United States securities and exchange commission logo
April 6, 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 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, 2022
Properties
Summary of Mineral Reserves, page 56
1. Please disclose your
wash plant recovery as a footnote to all of the tabulations that include
your reserve estimates
to address the requirements in Item 1304(d) of Regulation S-K.
Exhibits 96.1, 96.2, and 96.3
Technical Report Summaries for Mine No. 7, Mine No. 4, and Blue Creek,
page 89
2. The remaining comments
pertain to each of the three exhibits referenced above and will
require revisions to
conform to the requirements referenced in the comments. Please
discuss the concerns
outlined in the comments with the qualified persons involved in
preparing the reports
and arrange to obtain and file revised technical report summaries
that include all of the
information that is necessary to support your disclosures of
resources and reserves
pursuant to Item 1302(a)(1) of Regulation S-K.
Dale W. Boyles
FirstName LastNameDale W. Boyles
Warrior Met Coal, Inc.
Comapany
April NameWarrior Met Coal, Inc.
6, 2023
April 26, 2023 Page 2
Page
FirstName LastName
Section 1 - Executive Summary
1.6 - Mineral Resource, page ES-1
3. We note that estimates of resources as reported in this section and
elsewhere in the
Technical Report Summary include estimates of reserves.
As the qualified person has chosen to disclose mineral resources
inclusive of mineral
reserves, he or she must also clearly state the mineral resources
exclusive of mineral
reserves to comply with Item 601(b)(96)(iii)(B)(11)(ii) of Regulation
S-K.
1.7 - Mineral Reserve, page ES-1
4. The coal price used to estimate the reserves and the wash plant
recovery factor should be
specified to comply with Item 601(b)(96)(iii)(B)(12)(ii) and (iii) of
Regulation S-K.
Section 3 - Property Description
3.1 - Location, page ES-3
5. The location of your mining properties should be described with
details that are
accurate to within one mile, using an easily recognizable coordinate
system, and maps
having engineering details (such as scale, orientation, and titles)
that show the location of
the property to comply with Item 601(b)(96)(iii)(B)(3)(i) of
Regulation S-K.
Section 8 - Sample Preparation Analyses and Security
8.2 - Lab Procedures, page ES-8
6. The qualified person must provide his or her opinion as to adequacy of
your sample
preparation, security, and analytical procedures to comply with Item
601(b)(96)(iii)(B)(8)(iv) of Regulation S-K.
Section 10 - Mineral Processing and Metallurgical Testing
10.4 - Relevant Results, page ES-10
7. This section should include an estimate of your wash plant recovery
and the qualified
persons opinion as to adequacy of your metallurgical data to comply
with Item
601(b)(96)(iii)(B)(10)(v) of Regulation S-K.
Section 13 - Mining Methods
13.2 - Production Rates, page ES-13
8. The annual numerical values of the Life-of-Mine (LOM) production
schedule (including
totals), and descriptions (that include quantification) of any
resources and/or adverse tracts
that are included in your LOM production schedule, along with their
potential
significance/impact on future production, should be provided to comply
with Item
601(b)(96)(iii)(B)(13)(ii) of Regulation S-K.
Dale W. Boyles
Warrior Met Coal, Inc.
April 6, 2023
Page 3
Section 14 - Processing and Recovery Methods
14.1 - Description or Flowsheet, page ES-14
9. The historical wash plant recoveries over the last five years and the
projected recoveries
should be provided to comply with Item 601(b)(96)(iii)(B)(14)(ii) of
Regulation S-K.
Section 16 - Market Studies
16.2 - Price Forecasts, page ES-16
10. The source of the pricing information, the product specifications, and
the method of
calculation for the forecast pricing should be provided to comply with
Item
601(b)(96)(iii)(B)(16)(i) of Regulation S-K.
Section 18 - Capital and Operating Costs
18.1 - Capital Cost Estimate, page ES-18
11. The annual estimates of capital and operating costs should be provided
using a tabular
format including major line items and totals along with a statement as
to the accuracy of
the estimates to comply with Item 601(b)(96)(iii)(B)(18)(i) of
Regulation S-K.
Section 19 - Economic Analysis
19.2 - Results, page ES-19
12. The annual after-tax cash flow should be described and illustrated in
a tabular format with
appropriate line items, such as salable tonnes; coal price; revenues;
mining, processing,
and general and administrative costs; sustaining/development capital;
taxes; royalties; and
reclamation/closing costs on an annual basis to demonstrate the
economic viability or the
project or property to comply with Item 601(b)(96)(iii)(B)(19)(i) 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 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.
FirstName LastNameDale W. Boyles Sincerely,
Comapany NameWarrior Met Coal, Inc.
Division of
Corporation Finance
April 6, 2023 Page 3 Office of Energy
& Transportation
FirstName LastName