SEC Comment Letter 0000000000-23-004202 to WARRIOR MET COAL, INC. (HCC) (CIK 0001691303) (HCC)
WARRIOR MET COAL, INC. (HCC) (CIK 0001691303)
Date: April 25, 2023 · CIK: 0001691303 · Accession: 0000000000-23-004202
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United States securities and exchange commission logo
April 25, 2023
Dale W. Boyles
Chief Financial Officer
Warrior Met Coal, Inc.
16243 Highway 216
Brookwood, Alabama 35444
Re:Warrior Met Coal, Inc.
Form 10-K for the Fiscal Year ended December 31, 2022
Filed February 15, 2023
File No. 001-38061
Dear Dale W. Boyles:
We have reviewed your April 20, 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
April 6, 2023 letter.
Form 10-K for the Fiscal Year ended December 31, 2022
Exhibits 96.1, 96.2, and 96.3
Section 1 - Executive Summary
1.6 - Mineral Resource, page ES-1
1.We note your response to prior comment three explaining that for the Blue Creek property
the technical report summary includes resources both inclusive and exclusive of reserves,
although for Mine No. 4 and Mine No. 7, there are no resources incremental to
mineralization quantified as reserves, and therefore the corresponding reports present only
resources inclusive of reserves, i.e. reserves and no resources.
Please coordinate with the qualified persons as necessary to include a table in each of the
Mine No. 4 and Mine No. 7 reports to clarify that there are no resources exclusive of
FirstName LastNameDale W. Boyles
Comapany NameWarrior Met Coal, Inc.
April 25, 2023 Page 2
FirstName LastName
Dale W. Boyles
Warrior Met Coal, Inc.
April 25, 2023
Page 2
reserves for these two properties. In addition, please confirm that the qualified persons
will include the mine recovery factors and other relevant factors utilized in converting all
of the resources to reserves in these reports.
Section 3 - Property Description
3.1 - Location, page ES-3
2.We note your response to prior comment 5, indicating that you regard the maps provided
in Section 1.1 of each technical report summary as sufficiently responsive to the
requirements in Item 601(b)(96)(iii)(B)(3)(i) of Regulation S-K. However, we believe that
the qualified persons should add coordinate lines with appropriate labels to these maps, or
state the coordinates in the accompanying text, using a common coordinate system such as
latitude/longitude, UTM coordinates, or Section, Township and Range.
Section 18 - Capital and Operating Costs
18.1 - Capital Cost Estimate, page ES-18
3.We note your response to prior comment 11 including an example of the table that will be
provided in each technical report summary to disclose the annual estimates of capital and
operating costs, although the table does not appear to be representative in this regard.
However, certain details that would be responsive are included in the example of the table
shown in your response to prior comment 12, regarding estimates of the annual after-tax
cash flows used to demonstrate the economic viability of the project or property.
Please provide an example of the table that will include your estimates of annual capital
and operating costs, including major line items and totals as requested.
You may contact George K. Schuler, Mining Engineer, at 202-551-3718 if you have
questions regarding the engineering comments or Karl Hiller, Branch Chief, at at 202-551-3686
with any other questions.
Sincerely,
Division of Corporation Finance
Office of Energy & Transportation