2 unchanged sentences
Our Class A and Class B common stock are listed on the NASDAQ Global Select Market under the symbols “METC” and “METCB,” respectively.
−Removed: Our 9.00% Senior Notes due 2026 (the “Senior Notes”) are listed on the NASDAQ Global Select Market under the symbol “METCL”.
+Added: Our 9.00% Senior Notes due 2026 (the “Senior Notes due 2026”) and 8.375% Senior Notes due 2029 (the “Senior Notes due 2029,” together with our Senior Notes due 2026, the “Senior Notes”) are listed on the NASDAQ Global Select Market under the symbols “METCL” and “METCZ,” respectively.
Our principal corporate offices are located in Lexington, Kentucky.
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We believe each of these properties possesses geologic and logistical advantages that make our coal among the lowest delivered-cost U.S.
−Removed: metallurgical coal to our domestic target customer base, North American blast furnace steel mills and coke plants, as well as international metallurgical coal consumers.
−Removed: We also control mineral deposits near Sheridan, Wyoming as part of the Company’s initiatives regarding the potential recovery of rare earth elements as well as the potential commercialization of coal-to-carbon-based products and materials.
−Removed: Our operations include six active mines at our Elk Creek mining complex (the “Elk Creek Complex”), three active mines at our Berwind mining complex (the “Berwind Complex”), two active mines at our Knox Creek mining complex (the “Knox Creek Complex”), and one active mine at our Maben mining complex (the “Maben Complex”).
+Added: metallurgical coal to our domestic customer base, North American blast furnace steel mills and coke plants, as well as international metallurgical coal consumers.
+Added: We also control mineral deposits near Sheridan, Wyoming as part of the Company’s initiatives regarding the potential recovery of rare earth elements and critical minerals as well as the potential commercialization of coal-to-carbon-based products and materials.
+Added: Our operations include seven active mines at our Elk Creek mining complex (the “Elk Creek Complex”), two active mines at our Berwind mining complex (the “Berwind Complex”), one active mine at our Knox Creek mining complex (the “Knox Creek Complex”), and one active mine at our Maben mining complex (the “Maben Complex”).
Development of the Elk Creek Complex commenced in 2016 and included the construction of a preparation plant and rail load-out facilities.
−Removed: The Elk Creek property consists of approximately 20,200 acres of controlled mineral rights and contains approximately 16 seams that we have targeted for production.
−Removed: Expansion of the Elk Creek preparation plant occurred during 2022 and 2023 in order to increase production.
+Added: The Elk Creek property consists of approximately 20,200 acres of controlled mineral rights and contains approximately 16 seams targeted for production.
+Added: The Elk Creek Complex produces high-volatile A
+Added: and B metallurgical coals.
+Added: Expansion of the Elk Creek preparation plant occurred in 2022 and 2023 in order to increase production, and high-volatile additions at the Elk Creek Complex occurred during 2024, which were fully in production by the end of the third quarter.
Development of the Berwind Complex began in late 2017.
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Production restarted for the idle mine in the first quarter of 2023.
−Removed: Our Knox Creek Complex includes a preparation plant and 64,050 acres of controlled mineral rights that we expect to develop in the future.
−Removed: The Knox Creek preparation plant processed some coal from our Berwind Complex in 2023 as well as coal purchased from third parties.
+Added: The Berwind Creek Complex currently produces low-volatile and mid-volatile metallurgical coal.
+Added: The Company continues to increase production at the main Berwind low-volatile mine.
+Added: Our Knox Creek Complex includes a preparation plant and 64,050 acres of controlled mineral rights.
+Added: The Complex currently produces mid and high-volatile metallurgical coal and also processes and ships coal from other third-party operators.
+Added: The Company closed its Jawbone mine during 2024, which was nearing the end of its mine life and experiencing higher costs of production.
The Maben Coal acquisition in 2022 provides the Company with 28,000 leased acres of controlled mineral rights, which includes coal deposits that may be mined currently by surface and high wall mining methods as well as developed in the future through deep mining.
+Added: The Maben Complex currently produces low-volatile metallurgical coal.
+Added: The Company commissioned a preparation plant at the Maben Complex during 2024 in order to reduce trucking costs.
Our RAM Mine property is located in southwestern Pennsylvania.
−Removed: Following years of delays, the Pennsylvania Department of Environmental Protection issued a denial of the RAM Mine permit.
+Added: Following years of delays, the Pennsylvania Department of Environmental Protection issued a denial of the RAM Mine permit during 2023.
While the Company believes that the RAM permit was denied incorrectly and capriciously, we will not appeal the denial of the permit and will instead focus on our other core properties and monetize these assets at the appropriate time.
Our Brook Mine property consists of approximately 16,000 acres of controlled mineral rights and a research and development facility that were acquired as part of the purchase of Ramaco Coal in 2022.
−Removed: The mine is currently undergoing mineral analysis and core drilling assessment to assess the potential concentrations of rare earth elements.
−Removed: As of December 31, 2023, our estimated aggregate annual production capacity is just under four million clean tons of coal.
−Removed: We plan to complete development of our existing properties and increase annual production over the next few years to approximately seven million clean tons of metallurgical coal annually, subject to market conditions, permitting, and additional capital deployment.
+Added: The mine is currently undergoing testing and analysis to assess the potential concentrations of rare earth elements and critical minerals.
+Added: As of December 31, 2024, our estimated aggregate annual production capacity is approximately four to five million clean tons of coal.
+Added: We plan to complete development of our existing properties and increase annual production over the next few years to possibly as much as seven million clean tons of metallurgical coal annually, subject to market conditions, permitting, and additional capital deployment.
We may also acquire additional reserves or infrastructure that contribute to our focus on advantaged geology and lower costs.
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Metallurgical coal, also known as “met coal “ or “coking coal,” is a key component of the blast furnace steelmaking process and, therefore, demand for such coal is highly correlated with conditions in the steel industry.
−Removed: The metallurgical coal global market has grown steadily in recent years and is expected to continue to do so over the next few years.
+Added: The global metallurgical coal market has grown steadily in recent years and will likely continue to grow over the next few years driven by the industrialization of emerging economies and expansion of urbanization globally.
United States metallurgical coal mines are primarily located in the Appalachian area of the eastern U.S.
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metallurgical coal is also exported to the seaborne market and sold to buyers in Europe, South America, Africa, and Asia.
−Removed: metallurgical coal exports are primarily sold to buyers in the Atlantic Basin market (customers in Europe, Brazil and Africa), and serve as swing supply to buyers in the Pacific Basin (customers in India, South Korea,
−Removed: Japan and China).
+Added: metallurgical coal exports are sold to buyers in the Atlantic Basin market (customers in Europe, Brazil and Africa) as well as buyers in the Pacific Basin (customers in India, South Korea, Japan and China).
metallurgical coal exports compete with Australian metallurgical coals that are generally produced at a lower cost but are geographically disadvantaged to the Atlantic Basin.
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This geologically advantaged resource and reserve base allows for flexible capital spending in challenging market conditions.
−Removed: We plan to complete development of our existing properties and increase annual production over the next few years to approximately seven million clean tons of metallurgical coal, subject to market conditions, permitting, and additional capital deployment.
+Added: We plan to complete development of our existing properties and increase annual production over the next few years to as much as seven million clean tons of metallurgical coal, subject to market conditions, permitting, and additional capital deployment.
We may also acquire additional reserves or infrastructure that contribute to our focus on advantaged geology and lower costs.
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We believe that business excellence is achieved through the pursuit of safer and more productive work practices.
−Removed: Advancing our Initiatives in Rare Earth Elements and Advanced Carbon Products .
−Removed: We are also focused on critical mineral rare earth development as well as the potential commercialization of coal-to-carbon-based products and materials.
−Removed: These initiatives provide additional growth opportunities and upside potential in future periods.
+Added: Advancing our Initiatives in Rare Earth Elements, Critical Minerals, and Advanced Carbon Products .
+Added: We are also focused on the potential development of rare earth elements and critical minerals, including gallium and germanium which were recently banned for export to the United States by China, as well as the potential commercialization of coal-to-carbon-based products and materials.
+Added: These initiatives provide additional growth opportunities in future periods.
Our properties are primarily located in southern West Virginia, southwestern Virginia, southwestern Pennsylvania, and northeastern Wyoming.
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tons of clean saleable metallurgical coal as well as measured and indicated metallurgical coal resource tons of 211 million.
−Removed: We estimate that the mine life for the Elk Creek Complex is over 20 years.
+Added: We estimate that the mine life for the Elk Creek Complex is 15 years.
We currently market most of the coal produced from the Elk Creek Complex as a blended high-volatile A/B product.
When segregated, a portion of our coal can be sold as a high-volatile A product for a premium.
−Removed: Our market for Elk Creek production is principally North American coke and steel producers.
−Removed: We also market our coal to European, South American, Asian and African customers, and occasionally to coal traders and brokers for use in filling orders for their blended products.
+Added: Our market for Elk Creek production is North American coke and steel producers as well as European, South American, Asian and African customers, and occasionally to coal traders and brokers for use in filling orders for their blended products.
Additionally, we seek to market a portion of our coal in the specialty coal markets that value low ash content.
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While it is unusual to have a metallurgical reserve in this part of Central Appalachia remain idle for such an extended period of time, the configuration and location of the tracts lend themselves to be mined and processed far more efficiently from our Elk Creek property.
−Removed: The McDonald reserves have the same geologic advantages and low costs that are being experienced in our Elk Creek mines.
+Added: The McDonald reserves have the same geological advantages and low costs that are being experienced in our Elk Creek mines.
During 2022, we began work on a throughput upgrade at our Elk Creek Preparation plant.
The upgrade, which was completed in 2023, increased our annual processing capacity for this complex to approximately three million tons per year.
−Removed: In order to utilize the increased capacity, we also began development work on additional low-cost, high- volatile mines at Elk Creek, which began production during 2022.
+Added: In order to utilize the increased capacity, we also began development work on additional low-cost, high- volatile mines at Elk Creek, which were fully in production by the end of the third quarter of 2024.
Berwind Mining Complex
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We estimate that the mine life for the Berwind Complex is over 20 years.
−Removed: We view Berwind as the second flagship complex for Ramaco.
Development of our Berwind Complex began in late 2017 in the thinner Pocahontas No.
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In early 2021, as pricing and demand improved, Berwind development resumed, and we successfully reached the Pocahontas No.
−Removed: in late 2021.
−Removed: The Berwind Complex experienced an ignition event during the third quarter of 2022 that resulted in idling mining operations for one of the active mines.
+Added: 4 seam in late 2021.
+Added: The Berwind Complex experienced an ignition event during the third quarter of 2022 that resulted in idling
+Added: mining operations for one of the active mines.
Production restarted for the idle mine in the first quarter of 2023.
+Added: The Company continues to increase production at the main Berwind low-volatile mine.
We have the necessary permits for the Berwind Complex for our current and budgeted operations.
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The Knox Creek Complex consists of approximately 64,050 acres of controlled mineral rights as well as a preparation plant, a coal-loading facility, and a refuse impoundment.
+Added: The Complex currently produces mid and high-volatile metallurgical coal and also processes coal purchased from other independent producers from time to time.
Rail service is provided by Norfolk Southern.
−Removed: The Tiller Mine slope face-up and shafts were idled before our acquisition of the property.
−Removed: The Company has spent limited amounts of capital to review the feasibility of a high-vol A metallurgical deep mine in the Jawbone seam of coal.
−Removed: This seam is located slightly above the Tiller Seam and would be accessed via a short slope from within the existing Tiller seam mine.
−Removed: Jawbone coal could flow through the same portal and slope as the idle Tiller mine.
−Removed: Production is expected to resume once warranted by market conditions.
−Removed: We estimate that the Knox Complex contains reserves capable of yielding approximately 8 million tons of clean saleable metallurgical coal as well as measured and indicated metallurgical coal resource tons of 275 million.
−Removed: We estimate that the mine life for the Knox Creek Complex is approximately 15 years.
−Removed: From time to time, we process coal purchased from other independent producers at the Knox Creek preparation plant and load-out facilities.
−Removed: We have also processed and loaded coal from our Berwind Complex at this facility.
In the fourth quarter of 2019, we acquired multiple permits from various affiliates of Omega Highwall Mining, LLC.
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The mine reached full production during 2023.
+Added: We estimate that the Knox Complex contains reserves capable of yielding approximately 7 million tons of clean saleable metallurgical coal as well as measured and indicated metallurgical coal resource tons of 277 million.
+Added: We estimate that the mine life for the Knox Creek Complex is approximately 12 years.
+Added: The Company closed its Big Creek Jawbone mine during 2024, which was nearing end of mine life and experiencing higher cost production.
Following years of delays, the Pennsylvania Department of Environmental Protection issued a denial of the RAM Mine permit in southwest Pennsylvania.
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As part of the transaction, we assumed existing mining permits issued by the West Virginia Department of Environmental Protection, which authorizes mining by both surface and highwall mining methods as well as by underground methods.
−Removed: The property also has issued permits covering an existing haul road as well as an active refuse disposal area together with a preparation plant and unit train loadout, neither of which had been constructed as of the closing date.
−Removed: In early 2024, the Company completed the purchase of an existing coal preparation plant, which will be relocated to the Company’s Maben Complex.
+Added: property also has issued permits covering an existing haul road as well as an active refuse disposal area together with a preparation plant and unit train loadout, neither of which had been constructed as of the closing date.
+Added: During 2024, the Company completed the purchase of an existing coal preparation plant and relocated the plant to the Company’s Maben Complex, which was commissioned early in the fourth quarter.
+Added: The addition of the preparation plant is expected to reduce trucking costs going forward.
The Maben property contains various areas of high-quality low-vol metallurgical coal in the Sewell, Beckley, Pocahontas 3, Pocahontas 4, and Pocahontas 6 seams of coal.
The Company expects that coal contained in the Sewell seam will be mined by surface and high-wall mining methods.
−Removed: Initial production began in 2023, reaching an annualized production rate of approximately 250,000 tons of low-volatile coal.
−Removed: The Company will consider deep mine development of coal contained in Beckley, Pocahontas 3, 4, and 6 seams at a future point.
−Removed: Although the Company currently utilizes the Berwind preparation plant, such development would require the construction of a new preparation plant and loadout as mentioned above, which is under way.
+Added: Initial production of low-volatile began in 2023, and the Company will consider deep mine development of coal contained in Beckley, Pocahontas 3, 4, and 6 seams at a future point.
+Added: We estimate that the Maben Complex contains reserves capable of yielding approximately 11 million tons of clean saleable metallurgical coal as well as measured and indicated metallurgical coal resource tons of 230 million.
+Added: The expected mine life for the Maben Complex is estimated to be 15 years.
The property is located in northeastern Wyoming, near Sheridan, and consists of approximately 16,000 acres of controlled mineral rights and a research and development facility that were acquired as part of the purchase of Ramaco Coal during 2022.
−Removed: The property includes a thermal coal deposit and permit as well as occurrences of rare earth elements.
−Removed: The mine is currently undergoing mineral analysis and core drilling assessment to assess the potential concentrations of rare earth elements.
−Removed: This property is being used to support the Company’s possible expansion into the manufacture and commercialization of advanced carbon products and materials from coal.
−Removed: Three drillhole programs involving a total of 123 new core drillholes specifically targeting rare earth elements (REEs) have been completed within the current Brook Mine permit area.
−Removed: So far, the results of these drilling programs indicate elevated levels of REEs, along with significant concentrations of other critical elements such as Yttrium, Gallium, and Germanium.
−Removed: Work is ongoing to evaluate the potential exploitation of these minerals within the current Brook Mine permit area.
+Added: The property includes a thermal coal deposit as well as a large unconventional deposit of rare earth elements and critical minerals sourced from coal and carbonaceous ore.
+Added: This property is also being used to support the Company’s possible expansion into the manufacture and commercialization of advanced carbon products and materials from coal.
+Added: The Company continues to evaluate the commercial and technical feasibility of extracting critical minerals and rare earth elements within the current Brook Mine permit area.
+Added: Preliminary findings indicate significant concentrations of critical minerals scandium, gallium, and germanium as well as rare earth elements neodymium, praseodymium, dysprosium, and terbium.
Customers and Contracts
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The major factors influencing our business are the global economy and demand for steel.
−Removed: We market the bulk of our production to North American integrated steel mills and coke plants, as well as international customers in Europe, South America, Asia and Africa.
+Added: We market our production to North American integrated steel mills and coke plants as well as international customers in Europe, South America, Asia, and Africa.
Additionally, we market limited amounts of our production to various premium-priced specialty markets, such as foundry cokemakers, manufacturers of activated carbon products, and specialty metals producers.
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Generally, the Company’s domestic sales contracts have terms of about one year and the pricing is typically fixed.
−Removed: Export sales have spot or term contracts, and pricing can be either fixed or derived against index-based pricing mechanisms.
−Removed: We sold 3.5 million tons of coal during 2023.
−Removed: Of this, 33% was sold to North American markets and 67% was sold into export markets, excluding Canada.
−Removed: Principally, our export market sales were made to Europe.
−Removed: During 2023, sales to three customers accounted for approximately 41% of total revenue.
+Added: Export sales have spot or term contracts, and pricing can be either fixed or derived from index-based pricing mechanisms.
+Added: We sold 4.0 million tons of coal during 2024 and recognized $666.3 million of revenue.
+Added: Of this amount, 33% of our revenue was from sales into North American markets and 67% of our revenue was from sales into export markets.
+Added: During 2024, sales to two customers accounted for approximately 22% of total revenue.
No other customer accounted for 10% or more of our total revenue during 2024.
−Removed: If a major customer decided to stop purchasing coal or significantly reduced its purchases from us, revenue could decline and our operating results and financial condition could be adversely affected.
+Added: If a major customer decided to stop purchasing coal or significantly
+Added: reduced its purchases from us, revenue could decline and our operating results and financial condition could be adversely affected.
Trade Names, Trademarks and Patents
1 unchanged sentence
The names of the seams in which we have coal reserves, and attributes thereof, are widely recognized in the metallurgical coal market.
−Removed: However, trademarks related to our advanced carbon products business could become material depending on future developments.
+Added: However, trademarks related to our advanced carbon products business could become material depending on future developments, of which there are four registered trademarks and seven pending trademark applications.
In connection with our advanced carbon products business, the Company holds 76 intellectual property patents and pending patents related to the conversion of low-cost carbon ore into higher-value carbon products as well as exclusive licensing agreements, all of which have a remaining duration of 14-20 years.
−Removed: Our principal domestic competitors include Alpha Metallurgical Resources, Inc., Blackhawk Mining, LLC, Coronado Global Resources Inc., Arch Resources, Inc., Peabody Energy Corporation and Warrior Met Coal, Inc.
+Added: Our principal domestic competitors include Alpha Metallurgical Resources, Inc., Blackhawk Mining, LLC, Coronado Global Resources Inc., Arch Resources, Inc.
+Added: (now a subsidiary of Core Natural Resources), Peabody Energy Corporation, and Warrior Met Coal, Inc.
We also compete in international markets directly with domestic companies and with companies that produce coal from one or more foreign countries, such as Australia, Canada, and Colombia.
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Moreover, these laws are constantly evolving, and the trend has been for increasingly complex and stringent regulation over time.
−Removed: New legislative or administrative proposals, or judicial interpretations of existing laws and regulations related to the protection of the environment could result in substantially increased capital, operating and compliance costs.
+Added: New legislative or administrative proposals, changes in administrative and judicial interpretations of existing laws and regulations related to the protection of the environment could result in substantially increased capital, operating and compliance costs.
Due in part to these extensive and comprehensive regulatory requirements and ever-changing interpretations of these requirements, violations of these laws can occur from time to time in our industry and also in our operations.
−Removed: Expenditures relating to environmental compliance are a major cost consideration for our operations and safety and
−Removed: compliance is a significant factor in mine design, both to meet regulatory requirements and to minimize long-term environmental liabilities.
−Removed: The following is a summary of the various federal and state environmental and similar regulations that have a material impact on our business:
+Added: Expenditures relating to environmental compliance are a major cost consideration for our operations and safety and compliance is a significant factor in mine design, both to meet regulatory requirements and to minimize long-term environmental liabilities.
+Added: The following is a summary of the various federal and state environmental and similar laws and regulations that have a material impact on our business.
+Added: Potentially significant changes to federal laws and regulations are anticipated to occur under the new Trump Administration.
+Added: Accordingly, the following discussion pertains to laws and regulations as they existed prior at the end of 2024, prior to the change in Administration.
Surface Mining Control and Reclamation Act.
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The SMCRA also stipulates compliance with many other major environmental statutes, including the Clean Air Act (the “CAA”), the Clean Water Act (the “CWA”), the Endangered Species Act (the “ESA”), the Resource Conservation and Recovery Act (the “RCRA”) and the Comprehensive Environmental Response, Compensation and Liability Act of 1980 (the “CERCLA”).
−Removed: Permits for all mining operations must be obtained from the United States Office of Surface Mining Reclamation and Enforcement (the “OSMRE”) or, where state regulatory agencies have adopted federally approved state programs under SMCRA, the appropriate state regulatory authority.
−Removed: Our operations are located in West Virginia and Virginia, which have achieved primary jurisdiction for enforcement of SMCRA through approved state programs.
+Added: Permits for all mining operations must be obtained from the United States Office of Surface Mining Reclamation and Enforcement (the “OSMRE”) or, where state regulatory agencies have adopted federally approved state programs under SMCRA.
+Added: Our operations are located in West Virginia and Virginia, which have each individually achieved primacy to regulate and enforce surface mining and reclamation operations within the respective state to ensure compliance with SMCRA.
The SMCRA imposes a complex set of requirements covering all facets of coal mining.
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However, we cannot control the pace at which the government issues permits needed for new or ongoing operations.
−Removed: For example, the process of obtaining CWA permits can be particularly time-consuming and subject to delays and denials.
+Added: For example, the process of obtaining CWA permits can be particularly time-consuming and subject to delays and denials and generally involves multiple levels of agency review.
The Environmental Protection Agency (the “EPA”) also has the authority to veto permits issued by the U.S.
of Engineers (the “Corps”) under the CWA’s Section 404 program that prohibits the discharge of dredged or fill material into regulated waters without a permit.
+Added: And for many permit applications, the Corps is required to review the proposed activity under the National Environmental Policy Act (“NEPA”), which can involve the preparation of lengthy and complex environmental assessments or environmental impact statements.
Even after we obtain the permits that we need to operate, many of the permits must be periodically renewed, or may require modification.
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The regulations enacted under the Mine Act and MINER Act as well as under similar state acts are routinely expanded or made more stringent, raising compliance costs and increasing potential liability.
+Added: For example, in April 2024, the MSHA issued a new regulation (76 Fed.
+Added: 28218, April 18, 2024) amending standards increasing the stringency of and proposing new requirements to protect the health of miners exposed to respirable crystalline silica.
Our compliance with current or future mine health and safety regulations could increase our mining costs.
13 unchanged sentences
In addition, we obtained from a third-party insurer a workers’ compensation insurance policy, which includes coverage for medical and disability benefits for occupational disease under the Federal Coal Mine Health and Safety Act of 1969 and the Mine Act.
−Removed: Under the Black Lung Benefits Revenue Act of 1977 and the Black Lung Benefits Reform Act of 1977, as amended in 1981, each coal mine operator must pay federal black lung benefits to claimants who are current and former employees and also make payments to a trust fund for the payment of benefits and medical expenses to claimants who last worked in the coal industry prior to January 1, 1970.
+Added: Under the Black Lung Benefits Revenue Act of 1977 and the Black Lung Benefits Reform
+Added: Act of 1977, as amended in 1981, each coal mine operator must pay federal black lung benefits to claimants who are current and former employees and also make payments to a trust fund for the payment of benefits and medical expenses to claimants who last worked in the coal industry prior to January 1, 1970.
The Patient Protection and Affordable Care Act of 2010 includes significant changes to the federal black lung program including an automatic survivor benefit paid upon the death of a miner with an awarded black lung claim and the establishment of a rebuttable presumption with regard to pneumoconiosis among miners with 15 or more years of coal mine employment that are totally disabled by a respiratory condition.
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Any reduction in the amount of coal consumed by electric power generators as a result of these limitations could decrease demand for thermal coal.
−Removed: ● Acid Rain .
+Added: In February 2023, EPA found that 21 states’ state implementation plans (SIPs) did not protect downwind states from interstate ozone, leading to EPA’s finalization of a federal implementation Plan (FIP) in March 2023 under the CAA’s Good Neighbor requirements, referred to as the Good Neighbor Plan rule for the 2015 ozone National Ambient Air Quality Standards (“NAAQS”).
+Added: The Good Neighbor Plan rule implemented nitrogen oxide (“NOx”) limits on power plants and, for the first time, industrial sources, in 23 states.
+Added: Litigation has ensued, eventually leading to the Supreme Court’s stay of the enforcement of the Good Neighbor Rule in Ohio v.
+Added: In November 2024, EPA issued an interim final rule (89 Fed.
+Added: 6, 2024) confirming that the Good Neighbor Rule is stayed nationwide.
Title IV of the CAA requires reductions of sulfur dioxide emissions by electric utilities and applies to all coal-fired power plants generating greater than 25 megawatts of power.
3 unchanged sentences
NAAQS for Criterion Pollutants.
−Removed: The CAA requires the EPA to set standards, referred to as National Ambient Air Quality Standards (“NAAQS”), for six common air pollutants:
+Added: The CAA requires the EPA to set standards, referred to as the NAAQS, for six common air pollutants:
carbon monoxide, nitrogen dioxide, lead, ozone, particulate matter (“PM”) and sulfur dioxide.
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New rules and standards may also impose additional emissions control requirements on our customers in the electric generation, steelmaking, and coke industries.
−Removed: coal mining operations emit particulate matter and sulfur dioxide, our mining operations could be affected when the new standards are implemented by the states.
+Added: Because coal mining operations emit particulate matter and sulfur dioxide, our mining operations could be affected when the new standards are implemented by the states.
Mercury and Hazardous Air Pollutants .
The EPA has established emission standards for mercury and other metals, fine particulates, and acid gases from coal- and oil-fired power plants through the Mercury and Air Toxics Standards (“MATS”) rule.
+Added: In April 2024, EPA issued a final rule further strengthening MATS emission standards pertaining to mercury, toxic metals and filterable particulate matter.
Like CSAPR, MATS and other similar future regulations could accelerate the retirement of a significant number of coal-fired power plants.
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to withdraw from the Paris Agreement with an effective exit date in November 2020.
−Removed: In February 2021, the current administration announced reentry of the U.S.
+Added: In February 2021, the administration announced reentry of the U.S.
into the Paris Agreement along with a new “nationally determined contribution” for U.S.
1 unchanged sentence
In addition, shortly after taking office in January 2021, President Biden issued a series of executive orders designed to address climate change.
−Removed: In November 2021, the 26th Conference of the Parties to the United Nations Framework on Climate Change concluded with the finalization of the Glasgow Climate Pact, which aims to cut global methane pollution at least 30% by 2030 relative to 2020 levels, including “all feasible reductions” in the energy sector.
+Added: In November 2021, the 26th Conference of the Parties to the United Nations Framework on Climate Change concluded with the finalization of the Glasgow Climate Pact, which aims to cut global methane pollution at least 30% by
+Added: 2030 relative to 2020 levels, including “all feasible reductions” in the energy sector.
Forty-six countries signed onto a Global Coal to Clean Energy Transition Statement, committing to transition away from unabated coal power generation by about 2030 for “major economies” and a global transition by roughly 2040.
2 unchanged sentences
International commitments, reentry into the Paris Agreement and President Biden’s executive orders may result in the development of additional regulations or changes to existing regulations that may impact our business.
−Removed: The $1 trillion legislative infrastructure package passed by Congress in November 2021 includes a number of climate-focused spending initiatives targeted at climate resilience, enhanced response and preparation for extreme
−Removed: weather events, and clean energy and transportation investments.
+Added: The $1 trillion legislative infrastructure package passed by Congress in November 2021 includes a number of climate-focused spending initiatives targeted at climate resilience, enhanced response and preparation for extreme weather events, and clean energy and transportation investments.
In August 2022, President Biden signed the Inflation Reduction Act of 2022 into law.
9 unchanged sentences
Circuit vacated the ACE Rule and remanded it to the agency for further proceedings.
−Removed: In February 2021, the EPA issued a memorandum stating the agency’s position that neither the Clean Power Plan nor the ACE Rule are in effect, and future regulation of carbon dioxide emissions from existing power generation facilities remains uncertain.
−Removed: In May 2023, the EPA proposed revised new source performance standards for GHG emissions from new and reconstructed power plants that undertake a large modification.
−Removed: The finalization of this rule and any future rules or future GHG emission standards may encourage a shift away from coal-fired power generation, adversely impacting the market for our product.
+Added: In February 2021, the EPA issued a memorandum stating the agency’s position that neither the Clean Power Plan nor the ACE Rule are in effect, and future regulation of carbon dioxide emissions from existing power generation facilities remains uncertain In May 2024, EPA finalized new source performance standards (“NSPS”) regulating GHG emissions for new gas-fired power plants and existing coal-fired power plants (89 Fed.
+Added: 39798 (May 9, 2024).
+Added: In October 2024, the Supreme Court denied challenges seeking a stay of the NSPS GHG rule.
+Added: Under the Trump Administration, the future of the NSPS GHG rule is uncertain;
+Added: however, the finalization of this rule and any future rules or future GHG emission standards may encourage a shift away from coal-fired power generation, adversely impacting the market for our product.
Additionally, on March 6, 2024, the SEC adopted final rules to require registrants to disclose certain climate-related information in registration statements and annual reports.
1 unchanged sentence
Compliance with these rules will be phased in over time based on our filing status as well as the content of the disclosure and assurance requirements.
−Removed: Although the Company is in the process of evaluating the new rules, compliance may result in increased legal, accounting, and other compliance-related costs, as well as place strain on our personnel, systems, and resources.
+Added: Reporting under the rule may result in increased legal, accounting, and other compliance-related costs, as well as place strain on our personnel, systems, and resources.
+Added: On April 4, 2024, the SEC issued an order to stay the rule in response to legal challenges, which have been consolidated under the Eighth Circuit U.S.
+Added: Court of Appeals.
At the state level, several states, including Pennsylvania and Virginia, have already adopted measures requiring GHG emissions to be reduced within state or regional boundaries, including cap-and-trade programs and the imposition of renewable energy portfolio standards.
31 unchanged sentences
This definition never took effect as it was replaced by the Navigable Waters Protection Rule (the “NWPR”) in December 2019.
−Removed: A coalition of states and cities, environmental groups and agricultural groups challenged the NWPR, which was vacated by the U.S.
+Added: A coalition of
+Added: states and cities, environmental groups and agricultural groups challenged the NWPR, which was vacated by the U.S.
District Court for the District of Arizona in August 2021.
7 unchanged sentences
To the extent a new rule or further litigation expands the scope of the CWA’s jurisdiction, the CWA permits we need may not be issued, may not be issued in a timely fashion, or may be issued with new requirements which restrict our ability to conduct mining operations or to do so profitably.
+Added: It is anticipated that the Trump Administration will attempt to clarify the meaning of WOTUS largely in-line with the Supreme Court’s decision in Sackett .
Resource Conservation and Recovery Act.
The RCRA and corresponding state laws establish standards for the management of solid and hazardous wastes generated at our various facilities.
−Removed: Besides affecting current waste disposal practices, the RCRA also addresses the environmental effects of certain past hazardous waste treatment, storage and
−Removed: disposal practices.
+Added: Besides affecting current waste disposal practices, the RCRA also addresses the environmental effects of certain past hazardous waste treatment, storage and disposal practices.
In addition, the RCRA requires certain of our facilities to evaluate and respond to any past release, or threatened release, of a hazardous substance that may pose a risk to human health or the environment.
4 unchanged sentences
Additionally, in December 2016, Congress passed the Water Infrastructure Improvements for the Nation Act, which provided for the establishment of state and EPA permit programs for the control of CCR and authorizes states to incorporate the EPA’s final rule for CCR or develop other criteria that are at least as protective as the final rule.
−Removed: In May 2023, the EPA published proposed changes to the CCR rule for legacy CCR surface impoundments and a notice of data availability related to the proposed rule in November 2023.
−Removed: The finalization of this proposal, the current requirements of the CCR rules, as well as any future changes in the management of CCR, could increase our customers’ operating costs and potentially reduce their ability or need to purchase coal.
+Added: In May 2024, the EPA finalized regulations for legacy CCR surface impoundments and coal ash disposed in areas outside of regulated units including certain previously closed surface impoundments and landfills.
+Added: The current requirements of the CCR rules, as well as any future changes in the management of CCR, could increase our customers’ operating costs and potentially reduce their ability or need to purchase coal.
In addition, contamination caused by the past disposal of CCR, including coal ash, could lead to material liability for our customers under the RCRA or other federal or state laws and potentially further reduce the demand for coal.
20 unchanged sentences
These requirements may also include restrictions on timber harvesting, road building and other mining or agricultural activities in areas containing the affected species or their habitats.
−Removed: There is also increasing interest in nature-related matters
−Removed: beyond protected species, such as general biodiversity, which may similarly require us or our customers to incur costs or take measures which may adversely impact our business or operations.
+Added: There is also increasing interest in nature-related matters beyond protected species, such as general biodiversity, which may similarly require us or our customers to incur costs or take measures which may adversely impact our business or operations.
Use of Explosives.
16 unchanged sentences
Phase I of CEQ’s proposed rulemaking process was finalized on April 20, 2022 and generally restored provisions that were in effect prior to 2020.
−Removed: Phase II of the proposed rulemaking was published by CEQ in July 2023.
−Removed: Phase II proposes further revisions in an attempt to ensure the NEPA process “provides for efficient and effective environmental reviews,” and meets environmental, environmental justice, and climate change objectives.
−Removed: These rules could create additional delays and costs in the NEPA review process or in our operations, or even an inability to obtain necessary federal approvals for our operations due to the increased risk of legal challenges from environmental groups seeking additional analysis of climate impacts.
+Added: In May 2024, the CEQ published its final Phase II rule, further defining what federal actions are subject to NEPA, and what level of review required for those federal actions.
+Added: However, recent litigation has effectively rescinded these rules and left the future of NEPA regulation uncertain.
+Added: On November 12, 2024, the D.C.
+Added: Circuit Court of Appeals issued a ruling in Marin Audubon Society v.
+Added: Federal Aviation Administration holding that CEQ lacked the authority issue binding regulations implementing NEPA.
+Added: And on January 20, 2025, the Trump Administration ordered CEQ to issue guidance on NEPA implementation and to propose rescinding CEQ’s current NEPA regulations.
+Added: On February 3, 2025, the U.S.
+Added: District Court for the District of North Dakota in Iowa v.
+Added: Council on Envtl.
+Added: Quality , vacated the Phase II NEPA rule, finding that CEQ lacked authority to promulgate binding regulations.
+Added: Taken together, the rulings in Marin
+Added: Audubon and Iowa appear to eliminate CEQ regulations governing NEPA;
+Added: therefore, at present, federal agencies will need to determine their own process and requirements for evaluating major agency actions under NEPA.
Other Environmental Laws.
6 unchanged sentences
We believe our employees are a competitive advantage.
−Removed: We seek to foster a culture that supports diversity, equity and inclusion, and strive to provide a safe, healthy and rewarding work environment with opportunities for growth.
+Added: We seek to foster a culture that strives to provide a safe, healthy and rewarding work environment with opportunities for growth.
We had 984 employees as of December 31, 2024, including our named executive officers, and nearly all of our employees are full-time employees.
−Removed: None of our employees are covered by collective bargaining agreements, and we
−Removed: have not experienced any strikes or work stoppages related to labor relation issues.
+Added: None of our employees are covered by collective bargaining agreements, and we have not experienced any strikes or work stoppages related to labor relation issues.
We believe we have good relations with our employees.
38 unchanged sentences
A key element of our safety program is the recognition that safe work practices are a requirement of employment.
−Removed: We identify employee performance which is below expectations and develop specific action plans for improvement.
+Added: We identify employee performance that is below expectations and develop specific action plans for improvement.
● Employee Involvement .
9 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.