United States securities and exchange commission logo
October 31, 2022
Todd Munsey
Chief Financial Officer
Alpha Metallurgical Resources, Inc.
340 Martin Luther King Jr. Blvd
Bristol, Tennessee 37620
Re: Alpha Metallurgical
Resources, Inc.
Form 10-K for the
Fiscal Year Ended December 31, 2021
Filed March 7, 2022
File No. 001-38735
Dear Todd Munsey:
We have reviewed your filing 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.
Form 10-K for the Fiscal Year Ended December 31, 2021
Item 1. Business, page 8
1. Please tell us if your
mineral property summary disclosure includes all properties as
required by Item 1303
(a)(1) of Regulation S-K. For example the table on
page 8 lists eighteen
active mines, however your disclosure on page 56 states that you
have twenty active
mines.
Item 2. Properties, page 51
2. We note that the coal
reserves and resources disclosed in your annual filing for the
Kingston and Marfork
complexes are different than the coal reserves and resources
numbers in your
technical reports. For example, the Kingston coal reserve is 32,489,000
tons and the coal
resource is 21,254,000 tons in your 10-K filing compared to the coal
reserve of 60,740,000
tons and the coal resource of 28,337,000 tons in your technical
report summary filed as
Exhibit 96.3. Additionally the Marfork coal reserve is
Todd Munsey
Alpha Metallurgical Resources, Inc.
October 31, 2022
Page 2
145,741,000 tons and the coal resource is 128,786,000 tons in your
10-K filing compared
to the coal reserve of 117,491,000 tons and the coal resource of
121,702,000 tons in your
technical report summary filed as Exhibit 96.4 Please advise.
3. Please revise to include the information required under Item 1305 of
Regulation S-K
regarding internal controls used in your exploration and mineral
resource and reserve
estimation efforts.
Exhibit Index
Exhibit No. 96.1, 96.2, 96.3, 96.4, & 96.5, page 144
4. Please address the following with respect to you technical reports:
Include the information required under Item
601(b)(96)(iii)(B)(3)(iii) of Regulation
S-K regarding your title, claim, mineral lease, or option
agreements.
In certain instances it appears that mineral resources inclusive
of reserves have been
added to mineral resources that are exclusive of reserves. For
example, Table 11-4 of
Exhibit 96.3 includes a "Grand Total" measured resource of
105,204,000 tons that is
the sum of 102,715,000 tons of measured resources that are
inclusive of reserves and
2,489,000 tons of mineral resources that are exclusive of
reserves. Generally mineral
resources that are exclusive of reserves are a subset of mineral
resources that are
inclusive of reserves and are not additive. Please advise.
Please revise the "Reliance on Information by the Registrant"
section of your
technical reports to only include categories of information under
Item 1302 (f)(1) of
Regulation S-K. Other information that has been included in this
section should be
removed so that the information is consistent with the disclosure
specified under Item
1302 (f)(2) 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.
You may contact John Coleman at 202-551-3610 or Gus Rodriguez at
202-551-3752 if
you have questions regarding comments.
FirstName LastNameTodd Munsey Sincerely,
Comapany NameAlpha Metallurgical Resources, Inc.
Division of
Corporation Finance
October 31, 2022 Page 2 Office of Energy
& Transportation
FirstName LastName