SecProbe.io

October 25, 2024
Matthew Giljum
Chief Financial Officer
Arch Resources, Inc
1 City Place Drive
Suite 300
St. Louis, Missouri 63141
Re:Arch Resources, Inc
Form 10-K for the Fiscal year Ended December 31, 2023
Filed February 15, 2024
File No. 001-13105
Dear Matthew Giljum:
            We have reviewed your filing and have the following comments.
            Please respond to this letter within ten business days by providing the requested
information or advise us as soon as possible when you will respond. If you do not believe a
comment applies to your facts and circumstances, please tell us why in your response.
            After reviewing your response to this letter, we may have additional comments.
Form 10-K for the Fiscal year Ended December 31, 2023
Item 2. Properties., page 64
1.We note that you have disclosed measured and indicated resources of 12.9 million
tons for your Leer South property, however your technical report for Leer South, filed
as Exhibit 96.2, indicates that there are no mineral resources on the property,
exclusive of reserves.  Please advise.
Please address the following with respect to your S-K 1300 mineral property
disclosure:
•Include the commodity price for each resource, including nonmaterial properties,
with your summary resource table and your summary reserve table as required by
Item 1303(b)(3) of Regulation S-K; and
Include the commodity price, cut-off grade, and process recovery factor with your
individual property reserve tables as required by Item 1304(d)(1) of Regulation S-
K. To the extent you do not use a traditional cut-off grade include a brief
description of the parameters and assumptions that distinguishes material deemed •2.

October 25, 2024
Page 2
to have no economic value from material deemed to have economic value, for
example minimum quality specifications or other.
Exhibits to be included in 10-K
96.2, page 99
3.We have the following observations regarding your technical report summary for the
Leer South Complex, prepared by Marshall Miller and Associates, Inc. and dated
February 2024. Please consult with your qualified person and tell us how you plan to
address each of these items. In you do not concur with any of these observations
please explain in your response.

•Disclose the name or number of each title, claim, mineral right, lease or option
under which the property is held and describe the mineral rights, as required by
Item 601(b)(96)(iii)(B)(3)(iii) & (iv) of Regulation S-K. At a minimum this
disclosure should summarize property contracts, royalty payments, mineral rights,
and expiration dates;
•Disclose the current and future permitting requirements as required by Item
601(b)(96)(iii)(B)(3)(v) of Regulation S-K;
•Include Appendix C, which is referenced on page 47with respect to the footprint
of the LOM plan;
•Revise to remove uncontrolled tonnage from the reserve table;
•Revise to address all items in section 14 with respect to current processing,
including a flow sheet and equipment specifications;
•Revise to address all items in section 15 with respect to infrastructure, including a
description of the property infrastructure;
•Disclose the accuracy and contingency of the capital and cost estimates as
required by Item 601(b)(96)(iii)(B)(18)(i) of Regulation S-K; and
•Only reserves should be included in the cash flow model and life-of-mine plan.
Revise to move materials from the life-of-mine plan and cash flow model that do
not meet the definition of a mineral reserve, consistent with Item 1302(e)(5) & (6)
of Regulation S-K.
            We remind you that the company and its management are responsible for the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action or absence
of action by the staff.
            Please contact John Coleman at 202-551-3610 or Craig Arakawa at 202-551-3650 if
you have questions regarding comments.
Sincerely,
Division of Corporation Finance
Office of Energy & Transportation

October 25, 2024
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cc:Charlie Carpenter