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CORRESP
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filename1.htm

July 29,
2024

CORRESPONDENCE FILING VIA EDGAR

U.S.
Securities and Exchange Commission

Division of Corporation Finance

Office of Energy & Transportation

100 F Street, N.E.

Washington, D.C. 20549

Attention: John Coleman

  Craig Arakawa

      Re:
    Coronado Global Resources Inc.

    Form 10-K for the Fiscal Year Ended December 31, 2023

    Filed February 20, 2024

    File No. 000-56044

Ladies and Gentlemen:

Coronado Global Resources, Inc., a Delaware
corporation (the “Company”), is submitting this letter in response to the comment letter from the staff (the “Staff”)
of the Securities and Exchange Commission (the “Commission”), dated June 20, 2024, with respect to the Company’s
Annual Report on Form 10-K for the fiscal year ended December 31, 2023, filed February 20, 2024 (“Form 10-K”).

Below are the Company’s responses. For the
convenience of the Staff, the Company has repeated the Staff’s comment before the corresponding response.

Form 10-K for the Fiscal Year Ended December 31, 2023

Item 15. Exhibits, Financial Statement Schedules

96.1, page 163

 1. Please revise subsequent technical report summaries for the Curragh Mine Complex to include the entire discounted cash flow analysis
to comply with Item 601(b)(96)(iii)(B)(19) of Regulation S-K. At a minimum this should include material assumptions including line items
in tabular format for production, revenue, operating costs, royalties, taxes, and capital costs for each year for the life of the project.

Additionally we note that you include disclosure on page 11
of the technical report summary explaining that inferred resources have been included in the LOM plan, however have a minimal impact on
the net present value valuation. Please revise to remove the inferred resource from the LOM plan and economic analysis to comply with
Item 1302(e)(6) of Regulation S-K.

United States Securities and Exchange Commission

July 29, 2024

Page 2

Please include a draft of your proposed revisions with
your response. To the extent that the removal of the inferred from the LOM plan and economic analysis is material to the overall report
you should file a revised technical report summary.

Response:
The Company’s acknowledges the Staff’s comment, and will revise subsequent technical report summaries for the Curragh Mine
Complex that it files to (i) include the entire discounted cash flow analysis to comply with Item 601(b)(96)(iii)(B)(19) of Regulation
S-K and (ii) remove the inferred resource from the LOM plan and economic analysis to comply with Item 1302(e)(6) of Regulation
S-K, substantially in the format below.

The Company respectfully advises the Staff that
the removal of the inferred resource from the LOM plan and economic analysis is reflected in the revisions set out below. We consider
the revisions immaterial to the overall Technical Report Summary for the Curragh Mine Complex that the Company filed as Exhibit 96.1
to the Form 10-K. The removal of inferred resources from the cash flow model has reduced the estimated net present value of the project
cash flows to $1,015 million from $1,066 million, as previously disclosed; however, this change does not impact the conclusion of economic
viability supporting the disclosure of the mineral reserves for the Curragh Mine Complex.

Accordingly, the Company does not intend to file
a revised Technical Report Summary for the Curragh Mine Complex at this time.

The following is a draft of the Company’s
proposed revisions to Section 1.9 and Section 19 of the Technical Report Summary for the Curragh Mine Complex that the Company
filed as Exhibit 96.1 to the Form 10-K. The Company will include disclosure in substantially the same format in subsequent technical
report summaries that it files for the Curragh Mine Complex.

1.9 Economic Evaluation

The financial model prepared for this Technical Report Summary (TRS)
was developed to test the economic viability of the Coal Reserves. The results of this financial model are not intended to represent a
bankable feasibility study, required for financing of any current or future mining operations contemplated for the Coronado properties,
but are intended to establish the economic viability of the estimated Coal Reserves. Cash flows are simulated on an annual basis based
on projected production from the Coal Reserves.

The project cash flows, excluding debt service, are calculated by subtracting
direct and indirect operating expenses, tax payments and capital expenditures from revenue. Customer coal pricing have been estimated
based on industry specialists forecasts and appropriate discounts and adjustments applicable to Curragh’s products.

Economic outcomes include capital forecasts and government and contracted
royalty and rebate payments.

United States Securities and Exchange Commission

July 29, 2024

Page 3

As shown in Table 1.4 the Curragh Mine shows positive EBITDA over the
LOM. Overall, Curragh’s operations show positive LOM P&L and EBITDA of over $4.1 billion and $6.3 billion, respectively.

Curragh’s cash flow summary, excluding debt service, is shown
in section 19.2.

Table 1.4: LOM
tonnage, Profit & Loss (P&L) before tax and EBITDA

    LOM
    LOM
    PandL
    LOM
    EBITDA

    Tonnes
    Pre-Tax PandL
    Per Tonne
    EBITDA
    Per Tonne

    Curragh
    223Mt  $
    4.1 billion
    $ 18
    $ 6.3 billion
    $ 28

Consolidated cash flow from operations is positive over the mine life
with the post-production years showing negative cash flows due to end-of-mine reclamation spending.

Cash flow after tax, but before debt service, generated over the life
of the project was discounted to NPV at a 10.0% discount rate, which represents the risk adjusted return demanded by a hypothetical investor
in Curragh, also referred as the Weighted Average Costs of Capital (WACC). The assessment of an appropriate discount rate is a matter
of judgement considering market pricing information and the characteristics, circumstances and risks specific to the asset generating
the cash flows subject to discounting.

The NPV of the project cash flows is a point in time estimate of potential
economic outcomes with scope for further projects not exhausted. The NPV amounts to approximately USD 1,015 million as a base line only
with outcomes highly dependent upon market based pricing, exchange rates, and various other factors. The financial model prepared for
the TRS was developed to test the economic viability of each coal resource area. The NPV estimate was made for purposes of confirming
the economics for classification of coal reserves and not for purposes of valuing Coronado or its Curragh assets. Mine plans may change
or be optimised to increase cashflow/NPV from the mine. In all cases, the mine production plan assumes the properties are under competent
management.

19.0      Economic
Analysis

19.1  Assumptions, Parameters and Methods

The Mine plan, productivity expectations and cost estimates generally
reflect historical performance by Coronado and efforts have been made to adjust plans and costs to reflect future conditions and comply
with contractual obligations.

The financial model, prepared for this TRS, was developed to test the
economic viability of the Coal Reserve estimate. The results of this financial model are not intended to represent a bankable feasibility
study, required for financing of any current or future mining operations, but are intended to prove the economic viability of the estimated
Coal Reserves.

United States Securities and Exchange Commission

July 29, 2024

Page 4

On an unlevered basis, the NPV of the project cash flows after taxes
was estimated for the purpose of classifying Coal Reserves. The project cash flows, excluding debt service, are calculated by subtracting
direct and indirect operating expenses and capital expenditures from revenue. Revenue is derived from long term forward price estimates
observed at December 2023. The revenue pricing assumptions used in this cashflow model are outlined in section 16.2 of this TRS.
Both upstream and downstream costs are calculated based on site knowledge of costs profiles and contractor obligations. Net cash flows
incorporate applicable state and federal taxes plus progressive reclamation obligations to the end of mine closure. All cash flows are
denominated in nominal USD incorporating inflation of 2.5% in FY24 and 2.0% thereafter.

All figures are reported in USD millions unless otherwise stated and
volume related data is reported on a metric tonne basis. The net present value of the projected cash flows have been calculated adopting
a 10% post-tax discount rate.

The projection model also includes notional income tax calculations
at the Curragh level adopting a federal tax rate of 30%. To the extent the mine generates net operating losses for tax purposes, the losses
are carried over to offset future taxable income. The terms “cash flows” and “project cash flows” used in this
report refer to after tax, unlevered cash flows.

19.2 Cash Flow Model

As shown in Table 19-1, the Curragh Mine shows positive EBITDA
over the LOM. Overall, Coronado’s consolidated operations show positive LOM P&L and EBITDA of $4.1 billion and $6.3 billion,
respectively.

Table 19-1: Life-of-Mine Tonnage, P&L before
Tax, and EBITDA

    LOM
    LOM
    PandL
    LOM
    EBITDA

    Tonnes
    Pre-Tax PandL
    Per Tonne
    EBITDA
    Per Tonne

    Curragh
    223Mt  $
    4.1 billion
    $ 18
    $ 6.3 billion
    $ 28

United States Securities and Exchange Commission

July 29, 2024

Page 5

A summary of the key financial performance metrics projected through
2031 is provided below in Table 19-2.

Table 19-2: Summary of Curragh Key Financial
Performance Metrics (2024-2031)

     

    Rest

    of

     
    Total
    2024
    2025
    2026
    2027
    2028
    2029
    2030
    2031
    LOM
    Avg.1

    ROM Production Tonnes  (Mt)
    290.3
    13.8
    16.6
    16.4
    16.4
    16.9
    16.7
    16.7
    16.8
    14.5

    Yield  (%)
    77 %
    83 %
    81 %
    82 %
    82 %
    80 %
    79 %
    80 %
    76 %
    74 %

    Saleable Production Tonnes (Mt)
    223.4
    11.5
    13.5
    13.5
    13.5
    13.5
    13.2
    13.3
    12.9
    10.7

     

    Met Tonnes  (Mt)
    161.1
    8.4
    9.8
    9.5
    10.3
    10.2
    10.6
    9.7
    9.9
    7.5

    Thermal Tonnes (Mt)
    62.4
    3.2
    3.7
    4.0
    3.2
    3.3
    2.9
    3.5
    3.4
    3.2

      Total Saleable Tonnes  (Mt)
    223.4
    11.5
    13.5
    13.5
    13.5
    13.5
    13.5
    13.2
    13.3
    10.7

     

    Cash Costs per Tonne ($/t)

    Mine cash costs
    83.9
    77.0
    78.0
    77.5
    80.9
    81.2
    83.7
    85.7
    87.2
    86.1

    Freight costs
    19.9
    15.0
    15.3
    15.7
    17.9
    19.0
    19.3
    19.7
    19.5
    21.9

    Royalties and rebates
    23.1
    29.3
    21.8
    21.6
    16.4
    15.7
    19.7
    19.0
    20.7
    25.5

    SG&A and other costs
    4.1
    6.6
    3.4
    1.0
    6.3
    3.4
    5.0
    4.0
    4.1
    4.1

     Total Cash Costs
    131.0
    127.8
    118.6
    115.8
    121.5
    119.4
    127.8
    128.4
    131.4
    137.5

     

    EBITDA per Tonne ($/t)
    28.0
    9.8
    6.6
    9.9
    16.6
    23.0
    27.0
    23.8
    25.1
    30.7

     

    Expansion CapEx ($M))
    456
    50
    50
    36
    0
    49
    49
    63
    78
    80

    Sustaining CapEx ($M)
    1,334
    55
    50
    56
    64
    66
    74
    89
    73
    808

      Total CapEx  ($M)
    1,790
    105
    100
    92
    64
    115
    123
    153
    151
    888

1 For expansion and sustaining CapEx, the table presents
total investment in millions of dollars.

United States Securities and Exchange Commission

July 29, 2024

Page 6

After Tax Cash Flows were developed in order to calculate the NPV
for this Property. The projections adopt a life of mine average exchange rate of 0.69 which has been assessed having regard to exchange
rate forward curves, economic specialists’ forecasts and broker consensus as at 31 December 2023. The NPV is estimated to
be US$1,015 million at a discount rate of 10.0%. A summary of the Curragh after-tax cash flow is shown in Table 19-3.

Table 19-3: Project Cash Flow Summary

    US$ million
    (nominal)
    2024
    2025
    2026
    2027
    2028
    2029
    2030

    Production &
    sales (Mt)
      11.5
      13.5
      13.5
      13.5
      13.5
      13.5
      13.2

    Revenue
      1,584
      1,688
      1,696
      1,865
      1,920
      2,089
      2,010

    Operating costs
      (1,134 )
      (1,305 )
      (1,271 )
      (1,419 )
      (1,398 )
      (1,458 )
      (1,445 )

    Royalties & rebates
      (337 )
      (294 )
      (292 )
      (222 )
      (212 )
      (266 )
      (251 )

    EBITDA
      113
      89
      133
      224
      310
      365
      314

    Payable income tax
      (5 )
      0
      (11 )
      (43 )
      (63 )
      (78 )
      (59 )

    Working capital movement
      4
      38
      (29 )
      15
      (17 )
      7
      (1 )

    Capex
      (105 )
      (100 )
      (92 )
      (64 )
      (115 )
      (123 )
      (153 )

    Rehabilitation
    costs
      (9 )
      (5 )
      (4 )
      (4 )
      (5 )
      (4 )
      (5 )

    Free
    cash flow
      (2 )
      22
      (3 )
      128
      110
      166
      96

    US$ million (nominal)
    2031
    2032
    2033
    2034
    2035
    2036
    2037

    Production &
    sales tonnes (Mt)
      13.3
      12.9
      13.2
      13.0
      13.3
      12.4
      12.4

    Revenue
      2,085
      2,102
      2,155
      2,113
      2,304
      2,129
      2,238

    Operating costs
      (1,475 )
      (1,488 )
      (1,461 )
      (1,365 )
      (1,407 )
      (1,321 )
      (1,342 )

    Royalties & rebates
      (275 )
      (295 )
      (304 )
      (297 )
      (346 )
      (321 )
      (325 )

    EBITDA
      335
      319
      390
      451
      551
      486
      571

    Payable income tax
      (63 )
      (57 )
      (86 )
      (104 )
      (133 )
      (116 )
      (140 )

    Working capital movement
      (6 )
      2
      (11 )
      (23 )
      (9 )
      (6 )
      (17 )

    Capex
      (151 )
      (148 )
      (80 )
      (92 )
      (93 )
      (82 )
      (94 )

    Rehabilitation
    costs
      (9 )
      (8 )
      (9 )
      (9 )
      (10 )
      (7 )
      (7 )

    Free
    cash flow
      106
      107
      204
      224
      306
      275
      312

    US$ million (nominal)
    2038
    2039
    2040
    2041
    2042
    2043
    2044

    Production &
    sales tonnes (Mt)
      10.0
      9.9
      9.3
      8.3
      3.2
      0.0
      0.0

    Revenue
      1,823
      1,839
      1,764
      1,538
      583
      0
      0

    Operating costs
      (1,115 )
      (1,066 )
      (1,031 )
      (969 )
      (646 )
      0
      0

    Royalties & rebates
      (265 )
      (273 )
      (267 )
      (229 )
      (86 )
      0
      0

    EBITDA
      444
      500
      467
      339
      (149 )
      0
      0

    Payable income tax
      (105 )
      (122 )
      (113 )
      (75 )
      0
      0
      0

    Working capital movement
      (7 )
      (30 )
      (18 )
      0
      33
      (43 )
      0

    Capex
      (67 )
      (68 )
      (68 )
      (63 )
      (33 )
      0
      0

    Rehabilitation
    costs
      (10 )
      (10 )
      (10 )
      (12 )
      (21 )
      (24 )
      (25 )

    Free
    cash flow
      255
      270
      259
      189
      (170 )
      (66 )
      (25 )

United States Securities and Exchange Commission

July 29, 2024

Page 7

    US$ million
    (nominal)
    2045
    2046
    2047
    2048
    2049
    2050
    2051

    Production &
    sales tonnes (Mt)
      0.0
      0.0
      0.0
      0.0
      0.0
      0.0
      0.0

    Revenue
      0
      0
      0
      0
      0
      0