meridians 109° 51’ and 110° 33’ west. The Cananea mining district is located at an altitude between 1,600 and 2,485 meters (m) above mean sea level. The property covers an area of 89,220.5 hectares of mining concessions. The elevation of the mine is 1,604 meters above mean sea level. Page 64 La Caridad La Caridad mine and mill are located about 23 kilometers southeast of the town of Nacozari in northeastern Sonora at an average altitude of 1,500 meters above mean sea level. Nacozari is about 266 kilometers northeast of the Sonora state capital of Hermosillo and 125 kilometers south of the U.S.—Mexico border. The municipality of Nacozari de García is located between 30°17’ and 30°20’ of north latitude and 109°32’ and 109 35’ of west longitude with regard to the Greenwich meridian. The average elevation is 1500 m above mean sea level. Limits of the mining unit using UTM coordinates are listed in the following table: VERTEX UTM Zone 12 WGS 84 Easting Northing 1 629,600.00 3,361,303.35 2 655,325.58 3,361,303.35 3 655,325.58 3,350,065.74 4 629,600.00 3,350,065.74 Nacozari is connected by paved highway with Hermosillo and Agua Prieta and by rail with the international port of Guaymas, and the Mexican and United States rail systems. An airstrip with a reported runway length of 2,500 meters is located 36 kilometers north of Nacozari, less than one kilometer away from the La Caridad copper smelter and refinery. The smelter and the sulfuric acid plants, as well as the refineries and rod plant, are located approximately 24 kilometers from the mine. Access is by paved highway and by railroad. Page 72 El Pilar Project The El Pilar Property is located in north central Sonora, Mexico, about 15 kilometers south of the international border with United States. The property is situated within lands of Ejido Miguel Hidalgo (also referred to as San Lazaro), in the Santa Cruz Municipality. The property is situated between UTM coordinates 3,446,000N to 3,455,000N and 526,800 E to 534,700 E. The El Pilar property comprises 9,571.4 hectares in 19 concessions. These concessions are wholly owned by Recursos Stingray de Cobre S.A de C.V., our wholly owned Mexican subsidiary. Additionally, a total of 1,926 hectares of surface rights have been successfully negotiated with Ejido Miguel Hidalgo, which will ensure that the company has all necessary land ownership rights to develop the project. 3 SOUTHERN COPPER CORPORATION 7310 North 16th St. Suite 135, Phoenix AZ 85020 Phone: 1 (602) 264–1375 Executive Presidency Page 73 El Arco Project The El Arco deposit is located near the village of El Arco in Baja California, Mexico, which lies near the center of the Baja California Peninsula in the municipalities of San Quintin, Baja California and Mulegé, Baja California Sur, Mexico. The Project centroid is at approximately 28°03’ 24.08” N; 113° 27’ 35.23” W. The center of the El Arco deposit is located at approximately 28° 02’ 02.97” N; 113° 23’ 46.75” W. Route 1 is the only paved highway connecting the northern and southern parts of the Baja Peninsula. El Arco is located between the towns of Santa Rosalía and Guerrero Negro at kilometer 189. The El Arco site is accessed by taking Highway 1 approximately 30 kilometers south of the town of Guerrero Negro to the intersection with the highway MX 18, and following MX 18 for 42 kilometers east to the project site. Highway 1 is paved and in good condition and Highway 18 was originally paved but is now unpaved, leaving a gravel roadbed. Page 76 Charcas The Charcas mining complex is located approximately 110 kilometers north of the city of San Luis Potosi in the State of San Luis Potosi, Mexico. The mine uses the Universal Transverse Mercator (UTM) World Geodetic System (WGS84) Zone 14Q coordinate system and is located at 2 560 223 N and 280 042 E at an altitude of 2,150 meters above sea level. Charcas is connected to the state capital by a paved highway of 130 kilometers. It was discovered in 1573 and operations in the 20th century began in 1911. The complex includes three underground mines (San Bartolo, Rey Reina and La Aurora) and one flotation plant that produces zinc, lead and copper concentrates with significant amounts of silver. The Charcas mine is characterized by low operating costs and good quality ores and is situated near the zinc refinery. Charcas is exploited underground by room and pillar with hydraulic cut and fill. The crushed ore is transported to the surface for processing in the flotation plant. Page78 Santa Barbara The Santa Barbara mining complex is located approximately 26 kilometers southwest of the city of Hidalgo del Parral in southern Chihuahua, Mexico. The mine uses the Universal Transverse Mercator (UTM) World Geodetic System (WGS84) Zone 13R coordinate system and is located at 2 965 880 N and 418 948 E at an altitude of 2,000 m above sea level. The area can be reached via a paved road of from Hidalgo del Parral, a city on a federal highway. The area is also connected to the state capital of Chihuahua 250 km along Highway 24. It was discovered in 1536 and mining activities in the 20th century began in 1913. Santa Barbara includes three main underground mines (San Diego, Segovedad and Tecolotes) as well as a flotation plant and produces lead, copper and zinc concentrates with significant amounts of silver. Page 81 San Martin The San Martin mining complex is located in the municipality of Sombrerete in the northwestern part of the state of Zacatecas, Mexico. It is located approximately 185 kilometers from the city of Zacatecas. The elevation of the San Martin mining complex is approximately 2,600 meters (m) with geographic coordinates of 629,000 E and 2,614,000 N (WGS84, UTM Zona 13). The nearest major town is the municipality of Sombrerete (17 km away) in the Sierra Madre Occidental geographic province. It was discovered in 1555 and mining operations in the 20th century began 4 SOUTHERN COPPER CORPORATION 7310 North 16th St. Suite 135, Phoenix AZ 85020 Phone: 1 (602) 264–1375 Executive Presidency in 1949. The complex includes an underground mine and a flotation plant. The ore body contains lead, copper and zinc concentrates with significant amounts of silver. The state of Zacatecas has an extensive infrastructure of roads and highways that connect the San Martín to the rest of the country. The San Martin mining unit has a paved road to Highway 45, which leads to the town of Sombrerete, 17 kilometers away. Highway 45 then connects Sombrete to Fresnillo, Zacatecas and Durango at distances of 110,171 and 125 kilometers, respectively. The disclosure of geographic coordinates for Tia Maria, Los Chancas and Pilares was included in the 2022 Form 10-K Annual Report on pages 51, 52 and 71 respectively. UTM = Universal Transverse Mercator WGS World Geodetic System 2. For each of your material properties identified under this section, please ensure the metallurgical recovery factor and the cut-off grade are disclosed with the mineral resource table and the mineral reserve table, as required by Item 1304(d)1 of Regulation S-K. In this regard we note the Buenavista, La Caridad, Pilares, Pilar, Charcas, Santa Barbara, and San Martin mineral resource and/or mineral reserve tables are missing one or both of these items. We appreciate the staff’s comment and will expand our disclosure in future filings to include the information requested in the tables as follows: The new text is in italic and underlined. Page references correspond to Form 10-K for fiscal year 2022. 5 SOUTHERN COPPER CORPORATION 7310 North 16th St. Suite 135, Phoenix AZ 85020 Phone: 1 (602) 264–1375 Executive Presidency Page 62-64 Buenavista Mineral resources The following table contains the summary of copper, molybdenum and zinc mineral resources for Buenavista as of December 31, 2022, based on long-term price assumptions of $3.80, $11.50 and $1.32 per pound, respectively: 2022 Copper plant Amount (million tonnes) Copper grades Molybdenum grades Zinc grades Contained copper (million pounds) Contained molybdenum (million pounds) Contained zinc (million pounds) Variation Copper Variation Molybdenum Variation Zinc Measured mineral resources — — % — % — % — — — Indicated mineral resources 764 0.34 % 0.005 % 0.07 % 5,664 88 1,182 (28.2) % (21.6) % (18.4) % Measured + Indicated mineral resources 764 0.34 % 0.005 % 0.07 % 5,664 88 1,182 (28.2) % (21.6) % (18.4) % Inferred mineral resources 13,015 0.21 % 0.004 % 0.03 % 56,584 1,080 8,089 (15.7) % (16.9) % (14.8) % Zinc plant Amount (million tonnes) Copper grades Molybdenum grades Zinc grades Contained copper (million pounds) Contained molybdenum (million pounds) Contained zinc (million pounds) Measured mineral resources — — % — % — % — — — Indicated mineral resources 148 0.46 % 0.002 % 0.78 % 1,561 4 2,416 (16.4) % (33.3) % (22.8) % Measured + Indicated mineral resources 148 0.46 % 0.002 % 0.78 % 1,561 4 2,416 (16.4) % (33.3) % (22.8) % Inferred mineral resources 143 0.43 % 0.003 % 0.49 % 1,393 7 1,638 (23.9) % (50.0) % (22.0) % Leach plant Amount (million tonnes) Copper grades Molybdenum grades Zinc grades Contained copper (million pounds) Contained molybdenum (million pounds) Contained zinc (million pounds) Measure