SEC Comment Letter 0000000000-23-007683 to ALLIANCE RESOURCE PARTNERS LP (ARLP) (CIK 0001086600) (ARLP)
ALLIANCE RESOURCE PARTNERS LP (ARLP) (CIK 0001086600)
Date: July 19, 2023 · CIK: 0001086600 · Accession: 0000000000-23-007683
AI Filing Summary & Sentiment
File numbers found in text: 000-26823
Letter
United States securities and exchange commission logo July 19, 2023 Cary Marshall Chief Financial Officer Alliance Resource Partners LP 1717 South Boulder Avenue, Suite 400 Tulsa, Oklahoma 74119 Re:Alliance Resource Partners LP Form 10-K for the Fiscal Year ended December 31, 2022 Filed February 24, 2023 File No. 000-26823 Dear Cary Marshall: We have reviewed your July 14, 2023 response to our comment letter and have the following comments. In some of our comments, we may ask you to provide us with information so we may better understand your disclosure. Please respond to these comments 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 our comments apply to your facts and circumstances, please tell us why in your response. After reviewing your response to these comments, we may have additional comments. Unless we note otherwise, our references to prior comments are to comments in our July 5, 2023 letter. Form 10-K for the Fiscal Year ended December 31, 2022 Exhibits and Financial Statement Schedules Exhibit 96.5, page 190 1.We note your response to prior comment 1 proposing to address certain deficiencies in the Tunnel Ridge Mine Technical Report Summary when filing your next annual report, though also expressing the view that Figure 18-1 and Figure 18-2 are "consistent" with Item 1302(e)(12) and Item 601(b)(96)(iii)(B)(18)(i) of Regulation S-K, and that Figure 19-1 and Table 19-1 are "responsive" to Item 1302(e)(11) and Item 601(b)(96)(iii)(B)(19)(ii) of Regulation S-K.
We see that you have nevertheless included tabulations with the capital and operating cost estimates among the revisions proposed though have not agreed to include tabulations
FirstName LastNameCary Marshall Comapany NameAlliance Resource Partners LP July 19, 2023 Page 2 FirstName LastName Cary Marshall Alliance Resource Partners LP July 19, 2023 Page 2 with the annual cash flow forecasts based on your annual production schedule for the life of the project and therefore we partially reissue the comment. While we do not object to inclusion of the various graphical illustrations referenced in your response, we do not regard such illustrations alone, without tabulations of the corresponding numerical data, as providing an adequate level of detail or precision for the information that is required.
We continue to believe that you will need to obtain and file a Technical Report Summary that presents the annual cash flow forecasts and related line item details in a tabular format, similar to Table 19.1 in the July 2022 version of the report, in order to comply with Item 601(b)(96)(iii)(B)(19)(ii) of Regulation S-K.
You may contact John Coleman, Mining Engineer, at 202-551-3610 or Karl Hiller, Branch Chief, at 202-551-3686 if you have questions regarding comments. Sincerely, Division of Corporation Finance Office of Energy & Transportation
Show Raw Text
United States securities and exchange commission logo
July 19, 2023
Cary Marshall
Chief Financial Officer
Alliance Resource Partners LP
1717 South Boulder Avenue, Suite 400
Tulsa, Oklahoma 74119
Re:Alliance Resource Partners LP
Form 10-K for the Fiscal Year ended December 31, 2022
Filed February 24, 2023
File No. 000-26823
Dear Cary Marshall:
We have reviewed your July 14, 2023 response to our comment letter and have the
following comments. In some of our comments, we may ask you to provide us with information
so we may better understand your disclosure.
Please respond to these comments 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 our
comments apply to your facts and circumstances, please tell us why in your response.
After reviewing your response to these comments, we may have additional
comments. Unless we note otherwise, our references to prior comments are to comments in our
July 5, 2023 letter.
Form 10-K for the Fiscal Year ended December 31, 2022
Exhibits and Financial Statement Schedules
Exhibit 96.5, page 190
1.We note your response to prior comment 1 proposing to address certain deficiencies in the
Tunnel Ridge Mine Technical Report Summary when filing your next annual report,
though also expressing the view that Figure 18-1 and Figure 18-2 are "consistent" with
Item 1302(e)(12) and Item 601(b)(96)(iii)(B)(18)(i) of Regulation S-K, and that Figure
19-1 and Table 19-1 are "responsive" to Item 1302(e)(11) and Item
601(b)(96)(iii)(B)(19)(ii) of Regulation S-K.
We see that you have nevertheless included tabulations with the capital and operating cost
estimates among the revisions proposed though have not agreed to include tabulations
FirstName LastNameCary Marshall
Comapany NameAlliance Resource Partners LP
July 19, 2023 Page 2
FirstName LastName
Cary Marshall
Alliance Resource Partners LP
July 19, 2023
Page 2
with the annual cash flow forecasts based on your annual production schedule for the life
of the project and therefore we partially reissue the comment. While we do not object to
inclusion of the various graphical illustrations referenced in your response, we do not
regard such illustrations alone, without tabulations of the corresponding numerical data, as
providing an adequate level of detail or precision for the information that is required.
We continue to believe that you will need to obtain and file a Technical Report Summary
that presents the annual cash flow forecasts and related line item details in a tabular
format, similar to Table 19.1 in the July 2022 version of the report, in order to comply
with Item 601(b)(96)(iii)(B)(19)(ii) of Regulation S-K.
You may contact John Coleman, Mining Engineer, at 202-551-3610 or Karl Hiller,
Branch Chief, at 202-551-3686 if you have questions regarding comments.
Sincerely,
Division of Corporation Finance
Office of Energy & Transportation