10 unchanged sentences
We operate highly productive, cost-competitive coal mines across the CAPP coal basin.
−Removed: Our portfolio of mining operations consists of 14 active underground mines, six active surface mines and eight active coal preparation plants, as well as one underground mine and one coal preparation plant that have been temporarily idled.
+Added: Our portfolio of mining operations consists of 14 active underground mines, five active surface mines and eight active coal preparation plants, as well as one underground mine, one surface mine, and one coal preparation plant that have been temporarily idled.
We own a 65.0% interest in Dominion Terminal Associates (“DTA”), a coal export terminal in Newport News, Virginia.
8 unchanged sentences
In addition, our experienced management team regularly analyzes potential acquisitions, joint ventures and other opportunities that would be accretive and synergistic to our existing asset portfolio.
−Removed: Other Business Developments
+Added: Recent Business Developments
+Added: In 2025, due to continued softness in the met coal pricing environment, especially for U.S.
+Added: products driven by weak global steel demand combined with additional U.S.
+Added: production, we reduced production levels at our Jerry Fork and Black Eagle mines within our Power Mountain and Marfork mining complexes, respectively, and temporarily idled our Long Branch surface mine within our McClure/Toms Creek mining complex.
+Added: For more information refer to “Item 7.
+Added: Management's Discussion and Analysis of Financial Condition and Results of Operations.”
In 2024, we began the development phase for our new Kingston Wildcat underground mine located in Fayette County, West Virginia.
The mine, which will produce a Low-Vol.
−Removed: quality met coal, is expected to begin production late in 2025.
+Added: quality met coal, is expected to begin production in the first quarter of 2026.
In November 2024, due to a softening in the met coal pricing environment, we temporarily idled our Elk Run mining complex.
Its Checkmate Powellton mine, which had recently begun production and had not yet reached planned production levels, had relatively higher costs.
−Removed: The mine is expected to be restarted once market conditions improve.
−Removed: For more information refer to “Item 7.
−Removed: Management’s Discussion and Analysis of Financial Condition and Results of Operations”.
−Removed: In 2023, we completed development of and production began at our Rolling Thunder and Checkmate Powellton mines within our Power Mountain and Elk Run mining complexes, respectively, which produce High-Vol.
−Removed: B quality met coal from the Powellton coal seam.
−Removed: In August 2023, we completed our transition to a pure-play metallurgical producer with the closure of Slabcamp, our last remaining thermal coal mine.
+Added: The mine is being maintained and is expected to be restarted once market conditions improve.
+Added: In 2023, we completed development of and commenced production at our Rolling Thunder and Checkmate Powellton mines within our Power Mountain and Elk Run mining complexes, respectively, which produce High-Vol.
+Added: B quality met coal
+Added: from the Powellton coal seam.
We were formed in 2016 to acquire and operate certain of Alpha Natural Resources, Inc.’s former core coal operations, as part of the Alpha Natural Resources, Inc.
Plan of Reorganization.
−Removed: On December 8, 2017, we closed a transaction with Blackjewel to sell our Western Mines located in the PRB, Wyoming, along with related coal reserves, equipment, infrastructure and other real properties.
−Removed: On October 4, 2019, we closed on the ESM Transaction in connection with Blackjewel’s subsequent bankruptcy filing.
−Removed: On May 29, 2020, certain of our subsidiaries (Contura Coal West, LLC and Contura Wyoming Land, LLC), one of which held the mining permits for the Western Mines, were merged with certain subsidiaries of ESM to become wholly-owned subsidiaries of ESM and to complete the permit transfer process in connection with the ESM Transaction.
On November 9, 2018, we merged with Alpha Natural Resources Holdings, Inc.
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Our Mining Operations and Properties
−Removed: The following table provides a summary of information regarding our active and temporarily idled mining complexes as of December 31, 2024 (see also “Item 2.
+Added: The following table provides a summary of information regarding our active and temporarily idled mining complexes as of December 31, 2025 (refer to “Item 2.
Properties” for further information):
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Kepler WV 2018 1 CM CSX/NS 1,672 1,791 1,958 $ 219,843 36,159
−Removed: Kingston WV 2018 3 CM/S/H CSX/NS 2,146 2,254 1,935 $ 111,919 35,745
+Added: Kingston/ Mammoth WV 2018 3 CM/S/H CSX/NS 2,062 2,146 2,254 $ 158,655 33,324
Marfork WV 2018 6 CM/S/H CSX 3,895 4,642 4,345 $ 268,333 96,799
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(2) Equipment:
−Removed: S = Shovel/Excavator/Loader/Trucks;
CM = Continuous Miner;
+Added: S = Shovel/Excavator/Loader/Trucks;
H = Highwall Miner
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Coal is processed at the Bandmill Preparation Plant and loaded onto CSX rail for delivery to customers.
−Removed: Kepler – Kepler is a mining complex located in Wyoming, McDowell, and Raleigh counties, West Virginia.
+Added: Kepler – Kepler is a mining complex located in Wyoming and McDowell counties, West Virginia.
The complex has one active underground mine (with an estimated life of 12 years) which produces primarily Low-Vol.
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Coal is processed at the Kepler Preparation Plant and either loaded onto NS rail or trucked to the Feats Loadout and loaded onto the CSX rail for delivery to customers.
−Removed: Kingston – Kingston is a mining complex located in Fayette and Raleigh counties, West Virginia.
+Added: Kingston/Mammoth – Kingston/Mammoth is a mining complex located in Fayette and Raleigh counties, West Virginia.
The complex has one active underground mine, which produces primarily Mid-Vol.
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Coal from the underground mine is processed at the Kingston Preparation Plant and trucked to the Pax Loadout to be loaded onto CSX rail for delivery to customers.
−Removed: Coal from the surface mines may be processed through the Kingston Preparation Plant, trucked to and processed through the Mammoth Plant,
−Removed: or trucked directly to the Pax Loadout or Marmet Dock for delivery to customers.
+Added: Coal from the surface mines may be processed through the Kingston Preparation Plant, trucked to and processed
+Added: through the Mammoth Plant, or trucked directly to the Pax Loadout or Marmet Dock for delivery to customers.
During 2024, development began on a new Wildcat underground mine (with an estimated life of 11 years) which will produce Low-vol.
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Coal is expected to be short-line railed to and processed through the Mammoth plant to be loaded onto NS rail for delivery to customers.
−Removed: Production is expected to begin in late 2025.
+Added: Production is expected to begin in the first quarter of 2026.
Marfork – Marfork is a mining complex located in Raleigh, Boone, Kanawha, and Fayette counties, West Virginia.
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quality met coal from the Upper Banner, Lower Banner, and Jawbone coal seams.
−Removed: The complex also has two active surface mines which produce primarily High-Vol.
+Added: The complex also has one active surface mine and one idle surface mine which produce primarily High-Vol.
A quality met coal as well as some thermal quality coal as a by-product of mining from multiple coal seams.
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Coal is processed at either the McClure Preparation Plant or the Toms Creek Preparation Plant and loaded on the CSX or NS rail, respectively for delivery to customers.
−Removed: Power Mountain – Power Mountain is a mining complex located in Nicholas County, West Virginia.
−Removed: The complex has one active underground mine (with an estimated life of 4 years) which produces High-Vol.
−Removed: B quality met coal from the Eagle coal seam.
−Removed: Coal is processed at the Power Mountain Preparation Plant and loaded onto NS rail for delivery to customers.
−Removed: In addition, during 2023 production began at a second underground mine (with an estimated life of 15 years) which produces High-Vol.
−Removed: B quality met coal from the Powellton coal seam.
−Removed: Coal from the mine is currently trucked to and processed through the Mammoth Preparation Plant.
−Removed: Following the future development of a haul road, coal is expected to be trucked to and processed through the Power Mountain Preparation Plant.
+Added: Power Mountain – Power Mountain is a mining complex located in Nicholas and Clay counties, West Virginia.
+Added: The complex has two active underground mines (with estimated lives of 3 and 18 years) which produce High-Vol.
+Added: B quality met coal.
+Added: Coal from one mine, produced from the Eagle coal seam, is processed at the Power Mountain Preparation Plant and loaded onto NS rail for delivery to customers.
+Added: Coal from the other mine, produced from the Powellton coal seam, is currently trucked to and processed through the Mammoth Preparation Plant.
+Added: Following the future development of a haul road, coal is expected to also be processed through the Power Mountain Preparation Plant.
Elk Run – Elk Run is a mining complex located in Boone County, West Virginia.
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Our export shipments serviced customers in 19 and 26 countries during the years ended December 31, 2025 and 2024, respectively.
−Removed: Asia was our largest export market for the years ended December 31, 2024 and 2023, with coal sales to Asia accounting for approximately 43% and 46%, respectively of export coal revenues and 34% of coal revenues in each year.
+Added: Asia was our largest export market for the years ended December 31, 2025 and 2024, with coal sales to Asia accounting for approximately 45% and 43%, respectively, of export coal revenues and 33% and 34%, respectively, of coal revenues in each year.
All of our sales are conducted in U.S.
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Thermal coal accounted for approximately 4% and 3%, respectively, of our coal revenues for the years ended December 31, 2025 and 2024.
−Removed: We sometimes enter into long-term contracts with our thermal coal customers.
+Added: We sometimes enter into long-term contracts with our coal customers.
Terms of these agreements may address coal quality requirements, quantity parameters, flexibility and adjustment mechanisms, permitted sources of supply, treatment of environmental constraints, options to extend, force majeure, suspension, termination and assignment issues, the allocation between the parties of the cost of complying with future governmental regulations and many other matters.
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Provisions of this sort increase the difficulty of predicting the exact prices a coal supplier will receive for its coal during the course of the long-term agreement.
−Removed: During the years ended December 31, 2024 and 2023, approximately 24% and 21%, respectively, of our thermal coal sales volume were delivered pursuant to long-term contracts.
+Added: During the years ended December 31, 2025 and 2024, approximately 60% and 63%, respectively, of our met coal sales volume was delivered pursuant to long-term contracts.
+Added: During the years ended December 31, 2025 and 2024, approximately 65% and 24%, respectively, of our thermal coal sales volume was delivered pursuant to long-term contracts.
Distribution and Transportation
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and internationally.
−Removed: In the met coal market, of the approximately 73.1 million tons produced in the U.S.
+Added: We produced approximately 13.7 million tons of met coal in 2025.
+Added: At the time of filing, certain industry data for 2025 was unavailable due to a distribution delay resulting from U.S.
+Added: government shutdowns.
+Added: Of the approximately 73.1 million tons of met produced in the U.S.
in 2024, we produced approximately 14.6 million tons, or 20%.
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met coal production is shipped internationally, where it competes directly with international sources of production.
−Removed: Approximately 77% of our met coal tons sold were shipped internationally in 2024.
−Removed: In the thermal market, of the approximately 435.7 million tons produced in the U.S.
+Added: Approximately 76% and 77% of our met coal tons sold were shipped internationally in 2025 and 2024, respectively.
+Added: We produced approximately 1.2 million tons of thermal coal in 2025.
+Added: At the time of filing, certain industry data for 2025 was unavailable due to a distribution delay resulting from U.S.
+Added: government shutdowns.
+Added: Of the approximately 435.7 million tons produced in the U.S.
in 2024, we produced approximately 1.1 million tons, or less than 1%.
1 unchanged sentence
thermal production is shipped internationally, but there is strong competition in the domestic market.
−Removed: Approximately 70% of our thermal coal tons sold were shipped internationally in 2024.
+Added: Approximately 65% and 70% of our thermal coal tons sold were shipped internationally in 2025 and 2024, respectively.
We compete for U.S.
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Certain of our subsidiaries have wage agreements with the UMWA representing roughly 3% of our workforce.
−Removed: Certain of our subsidiaries have wage agreements with the UMWA that are subject to termination by either the employer or the UMWA, without cause, on July 31, 2025 and one on February 28, 2026.
+Added: These agreements are subject to termination by either the employer or the UMWA, without cause, on July 31, 2028 and one on February 28, 2026.
+Added: An agreement to succeed the latter is currently being negotiated.
We strive to maintain positive working relationships with organized labor.
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disability and life insurance coverages;
−Removed: and a 401(k) retirement savings program.
−Removed: All employees have access to our Employee Assistance Program at no cost, which gives them and their family access to licensed professionals for help with mental health, stress, addiction, grievances, relationship issues, childcare and eldercare services, legal and personal finance services and other work/life balance matters.
−Removed: To help retain key employees in
−Removed: certain positions, our long-term incentive program awards cash or equity grants with time-based and performance-based vesting conditions.
+Added: and a 401(k) retirement savings program with an employer match.
+Added: All employees have access to our Employee Assistance Program at no cost, which
+Added: gives them and their family access to licensed professionals for help with mental health, stress, addiction, grievances, relationship issues, childcare and eldercare services, legal and personal finance services and other work/life balance matters.
+Added: To help retain key employees in certain positions, our long-term incentive program awards cash or equity grants with time-based and performance-based vesting conditions.
Certain key employees are also eligible to participate in our non-qualified deferred compensation plan.
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industry average NFDL safety incident rate per 200,000 hours worked.
−Removed: The industry rate is based on available data for the first three quarters of 2024 for bituminous coal and the Alpha rate reflects full year 2024.
+Added: The industry rate is based on available data for the first two quarters of 2025 for bituminous coal and the Alpha rate reflects full year 2025.
+Added: At the time of filing, certain more recent industry data for 2025 was unavailable due to a distribution delay resulting from U.S.
+Added: government shutdowns.
+Added: In 2024, we achieved an overall Non-fatal days lost safety incident rate that was 45% better than the U.S.
+Added: industry average NFDL safety incident rate per 200,000 hours worked.
+Added: The industry rate is based on the full year 2024 for bituminous coal and the Alpha rate also reflects the full year 2024.
Alpha’s mine operations routinely collaborate with academic institutions as well as federal and state agencies to facilitate testing of new concepts and technologies and to utilize them whenever possible to provide the best safety and protection for our employees.
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We are party to legal proceedings from time to time that occur in the ordinary course of business.
−Removed: These proceedings, as well as governmental examinations, could involve various business units and a variety of claims, including, but not limited to, contract disputes, personal injury claims, property damage claims (including those resulting from blasting, subsidence, trucking and flooding), environmental and safety issues, and employment matters.
+Added: These proceedings, as well as governmental examinations, could involve various business units and a variety of claims, including, but not limited to, contract disputes, personal injury claims, property damage claims (including those resulting from blasting, subsidence, trucking and flooding), environmental and safety issues, securities-related matters and employment matters.
While some legal matters may specify the damages claimed by the plaintiffs, many seek an unquantified amount of damages.
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We record accruals based on an estimate of the ultimate outcome of these matters, but these estimates can be difficult to determine and involve significant judgment.
−Removed: For additional information about the Company’s legal proceedings, refer to Note 20 , part (d), to the Consolidated Financial Statements, which is incorporated herein by reference.
+Added: For additional information about our legal proceedings, refer to Note 20 , part (d), to the Consolidated Financial Statements.
ENVIRONMENTAL AND OTHER REGULATORY MATTERS
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If we cannot successfully negotiate for surface rights, we could be denied a permit to mine coal we already control.
−Removed: On October 4, 2019, the WV Bankruptcy Court entered an order approving the sale by Blackjewel of the Western Assets to ESM.
−Removed: The ESM Transaction occurred on October 18, 2019.
−Removed: We were the former owner of the Western Assets, having sold them to Blackjewel in December 2017 (the “2017 Blackjewel Sale”).
−Removed: As the mine permit transfer process relating to our sale of the Western Assets to Blackjewel had not been completed prior to Blackjewel’s and certain of its affiliates’ filing petitions for relief under chapter 11 of title 11 of the U.S.
−Removed: Code (the “Bankruptcy Code”), we remained the permitholder in good standing for both mines.
−Removed: In connection with ESM’s acquisition of the Western Assets from Blackjewel, on October 18, 2019, we and ESM
−Removed: finalized an agreement that provided, among other items, for the eventual transfer of the Western Asset permits from us to ESM and replacement by ESM of our surety bonds associated with these properties.
−Removed: In furtherance of certain objectives contemplated under that agreement, we and ESM agreed to the merger of two of our now-former subsidiaries, i.e.
−Removed: , Contura Coal West, LLC (“CCW”), which held and still holds the Western Asset permits, and Contura Wyoming Land, LLC (“CWL”), with certain entities formed by ESM for purposes of acquiring CCW and CWL.
−Removed: The ESM entities involved in the mergers were ESM Coal West SPV, LLC (“First Merging Entity”) and ESM Wyoming Land SPV, LLC (“Second Merging Entity”).
−Removed: The mergers were consummated effective May 29, 2020, with the First Merging Entity merging with and into CCW, with CCW as the surviving entity (the “First Surviving Entity”), and the Second Merging Entity merging with and into CWL, with CWL as the surviving entity (the “Second Surviving Entity”).
−Removed: Upon the mergers becoming effective, each of the First Surviving Entity and the Second Surviving Entity became wholly-owned subsidiaries of ESM.
−Removed: As such, the Western Asset permits are still held by the same entity, Contura Coal West, LLC, but said entity is no longer a subsidiary of ours, and we no longer have surety bonds associated with these permits and properties.
Surface Mining Control and Reclamation Act
−Removed: SMCRA, which is administered by the Office of Surface Mining Reclamation and Enforcement (“OSM”), establishes mining, environmental protection, reclamation, and closure standards for all aspects of surface mining as well as many aspects of underground mining that effect surface expressions.
−Removed: Mine operators must obtain SMCRA permits and permit renewals from the OSM or from the applicable state agency if the state agency has obtained primary control of administration and enforcement of the SMCRA program, or primacy.
+Added: Surface Mining Control and Reclamation Act (“SMCRA”), which is administered by the Office of Surface Mining Reclamation and Enforcement (“OSM”), establishes mining, environmental protection, reclamation, and closure standards for all aspects of surface mining as well as many aspects of underground mining that effect surface expressions.
+Added: Mine operators must obtain SMCRA permits and permit renewals from the OSM or from the applicable state agency if the state agency has
+Added: obtained primary control of administration and enforcement of the SMCRA program, or primacy.
A state agency may obtain primacy if OSM concludes that the state regulatory agency’s mining regulatory program is no less stringent than the federal mining program under SMCRA.
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Some SMCRA mine permits take over a year to prepare, depending on the size and complexity of the mine and may take months or even years to be issued.
−Removed: Regulatory authorities have considerable discretion in the timing of the permit issuance
−Removed: and the public and other agencies have rights to comment on and otherwise engage in the permitting process, including through intervention in the courts.
+Added: Regulatory authorities have considerable discretion in the timing of the permit issuance and the public and other agencies have rights to comment on and otherwise engage in the permitting process, including through intervention in the courts.
The Abandoned Mine Land Fund, which is part of SMCRA, requires a fee on all coal produced.
1 unchanged sentence
The current fee, which is effective through September 30, 2034, is $0.224 per ton on surface-mined coal and $0.096 per ton on deep-mined coal.
−Removed: For each of the years ended December 31, 2024 and 2023, we recorded $2.0 million of expense related to these fees.
+Added: For the years ended December 31, 2025 and 2024, we recorded $1.8 million and $2.0 million, respectively, of expense related to these fees.
While SMCRA is a comprehensive statute, SMCRA does not supersede the need for compliance with other major environmental statutes, including the Endangered Species Act;
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Federal and state laws require us to obtain surety bonds or other approved forms of security to cover the costs of certain long-term obligations, including mine closure or reclamation costs under SMCRA, federal and state workers’ compensation costs, coal leases and other miscellaneous obligations.
−Removed: As of December 31, 2024 and 2023, our posted third-party surety bond amount in all states where we operate totaled approximately $182.8 million and $177.1 million, respectively, which was used to primarily secure the performance of our reclamation and lease obligations.
+Added: As of December 31, 2025 and 2024, our posted third-party surety bond
+Added: amount in all states where we operate totaled approximately $170.0 million and $182.8 million, respectively, which was used to primarily secure the performance of our reclamation and lease obligations.
Posting of a bond or other security with respect to the performance of reclamation obligations is a condition to the issuance of a permit under SMCRA.
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Direct impacts on coal mining and processing operations include Clean Air Act permitting requirements and emission control requirements relating to particulate matter (“PM”), which may include controlling fugitive dust.
−Removed: The Clean Air Act indirectly affects coal mining operations by extensively regulating air emissions of particulate matter, sulfur dioxide, nitrogen oxides, mercury and other compounds emitted by coal-fired electricity generating plants or the use of met coal in connection with steelmaking operations.
+Added: The Clean Air Act indirectly affects coal mining operations by extensively regulating air emissions of PM, sulfur dioxide, nitrogen oxides (“NOx”), mercury and other compounds emitted by coal-fired electricity generating plants or the use of met coal in connection with steelmaking operations.
In recent years, Congress has considered legislation that would require increased reductions in emissions of sulfur dioxide, nitrogen oxide, and mercury.
2 unchanged sentences
Title IV of the Clean Air Act requires reductions of sulfur dioxide emissions by electric utilities.
−Removed: Affected electricity generators have sought to meet these requirements by, among other compliance methods, switching to lower sulfur fuels, installing pollution control devices, reducing electricity generating levels or purchasing or trading sulfur dioxide emission allowances.
+Added: Affected electricity generators have sought to meet these requirements by, among other compliance methods, switching to lower sulfur fuels, installing pollution control devices, reducing electricity generating levels and purchasing or trading sulfur dioxide emission allowances.
We cannot accurately predict the effect of these provisions of the Clean Air Act on us in future years.
• NAAQS for Criteria Pollutants.
−Removed: The Clean Air Act requires the EPA to set standards, referred to as National Ambient Air Quality Standards (“NAAQS”), for six common air pollutants, including nitrogen oxide, sulfur dioxide, particulate matter, and ozone.
+Added: The Clean Air Act requires the EPA to set standards, referred to as National Ambient Air Quality Standards (“NAAQS”), for six common air pollutants, including nitrogen oxide, sulfur dioxide, PM, and ozone.
Areas that are not in compliance (referred to as “non- attainment areas”) with these standards must take steps to reduce emissions levels.
−Removed: Over the past several years, the EPA has revised its NAAQS for nitrogen oxide, sulfur dioxide, particulate matter and ozone, in each case making the standards more stringent.
+Added: Over the past several years, the EPA has revised its NAAQS for nitrogen oxide, sulfur dioxide, PM and ozone, in each case making the standards more stringent.
As a result, some states have been, and will be, required to amend their existing individual state implementation plans (“SIPs”) to achieve compliance with the new air quality standards.
Other states will be required to develop new plans for areas that were previously in “attainment,” but do not meet the revised standards.
−Removed: On December 7, 2020, the EPA announced the agency’s final decision to retain the existing National Ambient Air Quality Standards for particulate matter set by the
−Removed: Obama-Biden Administrations in 2012 without changes.
+Added: On December 7, 2020, the EPA announced the agency’s final decision to retain the existing National Ambient Air Quality Standards for PM set by the Obama-Biden Administrations in 2012 without changes.
However, on January 6, 2023, the EPA proposed to revise the primary (health-based) annual standard for PM2.5, from its then-current level of 12.0 micrograms per cubic meter (µg/m3) to within the range of 9.0 to 10.0 µg/m3.
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The EPA also did not change the secondary (welfare-based) standards for fine particles and coarse particles.
−Removed: In October 2015, the EPA finalized the NAAQS for ozone pollution and reduced the limit to 70 parts per billion (ppb) from the previous 75 ppb standard.
+Added: In October 2015, the EPA finalized the NAAQS for ozone pollution and reduced the standard to 70 parts per billion (ppb) from the previous 75 ppb standard.
The EPA made the majority of area designations related to this rule on November 16, 2017 and June 4, 2018 and finalized designations for the remaining regions of the country on July 25, 2018.
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Nitrogen oxide and sulfur dioxide emission reductions were scheduled to commence in 2012, with further reductions effective in 2014.
−Removed: However, implementation of CSAPR’s requirements were delayed due to litigation.
−Removed: In October 2014, the EPA issued an interim final rule reconciling the CSAPR with the Court’s order, which called for Phase 1 implementation in 2015 and Phase 2 implementation in 2017.
+Added: However, implementation of CSAPR’s requirements was delayed due to litigation.
+Added: In October 2014, following a decision from the U.S.
+Added: Supreme Court, the EPA issued an interim final rule reconciling the CSAPR with the Court’s order, which called for Phase 1 implementation in 2015 and Phase 2 implementation in 2017.
In September 2016, the EPA finalized an update to the CSAPR ozone season program by issuing the Final CSAPR Update rule.
−Removed: The Final CSAPR Update rule was the subject of a pending legal challenge in the D.C.
+Added: The Final CSAPR Update rule was the subject of a challenge in the D.C.
Circuit by states and industry stakeholders.
2 unchanged sentences
The court directed the EPA to revise the rule to address this failure.
−Removed: For states to meet their requirements under the Final CSAPR Update rule, a number of coal-fired electric generating units will likely need to be retired, rather than retrofitted with the necessary emission control technologies, reducing demand for thermal coal.
−Removed: On October 15, 2020, the EPA proposed the Revised CSAPR Update rule in order to fully address 21 states’ outstanding interstate pollution transport obligations for the 2008 ozone National Ambient Air Quality Standards.
+Added: On October 15, 2020, the EPA proposed the Revised CSAPR Update rule in order to fully address 21 states’ outstanding interstate pollution transport obligations for the 2008 ozone National Ambient Air Quality Standard.
The EPA finalized the Revised CSAPR Update rule on April 30, 2021.
−Removed: The EPA estimated that the Revised CSAPR Update rule will reduce NOX emissions from power plants in 12 states in the eastern United States by 17,000 tons in 2021 compared to projections without the rule, yielding public health and climate benefits that are valued, on average, at up to $2.8 billion each year from 2021 to 2040.
+Added: The EPA estimated that the Revised CSAPR Update rule would reduce NOx emissions from power plants in 12 states in the eastern United States by 17,000 tons in 2021 compared to projections without the rule, yielding public health and climate benefits that are valued, on average, at up to $2.8 billion each year from 2021 to 2040.
An industry group challenged the Revised CSAPR Update rule in the U.S.
2 unchanged sentences
On March 15, 2023, the EPA issued its Good Neighbor Plan, a federal implementation plan (“FIP”) designed to replace SIPs submitted by over 20 states to implement their good neighbor obligations with respect to the 2015 ozone NAAQS.
−Removed: The FIP would require significant reductions in cross-state air pollution of ozone-forming NOx emissions from power plants and industrial facilities.
−Removed: The Good Neighbor Plan is intended to reduce seasonal ozone-forming emissions of NOx from power plants and industrial facilities in 23 states.
+Added: The FIP would require significant reductions of ozone-forming NOx emissions from power plants and industrial facilities in 23 states based on the EPA’s determination that these emissions were contributing to the nonattainment of, or problems maintaining the attainment of, the 2015 ozone NAAQs in downwind states.
Industry groups and states filed petitions for review in the U.S.
1 unchanged sentence
Circuit, challenging the Good Neighbor Plan.
−Removed: States and industry stakeholders also challenged the EPA’s disapproval of SIP submittal for several states in the regional circuits covering those states and obtained judicial stays of the SIP disapprovals in many states.
+Added: States and industry stakeholders also challenged the EPA’s disapproval of SIPs for several states in the regional circuits covering those states and obtained judicial stays of the SIP disapprovals in many states.
The EPA’s authority to issue a FIP for a state arises when the state fails to submit a SIP or when the EPA disapproves a SIP.
4 unchanged sentences
Court of Appeals for the D.C.
+Added: Circuit but have been held in abeyance based on the EPA’s announcement that it is reconsidering the Good Neighbor Plan and underlying SIP disapprovals.
• Mercury and Hazardous Air Pollutants.
6 unchanged sentences
Circuit stayed the litigation.
−Removed: In August 2018, the EPA stated that it plans on sending a draft proposal to the White House questioning the EPA’s earlier finding and intends to reevaluate the MATS rule itself.
+Added: In August 2018, the EPA announced plans to send a draft proposal to the White House questioning the EPA’s earlier finding.
On December 27, 2018, the EPA issued a proposed revised Supplemental Cost Finding for MATS, as well as the Clean Air Act required “risk and technology review.” After taking account of both the cost to coal- and oil-fired power plants of complying with the MATS rule and the benefits attributable to regulating hazardous air pollutant (“HAP”) emissions from these power plants, the EPA proposed to determine that it is not “appropriate and necessary” to regulate HAP emissions from power plants under Section 112 of the Clean Air Act.
2 unchanged sentences
Coal refuse includes low-quality coal mixed with rock, clay and other material.
−Removed: The EPA is also establishing emission standards from these facilities.
−Removed: The new subcategory and emission standards will affect six existing EGUs that burn EBCR.
+Added: The EPA established emission standards for facilities that burn EBCR.
+Added: This new subcategory and emission standards affected six existing EGUs located in Pennsylvania and West Virginia that burn EBCR.
On May 22, 2020, the EPA published the completed reconsideration of the appropriate and necessary finding for the MATS.
The EPA concluded that it is not “appropriate and necessary” to regulate electric utility steam generating units under Section 112 of the Clean Air Act.
−Removed: The EPA is also taking final action on the residual risk and technology review that is required by the CAA Section 112.
−Removed: The EPA states, “emissions of HAP have been reduced such that residual risk is at acceptable levels, that there are no developments in HAP emissions controls to achieve further cost-effective reductions beyond the current standard, and, therefore, no changes to the MATS rule are warranted.”
+Added: The EPA also took final action on the residual risk and technology review that is required by the CAA Section 112.
+Added: The EPA explained, “emissions of HAP have been reduced such that residual risk is at acceptable levels, that there are no developments in HAP emissions controls to achieve further cost-effective reductions beyond the current standard, and, therefore, no changes to the MATS rule are warranted.”
On February 15, 2023, however, the EPA revoked its 2020 finding that it was not appropriate and necessary to regulate coal- and oil-fired power plants under Section 112 of the Clean Air Act, which regulates HAP emissions.
2 unchanged sentences
On April 3, 2023, the EPA issued a proposed rule that the EPA said would strengthen and update the MATS for power plants to reflect recent developments in control technologies and the performance of these plants.
−Removed: The EPA issued a final revised MATS rule for EGUs in April 2024 that establishes more stringent standards than the previous rule.
+Added: The EPA issued a final revised MATS rule for EGUs in April 2024 that established more stringent standards than the previous rule.
Several states and industry stakeholders have challenged the rule in the U.S.
Court of Appeals for the D.C.
−Removed: Circuit and that litigation is ongoing.
+Added: Circuit and that litigation is being held in abeyance at the request of the parties.
+Added: In June 2025, the EPA published a proposed rule to repeal certain parts of the 2024 rule.
Apart from MATS, several states have enacted or proposed regulations requiring reductions in mercury emissions from coal-fired power plants, and federal legislation to reduce mercury emissions from power plants has been proposed.
5 unchanged sentences
In December 2011, the EPA issued a final rule under which the emission caps imposed under CSAPR for a given state would supplant the obligations of that state with regard to visibility protection.
−Removed: In May 2012, the EPA finalized a rule that allows the trading programs in CSAPR to serve as an alternative to determining source-by-source Best Available Retrofit Technology (“BART”).
+Added: In May 2012, the EPA finalized a rule that allows the trading programs in CSAPR to serve as an alternative to determining source-by-source Best Available Retrofit
+Added: Technology (“BART”).
This rule provides that states in the CSAPR region can substitute participation in CSAPR for source-specific BART for sulfur dioxide and/or nitrogen oxides emissions from power plants.
−Removed: This program may result in additional emissions restrictions from new coal-fueled power plants whose operations may impair visibility at and around federally protected areas.
−Removed: This program may also require certain existing coal-fueled power plants to install additional control measures designed to limit haze causing emissions, such as sulfur dioxide, nitrogen oxides, volatile organic chemicals and particulate matter.
−Removed: These limitations could result in additional coal plant closures and affect the future market for coal.
+Added: This program could result in additional emissions restrictions and the need to install additional control measures designed to limit haze causing emissions, such as sulfur dioxide, nitrogen oxides, volatile organic chemicals and particulate matter.
+Added: These limitations could contribute to additional coal plant closures and affect the future market for coal.
A final Regional Haze rule was published on January 10, 2017 that allowed states to submit their SIP revisions by July 2021.
In August 2022, the EPA issued a “finding of failure” to submit complete regional haze SIPs for 15 states, starting a two-year clock for the EPA to issue a FIP for any state that does not submit a revised SIP and have it approved before the FIP is issued.
+Added: In March 2025, the EPA announced plans to restructure the regional haze program.
+Added: In the months that followed, the EPA approved Regional Haze SIP revisions for a number of states.
+Added: Environmental groups have filed lawsuits in the Fourth and Sixth Circuits, challenging the EPA’s approval of West Virginia’s and Ohio’s SIPs, respectively.
+Added: In October 2025, the EPA issued an advance notice of proposed rulemaking (“ANPR”) seeking public comments on ways to clarify and streamline states’ obligations under the program.
+Added: Comments on the ANPR closed on December 1, 2025.
In addition, the EPA’s new source review program under certain circumstances requires existing coal-fired power plants, when modifications to those plants significantly change emissions, to install the more stringent air emissions control equipment required of new plants.
30 unchanged sentences
In 2009, the EPA issued a finding that emissions of carbon dioxide, methane and other GHGs present an endangerment to public health and the environment.
−Removed: The EPA has since adopted regulations under existing provisions of the CAA pursuant to this finding.
+Added: The EPA has since adopted regulations under existing provisions of the CAA pursuant to
+Added: this finding.
For example, the EPA has adopted rules requiring the monitoring and reporting of GHG emissions from specified large GHG emission sources in the U.S., including coal-fired electric power plants and steel-making operations.
6 unchanged sentences
However, the Court also held that the EPA’s determination that a source already subject to the PSD program due to its emission of conventional pollutants may be required to limit its GHG emissions by employing the “best available control technology” was permissible.
−Removed: As a result, the EPA is now requiring new sources already subject to the PSD program, including coal-fired power plants, to undergo control technology reviews for GHGs (predominately carbon dioxide) as a condition of permit issuance.
+Added: As a result, the EPA began requiring new sources already subject to the PSD program, including coal-fired power plants, to undergo control technology reviews for GHGs (predominately carbon dioxide) as a condition of permit issuance.
These reviews may impose limits on GHG emissions, or otherwise be used to compel consideration of alternative fuels and generation systems, as well as increase litigation risk for-and so discourage development of-coal-fired power plants.
+Added: In July 2025, the EPA published a proposed rule that would repeal the 2009 endangerment finding.
+Added: EPA Administrator Lee Zeldin signed the final rule repealing the endangerment finding on February 12, 2026.
+Added: We anticipate that the final rule, once published in the Federal Register, will be the subject of widespread litigation.
On August 3, 2015, the EPA released a final rule establishing New Source Performance Standards (“NSPS”) for emissions of carbon dioxide for new, modified and reconstructed fossil fuel-fired electric generating units (“Power Plant NSPS”).
12 unchanged sentences
However, on January 19, 2021, the Court of Appeals of the District of Columbia struck down the ACE rule.
−Removed: The EPA has since announced an intent to consider new regulations governing carbon emissions from existing power plants.
In May 2024, the EPA issued a final rule known as the GHG Power Plant Rule that requires stringent reductions in carbon dioxide emissions from existing coal-fired plants and relies heavily on the use of CCS.
1 unchanged sentence
Court of Appeals for the D.C.
−Removed: Circuit and remain pending.
+Added: Circuit and are being held in abeyance at the request of the parties.
+Added: In June 2025, the EPA published a proposed rule to repeal all GHG emissions standards for fossil fuel-fired power plants.
+Added: A final rule is likely to be published in the first half of 2026.
More stringent standards for carbon dioxide emissions as a result of these rulemakings could further reduce demand for coal, and our business would be adversely impacted.
4 unchanged sentences
A number of states have enacted legislative mandates requiring electricity suppliers to use renewable energy sources to generate a certain percentage of power.
−Removed: For example, on September 10, 2018, California adopted a law that requires all electricity consumed by the state to be generated from renewable sources such as solar, wind and hydropower by 2045.
+Added: example, on September 10, 2018, California adopted a law that requires all electricity consumed by the state to be generated from renewable sources such as solar, wind and hydropower by 2045.
On October 7, 2023, California Governor Gavin Newsom signed three landmark climate disclosure bills that are more stringent than the proposed U.S.
13 unchanged sentences
Disclosure will be required on or before January 1, 2026 and biennially thereafter.
−Removed: The Company currently does not do business in California.
+Added: We currently do not do business in California.
In addition, certain banks and other financing sources have taken actions to limit available financing for the development of new coal-fueled power plants, which also may adversely affect the future global demand for coal.
13 unchanged sentences
Prior to discharging any pollutants into waters of the United States, coal mining companies must obtain a National Pollutant Discharge Elimination System (“NPDES”) permit from the appropriate state or federal permitting authority.
−Removed: Section 402 of the CWA creates a process for establishing effluent limitations for discharges to streams that are protective of water
−Removed: quality standards through the NPDES program, and corresponding programs implemented by state regulatory agencies.
+Added: Section 402 of the CWA creates a process for establishing effluent limitations for discharges to streams that are protective of water quality standards through the NPDES program, and corresponding programs implemented by state regulatory agencies.
Regular monitoring, reporting and compliance with performance standards are preconditions for the issuance and renewal of NPDES permits that govern discharges into waters of the United States.
1 unchanged sentence
Furthermore, the imposition of future restrictions on the discharge of certain pollutants into waters of the United States could increase the difficulty of obtaining and complying with NPDES permits, which could impose additional time and cost burdens on our operations.
−Removed: For instance, waters that states have designated as impaired (i.e., as not meeting present water quality standards) are subject to Total Maximum Daily Load regulations, which may lead to the adoption of more stringent discharge standards for our coal mines and could require more costly treatment.
+Added: For instance, waters that states have designated as impaired (i.e., as not meeting present water quality standards) are subject to Total
+Added: Maximum Daily Load regulations, which may lead to the adoption of more stringent discharge standards for our coal mines and could require more costly treatment.
In addition, when water quality in a receiving stream is of high quality, states are required to conduct an anti-degradation review before approving discharge permits.
Anti-degradation policies may increase the cost, time and difficulty associated with obtaining and complying with NPDES permits and may also require more costly treatment.
−Removed: On March 5, 2014, the EPA, the U.S.
−Removed: Department of Justice (“DOJ”), West Virginia Department of Environmental Protection, the Pennsylvania Department of Environmental Protection and the Kentucky Energy and Environment Cabinet filed a Complaint against Alpha Natural Resources, Inc.
−Removed: and its permit holding subsidiaries in Kentucky, Pennsylvania, Tennessee, Virginia and West Virginia alleging that Alpha Natural Resources, Inc.’s mining affiliates in those states and in Tennessee and Virginia exceeded certain water discharge permit limits during the period of 2006 to 2013 and simultaneously entered into a Consent Decree with Alpha Natural Resources, Inc.
−Removed: resolving their claims.
−Removed: The Consent Decree was entered by the Southern District of West Virginia on November 26, 2014 and amended on June 12, 2016 and again on February 28, 2018 (the “Alpha Natural Resources, Inc.
−Removed: Consent Decree”).
−Removed: As part of the Alpha Natural Resources, Inc.
−Removed: Consent Decree, Alpha Natural Resources, Inc.
−Removed: agreed to implement an integrated environmental management system and an expanded auditing/reporting protocol, install selenium and osmotic pressure treatment facilities at specific locations, and certain other measures.
−Removed: The Alpha Natural Resources, Inc.
−Removed: Consent Decree required Alpha Natural Resources, Inc.
−Removed: to pay $27.5 million in civil penalties, to be divided among the federal government and state agencies.
−Removed: All required water treatment systems have been constructed, the environmental management system has been implemented, and the other terms and conditions of the Alpha Natural Resources, Inc.
−Removed: Consent Decree have been substantially satisfied.
−Removed: On February 25, 2020, partial termination of the Consent Decree was granted by the EPA for all but 6 of the Alpha Natural Resources, Inc.
−Removed: On January 29, 2021, full termination of the Consent Decree was granted for all the Defendants.
Dredge and Fill Permits
Many mining activities, including the development of settling ponds and the construction of certain sediment control structures, valley fills and surface impoundments, require permits from the U.S.
−Removed: Army Corps of Engineers (“COE”) under Section 404 of the CWA.
+Added: Army Corps of Engineers (“COE”) under Section 404 of the Clean Water Act (“CWA”).
Generally speaking, these Section 404 permits allow the placement of dredge and fill materials into navigable waters of the United States, including wetlands, streams, and other regulated areas.
−Removed: The COE has issued general “nationwide” permits for specific categories of activities that are similar in nature and that are determined to have minimal adverse effects on the environment.
−Removed: Permits issued pursuant to Nationwide Permits 5, 21, 49 and 50 generally authorize the disposal of dredged or fill material from surface coal mining activities into waters of the United States, subject to certain restrictions.
−Removed: Nationwide Permits are typically reissued for a five-year period and require appropriate mitigation, and permit holders must receive explicit authorization from the COE before proceeding with proposed mining activities.
−Removed: On December 27, 2021 (affecting Nationwide Permit numbers including 5 and 49) and January 13, 2021 (affecting Nationwide Permit numbers including 21 and 50), the COE published its final rules reissuing and modifying its Nationwide Permits.
−Removed: These Nationwide Permits now expire on March 14, 2026.
−Removed: The January 13, 2021 final rule finalized the proposed removal of the 300 linear foot limit for losses of stream bed from several of the Nationwide permits.
+Added: The COE has issued general “nationwide” permits (“NWPs”) for specific categories of activities that are similar in nature and that are determined to have minimal adverse effects on the environment.
+Added: Permits issued pursuant to NWPs 5, 21, 49 and 50 generally authorize the disposal of dredged or fill material from surface coal mining activities into waters of the United States, subject to certain restrictions.
+Added: NWPs are typically reissued for a five-year period and require appropriate mitigation, and permit holders must receive explicit authorization from the COE before proceeding with proposed mining activities.
+Added: On December 27, 2021 (affecting NWP numbers including 5 and 49) and January 13, 2021 (affecting NWP numbers including 21 and 50), the COE published its final rules reissuing and modifying its NWPs.
+Added: These NWPs now expire on March 14, 2026.
+Added: The January 13, 2021 final rule finalized the proposed removal of the 300 linear foot limit for losses of stream bed from several of the NWPs.
+Added: On January 8, 2026, the COE published a final rule in the Federal Register announcing the reissuance of 56 NWPs (including NWPs 5, 21, 49, and 50) and one additional NWP.
+Added: The NWPs will take effect on March 15, 2026 and will expire on March 15, 2031.
Expansion of our mining operations into new areas may trigger the need for individual COE approvals, which could be more costly and take more time to obtain.
−Removed: In January 2020, the EPA and the COE issued a final rule that attempts to clarify the Clean Water Act's (“CWA”) jurisdictional reach over waters of the United States, referred to as the Navigable Waters Protection Rule (“NWPR”).
+Added: In January 2020, the EPA and the COE issued a final rule that attempts to clarify the CWA’s jurisdictional reach over waters of the United States, referred to as the Navigable Waters Protection Rule (“NWPR”).
The rule replaced a rule issued in June 2015 by the previous presidential administration, the Clean Water Rule.
8 unchanged sentences
Supreme Court’s decision in Sackett v.
−Removed: EPA limited the jurisdiction of the EPA and the COE over
+Added: EPA limited the jurisdiction of the EPA and the COE over wetlands.
While the January 18, 2023 rule was not directly before the Court, the Court considered the jurisdictional standards set forth in the rule.
3 unchanged sentences
The final amended conforming rule became effective on September 8, 2023.
−Removed: Its ultimate impact on our operations remains uncertain until the agencies regularly implement and apply the rule.
A notice on the EPA’s website explains that, as a result of ongoing litigation on the January 2023 rule, the EPA and the COE are implementing the January 2023 rule, as amended by the August 2023 conforming rule, in 24 states, the District of Columbia, and the U.S.
In the other 26 states, the agencies are interpreting “waters of the United States” consistent with the pre-2015 regulatory regime and the Supreme Court's decision in Sackett until further notice.
−Removed: Cooling Water Intake
−Removed: In May 2014, the EPA issued a new final rule pursuant to Section 316(b) of the CWA that affects the cooling water intake structures at power plants in order to reduce fish impingement and entrainment.
−Removed: The rule is expected to affect over 500 power plants.
−Removed: These requirements could increase our customers’ costs and may adversely affect the demand for coal, which may materially impact our results or operations.
+Added: On November 20, 2025, the EPA and the COE published a proposed rule in the Federal Register that would further revise the regulations defining the scope of
+Added: waters of the United States.
+Added: The public comment period on the proposed rule ended on January 5, 2026.
Effluent Guidelines
1 unchanged sentence
It established the first federal limits on the levels of arsenic, mercury, selenium and nitrate-nitrites in flue gas desulfurization that can be discharged as wastewater from power plants, based on technology improvements over the last three decades.
−Removed: On April 25, 2017, the EPA stayed the implementation of the rule indefinitely to allow for reconsideration.
+Added: 25, 2017, the EPA stayed the implementation of the rule indefinitely to allow for reconsideration.
On August 31, 2020, the EPA finalized the rule to revise the ELGS.
4 unchanged sentences
Court of Appeals for the Eighth Circuit.
−Removed: The rule remains in effect during the pending litigation.
+Added: In March 2025, the EPA announced its intention to reconsider the rule, and the litigation is being held in abeyance while reconsideration is underway.
+Added: On December 31, 2025, the EPA published a final rule in the Federal Register extending the deadlines promulgated in the 2024 rule and updating the 2024 rule’s transfer provisions to allow facilities to switch between compliance alternatives.
Endangered Species Act
11 unchanged sentences
The new Biological Opinion was released on October 16, 2020.
−Removed: One of the most notable changes is the incidental take coverage if there is no agreement between the state regulatory authority and the FWS at the conclusion of the dispute resolution process and the
−Removed: regulatory authority issues the permit.
+Added: One of the most notable changes is the incidental take coverage if there is no agreement between the state regulatory authority and the FWS at the conclusion of the dispute resolution process and the regulatory authority issues the permit.
The new Biological Opinion states that “any prohibited take of listed species incidental to that permit action will not be exempted through this incidental take statement.” The Biological Opinion also includes discussion of OSM enforcement powers in primacy states potentially allowing the FWS to effect a permit veto via OSM enforcement actions.
11 unchanged sentences
The EPA and OSM plan additional rulemaking relating to CCR.
−Removed: Most recently, the EPA issued a final rule that took effect in November 2024 and applies to landfills, historic fill sites, and projects where CCR was placed at a power plant site.
−Removed: The rule will regulate previously exempt closed landfills.
+Added: Most recently, the EPA issued a final rule that took effect in November 2024.
+Added: That rule applies to inactive surface impoundments at closed facilities, CCR management units (which include impoundments and landfills that were closed before the effective date of the original 2015 CCR Rule), and inactive CCR landfills.
Petitions for review of the rule are pending in the U.S.
Court of Appeals for the D.C.
+Added: Circuit but are currently being held in abeyance while the EPA reconsiders the rule.
+Added: The EPA plans additional rulemaking relating to CCR.
There have also been several legislative proposals that would require the EPA to further regulate the storage of CCR.
46 unchanged sentences
The final rule also includes other requirements to protect miner health and update existing respiratory protection requirements.
−Removed: For coal mine operators, the deadline for compliance with the new rule is April 14, 2025.
+Added: For coal mine operators, the deadline for compliance with the new rule was April 14, 2025.
+Added: However, on April 11, 2025, the U.S.
+Added: Court of Appeals for the Eighth Circuit issued an order staying the rule’s compliance deadlines until the court completes a substantive review of the petition.
+Added: Accordingly, MSHA will continue to temporarily pause enforcement of the requirements in the final rule for mine operators until the litigation is concluded.
+Added: MSHA also announced in a November 26, 2025 status report in that litigation that it intends to engage in limited rulemaking to reconsider and seek comments on portions of the rule.
Our compliance with these or any other new health and safety regulations could increase our mining costs substantially.
6 unchanged sentences
On January 18, 2023, the U.S.
−Removed: Department of Labor (“DOL”)
−Removed: announced a notice of proposed rulemaking by its Office of Workers’ Compensation Programs to revise regulations governing the standards related to self-insurance by coal mine operators.
+Added: Department of Labor (“DOL”) announced a notice of proposed rulemaking by its Office of Workers’ Compensation Programs to revise regulations governing the standards related to self-insurance by coal mine operators.
The proposed rule would update the standards coal operators must meet to self-insure, modernize and streamline the application process and fix the amount of security applicants must post.
1 unchanged sentence
The final rule was published in the Federal Register on December 12, 2024 and became effective on January 13, 2025.
−Removed: We continue to evaluate the final rule, the potential for legal challenges to the final rule and the rule’s potential effects upon the Company.
+Added: We continue to evaluate the final rule, the potential for legal challenges to the final rule and the rule’s potential effects upon us.
Coal Industry Retiree Health Benefit Act of 1992
2 unchanged sentences
Compared sentence by sentence after normalising whitespace, quotation marks, case and digits, so re-formatting and restated figures do not read as changed language. Wording changes appear as one removal and one addition. The current filing and the prior one are authoritative.